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
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(Formerly NTTS-35)
Department of Commerce
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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
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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:
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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
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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.
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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.
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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
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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.
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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.
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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
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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.
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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
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(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.
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- 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.
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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
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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
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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
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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.
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APPENDIX 1 - TABLES
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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*.
-------
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.
-------
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.
-------
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.
-------
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. '
-------
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 .
-------
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.
-------
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.
-------
APPENDIX 2 - PZOURB8
-------
UCtNO .
Miff
me.
HNM
SRC UBOUI
-------
SERVICES we. | rwtoM
-------
N
'ICCNQ
ALL a*ct*rumt* (tram u
-------
ilCCMD
-------
N
-------
-------
APPENDIX 3 - ADMINISTRATIVE RECORD INDEX
-------
APPENDIX 4 - NY8DEC LETTER OF CONCURRENCE
-------
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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