United States
           Environmental Protection
           Agency
              Office of
              Emergency and
              Remedial Response
EPA/ROD/R02-89/081
September 1989
3EPA
Superfund
Record of Decision
            Fulton Terminals, NY

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50272-101
 REPORT DOCUMENTATION
        PAGE
                        1. REPORT NO.
                             EPA/ROD/R02-89/081
                                                                    3. Recipient1* Acceeaion No.
 4. Tide and Subtitle
   SUPERFUND  RECORD OF DECISION
   Fulton Terminals, NY
   First Remedial Action  - Final
                                                                    5. Report Date
                                                                            09/29/89
 7. Author(«)
                                                                   8. Performing Organization Rept No.
 9. Performing Organization Name and Addreaa
                                                                    10. Pro|ect/Taak/Work Unit No.
                                                                    11. ContracqC) or Grant(G) No.

                                                                    (C)

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

                                                                       800/000
                                                                    14.
 15. SupplemenUiy Now*
 16. Abetract (Limit: 200 worda)
  The 1.6-acre  Fulton Terminals site is  in  Fulton, Oswego  County, New  York.  The site is
 bordered to the west by the  Oswego River,  and a section of the site lies within the
 river's 100-year floodplain.   Commercial and industrial operations are the primary  land
 uses in the vicinity of the  site.  Spills  and leaks of chemical wastes stored in eight
 tanks at the site resulted in soil and  ground water contamination.  The wastes were
  reduced by a  combination  of former asphalt and roofing manufacturing operations
   nducted from 1936 to 1960,  and a more recent hazardous  waste storage operation.   From
 1972 to 1977 Fulton Terminals, Inc., operated a staging and storage area for hazardous
 wastes destined for offsite  incineration.   In 1981, following a citation for not meeting
 Federal and State standards  for the operation of a hazardous waste storage facility,
 Fulton Terminals initiated a cleanup which included emptying and removing four storage
 tanks.  From June 1986 to  May 1987 EPA  and the PRPs undertook removal activities which
 included securing the site,  removing all remaining storage tanks, excavating and removing
 approximately  300 cubic yards of contaminated soil and tar-like waste,  and partially
 removing and plugging a storm sewer pipe running to the Oswego River.   This remedy
 addresses the  low levels of  soil contamination remaining  at the site  and a plume of
 contaminated ground water  which threatens  the Oswego River.  The primary contaminants of
 concern affecting the soil and ground water are VOCs including benzene,  TCE, and xylenes;
 other organics including PAHs; and metals  including arsenic. (See Attached Sheet)	
                                              NY
17. Document Analyal* a. Deacriptora
  Record of Decision - Fulton  Terminals,
  First  Remedial Action - Final
  Contaminated Media:  gw, soil
  Key  Contaminants:   VOCs (TCE,  benzene), other organics  (PAHs),  metals  (arsenic)
  b. ktentifiera/Open-EndedTerme
   c. COSATI Field/Group
 18. Avallabitty Statement
                                                    19. Security Claaa (Thla Report)
                                                           None
                                                     20. Security Claaa (Thla Page)
                                                     	None	
21. No. ofPagea
      80
                                                                                22. Price
(See ANSI-Z39.ia)
                                      SM Instruction* on fiewwao
                                                                              OPTIONAL FORM 272 (4-77)
                                                                              (Formerly NTTS-35)
                                                                              Department of Commerce

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                   DO NOT PRINT THESE INSTRUCTIONS AS A PAGE IN A REPORT


                                                      INSTRUCTIONS
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     an organizational hlerachy. Display the name  of the organization exactly as It should appear In Government Indexes such as
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     of... Presented at conference of... To be published in... When a report Is revised, Include a statement whether the new
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     report contains a significant bibliography or literature survey, mention It here.

 17.  Document Analysis, (a). Descriptors. Select from the Thesaurus of Engineering and Scientific Terms the proper authorized terms
     that Identify the major concept of the research and are sufficiently specific and precise to be used as index entries for cataloging.

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 A GPO: 19830-381-526(8393)                                                                       OPTIONAL FORM 272 BACK
                                                                                                   (4-77)

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EPA/ROD/R02-89/081
Fulton Terminals, NY
First Remedial Action - Final


16.  Abstract (continued)

 The selected remedial action for this site includes excavation and low temperature
thermal treatment of approximately 4,000 cubic yards of contaminated soil and
backfilling- the treated soil provided it passes the TCLP Toxicity Test; placement of a
one foot cap of clean top soil over the site; ground water pumping and treatment onsite
using air stripping and carbon adsorption, followed by reinjection or other type of
recharge into the aquifer; disposal of soil and ground water treatment waste residues at
a RCRA-approved offsite hazardous waste facility; air monitoring; and ground water
monitoring for three years.  The estimated present worth cost for this remedial action
is $4,031,000, which includes an annual O&M of $732,000 for 3 years.

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              DECLARATION TOR THE  RECORD  OF  DECISION
8ITB NAME AMD LOCATION


Fulton Terminals Site, City of Fulton, Oswego County, New York.

STATEMENT OP BASIS AMD PURPOSE

This decision document presents  the  selected remedial action for
the Fulton Terminals site.  The selected remedial alternative was
developed  in  accordance  with  the  Comprehensive  Environmental
Response, Compensation, and Liability Act of 1980 (CERCLA),
as amended by the Superfund Amendments and Reauthorization Act of
1986 (SARA), and to  the  extent practicable,  the National Contin-
gency Plan  (NCP).   This decision is based  on the administrative
record for this site.  The attached index identifies the items that
comprise the administrative record upon which the selection of the
remedial action is based.

The State of New York has concurred with the selected remedy.


ASSESSMENT OF THE BITE

Actual or  threatened releases of hazardous  substances  from this
site, if not addressed by implementing the response action selected
in this ROD, may present  a current or potential threat to public
health,  welfare, or the environment.


DESCRIPTION OP THE SELECTED PflTffpY

The selected remedy  will address residual  soil contamination at
the site and contaminated groundwater in the underlying aquifer.
Prior cleanup  actions have resulted  in the removal  of visibly-
contaminated  surface  soil  and  all  storage  tanks  containing
hazardous substances.

The major components of the selected remedy are:

- Excavation and  treatment, via  on-site  low temperature thermal
extraction, of  approximately  4,000  cubic yards  of  contaminated
soil.

- Placement of the treated soils  into the excavated areas;

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- Extraction and treatment, via air-stripping and carbon
adsorption, of the groundwater underlying the site, and
reinjection, or another type of recharge technique, to recharge
the treated water into the ground; and

- Disposal of the treatment residuals at an off-site Resource
Conservation and Recovery Act (RCRA) hazardous waste facility.

The groundwater treatment will continue until federal and state
standards for the organic contaminants have been achieved.  Because
benzene, ethylbenzene and xylene have been detected in upgradient
wells  at  levels   exceeding groundwater   standards,  a  separate
investigation will be undertaken by the New York State Department
of Environmental Conservation (NYSDEC)  to define and eliminate the
source of the upgradient contamination if these contaminants remain
elevated at the time when federal and state standards for the other
organic contaminants have been achieved.

It should be  noted  that the  groundwater quality standards for
metals  may  not   be   achieved,   as  naturally  occurring  metal
concentrations in the groundwater surrounding the site are higher
than the  metal concentrations in the  groundwater underlying the
site.  As a  result, the  quality  of  the groundwater at the end of
this remedial action may not be adequate for use as a potable water
supply.  Therefore, institutional controls will be established to
prevent the  utilization  of the groundwater at the site  for such
purposes.     Any   institutional  controls,   including,   without
limitation,   well   construction  permits   and    water   quality
certifications, shall be consistent with New York State law.


DECLARATION

Consistent with CERCLA,  as amended  by SARA, and  the  NCP,  I have
determined that the selected remedy is protective of human health
and the environment,  attains  federal  and  state requirements that
are applicable or  relevant and appropriate  to the  remedial action,
and is cost  effective.   This  remedy utilizes permanent solutions
and  alternative treatment technologies  to  the   maximum  extent
practicable  and satisfies the statutory preference  for  remedies
that employ  treatment that reduces  toxicity,  mobility,  or volume
as a principal element.   Because this  remedy  will not  result in
hazardous substances remaining on-site above health based levels,
the five-year review will not apply to this action.
                                                  £
William J.Jsuszynski, P.E.                      Date
          *
Acting Regional Administrator

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               DECISION SUMMARY




            FULTON TERMINALS SITE




               FULTON,  NEW YORK
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY




                  REGION II




                   NEW YORK

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                        TABLE OF CONTENTS
SITE NAME, LOCATION AND DESCRIPTION 	   3
SITE HISTORY	   5
ENFORCEMENT HISTORY 	   6
COMMUNITY PARTICIPATION 	   7
SCOPE AND ROLE OF RESPONSE ACTION	   8
SUMMARY OF SITE CHARACTERISTICS 	   8
SUMMARY OF SITE RISKS	12
DOCUMENTATION OF SIGNIFICANT CHANGES	21
DESCRIPTION OF ALTERNATIVES 	  21
SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES 	  27
THE SELECTED REMEDY	33
STATUTORY DETERMINATIONS	35
          ATTACHMENTS

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

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BITE NAME, LOCATION. AMD DESCRIPTION
The Fulton Terminals site  is  located near the northern corporate
limits of the City of Fulton,  Oswego County, New York.  It is 10
miles southeast of the  City of Oswego and 22 miles north-northwest
of the City of Syracuse.  The site covers approximately 1.6 acres,
and is bounded on the west by First Street,  on the south by Shaw
Street, on the east by  Route 481,  and on the north by a warehouse.
The Oswego River lies  immediately west of First Street,  approxi-
mately fifty feet from  the  site  (see Figure 1).  The various waste
storage tanks shown in Figure 1 were associated with former activi-
ties at the site and have since been removed.

Land use  in  the vicinity  of  the  site is commercial  and indus-
trial. Immediately south of Fulton Terminals across Shaw Street is
a former waste disposal site, the Fulton  6th  Ward,  a portion of
which has been regraded and covered by a new industrial building.
This one-acre site  was used  from  1966 to 1969.   South  of Shaw
Street to the west  is a trucking  company,  and to the east is the
County Office Building.  North  of the  site is a large warehouse.
Across Route  481  and east  of Waterhouse Creek is  the former Van
Buren Street  Dump site,  which has been converted into  a park.  This
17-acre site  was  used from the early 1950s until the late 1960s for
the disposal  of_ municipal  waste  and construction  and demolition
debris.  A number of private homes and the fringe of the downtown
commercial district are within one-half mile of the site.

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According  to the  City of  Fulton Chamber  of  Commerce,  natural
resources  in the  area  consist  of  the  Oswego  River and  Lake
Neatahwanta.  Recreational water activities on the Oswego River,
which runs adjacent to  the site, include boating and fishing.  Lake
Neatahwanta, located approximately 3 miles southwest of the site,
is  utilized for public  swimming, fishing,  boating  and  camping
activities. Several sand and gravel pits are located within a few
miles of the site.

The population of  the  City  of  Fulton was 13,312 according to the
1980 U.S.  census.   The population of Oswego  County  was  113,901
according to the 1980 census.

The Fulton Terminals site is situated on a relatively flat parcel
of land created by filling of the former floodplain of the Oswego
River.   The Oswego  River  flows  south to  north and  is  located
approximately 50  feet west of the  site (see  Figure 1).   Four
hundred feet to the  east  is the Waterhouse Creek which drains a
small basin in the uplands into a  swampy area before emptying into
the Oswego  River,  approximately  1,250 feet  north of  the site.
During normal flow periods, the river level  is approximately 10
feet below  ground  surface in the vicinity of  site.   The western
portion of the site  is sloped  gently toward the Oswego River and
it occurs within the 100-year floodplain of the Oswego River.

The site is underlain by a relatively thick section of unconsoli-
dated deposits that overlie bedrock.   A  layer of sand and gravel
appears to  be laterally  continuous  over bedrock,  and  ranges in
thickness from approximately 25 to 58 feet.   A silt and clay unit
occurs above the sand and  gravel unit throughout most of the site,
with thickness varying from  0 to approximately 25 feet.  Artificial
fill, consisting  predominantly of sand  and  gravel,  covers the
surface of the site varying in thickness from approximately 4 to
12 feet.

The artificial fill is  the uppermost hydrologic unit, and is mostly
unsaturated.    The  water  table   generally  coincides  with  the
elevation of the bottom of the  fill.  The underlying silt and clay
unit has very low hydraulic  conductivity.  The next lowest sand and
gravel unit constitutes the main discharge toward the river.  The
bedrock unit has relatively low hydraulic conductivity, based on
slug tests, and  has a groundwater  flow  direction toward the Oswego
River.

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SITE HISTORY

From 1936  until  1960,  the Fulton Terminals  site  was utilized by
the Logan Long Shingle Company to manufacture asphalt and roofing
materials.  During these operations, asphalt was stored in above-
ground tanks,  and underground tanks were used for storing fuel oil.
The'underground tanks were abandoned in 1958 when the fuel source
was converted from oil to gas.  Logan Long discontinued its asphalt
manufacturing process in  1960,  and  deeded  the property to Cities
Service Oil  Company,  which reportedly  leased the site  to other
asphalt manufacturers.

In  1972,  the  site was purchased  by Fulton Terminals,   Inc.,  a
subsidiary of Pollution Abatement Services,  Inc.  (PAS), a hazardous
waste incineration  facility in the  City of Oswego, New York.  The
site was active from 1972 to 1977 as a staging and storage area for
materials scheduled for incineration at the PAS facility in Oswego.
From December 1977 to December 1978, Fulton Terminals leased Tank
No. 1 to Inland Chemicals Corporation of Fort Wayne,  Indiana.

In April 1981, NYSDEC  was  alerted to the fact that hazardous waste
was present on-site.  In May 1981, Fulton Terminals,Inc. was cited
for not meeting federal and state standards for a hazardous waste
storage facility.   Subsequent to  that citation,  a  cleanup was
initiated by  the principals of Fulton  Terminals,  which  included
sampling,  emptying, dismantling, and removing four tanks (Nos. 2,
3, 4, and 7).  The cleanup was terminated in March 1983,  when the
principals  were  fined  by  NYSDEC  for  using  an  unlicensed  PCB
handler.  Tank samples affirmed the presence of hazardous waste,
and PCBs were detected in surface soil samples.

The Fulton Terminals site was included on the National Priorities
List in December 1982, and is currently ranked 515.

In August  1985,  the US Environmental  Protection Agency (EPA) and
NYSDEC entered into a cooperative agreement, which provided funds
for NYSDEC to perform a  remedial  investigation  and feasibility
study (RI/FS) at the site.

In September 1985, field work for the RI commenced.  The work was
conducted by NYS.DEC'S contractor,  URS Company, Inc.  (URS) .

Subsequent to the start of the RI/FS, from June 1986 to May 1987,
removal activities were  undertaken by EPA and  the potentially
responsible parties (PRPs).  These actions resulted in the securing
of  the  site  by  the  erection  of   a  fence,   the  removal  of the
remaining tanks  (Nos.  1,  5, 6, and  8) and the wastes contained in
these tanks, and  the  removal  of approximately 300 cubic yards of
contaminated soil and tar-like waste.   In addition, a storm sewer
pipe which  ran from the  site  to  the Oswego  River was partially
removed, and the end was plugged in order to prevent the migra-

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tion of contamination.   At  the present time,  there are no above-?
ground and no below-ground containerized wastes remaining on-site.

The field work for the RI/FS was completed in March 1986.
Subsequently, it was discovered that the holding times for all of
the volatile  analyses and many of the semi-volatile analyses had
been exceeded by the laboratory.   The results,  therefore,  were
declared invalid. Resampling was performed in July 1986.  An RI/FS
report, based upon  the  new data, was  completed  in the summer of
1987.  However, problems   with the data were identified, and it was
again declared invalid by NYSDEC.

EPA collected additional soil samples from the site in August and
September  1987,   to evaluate  the  need  for  additional  removal
activities.

Groundwater, surface water,  and stream sediments were resampled by
URS during January 1988.   A  revised RI/FS  report based on this new
data was completed by URS in February 1988.  Based upon the results
of the RI/FS  report, EPA determined that  the  available data were
not sufficient to fully characterize the contamination at the site.
Ebasco Services  Inc (Ebasco)  was contracted by  EPA in September
1988 to  perform a  supplemental RI/FS  in order to  complete the
characterization of the  contamination on-site and to determine the
effects, if any,  of the  off-site transport of contamination into
the adjacent Oswego  River.  Ebasco conducted the supplemental field
investigation from January through  March  1989.   Versar,  Inc. was
contracted by EPA to conduct a Risk Assessment  for the site.  In
July 1989,  Ebasco's RI/FS  report  and Versar's  risk  assessment
report were released to the public.


ENFORCEMENT HISTORY

Fulton  Terminals,  Inc   was  cited  by  NYSDEC  in May  1981  for
violations  of   standards  governing   hazardous   waste   storage
facilities.  On November  10, 1981, a consent order was entered into
between  NYSDEC  and Fulton Terminals,   Inc.,  requiring  Fulton
Terminals, Inc.  to  perform a  partial  cleanup of  the  site.   The
cleanup activity was halted in March 1983 when  the principals of
Fulton Terminals, Inc. were fined by NYSDEC for using an unlicensed
PCB hauler during the cleanup.

In regard to the  RI/FS at the site, EPA notified the PRPs by letter
that they  may be liable for  the  conditions  at three NPL sites
(Clothier Disposal,  Fulton Terminals, and Volney Landfill).  That
letter also notified them that EPA intended to conduct investiga-
tions and  corrective measures at the  sites unless a responsible
party  volunteered  to  do  such  work.    No  responsible  party
volunteered  to  conduct  the  RI/FS.   An  EPA Action  Memorandum
approved on June 27, 1986 set  forth a removal action for removal

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and  disposal  of the  remaining on-site tanks  and drums  and the
excavation and disposal of visibly contaminated soil.

On August 4,  1986 EPA  issued notice letters  for the removal action
to Fulton PRPs.  The Fulton PRPs then formed a steering committee
in order to facilitate discussions amongst the parties and EPA.

On September  30,  1986,  EPA issued two Administrative Orders for
the  conduct  of  removal  actions  (i.e.  a  consent  order and  a
unilateral  order).    Pursuant  to  the Administrative Order  on
Consent, 65 PRPs  at the Fulton Terminals site agreed to the removal
and disposal of the tanks and their contents.

A second Administrative Order unilaterally ordered 7 PRPs who had
declined to  enter  into the Consent  Order to join with  the con-
senting PRPs to  perform the action required in the Consent Order
and to perform other  actions  set forth in the Action Memorandum.
The consenting PRPs performed  the work as agreed under the consent
order.  However, only one of the  non-consenting  PRPs which were
issued the Unilateral Order complied with it.

On September 28,  1987  EPA sent a demand letter to each of the PRPs
requesting reimbursement of all  costs that  have  been and will be
incurred up to the  issuance of the ROD.  Discussions regarding the
reimbursement of past costs were suspended pending the completion
of the RI/FS and the issuance of a ROD for the site.

The PRPs were contacted through the steering committee in September
1988 and were  asked whether they would be interested in undertaking
the  proposed  sampling and preparation of  a  supplemental  RI/FS
report.   An outline  of  the  proposed work was  sent to  the PRP
steering committee.  On September 19, 1988, the PRPs  informed EPA
that they chose not to undertake the proposed work.


COMMUNITY PARTICIPATION

USEPA and NYSDEC have kept the local citizens advised throughout
the Superfund process at the Fulton Terminals Site.   In September
1988, EPA awarded a Technical  Assistance Grant  (TAG) to the Fulton
Safe Drinking Water Action Committee for  Environmental Concerns,
Inc.  (FSDWAC), a citizens'  group, for the  hiring of a technical
advisor.  FSDWAC hired a technical advisor in June 1989.

In June 1987,  a public meeting was held to solicit comments on and
to discuss the findings of the RI/FS report issued in June  1987 and
the proposed remedy that was  based on the data presented in that
report.   The data were  later determined not  to be  valid.   The
supplemental RI/FS that was initiated by  EPA in January 1989 and
e Proposed Plan  for the  Fulton  Terminals site were released for
public comment in July 1989.  A public comment period was held from
July  7,  1989  through September  8,  1989.    In  addition,  a public

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meeting was held on July 26,  1989,  to discuss and receive comments
on the Supplemental RI/FS and the Proposed Plan.  Questions raised
at the public meeting and letters received and their corresponding
responses are  summarized in  the Responsiveness Summary, which is
part of this Record of Decision.


SCOPE AND ROLE OF RESPONSE ACTION

Prior cleanup actions by the State, EPA and the PRPs have already
addressed most of the contamination at the Fulton Terminals site.
These actions have resulted in the  removal of all above-ground and
underground tanks and of 300 cubic yards of contaminated soil.  The
low levels of  soil  contamination remaining  at  the site have been
found to present minimal risk to human health.

This  remedy  considers  the  fact  that  the  most  mobile  soil
contaminants at  the southwestern  portion of the site have been
released into  the groundwater, through rain water infiltration,
and that  a  plume of  contaminated groundwater,  which currently
exceeds State  and Federal  groundwater  quality  standards,  poses a
risk of off-site migration of contaminants to  the  nearby Oswego
River.

The  selected  remedy addresses  the  contaminated  soils  in  the
southwestern portion of the site and the contaminated groundwater
underlying the site.   The treatment of soils  to  remove the most
mobile wastes will result in  the elimination of a long-term source
of groundwater contamination,  and  it will mitigate  the risks to
public health and the environment associated with the migration of
those contaminants off-site.   The selected remedy mitigates those
risks by removing the most mobile wastes from the  soil,  leaving
only the less mobile organic  and metal  compounds in the soil to be
placed back into  the excavated area (provided that  the treated soil
has passed  the TCLP toxicity  test).   In addition,  the selected
remedy achieves federal and state groundwater quality standards for
the organic  contaminants by  providing the  required contaminant
removal during treatment of the groundwater utilizing air stripping
and carbon adsorption.

The purpose of  this response is  to  ensure  protection of  the
groundwater  and  surface water  from  the  continued  release  of
contaminants from soil,  and  to restore the  groundwater to levels
consistent with  state and  federal  water quality standards.   This
will be the final response action for this site.


SUMMARY OP 8ITB CHARACTERISTICS

Eight storage  tanks,  including  five above-ground,  one partially
above-ground, and two below  ground, were  known to have been used
to store hazardous  wastes  at the Fulton Terminals site from 1972

                                8

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to 1977, when the site was used as a staging and storage area for
materials scheduled for incineration at the PAS facility in Qswego,
New York.   Leakage and spillage from these  tanks  appear to have
been the primary source of  contamination at  the site.  The tanks
and their contents were removed by  the PRPs under EPA oversight in
the period from  1981  to  1986.   Three  hundred  cubic  yards  of
visibly-contaminated surface soil were also removed from the site
during that same period.

Analyses of  soil,  groundwater, sediment, and  surface water from
the site  and adjacent  areas indicate that  the majority  of the
contamination remaining at the site is concentrated in the soil in
the southwestern portion of  the site and in the underlying sand and
gravel aquifer.

Tables I,  2,  and 3 summarize the  range  and  the maximum contami-
nants  for  the  soil,  groundwater,  and   surface  water/sediment,
respectively.


SOIL

The characterization  of the soil contamination is based upon 79
soil samples collected  from 36 locations in  August and September
1987 and in January and  February 1989. These  samples were analyzed
for the full range of compounds specified in the target compounds
list (TCL).

Volatile organic  contamination in the soil  including trichloro-
ethene,   vinyl   chloride,   benzene,  xylene,  and   trans-1,2-
dichloroethene is concentrated at the southwest corner of the site.
High contaminant levels were detected at the surface and extended
to about 8 to 10 feet below ground  surface.   The locations of soil
samples with volatile organic contaminants are depicted in Figure
2.   The maximum volatile  organic concentration  (309 ing/kg) was
detected at  sample location U3 at 0-2 feet.   Volatile compounds
present included xylene (99 mg/kg),  styrene (79 mg/kg),  trichloroe-
thene (44 mg/kg), ethylbenzene  (40 mg/kg) and toluene  (20 mg/kg).
The second highest concentration of total volatile  organics (TVOs)
was 240 mg/kg,  and it  occurred at sampling location SB-14  at  a
depth of 2-4  feet.  The sample was  composed entirely of xylene.
High concentrations of  TVOs were also detected in locations SB-6
(64 mg/kg), SB-7 (121 mg/kg), and U2  (26  mg/kg).  All  of the above
locations  coincided with  or were in the proximity of the former
locations of above-ground tank nos 1, 2,  and 3.

Semi-volatile organic contamination occurs throughout  the site.
The highest  concentration  of  semi-volatiles was  found  at loca-
tions SB-14 and SB-10.  The total  concentration of semi-volatile
contamination at SB-14  was  31  mg/kg, and it  was found at a depth
of 2-4  feet.  The concentration of  semi-volatile organics at SB-10
was also  31 mg/kg, and it occurred at  8-10  feet.   The primary

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constituents of semi-volatile contamination at location SB-14 were
2-methylnaphthalene   (15  rag/kg)  and  naphthalene   (9.4  mg/kg).
Primary  semi-volatile  constituents  at  location SB-10  included
pyrene  (16 mg/kg)  and  phenanthrene  (10  mg/kg).   Carcinogenic
Polynuclear  Aromatic  Hydrocarbons  (CPAHs)   were also  detected
throughout the site and at  concentrations comparable to those at
off-.site  sampling  locations  (SB-25  and  SB-27) .   The  maximum
concentration of 10 mg/kg occurred at 6-8  feet at SB-3, which also
had volatile organics present, and lies within the primary area of
soil contamination in the southwestern portion of the site.  SB-
10, which had the  maximum total semi-volatile concentration, had
only 0.8 mg/kg CPAHs.   Figure 3 depicts  the total concentrations
of CPAHs and pyrene.

Heavy metal (inorganic) concentrations were generally low and well
within the typical values for soil reported for the eastern region
of the United States.
GROUNDWATER

Groundwater samples were collected in February and March 1989 from
21 monitoring wells installed on and adjacent to the  site.  Ten of
these wells had also been sampled previously during January 1988.
All groundwater samples from both rounds of sampling were subjected
to complete TCL analyses.

Volatile organic contaminants were detected in 15 of  21 wells (see
Figure 4)  predominantly in the shallow aquifer  (till,  silt and
clay, and sand and gravel units).

The highest total volatile organic contamination (17,672 ug/1) in
groundwater occurred  at Well  EBMW-3D,  screened in  the  sand and
gravel unit.  The primary constituents were cis-l,2-dichloro-
ethene   (14,387   ug/1),  trichloroethene   (2,388   ug/1)   1,1/1-
trichloroethane  (113  ug/1),  vinyl chloride  (88 ug/1)  and 1,1-
dichloroethene  (50  ug/1).    This well  is located at  the former
location of Tank No.  1, and approximately 20  feet from soil boring
SB-6, which had the second highest TVO concentration for soil on-
site, and was composed of the same constituents as well EBMW-30.

The second highest concentration of TVOs  (1,621 ug/1) occurred at
well FBW-6.  Compounds detected included ethylbenzene (432 ug/1),
benzene  (423  ug/1),  chlorobenzene  (162  ug/1), and  toluene (65
ug/1).  Well FBW-6 was screened from 6-10 feet across the structu-
ral fill and the silt and clay unit.  All other wells showed much
lower volatile organic contamination.

Several volatile  organic compounds  (benzene,  ethyl-benzene, and
xylene) were also detected in upgradient wells, which is indica-
tive  of  the  existence of  other  sources  contributing to the
groundwater contamination at the site.

                                10

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Specifically,  benzene  was  detected  in  three  shallow  aquifer
upgradient wells (FSW-1S, EBMW-6S, and EBMW-6D) at concentrations
exceeding groundwater quality standards, and ranging from 10 ug/1
to 88 ug/1.  Upgradient xylene and ethylbenzene concentrations were
106  and  85  ug/1   (EBMW-6S),   and   88  and  56  ug/1  (EBMW-6D),
respectively.

Semi-volatile organic  contaminants  were detected  in  the ground-
water both on-site and  off-site,  but at low concentrations.  The
maximum concentration of total  semi-volatile organics was 109 ug/1
and it was detected in on-site Well FBW-6.  Semi-volatile compounds
present  at  FBW-6  included  naphthalene  (92  ug/1),  and  1,2-
dichlorobenzene (11 ug/1).  Of the semi-volatile organics only 1,2-
dichlorobenzene  exceeds  New   York  State   Groundwater  Quality
Standards (4.7 ug/1).

Heavy metals  were  detected in the  groundwater at concentrations
exceeding groundwater quality  standards both  at  on-site and off-
site  wells.    Metals  exceeding  groundwater  standards  included
arsenic,  barium,  cadmium,  chromium  and  lead.    The  maximum
concentrations detected  for  on-site wells,  upgradient wells,  and
off-site  wells  are  tabulated  below.   All  concentrations  are
reported in ug/kg (ppb).
Arsenic
Barium
Cadmium
Lead
Nickel
Chromium
   On-Site
(Cone./Well No.l

  48.1/FBW-6
  2700/FBW-6
  21.4/EBMW-2
   241/FBW-3
   259/EBMW-5
   229/EBMW-5
   Upgradient
(Cone./Well  No.)

   58.2/FBW-1S
11,200/FBW-1D
   60.1/FBW-1D
    364/FBW-1S
  2,500/FBW-1D
10,800/FBW-1D
    Off-Site
rCone./Well  No.l

    19.5/FBW-4S
  21,100/FBW-4D
     5.1/FBW-4S
    54.l/EBMW-7
   1,180/FBW-4D
   1,690/FBW-4S
The  above  table  indicates  that metal  concentrations  in  the
groundwater  surrounding  the  site  are higher  than  the  metal
concentrations in the groundwater underlying the site, in
different hydrologic units.  Therefore, it appears that the
metals in the groundwater in the area may be naturally occurring.
According to the Oswego County Health Department,  four municipal
wells, located outside the  influence of the site adjacent to the
Oswego River,  recently taken  out of service had  shown elevated
levels of metals that  have  been attributed to the naturally high
levels of the metals in the lodgement till.
SURFACE WATER AND SEDIMENT

Surface water  and  sediment samples were taken  from  a total of 7
locations shown on  Figure 5.  The sampling locations were upstream,
adjacent to  and downstream from the Fulton  Terminals site.  All
                                11

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surface water and sediment samples were subjected to complete TCL
analyses.

The  surface  water samples collected  were virtually free  of TCL
organic contaminants.  Heavy  metals were detected at uniformly low
levels upstream, adjacent to and downstream from the site.

Sediment samples  were collected from the same locations  as the
surface water samples.   No volatile organic  contaminants were
detected in the sediment.  Seventeen semi-volatile compounds were
detected at similar concentrations upgradient (FSS-1) and, adjacent
to the  site  (FSS-2,  and SD-3).  The  maximum total semi-volatile
organics  concentration,   9.2  ing/kg,  occurred  at  location SD-3
adjacent  to   the  site.    The   total   semi-volatile  organics
concentration at the upgradient sediment location was 7.7 mg/kg.

Inorganic  concentrations  were  not   elevated  in  the  locations
adjacent to the  site,  as would be expected  if  the occurrence of
semi-volatiles was attributed to the washing of sediment from the
site. The semi-volatiles, therefore, are believed to be attributed
to activities along  the  banks  of the  canal (where  a loading dock
was utilized  for  the asphalt manufacturing process),  rather than
to sediment transport from the site.


SUMMARY OP SITE RISKS

Organic chemicals at  the  Fulton Terminals site, that were apparent-
ly released through spillage  and leakage of waste chemicals stored
in above- and below-ground tanks,  have contaminated the soil and
the groundwater underlying the  site.   Predominant transport routes
identified  for  the  migration  of  those  contaminants  to  other
environmental media  include:   1) volatilization of  the volatile
organic compounds from the soil and subsequent releases (emissions)
to air;  2)  movement through soils (percolation)  to groundwater; 3)
release to surface water, in the Oswego River adjacent to the site,
through discharge of the contaminated groundwater;  and 4) surface
runoff of soil contaminants to the Oswego River.


CONTAMINANT IDENTIFICATION

The risk assessment  for  the  Fulton Terminals site  has identified
10 contaminants of concern.  These include four non-carcinogenic
and 6 carcinogenic  compounds.   These  compounds or elements were
selected  because  of  their  highly   toxic effects,  potentially
critical exposure routes, and  higher concentrations  present in
comparison to other contaminants.  The indicator chemicals chosen
for this study were:
                                12

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     Noncarcinoaens                Carcinogens

     chlorobenzene                "pyrene
     1, 2-dichloroethene           benzene
     barium                        trichloroethene
     .methylisobutylketone          vinyl chloride
                                   arsenic
                                   nickel

The  volatile  organic compounds  were  selected because  of  the
frequency  of   occurrence   of  these  compounds   in   soils  and
groundwater,  and  their  toxic  effects.   Comparison  of  metals
concentrations  in  soil at the  Fulton  Terminals site to  that of
regional averages  (see Table 4) shows no appreciable differences.
However, arsenic, nickel, and barium were included to address any
potential public concerns that  may  be  expressed due to arsenic's
high carcinogenic  potency  factor and  the  prevalence,  concentra-
tion,  and  relative toxicity  of nickel and  barium.   Pyrene  was
included based  on  historical operations at  the Fulton Terminals
site (roofing and asphalt work) that may have contributed to site
contamination and  also due to  its  relatively high concentration
and toxic effects.

All of the contaminants of concern were detected in both the soil
and the groundwater with the exception  of pyrene that was detected
only in soil.   The concentrations of the  contaminants of concern
on which the risk  assessment  was based are shown on Tables 5 and
6.  The concentrations used for soil are the  geometric mean of the
surface soil contaminant concentrations.  The groundwater concen-
trations  represent  contaminant  concentrations  in  groundwater
discharging into the  Oswego River,  and they were  estimated from
actual  well concentrations  using  a  model.   Direct  ingestion
exposure to contaminated groundwater is not expected at the site.
EXPOSURE ASSESSMENT

The following  potential  exposure routes were  identified for the
Fulton Terminals site:

     (1) Direct contact (ingestion) with contaminated soil at
     the site;

     (2) Direct  contact  (dermal) with  contaminated surface
     water  during  recreational  uses  (swimming,  boating,
     fishing) of the Oswego River;

     (3) Ingestion  of contaminated  surface water  and fish
     during recreational use of the Oswego River; and
                                13

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     (4)  Inhalation  of   volatile  organics  emitted  from
     contaminated soils at the site.

Dermal absorption of contaminants through direct contact with soil
is expected to be negligible due  to the properties  (high partition
coefficients) of the site  contaminants that  favor retention of the
contaminants  by the  soil particles  rather than  desorption and
active transport across the skin barrier.

With regard to the groundwater, the principal concern for exposure
stems from the discharge of the contaminated water underlying the
site into the Oswego River.  No ingestion  exposures were identified
for groundwater users near  the Fulton Terminals  s  ite.   The city
of Fulton's water supply source is derived from wells south of the
city limits  (Great  Bear Wells) and augmented by  lake water piped
in from Lake Ontario which is not expected to be influenced by any
groundwater contamination from the Fulton Terminals site.


soil

Exposures through direct contact  (ingestion)  with  soil are expected
to be minor as the  site  is fenced and  secure  from unauthorized
entry.   The  exposure  scenario developed  for the  risk assessment,
however, is a worst case scenario that assumes free access to the
site by neighborhood children.

Mean contaminant concentrations in shallow soil samples of 0 to 2
feet (Table  5)  were used to  calculate direct contact exposures.
Thirty-six samples comprise the population of surface soil samples.
Each  sample   concentration  was  given  equal  weight   in  the
determination of mean contaminant concentration.
surface Water (Osweoo River)

Two distinct exposure routes  were identified related to contami-
nants that migrate to the Oswego River.  Dermal exposures may
occur to individuals who use the river for recreation.  Ingestion
exposures  may occur  to  those consuming  fish  from the  river.
Contaminants are generally sorbed onto soil particles at the soil
surface or they exist in a dissolved state around soil particles.
During rainfall events, these soil particles are conveyed by runoff
streams from the Fulton Terminals site into the Oswego River.

The amount  of contaminants that  will  be conveyed  to the Oswego
River from the Fulton Terminals site during a runoff event, both
in  suspended  form  (PX)  and  in  dissolved  form (PQ), have been
estimated using a model and are shown below.
                                14

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               CALCULATION OF SORBED AND DISSOLVED
                CONTAMINANT LOADS TO OSWEGO RIVER
                    FROM SURFACE WATER RUNOFF
                                         PX             PQ
Contaminant  •	(kg)	Ckgj	

arsenic                                4.82E-06       3.28E-07

barium                                 9.44E-08       9.00E-07

benzene                                7.08E-09       2.97E-00

chlorobenzene                          8.62E-09       8.39E-07

1, 2-dichloroethene (total)            5.16E-09       3.07E-06

4-methyl-2-pentanone (MIKB)            9.51E-09       1.58E-05

nickel                                 1.17E-08       6.90E-08

pyrene                                 1.82E-07       1.54E-07

trichloroethene                        8.46E-09       2.16E-06

vinyl chloride                         9.83E-09       5.54E-06

The transport of contaminants to the Oswego River through discharge
of the  contaminated groundwater underlying the  Fulton Terminals
site has  also been estimated  using a model  that relies  on the
concentration of  contaminants  measured in the monitoring wells.
The loading of contaminants to the Oswego River through groundwater
discharge is shown in Table 6.


Air

Volatile organic compounds found  in the  soil  at  Fulton Terminals
are expected to-volatilize, that  is evaporate  to the atmosphere.
The risk assessment has estimated  releases (emission rates) of the
organic  contaminants   of  concern   by  using  weighted  average
concentrations  of  the volatiles   for   areas  exhibiting  soil
contamination above 0.8 mg/kg.  This value was chosen because areas
with less than  0.8  mg/kg were  too discontinuous  and separated to
be representative of overall contamination.

Emission  rates  for the 5 chemicals of  concern most  likely to
evaporate to the atmosphere were estimated for short-term and long-
term exposures  ranging  from 10 days to 365  days  (short-term) and
70 year (long-term), as shown  in Table 7.

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Populations  potentially  exposed at  the  Fulton Terminals  site
include recreational users  of  the Oswego River near the site and
neighborhood children trespassing on to the site.

Total  body burden  rates were  computed  based on  all  potential
exposure routes using an average body mass of 70 kg (adult) or 10
kg  (child), an  inhalation rate of 22.0  cubic  meters/day,  and an
average 70-year  lifetime.   It was assumed that dermal exposures
(swimming, wading,  etc.) would  occur in  20  out of  the 70-year
average lifetime, while ingestion exposures (fishing)  would occur
in  40  out  of  an average 70-year lifetime.   Estimated short- and
long-term  time-weighted average  daily  doses  for  each chemical
subchrbnic  oral  intake  ranged from 4.68E  mg/kg/day  (chloro-
benzene) to 2.22E-03 mg/kg/day (barium).   Subchronic intake levels
for  inhaled  toxic substances  were  lower,  ranging  from 1.57E-08
ing/kg/day (chlorobenzene) to 9.59E-08 mg/kg/day  (trichloroethene).


TOXICITY ASSESSMENT SUMMARY

Cancer  potency  factors  (CPFs)  have been developed  by  EPA's
Carcinogenic Assessment Group for estimating excess lifetime cancer
risks  associated  with  exposure   to  potentially  carcinogenic
chemicals.  CPFs, 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 provide an upper-bound estimate  of the excess
lifetime cancer risk associated with exposure at that intake level.
The term "upper bound"  reflects  the  conservative estimate of the
risks  calculated from  the  CPF.   Use  of  this approach  makes
underestimation of the actual cancer  risk highly unlikely.  Cancer
potency   factors   are   derived  from   the  results   of   human
epidemiological  studies  or chronic  animal  bioassays to  which
animal-to-human extrapolation  and  uncertainty  factors  have been
applied.

Reference doses  (RfDs)  have been developed by EPA for indicating
the potential for adverse health effects from exposure to chemi-
cals exhibiting noncarcinogenic effects.  RfDs,  which are expressed
in  units of  mg/kg-day,  are  estimates  of lifetime daily exposure
levels  for  humans,   including  sensitive  individuals.   Estimated
intakes of chemicals from environmental media  (e.g., the amount of
a  chemical  ingested  from  contaminated   drinking  water)   can  be
compared to the RfD.  RfDs are derived from human epidemiological
studies or animal studies to which  uncertainty factors have been
applied (e.g., to account for the use of animal  data to predict
effects on humans).  These uncertainty factors help ensure that the
RfDs   will  not   underestimate   the   potential  for  adverse
noncarcinogenic effects to occur.

The cancer potency  factors  and the RFDS  for  the contaminants of
concern at the Fulton Terminals site are  listed in Table 8.

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RISK CHARACTERIZATION SUMMARY

Risk characterization  for the Fulton Terminals  site included an
assessment of risk associated with exposures to noncarcinogens and
carcinogens.  Noncarcinogenic  risks  were  assessed using a hazard
index computed  from  expected daily  intake levels (subchronic and
chronic) and  reference  levels (representing acceptable intakes).
Hazard index scores of 5.05E-02 (subchronic)  and 1.34E-04 (chronic)
were obtained.    The hazard  index  scores  are  well  below unity
indicating a negligible noncarcinogenic health impact.

Potential carcinogenic risks were computed by multiplying chronic
(long-term)  intake levels by  a respective  carcinogenic  potency
factor.  The  cumulative upper bound  excess  lifetime risk for all
carcinogens (all routes) was 2.35E-07.  The highest risk computed
for a given chemical  (arsenic)  was 1.72E-07, all derived from oral
exposures  (predominately from ingestion of contaminated soil).

The quantified carcinogenic risks for each contaminant of concern
as well as the combined carcinogenic  risks for all contaminants of
concern for the major  exposure routes (inhalation and ingestion)
at Fulton Terminals are presented in Table 9.

The potential for noncarcinogenic effects for each contaminant of
concern and the combined potential for noncarcinogenic effects as
expressed  by  hazard  indices  (HI)  are presented  in  Tables 10 and
11.

Excess lifetime cancer risks are probabilities that are generally
expressed  in  scientific notation  (e.g.,  IxlO*6 or 1.0 E-06).   An
excess  lifetime  cancer  risk  of  l.OE-06 indicates  that, as  a
plausible  upper bound, an  individual has  a  one in  one  million
chance of  developing cancer  as a  result  of site-related exposure
to a carcinogen over a 70-year lifetime under the specific exposure
conditions at a site.

Potential  concern   for   noncarcinogenic  effects  of  a  single
contaminant in a single medium is  expressed as the hazard quotient
(HQ)  (or  the  ratio of  the  estimated intake  derived from the
contaminant concentration in a given medium to the contaminant's
reference dose).  By adding the HQs for all contaminants within a
medium  or  across all  media  to  which  a  given population  may
reasonably be exposed,  the Hazard Index (HI)  can be generated.  The
HI provides  a useful  reference point for gauging  the potential
significance  of multiple contaminant exposures within  a single
medium or across media.

The context within which  to  judge the relative risk from each of
the pathways  has  been  established by EPA.   For carcinogens, the
target risk range is a E-07 to E-04  excess lifetime cancer risk.
For  noncarcinogens,  where the sum  of expected  dose/Rfd ratios

                                17

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exceeds  unity (1.0),  observed concentrations  pose unacceptable
risks of exposure.

For the Fulton Terminals site,  the upper-bound risk  from potential
carcinogens was calculated to be 2.35E-07.  Therefore, the existing
site, condition is already at the lower limit of the acceptable risk
range.  Both the chronic and sub-chronic hazard indices were less
than unity, which implies that  daily  intake of the noncarcinogenic
contaminants would not present  any adverse effects to human health.
Therefore, the site poses minimal threat to human health.

Environmental impacts overall are expected to be minimal; however,
localized impacts are expected in stream bed sediments because of
the presence of several semi-volatile organic com- pounds.  These
compounds  may directly  impact benthic  organisms   (predominantly
invertebrate   species).      Estimated    (modeled)   contaminant
concentrations  in the  Oswego  River were  well  below all  acute
toxicity criteria for fresh water.
CLEANUP LEVELS FOR THE CONTAMINATED MEDIA
Groundvater

The groundwater at the Fulton Terminals site was classified by New
York  State as  class  "GA",  which  indicates  that  the  water  is
suitable as a drinking water supply.   The RI  has determined that
contaminants  from   the   site  have   contaminated   the  on-site
groundwater.  A plume of contaminated groundwater presents a risk
of off-site migration of contaminants to the nearby Oswego River.
The remedial response objectives therefore include the following:

- ensure  protection  of  groundwater and  surface water  from the
continued release of contaminants from soils;  and

- restore groundwater to levels consistent with state and federal
water quality standards.

Several federal and New York State standards regarding the quality
of groundwater suitable for  drinking are  listed  in  Table 12.   A
comparison of the concentrations of  the contaminants of concern in
the groundwater  to  these  standards reveals  that most volatile
organic compounds exceed  the regulatory  concentrations.    As  a
result,  the  groundwater   cleanup  levels  should meet   the  most
stringent of the federal and state standards listed in Table 12.

However, benzene,  ethyl  benzene and  xylene may  exceed drinking
water standards  at the end  of the remediation,  since  they were
detected at higher concentrations  in  off  site  upgradient wells.
If this is the case,  a separate investigation will  be undertaken
by NYSOEC  to  define  and eliminate  the source of the upgradient

                                18

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contamination, and to treat the groundwater, if required, to meet
drinking water standards.

Many  of  the  metal  concentrations in  the groundwater  at Fulton
Terminals  exceed both  Federal  Safe Drinking  Water Act Maximum
Contaminant  Levels  (MCLs)  and  New York  State  drinking  water
standards.    Upgradient and  off-site   groundwater  samples  were
obtained and analyzed for the  same contaminants.  The following is
a  tabulation of  the maximum concentration detected  from  site,
upgradient,  and  off-site samples for selected metals.   However,
the values  for  each  parameter are not  necessarily  from the same
hydrologic unit.

                    Site           Upgradient          Off-Site
Metal                fppbl            fppbl               fppb)

Arsenic               48.1            58.2                 19.5
Barium              2,700          11,200              21,100
Cadmium               21.4            60.1                  5.1
Chromium              229          10,800               1,690
Lead                  241             364                  54.1
Nickel                259           2,500               1,180

The above table shows the occurrence of high metal concentrations
in the groundwater throughout  the area surrounding the site and in
wells outside the influence of  the site  which seems  to indicate
that these metals are naturally occurring.
In order to remediate the groundwater, it is necessary to remediate
volatile  organic  contaminants  detected  in   the  soil.     The
contaminants must be remediated  to concentrations where leaching
into groundwater will result in levels below MCLs.

The  most mobile  of  the  contaminants of  concern  (the  volatile
organic  compounds) were used  to calculate soil  cleanup levels.
Xylene was also included in the cleanup calculations since it was
detected at high levels in the area around borehole SB-14.

Pyrene, arsenic, barium, and nickel were  also used as contaminants
of concern for the risk assessment.   Pyrene is relatively immobile
compared  to  volatile  organics and  was  not detected  in  any of
groundwater samples.   Arsenic, barium,  and nickel were all found
to be present  in  groundwater samples.   However, these inorganics
are  widespread on-site  and off-site  with concentration  ranges
within the typical values of the eastern United States.  Therefore,
                                19

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cleanup levels  for pyrene, arsenic,  barium,  and nickel  are not
warranted.

Cleanup  calculations  assumed  that  eight  inches  per  year  of
rainwater will  percolate  through the contaminated  zone  and will
mix with  the  groundwater.   A dilution  factor  is calculated from
the.mixing with groundwater.  To meet the applicable or relevant
and appropriate federal  and state requirements  (ARARs)  the soil
cleanup levels would be:

                    DCE                        1 ppm
                    TCE                        2 ppm
                    Benzene                  1.4 ppm
                    Vinyl Chloride           0.4 ppm
                    Xylene  (total)             8 ppm
                    Chlorobenzene            5.5 ppm
                    MIBK                     2.5 ppm

The  soil  cleanup   levels  were  compared   to  the  contaminant
concentrations identified in each soil boring sample.  Any samples
with  contaminant  concentrations below  the cleanup levels  are
considered clean.

It should be noted that these  cleanup  levels were calculated based
on an estimated area of  contamination.   The soil  cleanup levels
will be recalculated during the remedial  design,  after the boun-
daries of contamination  in the  southwestern portion  of  the site
have been more precisely defined by additional sampling.   Futher-
more,  the extent  of  contamination in  the  northeastern portion of
the site  will  be defined  by  additional  sampling  between  soil
borings U4 and U6, where  xylene  was  detected at 8.8 and 3.8 mg/kg,
respectively, and the surrounding clean borings.

The depth of contamination varies with  each borehole.    For  a
conservative estimate,  it is assumed that contamination has reached
the groundwater table, which is approximately twelve feet deep
within this  area.   For  source control  remediation,  it  is not
necessary to excavate and remediate the soil  below the water table,
as any contaminated soil below the water table will be remediated
by  the  groundwater   alternative.     Therefore,   the  depth  of
contamination for the  source control remedy will be  defined as
twelve feet betow the  ground  surface.  Using  the  same criteria,
the  depth  of  contamination  at  boring  SB-14  is  defined  as
approximately eight feet below the surface. The approximate volume
of contaminated soils above the  soil cleanup levels at the Fulton
Terminals site is 4,000 cubic yards.

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


                                20

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DOCUMENTATION OP SIGNIFICANT CHANGES

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


DESCRIPTION OP ALTERNATIVES

All  the   above  ground   and   underground  storage   tanks  and
approximately 300  cubic yards of visibly-contaminated surficial
soil have  been  removed from the site.   The levels  of soil con-
tamination  on-site  present  risk  levels which  are  within  EPA's
acceptable range.  However, contaminants remaining at the site have
contaminated the underlying groundwater exceeding federal and state
groundwater  quality  standards.  Specifically,  a source  of soil
contamination at the southwestern portion of the site is releasing
organic  contaminants  into  the  groundwater  through  rainwater
infiltration, and a plume of  contaminated groundwater exceeds ARAR
and poses a  risk  of off-site migration  of  contami-  nants to the
nearby Oswego River.   The alternatives described below address the
remaining soil contamination at the site and the contamination in
the groundwater underlying the site.

A  total  of seven  alternatives  were  evaluated in detail  for
remediating  the site.   Four  remedial  alternatives address  the
contaminated soils that contribute to groundwater contamination at
the Fulton Terminals site.  In addition,  three alternatives address
the contamination  in  the  groundwater beneath  the  site.   These
alternatives are as follows:
Soil Alternatives

Alternative SC-1:  No Action

The Superfund program requires that the "no-action" alternative be
considered at every site.  Under this alternative,  EPA would take
no further action to control the source of contamination.  However,
long-term monitoring of the site  (for a minimum period of 30 years)
would be  necessary to  evaluate  the  performance of  SC-1,  and to
monitor contaminant migration.  Monitoring would consist of annual
soil, sediment,  and  surface  water sampling  and analyses  for a
variety of  contaminants.  Samples would be  analyzed  for Target
Compound List parameters.  Finally, the 6-foot high chainlink fence
that was installed around the site will be retained.

Because this alternative would result in  contaminants remainig on-
site, CERCLA requires that the site be reviewed every five years.
If justified by the review, remedial actions might be implemented
                                21

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at  that  time to remove  or  treat wastes.   The estimated present
worth cost for this alternative is $342,000.

Alternative SC-2;  Excavation and Disposal

This alternative involves excavating the contaminated soil down to
the water table,  placing  it in trucks and disposing of the material
in  a Resource Conservation  and  Recovery Act  (RCRA)  authorized
hazardous waste landfill.

The approximate area of contaminated soil that would be excavated
is  shown in  Figure  6.   The contaminated  areas consist  of two
circles, one  with  a 100-foot diameter  surrounding borings SB-6,
SB-7, U2, and U3 and  another with a 50-foot diameter surrounding
boring SB-14  in the vicinity of  the removed Tanks Nos.  1,  2, and
3.   Contaminated soils were found at depths ranging  from  0 to 2
feet at  the eastern boundary of  the excavation area to depths of
6-8  feet at  the  southwestern boundary.   Additionally,  the areas
surrounding soil borings U4 and U6 might have to be excavated, if
the contamination in these areas exceeds the recalculated cleanup
levels, as stated on page 20.

Prior to the excavation of site soils, a  field investigation would
be performed to delineate areas of contamination within the cleanup
goals.   This investigation  will  focus in defining the  exact
boundaries of contaminated soil in the southwestern portion of the
site.  Approximately 4,000 cubic  yards  (CY)  of soil is estimated
to be  contaminated  with  volatile and semi-volatile organics and
would  be excavated  and  then  transported to  an  off-site  RCRA-
permitted landfill for disposal.

RCRA manifest requirements,  under  40  CFR  262  and 263, must be
complied with for all  wastes  shipped off-site.  Effective November
8, 1990,  VOC-contaminated soil and debris resulting from a response
action taken  under  Section  104  or 106 of CERCLA or a corrective
action required under Subtitle C of RCRA are prohibited from land
disposal without treatment.  Until that date, these wastes may be
disposed in a landfill only  if such a unit  is  in compliance with
the requirements specified in 40 CFR 268.5(h)(2).  In addition, a
treatability variance for soil and debris must be  obtained from EPA
under  40 CFR  2j68.44.    To  obtain  a site-specific treatability
variance, it must be shown that  the waste is a contaminated soil
and debris and the current  treatment standards  for contaminants
detected  in  soil  and debris cannot  be  met or  the  treatment
technology upon  which the  current  standards  are based  is not
appropriate.   In order  to  gain  administrative  approval  of this
alternative, the  remedial action  must be  implemented and completed
prior to November 8, 1990 deadline.

Upon completion of  the excavation, all  excavated areas  would be
backfilled with clean  fill,  a one-foot  layer  of purchased clean
top soil would be placed on  the  site,  the site would be regraded

                               22

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to  promote drainage,  and  it would  be  revegetated to  prevent
erosion.

The excavation of contaminated soil and subsequent disposal in a
RCRA  landfill  would significantly decrease  the risks  to public
health and  the environment associated with  leaching of contami-
nants into groundwater.  The estimated present worth  cost for this
alternative is  $2,927,000.   The estimated time  to implement the
alternative is approximately 15 months.

Alternative SC-3;  Low Temperature Thermal Extraction

This alternative involves the excavation and on-site treatment of
approximately 4,000  CY of contaminated soils by low temperature
thermal treatment.   The excavated soil  would be fed to a mobile
thermal treatment unit brought to the site, where hot air injected
at a temperature above the boiling points of the organic contami-
nants of concern would allow the  moisture and the organic contami-
nants to be volatilized into gases and escape from the soil.  The
organic vapor extracted from the soil would then be treated in an
air pollution control unit to ensure acceptable air quality emmi-
sions.  Several  thermal treatment methods (such as heated screw
conveyors, rotary calcination devices etc.) may be applicable.  A
variety of air  pollution  control  options  are also  available,
including after-burners,  activated carbon  absorbers, and conden-
sers.  The specific type of the thermal treatment method  and of the
air pollution control  would be determined  in the Remedial Design
phase through engineering design and analysis and the competitive
bidding process.

All the residuals  from the treatment (such  as  spent carbon from
the carbon adsorption units) would be sent to  an off-site hazardous
waste facility for treatment and disposal.  Air pollution control
systems would be an integral part of the treatment plant to limit
emissions to within the regulatory requirements.   The  treated soils
would be  replaced  into the excavated areas  from which  they were
removed, one-foot of clean  top soil would  be placed on the site,
and the site  would be regraded  and revegetated to  prevent soil
erosion.

Long-term monitoring is  not required  with  Alternative SC-3 since
contaminated soils would be successfully treated. The contaminated
soils are  currently exempt from the RCRA  Land Disposal Restrictions
until November 8, 1990.  However, the existing data indicated that
the treatment process would meet  the regulations  even if they were
applicable.  Since all contaminated soil  above  the cleanup level
would be  treated,  it is expected that  clean closure of the site
would be achieved.

At the completion of the implementation of this alternative, the
most  mobile of  the  organic  contaminants  in the  soil  would be
reduced to concentrations that would result in groundwater levels

                               23

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below  the  federal  and  state  standards  when  leached  to  the
groundwater through rainwater infiltration.  The estimated present
worth cost of this alternative is $1,847,000.  The estimated time
to implement this alternative is approximately 18 months.

Alternative SC-4;  Off-Site Incineration

This alternative involves excavation of the contaminated soil and
transportation to a  permitted off-site incinerator for treatment
and disposal.  The facility would include a landfill for disposal
of treated soil.

Following excavation, the contaminated materials  would be placed
into 20 cubic yard trucks for shipment.   The loaded trucks would
proceed to the nearest available incinerator permitted to receive
bulk solid wastes.   The receiving facility would  be responsible
for proper disposal  of the  incinerator ash.   Clean fill would be
used to backfill the excavation  area,  one  foot of top soil would
be  placed on  the  site, and the  site  would be regraded  and
revegetated.   No long-term monitoring would be required.

The recently promulgated RCRA land disposal restrictions have been
considered during evaluation of SC-4 since the treated soil would
be  disposed  at  the incinerator  operator's  landfill.    These
regulations,  to be phased in over the next several years, require
hazardous wastes to be treated to the best demonstrated available
technology (BOAT)  before being  placed or replaced on  the land.
Incineration of  the  contaminated soil should  meet proposed land
ban requirements.

The  estimated    present worth  cost  for  this  alternative  is
$11,303,000.   The  estimated time for  the  implementation of this
alternative is 15 months.
Groundwater Alternatives

Alternative MM-li  No Action

This alternative includes the use of 18 existing wells to conduct
a long-term  monitoring program.   The program would  monitor the
groundwater  underlying the  site  for a  period  of  30 years  to
evaluate changes in contaminant concentrations and the migration
of contaminants  and to assess  the need  for  future remediation.
The groundwater would be analyzed for  TCL  organic compounds.  This
alternative  would  also require a  five-year  review  because the
contaminants would  remain  on site.   The  estimated total present
worth cost for this alternative would be $571,000.
                                24

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Alternative MM-2;  Air Stripping and Carbon Adsorption

Under this  alternative,  a well system would be  installed at the
site to withdraw contaminated groundwater, treat  it on-site by air
stripping and  carbon adsorption,  and reinject the  treated water
intg the ground.  Groundwater would  be  removed  from the sand and
gravel  unit by  extraction wells  located  at the  center  of the
contaminated area and it would enter the air stripper which would
be designed to strip out  the  volatile organic contaminants (VOCs).

The air and VOC mixture  exiting  the air stripper would  then be
treated by  a  vapor  phase carbon adsorption unit for the removal
of the.stripped VOCs.  The clean air would be emitted to the
atmosphere.  The air-stripped groundwater,  which may contain some
contaminants  would  be  processed through  liquid  phase  carbon
adsorbers.    The treated groundwater  would be directed  to  a
reinjection system.   The number of  extraction  wells  and  their
locations  as  well  as the type  of  reinjection  system would be
determined  during the Design  Phase.   Should the pumping tests,
conducted  during the  remedial design,   reveal  that  the  treated
groundwater can not  be reinjected  into  the  soil  (i.e. due to low
hydraulic conductivity in the silt and  clay layer)  an alternate
recharge technique would  be  used.  Also, the spent  carbon in the
carbon adsorption unit would be removed for off-site regenera- tion
or incineration, thus destroying all organic contaminants.

Environmental monitoring would be required during the life of the
treatment process.    In addition,  monitoring of the groundwater at
the  site would be  conducted for  a  period of 3   years  after
completion  of  the  remediation, to ensure  that  the  goals  of the
remedial action have been meet.
                             ' J

Groundwater would be treated to drinking water  standards before
reinjection.  The discharges  from the air stripper would meet the
requirements of 52 FR 3748, 6NYCRR 201,211 and 212,  and Air Guide
-1.   The residues  resulting  from the  treatment system  include
filtered suspended  solids (precipitated metallic hydroxides and
fine particles) and  spent carbon.  It is estimated that about 200
pounds  per  day of  solids would  be  shipped to   an  off-site RCRA
facility for treatment and disposal.

At  the  completion   of  this  remedial  alternative,   the  organic
contaminants found  in groundwater would meet groundwater quality
standards,  and  the  migration of  those contaminants  to the Oswego
River would be prevented.

The present worth  cost  for  this  alternative is estimated  to be
$2,184,000.  The time required to complete the  implementation of
this alternative (from design to complete aquifer remediation) is
estimated  to   be  approximately  4 years.    The  remedial  action
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undertaken by the  source  control  (soil)  alternative,  though, may
affect the time needed for the groundwater remediation.

Alternative MM-3; UV/Oxidation

This  alternative  consists  of  groundwater  extraction,  on-site
treatment of  the extracted  groundwater,  and reinjection  of the
treated water into  the ground using the same system described under
Alternative MM-2.  The treatment process, however, uses both ozone
and hydrogen peroxide as the oxidizing agents to destroy the VOCs
in the  groundwater.   Specifically, the  contaminated  groundwater
would  be  mixed   with  hydrogen   peroxide,   after  pretreatment
(precipitation/filtration) to reduce the suspended solids content,
and then fed to the UV/oxidation reactor to react with ozone gas.
In this reaction, the ozone oxidizes the VOCs to final products of
carbon dioxide,  water and chlorine while the ultraviolet  (UV) light
accelerates the degradation process.  The treated groundwater would
be reinjected into  the ground and the off-gas, together with excess
ozone, would  be directed  to  the  catalytic ozone  decomposer for
destruction of the ozone,  before being emitted to the atmosphere.

Based on  the  groundwater  analysis, a total  of 27  pounds/day of
carbon dioxide and 34 pounds/day of chlorine gas would be produced
from  the volatiles  present  in  the  groundwater  and  would  be
discharged to  the environment  dissolved  in  the  treated  water.
These gases  would not  pose any potential health  risks  in  such
dilute  concentrations.     The  groundwater would  be  treated  to
drinking water standards before reinjection.

The pretreatment residues, which are  mostly  metallic  oxides such
as iron oxide, and amount to about 200 Ibs/day,  would be disposed
of off-site in a RCRA landfill.

Based  on past  performances,  the  overall  removal of the  voc
contaminants  in groundwater  was  estimated and  the results are
summarized and presented  in  Table  13.  The actual performance of
the UV/oxidation treatment process must be substantiated by pilot
testing and full scale application at the site.

This alternative would  reduce the  level  of most organic contami-
nants in  the  groundwater  to  levels below the federal  and state
standards.  However,  one of the contaminants of concern  (4-methyl-
2-pentanone)  cannot  be  treated effectively by  this alternative,
unless the UV groundwater treatment system is augmented by liquid
carbon  adsorption for  treatment  of  the groundwater prior  to
reinjection.

The  estimated  present   worth  cost   for this  alternative  is
$1,861,000.   The time estimated for completion of this alternative
(from design to  complete  aquifer  remediation)  is approximately 4
years.


                               26

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SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES

During  the detailed  evaluation of  remedial alternatives,  each
alternative is assessed  against nine evaluation criteria, namely
short-term effectiveness, long-term effectiveness and permanence,
reduction of toxicity, mobility or volume, implementability, cost,
compliance with ARARs, overall protection of human health and the
environment, state acceptance and community acceptance.

Each criterion will be briefly addressed,  in order,  with respect
to the alternatives for both soil and groundwater.


Soil

A.  Short-Term Effectiveness

All alternatives, with the exception  of the no-action alternative,
include  activities  such  as  contaminated   soil  excavation  and
transport that could result in potential exposure of residents to
volatilized contaminants and contaminated dust.   However, mitiga-
tive measures  to  reduce the  probability of  exposure  would  be
implemented.  In addition to excavation, Alternatives SC-2 and SC-
4 include off-site transport and disposal of contaminated soils.

Alternative  SC-3  provides  treatment  on-site,  thereby  reducing
potential risks to residents along transportation routes.

Alternatives SC-2, SC-3,  and SC-4 would result in worker exposure
to volatilized contaminants  and dermal  contact  with contaminated
soils during waste excavation and handling.   In addition, Alterna-
tive SC-3 might result in low-level emissions exposure from the on-
site treatment unit.  The threat to on-site workers, however, would
be  mitigated  through  the use  of protection  equipment  and  the
control of emissions would be accomplished by emissions treatment.
Additionally,  scrubber  wastewater  would  require  removal  and
treatment prior to complete demobilization from the site.

All of the alternatives (with the exception of SC-1 which requires
no action)  could be  implemented within a period of  1  1/2  to 2
years.

B.  Long-Term Effectiveness and Permanence

Alternative SC-3 would effectively treat the  most  mobile wastes in
on-site soil,  thus permanently removing the source of ground- water
contamination.   Alternatives SC-2  and SC-4  would also provide a
high degree of effectiveness, since the  contaminated soil would be
removed from the  site.   In contrast, under Alternative SC-1, the
contaminants would be  left  untreated in the soil and a long-term
                                27

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monitoring  program  will  be  implemented  to  determine  if  the.
contamination was migrating from the site.

C.  Reduction of Toxicity. Mobility or Volume

Alternative SC -3 and Alternative SC-4 would result in significant
reductions  in  the toxicity, mobility,  or volume of  the treated
material.  Material toxicity would be reduced by thermal destruc-
tion of VOCs and semi-volatile organics.

Alternative SC-2 would provide  a  reduction in contaminant mobility
at the site, but no reduction in toxicity or  volume.  The reduction
in  mobility would reduce  the  ability  for  contaminants  to move
toward the groundwater.

Alternative SOI would provide  no reduction  in toxicity, mobility,
or volume.

D.   Implementability

All   of   the   alternatives  would  utilize   relatively  common
construction  equipment  and   materials.     Little  construction
difficulty would be encountered with any of the alternatives.

The technologies proposed for use in the alternatives are proven
and reliable in achieving  the  specified process efficiencies and
performance  goals.     Low temperature  thermal  extraction,  the
selected  remedy, has been  successfully pilot  tested  and  has
performed on full-scale basis with similar organic contaminants.

E.   Cost

The capital cost  for  Alternative SC-3  is $1,847,000.   Because of
the short duration of implementation of  this alternative, the cost
associated with this  alternative was considered  to be a capital
expenditure with no  operating  and maintenance  (O&M)  component.
Also, since the alternative would meet the cleanup  goals,  there
will be no long-term monitoring at the site and no  five-year review
would be  required.    Therefore,  the capital cost represents the
total worth cost of the selected remedy for the soil.

The total capital, annual O&M, and present worth costs  for all soil
alternatives are presented in Table 14 for comparison purposes.

F.   Compliance with ARARs

All technologies proposed for use in Alternatives  SC-2 through SC-
4 would be designed and implemented  to satisfy all action-specific
regulations.   No federal  or New York  State  regulations specify
cleanup levels for contaminants in the soil.  Target levels for the
soils for the purpose of  removing potential  sources of groundwater
contamination  were  developed.    Alternative  SC-3  along  with

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Alternatives SC-2 and SC-4, would  be quite effective in reducing
contaminant loading  from the  soils to the  groundvater to levels
which would be below ARARs.

G. Overall Protection of Human Health and the Environment

The  low  levels  of  soil  contamination  remaining  at the  site,
following the  removal  of all above-ground  and  underground tanks
and 300 cubic yards of contaminated soil, present minimal risk to
human health.

The treatment of soils to remove the most  mobile wastes will result
in  the   elimination  of  a  long-term   source   of  groundwater
contamination and it will mitigate the risks to public health and
the environment  associated with the migration of those contami-
nants off-site.  Alternative SC-3 would effectively mitigate those
risks by removing the most mobile wastes from the soil leaving only
the less  mobile organic  and  metal compounds in  the soil  to be
landfilled on-site (provided that the treated soil has passed the
TCLP toxicity test).

Alternatives SC-2 and SC-4 would also mitigate the risks to public
health  and  the environment  associated with  the  leaching  of
contaminants into the  groundwater and their migration off-site.
Under Alternative SC-1, contaminants would continue to leach from
the soil into the groundwater and continued off-site migration of
contaminants would  occur.   Monitoring  would  be  implemented to
observe contaminant migration, but  an indeterminate amount of time
would elapse between detection and the implementation of mitigation
measures.

H.   State Acceptance

NYSDEC concurs with the preferred soil alternative.

I.  Community Acceptance

In general  the community has expressed  support  for the selected
remedy for the remediation of  the soil.   It has also expressed two
principal concerns,  namely:  1)  that, in addition to the volatile
organic compounds,  the semivolatile  organic compounds as well as
the inorganic  compounds  that were  detected in the  soil on-site
should be fully addressed  by the remedial  action; and  2)  that
several  of  the  contaminants  found  in  the soil  at  the  Fulton
Terminals site might not be amenable to  the off-gas incineration
at the end  of  the low  temperature  thermal extraction process and
that  there  should  be  continuous  air  monitoring  during  the
remediation  to  ensure  against emissions of  all potential  air
contaminants.

These concerns are addressed as follows:


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1)  The  risk  assessment  for  the  Fulton  Terminals  site  has
demonstrated that there  are  minimal  risks associated with direct
contact  with  the soil  on the  site.   The soil  remediation was
developed  for  the   purpose of   providing  protection  of  the
groundwater from  the continued  release of  contaminants from the
soils.   Therefore,   in  order to  protect  the groundwatr,  it  is
necessary to  remediate  for  the most mobile  of  the contaminants
detected in soil, namely the volatile organic contaminants.

2)  The  off-gas   incineration  is  only  one  of  several  options
available for  the treatment of gases  generated during  the low
temperature thermal  extraction  process.  Other  options,  such as
carbon adsorption of the off-gases, would  also be evaluated during
the design  phase.   If  off-gas  incineration  is  implemented, its
effectiveness would be verified through a trial run prior to full
scale remediation.   In  addition,  air monitoring for particulates
and organic vapor emissions will be performed during the remedia-
tion period.  Emissions from the treatment unit will meet the Air
Emission standards listed in Table 12.
GROUNDWATER

A.   Short-Term Effectiveness

Both Alternative MM-2 and Alternative MM-3 include activities that
could  result in  potential  exposure  of  workers to  volatilized
contaminants during the installation of the groundwater extraction
and reinjection systems.  The threat to on-site workers, however,
would be mitigated through the use of protective equipment by on-
site workers.

The  implementation  of  Alternative  MM-1  would  result  in  no
additional risk to the community during implementation.

In  terms  of implementation  times,  Alternative MM-1 could  be
implemented in less than  a year.   Alternative MM-2  or MM-3 could
be implemented in about 4 years.

B.  Long—Term Effectiveness and Permanence

Alternative MM-2 and Alternative MM-3 would effectively reduce the
potential risks associated with the migration of contaminants in
the  groundwater  by  extracting  the  contaminated  groundwater,
treating it to remove contaminants  and returning the treated water
to the aquifer.

The time to achieve these risk reductions, however,  is limited by
the residual contamination emanating from off-site and upgradient
sources, which are the subject of separate investigations conducted
by NYSDEC.
                                30

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Alternative  MM-1  would not  reduce  the  risks  associated  with
migration of the contaminants in the groundwater.

C.  Reduction in Toxicitv.  Mobility, or Volume

Alternative MM-2 and Alternative MM-3 would effectively reduce the
toxicity,  mobility,  and  volume  of  the  most  mobile  organic
contaminants in the groundwater.  Alternative MM-1 would not reduce
the toxicity, mobility and volume of contaminants.

D.  Implementability

All  components   (extraction,   treatment  and   reinjection)   of
Alternative MM-2 utilize relatively common construction equipment
and materials and  could be  easily  implemented.   In addition,  the
air stripping and carbon adsorption technologies  that comprise the
treatment  are proven  and  reliable in  achieving  the  specified
performance goals are readily available.

In  contrast,  the  treatment  technology  for  Alternative  MM-3
(UV/oxidation), although successful in pilot  runs, has had limited
use to date.  Therefore, site-specific  pilot scale studies would
be required to confirm its adequacy for the Fulton Terminals site.
In addition,  UV/oxidation  is currently  available  from  only  two
sources nationwide.

All components of Alternative MM-1 would be easily implemented.

E.  Cost

The capital cost for Alternative MM-2 is estimated to be $823,000.
The  annual  operating  and  maintenance  costs are  approximately
$732,000.  The total present worth cost,  calculated  using a five
percent discount rate over two years, is $2,184,000.

Table 14 lists all the costs for the three groundwater alternatives
for comparison purposes.

F.  Compliance with ARARs

Alternative  MM-.2  would achieve  federal  and state  groundwater
quality standards  for  the  organic  contaminants  by providing  the
required contaminant removal during the treatment stage utilizing
air stripping and carbon adsorption.


Groundwater quality standards for metals may not be met sinc=j the
background concentrations for metals are  higher  than the concen-
tration of metals in the groundwater underlying the site.

The ability of Alternative MM-3  to  achieve the groundwater quality
standards for the organic contaminants is of a lower certainty than

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the preferred alternative's because of limited experience with the
UV/oxidation treatment process.

Alternative MM-1 would not  comply  with  state or federal drinking
water standards  or  criteria or those ARARs  required for protec-
tion of the groundwater resources.

G.   Overall Protection of Human Health and the Environment

Alternative MM-2, would provide the highest  degree of protection
to human health and the environment among the three alternatives,
since it would remove the treat the organic contaminants found in
groundwater and would prevent their migration off-site.  The higher
degree of protection associated with Alternative  MM-3   is due to
the higher certainty for contaminant treatment associated with the
air  stripping  and   carbon adsorption  technologies  versus  the
UV/oxidation treatment technology of Alternative MM-3.

H.  State Acceptance

NYSDEC concurs with the preferred ground water alternative.

I.  Community Acceptance

The community has, in general, expressed support for the selected
remedy for the remediation of the groundwater.  The community has
also voiced certain concerns,  namely:

1)  Whether  the  inorganic  as  well  as  the  semivolatile  organic
compounds detected in the  groundwater will be removed during the
groundwater treatment; and

2)  Whether  the  remediation  of  the groundwater  at the  Fulton
Terminals site through the  "pump and treat"  process would effect
and/or be effected by off-site sources of contamination such as the
adjacent Sixth Ward and Van Buren hazardous waste sites.

In addition, FSDWAC, the citizen's group at Fulton, has suggested
that the selected remedy be combined with in-situ bio-remediation
of the groundwater  at the site as  a potentially,  more effective
way of addressing on-site  migration of  contaminants serving from
areas adjacent to the site.

These concerns are addressed as follows:

1) Heavy metals and  semivolatile organic compounds detected in the
groundwater would be  removed during the pre-treatment and treatment
of the extracted groundwater.  The treated groundwater will meet
the drinking water standards before recharge into the ground.

2)  During  the pump  and  treat process  for the  groundwater,  the
withdrawal system will be designed such that the area of dewatering

                               32

-------
(cone  of  depression)  will  primarily  affect  the  groundwater
underlying the site.  Reinjection of the treated groundwater will
divert some portion of the upgradient groundwater to both sides of
the site.  A slight increase in groundwater flow towards the Sixth
Ward site may occur.  No measurable effect is expected towards the
Van Buren site.

To date, based on NYSDEC'S investigations,  there is no indication
that the Van Buren and Sixth Ward sites are sources of contamina-
tion for the  Fulton Terminals site.   The high concentrations of
benzene, ethyl benzene, and xylene in off-site wells upgradient to
Fulton  Terminals  could be  attributed  to  localized  upgradient
contaminant sources.

If,  following remediation  of the  organic  contaminants in  the
groundwater at  the site,  the three  upgradient contaminant  con-
centrations still exceed ARARs,  NYSDEC will continue to treat the
groundwater at the  site until the groundwater  ARARs are achieved
for those three contaminants.  If it is determined that the "pump
and treat" process  is  not effectively  reducing the concentration
of benzene,  ethyl benzene  and  xylene,  a separate investigation
would be undertaken by NYSDEC to define and  eliminate the source
of the  upgradient contamination  and to treat  the  groundwater to
achieve the most stringent groundwater quality standards for those
three contaminants.
THE SELECTED REMEDY

Based  upon  consideration of  the  requirements of  CERCLA,  the
detailed analysis of the  alternatives,  and  public  comments, both
EPA and NYSDEC have determined that Alternative SC-3, low temper-
ature thermal extraction, for treatment of the contaminated soil,
and Alternative  MM-2,  air stripping  and carbon adsorption,  for
treatment  of the groundwater  underlying the  site,  is  the most
appropriate  remedy  for  the  Fulton  Terminals  site.   The  major
components of the selected remedy are as follows:

   -  Approximately  4,000  cubic yards of VOC  contaminated soil will
be excavated from the southwestern portion of the site, in the area
of the former storage tank Nos.
-------
   -  The VOCs in the soil  will be treated using a low temperature
thermal treatment technology.  Approximately 99.99 percent of the
VOCs will be removed by this treatment process.

   -  The treated soils,  which will still contain some less mobile
organic compounds and metals, will be  tested  for TCLP  toxicity to
determine whether they constitute a RCRA hazardous waste and will
be placed back  into  the excavation  areas  from which  they were
removed.  One  foot of  clean  top  soil  will  be placed on the site,
and  accordingly the  site  will  be  regraded and revegetated  to
prevent soil erosion.

   -  In the unlikely event that  the treated  soils do not pass the
TCLP Toxicity  Test, they will be stabilized  by fixation prior to
their placement  in the excavated areas.

       Following remediation of  the  soil,  the groundwater
underlying the site will be treated.

      Contaminated groundwater will be removed from the sand and
gravel unit of the aquifer by a system  of extraction wells, located
at the contaminated area.  It will be treated on-site for removal
of the VOCs using a combination of air  stripping and carbon adsorp-
tion technologies, and the  treated water will be reinjected in the
ground  through a reinjection  system.  The  groundwater will  be
treated to  drinking  water  standards  before  recharge.   The exact
number and location of  the extraction wells, the pumping routes and
the type  of the reinjection system will be  specified  during the
design phase.  If reinjection of  the treated  groundwater proves to
be impractical  (due  to  site specific hydraulic conditions)  an
alternate recharge technique would be used.

      All  residuals  from the treatment of the soil and  of the
groundwater will be  shipped  to  an off-site  RCRA hazardous waste
facility.

      Air monitoring will be performed prior to,  during,  and
following  construction  at  the  site.   Air  emissions  from  the
treatment units  during both  the  soil  and  groundwater remediation
will meet the Air Emission ARARs.  Environmental monitoring  will
be required during the  life of the treatment process.  In addition,
monitoring of the groundwater at the site will be conducted for a
period of 3 years after  completion of the remediation,  to ensure
that the goals of the  remedial action have been met.

      Institutional controls will be  applied,  to the  extent
possible, to  prevent  the  utilization of  the  underlying ground-
water due to the high concentrations of metals naturally occurring
in the groundwater throughout the area surrounding the site.  These
controls will  include  well construction permits and water quality
certifications and will be consistent with New York State law.
                                34

-------
      The groundwater  treatment  will  continue until federal and
state standards  for  the  organic  contaminants have been achieved.
Three  of those  contaminants,  namely  benzene,  ethylbenzene  and
xylene, have been detected in upgradient wells  at levels exceeding
the groundwater standards.  Thus,  a separate  investigation will be
undertaken by  NYSDEC to  define  and  eliminate the  source  of  the
upgradient contamination.   A remedial  response action would then
be undertaken,  if needed,  to  ensure  that the  federal  and state
standards for these contaminants would be achieved.

   -  A floodplains assessment will be prepared during the design
phase.  This floodplains assessment  should include a delineation
of the  extent  of the  500-year floodplain, a  description  of  the
potential effects  on the floodplain associated with implementa-
tion  of  remedial actions,  a discussion  of  measures  to minimize
potential  adverse  impacts   to  the  floodplain,  and  the  design
considerations  proposed  to protect  treatment  units  and  other
remediation equipment from  flooding and flood damage.

Remediation Goals

The risk  assessment has  concluded  that,  with the contamination
presently remaining  on-site, minimal  threat to  human health  and
the environment exists.  Existing conditions  at the  site have been
determined to  pose an excess  lifetime cancer risk of  2.3 E-07,
predominantly  from  ingestion of  contaminated soil at  the site.
This  is within US  EPA's range  of acceptable  risk.   However,  the
federal and state ARARs for several of  the VOCs in groundwater are
being exceeded.

The purpose of this response action is to restore the groundwater
underlying the  site  to levels  consistent with state  and federal
ARARs and to ensure protection  of the ground  and surface water (in
the Oswego River adjacent to the site)  from the continued release
of contaminants from soils.   Since no federal or state ARARs exist
for soil, the  action level  for  the  VOCs in  soil  was determined
through a  site-specific analysis.  This  analysis  used fate  and
transport modeling  to determine  levels  to  which VOCs  in soils
should be reduced in order  to  ensure  no  leaching of contaminants
to groundwater above MCL levels.


STATUTORY DETERMINATIONS

Under  its legal authorities,   EPA's  primary  responsibility  at
Superfund sites is  to undertake remedial  actions  that achieve
protection of  human health and  the  environment.    In addition,
Section  121   of CERCLA  establishes   several  other  statutory
requirements and preferences.  These  specify that when complete,
the selected  remedial  action  for  this  site  must  comply  with
applicable or  relevant  and appropriate  environmental  standards
established under  federal and  state environmental  laws unless a

                               35

-------
statutory waiver is justified.   The  selected remedy also must be
cost  effective  and utilize  permanent solutions  and alternative
treatment technologies  or resource recovery  technologies  to the
maximum  extent  practicable.    Finally,  the  statute includes  a
preference for remedies that  employ treatment that permanently and
significantly reduce the volume, toxicity, or mobility of hazardous
wastes as their principal  element.  The following sections discuss
how the selected remedy meets these statutory requirements.
The  low levels  of  soil  contamination  remaining  at the  site,
following the  removal  of  all above-ground and  underground tanks
and 300 cubic yards of contaminated soil, present minimal risk to
human health.  The  selected  remedy further protects human health
and  the environment  through the  removal and  treatment  of  the
organic contaminants in groundwater, using air stripping and carbon
adsorption.    In addition,  treatment of the contaminated soils
through a low  temperature thermal  extraction process will remove
the most mobile wastes from the soil, resulting in the elimination
of a long-term source of  groundwater contamination,  and it will
mitigate the risks  to public  health and the environment associated
with the migration  of  those  contaminants off-site.   There are no
short-term threats  associated with  the selected remedy that cannot
be readily controlled.

Compliance with Applicable or Relevant and Appropriate Requirements

The  selected remedy  of  excavation  and  on-site  low temperature
thermal extraction of contaminated soils along with air stripping
and  carbon  adsorption of  the groundwater will comply  with  all
chemical-,  action-,  and  location-specific ARARs.   It  should be
noted,  though, that  the groundwater quality  standards for metals
may not be met, as  naturally  occurring metal concentrations in the
groundwater  surrounding  the  site  are  higher  than  the  metal
concentrations in the groundwater underlying the site.  The ARARs
are presented in Table 12.

Cost Effectivenesa

The selected remedy is cost effective because it provides overall
effectiveness proportional to its cost; the net present worth value
being $4,031,000.  The cost of the  soil treatment component of the
selected remedy ($1,847,000)  is only 60 percent  of the cost of the
excavation and off-site disposal alternative and only 16 percent
of the  cost of the alternative involving off-site incineration, and
yet  the  selected  remedy  mitigates  as  effectively  as  those
alternatives all the risks posed by the contaminants at the site.
The  cost  of   the  groundwater   component   of   the  remedy  is
approximately 17 percent higher than the  cost  for the UV/oxidation
alternative,  but it offers a much higher degree of certainty with
                                36

-------
regard  to  the  effective  removal  of  all  the  VOCs  from  the
contaminated groundwater.

utilization  of  Permanent  solutions  and  Alternative  Treatment
Technologies to the M*ximi.i<" Extenl
EPA and the New York State have determined that the selected remedy
represents  the maximum extent  to which permanent  solutions and
treatment technologies can be utilized in a cost-effective manner
for the final source control  operable unit at the Fulton Terminals
site.  Of  those  alternatives that are  protective of human health
and  the  environment  and  comply  with  ARARs,   EPA NYSDEC  have
determined that this selected remedy provides the best balance of
tradeoffs  in  terms  of long-term effectiveness and  permanence,
reduction  in  toxicity,  mobility  or  volume  achieved  through
treatment, short-term  effectiveness, implementability,  and cost,
also  considering the  statutory  preference  for  treatment  as  a
principal element and considering state and community acceptance.

With regard  to the  most mobile wastes in the soil  that pose the
major risks at the site, the selected remedy will offer as high a
degree  of long-term  effectiveness and  permanence  as  the  other
treatment alternative,  incineration, by  permanently removing the
source of  groundwater contamination.   In addition,  the selected
remedy will  result  in significant reductions in the  toxicity of
the contaminated material  (comparable  to the reductions achieved
by  incineration)  through thermal destruction of  the  organic
contaminants.  The  selected  remedy is as effective as  the other
remedial  action  alternatives  in the  short-term  offering  the
additional  advantage  of  on-site  treatment,   thereby  reducing
potential  risks  to residents  along  transportation routes.   The
implementability of the selected remedy is comparable to the other
alternatives.    The  selected  remedy   is also  the  least  costly
treatment option and also is less expensive than  off-site disposal.

The selection of treatment of the contaminated soil is consistent
with program expectations that indicate that  highly  toxic and
mobile wastes are a priority for treatment and often necessary to
ensure the long-term effectiveness of a remedy.   Since all of the
alternatives are reasonably  comparable with  respect to long-term
effectiveness, -the  toxicity,   mobility, and   volume  reductions
achieved and the  implementability, the major tradeoffs that provide
the basis for the selection of the soil portion of the remedy are
short-term effectiveness  and cost.  The selected  remedy  can be
implemented with less risk to the area residents and at less cost
than the  other remedial  action alternatives and,  therefore,  is
determined to be  the most appropriate solution for the contaminated
soils at the Fulton Terminals site.

The selected remedy for the groundwater offers as high a degree of
long-term  effectiveness and  permanence as  the other  treatment
option of UV/oxidation, and it reduces the toxicity, mobility and

                                37

-------
volume to the same extent as UV/oxidation through the destruction
of organic contaminants.

The  selected  remedy  is  as  effective  in  the  short-term  as
UV/oxidation.  With regard to implementability, the components of
the selected  remedy  are easily  implemented,  proven technologies
and'are readily available.  In contrast, the treatment technology
for UV/oxidation,  although  successful  in  pilot  runs,  has  had
limited use  to  date.    In addition,  UV/oxidation  is  currently
available from only two sources nationwide.

The cost  of  the selected  remedy  is  only  slightly higher  (17
percent) than the UV/oxidation treatment option.

Since  both  of  the  treatment options  for  the groundwater  are
reasonably comparable  with respect to  long-term  effectiveness,
toxicity reductions,  short-term effectiveness,  and cost, the major
tradeoff that provides the basis  for  the selection of  the air-
stripping and carbon adsorption as the remedy for the groundwater
is implementability.   The technology for the  selected  remedy is
proven and readily available.

Preference for Treatment as a Principal Element

By treating the VOC-contaminated soils in a low temperature thermal
extraction unit,  and by treating the groundwater by air stripping
and carbon adsorption the selected remedy addresses the principal
threats  posed   by   the  site  through   the   use   of  treatment
technologies.  Therefore,  the statutory  preference for remedies
that employ treatment as a principal element  is satisfied.
                                38

-------
APPENDIX 1 - TABLES

-------
                                    TABLE  1

                                   rULTO* TERMINALS
                              TCI VOLATILE OKANICS IN SOU
COMPOUND
Vinyl Cuter ide
Aettone
1,1-OicMorottfctnc
1.1-OlcMorotthvw
tfM.I.MI.hl.rMttar.
CMoreforw
2-twtvwne
1.1,1-TricMorofthant
TricMorotth«r«
Mrutne
4-Httliyl -2-Mmanon*
Tvtracfc 1 orottlwra
UlMm
Oitorotenztn*
Itfiyl M«u«nt
«yl«nt
eOHCEHTUTIOM
MNCE
20,000
17-110,000(1)
100
67
31-30,000
2
23-11,000(1)
380
270*110,000
5-W
2-1300
33-MOO
3-49
9
M7
7-240000
NLMEI Of
OCCMRENCES
1
14
1
1
3
1
2
1
4
3
2
3
3
1
3
4
LOCAUOl A* DE'TM
Of (HXIMLH
«-*, 4-* ft
n-u. «-io ft
H-6, 4-6 ft
tt-6. 4-6 ft
»•*. 4-* ft
••••. 0-2 ft
M-27, 4-6 ft
If-*, 4-4 ft
••7. 0-2 ft
M-6. 4-6 ft
••4, 0-2 ft
••7, 0-2 ft
•-1. 1-10 ft
••IB. ••» ft
•-1. •-« ft
••14, 2-4 ft
•ett:  imtr «rt *f MC* rarpt <» fro* «Mptt« Mfth dittctcd vslun only.
      All nmntrctfam In i«/k| (ppb).
      I • Cwpew* *t«et«tf in blinks.

-------
                                           TABLE  1 (Cent.)
                                       HA TON TIMINAIS
                    TOTAL CMCCirriATIOH  Of TCI SMI-VOLATILI OI6ANICS  IN SOIL
VOCATION
W-1
fi-2
88-3
«8-4
MS
88-6
88-7
88-8
88-9
88-10
88-11
a-12
•8-13
88-14
88-15
88-16
88-17
88-18
88-19
88-20
88-21
tt-22
n-n
n-2«
«-25
M-26
M-2?
SAMPLE DEPTH
0-2 2-4 4-6 6-8
318/152
724/333 . •• 21.470/10,240
534/124
U/u
U/U - 792/U
10,660/U 200/U
1.271/469 •- -- 467/240
6.264/2,860 3,118/1,149
U/u
2.169/827
492/232
993/620 - U/U
180/U 31,270/U
1,191/202 U/U
1.653/640
755/143
U/u
970/11
1,019/U
160/U •• 474/U
5,328/830 -• 403/173
860/U
1,053/U •• •• 292/U
2,845/980
160/U •• •• 89/U
4.118/1.576 - 2.527/835
8-10
1,376/660
..
1.924/420
1.297/402
* •
--
• *
•-
31.480/780
480/139
690/U
-
••
-
U/U
749/U
U/U
7.023/404
1,756/U
-
-
20,600/U
--
81 /U
••
..
Total MH-volati(M/tot»l ctrcinogtnic pelynuetiar arawtic hydrocarbon* (CPAMt)
•etm:  All  concentrations 
-------
                                                                       TABLE  1  (Cont.)
                                                                       turn remiMis
                                                       SUMMIT Or TCt IHMMIC COHCtHTMTIOW IN toil
                     CONCENTRATION MMt
ICCATION AND DW» Of
            ENTtAt
                                                                                       of OM-SITC mines
                                                                                            COKtNTRATIOVS
                                                                                               TATt NT
                      TTFICAl 8MXOMMO
AlMlnui
Ant loony
Arsenic
•erylllu*
Celtfun

Cobe.lt
Iron
leed
Mercury
Nickel

$elenluB

SodlUM
Sine
2.370-21.400
tl-4.3
2.1-79.7
18.4-1710
U-1.4

0.58-2.2
•98-54.100
5.4-140
1.7-18.9
4.1-347
3710-33.500
3.8-479
1.120-20,800
110-9,050
U-0.75
3.8-137
298-1.430
U-1.3
J-3.0
37.2-484
U-0.59
3.9-133
17.3-1040
                                                     It- 13. 0-2 ft
                                                     $0-27, 0-2 It
                                                     M-3. 4-8 ft
                                                     $•-16. §• 10 ft
                                                     M-2. 4-8 ft end
                                                       $•-18. 8-10 ft
                                                     $8-24. 0-2 ft
                                                     $•-15. 0-2 ft
                                                     $•-15, 0-2 ft
                                                     $•-21, 4-6 ft
                                                     $•-24, 0-2 ft
                                                     $•-*. 0*2 ft
                                                     $•-09. 0-2 ft
                                                     $•-15, 0-2 ft
                                                     $•-14. 0-10
                                                     $•-24. 0-2 ft
                                                     $•-05, 0-10 ft
                                                     $•-18. 1-10 ft
                                                     $•-3. 4-8 ft
                                                     $•-8. 4-8 ft
                                                     $•-18. 0-2 ft
                                                     $•-«. 8-10 ft
                                                     $•-4. 4-4 ft
                                                     $•-24, 0-2 ft
                                         5318
                                         5.1 V
                                         4.4
                                         80.4
                                         0.51

                                         1.4 V
                                         9784
                                         9.3 •
                                         5.S
                                         129
                                         14.742
                                         83.9
                                         2493
                                         425
                                         o.n v
                                         10.5
                                         715
                                         0.48 V
                                         U
                                         113 V
                                         II
                                         10.1
                                         225
      50,000

         4.1
         300
7.900-12.000
          30
         3-5
          20
      20.000
          15
 5.000-7.000
     200-300

        7-10
      14.000
    0.15-0.2

       7.000

          70
          45
7,000-100.000
     «150-500
      «0.2-73
     15-1.000
 <100-140.000
        1-100
        «3-70

 100-»100.000
       «7-SOO
    50-50.000
     «2-7.000

       <3-700
    50-37.000

       «0.5-5
  <200-15.000

       <5-300
       <5-400
Hot*:  U • Hot ditocttd
       V • Awrtft docs not  Inclu* unditcctod concentration*
       • • Aver*** tfMra not  Include rejected dot*
     (•) • •ecktround velueo fro* SyrecuM. NT ereo eolle In Upotete New York (Shecklette «vf Ooloven. 1984}
     (b) • •eckoround veluee fro* "•" Ivor I ton toll* In the lettern U.S. (Sliocklette. 1975)

-------
                                                         TABLE 2

                                                    FULTON TftMIMLS
                                           TCL VOLATILE ORGAN1CS  III C80UNDUATER
OMPOMD
Vinyl CMoHdt
Me hylww OlleH*
Atttont
1.1-OicMorMtlwnt
1,1>0ldiloro«th««
cU-1.2-OtcMoro«h«nt
1.1.1-TrtcMorottlMvw
Triehlorotthcfw
Etnt
rirjrl ** *^BWsBWOtTiT
TttrMMorwttwnt
Tolurw
Oilorotonxww
Ettiyl 8«ns«nt
lytcnt
NLMUt Of
OCCURRENCES
4
'
1
2
3
11
1
8
S
1
2
6
s
4
S
CONCENTRATION
•ANGE
1.8-88
185. 9
973
2.7-49.4
5.8-24.3
1.6-14.387
113.2
0.6-2588
10-422.7
593
0.6-6.8
0.4-64.9
1.3-162
2.4-432.5
1.4-503
LOCATION OF MAXIMUM
EIMW-30
EH* 30
E8MW-30
EVM-30
E8MU-30
EIMW-30
E8MV-30
EBMW-SO
F8W-6
E8MU-30
E8MU-50
F8V-6
F8W-6
F8W-6
F8U-6
•TBOM
iTANDARfit(A)
2
S
50
5
S
S
S
S
5
SO
S
S
S
S
S
NTS GUIDANCE V»^
5 S
SO
• •
0.07
50
--
SO
10 S
NO
m m
0.7
50
20
SO
50
•ott:  I • ITS
      A • ftvfcfon to tart S »f th« MT Itatt Scnittnr
      • • Net OvtMrcd
      All connntritim in i«/l fppb)
(1/89)

-------
                                         TABLE  2 (Cont.)
                                       FULTON TCMINAI.S
                             ICNI-VOUTIlt WCANICS IN 8MUNDUATEI
COMPOUND
•M.I
WMMM*.
tenxeic Acid
i^tMltn.
Z.*t»iyln*th.ltr»

liK2-tthylhtxyt)phth«l«tt
Df-n-oetyl phtlwUTt
NO. OF
OCCURRENCES
1
2
1
3
3

It
1
•ANCE
11
7-t1
47
7-92
3-4

2-62
3
LOCATION
or MAXIMUM
HMV-3S
HW-6
UNV-3S
«M-6
flW-6 end
IIMW-6S
riw-io
nw-10
•TS
STANDARD
--
4.7
-•
10 C
**

4200
*.
•ett:  6 • NTS Gufdwwt Valut
      All conctntration*  in ug/l (ppb)

-------
                 TABLE 2  (Cont.)

                 FULTON TERMINALS
SUMMIT OF TCL IHOtCAMlC CONCENTRATIONS IN 6MUNDUATER
Alwin*
Antiaony
Arwoo.
toriu*
terylliu*
Cafeii*
Old*
D,r.f*
Catett
UPPT
Iron
LMd
•mi,.
»n»~..
•treury
• in
                (ppb)

-------
                                          TABLE  3
                                               TEMINAIS
                           KNI-VOLATILES IH MFACt  «TEI AMD KOINENT
                                 KNI 'VOLATILE! IN MFACE MATE!
JtHl-VDLATILE 0»C*MIC Cua/l)

•UC2-Ethvlhe*yt>Pt»thalat«
Qfik
 J30
                                                                  «W-2         tW-3
                                                                                           21
                                   KM! -VOLATILE* IN KDIMCHT
CTOL
ttHl'VDL«TIL£ MCAM1C
                                                     10-1
Anthracene
B«nie(«)AnrhrK«w
•cnzo(b)Fluoranth«fw
•cnioUmuorcnthmt
Mntofluoranthm (Total)
•fs(2-fthylhtiyl)PMh«lm
ChryMnt
riuorvith«ra
riuorvw
lnrira(1.2.3*cd)»yrm
Mffcttalcnt
S30
330
330
330
330
330
330
330
330
330
330
330
330
330
S30
330
330
U
u
•5 J
M J
79 J
U
•1 J
U
U
•8 J
U
140 J
U
U
U
7S J
ISO J
U
U
U
u
u
u
u
u
u
u
u
u
u
u
u
u
u
120 J
220
•20
720
T
370 J
T
1*00 J
U
•10
140 J
1900
•7 J
370 J
*5 J
•20
1200
U
U
U
U
U
U
U
u
210 J
U
u
u
u
u
u
u
u
•ett:  CRDL • Contract toquirod fttttction K*it
          U • Conpotfid MlOM Dtttction Lf*ft
          J • EttfMttd Concentration
          T • leported as Totat Mnzofluoranthana

-------
                                        TABLE 3  (Cont.)
                                            TEMINALS
                                  INOtgUIICS  l« MFACE HATER
mammc
AntlaBnv
ArMnic
•aril*
Calcii*
Cobalt

Iron
laad
Htrcury
•iektt
Sllwtr
Varadiu*
Z1ne
200 •
60 •
10 •
200 •
$ «
$ «
$000 «
10 «
$0 «
2$ «
WO <
$ «
$000 «
1$ «
.2 «
40 <
$000 <
$ •
10 <
$000 <
10
$0 '
20 <
1 t
1 U
2.8
36.5
' U
1 U
' 63300
1 U
' U
1 U
> •
> 2.6
> 12400
' ft
1 U
• U
' 2230
• 2.7
• U
• 42600
• U
• U
• U
I
23.6
2.2
39.7
U
U
66000
^WW^FW
U
U
U
•
4.6
12900
•
U
U
2280
U
U
44200
U
U
U
1020 J
24.2 J
2.4 J
69.0 J
UJ
U
67400 J
U
7.6 J
7.9 J
1770 J
7.1 J
13700 J
248 J
U
U
2$40
1
U
47300 J
IU
U
37.9 i
Hott:  CtOL • Contract Mqulr«d 0«twttion
         J • Ittiwttd Canctntratien
         • • Data Net AvaUabla

-------
                                     TABLE  3  (Cent.)

                                   FULTON TEMINAIS
                                 IKBGANICS I" KDIMENT
                         ODL         »-01          K>-0?         10-03

 IK»aH)lC (
Artanic
Ctlclun
Cobalt
Cojper
Iror
I tad
•treury
•iektl
••tMtiun
tUvtr
Sadiw
Ttolliui
Zinc
40
12
2
40
1
1
1000
2
10
s
20
1
1000
3
.04
8
1000
1
2
1000
2
10
40
S620
UJ
r.j
99.9
1.3
U
*4600
9.3
5.0
14.8 J
11700
18 J
•000
313
U
13.0
338.0
UJ
UJ
214.0
UJ
10.7 J
•
4220
UJ
2.0
34.8
0.9
U
33100
7.3
3.4
12.8 J
14400
8.4 J
9660
1060
U
11.2
464. 0
U
UJ
128.0
UJ
7.6 J
I
9000
U
6.2 J
160.0
1.2
U
32200
8
6.7
41.2 J
15700
111.0 J
7710
278
1.4 J
16.4
1600
0.99
U
191.0
UJ
13.3 J
91.8 J
6580
UJ
7.2
72.2
0.31
U
21800
8.4
S.9
17.8 J
13900
4.8
•600
476
U
12.0
1100
0.64 J
U
170.0
UJ
13.1 J
32.8

-------
                                         TABLE A

                            TOTAL COMPARISON  OF  METAL CONCENTRATIONS IN SOIL
                                      FULTON  TERMINALS SITE
METALS
ALUMINUM
ANTIMONY
ARSENIC
IARIUM
BERYLLIUM
CADMIUM
CALCIUM
CHROMIUM
COBALT
COPPER
IRON
LEAD
NAGXESIUK
MANGANESE
MERCURY
RICKEL
POTASSIUM
SELENIUM
SILVER
SODIUM
THALLIUM
VANADIUM
ZIIC
totes:
            Obstrvtd
       Concentration Ranges
           2370
           0.55
           0.38
           18.4
           0.14
          0.027
            896
              3
            1.7
            2.9
           5710
            3.1
           1120
            110
           0.05
            2.B
            298
          0.125
           0.08
           23.1
          0.025
            S.9
           17.3
21400
  6.3
 79.7
 1710
  16
  2.2
56100
  140
 18.9
  228
35500
 1670
20800
 9050
 0.75
  137
 1630
  1.3
  3.3
  672
 0.75
  133
 1060
                   itrie Mt«n
               (All Sublet)
 6834.5
    1.6
    5.7
  101.2
    o.a
    0.3
 4858.5
   10.4
    5.4
   26.0
14701.6
   25.1
 3348.2
  Ml.4
    0.1
   14.5
  684.5
    0.4
    0.7
   98.4
    0.1
   16.1
   S6.4
                   Hit lorn 1 Rang*
  ND - 150
 0.10 - 194
 0.01 - 7.0

 S.O - 3,000

  2.0 . 100

  1.0 • 888



 1.0 . 1.530


  0.1 - 8.0

   Room

10.0 • 2.000
                  Typical Background
                    Concentrations
                 In Shale Badrock  (b)
0.7
7.0
0.3

82.5

23.5

13.5



35.0


0.07

1.10

S5.5
As revised by McClanahan (1984).
Adapt* frt» Onvtr (1979)

-------
           TABLE 5
      GEOMETRIC MEANS OF
 CONTAMINANTS OF CONCERN IN SOU
 CHEMICAL
     SOIL
CONCENTRATION
   (UO/KG)
 Arsenic
 Barium
Benzene
Chlorobenzene
1,2-DCE (tot)
   MIBK
   Nickel
   Pyrene
   TCE
 Vinyl Chloride
     4884
     7680
     8.15
     5.85
      6.26
    12.86
    12634
      202
     9.66
     12.2

-------
                   TABLE 6
   CONTAMINANT LOADING TO THE OSWECO RIVER
  FROM THE GROUND WATER AT FULTON TERMINALS
                                     Loading
Arsenic                               13.46
Barium                              6723 28
Benzene                               12 . 29
Chlorobenzene                          4 . 32
1,2-dichloroethene                   710.59
4 -Methyl -2-Pent«none                  21.32
Nickel                               749.59
Trichloroechene                      106.11
Viny?-. Chloride                         7.59

-------
                                 TABLE 7
Concentration
    Level
   (ug/m3 >
              CUMULATIVE SHORT-TERM AND LONG-TERM INHALATION
                   EXPOSURES TO  EACH INDICATOR CHEMICAL
                           FULTON TERMINALS SITE

                    Population Exposed and Exposure to
                             Benzene Emissions
       Cumulative  Population
               Exposed
       Persons       X
                 Tim«-Weighted
                  Average Dose
Short Term

  8.45E-01

     Term

  3.77E-05
       2.139
       2.139
32.91
32.91
                                                           2.66E-08
                                                           1.18E-08
Concentration
    Level
   (ug/m3)
Population Exposed and Exposure to
      Chlorobenzene  Emissions

        Cumulative Population
               Exposed
        Persons       X
                 Time-Weighted
                  Average Dose
                  (mgAg/day)
fihort Term

  4.99E-05

Lflflg Term

  2.65E-05
                           2,139
                            2,139
                   32.91
                   32.91
                    1.57E-08
                    B.33E-09
 Concentration
     Level
Population Exposed and Exposure  to
     Vinyl Chloride Emissions

        Cumulative Population
               Exposed
        Persons       1
                 Time-Weighted
                  Average  Dose
                  (mg/kg/day)
 S^hort Term

   1.77E-04

     Tern
                            2,139
                   32.91
                     5.56E-08
   1.77E-04
       2,139
 32.91
                                                            5.56E-08

-------
                                 TABLE 7

              CUMULATIVE SHORT-TERM AND LONG-TERM INHALATION
                   EXPOSURES TO EACH INDICATOR CHEMICAL
                           FULTON TERMINALS SITE
                                (Continued)

                    Population Exposed and Exposure  co
                       1.2-dichloroethene  Emissions
Concentration
    Level.
   (ug/m3)
        Cumulative Population
               Exposed
        Persons       X
Time-Weighted
 Average Dose
 
-------
                                     TABLE 8

                CRITICAL TQXICITY VALUES  FOR  INDICATOR  CHEMICALS
                          AT THE FULTON TERMINALS  SITE
•
Inhalation Route
Arsenic £
Barium
Benzene
Chlorobenzene
1,2-DCE (total)
M1BK
Nickel (e
Pyrene @
TCE @
Vinyl Chloride
Xngestion Route
Arsenic @
Barium
Benzene
Chlorobenzene
1.2-DCE (total)
MIBK
Nickel %
Pyrene @
TCE @
Vinyl Chloride
AIS

-------
                           TABLE  9
                   RISK ESTIMATES FOR CARCINOGENS

CHEMICAL


Exposure
Route

GDI
to/kg. day)
Carcinogenic
Potency Factor
1/dO/kg.day)
Route-
Specific
Risk
Total
Chemical-specific
Risk
Arsenic

BaHu»

Beiuene

Chlorobenzene

1.2-OCE (tot)

MIBX

mctei

Pyrene

TCE

Vinyl Chloride

Oral
Inhalation
HA
HA
Oral
Inhalation
HA
HA
NA
HA
NA
NA
NA
•A
Oral
Inhalation
Oral
Inhalation
Oral
Inhalation
9.57E-08
NA
NA
NA
1.70E-10
1.13C- 08
NA
NA
NA
NA
. NA
NA
NA
NA
3.9K-09
NA
3.66E-10
9.0K-06
2.40E-10
s.stt-oe
                                    1.8            1.72E-07
                                     IS            NA
                                     NA            NA
                                     NA            NA
                                  0.029            4.92E-12
                                  0.029            3.42E-10
                                     NA            NA
                                     NA            NA
                                     NA            NA
                                     NA            NA
                                     NA            NA
                                     NA            NA
                                     NA            NA
                                     NA            NA
                                   11.5 •          4.57E-OB
                                     NA            NA
                               1.10E-02            4.03E-12
                               1.70E-06            1.54E-13
                                    2.3            5.S2C-10
                                  0.29S            1.64C-08

                             Total Upper Bound Risk •
1.72E-07

      NA

3.47E-10

      NA

      NA

      NA

      NA

4.57E-08

4.1K-12

1.7K-M


2.35E-07
Notes:  •   based on CPF for benzo(a)pyrene
   -   NA  Not Available
Notes:  •   Based on CPF for benzo(a)pyrene. Carcinogenic Assessment Group (CAG)
            Risk Value (Clemt.  1985)
      GDI  » Chronic  Daily  Intake

-------
                    TABLE 10
        CALCULATION OF CHRONIC HAZARD INDICES
OCNICAl
Arunti
l»rii»
•tnzene
Qilorobtnztm
I.2-OCE (tot)
HI«
Nickei
Jyrtne
Tff
Vinyl Chloride
CD!
RA
MA
1. Iff -06
8.33E-09
2.16C-08
•A
HA
HA
9.0K-OB
S.JIE-OB
Inhalation
AIC CDI:A1C
MA
l.OOE-M
U
5.00C-03
U
2.00C-02
1.001-02
RA
2.60E-02
U
HAZARD INDEX:
RA
MA
U
1.67E-06
U
MA
MA
RA
3.49C-06
U
5.16C-06
9.
1.
1.
COI
S7E-06
04E-06
70E-10
1.21E-10
3.
2.
2.
3.
OK-10
54C-10
53E-07
9K-09
3.ME-10
2.40E-10
ORAL
AIC
0.001
5.10E-02
U
3.00E-02
U
0.05
2.00C-02
U
1.02E-02
U
HAZARD INDEX:
CDI:AIC
9.57E-05
2.04E-05
U
4.04C-09
U
S.09E-09
1.2SE-05
U
3.SK-06
U
1.2X^4
Notes:  U
        RA Rot Applicable

-------
                                     TABLE 11


                         CALCULATION OF SUBCHRONIC HAZARD INDICES
 CHEM1CAI
      Inhalation

SD1      AIS   S01:AIS
      ORAL

SDI      AIS    SDI-.AIS
    Ar»«t,'-         NA       NA       HA

     Bartw         RA     l.OOE-03    NA


    ttniene      2.66E-08    U        U

  Chlorobeiuene   1.S7E-08 5.00E-02 3.14E-07


  1,2-OCT (tot)   7.13E-08   NA       NA

      N1BK          NA    2.0K-01    NA

     Nickel         NA    2.00C-02    NA

     "yr^nc         PR      PR       w

      TCE        9.59C-06    U        U


Vinyl Chloride    5.5K-06    U        U

                  * NAIAftD INDEX:  3.14E-07
                                3.91E-04     U        U

                                2.22C-03     U        U

                                6.S2E-07     U        U

                                4.68E-07 3.00C-01 1.56E-06

                                5.02E-07     U        U

                                1.03E-06 S.OOE-01 2.06E-06

                                1.01E-03 2.00E-02 S.05E-02

                                1.62E-05     U        U

                                7.74E-07     U        U

                                9.76E-07     U        U

                                   HAZARD  IHXX:  S.05E-02
                 Nptn:  U  Unavailable
                         NA Not Applicable
                        SDI  - Subchronic  Daily  Intake

-------
                                                                         TABLE  12
                                                                        ARMS. CAITCRM. MB OUIOANCC
                                                                   nJLTOS* TfRNINAtt SltC
If ORATORY
federal
Federal
                      ARAR
               CMN Voter Quality Criteria (UK)
               for Protection of Ruaan Health
               and Aquatic life*
               ROM Nmlous Concentration llrita
Applicable
                                                                                      »T«»Slt
tederol
               SOIM ffaMoua Contaojlnant level*     Relevant
               (ntlsl - 40 CFR  141                      and
                                                  Appropriate
Contaalfiont levels  reoulated by UK are
provided  to protect hu«an health for
enpoture  fro* drink I nt water and fro*
contuainf  aquatic organitat (prinary
fish) and fro* H*h consi«ption alone.
                Provides  standard* for  H toate to
                and  peatlcidea for protection of
                froundnater.   These  standards are equal
                to the MCls established by the H»OVf.
                This refutation also provides basis for
                application of alternate concentration
                li«it (*Cl) on  a site specific basis.

                Provides standards  for SO toslc
                compounds. Including  the  U compounds
                adopted as «CI* iCls, for public  drinblno
                syste*.
federal
               fOMPCl Coals
 State
               « RTCRR «rounditater Quality    Applicable
               Refutations Part fOJ.I
                CM hat prosMlfated 9 centoainants and
                has proposed 40 others (SO fR 4o9]6) for
                the public voter systeoi.  The NClGs are
                nan-enforceable health fools and are set
                at levels that would result  In no know
                or anticipated adverse  health effects
                Mlth an adequate «erfin of safety.

                Provides  quality stondarda for
                froundwater.  Certain contaMlnont  levels
                are specified.
•ew Tork
 State
               10 WTCRR Port 170
Applicable       Provides quality standards  for public
                MSter supply.
•*v Tork        Revision to Port 5 of the State      Relevant
 fist*          tenttery Code                           ond
                                                  Appropriate
                                                                  establishes SMM!OMS contaminant levels
                                                                  (NClsl or standards  for Principal  Organic
                                                                  Conta«inants (POC) and  Unspecified
                                                                  Oroonic Centontnont*  (UOC).

-------
                                                             TABLE  12 (Cont.)
                                                         MMM NN VOIATUC ORGMICS IN OMUHMMTII
                                                           rut Ton TERMINALS si IF
                                                    fEDCRAl ARAM
 •V AMI HI WATER
QUAim STANDARDS/
 CUIDANCE VALUES
MAR (NUN
CONCENTRATION
OM Protection of RUM* Neelth
CONTAMINANTS DETECTED A1 SITE MATER ft FISH INCESTION FISH CONSUMPTION
VoletUet
Acetone
•ofuene
Oilorobentene
Ethyl Oewene
Me thy ten* Chloride
N Prepylbentene
••luene
4-Mtthyl -2-Pentenone
el«-1.2-OlcMoro-
ethene
1,1-Olchloroethene
1.1-Dldiloroethene
1,1.1-TrlcMoroethene
Tetrochloroethene
TrlcMoreetfcem
Vinyl Chloride
•ylenee (Total)

•71.4
422.7
142.0
432.5
185.9
27.7
64.9
3*3.0
14.387.0
24.3
49.6
113.2
6.8
2.388
88
303
i
HC
0.66
HS
1.400
RS
NC
14.300
NC
NS
HC
3.1.W*
18.400
0.8
2.7
2
HC
*
HC
40
RS
3.280
HS
HC
424.000
HC
RS
HC
1.85
1.030.000
8.85
80.7
525
HC
SMM
OJIDANCE PART 5. STATE
MCLs NCLG VALUE SANITARY CODE

* •
5
100*
700*
--
--
2.000*
•-
7
--
--
200
5*
5
2
10.000*

••
0
100*
TOO*
50
• *
2.000*
••
7
••
•-
200
0*
0
0
10.000*

NC
NS
20
50
50
HC
50
NC
HC
50
0.07
50
0.7
RS
RS
50

50
5
5
5
5
5
5
50
5
5
5
5
5
5
2
5
STANDARD

HC
NO
RS
HS
NS
HC
HS
RS
HC
RS
HS
RS
RS
10
5
m
Not*:  All Concentration* In uf/l  
-------
                                                 TABLE  12  (Cont.)

                           CHEMICAL-SPEC IMC AlAtS  F0»  INORGANICS IN GOJNOUATEI
                                          FULTON TERMINALS SITE
                                                                                    •t AMIENT WATER
                                                                                   QUALITY STANDARDS/
                                                                                    CU10AMCE VALUES

|JJO£JJ£^^£J
Ailffintf1
Antiaony
Arsenic
•Viu»
•tryUitfn
C**rikff
Calcti*
OtroBiun
Cctott
Ccoptr
Iron
LMd
••frwctt*
«W«*r«*t
•trcury
•ickil
»»tUIWA MCLS
NC
NC
50
1.000
NC
10
NC
50
NC
NC
NC
50
NC
NC
2
NC
NC
10
so
•C
NC
NC
NC
OltNKlNC
MATE*
NS
50
SO
1.000
NC
10
NC
50
NS
200
300
50
35.000
300
2
NS
NC
10
50
NC
4
VS
300
C.W. FOR
DRINKING
NS
3
25
1,000
NC
10
NC
NS
NS
1,000
300
25
35.000
300 .
2
NS
NC
20
SO
NC
4
NS
5.000
Nctt:  All Concwitntim fo «t/l
       •S • IncitlM tn ttw LUlint tut liaitt Not Sptcffitd
       NC • Hot • luted ContOTirant
       ND • Net Octtctwl

-------
                                                                  TABLE 12

                                                  ACTio*.-spf.ciric MMS ro» sou MB arawmMTt* TKAINMT
                                                                  ruitcH TCPMINM.S siu
                                            WTO?
                                                                 STUOMIl
     A.
TO ALL AlTfRWTIVtS:
OtM  - Central Industry Standards (29 CM  Applicable
1910)
OSNA  •  tefet* end Health Standards (29  Applicable
CM 1926)
OSM'Recerd Keeping. Reporting and  Applicable
•elated Regulations (29 CM 1904)
USiPA  Croundwater Protection Strategy •   To Re
USCPA Pel Icy Statement. August 19M         Considered
•CIA  - ttandvrdi f«r OMwri/optrator* of   IvIcvMit And
»*r«ltttd Miardom Wast* Facilltlm (40   Appreprlat*
CM 2o4.10-2M.18)

•CM •  •rtp«r«dn*«t and •ravtntlan   Ralavant And
(40 CM 1*4.50-264.9T)                     Appropriate
                                                 ragulatlona  apaclfy  t»»«  •-Ireur
                                          tlM-mlfhtcd avcraa* concentr*tIm far worker
                                          •upeturc  to war I out oraanic c<««KMid«.   Trainini
                                          reqwlraawnta  tar  Marker*  at  hatardau* naste
                                          operation* ara specified in 29 CM 1910.120.

                                          TMa ratulatlan tpaclflas the type af aafaty
                                          aqulpawnt and procedure*  to be followed durinf
                                          alte reacdiatlan.

                                          Tills reawlatlon outlines the record  kaeplne, and
                                          reporting requirement* for «n employer under
                                          OSH*.

                                          Identifies groundwater quality to be achieved
                                          during reaiedlal actions  bated on the equlfer
                                          characteristics and use.

                                          General  facility requirement*  outline general
                                          Masta analysis, security ewature*, inspection*.
                                          and  training requirement*.

                                          This regulator outlines  the requirement* for
                                          safety equipment and spill control.
•C*A  •  Contingency aim and emergency  Relevant And
Procedures (40 CM 264.M-264.So>           Appropriate
•CM  -  •roundveter Prefect Ion (40 Cf«   Relevant And
2M.90-2M.101)                           Appropriate
•CRA • Closure and Peat-Cloaure (40  CM   Relevant And
2M.110-2M.120)                          Appropriate
                                         This  regulation outlines the requirements for
                                         emergency  procedures  to be  used following
                                         explosions,  fires, etc.

                                         This  regulation datall a  requirements for  a
                                         groundwater  monitoring program to be Installed at
                                         the alte.

                                         The regulation details specific requirements far
                                         closure and post-closure of hatardou* waste
                                         facilities.
           •t* Tri
        tatlent
DOT Rulaa tar Transportation at aaierdoue   Applicable
Material*  (49 C'R  Parts  107.
in.1-172.558)
                                         This  regulation outlines procedures  for  the
                                         peckaglng,  labeling,  manifesting,  and
                                         transporting of hatardou* material*.

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                                                                      TABLE 12 (Cont.)

                                                                       •age 2 of 6
                                                                                 tnantt
     Uaste Tr
tRtlon (Cont'dlt
ttendards Applicable to Transporters of  AppllcobU
•aierdeus Wast* •  RCRA Section 1003, 40
cm 26t en* MS. 40 CfR in> to  ir9T
•CM  land tlapoMl  Restrictions  (40  CfR   Relevant And
268, Sutptrt 0)                            Appropriate
|»A  Administered Mrvlt f>rofrMi:  Tk«   Appllcablt
             ««t* Mr*lt frofr** RCIA
    lon 3005, 40 crR  270.  124*
                                       Citoblltktt  tk» r*»pontlbllltr of  off-««tt
                                       transporters of h»i«rdo«n  M*st«  in the hcndlinf.
                                       transport*!ion. end ••natevent of  the Mast*.
                                       •eojutrcs • «*nlf*st. r«cordkc«pint, and l*ncdi*t«
                                       action in the event of a discharge of haiardoin
                                       waste.
                                       After Noveatwr 8,  1988,  *»ve»ent of eicavated
                                       •aterlals to new location and placeaent  in or on
                                       land Mill trifter land disposal restrictions  (for
                                       non-CERCIA actions).  CC«CIA actions  Mill b*
                                       reaul*t*d under  this requireonet beoinninq on
                                       Covers  the basic peralttlna.  application,
                                       •on I tor I nff and reportlnfl requlrenents for
                                       off-site hatardous vaste MartageMent facilities.
          •. Mil THATICRTt

              laceration;

CAA  •  HAA8S  far  total Suspended   Relevant And
•articulates (40 C« 129.10S. 750)          Appropriate
40 CfR M2t  RCRA



40 CfR M4. Sutapart I


40 C» 244:  RCRA
                        Applicable



                        Applicable


                        Applicable
This  regulation specifies MailMUM primary and
secondary 24-hour concentrations  for partlculate
•atter.   fugitive dust  emissions  fro*  site
eicevatLen activities MUM  be Maintained below
260 ug/M* (prlMery standard).

fatabllsHes standards for generators of hatardous
waste* Including Mast* determination.  Manifests,
and pre-transport requirewnts.

Provides requlroaents to design and operate waste
piles.

Requires oMner/operator to control Mind dispersal.
of partlculate Matter.
40 CrR 50:  MAOS
                        Applicable     Provides air quality standards for particulate
                                      •atter and lead.

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                                                                            1.4.


                                                                       •ee» 3  e« 6
                 •••••                       ••AM^B                   ^tfJUII^M^WM* A^a*«^A.A
                 HUH1                       11*. nil                   moUHtiaUT 1THOPSI8

          |«cavatlon CCont'd>t

        Part ITS                           Applicable     Require*  oMner/operator to cover or otherwise
                                                         manage to control wind dispersal  of  partlcutate
                                                         matter.

* *TCM Part 211                           Applicable     Provides General Prohibition, for release  of air
                                                         contaminants.
            Clean Closure;

RCM - General Standard* (40 CFR 264.111)    Relevant And   General  performance standard  require*
                                          Appropriate     mlnimliatlon of need for further maintenance and
                                                         control;  mlnimliatlon or  elimination  of
                                                         post-closure escape of heierdou* Matte, haierdoua
                                                         constituent*, leachate.  cofltamtnoted  runoff, or
                                                         hatardou* «a*t* decompotltion products.  Alto
                                                         require*  dltpottl or decontamination  of
                                                         equipment, *tructuret, end toilt.
At era e*.S2t  NSPS                        Applicable      Provide*  pertlculate  eml**lon  limit*  for
                                                         Incinerator*.

41 era 2Mt  Ubpart 0                     Applicable      Provides performance stendard*  for hatardous
                                                         Matte Inclneratort.
6 NtCKt pwt 201                           Relevant And    Require* permit to construct  and permit to
                                          Appropriate     operate an air contawineti«n tource.

• RTCM Part 211                           Applicable      Provides General  Prohibition* for release of air
                                                         contaminant*.

a WTCRR Part 212                           Applicable      Requlrea control  and  prohibit*  release of air
                                                         contaminant* from any  nen or exist Ins process or
                                                         exhaust and/or ventilation cystem.

Air Guide-1                                Applicable      Guidelines  for control  of to«ic emblent elr
                                                         contaminants.

• HTCRR Part 219                           Applicable      Provides emlMlon  standards  for Incinerator*.


o HTCRR Part S73                           Applicable      Provide* performance ttandardt  for hatardou*
                                                         Mast*  inclneratort.

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                                                                TABLE  12  (Cont.)


                                                                    Page 4 of 6
                ARAM

       Thermal Treatment (Cont'd)
                                           JTATUS
                                                                              STMPSIS
40 c» 264.331


CM • MMS (40 tn 1-99)
                      *
Interim RCRA/CCRCIA  Guidance  on  tot*
•en-Contiguous Sites end On-Slte  Comldtrtd
Management of Waste and Treated Residue
(USCPA Policy Stetsment.  Hereh 27. 1986)
CM • HMOS for Partlculete Natter lets
Than 10 NIcroM In Diameter (40 C« fart
60. Append!* J>

       C. CMWHPWm TKATMIHT:

    XtcMrat of tra«t«d BroundMatart

40 cri 1K.41 and 44
Applicable      Provides retirements for disposal of  Incinerated
               ash, scrubber water, end scrubber sludge.

Applicable      Applies to major  stationary sources such as
               treatment units that  have the potential to-emit
               algnif leant  amounts  of  pollutants such as  HO  ,
               SO.,  CO,  lead,  mercury entf partlculates (moPe
               thin  2SO  tons/year).  Regulations under  CM do
               not specifically regulate emissions from
               hatardous  Maate Incinerators, but it is  likely
               that  Prevention of  Significant  Deterioration
               (PSO) provisions  Mould  apply  to an on-slte
               treatment facility.

               If a treatment  or storage  unit  Is  to be
               constructed  for on-slte remedial action, there
               should bo a clear Intent  ta dismantle, remove, or
               close the unit after  the CCRCIA  action Is
               completed.  Should  there be plena to accept
               commercial  waste at  the  facility after the CCRCIA
               waste has been processed,  it Is EPA policy that  a
               •CRA  permit be obtoined before the unit Is
               constructed.

Relevant And    This  regulation  specifies maximum annual
Appropriate     arithmetic  mean  and maximum  24-hour
               concentrations for particulate matter.
•elevent And   Require* use of best  available technology (Mf)
Appropriate    to control tonic and  nooeonventtonal pollutants;
              use  of best  conventional pollutant control
              technology  (RCT)  for conventional pollutants.
              Technology-based limitations My be determined on
              a case-by-case basis.

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                                                                                  1Z
                                                                            Page 5  of  6
                 ARARl

    Discharge of treated Broundmiter
                (Cont'd):

 40 CM 129.100 and 40 CM 129.104
40 CM 1S6.1-1M.4





          \



40 CM Port 2*2


40 CM 267.54


40 CM Port 2*1
                                             ttAfUf
Relevant And
Appropriate
                                           Mlovant And
                                           Appropriate
Applicable


Applicable


Applicable
                                                          Requires dtvelepwnt and Implementation of • Dest
                                                          Management  Practices program to prevent  the
                                                          'elee«e of tonic constituent* to turfac* water.

                                                          Approved tttt Mthodt for iM*t* constituent* to
                                                          b« Monitored  "utt  b* folloMed.   Oetolltd
                                                          r«qulr«*«ntt for  analytical  procedure*  and
                                                          quality control* arc provided.

                                                          fa«pla preaarvatlon procedure*,  container
                                                          •aterlal*. and waxlau* allo«*ble holding ti«es
                                                          era prescribed.

                                                          f*tabll*h«* *tandard*  for generator* of hatardoM
                                                          ua*t«*.
                                                          lequlre* «a«a«e4e«- atatu* if neat* la  stored for
                                                          over 90 days on-site.

                                                          »>rohlbita dilution as • substitute for treatment.
40 CfR  144.12, 144.IS,  144.1*.  144.21.
144.51.  144.55, 40 CM  144.55

40 CM 14o.4. 144.12, Ho.U
40 CM Uf


40 CM 2«8.2
Relevant And
Appropriate

Relevant And
Appropriate
                                          Relevant And
                                          Appropriate

                                          Relevant And
                                          Appropriate
                                                         •revidea  criteria  for Injection of  treated
                                                         eroundMater.

                                                         •revIdea criteria for determining whether an
                                                         aquifer My be determined to be an eieapted
                                                         aquifer,  uhleh Include current and future use,
                                                         yield, end uater quality characteristics.
                                                         Regulates  Injection conditions  and  monitorIng
                                                         requ! resents.
               Provides  requirements  to comply  with state
               underground Injection regulations.

               Ratardaus waste to be Injected  la subject to land
               ban regulations,   treated groundMater that meeta
               the definition of hatardous itaste and  Is  to be
               Injected also la subject to land ban regulations.
  vrcm rart no
                                          Applicable      Provides discharge requirements for the Hew Tort
                                                         Stete Pollution Discharge elimination System. '

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                                   TABLE 12  (Continued)
                                        Pag*  6 of  6
          ARAR8

     Air Emissionst

52 PR 3748
NESHAP (40 CFR 61)
STATUS
Applicable
Applicable
NYSAAS (6 NYCRR 257-3,5)
PSD (40 CFR 51 and 52)
Applicable
Applicable
REQUIREMENT SYNOPSIS
Provides proposed standards for
control of volatile organic emi-
ssions from equipment processing
the wastes.

Provides emission standards for
hazardous air pollutants such
as beryllium, mercury, vinyl
chloride, benzene, arsenic and
lead.

Provides State air quality
standards for particulates
and photochemical oxidants.

New major stationary sources
may be subject to PSD review,
i.e., require best available
control technology (BACT) ,
lowest achievable emission
limit (LAEL) , and/ or emission
offsets.
OSWER Directive 9355.0-88
To be considered
Adddresses controls for air
strippers .

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                               TABLE 13
                 PERFORMANCE OF A UV/OXIDATION SYSTEM
                  FULTON TERMINALS FEASIBILITY STUDY
VOLATILE
Acetone
4-Methyl-2-Pentanone
1,1-DCE
ci«-l,2-DCE
TCE
PCE
1,1-DCA
1,3,1-TC/.
Benzene
Toluene
Xylene
Chlorobenzene
Ethylbenzene
N-Propylbenzene
Methylene Chloride
Vinyl Chloride
FEED fpDb^
973.4
393.0
49.6
14,387.0
6.8
6.8
24.3
113.2
20.8
6.8
3.1
3.1
2.4
27.7
185.9
88.0
EFFLUENT (ppb)
584
236
<5
<5
<5
<5
<5
70
<5
<5
<5
<5
<5
<5
38
<2
Process Flow Rate:   150  gpn
Note:  Treatment  efficiency for lowest cost removal of 1,1-DCE,
       cis-l,2-DCE,  PCE,  benzene,  vinyl chloride.

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                                          TABLE 14
                           COST ESTIMATE SUMMARY OF ALTERNATIVES
BOIL
Alternative
BC-1 - Mo Action
sc-2 - Excavation and Disposal
sc-3 - LOW Temperature
Thonal Extraction
8C-4 - off-site incineration
OROUMDWATBR ALTERNATIVES
MM- 1 Mo Action
MM- 2 Air Stripping/
carbon Adsorption
MM- 3 Uv/oxidation
, Capital
Coat Annual OiM
0 $20,400
$2, 9 27, 000 0
1,847,000 0
11,303,000 0

$ 0 $35,300
•23,000 732,000
§11,000 511,000
3-Taar
Review
$10,000
0
0
0

$10,000
0
0
Total Preaent Worth
5% Discount Rata
$ 342,000
2,927,000
1,847,000
11,303,000

$571,000
2,184,000
1,861,000
Motess  i.  All capital ooata incorporate contingency and design factors.
        2.  All costs rounded to the nearest thousand.

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APPENDIX 2 - PZOURB8

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                  UCtNO .
                                  Miff
me.
      HNM
SRC UBOUI

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SERVICES we. |   rwtoM

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N
                                                                                                                     'ICCNQ
                                                                                                             ALL a*ct*rumt* (tram u

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ilCCMD

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N

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APPENDIX 3 - ADMINISTRATIVE RECORD INDEX

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APPENDIX 4 - NY8DEC LETTER OF CONCURRENCE

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Ntw York Stttt Department of Environmental Conservation
SO Wolf Road, Albany, Ntw Yortc 12233 * 7010
                                          September 29, 1989
       Mr. William J. Muszynski, P.E.
       Acting Regional Administrator
       United States Environmental
        Protection Agency
       Region II
       26 Federal Plaza
       New York, NY  10278

       Dear Mr. Muszynski:

                                     RE:  Fulton Terminals Site
                                          NYSDEC Site Code:  7-38-023
                                          Record of Decision
                                          Letter of Concurrence

       The State of New York has reviewed the Record of Decision (ROD), dated
       September 1989, for the Fulton Terminals Site, which includes
       excavation of contaminated soil, low-temperature thermal extraction of
       the contaminated soil, recovery of contaminated groundwater and air
       stripping and carbon adsorption of the recovered groundwater.

       The State of New York concurs with the ROD with the understanding that
       this concurrence is subject to the following:

            Although the State of New York accepts the soil cleanup
            criteria presented in the ROD as being protective of public
            health, recalculation of soil cleanup criteria will be performed
            during the remedial design using an analysis mutually acceptable
            to the State and United States Environmental Protection Agency
            (USEPA).   -

                                 *        Sincerely,
           MDK:slj
                      Edward 0. Sullivan
                      Deputy Commissioner
           bcc:
Sullivan (2)
O'Toole (2)
Goddard
Slack
 upe	

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