PB96-963819
EPA/ROD/R02-96/286
Janaury 1997
EPA Superfund
Record of Decision:
Carroll and Dubies Sewage Disposal,
Port Jervis, NY
9/30/1996
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DECLARATION FOR THE RECORD OF DECISION
SITE NAME AND LOCATION
Carroll and Dubies Sewage Disposal, Inc., Superfund Site
Town of Deerpark, Orange County, New York
STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected remedial action for
the contaminated groundwater at 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 the contaminated
groundwater at this Site. The information supporting this
remedial action decision is contained in the administrative
record for this Site. The administrative record index is
attached (Please see 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 an
imminent and substantial endangerment to public health, welfare,
or the environment.
DESCRIPTION OF THE SELECTED REMEDY
This operable unit represents the second of two operable units
planned for the Site. It addresses the contaminated groundwater
underlying and downgradient of the Carroll and Dubies site. The
remedy for the first operable unit (OU1), involving the cleanup
of lagoon sludges and contamination in the soil in and around the
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lagoons, was selected in a ROD, signed March 31, 1995, and is
presently in the design phase.
The major components of the selected remedy include:
Natural attenuation of organic contaminants in the
groundwater to below federal drinking water and State
groundwater standards through naturally occurring removal
processes. The remediation of the lagoons, which will be
implemented under OU1, will minimize any additional
contaminant contribution to the groundwater. Groundwater
modeling estimated that contaminants would attenuate to
these standards within five years of completion of the
remedy selected for the lagoons.
Implementation of institutional controls, such as deed
restrictions, contractual agreements, local law or
ordinances or other governmental action for the purpose of
restricting installation and use of groundwater wells
throughout the contaminated groundwater plume.
Monitoring of the groundwater to evaluate improvement in
groundwater quality and ensure the effectiveness of the
remedy.
Sampling in Gold Creek to ensure that site related
contaminants do not impact the creek.
STATUTORY DETERMINATIONS
The selected remedy is protective of human health and the
environment, complies with federal and state requirements that
are legally applicable or relevant and appropriate to the
remedial action and is cost-effective. The selected remedy
utilizes permanent solutions and alternative treatment
technologies to the maximum extent practicable for this Site.
However, the remedy does not satisfy the statutory preference for
treatment as a principal element of the remedy; naturally
occurring processes will be relied upon to reduce the mobility,
toxicity and volume of the contaminants in the groundwater.
Groundwater modeling has predicted that the natural attenuation
processes of the selected remedy will achieve drinking water and
groundwater standards in approximately the same time frame as
active treatment alternatives.
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Since contaminants will remain at the Site above levels which
allow for unrestricted use and unlimited exposure, this remedy
will require five-year reviews to ensure that the remedial action
is protective of human health and the environment.
Jeanne M. Fox//^7 /S' I Date
//• .
Regional Administra
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RECORD OF DECISION
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
September 1996
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TABLE OF CONTENTS
PAGE
SITE NAME, LOCATION AND DESCRIPTION 1
SITE HISTORY AND ENFORCEMENT ACTIVITIES 2
HIGHLIGHTS OF COMMUNITY PARTICIPATION 4
SCOPE AND ROLE OF OPERABLE UNIT 4
SUMMARY OF SITE CHARACTERISTICS 5
SUMMARY OF SITE RISKS 10
REMEDIAL ACTION OBJECTIVES 16
DESCRIPTION OF REMEDIAL ALTERNATIVES 16
SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES 21
SELECTED REMEDY 26
STATUTORY DETERMINATION 27
DOCUMENTATION OF SIGNIFICANT CHANGES 29
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 & Dubies site (the Site) is located just northeast of
the City of Port Jervis, on Canal Street in the Town of Deerpark,
Orange County, New York. The Site is approximately 5.5 acres in
size (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
that have been abandoned, and numerous portable toilets that are
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 is formed by remnants of the former Delaware and Hudson
Canal and towpath. Adjacent to the southern boundary of the
Carroll and Dubies property is the City of Port Jervis Landfill .
and gravel and cement block manufacturing operations. 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 nearest resident located downgradient of the Site is about a
quarter of a mile from the Site on the opposite side of Gold
Creek (see Figure 2).
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 sand
with some clay, 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,
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adjacent to the exposed bedrock slope. 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.
SITE HISTORY AND ENFORCEMENT ACTIVITIES
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 seven lagoons located at the Site (lagoons
1 through 4 and 6 through 8 are depicted in Figure 2) . No
industrial wastes were found in lagoon 5. 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 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.
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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 four PRPs were Carroll and
Dubies Sewage Disposal, Inc. (C&D), Kolmar Laboratories, Inc.
(Kolmar), Wickhen Products, Inc. (Wickhen) and Reynolds Metals
Co., Inc. (Reynolds) . 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 PRPs, Kolmar and Wickhen, submitted a
good faith offer to perform the RI/FS.. An Administrative Order
on Consent was signed by the two PRPs and by EPA in February
1990. Kolmar and Wickhen conducted all RI/FS work (addressing
both the groundwater and lagoons) , pursuant to the RI/FS Order
with oversight by EPA. 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.
In March 1995, EPA signed a Record of Decision (ROD) for the
first operable unit (OU1) which called for the excavation of
approximately 20,000 cubic yards (cy) of contaminated material
from the lagoons and soils in the vicinity of the lagoons.
Materials exceeding treatment levels will undergo treatment via
solidification/stabilization (for inorganic contaminants) and
bioslurry (for organic contaminants) or a combination of the two
treatment processes. All treated and untreated materials will
be placed on-site in a lined and capped cell with leachate
collection.
On May 19, 1995, EPA issued "special notice" letters to the PRPs
requesting that they submit a good faith offer to perform the
Remedial Design/Remedial Action (RD/RA) for OU1. The PRPs and
EPA were unable to reach an agreement and thus, on September 29,
1995, EPA issued a Unilateral Administrative Order to C&D, Kolmar
and Wickhen ordering them to implement the first operable unit
remedy.
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On September 29, 1995, EPA entered into a de -rininis Settlement
ir. the form of an Order on Consent with Reynolds regarding EPA's
past response costs for the Site, and Reynold's share of the OU1
RD/RA Costs. This settlement became effective on July IS, 1996.
After issuance of the ROD for OU2, ail r.on-de •?.ir.ir?.is ?R?s will
be offered the opportunity to design and implement the selected
OU2 remedy. EPA will offer Reynolds a ce mir.ir-.is settlement for
OU2 costs.
HIGHLIGHTS OF COMMUNITY PARTICIPATION
The Second Operable Unit RI/F5 reports and the Proposed Plan for
the contaminated groundwater beneath the Site were released for
public comment on August 28, 1996; a notice announcing the
availability of these documents was mailed to the Site mailing
list. These documents were made available to the public in the
administrative record file at the EPA-Region II Document Control
Center, 290 Broadway, 18th floor, New York, New York 10007-1866
and at the Deerpark Town Hall, Drawer A, Huguenot, New York. A
public newspaper notice announcing the availability of these
documents was placed in The Times Herald Record on September 10,
1996. The public comment period was held from August 28, 1996
through September 27, 1996.
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 September 11, 1996. Responses to
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) .
SCOPS AND ROLE OF OPERABLE UNIT
Site remediation activities are sometimes segregated into
different phases or operable units, so that remediation of
different environmental media or areas of a site can proceed
separately. This phased approach results in an expeditious
remediation of the entire site. EPA has designated two operable
units for the Carroll and Dubies site as described below.
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*The first operable unit (OU1) addresses the lagoon sludges and
contaminated soils from lagoons 1, 2, 3, 4, 6, 7, and 8, which
are contaminated primarily with heavy metals and volatile organic
compounds (VOCs). The ROD for OU1 was issued in March 1995 and
calls for the excavation of approximately 20,000 cubic yards (cy)
of contaminated material from the lagoons and soils in the
vicinity of the lagoons. Materials exceeding treatment levels
will undergo treatment via solidification/stabilization (for
inorganic contaminants) and bioslurry (for organic contaminants)
or a combination of the two treatment processes. All treated
and untreated materials will be placed on-site in a lined and
capped cell with leachate collection. This operable unit is
currently in the remedial design phase.
^Operable Unit 2 (OU2) addresses the contaminated groundwater
beneath and downgradient of the Carroll and Dubies site. This is
the final operable unit and is the subject of this ROD.
SUMMARY OF SITE CHARACTERISTICS
The nature and extent of groundwater contamination found at the
Carroll and Dubies site was assessed through sampling of
groundwater, sediment in Gold Creek, residential wells and
through groundwater modeling and geophysical surveys. A total of
34 monitoring wells was installed and four groundwater sampling
events were conducted during the investigation.
The geology under the Site consists of unconsolidated overburden
materials of glacial and glaciofluvial origin, which overlie
shale bedrock. The thickness of the unconsolidated overburden
materials ranges from zero foot 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, which constitutes an aquifer,
ranges in thickness from 31 feet to 52 feet along the
downgradient edge of the Site. The glacial till is not
continuous beneath the Site, and appears to pinch out toward the
northwestern edge of the Site, adjacent to the exposed bedrock
slope. The till formation is defined as an aquitard, because it
consists of silt and clay, which typically have low permeability.
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The till formation is underlain by shale bedrock. Groundwater
found in the bedrock can be developed and therefore the bedrock
is defined as an aquifer. The depth to groundwater from ground
surface ranged from approximately 30 to 40 feet along the
southeastern boundary of the Site. Groundwater movement beneath
the Site is generally to the southeast, towards Gold Creek, which
is located approximately 1,500 feet southeast of the Carroll and
Dubies property line (see Figure 2) .
Groundwater samples were collected downgradient of the lagoons
and analyzed for organic and inorganic compounds. The monitoring
wells monitor either the bedrock (well depths ranging from 39
feet to 86 feet below land surface) , the glacial till (well depth
at 60 feet below land surface) , the glacial outwash (well depths
ranging from 16 feet to 58 feet below land surface) or both the
glacial till and outwash units (well depths ranging from 35 feet
to 51 feet below land surface) . The analytical results for the
groundwater samples for the 1991, 1993, 1994, and 1995 sampling
events did not indicate the presence of organic contaminants
above federal drinking water or State drinking water or
groundwater standards in any of the bedrock or glacial till
monitoring wells. No pesticides or PCBs were detected in any of
the groundwater samples collected from the Site. The sampling
events did show VOCs, semivolatile organic compounds (SVOC), and
chlorinated organic compounds at concentrations exceeding federal
drinking water and State groundwater and drinking water standards
in monitoring wells that are screened in the outwash and across
the outwash and till interface (see Table 1) . As a result two
plumes of total organic compounds exceeding 100 micrograms per
liter (/KJ/L) or parts per billion (ppb) were defined (see Figure
3) . One plume originates at lagoons 1 and 2, the other at
lagoons 7 and 8. The concentration of organics in the
groundwater decreases dramatically further downgradient of the
lagoons, which suggests that significant attenuation of
contaminants has occurred. This has been simulated through
groundwater modeling conducted at the Site. The plumes are of
limited extent, and have not extended far enough to impact Gold
Creek, or to affect groundwater or the residential wells south of
Gold Creek.
The discussion below is intended to summarize groundwater results
for organic constituents by plume (i.e., results of samples
collected from monitoring wells in the plume downgradient from
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lagoons 1-4 and results of samples collected from monitoring
wells in the plume downgradient of lagoons 6-8) . The discussion
focuses on the 1?94 and 1995 sampling results, as these results
indicate the highest concentrations of organic contaminants and
during these sampling events all wells in the monitoring network
had been installed (the wells had been installed in phases).
Groundwater Dowr.cradient of Lagoons 1-4
During the 1994 sampling event, four organic compounds, benzene,
1, 2-dichloroether.e, tetrachloroethene and trichloroethene were
detected above the federal drinking water and/or State drinking
water and groundwater standards in the monitoring wells located
downgradient of lagoons 1 through 4. The highest concentrations
of the chlorinated organic compounds were observed in shallow
outwash well OW-2, located downgradient of lagoon 2. Groundwater
samples from monitoring well OW-2 detected 1,2-dichloroethene at
130 ppb, tetrachloroethene at 100 ppb, and trichloroethene at 24
ppb. The federal drinking water and State drinking water
standards for tetrachloroethene and trichloroethene are 5 ppb;
the State drinking water standard for 1,2-dichloroethene is 5
ppb, which is more stringent than the federal standard. Benzene
was observed in shallow outwash well MW-4 at 15 ppb. The State
groundwater standard for benzene is 0.7 ppb. The 1995
groundwater results detected organic constituents at similar
concentrations as those detected during the 1994 sampling event.
Groundwater Downgradient of Laaoons 6-8
Groundwater data collected in the 1995 sampling event, in the
vicinity of lagoons 7 and 8, indicates that benzene is the
primary organic contaminant in the plume originating from these
lagoons. During the 1995 sampling of monitoring wells located
downgradient of lagoons 6, 7 and 8 (OW-9, OW-10, OW-ll, OW-12,
OW-13), benzene (State grcundwater standard of 0.7 ppb) was
detected in monitoring well OW-9 at 900 ppb. Monitoring well OW-
10, which is located immediately downgradient of lagoon 8, had
concentrations of benzene at 2,600 ppb, xylene at 30 ppb (State
drinking water standard of 5 ppb), and isophorone at 440 ppb
(State drinking water standard of 10 ppb) . Monitoring well OW-ll
had concentrations of benzene at 970 ppb, ethylbenzene at 30 ppb
(State drinking water standard of 5 ppb), xylene at 51 ppb, and
naohthalene at 17 oob (State drinkinc water standard of 10 ocb).
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Benzene and phenol (State drinking water standard of 1 ppb) were
detected at 2,400 ppb and 55 ppb, respectively, in monitoring
well OW-12. Monitoring well OW-13 had concentrations of 1,2-
dichloroethene at 20 ppb, benzene at 350 ppb, and vinyl chloride
at 34 ppb (State drinking water standard of 2 ppb). The 1994
groundwater results detected organic constituents at similar
concentrations as those detected during the 1995 sampling event.
As previously stated, the concentrations of organics in
groundwater in the outwash aquifer decreased dramatically
downgradient from the lagoons in the 1994 and 1995 sampling
rounds. In 1995, sampling data from the furthest downgradient
wells from the lagoons (OW-17, OW-18, OW-19, and OW-23) only
indicated three organic compounds above the State drinking water
standards. Benzene was detected at 12 ppb, chlorobenzene at 10
ppb and xylene at 29 ppb in monitoring well OW-18. Benzene and
chlorobenzene were detected at 6 ppb and 8 ppb, respectively in
monitoring well OW-19. No organic compounds were detected in
monitoring wells OW-17 and OW-23.
The discussion below is intended to summarize groundwater results
for inorganic constituents. The discussion focuses on the 1994,
1995 and 1996 sampling results.
Inorganic sampling results for the September 1994 and April 1995
sampling events were contradictory, leading EPA to conduct
another round of groundwater samples in July 1996. Groundwater
samples collected in the 1994 sampling event were non-filtered
inorganic samples. Although the results of the 1994 analyses
indicated the presence of inorganic compounds, very few samples
indicated concentrations above federal drinking water and State
drinking water and groundwater standards. Monitoring well OW-19
detected arsenic at 28.9 ppb (State groundwater standard of 25
ppb), chromium was found in monitoring well OW-9 at 123 ppb
(State groundwater standard of 50 ppb), antimony was found at 65
ppb (State groundwater standard of 3 ppb) in monitoring well OW-
23 . For each of the inorganic compounds that exceeded their
respective criteria (arsenic, chromium and antimony) exceedances
occurred in only one sample out of the 32 samples collected.
Groundwater samples collected in the 1995 sampling event were
highly turbid. These samples were filtered in the field. The
results of the 1995 inorganic analyses indicated the presence of
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various inorganic constituents in the groundwater downgradient of
the lagoons above background concentrations. Several inorganic
constituents were detected at concentrations that exceeded the
federal drinking water and/or State drinking water and
groundwater standards. Monitoring well OW-10 detected antimony
at 15 ppb (State groundwater standard of 3 ppb) and nickel at 425
ppb (there is no drinking water standard for nickel at this
time), arsenic was detected at 105 ppb (State groundwater
standard of 25 ppb) in monitoring well OW-20, chromium was
detected at 669 ppb (State groundwater standard of 50 ppb) in
monitoring well OW-13, and lead was detected at 283 ppb (federal
drinking water action level of 15 ppb) in monitoring well OW-9.
Due to the inconsistency between the 1994 and 1995 sampling
results for inorganic constituents, EPA conducted another
sampling event for inorganic constituents in July 1996. It was
suspected that the high concentrations of inorganics detected in
1995 may have been an artifact of highly turbid samples resulting
from the sampling protocols used at that time. Because of this,
the July 1996 groundwater samples were collected via a low-flow
pump, and these samples were not filtered. Also, during sample
collection, the presence of high turbidity in some of the samples
was observed, an indication that the filter pack around the
screen zone had become filled with fine particles from the
geologic formation. Therefore some monitoring wells were
re-developed prior to collecting the groundwater samples. The
results of this sampling event only indicated the presence of
inorganic compounds in three samples. Chromium was detected in
monitoring well OW-9 at 70 ppb (State groundwater standard of 50
ppb), arsenic was detected at 43 ppb and 37 ppb (State
groundwater standard of 25 ppb) in monitoring wells OW-19 and OW-
18, respectively.
The levels of inorganics detected in the 1995 samples tend to
directly depend on the amount of suspended sediment (turbidity)
in the samples. Since the excessive turbidity present in the
1995 groundwater samples is believed to be both an artifact of
sampling and clogging of the filter pack in the wells, these
higher levels are not representative of true Site conditions in
the aquifer. Therefore, the results of the groundwater data
suggests that the inorganic compounds found in the groundwater
beneath the Site are likely present at naturally occurring
levels. As the potential for inorganic compounds to be present
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in groundwater at concentrations above naturally occurring levels
due to leaching from the lagoon sediments is low, the potential
for these inorganic compounds to subsequently discharge with
groundwater to Gold Creek is also low. It should be noted that
the results from the 1994 sampling event for inorganic
constituents were included in the risk assessment (see Summary of
Site Risks below).
Sediment samples were collected from two locations in Gold Creek
south of the Site. These samples were collected in September
1994 and analyzed for organic and inorganic compounds. The
analytical results of the sampling indicate that Site related
contaminants have not impacted Gold Creek.
As part of the RI, groundwater modeling was conducted to
determine whether the organic contaminant patterns found in the
groundwater beneath the Site have stabilized due to intrinsic
biodegradation and to estimate future concentrations of
contaminants at potential off-site locations. The results of the
groundwater modeling indicate that the organic contaminants in
the groundwater are not migrating to Gold Creek and that the
concentration patterns observed at the Site have stabilized or
are not expected to change in the future. Thus, contaminants in
the groundwater beneath the Site are not expected to reach Gold
Creek or off-site residences in the future.
Also, as part of the RI, limited data was collected to evaluate
the extent of biodegradation at the Site. This limited
evaluation included the collection of dissolved oxygen and the
presence of microorganisms in the groundwater capable of
degrading volatile organic compounds under expected Site
conditions. The dissolved oxygen levels in the benzene plume
indicated the potential for biodegradation to be occurring; the
degrading microorganisms population was in the range of 10s to
106, indicating a healthy and robust community of degraders
present in the aquifer. Therefore, the limited field data
combined with the groundwater modeling projections demonstrate
the potential for biodegradation of organic contaminants at the
Site. The groundwater modeling results estimated that
contaminants will attenuate to levels below State and Federal
drinking water standards within five years after completion of
the OU1 remedy.
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The City of Port Jervis is served by a municipal water supply
that relies on three hydraulically-upgradient reservoirs as water
sources. Outside of the City limits, private supply wells
provide drinking water. It should be noted that the New York
State Department of Health (NYSDOH) sampled several wells located
downgradient of the Site while the RI/FS was being conducted.
Several private wells were sampled 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.
Subsequently, in September 1994 and March 1995, NYSDOH sampled
and analyzed a total of ten private wells in the area for
volatile organic compounds. The wells were located along Andrew
Drive, Evergreen Lane, Mark Drive, Michael Drive, Van Avenue, and
NY Route 209. The results indicate that no volatile organic
compounds were detected in any of the wells sampled.
SUMMARY OF SITE RISKS
EPA conducted a baseline risk assessment to evaluate the
potential risks to human health and the environment associated
with the Site groundwater under current and future conditions.
The Risk Assessment focused on contaminants in the groundwater at
the Site, which are likely to pose significant risks to human
health and the environment, if no remedial action were taken.
Human Health Risk Assessment
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
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excess cancer risk) assessment of site-related risks.
The baseline risk assessment began with the selection of
contaminants of concern. A summary of the contaminants of
concern detected in the groundwater is provided in Table 2.
These contaminants included the organic contaminants benzene,
chloroform, 1,2-dichlorobenzene, tetrachloroethene, toluene,
vinyl chloride, xylene, phenol, and the inorganic contaminants
arsenic, antimony, barium, chromium, lead, and zinc. The organic
contaminants were present in monitoring wells close to the
lagoons at levels which exceeded State and Federal drinking water
standards and State groundwater standards.
EPA's baseline risk assessment addressed the potential risks to
human health by identifying several potential exposure pathways
by which the public may be exposed to contaminant releases at the
Site under current and future land-use conditions. Table 3
provides the potential exposure pathways for current and future
land-use scenarios evaluated in the risk assessment.
There are no current on-site groundwater users at the S-ite,
therefore there are no potential current receptors at the Site.
Potential off-site receptors included residents to the east and
southeast of Gold Creek who use groundwater as drinking water and
recreational users of Gold Creek. Groundwater modeling, in
conjunction with measured groundwater concentrations, sediment
data from Gold Creek and groundwater concentrations from off-site
residential wells, indicates that the plumes have stabilized and
that contaminants have not migrated either to Gold Creek or to
off-site residences on the other side of Gold Creek, nor are they
expected to migrate to or beyond Gold Creek in the future. Thus,
current exposures to either off-site residents or recreational
users of Gold Creek are not occurring and are not expected to
occur in the future. These exposure pathways therefore, were not
quantitatively evaluated in the risk assessment.
The Site and land immediately adjacent to the Site are currently
zoned exclusively for industrial land use; the Site is surrounded
by a sheer rock cliff, the City of Port Jervis Landfill and
gravel and cement block manufacturing operations. Therefore,
future residential or commercial use of the Site is not expected
to occur and industrial use of the Site was the only use
evaluated in the risk assessment.
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EPA was concerned that industrial workers at the Site could be
exposed to contaminants in the groundwater and evaluated these
potential exposures in the risk assessment. The baseline risk
assessment considered the potential health effects for industrial
workers that could result from incidental ingestion of
contaminated groundwater from the on-site aquifer.
Under, current EPA guidelines, the likelihood of carcinogenic
(cancer-causing) and non-carcinogenic health 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 risks and non-carcinogenic
health effects 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
slope factors developed by EPA for the contaminants of concern.
Cancer slope factors (SFs) have been developed by EPA's
Carcinogenic Risk Assessment Verification Endeavor (an Inter-
agency workgroup of scientists with expertise in carcinogens) 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 risk highly unlikely. The SF for the compounds of concern
are presented in Table 4 (see column identified as cancer slope
factor).
For known or suspected carcinogens, EPA considers excess upper-
bound individual lifetime cancer risks in the range of 10'4 to
10'6 to be acceptable. This level indicates that an individual
has not greater than a one in ten thousand to one in a million
chance of developing cancer as a result of Site-related exposure
to a carcinogen over a 70-year period under specific exposure
conditions at the Site. As noted above, under the current Site
13
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conditions, there are no current on-site groundwater users at the
Site, therefore there are no potential current receptors at the
Site. Evaluation of risks to potential future industrial workers
was 1.4 x 10'4 (approximately one-in-ten thousand) which is
considered to be within the.U.S. EPA target risk range of 10~4 to
10"6. The main contributors to the total cancer risk were
arsenic, vinyl chloride, and benzene through ingestion of
groundwater. A summary of the carcinogenic risks associated with
the chemicals for a potential future industrial worker drinking
contaminated groundwater is found in Table 5.
Non-carcinogenic health effects 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 milligrams/kilogram-day (mg/kg-day), are
estimates of daily exposure levels for humans which are thought
to be safe over a lifetime (including sensitive individuals).
Estimated intakes of chemicals from environmental media (the
amount of a chemical ingested from contaminated drinking water)
are compared to 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
that impact a particular receptor population.
An HI greater than 1.0 indicates that the potential exists for
non-carcinogenic health effects to occur as a result of site-
related exposures. The HI provides a useful reference point for
gauging the potential significance of multiple contaminant
exposures within a single medium or across media. The reference
doses for the compounds of concern at the Site are presented in
Table 4.
The calculated HI value, which reflects non-carcinogenic effects,
was estimated to be 0.55 which is below the acceptable level of
1.0 indicating no adverse health effects to future industrial
workers. The main contributor to the total noncancer risk was
arsenic through ingestion of drinking water. A summary of the
non-carcinogenic risks associated with the chemicals for a
potential future industrial worker drinking contaminated
groundwater is found in Table 5.
14
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Ecological Risk Assessment
There are no impacts to ecological receptors in Gold Creek, since
contaminants in groundwater have not migrated to Gold Creek and
are not anticipated to migrate there in the future.
Uncertainties
The procedures and inputs used to assess risks in this
evaluation, as in all such assessments, are subject to a wide
variety of uncertainties. In general, the main sources of
uncertainty include:
• environmental chemistry sampling and analysis
• environmental parameter measurement
• fate and transport modeling
• exposure parameter estimation
• toxicological data.
Uncertainty in environmental sampling arises in part from the
potentially uneven distribution of chemicals in the media
sampled. Consequently, there is significant uncertainty as to
the actual levels present. Environmental chemistry-analysis
error can stem from several sources including the errors inherent
in the analytical methods and characteristics of the matrix being
sampled.
Uncertainties in the exposure assessment are related to estimates
of how often an individual would actually come in contact with
the chemicals of concern, the period of time over which such
exposure would occur, and in the models used to estimate the
concentrations of the chemicals of concern at the point of
exposure.
Uncertainties in toxicological data occur in extrapolating both
from animals to humans and from high to low doses of exposure, as
well as from the difficulties in assessing the toxicity of a
mixture of chemicals and the availability of toxicity data for
all chemicals of concern. 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
15
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underestimate actual risks related to the Site.
More specific information concerning public health risks,
including a quantitative evaluation of the degree of risk
associated with various exposure pathways, is presented in the
Risk Assessment Report.
Actual or threatened releases of hazardous substances from this
Site, if not addressed by implementing the response action
selected- in the ROD, may present an imminent and substantial
endangerment to 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 objective for the groundwater beneath the
Site is to reduce or eliminate potential health risks associated
with ingestion of Site contaminated groundwater by potential
future industrial workers and to reduce the concentration of
contaminants in the groundwater to drinking water standards.
DESCRIPTION OF REMEDIAL ALTERNATIVES
CERCLA requires that each selected site remedy be protective of
human health and the environment, be cost effective, comply with
federal and state requirements that are legally applicable or
relevant and appropriate, 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 four remedial alternatives for
addressing the contaminated groundwater beneath the Carroll and
Dubies Sewage Disposal Inc., Site. Since each alternative would
still result in contaminants remaining at the Site above levels
which allow for unrestricted use and unlimited exposure, each
alternative would require five-year reviews to ensure that the
16
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remedial action is protective of human health and the
environment. Five-year reviews are currently required as part of
OU1. As used in the following text, the time to implement a
remedial alternative reflects only the time required to construct
or implement the remedy and does not include the time required to
design the remedy, negotiate with the responsible parties, or
procure contracts for design and construction, or conduct
operation and maintenance at the Site.
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. As demonstrated through the results of the
groundwater modeling study, naturally occurring processes for
reducing the concentration of contaminants in the groundwater are
at work at the Site. Under this alternative, no action would be
taken to address the contaminated groundwater. There would be no
monitoring of these naturally occurring processes in the
groundwater to evaluate the rate and extent of the reduction and
mobilization of contaminants in the groundwater beneath the Site.
The period for the groundwater to reach federal drinking water
and State drinking and groundwater standards was projected
through the groundwater modeling to be approximately five years
after the implementation of the OU1 remedy. The remediation of
the lagoons, which will be implemented under OU1, would'minimize
any additional contaminant contribution to the groundwater.
Alternative 2: Natural Attenuation with Institutional Controls
and Monitoring
Capital cost: $ 0
0 & M/yr Cost: - $ 58,000
Present Worth: $ 284,000
Time to Implement: 6 months
Similar to Alternative 1, Alternative 2 would also rely on
natural attenuation, with intrinsic biodegradation as a principal
17
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mechanism, to reduce contaminants in the groundwater to drinking
water standards. The remediation of the lagoons and the
contaminated soils, which will be implemented under OU1, would
minimize any additional contaminant contribution to the
groundwater. This alternative includes the implementation of
institutional controls, such as deed restrictions, contractual
agreements, local law or ordinances or other governmental action
for the purpose of restricting installation and use of
groundwater wells throughout the contaminated groundwater plume.
These restrictions would complement any restrictions implemented
as part of the OU1 remedy. Institutional controls restricting
the use of Site groundwater would be required until the
groundwater has been demonstrated to meet federal drinking water
and State groundwater and drinking water standards. Groundwater
modeling projected that intrinsic biodegradation and flushing
mechanisms would reduce the concentration of contaminants in the
groundwater to levels below drinking water standards within five
years of the completion of the GUI remediation. Once these
levels have been demonstrated to be met, the restrictions on
groundwater use would no longer be required. Groundwater
monitoring at the Site and sampling in Gold Creek would also be
conducted.
This alternative includes a component of initial assessment of
the groundwater parameters which favor natural attenuation and a
groundwater monitoring requirement to evaluate the rate and
extent of reduction of the organic contaminants in the
groundwater. The initial assessment would include an evaluation
for the presence of constituent-degrading microorganisms, pH,
oxygen or other electron acceptors, elemental nitrogen,
phosphorous and other parameters necessary to evaluate the
progress of natural attenuation. Groundwater monitoring would be
conducted on a semiannual basis.
Alternative 3: Groundwater Pump and Treat via Precipitation,
Filtration and Carbon Adsorption
Capital Cost: $ 1,070,000
O & M/yr Cost: $ 287,200
Present Worth: $ 2,105,000
Time to Implement: 9 months
This alternative would consist of a series of recovery wells used
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to capture contaminated groundwater immediately downgradient of
the source areas or the lagoons. The recovery wells would
capture the most concentrated portion of the contaminant plume
emanating from the source areas. Any impacted groundwater that
would not be captured by the recovery wells would be .naturally
attenuated. This alternative would eliminate the potential for
migration of organic contaminants off site. The recovery wells
would be located in that portion of the outwash aquifer located
downgradient of the towpath. Beneath the lagoons, a saturated
outwash unit does not exist.
The preliminary configuration of the treatment system assumes
that approximately six wells would be used to pump groundwater at
controlled rates to capture the impacted groundwater. Two sets
of three pumping wells, each pumping at a rate of 5 gallons per
minute (gpm), would be used. The total pumping rate of the six
wells is 30 gpm. One set of wells would be located between 100
feet to 150 feet downgradient of lagoon 8. This set of three
wells would be designed to capture impacted groundwater passing
beneath lagoons 6, 7, and 8. One set of wells would be located
between 100 feet to 125 feet downgradient of lagoons 1 and 2.
This set of three wells would be designed to capture impacted
groundwater passing beneath lagoons 1 and 2. The recovered
groundwater would be treated on-site through a series of
treatment processes. Conceptually, the treatment system would
consist of iron and suspended solids removal via precipitation
followed by filtration and carbon adsorption. Following
treatment, the groundwater would be discharged to Gold Creek in
accordance with the State Pollutant Discharge Elimination System
(SPDES) requirements. Residuals generated from the treatment
processes would be managed in accordance with the Resource
Conservation and Recovery Act (RCRA) regulations.
This alternative would also include groundwater monitoring to
measure the effectiveness of the pump-and-treat system, as well
as the institutional controls specified in.Alternative 2. The
treatment system would be operated until contaminant levels in
the groundwater reach federal drinking water and State drinking
water and groundwater standards, which has been estimated to be
approximately five years after implementation of the remedy for
the lagoons.
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Alternative 4: In Situ Groundwater Treatment
Capital Cost: $ 1,017,000
O & M/yr Cost: $ 248,000
Present Worth: $ 1,912,787
Time to Implement: 12 months
This alternative involves the injection of air into the saturated
zone (i.e., below the water table), via a series of wells, to
reduce the volatile constituents dissolved in groundwater. These
wells would be located in the same general vicinity as the
pumping wells outlined in Alternative 3, thus allowing treatment
of the most concentrated portion of the groundwater plumes. Any
impacted groundwater that would not be captured by the in situ
groundwater treatment system would be naturally attenuated. The
levels of organic constituents would be decreased in the
saturated zone during aquifer aeration via mass transfer of the
chemicals from the water phase to the gaseous phase. If the
levels of organic compounds exceed air quality guidelines, then a
soil venting system would be installed in the subsurface to
collect the air emissions. The exhaust air from the vapor
extraction system would be discharged to a treatment system. The
gaseous treatment system for this alternative would be an
activated carbon filter. Groundwater monitoring would also be
conducted as part of this alternative to evaluate the
effectiveness of the air sparging system. A reduction in the
levels of organics may also take place in the saturated zone
through the enhancement of biodegradation due to the increase in
oxygen. With this alternative, air sparging ma'y be used in
conjunction with vacuum extraction and/or enhanced bioremediation
with the addition of nutrients.
A preliminary configuration of the aquifer aeration system would
consist of approximately 30 air sparging wells. This alternative
would include the same monitoring program and institutional
controls described in Alternative 3. Treatment of the
groundwater would continue until contaminant levels in the
groundwater achieve federal drinking water and State drinking
water and groundwater standards. This alternative would achieve
groundwater remediation goals within about five years after
implementation of the remedy for the lagoons.
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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 C.F.R.
§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 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 toxicitv. mobility, or volume through treatment
is the anticipated performance of a remedial technology,
with respect to these parameters, that a remedy may employ.
21
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5. Short-term effectiveness addresses the period of time needed
to achieve protection and any adverse impacts on human
health and the environment that may be posed during the
construction and implementation 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
For No Action (Alternative 1) and Natural Attenuation with
Institutional -Controls and Monitoring (Alternative 2), the
concentration of contaminants in the groundwater would be reduced
due to natural attenuation of contaminants until federal drinking
water and State drinking and groundwater standards are met. This
period has been estimated to be approximately five years from
implementation of the OU1 remedy. The No Action alternative
would present a slightly greater risk to human health and the
environment than Alternatives 2, 3, and 4 in the short-term
because the potential would exist that an on-site worker could
come in contact with the contaminated groundwater. Under
22
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Alternative 2, protection of human health would be enhanced with
the implementation of institutional controls, preventing the use
of the contaminated groundwater.
For the Pump-and-Treat (Alternative 3) and In Situ Groundwater
Treatment (Alternative 4) scenarios, the potential risks to human
health from potential exposure to impacted groundwater would be
reduced by removal and treatment of contaminants in the
groundwater captured by the remedial systems. These alternatives
would achieve groundwater remedial goals within about five years
of the implementation of OU1. Institutional controls preventing
the use of Site groundwater would eliminate the potential
exposure to contaminated groundwater while the groundwater is
being remediated. The contaminants would continue to migrate
until attenuated under Alternatives 1 and 2. However, impacts
are expected to be minimal since, as noted in the risk assessment
section, the levels of contaminants in the groundwater present no
significant human health risk under current or future uses.
Furthermore, impacts to ecological receptors in Gold Creek from
the implementation of all the remedial alternatives would be
unlikely since contaminants in groundwater have not migrated to
Gold Creek and are not anticipated to migrate there in the
future.
Compliance with ARARs
Actions taken at any Superfund site must meet all ARARs of
federal and state law or provide grounds for waiving these
requirements. All of the alternatives have been designed to
achieve or comply with the ARARs.
Since the groundwater at the Site is a future potential source of
drinking water, federal drinking water standards (Maximum
Contaminant Levels [MCLs]) and New York State Drinking Water
Standards and New York State Groundwater Quality Standards are
ARARs. For No Action (Alternative 1) and Natural Attenuation
with Institutional Controls and Monitoring (Alternative 2),
federal drinking water and State drinking water and groundwater
standards would be achieved over time through natural
biodegradation of organic contaminants in the groundwater. The
period for the groundwater to reach federal drinking water and
State drinking and groundwater standards was projected through
groundwater modeling to be approximately five years from
23
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implementation of the OU1 remedy. For the Pump-and-Treat
(Alternative 3) and In Situ Groundwater Treatment (Alternative 4)
scenarios, groundwater standards would be met by removal and
treatment of contaminants in the groundwater. The discharge of
treated groundwater to Gold Creek during implementation of
Alternative 3 would comply with the Federal Clean Water Act arid
State Pollutant Discharge Elimination System (SPDES) regulations.
The residual sludges from the treatment system under Alternative
3 would be treated or disposed of off-site in accordance with
RCRA regulations. The spent carbon generated from the
groundwater treatment system under Alternative 3 and the gas
treatment system under Alternative 4 would either be regenerated
off-site or sent off-site for treatment and disposal in
accordance with RCRA regulations. As with Alternatives 1 and 2,
federal drinking water and State drinking water and groundwater
standards are expected to be achieved with Alternatives 3 and 4
within slightly less than five years after implementation of the
OU1 remedy.
Long-Term Effectiveness and Permanence
With all four alternatives, within approximately five years of
the implementation of OU1 remedy, the concentrations of
contaminants in the groundwater are expected to be permanently
reduced to levels below ARARs. Implementation of Alternatives 3
and 4 might result in a slightly reduced time frame to achieve
ARARs downgradient of the lagoons. Therefore, all alternatives
are relatively similar in terms of this criterion.
Reduction of Toxicity, Mobility, and Volume through Treatment
Alternatives 1 and 2 rely solely on naturally occurring
mechanisms to reduce the toxicity and volume of contaminants in
the groundwater, and therefore do not satisfy the CERCLA
preference for treatment to reduce toxicity, mobility, and volume
of contaminants. Under Alternatives 3 and 4, treatment to reduce
contaminants in the groundwater would be achieved by extraction
of the contaminants and subsequent treatment. Alternatives 3 and
4 are similar in their abilities to reduce toxicity, mobility and
volume and would provide reduction of toxicity, mobility and
volume somewhat more rapidly than Alternatives 1 and 2.
24
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Short-Term Effectiveness
Alternatives 1 and 2 would have no adverse effects at all on the
community, site workers, or the environment since there would be
no potential exposure to any of the contaminants because no
construction activities would occur. Alternative 2 includes
. Institutional controls preventing the use of Site groundwater,
which would minimized impacts during implementation until cleanup
goals are achieved. However, Alternatives 3 and 4 would present
greater impacts than Alternatives 1 and 2, due to construction
activities. For example, the construction of extraction wells
and piping to transport the created groundwater to Gold.Creek
would have minor negative impacts on residents and workers in the
area. These impacts would be associated with the disruption of
traffic,-excavation on public and private land, and noise and
fugitive dust emissions. Appropriate measures, however, would be
implemented to minimize these impacts.
Implamentability
Alternative 1 - No Action is clearly the most implementable.
Alternative 2 would require groundwater-use restrictions to
prevent the use of groundwater wells throughout the contaminated
aquifer; although sometimes difficult to obtain, these
restrictions are being used at numerous sites. Alternative 2
would also require additional geochemical and intrinsic
biodegradation studies and monitoring. These studies and
monitoring requirements are being implemented at numerous sites.
Alternatives 3 and 4 would be more difficult to implement due to
construction requirements. Additionally, Alternative 3 would
require that access be obtained to construct the piping to
transport the treated groundwater to Gold Creek; authorization to
discharge treated water to Gold Creek would add to the complexity
of implementing this remedy. Nonetheless, these are successfully
proven technologies at the field scale and considered to be
readily implementable.
Cost
There is. no cost associated with the No Action alternative.
Alternative 2, Natural Attenuation with Institutional Controls
and Monitoring, is the next lowest cost alternative with a
25
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present worth of $284,000; there is no capital cost associated
with this alternative. Alternative 3, Groundwater Pump and
Treat, has the highest cost with a present worth and capital cost
of $2,105,000 and $1,070,000, respectively. Alternative 4, In
Situ Groundwater Treatment, with a present worth and capital cost
of $1,912,787 and $1,017,000, respectively, is slightly less than
Alternative 3.
State Acceptance
The State of New York, through the NYSDEC, concurs with EPA's
selected remedy. The NYSDEC's letter of concurrence is attached
as Appendix IV.
Community Acceptance
Community acceptance of the preferred remedy has been assessed in
the Responsiveness Summary portion of this ROD following review
of all public comments received on the RI/FS report and the
Proposed Plan. All comments submitted during the public comment
period were evaluated and are addressed in the attached
Responsiveness Summary (Appendix V) . In general, the public is
supportive of EPA's preferred remedy.
SELECTED REMEDY
EPA has determined, after reviewing the alternatives and public
comments, that Alternative 2 is the appropriate remedy for the
groundwater beneath and downgradient of the Site, because it best
satisfies the requirements of CERCLA and the NCP's nine
evaluation criteria for remedial alternatives.
The major components of the selected remedy are as follows:
Natural attenuation of organic contaminants in the
groundwater to below federal drinking water and State
groundwater standards through naturally occurring removal
processes. The remediation of the lagoons, which will be
implemented under OU1, will minimize any additional
contaminant contribution to the groundwater. Groundwater
modeling estimated that contaminants would attenuate to
these standards within five years of completion of the
remedy selected for OU1.
26
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Implementation of institutional controls, such as deed
restrictions, contractual agreements, local law or
ordinances or other governmental action for the purpose of
restricting installation and use of groundwater wells
throughout the contaminated groundwater plume.
Monitoring of the groundwater to evaluate improvement in
groundwater quality and ensure the effectiveness of the
remedy.
Sampling in Gold Creek to ensure that site related
contaminants do not impact the creek.
STATUTORY DETERMINATIONS
Under Section 121 of CERCLA, EPA's primary responsibility at
Superfund sites is to undertake remedial actions that are
protective of human health and the environment, and complies with
federal and State requirements that are legally applicable or
relevant and appropriate 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 whether and how the selected remedy
meets these statutory requirements.
Protection of Human Health and the Environment
The selected remedy is protective of human health and the
environment. The concentration of contaminants in the
groundwater will be reduced to federal drinking water and State
drinking and groundwater standards via natural attenuation. It
has been estimated that these levels will be met approximately
five years after implementation of the OU1 remedy. Under this
remedy, protection of human health would be enhanced with the
implementation of institutional controls, preventing the use of
the contaminated groundwater.
27
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Compliance with ARARs
Alternative 2 remedy will comply with all ARARs for the
groundwater. These ARARs include the Federal Safe Drinking Water
Act Maximum Contaminant Levels (MCLs) (40 CFR Part 141.11-141.16
and Part 141.60-141.63), the New York Public Water Supply
Regulations (NYCRR Title 10, Part 5-1), and New York State Water
Classifications and Quality Standards for Class GA Ground Water
(NYCRR, Title 6, Parts 701-703). It has been estimated that
these levels would be met approximately five years after
implementation of the OU1 remedy.
Cost-Effectiveness
The selected remedy is cost-effective because it has been
demonstrated to provide overall effectiveness proportional to its
costs. The selected remedy is technically and administratively
implementable and represents the lowest cost of the alternatives
considered while achieving cleanup objectives in approximately
the same time-frame. The present worth of the selected
alternative is $284,000. There are no capital costs associated
with this remedial action.
Utilization of Permanent Solutions and Alternative Treatment
Technologies to the Maximum Extent Practicable
The selected remedy addresses all of the media of concern and
utilizes permanent solutions and treatment technologies to the
maximum extent practicable. In addition, the selected remedy
provides the best balance of trade-offs among the alternatives
evaluated with respect to the evaluation criteria.
Preference for Treatment as a Principal Element
Alternative 2 relies solely on naturally occurring mechanisms to
reduce the toxicity, mobility and volume of contaminants in the
groundwater. Groundwater modeling has predicted that Alternative
2 will attain ARARs in approximately the same time frame, five
years after the implementation of the OU1 remedy, as the other•
alternatives. This remedy is the most practical choice to
address the contamination of the groundwater underlying and
downgradient of the Carroll and Dubies site, even though it does
not satisfy the CERCLA preference for treatment.
28
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DOCUMENTATION OF SIGNIFICANT CHANGES
There are no significant changes from the preferred alternative,
as presented in the Proposed Plan.
29
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APPENDIX I
FIGURES
Figure 1 - Site Location Map
Figure 2 - Site Layout Map
Figure 3 - Isoconcentration Contours of Total Organics in the
Outwash Formation
30
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Carroll and Dubies She, Port Jerris, New York
Source: USGS 7W M3N. Topographk Qo*d.
Port Jerris North. .VY-PA 1969
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>CHV1S SOUllt. MJ-KT-PA. (l»«l). !
) ORAHCC COUNIY I/JC U^P. RIVISCO
*«0-OOI
GRAVEL PIT V
CITY LANDFILL
•(14)
\
IB uomioRiNC MIL IN CIACIAI ourwASn
• MONITORING MCLL IN OUrWASM/PLL
Q UOHllORINC *Cll IN GLACIAL HLL
0 MOKI10RINC WCLL IN BEDROCK
100- lSOCONC(NIRAt10N CONTOUR (ppb)
(II) AC1UAL CONCCHtHARON (ppo)
180 110 60 0 40 ISO
APPROXIMAIC SCALC IN fEEI
CARROLL AND OUBICS
DEER PARK, NEW YORK
1-II44-I11
ISOCONCENTRATION CONTOURS 01
TOTAL ORCANICS IN OUTWASH FORMATION • k
APRIL, 1995
-------
APPENDIX II
TABLES
Table 1 - Primary Constituents of Concern Detected in
Groundwater
Table 2 - Risk Assessment: Contaminants of Concern
Table 3 - Risk Assessment: Summary of Exposure Pathways
Table 4 - Risk Assessment: Non-carcinogenic and Carcinogenic
Toxicity Values
Table 5 - Risk Assessment: Non-carcinogenic and Carcinogenic
Risk Estimates
Table 6 - Detailed Cost Estimate for Alternative 2
31
-------
TABLEi (Continued)
VOLATILE ORGANIC COMPOUNDS
EXCEEDANCES FOUND IN GROUNDWATER SAMPLES
CARROLL & DUBIES SUPERFUND SITE
PORT JERVIS, NEW YORK
Well Number
Sampling Dale:
OW-2
9/94" 4/95
VOLATIl.ES(uR/L)
Clilofomelhanc
Irornomeihane
Vinyl Chloride
Chlorocllinnc
Mclbylcnc ClilotiJc
Acetone
,'arbon DisiilfiJc
l,l-l)ichloroclhcnc
I.l-Dichloroclliane
l.2-l)ichloroelliene(lolal)
Cliloiofonn
1.2-Dichloroelbane
'•Dutiinone
I.l.l-Trichloiociliane
Carbon Tctrachloride
Jromodichloromclliane
1 ,2-Dicbloropropane
cis-l,3-Dichloropropene
I'ricliloroctlicnc
Dibromochloromelhane
1.1.2-Tricliloroclhane
Dcnzcne
Trans- 1.3-Dicbloropropene
Biomofonu
4-Mclhyl-2-l>cnlonone
2-llcxanone
I'cirachlorocihcne
Toluene
1 , 1 .2.2-Telraclilorocllmne
Clilorobcnzcnc
l-iliylhcnzenc
Slyrcnc
rnliil Xylcnes
130 85
24 22
100 76
OW- 3
9/94" 4/95
15
OW-4
9/94 " '4/95
OW-5
9/94 4/95
19 7
OW-6 OW-7
9/94 4/95 9/94 4/95
6
8
17 19
OW-8
9/94 4/95
OW-9
~9/94~" 4~/95
4
530 900
OW-9
9/94" 4/95
:cdcral
MCI.
NYSUECT
SOV
5
780
NA
NA
2
NA
5
NA
NA
7
NA
70
100
5
NA
200
5
100
5
NA
5
NA
5
5
NA
100
NA
NA
5
1.000
NA
NA
700
100
10.000
NA
5(0)
2(S)
5(S)
5(S)
50(0)
NA
5(S)
5(S)
5(S)
7(S)
5(S)
50 (0)
5(S)
5(0)
50 (G)
5(S)
5(S)
5(S)
50 (G)
5(S)
0.7 (S)
5(S)
50 (G)
NA
50 (0)
5(S)
5(S)
5(S)
5(S)
5(S)
5(S)
5(S,
Nolti:
Analysis performed by method 8240.
Diiia lor wells OVV-12 and OW-14 have been torrccled for lliis table.
MC'I. • l;ederal Maximum Conlamiiiiml Level.
SOV • N YSDMC Ambient Water Quality Staiularils (S) mid (iiiidance ((!) Values.
NA • Not applicable/no value available.
I) Compound not detected above the sample qiiiinlilation limit.
J Reported value is estimated based on dalu validation.
F. Concentration rxcreded calibration range of instrument.
I) Diluted sample.
0 Compound was round in blank.
-------
TABLEi (Continued)
VOLATILE ORGANIC COMPOUNDS
EXCEEDANCES FOUND IN GROUNDWATER SAMPLES
CARROLL & DUBIES SUPERFUND SITE
PORT JERVIS, NEW YORK
\Vell Number 1
Suinpliri)! lljlc: |
VOI.ATII.ES(uR/I.)
.'lilixouiellianc
liunininctliane
Vinyl Clilnridc
tliloiocllirinc
Mcihylcne ChloiiJe
Acetone
Curium Divtilflde
I.l-Dicliluioclhcnc
,l-l)iclil(iroelliunc
l.}-l)ichloioi;llicnc(lolol)
lilorofdfin
l.2-l)icliloroelnane
2-llulanone
I.l.l-Tfichlotoclhanc
L'uibun Teirachlocide
liomoilicliloiomcllisne
1.2-DiclilofOpropanc
cis-IJ-Uicliloropropcne
Ificliloiocilicnc
libroniocliloromclhonc
1.1.2- 1 ricliloruclliane
Icnzcnc
1 r3iis-l,)-l)icliloropropcnc
Iliomuform
IMclli)l-2-IVnlDi)onc
2 llexanone
Iclraclilorocllicnc
toluene
1 . 1 .2.2-Tetracliloruclhanc
Cliloiobciizene
r.lliylben/cnc
Siyrene
1 ulal Xvlcncs
OW- 10 1
9/94 ' 4/95 1
1
68
1100 2600
8
9
S3 .10
O\V- 10 1
9/94 4/95 1
1
2900
OW- 1 1 1
9/9-1 4/95 1
1
8
8
JJO 970
20 30
62 51
OW- 14
9/94' 4/95
1
51
OW- 13 OW-IJ
9/94 4/95 9/94 4/95
9 34
6 20
40 390 350
OW- 12
9/94 4/95
4
1100 2400
18
9
12
50
OW- 1 5 1
9/94 '4/95 I
1
OW- 16
9/94 "4/95
I'cJcml
MCI.
NA
MA
2
NA
5
NA
NA
7
NA
70
100
5
NA
200
5
100
5
NA
5
NA
5
5
NA
too
NA
MA
5
1.000
NA
NA
700
100
1 0.111)0
NY$I>I:C
sc;v
NA
5(0)
2(S)
MS)
J(S)
30 (G)
HA
5(S)
5(S)
S(S)
7(S)
5(S)
50(0)
S(S)
5(0)
50(0)
J(S)
MS)
J(S)
50(0)
S(S)
0.7(S)
S(S)
50(0)
NA
50 (G)
S(S)
5(S)
5(S)
5(S)
5(S)
5(S)
5(S)
Nolci:
Analysis performed by incllioil 8240.
|)jia fur wells OW-12 and OW-14 liuvc been cnrrettod fur llii* liiblc.
MCI. • l-'ederul Maximum Conluininanl Level.
S(iV • NYSDCC Ambient Water Quality Standard* (S) ;mJ (iuidanvc (G) Values.
MA • Nut ;ipplicablc/no value available.
I) Compound mil dcleelcd above llie sample i|uanlilalion limit.
J Itepoiled value is estimated based on data validation.
E Coiieeiitiiiliiin exceeded cidtbrniton range "I inilriiinent.
D Diluted sninplc.
I) CuniputiiiJ wiij liuind in lilunk.
-------
TABLE 1 (Continued)
VOLATILE ORGANIC COMPOUNDS
EXCEEDANCES FOUND IN GROUNDWATER SAMPLES
CARROLL & DUBIES SUPERFUND SITE
PORT JERVIS, NEW YORK
Well Number
Sampling Hale:
VOI.ATII.ESfuR/l.)
Jliloroinelhane
Iromnrnclhine
Vinyl Chloride
Chloroelhonc
Meibylenc Chloride
Acetone
Carbon Disiilfide
I.l-Diclilwoellicno
1,1-Diclilnroelliunu
I.M)icliloroelhcnc(lolal)
Clilotoform
1.2-Didiloroelhanc
2-Dulanone
1,1.1-Trichloroelliane
Carbon Telrachloiide
Oromodicliloromclliane
1.2-Dicliloropropanc
cis-l.l-DichlotopfOpcne
Tricliloroclbcne
Oibromocliloromclhone
1,1,2-Trichlorucibane
Ocnzene
Kans-l,3-Uiclilotopropene
Dromoform
J-Mcthyl-2-l'cnlanone
2-llcxanone
fcliaclilotocllicnc
Toluene
1 . 1 .2.2- 1 elracliloroclhane
Clilorobcnzciie
lilbylbenzcnc
Slyrenc
I'mal Xvlencs
OW- 10 1
9/94 4/95 1
1
68
1100 2600
8
9
S3 30
OW- 10 1
9/94 4/95 1
1
2900
OW- 1 1
9/94 4/95
1
8
8
350 970
20 30
62 51
OW- 14
9/94 " 4/95
1
51
OW- 13 OW- 13
9/94 "4/95" 9"/94" '4/95'
9 34
6 20
40 390 350
OW- 12
9/94 " 4/95
4
1100 2400
18
9
12
50
OW- IS
9/94 4/95
1
OW- 16
9/94 "4/95
Federal
MCI.
NA
NA
2
NA
5
NA
NA
7
NA
70
100
5
NA
200
5
100
5
NA
5
NA
5
5
NA
100
NA
NA
5
1.000
NA
NA
700
100
10.00(1
HYSDKC
sov
NA
5(0)
2(S)
S(S)
5(S)
50(0)
NA
5(S)
5(S)
5(S)
7(S)
5(S)
50 (0)
S(S)
5(0)
50(0)
5(S)
5(S)
5(S)
50(0)
5(S)
0.7 (S)
5(S)
50(0)
NA
50(0)
5(S)
5(S)
5(S)
5(S)
5(S)
5(S)
5(S)
Nolei:
Analysis performed by method 8240.
Dala for wells OW-12 end OW-M have liccn corrected fur this table.
MCI. • Federal Maximum Coiiliiininanl Level
S(iV • NYSOCC Ambicnl W;iier Quality Standard* (S) and Guidance (G) Values.
NA • Noi applicable/no value available.
U
J
E
U
U
Compound mil tleleclcd above (lie sample (|iiaii(ilalion limil.
Reported value is estimated based uu data validation.
C'onecnlraliiin exceeded calibration range nl'instrument.
Diluted sample.
Compound was round in blank.
-------
TABLE ^Continued)
SEMI-VOLATILE ORGANIC COMPOUNDS
EXCEEDANCES FOUND IN GROUNDWATER SAMPLES
CARROLL & DUBIES SUPERFUND SITE
PORT JERVIS, NEW YORK
\Vrll Hiimlicr 1
Sampling Dale: |
OW- 2 I
9/9I 4/9$ I
Sl.MI VOI.A III.KS(|.R/I.) 1
rl.cnnl
llij(2 •Clitnioelliyl)l:llicr
•( ItllllllpllClllll
. ) |)iilil(iinlx;ii»cnc
.4-l)iililiiinlii-n/i:iie
, ? Dicliliunlxn/cnc
•Melliylpliennl
,2'-O«yliij(l-CldnnipropBne)
I- Mi-lli) l|>lii:iml
) Niliosoili H-l'iopyluiiiinc
IcxaililoKiclltaiie
tiliolien/eite
ioplipiune
2 Milinpliciiol
!.•! l)inii:lli)lpliciiol
lis(2-('lilofocllioxy) Mcllinnc
2.-) Dicliloidpliini)!
|.7,4-Tiichloiolien/cne
Haplillolcnv
l-Cldofoanilinc
le \ncliloiiibnliidiciic
l-ClilofO-3-Mclhylplienol
7-Mi-ili)lnaplillialtiie
llexarlilomcyclopcntndicne
7.-I.6- liicldoiopliciuil
2.1.5 lii(lilnio|i|iciiiiiti(ri)littnciic
VHitmaniliue
OW- ]
9/9 1 .J/9J
•I
OW- -I
9/9 1 4/95
OW. $ I
9/94 4/9$ |
OW- 6 .
9/94 -l'/9$
OW- 7
9/9.J" 4/9$
OW- g
9/9-1 4/9$
OW-9 1
9/91 4/9$ 1
71 -IX
OW- Ill
9/91 1/95
1 edciul 1
MC 1.
nvsnr.c
SVC
27
•no
HA
HA
HA
600
7$
600
HA
HA
HA
HA
HA
HA
HA
HA
HA
NA
HA
70
HA
HA
HA
HA
HA
50
HA
HA
HA
HA
HA
HA
HA
HA
1 (S)
MS)
HA
MS)
4.7 (S)
4.7 (S)
50lr/iiii value availdle.
II Compound not delected iiluive the sample ijiianlil.iiiiiii limit.
J Kepnilcd value is estimated Imscd on il.iln validation.
I: Concenlfiilion exceeded calilxalinn ijinge nl'iii
II Compound was found in blank.
l( D.il.i is (ejected based on data validation.
-------
TABLE i (Continued)
SEMI-VOLATILE ORGANIC COMPOUNDS
EXCEEDANCES FOUND IN GROUNDWATER SAMPLES
CARROLL & DUBIES SUPERFUND SITE
PORT JERVIS, NEW YORK
Well Number
Sampling Dale:
SKMI-VOI.ATII.KS(jiK/l.)
I'licnol
l)is(2-Chloroelliyl)Hihcr
2-Chloroplienol
l.3-l)ichlorobeiucrie
l.4'l)iclmmiben*ene
1,2-PiclilurobeM/cnc
2-Melliylphcnol
2,2'-Oxybis( 1 -Chloropropane)
4-Melhylphcnol
'•J-Nilrosodi-N-l'ropylaminc
llcxachloroetliiine
^iuobenzcnc
sophoronc
2-Niuophcnol
2,4-l)imc(hylplicnol
Ois(2-Cbloroclboxy) Methane
2.4-Dichlorophenol
1.2,4-Triclilorobciizciic
Naphthalene
4-Chloroaniline
llcxachlorohutadicnc
•J-Chloro-3-McUiylpticnol
2-Mclhylnaphihalcne
1 lexachlorocyclopcnladiene
2.4.6-Trichlorophenol
2,^,5-Trichlorophenol
2-Chloronaphlhalene
2-Nilroanilinc
Dimcthylphihalatc
Accnapluliylcne
2.6-l)inillOtulllCnO
3-Nilrnaniline
OW- 1 1
9/9-1 4/95
24
21 17
OW- U
9/94 .1/95
OW- 1 3
9/
-------
TABLE i (Continued)
SEMI-VOLATILE ORGANIC COMPOUNDS
EXCEEDANCES FOUND IN GROUNDWATER SAMPLES
CARROLL & DUBIES SUPERFUND SITE
PORT JERVIS, NEW YORK
Well Number
Sampling Dale:
SF.MI-VOI.AHI.KS (MR/I.)
Acenaphthcnc
2,4-Dinilrophcnol
4-Nilronhcnol
Dihciizofnran
2.4-l)inilrololiiene
Dielhylphlhalulc
•t-Clilorupliviiyl-l'liciiyl lithcr
l-luorenc
4-Nilroaniline
4,6-l)ini(ro-2-Mclliylphenol
hJ-Nilrosodipheny famine
4-Bromophenyl-Phenylclhcr
!lexachlorobcn/cnt:
Penlachlorophenol
Phenanlhrcne
Anlluacene
Carbazolc
Di-N-Hulylphlhalale
Fluoranlhenc
I'yrcne
Uulylbenzylphlhalale
3.3'-Dichlorobcnzidinc
[knzo(A)Anlhracene
Chrysene
l)is(2-i:lhylnexyl)l'hlhalale
Di-N-Oclylplilhalalc
Uenzo(IJ)Fluoranthcnc
[hnzo(K)Fluoranlhcnc
Rcnzo(A)l'yrenc
Indcno(l,2.3-Cd)l'yrcnc
Dibcn/(A,l IJAiithraccne
nenzo(O.IU)Pcrvlene
OW- 1 1
9/94 4/9$
57
OW- H
9/9-1 4/95
OW- 13
9/94 4/95
OW- 12
9/94 4/95
OW- 15
9/94 4/95
OW- 16
9/94 4/95
OW- 17
9/94 4/95
OW- 18
9/94 4/95
OW- 19
9/94 4/95
l:cdcr;il
MCI.
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
1
1
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
6
NA
NA
NA
2
NA
NA
NA
NYSDHC
SVG
20 (S)
NA
NA
NA
5(S)
50 (G)
NA
50(0)
NA
NA
50 (G)
NA
0.35 (S)
I(S)
50 (G)
50 (G)
NA
NA
50 (G)
50 (G)
50(0)
NA
0.002 (S)
0.002 (S)
50 (S)
NA
0.002 (S)
0.002 (S)
ND
0.002 (S)
NA
NA
Notes:
Analysis performed by method 8240.
Data for wells OW-12 imd OW-14 have been toneeled lor this table.
MCI. • Federal Maximum Contaminant Level.
SOV - NYSDIIC Ambient Water Quality Standards (S) and Guidance (G) Values.
NA - Not applicable/no value availble.
U Compound no( delected above the sample <|uanlilaiion limit.
J Reported value is estimated based on data validation.
!• Concentration exceeded calibration range of instrument.
I) Compound was found in blank.
It Data is rejected based on data validation.
-------
TABLE i
ANALYTE LIST METALS
HITS FOUND IN GROUNDWATER SAMPLES
CARROLL & DUBIES SUPERFUND SITE
PORT JERVIS, NEW YORK
Well Number
Sampling Dale:
M ETA I .S (MR/1
Aluiniiuun
Antimony
Arsenic
Barium
Ikryllitim
Cadmium
Chromium
Copper
Iron
Lead
Magnesium
Manganese
Mercury
Selenium
Silver
Sodium
Thallium
Zinc
Cyanide
Federal
MCLs
)
200
6
50
2,000
4
5
100
1.000
NA
NA
NA
50
2
50
100
NA
2
NA
200
NYSDI-C
SGVs
IOO(S)
3(0)
25 (S)
I.OOO(S)
3(0)
IO(S)
50 (S)
200 (S)
300 (S)
25 (S)
35,000(0)
300 (S)
2(S)
IO(S)
50 (S)
20.000 (S)
4(0)
300 (S)
IOO(S)
9/9-1
304
6060
38600
MW- 1
4/95 7/96
5640 5850
33100 28000
9/94
160
3250
3360
MW-3
4/95
1980
180
935
51900
54.3
4230
620
7/96
4520
9/94
172
17700
7850
257000
MW- 4
4/95
MOO
18200
6380
264000
4.2
7/96
12500
5880
205000
MW-5
4/95
2850
6710
355
MW- 10
7/96
26600
4640
Nolcs:
MCL - Federal Maximum Contaminant Level.
SGV - NYSDEC Ambient Water Quality Standards (S) and Guidance (G) Values.
NA - Not applicable/no value available.
-------
TABLE 4
ANALYTE LIST METALS
HITS FOUND IN GROUNDWATER SAMPLES
CARROLL & DUBIES SUPERFUND SITE
PORT JERVIS, NEW YORK
Well Number
Sampling Dale:
Federal
MCl.s
NYSDEC
SGVs
Y!ETALSOie/I.)
Aluminum
Antimony
Arsenic
Barium
Beryllium
Cadmium
Chromium
Copper
Iron
Lead
Magnesium
Manganese
Mercury
Selenium
Silver
Sodium
Thallium
Zinc
Cyanide
200
6
50
2.000
4
5
100
1.000
NA
NA
NA
50
2
50
100
NA
2
NA
200
IOO(S)
3(0)
25 (S)
I.OOO(S)
3(0)
IO(S)
50 (S)
200 (S)
300 (S)
25 (S)
35.000(0)
300 (S)
2(S)
IO(S)
50 (S)
20,000 (S)
4(0)
300 (S)
IOO(S)
OW-6
9/94
924
3930
3780
4/95
28200
3.3
28.8
61700
58.9
5940
OW-7
9/94 4/95
60! 43200
31.2
3.4
455
715 66800
79.9
4260
7/96
9/94
1170
12100
3850
OW-8
4/95 " '
12100
26.8
31800
35.3
4560
7/96
9740
4790
Noles:
MCL - Federal Maximum Contaminant Level.
SGV - NYSDEC Ambient Water Quality Standards (S) and Guidance (G) Values.
NA - Nol applicable/no value available.
-------
TABLE!
ANALYTE LIST METALS
HITS FOUND IN GROUNDWATER SAMPLES
CARROLL & DUBIES SUPERFUND SITE
PORT JERVIS, NEW YORK
Well Number
Sampling Dale:
VI ETA LS (UK/I
Aluminum
Antimony
Arsenic
Barium
Beryllium
Cadmium
Chromium
Copper
Iron
Lead
Magnesium
Manganese
Mercury
Selenium •
Silver
Sodium
Thallium
Zinc
Cyanide
Federal
MCLs
)
200
6
50
2.000
4
5
100
1,000
NA
NA
NA
50
2
50
100
NA
2
NA
200
NYSDEC
SGVs
IOO(S)
3(0)
25 (S)
I.OOO(S)
3(0)
!«
-------
TABLE 1
ANALYTE LIST METALS
HITS FOUND IN GROUNDWATER SAMPLES
CARROLL & DUBIES SUPERFUND SITE
PORT JERVIS, NEW YORK
Well Number
Sampling Dale:
Federal
MCl.s
NYSDI-C
SGVs
VI ETA I-S OIK/I.)
Aluminum
Antimony
Arsenic
Barium
Beryllium
Cadmium
Chromium
Copper
Iron
Lead
Magnesium
Manganese
Mercury
Selenium
Silver
Sodium
Thallium
Zinc
Cyanide
200
6
50
2,000
•1
5
100
1,000
NA
NA
NA
50
2
50
100
NA
2
NA
200
100(S)
3(0)
25 (S)
I,000(S)
3(0)
IO(S)
50 (S)
200 (S)
300 (S)
25 (S)
35,000 (G)
300 (S)
2(S)
10(S)
50 (S)
20,000 (S)
4(0)
300 (S)
IOO(S)
9/9«l
1750
53200
5420
O\V- 12
•1/95
8440
4.2
68100
6780
7/96
69800
8690
9/94
931
2320
1680
OW- 13
4/95 "
54200
3.2
39
3.3
669
236
73300
61
6010
1010
7/96
19200
7960
9/94
7540
17700
1990
22500
OW- N
4/95
19800
35800
2580
Notes:
MCL - Federal Maximum Contaminant Level.
SGV - NYSDEC Ambient Water Quality Standards (S) and Guidance (G) Values.
NA - Not applicable/no value available.
-------
TABLE 1
ANALYTE LIST METALS
HITS FOUND IN GROUNDWATER SAMPLES
CARROLL & DUBIES SUPERFUND SITE
PORT JERVIS, NEW YORK
Well Number
Sampling Date:
METALS (ME/I
Aluminum
Antimony
Arsenic
Barium
Beryllium
Cadmium
Chromium
Copper
Iron
Lead
Magnesium
Manganese
Mercury
Selenium
Silver
Sodium
Thallium
Zinc
Cyanide
Federal
MCLs
)
200
6
50
2,000
4
5
100
1,000
NA
NA
NA
50
2
50
100
NA
2
NA
200
NYSDEC
SGVs
IOO(S)
3(0)
25 (S)
I.OOO(S)
3(0)
IO(S)
50 (S)
200 (S)
300 (S)
25 (S)
35.000 (G)
300 (S)
2(S)
IO(S)
50 (S)
20,000 (S)
4(0)
300 (S)
IOO(S)
9/94
671
28800
6980
OW- 15
4/95
353
25700
5750
6.8
OW
9/94
2610
2720
2430
25200
-16
4/95
26700
81.1
65500
49.5
2130
22100
5.8
OW-16D
7/96
978
2640
OW-I6S
7/96
2650
31000
9/94
2290
f
4920
8890
OW- 17
4/95
20300
3.3
39100
29.4
7860
'"7/96""
8440
Notes:
MCL - Federal Maximum Contaminant Level.
SGV - NYSDEC Ambienl Water Quality Standards (S) and Guidance (G) Values.
NA - Not applicable/no value available.
-------
TABLE 1
ANALYTE LIST METALS
HITS FOUND IN GROUNDWATER SAMPLES
CARROLL & DUBIES SUPERFUND SITE
PORT JERVIS, NEW YORK
Well Number
Sampling Dale:
METALS (HE/I
Aluminum
Antimony
Arsenic
Barium
Reryllium
Cadmium
Chromium
Copper
Iron
Lead
Magnesium
Manganese
Mercury
Selenium
Silver
Sodium
Thallium
Zinc
Cyanide
Federal
MCl.s
)
200
6
50
2,000
4
5
100
1,000
NA
NA
NA
50
2
50
100
NA
2
NA
200
NYSDILC
SGVs
IOO(S)
3(G)
25 (S)
I.OOO(S)
3(G)
IO(S)
50 (S)
200 (S)
300 (S)
25 (S)
35.000(G)
300 (S)
2(S)
10(S)
50 (S)
20.000 (S)
4(G)
300 (S)
IOO(S)
9/94
7250
24300
7570
OW- 18
4/95
19900
5.7
70.9
98600
5090
21900
7/96
37.7 .
54000
1 480
9/94
1 220
28.9
58800
3190
31000
OW- 19
"4/95 "
22700
3.5
78.6
92800
46.9
3640
25700
' 7/96
43.1
67200
5060
24000
9/9'i
5 1 800
- 3520
OW- 20
"4/95 "
38000
4.5
105
375
121000
78.6
6560
364
7/96
29000
2440
Notes:
MCL - Federal Maximum Contaminant Level.
SGV - NYSDEC Ambient Water Quality Standards (S) and Guidance (G) Values.
NA - Not applicable/no value available.
-------
TABLE i.
ANALYTE LIST METALS
HITS FOUND IN GROUNDWATER SAMPLES
CARROLL & DUBIES SUPERFUND SITE
PORT JERVIS, NEW YORK
Well Number
Sampling Date:
V1ETALS(ne/L
Aluminum
Antimony
Arsenic
Barium
Beryllium
Cadmium
Chromium
Copper
Iron
Lead
Magnesium
Manganese
Mercury
Selenium
Silver
Sodium
Thallium
Zinc
Cyanide
Federal
MCLs
)
200
6
50
2,000
4
5
1 00
1, 000
NA
NA
NA
50
2
50
1 00
NA
2
NA
200
NYSDEC
SGVs
IOO(S)
3(0)
25 (S)
I,000(S)
3(0)
IO(S)
50 (S)
200 (S)
300 (S)
25 (S)
35,000 (G)
300 (S)
2(S)
IO(S)
50 (S)
20,000 (S)
4(0)
300 (S)
IOO(S)
9/94
6370
40900
4960
25400
OW-2I
4/95
453
30100
4720
24400
7/96
27000
4700
9/94
926
62900
3000
24600
OW-22
"4/95"
142
3.4
58000
2720
23500
7/96
35
52000
2450
42000
9/94
669
15700
2180
44100
OW-23
~4/95
11000
1080
31600
7/96
26300
1830
57000
Notes:
MCL - Federal Maximum Contaminant Level.
SGV - NYSDEC Ambient Water Quality Standards (S) and Guidance (G) Values.
NA - Not applicable/no value avnilnblc.
-------
TABLE i
ANALYTE LIST METALS
HITS FOUND IN GROUNDWATER SAMPLES
CARROLL & DUBIES SUPERFUND SITE
PORT JERVIS, NEW YORK
Well Number
Sampling Dale:
Federal
MCLs
NYSDEC
SGVs
METAI.S(|iu/I.)
Aluminum
Antimony
Arsenic
Barium
Beryllium
Cadmium
Chromium
Copper
Iron
Lead
Magnesium
Manganese
Mercury
Selenium
Silver
Sodium
Thallium
Zinc
Cyanide
200
6
50
2,000
4
5
100
1.000
NA
NA
NA
50
2
50
100
NA
2
NA
200
IOO(S)
3(G)
25 (S)
I.OOO(S)
3(G)
IO(S)
50 (S)
200 (S)
300 (S)
25 (S)
35,000 (G)
300 (S)
2(S)
10(S)
50 (S)
20,000 (S)
4(G)
300 (S)
IOO(S)
IJW
9/9
-------
TABLE L
ANALYTE LIST METALS
HITS FOUND IN GROUNDWATER SAMPLES
CARROLL & DUBIES SUPERFUND SITE
PORT JERVIS, NEW YORK
Well Number
Sampling Dal
Federal
MCLs
NYSDEC
SGVs
VIETAl,SOic/[,)
Aluminum
Antimony
Arsenic
Barium
Beryllium
Cadmium
Chromium
Copper
Iron
Lead
Magnesium
Manganese
Mercury
Selenium
Silver
Sodium
Thallium
Zinc
Cyanide
200
6
50
2,000
4
5
100
1,000
NA
NA
NA
50
2
50
100
NA
2
NA
200
IOO(S)
3(0)
25 (S)
I.OOO(S)
3(0)
IO(S)
50 (S)
200 (S)
300 (S)
25 (S)
35,000 (0)
300 (S)
2(S)
IO(S)
50 (S)
20,000 (S)
4(0)
300 (S)
IOO(S)
BU
9/94
558
4640
3440
22100
/-5
4/95
2100
7830
3390
TW-2
9/94
989
1410
4/95
1890
5190
5
TWO
9/94
123
28600
4/95
554
935
6910
25100
4.7
XW-2
4/95
11900
20300
2610
XW- 14
4/95
18900
36200
2540
4.7
Notes:
MCL - Federal Maximum Contaminant Level.
SGV - NYSDEC Ambient Water Quality Standards (S) and Guidance (G) Values.
NA - Not appliciible/no value available.
-------
TABLE 1
TARGET ANALYTE LIST METALS
FOUND IN GROUNDWATER SAMPLES
CARROLL & DUBIES SUPERFUND SITE
PORT JERVIS, NEW YORK
Well Number
SamplinK Date:
METALSOiC/L
Aluminum
Antimony
Arsenic
Barium
Beryllium
Cadmium
Calcium
Chromium
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Mercury
Nickel
Potassium
Selenium
Silver
Sodium
Thallium
Vanadium
Zinc
MW- 1
07/23/96
)
200 U
60 U
10 U
200 U
5 U
5 U
23000
12 J
50 U
25 U
100 U
3 U
8000
5850
40 U
5000 U
10 U
28000
50 U
20 U
MW-3
07/24/96
200 U
60 U
10 U
200 U
5 U
5 U
19000
10 U
50 U
25 U
300
3 U
5000
4520
40 U
5000 U
10 U
6000
50 U
20 U
MW-4 MW- 10
07/18/96 07/17/96
200 U 200 U
60 U 60 U
10 U 10.7
200 U 200 U
5 U 5 U
5 U 5 U
108000 76000
10 U 10 U
50 U 50 U
25 U 25 U
12500 26600
4.1 3 U
14000 7000
5880 4640
0.2 U 0.2 U
40 U 40 U
6000 5000 U
7 5 U
10 U 10 U
205000 18000
10 U 10 U
50 U 50 U
20 U 20 U
MW-20
07/18/96
200 U
60 U
10 U
200 U
5 U
5 U
112000
18
50 U
25 U
12500
3 U
15000
5890
0.2 U
40 U
6000
6.3
10 U
204000
10 U
50 U
20 U
MW-30
07/24/96
200 U
60 U
10 U
200 U
5 U
5 U
19000
10 J
50 U
25 U
338
3 U
5000
4470
40 U
5000 U
10 U
6000
50 U
20 U
OW-2 .
07/18/96
200 U
60 U
10 U
200 U
5 U
5 U
56000
10 J
50 U
25 U
100 U
3 U
7000
171
0.2 U
40 U
5 U
5 U
10 U
10000
10 U
50 U
20 U
Federal
MCLs
200
6
50
2,000
4
5
NA
100
NA
1,000
NA
NA
NA
50
2
NA
NA
50
100
NA
2
NA
NA
NYSDEC
SGVs
IOO(S)
3(G)
25 (S)
I.OOO(S)
3(G)
10(S)
NA
50 (S)
NA
200 (S)
300 (S)
25 (S)
35,000 (G)
300 (S)
2(S)
NA
NA
10(S)
50 (S)
20,000 (S)
4(G)
NA
300 (S)
Notes:
MCI. - Federul Maximum Contaminant Level.
SOV - NYSD1-C Ambient Water Quality Standards (S) and Guidance (G) Values.
NA - Not applicable/no value available.
U Not detected.
J Value is estimated.
-------
TABLE 1
TARGET ANALYTE LIST METALS
FOUND IN GROUNDWATER SAMPLES
CARROLL & DOBIES SUPERFUND SITE
PORT JERVIS, NEW YORK
Well Number
Sampling Date:
METALS(nc/L
Aluminum
Antimony
Arsenic
Barium
Beryllium
Cadmium
Calcium
Chromium
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Mercury
Nickel
Potassium
Selenium
Silver
Sodium
Thallium
Vanadium
Zinc
MW- 1
07/23/96
)
200 U
60 U
10 U
200 U
5 U
5 U
23000
12 J
50 U
25 U
100 U
3 U
8000
5850
40 U
5000 U
10 U
28000
50 U
20 U
MW-3
07/24/96
200 U
60 U
10 U
200 U
5 U
5 U
19000
10 U
50 U
25 U
300
3 U
5000
4520
40 U
5000 U
10 U
6000
50 U
20 U
MW-4 MW- 10
07/18/96 07/17/96
200 U 200 U
60 U 60 U
10 U 10.7
200 U 200 U
5 U 5 U
5 U 5 U
108000 76000
10 U 10 U
50 U 50 U
25 U 25 U
12500 26600
4.1 3 U
14000 7000
5880 4640
. 0.2 U 0.2 U
40 U 40 U
6000 5000 ' U
7 5 U
10 U 10 U
205000 18000
10 U 10 U
50 U 50 U
20 U 20 U
MW-20
07/18/96
200 U
60 U
' 10 U
200 U
5 U
5 U
1 12000
18
50 U
25 U
12500
3 U
15000
5890
0.2 U
40 U
6000
6.3
10 U
204000
10 U
50 U
20 U
MW-30
07/24/96
200 U
60 U
10 U
200 U
5 U
5 U
19000
10 J
50 U
25 U
338
3 U
5000
4470
40 U
5000 U
10 U
6000
50 U
20 U
OW-2
07/18/96
200 U
60 U
10 U
200 U
5 U
5 U
56000
10 J
50 U
25 U
100 U
3 U
7000
171 '
0.2 U
40 U
5 U
5 U
10 U
1 0000
10 U
50 U
20 U
Federal
MCLs
200
6
50
2,000
4
5
NA
100
NA
1,000
NA
NA
NA
50
2
NA
NA
50
100
NA
2
NA
NA
NYSDEC
SGVs
IOO(S)
3(0)
25 (S)
I,000(S)
3(G)
IO(S)
NA
50 (S)
NA
200 (S)
300 (S)
25 (S)
35,000 (G)
300 (S)
2(S)
NA
NA
10(S)
50 (S)
20,000 (S)
4(G)
NA
300 (S)
Notes:
MCI. - Federal Maximum Contaminant Level.
SGV - NYSDIiC Ambient Water Quality Standards (S) and Guidance ((J) Values.
NA • Not applicable/no value available.
U Not detected.
J Value is estimated.
-------
TABLE i (Continued)
TARGET ANALYTE LIST METALS
FOUND IN GROUNDWATER SAMPLES
CARROLL & DUBIES SUPERFUND SITE
PORT JERVIS, NEW YORK
Well Number
Sampling DaU
OW-5
07/22/96
OW-7
07/22/96
OW- 8 OW- 9
07/1 8/96 07/16/96
OW- 10
07/23/96
OW- 11
07/24/96
OW- 12
07/16/96
Federal
MCLs
NYSDEC
SGVs
METALSOie/L)
Aluminum
Antimony
Arsenic
Barium
Beryllium
Cadmium
Calcium
Chromium
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Mercury
Nickel
Potassium
Selenium
Silver
Sodium
Thallium
Vanadium
Zinc
200 U
60 U
10 U
200 U
5 U
5 U
31000
10 U
50 U
25 U
5710
3' U
5000 U
3440
40 U
5000 U
10 U
75000
50 U
20 U
200 U
60 U
10 U
200 U
5 U
5 U
119000
14
50 U
25 U
100 U
3 U
6000
38
40 U
5000 U
10 U
7000
50 U
20 U
200 U 200 U
60 U 60 U
17.5 10 U
200 U 200 U
5 U 5 U
5 U 5 U
12000 95000
14 70
50 U 50 U
25 U 25 U
9740 53800
3 U 4.6
5000 U 9000
4790 8600
0.2 U 0.2 U
40 U 48
5000 U 5000 U
5 U 5 U
10 U 10 U
13000 11000
10 U 10 U
50 U 50 U
20 U 25
677
60 U
10 U
200 U
5 U
5 U
128000
24
50 U
25 U
41400
3 U
9000
6180
40 U
5000
10 U
12000
50 U
20 U
200 U
60 U
10 U
200 U
5 U
5 U
163000
10 U
50 U
25 U
26800
3 U
9000
5660
40 U
5000 U
10 U
9000
50 U
20 U
200 U
60 U
10 U
200 U
5 U
5 U
134000
29
50 U
25 U
69800
3 U
. 10000
8690
0.2 U
40 U
5000 U
5 U
10 U
17000
10 U
50 U
20 U
200
6
50
2,000
4
5
NA
100
NA
1,000
NA
NA
NA
50
2
NA
NA
50
100
NA
2
NA
NA
IOO(S)
3(0)
25 (S)
1,000(8)
3(0)
IO(S)
NA
50 (S)
NA
200 (S)
300 (S)
25 (S)
35,000 (G)
300 (S)
2(8)
NA
NA
10(8)
50 (S)
20,000 (S)
4(0)
NA
300 (S)
Notes:
MCL • l;ederal Maximum Contaminant Level.
SGV - NYSDliC Ambient Water Quality Standards (S) und Guidance (G) Values.
NA - Not applicable/no value available.
U Not detected.
J Value is estimated.
-------
TABLEi (Continued)
TARGET ANALYTE LIST METALS
FOUND IN GROUNDWATER SAMPLES
CARROLL & DUBIES SUPERFUND SITE
PORT JERVIS, NEW YORK
Well Number
Sampling DaU
OW-5
011221%
OW-7
07/22/96
OW- 8 OW- 9
07/18/96 07/16/96
OW- 10
"07/23/96"""
OW- 11
07/24/96'
OW- 12
"07/16~/96"~~
Federal
MCLs
NYSDEC
SGVs
V1ETALS(uc/U
Aluminum
Antimony
Arsenic
Barium
Beryllium
Cadmium
Calcium
Chromium
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Mercury
Nickel
Potassium
Selenium
Silver
Sodium
Thallium
Vanadium
Zinc
200 U
60 U
10 U
200 U
5 U
5 U
31000
10 U
50 U
25 U
5710
3' U
5000 U
3440
40 U
5000 U
10 U
75000
50 U
20 U
200 U
60 U
10 U
200 U
5 U
5 U
119000
14
50 U
25 U
100 U
3 U
6000
38
40 U
5000 U
10 U
7000
50 U
20 U
200 U 200 U
60 U 60 U
17.5 10 U
200 U 200 U
5 U 5 U
5 U 5 U
12000 95000
14 70
50 U 50 U
25 U 25 U
9740 53800
3 U 4.6
5000 U 9000
4790 8600
0.2 U 0.2 U
40 U 48
5000 U 5000 U
5 U 5 U
10 U 10 U
13000 11000
10 U 10 U
50 U 50 U
20 U 25
677
60 U
10 U
200 U
5 U
5 U
128000
24
50 U
25 U
41400
3 U
9000
6180
40 U
5000
10 U
12000
50 U
20 U
200 U
60 U
10 U
200 U
5 U
5 U
163000
10 U
50 U
25 U
26800
3 U
9000
5660
40 U
5000 U
10 U
9000
50 U
20 U
200 U
60 U
10 U
200 U
5 U
5 U
134000
29
50 U
25 U
69800
3 U
10000
8690
0.2 U
40 U
5000 U
5 U
10 U
17000
10 U
50 U
20 U
200
6
50
2,000
4
5
NA
100
NA
1,000
NA
NA
NA
50
2
NA
NA
50
100
NA
2
NA
NA
100(S)
3(0)
25 (S)
1,000(5)
3(0)
IO(S)
NA
50 (S)
NA
200 (S)
300 (S)
25 (S)
35,000 (G)
300 (S)
2(S)
NA
NA
10(S)
50 (S)
20,000 (S)
4(G)
NA
300 (S)
Notes:
MCI. - Federal Maximum Contaminant Level.
SGV - NYSDI-C Ambient Water Quality Standards (S) and Guidance (G) Values;
NA - Not applicable/no value available.
U Not detected.
J Value is estimated.
-------
TABLE! (Continued)
TARGET ANALYTE LIST METALS
FOUND IN GROUNDWATER SAMPLES
CARROLL & DUBIES SUPERFUND SITE
PORT JERVIS, NEW YORK
Well Number
Sampling Dak
OW-21
07/17/96
OW-22
07/17/96
OW-23
07/24/96
EQBtfl
07/19/96
EB#3
07/24/96
EQB 02 [Federal
07/19/96 iMCLs
NYSDEC
SGVs
METALS (ne/L)
Aluminum
Antimony
Arsenic
Barium
Beryllium
Cadmium
Calcium
Chromium
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Mercury
Nickel
Potassium
Selenium
Silver
Sodium
Thallium
Vanadium
Zinc
200 U
60 U
10 U
200 U
5 U
5 U
78000
10 U
50 U
25 U
27000
3 U
8000
4700
0.2 U
40 U
5000 U
5
10 U
18000
10 U
50 U
20 U
200 U
60 U
35
200 U
5 U
5 U
73000
10 U
50 U
25 U
52000
3 U.
16000
2450
0.2 U
40 U
27000
8
10 U
42000
10 U
50 U
20 U
200 U
60 U
12.3
381
5 U
5 U
155000
10 U
50 U
25 U
26300
3 U
15000
1830
40 U
9000
10 U
57000
50 U
20 U
200 U
60 U
10 U
200 U
5 U
5 U
5000 U
10 U
50 U
25 U
100 U
3 U
5000 U
15 U
0.2 U
. 40 U
5000 U
5 U
10 U
5000 U
10 U
50 U
20 U
200 U
60 U
10 U
200 U
5 U
5 U
5000 U
10 U
50 U
25 U
100 U
3 U
5000 U
15 U
40 U
5000 U
10 U
5000 U
50 U
20 U
200 U
60 U
10 U
200 U
5 B
5 U
5000 U
29
50 U
25 U
130
3 U
5000 U
15 U
0.2 U
40 U
5000 U
5 U
10 U
5000 U
10 U
50 U
20 U
200
6
50
2,000
4
5
NA
100
NA
1,000
NA
NA
NA
50
2
NA
NA
50
100
NA
2
NA
NA
IOO(S)
3(0)
25 (S)
I.OOO(S)
3(0)
10(S)
NA
50 (S)
NA
200 (S)
300 (S)
25 (S)
5,000 (G
300 (S)
2(S)
NA
NA
10(S)
50 (S)
20,000 (S)
4(0)
NA
300 (S)
Notes:
MCL - Federal Maximum Contaminant Level.
SGV - NYSD1-C Ambient Water Quulily Standards (S) and Guidance (G) Values.
NA - Not applicable/no value available.
U Not detected.
J Value is estimated.
-------
TABLE i (Continued)
TARGET ANALYTE LIST METALS
FOUND IN GROUNDWATER SAMPLES
CARROLL & DUBIES SUPERFUND SITE
PORT JERVIS, NEW YORK
Well Number
Sampling Date
OW- 13
07/22/96
OW-I6D
07/22/96
OW-16S OW- 17
07/22/96 07/27/96
OW- 18
07~/24/96
OW- 19
07/24/96
OW-20
07/17/96
Federal
MCLs
NYSDEC
SGVs
VIETALSOie/L)
Aluminum
Antimony
Arsenic
Barium
Beryllium
Cadmium
Calcium
Chromium
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Mercury
Nickel
Potassium
Selenium
Silver
Sodium
Thallium
Vanadium
Zinc
200 U
60 U
10 U
200 U
5 U
5 U
148000
10 U
50 U
25 U
19200
3
10000
7960
40 U
5000 U
10 U
17000
50 U
20 U
200 U
60 U
10 U
200 U
5 U
5 U
18000
10 U
50 U
25 U
978
5.1
5000 U
2640
40 U
5000 U
10 U
7000
50 U
20 U
200 U 200 U
60 U 60 U
10 U 10 U
200 U 200 U
5' U 5 U
5 U 5 U
36000 52000
23 J 10 U
50 U 50 U
25 U 25 U
194 100 U
4.1 3 U
6000 6000
2650 8440
40 U 40 U
5000 U 5000 U
10 U 10 U
31000 15000
50 U 50 U
20 U 20 U
200 .U
60 U
37.7
200 U
5 U
5 U
62000
10 U
50 U
25 U
54000
3 U
8000
1480
40 U
25000
10 U
17000
50 U
20 U
200 U
60 U
43.1
261
5 U
5 U
85000
10 U
50 U
25 U
67200
3 U
12000
5060
40 U
18000
10 U
24000
50 U
20 U
200 U
60 U
10 U
200 U
5 U
5 U
58000
10 U
50 U
25 U
29000
3 U
5000
2440
0.2 U
40 U
5000 U
5 U
10 U
8000
10 U
50 U
20 U
200
6
50
2,000
4
5
NA
100
NA
1,000
NA
NA
NA
50
2
NA
NA
50
100
NA
2
NA
NA
IOO(S)
3(G)
25 (S)
1,000(8)
3(G)
10 (S) •
NA
50 (S)
NA
200 (S)
300 (S)
25 (S)
35,000 (G)
300 (S)
2(S)
NA
NA
10(S)
50 (S)
20,000 (S)
4(G)
NA
300 (S)
Notes:
OW-16S - Represents readings taken at a depth of 26.0
MCL - Federal Maximum Conlaminanl Level.
SGV - NYSDEC Ambient Water Quality Standards (S) and Guidance (G) Values.
NA - Not applicable/no value available.
OW-I6S - Represents readings taken at a depth of 43.5
U Not detected.
J Value is estimated.
-------
TABLE 3.
EXPOSURE POINT CONCENTRATIONS
CROUNDWATER IN OUTWASII.TILL, AND BEDROCK AQUIFERS
CARROLL & DUBIES SUPERFUND SITE
PORT JERVIS, NEW YORK
•" •. % *
'
tfbc^TiMBu^f'^vficcfif
VoUllle Organic empound
Vuiyl Chloride
QJorocUunc
l.2-Dichlorocthcncul)
Chloroform
rrichlon>c(hcnc
JOUCM
rctnchlorocthcnc
Toluene
Chlorobaucnc
:(hy|bcnune
Tool Xylcna
kml-V»UUl«'Oninlc Con
Phenol
,4-D)cUo(i>bcnzcnc
,2-Dichloiobcracne
2-Mclhylphenol
4-Mcthylphcnol
tophorone
Niphllulcnc
2-Mcthybuph!hilcnc
DieUi/lpodultl*
Di-fl-butylpbdultlc
Di-n-octylphuulue •
Mfi*t6M/U '"'.'":•• ' "••• "'''' •' •
Aluminum
Arsenic
lirium
Icryltium
Chrocnium
Copper
Utd
Selenium
Silver
VinAdium
line
-
Numtxr of
S*mi'|tf
i(nr/U
61
61
61
61
61
61
61
61
61
61
61
59
59
59
59
59
59
59
59
59
59
59
10
30
30
30
30
30
30
30
30
30
10
V <
Numtxr «t
Dflfrt*
,
6
1
10
1
4
21
4
5
10
5
1
• .'• ' 1
II
2
2
2
5
1
4
6
24
II
5
30
19
30
23
23
26
25
2
3
27
30
Number «f
Non<)rtf£li
'
55
60
51
60
57
31
57
56
51
56
53
41
57
57
57
54
51
55
53
35
4S
54
0
11
0
7
7
4
5
28
27
3
0
\ > % •*•
iw«i«A
Connnlratlon
- ' -
34
15
110
10 I
14
2.600
100
II
10 )
30 J
62
••
71
2 I
2 J
1 I
4 1
440
21
27
57
10 J
3 I
10.300
29
284
1 B
121
51
19.2
1.5 B
7.9 U
26.7 B
170
/'VVv£
*"^ ff'f » v ' * ,'
* *• >-. J '
, Geometric ',..
% . * < '* *
•• N- - ,
5.7B
5.64
6.4
5.tf
5M
14.7
6.34
5.31
5.74
5.73
6.41
6.15
5.04
5.04
4.91
4.79
5.46
5.57
5.69
4.69
4.57
49
1.180
3.16
69.3
0.145
6.35
5.75
1.64
0574
2.44
5.38
362
* >-;;
•f^njeiF
^Cl'lltfV'
' -i >
1.71
1.61
2.11
1.62
1.71
6.74
2.04
I.I
1.65
1.72
2.12
..
2.04
1.49
1.49
1.54
1.63
I.I
1.41
1.51
224
1.66
1.49
3.60
3.26
2.24
2.07
2.94
3.20
3.21
1.31
1.38
2.09
24J.
-: \ , ; c","'^; ";5 ;
*r 'uJL.siX*
n' • - *\9tVi -"'••
1.167
1.806
2.01]
1.106
1.167
3.355
2.012
1.167
1.167
1.867
2.012
>•
2.015
1.757
.757
.107
.807
.869
.757
.107
.100
.169
.107
2.756
2.565
2.213
2111
2.437
2.565
2.565
1.7449
1.797
2.1 II
2213
.7 »V
1 I-fmll
•,./,;-;'
7.60
7.IJ
10.)
7.03
7.61
207
9.12
7.39
7.34
7.55
104
9.5«
5.9S
5.91
6.07
6.05
7.5
6.5J
7.03
1.13
5.17
5.15
5.170
11.2
134
0.25
11.5
19.7
5.64
0.65
215
9.41
71.1 .
C;|;;.£<>:^
cV'Hn* pZT'' •
* j.\ *\ ..'i"1
1 * ConcepitratloB
> *»' ', ," s " '' ' '
1.60
7.1)
10.1
' 7.03
7.6J
207
912
7.39
7.J4
7.55
10.4
•••. ' , ' ' - '•• •• •*
9.5«
2.00
100
1.00
4.00
7.5
6.51
7.03
(.13
5.17
300
' .* ' » 7 s-
5.170
11.2
134
0.25
11.5
19.7
5.64
0.65
2.15
9.41
78.4
NaU*.
On* M/ihJ &MXOO+ Iwu uMd in «jiiiua.
otcrf
-------
TABLES-
POTENTIAL EXPOSURE PATHWAYS FOR
CURRENT AND FUTURE LAND USE SCENARIOS
CARROLL & DUBIES SUPERFUND SITE
PORT JERVIS, NEW YORK
Exposure;;
Selling -
Current
Future
. •:::^mm •&:{'•• ;-x ••••" ^^!5«"W^ .%®%wmti$$®$$!$
='• ReceptorM;i ;;}¥i^''.:- ^ >:WMedlavi:l- ^MedlumV$$^.
Off-sile Residential Groundwatcr User Groundwatcr Groundwater
S'hower Air
Off-sile Recreational User of Gold Creek Groundwaler Surface Water
On-iile Industrial Worker Groundwater Groundwater
Shower Air
On-sile Residential Groundwaler User Groundwiter Groundwater
Shower Air
Off-silt Residential Groundwtter Us«r Groundwater Groundwatcr
Shower Air
Off-site Recreational User of Gold Creek Groundwater Surface Water
ty!&fKW*^-f$t&?XfX:**f^-8-?'*iy>**i'?fl
:Ss\«;>*rasw;Mis':s-.''K**s;y«Jsi><'^:K'.»;».*''»'
%&$?&^y$^m$&&&&i%^*&
;;&*fo
Ingestion
Dermal ConUct
Inhalation While Showering
Ingestion
Dermal ConUct
Ingestion
Dermal ConUct
Inhalation While Showering
Ingeslion
Dermal ConUct
Inhalation While Showering
Ingeslion
Dermal ConUct
Inhalation While Showering
Ingeslion
Dermal Contact
jRtitiined For
;•:.•:••>::;:«•;;> *\ <<•'•**• ',-•••'• '•»;-•
lEjiitot^i
SYY'ea/Nblill
No
No
No
No
No
Yes
No
No
No
No
No
No
No
No
No
No
[^w^^-y^^^^^^K^^'r
W&S^^^^1^'^^^^.:^
RjitioQilc For Elimination
Incomplete exposure pathways.
Groundwater plume hu not reached
dosmestic wells.
Incomplete exposure pathways.
Groundwatcr plume bu not reached
turUce water.
Dermal conUct and inhalation of
volatile* during showering seems
unlikely at th« site.
Implausible scenario.
Site is expected to remain industrial
in the future.
Incomplete exposure pathways.
Groundwater plume is not expected
to migrate to ofiEiite domestic wells.
Incomplete exposure pathways.
Groundwatcr plume is not expected
to migrate to surface water.
-------
TABLE 4
CANCER SLOPE FACTORS AND REFERENCE DOSES
FOR CHEMICALS-OF-CONCERN
CARROLL &DUBIES STJPERFUND SITE
PORT JERVIS, NEW YORK
Clieniic*tof-Con«rn";'''-' -,•.:,•-',?
Volatile Organic CoupovuH
Vinyl Chloride
Chloroethane
1,2-Dichloroethene
Chloroform
Trichloroethene
Benzene
TetrachlorDethene
Toluene
Chlorobenzene
ithylbenzene
Total Xvlenes
SemJ-Vbla tiles Organic Compounds
Phenol
1 ,2-DichJorobenzene
1 ,4-Dichlorobenzene
2-Methylphenol
4-MethyIphenol
[sophorone
Naphthalene
2-Methylnaphthalene
Di-n-butylphthalate
Diethylphthalate
Di-n-ocrylphthalate
Meisili" ' * -"
Aluminum
Arsenic
Barium
Beryllium
Chromium (1)
Copper
Lead
Selenium
Silver
Vanadium
Zinc
; {m^/Ke/dmyy
^-y^-.'.X'^'-
—
0.4 N
0.009 H
0.01 I
0.006 N
—
0.01
0.2
0.02
0.1
2
, , .<< , " .,
0.6
0.09
—
0.05 i
0.005 H
0.2 I
0.04 N
-
0.1 i
O.S i
0.02 H
.' >
1 N
0.0003 i
0.07 i
0.005 i
0.005 i
0.037 H
—
0.005 i
0.005 i
0.007 H
0.3 i
'mt^Q^dayi-i
".j-Jl'VrV ~"&
1.9 H
0.0029 N
-
0.0061 i
0.011 N
0.029 i
0.052 M
—
—
-
-
,*% " > „ s "^
—
-
0.024 H
-
-
0.00095 i
-
-
-
-
—
~ - , '
—
1.5 i
-
4.3 I
-
-
—
-
—
—
-
:,Evidence>
'£?$,'?• ;• '''>
;•,-•.'' '' x -"
A
C-B2
~
B2
C-B2
A
C-B2
D
D
D
D
t~< ' '*.' t >
D
D
C
C
C
C
D
—
D
D
—
_
A
—
B2
A
D
B2
D
D
—
D
Notes:
— Indicates that no criteria is available.
I - Integrated Risk Information System (IRIS), January 1996.
H -Health Effects Assessment Summary Tables (HEAST), FY-1995. Annual and Supplement No. 1.
N - National Center for Environmental Assessment (NCEA).
(1)- Values presented are for Chromium VI.
-------
TABLE £
SUMMARY OF CANCER RISKS AND HAZARD INDICES FOR
INDUSTRIAL WORKERS EXPOSED TO
GROUNDWATER FROM OUTWASH , TELL, AND BEDROCK AQUIFERS
CARROLL & DUBIES SUPERFUND SITE
PORT JERVIS, NEW YORK
" " - "<•><•<
vocj* ~< *
Vinyl Chloride
Chloroethane
1 ,2-Dichloroethene(total)
Chloroform
Trichloroethene
benzene
Tetrachloroethene
Toluene
Chlorobenzene
Ethylbenzene
Total Xvlenes'
Total VOCs
Semi^VOCs - '--'•'•' -
Phenol
1 ,2-D ichlorobenzene
[ ,4-D ichlorobenzene
2-Methylphenol
4-Methylphenol
isophorone
SFaphthalene
2-Methylnaphthalene
Di-n-butylphthalate
Diethylphthalate
Di-n-octylphthalate
Total Semi-VOCs __,
WetaJiv<-:.V.i:'--:;U •' '•••- \w-r#vr ':-• •
Aluminum
Arsenic
Barium
Beryllium
Chromium
Copper
Lead
Selenium
Silver
Vanadium
Zinc
Total Metals
TOTAL
* V ^f
•, s *""
Cinctr Rbk
' «
5.0E-05
7.2E-08
NA
1.5E-07
3.0E-07
2.1E-05
1.8E-06
NA
NA
NA
NA
7.4E-05
•v;.;-:.::.-:,:.;.'::.;:' : •
NA
NA
1.7E-07
NA
NA
2.5E-08
NA
NA
NA
NA
NA
1.9E-07
NA
5.9E-05
NA
3.8E-06
NA
NA
NA
NA
NA
NA
NA
6.2E-05
1.4E-04
^ v
^Percent **-.,'
<• f V
" - Cin.ctr Rbk1
^ - > -
37.00%
0.05%
NA
0.11%
0.22%
15.38%
1.31%
NA
NA
NA
NA
54.06%
^ -.
NA
NA
0.12%
NA
NA
0.02%
NA
NA
NA
NA
NA
0.14%
•'•'•. •.<' .'••<•••••'.• '••• ':•• ••••••••
NA
43.04%
NA
2.75%
NA
NA
NA
NA
NA
NA
NA
45.80%
100%
ft ^
" \ *•
•>•> Chronic > -
-------
u
u
a.
5
01
o
TABLE 6
CAPITAL AND O&M COST ESTIMATE FOR ALTERNATIVE 2
INTRINSIC BIODEGRADATION WITH INSTITUTIONAL CONTROLS
Task
"_"" | (. <&aijtily_J.'. .V.'}!!l."L' UnU c<>sl I'TiMal Cost") [ " _"" Notes' I1....!.I..
I . Initial Latiorrilory Study,
Sample Collection
Study
Subtotal
I. Legal Costilor. Land- anil '.'.• '••;;::
aod («'rounilwi(cr-llsc Ucstrictionis; V."
5|>eijaj nn.< beyond Uiosc mxcssary for OU I
Suhunal - One-Time Expenditure |_^ $75,(XX)|
3: Knyifoririicntal SArtipling "''•> '•
'iroundwnier San>pling and AJialysis
Subiobil
Animal .Summary reports
« Subtotal
28_ I \vclls__ $1.000 J $28.000
$28.000
LS I $30.000 I S30.UOO
_S30,000
Organic :uia[y_sis of 2 upRrad'cnt and 12 Jtmtigradiem wells
Annual cost Tor unnual reporting to suntrnaiize above analyticnl
Subtotal (Annuiil O&M)
Total Net Presmit Value (@ 12% ROR)
S58,(XX)
S2&4.077
O1
o
(L
-------
APPENDIX III
ADMINISTRATIVE RECORD INDEX
32
-------
CARROLL AND DUBIES
OPERABLE UNIT TWO
ADMINISTRATIVE RECORD FILE
INDEX OF DOCUMENTS
3.0 REMEDIAL INVESTIGATION
3.4 Remedial Investigation Reports
P. 300001 - Report: Addendum to Supplemental Hydrogeologic
300245 Remedial Investigation; Results of Field
Investigation/ at the Carroll and Dubies Site,
During April/ 1995, prepared by Remediation
Technologies, Inc., prepared for Mr. Jonathan A.
Murphy, Lester, Schwab, Katz, Dwyer, and Mr.
Robert J. Glasser, Gould and Wilkie, August 4,
1995, revised November 1, 1995.
P. 300246 - Report: Supplemental Hydrogeologic Remedial
300579 Investigation, Carroll and Dubies Superfund Site,
Port Jervis, New York, prepared by Remediation
Technologies, Inc., prepared for Mr. Jonathan A.
Murphy, Lester, Schwab, Katz, Dwyer, and Mr.
Robert J. Glasser, Gould and Wilkie; April 7,
1995.
P. 300580 - Report: Exposure Pathway Analysis Report, Carroll
300604 and Dubies Site, Port Jervis, New York, prepared
by Remediation Technologies, Inc., prepared for
Mr. Jonathan A. Murphy, Lester, Schwab, Katz,
Dwyer, and Mr. Robert J. Glasser, Gould and
Wilkie; March 3, 1995.
4.0 FEASIBILITY STUDY
4.2 Feasibility Study Work Plans
P. 400001 - Letter to Ms. Sharon Trocher, U.S. EPA, Region II,
400090 from Mr. Robert Block, Principal, RETEC, and Mr.
David Morgan, Associate, RETEC, re: Revisions to
Groundwater Modeling Workplan, October 9, 1995.
(Attached: 1. "Response to Comments from EPA
Dated September 18, 1995," September 18, 1995. 2.
"Response to Comments from EPA Dated October 2,
1995," October 2, 1995. 3. Plan: Groundwater
Modeling Workplan, Carroll and Dubies Superfund
Site, undated.)
-------
4.3 Feasibility Study Reports
P. 400091 - Report: Groundwater Modeling Report, Carroll and
400349 Dubies Superfund Site, Port Jervis, New York,
prepared by Remediation Technologies, Inc.,
prepared for Mr. Jonathan A. Murphy, Lester,
Schwab, Katz, Dwyer, and Mr. Robert J. Glassner,
Gould and Wilkie, January 1996.
P. 400350 - Report: Feasibility Study for the Groundwater
400507 Operable Unit, Carroll and Dubies Site, prepared
by Remediation Technologies, Inc., prepared for
Mr. Jonathan A. Murphy, Lester, Schwab, Katz,
Dwyer, and Mr. Robert J. Glassner, Gould and
Wilkie, May 1996.
7.0 ENFORCEMENT
7.2 Endangerment Assessments
p. 700001 - Report: Baseline Risk Assessment, Carroll and
700534 Dubies Superfund Site, Port Jervis, New York,
prepared by Remediation Technologies, Inc.,
prepared for Mr. Jonathan A. Murphy, Lester,
Schwab, Katz, Dwyer, and Mr. Robert J. Glassner,
Gould and Wilkie, April 3, 1996.
7.8 Correspondence
P. 700535 - Letter to Ms. Sharon Trocher, U.S. EPA, Region
700838 II, from Jonathan A. Murphy, Esq., Lester, Schwab,
Katz & Dwyer, re: New York (Carroll & Dubies) v.
Kolmar Laboratories, Inc., November 9, 1995.
(Attached: 1. Zoning Map; 2. Report: Zoning
Laws, prepared by Town o'f Deerpark, New York,
adopted January 8, 1990, amended September 17,
1990, December 7, 1992, August 2, 1993, and
October 4, 1993; 3. Plan: Master Plan (Or
Comprehensive Development Plan), Town of Deerpark,
Orange County, New York, June, 1989, prepared by
Garling Associates, Consulting Planners, prepared
for the Town of Deerpark, Orange County, New York,
adopted by the Town Board, September 11, 1989; 4.
-------
Report: Subdivision Regulations of the Town of
Deerpark, County of Grange/ State of New York,
prepared by Ms, Shirley Zeller/ Town Clerk, Town
of Deerpark, Orange County, adopted by the Town of
Deerpark, Town Board, December 20, 1993.
10.0 PUBLIC PARTICIPATION
10.9 Proposed Plan
P. 10.00001- Plan: Superfund Proposed Plan, Carroll and
10.00020 Dubies Sewage Disposal Inc., Town of Deerpark,
Orange County, New York, prepared by U.S. EPA,
Region II, August 28,1996.
-------
CARROLL & DUBIES SEWAGE DISPOSAL SITE
OPERABLE UNIT TWO
ADMINISTRATIVE RECOFD FILE UPDATE
INDEX OF DOCUMENTS
3.0 REMEDIAL INVESTIGATION
3.1 Sampling and Analysis Plans
P. 300605- Report: Summary of Laboratory Data Sampling
300610 Event, Carroll & Dubies Sewage Disposal Site, Port
Jervis. New York. July 15-26. 1996.
5.0 RECORD OF DECISION
5.1 Record of Decision
P. 500001- Record of Decision - Carroll & Dubies Sewage
500250 Disposal, Inc., Superfund Site, Town of Deerpark,
Orange County, New York, September 30, 1996.
6.0 STATE COORDINATION
6.3 Correspondence
P. 600001- Letter to Mr. Richard Caspe, Director, Emergency &
600001 Remedial Response Division, U.S. EPA, Region II,
to Mr. Michael J. O'Toole, Jr., Director, Division
of Environmental Remediation, N.Y.S. Department of
Environmental Conservation, re: Carroll & Dubies
OU2 Proposed Remedial Action Plan, August 22,
1996.
10.0 PUBLIC PARTICIPATION
10.2 Community Relations Plan
P. 10.00021- List of interested parties, Carroll & Dubies
10.00032 Sewage Disposal Superfund Site, Port Jervis, New
York. (Note: This document is CONFIDENTIAL. It
-------
can be located at the. Superfund Records Center,
290 Broadway, 18th floor, New York, New York,
10007-1866.)
10.3 Public Notices
P. 10.00033- Public Notice: "The U.S. Environmental Protection
10.00033 Agency (EPA) Invites Public Comment on its
Proposed Plan for remediating contaminated
groundwater at the Carroll & Dubies Sewage
Disposal Superfund Site, Port Jervis, New York,"
prepared by U.S. EPA, Region II.
Note: The documents listed on the attached index for the Carroll
& Dubies Sewage Disposal Site Administrative Record file for
Operable Unit 1 (OU1) are hereby incorporated into this
Administrative Record file Operable Unit 2 (OU2) by reference.
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CARROLL S DUBIES SITE
OPERABLE UNIT ONE
ADMINISTRATIVE RECORD PILE
INDEX OP 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 Site,
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. Citv of Port Jervis. Orange
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 Study. 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 & Bouck
Engineers, P.C., November 1990.
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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 Troch.er, 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. Slurrv Treatment for Lacroon 7 Soil.
undated; 2. Table 2-1B, 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.
Oranae Countv, New York, prepared by U.S. EPA -
Region II, August 1994.
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P. 301366 - Letter to Ms. Sharon Trocher, Eastern New
301368 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: response to the January 5,
1993 letter from Doug Garbarini and subsequent
telephone conversations which have modified some
of the items addressed in~;that particular letter,
January 8, 1993.
P. 301369 - Letter to Mr. Tyler E. Gass, C.P.G., Vice
301372 President, Blasland- & Bouck Engineers, P.Cv, frcm-
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 Hap and Proposed
Sampling Locations, prepared by Blasland & 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.1 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 16> 1992. (Attached:.. Figure. 1,
New Potential Source Area. Site Map and Proposed
Sampling Locations, prepared.by Blasland & Bouck
Engineers, P.C., October 19, 1992.)
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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: 1.
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).)
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 locationsf
prepared by Blasland & Bouck, Engineers, P.C.,
October 6, 1992.)
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.
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, re: 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.
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P. 301404 - Letter to Ms. Sharon Trocher, Eastern New
301408 York/Caribbean Remedial Action Branch, Region II,
U.S. EPA, from Mr. Tyler E. Gass, c.P.G., Vice
President, Blasland & Bouck Engineers, P.O., 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., Kinston & Strawn,
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, Bias-land & 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.
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P. 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.
P. 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.
P. 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 Studv 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 Usina 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 Alternative 2. 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
& Dubies 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.G., 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 (mq/kg or ppm.) for Heavy
Metals, (undated); 3. Conventional. Sediment
Variables. Total Organic Carbon (TOO. March
1986.)
8
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P. 400467 -
400468
Letter to Mr. Tyler E. Gass, C.P.G., Vice
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 & Dubies 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: 1. Figure 1, Map:
Site Location Man. 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
700032
700033
700037
Notice letter to Honorable R. Michael Worden,
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.
Notice letter to Messrs Joseph Carroll and Gustave
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 #1. EPA to Conduct Investigation of
Carroll and Dubies Site. May 1991.
10.10 Correspondence (FOZA)
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: jresponse to
Ms. Hodson1s September 23, 1992 letter requesting
an update on the Carroll and Dubies Superfur.d
Site, November 16, 1992. (Attached: 1. Update
for the Carroll and Dubies Suoerfund Sire,
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 FILE
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 DDBIES SITE
OPERABLE UNIT ONE UPDATE
ADMINISTRATIVE RECORD FILE
INDEX OP DOCUMENTS
4.0 FEASIBILITY STUDY
4.2 Feasibility Study Work Plans
P. 400475 - Plan: Vapor Extraction and Bioslurrv 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 - Letter to Ms. Sharon Trocher, Carroll and Dubies
400513 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 Treatabilitv
Study, Carroll and Dubies Superfund Site, Final
Report (October 10, 1994.1. November 8, 1994.
P. 400514 - Report: Cost Estimates for Modified Remedial
400539 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.
P. 400540 - Report: Technology Evaluation Laboratory
400675 Treatabilitv Studv, 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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CARROLL & DUBIES SEWAGE DISPOSAL SITE
OPERABLE UNIT ONE
ADMINISTRATIVE RECOPD FILE UPDATE
INDEX OP DOCUMENTS
7.0 ENFORCEMENT
7.3 Administrative Orders
P. 700038- Letter to Mr. Brian D. Bertonneau, Reynolds Metals
7'00067 Company, from Ms. Sharon E. Kivowitz, Assistant
Regional Counsel, Office of Regional Counsel, U.S.
EPA, Region II, re: attached Administrative Order
on Consent, II-CERCLA-95-0217, in the Matter of
the Carroll & Dubies Superfund Site, Reynolds
Metals Company, Respondent, July 18, 1996.
P. 700068- Administrative Order for Remedial Design and
700111 Remedial Action, U.S. EPA Index No. II-CERCLA-95-
0221, in the Matter of the Carroll & Dubies
Superfund Site, September 29, 1995.
P. 700112- Administrative Order on Consent, II-CERCLA-95-
700131 0217, in the Matter of the Carroll & Dubies
Superfund Site, Reynolds Metals Company,
Respondent, September 27, 1995.
7.8 Correspondence
P. 700132- Letter to Mr. Brian D. Bertonneau, Reynolds Metals
700132 Company, from Ms. Sharon E. Kivowitz, Assistant
Regional Counsel, Office of Regional Counsel, U.S.
EPA, Region II, re: Carroll & Dubies Superfund
Site, Administrative Order on Consent, II-CERCLA-
95-0217, July 18, 1996.
;
P. 700133- . Letter to Mr. Robert J. Glasser, Gould &
700135 Wilkie, and Mr. Jonathan Murphy, Lester,
Schwab, Katz, & Dwyer, from Ms. Sharon E.
Kivowitz, Assistant Regional Counsel, Office of
Regional Counsel, U.S. EPA, Region II, re: Carroll
& Dubies Superfund Site Response to Comments on
Administrative Order on Consent II-CERCLA-95-0217,
July 16, 1996.
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P. 700136- Letter to Ms. Sharon E. Kivowitz, Esq., Assistant
700140 Regional Counsel, U.S. EPA, Region II, from Mr.
Robert J. Glasser, Gould & Wilkie and Mr.
Jonathan Murphy, Lester Schwab Katz & Dwyer,
re: Carroll & Dubies Superfund Site; U.S. EPA
Index No. II-CERCLA-95-0221, March 19, 1996.
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APPENDIX IV
STATE LETTER OF CONCURRENCE
33
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New York State Department of Environmental Conservation
50 Wolf Road, Albany, New York 12233
-__ ^ Michael D. Zagata
SEP 30 1998 Commissioner
Mr. Richard Caspc
Director
Emergency & Remedial Response Division
U.S. Environmental Protection Agency
Region II
290 Broadway
New York, NY 10007-1866
Dear Mr. Caspe:
Re: Carroll & Dubics, OU2, ID No. 3360)5
Record of Decision (ROD)
The New York State Department of Environmental Conservation has reviewed the ROD for the
above-referenced site anil finds il acceptable. It is understood to include the following provisions:
I. Natural attenuation of the groundwaler to below NYS groundwater standards for organics.
2. Institutional controls restricting the use of groundwater in the area of the groundwater plume.
3- Monitoring of the groundwater to ensure improvement in gronndwatcr quality.
4. Sediment sampling lo ensure contaminants do not reach Gold Creek.
Please contact Sal Ervolina at (518) 457-7924 if you have any questions.
Michael X/OToole, Jr.
Director
Division of Environmental Remediation
cc: D. Gtirbarini/M. Jon, USEPA-Rcgion II
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APPENDIX V
RESPONSIVENESS SUMMARY
CARROLL AND DUBIES SEWAGE DISPOSAL, INC.,
SUPERFUND SITE
GROUNDWATER OPERABLE UNIT
INTRODUCTION
A responsiveness summary is required by the National Contingency
Plan (NCP) at 40 CFR §300.430(f)(3)(F). It provides a summary of
citizens' 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 the
selected remedy for the Carroll and Dubies Sewage Disposal site
groundwater operable unit (OU2).
SUMMARY OF COMMUNITY RELATIONS ACTIVITIES
Community involvement at the Site has been relatively strong.
EPA has served as the lead Agency for community relations and
remedial activities at the Site.
The Proposed Plan for the groundwater contamination beneath and
downgradient of the Carroll and Dubies Site was released to the
public for comment on August 28, 1996. This document, together
with the Remedial Investigation report, the Baseline Risk
Assessment and other reports, were made available to the public
in the Administrative Record file at the EPA Docket Room in
Region II, New York, and in the information repository at the
Deerpark Town Hall, Drawer A, Huguenot, New York and the Port
Jervis Public Library, 138 Pike Street, Port Jervis, New York.
The notice of availability for the above referenced documents was
published in the Times Herald Record on September 10, 1996. A
similar notice was sent to the site mailing list on August 28,
1996. The public comment period on these documents was open from
August 28, 1996 to September 27, 1996.
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On September 11, 1996, EPA conducted a public meeting at the Port
Jervis High School, Port Jervis, New York to discuss the Proposed
Plan for Operable Unit Two and to provide an opportunity for the
interested parties to present oral comments and questions to EPA.
Attached to the Responsiveness Summary are the following
Appendices:
Appendix A - Proposed Plan
Appendix B - Public Notice
Appendix C - September 11, 1996 Public Meeting Attendance
Sheets
Appendix D - September 11, 1996 Public Meeting Transcript
Appendix E - Letters Submitted During the Public Comment
Period
SUMMARY OF COMMENTS AND RESPONSES
Comments expressed at the September 11, 1996 public meeting and
written comments received during the public comment period have
been categorized as follows:
A. Operable Unit Two (OU-2) Remedy Selection Issues
B. Operable Unit One (OU -1) Remedy
C. Extent of Groundwater Contamination
D. Residential Wells
E. Risk and Health Assessment
F. Other/miscellaneous
A summary of the comments and EPA's responses to the comments is
provided below.
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A. Operable Unit Two Remedy Selection Issues
Comment #1: Some commenters inquired about the use of natural
attenuation for the remediation of contaminated groundwater at
other Superfund sites and whether there are any documented
successes.
EPA'a Response:
Within the Superfund program, natural attenuation has been
selected as the remedy to address groundwater contamination at 73
sites. Some of these sites include municipal and industrial
landfills, refineries, and recyclers. Natural attenuation is
also being used to remediate many petroleum-contaminated
underground storage tank sites across the country.
At the Allied Signal Brake Systems Superfund site in St. Joseph,
Michigan, microorganism are effectively removing TCE and other
chlorinated solvents from groundwater. Scientists studied the
underground movement of TCE-contaminated groundwater from its
origin at the Superfund site to where it entered Lake Michigan
about half a mile away. At the site itself, they measured TCE
concentrations greater than 200,000 parts per billion (ppb), but
by the time the plume reached the shore of Lake Michigan, the TCE
was one thousand times less-only 200 ppb. About 300 feet
offshore in Lake Michigan concentrations were below EPA's
allowable levels. In fact, microorganisms were destroying about
600 pounds of TCE a year at no cost to taxpayers. EPA determined
that nature adequately remediated the TCE plume in St. Joseph
while avoiding significant costs which might have been spent on
conventional treatment without additional significant human
health or environmental benefit.
Comment #2: One commenter was concerned that the time frames to
implement Alternatives 3 (Groundwater Pump and Treat) and 4 (In
situ Groundwater Treatment) were shorter periods than the
estimated time frame for the groundwater to reach drinking water
standards through natural attenuation.
EPA's Response:
The time frame to implement a remedial alternative as provided in
the Proposed Plan, reflects only the time needed to construct the
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components of the remedial system. This time frame excludes the
time required for the design of the remedy, negotiations with the
responsible parties, or award of contracts, and the time needed
to operate the remedial system to achieve the remedial goals. The
estimated time frames to implement Alternatives 3 and 4 are 9
months and 12 months, respectively.
The estimated time frame for the contaminants in the groundwater
to meet drinking water standards is approximately five years
after implementation of the lagoon remedy is completed. This
time was estimated through a groundwater modeling study. In
order to restore the aquifer to drinking water standards, the
lagoons, which are the sources of groundwater contaminants at the
Site, would have to be removed. Therefore, all the alternatives
that were considered to address the contaminated groundwater
beneath the Site rely on the implementation of the lagoon remedy
before contaminant levels in the groundwater could reach drinking
water standards. For all of the alternatives that were
evaluated, the concentrations of organic contaminants in the
groundwater are expected to meet drinking water standards
approximately five years after implementation of the lagoon
remedy. Therefore, all the alternatives are relatively similar
in terms of the time frame to achieve drinking water standards.
Comment #3: One commenter inquired about the timetable for
implementation of Operable Units 1 and 2 remedies.
EPA's Response:
Operable unit one is currently in the remedial design phase.
Excavation and treatment of the wastes have not yet begun.
Construction of the remedy is expected to begin in 1998, and it
is anticipated that it would take another year to cleanup the
sludges and soils in and around the lagoons utilizing ex-situ
vapor extraction, bioslurry, and solidification/stabilization.
After the ROD for OU2 is signed, EPA will send out special notice
letters to the PRPs (with the exception of Reynolds, which is
considered a de-minimis PRP) 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
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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 remedy
would be initiated shortly after the conclusion of negotiations.
The period from signing the ROD to completing the remedial
design, which would entail development of a monitoring plan and
selecting the appropriate institutional control(s) to be
implemented, would be less than one year.
Comment #4: One commenter expressed concern about the ability of
the preferred remedy (natural attenuation with institutional
controls and monitoring) to meet drinking water standards at the
Site. Another commenter asked whether the groundwater modeling
conducted at the Site is reliable to estimate concentration
patterns in the groundwater.
EPA'8 Response:
As part of the remedial investigation, limited data was collected
to evaluate the extent of biodegradation at the Site. This
limited evaluation included the collection of data on dissolved
oxygen levels and the presence of microorganisms in the
groundwater capable of degrading volatile organic compounds under
expected Site conditions. The dissolved oxygen levels in the
benzene plume indicated the potential for biodegradation to be
occurring. The degrading microorganisms population was in the
range of 105 to 10s, indicating the presence of a healthy and
robust community of degraders present in the aquifer.
Groundwater modeling was conducted at the Site to determine
whether the organic contaminant patterns found in the groundwater
beneath the Site have stabilized due to intrinsic biodegradation
and to estimate future concentrations of contaminants at
potential off-site locations. The results of the groundwater
modeling indicate that the organic contaminants in the
groundwater are not migrating to Gold Creek and residences south
of Gold Creek, and that the concentration patterns observed at
the Site .have stabilized or are not expected to change in the
future.
Therefore, groundwater data combined with the limited
biodegradation field data and with the groundwater modeling
projections demonstrate the potential for biodegradation of
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organic contaminants at the Site.
Both the potential for biodegradation and the groundwater
modeling studies conducted at the Site were evaluated by
scientists and experts in the field of computer modeling and
biodegradation at EPA's Office of Research and Development in
Ada, Oklahoma. Based on their review and approval of the
modeling efforts, and the fact that monitoring will be conducted
to verify the modeling predictions, EPA is confident that the
selected remedy will be protective of human health and the
environment. If the monitoring indicates that the model
predictions are not reasonable accurate, EPA will evaluate the
need to modify the remedy.
Comment #5: One commenter suggested that the No Action remedy,
with no cost, should be selected for the groundwater operable
unit, since the wastes were placed in the lagoons 17 years ago
and the most downgradient monitoring wells have not detected any
levels of concern in the groundwater. The commenter suggested
that selection of Alternative 2 would be a waste of $284,000.
EPA's Response:
EPA evaluates the remedial alternatives against nine criteria,
only one of which is cost. Based on a detailed evaluation, EPA
selects a remedy based on all nine criteria, which are:
1)Overall protection of human health and the environment,
2)Compliance with Applicable or Relevant and Appropriate
Requirements, 3)Long-term effectiveness and permanence,
4)Reduction of toxicity, mobility, or volume through treatment
5)Short-term effectiveness, 6) Implementability, 7)Cost, 8) State
acceptance, and 9) Community acceptance.
Alternative 2 includes groundwater monitoring to evaluate the
rate of reduction of contaminants in the groundwater,
institutional controls to prevent the future use of the
contaminated groundwater, and sediment sampling in Gold Creek to
ensure that Site-related contaminants do not impact Gold Creek.
These measures are necessary to ensure that the remedy is
protective of the public and the environment. A detailed cost
estimate of Alternative 2 is presented in Table 6 of the Record
of Decision. Although $284,000 is a significant amount of money,
it is a reasonable amount to fulfill EPA's responsibility to
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ensure that the remedy continues to be protective of human health
and the environment, while alleviating community concerns about
the effectiveness of the remedy to protect the drinking water.
Some commenters indicated that they wanted additional monitoring
due to concerns about their drinking water wells. Please see
comment number 9.
B. Operable Unit One (OU-1) Remedy
Comment #6: One commenter inquired about the treatment
technologies that will be used to treat the organic and inorganic
contaminants in the lagoons and what type of materials would be
used to stabilize the inorganic contaminants. Another commenter
inquired if any excavation and treatment of the wastes had begun.
EPA's Response:
In March 1995, EPA signed a Record of Decision for the lagoons.
The remedy requires the excavation of approximately 20,000 cubic
yards of contaminated material from the lagoons and soils in the
vicinity of the lagoons.. Materials exceeding treatment levels
will undergo stabilization via solidification/stabilization (for
inorganic contaminants) and bioslurry (for organic contaminants)
or a combination of the two treatment processes. All materials
will be placed on-site in a lined and capped cell with leachate
collection.
Solidification/stabilization has been effectively used at several
Superfund sites to bind inorganic contaminants into an inert,
nonleaching mass that can be disposed of as a nonhazardous waste.
Different stabilization agents, such as cement-based, pozzolaic-
based, asphalt-based, and organic-polymer-based, are commercially
available. The specific stabilizing agent or agents that will be
used at the Carroll and Dubies site have not been selected at
this time, they will be selected during the remedial action phase
of the remedy.
Bioslurry has also been used effectively at Superfund sites to
treat organic contaminants, specifically semi-volatile organic
compounds. In bioslurry treatment, the contaminated soil/sludges
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. Microorganisms digest organic
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substances for nutrients and energy thereby breaking down
hazardous substances into less toxic or nontoxic substances.
Residual contaminants in the treated soil and sludge will be
contained in the capped cell to provide an extra margin of safety
against the continued migration of contaminants in the soil to
the groundwater.
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 Resource Conservation and Recovery Act
(RCRA) permitted hazardous waste 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 Land Disposal
Restriction (LDR) levels.
This operable unit is currently in the remedial design phase.
Excavation and treatment of the wastes have not yet begun.
Excavation and treatment of the lagoons is expected to begin in
1998.
Comment #7: One commenter inquired about the design of the
containment cell and cover for the treated materials from the
lagoons.
EPA'a Response:
The treated and untreated soils/sludges will be placed in a lined
and capped cell consistent with modified requirements of New York
Code of Rules and Regulations Part 360 (NYCRR Part 360 Solid
Waste Management Facilities regulations). The regulations
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require that the base and cover of the disposal facility meet the
minimum permeability requirements. Although the final design of
the cover has not been completed, it is envisioned that the base
of the cell will consist of a high density polyethylene (HOPE)
liner and a sand drainage layer; that the cell will be sloped to
a leachate collection system; and that the cover will consist of
a low-permeability clay layer, an HDPE membrane, a sand drainage
layer and a topsoil layer.
C. Extent of Groundwater Contamination
Comment #8: One commenter inquired when the most recent sampling
of the furthest downgradient wells was conducted. Another
commenter inquired about the concentrations of organic
contaminants in these wells and their corresponding drinking
water standards.
EPA's Response:
Groundwater samples were collected from these downgradient wells
in September 1994 and April 1995 and analyzed for both organic
and inorganic compounds. In July 1996, groundwater samples were
also collected from these wells and analyzed for inorganic
compounds only.
Groundwater data collected in the 1995 sampling event, in the
vicinity of lagoons 7 and 8, indicates that benzene is the
primary organic contaminant in the plume originating from these
lagoons. The 1995 sampling data of monitoring wells located
downgradient and closest to lagoons 7 and 8 (OW-9, OW-10, OW-11,
OW-12, OW-13), indicated various concentrations of organic
compounds. For example, monitoring well OW-10, which is located
immediately downgradient of lagoon 8, had the highest
concentrations of organic compounds, with concentrations of
benzene at 2,600 ppb (State groundwater standard of 0.7 parts per
billion or ppb), xylene at 30 ppb (State drinking water standard
of 5 ppb), and isophorone at 440 ppb (State drinking water
standard of 10 ppb).
However, the concentrations of organics in groundwater in the
aquifer decreased dramatically downgradient from the lagoons
(this was also the case for the 1994 sampling event). In 1995,
sampling data from the furthest downgradient wells from the
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lagoons (OW-17, OW-18, OW-19 and OW-23) only indicated three
site-related organic compounds above the State drinking water and
groundwater standards. Benzene was detected at 12 ppb (State
groundwater standard of 0.7 ppb), chlorobenzene at 10 ppb (State
drinking water standard of 5 ppb), and xylene at 29 ppb (State
drinking water standard of 5 ppb) in monitoring well OW-18.
Benzene and chlorobenzene were detected at 6 ppb and 8 ppb,
respectively, in monitoring well OW-19. No organic compounds
were detected in monitoring well OW-17. A comparison of the 1994
and 1995 sampling data for organic compounds indicates that only
2 of the 4 furthest downgradient monitoring wells had any organic
contaminants (benzene, chlorobenzene and xylene); the
contaminants were present at low levels in both sampling events.
The concentrations detected were low levels. No trends from 1994
to 1995 could be established.
D. Residential Wells
Comment #9: Some commenters asked about the residential well
sampling results, the dates that the sampling was conducted,
whether they could have their wells sampled, and the date of
sediment sampling in Gold Creek. One commenter requested that
the New York State Department of Health (NYSDOH) sample the
private wells and that the results of that sampling be considered
in EPA's determination of the final remedy for the Site.
EPA'a Response:
The NYSDOH sampled several private wells located downgradient of
the Site in 1991 and 1993 for organic and inorganic constituents.
Organic constituents were not detected in the groundwater from
these wells; inorganic constituents were detected below drinking
water standards, indicating their presence are at naturally
occurring levels. In September 1994 and March 1995, NYSDOH
sampled and analyzed a total of ten private wells in the area for
volatile organic compounds. The wells were located along Andrew
Drive, Evergreen Lane, Mark Drive, Michael Drive, Van Avenue, and
NY Route 209. The results indicate that no volatile organic
compounds were detected in any of the wells sampled. Mr. Tim
Vickerson of the NYSDOH indicated at the public meeting that any
concerned citizen who wants their private wells to be tested for
contaminants may contact him at 1-800 458-1158 ext. 305.
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Although the results of wells to be sampled by NYSDOH would
provide additional information to be utilized in EPA's
determination of the remedy for the Site, there is no reason to
believe that these results will be any different from previous
residential well sampling results. Additionally, EPA believes
that the results of groundwater monitoring, sediment sampling,
and groundwater modeling alone provide more than adequate support
for the selection of Alternative 2. In any case, EPA and NYSDOH
will evaluate the results of the future residential well
sampling, as well as results from the groundwater monitoring
program to ensure that the remedy remains protective of human
health and the environment.
In September 1994, sediment samples were collected in Gold Creek.
Analytical results indicate that Site related contaminants have
not impacted the sediments in Gold Creek.
E. Risk and Health Assessment
Comment #10: One commenter inquired about the risk posed by the
contaminated groundwater and EPA's acceptable risk range.
Another commenter questioned if EPA took into account all
contaminants in the groundwater in the risk assessment
calculation.
EPA'a Response:
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. There are no
current on-site groundwater users at the Site, therefore there
are no potential current receptors at the Site. EPA evaluated
whether residents to the east and southeast of Gold Creek that
use groundwater as drinking water and recreational users of Gold
Creek should be included as off-site receptors. Groundwater
modeling, in conjunction with measured groundwater
concentrations, sediment data from Gold Creek and groundwater
concentrations from off-site residential wells, indicates that
the plumes have stabilized and that contaminants have not
migrated either to Gold Creek or to off-site residences on the
other side of Gold Creek. Groundwater modeling results indicate
that contaminants are not expected to migrate to or beyond Gold
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Creek. Thus, current exposures to either off-site residents or
recreational users of Gold Creek are not occurring and are not
expected to occur in the future. These exposure pathways
therefore, were not quantitatively evaluated in the risk
assessment.
The exposure pathway evaluated under the potential future land-
use scenario included the exposure of industrial workers to the
on-site contaminated groundwater through ingestion. Because the
Site and land immediately adjacent to the Site are currently
zoned and used exclusively for industrial land use, future
residential or commercial use of the Site is not expected to
occur and therefore, only industrial use of the Site was
evaluated in the risk assessment. For purposes of conducting the
risk assessment it was assumed that a future industrial worker
would drink 1 liter of water per day from an on-site well for 5
days a week for 50 weeks a year (250 days/year with about 2 weeks
vacation) for 25 years out of a 70 year lifetime.
Groundwater data were evaluated to identify chemicals-of-concern
for the risk assessment analysis. All organic chemicals that
were detected in at least one sample were retained for evaluation
in the risk assessment with the exception of acetone and bis (2-
ethylhexyl)phthalate, which were determined to be laboratory
contaminants based on laboratory blank data. Since inorganic
contaminants are naturally occurring in groundwater, they were
evaluated to determine if they were present at the Site above
background concentrations. As a result of this evaluation eleven
(11) inorganic compounds were retained for evaluation in the risk
assessment. A list of all the contaminants of concern detected
in the groundwater that were used for the risk assessment
analysis is provided in Table 2 of the ROD. These contaminants
included benzene, chloroform, 1,2-dichlorobenzene,
tetrachloroethene, toluene, vinyl chloride, xylene, phenol,
arsenic, antimony, barium, chromium, lead, and zinc.
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.
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Evaluation of risks to potential future industrial workers was
1.4 x 1CT4 (approximately one-in-ten thousand). For this
scenario, the risk was determined to be within EPA's acceptable
risk range.
To assess the overall potential for noncarcinogenic effects posed
by the groundwater 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 value was 0.55 which is below the acceptable level
of 1.0 indicating no adverse health effects to future industrial
workers.
F. Other/miscellaneous
Comment #11: A commenter asked for the meaning of natural
attenuation.
EPA'a Response:
Natural attenuation is an approach for treating underground
pollutants that makes use of -natural processes to contain the
spread of contamination and reduce the concentration of
contaminants in order to restore soil or groundwater quality at
contaminated sites. Examples of these natural processes are
intrinsic biodegradation, dilution, dispersion, and adsorption.
Comment #12: A commenter asked what institutional controls are
and how they would be implemented?
EPA's Response:
Institutional controls are non-engineering measures that prevent
or limit exposure to hazardous substances, pollutants or
contaminants. They usually take the form of land and/or water
use restrictions. There are primarily two general categories of
institutional controls and several types within each category.
Governmental Controls are generally implemented through State or
local authorities that restrict activities or property, such as
zoning laws which control land use, and laws regarding well
drilling or water usage, including licensing or permitting
authorities. Proprietary controls are controls placed upon real
property that restrict the use of that property. Examples
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include covenants, easements, agreements or notices prohibiting a
specific land use or preventing activities that may negatively
impact specific remedial measures. Proprietary controls in the
form of deed restrictions (e.g. easements or covenants) are
property interests that an owner conveys to another. These deed
restrictions can "run with the land" which means they are binding
on future title holders.
Institutional controls will be implemented at the Carroll and
Dubies Site to restrict installation and use of groundwater wells
throughout the contaminated groundwater plume. The institutional
controls will be required until the groundwater has been
demonstrated to meet federal drinking water and State groundwater
and drinking water standards. To date, EPA has not determined
which type or types of institutional controls will be the most
effective and the easiest to implement for this Site. This
decision will, in all likelihood, be made during negotiations
with the PRPs regarding performance of the remedy, or during the
remedial design phase of this operable unit.
Comment #13: One commenter questioned whether EPA would implement
and pay for the remedy in the event the PRPs do not agree to do
so.
EPA's Response:
Following the selection of a remedy, EPA issues special notice
letters to the potentially responsible parties (PRPs) requesting
that they implement and fund the design and remediation of the
site. If the PRPs are not willing to pay for or implement the
cleanup of the site, then EPA can order them to perform the
remedial action, or EPA can use Superfund money 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.
Comment #14: One commenter inquired about whether the Superfund
program is an after the fact agency. This commenter was
concerned that efforts were not being made to prevent Superfund
sites from being created.
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EPA's Response:
Years ago, people did not understand how certain wastes might
affect people's health and the environment. Many wastes were
dumped on the ground, in rivers or left out in the open. As a
result, thousands of uncontrolled or abandoned hazardous wastes
sites were created. Some common hazardous waste sites include
abandoned warehouses, manufacturing facilities, processing plants
and landfills. In response to growing concern over health and
environmental risks posed by hazardous waste sites, Congress
established the Superfund program in December 1980 to provide EPA
with a powerful means of responding to cases of environmental
contamination. The Superfund remedial program is generally
retroactive in nature, addressing previously-contaminated sites,
as well as chemical emergency situations. Superfund personnel
are on call to respond at a moment's notice to chemical
emergencies, accidents or releases. Typical chemical emergencies
may include train derailments, truck accidents, and incidents at
chemical plants where there is a chemical release or threat of a
release to the environment. 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 future
Superfund sites. RCRA regulations also require owners and
operators of RCRA regulated facilities to properly "close"
facilities and to maintain financial assurance in amounts
sufficient to cover the cost of "closing" the facility and thus
avoiding the need for a Superfund clean up.
Comment #15: One commenter inquired about the potentially
responsible parties to the Consent Order.
EPA's Response:
There are four categories of PRPs: (1) Parties who conducted
operations at the site, which caused the site to become
contaminated, known as "operators"; (2)parties that transported
wastes to the site, known as "transporters"; (3) parties that
generated wastes that were disposed of at the site, known as
"generators"; and (4) past or present owners of the site, known
as "owners".
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The five PRPs at this Site are Carroll and Dubies Sewage
Disposal, Inc. (C&D), which is considered to be owner, operator
and transporter; Kolmar Laboratories, Inc. (Kolmar), Wickhen
Products, Inc. (Wickhen) and Reynolds Metals Co., Inc.
(Reynolds), all considered to be generators; and the City of Port
Jervis, also considered to be an owner.
Two PRPs, Kolmar and Wickhen, signed an Administrative Order on
Consent in February 1990 for the performance of the remedial
investigation and feasibility studies (RI/FSs) . During 'the OU1
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.
On May 19, 1995, EPA issued "special notice" letters to the PRPs
requesting that they submit a good faith offer to perform the
Remedial Design/Remedial Action (RD/RA) for OU1. The PRPs and
EPA were unable to reach an agreement and thus, on September 29,
1995, EPA issued a Unilateral Administrative Order to Carroll &
Dubies, Kolmar and Wickhen ordering them to implement the first
operable unit remedy.
On September 29, 1995, EPA entered into a de minimis Settlement
with Reynolds regarding EPA's past response costs for the Site
and remedial design/remedial action costs for OU1. Reynolds was
considered de minimis party because it contributed a very small
percentage of the waste to the Site, approximately 0.32 percent,
and this waste was neither more toxic nor of greater hazardous
effect than the other hazardous substances at the Site. This
settlement became effective on July 18, 1996.
After issuance of the ROD for OU2, all non de minimis PRPs will
be offered the opportunity to design and implement the selected
OU2 remedy. EPA will offer Reynolds a de minimis settlement for
OU2 costs.
Comment #16: One commenter expressed concern that the Port Jervis
landfill property, in which several of the Carroll and Dubies
lagoons are located, is the major contributor to the overall
contamination at the Site. The commenter believes that in
addition to the wastes disposed of in the lagoons, a great deal
of other Carroll & Dubies wastes were also disposed of in the
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Port Jervis Landfill. 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, and that EPA should be addressing
the Port Jervis landfill.
EPA's Response:
This ROD addresses only the groundwater beneath and downgradient
of the Carroll and Dubies Site. The landfill is not being
considered part of the Site, and therefore, is not being
investigated at this time. However, if specific information
regarding the location, methods and types of Carroll & Dubies
Sewage Disposal waste disposed of in the Port Jervis landfill is
provided to EPA, EPA will perform further investigation as
appropriate.
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 cover. To date, the City of Port Jervis
landfill has not yet been properly capped. Since the landfill is
not part of the Superfund investigation conducted to date, there
are no costs available for remediating the landfill. Typically,
landfills are addressed by installing a multi-layered cover over
the landfill to prevent the percolation of snow melt and
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. The Port
Jervis 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
17
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New York State Department of
Environmental Conservation
50 Wolf Road
Albany, New York, 12233-7010
Telephone # (518) 457-3976
Comment # 17: Several commenters requested that the water and
sediments of Gold Creek be sampled immediately and at frequent
intervals during the remediation of the lagoons. The Creek is
adjacent to the Port Jervis High School and Elementary School and
their playing fields. The commenters indicated that students
have had to enter the Creek to retrieve balls on more than one
occasion and that this may present a possible human exposure to
Site contaminants.
EPA's Response:
Sediment samples were collected from two locations in Gold Creek
south of the Site. These samples were collected in September
1994 and analyzed for organic and inorganic compounds. The
analytical results of the sampling indicate that Site related
contaminants have not impacted Gold Creek. This is further
supported by the groundwater sampling results which show that
contaminants were detected at low levels in monitoring wells
located close to the Creek. In addition, EPA's risk assessment
indicates that there is no risk associated with the sediments.
The contaminants in the groundwater at the Site have not migrated
to Gold Creek and are not anticipated to migrate there in the
future.
The selected remedy requires sediment sampling in Gold Creek to
ensure that Site related contaminants do not impact the Creek in
the future. With respect to surface water sampling, EPA has
determined that it will require sampling of the Creek water
during the first year of the monitoring program to support the
results of the sediment sampling.
Comment #18: One commenter indicated that the responsibility for
establishing the institutional controls should be placed on the
City of Port Jervis.
18
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EPA's Response:
EPA will determine the appropriate institutional control or
controls to be implemented during negotiations with the PRPs
regarding performance of the remedy, or during the remedial
design phase of this operable unit. After issuance of this ROD,
EPA will send "special notice letters" to all non-de minimis
PRPs; this includes the City of Port Jervis. The special notice
letter will invite the PRPs, including the City, to submit a good
faith offer to either implement the remedy themselves or fund
EPA's implementation of the remedy. If EPA determines that the
City is the most appropriate entity to implement the required
institutional controls, and the City does not agree to do so, EPA
could issue a unilateral order to the City, ordering them to
perform the remedy.
Comment #19: One commenter stated that no additional monitoring,
beyond what is required for OU1, is necessary.
EPA'8 Response:
The selected remedy for OU2 includes a groundwater monitoring
program. This monitoring program will include an initial study
of the groundwater parameters which favor natural attenuation and
periodic groundwater sampling to evaluate the rate and extent of
reduction of the organic contaminants in the groundwater.
The initial study will include an evaluation for the presence of
constituent-degrading microorganisms, pH, oxygen or other
electron acceptors, elemental nitrogen, phosphorous and other
parameters that are necessary to evaluate the progress of natural
attenuation. The results of the groundwater sampling and
analysis will be summarized to establish trends and/or reassess
further remedial actions that may be required.
The OU1 remedy includes groundwater monitoring only to ensure
that the containment cell for the treated lagoon sludges and soil
is functioning appropriately. The purpose of this monitoring is
to detect any potential releases to the groundwater that may
occur in the future. The OU1 groundwater monitoring program was
to be coordinated with monitoring expected to be conducted
pursuant to the OU2 remedy.
19
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Comment #20: One commenter expressed concern that the time period
presented in the Proposed Plan, for the groundwater to reach
drinking water1 standards, was of greater time duration than that
indicated by the groundwater model. The commenter indicated that
the groundwater modeling results predict that the contaminant
plumes will attenuate over a much shorter time than the five year
time period specified by EPA.
EPA's Response:
The groundwater model was used to predict concentrations in the
future for the following three different scenarios: (1) the
remedy for OU1 is not implemented. Under scenario 1 the extent
of the benzene and perchloroethylene (PCE) contaminant plumes
would remain constant for the foreseeable future. (2) The OU1
remedy is implemented and no residual contaminants remain in soil
beneath the lagoons. Under scenario 2 the benzene contaminant
plume would retract to the lagoons within approximately five
years, while the PCE plume would retract to the lagoons within
approximately one year. (3) The OU1 remedy is implemented and
residual contaminants remain in soil beneath the lagoons. Under
scenario 3 the benzene and PCE plumes would retract to the
lagoons within approximately five years. The five year time
period specified by EPA assumes that all contaminants in the
groundwater at the Site will attenuate to drinking water
standards following implementation of the OU1 remedy. EPA
believes that this is an accurate and appropriate representation
of the groundwater modeling results.
Comment #21: The Town Board of Deerpark requested that
Alternative 3 (Groundwater Pump and Treat via Precipitation,
Filtration and Carbon Adsorption) be the selected remedy to
address the groundwater contamination at the Site. The Town
Board believes that this alternative provides a better
containment and control of the contaminated groundwater than
Alternative 2. Another commenter requested that Alternative 4
(In Situ Groundwater Treatment) be the selected remedy.
EPA's Response:
EPA and NYSDEC believe that Alternative 2 provides the best
balance and trade offs with respect to the evaluation criteria.
20
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There are no current users of groundwater at the Site, therefore
no one is exposed to the contaminants present in the groundwater.
Sampling of the groundwater indicates that the levels of
contamination in the groundwater decrease dramatically from the
wells nearest the lagoons to those wells furthest downgradient of
the lagoons and closest to Gold Creek; sediment sampling
indicates that the Creek has not been impacted by contaminants
from the Site. This data and other data generated during the RI
were input into a groundwater model which predicted that
contaminants would not reach Gold Creek in the future. The
groundwater modeling also predicted that Alternative 2 will
attain drinking water standards in approximately the same time
frame, five years after the implementation of the OU1 remedy, as
Alternatives 3 and 4. Natural attenuation in combination with
institutional controls and groundwater monitoring will ensure
that the remedy is fully protective of human health and the
environment.
Given the fact that the remedy will be fully protective of human
health and the environment, and that it will achieve drinking
water standards in approximately the same time frame as more
costly alternatives, EPA and NYSDEC believe that Alternative 2 is
the most practical choice to address the groundwater
contamination at the Carroll and Dubies site.
21
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Appendix A
Proposed Plan
22
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Superfund Proposed Plan
Carroll and Dubies Sewage Disposal Inc.
Town of Deerpark
Orange County, New York
EPA Region 2
August 28, 1996
NYSDEC
PURPOSE OF PROPOSED PLAN
This Proposed Plan describes the remedial
alternatives considered for the contaminated
groundwater at the Carroll and Dubies
Sewage Disposal (C&D) Superfund site (the
Site) and identifies the preferred remedial
alternative for the contaminated
groundwater 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. §9617(a), 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 (RJ/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
RJ/FS can be found in the public repositories
listed on page 2.
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 of the remedial
alternatives evaluated, as well as the
preferred alternative.
The remedy described in this Proposed Plan
is the preferred remedy for the second
operable unit (OU2) at the Site, involving
the contaminated groundwater at the Site.
(The selected remedy for the first operable
unit (OU1), involving the clean-up of
sludges and contamination in the soil in and
around the lagoons, was announced in a
Record of Decision (ROD) dated March 31,
1995, and is presently in the design phase.)
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 remedial
action. The final decision regarding the
selected remedy will be made after EPA has
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taken into consideration all public
comments. We are soliciting public
comment on all of the alternatives
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 28, 1996
and concludes on September 27,1996.
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 Wednesday, September
11, 1996 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 in the Responsiveness
Summary Section of the Record of Decision
(ROD), the document which formalizes the
selection of the remedy.
MARK YOUR CALENDAR
August 28,1996 to September 27, 1996:
: Public comment period on; RI-/FS report,
Proposed Plan, and remedy considered.
Wednesday, September 11,1996
Public meeting to be held at 7:00 p.m. in
the auditorium of the Port Jervis High
Written comments should be addressed to
Maria Jon
Project Manager
U.S. Environmental Protection Agency
290 Broadway, 20th floor
New York, New York 10007-1866
(212) 637-3967
Copies of the RI/FS reports, Proposed
Plan and supporting documentation are
available at the following locations:
Town Hall
Drawer A.:.: . ...... .
.; Huguenot, New ,-York: 12746
Tel.: (914) 856r2210:,.:;: .
Hours: 8:00 a:rri;:- 4:00: p;m; (Mon. - Fri.)
EPA Document ControlGenter
290 Broadway,. 18th;floor
New York, New York ; 10007-1866
SITE BACKGROUND
The Carroll & Dubies site is located just
northeast of the City of Port Jervis, on Canal
Street in the Town of Deerpark, Orange
County, New York. The Site is
approximately 5.5 acres in size (see Figure
1). The northwest boundary of the Site is
formed by the valley wall, which consists of
exposed bedrock with talus comprising the
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base. The southeast boundary and a portion
of the northeast boundary of the Site is
formed by remnants of the former Delaware
and Hudson Canal and towpath. 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 about 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 located at the Site (lagoons 1
through 4 and 6 through 8 are depicted in
Figure 2). Lagoon 5 contains tires; no
industrial waste was found.
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 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, 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 four PRPs were Carroll and
Dubies Sewage Disposal, Inc. (C&D),
Kolmar Laboratories, Inc. (Kolmar),
Wickhen Products, Inc. (Wickhen) and
Reynolds Metals Co., Inc. (Reynolds). The
PRPs were given 60 days in which to submit
a good faith offer to undertake or finance the
PJ/FS for the Site.
On November 30, 1989, two PRPs, Kolmar
and Wickhen, submitted a good faith offer to
perform the RI/FS. An Administrative
Order on Consent was signed by the two
PRPs and by EPA in February 1990.
Kolmar and Wickhen conducted all RI/FS
work, pursuant to the RI/FS Order with
oversight by EPA. 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.
In March 1995, EPA signed a ROD for the
first operable unit which called for the
excavation of approximately 20,000 cubic
yards (cy) of contaminated material from the
lagoons and soils in the vicinity of the
lagoons. Materials exceeding treatment
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levels will undergo treatment via
solidification/stabilization (for inorganic
contaminants) and bioslurry (for organic
contaminants) or a combination of the two
treatment processes. All materials will be
placed on-site in a lined and capped cell
with leachate collection.
On May 19, 1995, EPA issued "special
notice" letters to the PRPs requesting that
they submit a good faith offer to perform the
Remedial Design/Remedial Action (RD/RA)
for OU1. The PRPs and EPA were unable
to reach an agreement and thus, on
September 29, 1995, EPA issued a
Unilateral Administrative Order to C&D,
Kolmar and Wickhen ordering them to
implement the first operable unit remedy.
On September 29, 1995, EPA entered into a
De Minimis Settlement with Reynolds
regarding past costs for OU1. This
settlement became effective on July 18,
1996.
After issuance of the ROD for OU2, all the
PRPs will be offered the opportunity to
design and implement the selected OU2
remedial alternative.
SCOPE AND ROLE OF ACTION
Site remediation activities are sometimes
segregated into different phases or operable
units, so that remediation of different
environmental media or areas of a site can
proceed separately. This phased approach
results in an expeditious remediation of the
entire site. EPA has designated two
operable units for the Carroll and Dubies site
as described below.
first operable unit (OU1) includes the
materials and contaminated soils from
lagoons 1, 2, 3, 4, 6, 7, and 8, which are
contaminated primarily with heavy metals
and volatile organic compounds (VOCs).
This operable unit is currently in the
remedial design phase.
"•Operable Unit 2 (OU2) addresses the
contaminated groundwater beneath and
downgradient of the Carroll and Dubies
property. This is the final operable unit and
is the subject of this Proposed Plan.
REMEDIAL INVESTIGATION
SUMMARY
The nature and extent of groundwater
contamination found at the Carroll and
Dubies site was assessed through sampling
of groundwater, sediment in Gold Creek,
residential wells and through groundwater
modeling and geophysical surveys. A total
of 34 monitoring wells was installed and
four groundwater sampling events were
conducted during the investigation.
The geology under the Site consists of
unconsolidated overburden materials of
glacial and glaciofluvial origin, which
overlie shale bedrock. The thickness of the
unconsolidated overburden materials ranges
from zero foot 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, which constitutes an
aquifer, ranges in thickness from 31 feet to
52 feet along the downgradient edge of the
Site. The glacial till is not continuous
beneath the Site, and appears to pinch out
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toward the northwestern edge of the Site,
adjacent to the exposed bedrock slope. The
till formation is defined as an aquitard,
because it consists of silt and clay, which
typically have low permeability. The till
formation is underlain by shale bedrock.
Groundwater found in the bedrock can be
developed and therefore the bedrock is
defined as an aquifer. The depth to
groundwater from ground surface ranged
from approximately 30 to 40 feet along the
southeastern boundary of the Site.
Groundwater movement beneath the Site is
generally to the southeast, towards Gold
Creek, which is located approximately 1,500
feet southeast of the Carroll and Dubies
property line.
Groundwater samples were collected
downgradient of the lagoons and analyzed
for organic and inorganic compounds. The
monitoring wells monitor either the bedrock
(well depths ranging from 39 feet to 86 feet
below land surface), the glacial till (well
depth at 60 feet below land surface), the
glacial outwash (well depths ranging from
16 feet to 58 feet below land surface) or both
the glacial till and outwash units (well
depths ranging from 35 feet to 51 feet below
land surface). The analytical results for the
groundwater samples for the 1991, 1993,
1994, and 1995 sampling events did not
indicate the presence of organic
contaminants above federal drinking water
or State drinking water or groundwater
standards in any of the bedrock or glacial till
monitoring wells. The sampling events did
show VOCs, semivolatile organic
compounds (SVOC), and chlorinated
organic compounds at concentrations
exceeding federal drinking water and State
groundwater and drinking water standards in
monitoring wells that are screened in the
outwash and across the outwash and till
interface. As a result two plumes of total
organic compounds exceeding 100 ug/L
(micrograms per liter) or parts per billion
(ppb) were defined. One plume originates
at lagoons 1 and 2, the other at lagoons 7
and 8. The concentration of organics in the
groundwater decreases dramatically further
downgradient of the lagoons, which suggests
that significant attenuation of contaminants
has occurred. This has been demonstrated
through groundwater modeling conducted at
the Site. The plumes are of limited extent
and have not extended far enough to impact
Gold Creek, or to affect groundwater or the
residential wells south of Gold Creek.
The discussion below is intended to
summarize groundwater results for organic
constituents by plume (i.e., results of
samples collected from monitoring wells in
the plume downgradient from lagoons 1-4
and results of samples collected from
monitoring wells in the plume downgradient
of lagoons 6-8). The discussion focuses on
the 1994 and 1995 sampling results, as these
results indicate the highest concentrations of
organic contaminants and during these
sampling events all wells in the monitoring
network had been installed (the wells had
been installed in phases).
Groundwater Downgradient of Lagoons 1-4
During the 1994 sampling event, four
organic compounds, benzene, 1,2-
dichloroethene, tetrachloroethene and
trichloroethene were detected above the
federal drinking water and/or State drinking
water and groundwater standards in the
monitoring wells located downgradient of
lagoons 1 through 4. The highest
concentrations of the chlorinated organic
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compounds were observed in shallow
outwash well OW-2, located downgradient
of lagoon 2. Groundwater samples from
monitoring well OW-2 detected 1,2-
dichloroethene at 130 ppb, tetrachloroethene
at 100 ppb, and trichloroethene at 24 ppb.
The federal drinking water and State
drinking water standards for
tetrachloroethene and trichloroethene are 5
ppb; the State drinking water standard for
1,2-dichloroethene is 5 ppb, which is more
stringent than the federal standard. Benzene
was observed in shallow outwash well
MW-4 at 15 ppb. The State drinking water
standard for benzene is 0.7 ppb. The 1995
groundwater results detected organic
constituents at similar concentrations as
those detected during the 1994 sampling
event.
Groundwater Downgradient of Lagoons 6-8
Groundwater data collected in the 1995
sampling event, in the vicinity of lagoons 7
and 8, indicates that benzene is the primary
organic contaminant in the plume
originating from these lagoons. During the
1995 sampling of monitoring wells located
downgradient of lagoons 6, 7 and 8 (OW-9,
OW-10, OW-11, OW-12, OW-13), benzene
(State drinking water standard of 0.7 ppb)
was detected in monitoring well OW-9 at
900 ppb. Monitoring well OW-10, which is
located immediately downgradient of lagoon
8, had concentrations of benzene at 2,600
ppb, xylene at 30 ppb (drinking water
standard of 5 ppb), and isophorone at 440
ppb (drinking water standard of 10 ppb).
Monitoring well OW-11 had concentrations
of benzene at 970 ppb, ethylbenzene at 30
ppb (drinking water standard of 5 ppb),
xylene at 51 ppb, and naphthalene at 17 ppb
(drinking water standard of 10 ppb).
Benzene and phenol (drinking water
standard of 1 ppb) were detected at 2,400
ppb and 55 ppb, respectively, in monitoring
well OW-12. Monitoring well'OW-13 had
concentrations of 1,2-dichloroethene at 20
ppb, benzene at 350 ppb, and vinyl chloride
at 34 ppb (drinking water standard of 2 ppb).
The 1994 groundwater results detected
organic constituents at similar
concentrations as those detected during the
1995 sampling event.
As previously stated, the concentrations of
organics in groundwater in the outwash
aquifer decreased dramatically downgradient
from the lagoons in the 1994 and 1995
sampling rounds. In 1995, sampling data
from the furthest downgradient wells from
the lagoons (OW-17, OW-18, and OW-19)
only indicated three organic compounds
above the State drinking water standards.
Benzene was detected at 12 ppb,
chlorobenzene at 10 ppb and xylene at 29
ppb in monitoring well OW-18. Benzene
and chlorobenzene were detected at 6 ppb
and 8 ppb, respectively in monitoring well
OW-19. No organic compounds were
detected in monitoring well OW-17.
In September 1994, April 1995 and July
1996, groundwater samples were collected
and analyzed for inorganic compounds.
Groundwater samples collected in the 1994
sampling event were non-filtered inorganic
samples. Although the results of the 1994
analyses indicated the presence of inorganic
compounds, very few samples indicated
concentrations above federal drinking water
and State drinking water and groundwater
standards. Arsenic was detected at 28.9 ppb
(drinking water standard of 25 ppb),
chromium was found in one sample at 123
ppb (drinking water standard of 50 ppb),
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antimony was found at 65 ppb (drinking
water standard of 3 ppb) and lead was found
in one sample at 39.2 ppb (drinking water
action level of 15 ppb). For each of the
inorganic compounds that exceeded their
respective criteria (arsenic, chromium, lead
and antimony) exceedances occurred in only
one sample out of the 32 samples collected.
Groundwater samples collected in the 1995
sampling event were highly turbid. These
samples were also filtered in the field. The
results of the 1995 inorganic analyses
indicated the presence of various inorganic
constituents in the groundwater
downgradient of the lagoons above
background concentrations. Several
inorganic constituents were detected at
concentrations that exceeded the federal
drinking water and/or State drinking water
and groundwater standards. Antimony was
detected at 15 ppb (drinking water standard
of 3 ppb), arsenic was detected at 105 ppb
(drinking water standard of 25 ppb),
beryllium was detected at 7.2 ppb (drinking
water standard of 3 ppb), chromium was
detected at 669 ppb (drinking water standard
of 50 ppb), lead was detected at 283 ppb
(drinking water action level of 15 ppb), and
nickel was detected at 425 ppb (there is no
drinking water standard for nickel at this
time).
Due to the inconsistency between the 1994
and 1995 sampling results for inorganic
constituents, EPA conducted another
sampling event for inorganic constituents in
July 1996. It was suspected that the high
concentrations of inorganics detected in
1995 may have been an artifact of highly
turbid samples resulting from the sampling
protocols used at that time. Because of this,
the July 1996 groundwater samples were
collected via a low-flow pump, and these
samples were not filtered. Also, during
sample collection, the presence of high
turbidity in some of the samples was
observed, therefore some monitoring wells
were re-developed prior to collecting the
groundwater samples. The results of this
sampling event indicated the presence of
inorganic compounds. Only three samples
indicated concentrations above State
groundwater standards. Chromium was
detected in monitoring well OW-9 at 70 ppb,
arsenic was detected at 43 ppb and 37 ppb in
monitoring wells OW-19 and OW-18,
respectively.
The levels of inorganics detected in the 1995
samples tend to directly depend on the
amount of suspended sediment (turbidity) in
the samples. Since the excessive turbidity
present in the 1995 groundwater samples is
believed to be an artifact of sampling, these
higher levels are not representative of true
site conditions in the aquifer. So, the results
of the groundwater data suggests that the
inorganic compounds found in the
groundwater beneath the Site are most likely
present at naturally occurring levels. Thus,
the potential for inorganic compounds to be
present in groundwater at concentrations
above naturally occurring levels due to
leaching from the lagoon sediments is low
and the potential for these inorganic
compounds to subsequently discharge with
groundwater to Gold Creek is also low. It
should be noted that the results from the
1994 sampling event for inorganic
constituents were included in the risk
assessment (see Summary of Site Risks
below). No pesticides or PCBs were
detected in any of the groundwater samples
collected from this Site.
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Sediment samples were collected in Gold
Creek. Analytical results indicate that Site
related contaminants have not impacted the
sediments in Gold Creek.
As part of the RJ, groundwater modeling
was conducted to determine whether the
organic contaminant patterns found in the
groundwater beneath the Site have stabilized
due to intrinsic biodegradation and to
estimate future concentrations of
contaminants at potential off-site locations.
The results of the groundwater modeling
indicate that the organic contaminants in the
groundwater are not migrating off-site and
that the concentration patterns observed at
the Site have stabilized or are not expected
to change in the future. Thus, contaminants
in the groundwater beneath the Site are not
expected to reach Gold Creek or off-site
residences in the future.
Also, as part of the RI, limited data was
collected to evaluate the extent of
biodegradation at the Site. This limited
evaluation included the collection of
dissolved oxygen and the presence of
microorganisms in the groundwater capable
of degrading volatile organic compounds
under expected Site conditions. The results
of this evaluation indicated that at the
Carroll and Dubies site the dissolved oxygen
levels in the benzene plume indicated the
potential for biodegradation to be occurring,
and the degrading microorganisms
population was in the range of 105 to 106,
indicating a healthy and robust community
of degraders present in the aquifer.
Therefore, the limited field data combined
with the groundwater modeling projections
demonstrate the potential for biodegradation
of organic contaminants at the Site. The
groundwater modeling results estimated that
contaminants will attenuate in five years
after completion of the remedy selected for
the lagoons. Since the groundwater
modeling results indicated the potential for
intrinsic biodegradation to be occurring in
the aquifer, this potential is evaluated in the
analysis of remedial alternatives.
The City of Port Jervis is served by a
municipal water supply that relies on three
hydraulically-upgradient reservoirs as water
sources. Outside of the City limits, private
supply wells provide drinking water. It
should be noted that the New York State
Department of Health (NYSDOH) sampled
several wells located downgradient of the
Site while the RI/FS was being conducted .
Several private wells were sampled 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.
Subsequently, in September 1994 and March
1995, NYSDOH sampled and analyzed a
total often private wells in the area for
volatile organic compounds. The wells were
located along Andrew Drive, Evergreen
Lane, Mark Drive, Michael Drive, Van
Avenue, and NY Route 209. The results
indicate that no volatile organic compounds
were detected in any of the wells sampled.
SUMMARY OF SITE RISKS
Based upon the results of the RI for the
groundwater operable unit, 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 baseline risk assessment began with
selecting contaminants of concern which
would be representative of the risks posed
by the groundwater underlying the Site.
These contaminants included benzene, 1,2-
dichlorobenzene, chloroform,
tetrachloroethene, toluene, vinyl chloride,
xylene, phenol, arsenic, antimony, barium,
chromium, lead, and zinc.
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. There are no current
on-site groundwater users at the Site,
therefore there are no potential current
receptors at the Site. Potential off-site
receptors included residents to the east and
southeast of Gold Creek that use
groundwater as drinking water and
recreational users of Gold Creek.
Groundwater modeling, in conjunction with
measured groundwater concentrations,
sediment data from Gold Creek and
groundwater concentrations from off-site
residential wells, indicates that the plumes
have stabilized and that contaminants have
not migrated either to Gold Creek or to off-
site residences on the other side of Gold
Creek. Groundwater modeling results
indicate that contaminants are not expected
to migrate to or beyond Gold Creek. Thus,
current exposures to either off-site residents
or recreational users of Gold Creek are not
occurring and are not expected to occur in
the future. These exposure pathways
therefore, were not quantitatively evaluated
in the risk assessment.
The exposure pathway evaluated under the
potential future land-use scenario included
the exposure of industrial workers to the on-
site contaminated groundwater through
ingestion. Because the Site and land
immediately adjacent to the Site are
currently zoned exclusively for industrial
land use, future residential or commercial
use of the Site is not expected to occur and
therefore, only industrial use of the Site was
evaluated in the risk assessment. For
purposes of conducting the risk assessment
it was assumed that a future industrial
worker would drink 1 liter of water per day
from an on-site well for 5 days a week for
50 weeks a year (250 days/year with about 2
-------
weeks vacation) for 25 years out of a 70 year
lifetime.
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 groundwater underlying
the Site poses no unacceptable carcinogenic
risk to industrial workers exposed to the
groundwater at the Site. The sum of the
current cancer risks for industrial workers
was 1.4 x 10^ (approximately one-in-ten
thousand) which is considered to be within
the U.S. EPA target risk range of 10" tolO'6.
The main contributors to the total cancer risk
were arsenic, vinyl chloride, and benzene.
To assess the overall potential for
noncarcinogenic effects posed by the
groundwater 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 value was 0.55 which is below
the acceptable level of 1.0 indicating no
adverse health effects to future industrial
workers. The main contributor to the total
noncancer risk was arsenic.
There are no impacts to ecological receptors
in Gold Creek, since contaminants in
groundwater have not migrated to Gold
Creek and are not anticipated to migrate
there in the future.
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
groundwater beneath the Site is to reduce or
eliminate potential health risks associated
with ingestion of Site contaminated
groundwater by potential future industrial
workers and to reduce the concentration of
contaminants in the groundwater to drinking
water standards.
SUMMARY OF REMEDIAL
ALTERNATIVES
CERCLA at Section 121, 42 U.S.C. §9621
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 four
remedial alternatives for addressing the
contaminated groundwater beneath the
Carroll and Dubies Sewage Disposal Inc.,
Site. Since contaminants will remain at the
Site above levels which allow for
unrestricted use and unlimited exposure,
each alternative would require five-year
10
-------
reviews to ensure that the remedial action is
protective of human health and the
environment. Five-year reviews are
currently required as part of OU1. As used
in the following text, the time to implement
a remedial alternative reflects only the time
required to construct or implement the
remedy and does not include the time
required to design the remedy, negotiate
with the responsible parties, or procure
contracts for design and construction, or
conduct operation and maintenance at the
Site.
Alternative 1: No Action
Capital Cost: $ 0
0 & M/yr Cost: $ 0
Present Worth: $ 0
Time to Implement: 0 month
The Superfund program requires that the
"no-action" alternative be considered as a
baseline for comparison with other
alternatives. As demonstrated through the
results of the groundwater modeling study,
naturally occurring processes for reducing
the concentration of contaminants in the
groundwater are at work at the Site. Under
this alternative, no action would be taken to
address the contaminated groundwater.
There would be no monitoring of these
naturally occurring processes in the
groundwater to evaluate the rate and extent
of the reduction and mobilization of
contaminants in the groundwater beneath the
Site. The period for the groundwater to
reach federal drinking water and State
drinking and groundwater standards was
projected through the groundwater modeling
to be approximately five years. The
remediation of the lagoons, which will be
implemented under OU1, would minimize
any additional contaminant contribution to
the groundwater.
Alternative 2: Natural Attenuation with
Institutional Controls and Monitoring
Capital cost:
O & M/yr Cost:
Present Worth:
Time to Implement:
$0
$ 58,000
$ 284,000
6 months
Similar to Alternative 1, Alternative 2 would
also rely on natural attenuation, with
intrinsic biodegradation as the principal
mechanism, to reduce contaminants in the
groundwater to drinking water standards.
The remediation of the lagoons, which will
be implemented under OU1, would
minimize any additional contaminant
contribution to the groundwater. This
alternative includes the implementation of
institutional controls, such as deed
restrictions, contractual agreements, local
law or ordinances or other governmental
action for the purpose of restricting
installation and use of groundwater wells
throughout the contaminated groundwater
plume. Groundwater monitoring at the Site
and sediment sampling in Gold Creek would
also be conducted. These restrictions would
complement any restrictions implemented as
part of the OU1 remedy. Institutional
controls restricting the use of Site
groundwater would be required until the
groundwater has been demonstrated to meet
federal drinking water and State
groundwater and drinking water standards.
This period was projected through the
groundwater modeling to be a five year
period necessary for the intrinsic
biodegradation and flushing mechanisms to
reduce the concentration of contaminants in
the groundwater to levels below drinking
11
-------
water standards. Once these levels have
been demonstrated to be met, the restrictions
on groundwater use would no longer be
required.
As predicted by the groundwater modeling
results, the organic contaminants in the
groundwater would meet drinking and
groundwater standards within a period of
approximately five years after the
implementation of the OU1 remedy. This
alternative includes a component of initial
assessment of the groundwater parameters
which favor natural attenuation and a
groundwater monitoring requirement to
evaluate the rate and extent of reduction of
the organic contaminants in the
groundwater. The initial assessment would
include an evaluation for the presence of
constituent-degrading microorganisms, pH,
oxygen or other electron acceptors,
elemental nitrogen, phosphorous and other
parameters necessary to evaluate the
progress of natural attenuation. Groundwater
monitoring would be conducted on a
semiannual basis.
Alternative 3: Groundwater Pump and
Treat via Precipitation, Filtration and
Carbon Adsorption
Capital Cost:
O & M/yr Cost:
Present Worth:
Time to Implement:
$ 1,070,000
$ 287,200
$2,105,000
9 months
This alternative would consist of a series of
recovery wells used to capture contaminated
groundwater immediately downgradient of
the source areas or the lagoons. The
recovery wells would capture the most
concentrated portion of the contaminant
plume emanating from the source areas.
Any impacted groundwater that would not
be captured by the recovery wells would be
naturally attenuated. This alternative would
eliminate the potential for migration of
organic contaminants off site. The recovery
wells would be located in that portion of the
outwash aquifer located downgradient of the
towpath. Beneath the lagoons, a saturated
outwash unit does not exist.
The preliminary configuration of the
treatment system assumes that
approximately six wells would be used to
pump groundwater at controlled rates to
capture the impacted groundwater. Two sets
of three pumping wells, each pumping at a
rate of 5 gallons per minute (gpm), would be
used. The total pumping rate of the six
wells is 30 gpm. One set of wells would be
located between 100 feet to 150 feet
downgradient of lagoon 8. This set of three
wells would be designed to capture impacted
groundwater passing beneath lagoons 6, 7,
and 8. One set of wells would be located
between 100 feet to 125 feet downgradient
of lagoons 1 and 2. This set of three wells
would be designed to capture impacted
groundwater passing beneath lagoons 1 and
2. The recovered groundwater would be
treated on-site through a series of treatment
processes. Conceptually, the treatment
system would consist of iron and suspended
solids removal via precipitation followed by
filtration and carbon adsorption. Following
treatment, the groundwater would be
discharged to Gold Creek in accordance
with the State Pollutant Discharge
Elimination System (SPDES) requirements.
Residuals generated from the treatment
processes would be managed in accordance
with the Resource Conservation and
Recovery Act (RCRA) regulations.
12
-------
This alternative would also include
groundwater monitoring to measure the
effectiveness of the pump-and-treat system,
as well as the institutional controls specified
in Alternative 2. The treatment system
would be operated until contaminant levels
in the groundwater reach federal drinking
water and State drinking water and
groundwater standards, which has been
estimated to be approximately five years.
Alternative 4: In Situ Groundwater
Treatment
Capital Cost:
0 & M/yr Cost:
Present Worth:
Time to Implement:
$ 1,017,000
$ 248,000
$ 1,912,787
12 months
This alternative involves the injection of air
into the saturated zone (i.e., below the water
table), via a series of wells, to reduce the
volatile constituents dissolved in
groundwater. These wells would be located
in the same general vicinity as the pumping
wells outlined in Alternative 3, thus
allowing treatment of the most concentrated
groundwater plume. Any impacted
groundwater that would not be captured by
the in situ groundwater treatment system
would be naturally attenuated. The levels of
organic constituents would be decreased in
the saturated zone during aquifer aeration
via mass transfer of the chemicals from the
water phase to the gaseous phase. If the
levels of organic compounds exceed air
quality guidelines, then a soil venting
system would be installed in the subsurface
to collect the air emissions. The exhaust air
from the vapor extraction system would be
discharged to a treatment system. The
gaseous treatment system for this alternative
would be an activated carbon filter.
Groundwater monitoring would also be
conducted as part of this alternative to
evaluate the effectiveness of the air sparing
system. A reduction in the levels of
organics may also take place in the saturated
zone through the enhancement of
biodegradation due to the increase in
oxygen. With this alternative, air sparging
may be used in conjunction with vacuum
extraction and/or enhanced bioremediation
with the addition of nutrients.
A preliminary configuration of the aquifer
aeration system would consist of
approximately 30 air sparging wells. This
alternative would include the same
monitoring program and institutional
controls described in Alternative 3.
Treatment of the groundwater would
continue until contaminant levels in the
groundwater achieve federal drinking water
and State drinking water and groundwater
standards. This alternative would achieve
groundwater remediation goals within about
five years .
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 applicable
and relevant and appropriate requirements
(ARARs); long-term effectiveness and
permanence; reduction of toxicity, mobility,
or volume through treatment; short-term
effectiveness; implementability; 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.
A 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.
A Reduction of toxicity. 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.
* Implementability 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
For No Action (Alternative 1) and Natural
Attenuation with Institutional Controls and
Monitoring (Alternative 2), the
concentration of contaminants in the
groundwater would be reduced due to
natural attenuation of contaminants until
federal drinking water and State drinking
and groundwater standards are met. This
period has been estimated to be
approximately five years from
implementation of the OU1 remedy. The
No Action alternative would present a
slightly greater risk to human health and the
environment than Alternatives 2, 3, and 4 in
the short-term because the potential would
exist that an on-site worker could come in
contact with the contaminated groundwater.
Under Alternative 2, protection of human
health would be enhanced with the
implementation of institutional controls,
preventing the use of the contaminated
14
-------
groundwater.
For the Pump-and-Treat (Alternative 3) and
In Situ Groundwater Treatment (Alternative
4) scenarios, the potential risks to human
health from potential exposure to impacted
groundwater would be reduced by removal
and treatment of contaminants in the
groundwater captured by the remedial
systems. These alternatives would achieve
groundwater remedial goals within about
five years. Institutional controls preventing
the use of Site groundwater would eliminate
the potential exposure to contaminated
groundwater while the groundwater is being
remediated. The contaminants would
continue to migrate until attenuated under
Alternatives 1 and 2. However, impacts are
expected to be minimal since, as noted in the
risk assessment section, the levels of
contaminants in the groundwater present no
significant human health risk under current
or future uses. Furthermore, impacts to
ecological receptors in Gold Creek from the
implementation of Alternatives 1 and 2
would be unlikely since contaminants in
groundwater have not migrated to Gold
Creek and are not anticipated to migrate
there in the future.
Compliance with ARARs
Actions taken at any Superfund site must
meet all ARARs of federal and state law or
provide grounds for waiving these
requirements. All of the alternatives have
been designed to achieve or comply with the
ARARs.
Since the groundwater at the Site is a future
potential source of drinking water, federal
drinking water standards (Maximum
Contaminant Levels [MCLs]) and New York
State Drinking Water Standards and New
York State Groundwater Quality Standards
are ARARs. For No Action (Alternative 1)
and Natural Attenuation with Institutional
Controls and Monitoring (Alternative 2),
federal drinking water and State drinking
water and groundwater standards would be
achieved over time through natural
biodegradation of organic contaminants in
the groundwater. The period for the
groundwater to reach federal drinking water
and State drinking and groundwater
standards was projected through
groundwater modeling to be approximately
five years. For the Pump-and-Treat
(Alternative 3) and In Situ Groundwater
Treatment (Alternative 4) scenarios,
groundwater standards would be met by
removal and treatment of contaminants in
the groundwater. The discharge of treated
groundwater to Gold Creek during
implementation of Alternative 3 would
comply with the Federal Clean Water Act
and State Pollutant Discharge Elimination
System (SPDES) regulations. The residual
sludges from the treatment system under
Alternative 3 would be treated or disposed
of off-site in accordance with RCRA
regulations. The spent carbon generated
from the groundwater treatment system
under Alternative 3 and the gas treatment
system under Alternative 4 would either be
regenerated off-site or sent off-site for
treatment and disposal in accordance with
RCRA regulations.
Long-Term Effectiveness and
Permanence
With all four alternatives, after
approximately five years, the concentrations
of contaminants in the groundwater are
expected to be permanently reduced to
15
-------
levels below ARARs. Implementation of
Alternatives 3 and 4 might result in a
slightly reduced time frame to achieve
ARARs downgradient of the lagoons.
Therefore, all alternatives are relatively
similar in terms of this criterion.
Reduction of Toxicity, Mobility, and
Volume through Treatment
Alternatives 1 and 2 rely solely on naturally
occurring mechanisms to reduce the toxicity
and volume of contaminants in the
groundwater. Although CERCLA has a
preference for treatment to reduce
contaminants, Alternatives 1 and 2 would
reduce the contaminants in the groundwater
by natural attenuation process. Alternatives
3 and 4 are similar in their abilities to reduce
toxicity, mobility and volume and would
provide reduction of toxicity, mobility and
volume somewhat more rapidly than
Alternatives 1 and 2. Under Alternatives 3
and 4, treatment to reduce contaminants in
the groundwater would be achieved by
extraction of the contaminants and
subsequent treatment.
Short-Term Effectiveness
Alternatives 1 and 2 would have no adverse
effects at all on the community, site workers,
or the environment since there would be no
potential exposure to any of the
contaminants because no construction
activities would occur. Alternatives 3 and 4,
with potentially shorter time periods to meet
ARARs, rank highest in terms of this
criterion to meet the response objectives.
However, Alternatives 3 and 4 would
present greater impacts than Alternatives 1
and 2, due to construction activities. For
example, the construction of extraction wells
and piping to transport the treated
groundwater to Gold Creek would have
minor negative impacts on residents in the
area. These impacts would be associated
with the disruption of traffic, excavation on
public and private land, and noise and
fugitive dust emissions. Appropriate
measures, however, would be implemented
to minimize these impacts.
Implementabiliry
Alternative 1 - No Action is clearly the most
implementable. Alternative 2 would require
groundwater-use restrictions to prevent the
use of groundwater wells throughout the
contaminated aquifer; although sometimes
difficult to obtain, these restrictions are
being used at numerous sites. Alternative 2
would also require additional geochemical
and intrinsic biodegradation studies and
monitoring. These studies and monitoring
requirements are being implemented at
numerous sites. Alternatives 3 and 4 would
be more difficult to implement due to
construction requirements. Additionally,
Alternative 3 would require that access be
obtained to construct the piping to transport
the treated groundwater to Gold Creek;
authorization to discharge treated water to
Gold Creek would add to the complexity of
implementing this remedy. Nonetheless,
these are successfully proven technologies
at the field scale and considered to be
readily implementable.
Cost
There is no cost associated with the No
Action alternative. Alternative 2, Natural
Attenuation with Institutional Controls and
Monitoring, is the lowest cost alternative
with a present worth of $284,000.
16
-------
Alternative 3, Groundwater Pump and Treat,
has the highest cost with a present worth of
$2,105,000. Alternative 4, In Situ
Groundwater Treatment, with a present
worth of $1,912,787, is slightly less than
Alternative 3.
Community Acceptance
Community acceptance of the preferred
alternative will be assessed in the ROD
following a review of the public comments
received on the RI/FS report and the
Proposed Plan. A response to comments
will be included in a Responsiveness
Summary, which will be attached to the
ROD.
State Acceptance
The State of New York concurs with the
preferred alternative
PREFERRED ALTERNATIVE
Based upon an evaluation of the various
alternatives, EPA and NYSDEC
recommend Alternative 2, Natural
Attenuation with Institutional Controls.
Long-term protection und'er this alternative
would be afforded by the reduction in the
concentration of contaminants in the
groundwater below the ARARs through
naturally occurring removal processes. This
alternative includes the implementation of
institutional controls, such as deed
restrictions, contractual agreements, local
law or ordinances or other governmental
action for the purpose of restricting
installation and use of groundwater wells
throughout the contaminated groundwater
plume, monitoring of the groundwater to
measure improvement in groundwater
quality and sediment sampling in Gold
Creek to ensure that contaminants have not
reached Gold Creek.
Since contaminants will remain on Site,
EPA will review the Site at least once every
five years to ensure that the remedy selected
continues to be protective of human health
and the environment. If the natural
attenuation of contaminants in the
groundwater at the Site has not improved
groundwater quality to federal drinking
water and State drinking water and
groundwater standards, EPA and NYSDEC
will determine the need for a program to
evaluate and implement contingency
alternatives for groundwater remediation at
the Site.
Alternative 2 addresses all of the media of
concern and provides the best balance of
trade-offs among the alternatives with
respect to the evaluation 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 to the maximum extent
practicable.
17
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A J VJ V. JXJJ 1
SITE LOCATION MAP
Carroll and Dubies Site, Port Jerris, New York
Source: USGS 7>/i MEN. Topographic Quad.
Port Jerris North, NY-PA 1969
-------
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-------
Appendix B
Public Notice
23
-------
* - • • c.i .,.•.•
The'Times Herald RECOUP ...... ' ' Tuesday: Sepferriber'TO. 1996
PUBLIC NOTICE
U.S. Environmental Protection Agency
Announces Public Meeting and Comment Period
on the Proposed Plan for the
CARROLL AND DUBIES SEWAGE DISPOSAL SUPERFUND SITE
Port. Jervis, New York- g-
The United States Environmental Protection Agency (EPA) invites public comment on
its Proposed Plan for remediating contaminated groundwater at the Carroll and
Dubies Sewage Disposal (C&D) Superfund Site in Port Jervis, New York. EPA will
accept comments during a public comment period which begins on August 27, 1996
and ends September 26, 1996. A public meeting will be held on Wednesday,
September 11, 1996 at 7:00 PM at the Port Jervis High School auditorium.
Complete analyses of the alternatives listed beiow are presented in the Remedial In-
vestigation/Feasibility Study and Proposed Plan, along with other documents csed by
EPA in the decision-making process for this Site. These documents are available for
public review at the following locations:
Deerpark Town Hall Port Jervis Public Library
Route 209N 1 38 Pike Street
Drawer A Port jervis NY -| 2271
Hugenot, NY 12746
The Proposed Plan evaluates four remedial alternatives for addressing the contami-
nated groundwater beneath the Carroll and Dubies Sewage Disposal Inc. Site:
Alternative 1 : No Action
Alternative 2: Natural Attenuation with Institutional Controls and
Monitoring
Alternative 3: Groundwater Pump and Treat via Precipitation,
Filtration and Carbon Adsorption
Alternative 4: In Situ Groundwater Treatment
Based upon evaluation of the various alternatives, EPA recommends Alternative 2,
Natural Attenuation with Institutional Controls and Monitoring. This alternative would
rely on natural attenuation, with intrinsic biodegradation as the principal mechanism,
to reduce contaminants in the groundwater to drinking water standards. Groundwater
modeling results indicate that a five year period would be necessary for the intrinsic
biodegradation and flushing mechanisms to reduce the concentration of organic con-
taminants in the groundwater to levels below drinking water standards. This alterna-
tive includes the implementation of institutional controls for the purpose of restricting
installation and use of groundwater wells throughout the contaminated groundwater
plume, which is limited to the industrial area north of Gold Creek, in the vicinity of the
C&D property. Groundwater monitoring at the Site and sediment sampling in Gold
Creek would also be conducted.
Written comments must be postmarked no later than September 26, 1996 and sub-
mitted to:
Maria Jon, Project Manager
U.S. Environmental Protection Agency
290 Broadway, 20th Floor
New York, NY 10007-1866
. . (212)637-3967
-------
Appendix C
September 11, 1996 Public Meeting Attendance Sheets
24
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Q
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UNITED STATES ENVIRON1-1ENTA1, PROTECTION AGENCY
REGION II
PUBLIC MEETING
FOR
Carroll and Dubiea Superfund Sit"
Port Jervis, NY
Wednesday, September 11, 1996
ATTENDEES
r\j
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(Please Print Clearly)
NAME
STREET
CITY
ZIP
PHONE
REPRESENTING
-------
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1/1
5
(M
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION II
PUBLIC MEETING
Carroll and Dubies Superfund Site
Port Jervis, NY
Wednesday, September 11, 1996
ATTENDEES
(Please Print Clearly)
NAME
STREET
CITY
XAA///CI//
ZIP
PHONE
REPRESENTING
-------
S
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ID
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION II
PUBLIC MEETING
FOR
Carroll and Dubies Superfund Site
Port Jervis, NY
Wednesday, September 11, 1996
ATTENDEES
(Please Print Clearly)
g
NAME
STREET
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Appendix D
September 11, 1996 Public Meeting Transcript
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CARROLL and DUBIES
SUPERFUND SITE
Wednesday,
September 11, 1996
7:05 p.m.
Port Jervis High School
Route 209
Port Jervis, New York
BEFORE:
NATALIE LONEY,
Public Outreach Branch
MARIA JON,
Remedial Project Manager
DOUG GARBARINI,
Chief of the Eastern New York
Remediation Section
LINDA ROSS,
Hydrogeolegist
Jacqueline Maloney, CSR
Certified Court Reporter
ROCKLAND & ORANGE REPORTING
20 South Main Street
New City, New York 10956
(914) 634-4200
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2 MS. LONEY: We're going
3 to get started.
4 We're going to start by way of
5 introducing all of the participants who
6 are here. My name is Natalie Loney, I'm
7 with the Public Outreach Branch in EPA,
8 and starting from my left is Maria Jon,
9 who is the RPN for the Carroll and Dubies
10 Site, next to her is Doug Garbarini, who
11 is the Chief of the Eastern, New York
12 Remediation Section, and next to Doug is
13 Linda Ross, who is an EPA Hydrogeologist,
14 and she is specializing in groundwater.
15 I'd like to thank all of you for
16 coming out this evening. We're here to
17 discuss and to present to you the results
18 of the remedial investigation and to
19 present our proposed plan for remediating
20 the Carroll and Dubies Site.
21 After my brief introduction, Doug
22 Garbarini will be coming before you. He
23 will give you a brief overview of the
24 Superfund Program, followed by Maria Jon,
25 who will give the results of the remedial
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2 investigation, in addition to our proposed
3 plan and an explanation of the plan. That
4 will be followed by questions and
5 answers. I will then come back to the
6 podium and open the floor for questions
7 and we will hopefully provide the
8 answers.
9 Many of you have received in the mail
10 a copy of the proposed plan and we also
11 had a brief one page flier that was also
12 enclosed in the mailer, which gives a
13 little bit of the detail in terms of what
14 the proposed plan is, in addition, it
15 gives the dates for the opening and
16 closing of the comment period. We're
17 going to present the plan to you and open
18 the floor not only for questions tonight,
19 but we are requesting that you submit
20 comments to us. The person that you would
21 be submitting the comments to is Maria
22 Jon, and her address is on the bottom of
23 the sheet. If you don't have one, there
24 are some of the handouts at the end. The
25 closing date for the comment period is in
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2 fact September 27, 1996, so we're
3 requesting that all formal written
4 comments be submitted to our office by
5 that date.
6 In addition, we have Tim Vickerson,
7 from the New York State Department of
8 Health, here who can answer some questions
9 for you as well.
10 So without further adieu, let me
11 bring up Doug Garbarini and we're going to
12 open the meeting. Thank you.
13 MR. GARBARINI: Thank you, Natalie.
14 First of all, I'd like to thank all
15 of you for coming out tonight. I see a
16 lot of familiar faces. I've been out for
17 a couple of other public meetings over the
18 last few years. The last time I was out
19 here was about two years ago when we came
20 out to discuss the remediation of the
21 source areas for the lagoons at the
22 Carroll and Dubies Site.
23 And as you're all probably very well
24 aware, we did select a remedy, a rather
25 complex remedy, which called for treating
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the lagoons, materials in the lagoons, and
the soils around those lagoons, and that
remedy was selected last year.
Tonight we're here to discuss the
remedy for the groundwater at the Site.
So we've basically partitioned the Site
off into two separate, well, as we call
them, operable units that allowed us to
move forward with the project in a more
expedited fashion. We are already in the
middle -- but not in the middle, but
underway with the remedial design for the
treatment of the lagoons. So tonight,
since we had to collect additional data
before we make the decision on the
groundwater, we're here tonight to discuss
our groundwater investigation and the
proposed plan for the groundwater.
What I'm going to do is just give you
a brief overview of the Superfund process,
in about ten minutes or so, give you an
idea how the program came about and where
it's headed.
Superfund was passed in 1980.
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2 Superfund Law is also more formally known.
3 as Comprehensive Environmental Response,
4 Compensation, and Liability Act, or
5 CERCLA. It was passed in 1980 by
6 Congress. Basically it was passed in
7 response to a number of natural
8 environmental disasters that were
9 occurring in terms -- when I say natural
10 environmental disasters I'm really talking
11 about hazardous -- the uncovering of
12 hazardous waste sites, most notably, I'm
13 sure you all have heard about Love Canal
14 in the past.
15 At that point in time the Federal
16 Government really didn't have a mechanism
17 for dealing with such sites, with
18 hazardous waste sites, it was really
19 crisis management. There were a number of
20 them springing up across the Country.
21 People were pointing fingers, saying,
22 well, how are we going to get the work
23 done? Who's responsible? Where is the
24 money going to come from? How can we get
25 those that were responsible for the
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2 contamination to take part in the
3 cleanup? And it was a very complex issue
4 that Congress first passed CERCLA or
5 Superfund in 1980, and the idea was to
6 provide a Superfund or pot of money that
7 could be used to address abandoned
8 hazardous waste sites.
9 Congress at the time we were looking
10 at a two-pronged program. He were looking
11 as those sites that could be studied
12 rather extensively before a decision was
13 made so that we could move forward with an
14 appropriate remedial action, and we were
15 also looking at sites that presented a key
16 health risk, that were real, real
17 problems. Just to give you an example, if
18 you can imagine having a whole load of
19 drums uncovered on a school yard or
20 someplace where children would be playing,
21 perhaps they were leaking or they were
22 exposed to conditions that were hazardous
23 when these drums were revealed. Those
24 sorts of situations would present a key
25 health threat, and EPA has mechanisms
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2 whereby we can go out and take immediate,
3 rather rapid removal actions. And we've
4 conducted more than 3,000 of these across
5 the Country, it's been a very successful
6 portion of pur program.
7 The other side of the program is the
8 remedial side of the program, which we're
9 discussing here tonight, includes sites
10 like the Carroll and Dubies Site, which
11 are on the National Priorities List.
12 The other thing that CERCLA or
13 Superfund gave us was mechanisms to force
14 those parties that were responsible for
15 the contamination to cleanup the
16 contamination. By responsible parties we
17 refer to them as PRP's or potentially
18 responsible parties. And they are those
19 parties that generate waste that was
20 disposed of at a Superfund site,
21 transported waste that was disposed of at
22 a Superfund site, that operated a waste
23 disposal processes at the site or that are
24 current or were formerly owners of the
25 site during times of waste disposal. And
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2 it gave us some real, real clout which we
3 did not have before, which allowed us
4 basically to request that the PRP's do
5 work on consent, and it also gave us the
6 ability to order them to do the work. And
7 if those two mechanisms were not
8 successful, it gave us an approach whereby
9 we could go back after the responsible
10 parties, once we had completed the cleanup
11 at the site, and try and recover costs
12 from them at that point in time.
13 You might ask, well, how does a site
14 like the Carroll and Dubies Site or any
15 other sites in New York become a National
16 Priorities List Site? It's a rather
17 complicated process, but the first step of
18 the process is for the site to be listed
19 on a Preliminary List, or what we call our
20 Surplus List, and there are more than
21 30,000 of these types of sites that have
22 been evaluated across the Country. There
23 are more than 1,700 of these that were
24 located in New York State.
25 And we go through a process where we
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2 do preliminary assessments and site
3 inspections, if necessary, to try and
4 determine whether the sites should be
5 included on the National Priorities List.
6 As you can see here, we've really
7 done a pretty thorough job of looking at
8 almost all the sites. There are about 130
9 that have not been evaluated to date, but
10 most of them have either been dealt with
11 and are being deleted, they no longer need
12 to be on the National Priorities List, or
13 there's a big bunch here that we're still
14 trying to decide whether they should be
15 put on the list or not.
16 As you can see, there are 89 sites
17 that are on the National Priorities List
18 in the State of New York. I'd say
19 approximately a quarter of those are
20 located in Long Island, if you want to get
21 a. feel for the density of sites across the
22 State.
23 So most of those 89 sites have had
24 remedies selected for them and are -- you
25 know, we've completed our investigation,
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2 we've decided what sort of remedies need
3 to take place at these sites.
4 Okay. Once we've gotten through the
5 preremedial phase, as we call it, we've
6 discovered the site, we've ranked it,
7 placed it the National Priorities List, as
8 I discussed before, we are also able to
9 conduct immediate removal actions at these
10 sites or other sites requiring immediate
11 response.
12 We then get into the remedial studies
13 phase, and we start off with a remedial
14 investigation. We go out and we sample
15 the soils, the groundwater, the air,
16 whatever streams nearby, whatever might be
17 necessary to try and determine, you know,
18 how extensive the contamination is, what
19 type of contamination you have; do you
20 have volatile organic compounds, solvents,
21 do you have heavy metals. We then move
22 forward and utilize this information and
23 try and discern what sort of risk these
24 contaminants pose to people or to the
25 environment, ecological receptors. If
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2 these risks are deemed to be unacceptable,
3 we then have to look at means for reducing
4 the risk to acceptable levels, and we do
5 that in what's call a feasibility study.
6 A feasibility study lays out different
7 alternatives for reducing the risks to
8 acceptable levels. When we're doing the
9 feasibility study we evaluate each of
10 these alternatives against nine criteria.
11 And the two most important of those are
12 overall protection of human health and the
13 environment, and compliance with all
14 environmental regulations.
15 In doing this comparison we then come
16 out with what we feel is the best
17 alternative using these nine criteria, and
18 we put that alternative forward in what's
19 called a proposed plan, which is what
20 we're here to discus tonight, and we open
21 up a public comment period, we take
22 comments at the public meeting, we'll
23 also, as Natalie said, take comments in
24 writing. We'll go back to our offices and
25 review all these comments and make
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2 modifications to the remedy, if necessary,
3 but these responses are all put forward in
4 a document called the Responsiveness
5 Summary, which becomes part of a larger
6 document, which is called the Record of
7 Decision. This Record is Decision is
8 signed by the highest ranking official in
9 our regional office, the Regional
10 Administrator.
11 This remedy is -- this Record of
12 Decision lays out a conceptual remedy for
13 cleaning up the site. We then go into the
14 construction phase. The first step there
15 is the remedial design. As I mentioned
16 before, we are currently in the remedial
17 design phase for treating the lagoon
18 sediments, but a remedy has already been
19 selected there, as I mentioned. The
20 remedial design phase is the nuts and
21 bolts. If you're going to have to build
22 the groundwater treatment system, you
23 decide where you want to place the wells,
24 what sort of pipe you're going to have, if
25 it's going to be housed in a building, you
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2 decide how the building is going to be
3 built, how large it's going to be, where
4 the doors are going to be, the typical
5 design type issues like if you're just
6 building your own home.
7 Then we go out and do the remedial
8 action. This is where we actually get in
9 and move the earth, if earth needs to be
10 moved, build our treatment systems, if
11 they need to be built, and start the
12 actual cleanup of the site. Subsequently
13 we move then to monitoring, if necessary,
14 and we start closeout procedures for the
15 site, and then we go through a deletion
16 process, whereby the site is deleted from
17 the National Priorities List.
18 As I mentioned earlier, there are
19 approximately 89 -- well, there are 89
20 sites on the NPL, National Priorities
21 List, in New York State. There are about
22 1,200 that have been included on the list
23 across the Country.
24 There really isn't any typical
25 Superfund site per se. As I think I've
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2 probably mentioned to some of you in the
3 past, we've got all sorts of sites with
4 different types of contamination. We have
5 half acre -- sites as small as a half acre
6 down in Long Island. We've got, you know,
.7 landfills that approach 100 acres or
8 more. We've got sites out West that are
9 old mine sites that might even be as large
10 as 200 square miles.
11 The cost for cleaning up a site, also
12 ranges, you know, very widely. On
13 average, a Superfund site costs about 25
14 to 30 million dollars to cleanup.
15 Obviously, some of those may run into the
16 hundreds of millions of dollars, others
17 maybe not, just be in the hundreds of
18 thousands or not cost the State anything
19 at all in terms of the remedial action at
20 the site.
21 In terms of time frame, it is a very
22 long and complex process. It takes, on
23 average, about ten years to move from the
24 investigation phase to the cleanup phase.
25 So it's not a quick process. It's not
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2 like our removal program, but it is a very
3 thorough process, to say the least.
4 Just to give you an idea of the sort
5 of expenditures we've made in New York
6 State. As you can see here, this is a
7 chart that shows expenditures and
8 settlements in New York State through
9 1995. The total is approximately 1.3
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10 billion dollars. Remedial expenditures,
11 i.e., the funds, money that came out of
12 the funds of Superfund that has not been
13 replaced is 400 million. We've had
14 settlements in the amount of over 800
15 million dollars. So the enforcement
16 program has been quite successful and
17 we've been able to get a lot of money in
18 for the State -- for cleanups in the State
19 of New York.
20 As I stated before, the program is a
21 very complex one. I think when Congress
22 originally passed the Law in 1980 there
23 was a feeling that we needed to put
24 something together quickly, that this was
25 not going to be a long-lived program,
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2 might last in the order of a decade. I
3 think they felt the cleanups were going to
4 be a little bit easier, maybe they'd be
5 more contained and we might just go in and
6 put some soil over or cap over sites and
7 • you might be removing a bunch of drums and
8 things like that, but the program has
9 become much more complex. We're really
10 just getting a better feel for it these
11 days. I think in 19 -- the Law was first
12 passed in 1980 in the amount of 1.6
13 billion dollars for a five year period.
14 It was reauthorized in 1986 at a run of
15 about 8.6 billion. So you're looking at
16 close to 1.6 billion a year. So Congress
17 realized how complex the program was, and
18 we're trying to work out the kinks of the
19 program now. We have a bunch of
20 administrative reforms that are helping us
21 move along in the process at this point.
22 And I think that's pretty much all I
23 had to say. I'll turn it over to Maria
24 now, she'll discuss the second operable
25 unit, the groundwater remedy with you, get
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2 into the details of the sampling analysis
3 and various alternatives that we evaluated
4 at the Site.
5 MS. JON: Thank you, Doug.
6 I'm going to begin by giving you a
7 presentation on the background of the
8 Site, the findings of the remedial
9 investigation, the result of the risk
10 assessment, the feasibility study, and
11 then I will discuss and describe all the
12 alternatives that we evaluated and the
13 preferred alternative.
14 Site background. The Carroll and
15 Dubies Superfund Site is located on Canal
16 Street in the City of Port Jervis.
17 This is a map of the Site and the
18 surrounding land. So the shaded area
19 right here represents the Carroll and
20 Dubies Sewage Disposal Site. The Site, as
21 well as the land surrounding the property,
22 is being used for industrial purposes.
23 It's currently being used for that
24 purpose. The City of Port Jervis Landfill
25 is located on the southern portion of the
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2 Carroll and Dubies Site. The landfill is
3 currently inactive; however, it's been
4 used for the -- as a solid waste transfer
5 station. We also have a gravel operation
6 right here. Gold Creek is located 1,500
7 feet downgradient from the Site. The
8 closest groundwater treatment wells
9 downgradient from the Site are located
10 south of Gold Creek. These dots here
11 represent the drinking water wells that we
12 have identified during the investigation.
13 The Neversink River is right here.
14 The Carroll and Dubies Site was used
15 for the disposal of septic and municipal
16 and industrial waste from 1970 to 1979.
17 The waste was disposed of into several
18 unlined lagoons on the Site. The waste
19 which contained hazardous substances were
20 placed on these lagoons on the property.
21 Lagoon one is located here, two,
22 three, four. Five was never used for the
23 disposal of industrial waste. Six and
24 seven and eight are located here. This is
25 a close-up of the Site. And to locate
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2 you, this is the City of Port Jervis
3 Landfill, this is Gold Creek, and the
4 Sewage Disposal Site is up here.
5 EPA placed the Carroll and Dubies
6 Sewage Disposal Superfund Site on the
7 Superfund National Priorities List in
8 February 1990 because hazardous substances
9 were released from the facility. A
10 Consent Order was signed by EPA and the
11 potentially responsible parties in
12 February 1990. The Consent Order required
13 the responsible parties to complete a
14 remedial investigation to determine the
15 nature and the extent of the contamination
16 at the site and to complete the
17 feasibility study to evaluate cleanup
18 alternatives. Both the remedial
19 investigation and the feasibility study
20 have been completed by the responsible
21 parties.
22 Site remediation activities at
23 Superfund sites are sometimes segregated
24 into different phases or operable units so
25 that remediation of different
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2 environmental media can proceed
3 separately. So at this Site EPA has
4 designated two operable units. Operable
5 Unit One, or OU1, addresses the
6 contaminated materials and surrounding
7 soil from Lagoons 1, 2, 3, 4, 6, 7 and 8.
8 Operable Unit Two, or OU2, addresses
9 the contaminated groundwater beneath and
10 downgradient of the Carroll and Dubies
11 Property.
12 Operable Unit 1, which represents the
13 lagoons, are contaminated with heavy
14 metals and organic compounds. A Record of
15 Decision was issued by EPA on March 31,
16 1995. The Record of Decision requires
17 excavation and on-site treatment of
18 approximately 20,000 cubic yards of
19 contaminated materials and soils. The
20 treated material is going to be placed in
21 a lined cell which is going to be built
22 on-site and then it would be capped. The
23 disposal cell will have a leachate
24 collection system, as well as groundwater
25 monitoring.
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2 The remedy for the lagoon is
3 currently in the design phase. We expect
4 implementation of the remedy in 1998.
5 Operable Unit Number 2, which
6 addresses the contaminated groundwater
7 beneath and downgradient of the Carroll
8 and Dubies Site, is going to be the
9 subject of my presentation.
10 The nature and the extent of the
11 groundwater contamination found beneath
12 the Site was assessed through sampling of
13 the groundwater, sediments in Gold Creek,
14 residential wells nearby and through
15 groundwater modeling.
16 The groundwater modeling is like a
17 computer monitor that was used to
18 determine the fate and transport of the
19 groundwater contaminants found at the
20 Site.
21 The groundwater investigation
22 conducted at the Site have identified two
23 aquifers, the shallow and the bedrock
24 aquifer or a deep aquifer.
25 Groundwater beneath the Site flows to
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2 the southeast, in this direction, to Gold
3 Creek.
4 The shallow aquifer is contaminated
5 with organic compounds, mainly volatile
6 organic compounds, chlorinated
7 hydrocarbons. The contaminants that were
8 found include benzene, dichloroethene and
9 tetrachloroethene. These compounds are
10 known to degrade in the environment or in
11 the groundwater under certain conditions,
12 they decompose from toxic to less toxic
13 compounds due to natural occurring
14 microorganisms in the groundwater. The
15 deep aquifer is not contaminated. The
16 highest concentrations in the groundwater
17 were found near the lagoons. These are
18 the lagoons.
19 Two plumes of organic compounds were
20 identified in the groundwater. One plume
21 is emanating from Lagoons 1 and 2, and the
22 other plume is emanating from Lagoon
23 Number 8.
24 The groundwater investigation
25 conducted at the Site have identified at
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the highest levels found near the lagoons
and that the concentrations further
downgradient from the lagoons have
significantly decreased. So the levels
found down here are very low compared to
the levels that were found near the
lagoons, which would give you an
indication that there is some attenuation
or biodegradation of contaminants in the
groundwater.
The sediment sampling conducted in
Gold Creek, the analysis indicates that
the sediments in Gold Creek have not been
impacted by contaminants from the Carroll
and Dubies Site.
The private and residential wells
that are located south of Gold Creek were
also analyzed by the New York State
Department of Health, and the results show
that those wells have not been impacted by
the Site contaminants.
The groundwater modeling conducted as
part of the investigation was to determine
whether the organic contaminants in the
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2 groundwater have stabilized due to
3 biodegradation and also was conducted to
4 estimate the future migration of those
5 contaminants and also the future
6 concentration of those contaminants in the
7 groundwater. The results of the
8 groundwater modeling indicates that there
9 is potential -- there is a potential for
10 the organic contaminants to biodegrade in
11 the groundwater, that the contaminants
12 have not reached Gold Creek, and they are
13 not expected to reach Gold Creek. And
14 also, the modeling results indicate that
15 contaminants in the groundwater would
16 reach drinking water standards five years
17 after the remediation of the lagoons.
18 The risks posed by the Site
19 groundwater. Based upon the groundwater
20 investigation conducted at the Site, a
21 risk assessment was conducted by EPA to
22 estimate the risks associated with current
23 and future Site conditions. The risk
24 assessment estimates the human health and
25 ecological risk posed or that could pose
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by the contaminants in the groundwater if
no remediation were taken. So because
this Site and the land immediately
adjacent to this Site has been zoned
exclusively for industrial use, and future
residential and commercial use of the
property is not expected to occur, we in
the risk assessment, we only assume
industrial use of the property. So on the
current industrial use there is no --
there are no current groundwater users at
this Site, therefore, no current human
health risks associated with the
contaminated groundwater at the Site.
However, there is a future risk for an
on-site industrial worker who could drink
contaminated at the Site if the
groundwater drinking water well would be
installed on the property and the risk was
estimated to be one in 10,000. Which is
within EPA's acceptable risk range. There
are some assumptions that were used to
estimate the future risk for an industrial
worker drinking contaminated groundwater
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2 were the following: That a future
3 industrial worker would drink one liter a
4 day of contaminated water for five days a
5 week, for 50 weeks a year, for 25 years
6 out of a 70 year lifetime.
7 The risk assessment also concluded
8 that there is no risk to ecological
9 receptors in Gold Creek, because the
10 contaminants have not reached Gold Creek
11 and they're not expected to reach Gold
12 Creek.
13 Remedial Action Objectives. Remedial
14 action objectives are goals to protect
15 human health and the environment. The
16 goals for cleaning up the Site are to
17 minimize or eliminate potential health
18 risks posed by drinking contaminated
19 groundwater by a potential future
20 industrial worker, and to reduce the
21 concentration of contaminants in the
22 groundwater to drinking water standards.
23 Four cleanup alternatives were
24 evaluated in the feasibility study to meet
25 the remedial objectives that have been
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previously described. These alternatives
are Alternative 1, which is no action;
Alternative 2, which is natural
attenuation; Alternative 3, which is
groundwater pump and treat; Alternative 4,
which is in situ groundwater treatment. I
will briefly discuss each one of these.
For Alternatives 2, 3 and 4
institutional controls and groundwater
monitoring will be required for these
three alternatives. For all the
alternatives a review every five years
would be required by EPA so that that
would assure that the remedy that would be
selected for the Site continues to be
protective.
So under the Alternative 1, no
action, the Superfund Program requires
that the no action alternative be
considered as a baseline for comparison
with other alternatives. Under this
alternative no action will be taken to
address the contaminated groundwater.
Although groundwater monitoring as
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2 indicated the contaminants in the
3 groundwater will reach drinking water
4 standards due to natural biodegradation of
5 the contaminants in the groundwater, there
6 would be no monitoring of the groundwater
7 to measure the rate of reduction of these
8 organic contaminants in the groundwater
9 and there would be no institutional
10 controls to prevent the use of the
11 contaminated groundwater. There is no
12 cost associated with Alternative
13 Number 1.
14 Alternative Number 2 is natural
15 attenuation. Alternative Number 2 would
16 rely solely on natural attenuation to
17 reduce the organic contaminants in the
18 groundwater to drinking water standards.
19 The groundwater monitoring results
20 indicate that after remediation of the
21 lagoons, the levels in the groundwater
22 would reach drinking water standards in
23 approximately five years after remediation
24 of the lagoons. The remediation of the
25 lagoons will remove the sources of the
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2 groundwater contamination and will
3 eliminate any additional contribution of
4 contaminants in the groundwater.
5 Groundwater monitoring will be conducted
6 under this alternative to measure
7 improvements in groundwater quality.
8 Institutional controls to prevent the
9 installation of groundwater wells and the
10 use of contaminated groundwater throughout
11 the entire Site would be required, as well
12 as sediment sampling in Gold Creek. The
13 estimated cost associated under -- with
14 Alternative 2 is approximately $284,000,
15 and it will take about six months to
16 implement.
17 Alternative Number 3, which is
18 groundwater pump and treat. This
19 alternative consists of using recovery
20 wells to extract contaminated
21 groundwater. Approximately six recovery
22 wells will be placed on the Site, they
23 will be placed immediately downgradient of
24 the lagoons. These are the approximate
25 locations. Three under Lagoons 1 and 2
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2 and 3 downgradient of Lagoon Number 8. At
3 this location the recovery wells will
4 capture the most contaminated portion of
5 the groundwater. The portion of the
6 contaminated groundwater that's not going
7 to be captured by these recovery wells
8 will be left to attenuate naturally. This
9 alternative includes groundwater
10 monitoring to measure or to evaluate
11 effectiveness of the groundwater system
12 and also institutional controls similar to
13 those that I have discussed under
14 Alternative Number 2. The groundwater
15 pump and treat system would continue to
16 operate until the levels of organic
17 contaminants in the groundwater reached
18 drinking water standards, and from the
19 groundwater modeling that was conducted at
20 the Site that to reach drinking water
21 standards was estimated to be
22 approximately five years.
23 Under Alternative 3, the estimated
24 cost is 2.1 million dollars and it would
25 take nine months to implement.
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2 Alternative Number 4, which is in
3 situ or in place groundwater treatment.
4 This alternative consists of injecting air
5 into the contaminated groundwater through
6 a series of injection wells.
7 Approximately 30 injection wells would be
8 used to treat the contaminants in the
9 groundwater, they would be placed
10 immediately downgradient of the lagoons.
11 These circles represent clusters of air
12 injection wells. These wells would treat
13 the most contaminated portion of the
14 plume, and the portion of the plume that's
15 not going to be captured or treated by the
16 air treatment system would be left --
17 would be attenuated naturally. The
18 organic contaminants in the groundwater
19 would be reduced by transferring
20 contaminants from the groundwater to the
21 air. A soil air venting system would be
22 installed in the subsurface to capture any
23 air emissions and the air emissions would
24 be treated on-site. Groundwater
25 monitoring would be required in order to
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2 measure the effectiveness of the air
3 treatment system. Institutional controls
4 similar to those I have discussed on the
5 Alternatives 2 and 3, as well as the
6 groundwater monitoring, would be required
7 under Alternative 4. The estimated cost
8 for Alternative Number 4 would be 1.9
9 million dollars, and it would take about
10 12 months to implement.
11 Regarding Alternative Number 3, the
12 groundwater pump and treat system remedy,
13 the extracted groundwater that would be
14 collected from the recovery wells would be
15 treated on-site and then would be
16 discharged to Gold Creek in accordance
17 with the State and Federal Requirements,
18 which I forget to mention before.
19 There are nine criteria that we use
20 to evaluate remedial alternatives. These
21 criteria are divided into three different
22 sets, and they are the threshold criteria,
23 which includes the overall protection of
24 human health and the environment, and
25 compliance with environmental
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2 regulations.
3 The second set, which are the primary
4 balancing criteria, are long-term
5 effectiveness and permanence, reduction of
6 toxicity, mobility or volume through
7 treatment, short-term effectiveness,
8 implementability, and cost.
9 And the last set is the modifying
10 criteria; State acceptance and community
11 acceptance.
12 Based upon these evaluation criteria,
13 EPA's preferred alternative is Alternative
14 Number 2, which is natural attenuation
15 with institutional controls and
16 groundwater monitoring.
17 Alternative 2 consists of several
18 actions to address the groundwater
19 contamination beneath and downgradient of
20 the Carroll and Dubies Sewage Disposal
21 Site. This remedy relies on natural
22 attenuation of the organic contaminants to
23 reduce the contaminants in the groundwater
24 to levels below drinking water standards.
25 The length of time that was estimated
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2 that the groundwater would reach drinking
3 water standards, it's about --it was to
4 be about five years, following
5 implementation of the lagoon remedy. The
6 lagoon remedy would remove the source of
7 the groundwater contamination at the Site,
8 therefore, they would -- there's not going
9 to be any contaminant contribution from
10 the lagoons to the groundwater.
11 So as far as this remedy, groundwater
12 monitoring would be required to measure
13 improvement in groundwater quality,
14 institutional controls to prevent the
15 installation of groundwater wells, and the
16 use of the contaminated groundwater
17 throughout the entire plume would be
18 required, sediment sampling in Gold Creek
19 to ensure that contaminants have not
20 reached Gold Creek would be implemented.
21 Also, since the contaminants would remain
22 on the Site, EPA would review the remedy
23 within five years to ensure that the
t
24 remedy continues to be protected. If the
25 monitoring data shows that there is not
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2 improvement in groundwater quality within
3 the five year period, EPA will determine
4 the need to implement or evaluate cleanup
5 alternatives for groundwater remediation
6 at the Site.
7 The rationale for proposing
8 Alternative 2 as the preferred alternative
9 are it reduces risk to human health and
10 environment, it minimizes impact of
11 remedial activities on community, uses
12 permanent solutions, and it is
13 cost-effective.
14 This concludes my presentation. What
15 I have just discussed is just an overview
16 of the results of the remedial
17 investigation, the feasibility study, EPA
18 preferred alternative, and the rationale
19 for selecting the preferred alternative.
20 The proposed plan, which we provided
21 • here, provides a more detailed description
22 of the preferred alternative.
23 The Deerpark Town Hall has copies of
24 the Feasibility Study and the Remedial
25 Investigation Reports for your review if
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2 you would like to see --to find out more
3 information about the findings of all the
4 studies and investigation that have been
5 conducted at the Site.
6 The comment period extends through
7 September 27th, all written comments
8 should be provided to EPA to the address
9 that's presented in the proposed plan.
10 We are open for questions, and any
11 comments.
12 MS. LONEY: I'm going to request that
13 you step forward so you can speak in the
14 microphone clearly and that the
15 stenographer can get it clear and can hear
16 your question clearly. I'm also going to
17 ask that you state your name prior to
18 asking your question, so the stenographer
19 can also keep a record of who asked what.
20 Yes?
21 MS. HODSON: I'm Frances Hodson.
22 When I first read this report,
23 there's language in it that I thought was
24 difficult if this is for the general
25 public. Say the word attenuation, would
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2 you please describe what attenuation
3 means.
4 MS. ROSS: Natural attenuation --
5 there's a glossary on the back of the
6 handout that you have. I'm just going to
7 read it first and then I'll describe it.
8 Natural attenuation is a process where
9 groundwater is cleaned up by relying on
10 natural processes. Examples of these
11 natural processes are; intrinsic
12 biodegradation, dilution (dispersion), and
13 adsorption. There are several other
14 processes, but they're real minor in this
15 case.
16 So intrinsic biodegradation is one
17 that was discussed in this instance, and
18 I'll read again my glossary. It's soil
19 and groundwater contain many naturally
20 occurring microorganisms, such as
21 bacteria, which can use the contaminants
22 as a food source, naturally decreasing the
23 contamination and forming simpler
24 compounds, eventually leading to carbon
25 dioxide and water.
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2 MS. HODSON: Thank you.
3 MS. LONEY: Does it answer your
4 question?
5 MS. HODSON: Yes, it does. I looked
6 it up in the dictionary, but you don't get
7 as good a description, and I'm a very
8 ordinary citizen, I'm not a scientist, so
9 I needed that.
10 Now, institutional controls. What
11 institution is going to be doing the
12 controlling?
13 MR. GARBARINI: When you get into
14 institutional controls, it's a very
15 difficult thing to try and explain, but
16 there are a number of different mechanisms
17 that you can use. And as far as who would
18 be implementing those institutional
19 controls, typically what we try and do is
20 get the responsible parties, as I
21 mentioned earlier, potentially responsible
22 parties, responsible for the contamination
23 at the Site to implement those
24 institutional controls. And typically
25 what we try and do is lay that out with a
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2 consent order with them and ask them to
3 follow-up, often it requires -- if you go
4 off the property and the responsible
5 parties no longer own the property, it
6 requires some coordination with town
7 officials and with the property owners.
8 So, for instance, in this case we're
9 not saying exactly how we would implement
10 the institutional controls, but we would
11 probably restrict use of groundwater at
12 the Site perhaps with some sort of deed
13 restrictions, and EPA also has mechanisms
14 whereby we can -- it's very, very legal,
15 you get into real estate law and other
16 things whereby we can actually try and
17 enforce some of these institutional
18 controls. What we do, we can give you a
19 more detailed answer in your
20 Responsiveness Summary. We have an
21 attorney actually write up a more detailed
22 response to your question.
23 MS. HUDSON: All right. Thank you.
24 MR. GARBARINI: You're welcome.
25 MS. LONEY: I'm going to ask that
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2 anyone and everyone who has any questions,
3 you can just lineup here, that way you can
4 kind of expedite it rather quickly.
5 MR. MAYFIELD: Hi. My name is
6 Richard Mayfield from Congressman Oilman's
7 office.
8 I'd like to thank the EPA for this
9 opportunity for this public comment period
10 and recognizing the relative infancy of
11 environmental science and every site being
12 unique of course.
13 Can you point to some sites for us or
14 some past history that this proposal that
15 you're doing will be successful, so five
16 years down the road we don't have to come
17 back and revisit this and say, gee,
18 fellows, we spent "X" amount of dollars
19 and we're no better off than we were five
20 years ago? Thank you.
21 MR. GARBARINI: Thank you. I guess a
22 major portion of this remedy really relies
23 on the remedy that we selected for the
24 lagoons last year and the effectiveness of
25 that remedy, but there are a number of
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2 other sites out there where we have
3 actually gone out and cleaned up sources
4 and sources of contamination. So as soon
5 as you remove that source of contamination
6 to the groundwater, you will see some
7 improvements in the groundwater.
8 And the other alternative really is
9 to try and aggressively cleanup the
10 groundwater, go out there with a pump and
11 treat system, which is not necessarily a
12 very efficient system.
13 At this Site here we are seeing that
14 the level of contamination dropped
15 dramatically from just below the lagoons
16 further downgradient of the Site just
17 before Gold Creek. So we are very
18 confident that once we get the source out
19 of there, we'll start to see some
20 significant improvements in groundwater
21 quality. We had our -- our experts out
22 in Oklahoma, folks that actually are very
23 good with groundwater modeling and looking
24 at biodegradation and things like that,
25 they reviewed all the modeling here and
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2 data that we had for the Site and they
3 also felt confident that some
4 biodegradation was going on and that the
5 modeling results, as predicted -- there's
6 always -- when you're dealing with
7 modeling, you never know exactly how
8 things are going to turn out, but they
9 were pretty confident with the effort that
10 was conducted here.
11 MR. DECKER: Wayne Decker.
12 You mentioned that the contaminants
13 are significantly decreasing in the
14 monitoring wells as the wells are further
15 from the lagoon sites. On those wells
L6 that are furthest from the lagoon sites,
L7 are the levels approaching safe levels?
L8 Are they still considered hazardous levels
19 that are found there now? Do you have any
JO numbers on that? And besides just giving
51 me numbers, I don't know what the numbers
12 mean unless I know what the ranges are,
!3 unless you can sort of indicate.
:4 MS. ROSS: Just in general, right
:5 near the lagoons our chief contaminant is
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2 . benzene, and benzene is in the thousands
3 of ppb right adjacent to the lagoon, and
4 at our furthest downgradient wells, which
5 are just north of Gold Creek, the benzene
6 is either non-detect or about
7 approximately 10 ppb. So we're seeing two
8 orders of magnitude decrease in that 1,500
9 feet. So they're either at or below mcl's
10 or just above mcl's in that ar'ea.
11 MS. LONEY: What's ppb?
12 MS. ROSS: Oh, ppb is parts per
13 billion.
14 MR. DECKER: What's allowable in
15 drinking water?
16 MS. ROSS: 0.7 is the State
17 standard. Federal standard is 5.
18 MR. DECKER: Five what was that?
19 MS. ROSS: Five ppb's below standard.
20 MR. GARBARINI: Just to add to that,
21 so if people were actually drinking that
22 water, I mean no one is currently drinking
23 the water and we don't anticipate that
24 people will be drinking it in the near
25 future, but as an added measure of safety
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you would have the institutional controls
also just to make sure it didn't happen.
MR. DECKER: While I'm trying to
figure out numbers, we've got this
mythical industrial worker who's drinking
water five days a week, and I believe you
said the risk is 1 in 10,000 and that is
within the acceptable range. Again, what
is the acceptable range if it's 1 in
10,001 I'm not too happy about that, if.
it's 1 and not much more than 10,000, is
it significant?
MR. GARBARINI: Yeah, the acceptable
risk range -- there was a little bit of
discussion of what is acceptable in the
proposed plan, but for carcinogens it is
1 in 10,000 to 1 in 10,000,000. That's
our acceptable risk range. So what we saw
here was 1 in 10,000, so we were right at
the acceptable risk range. Again, the
assumptions are that someone would be
exposed to the water for twenty-five
years, five days a week, drinking a liter
a day, which are some pretty conservative
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2 assumptions.
3 MR. DECKER: I guess my comment would
4 be that it seems like this approach is
5 conservative along with the rest of your
6 thinking there. And what concerns me is
7 that since it is related to the success of
8 the lagoons being cleaned up in a timely
9 manner, that if in fact we see any delays
10 in that process, this five year window,
11 which begins upon the completion of the
12 lagoons, is going be to stretching out
13 further and further, and a couple of the
14 other alternatives that were mentioned
15 seemed to have much shorter periods of
16 time for effectiveness, unless I wasn't
17 . understanding those numbers right.
18 MR. GARBARINI: That's a little
19 confusing actually. If I could respond.
20 MR. DECKER: Sure.
21 MR. GARBARINI: I think you might be
22 talking about the time to implement, Maria
23 had mentioned some time frames before;
24 nine months, twelve months.
25 MR. DECKER: Right. Right.
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2 . MR. GARBARINI: That doesn't include
3 such things as negotiating with
4 potentially responsible parties to do the
5 work, the design phase of the process,
6 actually going out and bidding or trying
7 to get a contractor on board to do the
8 construction work. That really looks at,
9 okay, we've got a contractor on board, now
10 you need to go back out and construct the
11 unit. So in one instance, say the
12 groundwater pump and treat would take us
13 12 months to go out there and lay all the
14 pipe work, construct the unit, start
15 operating it, shake is down, make sure
16 it's operating effectively, and then after
17 that, the model projects that it can still
18 be about five years before -- after the
19 cleanup, until you achieve the same
20 levels, but obviously if you're taking an
21 aggressive approach, you'll probably going
22 to clean it up a little bit quicker, but
23 the modeling is showing that it wouldn't
24 be that much quicker.
25 MR. DECKER: Thank you. These people
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2 have all gotten mad at me before, so...
3 Just my last one is that you
4 mentioned that there were no site-related
5 contaminants found in any of the test
6 wells and any of the neighboring water
7 wells and the stream. And I'm just
8 wondering if there were any
9 non-site-related contaminants that we
10 ought to be aware of.
11 MR. GARBARINI: Actually, I think I'm
12 going to pass that question along to Tim
13 Vickerson of the Department of Health.
14 DOH actually conducted the sampling of
15 those wells.
16 MR. VICKERSON: Yeah, my name is Tim
17 Vickerson, New York State Health
18 Department.
19 My agency has been involved in
20 sampling a few of those residential wells
21 in that area as of a couple years ago.
22 Bottom line is I don't recall seeing any
23 non-site related contaminants, as well as
24 any site-related contaminants in those
25 wells. I don't have the results with me
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2 tonight, but as far as I recall, I don't
3 remember seeing anything else in there.
4 MR. DECKER: Thank you.
5 MR. PINES: Larry Pines.
6 I was wondering why no mention was
7 made of EPA's own invention by John Wilson
8 of biodegradation, what you call
9 co-metabolism, the use of oxygen in a foam
.0 medium made of surfactant and purified
.1 water pumped into the ground to increase
.2 the activity of the bio-organisms.
.3 And I'm also wondering, on another
.4 issue, that the lagoon, as you talk about
.S in your information here, that you got
.6 20,000 cubic yards got to be contained, I
.7 guess that means it's gonna be --
:8 MR. GARBARINI: Treated.
L9 MR. PINES: Treated?
>0 MR. GARBARINI: Treated and
21 contained.
12 MR. PINES: Treated as in how;
23 water?
24 MR. GARBARINI: I guess I'll take
25 your second question and respond to that,
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2 since it's fresh in ray mind and before I
3 forget.
4 The Operable Unit 1 remedy that was
5 selected last March called for basically
6 the handling of 20,000 cubic yards of
7 material, some of those are contaminated
8 with inorganic compounds, they would have
9 to be stabilized prior to being placed in
10 a Part 360 or cell, the cell that was
11 Maria was talking about, others have or
12 organic contamination. We think we're
13 going to be treating those via a
14 bioslurry, using bugs basically. And
15 other materials will be below our
16 treatment levels that were specified so
17 they would not have to be treated via
18 either mechanism, but they're high enough
19 that they would have to go into the cell.
20 MR. PINES: What about the heavy
21 metals you talked about?
22 MR. GARBARINI: The heavy metals
23 would be stabilized if they exceed
24 the --
25 MR. PINES: HOW?
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2 MR. GARBARINI: The actual types of
3 materials that would be used for the
4 stabilization process? Those have not
5 been selected yet, but there are a number
6 of different types that are out there.
7 MR. PINES: Yeah, I know.
8 MR. GARBARINI: If you're interested,
9 when we start approaching the phase where
10 we're going to be -- a lot of those are
11 proprietary too, so it gets touchy, but we
12 can keep you up-to-date on where we think
13 we're headed on that.
14 MR. PINES: It's just that I know of
15 a. person at Ohio State or Penn State who
16 developed a system by taking phosphates to
17 so call stabilize lead in the soil to make
L8 it say non-hazardous if consumed, that the
L9 body -- won't be absorbed into the blood
20 stream, and also work done by somebody, I
>1 don't know if it's EPA or whose it is, but
12 there's some work down at Liberty State
'.3 Park in New Jersey where they use
14 sunflowers and actual mustard plant to
:5 absorb chromium and lead out of the soil
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2 and it stays inside the root system, which
3 can be disposed whichever way you want,
4 but it leaves the soil clean apparently.
5 MR. GARBARINI: Yes, I've heard of
6 the latter. I know it's been used in some
7 ' of the Eastern block countries too, it's
8 been quite effective. I think typically,
9 like you said, to use a foam medium to try
10 and absorb the contaminants, but we'll
11 take note of your comments here and Maria
12 will be handling the design, so I'm sure
13 she'll keep it in mind.
14 MR. PINES: Okay. Thanks.
15 MS. ROSS: About the co-metabolism,
16 you had said --
17 MR. PINES: Yes.
18 MS. ROSS: -- why we're using the
19 intrinsic bioremediation, just using the
20 natural biological population, and not
21 adding to it, not adding surgots or any
22 additional things, but that is another
23 technique that's used. But John Wilson of
24 the U.S. EPA Lab Ada endorses intrinsic
25 bioremediation.
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2 And I'm just going to add this, do
3 you feel that you need that to achieve
4 your goal? Right now we believe the Site
5 conditions are such that we can do this
6 without adding anything at this time.
7 MR. PINES: Are these the same people
8 at Ada that told me when I was in Oklahoma
9 City that the high levels of chemicals in
10 the water system at Norman were not a
11 danger?
12 MS. ROSS: Probably not.
13 MR. PINES: I ended up in the
14 hospital and I lost my job with the postal
15 service because of it. I'm just wondering
16 if those were the same people that say
17 it's relatively safe.
18 MS. ROSS: Probably not.
19 MR. PINES: I hope not.
20 MR. STEIN: Thank you for your
21 presentation so far. My name is Eric
22 Stein. I represent the Deerpark Planning
23 Board.
24 And I'd like to get a little bit
25 clearer line on your time line, basically
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2 for the public. You've got the OU1
3 system, which is the containment and the
4 treatment of the tanks for the lagoons,
5 and you've got the OU2 , which is the
6 groundwater section. Now, you keep
7 referring to five years of OU2 before it's
8 drinkable and that's, I'm assuming, after
9 the lagoons have been completely treated
10 and contained; right?
11 And I'd like to know approximately
12 how long or what kind of an estimate you
13 expect that it would take from, you know,
14 working it out with the PRP's, finding out
15 the resolutions, determining the chemicals
16 you expect to use for treating the heavy
17 metals, containing the lagoons and then
18 adding five years? Can you give me a time
19 line, effective time line? Saying that we
20 started working it out with the PRP's
21 today.
22 MR. GARBARINI: Okay. Actually,
23 we're a little bit ahead of that because
24 we signed the Record of Decision for the
25 source control last March.
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2 MR. STEIN: Right.
3 MR. GARBARINI: And we' had
4 negotiations with the responsible parties,
5 with a couple of the responsible parties,
6 last year. We were not able to come to
7 terms on consent and we did issue them an
8 Order at the end of September of last year
•
9 and they complied with the Order and they
10 have submitted a work plan to us for the
11 remedial design, which Maria has already
12 taken a look at and commented on, as has
13 the State of New York and other entities
14 within EPA. So --
15 MR. STEIN: So we have a year or so
16 into it already?
17 MR. GARBARINI: Yeah. We're already
18 into the process.
19 MR. STEIN: But we haven't started
20 any treatment or building?
21 MR. GARBARINI: That's correct. So
22 basically what we have is we have a work
23 plan that will allow us to now start to
24 proceed.with the design and the remedy,
>5 and there probably will be some testing
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2 that goes on before we actually figure out
3 exactly what types of materials we're
4 going to be using, what kind of slurry is
5 going to work. But the long and short of
6 it is, is that we should have that design
7 complete by the end of 1997, beginning
8 part of '98.
9 MR. STEIN: Okay.
10 MR. GARBARINI: And then I'd say it
11 would probably take a year.
12 MR. STEIN: Okay. So at the end of
13 '98 you said?
14 MR. GARBARINI: Beginning of 19 --
15 yes, end of '98 say for the --
1.6 MR. STEIN: The end of '98 you'd be
17 ready to implement the actual treatment
18 and construction activities?
19 MR. GARBARINI: The beginning of '98
20 we probably will be ready to implement,
21 and it would take a year from there I
22 would say.
23 MR. STEIN: A year after that OU1
24 would be complete?
25 MR. GARBARINI: Yes. In the
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2 meantime, what we'd probably -- we'd
3 probably be excavating and staging
4 material as they're being treated and
5 whatnot. So taking them -- hopefully
6 we'll be taking them out as we're building
7 the cells. Some of the materials are
8 going to have to go because we have to
9 build a new cell for them, so they're
10 going to have to be staged in certain
11 areas and things like that. So hopefully
12 the impacts to the groundwater will be
13 elevated to a certain extent before we
14 actually finish all the treatment and
15 place the materials in the cell and
16 capping the cell.
17 MR. STEIN: So we've got '98, '99 for
18 the finish of the lagoon section?
19 MR. GARBARINI: I would say
20 hopefully -- hopefully we get the work
21 done in the construction season of 1998
22 and be done by the end of 1998. That
23 would be my hope.
24 MR. STEIN: Optimum scenario.
25 MR. GARBARINI: Yes, if we don't have
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2 any problems, that's right.
3 MR. STEIN: And then another
4 additional five years after that. So
5 we're talking 2004, 2005 for --
6 MR. GARBARINI: 2004, 2005, yes. But
7 you have to remember that the modeling
8 shows that you really need to get in there
9 and remove the source before any of the
10 remedies that we looked at are going to do
11 much good.
12 MR. STEIN: Yes, of course. It's
13 very understandable why OU1 and OU2 are
L4 connected and correlated.
L5 I had another question about the
16 actual retainment, the actual treatment
17 and the containment for the materials from
L8 the lagoons. Could you briefly explain
.9 what that's going to be.
10 MR. GARBARINI: Okay. It's going to
11 be consistent with New York State Part
:2 360, the 360 Landfill Requirements, which
:3 include clay and probably some synthetic
4 liner, leachate collection. And I don't
5 know, Maria, do you have anymore details
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2 that you can add to that?
3 It would be consistent with the
4 current landfill requirements for the
5 State of New York Part 360.
6 MS. JON: Right, it's going to be a
7 . composite layer of clay, soil, compacted
8 soil at the bottom and then a high density
9 polyethylene liner will be placed beneath,
10 before the true material gets placed on
11 the cell, and it's going to have a
12 leachate collective system and will
13 collect any liquid that might possibly be
14 generated overtime and then a cap is going
15 to be placed, also made of composite layer
16 of clay and soil and gravel. This is
17 going to be about three feet -- thickness
18 of three feet the cover's going to be, so
19 that would be consistent with the State
20 Regulations.
21 MR. STEIN: And these are the
22 guidelines of the landfill State Law 360?
23 MS. JON: That's correct, for solid
24 waste landfills.
25 MR. GARBARINI: Yes. And the Law
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2 also allows for some variation in terms of
3 the materials that you use, but it would
4 be consistent. You know, typically the
5 materials that Maria was describing are
6 the types of material that are typically
7 used.
8 MR. STEIN: Landfills are a favorite
9 subject around here.
10 MR. GARBARINI: I can imagine.
11 .MR. STEIN: Thank you very much.
12 MR. GARBARINI: You're welcome.
13 Thank you.
14 MR. BERKMAN: I'm Jeffrey Berkman.
15 I'm here representing Assemblyman Jake
16 Gunther, and thank you for the
17 presentation.
18 I have a question of process. If
19 there's a disagreement by the possible
20 responsible parties, does EPA go ahead and
21 do the work and then discuss how it's
22 going to be paid for later or do you wait
23 to have that all lined up first before you
24 do the work?
25 MR. GARBARINI: Typically what we do,
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2 the process that we use in most cases, at
3 least when we get to the design phase, is
4 we'll issue letters to the responsible
5 parties requesting that they perform the
6 cleanup or pay for the cleanup. We then
7 ask them to give us a good faith offer, if
8 they're willing to do that, if they want
9 to do that, they'll give us a good faith
10 offer and we'll sit down and negotiate
11 terms of the agreement with us and then
12 they would implement the remedy.
13 If they decide that they don't want
14 to negotiate with us or if they negotiate
15 with us and then say, listen, we don't
16 have a deal here, what we can do is issue
17 an Order to them, order them to timely do
18 the work. They can chose to comply with
19 the Order or not comply with the Order.
20 If they don't comply with the Order, we
21 would actually fund the additional work
22 and then go after them later on for the
23 cost of the cleanup.
24 In the case of the first, the
25 operable unit with the lagoon remedy, the
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2 PRP's are implementing that remedy.
3 MR. BERKMAN: They agreed?
4 MR. GARBARINI: They sat down and
5 negotiated with us and we were unable to
6 reach an agreement on consent, but we did
7 issue them an Order and they choose to
8 comply with it, and they have been
9 conducting the work in good faith. They
10 also did the remedial investigation under
11 . Administrative Order on Consent. So they
12 consented to do all this study work.
13 MR. BERKMAN: I'm not sure how many
14 documents you dropped off at Town Hall,
15 Deerpark Town Hall. Is it like one of
16 those large books there?
17 A VOICE: It's one of these.
18 MR. BERKMAN: It is just one of these
19 documents that I have?
20 MR. GARBARINI: This should also be
21 in the repository, but that provides a
22 summary of everything that's been done.
23 MR. BECKMAN: I was going to suggest
24 at least this, I don't know about those,
25 but some of these copies you might
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I consider dropping them off in the Port
} Jervis Free Library, which also is part of
i Deerpark, part of their library district,
5 and it might be convenient for people that
6 live in Deerpark, if they work in Port
7 Jervis, they might have the opportunity to
8 review the documents in Port Jervis and
9 also might be interested for people in
0 Port Jervis and Middletown and other
1 people who might be interested as well, so
2 if you have two sites for information, it
3 might be helpful.
.4 MR. GARBARINI: Okay. Yes, we'll do
.5 that.
.6 MR. BECKMAN: Thank you. And lastly,
.7 I was hoping the State Official, after you
.8 review the documents, I was hoping you
19 could write a letter to Senator Gunther
>0 stating that it's your belief that none of
El the wells in the vicinity have any
22 contaminants. I think that's what you
23 said. I don't want to put words in your
24 mouth. But could you please write a
25 letter on that, so that when we get
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> constituents asking about that, we can
} always refer to your letter.
I MR. VICKERSON: I will.
5 MS. LONEY: I just want to make sure
5 I understand, you're requesting that there
7 be an additional repository? We have two
8 existing repositories; one at Deerpark
9 Town Hall and the other at the Port Jervis
0 Public Library.
1 MR. BECKMAN: You do have the Public
2 Library?
.3 MS. LONEY: Yes, there are two.
4 MR. BECKMAN: I didn't hear him state
.5 that in the beginning.'
.€ MS. LONEY: There's a copy of it
.7 there, if you need copies of this
18 document. This was handed out and mailed
19 out. It should, in fact, I believe, in
20 that document it may in fact list the
21 repositories where they're located.
22 MR. BECKMAN: If you have it at the
23 Port Jervis Library, that's great.
24 MS. LONEY: Yes.
25 MR. BECKMAN: Thank you.
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2 MS. LATINI: I'm Louise Latini. I
3 live at Vans Beach in the Town of
4 Deerpark, Port Jervis, New York.
5 I was here two years ago for this
6 meeting. What is the condition of the
7 situation up there now since two years
8 ago? Has there been testing at those
9 points to see if anything has decreased
10 naturally?
11 MS. LONEY: When you say points,
12 what do you mean?
13 MS. LATINI: Up there at the --at
14 the dump.
15 MS. LONEY: Okay. You mean the
16 specific wells that they were testing?
17 MS. LATINI: Yes, were they tested
18 since two years ago, and I want to know
19 what the results are.
20 MR. GARBARINI: Okay. I'll respond
21 to that, and Linda can correct me or Maria
22 can correct me if I'm not accurate with
23 what I'm saying.
24 As I mentioned before, we really
25 aren't going to see .any real significant
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results until we remove the source, but in
t terms of what we have seen, the
I groundwater testing that was done up there
was sort of done in phases; we went out
with one stream of wells, then we went out
j ..further with another stream of wells, and
} then further with another stream of wells,
) and so the first couple of runs of
) sampling didn't include the furthest
L wells, so we can't really compare or say
2 the first round of sampling -- we can't
3 compare four rounds of sampling to wells
| that are further off. But the wells from
J5 the lagoon, the results were pretty
6 similar from round to round. When we
i
start to move away from the lagoons we see
a very big decrease in the level of
contamination and we don't think that the
contaminants are really migrating all that
far before they're naturally attenuating,
I being eaten by the bugs that are out
I there, so to speak. So we haven't really
been able to document a real decrease say
in one given well of contamination, but we
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expect to see that once we remove the
source.
MS. LATINI: Okay. I have another
question. Two years ago when I was here I
requested to have my well checked by the
State. They did come down on
September 12th, 1994. 1 received the
report November 22, 1994. There was a man
here asking if the wells are
contaminated. I do have some in mine.
They say it's under the New York State
i Regulations, but it is in my water. Says
I it's okay to drink, but it's there. You
can't say that they're free. This
gentleman here signed this letter that I
l got. Everything is written here, the
5 amounts and what they are, in three pages
) that I have. I do not understand it. All
) I know is what they're telling me, is that
L it's below the standards. What I'm asking
I for tonight, I already spoke to him. I
3 want another test done. I cannot afford
i to go to Orange County Department of
5 Health. I have my water checked for
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several things once a year, but not all
these chemicals because I couldn't afford
4 it. So I feel that I want to ask tonight
5 again to have this test done, and I will
match them up what I had two years ago to
see if there's any changes, then I will
8 know myself if the natural way is the best
J way to go. As far as I was told years
0 ago, the sand does not take out these
I/
>:1 chemicals, you have to use something to
j2 get rid of 'em, they're just not going to
|3 go naturally. That's why I asked you what
i!4 the difference was in two year's time,
I
what was found two years ago and now two
6 years later or one year, however you test
i\7 them, there should be a change. And I'm
18 very much interested in getting this done
r
9 again on my water so that I can see for
i
,0 myself how the tests are coming. If it's
1 decreasing, fine. If it's increasing then
12 it's not too good.
MR. VICKERSON: Yeah, I'd just like
!4 to say that most of those samples, nearly
i1
is all of them were metals, we tested for
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metals, and there were -- can't call them
contaminants, but they're naturally
occurring elements, that if you go test
the gravel you're going to find naturally
occurring metals. You know, in some areas
of New York State you find them at higher
levels than others, but they're not really
contaminants, they're naturally occurring
in the ground.
I'd like to elaborate a little bit on
what Doug said about the outer stream of
monitoring wells that you have coming out
of the Site. Those wells will be acting
as a sort of a sentinel or guard, if you
will, for contaminants that have the
potential to migrate in the direction of
residential wells which are even further,
so if we start to see any trends or if we
even start to see any detection at all on
those wells, that would be an indication
to me to get out there and get some more
private well samples.
And I encourage anybody else, if you
live out in that area, Maria had a map up
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2 that showed all those tiny little
3 triangles, there's quite a few of them out
I there, if you're really concerned about it
5 and you're really lost, get us out there
5 and get a sample, so let me know. I guess
7 this is a good opportunity, I'll give you
B my 800 number: 1-800-458-1158,
9 Extension 305. And I'll give that again,
D it's 1-800-458-1158, Extension 305. Thank
1 you.
2 MR. GARBARINI: Yes, I'd just like to
3 reiterate what Tim had said, I have public
4 water from my town and I have a lot of
5 iron magnesium in mine, it stains the
6 bathtub and it's a pain to scrub off, but
7 those are naturally occurring. Metals are
8 naturally occurring, so you would expect
9 to see some of those in your water.
0 MS. LATINI: What's in mine is metals
1 plus these contaminants. You can look at
2 this.
3 MR. GARBARINI: I'm sure Tim will.
4 MS. LATINI: Not natural.
5 MR. VICKERSON: See me after.
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2 MR. GARBARINI: Sounds like he's
3 willing to get another sample for you.
4 Maybe you can see Tim after.
5 MS. SADANIANI: Kathy Sadaniani.
6 My question is very similar to
7 Louise's. I was just wondering what was
8 the date say of the last sampling of the
9 sediment sampling of Gold Creek or of the
0 last -- this last band of contingency
1 wells? If anybody knows, what was your
2 last date. Are you the one who does --
3 MR. VICKERSON: I guess I could
4 answer part of that. The last sample I
5 got was March of '95.
6 As far as the groundwater wells, I'm
7 not sure, so I'll leave it to Doug.
8 MR. GARBARINI: I think, if you do
9 not mind, we'll take a little bit of time
0 and look through our document and get back
1 to you later on in the meeting about when
2 things were last sampled. EPA actually
:3 went out there with our own staff in July
:4 to sample some of the monitoring wells.
:5 MS. SADANIANI: This July?
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2 MR. GARBARINI: This July, this year,
.3 to take a look at some of the inorganic
4 contaminants there. Before that, in terms
5 of groundwater, I think our last sampling
6 that was done was spring of '95.
7 MS. JON: September '95.
8 MR. GARBARINI: Was it September?
. 9 That might be when we had the results come
10 in.
11 MS. JON: Yes, you're right.
12 MR. GARBARINI: Sometime between the
13 spring and September of 1995. So spring
14 or summer.
15 The Creek sediment sampling, we're
16 going to take a look at the documents and
17 see if we can get that information for
18 you. That probably was done I think in
19 '94. I'm not sure, but we'll try and
20 figure it out for you.
21 MS. SADANIANI: And if it doesn't get
22 to the Creek, then the people on the south
23 of that are clear; is that correct? So
24 the Creek would be your way of saying, and
25 that has not been done since '94,
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supposedly?
J MR. GARBARINI: Well, the Creek, as
I well -- we're really more concerned about
what's showing up in the monitoring wells
then the Creek. I think the Creek
provides us with the indication that it's
a good sign that nothing has shown up in
the Creek and it's worthwhile to continue
) to monitor that, but what we're really
L concerned about is the monitoring wells
themselves.
J MS. SADANIANI: Okay. But it's over
I a year since they were done, the last
band, but that was negligible?
MR. GARBARINI: That's right.
MS. SADANIANI: A year ago.
MR. GARBARINI: That'8 right.
MS. SADANIANI: Over a year ago.
) MR. GARBARINI: Yeah, sometime
L between spring and summer of last year,
aside from the wells we sampled this
i summer for inorganic chemicals.
L MS. SADANIANI: So you have no idea
of what the situation is in that last band
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2 of wells right now?
3 MR.. GARBARINI: No, I think --
4 MS. SADANIANI: You know, I'm
5 bringing this up because we live south of
6 the Creek. There's three cancer cases in
7 ten houses. That to me is a hell of a lot
8 of cancer in ten houses, that I'm shocked
9 to see the map to see where we live. I'm
10 shocked.
.1 MR. GARBARINI: Have you had your
.2 well tested by the Department of Health?
.3 MS. SADANIANI: No, we were not, none
.4 of us were tested.
.5 MR. GARBARINI: I can understand your
6 concern. It's hard not to be concerned
7 about it.
8 MS. SADANIANI: It blew our mind
9 tonight.
0 MR. GARBARINI: Right. But yet you
1 have to understand, we look at the history
2 of the disposal at the Site, we look at
3 the wells, how it's confined in the wells,
4 I mean, the sort of nasty stuff, if you
5 recall, that was disposed of a number of
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2 years ago, probably in the '70's, so you
3 would expect if that was migrating
4 off-site, you would expect probably to see
5 something in that last string of wells.
6 MS. SADANIANI: Right.
7 MR. GARBARINI: And we haven't seen
8 anything over the last few years in those
9 wells, so we really believe that these
10 natural processes are taking care of
11 things.
12 MS. SADANIANI: Taking care of
13 things.
14 MR. GARBARINI: But we will continue
15 to monitor. We have semiannual monitoring
16 in the remedy. But in the meantime, just
17 to put yourself at a little bit more ease,
18 I suggest that you call Tim and try and
19 get your well sampled.
20 MS. JON: Just to give you an idea,
21 the most -- the most furthest monitoring
22 wells are located here. This is the Site,
23 and Gold Creek is right here. So the
24 levels that we found in the monitoring
25 wells around here were either at the
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drinking water standards or slightly,
slightly, above the drinking water
standards.
MR. PEILL: Arthur Peill.
I'd just be grateful if somebody on
the panel here could remind us of who the
responsible parties to the Consent Order
are.
MR. GARBARINI: Okay. We have a
series of PRP's at the Site. Some of them
had signed on to do work or given us
notice of intent to comply and others were
noticed and are not preforming the work.
I'm just going to read from the list right
here. We have, first of all, Carroll and
Dubies Sewage Disposal, the owners of the
property, and we have Kolmar Laboratories
and Wickhen Products. They were both
companies that had waste that were
provided to disposers or transporters that
were eventually dumped at the Site. We
also had Reynolds Metals. EPA signed a
settlement, what's called a De Minimis
Settlement, with Reynolds last year and it
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was finalized this year. Basically what
that says is they were a small contributor
to the contamination at the Site and
because of that they played, so to speak,
a much more -- a much smaller role, a
minor role than the other PRP's, therefore
we signed a De Minimus Settlement with
them. So they basically signed off, paid
us some money and they're out of the
picture unless we find some additional
contamination or evidence in the future
that said they were a larger player in the
contamination of the Site. And we have
one other party, that is the City of Port
Jervis. Now, Kolmar and Wickhens, they
»
both signed an Administrative Order on
Consent to conduct the remedial
investigation, and they were also the
responsible parties that gave us notice of
intent to comply with our order to perform
the remedial action.
MR. PEILL: Thank you.
MR. GARBARINI: You're welcome.
MR. CARROLL: My name is Carroll,
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2 Carroll and Dubies.
3 In the paper this morning I read
4 where you're concerned about two
5 and-a-half acres of land adjoining the
6 landfill, the Port Jervis Landfill. Who
7 owns those two and-a-half acres?
8 MR. GARBARINI: What was the
9 reference again? I'm not sure of the
0 reference you're speaking of.
1 MR. CARROLL: In the paper today it
2 was stated that you're concerned about two
3 and-a-half acres of land adjoining the
4 Port Jervis Landfill, two and-a-half acres
5 joining the Port Jervis landfill. Who
6 owns those two and-a-half acres?
7 MR. GARBARINI: Is the question
8 you're trying to get out is who owns the
9 land under which the lagoons --
0 MR. CARROLL: Who owns -- you're
1 concerned with two and-a-half acres.
2 MR. GARBARINI: I'm not sure of the
3 reference that you're talking about that
4 we're concerned with two and-a-half acres,
5 but we are concerned about the property
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that you own, the property that the City
of Port Jervis owns.
MR. CARROLL: I want to clarify.
MR. GARBARINI: I'd have to see the
article before I can respond to your
question. I'm not sure what context that
two and-a-half acres was placed in.
MR. CARROLL: Look, I say that the
land that you're referring to is
contaminated ground is the City of Port
Jervis Landfill, not Carroll and Dubies.
We paid the City of Port Jervis to dump in
the Port Jervis Landfill. And something
that's not used anymore, common sense, we
have 32 acres and we have stuff to dump,
where would you dump it? Would you dump
it on your own land or would you dump it
in the Port Jervis Landfill? You're
talking about five to ten percent of
contaminated ground. I know where the
other 90 is, right in the center of the
Port Jervis Landfill, and I know because I
was there.
MR. GARBARINI: Well, all I can tell
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you right now is that the center of our
J attention, as we described over the last
I years, is the lagoons, that's what we're
focusing on cleaning up.
MR. CARROLL: Yeah, I know, but --
7 MR. GARBARINI: Some of those lagoons
3 are located on the City of Port Jervis
3 property, I agree with you.
3 MR. CARROLL: Those that you are
L really concerned with are a part of Port
I Jervis Landfill, in fact the whole thing
3 is. Our land hasn't been touched. Our
i land is pristine.
MR. GARBARINI: I guess that's
5 debateable, but I don't want to debate you
7 about it right at this point in time.
3 MR. CARROLL: You know why, I'll tell
you what you would do, you know, clarify
D the ownership. Who owns it?
L MR. GARBARINI: The City of Port
2 Jervis owns some of the property in which
3 the lagoons are located and you own some
4 of the property also.
MR. CARROLL: No, no. The City of
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I Port Jervis owns it all.
MR. GARBARINI: I'll go back and
check with our attorneys.
MR. CARROLL: All right. All right.
Check it out.
MR. GARBARINI: But regardless, as I
I mentioned earlier in my discussion, we had
) four different types of potentially
i responsible parties, and one of those are
operators of a facility where waste was
disposed, another is a transporter of
waste, so in either instance you are
still --
MR. CARROLL: Absolutely.
MR. GARBARINI: -- considered to be a
responsible party.
MR. CARROLL: You know what, I'm
willing to come here and tell you that
you're concerned about ten percent, we
dumped 90 percent on the City of Port
Jervis Landfill, right'in the middle.
MR. GARBARINI: We're not responsible
for the City of Port Jervis Landfill.
MR. CARROLL: If you can get the
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price up to six or seven million on two
and-a-half acres, what are you going to do
with the City of Port Jervis Landfill.
That will run into the billions.
MR. GARBARINI: From what I
understand, that needs to be closed
properly under the New York State
Municipal Landfill Closure, --
MR. CARROLL: What you should do - -
MR. GARBARINI: -- and that's where
it's being handled.
MR. CARROLL: What you should do
first is find out who owns what. And
Carroll and Dubies does not own the land
that you're concerned about. You can
check that out.
MR. GARBARINI: Thank you.
MR. JARVIES: My name is Jack
Jarvies. I live in Huguenot. I have a
couple questions.
First of all, the last of the
material that was dumped in there was in
'79, it's now 17 years old. The material
hasn't reached your test wells, your
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2 farthest wells.
3 You also state here if no action is
4 taken there, within five more years the
5 groundwater should meet the State drinking
6 standards. I don't understand why you
7 picked option two if after 17 years that
8 material hasn't reached the wells, and if
9 it's not there now with the material
0 naturally degrading, the logic is that
1 it's never going to reach there. So now
2 we're going to spend taxpayer dollars for
3 $284,000 for what purpose? Why do you
4 recommend number two? What's the
5 difference or what is your projection,
€ because even under number two you'll say
7 it takes five years to meet the
8 groundwater standards. It doesn't -- your
9 whole presentation here doesn't make
0 sense, whether it's no action,
1 Alternative 2 or 3, and four I don't see a
2 number on. Thank you.
3 MR. GARBARINI: I have to agree with
4 your description, the very reason why we
5 did go with Alternative Number 2, the
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2 waste has been there for at least 17
3 years. We aren't seeing it in that last
4 string of wells in any significant
5 quantities, that is a good sign, it's
6 telling us that in fact the material that
7 has gotten into the groundwater is
8 probably naturally degrading, but we've
9 got a number of other people in the
0 audience that are concerned that the
1 contamination might somehow spread. So
2 what we need to do, to be responsible
3 public officials, is to actually sample
4 the wells to make sure this isn't in fact
5 happening and nothing unusual happens in
6 the next few years. It's not necessarily
7 going to be a taxpayer dollars, we're
8 hoping that the responsible parties will
9 pickup the tab. And providing people with
0 the level of comfort is something we need
1 to give them.
2 MR. JARVIES: I don't care what
3 company pays for it, the insurance company
i pays for it. It's eventually coming out
5 of our pocket, increased cost.
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2 The other item is your logic doesn't
3 follow. If you already have those wells,
4 if you continue to monitor them and
5 nothing happens, why spend money? I know
6 you're just paying for your existence.
7 This is one of my problems with DEC. For
8 example, if you go to Alternative 2, it
9 might be two years before you even start
0 any action, by the time you draw up all
1 your plans, that's two of the five years
2 it's going to take to happen naturally. I
3 do not understand your reasoning. Thank
i you.
MR. GARBARINI: Part of what you're
mentioning there, in fact we do have these
7 monitor wells in place, we're going to be
3 monitoring them anyway, the $284,000
includes those costs in monitoring.
MR. JARVIES: But not in Option 2.
MR. GARBARINI: In Option 2 it does
include those costs, it also includes some
other costs that probably are not quite as
significant as those monitoring costs, and
those are costs related to other types of
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2 monitoring that we may not typically do,
3 like looking at the number of bugs, so to
4 speak, or bacteria that are in the
5 groundwater, things like that we wouldn't
5 typically do in a monitoring program. And
7 the only other thing that might be related
3 to it would be some small costs associated
9 with institutional controls.
3 Just to reiterate, it is a
L significant amount of money, but it's not
I significant when it brings the level of
comfort that's going to be required here.
MS. HODSON: And I'm just asking
these questions because I only have a
little knowledge of things.
I see these three organic compounds,
I and is this whole thing just about these
I three organic compounds, all this, because
I there's pages and pages of chemicals that
were in this dump and so there's so many
parts per billion of this, so many parts
per billion of that, but don't they all
add up to something harmful to the
people? I do not understand why you're
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just talking about these three organic
I compounds alone.
I MR. GARBARINI: You're right, there
were a whole lot of different types of
chemicals that were found in the lagoons.
i Basically when we go through our process,
5 we look at all those different compounds
and we pick the ones out that are the most
significant, either in terms of
concentration or risk or the two put
together, in coming up --
\ MS. HODSON: You know, add them all
I up.
MR. GARBARINI: Those are all added
up when we do the risk assessment. What
1 we're trying to say is that in the
I proposed plan, this little plan that we
> have here, we're really just focused on
three or four contaminants because those
are the big factors, in this case they're
the most toxic and also found in the
; highest levels. If we want to include
I everything, we'd have to go back to this
large document that we were pointing out
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2 before. So we simmer the information
3 down. It doesn't mean that it isn't all
4 factored into our risk assessment in all
5 this.
6 MS. HODSON: Thank you.
7 MS. SOMARELLI: My name is Viola
8 Somarelli. I have just one question.
9 Does the -- is the EPA an after the
0 fact agency with the Superfund and so
1 forth? I mean, do you monitor these
2 places, all these polluters, any time at
3 all or just after the fact? Thank you.
4 MR. GARBARINI: Thank you. That's a
5 good question.
6 Back around the time when a lot of
7 these different hazardous waste sites were
8 popping up, obviously it became known that
9 there is a greater need to control what
0 was being disposed of out in the
1 environment, and there is another law,
2 which isn't the Superfund Law, but it's
3 closely associated with it, which is
4 called the Resource Conservation and
5 Recovery Act. And basically what this Act
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2 was intended to do was to basically trap
3 waste from the time they were generated to
4 the time they were ultimately disposed,
5 treated, whatnot, basically the term
6 that's used is from cradle to grave. So
7 there's a whole lot of manifesting that
8 goes on when someone wants to
9 manufacture. Operating under this Law if
0 he wants to dispose of some waste, he
1 needs to have a transporter that manifests
2 the waste being taken from his site and
3 then brought ultimately to a licensed or
4 permitted facility that's able to handle
5 these types of wastes. That manufacturer
6 then signs when the wastes are dropped off
7 and these facilities are inspected and
3 whatnot.
9 MS. SOMARELLI: Well, one note to
0 that is that there's a hazardous -- well,
I hazardous material, benzene, was in the
2 soil, and it's adjacent to our home, the
3 plant. They have been now -- we were
1 told, by the people who owned it at that
5 time, big business, of course, that in six
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months -- they were running this big
vacuum machine taking the benzene out of
the soil, running it on their property.
They said in six months we'll have it all
cleaned up, that's five years ago and
they're still running it, so how long is
this going to take.
MR. GARBARINI: I'm not sure whether
they actually removed the source of
contamination there, but if they didn't,
that could be why it's taking so long.
j MS. SOMARELLI: It's taking so long.
I MR. GARBARINI: Where is this
located?
5 MS. SOMARELLI: Pardon?
7 MR. GARBARINI: Where was this? This
8 is in another town.
9 MS. SOMARELLI: No, it's right in
0 Deerpark.
1 MR. GARBARINI: Oh, it's in Deerpark.
2 MS. SOMARELLI: And right now -- it
3 was the Dow Chemical Company, before that
4 it was the Wickhen Company. Now it's
5 Summit Research, which I'm sure is a
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Proceedings
branch of Dow Corning.
MR. GARBARINI: Right. Well, when it
comes to groundwater remediation it's a
very complex field, and I think the key
here for us is to get the materials out of
l the ground and treat them.
5 MS. SOMARELLI: I hope it doesn't
take as long as they did with that small
) spill or whatever it was.
L MR. GARBARINI: I hope not either.
MS. JON: I just wanted to add that
\ the regulations that Doug just discussed
I. about that all generators have to manifest
the waste from where they originate to
where they're disposed of, that regulation
? came up to prevent sites like the
) Superfund sites to be created again. So
) those regulations are there to prevent
) sites like this to occur.
L MR. LATINI: My name is Louis M.
Latini. I live in Vans Beach, Port
J Jervis, New York.
L You could almost hit a golf ball
close to where I live to the Port Jervis
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2 School District. You put up a map or an
) overlay before of the local wetlands,
I peoples' wells. Could you put that up and
then overlay this map over the map of it,
please.
7 MS. LONEY: It won't work. They're
3 two different --
MR. LATINI: Put the local map up
D also. Now, the Site is on this side right
L here; correct?
2 _N MS. JON: The immediate area, right,
3 that's where the lagoons are.
MR. LATINI: Okay. So you basically
5 tested all the wells from like Evergreen
5 Lane, Orchard Lane, just north of us, by
7 the Illet School?
B MS. LONEY: This is where they were.
9 Here's Gold Creek.
D MR. LATINI: All right.
1 MS. LONEY: Okay.
2 MR. LATINI: Here, Gold Creek goes
3 through there. That's there. That's Gold
4 Creek.
5 MS. LONEY: They're two different --
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Proceedings
you can see they're two different scales,
it won't work.
And this is Gold Creek.
MR. LATINI: And basically, the last
time these wells were tested is basically
1995 or 1994?
I MR. VICKERSON: That's correct.
) MR. LATINI: 1994.
) MR. VICKERSON: 1994. Saw them in
L 1995.
> MR. LATINI: And the last time these
3 wells were tested was when?
I MS. JON: April '95.
5 MR. LATINI: And that was it?
6 MS. JON: April '95 for the organic
7 compounds. For the metals, the last time
8 they were tested was July, July '96.
9 MR. LATINI: July '96.
0 MS. JON: For metals.
1 MR. LATINI: Is there any way I can
2 get a photocopy of this?
3 MS. LONEY: It will be in the
4 repository.
;5 MS. JON: Let me see if I have it.
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2 MR. LATINI: I would appreciate it,
3 if possible. Thank you.
4 MS. LONEY: . What we'll do is the
5 handouts that were given out this evening
6 will be -- photocopies will be made
7 • available and they will be placed in both
8 repositories, so you can take a look at
9 not only the handouts that were given, but
0 the presentation as well.
1 Are there any other questions?
2 MS. HODSON: You referred to
3 institutional controls, all these very
4 interesting words. The perpetrators of
5 the crime, like Carroll and Dubies,
6 Wickhen, Dow Corning and all the others,
7 maybe not Carroll and Dubies, but
8 certainly the big firms knew what they
9 were doing and what chemicals they were
0 letting go and go into the ground. Now,
1 this whole area, I have a list of 25
2 companies, all along 209 for about five
3 miles, that are all polluting companies.
4 They're all gasoline, metals, all kinds of
5 contaminations. There's lagoons where
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2 only septic waste is to be put, but of
3 course the local gossip is that the
4 sanitation company has stock pills of
5 sludge, so they'll make a little
6 cocktail. I called the DEC and I cannot
7 get them to check one of the trucks going
8 through.
9 Now, the DEC also gave a permit to
.0 the Sky Dime Corporation. They're located
.1 right on the Delaware River. They are
.2 permitted to put I believe it's either
.3 chromium or cadmium -- I believe it's
.4 chromium -- into the sewage system, but
L5 the allowance they received wasn't enough
L6 for them, so they cheated a little and put
L7 plenty more, and they were setup for a
L8 $250,000 fine. Do you think they paid
19 it? Can I find out? Because as that
20 gentleman says, it all ends up in the end
21 with the consumer, the local resident,
22 footing the bills for these things, and
23 not only that, that chromium was going
24 into the Port Jervis Sewage Treatment
25 Plant. The local people here, we have our
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2 own systems, they're on-site, our wells
3 and our septics. The Port Jervis Sewage
4 System is owned by the City of New York.
5 Now, they're permitting people to dump
6 that stuff into the sewer system, it's not
7 cleaned as tox -- it's not a third -- a
8 tertiary sewage treatment plant, it goes
9 right into the Delaware, their drinking
10 water. That they don't bother with, but
LI they just made a lovely agreement that
12 they're going to pull more water out of
L3 this area to satisfy the needs of New York
L4 ' City.
L5 I live on the Neversink River. I can
L.6 walk across that river and not get my
L7 knees wet, and that was once a famous
L8 trout stream until they put the damn up in
19 1955. It's ruined as a food source. It's
10 being ruined as a recreation source. What
21 are we being left with?
12 And institutional controls do not
53 exist, even the DEC is guilty of giving
54 anyone a license to put that kind of stuff
!5 into a sewage treatment plant.
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2 MS. LONEY: I'm not sure what exactly
3 your question is for the panel, ma'am.
4 MS. HODSON: Well, when you describe
5 removing toxic chemicals and heavy metals
6 with biodegradable bacteria, considering
7 how old the earth is, I wonder how come
8 there's any lead left. How come there's
9 any mercury left. Wouldn't they have
.0 gobbled it up in all these ages, in the
.1 ions of the earth's existence? I don't
.2 know. I can't -- I can't accept that.
.3 MR. GARBARINI: Now, just to put it
.4 simply in terms of the bugs, so to speak,
.5 bacteria and all that, what it comes to
.6 what the bugs like to eat, they're just
.7 like the rest of it, you know, if you're
.8 growing plants or whatever, you have to
.9 have the right conditions in order for the
50 plants to consume the food correctly and
51 for us to consume the food correctly, so
52 it really does depend upon the conditions
53 that the bacteria face.
>4 You have raised a number of other
55 issues that are concerns you have there
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2 regarding things that were sort of outside
3 the scope of this meeting, but if you have
4 some additional concerns and you'd like
5 the EPA to take a look into them, feel
6 free to put them in writing and we'll
7 respond to them in the appropriate
8 division, if they're able to.
9 MS. LATINI: I have one final
LO question.
LI This plan that you're going to put
L2 into implement here in this Site, has this
L3 been used any place in the United States?
L4 MR. GARBARINI: Yes.
15 MS. LATINI: When and how and did it
16 cleanup what it was supposed to do and how
17 long did it take?
18 MR. GARBARINI: I'm not sure whether
L9 you're referring to the Operable Unit 1 or
JO Operable Unit 2.
>1 MS. LATINI: The one that you have
>2 already planned to put into effect.
>3 MR. GARBARINI: For the treatment of
»4 the soils and lagoon materials?
>5 MS. LATINI: The number two plan.
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2 MR. GARBARINI: The one that we're
3 discussing tonight about the groundwater?
4 MS. LATINI: Yes.
5 MR. GARBARINI: Yes, that has been
6 chosen at a number of different Superfund
7 sites as a remedy, and we can give you
8 details as to the names of those sites and
9 things like that when we put our
LO Responsiveness Summary together.
11 MS. LATINI: It has been implemented
12 and it's proven that it cleared these
13 chemicals up out of the Site?
14 MR. GARBARINI: Yes. Again, it
15 depends upon the level of contamination
16 that you're looking at, but it has been
17 proven effective in different sites around
18 the Country.
19 MS. LATINI: And they've checked them
20 now after a couple years to see if there's
21 anything left there? That's what I want
22 to know. When they did it, if they did it
23 ten years ago, and if they're doing checks
24 now and it's still there, then it didn't
25 do its job.
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2 MR. GARBARINI: Yes, there are a lot
3 of --. when you're talking about these
4 things, everything is very, very site
5 specific when you're talking about
6 biodegradation, but if you want, we can
7 give you a list of other sites where it's
8 been implemented, both Superfund sites and
9 ' sites that aren't Superfund sites that
10 have had other similar .contaminants.
11 MS. LATINI: Because if it doesn't
12 work, it's just a waste of money and time.
.13 MR. GARBARINI: That's right. Let me
14 pass this over to Linda who has got a lot
15 more background in this area.
16 MS. ROSS: One of the previous
17 speakers talked about John Wilson, and
18 John Wilson's an expert in this particular
19 field of bacteria, of degrading compounds
20 and cleaning up sites. And when this
21 first started there was a lot of jet fuel
22 spilled on actual military bases, and he
23 focused his study on that, and it really
24 does cleanup benzene quite remarkably
25 under the right conditions and it's proven
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2 and is very well documented. We will •
3 provide more references on that with the
4 Responsiveness Summary.
5 MS. LATINI: Thank you.
6 MS. LONEY: Are there any further
7 questions?
8 . (No response given.)
9 MS. LONEY: All right then. I just
10 want to encourage all of you who may have
11 additional questions, you can contact
12 Maria Jon, she's the Remedial Project
13 Manager, and we also are encouraging you
14 to submit written comments to us.
15 The closing date, again, for
16 submission of your comments is
17 September 27th. So you get your written
18 comments in to us. They are taken quite
19 seriously and read and taken into
20 consideration. So I'm going to thank all
21 of you once again for coming out, and I
22 wish you all a safe trip home. Thank you
23 so much.
24 oOo
25
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2
3
4
5
6
7
8
9
10
12
13
14
15
16
17
18
19
20
21
22
23
24
25
THE FOREGOING IS CERTIFIED to be
a true and correct transcription of the
original stenographic minutes to the best
of my ability.
UJl
.,
Jacqueline Maloney, CSR
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Appendix E ;
Letters Submitted During the Public Comment Period
26
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/• nance.4. $. Hudson
HCK 608 Ave. 6
September 25, 1996
Maria Jon, Project Manager
U.S. Environmental Protection Agency
200 Broadway, 20th Floor
New York, New York looo?-!866 \
Rei Carroll & Dubies
Dear Ms. Jom
I moved to Godeffroy from Nassau County in I9b3. I have lived
in Nassau over 3° years and contaminated water fupplies necessitated
the closing of 33 welJs on Long Island. Naturally the public be-
came very conscious of the importance of a clean water supply. When
I read about the Carroll & Dubies Site I recognized it as a big
problem.
When I read the announcement about the Public Meeting on September
llth, and read the report I took out ray file to review the past
public hearings. My first shock was EPA's Alternative #l' which
was to do nothing. How could you, as professionals, even suggest
leaving a.community with no remedial action to protect us, your
fellow Americans? Only a few thousand feet downgrade if the Port
Jervis School Complex which has over 1,000 students, as well as
a bus garage, custodial, maintenance, groundsmen, cafeterias
workers .Plus the professional staff - probably boo people. The
school was built in 1968, In 199^ lead was in the drinking water
and it was blamed on pipes. Adjacent to the school are junkyards,
retail auto salesrooms with repair shops on the southside.
On the upriver side is a milk farm and the smell of cow manure
drifted over to the bus garage.. This is just a little description
of the school site and environs.
As for the people of our area. We are a low income area. Wages
go from the minimum to about $8.uo at the acid battery plant.
You can check with the Department of Health for cancer and res-
peritory illnesses. You should check on birth defects too.
You, as a federal agency can also get the figures on the mentally
deficient and physically handicapped children in the schools
and medical facilities in Orange County.
I was shocked that the Mayor of Port Jervis was absent and that
there was no representative present with a statement. I was also
shocked that our Supervisor* Mr. Robert Cunningham, was absent
but a Councilman, Mr. Robert Zeller, was present as an observer
to report back to the Town Board,
Our very beautiful valley has many hidden dangers in addition to
the toxics released into the Neversink, streams and ground.
-------
We have a heavy inversion each morning which rises and then
is dispersed. Naturally, the toxins in the air rise up and are
part of the air we breathe. Respiratory problems are common.
A foul environment produces a sick population.
I love this valley for its beauty. I am 78 years old and will
be content to end my days here. However, I was lucky and eng'oyed
good health. I I was very concerned with a healthy lifestyle
and ray two daughters, my seven grandchildren and two great rrand-
children are fine healthy people who can enjoy living a full life.
A foul environment will preclude raising healthy children.
Please take all these considerations into your decision making
process. The Town of Deerpark and the City of Port Jervis need
the best possible remediation. The burden our residents carry
must be lightened.
:ou are trained as environmentalists and I urge you to do the
right thing and select #4- as the alternative remedy for the
sad state of affairs this area is in.
Sincerely yours,
Frances Hodson
HCR 60 B
Godeffroy, New York 12739
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» I
New York State Department of Environmental Conservation
60 Wolf Road. Albany, New York 12233-0001
Henry G. Williams
Commissioner
August. 8, 1984
Ms. Francis Hodson
HCR Box 60 B
Godeffroy, New York 12739
Dear Ms. Hodsor.:
Governor Cucmo has requested that this Department reply to your letter
of July 9, 1984.
The State of New York does have a long standing active program for
controlling the injection of contaminants into our grouiidwaters. The State
Pollutant Discharge Elimination System (SPDES) has regulated discharges to
ground and surface waters of New York State since the system became law on
September 1, 1973.
Under the SPDES system all discharges of industrial type waste to
grcuncwaters are required to have a SPDSS permit. Standards for such
discharges are provided by Part 703 of New YOrk State' s official
ccnpliation of codes, rules, ar.d regulations. The water quality standards
and discharge standards contained in Parr 703 (attached) are quite
restrictive in controlling a wide variety of toxic pollutants.
Currently, about 300 industries that discharge to groundwater are
regulated under SPDES permits. For most of these facilities, pollution
abatement systems have long since been in place. Thus, much has been done
to prevent further contamination of our groundwater resources by industrial
discharges.
However, despite the successful ijiplementation oi the SPDES program as
it relates to groundwater dischargers, the protection of our groundwater
supplies frcm toxic chtznicals still presents a major challenge for the
following reasons:
1. An effective survellience and enforcement program for such
discharges requires a great deal of time and manpower and
resources:
a. The overwhelming majority of industrial groundwater .
dischargers are in Nassau and Suffolk Counties and the
majority of these coiisist of small operations. Our
experience has been that the list of Industrie.- groundwater
-------
dischargers changes by an astonishing 25% per year due to
new industries coming into existence, existing industries
proving or going out of business, and facilities which change
ownership.
Thus, administrative tracking of these dischargers alone is
a complicated arid demanding task.
b. A subsurface discharge by its very nature is invisible.
Thus, spills, whether accidental or otherwise, may go
unnoticed or unreported. Only frequent inspections and
sampling by the Department can serve as an effective check
on the data which industries are required to report by their
permits.
2. The SPDES permit program does not apply to toxics leaching out of
old landfills and other abandoned waste disposal sites. These
sites must be investigated and cleaned up through appropriate
enforcement action.
From the forgoing one can see that the protection of groundwater from
toxic industrial chemicals is a difficult and demanding task. However,
this Department has provided strong and effective controls for industrial
discharges to the extent possible with the resources available.
Thank you for your interest in this matter, if there are any further
questions or information needed please contact this office directly at
(518) 457-1067.
Very truly yours,
J_
t(c(• •->-<•£>?-
•> i -
Anthony F. Adamczyk, P.E.
Director
Bureau of Wastewater Facilities Design
cc: Commissioner Williams
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.Citizen's Clearinghouse for Hazardous Wastes
Center for Environmental Justice
Sewage SIudge...A Dangerous Fertilizer
By Stephen Lester. CCHW Science Director
The land application of municipal waste-
water sludge is fast becoming a major
toxics issue. Hundreds of mostly rural
communities are suddenly being targeted
for "land fanning" of sludge. In some
communities like Wise County. Virginia.
authorities want to reclaim strip mined
land by filling it with sludge. Other com-
munities such as those in the Texas pan-
handle, those in Prowers and Kiowa coun-
ties in Colorado, and those in eastern Penn-
sylvania have become targeted for sludge
generated in New York City.
What is spurring this latest craze? Its
simple. A ban on ocean dumping went
into effect on July 1, 1992 sending many
coastal cities like New York scrambling to
find a way to get rid of their sludge. But
sludge is also generated by every commu-
nity that operates a wastewater treatment
plant. Sludge is the end product of "clean-
ing" waste water and disposal of this sludge
is extremely complicated and difficult.
The theory behind the land fanning of
sludge is to spread the sludge over farm
land to allow the chemicals in the sludge to
either dilute into local groundwaters and/
or evaporate in to the air. This method does
little more than transfer the chemicals in
the sludge to groundwater and into the air
and. therefore, is an inappropriate and
poor method of "disposal" for sludge thai
contains toxic and hazardous chemicals.
Twenty years ago, when EPA Tint consid-
ered the idea of land fanning sludge, there
was some merit to the concept primarily
because the constituents in sludge were
mostly heavy metals. One could make the
argument that some of these substances
could serve as "nutrients" or fertilizer in
some instances. In some circles, support
for this idea has grown to the point where
some believe that land farming is the ideal
solution, '"an environmentalist's dream
come uue—waste becomes a resource."
Unfortunately this view is naive and unre-
alistic. While in theory, if there were few
or no toxic substances present in sludge, it
would be possible to land farm it safely.
But as a practical matter this situation
simply does not exist. All sludge contains
large amounts of organic chemicals, heavy
metals and pathogens.
This toxiciry is the result of many small
(and some large) businesses that dump
their toxic waste into municipal sewage
lines. Every study that has tested for
organic chemicals in sludge has found
them, lots of them. One landmark study by
the American Society of Civil Engineers
clearly identified a significant number of
toxic organic chemicals that are typically
found in sewage sludge including PCBs,
pesticides and many chlorinated com-
pounds (see What's in Sludge, p. 9).
Dr. Donald Lisk from Cornell University's
College of Agriculture and Life Sciences
estimates that typically 100-200 compa-
nies will flush their waste into a single
treatment plant and that literally thousands
of chemicals may be present in a single
sludge sample. In addition, newly formed
toxic substances are created as waste prod-
ucts break down in sludge.
Dr. Stanford Tackett of Indiana Univer-
sity of Pennsylvania describes sludge as
being "closer to the definition of a toxic
• waste than it is to fertilizer." in testimony
. before the Pennsylvania House of Repre-
fSentatives. Dr. Tackett. who has studied
'the effects of lead on soil and groundwater
j for 25 years, warned that "one application
\ of sludge adds more lead to the soil than
idid SO years of using leaded gasoline" and
''that once sludge is applied, the soil can
\ never be recovered.
Land farming sludge poses a number of
threats. The most prominent risk is to
groundwater that passes through the sludge.
•"As rain falls on sludge, many organic
chemicals are pulled into the groundwater ~
as are heavy metals. According to Dr.
Tackett, "All lead does not stay immobi-
lized in soil as claimed." Some of it always:
moves from the soil to groundwater "rela- j
lively quickly." People depending on this
groundwater for drinking or for livestock
use and to water crops are at increased risk
of exposure to toxic chemicals. "~
Another threat is air emissions. Airpollut-
ants are generated when volatile chemi-
cals evaporate from sludge and when
sludge-treated soil dries out and is carried
away as dust. Thtse pollutants pose health
risks to people living downwind.
The most common concern raised about
the land farming of sludge is the impact on
crops grown on the sludge-treated soil.
EPA has set standards that limit theamoum
of heavy metals and PCBs that can be
applied to soil. These standards address
the ability of crops to absorb chemicals
when sludge is used as a nutrient or fertil-
izer. They do not address sludge as a
disposal alternative and the potential health
and environmental impacts of groundwa-
ter contamination, air emissions or the
ingestion of contaminated soil by cattle or
other grazing animals. The absorption of
chemicals by crops is important but it is
not the only issue needing attention and
regulation.
A critical issue that has received little
attention is the presence of organic chemi-
cals in sludge. Few studies address the
health risks these components pose and
there is little test data on the extent of these
contaminants in the sludge. Federal regu-
lations also fail to address their impact.
Unless sludge is tested for these substances.
the health and environmental risks will
remain unknown. Make sure any sludge
coming into your community is tested for
organic chemicals.
Con't oa next ptgc
October, 1992
Everyone's Backyard
-------
Center for Environmental Justice
Citizen's Clearinghouse for Hazardous Wastes
Another concern thai cannot be ignored is
the track record of land farming sludge.
There is little long-term experience. There
are success stories and horror stories. For
example. EPA originally allowed sludge
with over 100 mg cadmium per kg soil to
be given to farmers and gardeners. These
sludges had high zinc to cadmium ratios
causing high crop uptake of cadmium.
EPA was unaware of this factor until it was
too late. Now crops grown in these areas
cannot be used and the soil needs to be
cleaned up.
In Oklahoma, nine horses died and 113
others developed liver problems eating
hay grown on land fertilized with sewage
sludge and in Bloomington, Indiana. PCB-
rich sludge was mistakenly given to gar-
deners and farmers. Problems like these
prompted the Del Monte and Heinz cor-
porations to ban the use of sludge on any
land used for growing their food crops.
EPA has been very slow to address this
issue and is reluctant to even identify sludge
treated sites that need to be cleaned up.
Despite these realities, some environmen-
tal groups, including the Environmental
Defense Fund, believe there can be "ben-
eficial" uses of sludge. They argue that if
toxic substances are minimized or. better
still, eliminated from the waste scream.
then sludge would be "clean" and could be
used as nutrient or fertilizer.
Theoretically, it's possible to create
"cleaner" sludge by passing toxic use re-
duction laws to limit chemicals discharged
into sewage lines and to pretreat sludge to
reduce contaminants. Some day this may
be achieved, and we should strive towards
this, but at this time, let's be clear, there is
no such thing as "clean sludge."
Dr. Lisk agrees. He commented. "The
concept of 'well engineered' sludg&is a
myth. There is no sound scientific oasis
for limiting levels of potential toxicants in
sludge since we do not know the identity
of most of them. Even if both of these
problems didn't exist, it is extremely un-
likely that any feasible monitoring and
enforcement program could ensure that
application regulations are met."
In the end. whether a community wants to
land farm sludge is a local decision that
should be made by the people who will be
directly affected. No one has the right to
say that land farming sludge is good for
another community. The impacted com-
munity must be given both sides of the
story, so they can decide for themselves
what risks they are willing to accept. How
can community people be expected to ac-
cept land farming sludge if the expert's
can't agree if sludge is safe?
Resources:
"LandFarmingSludge:AFactPack." CCHW.
1992. A compilation ofnewsclips. articles and
scientific papers on what's in sludge and how
communities have been dealing with this issue.
Available from CCHW for S5.9J.
"Land Application of V/astewater." A Report
of the Land Application Committee of the
American Society of Civil Engineers. 1987.
(ASCE. 1987).
"National Survey of Elements and Other
Constituents in Municipal Sewage Sludges."
Ralph O. Mumma et at. Archives of
Environmental Contamination andToxicology,
Voi 13. 75-83.1984. (Mumma. 1984).
"Organic Toxicants and Pathogens in Sewage
Sludge andTheir Environmental Effects." JC
Babish. DJ Lisk. CS Stoewsand and C
Wilkinson. A Special Report of the
Subcommittee on Organics in Sludge, Cornell
University. College of Agriculture and Life
Sciences. December. 1981 (Lisk. 1981).
What's In Sludge
According to researchers at Cornell University and a report of the American Society of Civil Engineers, the following substances
are typically found in sludge:
• Polychlorinated Biphenyls (PCBs)
• Chlorinated pesticides — DDT. dieldrin. aldrin. endrin, chlordane. heptachlor. lindane, mirex. kepone, 2.4.5-T, 2,4-D.
• Chlorinatedcompounds—dioxin(TCDD)oUchlorobenzene,trichlorobenzene,tetrachlorobenzene.chloroaniline,dichloroaniline.
dichloronaphthalene. tetrachloronaphthalene, trichlorophenol. pemachlorophenol. chlorobiphenyl.
• Polynuclear aromatic hydrocarbons - chrysene. benzo(b)fluoranthene. benzo(k)fluoranthene, benzo(a) pyrene, perylene,
dibenzoU,j)anthracene. indo(1.2.3.c.d) pryene.
Heavy metals — antimony, arsenic, cadmium, chromium, copper, lead, mercury, nickel, selenium, thorium, uranium, vanadium
and zinc.
Bacteria. Viruses. Protozoa. Parasitic worms. Fungi.
Miscellaneous—flame rcurdants (asbestos),petroleum products, industrial solvents, iron. gold, nitrogen, phosphorus! potassium.
calcium.
Sources: ASCE. 1987; Lisk. 1981: and Mumma. 1984.
-------
New York State Department of Environmental Conservation
21 South Putt Corners Road, New Paltz, New York 12561
914-255-5453
Thomas C Jorling
Commissioner
December 21, 1987
Frances Hodson
HCR 60B
Godeffray
New York 12739
Dear Mr. Hodson:
In response to your letter of October 15, 1987, a study of the Carrol and
Dubies waste disposal site in Port Jervis, New York, has just recently been
completed and it has been determined that this operation has caused contami-
nation of-the groundwater.
The Department is currently pursuing measures to further study and define
the extent of the contamination, as well as control and remediate this
situation.
If you .have any further questions, please feel free to call me.
Yours truly,
' ' S'\
Sandra L. White
Assistant Sanitary Engineer
Region 3
SLW:zl
-------
\m
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
^
rtc, .,<" REGION I I
26 FEDERAL PLAZA
NEW YORK. NEW YORK 1O278
NOY 21 1988
Ms. Frances Hodson
P.O. Box 60B
Godeffroy, New York 12739
Dear Ms. Hodson:
Your October 18, 1988 letter to Mr. Richard T. Dewling, former
Regional Administrator of Region II, concerning the Carroll &
Dubies Landfill has been referred to me for response. The Carroll
& Dubies site, now referred to as Carroll & Dubies Sewage Disposal,
was proposed for inclusion on the National Priorities List (NPL)
in the June 24, 1988 Federal Register. This means that it is now
eligible for funding under EPA's Superfund program.
I must advise you, however, that prior to the expenditure of
Federal funds, EPA must attempt to locate those parties potentially
responsible for the contamination at the site in an effort to
have those parties fund the response action (cleanup). I can
assure you that the enforcement process, i.e. the search for and
negotiation with potentially responsible parties will begin by
the end of this calendar year. It may take several months to
conclude this effort. Based on the results of the enforcement
process for this site and several others in the same situation,
we will make a determination as to which sites will be funded by
EPA for further action under the Superfund program. Thereafter,
the process to study the extent of contamination at a site like
the Carroll & Dubies Sewage Disposal site typically takes about
18 months. The study process would then be followed by a period
of time to develop an engineering design for the site remedy and,
after completing the design, the remediation (cleanup) of the
si te.
I hope that I have addressed your concerns satisfactorily. For
continued site updates please contact Mr. George Pavlou of my
staff at (212) 264-0106. Mr. Pavlou can keep you apprised of our
enforcement efforts and .our future funding plans.
Sincerely yours,
Stephen D. Luftig, Director
Emergency and Remedial Response Division
cc: Michael O'Toole, Director
Division of Solid & Hazardous Waste
-------
-"*•'
Cortese
clean-up
continues
By TOM KANE
Record Correspondent » / .—^
NARROWSBURG — The Cortese land- |
fill toxic removal project began two weeks I
ago and will be completed by (
mi
id-December.
^
During the next few weeks, workers
will be excavating sediment from two
seepage lagoons that contain toxic waste
deposited mere years ago. Samples will
be taken of the seepage and, according to
the results, the seepage will be taken to a
toxic waste site or a non-toxic site.
"We will also construct a storm water
channel which will divert rain water away
from the contaminated area," said David
Moreira, project manager of Waste Man-
agement Inc. of Massachusetts, the com-
pany contracted to oversee the removal
action.
Moreira is acting on behalf of the Town
of Tusten.
OHM Inc of Trenton, N.J., is the com-
pany doing the excavating.
The landfill, which was used in the
1950s, 1960s and 1970s, is south of the
Hamlet of Narrowsburg along the
>elaware River and next to the Erie Rail-
ad line.
he second phase, which .wiH bcgiq
Workers In protective gear move burled waste yesterday
at the Cortese landfill In Narrowsburg. This portion of the
J. TALBOTTrth* Rocord
clean-up Is expected to be complete by mid-December.
Another phase will begin In the spring.
next spring, will sec the removal of bar-
rels of toxic chemicals that were also
buried years ago.
The cost for the entire project is about
$1 million.
"It won't cost the town anything,", said
Supervisor George Burkle.
The money for the project comes from
the federal Environmental Protection
Administration Supcrfund nnd from the
companies and individuals responsible for
the contamination.
More than 20 years ago, the EPA closed
the landfill because toxic effluent was in
danger of seeping . into the nearby
. Delaware River.
The town owns about H/i acres of the
4i/i-acre site. The remaining three acres
are owned by John Cortese, Moreira said.
It took years of negotiations and court
cases to have the landfill cleaned up.
"It's finally going to be done and over
with," Burkle said.
-------
age
lit
Tests show
soil, water
Still tainted
/ *
But RSR site no threat
to area, DEC official says
By MARIE SZANISZLO
Staff Writer
CRYSTAL RUN — About two years after a state
agency ordered Revere Smelting and Refining Corp. to
monitor the soil and water around its plant, samples of
both continue to show high levels of arsenic and other
contaminants.
However, a Department of Environmental Conserva-
tion official says there is no imminent threat to either
the public's health or the environment
In a recent memorandum, the Town of WalMU's con-
sulting engineer, Richard McGoey, said ground water on
the south side of the Ballard Road plant showed ele-
vated levels of arsenic, antimony, cadmium and
chromium.
The company's first quarterly report for 19% also
indicated that a nearby pond and stream, as well as soil
samples on the plant's boundary, also showed high
levels of arsenic and lead, McGoey said.
The findings are of particular concern to residents
who have been monitoring the battery-recycling com-
pany because the state DEC geologist most familiar
with RSR is one of several employees who are losing
their jobs because of budget cuts.
"I would like to see that (the findings) don't fall into
the cracks," said Harry Ross, chairman of the commu-
nity advisory committee overseeing the company's
efforts to bring its plant into compliance with state and
federal regulations. "To fire the one expert you have
working on this to save money doesn't make sense."
Ellen Stoutenburghi a DEC spokeswoman, said it was
unclear how James Yuchniewicz's workload would be
handled after his June 14 departure.
"There are other geologists that work for the depart-
ment," Stoutenburgh said. "... Any time someone with
experience leaves, however, it always takes time to
bring someone else up to speed."
The levels found in the soil and water samples were
consistent with previous findings, she said, and posed no
"imminent threat to human health or the environment"
"We think the contamination could be contained to
the RSR property," said Aida Potter, an environmental
engineer for the DEC.
To bring its plant into compliance, the company began
excavating lead-contaminated soil at the site last July,
and was to build and begin operating by July of this year
a separate facility designed to reduce sulfur dioxide
emissions odors at the plant
RSR had asked for an extension until May 10, 1997,
Dumas said, because its engineers are looking at differ-
ent ways to reduce the sulfur dioxide emissions.
The DEC has agreed to give the company until Sept 7
to finish the building and begin reducing emissions.
-------
Lead linked to crime
By LEE BOWMAN
Scripps Howard News Service
Lead contamination not only
impedes brain development and
learning in children, but also
makes them more aggressive
and likely to engage in delin-
quent acts, a new study pub-
lished Wednesday concludes.
A four-year study of 301 Pitts-
burgh public schoolboys found
those with elevated levels of
lead in their bones were report-
ed by parents and teachers —
and themselves — to be more ag-
gressive and more likely to steal,
fight and vandalize than low-
lead counterparts.
The results were reported by
Dr. Herbert Needleman and col-
7/
-------
Law to protect
area reservoirs
By MICHAEL MELLO O \ 1 \ 9 L
Ottaway News Service V \ x x
WASHINGTON — President Clinton yesterday signed
into law a bill that could provide New York state with
$112 million over the next few years to help protect
New York City's upstate reservoirs from pollution.
Congress must approve a separate request to actually
spend the money, however. That makes it unclear
whether federal aid will reach the city or upstate com-
munities in the reservoirs' watershed next year.
Rep. Sherwood Boehlert, R-New Hartford, says he is
confident that it will. He'll have to move quickly to make
it happen. When Congress returns from the summer
recess after Labor Day, lawmakers will have only three
weeks to wrap up legislative business before they
adjourn for the fall elections.
Boehlert, along with the state's senators, championed
the effort to win federal aid to help protect New York
City's water supply.
Under an agreement with the federal Environmental
Protection Agency, the city would widen the buffer of
land it owns around the reservoirs in Delaware, Ulster
and Sullivan counties, and restrict development and
some farming practices in the area that could pollute
their waters.
Communities in the region would have to upgrade
their sewer and storm water systems to prevent runoff
into the reservoirs, potentially forcing residents to pay
some of the expensive construction costs.
Federal money would help pay part of what could
be up to SI billion in project-related costs. If the city
does not act, Washington would force it to build a
filtration system that could cost more than $2 billion.
Last week, the House approved another measure
sponsored by Boehlert seeking $25 million for watershed
protection in upstate New York. But that plan, in which
Washington would award grants to communities to help
them meet the new watershed protection requirements,
must still be approved by the Senate.
-------
4. Provide [or the care, custody, and control of Ike forest pre-
serve.
5. Provide for tlie protection and management of marine and
coastal resources and of wetlands, estuaries and shorelines.
C. Foster und promote sannd practices for the use of agricultural
land, river valleys, open land, and other areas of unique value.
7. Encourage industrial, commercial, residential and community
development wliicli provides the best usage of land areas, maxi-
mizes environmental benefits and minimizes the effects of less desir-
able environmental conditions.
8. Assure //ic preservation and enhancement of natural beauty
and man-made scenic qualities.
9. provide for prevention and abatement of all water, land and
iiir finlliilii'ii Including iiiil mil Innildl l<> Hull rilnhil In ntir-
ticiiiatcx, ynscs, •/, rnptirs, nnise, radiation, odor, nutrients and
lir-atcd liquids.
10. Promote control of pests and regulate the use, storage and
disposal of pesticides and other chemicals winch may be harmful
to man, animals, plant life, or natural resources.
11. 1'rontotc cnntrol tif weeds and aquatic growth, develop
methods of prevention and eradication, and regulate herbicides.
'5. Provide and recommend methods for disposal of solid wastes,
including domestic and industrial refuse, junk cars, litter and
debris consistent with sound health, scenic, environmental quality,
and land use practices.
13. Prevent pollution through the regulation of the Storage,
handling and transport iif sttlids, liquids and gasrn which tuny cniixi
or contribute to pollution.
14. Promote restoration and reclamation of degraded or despoiled
f areas and natural resources.
15. Encourage recycling and reuse of products to conserve
resources and reduce ivaste products.
16. Administer properties having unique natural beauty, wilder-
ness character, or geological, ecological or historical signilicancc
dedicated by law to the state nature and historical preserve.
17. Formulate guides for measuring presently unqualified
environmental values and relationships xi> they may br. given appro-
priate consideration along with social, economic., and technical con-
siderations in decision-making.
1^. Encourage and undertake scientific investigation and research
mi the cctilinjieul process, pollution prevention and abatement.
recycling anil reuse of rcsDure.es, and other areas essential to under-
standing and achievement of the environmental policy.
1'J. Afsexs new and changing technology, and development pat-
terns to identify Inng-ranfie implications (nr the environment and
• nr-iii I'niji ulti I'n'iti i'i \ irlncli iniitiiniii' ntlt'i'i'xi- impart.
;?(). Monitor the environment to affonl nwre. effective and efficient
control practices, to identify changes and conditions in ccnlogical
systems and to warn of emergency conditions.
-------
Pubflc Notice 93-53
Dots: August ". 1993
Notice of proposed odmW-
jtrotlve penalty assessment
and opportunity to
comment
Agency: Environmental
Protection Agency (EPA)
Action: Notice of proposed
odrrtnlstrattve penalty as-
sessment cod opportunity
to comment
Summer/: EPA Is providing
notice of proposed odmlnj-
stratlve penalty assessment
for aleged violations of the
clean water act. EPA is atso
providing notice of oppor-
tunlty to comment on the
proposed penalty
assessment.
Under 33 U.S.C. §1319(G).
EPA Is authorized to issue
orders assessing cMI penal-
ties for various violations of
the act. EPA may Issue such
orders after the com-
mencement of a Class II
penalty proceeding. EPA
provides public notice of
the proposed assessment
pursuant to 33 U.S.C.
§1319
-------
-Y.
August 12, 1993
EPA may fine Skydyne $10
By DAVID CORDON
SUIT Reporter
PORT JERVIS — The federal
Environmental Protection Agency is
seeking a SI00,000 fine against
Skydyne Corp. for alleged dumping
of excess chromium into (he city's
treatment plant.
Skydyne's general manager Jay R.
Benson said today the company has
redesigned its production processes to
eliminate the problem. The proposed
fine is not final, and the company is
seeking a hearing, he said.
Skydyne manufactures cases for
45 Cents
10,000
' Sl'(f
EPA officials could not comment
on whether the company is currently
' in compliance, but John Dolinar, EPA
| assistant regional counsel, said the
fine would be levied on previous non-
compliance.
"We would expect them to be in
. compliance, especially after we noli-
• fied them (hat we were aware of the
I noncompliance," he said. "It's nice
that they are now complying and be-
ing responsible, but the fines are for
the past violations.
gauges and instruments, and metal
containers. ,_ *-
The alleged violations occurred
between January 1989 and December
1982, according to a complaint Hied
by the EPA. Wastewater from the
plant exceeded (he maximum
monthly average limits for chromium
in eight months during the period. On
one day. Dec. 8.1992, the waslcwater
contained more than the daily maxi-
mum of chromium.
According to the EPA complaint,
industries are required to pretreat
wastewater going into a public treat-
ment plant to reduce or eliminate
heavy metals and other hazardous
substances.
Wastewater entering the Port Jervis
sewage treatment plant, which is
owned by New York City, must
contain no more than 2.77 milligrams
of chromium per on any given day.
The monthly average must not exceed
1.71 milligrams per liter.
The amounts of chromium found in
the EPA's review varied from 1.72
milligrams per liter to 3.45. Most
results were in the 2.2 to 2.68 range,
with one reading of 3.45.
The EPA complaint also charges
that Skydyne failed to maintain-waier
samples to be tested for cyanide on
July 8, 1992, at the required 4 degrees
centigrade during transport from the
plant to the laboratory.
Benson has been Skydyne's gen-
eral manager since last August. He
received the first notice from the EPA
on the violations in December, he
said.
"We were in total compliance in
January," he said. "We've changed
the process, we've invested the mo-
ney, and we're within all the limits."
llotlson
HCROOD
Oodeffroy. KY 12739
Thursday, August 12 199?
The rest of the story
*EP/\
(Continued from page 1)
Before the fine is levied, a hearing
will be held to determine whether the
amount is appropriate. Members of
the public may contact EPA Hearing
Clerk Karen Maples at the Region II
office, 26'Federal Plaza, Room 437,
New York, N.Y. 10278 to submit
written comments.
F.PA. hack ptqe)
-------
Public Notice 93-53
Dote: August 11. 1993
Notice of proposed odminl-
ttrcrttve penorty assessment
and opportunity to
comment
Agency: Environmental
Protection Agency (EPA)
Action: Notice of proposed
administrative penalty as-
sessment and opportunity
to comment
Summary: EPA Is providing
notice ot proposed admini-
strative penalty assessment
for oflecied violations of the
clean water act. EPA is also.
provtdng notice of oppor-
tunity to comment on the
proposed penalty
assessment.
Under 33 U.S.C. §1319(G).
EPA Is authorized to issue
orders assessing cM penal-
ties (or various violations of
the act. EPA may bsue such
orders after the com-
mencement of o Class II
penoJIy proceeding. EPA
provides pubic notice of
the proposed assessment
pursuant to 33 U.S.C.
§1319»c comment on a prop-
osed class II order Is thirty
(30) days after Issuance of
pubBc notice.
On the date Identified be-
low. EPA commenced the
(otowtng class H proceed-
ing for the assessment of
penotttes: i
Irv «•*» mnttar <•»/ A AD <~/-»r*s-
S«
to
P<
t>
N
n
c
S<
1
m
P/
w«
In the matter of AAR Corpo-
ration (Skydyne. a drvtolon
of AAR Brooks * Pertdns Cor-
poration). 21 Rtver Rood.
Port Jervb. New York 12771.
Docket No.
EPA-CWA-ll-93-SO: fted on
Jury 28. 1993 wtlh regional
hearing derV Karen Maples.
VS. EPA. Region B. 26 Fed-
eral Plaza. Room 437. New-
York. NSW York fQ278. (212)
264-9&80; proposed pen-
alty. S 100.000. for foSure to
comply wtth the section 307
of the Clean Water Act and
the categorical preheat-
ment regulations found at
40 C.F.R. §433.
For further Information: per-
sons wtehJng to recerve a
copy of EPA's consolidated
rules, review the complaint
or other documents filed In
this proceeding, comment
upon the proposed assess-
ment, or otherwise partici-
pate In any of the proceed-
ing should contact the reg-
lonal hearing clerk
Identified above. Unless
otherwise noted, the admi-
nlstrattve record for the pro-
ceeding b located In the
EPA regional office Identt--
fled above, and the fie win
be open for pubBc Inspec-
tion during normal business
hours. All Wormalton sub-
mitted by the respondent Is
available os part of the ad-
mlnbtraflve record. sub)ect
to provisions of taw restrict-
ing public disclosure of con-
fidential Information. In or-
der to provide opportunity
for public comment. EPA
will Issue no final order as-
sessing a penarty m this pro-
ceeding prior to thirty (30)
days from the date spect-
ned below.
CXited: August 11.1993
Richard L Caspe. P.E..
Director
Water Management
Drvteton
Ai
we
32
Nf
S3
St<
-------
N.Y. lii'oy
INDUSTRY ALONG ROUTS 209
DBERPARK, N.Y.
1. Marcy South Power Line
2. MAS lagoons for septic waste.
hauling it to this site.
3. Pete's Auto Service Westbrookville
4. Lafarge-Sullivan - next to Basha Kill
5. Brim Recycling - auto crushing, batteries, etc. Basha Kill
6. Westbrookville Auto Body
r-ASLu
7. Tenke's - Auto repair and junkyard
8. Lewis's Convenience store .- gas pumps
9. Firohouse
10. C & D Battery
>
11. Town Hall and Maintenance Sheds for Road Equipment
12. Deerpark Auto Sales - repairs and painting
15. Deerpark Equestrian Farm - Han Corp.
14. Feenpack Sand and Gravel and Cement Plant off
Peenpack Trail about i mile from 209
15. Summit Labaratories (formerly Dow Chemical, and
before that Wickham. Tons of contaminated soil removed
by Dow and furnace to burn off toxic fumes from under-
ground. Development on this site has caused water
problems to neighbors, low pressure from wells and
flooding of their soil.
16. Port Jervis School District. Transportation garage
and sewer system
17. Monk and Tony and Delaware Valley Sand and Cement Block.
Recently rezoned Rural Residential Area. Monk and
Tony had 6 acres "Industrial". Industrial zone is now
350 acres.
18. Port Jervis landfill
19. Carroll & Dubies toxic landfill
20. Trovei Junkyard
21. S & K Vehicle - Battery repair and tire yard with
30,000 tires.
22. Columbia Gas - gas line and station on 209. Line
crosses from west to east
In addition we have many gravel pits scattered along 209.
There are several power lines crossing over the river.
Numerous auto mechanics operating on their homesite.
w.,o, - ?0 vrars of contamination
'- J y .../..,• ty .•<££-.**.&
-------
TOWN OF DEERPARK TOWN CLERK OFFICE
DRAWER A, ROUTE 209 N.
HUGUENOT, N.Y. 12746
SHIRLEY ZELLER.TOWN CLERK
TELE.NO. (914) 856-5705
September 23,1996
PROJECT;CARROLL AND DUBIES SEWAGE
DISPOSAL INC.
TOWN OF DEERPARK, ORANGE CO.
NEW YORK
U.S. Envrionmental Protection Agency
Attention: Maria Jon, Project Manager
290 Broadway, 20th Floor
New York, New York 10007-1866
Councilman Robert Zeller, attended your public hearing representing the
Town Board and reported the information that was presented to the public
by your agency, with the board taking the following action, regarding the
several plans submitted for the clean up of the area.
The Town Board requests the Agency be informed they wished the
Alternative proposal 3-Groundwater Pump and Treat via Precipitation,
Filtration and Carbon Adsorption, be the plan used in handling the clean
up of this area.
It is felt this is a better control plan and containment of any contaminated
ground water that may be on the location of the site.
Shirley Zell
Town
-------
Dr. and Mrs. Hassan Sadaghiani
14 Orchard Lane • Port Jervis, NY 12771
-------
PJHS Parent Teacher StucCent Association
Jioute209
Port Jervis, New york, 12771
September 13, 1996
Maria Jon. Project Manager
U.S. Environmental Protection Agency
290 Broadway, 20th Floor
New York, NY 10007-1866
Dear Ms. Jon:
Because of a prior commitment to a mandatory meeting, the majority of
our membership were unable to attend your public hearing in Port Jervis on
September 11. We do not wish this to be misconstrued as disinterest in the
problem of a Superfund Site in such close proximity to our High
School/Elementary School complex.
Rather, we. the Port Jervis High School PTSA. would like to go on public
record encouraging the prompt and complete clean-up of the Carroll and Dubies
Sewage Disposal Site, Canal Street, Port Jervis/Deerpark, New York. We
strongly urge you to proceed quickly with the completion of your recommended
action on Operable Unit 1. It was upsetting to hear that may be as far away as
1999. We currently have more than 1000 students in our high school, close to
900 in the contiguous elementary school, and the number is continually rising.
Since the school district is using Port Jervis City water, contamination of
groundwater used for drinking is not a concern for our student population. We
do have a major concern with the possible contamination of Cold Brook (given
the name Gold Creek on your maps). This stream runs within 1,500 feet of the
contaminated lagoons on the Carroll and Dubies property and is downgradient
of them. It is adjacent to our playing fields and our students have had to enter it
to retrieve balls on more than one occasion.
Out of concern for the health of our students and possible exposure to
-------
deleterious material, we urge that you do repeat testing of the waters of Cold
Brook (Gold Creek) and its sediment immediately and at frequent intervals
until completion of your planned excavation, onsite treatment of contaminated
materials, and containment and capping of the lagoons. We had a lot of snow
last winter and heavy rains since which have most likely caused flooding of the
lagoons on site and escape of probable contaminated material through the
wooden fence surrounding Lagoons 1 and 2, as well as seepage through
groundwater from the other soil-covered lagoons. We have approached our
Superintendent to ask the School Board's permission to conduct independent
studies which can be compared with your results.
, Our children are too precious to us. We, as parents, and you as agents of
our government must do all in our power to protect them from harm. We trust
you will do your part, as we will do ours.
Sincerely yours,
anine LaFemina, PTSA President
Irene Lntranuovo, Vice-President
Erin Cunningham. Vice/President
r^r-As*
Deborah Cun'ningham,cSecretary
Catherine Sadaehiani. Treasurer
jl/hf
cc: Patrick Hamill, Superintendent of Schools
-------
September 19, 1996
Miss Haanof Back
Maria Jon, Project Manager
U.S. Environmental Protection Agency '«V^V?' PcrtJ<"vis>NY12771
290 Broadway, 20th floor fRAL
New York, New York 10007-1866
Dear Ms. Joni
Enclosed is a copy of my letter to the Editor of the Tri-
State Gazette.
I have struggled through the EPA report presented at the
Public Hearing on the Carroll and Dubies Toxic Dump.
1. Because of the inconsistency between 199^ and 1995
sampling results, you did another test in 1996. The report
stated turbidity caused the high concentrations of inorganizs.
The cause was the pump used and that the samples were not
filtered. The report stated that some monitoring wells were
re-developed and some monitoring wells now have lower levels
in the samples. I can's help but wonder if turbidity is not
a normal condition underground during heavy rainfalls or
flooding. If filtering removese harmful chemicals, can an
ordinary sink filter do the same?
2. I refer to the statement that ground water modelling is
an indication that concentration patterns have been stabilized.
I s this water modelling a foolproof system?
I have no confidence in the plans 1 and 2 and do not under-
stand the mechanics/engineering of the other systems. I
believe the public should have a clearer explanation of this
whole situation.
\
I will appreciate your considering these questions and will
appreciate hearing from you before the end of the comment
period, September 27th.
Thank you for your kind attention.
Sincerely yours,
Eleanor Back
•k 12771
Miss Eteanot Back
SUaikO
£, PwlJerve. NY 12771
-------
L«tter to the Editor - Septemoer xy,
Dear Editor i
I am a newcomer to this area - only three years. It is lovely here
and I enjoy it greatly, but it is so sad to hear of the careless
selfish acts of those who have dumped their toxic wastes on poor,
pretty Deeerpark.
The E.P.A. held a public hearing on September 11 th, 1996 to inform
us of their plane to clean up "some of the lagoons and surrounding
soil* polluted by Reynolds Metals, Wickhara and KoTmar.
This particular site opened in 1970 and closed in 1979. It IB
now almost 1997. This site was on the "National Priority List."
The E.P.A. has four alternative plans for clean-up and each takes
five years.' Alternative one is to do nothing and the second is
similar except that it requires monitoring. The third and fourth
require great effort and more expense. The E.P.A. prefers Plan #2.
The original polluters are required to help pay for or take care
of the problems with E.P.A. supervision by removing 20,000 cubic
yards yards of contaminated soil from the area. The remaining
contamination would be treated, placed on-site in a lined capped cell
with leachate collection. This leachate should be monitored. The
whole area should be monitored. This seems unlikely since no elected
official was at this meeting in an official capacity to show
concern for the citizens of Deerpark.
The final result in five years would be the area could be used as
an industrial site. Who knows how that would turn out.
The B.P.A. Federal, State or Local governments have failed to
protect our environment and our health. I have a very cynical
feeling that they will continue to fail to protect our environment
and our health.
Very truly yours,
Eleanor Back
Port Jervis, New York
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THEODORE J CARLSON
WILLIAM P REILLY
GEORGE J WALSH III
JOHN E. GOULO
ROBERT J GLASSER. P C
FREDERICK W LONDON
PETER V K FUNK. JR
ROBERT E PEOERSEN
ANDREW W BANK
EDWARD V. ATNALLY
RICHARD T KORTRIGHT
WALTER A. 8OSSERT. JR.
OF COUNSEL
OOREEN M SCHRAUFL
ADMINISTRATOR
GOULD & WILKIE
iFOUNOCO IN 1692)
COUNSELLORS AT LAW
ONE CHASE MANHATTAN PLAZA
NEW YORK. N.Y. I OOO5-I 4O 1
2 I 2-344-S68O
SALLY A MUIR
MICHAEL R- MANLEY
ERIC O COSTELLO
GREGORY I SIMON
ROBERT T BARNARD
MARYLOU SCOFIELO
C4BLC *OO*»ESS
COLDKE"
TELECOPIER
By-Hand
September 26, 1996
Ms. Maria Jon
Project Manager
U.S. Environmental Protection Agency
Region II
290 Broadway, 20th Floor
New York, New York 10007-1866
Re: Carroll & Dubies Sewage Disposal Superfund Site
Port Jervis. New York
Dear Ms. Jon:
This letter presents the comments of Koltnar Laboratories,
Inc. and Wickhen Products, Inc. concerning the proposed Remedial
Action Plan dated August 28, 1996 for the Second Operable Unit
(OU2) at the above-referenced site. Kolmar and Wickhen believe
that the proposed Plan generally presents an appropriate recom-
mendation for adoption of alternative 2, natural attenuation with
institutional controls and monitoring, subject to the following
qualifications.
First, the responsibility for establishing institutional
controls should be placed on the City of Port Jervis. The land on
which a majority of the site exists is owned by the City of Port
Jervis and it is appropriate that the Agency establish any required
institutional controls with the landowner. The City of Port Jervis
has been the owner of this site for many years and it clearly knew
of the activities being carried on on its property. Furthermore,
the City controlled access to the Site through controlling access
to the general area of the Site's Municipal Landfill/County
Transfer Station.
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GOULD &. WILKIE
Ms. Maria Jon
September 26, 1996
Page 2.
Second, with regard to monitoring the proposed Plan.is
unclear. The Agency will require monitoring as part of the resolu-
tion of the First Operable Unit (OU1) and it remains unclear as to
whether any additional monitoring is contemplated for OU2. Kolmar
and Wickhen believe that no additional monitoring should be re-
quired, based upon the indications previously provided to them
concerning monitoring requirements in connection with GUI.
The presentation made by the Agency at the Public Meet-
ing held on September 11, 1996 at the Port Jervis High School
Auditorium generally described the attenuation of the plumes that
will occur upon removal of the source area.
It should be noted, however, that the existing plumes are
static and are not expanding. The existence of a steady state
condition at this time is significant because it shows that the,
source areas do not presently threaten any off-site receptors, and
upon removal of the source areas, the plume will contract over a
very short period of time. The time periods presented by the
Agency at the Public Meeting were the more conservative values
(i.e.. of greater time duration) indicated by the groundwater
modelling. In fact, the groundwater modelling results suggest that
the plumes will attenuate over a much shorter time than the five
year period suggested by the Agency at the Public Meeting. It
appears that a number of the comments presented at the Public
Meeting are traceable to the fact that the full extent of the
groundwater modelling results were not described by the Agency in
its presentation at the Public Meeting. In reality, the concerns
of many of those at the Public Meeting chat a significant time
period will be required for remediation have already been addressed
by the groundwater modelling studies indicating that natural
attenuation will be accomplished rapidly upon source removal.
The presencacion made by che Agency ac the Public Meeting
did indicated the relative costs for che various alternatives. How-
ever, in fact, from a tirr.e line standpoint alone, alternative 2
will accomplish the desired results over a time period as short: or
shorter than could be accomplished by alternatives 3 or 4. When
the much greater coses of alternatives 3 or 4 are considered, the
Agency's proposal to adopt alternative 2 clearly becomes the only
reasonable choice, subject to the concerns noted at the beginning
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GOULD &. WILKiE
Ms. Maria Jon
September 26, 1996
Page 3
of this letter. We hope that these comments will be of assistance
to the Agency in the presentation of the record of decision and
request that they be included in the public record of this matter.
Respectfully submitted,
Robert J. Giasser '
Gould & Wilkie
One Chase Manhattan Plaza
58th Floor
New York, New York 10005-1401
(212) 320-0109
Murphy
Lester Schwab Katz & Dwyer
Y20 Broadway
New York, New York 10271-0071
(212) 964-6611
RJG:cw
By-Hand
arglmmj.Itr
cc: v/Sharon E. Kivowitz, Esq.
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