United States
Environmental Protection
Agency
Office ol
Emergency and
Remedial Response
EPA/ROOR02-90/117
September 1990
Superfund
Record of Decision:
Hooker-102nd Street, NY
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REPORT DOCUMENTATION
PAGE
I. REPORT NO.
EPA/ROD/R02-90/117
J. Redplenf e Acceeefon No.
4. Tine ind Subllde
SUPERFUND RECORD OF DECISION
Hooker-102nd Street, NY
First Remedial Action - Final
7. AutfiorO)
5. Report Date
09/26/90
8. Performing Organization Rapt No.
9. Performing OrgainUatfon Hunt and Addreea
10. ProjecvTiek/Work Urtt No.
11. ContncXC) or Grant(G) No.
(C)
12. Sponaorlng Organization Name and Addreee
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
13. Type ol Report t Period Covered
800/000
15. Supplementary Note*
IS. Abelract(UfflH: 200worde)
The 22-acre Hooker-102nd Street site is a former industrial landfill in the city of
Niagara Falls, Niagara County, New York. The site is adjacent to, and partially within
the Niagara River's 100-year floodplain. Surrounding land use is industrial and
residential. From 1943 to 1970, the site was used by Occidental Chemical Corporation
(formerly Hooker Chemicals and Plastics Corporation) and Olin Corporation as a disposal
area for at least 159,000 tons of solid and liquid industrial wastes including benzene,
chlorobenzene and hexachlorocyclohexanes. In 1970, the U.S. Army Corps of Engineers
ordered landfilling operations to cease temporarily until a bulkhead between the
landfill and the river could be constructed. The bulkhead was completed in 1973, but
landfill operations were not resumed. In 1973, a series of investigations were
conducted by EPA to characterize site subsurface conditions. These studies and the
Remedial Investigation (RI) initiated in 1984, identified contamination in ground water,
onsite and offsite soil, rivershore sediment, and within a storm sewer. Additionally,
the presence of a leachate plume of non-aqueous phase liquids (NAPLs) was discovered
emanating from the landfill area. This Record of Decision (ROD) is the final remedy,
(See Attached Page)
17. Document Anelyele «. Deecriptora
Record of Decision - Hooker-102nd Street,NY
First Remedial Action - Final
Contaminated Media: soil, sediment, gw
Key Contaminants: VOCs (benzene, TCE, toluene), other organics (PCBs, phenols),
metals (arsenic)
b. Identtflera/Open-Ended Term
c. COSATI Reid/Group
18. Availability Statement
19. Security CUee (Thle Report)
None
20. Security One (TMe Page)
None
21. No. olPagee
70
22. Price
(See ANS(-Z39.18)
See (nelructfaiM en Jtenrw
OPTIONAL FORM 272 (4-77)
(Formerly NTIS-JS)
Department o< Commerce
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EPA/ROD/R02-90/117
Hooker-102nd Street, NY
First Remedial Action - Final
Abstract (Continued) .
which addresses all of the contaminated media. The primary contaminants of concern
affecting the soil, sediment, and ground water are VOCs including benzene, TCE, and
toluene; other organics including PCBs and phenols; and metals including arsenic.
The selected remedial action for this site includes consolidating offsite soil and
lesser contaminated sediment within the landfill area then capping the landfill and
perimeter soil; constructing a slurry wall around the site perimeter to contain the NAPL
plume; extracting NAPLs from the landfill and dredging "hot spot" river sediment,
transporting sediment and leachate offsite for incineration; dredging and dewatering
remaining sediments and consolidating them within the landfill area; recovering ground
water with an interception drain, followed by onsite discharge to the Niagara River or
offsite treatment and discharge to a city sewer; cleaning the storm sewer, and placing a
plastic slipliner within the sewer; extracting and incinerating offsite NAPLs within
consolidated river or sewer sediment; long-term ground water monitoring; and implementing
institutional controls including deed and land use restrictions, and site restrictions
such as fencing. The estimated present worth cost for this remedial action is
$30,080,000, which includes an annual O&M cost of $7,209,600.
PERFORMANCE STANDARDS OR GOALS: Cleanup goals for ground water will be the more
stringent of Federal MCLs or State regulated levels. Chemical-specific ground water
goals include benzene to detection limits (State), TCE 5.0 ug/1 (State), PCBs 0.1 ug/1
(State), phenols 1 ug/1 (State), and arsenic 25.0 ug/1 (State). Sediment remedial levels
will be the solid phase concentrations necessary to potentially exceed State Ambient
Water Quality Standards in the liquid phase. Chemical-specific cleanup levels for
sediment include benzene 40 ug/kg, TCE 111 ug/kg, and PCBs 42.4 ug/kg.
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RECORD 07 DECISION
102nd STREET IAKP7ILL
NIAGARA PALLS. NEW YORK
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION ZZ
NEW YORK, NEW YORK
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ROD FACT SHEET
SITE-
Name: 102nd Street Landfill
Location: Niagara County
Niagara Falls, New York
MRS Score: 30.48
NPL Rank: 973
ROD-
Date signed: September 26, 1990
Remedy: Synthetic-lined cap (covering approx. 24
acres), consolidation of "off-site" soils
beneath cap, containment via a circumferential
slurry wall, dredging and incineration of
highly contaminated sediments, dredging and
consolidation beneath the cap of the remaining
contaminated sediments, recovery and treatment
of ground water, incineration of any recovered
NAPL, post-remedial monitoring, fence, and
institutional controls.
Capital Cost: $22,870,000.
O&M/Year: $7,209,600.
P-W Cost: $30,080,000.
LEAD-
PRPs: Occidental Chemical Corporation (OCC)
and Olin Corporation (Olin)
Primary contact:.. Paul J. Olivo (212)-264-6477
PRPs contacts: OCC: Alan F. Weston (716)-286-3607
Olin: David L. Cummings (615)-336-4549
WASTE-
Type: industrial landfill. Waste included
approximately 4,600 tons of benzene,
chlorobenzene, chlorophenols a'nd
hexachlorocyclohexanes (HCCHs).
Media: ground water, soils and river sediments
Origins: landfill dumping
Est. Quantity:.-... 159,000 tons of liquid and solid wastes.
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DECLARATION FOR THE RECORD O7 DECISION
102nd Street Landfill
Niagara Falls, New York
Statement of Basis and Purpose
This decision document presents the selected remedial action for
the 102nd Street Landfill Site (the "Site"), located in Niagara
Falls, New York. The remedial action was chosen in accordance with
the requirements of the Comprehensive Environmental Response,
Compensation, and Liability Act of 1980 (CERCLA), as amended by the
Superfund Amendments and Reauthorization Act of 1986 (SARA), and
the. National Oil and Hazardous Substances Pollution Contingency
Plan (NCP). This decision document explains the factual and legal
basis for selecting the remedy for the Site. The New York State
Department of Environmental Conservation (NYSDEC) concurs with the
selected remedy.
The information supporting this remedial action decision is
contained in the administrative record for the Site.
Assessment of the Site
Actual or threatened releases of hazardous substances from the
Site, if not addressed by implementing the response actions
selected in this Record of Decision (ROD), nay present an imminent
and substantial threat to the public health or welfare, or to the
environment.
Description ef the Selected Remedy
The remedial actions described in this document address the three
operable units (OUs) at the Site. The three OUs are:
OU-1: Landfill residuals including on-site fill, •'off-
site'* soils, shallow ground water, and non-aqueous phase
liquids (NAPL), (For purposes of this document, "off-
site" soils are located on the triangular plot of land
adjacent to the Site, north of Buffalo Avenue and south
of the LaSalle Expressway, as veil as on the areas
immediately adjacent to the Site to the east and to the
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vest);
ou-2: River sediments within the shallow embayment of the
Niagara River adjacent to the Site; and,
ou-3: The storm sewer which crosses the Site and
discharges into the Niagara River.
The major components of the selected remedy include the following:
Capping of the sitj
A synthetic-lined cap, constructed in accordance with
federal and state standards, will be installed over the
landfill and perimeter soils.
Consolidation of Soils
All off-site soils above cleanup thresholds, will be
consolidated beneath the cap.
Erection of a Slurry Wall
A slurry wall, completely surrounding the Site's
perimeter, will be constructed and keyed into the
underlying clay/till geologic formation. The precise
location of the slurry wall will be established through
the use of geotechnical borings which will determine the
extent of the NAPL plume. The NAPL plume will be
contained by the slurry wall.
Recovery and Treatment of Ground Water
Ground water will be recovered using an interception
drain installed at the seasonal low-water table in the
fill materials. Recovered ground water will be treated.
Although the recovery of ground water does include a
treatment component, the primary function of ground-
water recovery in general, is to create and maintain an
inward gradient across the slurry vail.
Recovery and Treatment of NAPL
- NAFL beneath the Site will ba recovered uring dedicated
extraction wells, and will b« incinerated at an off-site
facility.
Embayrnent Sediments ' '
The two areas of Niagara River sediments which contain
elevated concentrations of contaminants ("hot spots"),
will be dredged, and these highly contaminated sediments
will be incinerated at an off-site facility. The
remaining sediments will be dredged out to the "clean
line11 with respect to site-related contamination. These
remaining sediments, after dewatering, will then be
consolidated on the landfill. Any NAPL found within the
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remaining sediments will be extracted, and will be
incinerated at an off-site facility.
The primary focus of this remediation plan is to contain
the NAPL plume with the slurry wall. In the event the
slurry wall's initial positioning places it across the
"hot spot" area(s), practicality may dictate that the
wall be extended outward to enclose these "hot spots."
In such case, these highly contaminated sediments, rather
than being dredged and incinerated, would be left in
place, that is, contained by the slurry wall, covered
with fill, and finally covered with the cap. The
remaining sediments beyond the slurry wall would still
be dredged and consolidated beneath the cap.
Storm Sever
The existing storm sewer will be cleaned, and a high
density polyethylene (HDPE) plastic slipliner will be
installed within the sewer. The annular space between
the original pipe and the slipliner will then be
pressure-grouted. Any NAPL found within the soils and/or
sediments taken from the existing sewer will be
extracted, and will be incinerated at an off-site
facility.
Monitoring
Post-remedial monitoring shall be performed to determine
the effectiveness of the remedial alternatives which have
been selected.
Restriction of Access
A 6-foot high chain-link fence will be installed around
the perimeter of the cap in order to restrict access to
the Site.
Institutional Controls
Institutional controls in the fora of deed restrictions,
or similar restrictions, on the future uses of the
lanrt?.U" .. will be established.
Declaration of Statutory Determinations
The selected remedy is protective of human health and the
environment, complies with federal and state requirements that are
legally applicable, or relevant and appropriate to the remedial
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actions, and is cost-effective. This remedy utilizes permanent
solutions and alternative treatment technologies to the maximum
extent practicable for the Site. However/ because treatment of the
principal threats of the Site was not found to be practicable, this
remedy does not satisfy the statutory preference for treatment as
a principal element. Because the selected remedy will result in
hazardous substances remaining on-site above health-based levels,
a review will be conducted within five years after commencement of
the remedial action to ensure that the selected remedy continues
to provide adequate protection of human health and the environment.
Constantine Sidamon-EristQf?/
Regional Administrator
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TABLE 0? CONTENT^
Page
DECISION SUMHARY 1
I.- Site Location and Description 1
II.- Site History and Enforcement Activities .3
III.- Highlights of Community Participation 5
IV.- Scope and Role of the Response Actions
Within Site Strategy 5
V.- Summary of Site Characteristics 6
VI.- Summary of Site Risks 8
VII. - Description of Alternatives 12
VIII.- Summary of Comparative Analysis of Alternatives .. 18
IX.- Selected Remedy 30
X.- Statutory Determinations 32
Figure 1.- Landfill and Survey Area
Figure 2.- Remedial Investigation Summary
Figure 3.- SSIs Above Survey Levels in the Embayment Area
Figure 4.- Cap and Containment Wall
Table 1.- Chemicals of Concern
Table 2.- Summary of RI Sampling Data for Significant-Risk
Chemicals
Table 3.- Reference Doses and Cancer Potency Factors for
Chemicals Used in Risk Calculations (3 pages)
Table 4.- Summary of Reasonable Maximum Potential Human Health
Risks
Table 5.- Chemicals of Probable and Possible Concern for
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Environmental Endangerment
Table 6.- Operable Unit One Final Alternatives
Table 7.- Operable Unit Two Final Alternatives
Table 8.- Operable Unit Three Final Alternatives
Table 9.- Location-Specific ARARs (2 pages)
Table 10.- Chemical-Specific ARARs - Ground Water
Table 11.- Evaluation of Ground-Water Concentrations
Table 12.- Estimated Sediment Quality Criteria
RESPONSIVENESS SUMMARY 39
I.- Overview 39
II.- Background on Community Involvement and Concerns 39
III.- Summary of Major Questions and Comments Received
During the Public Meeting and the Responses
of the EPA 40
IV.- Summary of Major Written Comments Received During
the Public Comment Period and the Responses
of the EPA 43
V.- Remaining Concerns 46
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DECISIONSUKMXRY
102nd STREET
NIAGARA FALLS. NEW YORK
I.- Site Location and Description
The 102nd Street Landfill (the "Site"), which covers 22.1 acres,
is located at the eastern edge of the City of Niagara Falls in the
County of Niagara and the State of New York. As shown in the
attached Figure 1., the Site is adjacent to the Niagara River (the
"River") on the south, and abuts Buffalo Avenue on the north. The
geographical coordinates of the Site are long. 78*56'53" W. and
lat. 43'04'21" N.
The Site, which is presently owned by Occidental Chemical
Corporation (OCC) and Olin Corporation (Olin), collectively
referred to as the "Companies," was operated as a disposal location
for industrial wastes by the Companies and their respective
predecessors. OCC, and its predecessors, operated their 15.6-acre
portion of the Site as a landfill from approximately 1943 until
1970. Olin, and its predecessors, operated their 6.5-acre portion
(which occupies the eastern section of the overall Site) as a
landfill from 1948 to 1970.
To the west of the Site is Griffon Park (12.8 acres) which was used
as a refuse-dumping facility by the City of Niagara Falls until
1953. Thereafter, it was converted into a recreational park until
1986. At the present time, only the boat-launch facilities to the
west of the park are open to the public. Griffon Park in turn, is
bordered on its west by the Little Niagara River. Cayuga Island,
which is zoned "one family residential," is immediately across the
Little Niagara River from Griffon Park. Cayuga Island has a
population of approximately 2,.000.
The privately owned property to the east of the Site (the "Belden
Site") was, from 1955 through 1967, an industrial disposal area.
The Belden Site is now a New York State registered inactive
hazardous waste site that is classified as one which does not
present a significant threat to the public health or to the
environment. Along Buffalo Avenue to the north of the Site, there
are several uninhabited residences.
The RI/FS study area included the triangular plot of land adjacent
to the Site, north of Buffalo Avenue and south of the LaSalle
Expressway, the areas immediately adjacent to the Site to the east
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[
and to the west, as well as the River sediments adjoining the Site.
For ease of reference, the triangular plot of land north of Buffalo
Avenue and south of the LaSalle Expressway, is denoted herein as
an "off-site" area to distinguish it from the area that was
historically used as a landfill. All areas, including the
landfill area, this off-site area, and others where contamination
associated with the landfill has come to be located, are included
within the definition of the Site's "facility" as defined in
Section 101(9) of CERCLA, 42 U.S.C. §9601(9).
According to the 1980 Census, the population of the City of Niagara
Falls was approximately 71,000 and the population of the Town of
Wheatfield was approximately 9,600. The Town of Wheatfield adjoins
the City of Niagara Falls on the east.
In December 1970, the Buffalo District of the U.S. Army Corps of
Engineers (COE) notified OCC and Olin that any construction or
landfilling at the Site must cease until a dike or bulkhead was
installed along the River shoreline, under a permit issued by the
COE. A bulkhead was completed in 1973, and no subsequent
construction or landfilling occurred.
Areas near the Site have historically experienced flooding in low-
lying areas adjacent to the Niagara River. Both Cayuga Island
located west of the Site and a residential area along River Road
in the Town of Wheatfield, east of the Site, have been flooded
numerous times in the past 40 years with major flood events
occurring in 1942, 1943, 1954, 1955, 1962, 1972, 1975, 1979, and
1985. Both of the affected areas are within a one-mile radius of
the Site. However, as expected due to the elevated height of the
Site behind the bulkhead, no flood events are known to have
occurred for portions of the Site which are located between the
bulkhead and Buffalo Avenue. The small lowland area, which
consists of 0.6 acres, at the edge of the southern property line
on the Niagara River, however, is designated as being a location
which is subject to 100-year flooding with average depths of less
than one foot. In addition, the ditch area immediately to the east
of the Site, is expected to be included in the 100-year flood
plain.
Topographical relief at the Site is aininal since *•>.«. ground
surface is relatively flat. The maximum change in elevation across
the Site behind the bulkhead is approximately 5 feet. This flat
topography, except for the embankment at the River's edge, limits
runoff. Elevations within the study area range from 564 feet above
mean sea level (MSL), at the River's edge, to 578 feet, on a slight
crest behind the bulkhead. There are also some slight depressions
on the OCC portion of the Site in which surface water collects.
The slightly mounded effect of the surface topography essentially
results in surface-water flowing off-site in four directions,
although all surface-water eventually discharges into the Niagara
River. The majority of the Site drains directly to the Niagara
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River to the south. • However, there are some surface areas where
surface water runoff flows to the east, west and north. The
easterly component flows to the ditch that parallels the eastern
property boundary. This ditch discharges to the south into the
Niagara River. The flow off the western edge of the Site
eventually flows into the Niagara River or the Little Niagara
River. Flow off site to the north follows along the southern edge
of the pavement of Buffalo Avenue either in an easterly or westerly
direction until it is past the limits of the Site and then turns
south and flows to the River.
Since the ground surface is covered by a thick growth of
vegetation, and since the topography is rather flat, the present
potential for off-site transport of soil in surface water is
minimal. Historically, while the Site was still operating, erosion
of material from the Site and subsequent sedimentation in the
Niagara River probably did occur. However, the bulk of the
sediment deposition would be expected to have occurred in the area
immediately adjacent to the shoreline. This condition was
substantiated by the Sediment Survey which was part of the Remedial
Investigation (RI) report. This Survey identified the major
portion of the chemical presence in the sediment to be limited to
the shoreline vicinity. As landfilling operations continued to
expand farther south, many of the sediments historically deposited
are now under the current landfill.
In order to minimize the erosion of material from the Site, certain
preventive measures have already been taken along the shoreline.
The most significant was the construction of the bulkhead. The
placement of the bulkhead material created a buffer between the
River and the waste materials. Furthermore, the riprap placed on
the River face of the bulkhead, reduced erosion. In addition, the
Olin section of the bulkhead (toward the eastern portion of the
Site), was constructed with a filter fabric membrane behind the
riprap and a surface swale along the top of the riprap. Both of
these measures aid further in the prevention of erosion by the
River and erosion by surface-water flow off the Site.
II.- Site History and Enforcement Activities
The present OCC portion of the Site (15.6 acres) was created by the
combination of properties resulting from the merger of two firms
(Niagara Alkali in 1955 and Oldbury Electrochemical in 1956) with
Hooker Electrochemical Company (Hooker). Site ownership has been
continuous by Hooker since that time, although the company name
changed to Hooker Chemical Corporation (1958), Hooker Chemicals and
Plastics Corporation (1974), and OCC (1982).
The Olin portion of the Site (6.5 acres) was acquired by its
predecessor company, Mathieson Chemical Corporation, in 1948. Site
ownership has been continuous although the company's name vas
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changed to 01 in Mathieson Chemical Corporation in 1954 and to Olin
Corporation in 1969.
As mentioned earlier, OCC and Olin used the Site as an industrial
waste landfill from the nid-1940s until 1970. During this period,
the Companies deposited at least 159,000 tons of waste, in both
liquid and solid form, into the landfill. These deposits included
approximately 4,600 tons of benzene, chlorobenzene, chlorophenols,
and hexachlorocyclohexanes (HCCHs).
In 1973, upon the completion of the bulkhead along the shoreline,
a series of investigations began regarding subsurface conditions
at the Site. Sampling programs were also undertaken with respect
to the sediments adjacent to the Site in the Niagara River. On
December 20, 1979, a complaint pursuant to the Resource
Conservation and Recovery Act (RCRA), the Clean Water Act (CWA),
and the Rivers and Harbors Act of 1899 (RHA), was filed by the
United States of America, on behalf of the Administrator of the
EPA against the Companies in the U.S. District Court in Buffalo,
New York, seeking injunctive relief and civil penalties for an
imminent and substantial endangerment to the public health and
welfare. On November 18, 1980, a complaint pursuant to the New
York State Conservation Law and the state's common law of public
nuisance, was filed by New York State (NYS) against the Companies
in the U.S. District Court in Buffalo, New York, seeking civil
penalties. The Site was formally listed as a National Priority
List (NPL) site on September 8, 1983. The EPA and NYS, working
with the Companies, prepared a Remedial Investigation (RI) Work
Plan for the Site in 1984, for a study of the nature and extent of
the contamination. The RI was conducted by the Companies pursuant
to a Stipulation filed with the U.S. District Court on June 26,
1984. The Feasibility Study (FS) Work Plan was prepared by the EPA
and NYS. The Companies performed the FS Work Plan pursuant to a
Stipulation and Decree entered with the U.S. District Court on May
15, 1989. The Work Plan provides the guidance under which the
Companies conducted the FS. The FS report describes the
development and analyses all of the remedial alternatives for the
Site. Throughout the RI/FS process, the EPA and NYS have reviewed
all of the interim documentation and monitored the collection and
analysis of samples from the Site.
III.- Highlights ef Community Participation
The RI/FS and the Proposed Plan were released to the public for
comment on July 25, 1990. The public comment period began on July
25, 1990 and continued until August 25, 1990. The administrative
record file, containing the information upon which the selection
of the response action was based, including the RI/FS reports and
other site-related documents, was made available to the public at
the following locations:
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Michael J. Basile
U.S. EPA Public Information Office
Carborundum Center - Suite 530
345 Third Street
Niagara Falls, New York 14303
Paul J. Olivo
U.S. EPA - Region 2
Room 737
26 Federal Plaza
New York, New York 10278
Michael Podd
Love Canal Public Information Office
9820 Colvin Blvd.
Niagara Falls, New York 14304
Thomas R. Christoffel, P.E.
NYSDEC
50 Wolf Road
Albany, New York 12233
A notice regarding the availability of these documents, along with
a statement regarding the Proposed Plan, the duration of the public
comment period, and the date and location of a public meeting, was
published in two local newspapers, namely, THE BUFFALO NEWS and THE
NIAGARA GAZETTE, on July 25, 1990. The public meeting was held on
August 15, 1990, at the Red Jacket Inn located at 7001 Buffalo
Avenue in Niagara Falls, New York. At this meeting,
representatives of the EPA and the NYSDEC presented the Proposed
Plan regarding remediation of the Site, and later answered
questions and responded to comments concerning such Plan and other
details related to the RI/FS reports. Responses to the comments
and questions received at the public meeting, along with other
questions and comments received during the public comment period,
are included in the Responsiveness Summary, which is a part of this
ROD.
TT.- ?eope and Role of the Response Actions ff.lthin Site StraV:crv
The problems at the 102nd Street Landfill Site are complex. As a
result, the work was divided into three discrete segments or
operable units (OUs). Although the remedies for these three
aspects (OUs) of the Site were evaluated separately, the OUs will
be remediated concurrently where practical. Remediation of each
of these OUs is addressed in this ROD.
The OUs are defined as follows:
• OU-1: Landfill residuals including on-site fill, "off-
site" soils, shallow ground water, and non-aqueous
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phase' liquids (NAPL), (For purposes of this
document, "off-site" soils are located on the
triangular plot of land adjacent to the Site, north
of Buffalo Avenue and south of the LaSalle
Expressway, as well as on the areas immediately
adjacent to the Site to the east and to the vest.)
• OU-2: River sediments within the shallow embayment of the
Niagara River adjacent to the Site; and,
• OU-3: The storm sewer which crosses the Site and
discharges into the Niagara River.
During the compilation of the RI report, samples were collected of
ground water, on-site and off-site soils, offshore sediments, and
storm sever discharge (see Figure 2.}. These samples were analyzed
for chemical contamination. Additional sampling was conducted to
detect the presence of NAPL. The RI/FS reports supply detailed
data for a total of 69 "chemicals of concern" for the Site. No
site-related contamination was found in the bedrock aquifer. The
response actions described in this ROD will address all of the
principal threats posed by these contaminants and the present
conditions at the Site.
V.- Summary cf Site Characteristics
During the time the Site was operated as an industrial waste
landfill, from 1943 to 1970, it is estimated that approximately
159,000 tons of waste were deposited by OCC, Olin, and their
predecessors.
As part of the RI/FS monitoring program, approximately ninety-five
(95) boreholes and monitoring wells were installed and sampled.
During the RI/FS monitoring period, conducted from 1986 through
1989, hundreds of ground-water, soil, and sediment samples were
collected and analyzed. Hydrogeologic and special sampling for
the presence of non-aqueous phase liquid (NAPL) contamination was
also performed. Chemical analyses of all hazardous substances
found at the Site led to the development of a listing of the
chemicals whi"!> generated the-most concern. In all, a total of 69
"chemicals of concern" were identified and evaluated. These
chemicals include both the "site-specific indicators" (SSIs)
monitored during the RI, and the "assessment chemical monitoring
program chemicals," monitored during the FS. The SSIs are
chemicals representative of Site contamination and were selected
based on their respective prevalence at the Site, uniqueness to the
Site, stability and mobility, and reliability of analytic method.
The assessment chemicals (which include some of the SSIs) are those
Site contaminants which were considered to pose the greatest
possible threats to human health and the environment. The SSIs and
assessment chemicals, as stated above, can be found in Table 1.
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Contaminants found within the Survey Area during the RI/FS
monitoring period included heavy metals (such as mercury),
chlorinated single-ring aromatics (e.g., chlorobenzene compounds),
chlorinated phenols, hexachlorocyclohexanes (HCCHs),
polychlorinated biphenyls (PCBs), and polychlorinated dioxins and
dibenzofurans (PCDDs and PCDFs).
The principal pathway for current migration of contaminants off-
site is via ground-water discharge from the fill and alluvium zones
of the landfill into the embayment. Based on RI chemical
monitoring data and estimated ground-water discharge rates, the
total SSI organic chemical load in ground water discharging from
the Site is estimated to average approximately 1.7 to 3.5 pounds
per day. The average total organic chemical load discharging in
ground water, using general chemical analyses (not specific
chemicals) and extrapolation methods, is estimated to range from
17.2 to 34.6 pounds per day. The phosphorus load in ground water
is estimated to average between 17.1 and 34.1 pounds per day, and
the average mercury load in ground water is estimated to range from
0.0001 to 0.0003 pounds per day. Ground water seeping into the
storm sewer was analyzed for SSI contaminants, and does not appear
to carry a significant chemical load (approximately 2% of the total
organic chemical load in ground water). The storm sewer bedding
material, upon which the sewer was constructed, does not appear to
be a preferential pathway for ground-water flow.
Ground-water samples taken from the bedrock aquifer beneath the
Site did not contain SSIs. Based on this finding, and considering
the highly impermeable nature of the clay/till layer separating the
alluvium from the bedrock, shallow (overburden) ground water does
not appear to flow vertically from the Site into the bedrock
aquifer. Rather, the overburden ground water discharges laterally
into the embayment and across the Site's eastern and western
boundaries.
The EPA prepared an evaluation of the possible threats to human
health and the environment that could result if the Site were to
remain in its current condition with no cleanup. This type of
analysis is referred to as a "baseline" risk assessment, and a copy
of the evaluation can be found in the Administrative Record. Thp
EPA's risk assessment is dated May 25, 1990, and is titled
••Baseline Human Health Risk and Environmental Endangerment
Assessments for the 102nd Street Landfill," (Gradient Corporation,
1990), and is hereinafter referred to as the "Risk Assessment."
A summary of the RI/FS sampling results is provided in Table 2 for
the compounds demonstrating the largest health or environmental
risks in the EPA's risk assessment.
During the RI, NAPL was found within the fill and alluvial zones
on the Site. The Companies estimated that approximately 300,000
gallons of NAPL are on-site. None of the NAPL was found in the
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clay/till zone. NAPL is prevented from migrating into the bedrock
beneath the Site due to the presence of the clay/till confining
layer which is highly impermeable. It is not possible to reliably
estimate the rate of NAPL migration, if any, toward the River
through the fill and alluvial zones, or into the storm sewer.
Storm sewer sediment samples indicated the presence of NAPL in the
buried sediments, however the surface sediment samples were free
of NAPL suggesting that NAPL is not currently discharging into the
sewer. The remedy for the Site will address any areas of NAPL
contamination which may extend beyond the Site boundaries and will
prevent any future migration from the Sita.
Niagara River sediments within the embayment were extensively
sampled during the RI. Based on the sediment monitoring, the
extent of SSIs in the sediments is limited to an area within 300
.feet from the shore. The "clean line," which defines the extent
of SSIs above the survey level (100 ppb for organics, 200 ppb for
mercury) is shown in Figure 3. The "clean line" is considered the
extent to which site-related contamination has migrated.
Surface soils around the Site's perimeter .(tne "perimeter soils")
and surface soils north of Buffalo Avenue (the "off-site soils")
contained SSIs exceeding the survey levels. Upper-bound chemical
concentrations in the surface soil samples, on the order of several
parts per million, were summarized in Table 2 for the chemicals of
greatest health concern. Dioxin (2,3,7,8-TCDD) was detected in the
surface soils in the area immediately north of the Site's fence and
south of Buffalo Avenue, that exceeded the 1 ppb action level
recommended by the Centers for Disease Control. Interim corrective
measures, which included placing several inches of gravel over the
contaminated areas, were implemented during the RI to preclude
possible exposure at these locations.
VI.- BumTBHry of Site Risks
The EPA's Risk Assessment evaluated potential human health risks
and environmental endangerment for each aspect of the Site assuming
current conditions (i.e., no future residential/commercial uses of
the Site were considered). These aspects of the Site include:
" - (1) surface water contamination due to ground-water
discharge;
(2) surface water contamination due to storm-sewer discharge;
(3) contaminated embayment sediments; and,
(4) surface soil contamination (including airborne
particulates).
8
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Toxieitv
Cancer potency factors (CPFs) have been developed by the 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 (dose) 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 risks unlikely. CPFs are
derived from the results of human epidemiological studies or
chronic bioassays to which animal-to-human extrapolation and
uncertainty factors have been applied.
Reference doses (RfDs) have been developed by the EPA for
indicating the potential for adverse health effects from exposure
to chemicals 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 he.1.)
ensure that the RfDs will not underestimate the potential for
adverse noncarcinogenic effects to occur. Table 3 summarizes the
toxicity values for the chemicals of concern.
Human health risks posed by exposure to the chemicals of concern
from the 102nd Street Site were quantified for potential pathways
by which the local population may be exposed to Site contaminants.
Because one area adjacent to the Site is zoned "residential," and
residences currently exist near the Site, exposures to surface soil
contamination around the Site perimeter and in the off-site soils
were calculated for residential populations who potentially receive
higher exposures than do either occupational populations, or
individuals ncing the area recreationally. The major human
exposure rouXca evaluated include: -"=
• ingestion of fish from the embayment of the Niagara
River;
• chemical exposure while swimming in the embayment;
drinXing water from the Niagara River as it is withdrawn
at the Niagara Falls Drinking Water Treatment Plant; and,
• dermal contact with, ingestion of, and inhalation of dust
from off-site contaminated soils.
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Other potential exposure routes which were mentioned in the Site's
Work Plan were discussed either semiquantitatively (such as
exposure _ to eiabayoent sediments) or reviewed and concluded to be
insignificant due to the lack of current exposure pathways.
Because the shallow overburden ground water is not now used for
drinking water (and is not anticipated to be used in the future)
potential health risks associated with such use were not
considered.
Conservative but reasonable assumptions were utilized throughout
the EPA's risk assessments to evaluate "reasonable maximum
exposures" consistent with current EPA guidance. The
reasonableness of predicted chemical concentrations (predicted for
areas or media for which RI data are unavailable) used in the Risk
Assessment was verified against measured data from other (non-RI)
sources, when such information existed. Predicted surface water
concentrations in the embayment agree favorably with the small
number of pre-RI measurements of several chemicals of concern in
embayment surface water samples. Similarly, predicted contaminant
levels in fish are in general agreement with the limited available
site-specific fish data from published (non-RI) sources, typically
differing from the measured values by less than an order of
magnitude.
Both carcinogenic and noncarcinogenic human health risks were
estimated for the chemicals of concern. Based on exposures to
contaminants in the embayment of the Niagara River and to soil
contaminants off-site, total increased lifetime carcinogenic health
risk is estimated to be 2.2 x 10J, with ingestion of fish from the
embayment of the River the most important route of exposure
contributing to this risk (see Table 4). Potential exposure to
off-site soils yields an increased cancer risk of 8.1 x io5. The
carcinogens which contribute to the greatest extent to the Site's
health risks are PCBs, HCCHs, hexachlorobenzene, and 2,3,7,8-TCDD
(dioxin).
The total calculated "reasonable maximum" noncarcinogenic hazard
index (a ratio of calculated exposure compared to an "allowable"
exposure, as measured by the risk-reference dose) is estimated to
be 4.3, where 'ti^'.i 'fngestion is 'tha only exposu: pathway which
leads to the potential of significantly adverse health effects
(Table 4). The 1,2,3,4- and 1,2,4,5-tetrachlorobenzene isomers are
the chemicals with the largest hazard indices with respect to fish
consumption.
Environmental Assessment
Environmental endangerment was evaluated for aquatic organisms and
fish-eating species at the Site. No site-specific ecological data
were gathered during the RI/FS so representative sensitive species
were identified using EPA environmental risk assessment methods.
10
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The potential environmental risks were quantified by comparing
estimated environmental concentrations in the embayment with either
water quality criteria for the protection of aquatic species
(whenever available) or published aquatic toxicity factors. Using
this methodology, EPA determined that environmental endangerment
in the embayroent is probable due to a number of Site contaminants.
These chemicals, which enter the water in the embayment by way of
ground-water discharge, discharge from the storm sewer, and
chemicals emanating from the contaminated sediments, are identified
in Table 5. Chemicals of "probable" concern are those whose
embayment surface water concentrations exceed water quality
criteria or aquatic toxicity criteria by more than an order of
magnitude (factor of 10). Chemicals of "possible" concern are
those which are predicted to occur in the embayment surface water
at levels ranging from 1/10 up to 10 times relevant water quality
and aquatic toxicity criteria. A number of site-related chemicals,
including HCCHs, chlorinated benzenes, 2,3,7,8-TCDD, and Mirex, are
of probable ecological concern. The contaminated embayment
sediments pose the most significant threat to the environment.
Discussion of Uncertainties in Risk Assessment
Estimating human health risk requires many assumptions in order to
quantify potential exposure and subsequent adverse health effects.
In many instances potential exposure levels estimated for the 102nd
Street Site were extrapolated from contaminant levels measured in
different media from the medium of direct contact or exposure. For
example, surface water concentrations were estimated from ground
water (and storm sewer) chemical loads into the embayment. These
chemical loads were estimated from measured chemical concentrations
in ground water and estimated ground-water discharge rates.
Finally, the chemical concentrations in the surface water of the
embayment and the Niagara River near the Site were calculated based
on the likely dilution in the areas considered most likely to be
influenced by Site contaminants. These, and other similar
calculations, all result in uncertain predictions of possible
health risks.
The uncertainties in each step of the exposure and risk assessment
process Combine jnultiplirt'r/vr.'y in the final risk calculation.
EPA's risk assessment followed'the most recent "Risk Assessment
Guidance for Superfund" (December, 1989) recommendations for
assessing "reasonable maximum exposures" (RMEs) and risks posed by
the Site. For those pathways which yielded the highest risk
estimates (ingestion of fish and exposure to soil) sufficient
monitoring data were available to construct statistically based
RMEs and risk calculations. Monte Carlo methods (which involve
statistically based calculations) were used to calculate reasonable
maximum chemical loads from the Site and also used to calculate
reasonable maximum ingestion of possibly contaminated fish. The
possible risks due to consuming contaminated fish using these
methods were approximately 10 times higher than "average" risk
11
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estimates which did not consider uncertainties in the RI data and
exposure_calculati9ns, but the Monte Carlo risk estimates for fish
consumption were approximately 10 times lower than "worst case"
calculations which adopt overly conservative assumptions of maximum
values for all exposure estimates'. For soil exposure pathways, the
95% upper-bound chemical concentration in soil was used in the
exposure calculations, which, again, provided RME estimates which
were approximately 10 times higher than average conditions, but
also 10 times less extreme than if the maximum detected chemical
concentrations would have been used. Although rigorous statistical
analyses of the uncertainties in the risk assessment were not
performed, the above discussion indicates that, for the most
significant pathways of chemical exposure, reasonable maximum
exposures have an "uncertainty" range of approximately ± 10 (an
order of magnitude).
In conclusion, based on the results of the Risk Assessment, actual
or threatened releases of hazardous substances from the 102nd
Street Landfill Site, if not addressed by implementing the selected
remedy as contained in this ROD, may present an endangerment to the
public health, to the public welfare, or to the environment.
VII.- Description of Alternatives
OU-1 (Landfill. Off-site Soils. Ground Water, and NAPL)
The FS describes various remedies for the Site, including, as
required by CERCLA, the option of taking "no-action" and leaving
the Site as it is with a fence and existing soil cover. Following
a general screening of the many possible alternatives, a total of
15 alternatives were evaluated including the no-action alternative
(see Table 6).
The final-candidate remedies for OU-1 can be grouped into several
broad categories (the numbered categories below and in all future
discussions, correspond to the numbered alternatives in the FS).
Each of these categories consists of several alternatives for the
remediation of ground water and soils.
Accordingly, thaaa categories (for •:»U-1 .O.ternatives only) can be
defined as follows:
Alternative Remedy .
(1) Ho-Action — (leaves existing fence and soil
cover on landfill)
(2) Limited Action — Upgrade existing fence and
leave existing soil cover; includes options
that remove/remediate off-site soils and
stabilize or deposit these soils in a "secure
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cell" on-site; recover and treat ground water
with installation of a ground-water cutoff
wall.
(3) Cap Site/On-Site Waste Containment — Includes
options that incorporate soil from off-site
areas, and recover and treat ground water with
installation of a ground-water cutoff wall or
circumferential slurry wall. (Post-remedial
monitoring will be performed to determine the
effectiveness.)
(5) Excavate/Incinerate Landfill Wastes and Off-
Site Soils -- Recover and treat ground water;
installation of ground-water cutoff wall or a
circumferential slurry vail.
The most comprehensive alternatives of each of the three "action
alternative" categories involving Site cleanup are outlined below.
The FS report contains complete summaries of all 15 alternatives
for this Operable Unit. Estimated costs and implementation times
summarized here are from the FS. Since the implementation periods
for each operable unit may overlap, the overall time to complete
remedies for all OUs may be somewhat less than the implementation
times of each OU added together. It should also be noted that the
stated implementation periods include a component for the design
of the intended remedial action. In specific terms, for OU-1,
Alternatives 2A through 2E allow 18 months for design, while
Alternatives 3A through 3F allow 24 months, and Alternatives 5A,5B,
and 5C, anticipate 36 months. The implementation periods for OU-
2 and OU-3 include 12 months for remedial design.
OU-1 Alternative 2Et Existing Landfill Cover; Stabilize Perimeter
and Off-site Soils; Cutoff Wall for Ground-Water and NAPL Control
and Ground-Water Recovery
Implementation Period: 24 months
Capital Costs: $5,830,000
Operation & Maintenance: $4,820,000
Present Worth Costs: $10,700,000
t~ '
This alternative would involve excavation of all perimeter and off-
site soils (5,800 yd1) above cleanup thresholds. These soils would
then be treated so as to form cement-like materials, and thereafter
be deposited on-site. A low permeability "cutoff" vail would be
installed in the soil along the river boundary so as to control
water intrusion from the River and to retard ground-water and NAPL
migration. Actual placement of the cutoff vail (in certain
options, a circumferential slurry vail) vill be determined through
the installation of geotechnical borings along the proposed route
of the vail. These borings vill extend to the clay/till layer and
vill be used to define the extent of NAPL. The cutoff vail vill
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be constructed outside the extent of the NAPL. Ground-water
recovery wells would remove an estimated 25 gpm for treatment to
remove organic and inorganic contamination. This treated water
would then be discharged either to a City sewer or to the Niagara
River in accordance with applicable laws and regulations.
Optional, less comprehensive, variations cf this alternative
include the following. The variations' implementation period and
present-worth cost follow their respective descriptions.
2A) Excavation of only perimeter soils "hot spots" for
mercury and dioxin with permanent placement in a secure
(lined and capped) cell on-site; no other remedial
components (19 months, $1.8 million).
2B) Same as 2A for perimeter soils plus a slurry cutoff wall
along the riverbank with ground-water recovery and
treatment (23 months, $9.62 million).
2C) Same as 2B, except perimeter soils would be incinerated
rather than buried on-site (23 months, $9.51 million).
20) Excavate all perimeter and off-site soils above cleanup
thresholds with burial on-site in a secure cell (without
stabilization) and cutoff wall/ground-water recovery
identical to 2E (24 months, $9.86 million).
00-1 Alternative 3Pt Cap Landfill and Perimeter Soils; Excavate
Off-Site Soils and Bury Beneath Cap; Circumferential Wall; Ground-
Water Recovery and Treatment; NAPL Recovery and Incineration
Implementation Period: 36 months
Capital Costs: $13,200,000
Operation & Maintenance: $7,140,000
Present Worth Costs: $20,340,000
This alternative involves moving off-site soils above cleanup
thresholds to the Site, capping the entire Site (about 24 acres)
using a combined compacted soil layer with a synthetic liner, and
ground-water and NAPL controls. A 4,800 ft slurry wall completely
encircling the Site would be install.-.:i throughout the ••^•yL.Vj depth
of 10 to 35 feet to the clay/till confining layer so as to minimize
ground-water flow through the landfill soils. Ground water would
be collected (for treatment) via interceptor drainage trenches
installed below the seasonal low water table, creating inward
gradients across the wall. In order to create such inward
gradient, it is estimated that an approximate amount of 1,000,000
gallons will be extracted initially over a short time period (e.g.,
3 months). Thereafter, ground-water recovery on a steady-state
basis would total an estimated 2,500 gallons per day, a relatively
small amount because the cap and circumferential slurry wall reduce
infiltration and ground-water inflow at the Site. In addition,
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NAPL extraction wells would be placed in areas of NAPL
contamination. NAPL would be incinerated at an off-site facility,
and ground water would be treated either on-site or in one of three
off-site treatment facilities prior to discharge to a City sewer
or to the River in accordance with applicable laws and regulations.
As is the case in all instances, post-remedial monitoring will be
performed to determine the effectiveness of the remedial action.
Optional less comprehensive variations on Alternative 3 include:
3A) Excavation of perimeter soils above cleanup thresholds
and burial beneath a newly constructed Site cap; no other
remedial activities (30 months, $9.55 million).
3B) Same as 3A plus a cutoff wall along the River boundary
with ground-water/NAPL recovery wells (34 months, $17.6
million).
3C) Same as 3B except the cutoff wall would become a
circumferential wall and ground-water extraction would be
via shallow drainage trenches; no remediation of off-
site soil (36 months, $16.6 million).
3D) Same as 3C plus removal of all off-site soils above
cleanup thresholds and burial on-site (36 months, $16.7
million).
3E) Same as 3B (i.e., cutoff rather than circumferential
wall) with removal and on-site burial of off-site soils
above cleanup thresholds (34 months, $21.3 million).
OD-1 Alternative 5Ct Excavate NAPL areas. Off-site and Perimeter
Soils with On-5ite Incineration and Capping of Landfill; Ground-
Water Recovery and Treatment
Implementation Period: 156 - 180 months (13 - 15 years)
Capital Costs: $288,000,000 to $448,000,000
Operation & Maintenance: $8,000,000
Present Worth Cost: $296,000,000 to $456,000,000
This alternative would involve excavation of approximately 7.9
acres of NAPL-contaminated soils to the interface of the alluvium
with the clay/till layer, a depth of as much as 35 feet in some
areas. Prior to excavation, a circumferential slurry wall would
be constructed. The enclosed area will approximate 24 acres. The
excavation would yield an estimated 406,000 yd1 of material, which
would be incinerated on-site. Negligible volume reduction is
likely to occur upon incineration, since the volume of the organic
compounds, which are destroyed by incineration; is small compared
to the volume of the solid material. Thus, approximately 406,000
yd1 of ash would remain after incineration, which would either be
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buried on-site or disposed of in an off-site landfill. After
excavation, a cap would be installed over the entire Site. Ground
water would be recovered using an interceptor drain, and treated.
Ground-water treatment and discharge would be performed as
described for the other remedial alternatives, listed above.
Two variations of this alternative were also considered:
5B) This Alternative requires less extensive excavation and
incineration than Alternatives 5C. Excavation would be
limited to NAPL-contaminated soil above the water table,
a depth of approximately 10 feet, yielding an estimated
127,500 yd1 of excavated material to be incinerated on-
site. As before, negligible volume reduction is likely
to occur upon incineration, so approximately 127,500 yd
of ash would remain after incineration, which would be
buried on-site or disposed of in an off-site landfill.
Because NAPL in the soil below the water table would not
be excavated, attempts would also be made to collect this
NAPL after excavation by selectively installing NAPL
extraction wells. Any NAPL so recovered would be
incinerated on-site. All other aspects of this
alternative are as in 5C (156 months, $80.4 to $148
million).
5A) This Alternative is identical to 5B except that selective
NAPL extraction/incineration would not be attempted (108
months, $77.1 to $144 million).
OU - 2; River Sediments
The final-candidate remedial alternatives for OU-2 are summarized
in Table 7, and described briefly below.
OU-2 Alternative 2At Dredoe/Dewater Sediment Areas with Elevated
Concentrations. Spread On-site and Can
Implementation Periods
Capital Costs:
^n^r^tion & Maintenance:
Present Worth Costa:
15 months
$1,390,000 to $2,310,000
$420,000
*~,300,GOO to $2,730,000
Two areas just offshore from the Site, one near the sewer outfall
and the other near the Griffon Park boundary, would be dredged.
These are the most contaminated sediment areas in the embayment.
Prior to dredging, a berm would be constructed outside of the
contaminated area to prevent the downstream transport of sediment.
The estimated 4,600 yd1 of sediment would be dewatered using a
filter press and spread upon the surface of the Site prior to its
capping as part of OU-1-3 options.
One variation of this alternative was considered in depth:
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2C) Alternative 2C would involve incineration rather than
landfiiiing of the dredged sediments from the two areas
which contain elevated concentrations of contaminants
("hot spots") (16+ months, $3.66 to $4.48 million).
OU-2 Alternative 4t Dredge All Site-Contaminated Sediments:
Devater; Extend Cap Over Dewatered Sediment^
Implementation Period:
Capital Costs:
Operation & Maintenance:
Present Worth Costs:
20 months
$4,620,000 to $6,180,000
(No 0 & M Costs)
$4,620,000 to $6,180,000
All sediments between the shore and the point farthest offshore
which exceed cleanup thresholds (this point or line is known as
the "clean line11} would be dredged to a depth estimated at 2'ft.
Cleanup thresholds are defined as SSI concentrations above survey
levels as shown by the "clean line" depicted in Figure 3. These
sediments, estimated to be 15,000 yd1, would then be filled (behind
a newly constructed berm) into the marshy lowland area between the
Site and the River which would provide a settling/dewatering basin.
The entire area to be dredged would be separated from the River by
the construction of a second berm (beyond the clean line) which
would prevent downstream transport of dredged sediment. After ?.
sediment settling period, excess water from the settling basin
would be removed for treatment (4.5 million gallons) and then an
additional 8,500 yd1 of fill would be added to the settling basi~
and the area which would be capped (1.8 acres) in conjunction with
OU-1. This alternative anticipates more cap coverage than
Alternative 6A, hence the increased cost figures and implementation
times.
OU-2 Alternative 6At Dredge All Site-Contaminated Sediments,,
Dewater and Burv Sediments On-site Beneath Cap
Implementation Period:
Capital Costs:
Operation & Maintenance:
Present Worth Costs:
18 months
$3,600,000 to $5,570,000
(NO 0 4 M Costs)
$3,600,000 to $5,570,000
This alternative would involve dredging the same sediment area as
in Alternative 4, with the exception that once dewatered (as
accomplished in Alternative 4), the sediments and temporary berm
would be re-excavated and buried on-site beneath the cap
(Alternative 4 extends landfill cap over the settling basin). The
temporary berm would be constructed parallel to the shore and
dredged sediments would be stored between this berm and the
existing shoreline bulkhead for dewatering. Following dewatering,
all contaminated sediments and the benn, totalling approximately
28,000 yd1, would be buried on-site beneath, the cap installed as
part of OU-1.
1?
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One variation of this alternative which was considered:
6C) Alternative OU-2-6C, would involve incineration of the
dredged sediments. The berm material would not be
incinerated (27+ months, $11.8 to $13.2 million).
OP - 3; Storm 8ev«r
The final-candidate remedial alternatives for the storm sewer are
summarized in Table 8 and described briefly below.
OU-3 Alternative 2\i Install HOPE Slipliner in Sewer
Implementation Period: 15 months
Capital Costs: $535,000
Operation & Maintenance: $69,600
Present Worth Costs: $605,000
The existing sewer pipe would be cleaned and left in place but
lined with a chemically resistant sleeve made of high density
polyethylene (HOPE) plastic. The annular space between the
original pipe and the sleeve would be pressure-grouted. This would
prevent ground water and NAPL from infiltrating the conduit or the
annulus, thereby eliminating enhanced transport of contaminants to
the River via this pathway.
One variation of this alternative was considered:
2B) Alternative OU-3-2B would use "insitufonn," an inversion
lining method which employs a thermosetting polyester
resin to line the sewer pipe (14 months, $718,000).
OU-3 Alternative 3 (A t Bit Bypass Site with a Lift Well and Force
Main
Implementation Period: 19 - 20 months
Capital Costs: $1,830,000/$3,980,000
Operation & Maintenance: $1,160,000/$970,000
Present Worth Costs: $2,990,000/$4,950,000
The existing sewer on-site would be abandoned and a 36-inch
diameter pressurized pipe and pumping station would be installed.
The new sewer would bypass the Site and be capable of handling 20
MGD (million gallons per day) flow. The abandoned sewer would
either be plugged (Option A) or removed (Option B).
VIII.- S'"n™ary of Comparative Analysis of Alternatives
In accordance with CERCLA, a detailed analysis of each alternative
is required. The purpose of the detailed analysis is to
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objectively assess the alternatives with respect to nine evaluation
criteria that encompass statutory requirements and include other
gauges of the overall feasibility and acceptability of remedial
alternatives. This analysis is comprised of an individual
assessment of the alternatives against each criterion and a
comparative analysis designed to determine the relative performance
of the alternatives and identify major trade-offs, that is,
relative advantages and disadvantages, among them.
The nine evaluation criteria against which the alternatives are
evaluated are as follows:
Threshold Criteria - The first two criteria roust be satisfied in
order for an alternative to be eligible for selection.
1. Overall Protection of Human Health and the Environment
addresses whether a remedy provides adequate protection
and describes how risks posed through each pathway are
eliminated, reduced, or controlled through treatment,
engineering controls, or institutional controls.
2. Compliance vith Applicable, or Relevant and Appropriate
Requirements (ARARs) is used to determine whether each
alternative will meet all of its federal and state ARARs.
When an ARAR is not met, the detailed analysis should
discuss whether one of the six statutory waivers is
appropriate.
Primary Balancing Criteria - The next five "primary balancing
criteria" are to be used to weigh major trade-offs among the
different hazardous waste management strategies.
3. Long-term Effectiveness and Permanence focuses on any
residual risk remaining at the Site after the completion
of the remedial action. This analysis includes
consideration of the degree of threat posed by the
hazardous substances remaining at the Site and the
adequacy of any controls (for example, engineering and
institutional) used to manage the hazardous substances
remaining at the Site.
4. Reduction of Toxicity, Mobility, or Volume Through
Treatment is the anticipated performance of the treatment
technologies a particular remedy may employ.
5. Short-term Effectiveness addresses the period of time
needed to achieve protection and any.adverse impacts on
human health and the environment that nay be posed during
the construction and implementation period, until cleanup
goals are achieved.
6. Implementability addresses the technical and
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administrative feasibility of implementing an alternative
and the availability of various services and materials
required during its implementation.
7. Cost includes estimated capital, and operation and
maintenance costs, both translated to a present-worth
basis. The detailed analysis evaluates and compares the
cost of the respective alternatives, but draws no
conclusions as to the cost-effectiveness of the
alternatives. Cost-effectiveness is determined in the
remedy selection phase, when cost is considered along
with the other balancing criteria.
Modifying Criteria - The final two criteria are regarded as
"modifying criteria," and are to be taken into account after the
above criteria have been evaluated. They are generally to be
focused upon after public comment is received.
8. State Acceptance indicates whether based on its review of
the RI/FS and the Proposed Plan, the state concurs with
the selected remedy.
9. Community Acceptance refers to the community's comments
on the remedial alternatives under consideration, along
with the Proposed Plan. Comments received during the
public comment period, and the EPA's responses to those
comments, are summarized in the Responsiveness Summary
which is a part of this ROD.
At this point, it may be convenient to summarize the selected
remedy so as to facilitate the analysis of the alternatives which
also follows. Accordingly, the selected remedy consists of these
components:
OU-1- Alternative 37: Cap Landfill and Perimeter Soils;
Excavate Off-Site Soils and Bury Beneath Cap; Install
Circumferential Slurry Wall; Recover and Treat Ground Water;
Recover and Incinerate NAPL.
OU-2- Alternative 6A as modified by Alternative 2C: Dredge
Sediments From Two Areas Which ro;-.c.a5n Elevated Concentrations
Of Contaminants, and Incinerate These Sediments (2C). Dredge
All Remaining Site-Contaminated Sediments, Dewater and Bury
Sediments On-site Beneath Cap (6A).
OD-3- Alternative 2A: Install Plastic (HDPE) Slipliner in
Storm Sewer which crosses the Site.
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Analysis of
Overall Protection of Human Health and the Environment
With the exception of the no-action alternatives, all alternatives
would provide some protection of human health and the environment.
Because risks from off-site soil exposure and consumption of fish
from the Niagara River pose the largest risks, the alternatives
which deal with these exposure pathways most effectively, will be
the most desirable.
Protection for Soil Exposure Pathways (OU-1)
Alternatives 2A,2B,2C for OU-1 do not remediate the off-site
contaminated soils north of Buffalo Avenue, hence these options do
not adequately protect human health or the environment from the
effects of Site contaminants. The other two alternatives
considered for Alternative 2 (20 and 2E) , would provide adequate
health and environmental protection by either isolating the
contaminants in a secure cell (2D) or stabilizing them (2E).
However, none of the Alternative 2 options provides adequate
protection from contaminants on the Site, since remediation of the
on-site area is limited to an improved fence surrounding the Site.
As in the above case, Alternatives 3A,3B,3C for OU-1 do not
remediate contaminated off-site soils and, hence, do not provide
adequate human and environmental protection. The remaining
variations of Alternative 3 (3D,3E,3F) would address off-site and
perimeter soils by excavating off-site soils and reburying the off-
site soils beneath a cap over the Site (the cap would cover the
perimeter soils) , a sufficient technology to provide overall
protection given the contaminant levels and exposure pathways.
Since the entire Site receives a cap (with a synthetic liner), this
alternative provides greater overall protection than Alternative
2, by removing all soils above cleanup thresholds outside the
landfill boundaries, with on-site burial accompanied by a new cap
over the landfill.
Soil incineration (Alternative 5 for OU-1) provides protection of
greater permanence because contaminants are excavated from the Site
and destroyed by incineration. Howevar, vith adecjuate
implementation and monitoring of the selected option (OU-1-3F) , the
contaminants will be effectively isolated from future human and
environmental exposure such that the increased permanence provided
by Alternative 5 nay only result in a slight increase in
protectiveness. Furthermore, as discussed later, the increased
long-term protection provided by Alternative 5 is accompanied by
short-term risks associated with excavation/ incineration, the
technical difficulties involved in the construction of the
circumferential slurry wall and in the prevention of the inflow of
River water into the excavated area, and ouch higher costs than
those of Alternative 3F.
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Protection for Niagara River Exposure Pathways
Protection of the Niagara River and associated exposure pathways
requires action to control contaminant exposure/migration from all
three Operable Units.
OU-1. Migration of contaminants in ground water from the landfill
(OU-1) is the primary concern for Niagara River exposure scenarios
for this OU. Health risks will be directly influenced by reducing
the potential for bioaccumulation in fish caused by discharge of
contaminated ground water from the Site into the Niagara River
embayment. Alternative 3 combines a cap over the landfill (which
reduces infiltration and subsequent ground-water discharge) with
more extensive ground-water recovery and treatment options, than
Alternative 2. In addition, various options under Alternative 3
(3B,3C,3D,3E,3F) provide varying degrees of NAPL control and
remediation.
Therefore, Alternative 3 provides greater health protection than
Alternative 2. Alternative 5 controls ground-water migration using
the same remedial actions as Alternative 2, but offers increased
protection by also removing and incinerating the "NAPL areas," thus
greatly reducing the source of contaminants migrating in ground
water.
OD-2. Dredging of contaminated sediments (OU-2-6A) will be
required to reduce risks to aquatic biota as veil as to reduce
contaminant bioaccumulation in edible fish. Dredging and
incinerating "hot spots" (OU-2-2C) will provide permanent
protection from these highly contaminated sediments. Since health-
based or risk-based sediment remediation criteria have not been
established, these combined alternatives (6A and 2C) which have
the net effect of excavating all sediments that have migrated to
the "clean line," incinerating those sediments from the areas of
elevated concentrations, and burying the remaining sediments
beneath the cap, were selected as the most reasonable action-
alternatives designed to ensure the maximum overall human and
environmental protection.
00-3. Remediation of the storm sewer (OU-3) will eliminate the
contaminant loadings to the River attributable to the sewer. With
adequate installation, monitoring and maintenance, Alternative 2
(the selected alternative) should provide adequate protection of
human health and the environment. Alternative 3, which replaces
the existing sewer and re-routes another sever line around the
Site, would provide even greater protection. Because the chemical
loads in the sewer are less significant than other sources of the
Site's contamination, the somewhat greater protection afforded by
Alternative 3, is outweighed by the greater technical difficulties
and increased costs associated vith this alternative.
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Compliance With ARARs
Tables 9 through 11 summarize the ARARs and "To-be-Considered"
guidelines (TBCs) identified for the Site. Each of the remedial
alternatives was evaluated for compliance with ARARs and TBCs.
OU-1. Ground water located in the landfill soils at the Site is
classified by EPA as Class IIB and by NYSDEC as Class GA (potential
source of drinking water), although it is not a source of drinking
water. The Safe Drinking Water Act Maximum Contaminant Levels
(MCLs) and NYSDEC Quality Standards for Groundwaters are chemical-
specific ARARs for the ground water on-site. Although RCRA
Groundwater Concentration Limits (RCRA limits), which are also
ARARs for ground water, exist for 4 of the chemicals of concern,
Lindane (4 ppb), mercury (2 ppb), arsenic (50 ppb), and cadmium (10
ppb), these limitations are identical to the previously mentioned
MCLs.
Ground water in the landfill soils discharges into the Niagara
River and across the western and eastern boundaries of the Site.
As stated in the NCP, when wastes are left in place, the "point of
compliance" lies at that point beyond the areal limit of the
contained wastes where ground water discharges. In the case of the
102nd Street Site, the point of compliance for ground water is the
enbayment of the Niagara River (just outside the planned location
of the slurry wall), the ground water outside the slurry wall in
Griffon Park (to the west), and the ground water outside the slurry
wall to tne east of the Site within the area bounded by the
drainage ditch. Relevant ARARs for ground water discharging into
the embayment are the Clean Hater Act ambient water quality
criteria (AWQC) and the New York State ambient water quality
standards (AWQS). Chemical-specific ARARs for ground water
discharging to the vest and to the east of the Site include MCLs
and NYS Ground-water Standards. Any remedial alternative selected
must be one which reduces the quantity of ground-water discharge,
and/or improves its quality to reduce surface-water contaminant
concentrations in the embayment, and to reduce ground-water
contaminant concentrations to the vest and east of the Site; all
of which vould be done to meet ARARs.
Alternatives 2A and 3A, which do not includa tihe installation of
a circumferential slurry vail, and vhich do not remediate ground
water, will not comply with ARARs at the point of compliance.
Furthermore, alternatives which do not accomplish any NAPL removal
(2A,2B,2C,2D,2£ and 3A,3B), and do not enclose the landfill with
a slurry wall, thus leaving NAPL as a significant source for
ground-water contamination, are unlikely to achieve ARARs at the
point of compliance. Only Alternative 5C (the comprehensive
incineration option) will remove all NAPL at the Site.
Alternatives 3F,5A,5B, and 5C, which provide for some NAPL removal,
and which include either a cutoff wall or a circumferential slurry
wall, will achieve ground-water ARARs at the point-of-compliance.
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It should be noted that although the recovery of ground water does
include a treatment component, the primary function of ground-
water recovery is to create and maintain an inward gradient across
the slurry wall. Since much of the NAPL occurs in the soil beneath
the fill (the alluvium), Alternatives 5A and 5B, which require only
excavation and incineration of the fill material, but not the
alluvium, would not necessarily provide significantly accelerated
compliance with ARARs, but would provide more permanent solutions
due to incineration, than does Alternative 3F.
The EPA's Risk Assessment, using embayment water concentrations
derived from ground-water chemical discharge and embayaent
dilution, determined that several compounds currently exceed the
AWQC or AWQS. Surface water ARARs will be achieved by those OU-
1 alternatives which limit future discharge of contaminated ground
water into the River. Alternatives 2A and 3A, which do not
restrict ground-water discharge to the River, will not comply with
ARARs. The action alternatives employing a cutoff wall
(2B,2C,2D,2E;3B;5A,5B) and those employing a circumferential slurry
wall (3C,3D,3E,3F;5C) should effectively limit ground-water
discharge to the embayment, and thereby meet ARARs. A
circumferential slurry wall provides the most complete ground-
water control and greatest assurance of meeting the ARARs
associated with the embayment.
No ARARs are established for contaminated soils, although the
Centers for Disease Control has established a guidance value of 1
yg/kg (ppb) for dioxin in residential soils. Since the Risk
•Assessment indicates significant health risks are associated with
soil exposure, all perimeter and off-site soils above cleanup
thresholds will be remediated (including dioxin contaminated soils
south of Buffalo Avenue).
Land Disposal Restrictions (LDRs) preclude the placement of
restricted RCRA hazardous wastes into a land disposal unit. The
off-site and perimeter soils, and the embayment sediments are a
restricted RCRA hazardous waste, in part because they contain
dioxin. If consolidating these soils and sediments on the landfill
constitutes placement into a land disposal unit, then such remedial
actions would fail to satisfy the LDRs. According to EPA's
Superfund LDR Guide 35 (OSWZR Directive 9347.3-05FS, July 1989),
"Placement does not occur when wastes are ... moved within a single
AOC [area of contamination]." An AOC is "the areal extent of
contiguous contamination," such as a "landfill ... and the
surrounding contaminated soil. Such contamination must be
continuous, but may contain varying types and concentrations of
hazardous substances." The perimeter soils and embayment sediments
are contiguous and continuous with the contamination at the
landfill. The contamination north of Buffalo Avenue is considered
contiguous with the contamination surrounding the Site boundaries
(even though these areas are separated by the road) because
continuous contamination was found between the Site fence and the
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south side of Buffalo Avenue, as well as on the northern edge of
Buffalo Avenue. Thus, the contamination north of Buffalo Avenue
is continuous and contiguous. Therefore, LDRs are not applicable
to the placement of the perimeter and off-site soils, and the
embayiDent sediments on the landfill beneath the cap, and
accordingly are not ARARs.
OU-2. No promulgated federal or state ARARs exist for contaminated
sediment, however New York State does have "To-Be-Considered"
guidelines (TBCs) for sediment which require aqueous contaminant
levels in the water surrounding the sediment ("interstitial" water)
to meet ambient water quality criteria (AWQC) and state ambient
water quality standards (AWQS). Alternative OU-2-2C, which
incinerates the sediment "hot spots," will achieve these TBCs, as
well as providing permanent protection from these areas of elevated
contaminant concentrations. Alternatives 4 and 6 would achieve the
compliance with the sediment TBCs since all site-related sediment
contamination would be dredged from the embayment.
Dredging activities for all alternatives would be conducted in
compliance with ARARs for excavation in a 100-year floodplain,
wetlands, and construction of bulkheads in navigable waters.
OD-3. Ground-water infiltration into the sewer and subsequent
discharge to the embaynent must meet surface water AWQC. All
action alternatives should effectively eliminate future discharge
of the Site's contaminants a.id thereby meet these criteria.
Long-Term Effectiveness and Fermanenc*
OU-1. Alternative 5C and to a lesser extent Alternatives 5A and
5B, which entail the most removal/destruction of the Site's
contaminants, provide the greatest long-term effectiveness. The
alternatives aimed at NAPL and ground-water recovery/treatment (3E
and 3F) or ground-water recovery/treatment (2B,2C,20,2E) and
(3B,3C,3D,3E,3F) also offer degrees of permanent destruction of the
most mobile contaminants over the long term. However, these
remedies are not "permanent" because long-term monitoring of
treatment processes and effective maintenance of the remedy must
be achieved to ensure long-term effectiveness for these Alternative
2 and w remedial options. All of these alternatives will have
similar, positive long-term impacts on the Niagara River.
OU-2. Remediation Alternative 6C, which removes all site-related
contaminated River sediments to the "clean line" and destroys
contaminants by incineration, provides the most permanent overall
remedial option. Alternative 2C which removes and incinerates the
sediments from the two "hot spots," will likewise provide the
highest degree of permanence for these specific areas.
Alternatives 4 and 6A also dredge sediments to the "clean line,"
but do not incinerate the sediment; rather these two alternatives
call for depositing sediments on the Site (the difference between
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them is in the specifics of where the sediments are backfilled) .
Because of the low mobility of the primary contaminants of concern
in the sediments, with continued monitoring, their excavation and
reburial on-site should provide adequate long-term effectiveness.
Alternative 2A would provide less long-term effectiveness and
permanence because it addresses only two sediment "hot spots" in
terms of dredging those sediments and placing them beneath the cap.
Although not offering the same degree of permanence, the long-term
effectiveness of Alternatives 4 and 6A may be indistinguishable
from 6C. This presumes that the site-containment remedial
components will be maintained effectively.
OU-3. Alternative 3B would be the most permanent solution because
it would replace the existing sewer with a new one which bypasses
the Site. Plugging the existing sewer and adding a bypass
(Alternative 3A) or lining the existing sewer to prevent
infiltration (Alternative 2) would be less permanent than
Alternative 3A, but would provide essentially the same long-term
effectiveness with continued maintenance and periodic replacement
of the plug or sewer lining. Without proper inspection and
maintenance, plugging or lining the sewer offers less long-term
effectiveness than does excavating and rerouting it around the
Site.
Reduction of Toxicity, Mobility or Volume of Contaminants
With the exception of the no-acti'n alternatives, all of the
alternatives reduce the toxicity, mobility and/or volume of the
Site's contaminants. Many of the final alternatives considered for
the Site focus on reducing contaminant mobility (which effectively
isolates contaminants from future human/environmental exposure
risks) as the primary remediation method; to varying degrees, the
remedies reduce contaminant toxicity or volume for targeted areas
or media.
OU-l. Alternative 2, which upgrades the fence around the Site and
provides some remediation of off-site soil and ground water beneath
the Site, has the least impact on toxicity, mobility or volume of
Site contamination. Placement of off-site soils in a secure cell
(2D) or stabilization (2E) reduces contaminant nobility, but does
not reduce thei. toxicity or volume (stabilization methods actually
increase the volume of disposed solids). Ground-water recovery and
treatment (2B-2E) will reduce the toxicity and volume of
contaminants over very long time periods. Alternative 3 reduces
contaminant nobility and volume to a greater extent than
Alternative 2 since the cap reduces infiltration (thereby reducing
ground-water recharge, while also reducing chemical mobility and
volume). Alternative 3 also reduces the toxicity and volume of
ground-water contaminants through recovery and treatment. The most
comprehensive options of this alternative (3E,3F), which call for
selective NAPL removal and incineration, reduce contaminant volume
and toxicity to the greatest extent of alternative 3 options.
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Finally, Alternative 5, which calls for excavation and incineration
of the NAPL areas (5A,5B,5C), provides the greatest contaminant
removal/destruction. However, a large volume of ash must be
disposed of for this alternative.
OU-2. With the exception of Alternative 6C, which involves removal
and incineration of all contaminated sediments to the "clean line,"
and Alternative 2C, which incinerates the sediments from the "hot
spots" only, all action alternatives for OU-2 reduce the mobility
and toxicity of contaminants by removing them from the River.
Alternatives 6C and 2C provide essentially complete destruction of
organic contaminants, but, as above, these options can require
disposing of a substantial volume of ash. Alternative 2A, which
only remediates the two "hot spots" in terms of removal and
placement of sediment beneath the cap, reduces contaminant mobility
less than Alternatives 4 and 6A, which dredge all site-related
contaminated sediments out to the "clean line."
00-3. All action alternatives of OU-3 will reduce contaminant
mobility by preventing transport via the storm sewer; none of them
reduce contaminant toxicity or volume. With careful installation,
maintenance, and monitoring, Alternative 2, which involves lining
the sewer, should provide results comparable to Alternative 3,
which completely reroutes the sewer.
Short-Term Effectiveness
Alternatives involving incineration (Alternatives OU-1-5, OU-2-
2C, and OU-2-6C) would be the least effective over the short term
due to delays anticipated with getting a incinerator available, and
due to the potential health risks associated with the excavation
and incineration process. It is estimated that an incinerator
trial burn would require 2 years during which remedial activities
at the Site would be inhibited. Excavation and incineration
activities can pose health risks to the nearby residents due to
exposure to fugitive dust generated during excavation, and
potential emissions from the incinerator. However, both fugitive
dust and incinerator emissions can be and would be controlled such
that the short-term health risks are either minimized or
eliminated. As discussed below with respect to the
11 imp .lament ability" critrrvm, excavation may have its effectivensss
limited and worker safety threatened due to the presence of
phosphorus waste at the Site.
Dredging activities associated with the OU-2 alternatives could
have short-term negative impacts on the Niagara River. The
construction of berms (to contain dredged sediment) in all action
alternatives would temporarily increase sediment loads to the
River, and some of this sediment transported in the River may be
contaminated. However, since the berms in question will clearly
be located outside the area of contamination, it is highly unlikely
that any contaminated sediments will be released into the River.
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As discussed below with respect to the "impleraentability"
criterion, Alternative OU-1-5C could result in serious
environmental damage or threats to worker safety from potential
slurry wall failure.
Alternatives involving excavation of off-site/perimeter soils, the
storm sewer, or trenches for the installation of slurry walls or
drains, will all involve some short-term health risks to workers
and/or nearby residents due to fugitive dust and vapor emissions.
Workers would be required to wear protective clothing in order to
minimize potential health risks. All activities requiring
excavation of soils along Buffalo Avenue would create short-term
concerns of disrupting local utilities. Excavation would be
performed in such a way and under such conditions as to minimize
risks to nearby residents.
Many of the remediation activities are likely to involve excavating
areas containing NAPL (e.g., during slurry wall construction,
removing sediments in the storm sewer, and excavating embayment
sediments). Although possible worker exposure to NAPL on the Site
during excavation will be a concern, standard health and safety
measures will be instituted to protect the workers' welfare.
Implementability
In general, remediation alternatives for the Site involve
technologies and methods which have been used at other hazardous
waste sites and should not lead to unusual difficultie' at 102nd
Street. However, some difficulties may arise requiring
contingencies. Potential problem areas for each OU are summarized
below.
00-1. Almost all of the action alternatives require construction
of a slurry wall (either a cutoff wall or a circumferential wall),
keyed into the clay/till layer beneath the Site. The slurry wall
will restrict ground-water migration from the Site. This remedy
may encounter difficulties if the clay/till layer is non-contiguous
or varies greatly in depth below ground surface across the Site.
Areas traversed by the slurry wall which are highly contaminated,
would require precautions to protect worker health and safety. In
addition, the compatibility of the slurry vail with densely
cn-'orinatec1. ornanics found in NA?Lf Must be determined in order to
ensure that NAPL will not reduce the slurry wall's effectiveness.
Furthermore, since NAPL may extend to an unknown extent beneath the
embayment area, and since the primary function of the slurry vail
will be to contain the NAPL plume, the planned location of the
slurry vail may need to be adjusted after data from geotechnical
borings give the precise dimensions of the NAPL plume.
The excavation/incineration alternatives (5A,5B,5C) pose the most
significant implementation difficulties. In addition to the short-
term effectiveness and health risks mentioned previously, other
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Site conditions must be considered. The RI report indicates that
several locations on the Site received drummed wastes containing
elemental phosphorus. Elemental white phosphorus combusts when
exposed to the atmosphere. Although the phosphorus disposal areas
generally do not coincide with the NAPL-contaminated areas to be
excavated, the possibility of inadvertently exhuming phosphorus
during excavation poses technical difficulties and potentially
threatens worker safety. One area of suspected phosphorus
disposal, near the OCC and Olin property boundary, is very close
to the NAPL contamination area. If this precludes excavation in
this area, the overall effectiveness of Alternative 5 will be
reduced.
Additional implementation difficulties exist for Alternative 5C,
which involves excavation of the saturated fill and soil in the
NAPL-contaminated areas. Excavation in the saturated zone would
require dewatering of the Site, which will be made more difficult
by the proximity of the Niagara River. Large hydraulic gradients
would exist between the dewatered area of the Site and the Niagara
River, and also between the dewatered excavation trench and the
bedrock beneath it. Failure of the slurry wall and/or the
clay/till confining layer during excavation could result in a
serious release of contamination to the environment and potentially
threaten worker safety.
OU-2. All of the action alternatives for embayment sediments pose
some technical problems due to the need to implement sedimer'.
control measures, dewater sediments, and treat the water removed
from the sediment. Alternative 2A, which only dredges "hot spots,"
poses the fewest implementation difficulties since much less
sediment is removed than in Alternatives 4 and 6. There is little
difference in implementation requirements for Alternatives 4 and
6A, both of which excavate similar sediment areas and volumes.
Options 2C and 6C (sediment incineration) may have implementation
difficulties similar to those for the OU-1 incineration options.
OU-3. The storm sewer remediation alternatives requiring
installation of a lining will require a blocking of the sewer
during remediation activities and cleaning the sewer of sediments
and other obstructions such as protruding stalactites. These
activities, which are straightforward, ca:. ::_ accomplished without
significant difficulties and will require blocking the sewer for
a relatively short period of time. As described previously, the
Companies found NAPL in the sewer sediments, and this fact will
require special attention to protect the health of workers during
the cleaning process and will also require measures to temporarily
store the NAPL contaminated sediments before they are incinerated
(off-site). Sewer remediation activities should be scheduled
during a dry, "low flow" period to minimize any sewer flow which
must be temporarily diverted and discharged to the River.
The HDPE slipliner (Alternative 2A), poses fewer difficulties than
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installing an "insituform" thermosetting resin liner (2B).
Alternative 2A also poses significantly fewer technical
difficulties than plugging (3A) or excavating (3B) the existing
sewer and rerouting a new sewer line around the Site. Rerouting
the sewer would require as long as 8 months to complete, thereby
requiring a more elaborate sewer bypass system than 2A which is
projected to take 3 months to implement. In addition, Alternative
3 requires installation and long-term maintenance of a punping
station, since the rerouted sewer would no longer be a "gravity"
sewer.
Cost
Cost estimates for remediation, as shown in Table 6, range from
$1.3 million to $456 million for OU-1, with costs for most OU-1
alternatives falling in the $9 to $21 million range. Costs for OU-
2 alternatives range from $0.4 million to $13.2 million, with most
in the $2 to $5 million range. For OU-3, estimated costs range
from $0 to $4.95 million, with most alternatives in the $2 to $5
million range.
Cost effectiveness is an important issue in balancing the
evaluation criteria used in the selection of the final remedy. For
example, the incineration alternative for OU-1 (Alternative 5C) is
nearly 20 times greater in cost than the next most expensive
alternative (Alternative OU-1-3F). The comprehensive incineration
alternative for sediments (OU-2-6C) would cost more than twice as
much as Alternative OU-2-6A which requires the excavation and
disposal of sediments beneath the landfill cap. Incineration
alternatives do however, provide remedies of greater permanence and
greater reduction of the volume, tpxicity, and mobility of the
Site's contaminants than do alternatives which contain and isolate
contamination, but such incineration options do not necessarily
provide greater protection of human health and the environment.
State Acceptance
The State of New York supports and concurs with the selected remedy
as presented in this document.
Community Acceptance
i
Community acceptance of the selected remedy was evaluated after the
public comment period had ended. Comments raised at the public
meeting and during the public comment period, as veil as detailed
responses to community concerns, are summarized in the
Responsiveness Summary which is a part of this ROD.
IX.- The Selected Remedy
After careful consideration of all reasonable alternatives, as well
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as a detailed evaluation of all comments submitted by interested
parties during the public comment period, the EPA has selected the
rer.edy defined by the following alternatives for each Operable
Unit:
Landfill fOU-ll - Alternative 37:
• A synthetic-lined cap, constructed in accordance with
federal and state standards, will be installed over the
landfill and perimeter soils.
All "off-site" soils above cleanup thresholds will be
consolidated beneath the cap. "Off-site" soils are
located on the triangular plot of land adjacent to the
Site, north of Buffalo Avenue and south of the LaSalle
Expressway, as well as on the areas immediately adjacent
to the Site to the east and to the west.
A slurry wall, completely surrounding the Site's
perimeter, will be constructed and keyed into the
underlying clay/till geologic formation. The precise
location of the slurry wall will be established through
the use of geotechnical borings which will determine the
extent of the NAPL plume. The NAPL plume is to be
contained by the slurry wall.
• Ground water will be recovered using an interception
drain installed at the seasonal low-water table in the
fill. Recovered ground water will be treated. Although
the recovery of ground water does include a treatment
component, the primary function of ground-water recovery
in general, is to create and maintain an inward gradient
across the slurry wall.
• NAPL beneath the Site will be recovered using dedicated
extraction wells and will be incinerated at an off-site
facility.
• A 6-foot high chain-link fence will be installed around
the perimeter of the cap in order to restrict access to
.he site.
• Institutional controls in the form of deed restrictions,
or similar restrictions, on future uses of the landfill,
will be established.
Niagara River Sediments fOU-2) - Alternative 6X Xs Modified Bv
Alternative 2C;
• River sediments will be dredged from the two areas which
contain elevated concentrations of contaminants ("hot
spots") (2C).
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These dredged sediments will be incinerated (2C).
The remaining sediments will be dredged from all areas
exceeding the cleanup thresholds to an approximate depth
of 2 feet (i.e., dredging will proceed outward from the
planned location of the slurry wall to the "clean line")
(6A).
• These remaining sediments will be dewatered and placed
beneath the landfill cap (6A). (The landfill cap is part
of the prior selected alternative, OU-1-3F.)
• Any NAPL found in the remaining sediments will be
extracted and will be incinerated at an off-site facility
(6A).
• The primary focus of this remediation plan is to contain
the NAPL plume with the slurry wall. In the event the
slurry wall's initial positioning places it across the
"hot spot" area(s), practicality may dictate that the
wall be extended outward to enclose these "hot spots."
In such case, these highly contaminated sediments, rather
than being dredged and incinerated, would be left in
place, that is, contained by the slurry wall, covered
with fill, and finally covered with the cap. The
remaining sediments beyond the slurry wall would still be
dredged and consolidated beneath the cap.
Storm Sewer fOU-31 - Alternative 2X:
• The existing storm sewer will be cleaned, and a high
density polyethylene (HOPE) plastic slipliner will be
installed within the sewer.
• Any NAPL found in the soils and/or sediments taken from
the existing sewer will be extracted, and will be
incinerated at an off-site facility.
Monitoring;
• In all instances, post-remedial monitoring shall be
performed to determine the effectiveness of the remedial
alternatives which have been selected.
Figure 4 shows a schematic representation of the major features of
the selected remedy. The precise location of each aspect of the
selected remedy will be determined during the Remedial Design phase
of this overall remediation project.
During the Remedial Design Phase, the lowland area of 0.6 acres,
as shown in Figure 1., will be the subject of a "wetlands
32
-------
assessment."
I.- The Statutory Determinations^
Protection of Human Health and the Environment
The major human exposure pathways include: the ingestion of fish
from the embayment in the Niagara River, exposure of individuals
while swimming in the embayment and the Little Niagara River, the
ingestion of drinking water from the Niagara River as it is
withdrawn at the Niagara Falls Drinking Water Treatment Plant, and
dermal contact with, ingestion of, and inhalation of dust from off-
site contaminated soils. The selected remedy of consolidation,
capping, and containment will effectively eliminate each of these
pathways leading to human exposure. The "ingestion of fish"
pathway will be eliminated since no contaminants can leach from the
landfill area due to the existence of the slurry vail keyed into
the confining clay/till layer, the capping of the Site, and the
maintenance of an inward gradient across the slurry wall. In a
similar manner, the pathways involving swimming in the River and
drinking water from the River, will be eliminated since the entry
of contaminants into the River will be eliminated. Exposure to any
dust from contaminated off-site soils will be avoided since all
off-site soils which have contamination levels above those levels
deemed actionable, will be removed from their present location and
consolidated beneath the cap. After implementation of the options
which comprise the selected remedy, the overall risk associated
with the Site will be reduced to 10* for carcinogens, and the
hazard indices for non-carcinogens will be less than one.
Although excavation, as in the case of the off-site soils, can pose
short-term risks to workers and to nearby residents due to exposure
to fugitive dust, any such risks can be minimized or eliminated by
the application of the appropriate emission-control technologies.
In a similar manner, any emissions due to the incineration of
highly contaminated sediments or the incineration of NAPL, can be
controlled or eliminated through the application of currently
available emission-control technology.
Dredging activities associ.tcsd with the removal of sediments froa
the River can have short-term impacts on the River due to the
release of contaminated sediments. Prior to the initiation of any
dredging activities however, a berm vill be constructed beyond the
area of contamination so as to effectively retain any loosened
sediments, thereby preventing their transport into the River proper
from the embayment.
Compliance with ARARs
The selected remedy will comply with federal and state ARARs. A
listing of such ARARs can be found in Tables 9 through 10. The
33
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ARARs are organized 'as appropriate according to their respective
designations as chemical-specific, or location-specific and action-
specific. Distinctions have also been made between applicable
requirements, and relevant and appropriate requirements. When the
utilization has been made of a requirement which is not an ARAR ,
but is in the "To-Be-Considered" (TBC) category, a notation in
Table 10 has also been made to that effect.
In terms of a specific discussion of the selected remedy and its
compliance with ARARs and/or TBCs as the case may be, an
appropriate frame of reference for such discussion is the Operable
Unit (OU) structure.
OU-1. As mentioned earlier, ground water located in the landfill
soils at the Site is classified by EPA as Class IIB and by NYSDEC
as Class GA (potential source of drinking water), although it is
not a source of drinking water. The Safe Drinking Water Act
Maximum Contaminant Levels (MCLs) and NYSDEC Quality Standards for
Groundvaters are chemical-specific ARARs for the ground water on-
site. Although RCRA Groundwater Concentration Limits (RCRA
limits), which are also ARARs for ground water, exist for 4 of the
chemicals of concern, Lindane (4 ppb), mercury (2 ppb), arsenic (50
ppb), and cadmium (10 ppb), these limitations are identical to the
previously mentioned MCLs.
Ground water in the landfill soils discharges into the Niagara
River and across the western and eastern boundaries of the Site.
As stated in the NCP, when wastes are left in place, the "point of
compliance** lies at that point beyond the areal limit of the
contained wastes where ground water discharges. In the case of the
102nd Street Site, the point of compliance for ground water is the
embayment of the Niagara River (just outside the planned location
of the slurry wall), the ground water outside the slurry wall in
Griffon Park (to the west), and the ground water outside the slurry
wall to the east of the Site within the area bounded by the
drainage ditch. Relevant ARARs for ground water discharging into
the embayment are the Clean Water Act ambient water quality
criteria (AWQC) and the Mew York State ambient water quality
standards (AWQS). Chemical-specific ARARs for ground water
discharging to the west and to the east of the Site include MCLs
and NYS Ground-water Standards.
The remedial alternative which was selected (OU-1-3F): eliminates
ground-water discharge from the landfill by means of the
circumferential slurry wall, the maintenance of an inward hydraulic
gradient across the slurry wall through ground-water recovery, and
the capping of the consolidated landfill; eliminates surface-water
contaminant concentrations in the embayment; and, eliminates
ground-water site-related contaminant concentrations to the west
and to the east of the Site. In so doing, all ARARs will be met.
The EPA's Risk Assessment, using embayment water concentrations
34
-------
derived from ground-water chemical' discharge and embayment
dilution, determined that several compounds currently exceed the
AWQC or AWQS. Surface-water ARARs will be achieved by the OU-1
segment of the selected remedy which limits future discharge of
contaminated ground water into the River. The circumferential
slurry wall component of the selected remedy should effectively
limit ground-water discharge to the embayment and thereby meet
ARARs. The circumferential slurry wall component of the selected
remedy provides the most complete ground-water control and the
greatest assurance of meeting ARARs.
No ARARs are established for contaminated soils, although the
Centers for Disease Control has established a guidance value of 1
Mg/kg (ppb) for dioxin in residential soils. Since the EPA's Risk
Assessment indicates significant health risks are associated with
soil exposure, the selected remedy will remediate all perimeter and
off-site soils above cleanup thresholds (including dioxin
contaminated soils south of Buffalo Avenue). The perimeter soils
will be covered by the cap, and the off-site soils will be
excavated and consolidated beneath the cap.
Land Disposal Restrictions (LDRs) preclude the placement of
restricted RCRA hazardous wastes into a land disposal unit. The
off-site and perimeter soils, and the embayment sediments are a
restricted RCRA hazardous waste, in part because they contain
dioxin. If consolidating these soils and sediments on the landfill
constitutes placement into a land disposal unit, then such remedial
actions v.>uld fail to satisfy the LDRs. According to EPA's
Superfund LDR Guide #5 (OSWER Directive 9347.3-05FS, July 1989),
"Placement does not occur when wastes are ... moved within a single
AOC [area of contamination]." An AOC is "the areal extent of
contiguous contamination," such as a "landfill ... and the
surrounding contaminated soil. Such contamination must be
continuous, but may contain varying types and concentrations of
hazardous substances." The perimeter soils and embayment sediments
are contiguous and continuous with the contamination at the
landfill. The contamination north of Buffalo Avenue is considered
contiguous with the contamination surrounding the Site boundaries
(even though these areas are separated by the road) because
continuous contamination was found between the Site fence and the
south side of Buffalo Avenue, as veil as on the northern edge -^
Buffalo Avenue. Thus, the contamination north of Buffalo Avenue
is continuous and contiguous. Therefore, LDRs are not applicable
to the placement of the perimeter and off-site soils and the
embayment sediments on the landfill beneath the cap, and
accordingly are not ARARs.
OU-2. No promulgated federal or state ARARs exist for contaminated
sediment, however New York State does have "To-Be-Considered"
guidelines (TBCs) for sediments which require aqueous contaminant-
levels in the water surrounding the sediment ("interstitial" water)
to meet ambient water quality criteria (AWQC) and State ambient
35
-------
water quality standards (AWQS). These sediment TBCs are summarized
in Table 10. The OU-2-2C segment of the selected remedy, which
incinerates the sediment "hot spots," will achieve these TBCs, as
well as provide permanent protection from these areas of elevated
contaminant concentrations. The OU-2-6A portion of the selected
remedy will achieve compliance with the sediment TBCs since all
site-related sediment contamination will be dredged from the
emhayroent. In all instances, confirmatory sampling will be
conducted to insure that cleanup criteria have been met.
Dredging activities involved in the selected remedy will be
conducted in compliance with ARARs for excavation in a 100-year
floodplain, wetlands, and construction of bulkheads in navigable
waters.
OD-3. Any ground water which infiltrates into the storm sewer and
subsequently discharges into the embayment must meet surface water
AWQC. Since the selected remedy will line the storm sewer with an
HOPE pipe, and pressure-grout the annular space between the new
pipe and the existing storm sewer, the discharge of any
contaminants will be eliminated, hence the AWQC criteria will be
met.
Cost Effectiveness
Cost effectiveness is a critical component used in the balancing
of the evaluation criteria which eventually led to the remedy which
was selected. The selected remedy, at a total estimated cost of
$30.OM, is cost-effective, proportionately to its effectiveness.
While incineration alternatives do provide greater degrees of
permanence and greater degrees of the reduction of the volume,
toxicity, and mobility of site-related contamination, the cost
figures for the comprehensive incineration options approach $460M.
Such incineration options however, do not necessarily provide
greater protection of human health and the environment.
Utilization of Permanent Solutions and Alternative Treatment
Technologies or Resource Recovery Technologies to th« Maximum
Extent Practicable (MZP)
The EPA and the State of New York believe that the selected remedy
represents the maximum extent to whl-.f. permanent solutions and
treatment technologies can be utilized in a cost-effective manner
for the final remedy at the 102nd Street Landfill Site.
A discussion of the prospective utilization of permanent solutions
to the maximum extent practicable (HEP) was performed through an
analysis of the nine evaluation criteria. Once the threshold
criteria of overall protection and compliance with ARARs were met,
the critical decisional role was given to the five balancing
criteria of long-term effectiveness and permanence, reduction of
toxicity, mobility, or volume (RTMV), short-term effectiveness,
36
-------
implementability, and cost. The selection of remedy process was
additionally affected by the considerations given to the statutory
preference for treatment, and the considerations given to
acceptance by New York State and the community. The balancing
criteria are best considered on a one-by-one basis in order to
assess their collective impact on the remedy selection process.
To begin, long-term effectiveness as a factor in the selected
remedy is more than adequate in terms of the degree of permanence
which it offers. The off-site soils will be removed, the NAPL
permanently destroyed, and the contaminated sediments removed,
thereby eliminating the problem of residuals management for those
portions of the remedy. The containment of the landfill also
provides long-term effectiveness even though long-term monitoring
will be required to insure that the engineering controls are
performing as intended. Other options such as the use of a "secure
cell" and a cutoff wall, and the incineration options, are either
deficient on a short-term basis due to a failure to meet ARARs, or
as in the case of the comprehensive incineration option, offer a
very high degree of permanence at a very high degree of cost. The
RTMV criterion again is achieved more than adequately by the
selected remedy since the pathway of migration of contaminants into
the Niagara River will be eliminated. Other options are either
inadequate since capping is rot included, or highly effective as
in the case of the comprehensive incineration option but again with
an overreaching cost factor ($30M versus $456M). Regarding short-
term effectiveness, it is fairly clear that remediation goals will
be achieved within a much shorter time frame (36 months) without
any uncontrollable excavation or dredging risks, while incineration
options will take far longer, up to 15 years, before the requisite
goals are attained, and unknowns will still remain as to the
technology required to safely excavate the Site. In terms of
implenentability, the selected remedy will utilize proven
technologies, while other options, mainly incineration with its
accompanying excavation, will be faced with developing techniques
for uncommon engineering design problems such as excavating as deep
as 35 feet adjacent to the Niagara River. Considering cost alone,
after the threshold criteria have been met, the selection of remedy
process points dramatically away from comprehensive incineration
possibilities and toward the selected remedy.
The iij.-it critical criteria in the selection process were short-
term effectiveness, implementability, and cost. These criteria can
be regarded as the most critical due to the great disparity, as
stated above, in these areas among the options which were
ultimately given the most serious consideration after the threshold
criteria were met. The trade-offs favor the selected remedy in the
sense that cost, implementability, and short-term effectiveness
have driven the selection, while countering is a much higher degree
of permanence from the prospect of excavation and incineration of
the landfill soils. The selected remedy does however, propose a
permanent option in that the highly contaminated sediments will be
incinerated (after dredging) along with any NAPL which can be
37
-------
I
extracted from the landfill, from the remaining sediments, and from
the sediments renuved during the cleaning and lining of the storm
sewer. I
As stated above, permanent solutions have been utilized to the
maximum extent practicable in that the highly contaminated
sediments and recovered NAPL will be incinerated. Since it is
anticipated that the highly contaminated sediments will be handled
during the dredging process, a window of opportunity exists to
permanently treat these contaminants rather than consolidate them
beneath the cap. An element of practicability as to a permanent
solution for these highly contaminated sediments is available and
should be utilized, since the sediments should be handled during
the dredging process.
In summary, the selected remedy is considered to be the most
appropriate solution to contamination at the Site because it
provides the best trade-offs with respect to the nine evaluation
criteria and represents the maximum extent to which permanent
solutions and treatment technologies are practicable.
Preference for Treatment as a Principal Element
The preference for treatment as a principal element is not
satisfied since treatment of the principal threat (the landfill
residuals) was found to be distinctly impractical. However, the
material containing the highest concentrations of contaminants,
meaning NAPL, will be treated through incineration.
As mentioned in the prior section, the critical balancing criteria
of short-term effectiveness, implementability, and cost, all
highlight the impracticable nature of selecting a treatment remedy
such as incineration, in order to neutralize the principal threat
at the Site.
38
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Table 1
Chemicals of Concern
at the 102nd Street Landfill
SSIs - Ground Water
SSb - So'lSediment
Assessment Chemicals
arsenic
benzene
cnlorobenzene
cblorobenzoic acid, 2-
cnlorobenzoic acid, 3-
chlorobenzoic acid, 4-
chlorooapbthalene, 2-
chJoropbenol, 2-
cbJoropbenol, 4-
chtoroioluene, 2-
cblorotoluene, 4-
dichloroanilioe, 24-
dichloroanitine, 3,4-
dichlorobenzene, 1,2-
dichlorobenzene, 1,4-
dichloroetbylene, 1,1-
dichlorophenol, 2,4-
dichlorophenol, 24*
dimeihylphenoU 2,4-
bexachlorobenzene
bexachlorocyclobexaoe, a-
bexachlorcxyclobexane, b-
bexachlorocyclohexane, d-
bexachlorocyclohoane, g-
mercury
phenol
phosphorus
tetrachlorobenzene,
tetrachtorobenzene,
toluene
trichlorobenzene,
irichlorobenzeoe,
tncbloropbeoot, 2,44-
tricbJorophenol, 2,4,6-
cnJorobeozeae
dicblorobenzeae, 1J-
dichJorobenzene, 1,4-
dicbloropbenc4,2,4-
dJchJoropbenot, 24*
dimethylphenol, 2,4-
beacblorobenzeoe
bexachlorocyclobaaoe, •-
bexacblorocyclobexaoe, b»
bexacblorocycloheane, d-
bexachlorocydohejane, |-
mercury
pentachlorobenzene
phenol
leirachlorobenzene, Ii3,4-
teirachlorobenzeoe,
tricblorobenzene, Ii3-
inchlorobenzene, 1A4-
triehlorophenol, 2,44-
trichlorophenol, 2,4,6-
beozo(a)anihractne
benzo(b)fluoranifleoe
beQzo(1c)Quoraotheoe
cadmium
cbJoro-m-cresol, 4-
chJococaphihalene, 2-
cbloropbenol, 2-
dichloroetbyleoe, 1,1-
dicbloropbenol, 2,4-
dimetbylpbenol, 2,4-
bexacblorobeozene
bexachlorocyclohexane, a-
hexacblorocyclohexane, b-
bexachlorocyclobexane, d-
bexachlorocycloheane, g-
nirex
PCBs
PCDDs (tetra - octa congeners)
PCDFs (teira - ocva congeners)
pentachlorobenzene
pcntacblorophenol
phenol
trichlorccihytene
trichlorophenol, 2,44-
irichlorophenol, 2,4,6-
-------
Table 2
102nd Street Landfill Site
Summary of RI Sampling Data for
Significant Risk Chemicals
Medium Sampled/
Parameter
Groundwater - Overburden, [b]
henchJorobenzene
bexachJorocycJobeanes (HCCHs) [e]
TCDD, 24,7,8-
tetrac&Jorobeozeaet
PercbJoropentacycJodecafle (Minx) [d]
PCBs (Arodor 1248)
Surface Soil (Off-Site and Perimeter)
bexachlorobenzene
bexachJorocyclobeaanes (HCCHs)
mercury
TCDD, 24,7,8-
tetrachlorobenzenes
Niaeara River (EmbavmenO Sediment
bexacblorobeozene
bexachlorocyclohexanes (HCCHs)
TCDD, 24.7,8- [e]
tetrachlorobenzenes
mercury
Number
of
Samples
84
85
17
60
90
90
113
113
132
18
113
114
114
16
114
121
Number
of
Deieca
6
50
3
21
11
8
24
48
118
3
22
15
17
2
25
76
Mean
(ppb)
29
1,482
0.0002
1,420
28461
3,680
252
735
1,731
0.5
341
139
64,768
-
5,423
2,196
Upper
Bouad[a]
(PPb)
215
13,025
0.0006
9,980
24400
8,000
1,910
3,753
6.491
iS
3,770
1,694
867453
33
99,212
36485
Notes:
[a] Upper 95tb percentile of data set for cotnpouod/medium,
[b] Ground water cooceotratioos are summaries of fill aod alluvium samples from boundary wells along the
Niagara River embaymeot and the Site perimeter.
[c] HCCHs include the summation of 4 tomers (a-, b-, |-, tad d->
[d] Mires was detected but below the survey level of 7 ppb.
[e] TCDD sediment data a from Love Canal investigations (ooo-RI samples); two samples bad detectable
24,7,8-TCDD levels of 0.1 and 3.3 ppb.
-------
TtblO
Reference Doses tod Cancer PoUncj F»cton for Chemicals Used to Risk CiJculadoni
Compound :
EPAWLOf
Noocarciaojens Evidence
gadminfyt
cbJcro-m
-------
Tib)«3
Reference Doses and Cucer Potency Factor* for Chemicals Used in Risk Calculation!
Compound
Caroflogens
arodorl248
arsenic
benzene
benzo(a)antlsracene
benzo(b)Buoroanthene
benzo(i)fluoroantnene
cadmium
dichJorobenzene, 1,4-
dicbloroeUiylene, 1,1-
bexachlorobenzene
bexacblorceyctobexane, a-
bexachJorccyclobexane, b-
bexachJorocyclobexane, d-
bexachtorocyclobexane, g-
miret
tricbJoroetbylene
trichJoropbenol, 2,4,6-
HepuCDD, 1,24,4,6,7,8-
HeptaCDD, total
HeptaCDF, 1,24,4,6,7,8-
HeptaCDF, 1^3,4,7^,9-
HeptaCDF, total
HexaCDD, 1 A3.4.7.8-
HexaCDD, 1A3,6,7,8-
HexaCDD, 1^3,7,8,9.
HexaCDD, total
HexaCDF, 1A3.4.73-
HexaCDF, 1,23,6,7,8-
HexaCDF, 1^3,73,9-
HexaCDF, 23,4,6,73-
HexaCDF, total
OCDD
OCDF
PentaCDD. 1^3.7^-
PenuCDD, total
PeataCDF, 1A3,7^.
PtntaCDF, 24,4,73-
PentaCDF, total
TCDD, 23,73-
TCDD, total
TCDF, 24,73-
TCDF, total
EPAWtof
Evidence
B2
A
A
B2
B2
D
Bl
62
C
B2
62
B2
B2
B2
B2
Tonaty Factor
Oral RID Inbalaboc RID
fma^g-tf) (m&1cg-d)
7.7E+00
l.SE-t-00
25E-02
1.7E+00
1.6E+00
IjSE-Ol
14E42
6.0E41
1.7E+00
6JE+00
1£E+00
6JE-1-00
1JE+00
l.SE+00
1.1E-02
10E-02
1.6E+03
O.OE+00
1.6E+03
1.6E+03
O.OE+00
1.6E+04
1.6E+04
1.6E+04
O.OE-t-00
1.6E+04
1.6E+04
1.6E-f04
1.6E+04
O.OE+00
1.6E+02
l^E+02
73E4-04
O.OE+00
73E+03
7JE+04
O.OE+00
l^E+05
O.OE+00
1.6E+04
O.OE+00
5.0E+01
2JE-02
&9E-01
&SE-01
4.0E-01
6.1E+00
L2E+00
1.7E+00
64E+00
l^E+00
64E+00
14E-02
2.0E42
L6E+Q5
Reference Notes
DUS.1989
IRIS, 1989
IRIS, 1989
ICF, 1988; VS. EPA, 1987i
ICF, 1988; U^. EPA, 1987a
ICF, 1988; U^. EPA, 1987t
DUS, 1989 d
U3. EPA, 1989t
IRIS, 1989
IRIS, 1989
IRIS, 1989
IRIS, 1989
Assume most toxic
IRIS, 1989
IRIS, 1989
IRIS, 1989
IRIS, 1989
US EPA, 1989a
U.S. EPA. 1989a
U.S. EPA, 1989a
U.S. EPA, 1989a
U^. EPA, 1989b
US. EPA, 1989b
USEPA,1989b
U^. EPA, 1989b
U^. EPA, 1989b
U^. EPA, 1989b
U^. EPA, 1989b
VS. EPA, 1989b
VS. EPA, 1989b
U^. EPA. 1989b
VS. EPA, 1989b
U3.EPA,1989b
VS. EPA, 1989b
U^.EPA,1989b
VS. EPA, 1989b
VS. EPA. 1989b
VS. EPA, 1989b
UJS.EPA.1989*
US EPA, 19896
VS. EPA, 1989b
VS. EPA, 1989b
Notes
• •water
b-food
c - subcbronie RfD divided by u additiooal uncertainty ft«or
d - Bl earooogen by inhalation route only
e • Oral RID for 3,4-dimeibylpbenol
RflD - reference dose
CPF • cancer potency factor
-------
TibU 1 Notes tod Refereoc
NOTES
No tooaty information was found for 2-chJorooapihaIene, 24-dichloroanfline and 3,4-dichJoroaniliae
Toririry faaor for phosphorus derived from the occupational guideline for yellow phosphorus
Too'city factors for diarin and furan isomers were derived by multiplying Toticity Equivalence Factor*
(TEFs) for each isomer, developed in U.S EPA, 1989b, by the toxiciry of 2^,7,8-TCDD.
Tondry boors for poiycyclic aromatic hydrocarbons (PAHs) were determined based oo the
benzo(a)pyrene relative potency approach ICF, 1988; U.S. EPA, 1987a,
REFERENCES
U^. Envvonineotal Protection Agency. July 1989a. Health Effecu Assessment Summary Tables.
Third Quaner FY 1989. O£Sce of Solid Waste and Emergency Response, Washington, D.C
OERR 9200.6-303-(89.3>
US. Environmental Protection Agency. 1989b. Interim Procedures for Estimating Risks Associated
with Exposures to Mixtures of Chlorinated Dibenzo-p-Diorins and •Dibenzofurans
(CDDs and CDFs). Risk Assessment Forum. Washington, D.C EPA/625/3-8%)12
U^. Environmental Protection Agency. 1989. Integrated Risk Information System (IRIS) Database.
Maintained and updated periodically by the U.S. EPA. Washington, D.C
American Conference of Governmental Industrial Hygienists (ACGK). 1988. Threshold Limit
Values and Biological Exposure Inuces for 19SS • 1989. ACOIH: Cincinnati, Ohio
US. Environmental Protection Agency. 1988. Superfuod Public Health Evaluation Manual Update.
Office of Emergency and Remedial Response. Washington, D.C
ICF-Clemem Associates. 1988. Compariuve Potency Approach for Estimating the Cancer Risk
Associated with Exposures to Matures of Poiycyclic Aromatic Hydrocarbons. Interim Final Report.
US. Environmental Protection Agency. 1987. Updated Reference Dose and Cancer Potency Numbers
for Use In Risk Assessments. Memorandum from Sandra Lee of Toxic Integration Branca.
Rodricks, Joseph. 1985. Affidavit of Joseph V. Rodricks, PhD. in support of Stipulation and
Judgement Approving Settlement Agreement Hyde Park Landfill Civil Action No. 79-989.
-------
Table 4
Summary of Reasonable Maximum Potential Human Health Risks
for the 102nd Street Landfill
Surface Water Pathways
Surface Soil Pathways
TYPE OF RISK
Fish Dermal, Ingeaioo
Drinking Water Swimming Ingesuon and Inhalation TOTAL
fWTP) (Embayment) (Embayment)
Noncarcinogens
Groundwater Loadings
Storm Sewer Loadings
Soil Exposure
Z2E-Q3 2.0E42 17E+00
1.1E-04 LOE-03 S.6E-01
3.7E+00
Z9E-02 2SE-02
Total Haiard lodes
2JE-03
Z1E-02
4^E+00
23E-O2
Abbreviation*:
HCCHs: bexachJorocydobennes
PCBs: polychJorinated bipnenyte
TCDD: letncbJorodSbenzo-p-dioaB
HCB: bencbJorobeazeae
TeCB: tetrachlorobenzene
OE-fOO
•'Significant Risk Chemicals
Carcinogens
Groundwater Loadings
Storm Sewer Loadings
Soil Exposure
Total Carcinogenic Risk
1 Significant Risk Chemicals
1
» t; ~" » "~ "™iXiv>;.!:. vv« . ~~~7™z,>"x;
none none _ TeCB
7.0E-06 6JE-05 1JE-03
1.1E-07 1.0E46 5.4E-04
73E-Q6 6.6EX15 10E43
HCCHs HCCHs HCCHs
PCBt
TCDD
HCB
none:
8.1E-05
8.1EXJ5
TCDD^
HCCHs1
HCB
1.6E-03
5JEXM
8.1E-05
12E43
-------
Tables
Chemicals of Probable and Possible Concern
for Environmental Endangerment
at the 102nd Street Landfill
Probable Concern
Possible Cooetra
Groundwater
rara
Storm Sewer
mire*
PCBi
cblorobenzeBC
cbtoropoeool, 4-
bcBcbJorocyclobaBDe, ••
boochtorocycJoboaoe, d-
bexachlorocydobeoae, |-
mercury
TCDD,24,7,S-«
tetrachJorobenzene, 1A3.4-
trichlorobeozeoe,
PCBs
bex3Chlorocyclobeaoe,
TCDD.24,7^-*
Sediment Pore Water
dicbJorobeozeoe, 1,2-
bexachJorocyciobesoe, a-
bnochlorocyclobexaoe, N
bexacblorocyctobaiane, |-
peatacblorobenzeoe
TCDD, 23,73-
tetracblorobeozeae, 1A3,*-
tricbJoiobenzeoe, 1,23-
thcbJorobenzeoe, 1,2,4-
dicblorobenzene, 1,4-
bocacblorocyclobexaoe, d
tetracblorobenzeae,
• of potential concern wben UK combined cbemical leads from groundwater aad tbe
Korm wwer are considered
-------
Table 6
Operable Unit One (OU-1) Final Alternatives
Alternative
1
2A
2B
2C
2D
2£
3A
3B
3C
3D
3E
3F
5A
SB
5C
i^m
Existing
fence, cover
Upgrade
fence, use
existing cover
Upgrade
fence, use
existing cover
Upgrade
fence, use
existing cover
Upgrade
fence, use
existing cover
Upgrade
fence, use
existing cover
Capping
Capping
Capping
Capping
Capping
Capping
Indnerarion of
contaminated fill.
capping
Incineration of
contaminated fill,
capping
Incineration of
contaminated fill
Perimeter
Soils
Existing
cover
Secure cell
Secure cell
Off-She
Incineration
Secure cell
Stabilization
Capping
Capping
Capping
Capping
Capping
Capping
Inoneraoon
oo-«ite
Incineration
on-site
Incineration
on-site
Off-Sins
Sons
No Action
No Action
No Action
No Action
Secure Cell
Stabilization
No Action
No Action
No Action
Consolid.
Consolid.
Consolid.
Incineration
on-Bte
on-cxe
incineration
on-site
Groupd Water
No Action
No Action
Cutoff wafl
recovery and
treatment
Cutoff wall
recovery and
treatment
Cutoff wall
recovery and
treatment
Cutoff wall
recovery and
oeaonent
No Action
Cutoff wall.
recovery and
treatment
Circumferential
wall, recovery
treatment
Circumferential
wall, recovery
Cutoff wafl,
recovery and
Circumferential
wafl,recovery
Cutoff wall.
recovery and
treatment
Cutoff waH.
lecuveiy and .
oeaonent
Circumferential
wafl.recovery ai
and alluvium, cap
Present Worn
NAPL Costs
No Action $1,380.000
No Action $1,800.000
No Action $9,620,000
No Action $9,510,000
No Action $9,860,000
No Action $10,700,000
No Action S9.S50.000
Cutoff wall $17,600.000
Circum/erenr'l $16.600,000
wall
Circumferenrt $16,700,000
wall
Recovery and $21,300,000
incineration
Recovery and $20,340,000
incineration
Cutoff wall $77,100.000
to
$144.000.000
Recovery and $80,400,000
incineration to
$148,000,000
New remains $296,000.000
after excavation to
treatment $456,000,000
-------
Table 7
Operable Unit Two (OU-2) Final Alternatives
Alternative
1
2
2A
2C
4
6A
6C
6A modified
by2C
Description
No Action
Sediment control around *bot
spots,' dredge "hot spots/
mechanically dewater sediments,
combine with Operable Unit 1
treatment alternatives:
Capping
Incineration
Sediment control around 'clean
line,* dredge sediments,
dewatering cell near shoreline,
extend cap over 'hot spots.'
Sediment control around 'clean
line,' dredge sediments,
mechanically dewater sediments,
combine with Operable Unit 1
treatment alternatives:
Capping
Incineration
Incineration/
Capping
Present Worth Costs
$415,000
$2,730,000
$4,480,000
$6,180,000
$5,570,000
$13,200,000
$9,135,000
-------
Table 8
Operable Unit Three (OU-3) Final Alternatives
Alternative Description Present Worth Costs
1 No Action $375,000
2 dean existing sewer and install
a storm sewer liner.
2A Plastic slipliner $605,000
2B Insituform thennosetting $718,000
resin liner
3 Excavate existing sewer and
replace it with another sewer
line routed around the Site.
3A Plug Existing Sewer $2,990,000
i
3B Remove Existing Sewer $4,950,000
-------
Table 9
Location-Specific and Action-Specifie ARARS
102nd Street
FEDERAj,
Requirement
Coastal Zone Management
Act (16 U.S.C. §1451
etseq.)
Synopsis
Consideration in the FS
This regulation requires federal agencies Remediation activities would have to be
conducting any activities which affect consistent with state coastal zone
coastal zones, to do so in a manner management program*.
consistent with state coastal plans.
RCRA Location Standards
(40 CFR 264.18)
Floodp'.ains Executive Order
(EO 11998)
This regulation outlines the requirements Construction activities in the lowland
for constructing a RCRA facility on a area would have to control the effects
100-year floodplain. A facility located of a 100-year flood event.
on a 100-year floodplain must be
designed, constructed, operated, and
maintained to prevent washout of any
hazardous waste by a 100-year flood,
unless no adverse effects on human
health and the environment would
result.
Federal Agencies are required to reduce Construction activities in the lowland
the risk of flood loss, to minimize impact area would control flood impacts.
of floods, and to restore and preserve
the natural and beneficial value of
floodplains.
U.S. Army Corps of Engineers Activities involving the construction of or Construction activities in the Niagara
Nationwide Permit Program alteration to bulkhead, dikes or River would be coordinated with the
(33 CFR 330) navigable waters are regulated by the VS. Army Corps of Engineers.
Corps of Engineers.
Fish and Wildlife Coordination This regulation requires that any action Construction activities in the Niagara
Act that proposes to modify a body of water River would be coordinated with the
(16 U.S.C. 662) or wetlands must consult with the US. U.S. Fish and Wildlife Service,
Fish and Wildlife Services. This
requirement is addressed under CWA
Section 404 requiremena.
Endangered Species Act
(50 CFR 200, 402)
Site activities must minimize impact on Not applicable «»«*•• there are
identified endangered plant and animal endangered species at the sue.
•peda.
no
Executive Order 11990 Site activities oust minimize the Construction activities must consider
Protection of Wetlands destruction, las or degradation of the potential classification of the
wetland*. lowland area as a wetlands.
EPA Policy on Wetland CERCLA actions taking place m land A wetlands assessment must be
Assessments for CERCLA areas potentially consider a wetlands conducted for any construction
Actions (OSWER Dir. 9280.0- must conduct an assessment to evaluate activities in the lowland area.
02, August 5, 1985) any environmental impacts.
-------
Table 9
Requirement
Location-Specific and Action-Specific ARARS
102nd Street landfill
STATE
Synopsis
Consideration in the FS
Floodplain Management These regulations protect areas at flood Remedial alternatives which effect the
Regulations (6 NYCRR Part hazard, related erosion hazard, or special floodplain must meet these
500) mudslide hazard. requirements.
Use and Protection of Waters
(6 NYCRR Part 608)
New York State Ambient Water
Quality Standards
(6 NMCRR Parts 700-70S)
Species of Wildlife
(6 NYCRR Part 182)
Under this regulation, • permit is Remedial alternatives affecting any
required to change, modify, or disturb protected streams, its beds or banks or
any protection stream, its bed or banks any navigable waters or contiguous
sand, gravel, or other material; or to marshes or wetlands, wul be
excavate or place fill in any of the coordinated with NYSDEC.
navigable waters or in any marsh,
estuaries or wetland, contiguous to any
of the navigable waters.
Defines surface water classification (A- Use classifications and standards to
special, International Boundary Waters) help establish remedial requirements.
and aquifer classification (CA) and lists
specific chemical standards.
Site activities must minimize impact on Not applicable since there are no
identified endangered or threatened endangered or threatened species at
species of fish or wildlife. the Site.
Freshwater Wetlands Area must be at least 24 acres of Lowland area is not a wetlands by
Regulations unusual importance to be considered • Rate nandards.
(6 NYCRR Part 664) wetlands.
-------
Figure 1 102nd Street Landfill and Survey Area
Survey Area
Direction of Flow
- Landfill Boundary
-------
Figure 2
102nd Street Landfill - Remedial Investigation Summary
Soil - Off-Site and Perimeter (167 Samples)
Survey Area
Ground Water (354 Sampl
N
Little
Niagara
River
Belden Site
Cayuga Island
Sewer Samples
Sewer Water (4 Samples)
Sewer Sediment (1 Sample)
Sewer Betiding Water (2 Samples)
Sewer Bedding Soil (4 Samples)
O Monitoring Well
(Not all RI Wells Shown)
-------
Figure 3
102nd Street Landfill - Sediment Clean Line
Numbers in parentheses are clean line distances from shore (in feet) measured along the vectors
Little
Niagara
River
Perimeter Soils
Belden Site
Cayuga Island
G F E D \ C B A
(»0) (145) (|64) (253) (227) (298) (250)
Niagara River
Clean Line
-------
Figure 4
102nd Street Landfill Remedy - Schematic
LaSniicj^xpressway
Capped Area
Little
Niagara
River
Cayuga Island
Interception
Synthetic
Liner
NAPL Extraction Wells
(positions shown are not exact)
Survey Area
Perimeter Soils
Bclden Site
Circumferential Wall
Gay
Off-Site Soils and Sediments
-------
TcbU 10
Cbemleal-SpeciOe ARVRi - Gronodwiur
102od Street S1U
Regulatioq
FEDERAL RCRA Grouodwater Concentration Limiu
(40 CFR 264.94)
Sale DrintiDg Water Aa Maximum
Contaminant Levels (MCLs) (40 CFR
14L11-.16)
STATE NYSDEC Quality Standards fcr
Grounduaters (6 NYCRR 703J)
NYSDOH Public Water Supplies (10
NYCRR M)
NYDOH Sources of Water Supply (10
NYCRR 170)
NYSDEC Standards of Water Quality (6
NYCRR 701.4 and 701.7)
Application Type
Establishes grouodwater protection standards RA
for RCRA facilities
Enforceable standards for public drinking RA
water system*
Establishes standards for das GA A
grouodwaten
Establishes standards for public drinking RA
water systems (MCLi)
Establishes standards for raw water quality RA
Process for deriving standards based on
health levels or chemical correlations
TBC
A - Applicable
RA • Relevant and appropriate
TBC • To be considered
-------
Compound
Table 11
Evaluation of Groundwater Concentrations
at the 102nd Street Landfill
Regulatory
Level
Maximum Site
Concentration
SSI Parameters
benzene
toluene
chJorobenzene
chJorotolueae, 2-
cbJorotoluene, 4-
dJcnJorobenzene, 1,2-
dichlorobenzene, 1,4-
tricblorobenzenes
tetiacblorobeazenes
bexachlorobenzene
hexacblorocyclobexanes
dichloroaniline, 24-
dich!oroaniline,3,4-
phenols (total)
chlorooenzoic acids
mercury
arsenic
ND
5.00
5.00
5.00
5.00
4.70
4.70
5.00
5.00
0.35
ND
5.00
5.00
1.00
50.00
2.00
25.00
703.5
10NYCRR5
10NYCRR5
10NYCRR5
10NYCRR5
7034
7034
10NYCRR5
10NYCRR5
7034
703J
10NYCRR5
703.5
10NYCRR5
703J
703J
8200
5700
16000
560
PI
3000
1200
3100
2700
4
1815
16000
[2]
76
10000
68
230
Endagerment Assessment Chemicals
dichloroethyiene, 1,1-
trictuoroethylene
benzo(a )ani hracene
benzo(b)fluoraatbene
benzo()c)f1uorantbene
cbloronapbtbaleoe, 2-
cblorepbenol, 2-
dichlorophenol, 2,4-
dimetbylpbenol.2,4.
tricbloropbenol, 2A$>
thcbJorophenol, 2,4,6-
cnlon>oi-cresol,4-
pentacbloropbenol
mirex
PCBs
TCDD.V.7,8.
cadmium
0.07
5.00
0.00
0.00
0.00
0.00
5.00
1.00
1.00
1.00
1.00
1.00
1.00
0.04
0.10
0.000035
10.00
701.4
10NYCRR5
701.7
701.7
701.7
10NYCRR5
703 J P]
7034 PJ
703 jp]
7034 P]
7034 pj
7034 pj
701.4
7034
7034
7034
7034
3
130
ND
ND
ND
10
390
6400
68
2500
180
28
38
ND
140
04
33
Noter
[1] All regulations are 6 NYCRR unless suied otherwise
[2] Total of all isomers
[3] Total may not exceed 1 ng/L
ND- Not Detected
-------
Table 12
Estimated Sediment Quality Criteria
at the 102nd Street Land Oil
Compound
TCDD, 2,3,73-
trichJoroetaylene
benzene
chlorobenzene
dicbJorobenzene, 1,2-
dichJorobenzene, 1,4-
trichlorobenzene, 1^3-
trichJorobenzeoe, 1&4-
tetracaJorobenzene, 1,24,4-
beachJorobenzeoe
chJorobenzoic acid, 2*
cbJorophenol, 4-
tricaiorophenol, 2,4,6-
dichloroaniline, 24-
bexachlorocyclobexane, •-
boacbloroq'dohenne, N
bexacblorocyclohexane, g-
PCBs
arsenic
cadmium
mercurv
hfYSDEC
AWQS [1]
fus/L)
0.000001
11(2]
6 [2]
PI
UA
UA
1
1
UA
0.01
0.0!
0.01
0.001
190
2.77
0.2
Sediment
Remed. Level
fuaflcg) [41
0^6
111
40
132
680
680
3680
3680
640
NC
160
3.04
3.04
0.86
4Z4
ND
ND
ND
Notes:
UA-Unavailable
NC • Cannot be calculated without Koc
ND - No algorithm available for metals
[1] NYSDEC Division of Water TOGS 1.1.1 Ambient Water Quality Standard* (1987)
[2] NYSDEC TOGS 1.1.1 Guidance Value
[3] NIH IRIS Chronic AWQC for l,2,4,5.tetracnlorobenzeoe (19S9)
[4] Based on the sediment concentration necessary to potentially eacegd AWQS
Organic Carbon (traction): 0.08
-------
RESPONSIVENESS SUMMARY
102nd STREET LANDFILL
NIAGARA PALLS. NEW YORK
I.- Overview
The U.S. Environmental Protection Agency (EPA) held a public
comment period from July 25, 1990 through August 25, 1990 so as to
allow interested parties to comment upon the EPA's Proposed Plan
for the remediation of the 102nd Street Landfill Site (the "Site").
The EPA also held a public meeting on Wednesday, August 15, 1990,
at the Red Jacket Inn located at 7001 Buffalo Avenue in Niagara
Falls, New York. The purpose of the public meeting was to review
the Proposed Plan, to present the EPA's preferred remedy, and to
solicit, record and consider all comments received from interested
parties during the course of the actual meeting. The preferred
remedy carried the concurrence of New York State (NYS), and a
technical representative of NYS assisted in the presentation and
discussion.
A responsiveness summary is required for the purpose of providing
the EPA, NYS, and the public with a summary «jf citizens' comments
and concerns regarding the proposed remediation as such comments
and concerns were raised during the public comment period, and the
responses to those comments and concerns. All comments summarized
in this document were given full consideration in terms of
selection of the final remedy as stated in the Record of Decision
(ROD).
II.- Background on Community Involvement and Concerns
The 102nd Street Landfill Site initially became an issue of public
concern in December, 1970, when the Buffalo District of the U.S.
Army Corps of Engineers (COS) notified Occidental Chemical
Corporation and 01in Corporation (the "Companies") that no further
construction or landfilling could occur until a bulkhead was
installed along the shoreline. Although the bulkhead was
completed in 1973, no further landfilling at the Site occurred
after construction of the bulkhead. A series of investigations
regarding sub-surface conditions at the Site, led to the filing of
a complaint in December, 1979, in the U.S. District Court in
Buffalo, New York, by the United States of America, on behalf of
the Administrator of the EPA, against the Companies seeking
injunctive relief and civil penalties for an imminent and
substantial endangennent to the public health and welfare. In
November, 1980, a compliant pursuant to the New York State
39
-------
Conservation Law and "the state's common law of public nuisance, was
filed by the State of New York (NYS) seeking civil penalties.
These lawsuits are still pending contingent upon the final
remediation of the Site.
The major issues and concerns expressed by the community regarding
the 102nd Street Landfill are as follows:
• Incineration Concerns - Certain concerns were expressed
at the^public meeting, and by means of written comments,
regarding incineration emissions in general, and in
specific terms, concerns over the incineration of
sediments, or other wastes, which contain metals such as
mercury.
• Long-Term Monitoring - Concerns were stated at the public
meeting as to the precise nature and extent of long-term
monitoring which the EPA would require and put into
effect.
Restricted Access to Site After Remediation - The Health
Department of Niagara County expressed their objections
in writing as to the plan to restrict access to the
shoreline after the remediation is completed.
• Containment and/or Removal of NAPL - Concerns were
expressed at the public meeting as to the indentions and
abilities of the EPA regarding NAPL, specifically its
containment and its removal from the landfill and from
the contaminated sediments.
• Dredging and Incineration of Contaminated Sediments -
The Companies expressed their objections in writing
regarding the EPA's plan to incinerate the sediments
which contain high levels of contamination, and regarding
the EPA's plan to dredge all remaining contaminated
sediments out to the "clean line."
III.- Summary of Major Questions ar»a geHnmgBts Received Purina
tfrs Public Meeting and the Responses of the EPA
The summary of the questions and comments made during the public
meeting held on August 15, 1990 for the 102nd Street Landfill Site,
is organized into the following categories:
A.- Incineration;
B.- Long-Tern Monitoring;
C.- Contaminated Sediments; and,
D.- Miscellaneous Concerns.
40
-------
A.-. Incineration
1.- Comment: A resident stated her general opposition to any form
of incineration, be it incineration of NAPL or incineration of the
highly contaminated sediments. She did not believe that the
emissions coming from incinerators are or could be safe with
respect to human health.
Response: The EPA feels that it is more prudent and safe to
extract the most toxic and most mobile substances from the
landfill, meaning the NAPL and the highly contaminated sediments,
and permanently destroy these toxic substances by means of
incineration. The individual who made the comment was advised that
the present state of emission-control technology is sufficiently
advanced so that there will be no danger to the public from any
incineration efforts.
2.- Comment: A resident stated his concerns regarding the presence
of mercury in the highly contaminated sediments and the landfill,
and the EPA's ability to safely control stack emissions during the
incineration of any sediments or NAPL which might contain mercury.
He was concerned that mercury would be released to the atmosphere,
and would thereby be a threat to public health. The remedy will
meet all federal and state regulatory requirements.
Response: The EPA stated that any incineration would be performed
with highly efficient mechanisms which would prevent the release
of any mercury through stack emissions.
B.- Long-Term Monitoring
1.- Comment: A resident stated his concerns over the fact that the
EPA mentioned only briefly its intent to perform long-term
monitoring of the hazardous substances which will be left at the
Site, and that the EPA did not state any specifics as to its
monitoring plans.
Response: The EPA advised the individual that the Proposed Plan
was only conceptual in nature, and that during the remedial design
phase, more than adequate details would be developed as to the
nature, -nu^'-er, and locations of the various types of monitoring
wells which the EPA routinely utilizes under these circumstances.
The EPA also stated that it will, as required by law, review the
situation every five years to insure that the engineering controls
installed at the Site are in fact, performing as intended.
C.- Contaminated Sediments
1.- Comment: A resident expressed concern that the EPA might have
some degree of difficulty in locating the positions of the NAPL in
and under the sediments.
41
-------
Response: The individual was informed that during the remedial
design process, a series of borings would be made into the soils
and sediments to determine if any NAPL had been overlooked during
our initial assessment. In any event, the EPA intends to use
geotechnical^ borings to determine the precise location of the NAPL
plume. The individual was assured that any containment structures
would be farther out into the Niagara River than any NAPL. An
explanation was offered regarding the existence of the clay/till
confining layer, the fact that NAPL is rather dense in nature, and
the fact that the confining layer would collect any descending
NAPL, thereby preventing further migration of the NAPL.
D.- Miscellaneous Concerns
1.- Comment: A resident expressed an interest in the adjoining
Belden Site, and the apparent fact that there were no plans to
remediate the Belden Site at the same time as the 102nd Street
Landfill.
Response: The resident was advised that the Belden Site is listed
by New York State as an inactive hazardous waste site. Any further
investigations into the Belden Site will be conducted by New York
State. The Belden Site appears at this time to pose less of a risk
to human health and the environment. The remedial action conducted
at the 102nd Street Landfill will not interfere with any
investigations or remedial actions undertaken regarding the Belden
Site.
2.- Comment: A resident asked who is paying for all this remedial
work.
Response: A brief explanation was offered as to the operation of
Superfund, and how responsible parties are encouraged to use their
own money to perform remediation work, rather than to use Superfund
money initially and then attempt to collect at a later date from
the responsible parties.
3.- Comment: A resident asked what the character of the fill was
which was deposited on the Site by the Companies.
Response: A description was offered as to the different types and
estimated quantities- of wastes which were placed on the Site, and
how the confining clay/till layer and the bulkhead along the
shoreline, prevented most of these wastes from entering the Niagara
River. During the time the Site was operated as a landfill, it is
estimated that approximately 159,000 tons of waste were deposited
by the Companies. Contaminants included heavy metals (such as
mercury), chlorinated single-ring aromatics (e.g., chlorobenzene
compounds), chlorinated phenols, hexachlorocyclohexanes (HCCHs),
polychlorinated biphenyls (PCBs), and polychlorinated dioxins and
dibenzofurans (PCDDs and PCDFs).
42
-------
4.- Comment: A resident inquired as to the boating area at the
mouth of the Littl<* Niagara River, and whether the Companies
intended to allot some money to dredge the mouth of the river of
contamination, if in fact the area was contaminated.
Response: ^ The answer consisted of a description as to how the
remedial investigation was conducted in order to determine the
extent of site-related contamination. The point was made that the
limit of contamination has been well defined, that it's very close
to the shoreline, and that it doesn't extend very far beyond the
western edge of the property. Since there is no connection
between the mouth of the river and site-related contamination, the
mouth of the river is not included within the remediation plans for
the 102nd Street Site. A suggestion was made that the resident
contact the U.S. Army Corps of Engineers regarding the issue of
dredging the mouth of the river.
5.- Comment: A resident inquired as to why Griffon Park was closed
down. (The resident was apparently aware of the fact that the boat-
launch facilities on the western side of the park are open and in
regular use) .
Response: The belief was expressed that the eastern portion of
Griffon Park was closed due to the investigations being conducted
at the adjoining 102nd Street Site. No comment could be offered
as to the intentions of the local governmental officials regarding
the refurbishing of the eastern side of the park.
6.- Comment: A question was asked as to why the original survey
area of the 102nd Street Site did not include the portion of the
Belden Site used by Goodyear (to apparently dump tires) , and were
there any plans to remediate various sites upriver toward
Tonawanda.
Response: During the time when the initial lawsuit was filed
against the Companies (1979), the EPA knew from aerial photographs,
the area that the Companies used for dumping (meaning the 102nd
Street Site) , and concentrated its efforts there. At that time,
the Belden Site was not identified. As to remediation of other
sites along the Niagara R.lver, it vill depend on the priorities
which are established. As a yanerai rule, the most serious sites
will be remediated first.
IV. - _ Butnumy of Ma^ot Writ**" Pftmments Received During the
A public comment period was held from July 25, 1990 through August
25, 1990 in order to receive comments front the public on the RI/FS
reports and the Proposed Plan. Written comments submitted during
the public comment period are summarized in this section, along
with the EPA's responses.
43
-------
A.- Letter dated August 8. 1990 from the Companies
Comment: The Companies believe that dredging out to the limit of
site-related chemicals above survey levels, and that incinerating
sediments containing elevated levels of site-related chemicals, are
not warranted based on risk or regulatory considerations. The
additional costs to implement these measures (approximately
$4,500,000. to $6,600,000.) are excessive in light of the absence
of any additional protectiveness of human health or the environment
that would be achieved.
B.- Letter dated August 24. 1990 from the Companies
Comment: The Companies continue to believe that incineration of
sediments with elevated concentration* of chemicals is not
warranted based on risk or regulatory considerations and the
additional costs are excessive in light of the absence of any
additional protectiveness of human health and the environment.
Placing the dewatered sediments under the cap effectively removes
the sediment areas of concern from the environment and the
additional cost of incineration is not justified in this instance.
C.- Letter dated August 30. 1990 from the Companies
Comment: The Companies believe that, where practicable, extension
of the slurry wall to enclose sediments with elevated chemical
concentrations followed by dredging and placement beneath the cap
of the remaining site-related sediments is an appropriate remedy
for the Site.
D.- Letter dated September 5. 1990 from the Companies
Comment: The Companies believe that the presence of mercury and
the logistics of ash disposal are further justification that the
incineration of Site sediments is unwarranted and inappropriate.
Placement of sediments beneath the Site cap or within the slurry
vail is a technically feasible remedy that can be readily
integrated with the remaining remedial design elements and is
protective of human health and the environment.
EPA Response (to the four letters received from the Companies):
The selected remedy in part, does propose that the highly
contaminated sediments be incinerated and that the remaining
sediments be dredged out to the "clean line." (The "clean line"
represents the extent to which site-related contamination has
migrated.) These remaining sediments would then be consolidated
beneath the cap. The EPA's intent will always be to use permanent
solutions to the maximum extent practicable. In the present case,
a window of opportunity exists as to the highly contaminated
sediments in that they must be handled during the dredging process.
Once removed from the Niagara River, rather than placing these
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sediments beneath the cap, it appears more prudent to incinerate
them thereby permanently destroying this source of high
contamination, and thereby obliging the statutory urgings to search
for and to implement permanent solutions to the maximum extent
practicable.
The EPA's position regarding dredging all remaining sediments out
to the "clean line" is firm. As the Companies are aware, the
"clean line" is the acknowledged extent of site-related
contamination outward into the embayment. These sediments must be
removed or they will simply remain as a source of contamination and
an exposure pathway which threatens human health and the
environment.
With respect to the comment by the Companies regarding the EPA's
plan to incinerate the highly contaminated sediments, one further
note is in order. As mentioned elsewhere in this ROD, the primary
focus of this remediation plan is to contain the KAPL plume with
the slurry wall. If, based on the data obtained from the
geotechnical borings installed during the design period to detect
the extent of the NAPL plume, the slurry wall's initial positioning
places it across the areas containing elevated levels of
contaminants, practicality may require that the wall be extended
outward to enclose these areas of high contamination. In such
case, these highly contaminated sediments, rather than being
dredged and incinerated, would be left in place, that is, contained
by the slurry wall, covered with fill, and finally covered with the
cap. The remaining sediments beyond the slurry wall would still
be dredged and consolidated beneath the cap.
E.- Letter dated Auo~ust 14. 1990 from the Health Department of
Niagara County
Comment: While not objecting to the response action as presented
in the Proposed Plan, the Health Department is concerned about
restricting access to the Site after the remediation is completed.
The Health Department contends that there is a limited amount of
waterfront space in Niagara County and that long-term demand for
waterfront space will intensify. New York State has recognized
that the community needs protection against proposed projects which
will prevent best usage of coastal lands and has thus created the
Coastal Management Plan. Any proposed remediation project along
coastal lands should, in the spirit of the Coastal Management Plan,
evaluate what additional actions would be necessary to comply vith
as many coastal management policies as possible. The Niagara River
coast line is now recognized as a significant scenic resource.
Accordingly, a review of the proposed remediation should be
conducted to determine how this scenic resource might best be
protected and preserved. One suggestion which might be feasible
would be to incorporate a "public right-of-way" along the
shoreline. Since the remediation project will modify the existing
shoreline by construction of a slurry vail, there may be (with
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minimal design modification), enough room between the river and the
landfill site to dedicate a strip of land to be used as a
pedestrian and bicycle trail. Also, by properly placing vegetation
upon conclusion of construction, unattractive elements can be
obscured and wildlife will be encouraged.
EPA Response: The merits and feasibility of the proposal made by
the Health Department of Niagara County will be given the fullest
consideration during the remedial design phase of this project.
Restriction of access to the shoreline may not be necessary if it
can be demonstrated to the satisfaction of the EPA that "public
right-of-way" or other recommendations of local governments, will
not interfere with the EPA's selected remedy.
V.- Remaining Concern*
Concerns raised by the community regarding the alleged negative
impacts of incineration emissions upon the public health will
continue to linger.
The recommendations made by the Department of Health of Niagara
County as to not restricting public access to the waterfront after
completion of the remediation, will continue as a public issue,
especially during the period when the remedial design is conducted.
The community appears to be concerned about and interested in the
initiation of additional remediation projects along the Niagara
River.
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New York State Department of Environmental Conservation
50 Wolf Road, Albany, New York 12233
Mr. Rich«rd
Oirtctor
emergency and Remedial Response
u.S. Environmental Prvtection Agency
Region 11 • 26 Federal Plaza
New York, NY 10278
Thomai C. Jorllng
CommlMloner
.SEP
2 6
1230
Re: 102nd Street Landfill (Site #932022, 932031)
Record of Decision
Dear Mr. Caspe:
The Revised draft Record of Decision (ROD) for the 102nd Street Landfill,
received by the New York State Department of Environmental Conservation
(NYSDEC) on September 21, 1990 has been reviewed. The NYSDEC concurs with
the selected remedy for each operable unit as presented in the draft ROD.
Specifically, the ROD calls for: containment of the site, with excavation
of contaminated off-site soils and placement on the site (Operable Unit
One); dodging of those contaminated embayment sediments, with incineration
of the areas with high levels of chemicals (Operable Unit Two); and
slipllr.ing of the 100th Street storm sewer that runs through the site
(Operable Unit Three).
NYSDIC recommends that a draft Consent Order be presented 1n the very near
future to the Potential Responsible Parties by the EPA/State so that
implementation can begin. Our respective legal representatives should
develop this order as soon as possible. Further, NYSDEC recommends that
the selected remedy for each operable unit be implemented as soon as
possible. We look forward to working with the USEPA to achieve this goal.
If you have any questions or concerns on this matter, please contact
Kr. itiehMl J. O'looli, Jr., F.E. at 518/457-5561.
Sincerely,
Edward 0. Sullivan
Deputy Commissioner
u: C, Petersen, US£PA
K. Lynch, USEPA
P. OHvo, USEPA
A. Wakeman, NYSDOH
N. Spiegel, NYSDOL
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