PB94-963848
EPA/ROD/R02-94/243
April 1995
EPA Superfund
Record of Decision;
GCL Tie & Treating Inc.
(O.U. 1), Sidney, NY
9/30/1994
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DECLARATION FOR TEE RECORD OF DECISION
SITE NAME AND LOCATION
GCL Tie & Treating
Sidney, Delaware County, New York
STATEMENT OF BASIS AND PURPOSE
This Record of Decision (ROD) documents the U.S. Environmental
Protection Agency's (EPA's) selection of the remedial action for
the GCL Tie & Treating site in accordance with the requirements
of the Comprehensive Environmental Response, Compensation and
Liability Act of 1980, as amended (CERCLA), 42 U.S.C. §§9601-9675
and the National Oil and Hazardous Substances Pollution
Contingency Plan (NCP), 40 CFR Part 300. An administrative
record for the site, established pursuant to the NCP, 40 CFR
300.800, contains the documents that .form the basis for EPA's
selection of the remedial action (see Appendix III).
The New York State Department of Environmental Conservation
(NYSDEC) has been consulted on the planned remedial action in
accordance with section 121(f) of.CERCLA, 42 U.S.C. §9621(f), and
concurs with the selected remedy (see Appendix IV).
ASSESSMENT OF THE SITE
Actual or threatened releases of hazardous substances from the
site, if not addressed by implementing the response action
selected in this ROD, may present an imminent and substantial
endangerment to public health, welfare, or the environment.
DESCRIPTION OF THE SELECTED REMEDY
The selected remedy pertains to the first of two operable units
for the site and addresses the contaminated soils and debris
located on the GCL property. T> - second operable unit ac?' -S£ =• ->s
the contamination in the soils or. the remainder of the site
(referred to as non-GCL property), as well as contaminated
groundwater, surface water, and surface water sediments.
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The major components of the selected remedy include:
• Excavation and treatment of approximately 36,100 cubic yards
of contami atod soils and debris (with the possible
exception of wood debris as noted below) on-site through a
thermal desorption process; the expected depth of excavation
ranges from 2 to 8 feet below grade, and will include
excavation of non-native soils and debris located below the
water table which exceed health-based cleanup levels;
• Replacement of the treated soils (mixed with clean fill as
necessary) to the excavated areas, following by grading and
revegetating; and
• Demolition and off-site disposal of existing structures on
the GCL property which are either contaminated or would
interfere with the remediation of the GCL-property soils.
Residual waste from the treatment process and excavation
activities (e.g., wastewater collected during dewatering
operations or dense nonagueous phase liquids encountered during
excavation) would be treated on-site and/or disposed off-site at
a facility permitted to handle such wastes. As a contingency,
wood debris classified as nonhazardous under the Resource
Conservation and Recovery Act (RCRA) could also be disposed off-
site at a facility permitted to burn creosote-treated wood for
energy generation. In addition, EPA will recommend to local
agencies that institutional control measures be undertaken to
ensure that land use of the property continues to be
industrial/commercial.
DECLARATION OP STATUTORY DETERMINAmIONS
The selected remedy meets the requirements for remedial actions '
set forth in section 121 of CERCLA, 42 U.S.C. §9621: (1) it is
protective of human health and the environment; (2) it attains a
level or standard of control of the hazardous substances,
pollutants and contaminants, which at least attains the legally
applicable or relevant and appropriate requirements (ARARs) under
federal and state laws; (3) it is cost-effective; (4) it utilizes
permanent solutions and alternative treatment (or resource
recovery) technologies to the maxirum extent practicable; and (5)
it satisfies -;:.ie statutory pre^'ere ce for remedies that einp" y
treatment to reduce the toxicity, mobility, or volume of the
hazardous substances, pollutants or contaminants at a site.
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A five-year review of the remedial action pursuant to section
121(c) of CERCLA, 42 U.S.C. §9621(c), will-not be necessary,
because this remedy will not result in hazardous substances
remaining on-site above health-based levels.
\
Jeanne ^
Regionah
-^/) <
Jbtf<~/t^^^ li>- ' 0 /C
. Fox
Administrator
Date
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RECORD OF DECISION
DECISION SUMMARY
Operable Unit 1
GCL Tie & Treating
Sidney, Delaware County, New York
United States Environmental Protection Agency
Region II
New York, New York
September 1994
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TABLE OF CONTENTS
Section Page
SITE NAME, LOCATION AND DESCRIPTION . . . '..
SITE HISfORY AND ENFORCEMENT ACTIVITIES 1
HIGHLIGHTS OF COMMUNITY PARTICIPATION 2
SCOPE AND ROLE OF OPERABLE UNIT 3
SUMMARY OF SITE CHARACTERISTICS .3
SUMMARY OF SITE RISKS 5
'•-•'-•*.* ' "
REMEDIAL ACTION OBJECTIVES . . . 8
DESCRIPTION OF REMEDIAL ALTERNATIVES ...... 9
SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES . 12
SELECTED REMEDY 16
STATUTORY DETERMINATIONS .... ...... 18
DOCUMENTATION OF SIGNIFICANT CHANGES 20
ATTACHMENTS
APPENDIX I.
APPENDIX II.
APPENDIX III.
APPENDIX IV.
APPENDIX V.
FIGURES
TABLES
ADMINISTRATIVE RECORD INDEX
STATE LETTER OF CONCURRENCE
RESPONSIVENESS SUMMARY
11
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LIST OF FIGURES
FIGURE 1
FIGURE 2
FIGURE 3
FIGURE 4
FIGURE 5
FIGURE 6
FIGURE 7
FIGURE 8
FIGURE 9
GCL TIE & TREATING SITE LOCATION MAP
GCL PROPERTY PLAN
TRENCH LOCATIONS
TRENCH A CROSS SECTION
TRENCH B CROSS SECTION
TRENCH C CROSS SECTION
TRENCH D CROSS SECTION
TRENCHES E & F CROSS SECTIONS
EXCAVATION CONTOURS FOR SOIL REMEDIATION
ill
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LIST OF TABLES
TABLE 1
TABLE 2
TABLE 3
TABLE 4
TABLE 5 .
.TABLE 6.
TABLE 7
.TABLE 8
TABLE 9
TABLE 10
TABLE 11
SUMMARY OF CONTAMINANTS MOST FREQUENTLY DETECTED
DURING THE FFS AND REMOVAL ASSESSMENT
.CHEMICAL SUMM2RY STATISTICS
CONTAMINANTS OF POTENTIAL CONCERN USED IN THE RISK
ASSESSMENT
RISK ASSESSMENT CURRENT USE SOIL EXPOSURE PATHWAY.
RISK ASSESSMENT FUTURE USE SOIL EXPOSURE PATHWAY
TOXICITY DATA FOR NONCARCINOGENIC AND CARCINOGENIC
RISK EVALUATION
CARCINOGENIC RISK LEVELS
NONCARCINOGENIC RISK LEVELS
HEALTH-BASED SOIL CLEANUP LEVELS
LIST OF ARARS AND TBCs
BREAKDOWN OF COSTS ASSOCIATED WITH TH? SELECTED
REMEDY •
IV
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SITE NAME, LOCATION AND DESCRIPTION
The GCL Tie and Treating site occupies approximately 60 acres in
an industrial/commercial area in the Village of Sidney, on the
southwest side of Delaware County, New York (see Figure 1) . The
site includes an inactive sawmill and wood-treating facility
known as GCL Tie & Treating (the GCL property) , and three active,
light-manufacturing companies located on adjacent parcels of
land.
The site is bordered on the north by a railroad line. A
warehouse and a municipal airport are located to the north of the
railroad line. Route 8 and Delaware Avenue delineate the eastern
and southern borders of the site, respectively. A drainage ditch
and woodland area lie between Delaware Avenue and the site. The
western portion of the property abuts a small impoundment and
wetlands area. The site eventually drains via overland flow to
the Susquehanna River, which is located within one mile of the
site. In general, groundwater in the area flows in the north-
northwesterly direction, toward the Susguehanna River.
The GCL property encompasses approximately 26 acres and includes
four structures (see Figure 2) . The primary building housed the
wood pressure treatment operations including two treatment
vessels (50 feet long by 7 feet in diameter), an office, and a
small laboratory. Wood (mostly-railroad ties) and creosote were
introduced into the vessels which were subsequently pressurized
in order to treat the wood. The remaining three structures
housed a sawmill and storage space. .
Approximately 1,100 people are employed in a nearby industrial
area. About 5,000 people live within, 2 miles of the site and
depend on groundwater as their potable water supply. The nearest
residential well is within 0.5 mile of the site. Two municipal
wells, which supply the Village of Sidney with potable water, are
located within 1.25 miles of the site. A shopping plaza
consisting of fast-food restaurants and several stores is located
approximately 300 feet south of the site. Other facilities
(i.e.. a hospital, public schools, senior citizen housing, and
child care centers) are located within 2 miles of the site.
SITE HISTORY AND ENFORCEMENT ACTIVITIES
According to an analysis of historical photographs conducted by
the U.S. Environmental Protection Agency (EPA) and accounts by
local residents, wood-preserving activities at the site date as
far back as the 1940's.
The site first came to the attention of the New York State
Department of Environmental Conservation (NYSDEC) in 1986, after
one of the pressure vessels used at the GCL facility
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malfunctioned, causing a release of an estimated 30,000 gallons
of creosote. GCL representatives excavated the contaminated
surface soil and placed it in a mound; no further action was
undertaken at the time.
In September 1990, NYSDEC requested that EPA conduct a removal
assessment at the site to determine whether it was eligible for a
response action pursuant to the Comprehensive Environmental
Response, Compensation, and Liability Act (CERCLA). To assess
conditions at the site, EPA conducted sampling of the GCL Tie and
Treating facility in August 1990 and October 1990, which
complemented sampling conducted in December 1989. The sampling
data and other information obtained during the assessment process
led EPA to conclude that site conditions warranted the initiation
of a Removal Action which was initiated by EPA in March 1991.
The removal action activities included: site stabilization (e.g.'.
runoff and dust control), delineation of surface contamination,
installation of a chain-link fence, identification and disposal
of containerized (e.g., tanks and drums) and uncontainerized
(e.g., wastes in sumps) hazardous wastes, segregation and staging
of approximately 6,000 cubic yards of contaminated soil and wood
debris for disposal, and development of a pilot study to
determine the effectiveness of composting for bioremediation of
creosote-contaminated soils.
The site was proposed for inclusion on the National Priorities
List (NPL) in February 1994 and was added to the NPL in May 1994.
EPA has been conducting a search for Potentially Responsible
Parties (PRPs). EPA has identified one PRP to date, and is
investigating to determine whether there may be other PRPs.
After EPA completes its investigation, EPA plans to take
appropriate enforcement action to recover its response costs
pursuant to section 107(a) of CERCLA, 42 U.S.C. § 9607(a).
HIGHLIGHTS OF COMMUHITY PARTICIPATION
The Focused Feasibility Study (FFS) report and the Proposed Plan
for the site were released to the public for comment on July 30,
1994. These documents were made available to the public in the
administrative record file at the EPA Docket Room in Region II,
NY -and the information repository at the Sidney Memorial Library
in Sidney, NY. The notice of availability of the above-
referenced documents was published in the Tri-Town News and the
Oneonta Daily Star on August 3, 1994 and August 5, 1994,
respectively. The public comment period on these documents was
held from July 30, 1994 to August 29, 1994.
On August 9, 1994, EPA and NYSDEC conducted a public meeting at
the Civic Center in Sidney, NY, to inform local officials and
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interested citizens about the Superfund process, to review
current and planned remedial activities at the site, and to
respond to any questions from area residents and other attendees.
Responses to the comments received at the public meeting and in
writing during the public comment period are included in the
Responsiveness Summary (see Appendix V).
SCOPE AND ROLE OF OPERABLE UNIT
The GCL Tie & Treating site was selected as a pilot project for
the Superfund Accelerated Cleanup Model (SACM) initiative. Under
this pilot, activities which would normally have been performed
sequentially (e.g., site assessment, NPL placement, removal
assessment) Were performed concurrently. In June 1993, while
attempting to determine if the site would qualify for inclusion
on the NPL, EPA initiated a remedial investigation and
feasibility study (RI/FS) and FFS activities to delineate further
the nature and extent of contamination at the site.
The remediation of the GCL-property soils represents the first of
two planned operable units for the site, as described below..
e Operable unit 1 addresses only the contaminated soils on the
GCL-property portion of the site and is the focus of this
document.
• Operable unit 2 addresses the contamination in the soils on
the remainder of the site (referred to as non-GCL property),
and in the groundwater, surface water, and sediments at the
site. To assess the contamination in these media and
identify remedial alternatives,*EPA is conducting an RI/FS
which is scheduled for completion by the end of 1994.
SUMMARY OF SITE CHARACTERISTICS
A detailed assessment of the nature and extent of soil
contamination on the GCL-property portion of the site was
performed as part of the FFS. Approximately 200 trenches,
ranging from 2 to 14 feet in depth, were excavated (see Figure
3). Soil samples were collected from the trenches and analyzed
for organic and inorganic contaminants. The soil investigation
focussed on contaminants typically associated with the creosote
wood-preserving process. These contaminants include numerous
polyaromatic hydrocarbons (PAHs), dibenzofuran, carbazole, and
phenol. Table 1 presents a summary of the contaminants most
frequently detected'as part of the FFS and removal assessment
investigations. Table 2 presents a comprehensive summary of the
contaminants detected at the site and their corresponding
statistics.
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Nature and Extent of Contamination
The site investigation data showed numerous occurrences and high
concentrations of PAHs in the GCL-property soils. The locations
with the highest concentrations of contaminants corresponded to
areas in the vicinity of the former process building. .Maximum
concentrations for the total PAHs were generally higher in the
surface soils (up to 37,700 parts per million [ppm]), than in the
subsurface layers (971 ppm). Some of the PAHs detected include:
benzo[a]anthracene (2,400 ppm), chrysene (2,200 ppm),
benzo[b]fluoranthene (1,200 ppm), benzo[k]fluoranthene (470 ppm),
benzo[a]pyrene (700 ppm), indeno[l,2,3-c,d]pyrene (93 ppm), and
dibenzo[a,h]anthracene (44 ppm).
In comparison to the PAHs, there were few occurrences of
volatiles, noncreosote-related semi-volatiles, pesticides or
PCBs. For these contaminant groups, methylene chloride (0.2
ppm), chloroform (0.5 ppm), 2-butanone (1 ppm), 1,1,1-
trichloroethane (I ppm), benzene (0.1 ppm), toluene (3 ppm),
xylenes (8 ppm), dibenzofuran (33 ppm), and total volatiles (17.8
ppm) were detected in significant concentrations. The highest
concentrations of these non-PAH organics were generally present
in the same sample locations as the highest PAH concentrations.
Inorganics were rarely present at concentrations greater than
twice their respective background concentrations. The exception
was one sampling location (SA35.) where lead (346 ppm) and
chromium (115 ppm) were detected at the highest concentrations.
Creosote compounds are known to contribute to dense nonaqueous
phase liquid (DNAPL) contamination at wood-preserving sites.
Although the presence of DNAPL wa§ noted at three soil sampling
locations (Trench A, stations 13, 14 ,and 15) out of more than
200, total PAH levels in the remaining locations did not indicate
the presence of DNAPL. The discovery of free creosote product in
only one of the monitoring wells installed at the site indicates
the limited presence of a DNAPL area.
Contaminants concentrations were compared with soil cleanup
levels developed to protect human health. Benzo[a]pyrene was the
contaminant which exceeded its health-based soil cleanup level
most frequently. Generally, the concentrations of other
contaminants exceeded their respective health-based cleanup
levels in locations where the health-based cleanup level for
benzo[a]pyrene was exceeded.
Volume of Contaminated Soil
During the long history of operations at this site, portions of
the GCL property (i.e., areas formerly occupied by wetlands) were
backfilled with non-native materials. The results of the soil
investigations indicate that the fill consisted predominantly of
dirt, but also included wood debris (creosote-treated and
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untreated), sawdust, rocks, metal parts, old tires, and other
assorted debris. The fill material thickness ranges from 2 to 6
feet, increasing in thickness as it gets closer to the wetlands.
In some areas of the site, the non-native fill material lies
below the groundwater table, which ranges from 5 to 8 feet below
grade. Cross sections of the fill material are presented on
Figures 4 through 8. ...
It is estimated that approximately 36,100 cubic yards of soil and
debris contain contaminants in concentrations exceeding health-
based cleanup levels. Wood debris is estimated to account for
one third of the total volume of this material.
SUMMARY OF SITE RISKS
Based upon the results of the soil investigation, a baseline risk
assessment was conducted to estimate the risks associated with
current and future site conditions. The baseline risk assessment
estimates the human health and ecological risk which could result
from the contamination at the site, if no remedial action were
taken.
Human Health Risk Assessment
A four-step process is utilized for assessing site-related human
health risks for a reasonable maximum exposure scenario: Hazard
Identification—identifies the contaminants of concern at the
site based on several factors such as toxicity, frequency of
occurrence, and concentration. Exposure Assessment—estimates -
the magnitude of actual and/or potential human exposures, the
frequency and duration of these exposures, and the pathways
(e.g.. ingesting contaminated'soil) By which humans are
potentially exposed. Toxicity Assessment—determines the types
of adverse health effects associated with chemical exposures, and
the relationship between magnitude of exposure (dose) and
severity of adverse effects (response) . Risk Characterization—
summarizes and combines outputs of the exposure and toxicity
assessments to provide a quantitative assessment of site-related
risks.
EPA conducted a baseline risk assessment to evaluate the
potential risks to human health and the environment associated
with the GCL property in its current state. The Risk Assessment
focused on contaminants in the soil which are likely to pose
significant risks to human health and the environment. A summary
of the contaminants of potential concern in soils is listed in
Table 3.
An exposure assessment was conducted for reasonable maximum
exposures to estimate the magnitude, frequency, and duration of
actual and/or potential exposures to the contaminants of
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potential concern present in soils. Reasonable maximum exposure
is defined as the highest exposure that is reasonably expected to
occur at the site for individual and combined pathways. The
baseline risk assessment evaluated the current health effects
which could potentially result from ingestion, inhalation and
dermal contact of soils by site trespassers, and the inhalation
and dermal contact of soils by off-site residents and workers
(see Table 4). The future-use scenario evaluated the same
scenarios and also evaluated the potential health impacts
resulting .from., ingest ion, inhalation and direct contact by future
on-site workers (see Table 5). The current land use of the
property is industrial/commercial. Input from the community and
local officials, indicated that industrial/commercial use of the
property would continue to be the preferred use of the property
in the future. Therefore, it was assumed that future land use of
the property would continue to be industrial/commercial.
Under current EPA guidelines, the likelihood of carcinogenic
(cancer-causing) and noncarcinogenic effects due to exposure to
site chemicals are considered separately. It was assumed that
the toxic effects of the site-related chemicals would be
additive. Thus, carcinogenic and noncarcinogenic risks
associated with exposures to individual compounds of concern were
summed to indicate the potential risks associated with mixtures
of potential carcinogens and noncarcinogens, respectively.
Potential carcinogenic risks were evaluated using the cancer
slope factors developed by EPA for the contaminants of concern.
Cancer slope factors (SFs) have been developed by EPA's
Carcinogenic Risk Assessment Verification Endeavor for estimating
excess lifetime cancer risks associated with exposure to
potentially carcinogenic chemicals. ,SFs, which are expressed in
units of (mg/kg-day)"1, are multiplied by the estimated intake of
a potential carcinogen, in mg/kg-day, to generate an upper-bound
estimate of the excess lifetime cancer risk associated with
exposure to the compound at that intake level. The term "upper
bound" reflects the conservative estimate of the risks calculated
from the SF. Use of this approach makes the underestimation of
the risk highly unlikely. The SFs for the compounds of concern
in the soil are presented in Table 6.
For known or suspected carcinogens, EPA considers excess upper-
bound individual lifetime cancer risks of between 10"1 to 10* to
be acceptable. This level indicates that an individual has not
greater than a one in ten thousand to one in a million chance of
developing cancer as a result of site-related exposure to a
carcinogen under the specific exposure conditions at the site.
The total potential current and future carcinogenic health risks
from exposure to site soil are: 6.3 x 10"* for off-site children
residents, 2.7 x 1CT1 for off-site adult residents, 9.6 x 1CT4 for
off-site workers, 2.7 x 10" for children trespassers, and 2.7 x
10" for adult trespassers. In addition, under the future-use
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scenario, the potential carcinogenic health risk to the on-site
workers is 9.6 x 10"4. These risk numbers mean that approximately
one worker out of a thousand would be at risk of developing
cancer if the site were not remediated. Hence, the risks to
workers from carcinogens at the site are outside the acceptable
risk range of 10"4 to 10"6 (see Table 7). The estimated total
risks are primarily due to PAHs, which contributed over 95% to
the carcinogenic risk calculations. These estimates were
developed by taking into account various conservative assumptions
about the likelihood of a person being exposed to the soil (see
Tables 5 to 16 of the FFS Risk Assessment Report, dated April
1994). For example, it was assumed that a children trespasser
would ingest 200 mg/day of contaminated soils, 130 days a year,
for 6 years.
Noncarcinogenic risks were assessed using a hazard index (HI)
approach, based on a comparison of expected contaminant intakes
and safe levels of intake (Reference Doses). Reference doses
(RfDs) have been developed by EPA for indicating the potential
for adverse health effects. RfDs, which are expressed in units
of milligrams/kilogram-day (mg/kg-day), are estimates of daily
exposure levels for humans which are thought to be safe over a
lifetime (including sensitive individuals). The reference doses
for the compounds of concern at the site are presented in Table
6. Estimated intakes of chemicals from environmental media
(e.g.. the amount of a chemical ingested from contaminated
drinking water) are compared to the RfD to derive the hazard
quotient for the contaminant in the particular medium. The HI is
obtained by adding the hazard quotients for all compounds across
all media that impact a particular receptor population. An HI
greater than 1.0 indicates that the potential exists for
noncarcinogenic health effects to occur as a result of site-
related exposures. The HI provides a useful reference point for
gauging the potential significance of multiple contaminant
exposures within a single medium or across media.
It can be seen from Table 8 that the His for noncarcinogenic
effects from ingestion, inhalation, and dermal contact
'(reasonable maximum exposure) is less than 1.0, therefore,
noncarcinogenic effects .are unlikely to occur from the exposure
routes evaluated in the Risk Assessment.
Ecological Risk Assessment
The ecological risks associated with this site will be addressed
as part of the second operable unit RI/FS. The second operable
unit will evaluate, among other things, impacts to nearby surface
water (wetlands) as well as terrestrial receptors.
Uncertainties
The procedures and inputs used to assess risks in this
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evaluation, as in all such assessments, are subject to a wide
variety of uncertainties. In general, the main sources of
uncertainty include:
• environmental chemistry sampling and analysis
• environmental parameter measurement
o . fate and transport modeling
• exposure parameter estimation
« toxicological data
Uncertainty in environmental sampling arises in part from the
potentially uneven distribution of chemicals in the media
sampled. Consequently, there is significant uncertainty as to
the actual levels present. Environmental chemistry-analysis
error can stem from several sources including the errors inherent
in the analytical methods and characteristics of the matrix being
sampled.
Uncertainties in the exposure assessment are related to estimates
of how often an individual would actually come in contact with
the chemicals of concern, the period of time over which such
exposure would occur, and in the models used to estimate the
concentrations of the chemicals of concern at the point of
exposure. •
Uncertainties in toxicological data occur in extrapolating both
from animals to humans and from high to low doses of exposure, as
well as from the difficulties in assessing the toxicity of a
mixture of chemicals. These uncertainties are addressed by
making conservative assumptions concerning risk and exposure
parameters throughout the assessment. As a result, the Risk
Assessment provides upper-bound estimates of the risks to
populations near the site, and is highly unlikely to
underestimate actual risks related to the site.
More specific information concerning public health risks,
including a quantitative evaluation of the degree of risk
associated with various exposure pathways, is presented in the
Risk Assessment Report.
Actual or threatened releases of hazardous substances from this
site, if not addressed by implementing the response action
selected in the ROD, may present an imminent and substantial
endangerment to the public health, welfare, or the environment.
REMEDIAL ACTION OBJECTIVES
Remedial action objectives are specific goals to protect human
health and the environment. These objectives are based on
available information and standards such as applicable or
relevant and appropriate requirements (ARARs) and risk-based
8 . .
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levels established in the risk assessment.
The following remedial action objectives were established:
• Prevent public exposure to contaminant sources that present
a significant health threat (contaminated dust and soils);
and,
» Reduce the concentrations of contaminants in the soils to
levels which are protective of human health and the
environment to allow for continued industrial/commercial use
of the property. The health-based cleanup levels for
carcinogenic PAHs and total PAHs are presented in Table 9.
These cleanup levels were developed, based on the risk
assessment, to be protective of human health for future
industrial/commercial uses of the property. If these levels
are achieved, individuals would have less than a one in a
hundred thousand chance of developing cancer as a result of
exposure to the contaminated soils over a 25-year period
under specific exposure conditions at the site.
DESCRIPTION OF REMEDIAL ALTERNATIVES
Section 121(b)(1) of CERCLA, 42 U.S.C. §9621(b)(1), mandates that
a remedial action must be protective of human health and the
environment, be cost-effective, and utilize permanent solutions
and alternative treatment technologies or resource recovery
technologies to the maximum extent practicable. Section
121(b)(1) also establishes a preference for remedial actions
which employ, as a principal element, treatment to permanently
and significantly reduce the 'volume, *toxicity, or mobility of the
hazardous substances, pollutants and"contaminants at a site.
Section 121(d) of CERCLA 42, U.S.C. §9621(d), further specifies
that a remedial action must attain a level or standard of control
of the hazardous substances, pollutants, and contaminants, which
at least attains ARARs under federal and state laws, unless a
waiver can be justified pursuant to section 121(d)(4) of CERCLA,
42 U.S.C. §9621(d)(4).
Eight alternatives, namely, no action, limited action, capping,
thermal desorption, off-site incineration, on-site incineration,
composting, and bioslurry treatment were evaluated during the
screening phase of the FFS. In the spirit of the SACM initiative
and relying on the Agency's technology selection guidance for
wood-treating sites, EPA considered technologies which have been
consistently selected at wood-preserving sites with similar
characteristics (e.g., types of contaminants present, types of
disposal practices, environmental media affected) during the ~ "
development of remedial alternatives. The historical information
acquired from evaluating and cleaning up these sites, combined
with specific data for the GCL property (e.g., soil cleanup
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goals) was used to streamline the investigation and the
identification of remedial activities. Technologies such as
bioremediation (e.g., composting, bioslurry) and incineration,
although frequently selected at wood-preserving sites, were
eliminated during the alternative screening phase. A site-
specific pilot-scale treatability study concluded that composting
would not meet the health-based cleanup goals developed for the
GCL-property soils. Bioslurry and incineration were screened out
because they would be much more costly to implement than the
preferred alternative, while achieving similar levels of
protectiveness. As a result, this ROD evaluates in detail, two
remedial alternatives for addressing the contaminated soil and
debris associated with the GCL-property portion of the site. As
referenced below, the time to implement a remedial alternative
reflects only the time required to construct or implement the
remedy and does not include the time required to design the
remedy, negotiate with responsible parties, procure contracts for
design and construction, or conduct operation and maintenance at
the site.
The remedial alternatives are:
Alternative 1: No Action
Capital Cost: Not Applicable
0 & M Cost: $54,600'per year, $20,000 for each
five-year review
Present Worth Cost: $720,700 (over 30 years)
Implementation Time: Not Applicable
»
The Superfund program requires that the No Action alternative be
considered as a baseline for comparisbn with other alternatives.
The No Action alternative for the soil at the GCL site would
consist of a long-term monitoring program. Soil in the
contaminated area would be monitored semi-annually for total PAHs
and benzo[a]pyrene. For cost-estimation purposes, it was assumed
that ten surface soil samples would be collected and analyzed
semi-annually.
Because this alternative would result in contaminants being left
on-site above health-based levels, the site would have to be
reviewed every five years per the requirements of CERCLA. These
five-year reviews would include the reassessment of human health
and environmental risks due to the contaminated material left on-
site, using data obtained from the monitoring program.
Alternative 2: Thermal Desorption
Capital Cost: $14,839,000-
O & M Cost: Not Applicable
Present Worth .Cost: ..$14,839,000
Implementation Time: 12 months
10
-------
Under this alternative, a total of 36,100 cubic yards of
contaminated soil and wood debris would be excavated and treated
by a thermal desorption process. The total treatment volume
includes 30,100 cubic yard of excavated material in addition to
6,000 cubic yards of previously staged soil/debris.
Institutional controls would be recommended to ensure that in the
future the property is used for industrial/commercial purposes.
A typical thermal desorption process would consist of a feed
system, thermal processor, and gas-treatment system (consisting
of an afterburner and scrubber, a carbon adsorption system or a
.condenser). Screened soil and shredded/crushed materials would
be placed in the thermal processor feed hopper. Because of the
combustible nature of the wood chips, nitrogen or steam may be
used .as a transfer medium for the vaporized PAHs to minimize the
potential for fire. The gas would be heated and then injected
into the thermal processor at a typical operating temperature of
700°F - 1000°F. PAH contaminants of concern and moisture in the
contaminated soil would be volatilized into gases, then treated
in an off-gas treatment system. Treatment options for the off-
gas include burning in an afterburner (operated to ensure
complete destruction of the PAHs), adsorbing contaminants onto
activated carbon or collection through condensation followed by
off-site disposal. If an afterburner were used, the treated
off-gas would be treated further in the scrubber for particulate
and acid-gas removal. Thermal desorption typically achieves
approximately 98 to 99 percent reduction of PAHs in soil.
The contaminated soil/debris would be thermally treated at a rate
of approximately 30 tons per hour/ This treatment rate would be
accomplished with a single high-capacity unit or two or more
smaller units operating concurrently/ The treatment unit
configuration would depend on the residence time and other
operating parameters determined during the treatability-study
stage of the design. Actual treatment of the contaminated soils
is expected to take approximately one year.
A post-treatment sampling and analysis program would be
instituted in order to ensure that contamination in the soil had
been reduced to below the risk-based cleanup levels. Treated
soils which still exceeded the action levels would be
recirculated through the treatment unit in order to further
reduce contamination. Treated soil achieving action levels would
be redeposited in excavated areas. To replace any volume lost by
thermal destruction of wood debris, treated soil would be mixed
with clean fill obtained from an off-site source, which would
also serve to restore the geotechnical stability to the soils.
The homogenized mixture would then be covered with a 6-inch layer
of topsoil. After the-excavated areas are filled, the surface
would then be graded to promote drainage and seeded to prevent
erosion. Site structures (e.g., former process buildings) would
be decontaminated, demolished and disposed of off-site. Residual
11
-------
waste from.,.the treatment process and excavation activities (e.g.,
wastewater collected during dewatering operations or DNAPLs
encountered during excavation) would be treated on-site and/or
disposed off-site at a facility permitted to handle such wastes.
As a contingency, wood debris classified as nonhazardous under
the Resource.Conservation and Recovery Act (RCRA) could also be
disposed off-site at a facility permitted to burn creosote-
treated wood for energy generation (See Public Acceptance and
Documentation of Significant Changes sections below) .
It is assumed that both F034 and U051 RCRA listed hazardous
wastes are present at the GCL property. However, once the soils
are treated to health-based levels, they would no longer contain
listed- hazardous wastes and could be safely redeposited on-site
without triggering land disposal restrictions (LDRs) or delisting
issues.. .The,.GCL property would be ..considered a corrective action
management unit for the purpose of implementing this alternative.
A list of ARARs and To-Be-Considered (TBC) guidance pertinent to
this alternative is provided in Table 10.
SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
In selecting a remedy, EPA considered the factors set out in
section 121 of CERCLA, 42 U.S.C. §9621, by conducting a detailed
analysis of-the viable remedial alternatives pursuant to the NCP,
40 CFR §300.430(e)(9) and OSWER Directive 9355.3-01. .The
detailed analysis consisted of an assessment of the alternatives
against each of nine evaluation criteria and a comparative
analysis focusing upon the relative performance of each
alternative against those criteria.
*
. j.
The following "threshold" criteria must be satisfied by.any
alternative in order to be eligible for selection:
1. Overall protection of human health and the environment
addresses whether or not a remedy provides adequate
protection and describes how risks posed through each
exposure pathway (based on a reasonable maximum exposure
scenario) are eliminated, reduced, or controlled through
treatment, engineering controls, or institutional controls.
2. Compliance with ARARs addresses whether or not a remedy
would meet all of the applicable (promulgated by a state"or
federal authority), or relevant and appropriate requirements
(that pertain to situations sufficiently similar to those
encountered at a Superfund site such that their use is well
suited to the site) of federal and state environmental
statutes or provide grounds for invoking a waiver.
The following "primary balancing" criteria are used to make
comparisons and to identify the major trade-offs between
12
-------
alternatives:
3. Long-term effectiveness and permanence refers to the ability
of a remedy to maintain reliable protection of human health
and the environment over time, once cleanup goals have been
met. It also addresses the magnitude and effectiveness of
the measures that may be required to manage the risk posed
by treatment residuals and/or untreated wastes.
4. Reduction of toxicity, mobility, or volume via treatment
refers to a remedial technology's expected ability to reduce
the toxicity, mobility, or volume of hazardous substances,
pollutants or contaminants at the site.
5. Short-term effectiveness addresses the period of time needed
to achieve protection and any adverse impacts on human
health and the environment that may be posed during the
construction and implementation periods until cleanup goals
are achieved.
6. Implementabilitv refers to the technical and administrative
feasibility of a remedy, including the availability of
materials and services needed.
7. Cost includes estimated capital and operation and
maintenance costs, and the' present-worth costs.
The following "modifying", criteria are considered fully after the
formal public comment period on the-Proposed Plan is complete:
»
8. State acceptance indicates whether, based on its review of
the RI/FS and the Proposed Plan,* the State supports,
opposes, and/or has identified any reservations with the
preferred alternative.
9. Community acceptance refers to the public's general response
to the alternatives described in the Proposed Plan and the
RI/FS reports. Community acceptance factors to be discussed
below include support, reservation, and opposition by the
community.
A comparative analysis of the remedial alternatives based upon
the evaluation criteria noted above follows.
• Overall Protection of Human Health and the Environment
Alternative 1 would not meet any of the remedial action
obj ectives and thus would not be protective of human health or
the environment. Contaminated soils would remain on-site and
risks associated with exposure to the soils would remain
unaltered.
13
-------
Alternative 2, involving excavation and thermal desorption of
contaminants, would reduce the public health risks associated
with direct contact, ingestion, and inhalation of contaminated
soil. This alternative would also minimize the potential
leaching of contaminants from the soil into groundwater and
surface water. Treated material is expected to meet the cleanup
levels and would be considered nonhazardous. This alternative
would result in overall protection of human health and the
environment, since risk-based cleanup levels would be achieved.
• Compliance with ARARs
Alternative 1 would comply with all associated action-specific
ARARs, since no action will be taken.
Alternative 2 would be designed and implemented to satisfy all
the ARARs identified for the site. Excavation activities would
be conducted in compliance with the Occupational Safety and
Health Administration (OSHA) standards, soil erosion and sediment
control requirements, stormwater discharge requirements and air
pollution control regulations pertaining to fugitive emissions
and air quality standards. Residual waste from the treatment
process would be treated on-site and/or disposed off-site at an
EPA-approved treatment, storage and disposal facility (TSDF).
The remedy will comply with other applicable ARARs, including:
RCRA Standards Applicable to Transport of Hazardous Waste, NY Air
Quality Standards, NY Hazardous Waste Manifest System Rules, and
NY Hazardous Waste Treatment, Storage, and Disposal Facility
Permitting Requirements. A full list of ARARs and TBCs (e.g. ,
advisories, criteria, and guidance) pertinent to this alternative
is provided in Table 10.
*
• • j-
• Long-Term Effectiveness and Permanence
Alternative 1 would only involve monitoring of contamination at
the site and does not provide for removal and/or treatment of
contaminants. Therefore, this alternative would not reduce the
long-term risks to human health and the environment associated
with the GCL portion of the site.
Alternative 2 would provide long-term protection by permanently
reducing contaminant levels in site soils to health-based cleanup
levels. This alternative would reduce the levels of PAH
contaminants in soils by 98 percent to 99 percent. Soil cover
and revegetation would provide protection against erosion. No
long-term monitoring would be required.
• Reduction in Toxicity, Mobility, or Volume via Treatment
Alternative 1 would not reduce toxicity, mobility or volume of
PAHs in site soils; minimal reduction in contaminant levels may
be achieved by natural attenuation.
14
-------
It is expected that Alternative 2, thermal desorption, would
remove 98 to 99 percent of the PAHs from the soils, thereby
significantly reducing the toxicity, mobility and volume of
contaminants. Residuals (e.g.. scrubber water or spent carbon)
generated from the thermal desorption process would be treated
on-site or transported off-site to a TSDF for treatment and/or .
disposal. If feasible and cost-effective, creosote contaminated
wood debris would be utilized as a resource via burning in a
facility permitted to burn creosote-treated wood for energy
generation, thereby reducing the mobility, toxicity or volume of
the contaminants in this material.
• Short-Term Effectiveness
The implementation of Alternative 1 would not pose any additional
risks to the community, since this alternative does not involve
any major construction. Workers involved in periodic sampling of
site soils would be exposed to minimal risks because appropriate
health and safety protocols would be followed for this activity.
For purposes of this analysis, monitoring of the site would occur
for 30 years.
Alternative 2 includes activities such as excavation, screening,
shredding and handling of contaminated soils and debris which
could result in potential exposure of workers and residents to
fugitive dust. In order to minimize potential short-term
impacts, the area would be secured and access would be restricted
to authorized personnel only. In addition, dust control measures
such as wind screens and water sprays would be used to minimize
fugitive dust emissions from material handling. The risk to
workers involved in the remediation would also be minimized by
establishing appropriate health and safety procedures and
preventive measures, (e.g.. enclosed'cabs on backhoes and proper
personal protection equipment) to prevent direct contact with .
contaminated materials and ingestion/inhalation of fugitive dust.
All site workers would be OSHA certified and would be instructed
to follow OSHA protocols.
Under Alternative 2, short-term impacts on the environment from
removal of vegetation and destruction of habitat are expected to
be minimal. Erosion and sediment control measures such as silt
curtains and berms would be provided during material handling
activities to control migration of contaminated materials to
surface waters via runoff from the site. Some increase.in
traffic and noise pollution would be expected from site
activities. Short-term impacts may be experienced for about a
year which is the estimated time for construction and remedial
activities.
• Implementabilitv
Alternative 1 does not involve any major site activities other
15
-------
than monitoring and performing five-year reviews. These
activities are easily implemented.
Alternative 2 can be easily implemented, as the technology is
proven and readily available. The enhanced volatilization
component of this alternative has been shown to be effective for
destruction of PAHs and is commercially available. Sufficient
land is available at the site for operation of a mobile thermal
desorption system and supporting facilities. Performance tests
would be required for the thermal desorption process to define
optimum operating conditions. Thermally treated soils would be
placed back into the excavated areas. The treated soils may need
to be mixed with clean fill to restore geotechnical stability and
restore existing grades on the property. Implementation of this
alternative requires the restriction of access to the site during
the remediation process. Coordination with state and local
agencies would also be required during remediation. The
availability of facilities permitted to burn creosote-treated
wood for energy generation at the time of the remediation can not
be ascertained at this time, however, it is likely.that one would
be available to treat segregated wood debris. If a facility is
not available or if it is not cost-effective, the wood debris
would treated in the on-site thermal unit.
o Cost
Alternative 1 is the less expensive alternative, but does not
provide treatment of contaminated soils. Alternative 1 has a
present worth cost of $720,700 which is associated with
conducting a sampling and analyses program and five-year reviews
over a 30-year period. The preseflt worth cost of $14.8 million
for Alternative 2 provides for the on-site treatment of 36,100
cubic yards of contaminated soil using a proven technology.
o State Acceptance
The State of New York has concurred with the selected remedy.
• Community Acceptance
The public has generally accepted the selected remedy, however,
some members also have urged that materials on site be used as a
resource if possible and have suggested that creosote-treated
wood debris be separated and burned at a facility permitted to
burn creosote-treated wood for energy generation (See discussion
under Documentation of Significant Changes section below).
SELECTED REMEDY
EPA and NYSDEC have determined, after reviewing the alternatives
and public comments, that Alternative 2 is the appropriate remedy
for the site, because it best satisfies the requirements of
16
-------
section 121 of CERCLA, 42 U.S.C. §9621, and the NCP's nine
evaluation criteria for remedial alternatives, 40 CFR
§300.430(e)(9). The capital and present worth costs for this
remedy are $14,839,000. There are no operation and maintenance
costs associated with the remedy.
The major components of the selected remedy are as follows:
• Excavation and treatment of approximately 36,100 cubic yards
of contaminated soils/debris (with the possible exception of
wood debris as noted below) on-site through a thermal
desorption process; the expected depth of excavation ranges
from 2 to 8 feet below grade, and will include excavation of
non-native soils and debris located below the water table
which exceed health-based cleanup levels;
o Replacement of the treated soils (mixed with clean fill as
necessary) to the excavated areas, followed by coyer with 6
inches of clean fill, grading and revegetating; arid
o Demolition and off-site disposal of existing structures on
the GCL property which are either contaminated or would
interfere with the remediation of the GCL property soils.
Residual waste from the treatment process and excavation
activities (e.g., wastewater collected during dewatering
operations or DNAPLs encountered during excavation) would be
treated on-site and/or disposed off-site at a facility permitted
to handle such wastes.
9
As a contingency, wood debris classified as nonhazardous under
the Resource Conservation and Recovery" Act (RCRA) could also be
disposed off-site at a facility permitted to burn creosote-
treated wood for energy generation.
In addition, EPA will recommend to local agencies that
institutional control measures be undertaken to ensure that land
use of the property continues to be industrial/commercial.
Remediation Goals
The purpose of this response action is to control risk posed by
direct contact with soils and to minimize migration of
contaminants to surface water arid groundwater. The results of
the risk assessment indicate that existing site conditions pose
an excess lifetime cancer risk of 9.6 x 10~* to workers exposed to
contaminated soils. This risk is due to the PAH concentrations
in soils. This remedy will address all soils contaminated with
PAHs in excess of the health-based soil cleanup levels developed
for this site and listed in Table 9. PAH contamination remaining
in soils after treatment corresponds to an excess lifetime cancer
risk for future site workers of 10"5. Since no federal or state
17
-------
ARARs exist for soil, the cleanup level for the PAHs in,soil-was
determined through a site-specific analysis to be protective at
the 10"5 excess cancer risk level for each contaminant of concern.
It was assumed that future land use of the site will continue to
be industrial/commercial. The health-based. cleanup levels for
the soils area as follow:
Contaminant .. Concentration
Benzo[a]anthracene 78
Benzo[a]pyrene 8
benzo[b]fluoranthene 78
Benz o [ ]c ] f luoranthene 7 8
•'• Dibenzo [ a, h] anthracene 8
Indeno[l,2,3-c,d]pyrene . 78
Total PAHs 500
STATUTORY DETERMINATIONS
As previously noted, section 121(b)(1) of CERCLA, 42 U.S.C.
§9621(b) (1), mandates that a remedial action must be protective
of human health and the environment, be cost-effective, and
utilize permanent solutions and alternative treatment
technologies or resource recovery technologies to the maximum
extent practicable. Section 121(b)(1) also establishes a
preference for remedial actions which employ treatment to
permanently and significantly reduce the volume, toxicity, or
mobility of the hazardous substances', pollutants, or contaminants
at a site. Section 121(d) of CERCLA, 42 U.S.C. §9621(d), further
specifies that a remedial action must attain a degree of cleanup
that satisfies ARARs under federal and state laws, unless a
waiver can be justified pursuant to section 121(d)(4) of CERCLA,
42 U.S.C. §9621(d)(4). As discussed below, EPA has determined
that the selected remedy meets the requirements of section 121 of
CERCLA, 42 U.S.C. §9621.
Protection of Human Health and the Environment
The selected remedy is considered fully protective of human .. .
health and the environment. The treatment of the contaminated
soils and debris through a thermal desorption process will remove
the organic contaminants from the soil. Treatment of the soils ...
will result in the elimination of the potential direct human
health threats posed by the soils, and will eliminate potential
long-term sources of groundwater and surface water contamination.
Compliance with ARARs
At the completion of the response action, the selected remedy
will have complied with all applicable ARARs, including:
18
-------
Action-Specific ARARs:
• National Ambient Air Quality Standards for Hazardous Air
Pollutants
• RCRA - Land Disposal Restrictions
• RCRA - Standards Applicable to Transport of Hazardous Waste
• RCRA - Standards for Owners/Operators of Permitted Hazardous
Waste Facilities
• RCRA - Preparedness and Prevention
• RCRA - Contingency Plan and Emergency Procedures
• DOT - Rules for Transportation of Hazardous Materials
• New York State Hazardous Waste Manifest System Rules
• New York State Hazardous Waste Treatment Storage and
Disposal facility Permitting Requirements
• OSHA - Safety and Health Standards
• OSHA - Record keeping, Reporting and related Regulations
Chemical-Specific ARARs:
• None applicable.
Location-Specific ARARs:
• None applicable.
A full list of ARARs and TBCs (e.g.. advisories, criteria, and
guidance) being utilized is provided in Table 10.
Cost-Effectiveness
The selected remedy is cost-effective in that it provides overall
effectiveness proportional to its cost. The total capital cost
of the remedy is $14,839,000; no long-term operation and
maintenance costs are expected. With respect to the total cost,
approximately 50% of the cost is attributed to excavation,
backfilling, soil conditioning (e.g., crushing, dewatering), and
other miscellaneous activities (e.g.. building demolition and
disposal);-the remaining 50% is attributed to processing the"'
waste in the thermal desorption unit. A breakdown of the costs
associated with this remedy is provided in Table 11.
19
-------
Utilization of Permanent Solutions and Alternative Treatment (or
Resource Recovery) Technologies to the Maximum Extent Practicable
The selected remedy utilizes permanent solutions and treatment
technologies to the maximum extent practicable via the use of the
thermal desorption technology. The option to burn creosote
contaminated wood debris at a facility permitted to burn
creosote-treated wood for energy generation complies with the
preference for remedies that incorporate resource-recovery. The
selected remedy provides the best balance of trade-offs among the
alternatives with respect to the evaluation criteria.
Preference for Treatment as a Principal Element
In keeping with the statutory preference for treatment as a
principal element of the remedy, the remedy provides for the
treatment of contaminated soils and debris which constitute the
principal threat known to exist at the site.
DOCUMENTATION OP SIGNIFICANT CHANGES
There are no significant changes from the preferred alternative
presented in the Proposed Plan. However, based upon suggestions
raised by members of the public, the preferred remedy has been
modified to reflect the public preference that contaminated soil
or debris be utilized as a resource to the greatest extent
practicable. The selected remedy calls for creosote-contaminated
wood debris to be segregated and burned off-site at a facility
permitted to burn creosote-treated wood for energy generation
pending the availability of such a facility and assuming this
would still be a cost-effective measure at the time the remedial
action is undertaken.
20
-------
APPENDIX I
FIGURES
-------
FIGURE 1. GCL TIE & TREATING SITE LOCATION MAP
', *••/AV/I
: A. . • ! i V •
-------
FIGURE 2. GCL PROPERTY PLAN
"_>
SAWMl
-
PROCESS
BtfflJJlNC
.SOt-MOUND.
-SEE ENLARGED VIEW
/-
V.--
\J
.
/r i ?:cisv i
.' i F?:AW£ SJW. i
II
:DRIP AREA:
-CREOSOTE-UKE
,STORAGE TANKS
-CREOSOTE-UKE^
i SLUDGE TANK
PRESSURE TANKS!
fi
fl 0 I
A n 1
l| V
CD
AUXILIARY
ROOM
>*•>»
t i
f ~^^
) ^-^
omen
r i f i r e.r.
ENLARGED VIEW
-------
FIGURE 3. TRENCH LOCATIONS
-------
1000-1
' 995-
985-
980-
875-1
GCL TIE & TREATING SITE
TRENCH LINE A
SOUTHWEST
NORTHEAST
STATION 50
NUMBER I
45
I
40
I
35
I
JO
I
25
I
20
15
I
10
I
5
I
STAINED FILL
^^^=^^==^^^_-^L^J-_-^-_ _
— —»- — — _ _ _ _ _ ___ -j^—
LEGEND:
® SAMPLE LOCATION
JL CBOUNOWATER ENCOUNTERED
80 0 80
HORIZONTAL SCALE IN FEET
160
U.S. ENVIRONMENTAL PROTECTION
AGENCY
CCL TIE Ic TREATING SITE
FIGURE
TRENCH LINE A
-------
SOUTHWEST
STATION J6
NUMBER |_
30
GCL TIE & TREATING SITE
TRENCH LINE B
25
20
15
10
NORTHEAST
lOOO-i
5
<
3
995-
990-
985-
980 J
LEGEND:
® SAMPLE LOCATION
JL GROUNDWAIER ENCOUNTERED
80 0 80
3E
HORIZONTAL SCALE IN FEET
160
U.S. ENVIRONMENTAL PROTECHON
AGENCY
CCL TIE it TREATING SITE
'• FIGURE 5
TRENCH LINE B
-------
STATION
NUMBER
WEST
JO
GCL TIE & TREATING SITE
TRENCH LINE C
25
20
15
10
EAST
I
lOOO-i
995-
3
jji 990-
I
I
905-
980-1
LEGEND:
® SAMPLE LOCATION
_Y_ CnOUNOWATER ENCOUNTERED
80 0 80
• UJ U
HORIZONTAL SCALE IN FEET
160
U.S. ENVIRONMENTAL PROTECTION
AGENCY
CCL TIE A TREATING SITE
FIGURE
FRENCH LINE C
-------
SOUTHWEST
STATION 60
NUMBER |
GCL TIE & TREATING SITE
TRENCH LINE D
NORTHEAST
55
50
45
35
30
25
_JL_
20
15
10
1000
995-
rf
*
I
»•
£ 990
r
|
4
985-
980 -J
"-*• - «"0r«SrS-
lECENO:
® SAMPLE LOCATION
JL CROUNDWATER ENCOUNTERED
SO 0 80
HORIZONTAL SCALE IN FEET
160
U.S. ENVIRONMENTAL PROTECTION
AGENCY
GCL HE fc TREATING SITE
FIGURE 7
TRENCH LINE 0
-------
GCL TIE & TREATING ^SITE
: STATION 5
NUMBER I
TRENCH LINE E
SOUTH NORTH
• « 3 2 I
J
TRENCH LINE ;F
SOUTHWEST NORTHEAST
STATION
NUMBER
1000 -i
995-
uj ggo-
Z
985-
980-
LEGEND:
® SAMPLE LOCATION
T CROUNDWATER ENCOUNTERED
80 0 80 160
HORIZONTAL SCALE IN FEET
U.S. ENVIRONMENTAL PROTECIION
AGENCY
GCL TIE & TREAnNG SITE
FIGURE O
TRENCH LINE E k F
-------
FIGURE 9. EXCAVATION CONTOURS FOR THE SOIL REMEDIATION
-------
APPENDIX II
TABLES
-------
TABLE 1
SUMMARY OF CONTAMINANTS MOST FREQUENTLY
DETECTED DURING THE FFS AND REMOVAL ASSESSMENT
CONTAMINANT
Methylene Chloride
2-Butanone
1,1,1-Trichloroethane
Benzene
Toluene
Xylenes
Choloroform
Dibenzofuran
Naphthalene
2-MethylnaphthaIene
Acenaphthene
Fluorene
Phenanthrene
Anthracene
Fluoranthene
Pyrene
Benzo(a)anthracene
Chrysene
Benzo(b)fluoranthene
Benzo(k)fluoranthene
Benzo(b/k)fluoranthene
Benzo(a)pyrene
Indeno(l,23-cd)pyrene
Dibenzo (a,h) anthracene
Benzofe,h,i)perylene
Total PAHs
Cadmium
Chromium
Lead
CONCENTRATION (PPM)
Focused Feasibility Study
0.2
1
1
0.1
3
8
0.5
33
170
59
110
150
100
630
540'
520
160
140
46
13
120
76
22
44
20
2,323
1.0
29.3
33.5
Removal Assessment
—
...
.
»
.
m
.
„
1,600
580
2,500
4,700
10,000
6,400
11,000
8,200
2,400
2,200
UOO
470 -...'" ':'"'.-
.
700
93
38
1,600
37,700
m
m
-
-------
TABLE 2
CHEMICAL SUMMARY STATISTICS - PAH SAMPLES
GCL Tie and Treating Site
Compound
Naphthalene
Accjiaphtitylene
Acctiaphlhene
Fluorene
Phenautlirene
Anthracene
Fluoranthene
Pyreae
Demo (a) anthracene
Ctuyieoe
Benio (b/V) fluoranlhene
Beiuo (b) fluoruillieno
Benio (k) fluoranlhene
Elemo (a) pyretic
IndenoU. 2. 3-cd) pyrene
3ibeozo (a, b) anthracene
9eiuo (g. h, i) peryletie
Valid
420
418
421
425
424
426
423
422
420
428
263
163
163
419
415
421
411
Occur
191
122
186
201
254
257
307
301
254
299
160
117
58
231
191
128
185
Undelecl
229
296
235
224
170
169
116
121
166
129
103
46
105
188
224
293
226
Estimated
112
86
100
109
98
108
94
91
95
90
69
• 10
11
84
85
78
. 100
Reject
14
14
13
9
10
8
11
12
14
6
8
0
0
15
19
13
23
Frequency
Delected
0.45
0.29
0.44
0.47
0.60
0.60
0.73
0.71
0.60
0.70
0.61
0.72
0.36
0.55
0.46
0.30
0.45
Minimum
Concentrollon
Delected
12.00
22.00
20.00
18.00
18 .00
27.00
25.00
19.00
4.20
14.00
44.00
110.00
70.00
24.00
40.00
49.00
6.70
Maximum
Concentration
Delected
6.792B+07
410000.00
4.037B+07
3.682B+07
8.695B+07
1. 665111 07
5.535B+07
4.S35B+07
1.3630+07
1.403E+07
120000.00
7.06IB+06
2.109E+06 .
4.398B+0).
'Ilic "x" imlic.iles llial the 95% Upper Confidence Limit is greater then the maximum tteleclcil ctmccnlrnlinn.
-------
TABLE 2
CHKMICAL SUMM ARV STATISTICS - SI5MI-VOLATILE ORGANIC SAMPLES (RXCLUDINC, PAHS)
GCL Tic and Treating Slle
Compound
Phenol
bii(2-njoioel)iyl)ellic(
2-Cliloropltcnol
1, 3'Dichlcrobeuzcne
1 , 4'r)ichlorobcnzctie
1,2-Dicliloro benzene
2-Melhylphenol
2,2*-oxybUn-Ctiloruf>ropiinc)
4-Mclliyl|iheiiol
^•NiucdoJi-n-propylaiiiinB
lie zicliloroc thane
NitroUlttenc
fophoiotie
2-Nitrcitticnui
2, 4.Diiiielhyl)ilKiitJ
>ii(2-Qilorocl)ioxy)uK italic
2.4 l)kliluu|Ji:iiul
. 2, 4Tricltluobciucnc
l-Oilorojuuliiic
IcXJclilorobulatliclK
4-CIJoio-3 Mtll.ylplKiiol
2-McdiyUi«|*l)ulci«:
lexacalorocyclopcntailiciie
.4.c-Tri<:liJoiuf4Ki>J
,4,5-Trichloiopnend
-CUofompulhilene
•Nitfconiline
)uiKlliylj4il1ulile
,6-Dilliuololueitf
-Niuoeniliue
,4-Dmiiru|ilicmJ
4-NivlieiKj
)ibcazofurto
,4-Duii(Aj4otuciK
Dielhylpbltullle
4-CUoroplruyl plienylclher
-Nilrouuliiie
4,£Diuilro-2-MelhylplicncJ
'-Niuxaodjplienylunuie
•Dromopheoyl pttcnylciher
exBcblofubenzcne
'cnuchlorophenol
Cafbazolc
ViUd
29
27
27
27
27
27
29
27
V)
27
27
27
»
27
29
27
27
27
29
27
27
27
27
27
27
27
29
27
27
29
27
27
29
27
29
27
28
29
27
27
27
27
29
Occur
2
0
a
0
0
0
3
a
2
a
a
0
0
0
2
a
0
0
2
0
0
13
0
a
a
a
2
0
0
2
0
a
15
a
2
0
1
2
0
0
0
1
13
Undelecl
27
27
27
27
27
27
26
27
27
27
27
27
27
27
27
27
27
27
27
27
27
14
27
27
27
27
27
27
27
27
27
27
14
27
27
27
27
27
27
27
27
26
16
Eilllhaled
0
0
0
0
0
0
1
0
0
0
0
0
0
0
0
0
a
. 0
a
0
0
10
0
0
0
0
0
0
a
a
0
0.
10
a
0
0
a
0
0
0
0
i
10
Rcjecl
0
a
o
0
0
0
0
0
0
a
0
0
a
0
0
0
0
0
0
0
0
0
0
a
Jo
1 0
0
0
0
0
0
0
0
0
0
0
a
0
0
0
0
a
0
Frequency
Delected
0.07
0.00
0.00
0.00
000
0.00
0.10
000
0.07
0.00
0.00
000
o.oo
0.00
007
000
0.00
0.00
o.o;
0.00
0.00
0.48
0.00
0.00
0.00
0.00
0.07
o.oo
000
0.07
0.00
0.00
0.52
0.00
0.07
0.00
0.04
0.07
0.00
0.00
0.00
0.04
0.4S
Minimum
Concentration
Delected
1.3980*06
0.00
0.00
0.00
0.00
0.00
95.00
0.00
1.887 IJI06
0.00
0.00
0.00
0.0(1
0.00
I.IMOI'IIVS
0.00
0.00
0.01)
6000.00
0.00
0.00
27.00
0.00
0.00
0.00
0.00
2000.00
0.00
0.00
34000.00
0.00
0.00
19.00
0.00
10000.00
0.00
0.00
47000.00
0.00
0.00
0.00
180.00
21.00
Maximum
Concentration
Delected
2.643BiOS
0.00
0.00
0.00
0.00
0.00
U2IL't06
0.00
3.348I!»06
0.00
0.00
0.00
0.00
0.00
I.671l!l06
0.00
0.00
0110
28000.00
0.00
. 0.00
56008.00
0.00
0.00 '
•i 0.00
0.00
16000.00
0.00
0.00
42000.00
0.00
0.00
3.010E«07
0.00
1 (1000.00
0.00
0.00
53000.00
0.00
0.00
0.00
180.00
9.7000 • 06
Median
190.00
190.00
190.00
190.00
190.00
190.00
190.00
190.00
190.00
190.00
190.00
190.00
190.00
190.00
19000
190.00
190.00
190.00
190.00
190.00 •
190.00
190.00
190.00
190.00
460.00
190.00
465.00
190.00
190.00
465.00
460.00
460.00
190.00
190.00
190.00
190.00
460.00
465.00
190.00
190.00
190.00
460.00
210.00
Geunttlrlc
Mean
556.45
304.31
304.11
304.31
304.31
304.31
499.34
301.31
566.83
304.31
304.31
304.31
3OI.3I
304.31
542.18
.- 3M.3I
3M.3I
304.31
394.18
301.31
301.31
268.5$
304.31
3OI.3I
740.61
304.31
852.09
304.31
3OI.3I
971.33
740.61
740.61
670.76
304.31
387.19
304.31
662.73
990.15
301.31
304.31
304.31
677.75
574.28
Arlllutielrlc
Mean
139898.10
594.26
594.26
594.26
594.26
594.26
64506.21
594.26
181070.52
594.26
594.26
594.26
594.26
594.26 .
'XI OS. 00
594.26
594.26
594.26
1725.69
594.26
594.26
2-145.74
594.26
594.26
1480.93
594.26
1999.48
594.26
594.26
3999.48
1480.93
1480.93
2.052IU06
594.26
1242.93
594.26
1429.21
4827.07
594.26
594.26
594.26
1454.26
411101.52
Standard
Deflation
546819.57
1181.26
1181.26
1181.26
1181.26
1181.26
251578.74
1181.26
702523.7J
1181.26
1181.26
1181.26
1181.26
1181.26
359749.82
1181.26
1181.26
1181.26
5276.13
1181.26
1181.26
10716.51
1181.26
1181.26
3035.99
1181.26
3977.27
1181.26
1181.26
9919.29
3035.99
3035.99
7.6671!. 0
110463.642
705.554 i
705.554 «
705.554 »
705.554 <
705.554 »
569IH.I8I
705.554 *
705.554 >
705.554 »
1940.073
705.554 x
705.554 x
1934.543
705.554 i
705.554 <
1746.461 i
705.554 x
2520.501
705.554 x
705.554 i
5063.044
1746.461 x
1746/161 x
5.9IOB«06
705.554 i
1657.315
705.554 x
2023.108 «
5848.510
705.554 >
705.554 x
705.554 i
1751.136 x
377826.772
Concentrations ere given in (mils of tig/kg (ppb).
The "x" indicates dial (lie 95% Upper Confidence Limit is greater then die maximum delected concentration.
-------
TABLE 2
CHEMICAL SUMMARY STATISTICS - SEMI-VOLATILE ORGANIC SAMPLES (EXCLUDING PAHS)
GCL Tie find Treating Site
Compound
Di-D-botylphlhllilc
ButylbenzylphlhkUte
J.J'-Dithlorobenildinc
bb(2-EiliyllK«yl)Fhlhilitc
Di-itactylpblhilate
Aniline
^•PbenylbeittyluniiiB
Valid
27
27
27
27
27
2 i
2
Occur
1
0
0
2
5
2
2
Undeleel
26
27
27
25
22
a
0
Eillmilid
I
0
0
2
5
0
0
Reject
0
0
0
0
0
0
0
Frequency
Delected
0.04
0.00
0.00
0.07
0.19
1.00
1.00
Minimum
Concentration
Delected
53.00
0.00
0.00
26.00
19.00
67000.00
31000.00
Mailmum
Concentration
Detected
33.00
0.00
0.00
150.00
230.00
166000.00
152000.00
Medlin
1 90.OO
190.00
190.00
190.00
190.00
116500.00
91500.00
Geometric
Mem
289.71
304.31
304.31
299X7
233.32
105460.89
68644.01
Arllhmelrle
Mean
588.81
594.26
594.26
618.74
566.67
116500.00
91500.00
Standard
DtTlitlon
1183X8
1181.26
1181.26
1187.82 .
1191.70 '
70003 SI
85559.92
mean(y)
5.669
5.718
5.718
5.702
5.452
11.566
11.137
lldtTfj)
0.971
0.914
0.914
1X150
1.212
0.642
1.124
n(j)
27.000
27.000
27.000
27.000
27.000
1000
2.000
Lower
Quartlle
150/462
164 J89
164.289
147X77
103.021
68409.003
32151.426
Upper
Quartlle
557.820
563.683
563.683
608.113
528.405
162580.928
146556X87
tipper 95
737.787 i
705JS4 i
705.554 >
875.064 i
932.744 i
9.457E409 i
2.I93E«20 i
Concentrations are given In units of ugAg (ppb).
The "x" intlicatei dial the 9S% Upper Confidence Until Is greater then the ninxiniuin delected concentration.
-------
TABLE 2
CHEMICAL SUMMARY STATISTICS - INORGANIC SAMPLES
GCL Tie and Treating Site
Compound
Aluminum
Antimony
Anenic
Uarium
UOyllium
Cadmium
Calciutn
Chromium
Cobalt
Copper
\toa
I.Uli
Magnesium
^uigauuo
Mercury
Nickel
'oUMium
Selenium
Silver
Sudiuin
riialliutn
Vanadium
Ziiic
Cyanide
Valid
n
n
27
27
27
27
27
27
27
27
27
27
27
27
27
27
27
27
27
27
27
27
27
26
Occur
27
9
27
27
22
8
27
27
27
27
27
27
27
27
0
27
26
6
i !
27
0
27
27
2
llmlrlrcl
0
18
0
0
5
19
0
0
0
0
0
0
0
0
27
0
1
21
26
0
27
0
0
24
Estimated
0
9
14
0
0
0
0
6
0
1
0
24
0
5
0
0
0
4
0
0
0
2
|
1
lltjtcl
0
a
0
n
0
0
0
0
0
0
0
0
0
0
a .
0
0
0
a
0
0
0
0
0
Frequency
Delected
1.00
0.33
1.00
1.00
081
0.30
I.QO
1.00
1.00
1.00
1.00
1.00
1.00
1.00
0.00
1.00
0.96
0.22
0.04
1.00
0.00
1.00
1.00
0.08
Minimum
Concentration
Delected
3490.00
3.50
• 1.70
26.80
0.27
0.25
212.00
4.10
2.30
4.40
5180.00
5.40
442.00
152.00
0.00
4.10
360.00
0.22
0.46
29.70
0.00
5.00
14.40
3.20
Maximum
Concentration
Delected
14700.00
6.50
9.70
84.90
0.57
1.00
6370.00
115.00
16.30
32.80
32900.00
33.80
4490.00
890.00
0.00
41.10
mo.oo.
0.59
, 0.46
65.40
0.00
24.10
81.40
15.90
Median
10900.00
1.95
5.10
49.00
0.41
0.30
901.00
16.50
10.50
18.80
22200.00
12.50
3130.00
426.00
0.05
23.90
584.00
0.18
0.34
47.70
0.16
15.90
55.60
1.18
Geometric
Mean
9138.15
1.94
5.19
48.16
0.32
0.32
959.18
16.53
9.36
18.58
19510.83
13.51
2697.01
417.57
0.04
21.14
607.37
0.21
0.30
47.69
0.17
14.28
51.23
1.08
Arllhinelrlc
Mean
9722.22
2.53
5.65
50.61
0.36
0.38
1485.56
20.58
9.91
19.88
20764.44
14.74
2927.11
464.11
0.04
22.82
643.09
0.24
0.32
48.69
0.18
15.15
53.47
1.69
Standard
Deviation
3125.32
1.86
2.25
16.12
0.15
0.26
1603.73.
20.66
2.90
6.68
6336.23
6.83
974.08
211.46
0.02
7.71
238.30
0.15
0.10
10.00
0.04
4.91
13.79
2.97
mcun(y)
9.120
0.663
1.647
3.874
-1.136
-1.154
6.866
2.805
2.236
2.922
9.879
2.603
7.900
6.034
-3.207
3.051
6.409
-1.578
-1.208
3.865
-1.765
2.659
3.936
0.077
sldev(jf)
0.381
0.742
0.438
0.324
0.570
0.582
0.938
0.591
0.382
0.408
0.398
0.417
0.477
0.482
0.367
0.450
0.336
0.508
0.339
0.210
0.215
0.366
0.329
0.766
n(y)
27.000
27.000
27.000
27.000
27.000
27.000
27.000
27.000
27.000
27.000
27.000
27.000
27.000
27.000
27.000
27.000
27.000
27.000
27.000
27.000
27.000
27.000
27.000
26.000
Lower
Quarllle
7064.674
1.176
3.861
38.698
0.219
0.213
509.272
11.094
7.232
14.108
14913.610
10.193
1954.998
301.629
0.032
15.602
484.138
0.146
0.238
41.390
0.148
11.158
41.016
0.644
. Upper
Quarllle
11820.183
3.200
6.975
59.927
0.471
0.467
1806.543
24.639
12.115
24.479
•25525.161
• 17.896
3720.661
578.080
0.052
28.640
761.981
0.291
0.375
54.939
0.198
18.287
63.976
1.810
Upper 95
11293.527
3.504
6.726
56.979
0.472
0.471
2313.994
24.907
11.577
23.478
24442.967
17.188
3619.246
563.076
0.049 «
27.684
724.975
0.285
0.357
52.401
0.189 i
17.442
60.846
2.030
Concenlraliorx arc given iiumils of mg/kg (ppin).
'Ilic "*" iiulitnlc* llinl (he 95% I Ipper Cniifiilcncc Limit is gtunlcr (hen Ihc maximum ilelccleil coiicunlrnlinn.
-------
TABLE 2
CHEMICAL SUMMARY STATISTICS - PESTICIDE SAMPLES
GCL Tie and Treating Site
Compound
Alphi-DIIC
Oela-DlIC
Della-BIIC
Gunma-BIIC
lleplacblor
Aldrin
tleptachlor epoxide
Bodoiulfan 1
Dieldrin
DDE
Qndrin
Gndoiulfan II
ODD
Bndosulfan sulfale
DDT
Meluoxyclilor
Endrin kelone
Qndrin aldehyde
alpha-Chlotdane
gamina-Chlonlajie
foxaplieno
Aroclor-1016
Atoclor-1211
Araelor-1232
Aioclor-1242
Aioclor-1248
Aroclor-1254
Aroclor-1260
Valid
23
23
23
23
25
23
24
23
21
23
23
24
23
23
20
23
23
23
21
23
23
23
23
23
23
23
23
23
Octur
0
0
0
0
6
0
3
0
0
2
0
2
1
' 1
2
0
0
0
1
1
0
0
0
0
0
2
0
0
Undclccl
23
23
23
23
19
23
21
23
21
21
23
22
22
22
18
23
23
23
20
22
23
23
23
23
23
21
23
23
Eillmaltd
0
0
0
0
5
0
3
0
0
1
0
2
0
0
2
0
0
0
1
1
0
0
0
0
0
2
0
0
Reject
4
4
4
4
2
4
3
4
6
4
4
3
4
4
7
4
4
4
6
4
4
4
4
4
4
4
4
4
Frequency
Delected
0.00
0.00
0.00
o.oo
0.24
0.00
0.13
0.00
0.00
0.09
0.00
0.08
O.O4
0.04
0.10
0.00
0.00
o.oo
0.05
0.0-1
0.00
0.00
0.00
0.00
0.00
0.09
0.00
o.oo
Minimum
Concentration
Delected
0.00
0.00
0.00
0.00
2.00
0.00
2.50
0.00
0.00
5.00
0.00
3.70
5.80
•4.40
7.20
0.00
0.00
0.00
0.21
2.20
0.00
0.00
0.00
0.00
0.00
8.30
0.00
0.00
Maximum
Concentration
Delected
0.00
0.00
o.oo
0.00
22.00
0.00
24.00
o.oo
0.00
5.00
0.00
39.00
5.80
4.40
48.00
0.00
0.00
0.00
o.ii
2.20
0.00 '
' 0.00
o.oo
0.00
0.00
160.00
0.00
0.00
Median
1.00
1.00
1.00
1.00
1.00
1.00
1.00
1.00
1.90
1.90
1.90
1.90
1.90
1.90
1.88
10.00
1.90 .
1.90
1.00
1.00
100.00
19.00
38.50
19.00
19.00
19.00
19.00
19.00
(ieomelrlc
Mean
1.05
1.05
.05
.05
.40
.05
.32
.05
2.05
2.34
2.04
2.37
2.14
2.12
2.48
10.54
2.04
2.04
0.98
1.08
105.38
20.43
41.50
20.43
20.43
21.65
20.43
20.43
Arlllimefrlc
Mean
1.10
1.10
1.10
1.10
2.21
1.10
2.25
1.10
2.15
3.00
2.13
3.73
2.29
2.23
4.63
11.00
2.13
2.13
1.06
1.14
110.00
21.26
43.26
21.26
21.26
26.95
21.26
21.26
Standard
Deviation
0.43
0.43
0.43
0.43
4.18
0.43
4.71
0.43
0.84
3.63
0.80
7.56
1.11
0.93
10.31
4.34
0.80
0.80
0.49
0.49
43.43
8.00
16.83
8.00
8.00
30.20
8.00
8.00
mean(j)
0.052
0.052
0.052
0.052
0.338
0.052
0.274
0.052
0.720
0.852
0.714
0.862
0.762
0.750
0.908
2.355
0.714
0.714
-0.023
0.079
4.658
3.017
3.726
3.017
3.017
3.075
3.017
3.017
ftdev(,)
0.262
0.262
0.262
0.262
0.711
0.262
0.750
0.262 .
0.265
0.554
0.254
0.658
0.334
0.300
0.794
0.262
0.254
0.254
0.444
0.303
0.262
0.254
0.258
0.254
0.254
0.538
0.254
0.254
n(r)
23.000
23.000
23.000
23.000
25.000
23.000
24.000
23.000
21.000
23.000
23.000
24.000
23.000
23.000
20.000
23.000
23.000
23.000
21.000
23.000
23.000
23.000
23.000
23.000
23.000
23.000
23.000
23.000
Loner
Quarllle
0.883
0.883
0.883
0.883
0.868
0.883
0.793
0.883
1.719
1.613
1.721
1.519
1.710
1.729
1.451
8.831
1.721
1.721
0.724
0.882
88.310
17,211
34.866
17.211
17.211
15.055
17.211
17.211
Upper
Quarllle
1.258
1.258
1.258
1.258
2.266
1.258
2.181
1.258
2.457
3.408
2.425
3.690
2.684
2.591
4.238
12.576
2.425
2.425
1.319
1.327
125.759
24.249
49.388
24.249
24.249
31.122
24.2-19
24.249
Upper 95
1.206
1.206
1.206
1.206
2.471
1.206
2.462
1.206
2.369
3.471
2.325
3.927
2.583
2.487
5.184
12.059
2.325
2.325
1.308
1.274
120.587
23.252
47.357
21.252
23.252
31.498
23.252
23.252
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Concentrations are given in units ofttg/kg (ppb).
Tlie "x" indicates Ilial Ilie 95% Upper Confidence l.iinil is greater then the maximum delected concentration.
-------
TABLE 2
CHEMICAL SUMMARY STATISTICS - PAH BACKGROUND SAMPLES
GCL Tie and Treating Slle
Compound
Niphtbilene
Acouphihylenc
Aceaiphlhene
Ptuoiene
PhetutDlhreno
Anthnceno
Fhionnlbene
Pyteno
Benin (•) ulhriceno
Chiyiene
Benzo (bJO Huonnlheno
Denzo (b) nuorinthene
Benzo (k) fluorantheno
9enzo (•) pyrene
adeoo (1,2,3-cd) pyieno
Dibemo (i,h) unhrtceno
Benzo ((.h.Operyleno
Villd
4
4
4
4
4
4
4
4
4
4
1
2
1
4
4
4
4
Occur
0
0
0
0
0
0
t
2
0
2
!
2
1
2
0
0
1
Undelecl
4
4
4
4
4
4
3
2
4
2
1
1
1
2
4
4
3
Estimated
0
0
0
0
0
0
. 1
2
0
•• 2
1
1
I
2
0
0
1
Rcjccl
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
Frequency
Delected
0.00
0.00
0.00
0.00
0.00
0.00
0.25
0.50
0.00
0.50
0.50
1.00
1.00
0.50
0.00
0.00
0.25
Minimum
Concentration
Delected
0.00
0.00
0.00
. 0.00
0.00
•o.oo
24.00
23.00
0.00 •
36.00 .
160.00 •
42.00
54.00
36.00
0.00
0.00 .
200.00
Minimum
Concentration
Delected
0.00
0.00
0.00
0.00
0.00
0.00
24.00
76.00
0.00
82.00
160.00
42.00
54.00
250.00
- 0.00
0.00
200.00
Medltn
175.00
175.00
175.00
175.00
175.00
175.00
165.00
120.50
175.00
123.50
162.50
113.50
119.50
175.00
175.00
175.00
185.00
(icomelrlc
Mem
174.71
174.71
174.71
174.71
174.71
174.71
104.85
85.47
174.71
97.43
162.48
88.15
99.95
128.74
174.71
174.71
183.32
Arllhmelrle
Mt«n
175.00
175.00
175.00
175.00
175.00
175.00
. 134.75
112.25
175.00
117.00
162.50
113.50
119.50
159.00
175.00
175.00
183.75
Slindird
Derlillon
11.55
11.55
11.55
11.55
11.55
11.55
74.43
76.06
11.55
70.03
3.54
101.12
92.63
89.67
11.55
11.55
14.36
mean(y)
5.163
5.163
5.163
5.163
5.163
5.163
4.653
4.448
5.163
4.579
5.091
4.479
4.605
4.858
5.163
5.163
5.211
sldev(T)
0.066
0.066
0.066 :
0.066
0.066
0.066
0.984
0.960
0.066
0.755
0.022
1.048
0.871
0.867
0.066
0.066
0.079
»(T)
4.000
4.000
4.000
4.000
4.000
4.000
4.000
4.000
4.000
4.000
2.000
2.000
2.000
4.000
4.000
4.000
4.000
Lower
Qu»rltle
167.099
167.099
167.099
167.099
167.099
167.099
53.967
44.716
167.099
58.547
160.113
43.453
55.547
71.708
167.099
167.099
173.779
Upper
Qutrtlle '
182.676
182.676
182.676
182.676
182.676
182.676
203.727
163.357
182.676
162.138
164.884
178.814
179.848
231.144
182.676
182.676
193.389
Upper 95
190.093
190.093
190.093
190.093
190.093
190.093
7129.465
4752.658
190.093
1214.929
174.924
2.57E+15
1.76E+II
3482.854
190.093
190.093
203.185
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Concentrations are given in units of ug/kg (ppb).
The "x" indicates that (he 95% Upper Confidence Limit is greater (hen the maximum detected concentration.
-------
TABLE 2
CHEMICAL SUMMARY STATISTICS - VOLATILE ORGANIC IIACKGROUNI) SAMPLES
; GCL Tie and Treating SKe
Compound
Chlofomcthane
Bromomethane
Vinyl Chloride
Chloroethaiie
Methylene Chloride
Acetone
Carbon Oiiulfide
1,1'Dichloroelliene
1,1-Dichloroelliane
1 ,2-Dichloroelhene
Chloroform
1 ,2-Dichloroelliane
2-Dutanoiie
1 .1 ,1-Trichloroelliane
Carbon Iclrachtoride
}romodichloromettiane
1.2-Dichloropropane
C'l,3-Dichloropropette
frichloroelhene
)ibromochloroinelhane
,1.2-Trichloroelhane
lenzene
1- 1 ,3-Dichloropropene
Iromoibrm
-Melhyl-2-pentanone
2-lleianone
'elrachloroelhene
,1 ,2,2-Telrachloroelliane
'oluene
Thloro benzene
ilhylbenzene
Slyrene
ylenes
Valid
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
Occur
0
0
0
0
2
0
0
0
0
0
2
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
2
0
2
0
0
0
0
Undcltcl
2
2
2
2
0
2
2
2
2
2
0
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
0
2
0
2
2
2
2
Estimated
0
0
0
0
0
0
0
0
0
0
2
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
. 0
: 0
2
0
0
0
0
Rtjtcl
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
a
0
0
0
0
0
0
0
Frequency
Delected
0.00
0.00
0.00
0.00
1.00
0.00
o.oo
0.00
0.00
0.00
1.00
0.00
0.110
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
1.00
0.00
1.00
0.00
0.00
0.00
• '0.00
Minimum
Concentration
Delected
0.00
0.00
0.00
0.00
26.00
0.00
0.00
0.00
0.00
0.00
4.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00 -
0.00
0.00
0.00
0.00
0.00
0.00
13.00
0.00
3.00
0.00
0.00
0.00
0.00
Maximum
Concentration
Delected .
0.00
0.00
0.00
0.00
26.00
0.00
0.00
0.00
0.00
0.00
4.00
0.00
O.CIO
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
15.00
0.00
3.00
0.00
0.00
0.00
0.00
Median
5.50
5.50
5.50
5.50
26.00
7.25
5.50
5.50
5.50
5.50
4.00
5.50
5.50
5.50
5.50
5.50
5.50
5.50
5.50
5.50
5.50
5.50
5.50
5.50
5.50
5.50
14.00
5.50
3.00
5.50
. 5.50
'5.50
5.50
Geometric
Mean
5.50
5.50
5.50
5.50
26.00
7.04
5.50
5.50
5.50
5.50
4.00
5.50
5.50
5.50
5.50
5.50
5.50
5.50
5.50
5.50
5.50
5.50
5.50
5.50
5.50
5.50
13.96
5.50
3.00
5.50
5.50
5.50
5.50
Artlhmelrlc
Mean
5.50
5.50
5.50
5.50
26.00
7.25
• 5.50
5.50
5.50
5.50
4.00
5.50
5.50
5.50
5.50
5.50
5.50
5.50
5.50
5.50
5.50
5.50
5.50
5.50
5.50
5.50
14.00
5.50
3.00
5.50
5.50
5.50
5.50
Standard
Deviation
0.00
0.00
0.00
0.00
0.00
2.47
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
o.oo
0.00
0.00
0.00
0.00
1.41
0.00
0.00
0.00
0.00 '
0.00
0.00
meanfj)
1.705
1.705
1.705
1.705
3.258
1.951
1.705
1.705
1.705
1.705
1.386
1.705
1.705
1.705
1.705
1.705
1.705
1.705
1.705
1.705
1.705
1.705
1.705
1.705
1.705
1.705
2.636
1.705
1.099
1.705
1.705
1.705
1.705
sldev(y)
0.000
0.000
0.000
0.000
0.000
0.348
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.101
0.000
0.000
0.000
0.000
0.000
0.000
»).
'Mie "»" imlicnlcs Ilia! the 95% Upper Confidence I Jmil is .greater then (lie maximum delected concentration.
-------
TABLE 2
CHEMICAL SUMMARY STATISTICS - VOLATILE ORGANIC SAMPLES
GCL Tie and Treating Site
Compound
Chloromeili'ano
Dromoinelliane
Vinyl Chloride
Chloroclliane.
Mediylene CliloriJc
Acetone
Cftjbon Diiutfide
1,1-Dichloroelliene
1,1-Dichloroethane
1 ,2-Dicliloroelheiic
Chloroform
1,2-Dicliloroelliane
2-Rulanone
1,1,1-TrtcMoroeihane
Cubon telrachlorido
Dcomodicliloromeihaiie
1 ,2-Dichloropropane
c- 1 ,3-Dicliloropropene
frichlofoelhene
)ibroinocliloroni
-------
TABLE 2
CHEMICAL SUMMARY STATISTICS - SEMI-VOLATILE ORGANIC BACKGROUND SAMPLES (EXCLUDING PAHS)
GCL Tie and Treating Site
Compound
N-Nib-oiodipbcnyUiniiw
4>Bromopbenyl pheoykiher
1 lexichlofobenzcne
PenUchlorophenol
Cubuale
DI-D-butytphthiUle
Butylbenzylpnihibte
3,?-Dkh)onbenzidiiK
bli(2-Blhyllmyl)phlhilite
Di-n-ortylphlhilite
Aniline
N-FbenylbenzyUnifatt
Villd
1
1
2
2
2
2
2
2
2
2
NR
NR
Occur
0
0
0
0
0
0
0
0
0
0
NR
NR
Undelccl
2
2
2
2
2
2
2
2
2
2
NR
NR
Eillmiied
0 '
0
0 '
0 •
0
0
0
0
0
0
NR
NR
Reject
0
. 0
0
0
0
0
0
0
0
0
NR
NR
Frequency
Delected
0
0
0 :
0
0
0
0
0
0
0
NR
NR
Minimum
Coneenlrtllon
Delected
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
NR
NR
Maximum
Coneenlrftflon
Delected
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
NR
NR
MedUn
185.00
185.00
185.00
447.50
185.01)
185.00
185.00
185.00
185.00
185.00
NR
NR
Geometric
Mem
185.00
185.00
185.00
447/19
185.00
185.00
185.00
185.00
185.00
185.00
NR
NR
Arllhmetric
Mem
185.00
185.00 .
185.00
447.50
185.00
185.00
185.00
185.00
185.00
185.00
NR
NR .
Slindtrd
Devil lion
0.00
0.00
0.00
3.54 .
0.00
. 0.00 '
0.00
0.00
0.00
0.00
NR
NR
mein(j)
5.220
5.220
5.220
• 6.104
. 5.220
5.220
5.220
5.220
5.220
5.220
NR
NR
ilderfr)
0.000
0.000
0.000
0.008
0.000
0.000
0.000
0.000
0.000
0.000
NR
NR
n(j)
2.000
2.000
2.000
2.000
2.000
2.000
2.000
2.000
2.000
2.000
NR
NR
l>ower
Quirllle
185.000
185.000
185.000
445.114
185.000
185.000
185.000
185.000
185.000
185.000
NR
NR
Upper
Quirlllt
185.000
185.000
185.000
449.885
185.000
185.000
185.000
185.000
185.000
185.000
NR
NR
Upper t5
185.000
185.000
185.000
459.465
185.000
185.000
185.000
185.000
185.000
185.000
NR
NR
x
i
X
X
X
X
X
X
X
X
Concentration,! are given in units of ug/kg (ppb).
The "NR" means not analyzed.
The "x" indicates dial Hie 95% Upper Confidence Limit is greater Uicti Die maximum detected concentration.
-------
TABLE 2
CHEMICAL SUMMARY STATISTICS - INORGANIC HACIUJROUND SAMPLES
CCL Tie and Treating Site
Compound
Aluminum
Antimony
Ancnic
Duhun
Beryllium
Cadmium
Calcium
Chromium
Cobalt
Copper
Iroo
Lead
Magnejium
Manganese
Mercury
Nickel
'olMjium
Selenium
Silver
Sodium
Thallium
/anadium
Zinc
Cyanide
Valid
• 2
2
2
2
2
2
2
2
2
1
2
2
1
2
2
2
2
2
2
2
2
2
2
2
Occur
2
0
2
2
2
0
2
2
2
2
2
2 .
2 '
2
0
2
2 i
o :
0
2 i
0
2
2
0 '
llndeltel
0
2
0
0
0
2
0
0
0
0
0
0
0
0
2
0
0
2
2
0
2
0
0
2
Rillmaltd
0
0
2
0
0
0
0 ,
0
0
0
0
0
0
0
0
0
0
0
0
0
0
2
0
0
Reject
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
Frequency
Delected
1.00
0.00
1.00
1.00
1.00
0.00
1.00
1.00
i.oo
1.00
1.00
1.00
1.00
1.00
0.00
1.00
1.00
0.00
0.00
1.00
0.00
1.00
1.00
0.00
Minimum
Concentrnllon
Delected
10200.00
0.00
7.311
66.90
0.38
0.00
1660.00
14.60
11.70
19.70
19700.00
6.70
3770.00
632.00
0.00
23.50
716.00
0.00
0.00
57.50
0.00
12.30
53.60
0.00
Maximum
Concentration
Delected
10400.00
0.00
8.50
76.80
0.44
0.00
15400.00
16.20
13.90
26.20
20900.00
11.20
4220.00
715.00
0.00
24.40
723.06*
0.00
" ., 0.00
73.20
0.00
13.20
57.00
0.00
Median
10300.00
1.65
7.90
71.85
0.41
0.25
8530.00
15.40
12.80
22.95
20300.00
8.95
3995.00
673.50
6.05
23.95
719.50
0.15
0.33
66.35
0.15
12.75
55.30
1.03
Ctroinelrle
Mean
10299:51
1.65
7.88
71.68
0.41
0.25
5056.09
15.38
12.75
22.72
20291.13
8.66
3988.66
672.22
. 0.05
23.95
719.49
0.15
0.33
65.76
0.15
12.74
55.27
1.02
Arllhinetrle
Mean
10300.00
1.65
7.90
71.85
0.41
0.25
8530.00
15.40
12.80
22.95
20300.00
8.95
3995.00
673.50
0.05
23.95
719.50
0.15
0.33
66.35
0.15
12.75
55.30
1.03
Standard
Deviation
141.42
0.07
0.85
7.00
O.O4
0.01
9715.65
1.13
1.56
4.60
848.53
3.18
318.20
58.69
0.00
0.64
4.95
0.00
0.02
12.52
0.00
0.64
2.40
0.04
mean(r)
9.240
0.500
2.064
4.272
•0.894
-1.387
8.528
2.733
2.546
3.123
9.918
2.159
8.291
6.511
-3.101
3.176
6.579
-1.897
-1.102
4.186
-1.897
2.545
4.012
0.024
sldev(i)
0.014
0.043
0.108
0.098
0.104
0.057
1.575
0.074
0.122
0.202
0.042
0.363
0.080
0.087
0.000
0.027
0.007
0.000
0.053
0.190
0.000
0.050
0.043
0.034
n(7)
2.000
2.000
2.000
2.000
2.000
2.000
2.000
2.000
2.000
2.000
2.000
2.000
2.000
2.000
2.000
2.000
2.000
2.000
2.000
2.000
2.000
2.000
2.000
2.000
Loner
(jiiitrllle
10204.544
1.602
7.326
67.112
0.381
0.240
; 1747.024
14.635
11.746
19.829
19726.738
6.779
3779.764
633.791
0.045
23.520
716.160
0.150
0.321
57.855
0.150
12.320
53.676
1.001
Upper
Qunrlllt
10395.369
1.698
8.470
76.557
0.439
0.260
14632.881
16.161
13.845
26.029
20871.671
11.069
4209.099
712.979
0.045
24.379
722.839
0.150
0.344
74.738
0.150
13.179
56.920
1.049
Upper 95
10785.964
1.916
12.102
104.809
0.616
O.306
1. 76012+34
20.175
21.116
65.511
23474.926
235.240
5374.214
936.622
0.045
26.218
736.207
0.150
0.401
171.660
0.150
15.200
64.347
1.154
X
X
X
X
X
X
*
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Concentrations are given in units of ing/kg (ppm).
lite "x" indicates dial the 95% Upper Confidence Limit is greater llicn (he maximum delected concentration.
-------
TABLE 2
CHEMICAL SUMMARY STATISTICS - PESTICIDE BACKGROUND SAMPLES
GCL Tic and Treating Site
Compound
Alpht-DIIC
Dell-BIIC
nclli-DIIC
Gunnu-UUC
Ueplichlor
Aldrin
llcpuchlor epoxide
Bndosulfan I
[)ieldfin
ODE
Undilll
Endojulfaii II
DDD
tadosulfan sulfato
DDT
Meilioiyctilor
Endiin ketono :
Endt in tldchydc
ilpbi-Chlorduie
gunnu-Cblonltiie
Toupheae
Aroclor-1016
Aroclor-1221
Aioclor-1232
Araclur-12-12
Aroclor-1248
Arocloi-1254
Afaclor-1260 .
Valid
2
2
2
1
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
Occur
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
(Indued
2
2
2
2
1
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
Eillmitcd
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
•o
0
0
0
0 '
0
0
0
0
0
Reject
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
Frequency
Delected
0.00
0.00
0.00
0.00
0.00
0.00
o.oo
0.00
0.00
o.oo
0.00
0.00
0.00
o.oo
o.oo
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
o.oo
o.oo
o.oo
0.00
Minimum
Concentration
Delected
0.00 •
0.00
0.00
0.00
0.00
0.00
0.00
o.oo
0.00
0.00
0.00
0.00
o.oo
0.00
o.oo
o.oo
o.oo
o.oo
0.00
0.00
0.00
0.00
0.00
0.00
11.00
0.00
o.oo
0.00
Maximum
Concentration
Delected
. 0.00
0.00
o.no
o.oo
o.oo
o.oo
o.oo
o.oo
o.oo
o.oo
o.oo
o.oo
o.oo
o.oo
o.oo
0.00
0.00"
0.00
'' , 0.00
0.00
0.00
0.00
0.00
. • o.oo
0.00
0.00
0.00
o.oo
Median
0.95
0.95
0.95
0.95
0.95
0.95
0.95
. 0.95
1.85
1.85
1.85
1.85
1.85
1.85
1.85
9.50 .
1.85
1.85
0.95
0.95
95.00
18.50
37.25
18.50
18.50
18.50
18.50
18.50
Geometric
Mean
0.95
0.95
0.95
0.95
.0.95
. 0.95
. 0.95
• 0.95
1.85
. 1.85
1.85
1.85
1.85
1.85
. 1.85
9.50
1.85
1.85
0.95
0.95
95.00
18.50
37.25
18.50
18.50
18.50
18.50
18.50
Arllhinetrlc
Mean
0.95
0.95
0.95
0.95
0.95
0.95
0.95
0.95
1.85
1.85
1.85
1.85
1.85
1.85
1.85
9.50
1.85
1.85
0.95
0.95
95.00
18.50
37.25
18.50
I8.5H
18. SO
18.50
18.50
Standard
Deviation
. 0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
.0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.35
0.00
0.00
o.oo
0.00
0.00
meanly)
-0.051
•0.051
-0.051
.0.051
-0.051
•0.051
•0.051
-0.051
0.615
0.615
0.615
0.615
0.615
0.615
0.615
2.251
0.615
0.615
-0.051
-0.051
4.554
2.918
3.618
2.918
2.918
2.918
2.918
2.918
Jldev(r)
0.000
0.000
0.000
0.01)0
0.000
0.000
0.000
0.000
0.000
0.000
o.ooo
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.009 .
0.000
o.ooo
0.000
0.000
o.ooo
n(r>
2.000
2.000
2.000
2.000
2.000
2.000
2.000
2.000
2.000
2.000
1.000
2.000
2.000
2.000
2.000
2.000
2.000 '
2.000
2.000
2.000
2.000
2.000 •
2.000
2.000
2.000
2:000
2.000
2.000
Lower
Quarllle
0.950
0.950
0.950
0.950
• 0.950
0.950
0.950
0.950
1.850
1.850
1.850
1.850
1.850
1.850
1.850
9.500
1.850
1.850
0.950
0.950
95.000
18.500
37.011
18.500
18.500
18.500
18.500
18.500
Upper
Quarllle
0.950
0.950
0.950
0.950
0.950
0.950
0,950
0.950
1.850
1.850
1.850
1.850
1.850
1.850
1.850
9.500
1.850
1.850
0.950
0.950
95.000
18.500
37.488
18.500
18.500
IB. 500
18.500
18.500
Upper 95
0.950 x
0.950 x
0.950 i
0.950 i
0.950 x
0.950 x
0.950 >
0.950 x
1.850 x
1.850 x
1.850 x
1.850 x
1.850 x
1.850 x
1.850 x
9.500 x
1.850 x
1.850 x
0.950 x
0.950 x
95.000 . x
18.500 x
37.300 x
18.500 x
18.500 x
18.500 x
18.500 x
18.500 x
Concentrations are given in units ofug/kg (ppli).
The "x" indicates thai (lie 95% I Ipper Confidence Ijniii is greater then the maximum delected concentration.
-------
TABLE 3
GCL TIE & TREATING SITE
CHEMICALS OF POTENTIAL CONCERN
ORGANIC
Acenaphthylene
Anthracene
Benzo(a)anthracene
Benzo(a)pyrene
Benzo(b)fluoranthene
Benzo(k)fluoranthene
Chrysene
Dibenz(a,h)anthracene
Flouranthene
Fluorene
Indeno (l,2,3-cd)pyrene
Pyrene
Aniline
Bis(2-ethylhexyl)phthalate
4-Chloroaniline
2,4-Dimethylphenol
Di-n-octylphthalate
Napthalene
Chloroform
Phenol
Ethylbenzene
Methylene Chloride
Tetrachloroethene
'Toluene
Xylenes
Aroclor 1248 (PCB)
Chlordane
DDE
DDT
Heptachlor
Heptachlor Expoxide
INORGANIC
Arsenic
Chromium
D006S.LYN
-------
TABLE 4
GCL TIE & TREATING SITE
RISK ASSESSMENT CURRENT USE SOIL EXPOSURE PATHWAYS
Current Use Receptors •
Primary Source Secondary Source
Off-Sile Residents
Child Adult
Current Use Receptors
Off-Sile Workers
Sile Trespassers
Child Adult
Industrial and —>
Commercial Activities
Spill/Discharge
Soil
Ingeslion
Dermal Contact
Inhalation
X
X
X
X
X
X
X
X
X
X
-------
TABLE 5
GCL TIE & TREATING SITE
RISK ASSESSMENT FUTURE USE SOIL EXPOSURE PATHWAYS
Future Use Receptors
Primary Source
Secondary Source
Off-Site Rcsidenls Site Trespassers
Child Aclnll Off-Site Workers On-Site Workers Child Adult
Industrial and ->
Commercial Activities
Spill/Discharge
Soil
Ingestion
Dermal Contact
Inhalation
X
X
X
X
X
X
X
X
X
X
X
-------
TABLE 6
GCL TIE & TREATING SITE
TOXICITY DATA FOR NONCARCINOGENIC
AND CARCINOGENIC RISK EVALUATION
Sheet 2 of 2
Chemical Name
Semi-Volaliles
(Cont'd)
.
Inorganics
Denzo(a)pyrene
Dibenz(aji)an(hracene
Bis(2-ethylhexyl)phthalate
Di-n-octylphthalate
Phenol •
2,4-Dimelliylphennl
4-Cliloroaniline
Aniline
Heptachlor
lleptaclilor epoxiclc
DDE1
DDT
alpha-Chlordane
Aroclor 1248 (PCDs)
Arsenic
Chromium HI
Cliromium VI
Noncarcinogenic Reference Doie
RfD RfC RiD
(oral) (inhalation) (inhalation)
(mg/Kg/day) mg/Cu.ni) . (mg/Kg-day)
-
.
2.0E-02
2.0E-02
6.0E-OI
2.0E-02
4.0E-03
.
5.0E-04
I.3E-05
.
5.0E-04
6.0E-05
.
3.00E-04
l.OOfi+00
5.00E-03
- ' •
.
.
.
.
.
.
l.OE-2
.
-*
•
.
.
.
.
.
-
-
.
.
. .
.
.
.
2.86E-03
.
.
.
.
.
.
.
.
-
Carcinogen Slope Factor
SP Weight Unit Risk SF Weight
(Oral) of (Inhalation) (Inhalation) of
(mg/Kg-day)-t Evidence (ug/Cu.m)-l (mg/Kg-day)- Evidence
7.3E+00
TEF-I.O
1.4E-02
.
.
.
.
.
4.5E+00
9.1 Ei CO
3.4E-OI
3.4E-OI
I.3E+00
7.7E+00
I.75E+00
.
-.
D2
B2
B2
.
-
.
-
.
.
.
.
.
.
.
A
.
-
-
-
.
-
-
.
.
.
.
.
.
.
.
.
4.30E-03
•„
I.I7F.-02 '
6.IE+00
. •
.
.
• - •
.
.
-
.
.
.
.
.
.
I.50E+05
.
4.IOE+01
B2
-
i
.
.
.
.
.
.
'
.
.
A
_
A
EPA Weight of Evidence classifications are as follows:
Group A: Human Carcinogen. Sufficient evidence from epidemiologic studies to support a casual association between exposure and cancer.
Group Dl: Probable Human Carcinogen. Limited evidence of carcinogenicity in human from epidemiological studies.
Group U2: Probable Human Carcinogen. Sufficient evidence of carcinogenicity in animals. Inadequate evidence of carcinogenicity in huniani.
Group C: Possible Human Carcinogen. Limited evidence of carcinogenicity in animals.
Group D: Not classified. Inadequate evidence of carcinogenicity in animals.
Note: - No data/Not available.
-------
TABLE 7
CARCINOGENIC RISK LEVELS
SUMMARY ACROSS EXPOSURE PATHWAYS
PRESENT/FUTURE USE SCENARIOS
EXPOSURE TO SOIL
Adult Trespassers
1) Inhalation
2) Ingestion ' ... '
3) Dermal Contact
TOTAL
Older Child Trespassers
1) Inhalation
2) Ingestion
3) Dermal Contact
TOTAL
On-Site Worker
1) Inhalation
2) Ingestion
3) Dermal Contact
TOTAL
Off-Site Worker
1) Inhalation
2) Ingestion
TOTAL
CARCINOGENIC RISK LEVELS
(REASONABLE MAXIMUM
EXPOSURE)
3.49 X10"6
2.67x10*
1.98 X1CT7
2.71 x 10*
1.09 xirj6
2.67 x 10*
5.51 x 10* -
2.68x10*
2.60 x 1Q-6
9.54 x 10*
5.09 x 1Q-8
9.57 x 10*
2.60 X 10*
9.54 x 10*
9.57 x 10*
-------
TABLE 8
NONCARCINOGENIC RISK LEVELS
SUMMARY ACROSS EXPOSURE PATHWAYS
PRESENT/FUTURE USE SCENARIO
EXPOSURE TO SOIL
Adult Trespassers
1) Inhalation
2) Ingestion
3) Dermal Contact
TOTAL
Older Child Trespassers
1) Inhalation
2) Ingestion
3) Dermal Contact
TOTAL
On-Site Worker
1) Inhalation
2) Ingestion
3) Dermal Contact
TOTAL
Off-Site Worker
1) Inhalation
2) Ingestion
TOTAL
NONCARCINOGENIC HAZARD
INDEX VALUES
(REASONABLE MAXIMUM EXPOSURE)
8.67 x ID"4
4.94 xlO'2
*
5.03 X 10'2
1.08 x 10*
1.98 x 10'1
*
1.99 x 10'1
6.19 x 1C"4
1.69 x 10'1
*
1.70 x 10'1
6.19 x 10-4
1.69 x 10'1
•-l.7Q.xlO-1 - ' - -
No noncarcinogenic dermal contact chemicals of concern
-------
TABLE 9
HEALTH-BASED SOIL CLEANUP LEVELS
COMPOUND
Benzo (a) anthracene
Benzo(a)pyrene
Benzo (b)fluoranthene
Benzo(k)fluoranthene
Dibenzo(a,h)anthracene
Indeno(l,2,3-c,d)pyrene
Total PAHs
RISK-BASED
CLEANUP LEVEL
(PPM)
78
8
78
78
8
78
500
-------
TABLE 10
LIST OF APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS (ARARS)
AND TO-BE-CONSIDERED (TBC) FOR THE SELECTED REMEDY
APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS'
National Ambient Air Quality Standards for Hazardous Air Pollutants (NAAQS) 40 CFR 61
RCRA- Land Disposal Restrictions (40 CFR 268)
RCRA- Standards Applicable to Transport of Hazardous Waste
(CFR 263.11, 263.20-21 and 263.30-31)
RCRA- Standards for Owners/Operators of Permitted Hazardous Waste Facilities
(40 CFR 264.10-264.18) ;
RCRA- Preparedness and Prevention (40 CFR 264.10-264.18)
RCRA- Contingency Plan and Emergency Procedures (40CFR 264.50-264.56) '•
DOT- Rules for Transportation of Hazardous Materials (4p CFR Parts 107, 171.1-172.558)
New York State Hazardous Waste Manifest System Rules (6NYCRR 372) ;
*
New York Hazardous Waste Treatment Storage and Disposal Facility Permitting Requirements
(6 NYCRR 370 and 373)
TO-BE-CONSIDERED2
New York State Air Emission Requirements (6 NYCRR 364 and 372)
OSHA- Safety and Health Standards (29 CFR 1926)
OSHA- Record keeping, Reporting and Related Regulations (29 CFR 1904)
REGULATORY
LEVEL
Federal
Federal
Federal
Federal
Federal
Federal
Federal
NY State
NY State
REGULATORY
LEVEL
NY State
Federal
Federal
1 Environmental statutes promulgated by a federal or state authority.
2 Advisories, criteria, and guidance of federal or state origin.
-------
TABLE 11
ALTERNATIVE 5: EXCAVATION AND SCREENING/ON-SITE THERMAL DESORPTION/
BACKFILL WITH TREATED SOIL AND CLEAN OFF-SITE SOIL
CAPITAL COST ESTIMATES (1994 DOLLARS)
Sheet I of 2
FACILITY/CONSTRUCTION
I. SITE PREPARATION
I. Warning Signs
2. Fence Completion
3. Equipment Parking and Storage Area
II.
III.
SUPPORT FACILITIES
I. Office Trailer
2.
Decontamination Trailer
BUILDING DECONTAMINATION, DEMOLITION
AND DISPOSAL
I. Decontamination
2. Demolition :
3. Disposal
IV. CONTAMINATED SOIL EXCAVATION
V. SCREENING/SHREDDING
VI. ON-SITE THERMAL DESORPTION
VII. DISPOSAL
VIII. CLEAN OFF-SITE BACKFILL
* All numbers arc rounded to nearest hundred.
ESTIMATED
QUANTITIES
31
1,200 If
2,500 sy
1
1
)N
84,100 flz
20,900 ft5
148 cf
36,1 00 cy
36,IOOcy
36,1 00 cy
36,1 00 cy
6,676 cy
MATERIAL
UNIT
PRICE COST
80
18
8
14,300
• 42,900
Included
Included
Included
Included
Included
Included
Included
Included
2,500
21,600
20,000
: 14,300
42,900
in installation
in installation
in installation
in installation
in installation
in installation
in installation
in insinuation
INSTALLATION
UNIT DIRECT CONST1
PRICE COST COST*
20
8
4
Included
Included
11.5
27
18
25
600
9,600
10.000
967,200
564,300
2,700
902,500
3,100
31,200
30;()00
I4,3(K)
42,900
967,200
564,300
2,700
902,500
Included in Item IV
200
10
28
7,220,000
361,000
186,900
7,220,000
361,000
186,900
W0792.I.YN
-------
TABLE 11
ALTERNATIVE 5: EXCAVATION AND SCRF1NING/ON-SITE THERMAL DESORPTION/
BACKFILL WITH TREATED SOIL AND CLEAN OFF-SITE SOIL
FACILITY/CONSTRUCTION
IX. TOPSOIL COVER
X. TREATABILITY STUDY
CAPITAL COST ESTIMATES (1994 DOLLARS)
MATERIAL
INSTALLATION
Sheet 2 of 2
ESTIMATED
QUANTITIES
5,324 cy
I
UNIT
PRICE
40
Included
COST
213.000
in installation
UNIT
PRICE
10
60,000
COST
53.200
60.000
DIRECT CONST
COST*
266,200
60.000
XI. HEALTH AND SAFETY
XII. MOBILIZATION/DEMOBILIZATION
Lump Sum Included in installation
Lump Sum Included in installation
250,000 NA
90,000 NA
250.000
90,000
Total Direct Construction Cost (TDCC)
Contingency @ 20% of TDCC
Engineering @ 10% of TDCC
Legal and Administrative @ 5% of TDCC
Total Construction Cost
10,992,300
2,198,500
1,099,300
549.700
14,839,800
All numbers are rounded to nearest hundred.
-------
APPENDIX 111
ADMINISTRATIVE RECORD INDEX
-------
6CL TIE & TREATING SITE
OPERABLE UNIT ONE
ADMINISTRATIVE RECORD FILE
INDEX OF DOCUMENTS
3.0 REMEDIAL INVESTIGATION
3.3 Work Flans
P. 300001 - Report: .Final Field Operations Plan, Phase I
300362 Field Investigation. GCL Tie & Treating Site,
Sidney, New York, prepared by Ebasco Services
Incorporated, prepared for U.S. EPA, April 1993
P. 300363 - Report: Final Work Plan for Remedial
300466 Investigation and Feasibility Study. GCL Tie &
Treatyr? Site. Sidney, New York, prepared by
Ebasco Services Incorporated, prepared for U.S.
EPA, February 1993.
4.0 FEASIBILITY STUDY
4.3 Feasibility study Reports
P.
P.
P.
400001 - Report: Final Focused Feasibility Study Report.
400317 GCL Tie & Treating Site. Sidney. New York.
prepared by Ebasco Services Incorporated, July
1994.
>
;•
400318 - Report: Focused Feasibility Study, Baseline Risk
400467 Assessment. GCL Tie & Treating Site. Sidney, New
York, prepared by Ebasco Services Incorporated,
April 1994.
400468 - Report: Draft Final Report. Treatability Studies.
400557 GCL Tie and Treating Company. Sidney. Delaware
County. New York, prepared by Roy F. Weston, Inc.,
prepared for U.S. EPA/ERT, March 1994
-------
8.0 HEALTH ASSESSMENTS
8.3 Correspondence
P. 800001 - Memorandum to Ms. Lisa K. Voyce, ATSDR Regional
800007 Representative, U.S. EPA - Region II, from Mr.
Robert L. Williams, Ph.D., ATSDR, Department of
Health and Human Services, and Mr. Allan S.
Susten, Ph.D., DABT, ATSDR, Department of Health
and Human, Services, re: discussion of a number of
health related issues relevant to the GCL Tie and
Treating.Site, July 29, 1991.
10.0 PUBLIC PARTICIPATION
10.2 Community Relations Plans
P. 1000001 - Report: Community Relations Plan, GCL Tie &
1000012 Treating Siter Sidney^ New York, prepared by U.S.
EPA, November 1993.
10.3 Public Notices
P. 1000013 - Federal Register, National Priorities List for
1000039 Uncontrolled Hazardous.Waste Sites, Final Rule,
Volume 59, No. 103, May 31, 1994.
P. 1000040 - Federal Register, National Priorities List for
1000046 Uncontrolled Hazardous Waste Sites, Proposed Rule
No. 16, Volume 59, No. ,ir, January 18, 1994.
10.6 Fact Sheets and Press Releases
P. 1000047 - Fact Sheet: Superfund Update. GCL Tie and
1000049 Treating Superfund Site. Sidney. Delaware County.
New York, EPA to Conduct Investigation of GCL Tie
and Treating Site, prepared by U.S. EPA, August
1993.
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APPENDIX IV
STATE LETTER OF CONCURRENCE
-------
SEF-23-l?S4 15:24 -ROM NYS.EN' ;T-.CONSEP','fiTION
TO
8592687212264663?
P. 01
New York State Department of Environmental Conservation
50 Wolf Road, Albany. New York 12233-7010
SEP 2 S 1994
Langdon Marsh
Commissioner
Post-ir brand fax yansmittai memo 7671 * °* p»9«»
CO.
DCpt.
Ms. Kathleen C. Callahan
Director
Emergency & Remedial Response Division
United States Environmental Protection Agency
Region ii
26 Federal Plaza - Room 930
New York, NY 10278
Dear Ms. Callahan:
Re: GCL Tie & Treating Site ID £ 413011
Draft Record of Decision
The New York State Department of Environmental Conservation (NYSDEC) has
reviewed the draft Record of Decision (ROD) for the GCL Tie & Treating site, Operable
Unit 1, and in particular the selection of Alternative 2, Thermal Desorption. This
alternative will incorporate the following:
1. Thermal desorption of 36,100 cubic yards of contaminated soil and debris
on the GCL-property portion (Operable Unit 1) of the site;
2. Decontamination, demolition, and off-site disposal of former process
buildings;
3. Post-treatment sampling and analysis to ensure attainment of
established cleanup levels;
4. Re-deposition of treated soils in excavated areas, placement of clean
topsoil over treated soil, grading to promote drainage, seeding to establish
vegetation cover;
5. Institutional controls, including deed restrictions, to maintain current
industrial land usage, and;
6. Remedial design to determine: plans, operating specifications, and
performance parameters (including pilot studies) for the on-site thermal
desorption system; engineering controls and mitigation options for
emissions, dusts, runoff, contaminated groundwater encountered during
-------
-?-23-lr?4 15=25 ™GM NV?.rN: •!-.COu'EEr' :H~:r.K ~C c5?2S572l22S46c37 F.C2
Ms. Kathleen C. Callahan Page 2
excavation, and other residual wastes generated during the remedial
action; off-site disposal options for demolition debris and other unbeatable
residues; sampling and analytical protocols; grading and vegetation plans;
and site security and access.
The NYSDEC concurs with the selected remedy for Operable Unit 1. Our
concurrence is conditioned on the completion of the remedial design proposed for. GCL
Tie & Treating, Operable Unit 1. As discussed in the section on Implementability, the
disposal of creosote-contaminated wood debris at an off-site facility is contingent on the
availability of a facility permitted to handle such wastes and the classification of the
debris as non-hazardous.
It is understood that a Remedial Investigation/Feasibility Study is underway on
Operable Unit 2. This effort wili address contaminated soil on the remaining no'n-GCL
property portions of the site, as well as site-wide groundwater, surface water, and
sediment issues. Additionally, the New York State Department of Health (NYSDOH) is
in the process of preparing a Public Health Assessment (PHA) for the Agency for Toxic
Substances and Disease Registry (ATSDR). Available data and information about the
site, including the draft Remedial Investigation report for Operable Unit 2, is .being
reviewed to characterize .site conditions and possible existing or potential human
exposure to contaminants. NYSDOH concurrence with the draft Record of Decision will
be postponed until review of the site information is complete.
»
If you have any questions, please contact Walter E. Demick, P.E. at (518) 457-
5637.
Sincerely,
Ann Hill DeBarbieri
Deputy Commissioner
-------
APPENDIX V
RESPONSIVENESS SUMMARY
-------
Superfund Proposed Plan
GCL TIE & TREATING SITE
Operable Unit 1
Town of Sidney
Delaware County, New York
EPA
Region 2
July 1994
PURPOSE OF PROPOSED PLAN
This Proposed Plan describes the remedial
alternatives considered for the contaminated soils
and debris located on a portion of the GCL Tie &
Treating site and identifies the preferred
remedial alternative with the rationale for this
preference. The Proposed Plan was developed by
the U.S. Environmental Protection Agency (EPA), -
as lead agency, with support from the New York
State Department of Environmental Conservation
(NYSDEC). EPA is issuing the Proposed Plan as
part of its public participation responsibilities
under Section 117 (a) of the Comprehensive Envi-
ronmental Eesponse, Compensation, and Liability
Act (CERCLA) of 1980, as amended, and Section
300.430(f) of the National Contingency Plan
(NCP). The remedial alternatives summarized
here are described in a focused feasibility study
(FFS) report which should be consulted for a
more detailed description of all the alternatives.
This Proposed Plan is being provided as a
supplement to the FFS report to inform the
public of EPA's and NYSDEC's preferred remedy
and to solicit public comments pertaining to all
the remedial alternatives evaluated, as well as the
preferred alternative.
The remedy described in this Proposed Plan is
-the preferred remedy for contaminated soils and
debris on the GCL-property portion of the site.
Changes to the preferred remedy or a change
from the preferred remedy to another remedy
may be made, if public comments or additional
data indicate that such a change will result in a
more appropriate remedial action. The final
decision regarding the selected remedy will be
made after EPA has taken into consideration all
public comments. We are soliciting public
comment on all of the alternatives considered in
the detailed analysis section of the FFS because
EPA and NYSDEC may select a remedy other
than the preferred remedy.
COMMUNITY ROLE IN SELECTION PROCESS
EPA and NYSDEC rely on public input to ensure
that the concerns of the community are
considered in selecting an effective remedy for
each .Superfund site. To this end, the FFS report,
Proposed Plan, and supporting documentation
have been made available to the public for a
public comment period which begins on July 30,
1994 and concludes on August 29, 1994.
Dates to remember:
MARK YOUR CALENDAR
July 30 to August 29,1994
Public comment period on FFS report, Proposed
Plan, and remedies considered
August 9, 1994
Public meeting at the Civic Center, 21 Liberty
-Street, Sidney, NY
A public meeting will be held during the public
comment period at the Sidney Civic Center on
August 9, 1994 at 7:00 p.m. to present the
-------
conclusions of the FFS, to elaborate further on
the reasons for recommending the preferred
remedial alternative, and to receive public
comments.
Comments received at the public meeting, as well
as written comments^ will be documented in the
Responsiveness Summary Section of the Record
of Decision (ROD), the document which
formalizes the selection of the remedy.
All written comments should be addressed to:
Carlos R. Ramos, Remedial Project Manager
U.S. Environmental Protection Agency
26 Federal Plaza, Room 29-100
New York, NY 10278
Copies of the Focused Feasibility Study
Report dated July 1994, Proposed Plan, and
supporting documentation are available at
the following repositories:
Sidney Memorial Library
Main Street
Sidney, NY
Telephone: (607) 563-8021
and
U.S. Environmental Protection Agency
Emergency and Remedial Response Division
*Superfund Records Center
26 Federal Plaza, Room 2900
New York, N.Y. 10278
Telephone: (212) 264-8770
Hours: 9:00 a.m. - 5:00 p.m. (M-F)
SITE BACKGROUND
The GCL Tie and Treating site occupies
approximately 60 acres in an industrial/
commercial area on the southwest side of
Delaware County, New York. The site includes an
inactive sawmill and wood-treating facility known
as GCL Tie & Treating (the GCL property), and
three active light manufacturing companies
located on an adjacent parcel of land (see Figure
1). According to an analysis of historical
photographs conducted by EPA and accounts by
local residents, wood-preserving activities at the
site date as far back as the 1940's.
The site is bordered on the north by a railroad
line. A warehouse and a municipal airport are
located to the north of the railroad line. Route 8
and Delaware Avenue delineate the eastern and
southern borders of the site, respectively. A
drainage ditch and woodland area lie between
Delaware Avenue and the site. The western
portion of the property abuts a small
impoundment and wetlands area. The site
eventually drains via overland flow to the
Susquehanna River, which is located within one
mile of the site.
The 26 acre GCL property includes four
structures (see Figure 2). The primary building
housed the wood pressure treatment operations
including two treatment vessels (50 feet long by 7
feet in diameter), an office, and a small
laboratory. Wood (mostly railroad ties) and
creosote were introduced into the vessels which
were subsequently pressurized in order to treat
the wood.
Approximately 1,100 people are employed in a
nearby industrial area. About 5,000 people live
within 2 miles of the site and depend on
groundwater as their potable water supply. The
nearest residential well is within 0.5 mile of the
site. Two municipal wells, supplying the Village
•of Sidney, are located within 1.25 miles of the
site.^ A shopping plaza consisting of fast-food
restaurants and several stores is located approxi-
mately 300 feet south of the site. Other facilities
(i.e., a hospital, public schools, senior citizen
housing, and child care centers) are located within
2 miles of the site.
The site first came to the attention of the
NYSDEC in 1986, after one of the pressure
vessels used at the GCL facility malfunctioned,
causing a release of an estimated 30,000-gallons of
creosote. GCL representatives excavated the
contaminated surface soil and placed it in a
mound; no further action was undertaken at the
time.
In September 1990, NYSDEC requested EPA to -
conduct a removal assessment at "the site.
Consequently, EPA conducted sampling of the
GCL Tie and Treating facility in December 1989,
October 1990, and August 1990. As a result of
the data and information that were obtained as
part of the assessment, a Removal Action was
initiated by EPA in March 1991.
-------
Activities conducted as part of the removal effort
included: site stabilization (e.g., run-off and dust
control), delineation of surface contamination,
installation of a chain-link fence, identification
and disposal of containerized (e.g., tanks, drums)
and uncontainerized hazardous wastes (e.g.,
wastes in sumps); preparation of approximately
6,000 cubic yards of contaminated soil and wood
debris for disposal; and development of a pilot
study to determine the effectiveness of
composting for bioremediation of creosote-
contaminated soils.
The site was proposed for inclusion on the
National Priorities List (NPL) in February 1994 .
and was added to the NPL in May 1994.
SCOPE AND ROLE OF ACTION
The GCL Tie & Treating site was selected as a
pilot project for the Superfund Accelerated
Cleanup Model (SACM) initiative. The purpose of
SACM is to make Superfund cleanups more
timely and efficient. Under this pilot, activities
which would normally have been performed
sequentially (e.g., site assessment, NPL
placement, removal assessment) were performed
concurrently. In June 1993, while attempting to
determine if the site would score high enough for
inclusion on the NPL, EPA initiated remedial -
investigation (RI) and FFS activities to delineate
further the nature and extent of contamination at
the site. These activities would not typically have
been initiated until after the site had been
proposed to the NPL.
Site remediation activities are sometimes
segregated into different phases, or operable
units, so that remediation of different
environmental media or areas of a site can
proceed separately, resulting in an expeditious
remediation of the entire site. EPA has
designated two operable units for the GCL Tie &
Treating site as described below.
> Operable unit 1 addresses only the
contaminated soils on the GCL-property portion
of the site and is the focus of this Proposed Plan.
*• Operable unit 2 addresses the contamination
in the soils on the remainder of the site (referred
to as non-GCL property), and in the groundwater,
surface water, and sediments. To assess the
contamination in these media and identify
remedial alternatives, EPA is conducting an
RI/FS which is scheduled for completion by the
end of 1994.
SUMMARY OF CONTAMINATED SOIL
INVESTIGATION
A detailed assessment of the nature and extent of
soil contamination on the GCL-property portion
of the site was performed as part of the FFS. The
soil investigation focussed on contaminants
typically associated with the creosote wood-
preserving process. Creosote contaminants
typically found included numerous polyaromatic
hydrocarbons (PAHs) such as benzo[a]anthracene,
chrysene, benzo[b]fluoranthene, .
benzo[k]fluoranthene, benzo[a]pyrene,
indeno[l,2,3-c,d]pyrene and
dibenzo[a,h]anthracene.
Approximately 200 trenches, ranging from 2 to 14
feet in depth, were excavated. Soil samples were
•collected from the trenches and analyzed for
organic and inorganic rnntaTninflnts. A summary
of the highest concentrations of contaminants
most frequently detected during the site
investigations (FFS and removal assessment) is
-presented in Table 1.
>
The site investigation data showed numerous
occurrences and high concentrations of PAHs in
the GCL property soils. Maximum concentrations
for the total PAHs were generally higher in the
surface soils (up to 37,700 parts per million
[ppm]), than in the subsurface layers (up to 971
ppm).
In comparison to the PAHs, there were few
occurrences of volatiles, noncreosote-related semi-
volatiles, pesticides or PCBs. For these
contaminant groups, methylene chloride,
chloroform, 2-butanone, 1,1,1-trichloroethane,
benzene, toluene, xylenes, and total volatiles were
detected in significant concentrations. The
highest concentrations of these non-PAH organics
were generally present in the same sample
locations as the highest PAH concentrations.
Inorganics were rarely greater than twice their
respective background concentrations. The
highest levels found were for lead and chromium.
-------
Table 1. Summary of Contaminants Detected in the
GCL-Property Soils During the FFS and Removal Assessment
Investigations
CONTAMINANT
Methylene Chloride
2-Butanone
1,1,1-Trichloroethane
Benzene
Toluene
Xylenes
Chloroform
Dibenzofuran
Naphthalene
2-Methylnaphthalene
Acenaphthene
Fluorene
Phenanthrene
Anthracene
Fluoranthene
Pyrene
Benzo(a)anthracene
Chrysene
Benzo(b)fluoranthene
Benzo(k)fluoranthene
Benzo(b/k)fluoranthene
Benzo(a)pyrene
Indeno(l,23-cd)pyrene
Dibenzo(a,h)anthracene
Benzo(gjM)perylene
Total PAHs
-Cadmium
Chromium
Lead
CONCENTRATION
(PPM)
Focused
Feasibility
Study
0.2
1
1
0.1
3
8
0.5
33
170
59
110
150
100
630
540
520
160
140
46
13
120
76
22
44
20
2323
1.0
293
33.5
.Removal
Assessment
.
.
.
.
.
.
.
.
1,600
580
2#K)
4,700
10,000
6,400
11,000
8,200
2,400
2,200
1,200
470
.
700
93
38
1,600
37,700
.
.
-
- Not available
Contaminants concentrations were compared with
soil cleanup levels developed to protect human
health. Benzo[a]pyrene was the contaminant
which exceeded its health-hased soil cleanup level
most frequently. Generally, the concentrations of
other contaminants exceeded their respective "
health-based cleanup levels in locations where the
health-based cleanup level for benzo[a]pyrene was
exceeded.
It is estimated that approximately 36,100 cubic
yards of soil contain contaminants in
concentrations exceeding health-based cleanup
levels. Wood debris is estimated to account for
one-third (33%) of the total volume of this
material.
SUMMARY OF SITE RISK
Based upon the results of the investigations, a
baseline .risk assessment was conducted to
estimate the risks associated with current and
future site conditions. The baseline risk
assessment estimates the human health and
ecological risk which could result from the
contamination at the site, if no remedial action
were taken.
Human Health Risk Assessment
•A four-step process is utilized for assessing site-
related human health risks for a reasonable
mfl-jmrmTn exposure scenario: Hazard Identifica-
tion-identifies the contaminants of concern at the
site based on several factors such as toxicity,
frequency of occurrence, and concentration.
Exposure Assessment-estimates the magnitude of
actual and/or potential human exposures, the
frequency and duration of these, exposures, and
the pathways (e.g., ingesting pnnr.flTTnTiflf.er! well-
water) by which humans are potentially exposed.
Toxicity Assessment-determines the types of
adverse health effects associated with chemical
exposures, and the relationship between magni-
tude of exposure (dose) and severity of adverse
effects (response). Risk Characterization—
summarizes and combines outputs of the
exposure and toxicity assessments to provide a
quantitative assessment of site-related risks.
The baseline risk assessment began with selecting
contaminants of concern which would be
representative of site risks. These contaminants,
which are listed in Table 2, are known to cause
cancer in laboratory animals and are suspected to
-------
be human carcinogens. In addition, since the
current land use of the property is industrial,, and
based on input from the community and local
officials, it was assumed that future land uses of .
the property would continue to be industrial.
The baseline risk assessment evaluated the health
effects which could result from exposure to
contamination as a result of:
*• Ingestion and inhalation of soil by off-site
young children and adult residents,
> Ingestion, inhalation and dermal contact with
soil by older children and adult trespassers,
»• Ingestion and inhalation of soil by off-site
workers, and
»• Ingestion, inhalation and dermal contact with
soil by future on-site workers.
Current federal guidelines for acceptable
exposures are an individual lifetime excess
carcinogenic risk in the range of 10"4 to 10"6 (e.g.,
a one-in-ten-thousand to a one-in-a-million excess
cancer risk) and a maximum health Hazard Index
(which reflects noncarcinogenic effects for a
human receptor) equal to 1.0. A Hazard Index
greater than 1.0 indicates a potential of
noncarcinogenic health effects.
The results of the baseline risk assessment
indicate that the contaminated soils at the site
pose an unacceptable risk to human health. The
total potential future carcinogenic health risks to
on-site and off-site workers from exposure to site
soil via all exposure pathways (i.e., ingestion,
inhalation, and dermal contact) are 1.2 x 10"3 and
1.6 x 10"3, respectively. These risk numbers mean
that approximately one worker out of 1,000 would
be at risk of developing cancer if the site were not
remediated. The potential cartinogenic health
risks to the other potential receptors are:
8.6 x 10"4 for future young children residents; 2.8
x W4 for future adult residents; 3.7 x W4 for
current older children trespassers; and 2.8 x 10"4
for current adult trespassers. The HI for
ingestion, inhalation and dermal contact is less
than 1.0 for all receptors.
The health-based cleanup levels for carcinogenic
PAHs and total PAHs are presented in Table 2.
These cleanup levels were developed, based on
the risk assessment, to be protective of human
health for future industrial/commercial uses of
the property.
Table 2. Health-Based Soil Cleanup Levels
CONTAMINANT
Benzo(a)anthracene
Benzo(a)pyrene
Benzo(b)fluoranthene
Benzo(k)fluoranthene
Dibenzo(a,h)anthracene
Indeno(1^3-c,d)pyrene
Total PAHs
HEALH-BASED
CLEANUP LEVEL
(PPM)
78
' 8
78
78
8
78
500
Ecological Risk Assessment
The ecological risks associated with this site will
be addressed as part of the second operable unit
RI/FS. This operable unit will evaluate, among
other things, impacts to nearby surface water
•(wetlands) as well as terrestrial receptors.
Actual or threatened releases of hazardous
substances from this site, if not addressed by the
preferred alternative or one of the other active
measures considered, may present a current or
potential threat to public health, welfare or the
environment.
REMEDIAL ACTION OBJECTIVES
Remedial action objectives are specific goals to
protect human health and the environment.
These objectives are based on available
information and standards such as applicable or
relevant and appropriate requirements (ARARs)
and risk-based levels established in the risk
assessment. '
Organic contamination has been detected at
concentrations above levels determined to be
protective of human health in soils at the site.
Therefore, the following remedial action
objectives have been established for the
contaminated soil:
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*• Prevent public exposure to contaminant
sources that present a significant health threat
[contaminated dust and soils); and,
«• Reduce the concentrations of contaminants in
the soils to levels which are protective of human
health and the environment such that industrial
landruse of the property is not precluded.
SUMMARY OF REMEDIAL ALTERNATIVES
CERCLA requires that each selected site remedy
be protective of human health and the
environment, be cost-effective, comply with other
statutory laws, and utilize permanent solutions
and alternative treatment technologies and
resource recovery alternatives to the maximum
extent practicable. In addition, the statute
includes a preference for the use of treatment as
a principal element for the reduction of toxitity,
mobility, or volume of the hazardous substances.
Eight alternatives, including: no action, limited
action, capping, off-site incineration, on-site
incineration, composting, and bioslurry treatment •
were evaluated during the screening phase of the
FFS. In the spirit of the SACM initiative and
relying on the Agency's technology selection
guidance for wood-treating sites, EPA considered
technologies which have been consistently
selected at wood-preserving sites with similar
characteristics (e.g., types of contaminants
present, types of disposal practices, environmental
media affected) during the development of
remedial alternatives. The historical information
acquired from evaluating and cleaning up these
sites, combined with specific data for the GCL Tie
& Treating site (e.g., soil cleanup goals) was used
to streamline the investigation and the
identification of remedial activities. Technologies
such as bioremediation (e.g., composting,
bioslurry) and thermal destruction (e.g.,
incineration), although frequently selected at
wood-preserving sites, were eliminated during the
alternative screening phase. A site-specific pilot-
scale treatability study concluded that composting
would not meet the health-based cleanup goals
developed for the GCL-property soils. Bioslurry
and incineration were screened out because they
would be much more costly to implement than
the preferred alternative, while achieving similar
levels of protectiveness. As a result, the FFS
report evaluated in detail two remedial
alternatives for addressing the contamination
associated with the GCL Tie & Treating portion
of the site as discussed below.
The alternatives developed are:
Alternative 1: No Action
Capital Cost:
0 & M Cost:
Present Worth Cost:
Implementation Tune:
Not Applicable
$54,600 per year,
$20,000 for each five-
year review
$720,700 (over 30
years)
Not Applicable
The Superfund program requires that the No
Action alternatives be considered as a baseline for
comparison with other alternatives. The No
Action alternative for the soil at the GCL site
would consist of a long-term monitoring program.
Soil in the contaminated area would be monitored
semiannually for total PAHs and benzo[a]pyrene.
For cost-estimating purposes, it was assumed that
ten surface soil samples would be collected and
analyzed semi-annually.
Because this alternative would result in
.contaminants being left on-site above health
levels, the site would have to be reviewed every
five-years for .a period of 30 years per the
requirements of CERCLA. These five-year
reviews would include the reassessment of human
health and environmental risks due to the
contaminated material left on-site, using data
obtained from the monitoring program.
Alternative 2: Thermal Desorption
Capital Cost:
0 & M Cost:
Present Worth Cost:
Implementation Time:
$14,839,000
Not Applicable
$14,839,000
12 months (includes
contracting and
design)
Under this alternative, a total of 36,100 cubic
yards of contaminated soil and wood debris would
be excavated and treated by a thermal desorption
process. The total treatment volume includes
30,100 cubic yard of excavated material in
addition to 6,000 cubic yards of previously staged
soil/debris. This alternative would also include
-------
institutional controls to ensure that land use of
the property remains industrial.
A typical thermal desorption process consists of a
feed system, thermal processor, and gas treatment
system (consisting of an afterburner and scrubber
or a carbon adsorption system). Screened soil and
shredded/crushed materials are placed in the
thermal processor feed hopper. Because of the
combustible nature of the wood chips, nitrogen or
steam may be used as a transfer medium for the
vaporized PAHs to minimize the potential for fire.
The gas would be heated and then injected into
the thermal processor at a typical operating
temperature of 700° F -1000° F. PAH
contaminants of concern and moisture in the
contaminated soil would be volatilized into gases,
then treated in the off-gas treatment system.
Treatment options for the off-gas include burning
in an afterburner (operated to ensure complete
destruction of the PAHs), adsorbing contaminants
onto activated carbon or collection through
condensation followed by off-site disposal.
Thermal desorption achieves approximately 98 to
99 percent reduction of PAHs in soil. If an
. afterburner is used, the treated off-gas would
then be treated further in the scrubber for
particulate and acid gas removal.
In order to accomplish remediation of the
estimated volume of contaminated soil/debris on
site, the thermal desorption process would
operate at a rate of approximately 30 tons per
hour. This treatment rate would be accomplished
with a single high-capacity unit or two or more
smaller units operating concurrently. The
treatment unit configuration would depend on the
residence time and other operating parameters
determined during the treatability study stage of
the design. Actual treatment of the contaminated
soils is expected to take 1 year.
A post-treatment sampling and analysis program
would be instituted in order to ensure that
contamination in the soil had been reduced to
below the risk-based cleanup levels. Treated soils
which still exceeded the action levels would be
recirculated through the treatment unit in order
to further reduce contamination. Treated soil
achieving action levels would be redeposited in
excavated areas. To replace any volume lost by
thermal destruction of wood debris, treated soil
would be mixed with clean off-site fill which
would also serve to restore geotechnical stability
to the soils. The homogenized mixture would
then be covered with a 6-inch layer of topsoil.
After filling of the excavated areas is completed,-
the surface would then be graded to promote
drainage and seeded to prevent erosion. Site
structures (e.g., former process buildings) would
be decontaminated, demolished and disposed of
off-site. Residual waste from the treatment
process and excavation activities (e.g., wastewater
collected during dewatering operations) would be
treated on-site and/or disposed off-site in
accordance with applicable AEARs.
EVALUATION OF ALTERNATIVES
During the detailed evaluation of remedial
alternatives, each alternative is assessed against
nine evaluation criteria, namely, overall
protection of human health and the environment,
compliance with ARARs, long-term effectiveness
and permanence, reduction of toxicity, mobility,
or volume, short-term effectiveness,
implementability, cost, and state and community
acceptance.
The evaluation criteria are described below.
• »• Overall protection of human health and the
environment addresses whether or not a remedy
provides adequate protection and describes how
risks posed through each pathway are eliminated,
reduced, or controlled through treatment, engi-
neering controls, or institutional controls.
> Compliance with applicable or relevant and
appropriate requirements (ARARs) addresses
whether or not a remedy will meet all of the
applicable or relevant and appropriate
requirements of other federal and state
environmental statutes and requirements or
provide grounds for invoking a waiver.
* Long-term effectiveness and perniflTience
refers to the ability of a remedy to maintain
reliable protection-of human health and the
environment over time, once cleanup goals have
been met.
*• Reduction of toxicitv, mobility, or volume
through treatment is the anticipated performance
of the treatment technologies a remedy may
employ.
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»• Short-term effectiveness addresses the period
of time needed to achieve protection and any ad-
verse impacts on human health and the
environment that may be posed during the
construction and implementation period until
cleanup goals are achieved.
»• Implementabih'tv is the technical and
administrative feasibility of a remedy, including
the availability of materials and services needed
to implement a particular option.
»• Cost includes estimated capital and operation
and maintenance costs, and net present worth
costs.
> State acceptance indicates whether, based on
its review of the FFS report and Proposed Plan,
.the state concurs, opposes, or has no comment on
the preferred alternative at the present tune.:
»• Community acceptance will be assessed in the
Record of Decision (ROD) following a review of
the public comments received on the FFS report
and the Proposed Plan.
A comparative analysis of these alternatives based
upon the evaluation criteria noted previously
follows.
>• Overall Protection of Human Health and the
Environment
Alternative 1, would not meet any of the remedial
objectives and thus would not be protective of
human health or the environment. Contaminated
soils would remain on-site and exposure risks
would remain unaltered.
Alternative 2 involving excavation and thermal
desorption of contaminants, would reduce the
public health risks associated with direct contact,
ingestion, and inhalation of contaminated soil.
This alternative would also minimize the
potential leaching of contaminants from the soil
into groundwater. Treated material is expected to
meet the cleanup levels and would be considered
nonhazardous. This alternative would result in
overall protection of human health and the
environment, since risk-based cleanup levels
would be achieved.
»• Compliance with ARARs
Alternative 1 would not comply with any
contaminant-specific ARARs, but would comply
with all associated action-specific ARARs.
Alternative 2 would be designed and implemented
to satisfy all location-specific, action-specific and
contaminant-specific ARARs identified for the
site. Excavation activities would be conducted in
compliance with the Occupational Safely and
Health Administration (OSHA) standards, soil
erosion and sediment control requirements,
stonnwater discharge requirements and air
pollution control regulations pertaining to fugitive
emissions and air quality standards. Residual
waste from the treatment process would be
treated on-site and/or disposed off-site in
accordance with applicable ARARs.
> Long-Term Effectiveness and Permanence
Alternative 1 would only involve monitoring of
contamination at the site and does not provide for
removal and/or treatment of contaminants.
Therefore, this alternative would not reduce the
long-term risks to human health and the
environment associated with the GCL portion of
•the site.
Alternative 2.would provide long-term protection
by permanently reducing contaminant levels in
site soils to health-based cleanup levels. This
. alternative would reduce the levels of PAH
contaminants in soils by 98 percent to 99 percent.
Soil cover and revegetation would provide
protection against erosion. No long-term
monitoring would be required.
»• Reduction in Toxicitv. Mobility, or Volume
Through Treatment
Alternative 1 would not reduce toxicity, mobility
or volume of PAHs in site soils; minimal
reduction in contaminant levels may be achieved
by natural attenuation.
It is expected that Alternative 2, thermal
desorption, would remove 98 to 99 percent of the
PAHs from the soils, thereby reducing the
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toxicity, mobility and volume of contaminants.
Scrubber water and spent carbon generated from
the thermal desorption process would be treated
on-site or transported off-site for treatment
and/or disposal. ...
*• Short-Term Effectiveness
The implementation of Alternative 1 would not
pose any additional risks to the community, since
this alternative does not involve any major
construction. Workers involved in periodic
sampling of site soils would be exposed to minimal
risks because appropriate health and safety
protocols would be followed for this activity. For
purposes of this analysis, monitoring of the site
would occur for 30 years.
Alternative 2 includes activities such as
excavation, screening, shredding and handling of
contaminated soils which could result in potential
exposure of workers and residents to fugitive
dust. In order to minimize potential short-term
impacts, the area would be secured and access
would be restricted to authorized personnel only.
In addition, dust control measures such as wind
screens and water sprays would be used to
minimize fugitive dust emissions from material
handling. The risk to workers involved in the
remediation would also be minimized by
establishing appropriate health and safety
procedures and preventive measures, (e.g.,
enclosed cabs on backhoes and proper personal
protection equipment) to prevent direct contact
with contaminated materials and ingestion/
inhalation of fugitive dust. All site workers would
be OSHA certified and would be instructed to
follow OSHA protocols.
Under Alternative 2, short-term impacts on the
environment from removal of vegetation and
destruction of habitat are expected to be minimal,
Erosion and sediment control measures such as
silt curtains and berms would be provided during
material handling activities to control migration
of contaminated materials to surface waters via
runoff from the site. Some increase hi traffic and
noise pollution would be expected from site
activities. Short-term impacts may be
experienced for about a year which is the
estimated time for construction and remedial
activities.
> Implementabilitv
Alternative 1 does not involve any major site
activities other than monitoring, and performing
five-year reviews. These activities are easily
implemented.
Alternative 2 can be easily implemented, as the
technology is proven and readily available. The
enhanced volatilization component of this
alternative has been shown to be effective for
destruction of PAHs, and is commercially
available. Sufficient land is available at the site
for operation of a mobile thermal desorption
system and supporting facilities. Performance
tests would be required for the thermal
desorption process to define optimum operating
conditions. Thermally desorbed materials would
be placed on site.
Implementation of this alternative requires
restriction of access to the site during the
remediation process. Coordination with state and
local agencies would also be required during
remediation.
" Cost
•Alternative 1 is the less expensive alternative, but
does,not provide treatment of contaminated soils.
Alternative 1 has a present worth cost of $720,700
which is associated with conducting a sampling
and analyses program and five-year reviews over a
30-year period. The present worth costs of $14.8
million for Alternative 2 provides for the on-site
treatment of 36,100 cubic yards of contaminated
soil using a proven technology.
>• State Acceptance
NYSDEC concurs with the preferred remedy.
»• Community Acceptance
Community acceptance of the preferred
alternative will be assessed in the ROD following
review of the public comments received on the
FFS report and the Proposed Plan.
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PREFERRED ALTERNATIVE
Based upon an evaluation of the various
alternatives, EPA and NYSDEC recommend
Alternative 2 as the preferred alternative for
remediation of contaminated soils on the GCL-
property portion of the site. Alternative 2 would
address the contamination by excavating and
treating contaminated soils on-site through a
thermal desorption process, followed by
replacement of the treated soils on-site. In
addition, debris generated from the demolition of
structures (i.e., buildings) and other untreatable
materials would be decontaminated and/or sent
off-site for disposal. Institutional control
measures would also be recommended to ensure
that land use of the property continues to be
industrial.
The preferred alternative would provide the best
balance of trade-offs among alternatives with
respect to the evaluating criteria EPA and the
NYSDEC believe that the preferred alternative
would be protective of human health and the
environment, would comply with ARARs, would
be cost-effective, and would utilize permanent
solutions and alternative treatment technologies
or resource recovery technologies to the
maximum extent practicable. The remedy also
would meet the statutory preference for the use
of treatment as a principal element.
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11
F'9Ufe 1- GCL Tie & Treating Site Location Map
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12
Figure 2. GCL Tie & Treating Site Plan
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APPENDIX B
PUBLIC NOTICES
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E3ASCO/ENSERCH ENU.CORF.
201 842 7234 P.33/03
Tri-Town News
' , THE UNITED STATES . .
, ; . ENVIRONMENTAL PROTECTION AGENCY
•' • • • ..,-.. . • Invites •
: PUBLIC COMMENT ON THE
PROPOSED CLEANUP OF THE GCL TIE & TREATING
SUPERFUND SITE
•••-'•••. • •/..- '.. ••• at
;- DELAWARE AVENUE, SIDNEY, NEW YORK
The U.S. Environments) -Prelection Agency (EPA) .and the New York State Department or environmental Conservation (NYSDSC)
will-hold a pubiic..meeting to discuss the findings of the Focusec! Feasibility Study "(FFS) and the Proposed Plan (P.°) for the GCL Tie
a^reating.SyperJund site. . ; ... .. ..• L>••"•••'-•-••••
The meeting will be held on Tuesday. August 9..1994 at 7 pm in the Sidney Civic Center, .2-1 Liberty Street, Sidney, NY, The release
of the Proposed'Plan and the scheduled public meeting1 are in accordance, with,EPA's public participation responsibilities under
Section 1 17(a).of the Comprehensive-Environmental Response, Compensation and Liability Act (CERCLA) of 1980.
Site-remediation activities; at this site.were'seiffegated into'two different-phases,, qr operable units, so that remediation of different
environmental media br'a'reas of asite'carvprpc'eed separate!y,-'resui'tin§«r4n expeditious remediation of the entire' site. Operable
..unit 1. (Q0:i).addresses^niy;the'contaminated'spiis''on'the GCL-prcper$£brt6h"."of the site and is the focus of this FFS and PP.
' Operable unit.2,.cuitenfly underway/addresses trie'cohtamiriation irftrie/soils'on the remainder ci the site (referred to as non-GCL
property),-ahdin:fhe-grouridwater, surface water, and .sediments. H "'- .'-.. -.;.-
Based on the available information,-the preferredremedy forCU-1 isio excavate arid.treat the approximately 36,100 cubic yards of
contaminated, soil-'ahddebriron-site using a-thermal .desorption[process, followed by replacement of the treated soils en-site.
EPA.'in consultation with WY.5DEC, may modify the'preferred alternative or select another response action presented in this
Proposed Plan;based;cn-nevv information or public comments.' Therefore; the'public is encouraged to review and comment on all'
of the alternatives identifiec herein.' Documentation of the project findings is presented in the site file. These documents are
s available at the: •• - ,- .'''"•
•. ....!. ... - Sidney-Memorial Library •
: ••.-.::. .-:• .:. Main Street
';'-.;•' '" . . - .Sidney, NY
Comrnents on-the Proposed Plan.Will be. summarized and responses provided in the Responsiveness Summary section of the
Record-of Decision.- The Record of Decision is tfre document that p'resents EPA's-final seiecticn for response actions. Written
commems-.bn this Proposed Plan should-be sent by close of business, August 29,1994 to:
" .. .. Carlos R.Ramos, Bemediaf Project Manager
-.''•'••••• • . . U.S. Environmental Protection Agency
26 Federal Plaza, Room 29-i 00
.• '"'"'!/' . -;:'"' , • . .". ' ..' ..New York, New York 10278- "• ' ,
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Oneonta Daily Star - 8/5/94
THE UNITED STATES
ENVIRONMENTAL PROTECTION AGENCY
Invites
PUBLIC COMMENT ON THE
PROPOSED CLEANUP OF THE GCL TIE & TREATING
SUPERFUND SITE
DELAWARE AVENUE, SIDNEY, NEW YpRK
The U.S. Environmental Protection Agency (EPA) and the New York State Department of Environmental
Conservation (NYSDEC) will hold a public meeting to discuss the findings of the Focused Feasibility
Study (FFS) and the Proposed Plan (PP) for the GCL Tie & Treating Superfund site.
The meeting will be..held onTuesday, August 9,1994 at 7 pm in the Sidney Civic Center, 21 Liberty Street,
Sidney, NY. The release of the Proposed Plan and the scheduled.public meeting.are in accordance with
EPA's public participation responsibilities under Section 117(a) of the Comprehensive Environmental
Response, Compensation and Liability Act (CERCLA) of 1980.
Site remediation activities at this site were segregated into two different phases, or operable units, so that
remediation of different environmental media or areas of a site can proceed separately, resulting in an
expeditious remediation of the entire site. Operable unit 1 (OU-1) addresses only the contaminated soils
on the GCL-property portion of the site and is the focus of this FFS and PP. Operable unit 2, currently
underway, addresses the contamination in the soils on the remainder of the site (referred to as non-GCL
property), and in the groundwater, surface water,'and sediments.
*
Based on the available information, the preferred remedy for OU-1 is to excavate and treat the approxi-
mately 36,100 cubic yards of contaminated soil and debris on-site using a thermal desorption process,
followed by replacement of the treated soils on-site.
EPA, in consultation with NYSDEC, may modify the preferred alternative or select another response
action presented in this Proposed Plan based on new information or public comments. Therefore, the
public is encouraged to review and commenton all of the alternatives identified herein. Documentation of
the project findings is presented in the site file. These documents are available at the:
Sidney Memorial Library
•••••••• .".: . Main Street ...... ........
Sidney, NY
Comments on the Proposed Plan will Be summarized and responses provided in the Responsiveness
Summary section of the Record of Decision. The Record of Decision is the document that presents EPA's
final selection for response actions. Written comments on this Proposed Plan should be sent by close of
business, August 29, 1994 to:
Carlos R. Ramos, Remedial Project Manager
U.S. Environmental Protection Agency
26 Federal Plaza, Room 29-100
New York, New York 10278
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APPENDIX C
AUGUST 9, 1994 PUBLIC MEETING ATTENDANCE SHEETS
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION II
PUBLIC MEETING
FOR
GCL TIE & TREATING 8UPERFUND SITE
TUESDAY, August 9, 1994
ATTENDEES
(Please Print clearly)
NAME
STREET
CITY
ZIP
12-2?^
1^3x33
PHONE
77^3?
U A" 3
/???&
REPRESENTING
/ p A f cA. i
' -T7;-
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION II
PUBLIC MEETING
FOR i
GCL TIE & TREATING SUPERFUND SITE
TUESDAY, August 9, 1994
ATTENDEES
(Please Print Clearly)
NAME STREET
V// >/,. I /.'. .'/• V.IJ-/ > ' '/ 0 /)..-.! | hi
//?/ rt
CITY ZIP
'-< .i'
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION II ;
PUBLIC MEETING
! FOR
GCL TIE ft TREATING SUPERFUND SITE
TUESDAY, August 9, 1994
ATTENDEES
(Please Print Clearly)
NAME STREET CITY ZIP PHONE REPRESENTING
H^M
—3-
.i, IU
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U.S. ENVIRONMENTAL PROTECTION AGENCY PUBLIC MEETING
GCL TIE & TREATING SUPERFUND SITE
A public meeting held at the Sidney Civic Center,
21 Liberty Street, Sidney, New York, on Tuesday, the 9th day
of August, 1994, commencing at 7:09 p.m.
APPEARANCES:
BEFORE;
CECILIA ECHOLS
Community Relations Coordinator
DOUG GARBARINI, Chief
New York Caribbean Superfund Section 1
CARLOS RAMOS
Project Manager
Ruth I. Lynch
Registered Professional Reporter
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MS. ECHOLS: Okay, we're ready to begin.
Welcome. My name is Cecilia Echols, I'm the Community
Relations Coordinator for the GCL Tie and Treating
Superfund Site located here in Sidney. Many of you may
have met me before/ if not I would just like to thank
you all for coming out this evening to hear what we
have to say about our cleanup for the site. Your input
•
is very important to us about how you feel EPA is doing
with cleaning up the site. We take a lot of your
comments — excuse me, we take a lot of your comments
and gather them and go over them to see that our
cleanup criteria meets the Town and the citizens in
your community.
Right now we're at a cleanup — well, we're at a
operable unit, one, that is addressing contaminated
soils on the GCL property. There's two parts of the
GCL site, well, there's the non — nonproperty and the
property portion, and right now we're working with the
GCL property and we're looking at contaminated soil on
that site.
I would like to mention that we have a technical
assistance grant which allows a community organization
in — that directly affected to any Super fund site to
apply for a grant that's worth $50,000. They hire a
technical advisor who reviews documents related to the
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1 site, and he goes back to the community and lets people
2 know about EPA's findings in terms of cleanup,
3 feasibility studies and remedial investigations.
4 I presume everyone signed in, everyone has the
5 handouts, if anyone ever wants to.read up about
6 documents related to the site they can go to the Sidney
7 Memorial Library. That's where we have all the
8 documents. Instead of coming all the way to Manhattan
9 you can just go to the library here in town.
10 We have a stenographer who's recording everything
11 for the record, and a transcript will be placed in the
12 information repository, right? We will also put
13 together a responsiveness summary. Everyone's
14 responses to the meeting, anyone's comments will be
15 gathered, and EPA will do a responsiveness summary for
16 that. That's written or verbal.
17 At the end we will give questions and answers,
18 and we hope that everyone would raise — let the
19 stenographer know their name, and possibly their
20 address.
21 I also forgot to introduce everyone else on the
22 panel. We have Doug Garbarini to my right, he's the
23 chief of the New York State Caribbean Superfund
24 Section 1, he's gonna give an overview of the Superfund
25 process. And to my right is Carlos Ramos, he is the
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project manager for the sites — for the site, and he
will discuss the Focus Feasibility Study results as
well as remedial alternatives.
With us also are two people from the New York
State Department of Environmental Conservation; Martin
Brand/ he's in the back, and Walter Demick? Did I say
that right?
MR. DEMICK: Pretty close.
MS. ECHOLS: Okay. And he's — he's the section
chief for the Bureau of Remedial Action, and Mark is an
engineering geologist.
And now I'm gonna open up the floor to Doug, and
he will give an overview of the Superfund process.
I'm gonna have to turn off the lights for a
little while so everyone can see the slides on the
overhead.
MR. GARBARINI: Thanks all of you for coming out.
As Cecilia said, my name is Doug Garbarini, and I am
just gonna give you a brief overview of the Superfund
process, give you a little bit of background on, you
know, how Superfund was created and basically what it's
all about and how we move through the process of
discovering a site and then finally cleaning it up.
Superfund came about back in 1980-with passage of
the Comprehensive Environmental Response Compensation
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and Liability Act. Otherwise known as CERCLA. And
basically what it did is Congress gave us the authority
to use the Superfund, or super pot of money/ which at
the time totaled about one point five billion dollars,
to clean up abandoned hazardous waste sites or
hazardous waste sites that we knew about where we
didn't have — we didn't have parties who were
. •
responsible for the contamination that were viable to
pay for the cleanup. Not only did it give us a fund
but it also gave us the authority/ the enforcement
authority/ to force those parties that were viable and
were responsible for the contamination to clean it up.
Superfund was initially passed for a five-year
term at a cost of about one :— with a funding level of
about one and a half billion/ as I said. As we got
into the program, Congress really got a better feel for
how complex the program was. And, you know, initially
I think the feeling was that well/ okay, we'll be in
and out of here in five to seven years, something like
that, it will be a quick program, we'll clean up all
the hazardous waste sites across the country and that
will be it. But with the reauthorization of Superfund
in 1986, I think they got a better feel for the
complexity because they gave us about one point five
billion dollars a year over the course of five years.
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So we were reauthorized for five years but the funding
level went from one point five billion over a
five-year term to about one point five billion each
individual year over five years.
Basically we have the Act, and then we say okay,
what do you do after that. You've got the Act, what
you need is regulations to implement the Act, and we
have the National Contingency Plan which basically
provides us with the regulatory framework to go out and
clean up sites.
When you — when you've got a site that you think
needs addressing, you go into the preremedial phase.
And the site can come to our attention either from the
State, from a local authority, even from an individual
resident. They can petition us to actually do what's
called a preliminary assessment and see if the site is
worthy of being on our national list of — of sites
that need to be cleaned up under the Superfund program.
So the first thing that's done in a preremedial
phase is discover and rank a site. And we basically go
out, we'll do a preliminary assessment and review
documents, if necessary we'll go out and do a site
inspection where we might actually collect a few
different types of samples from different types of
media. Just to try and get a better feel for the
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1 relative risk posed by the site. We then basically
2 plug all this information into a system called a hazard
3 ranking system. And if all this data generates a
4 number above a predetermined score, the site will be
5 proposed for inclusion on the national priorities list
6 which is — which is the list of national sites which
7 are worthy of — of attention via the Superfund
•'
8 program.
9 That proposal is then commented upon by the
10 public, and assuming that there are no — there's no
11 reason or there isn't anything that we've overlooked,
12 the sites will be placed on the national priorities
13 list and given final listing status.
14 There are approximately — there have been
15 approximately 1300 sites that have been on the list, so
16 we're in the 1200 range right now. About 200 of those
17 are located in the Region 2 auspices; Region 2 handles
18 New York, New Jersey, Puerto Rico and the Virgin
19 Islands. About 80 or so of those are located in New
20 York. So that just gives ya a relative feel for the
21 density of the sites across the country.
22 There is an initial screening process that we go
23 . through which basically we've got a listing of over
24 30,000 sites, many of them are — that have gone
25 through an initial preliminary assessment process so
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far, so you can see the universal sites really gets
funneled down to those that require attention via the
national priorities list. There's — those sites that
are placed on the national priorities list are eligible
for the long-term remediation program which is
basically what we're here to discuss, part of what
we're here to discuss tonight.
But there's also another part of the program
called the removal program. The removal program
handles those sites which may have very acute health
risk. There's an immediate threat, you need to go out
and take quick action. And we've taken — that's been
a very, very successful program. It deals not only
with sites on the national priorities list but also
sites that are not on the list, and we've taken over
two — 2,500 remedial removal actions on — on
different sites across the country. That's been very
successful.
We've also taken, as Carlos will mention later,
some removal actions here at the GCL site. And those
removal actions focused on the immediate and acute
threats that were posed by the site.
Okay. After the site is listed and ranked and it
goes into a long-term remedial-phase, we-get-into
the remedial studies phase. And that starts with
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1 what's called generally a remedial investigation. With
2 the remedial investigation we go out and we collect a
3 whole slew of samples, we sample different media that
4 happen to pose — may pose a problem at the site; for
5 instance/ generally almost always soil and groundwater,
6 but if you have a stream or pond or lagoons you may
7 sample the water and sediments from the lagoons.
8 We basically collect those samples, send them off
9 to a laboratory, get the results back and try and
10 define the nature of contamination, the different types
11 of contaminants and the extent. You know, how — how
12 extensive is the contamination, how deep does it go in
13 the soil, how far afield does it go horizontally. We
14 take that information and we try and prepare a risk
15 assessment with it. And the risk assessment is one
16 that touches on human health concerns as well as
17 ecological concerns.
18 So you've got these contaminants out there, okay,
19 but how nasty are they. What are they gonna do to
20 people, .what are they gonna do to plants and animals.
21 So we basically, you know, go through a plug-in-chug
22 process, and we make some very conservative assumptions
23 • about how people will be exposed to these different
24 contaminants. And we —we generate a series of
25 numbers, and we've got sort of guidelines that we look
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1 at and we see whether the numbers that are generated
2 exceed these allowable levels. And if these allowable
3 levels are exceeded, we get into what's called the
4 feasibility study phase of the program.
5 And the feasibility study phase basically
6 identifies different alternatives for reducing those
7 unacceptable risks to acceptable levels or allowable
8 levels. In certain instances when we're just focusing
9 on a particular aspect of the site and we want to move
10 ahead as quickly as possible, we'll combine the
11 remedial investigation and feasibility steps into
12 what's called a Focus Feasibility Study. And tonight
13 will be a prime example of that, we'll be talking about
14 the Focus Feasibility Study that was done for the soils
15 on the GCL property of the GCL site.
16 The next thing we do is we go through the
17 feasibility study alternatives and we try and select
18 what we believe to be the most appropriate alternative.
19 We use a series of criteria, and we basically come out
20 with a plan that says okay, public, you know, we've
21 evaluated a number of different things, here are the
22 results that we have for the site, and that is the
23 alternative that we think will be able to reduce the
24 risks that are posed-by the site to acceptable levels.
25 And we provide our rationale for that preferred
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1 alternative.
2 We come out, we offer a 30-day comment
3 period, we have a public meeting, we take your
4 responses and basically put them in what's called a
5 responsiveness summary. And so basically it's like a
6 question and answer type document which is part of an
7 overall document called the Record of Decision. And
«'
8 this Record of Decision is signed by the highest
9 ranking official in our regional office, the regional
10 administrator. And it basically defines conceptually
11 what the remedy will be for the site. So this
12 basically gives us the approval to go forward and
13 use — use additional funds to both design the remedy,
14 now we're moving into the construction phase so you're
15 gonna design the remedy, if you're gonna be excavating
16 soils you'll — you'll define the limits of excavation,
17 how far you're gonna be excavating. If you're gonna
18 be — and how deep. If you're gonna be purging and
19 treating groundwater, for instance, you might have a
20 groundwater treatment system, you design that. If it's
21 gonna be a building you'll lay out, you know, exactly
22 how the building will be built. So that's the design
23 phase.
24 We then get into the remedial action phase. You
25 know, this is where you actually get out there with the
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earthmoving equipment and take some action. When that
remedial action is done we go through a period, there
may be some monitoring that's necessary, in any case
we'll go through the process of preparing a close-out
report for the site, and then we'll propose the site
for deletion from the national priorities list. And
that's basically the final phase of the remedial
process.
Now, throughout the phase, throughout these
phases, we concentrate on getting those parties that
are responsible for the contamination, the PRPs, to
clean up the site. And if they're not willing to clean
it up we try to get them to pay for — for the cleanup.
Generally we'll come in here with the remedial
investigation study phase and we'll invite all those
parties who are responsible for contamination to do
the study. And we generally categorize responsible
parties, or PRPs, as those people that either owned the
site while the generation of wastes was going on, while
the contamination was going on, those that currently
own the site or have been owners of the site, those
who have generated wastes that end up at the site, or
those who just basically operated at the facility. If
the responsible parties decline to do the work we can
order them to do it. Otherwise we can wait and try and
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1 come back at a later phase and cost recover for the
2 moneys that we've spent.
3 We do the same thing at the construction phase
4 right before the remedial design. We'll again send out
5 notice letters to these responsible parties saying this
6 is the work we want to do, you guys are liable, you
7 know, what do you think, are you gonna put the money
8 up, are you gonna do the work or what's the story
9 gonna be here, and you go through a negotiation
10 process. Again, we can order the responsible
11 parties to do the work, otherwise they can — we can
12 undertake the work ourselves using the Superfund pot of
13 money.
14 Now, what we want to do generally is get the
15 responsible parties to pay so that we can use the
16 Superfund for other sites where PRPs don't exist. And
17 again, at the end of the process we can come back and
18 go through — go through the courts and try and cost
19 recover the money through the courts or through another
20 out-of-court settlement.
21 We've been fairly successful with our enforcement
22 program in the last few years dating back through 1992,
23 I've got some statistics there, we've been able to have
.24. .-settlements for construction on the order of about
25 seven and a half billion dollars worth of work. We've
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1 gone back through that same time frame and recovered
2 over a billion dollars for work that had been conducted
3 at sites. And in the — in 1992 we basically had I
4 think 70 percent of the actions that were being taken,
5 those actions were being -conducted by responsible
6 parties. So that's a pretty good ratio there.
7 Just to give you a general feel for the program,
8 aside from having, you know, 1200 and some odd sites
9 across the country, you can't really say there's a
10 typical Superfund site. You can be dealing with
11 half-acre plating facilities, you can be dealing with
12 landfills, you can be dealing with 200-square-mile
13 mining sites, like we have a few of those outside —
14 out west.
15 As far as time frames for cleaning up sites,
16 we're running from the start of an RFS through the
17 construction on the order of 10 years or so. And the
18 costs are running about $25 million per site.
19 So that's just to give you a little bit of a feel
20 ' for the program, I think there's — we're up for
21 reauthorization again this year.
22 There are a lot of people that are frustrated
23 with the pace of the program, and people are looking at
24 a lot of different-measures to try-and speed the whole
25 process up. And GCL is one site where .we've taken a
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number of steps, and I think Carlos will touch on that
a little bit later as far as the removal action that
was conducted and the different sampling that we did.
We're basically trying to consolidate thingsr;and get
things going on early on in the process. We did a lot
of work here before the site was actually ever listed
on the national priorities site. So that had not been
«
the case in the past, so we're.experimenting with some
different things, and hopefully some of them will pan
out.
And I think I'll turn it over to Carlos, who will
tell you about the Focus Feasibility Study.
MR. RAMOS: Thank you.
Hi. My name is Carlos Ramos, I am the Project
Manager for this specific site, GCL Tie and Treating
Site. All these overheads are in your handout, so
if you cannot see well you can just refer to your
handout sheets, the one that says public meeting on the
front of it.
I'll give you some idea about the site, I know
most of you guys are familiar with the site. This, is
what we call the historic GCL Tie and Treating Site.
It's about 60 acres, it's right across Delaware Road,
or Gifford Road, it's south of-the-jfacility, .it's, also
the airport. To the east you have Route 8 and to the
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west you have some wetland areas. Part of our purpose
is we divide the site into two areas. This western
area is what we call the GCL property site. The
eastern area is what we call the non GCL property site.
The GCL property area is the area which has been
more -- most generally used for wood preserving
operations. The non GCL property has been more
generally used for other purposes, mostly industrial
operation, and also a sawmill right there.
If we just focus on the GCL portion of the site,
that was that black square, you can see the site
consists mostly of four main buildings. The most
important building is the process building, and that's
where wood preserving operations took place. It was a
very simple wood preserving process, basically they
have two big vessels where they put wood inside the
vessels, there will be creosote inside the vessel, and
then they will apply pressure and the creosote will
be — will get into the wood under that high pressure.
And that's — this is just a blow-up of that
process building so you see it in more detail.
Inside that building also there was some — some
laboratory facilities, and some office space also
there.
The area around the building is also the area
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1 considered to be at the beginning most highly
2 contaminated. Basically due to several instances of
3 spills at the site. At some point of time during the
4 wood treatment process, the vessels used to treat the
5 wood exploded. And this causes the creosote to spread
6 all around this area, including inside the building.
7 At some other point of time there was a spill,
8 approximately 30,000 gallons of - creosote which was
9 spilled also on-site. Many of the other areas of the
10 site also have creosote on the soils because after the
11 wood was treated creosote was taken out of the vessels
12 and allowed the creosote, the excess creosote, to drain
13 into the soils. So after the wood was treated, any
14 excess creosote was gonna be dripping on the soils or
15 around the site.
16 Okay. This refers to the process. Is that
17 focused for you guys, or? No. Where's the focus
18 thing?
19 It is on your handout, though, so if you cannot
20 see it from the — I apologize for these.
21 The first, basically we divided the remedial
22 activities at the site into three different phases.
23 . The first phase that we did was the removal action.
24 And that's what Doug Garbarini was referring to. We
25 went to the site to look for those things which
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1 constitute the most immediate threat at the site, and
2 those things were mostly creosote wastes in
3 above-the-ground and underground tanks. There were
4 quite a few tanks on the property that contained
5 creosote wastes. Those tanks were found by the
6 condition and were presented a threat if it were to
7 burst.
8 We also installed fence on the side to keep
9 people from accessing the site so people would not be
10 wandering into the property. We also established
11 run-off control and flows control. So when it rains,
12 when the rainy period, the soil would not wash it into
13 the wetlands or wash it into a nearby drainage ditch.
14 We also took measures to control the dust by putting —
15 by covering some of the soils with plastic sheets. In
16 addition to that, the removal action took samples from
17 surface soils. We basically went to those areas which
18 looked most contaminated and took some samples from
19 those areas. Concurrent to that we did what we call
20 the Focus Feasibility Study, which is the focus of our
21 meeting today.
22 Under the Focus Feasibility Study we took
23 additional samples of those soils which were already
24 partially sampled in the removal action. Since the
25 removal action focused on the — on the soil surface,
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the Focus Feasibility Study focused on the soil
subsurface. Basically what we did is that we went down
to the site and we dug about 200 trenches and took
samples at different depths to determine the full
extent of contamination at the site. We already knew
that creosote was the biggest concern there but we
didn't know the extent of that contamination. And that
was what we did during the .Focus Feasibility Study.
Right now the Focus Feasibility Study proposes a remedy
for those soils already identified in the GCL property
as being contaminated with creosote.
Concurrent to that also we began a Remedial
Investigation Feasibility Study. The Remedial
Investigation Feasibility Study addresses soils outside
the GCL property. It also addresses the groundwater,
the surface water and also sediments within those
surface water bodies. That's all being addressed as
part of the Remedial Investigation Feasibility Study.
This — this portion — this portion of the remedial
action/ RIFS, call it short, will be finalized by
the end of this year, and then we will be back here
again also proposing remedy for those areas. So the
procedure would be the same again for the other portion
of the property. ~
This is just again a close-up of the GCL
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property, and those — those lines here represent areas
which were excavated and sampled. Basically what we
did is that we dig trenches along these lines, all
these lines here, and those were the areas where we
actually took samples. That data, in addition to the
data already collected in the removal action, gave us a
complete picture of the extent and nature of the
contamination on that portion of the site.
And now I just want to switch to the — to the
slide. You can see how actually we did the work.
That's a view of the building, of the process
building, where the actual vessels are. You can see
here, these two are the treatment vessels. Wood was
actually carried inside those vessels, and then here in
this area they used to be holding area of aboveground
tanks holding creosote, and that creosote was pumped
inside those vessels, this is a door that was closed,
pressure was applied and the creosote would get into
the wood. You can see this building is black. That's
because when the explosion happened, when these vessels
exploded, creosote was spread all around. And the
building was all stained with creosote, and creosote
was — was spread all around here. They also have an
area down here where "creosote was spilled." "There is
railroad track running down this area, and actually the
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creosote was brought via railroad into the side and
then pumped into the aboveground tanks. And at some
point of time a spill of creosote happened also in this
area here. Next one.
This is just a close-up again of — of the
building, you can see it's all stained, and the two
vessels and the tracks used to move the — the wood
inside the vessels. Next one.
And this is actually the work that we did, we
basically on those lines there, we began to dig
trenches or pits, and you can see this operator which
is wearing some kind of a respiratory protection, and
we just excavate — we excavate, depending where we
were, anywhere from 2 feet to 10 to 12 feet deep. Next
one.
This is just to give you a view of what's, you
know, what a typical trench looks like. You can see
soil here which is darker, you saw contamination is
higher on the surface. Well, the reason is that
because creosote doesn't move much. Creosote really
binds towards the soil. So you can see that high
concentration of creosote were easily found on the top
layers of soils. Next one.
I mentioned before, trenches varied from a few
feet deep to 12 feet. This is one of the shallower
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1 trenches, you can see two technicians actually getting
2 ready to take a sample, he is monitoring for volatile
3 organic compounds to make sure it is safe to take a
4 sample and also to see whether there is contamination
5 at the site. This is just creating health and safety.
6 Next one.
7 And this is a sample from the site, the trench,
8 and you can see sometime the workers are wearing
9 respiratory protection, sometimes they're not. That's
10 because this person here using this instrument telling
11 them when it is appropriate to wear respiratory
12 protection and when it's not appropriate or needed.
13 This guy's just getting a sample from this soil here.
14 For the deep trenches we have to use other
15 techniques to collect samples, like in this specific
16 case the trench is just too deep for a person to jump
17 inside the trench, the trench would collapse, and also
18 working in such deep areas. So we use the device which
19 is a core and a stationed tube to collect a soil sample
20 from the side of the trench. And you can see again
21 different coloring on the sides of the trench.
22 This is just a closer up of coring device getting
23 into the soil and taking a sample. Some were taken at
24 different depth. You saw the-shallow depth, the
25 intermediate depth, and a deeper depth. The deepest
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one in the trench.
Once a sample was taken out, they screened a
sample, they measured to see whether they get any hit
from VOCs, volatile organic compounds, and then they
proceed to collect the sample.
Which is what they're doing there, they're just
retrieving a sample, to see, he has a vial in his hand,
he has here kind of like a spoon that will be putting
the sample inside that vial.
And this is sideway view of the trenches. As
you can see, one thing that we leave there is that —
you want to do that?
MR. GARBARINI: Sure.
MR. RAMOS: Maybe just go back.
MR. GARBARINI: That's what I'm trying to do, go
back. All right.
MR. RAMOS: Basically I just want to say on this
one, we —
MR. GARBARINI: Want me to turn it upright?
MR. RAMOS: That would work, there you are.
In addition to just collecting samples, we also
make other notations; we look for area where there
may be high staining, you can identify portions where
there are staining, also you can make a notation of the
damage here that you find within that trench. And that
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1 helps you later on when you're trying to monitor the
2 extent of contamination and to see how you're gonna
3 deal with that. Having all that knowledge and
4 information.
5 In some of the most deepest trenches we had to
6 , put a bridge over the trench for the technician to be
7 - able to actually reach into, using that coring device,
8 and then grab a sample. Some of these trenches are
9 very deep, ten feet deep, so it was impossible just
10 from getting close to the trench outside and taking a
11 sample, you actually had to be on top of the subsurface
12 like these. You can see this is a trench line, and you
13 can see inside those trenches we find much more than
14 only soil. As a matter of fact, 30 percent here which
15 we found was wood, which actually contained creosote in
16 some instances. Those kind of material and some of
17 those railroad ties and other criteria that were
18 processed at that facility. So any excess wood was
19 kind of dumped at the site. And they usually use that
20 material to backfill a big portion of the site.
21 All this other area used to be low grade, it used
22 to be deeper, actually some of this used to be a
23 . wetland. And so throughout the years these people that
24 operated this facility began'to dump excess wood,
25 debris, so, whatever they can find there just to
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backfill the area and use it later on for their
operations. So that's why you see all this down
through there.
You can see here, the difference here, you find
more soil and less wood. That's because this area
wasn't as backfilled as the other area which is further
down here.
And you can see some of the stuff that we dug up
there looked pretty ugly. Some of these were highly
saturated with creosote, some of it was highly
saturated with water because it was below the water
table. Again because it was a wetland, and once
they backfilled that area, all the soils saturated with
water. We find all kind of things; wood, metal, big
rocks, anything that you can find, you can find it
there, you know. Anything you can think of they find
it there because they just dump whatever they could
find there. Next one.
And this is also sideways. But —
MR. GARBARINI: Want me to turn it? I'll give it
a quick turn.
MR. RAMOS: Okay, good. Thanks. And this is
just a close-up, some of the materials you find inside,
you can see plastic, wood-, rocks./-metal, -and this -is
one of those trenches where we actually reached the
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water table. This is toward the west of the site where
it's closer to the wetland, and you can see some of the
materials that you find, you know, floating in the
water look kind of oily in some — in some instances.
Some of it just looks that way because it is -- you
know, it was just kind of a wetland type of water, it's
kind of natural degradation in there. But some areas we
find creosote there. Many of this wood, that is
contaminated with that creosote also.
And this is again a picture, it just shows I
guess the sheen in some of those pits which are
excavated.
And in addition, one of the nice things that we
found on the site is that the soil is very clay,
there's a lot of clay in that soil. And that's good
because that means that things don't move as fast as
they would in other type of soil. The creosote by
nature combines with the soil. That's good. When you
have this type of material, and this is actually clay,
this is clay, I just put this piece of — these flowers
there, you can compare the color. But it is kind of a
green-gray kind of material. And that's a natural clay
that actually makes the moving of creosote toward the
-groundwater even more "difficult. ~ ~~
Okay. Now we can go back to the overhead.
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Okay. After we took all those samples, we sent
the samples to the lab, and we get our summary of soil
back from the lab. Based from the removal as
previously/ we anticipated most of the contamination of
the site was from creosote type materials. As you
might know, creosote is no one pure product, it's
purely a combination of hundreds of different petroleum
hydrocarbons. And that's what we actually found when
we went out to the site and we sampled, we confirmed
that mostly what it is on the site is creosote type
materials. The first few compounds you see here they
call volatile organic compounds. And this compound we
found you can see very low concentrations of those
compounds. Nothing really that — that will pose any
concern. Once we move into creosote type materials we
can see the concentrations increased a lot. And these
are these high numbers here. All these are creosote
constituents.
We have two — two different samplings. We have
the Focus Feasibility Study sampling and we had a
removal action sampling. In general those numbers for
the removal assessments were much higher because they
focus on the very highly contaminated portion of the
site. That's what they look for,•-they-look for
immediate threats, so they go to those very high
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concentrates area. So you see this one is much higher
from this one, because on the Focus Feasibility Study
we already knew that the highly contaminated areas were
already contaminated, but we wanted to see about the
rest of the site. And the rest of the site wasn't as
contaminated as some of these soils but still was very
highly contaminated with creosote type materials. We
also found metals, but nothing really of" concern, some
low concentrations.
Okay. What did we do with that information.
Here we are. We did baseline risk assessment, which
was what Doug mentioned before. We know how much is
there, and we know what is it, the question is what
risk does that contamination pose to human beings. And
what we did is that we put together scenarios. We say
well, these are the difference, these are the different
populations for potentially getting in contact with
those soils. Then we look at off-site young children
which might be exposed to soils, we look at future
adult residents. This is — this is thinking that in
the future maybe one possibility for the property is to
be converted into some kind of residential use. So if
somebody were to actually build a house there, without
any-kind of cleanup, what would be the result of that.
So that's one scenario.
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The other thing that we look at are children
actually going into the site and trespassing into the
site. We have signs, we have a fence there which keep
people away from the site but this is always a
potential, so that's one scenario that we look at. The
older trespassers, people trespassing into a site. I
know in the past before we initiated a removal action
some people used to use the site as a shortcut to get
to those fast food restaurants there, to Pizza Hut and
the Burger King. So that was one also potential
scenarios that we wanted to look at.
We also wanted to look at off-site workers,
people that actually work and were exposed to those
soils there. And the other thing was future on-site
workers. Assuming that the site gets developed and
there's somebody working there without any kind of
cleanup, what would be the exposure to those people.
For people to be exposed they have — there have
to be a pathway, I mean how do people get exposed to
contamination. Well, there are two ways you can get
exposed to contamination. There is ingestion, you can
actually eat the soil; you know, you might be having
your lunch break, the dust gets into your sandwich
or your hands and then-you eat the sandwich, that -way
you are eating dirt. You can inhale the dirt, actually
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1 the wind can suspend the soils and then you can breathe
2 them. And the last way is by dermal contact, simply
3 touching the soil. That's the other way you can get
4 into contact with the contaminants in the soils.
5 So for different type of scenarios/ you know
6 that — you just assume somebody's gonna be outside,
7 the pathway will be ingestion and inhalation. So
8 the pathway I set for each different scenario. That's
9 why you see some of them only includes ingestion and
10 inhalation or it includes ingestion, inhalation and
11 dermal contact, which would be the case of the people
12 getting on-site, by the trespassers or the workers.
13 Then what we did is we actually calculated, we
14 quantified what will be the potential threats to the
15 people if they were exposed to those contaminants. And
16 that we expressed that in excess cancer risk. As you
17 know, there is — in any population there is some kind
IS of cancer risk. So we look at excess cancer risk which
19 might happen if people were exposed to those
20 contaminations. And this is a very — these are very
21 conservative numbers, basically by nature we tend to be
22 conservative in these estimates. We make some
23 assumptions to be able to come with those numbers.
24 -For" example/this — this'big one in particular,
25 say children trespasser, on the scenario we assume that
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children go out to the site 350 days a year for 6
years. That's a very conservative scenario. But we
want — we want to err it on the conservative side
rather than being too leisure and then missing some
kind of risk. And the same thing happen with all the
different scenarios, we use very conservative
assumptions just to be sure we err on the safe side.
And as you can see here, we can calculate
different cancer — potential excess cancer risk for
each different scenario. This number doesn't mean that
anybody's getting cancer right now or anybody will get
cancer in two years. This is just a number that helps
you make a decision whether something is to be done or
not at the site. We tell you that that is a potential
there, doesn't mean that it will happen. Just that
there is a potential that it may happen. And we got
different numbers for that. We had for off-site young
children there's a potential of cancer risk of 9 out of
10,000 individuals; for future adult residents 3 out of
10,000; for older children trespassers 4 out of 10,000;
adult trespassers 3 out of 10,000; and workers 1 out of
10,000.
All those scenarios, the ones that actually are
significant based on the current -guidances that the EPA
uses is the last two ones, is the workers. Workers
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were to get on the site and they were to get into those
highly contaminated areas and they were to be there for
25 years working 250 days, 250 days per year, what's
the potential threat for those workers. And what this
worker will be one out of a thousand in each case. So
when they are in the ten thousands means that threats
are not significant enough to warrant any kind of — of
action. But these two scenarios mean that yes, there
are potential risks which we are warranted to take
some kind of action there.
Okay. We have those — we already know that
there's contamination at the site, we already know
that some of the contamination might pose, you know,
unacceptable threat to workers if they were to get to
the site, be in contact with those contaminants. What
are the goals, then, for the Agency for this site.
Well, we have two goals. One is to prevent public
exposure to contaminant surfaces. We don't want — we
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want to keep it that way. Right now there are no
exposure because the site is fenced off, we have
erosion control, we have those measurements. We want
to keep that, we want to keep it that nobody's exposed
to those contaminants.
Our second goal is to reduce the concentrations
of contaminants in the soils to levels which are
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1 protective of human health and the environment. We
2 want to treat those soils/ we want to make sure that
3 those soils are no longer a threat to people. So
4 that's our second goal.
5 Having our goals already set up/ we develop what
6 we call health-based cleanup levels. These are the
7 levels that you can be exposed to under the
8 assumptions — under the assumptions of the baseline
9 risk assessment and not be at any significant threat.
10 We have — if we were to have any concentration of
11 these or below this level at the site/ there wouldn't
12 be any significant risk for people, for workers to be
13 there at the site. So this is actually where we want
14 to get. We know that we have concentration/ many times
15 higher than these levels, so we want to get to these
16 levels to be able to say that yes/ once we get to those
17 levels the soils will be safe. Under those assumptions
18 we're able to eat, able to ingest some of the soils/
19 we'll be able to get in contact with the soils for 25
20 years and still be safe without being no significant
21 threat.
22 So we have the numbers that we have to achieve
23 to make the soils safe. So based on that we develop
24 -cleanup alternatives. What could we do — what can we
25 do with the site. And we developed eight alternatives
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1 for the site at the very beginning, as our
2 alternatives. The first one we considered was no
3 action. No action is that we do nothing, what would
4 happen. We are required to include that alternative as
5 a baseline. That give you that — that give you a
6 comparison toward the rest. We have no action, what
7 happen, something, if you do something this is what
8 will happen. So that's like a comparison we are
9 required to have.
10 The other thing that we look at was access
11 restriction. We put a fence at the site, we put some
12 deed restrictions, nobody will use the property in the
13 future, what would happen. That's one alternative
14 that you can work.
15 The other one will be capping. Capping is that
16 you put a layer over the site, over the soils so people
17 cannot get in contact with the soils.
18 We have off-site disposal, which is to excavate
19 all the contaminated soils and we will send that soil
20 somewhere off site for treatment and disposal.
21 The other one that we look at is incineration;
22 excavate the soils and you put them through an
23 . incineration on-site, and we'll incinerate the soils
24 right there.
25 Next one is on-site treatment composting. We —
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we did a pilot study just to look at our alternative,
and the principle was no different to the composting
that you would do, you know, in your backyard.
Basically you take the soil, you put it on the pile,
you provide some nutrients, you provide air,
temperature controlled and you let the bacteria inside
the soil digest, eliminate the contamination.
Basically that's a natural process.
The next one that we looked at was bioslurry;
it's kind of similar to that, it's the same principle,
you let bacteria eliminate the contamination. The
only difference there is that you are to suspend the
soils in water and then you put that combination of
water and soils into a reactor, what we call a bio
reactor because the bacteria will be eating the
contamination.
And the last one that we look at was thermal
desorption, which is different from incineration. In
this case you take the soil, you put it through a
thermal desorption unit, what you do is you inject hot
air, it could be steam, it can be something like
nitrogen, you put that hot air to the soil, and when
the soil contact — the gas will absorb the
contamination from the soil into the gas phase.
Basically it's like you are volatilizing the
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1 contamination/ you're taking the contamination out of
2 the soil into gas phase, and then you end up with a
3 clean soil because all the contamination was
4 volatilized; and then you have the gas phase which have
5 the contaminants/ and you can do many things with that
6 gas phase. You can either burn that gas phase or you
7 can try to recuperate the contaminant from there/ you
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8 can use a condenser to condense the contaminants back
9 and then you can recycle that or you can burn it.
10 There are many things you can do with the gas phase
11 once the contaminants are out of the soils.
12 So those were the alternatives that we look at.
13 And we put those alternatives into what we call a
1<4 screening process. And basically knowing — knowing
15 the conditions of the site, we — we look to see how
16 applicable they will be for the site/ how effective
17 that will be, how cost effective that will be. Then we
18 end with no action, that one we have to retain again so
19 it's a comparison for anything else. So that one we
20 kept.
21 Limited action. We eliminated that one through
22 the screening process because it doesn't give us any
23 . kind of protection. You can fence the site, you can
-24 post signs but still -the contamination rwill be there
25 and will be a threat to the groundwater, to the
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1 wetlands, and people might get in contact with that.
2 So that was eliminated.
3 Capping. Capping works good for — for
4 correcting the thing about people being exposed to the
5 soils. You put a cover over the soils, then people
6 cannot reach the contaminated soils. Not be able to
7 breathe them or — or eat them. But the problem is
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8 that the groundwater there is such that even if
9 you cap a site the groundwater will still be in contact
10 with those contaminated soils. So yes/ it impedes
11 people from actually touching the soils but the soil
12 will still be a source of groundwater contamination
13 and also surface water contamination. So that's why we
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14 also eliminated that alternative.
15 The next one we look at was excavation and
16 off-site disposal. That worked out fine, you can
17 excavate all the soils at the site. There are about
18 36,000 cubic yards of contaminated soils at the site,
19 so it's a lot of soil. And you can send it out to one
20 incinerator, to treatment facility, there are many
21 facilities that could take those contaminated soils,
22 the problem is that getting rid of those contaminants
23 . outside would cost a hundred and thirty million
24 dollars. .So that was.way too expensive, it wasn't .cost
25 effective. So that was also eliminated.
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The next one we look at was incineration. That's
fine, that will work, bring an incinerator on-site and
burn the soils. The problem with that still that it
was a very costly alternative, was $34 million. So '
that was also eliminated because of the cost involved.
We also had some problem with incineration
because the communities around incinerators are
sometimes opposed to having incinerators nearby. So
that's also from the point of view, sometimes it's not
recommended.
The next one, composting, which was the one that
we did the pile study at the site to see whether that
technique would work or not. The problem with that
technique was that it would not achieve the cleanup
levels that we already established. We already
established that we need to clean the soils so much,
and composting would only take you so far. It will
somehow clean up the soil but it will not clean up the
soil good enough to make the soil safe. And since it
will not make the soil safe, it was also eliminated
from the — from the potential alternatives.
The next one that we look at was bioslurry,
which was some kind of biodegradation. That also would
work, the-problem with that one is that it'-s -also -very
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And the last one that we look at was thermal
desorption, that would give you clean soils, and was to
be more cheaper than any of these alternatives here.
So what did we ended up with. We ended up with really
two alternatives. Two alternatives, really. One of
which is the no action, which we had to keep again as a
comparison. The other one that make it through the
final list was thermal desorption. And just to give
you a little more detail how thermal desorption, this
remedy, will work is that we will actually go out to
the site, we will excavate pretty much most of the
site, this 36,000 cubic yards, and that means in areas
we just excavate one or two feet of soil, in some
areas we might have to go as deep as ten feet of soil.
But we're going to excavate pretty much all this here
property because most of it has creosote contamination
in excess of those cleanup levels we already
established.
We will take that soil and we would sort it out.
As you saw before, we have wood, we have — we have big
rocks, you have metals, you had different kind of
materials. So you have to sort those components out.
Things such as metal -and things that cannot be treated
will be sent off site for disposal, but there's a very
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small volume. All the wood and all the soils could be
treated on-site. The wood would have to be threaded.
You put it through a threader, and you — you make it
small enough that you can put it with the soil into the
thermal desorption unit, so that will work out fine.
You end up only with very small amount of material that
has to be sent out for disposal.
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Once the soils are treated they're safe, they're
clean so that you can put them back to the place where
you excavated them. So that that's — that's just
great, you don't have to send the soils off site, you
don't have to bring lots of clean soil on-site to
backfill, you can use the same material once it's
treated and clean to backfill the site.
One of the things also included in this remedy
will be — you can see — you probably saw, some of
those building that we found there are either in very
bad condition, they're kind of — kind of a hazard. So
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they will have to be demolished because of that. Other
of them that are just around very highly contaminated
area. So they would have to be demolished to be able
for us to excavate the soils and then get rid of those
contamination there. So those areas we generated
from the building would either be decontaminated
on-site and then somewhere like a landfill to be
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1 disposed of, or they can be used on-site also.
2 And the last thing that we recommend as part of
3 our remedy is institutional control. Basically the
4 cleanup that we are designing for this property is for
5 industrial use. So we want — we will like the
6 property to be kept in the same usage as it is right
7 now. During the last meeting that we had here back
8 last summer we have another input in that, people told
9 us that they want to keep that property, put it back
10 into the tax roll, keep it industrial. There were many
11 industry interested in that piece of property which is
12 already surrounded by other industry. We would like to
13 see the same land use kept for that property, and we
14 would be recommending that, you know, to the local.
15 Let me see, what else do we have here. Okay.
16 The cost of this alternative would be $14.8 million.
17 That's how much it would cost to bring those thermal
18 desorption units to the site and to treat the soil. We
19 estimate that will take approximately 12 months to 18
20 months to do all the design and all the contracting.
21 It will take about a year to actually treat the soil.
22 So we're talking about two years to two years and a
23 half to be able to say that — that soils are gonna be
24 clean and .the site will be clean. Or that portion-of
25 the site will be clean.
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1 And this is just — just a diagram so you can see
2 how a typical desorption unit might look. As I
3 mentioned to you before, we have pretreatment where
4 you do excavation/ you do the sorting the different
5 type of materials, you might do some blending, all
6 those things you do in pretreatment. Then you put the
7 soil through thermal desorption units, there are many
8 types that you could use, and these are just a few of
9 them, and then you end up again with the gas phase and
10 the solid phase. The solid phase is the clean soil,
11 the gas phase are the contaminants, but then you have
12 to put some kind of means of treatment control to be
13 able to address them. A city such as this would
14 have to meet — you know, would have to have some kind
15 of emission control standards to ensure it meets all
16 federal and state criteria in terms of air pollution.
17 And the same thing would have to be for the rest,
18 handling of the soils off site, any material that
19 has to be sent off site would also be handled in a way
20 to meet the federal and standard regulations. And
21 that's basically what we have here.
22 So at this point of time we just came to you
23 again with those two options that we have. And we
24 " are -- or those two options we are recommending"that we
25 go ahead and implement the thermal desorption unit to
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1 address the contaminated soils at the site.
2 MS. ECHOLS: At this time we're gonna open up for
3 questions. Please state your name and your address.
4 Any questions?
5 Sir?
6 MR. DIBBLE: I'm Clarence Dibble, from Sidney
7 here. I don't— I'm not sure whether or not/ is it
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8 gonna have any impact on our taxes locally? I'm — you
9 know, I live here, I don't want 14 and a half million
10 dollars coming from my taxes. Is this all coming
11 from the Superfund or is it coming from — local tax be
12 paying it too?
13 MR. GARBARINI: It's all ~ it's all going to be
14 coming from the Superfund at this point in time.
15 Unless — unless we were to go after responsible
16 parties to do the work. It will all come out of the
17 Superfund. It won't affect your taxes individually.
18 There's a certain percentage of the Superfund that is
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19 taken from the general tax revenues.
20 MR. DIBBLE: Well, yeah, I understand.
21 MR. GARBARINI: But otherwise your local property
22 taxes and things like that won't be affected.
23 . MR. DIBBLE: My other question is, I guess, why
24 are we doing anything at all? I mean supposing we
25 build a big high fence around that area, it's not gonna
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1 go anywhere, is it? It's not useable for — the swamp
2 down there isn't useable for building on or anything
3 else. The material that's in there doesn't migrate
4 other places what I'm asking.
5 MR. RAMOS: No, actually the materials and
6 anything at the site will migrate into the groundwater
7 and probably through the wetland through runoff. As a
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8 matter of fact, as part of the continuing investigation
9 that we're doing, the remedial investigation, that
10 includes groundwater investigation. And we found that
11 one of the wells on-site has high concentrations of
12 creosote. Creosote doesn't move fast, it doesn't move
13 much, but when you have such high concentrations in the
14 soils it's bound to go somewhere. So even if we do
15 nothing, just put a fence around, it will still get
16 into the groundwater and probably will get also into
17 the wetlands further.
18 MR. DIBBLE: It's not soluble water, is it?
19 MR. RAMOS: It's not highly soluble but it will
20 move into the well water. It will be like oil into the
21 groundwater and oil into the wet lands.
22 MR. DIBBLE: Okay.
23 MS. ECHOLS: Question, sir?
24 MR.. UMBRA: Yeah, my name's Greg Umbra, and I'm
25 from Unadilla. You said you encountered the water
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1 table in the west end where you dug up and where they
2 build? Did you encounter the water table underneath
3 the site itself? You know, underneath where the
4 building were itself, did you dig down deep enough to
5 the water table there, was the water table consistent?
6 MR. RAMOS: No, actually we didn't — usually the
7 trenches — let me put a map here. Here we are. This
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8 is — this is — you see the property, this is the
9 lines where we did the trenches. As we move west we —
10 the trenches became deeper and deeper. The trenches in
11 this area weren't as deep as the one further down.here.
12 One of the reason is that the soils around here were
13 mostly native soils. And further down here they were
14 just fill. So as you go further back here we had to go
15 deeper with the trenches.
16 One of the thing that we did is that we installed
17 monitoring wells. As part of the continuing
18 investigation we have you'll look closer here, over
19 here and over here, and we have also monitoring wells
20 around here and further — further east on the
21 property. And so — and we put wells in different
22 depths within the aquifer. We had some shallow, some
23 intermediates and some deep. So yes, the trenches
24 around here didn't encounter the water table, it didn't
25 go as deep as — as the water table. It went further
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1 down west.
2 MR. UMBRA: Did you encounter contaminants on the
3 far — on the eastern end of the — on — on the
4 .eastern end?
5 MR. RAMOS: Yes, we did.
6 MR. UMBRA: For the monitoring wells?
7 MR. RAMOS: Actually, as a matter of fact, the
8 well where we found contaminated with creosote is —
9 we can — this well right here.
10 MR. UMBRA: Now, have you determined a direction
11 of the groundwater flow in that area?
12 MR. RAMOS: That's the focus of that IFS which
13 is not the focus of this investigation. This is only
14 for the soils. But yes, the focus of the remedial
15 investigation that we're going to be releasing at the
16 end of the year, it does address that. We're looking
17 at groundwater contamination, we're looking at how the
18 water is moving, which direction the groundwater is
19 moving, how deep is the contamination. We also have
20 other factors around here, as — as you might know,
21 they already found groundwater contamination in this
22 area due to other site.
23 MR. UMBRA: Right.
24 MR. RAMOS: And--so the groundwater picture
25 becomes a little more complicated because you have more
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1 than one plume. Which is kind of a —
2 MR. UMBRA: Right, do you know where the plume is
3 right now? There was a plume encountered on the other
4 site there, but have — have those two plumes come
5 together at any point that you know of? In your
6 studies?
7 MR. RAMOS: That we'll know when we complete the
8 Remedial Investigation Feasibility Study. That's
9 the — that's part of the focus of that other
10 investigation. And we'll have that picture by the end
11 of this year, we'll be able to say yes, this is where
12 the plume of the GCL is, and we have data from these
13 other plumes so we know how that interact and what •
14 events lead down with the plume and also we coordinate
15 to make sure that whatever we do here doesn't affect
16 the remediation already going on to address this other
17 plume. So there are different things we are involved,
18 we want to make sure that that's done correctly.
19 MR. UMBRA: So that is something else in addition
20 to this, the cost of this, you know, if it does get
21 into the groundwater and if the plume has spread out in
22 that area, along with if you start pumping here, well,
23 they've started pumping over toward Route 8, they
24 could — they could start drilling that, the creosote,
25 the plume, toward that, toward that other site there
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1 too. Spreading the plume out.
2 MR. RAMOS: That's correct, the 14.8 million .we
3 just addressed the source of contamination. Which is
4 the — which is the soils. And that was — that will
5 mean that nothing else- will be getting into the
6 groundwater. But the groundwater problem we'll know
7 for sure by the end of this year when we have that
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8 report. Then we'll be able to tell you this is the -
9 extent of the contamination of the groundwater and this
10 is what needs to be done. And taking into
11 consideration all those factors, like existing
12 contamination already from other source/ system already
13 in place for that other source, and also this is a very
14 difficult geology, as a matter of fact, what I've seen
15 in the reports is the groundwater in some areas can
16 achieve — this area might be going this direction,
17 further down might be going a little bit more toward
18 the east, so it's kind of a complex picture for the
19 groundwater. But that's something that we think that
20 we will have a good hold on once we finish the report.
21 MR. UMBRA: Well, that's something else, you said
22 you encountered clay there. You know, the layer of
23 . clay, is it, you know, constant throughout the area or
-24 is -that just one small lens of clay that you have
25 encountered?
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MR. RAMOS: We don't think it is a continuous
layer of clay that would constitute a barrier, a
complete barrier, for contamination to get further
down. I think it's slowing down the contamination.
But it will not — it is not stopping the contamination.
But again/ we are in the process of analyzing all of
this data from the groundwater investigation. And
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right now until we go ahead, we go and complete this
report, we will not have the complete picture of this.
This is the kind of a — in terms of groundwater.
MR. UMBRA: Okay, I have one last question.
During the treatment, you said you're gonna excavate,
okay. When you excavate the fill area there, you're
gonna expose the groundwater. Now, what method are
you gonna use to clean out — clean the groundwater
when that is disposed? You're gonna dispose the water
that would be like — that will be — when you're
digging out that will be exposed water, the ground, the
water table will be exposed there, where in the
pictures that you showed showed the oily film on there.
MR. RAMOS: Yeah.
MR. UMBRA: Are you gonna try to treat that water
right there?
MR. RAMOS: We're only — at this point here, as
far as this remedy, when we excavate we will find an
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1 area where we have, like what we called that, we have a
2 leap, a phase of creosote coming into an area. We will
3 address that. But we.are not addressing the
4 groundwater at this point. We will take care of all
5 the soils which are contaminated, and if we find any
6, creosote in that, you know, concentration of creosote
.7 in that area, we will address that as incidental to the
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8 excavation. But the ground—
9 MR. UMBRA: You said — you said— you said you
10 encountered it with all those pictures there with the
11 fill, the wood, the plastic and everything else was
12 there.
13 MR. RAMOS: Yeah.
14 MR. UMBRA: All right, you're gonna take all that
15 stuff out. Okay? That's gonna expose that water layer
16 there.
17 MR. RAMOS: 'Yes'. Yes.
18 MR. UMBRA: And then you said you're gonna put
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19 the fill in on top of that. You're gonna treat that
20 water, that contaminated water that's right in that
21 area first before you fill back in.
22 MR. RAMOS: Well, we will -- we will do as much
23 of the watering and treatment we need to do to do
24 the excavation. And— and treat the-soil. But we
25 will not be pumping the groundwater all the time from
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1 the trenches to do that. Probably for the groundwater
2 we do what needs to be done for the groundwater, if we
3 need to do some kind of pump and treatment which is
4 what we do sometimes, this remedy takes 20, 30 years of
5 pumping groundwater and treatment. And so that's
6 something that we cannot address with the soil. We're
7 gonna go out there, we're gonna excavate the soils and
8 in the process of excavating the soils we find areas
9 which are, you know, we see creosote like floating
10 on the water or something? Like that, yes, we'll
11 address that.
12 MR. UMBRA: This is an added cost that you
13 haven't even establish yet, right?
14 MR. RAMOS: That's — we think you would include
15 that as part of the watering process. The final — the
16 final cost will be done in the design phase, which is
17 the next phase. Now we know what it is that we're
18 gonna be doing, now we have now to design the facility.
19 Which takes into consideration all those things. You
20 excavate the trenches, you find water, you know, how
21 you gonna deal with that. You have to pump out that
22 water, do you have to construct some kind of a barrier
23 to impede the water into getting into the trench? So
24 all those things are worked -out during the design
25 phase, all those details are worked out during the
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MR. GARBARINI: Our cost estimates here are
usually/ you know, plus 50, minus 30 percent, something
along that order. So there's a lot of variation.
That's what we shoot for in feasibility.
MS. ECHOLS: Any more questions? Craig?
MR. VANCOTT: Craig VanCott with Uni-Lam. Back
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on your baseline risk assessment summary you mentioned
on the older children trespassers, you said that they
would have to — that that study was based on exposure
6 — 360 times per year for 6 years? And then you —
then under the pathway you talk about ingestion and
inhalation and dermal contact. What — how much would
they have to ingest 360 times a year for 6 years to
be in the 4 out of 10,000 excess risk factor?
MR. RAMOS: For the risk"assessment what are the
assumptions. Basically, the basic association for use
for ingestion is half a gram per day, is 480-something
milligrams per day, which is half a gram per day.
And I know we spoke about this before.
MR. VANCOTT: Right.
MR. RAMOS: And I think we made a mistake when we
transferred the units. It's actually the personal — a
person — let's put it this way, for a person— the
assumption for ingestion of soils at the site for long
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term, say like a resident of the site, older
trespassers? Generally the chance you have you would
have to — the assumption is that you would be
ingesting about-half a gram per day/ usually for 25
years, for — for about six years the assumption's
involved there. For children it's six years. I mean
there are — there are conservative assumptions
assuming that you actually ingest half a gram of dirt
for 365 days a year most of the time for 25 years.
Most of us will not be doing that, we won't be
ingesting a half a gram of dirt for the rest of our
life, I guess, but that's the assumption that we are
required to use on the baseline risk assessment. And
again, to make sure that we don't underestimate the
risk associated with the site.
MR. VANCOTT: And then one other thing. The —
and I told you this before in meetings that weren't
public, but I'm concerned about the viability of the
businesses in the area with — already one is gonna be
leaving the — that site, the quality hardwoods, and
moving across the river, but we would hope that the EPA
works with the Village and the local manufacturers in
the area to make sure that they're — the viability of
those businesses continues.
MR. RAMOS: Yeah, that's — that's a point we'll
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take in. I mean we — you know, we have been talking
with the Town from the very beginning, we had a small
meeting last year, I know we have spoken to you and the
other businesses around there to make sure that our
investigation doesn't interfere with your activities
there. We try to coordinate, you know, so we have not,
you know, harmed the way to other businesses. The
«
cleanup for this property is. designed so that property
can continue to be an industrial property or be in
the — turned back into the tax roll, into the tax
rolls that could be used for the future again. For
another type of commercial or industrial purpose.
MR. DAVIS: Not a tie and treating plant.
THE STENOGRAPHER: I need your name.
MS. ECHOLS: Maynard Davis.
MR. GARBARINI: Just to add to that too, I think
we've appreciated the cooperativeness of the businesses
that have been down there as well as the town officials
>
here. But obviously we have a job to do in terms
of protecting the environment, so we — we try and keep
a balance with it too. But we've got to make sure we
get our job done, and you guys have been real
cooperative with us to date, so we appreciate that.
MS. ECHOLS: Sir, did you have a question?
MR. CARR: Yeah. Have you detected any plume,
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1 Decker Sawmill, in that direction at all?
2 MS. ECHOLS: Could you give your name for us,
3 please.
4 MR. CARR: Jim Carr, I'm from Gilbertsville. You
5 have monitoring wells around that property. Have you
6 detected any leaving that area which you are testing
7 there?
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8 MR. RAMOS: Yes, we — I'm sorry, go ahead.
9 MR. CARR: Yeah, that's what I was wondering,
10 what have you found there.
11 MR. RAMOS: We haven't finalized, as mentioned
12 before, you know, right now we are focusing on the
13 source of the contamination, which is the soils on the
14 GCL portions of the site. We are looking at the
15 groundwater, excuse me, and we have the data back from
16 the lab, but we have to make sense of that data. To
17 see, you know, we know that it wasn't really
18 contamination there from before, we have to see where
19 this contamination from GCL and how we gonna deal with.
20 At this point we cannot tell you really, you know,
21 what's — what's the groundwater picture yet. We'll be
22 able to tell you that when we come back by the end
23 of — of this year with the report which addresses
24 exactly that point, what kind of contamination is there
25 from GCL.
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1 So at this point I cannot tell you, you know, one
2 way or the other what is in the groundwater other than
3 tell you that there was one well on-site on the GCL
4 property where we found creosote.
5 MR. CARR: Well, I know testing is really
6 expensive, so, any time, you can just arbitrarily test
7 a lot of area unless you're really going to have a
•
8 reason to go there, I mean.
9 MR. RAMOS: Exactly. We — we were fortunate
10 enough that we were able to use data already generated
11 by — by the Amphenol Arrowspace because they
12 already — they have monitoring wells in that area, so
13' we were fortunately enough to save money because we
14 were able to use their data and their wells actually to
15 collect more data. And we just, you know, having
16 already that data we just decided which — which
17 additional information was needed to fill those data —
18 data gaps. And that's what actually we're tying to do.
<*
19 Because you're right, I mean, you know, in studying
20 wells and sampling wells is a very expensive
21 enterprise, we try to minimize that to the extent that
22 is possible. And in this case we were able to because
23 there were already information available. And we have
24 - shared that information also with— with Amphenol,
25 you know, people. They gave us their data, what they
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have found, and we gave them our data to see what we
have found.
But the whole picture, just I mean the data's
just one step, you get all of these analytical results
from the lab, you have to make sense of it, what does
it mean, I mean what's the picture based on that. It's
like small pieces of a puzzle we need to put together.
*'
And that's what we're doing right now.
MS. ECHOLS: Sir?
MR. WILKLOW: Couple different questions, my
name's Ted Wilklow, I'm from the Town of Sidney. In
perspective can you tell us already how much money has
been spent at that site?
MR. RAMOS: Between the removal and — removal
action and the remedial investigation we have spent
over $2 million at the site.
MR. WILKLOW: Over two million. For the off-site
incineration, we have a coal fire generator utility
•
nearby which I understand is certified or licensed for
coal tar. Was that considered?
MR. RAMOS: We in conversation, as a matter of
fact, from the State, the Department of Environmental
Conservation brought that to our attention. And that's
one thing that we will be exploring to see whether we
could use — to ask if we can use their facility. Some
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1 of the problem here is that the waste that we generate
2 is classified as hazardous waste. And so that limits
3 the number of places where you can deal with that, you
4 know, you can deal with that, the number of places
5 which are licensed to deal with that waste. And we
6 simply want to explore that option to see whether, you
7 know, we could use that facility, and we're gonna keep
8 talking with New York State DEC and also to that
9 utility to see if in substance it could be done to that
10 fact.
11 MR. GARBARINI: But there's really — I think
12 it's important to note that we are dealing with
13 hazardous wastes here and they are not permitted to
14 handle hazardous waste at this point. Okay, so that's
15 a very — it's a permanent process to be able to do
16 that. So that would take some time and some work. So
17 until we reach that point in time they won't be allowed
18 to handle our wastes.
19 MR. WILKLOW: I guess I was putting coal tar in
20 that general category. And maybe I shouldn't.
21 MR. GARBARINI: Right.
22 MR. WILKLOW: One last question. Is — out of
23 the roughly 15 million, can you break that down at all
24 as how much of that you're estimating is going to
25 private contractors and how much of it's gonna be the
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overall let's say monitoring by the Government? Or,
can you break down the 15 million in any way?
MR. RAMOS: We pretty much — those 15 millions
are for — that's the cost of getting the remedy there.
That doesn't include the cost of the Government and
overseeing that remedy. That's because of actually
having a private contractor to design/ build and run
that facility. The EPA and Government costs are not
included there.
MR. GARBARINI: The Government costs for
oversight would be very small in comparison to that
$15 million figure, though.
MR.'WILKLOW: So that's the contracting costs to
take care of the site.
MR. GARBARINI: Yeah.
MR. WILKLOW: Thank you.
MR. CARR: Again on the classification —
MS. ECHOLS: Your name again?
MR. CARR: — creosote, coal tar. Jim Carr.
MS. ECHOLS: Okay.
MR. CARR: Isn't creosote considered coal tar?
And isn't — aren't they hazardous? And the power
plant in the Southern Tier right now is allowed to
handle coal tar soil and burning. Which would be
hazardous, I would think. Have you —
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MR. GARBARINI: It's probably a hazardous
substance, whether it's actually listed as a listed
hazardous waste or not I can't tell — I can't tell you
I know that, but I would tend to doubt that it was.
And if it is perhaps it's got some sort of specific
exemption which allows them to handle the waste at
that facility. But it's — it's not a, quote, unquote,
Subtitle C hazardous waste incinerator, which is what
we would generally need to send this material to.
MS. ECHOLS: Sir, in the back?
MR. DAY: My name's Keith Day, from Greene, New
York. And I'm responsible for NYSEG's coal tar soils
program. We are — the soils that we're permitted to
receive are classified as solid waste. Through a
process that's been approved by the EPA you can go to
these MGP sites, take a hazardous soil, blend it with
less hazardous soils, render the whole combination not
hazardous. So that's how we're able to receive those
*
materials. Anything coming in to Jensen Station is
nonhazardous. So my question would be is if a variance
could apply to the same site, the creosote contaminated
soils, if they're looking at the analytical datas there
are areas on the site that are less contaminated, could
that soil be blended with the more contaminated
material, the combination of material be rendered not
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1 hazardous? Again, NYSEG is only permitted to burn
2 nonhazardous soils at this time. But that's really
3 what our program involves. And, any further question
4 related to that.
5 MR. GARBARINI: You're actually able to blend
6 hazardous —
7 . MR. DAY: Yeah, EEI document, Edison Electric
•'
8 Institute document, myself and one other gentleman
9 served on that committee in the development of that
10 document, we worked with utilities all over the country
11 because there's so many of these MGF sites across the
12 country, we got together and developed a document for
13 taking hazardous soils on an MGP site, okay, which
14 there are some right here; Onebnta has a site, Norwich
15 has a site. Take those soils, you blend them on the
16 MGP site, the hazardous soils with less hazardous
17 soils or coal or sawdust or fly ash or something of
18 that nature, all this has to take place right on the
19 MGP site, and it renders the material nonhaz' —
20 nonhazardous, okay. And —
21 MR. GARBARINI: So basically you're diluting the
22 hazardous nature of the —
23 MR. DAY: You're diluting the hazardous nature of
24 it, and once it's rendered nonhazardous it can be taken
25 to a utility boiler. And this document was approved by
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MR. GARBARINI: When was that approved?
MR. DAY: When was it approved?
MR. GARBARINI: Yeah.
MR. DAY: In April of — I have a copy of the
document here.
MR. GARBARINI: Just the year would be fine, I'm
just wondering.
MR. DAY: Well, it's right on the front of it,
so.
MR. GARBARINI: And were the soils actually —
were those hazardous substances in the soils or were
they listed hazardous wastes?
MR. DAY: They're listed hazardous wastes. It
was approved by the EPA in April of '93. It's called
manufactured gas plant site remediation strategy.
MR. GARBARINI: Okay, well, we can — maybe we
can talk some more about that.
*
MR. DAY: Just one thing for consideration.
MR. GARBARINI: Okay, can we get a copy of the
report?
MR. DAY: Certainly.
MS. ECHOLS: You signed it?
MR. DAY:" Yes, I did.
MS. ECHOLS: Okay.
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MR. CARR: Jim Carr again, make a comment that
NYSEG raises it's rates quite a lot lately, maybe they
can use the energy.
MR. DAY: Well-taken.
MR. GARBARINI: But just add one thing there,
generally we're pretty much directed to go for
permanent treatment remedies, you know, remedies that
actually render wastes nontoxic. And one of the things
we're generally diverted away from is diluting the
hazardous wastes to various guidelines. So that's just
a point of clarification from our perspective. But
we'd definitely like to talk to you about it.
MR. DAY: Could I comment further? Quickly? I
took a look at the site today, and just by looking at
the volume of wood on that site that it looks like a
lot of it is very, very lightly contaminated wood. And
the wood is an excellent product for chipping up and
blending that with the nonhazardous material, and that
wood is gonna go into your thermal desorption unit
anyways. And your thermal desorption units, my
understanding, is gonna be about 700 degrees. And I
don't know what the temperature of the off gasses is
gonna be, but the utility boiler's upwards of around
3,000 degrees. So the level of destruction is
certainly there, but you still have the parameter of
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the material does have to be rendered nonhazardous on
your site. If it were to come to us. And right now
we're not permitted specifically to receive creosote
contaminated soils, just coal tar. So there'd have to
be some variance.
MR. GARBARINI: Thank you.
MS. ECHOLS: Any more questions? Sir?
«'
MR. GLEASON: Yes, Sam Gleason from Syracuse.
Has a consent order been established for the site?
MR. GARBARINI: No.
MR. RAMOS: No.
MR. GLEASON: Okay, there is — what about —
there's talk, there's mention in here about community
acceptance of the preferred alternative will be
assessed in the ROD? Is there gonna be a ROD
established?
MR. GARBARINI: Yeah.
MS. ECHOLS: Yes.
MR. GARBARINI: We're hoping to sign a ROD next
month, by the end of September, and there will be a
responsiveness summary that would be part of that
Record of Decision. Which would respond to any public
comments we receive during the course of the comment
period.
MR. GLEASON: What is the outline for the ROD
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1 submittal, is it just a — is there a 30, 60 and 90
2 percent submittal?
3 MR. GARBARINI: No, it's very conceptual; if
4 you were gonna call it a design document it's very,
5 very, very conceptual. Basically we just take the
6 results of the Focus Feasibility Study, summarize them
7 in a shorter document, and then provide the rationale
•'
8 for our selection of one of the alternatives that are
9 described in the document. And then — then the next
10 stage would most likely be — there are two types of
11 designs that are processes that we go through, one is
12 the 30, 60, 90, lot of detail designs. Lot of details
13 in the design. Another one is a request for proposal
14 where we basically just have a conceptual design and we
15 ask someone to come on-site, there are people that bid
16 on the project based upon performance-based
17 specifications. For instance, we give them the cleanup
18 numbers that were just went over before, say we want
»
19 you to bring a thermal desorption unit on the site and
20 we want you to achieve these levels and these emission
21 requirements. Tell us how much it's gonna cost. Give
22 us a bid and also give us detailed designs as to what
23 your unit looks like that you're gonna treat the
24 materials with. So it would end up on this-site. We'd
25 probably end up going with the request for proposal
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MR. GLEASON: But wouldn't the — that would also
have to include the treatability study, right? I mean
'cause the treatability would have to be incorporated
into the ROD.
MR. GARBARINI: No, the ROD would not include
treatability studies. Treatability studies work would
be incorporated into the design.
MR. GLEASON: So you would have to guarantee that
before you did your treatability study?
MR. GARBARINI: Guarantee the process would work?
MR. GLEASON: The process?
MR. GARBARINI: We'd do some treatability study
testing just to show that we're confident/
yeah.
MR. RAMOS: Just a point there/ I mean the
technology's actually been proven to work for this kind
of contamination. Really what it would do for you at
this time would give you the optimal operating
conditions for that/ for that process. So whoever
will be bidding on this system would actually do
the study because they want to optimize their design.
They'll do it basically for that, but the technology
will work. I mean it's been used already at other
sites for the same type of contamination. So the
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question is not whether it will work or not but the
question is what is the most optimal operating system
for that parameters. And that's probably what they
will do.
MR. GLEASON: Just to establish your blending
grades or something like that?
MR. RAMOS: Same pictures, flow rates, blending,
•' .,
you know, water contents, all those, the core of the
operation, you want to optimize the operation. That's
what you do on your treatability study.
MR. GLEASON: You talked, you just had mentioned
about air quality. Have there been — have there been
cleanup levels established for the air emissions?
MR. GARBARINI: We would — we would follow the
New York State air guide. It's a — it's a guide,
basically, it's not — I don't think it's promulgated
regulations but there are guidelines that the State
uses. And we'd also use federal regulations. So yes,
they have been established.
MR. GLEASON: So then it would be up to the
contractor to establish a permit for the site? An air
discharge permit?
MR. GARBARINI: On Superfund sites per se you
aren't required to obtain permits but you are required
to meet the substantive requirements.
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. 1 MR. GLEASON: Yeah, but for the incineration
2 you'd have to.
3 MR. GARBARINI: For the thermal desorption?
4 Yeah.
5 MR. GLEASON: I understand this is Superfund, but
6 . you still would have to go through an approval process
7 with the DEC.
8 . MR. GARBARINI: Exactly. .But that ~ that
9 approval process, a lot of the — a lot of the
10 paperwork should be cut out of that. You'd still have
11 to go — when you have the unit on-site you'd have to
12 be aware of the fact that when you put the bid in you'd
13 have to meet certain requirements, and then when the
14 unit is on-site we'd actually go through a testing
15 phase to make sure all the emission requirements were
16 met.
17 - MR. GLEASON: It just seemed like an aggressive
18 schedule you're talking if you mentioned a year to get
*
19 someone on board and to establish everything and then a
20 year construction.
21 MR. RAMOS: We're saying a year, year and a half.
22 The reason for that is that these units are mobile
23 . units. They are brought on-site, they're already
.24 built,.they just — a contractor-would just bring it
25 on-site and build, support the facilities and then work
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out with the, you know, the optimal corporation or
safety for that system. So you start from scratch, you
know, like you will do for something else. Groundwater
pump and treatment facility, you know, you have to
start from scratch, you have to build the whole thing
from nothing. It's not like you're bringing, you
know, a system on-site. This one is not a system where
•
you can bring, you know,-bring assembled on-site, all
right. It's a mobile unit.
MR. GARBARINI: That assumes we would use the
RFP performance-based specifications rather than the
detailed approach. If we went through the detailed
approach here it would take us two and a half years,
probably.
MR. GLEASON: Construction, that would be done
during a year, just front end stuff I would think
would take more than a year.
MR. GARBARINI: Like Carlos said, a year, year
*
and a half, I'd say probably more toward the year and a
half side of things. And if it was detailed design it
would definitely be probably over two years. Designs
generally are running two years. But since this one is
an RFP, a performance based, at least that's our
intention, it should-be able to be a little bit
quicker.
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1 MR. GLEASON: Back to the blending, do you think
2 that with the amount of organic material that is
3 present on-site that you could actually obtain a
4 nonhazardous level in that material? Just through
5 blending, with the absorbed material in the organic?
6 MR. GARBARINI: I know it sounds like it's
7 basically a — I mean it's — if we have enough clean
8 wood around and we blended it.
9 MR. GLEASON: Yeah, but if you did an extraction,
10 what you're saying is you would blend the material to
11 allow for an extraction level to be nonhazardous? I
12 mean would you take an inorganic material and you
13 mix — you have a hundred yards and you mix another
14 hundred, 200, you've doubled it and you might be able
15 to deem it as nonhazardous, but if you have an organic
16 material —
17 MR. GARBARINI: I'm not that familiar with what
18 they're doing out there so I'm not exactly sure how
19 they're achieving that. But we're dealing with listed
20 hazardous wastes. If we were dealing with
21 characteristic, it sounds like you're somewhat familiar
22 with the process, if we were dealing with
23 characteristic hazardous wastes and then you blended
24 them and then you did the extract you might be able to
25 achieve it that way.
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MR. RAMOS: Two types of listed wastes.
MR. GARBARINI: We're gonna have to get below
health-based levels or treatment levels.
MR. RAMOS: You do have hazardous waste contained
within the soil. You have to treat to a level where —
to health-based level to say that the soil no longer is
a hazardous waste because it isn't hazardous listed
»
waste. And in the case of creosote, this site we have
two different types of waste. One, one type is just —
one is processed either — for those people familiar
with the EPA regulations how we classify hazardous
wastes, source at the site will be classified two
different types of hazardous waste. Because the
processes they use at the site.
MR. GARBARINI: So whether we're confident or
not, we don't — we don't know, we're just sort of
having a discussion here for the first time about it.
MR. GLEASON: I understand.
MR. GARBARINI: We're not really sure what
they're doing but we don't want to just off the bat say
forget it.
MR. GLEASON: You're talking incineration versus
desorption, that's a whole different process. The
reason why the incineration was ruled out in
feasibility was cost, not really because of process.
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MR. GARBARINI: That's true, yeah.
MR. RAMOS: Yes.
MR. GARBARINI: Yeah, I could see some real road
blocks using the approach that they're using/ but/ you
know, we haven't really taken a look at what they've
done out there, so.
MR. GLEASON: Well/ it is — like you said/ it
was just established in '93, so I mean it's fairly —
it's fairly new/ so.
MR. GARBARINI: Right. And EPA policy regarding
the use of incinerators for different types of things
has —
MR. GLEASON: Right.
MR. GARBARINI: — sort of come under some
significant attention over the course of the last
couple years. I'm not sure exactly where that policy
is going either, so that could put up some sort of road
block also.
MR. GLEASON: It would just cause you people more
paperwork, really.
MR. GARBARINI: Uh-huh.
MS. ECHOLS: Any more questions?
(No response)
MS."ECHOLS: Okay. I guess we're-gonna end here.
I would just like to let everyone know that the public
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comment period began on July 30th and it ends on
August 29th. If you have any written comments, you can
send them to Carlos, his address is in the proposed
plan on the second page, and he'll address those
comments, questions and questions. On that note, I
guess we'll resume. Thanks for coming out.
(Proceedings were adjourned at 8:4y p.m.)
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IN THE MATTER OF:
ON:
BEFORE:
CERTIFICATE
Public Meeting
GCL Tie & Treating Superfund Site
Tuesday, August 9, 1994
RUTH I. LYNCH
Registered Professional Reporter
This is to certify that the foregoing is a true and
correct transcript, to the best of my ability, of the
stenographic minutes of a public hearing held in the
above-mentioned matter, on the above-mentioned date, and
of the whole thereof, taken by Ruth I. Lynch, Registered
Professional Reporter.
EMPIRE COURT REPORTERS
fCi fii
Signed this / / day of
BY_
1994
Ruth I. Lynch / )
Registered Professional Reporter
Telephone: (607) 724-8724
Empire Court Reporters
One Marine Midland Plaza
Binghamton, NY 13901
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APPENDIX E
LETTERS SUBMITTED DURING THE PUBLIC COMMENT PERIOD
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August 18, 1994
GEMEPA 94-0033
Mr. Carlos R. Ramos
Remedial Project Manager
U. S. Environmental Protection Agency
26 Federal Plaza, Room 29-100
New York, NY 10278
RE: Superfund GCL Tie & Treating Site, Operable Unit 1
Town of Sidney, Delaware County, NY
Dear Mr. Ramos:
New York State Electric & Gas Corporation (NYSEG) has reviewed the referenced
proposed plan which describes the remedial activities at the GCL Tie & Treating Site. We believe
that our power generating stations offer a unique and cost effective permanent disposal option.
for the contaminated material.
NYSEG proposes that the creosote contaminated soil and debris be excavated and
transported to our Jennison Generating Station in Bainbridge, NY. The material will then be
blended with coal for thermal destruction in the boilers, which operate at approximately 3000°F,
and the energy component of the material will be converted to electricity.
Existing NYSEG permits, which contain strict special conditions and regulatory
requirements, should be sufficient for creosote contaminated soil and debris to be burned in our
utility boilers. NYSEG has New York State Department of Environmental Conservation (NYSDEC)
permits to bum coal tar soil (CTS) and tire derived fuel (TDF) at Jennison Station. NYSEG's
Hickling Station, located in East Coming, NY, has boilers similar to Jennison Station and has
NYSDEC permits to bum CTS. Also, having conducted a very successful test bum, we expect
to soon receive a NYSDEC permit to routinely bum creosote treated wood (CTW) at Hickling
Station.
From NYSEG's perspective, there is essentially no difference between creosote and coal
tar. Creosote is a derivative of coal tar and, as noted above, we are permitted to burn CTS which
is the coal tar material from former Manufactured Gas Plant (MGP) sites. To mitigate potential
concerns regarding hazardous waste, enclosed is a copy of the EPA approved MGP Site
Remediation Strategy document. This approval allows MGP site wastes to be rendered non-
hazardous on site if they are destined for a utility boiler.
We look forward to the opportunity of providing this cost effective beneficial service.
Sincerely,
£, (i
ru^
M
Murphy ' /
Manager, Alternative Methods
PMM/fhl
Enclosures
cc: Steven Hammond - NYSDEC, Albany
Walter Demmick - NYSDEC, Albany
Martin Brand - NYSDEC, Albany
John Cianci - NYSDEC, Albany
An Ecual Cpconunity r.7?picyr'
F:1994/PMM-73
New York State E!ec:r:c Z Gas Circntion C:rporate Orive-Kirkwoot) Industrial Park, P.O. Sox 5224, Binghamton, New York 13902-5224 (607; 729-255)
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, O.C. 20460
oe
SOLID WASTE AND EMERGENCY RESPONSE
APR 2 6 1993
MEMORANDUM
SUBJECT: Remediation of Historic Manufactured Gas Plant
Sites
FROM: Sylvia K. Lowrance, Direc
Office of Solid Waste
TO: Regional Waste Management Division Directors
Attached please find a document that describes.a strategy
for voluntary remediation of historic manufactured gas plant
(MGP) sites. There are in excess of 1500 historic manufactured"
gas plant utilities. The utility industry is interested in
initiating voluntary assessment and remediation of the sites;
Last year, under the aegis of the Edison Electric Institute, the
industry requested the Agency' s assistance in clarifying the
applicability of existing RCRA regulations to certain remediation
activities and materials at these sites. At the direction of the
Assistant Administrator, a group was established under the
leadership of the Office of Solid Waste to work with Edison
Electric Institute (EEI) to clarify the regulations and thereby
facilitate early voluntary clean-up. The EPA working group
included representatives from various Headquarters offices as
well as Region VII, who has had extensive experience in
addressing MGP sites.
The attached strategy document was developed by EEI for use
by its member companies. Its purpose is to claz*ify the RCRA
regulations and other requirements applicable to MGP sites. It
has been reviewed and commented on by the EPA working group.
The strategy document consists of legal interpretations of
EPA rules and regulations as well as technical and procedural
guidance that either draws directly on published EPA guidance or
constitutes EEI's best engineering or technical judgement based
on their experience at MGP sites. OSW expects that the strategy
would be implemented taking into account site-specific
circumstances and that it would not necessarily be appropriate or
practical at all sites. The strategy does not supersede existing
regulations; it is not intended to be the presumptive remedy
under CERCLA; nor can it serve as a shield against enforcement
under RCRA or any other statute. Rather, it is intended to
provide useful, practical advice on how to address materials at
°aor
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these sites that may exhibit the RCRA characteristics.
It is my view that the strategy described in the document
can be implemented in a fashion that is consistent with existing
federal RCRA regulations and, thus, protective of human health
and the environment. I encourage Regions and States to work with
site owners in implementing the strategy, thus promoting early
and voluntary clean-up.
The remediation strategy is based on the fact that
contaminated soils generated at these sites are capable of being
burned with coal and other fuel in high efficiency utility
boilers. Prior to the burning of these materials in utility
boilers, remediation waste that exhibits a hazardous
characteristic will be rendered non-hazardous before it leaves
the generation site. This may be accomplished without tha delays
caused by RCRA permitting through the use of 90-day tanks,
containers, or containment buildings covered by 40 CFR Section
262.34(a). Under federal regulations, waste may be treated in
such units during the 90-day accumulation period without a
permit, and if the waste thereafter no longer exhibits a
hazardous characteristic, any further management of the waste, .
including the burning of such materials in utility boilers, no
longer would be subject to Subtitle C of RCRA.
Contaminated soils addressed in this strategy are those that
are former Bevill wastes and are hazardous under the
characteristics. Land disposal restrictions do not currently
apply to these wastes and therefore LDR compliance should not be
an issue at this time. However, it should be noted that LDRs
will be promulgated in the future. The recent "Third Third"
court decision, however, may have an impact on the approach
discussed in the strategy sometime in the future. In the
-development of strategies to conduct remediation activities, it
would be appropriate to consider treatment in anticipation of
future LDR requirements. I will keep the Regions informed as to
the effects of this decision on all aspects of our program.
Throughout the document, reference is made to consultation
with and obtaining approvals from appropriate governmental
authorities. The assumption underlying the document is that the
remediation activities are not being carried out under the
Federal Corrective Action or Superfund program but that they are
being voluntarily conducted with appropriate state and/or local
oversight. The document is not intended to provide detailed
procedural guidance on obtaining governmental approvals. And, as
always, state requirements can be more stringent than their
federal counterpart.
I view the attached remediation strategy as another step in
the direction of achieving more risk-oriented and effective
application of RCRA regulations to environmental clean-up
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activities. As the Regional Offices gain experience working with
these sites, I would appreciate hearing from you if the
recommended strategy is helpful in expediting clean-up and if you
encounter any problems that further or more specific guidance
would alleviate.
If you have any questions about this strategy document,
please call Ed Abrams, Chief, Listing Section at 202-260-4770, or
David Bussard, Director, of the Characterization and Assessment
Division at 202-260-4637.
Attachment
cc: OSW Division Directors
MGP workgroup
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MGP SITE REMEDIATION STRATEGY
I. Introduction.
The manufactured gas industry operated during the period from the early 1800s
until the mid-1950s. An illustration of a typical manufactured gas plant (MGP) that
operated during that period is shown in Figure 1. Included in this illustration are
several key structures including the gas generator house, the gas purifier boxes,
the gas relief holder, the product gas storage holder, the tar separator and the tar
.well. These structures were central to the production, purification and storage of
'the manufactured gas and to the management of the by-product tar and process
cooling waters. _v
There are in excess of 1500 historic MGP sites and a substantial number of these
sites will undergo assessment in the near future. The purpose of this document
is to provide guidance to facilitate remediation activities involving excavated solid
materials generated at these historic MGP sites in a manner consistent with RCRA
regulations currently extant. Thus, for example,-to the extent these solid materials
are classified as hazardous wastes, no land disposal restrictions ("LDRs") currently
apply because LDRs have not yet been promulgated for these wastes. Future
EPA rulemakings could affect the way cleanup and disposal activities at MGP sites
are regulated.
This strategy document will address activities insofar as some of the excavated
solid materials may be characterized as hazardous wastes under the Resource
Conservation & Recovery Act ("RCRA") and hence may be subject to regulation
under Subtitle C of RCRA. The on-site activities are:
Site characterization - the assessment of in situ MGP site materials
(e.g., sludges, coal tar contaminated soils and sediments) to be
excavated- in order to determine appropriate materials handling
practices and procedures;
Excavation of materials -- the generation of, wastes subject to
regulation under RCRA; and
Accumulation and treatment of excavated wastes in 90-day units
excluded from RCRA permit requirements.
In addition, the document will address the off-site transportation of any
excavated waste that may remain subject to Subtitle C regulation when it leaves
the site of generation. It will not address other site remediation issues at
this time. The utility company that has been identified as an entity that may
be liable for addressing environmental contamination at the site and for
undertaking clean-up activity .will -be referred to herein either as the
"Company" or as the "Generator" of the waste removed from the ground.
References in this document to activities taken by a Company may be deemed to
include contractors or other Company representatives.
1
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FIGURE 2
PLAN AND ELEVATION VIEW OF SUBSURFACE STRUCTURES
AND HOT SPOTS OF CONTAMINATION AT TYPICAL MGP SITE
TAR WELL
PLAN VIEW
GRADE
SOIL
COAL- TAR
son.
^—COAL TAR
COAL TAR/DEBRIS
i -J
• EXCAVATION BOUNDARY ELEVATION VIEW
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II. Purpose of the Strategy Document.
This strategy document is intended to facilitate responsible parties undertaking the
source removal of heavily contaminated organic residues (i.e., coal tars) and
contaminated soils at historic MGP sites in a manner that is consistent with the
RCRA hazardous waste program. This strategy document does not address other
remedial actions such as groundwater remediation. To the extent required by
existing federal or state regulatory requirements, all removal actions of MGP site
contaminated material that exhibits hazardous characteristics must be performed
with the oversight of appropriate regulatory agencies. To that end, this document
sets forth management strategies consistent with the Federal RCRA regulations
that may be used at MGP sites where excavation of waste that is potentially
hazardous is expected to occur. As discussed more fully below, this document
sets forth procedures under which generators of any hazardous MGP site
remediation wastes may manage these wastes in on-site 90-day accumulation
units pursuant to 40 C.F.R. § 262.34. If within the 90-day period contemplated by
§ 262.34 these characteristically hazardous wastes are treated and thereby
rendered nonhazardous, they would cease to be subject to regulation under
Subtitle C of RCRA and there would be no regulatory barrier under Subtitle C of
RCRA for the burning of these materials in utility boilers or similar high efficiency
combustion units. The recent decision of the U.S. Court of Appeals in Chemical
Wsste Management v. FPAT 976 F.2d 2 (D.C. Cir. 1992) calls into question EPA's
rules regarding application of LDR standards to wastes which exhibited a
hazardous characteristic at the point of generation, but no longer exhibit the
characteristic. Tne effects of this ruling ari stii! under consideration at EPA, and
may require reconsideration of this remediation approach after LDRs become
applicable to MGP wastes. These materials would then be subject only to
regulatory requirements applicable to nonhazardous solid wastes or to
nonhazardous waste-derived fuels. If the waste cannot be treated within the 90
days, generators must request an extension from the Regional Administrator or will
be required to obtain a permit.
It should also be made clear that this document applies only to the management
of excavated solid materials that exhibit a hazardous characteristic." The
management strategy outlined here does not apply to any listed hazardous wastes
that may be excavated from a historic MGP site. The detennination of whether
listed hazardous wastes are present is to be based on available site information
or records, such as manifests, storage records and vouchers, about the source of
contaminants, as described by EPA, but in the absence' of such information, the
Company may assume that no listed hazardous wastes are present. See 53 Fed.
Reg. 51394, 51444 (Dec. 21,1988); 55 Fed. Reg. 8666, 8763 (Mar. 8,1990). The
Company is expected to make a reasonable inquiry into whether listed wastes are
present at the site. Where required by applicable federal or state regulatory
requirements, this determination is to be made in consultation with overseeing
agencies. This strategy also does not apply to materials at an MGP site that may
contain regulated levels of poiychlorinated biphenyls ("PCBs").
It should be understood that this document is not a detailed procedural manual for
dealing with federal, state or local regulatory agencies, but constitutes a general
strategy for remediation of historic MGP sites in a manner consistent with RCRA
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regulations. Except for RCRA, it does not evaluate the. remedy for consistency
with the Clean Air Act or other statutes, and it does not address other possible
remedies that may be more appropriate to the characteristics of a particular site.
As a strategy for facilitating voluntary remediation activities, it should not be
regarded as supplanting the. Superfund process for remedy selection or creating
a presumption in favor of this strategy where it may not be appropriate to the
characteristics of the site.
III. Characterization of the Excavation Zones.
Since the wastes at these historic MGP sites generally were disposed of before
the enactment of RCRA and thus before the November 19, 1980 effective date of
EPA's hazardous waste treatment, storage, and disposal facility regulations, the
wastes currently at these sites have not been subject to RCRA regulation. 53 Fed.
Reg. at 51444; 55 Fed..Reg. at 8762-63. However, if these wastes are excavated
and removed from the disposal unit (e.g., the tar separator or well), or if they are
managed in tanks, containers, or containment buildings, they are deemed to have
been generated and become subject to the requirements of Part 262 of EPA's
rules.
Most MGP sites, today, have had the primary gas generation and purification
structures razed. Occasionally, one or more gas holders may remain standing
although these too have often been demolished to ground level. As a result of the
plant operations and these demolition activities, these sites may contain areas
where coal tar.s have accumulated or where coal tars were stored. Tnese
locations typically include, but are not limited to, the subsurface portions of gas
relief holders that were also known as "pit holders" and the remaining subsurface
structures associated with tar separators and tar wells. The tar separators were
rectangular wood or concrete basins that were used to separate the tar from the
recirculating process cooling waters. The tar wells were similar in shape and
construction to the tar separators but were used to store tar prior to its dewatering
and sale. These areas of more highly concentrated coal tar contamination are the
areas that may pose a potential risk to groundwater and are often targeted for
source removal actions. These areas also provide the greatest potential to exhibit
the toxicity characteristic for benzene. Rgure 2 depicts a plan and elevation view
of an MGP site today and the areas that are commonly founcrand designated as
excavation areas. The areas associated with the tar separators and tar wells
generally consist of layers of residual coal tar which remained in the structures at
the time the plant was closed and which were covered with soil during demolition
activities. This contamination is typically located in the shallow subsurface zones.
The "pit holder" may be set deeper in the subsurface and may contain larger
quantities of coal tar which have been mixed with fill, including demolition debris
and soil. The structure of the subsurface holder is often intact, preventing
movement of the coal tar and contaminated fill.
As shown in Rgure 2, the nature of these areas (e.g., depth, type of contaminated
media) dictates the use of different excavation schemes. For example, it is likely
that the excavation of the more shallow tar separator and tar well will include the
subsurface structures as well as the coal tar and contaminated soil. On the other
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hand, excavation of the deeper pit holder may be limited to the removal of the
contents of the subsurface structure. Sampling should'be designed to develop a
three dimensional profile of MGP waste distribution (see Section XI). These
profiles will be used to develop excavation work plans and to identify
representative samples of the zones of excavation.
Issues to be addressed by the Company:
(1) delineation of excavation zones containing wastes that will require 90-day
accumulation management (i.e., those portions of the area to be excavated
where there is a reasonable probability that excavated waste will exhibit a
hazardous characteristic and therefore will require compliance with Subtitle C
regulations).
(2) determination of blending ratios and mixing material to be used during 90-day
accumulation. . .
(3) Establishment of field analysis techniques for the rapid determination of TC
hazardous characteristics of concern (e.g., benzene). These field analysis
techniques, which include methods such as manual extraction of soil and
groundwater samples followed by gas chromatographic analysis of the extracts
in the field, permit a rapid determination of the chemical composition of the
sample. These rapid determinations are required during the excavation of the
source areas and during the subsequent handling and blending processes
since they will expedite the field activities and minimize the overall time
required pn-site. The time pn-site is a critical factor since many MGP sites are
located in urban or residential settings and it is imperative that the
inconvenience and potential disruption caused by the field activities be
minimized to the greatest extent possible.
The burden of ensuring that all excavated solid materials are properly managed
on the site and that no hazardous waste leaves the site misclassified is borne by
the Company. Therefore, it is critical that the field analysis method provides
consistent results with the applicable testing protocols for identifying characteristic
hazardous waste. If the materials generated include hazardous wastes, the
generator must comply with Part 262 of EPA's rules including the requirement to
obtain an EPA identification number.
IV. Development of Excavation Design. i
Excavation design will be developed by the Company using accepted engineering
and construction practices (see Section V). Issues to be addressed by the
Company as part of the development of the excavation design include:
(1) determination of the 3-dimensional excavation boundaries.
(2) identification and preparation of the material processing area.
(3) identification and preparation of the staging area.
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FIGURE 1
PLAN VIEW OF MANUFACTURED GAS PLANT DURING FACILITY OPERATION
CAS.
HOUSE
CAS
PURIFICATION
TAR.WELL
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(4) identification and consideration of geotechnical conditions.
(5) determination of whether a vertical barrier is needed for structural support
and/or groundwater control.
(6) selection of excavation equipment.
(7) determination of health and safety procedures.
V. Excavation Procedures.
Contaminated soils should be excavated by the Company (or its representative)
using appropriate equipment such as screw augers, back hoe buckets, clamshell,
or other similar equipment. When practical to do so, large pieces of demolition
debris may be segregated in the excavation pit and handled separately from the
soils. Experience at MGP sites indicates that the impact of air emissions and odor
from the excavations can be effectively managed by employing excavation
practices that minimize the release or gaseous contaminants and by utilizing air
monitoring and respiratory protection equipment. Excavation practices to minimize
air emissions will include the pacing of the excavation activities and/or the
placement of additives or absorbents"such as coal fines, wood chips, synthetic
foams, or other non-hazardous materials into the excavation. Concurrently, the air
space in and around the excavation should be monitored using real-time.
contaminant detection instruments (e.g., organic vapor analyzers). The site health
and safety plan will identify predetermined concentration limits which, if exceeded
at any time, would require the use of air respiratory equipment by site workers.
Air monitoring should be conducted at predetermined zones around the perimeter
of the excavation to ensure that the excavation activity is protective of human
health and the environment.
Should excavation occur in the saturated zone, groundwater management may be
required. The management steps may include isolation and dewatering of the
zone of excavation and treatment of the wasiewaters that are generated. Isolation
of the zone of excavation may be accomplished using sheet piles or other barriers.
In some instances, the historic structures themselves may serve as an adequate
barrier. This is especially true for the subsurface structures associated with the
pit holders. These barriers can prevent cross-contamination from occurring due
to contaminant migration into or out of the excavation zone. If dewatering is
required for the excavation, it should be achieved using conventional construction
techniques (e.g., recovery wells or collection trenches set within the isolated zone
of excavation). Wastewaters generated in the process of dewatering that exhibit
a hazardous characteristic must be managed as a hazardous waste. Additional
remedial actions may be required for the site groundwaters; however, these
actions are beyond the scope of this document.
VI. Screening.
Material removed from the excavation can be handled in several ways. If it is
classified as-hazardous pursuant to 40 C.F.R. § 262.11 and managed offsite, it is
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subject to all of the applicable requirements of Subtitle C of RCRA. If it is
managed on-site, it can be processed through either a stationary or vibrating
screen if large items of debris are present. The Company will determine whether
the waste materials that have been screened out are hazardous and require
management under Subtitle C of RCRA. Waste that is not amenable to screening
(i.e., wet clay soils, viscous sludges) may be dewatered and/or enhanced with
suitable material to facilitate material handling in a 90-day accumulation unit.
Once the material can be handled it may then be screened.
The screen may be angled to deflect the larger items (i.e., construction debris,
wood, concrete) that cannot be segregated in the excavation. Cobbles, bricks and
other similar size materials may be conveyed through the screen along with the
contaminated soil. If the screened out materials are determined to be hazardous,
they will be conveyed to a 90-day accumulation unit (see Section VII). Plans will
be prepared to prevent or contain any spillage which may occur during the material
handling process.
VII. Accumulation/Blending Stage.
Following segregation from the larger items of debris, the screened material will
be accumulated or blended in a 90-day accumulation unit. EPA has interpreted
the term "accumulate" in § 262.34 to include both storage and treatment. See 55
Fed. Reg. 30798, 30807 (July 27, 1990); 51 Fed. Reg. 10146, 10168 (March 24,
1986). Under current regulations (40 C.F.R. § 262.34(a)), three units are eligible
for this purpose. Two units are tanks meeting the standards of 40 C.F.R. Part 265,
Subpart J, and containers meeting the standards of 40 C.F.R. Pan 265, Subpari
I. As long as treatment activities are conducted in units meeting the.definitions of
tank and container, and the time limitations and requirements of § 262.34 are met
(including contingency planning requirements), treatment activities may be
conducted at the site of generation without a permit.
EPA has defined "container" and "tank" in 40 C.F.R. § 260.10 as follows:
Tank: A tank is a "stationary device, designed to contain an
accumulation of hazardous waste, which is constructed primarily of
non-earthen materials (e.g., wood, concrete, steel, plastic) which
provide structural support."
Container A container is "any portable device in which a material is
stored, transported, treated, disposed of, or otherwise handled."
This definition of container includes a wide range of items such as cans, drums,
boxes, roll-off boxes, container trucks, tanker trucks, rail box-cars, and rail
container cars. Some portable process-type units, such as mixers, could also be
included within this definition.
EPA recently added a third unit as an eligible 90-day accumulation unit that may
facilitate accumulation and blending at MGP sites. This new unit, called a
containment building, generally consists of a concrete pad or a similar floor inside
a building. According to EPA, this
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unit must, among other things, be completely enclosed and have
self-supporting walls, a primary barrier, designed to be sufficiently durable
to withstand the movement of personnel, wastes, and handling equipment
in the unit, a secondary containment system (unless the unit manages
non-liquid wastes only or has obtained a variance from the secondary
containment standard), a liquid collection system and controls for fugitive
dust. The floors, the walls, and roof of the unit must be constructed of
man-made materials with sufficient structural strength to support
themselves, the waste contents, and any personnel and heavy equipment
that operate within the unit. The unit also must be designed and operated
to prevent tracking of materials out of the unit.
57 Fed. Reg. 37194, 37212 (Aug. 18, 1992). See generally 40 C.F.R.
§ 262.34(a)(1)(iv); 40 C.F.R. §§ 264.1100-.1102;40C.F.R.§§ 265.1100-.1102; 57
Fed. Reg. at 37211-18.
The time limitations of § 262.3_4(a) require that all storage and treatment be
achieved in SO days or iess. Tnis limitation applies ur,les~s an extension of 30
additional days is obtained pursuant to 40 C.F.R. § 262.34(b) or the generator
qualifies as a conditionally exempt small quantity Generator under 40 C.F.R.
§261.5.
The blending material may consist of a relatively dry, combustible medium such
as coal, coal fines, clean wood chips, com cobs, less contaminated soil or other
suitable material. Blending materials and blending ratios will be determined to
ensure that the blended material does not exhibit a hazardous characteristic.
Blending ratios will be established after a field testing process aimed at
establishing a statistically valid worst-case ratio that will render nonhazardous the
most concentrated sample of hazardous site remediation waste and therefore all
less concentrated wastes. If the contents of the 90-day accumulation unit are
determined not to exhibit a hazardous characteristic after blending, the material
further processed on-site using the established blending ratio would no longer be
subject to Federal regulation under Subtitle C of RCRA. Thus any crushing,
further blending with coal, or other material or off-site transport for ultimate
disposal would not be subject to the Federal hazardous waste regulation. Should
the contents of the 90-day accumulation unit fail to be rendered nonhazardous, the
waste must be managed as a hazardous waste in accordance with applicable state
and federal regulations.
VIII. Nonhazardous Waste Storage.
Nonhazardous soils may be stored either off-site or on-site. Sound management
practices should be followed for handling and storing nonhazardous soils (e.g. dust
suppression, etc.). The storage area should be designed to control run-off,
leachate generation, dust, etc. All soil storage must comply with any applicable
local, state, and federal regulations.
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IX. Transportation of MGP Waste to Off-Site 1 ocatjon.
Nonhazardous soils may either be transported off-site or may undergo further
blending on-site with a fuel for purposes of utility boiler fuel preparation. If it
becomes necessary to transport hazardous MGP waste off-site (e.g., either
because site conditions preclude management of excavated wastes in 90-day
accumulation units or because mixing activities in such units have not been
successful in rendering the waste nonhazardous within the 90-day time period
authorized by 40 C.F.R. § 262.34), the generator must comply with the
requirements for off-site transportation of hazardous waste, including the manifest
requirement in 40 C.F.R. § 262.20 el seq.
X. Utility Roller Operation
There are no regulatory requirements under RCRA applicable to utility boilers that
bum excavated solid materials from MGP sites as fuel so long as the materials do
not exhibit a hazardous characteristic and do not contain a listed hazardous waste.
The remedial strategy described in this document contemplates that only
nonhazardous excavated materials will be burned in utility boilers along with fossil
fuels.
Utility boilers that burn excavated materials may nevertheless be subject to state
or Federal regulatory requirements under the Clean Air Act or other environmental
statutes. Any required regulatory oversight or approvals will occur under those
programs.
Boiler safety and operational issues are specific to the boiler design. Therefore,
such issues should be addressed on a case-by-case basis by the Company prior
to commencement of burning activities.
XI. Sampling and Analysis Strategy.
Sampling and characterization of the excavated solid material should occur at the
four stages of the excavation activities addressed by this guidance:
Characterizing the soil prior to excavation.
Characterizing the excavated solid materials pursuant to RCRA
generator requirements.
Determining blending ratios that will ensure that the resulting mixture of
excavated remediation material and blending material will not exhibit a
hazardous characteristic.
Confirming the nonhazardous status of mixed materials.
The Company's implementation of this sampling and analysis is intended to
achieve the following objectives:
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(1) characterize MGP contaminated soils that are targeted for excavation and
off-site disposal;
(2) determine which portions of the soils targeted for excavation will require
management in 90-day accumulation units (i.e., wastes that are known or
determined by the generator to exhibit a hazardous characteristic or wastes
for which a determination is not made but which the generator assumes
require management under Subtitle C of RCRA);
(3) develop a sampling protocol that statistically addresses the number of samples
that have to be taken to establish the characteristic of the excavated waste
(Chapter 9 of EPA's Manual "Test Methods for Evaluating Solid Waste,"
SW-846, may provide guidance in developing such a protocol). Caution
should be taken when developing the sampling protocol because waste may
not be homogeneous across the site; and
(4) develop a sampling protocol that statistically determines that al! wastes
managed in 90-day accumulation units no longer exhibit any hazardous
characteristics upon removal.
If an adequate database exists that accurately describes the current characteristics
of the contaminated media at that site, it may be unnecessary to undertake an
additional assessment of the waste characteristics within the excavation zone.
However, in the absence of such a database and if the generator plans to manage
any excavated materials under nonhazardous waste standards, in situ sampling
will be necessary to ensure compliance with RCRA regulations and for excavation
planning purposes.
Sampling activities should be designed to delineate the portions of the excavation
zones that can be expected to generate MGP remediation waste that will require
(or should be assumed to require) compliance with Subtitle C management
standards. TCLP or total analysis methods should be employed to characterize
the portions of the excavation zones potentially subject to Subtitle C standards.
If the site manager elects to base his excavation zone characterization on total
analysis, waste samples will be assumed to be nonhazardous due to toxiciiy if they
exhibit statistically valid concentrations of TC parameters less than twenty times
the regulatory levels that are presented in Table 1 of 40 C.F.R. § 261.24. See 53
Fed. Reg. at 51444 (Dec. 21,1988). Recent site-specific research conducted by
the Electric Power Research Institute indicates that multiples of 40 to 50 may be
more appropriate in some instances. The multiple that is selected for a given site
will be negotiated with appropriate overseeing agencies on a case-by-case basis
using the multiple of 20 as a baseline and considering higher multiples, as
appropriate, based upon actual waste characterization and leaching data. In all
cases, the multiple will be chosen to ensure that the on-site management of the
excavated materials will be consistent with RCRA regulations. If none of the
excavated materials exhibits an^ RCRA hazardous characteristic, these materials
may be managed as a nonhazardous waste. Any hazardous waste generated in
such an excavation may be managed on-site in 90-day accumulation units
authorized by 40 C.F.R. § 262.34. -
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Waste that is being managed in 90-day accumulation units may be periodically
sampled by means of the surrogate analysis (e.g., total analyte method) to
determine if the waste exhibits any toxic characteristic. When it is determined by
the Company that a waste in a 90-day accumulation unit no longer exhibits any
hazardous characteristic, the waste may be removed from the 90-day accumulation
unit and may thereafter be managed as a nonhazardous waste (e.g., burning in a
utility boiler). Statistically based sampling procedures will be used to determine
whether MGP wastes exhibit any hazardous characteristics. The procedures
should be documented in the site Sampling and Analysis Plan. See Section Xli.2.
i his plan should be provided to the regulatory agency directing or providing
regulatory oversight for the MGP remediation project. If this methodology indicates
that the waste exhibits a hazardous characteristic and the generator does not
qualify as a conditionally exempt small quantity generator, then the waste will be
managed as a hazardous waste in 90-day accumulation units. If there is no
indication that the waste is hazardous, the waste may be managed under any
permissible reaulatory category (e_4^, nonhazardous solid waste, fuel supplement,
etc.). . .
As sampling and analysis experience is acquired at these sites, it may be possible
to construct a database from waste matrix information and site characterization
data to correlate TC criteria and site specific waste characteristic analysis. Once
such a database has been assembled, future Sampling and Analysis Plans may
be developed, and to the extent required by federal or state regulation, should be
submitted to the appropriate government agency.
Xil. Controlling Plans for MGP Waste Excavations.
In addition to the foregoing, the remediation activities addressed by this strategy
document may require development by the Company of a number of Remedial
Design (RD) and Remedial Action (RA) Plans. Examples of such plans are
described below and would control all source removal actions to be performed at
the site and require any necessary approvals by agencies overseeing the site
management.
1. Quality Assurance Project Plan.
A site-specific Quality Assurance Project Plan (QAPP) should be developed in
accordance with applicable regulatory criteria. The purpose of this QAPP is to
establish Quality Assurance (QA) standards applicable* to the specific field and
laboratory work to be performed. Documented conformance with these standards
during the performance of the remedial action will produce scientifically defensible
data which can be used throughout the remedial action and will assure that the
objectives of the remedial action are met.
2. Sampling and Analysis Plan.
A site-specific Sampling and Analysis Plan (SAP) should be prepared that contains
objectives, site background, evaluation of the zones to be excavated, and identifies
chemical constituents of interest, sample types, statistical sampling approach,
sampling locations and frequency, sample preparation, sample QA/QC, operations
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plans forsampling, sampling personnel qualifications, decontamination procedures,
and specifications for sampling procedures.
3. Health and Safety Pfon.
A site-specific Health and Safety Plan (HSP) should be prepared in accordance
with all applicable EPA and other safety regulations (e.g., OSHA regulations).
Special emphasis should be given to safety concerns of non-remedial workers at
the site and nearby residents. Specifically, the HSP should address air monitoring
and odor control procedures that are protective of the on-site workers and general
public.
4. Alternative Management Plan for Wastes Remaining in the Subtitle
C Program.
A plan should be developed to manage any waste that is not rendered
nonhazardous within 90 days (or any extension of the 90-day period granted by
the Regional Administrator). These plans should provide for proper storage,
transportation, and disposal/treatment of hazardous waste in accordance with
Subtitle C of RCRA. If off-site transportation of hazardous waste becomes
necessary, the requirements described in Section IX apply.
5. Recordkeeping.
All recordkeeping requirements applicable to generators (and, if necessary, to
transporters) of hazardous waste should be complied with.
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RECORD OF DECISION FACT SHEET
EPA REGION II
Site;
Site name: GCL Tie & Treating, Operable Unit I
Site location: Sidney, Delaware County, New York
HRS score: 48.54 (10/14/93)
Listed on the NPL: 5/94
EPA ID #: NYD 981 566 417
Record of Decision (Operable Unit l);
Date signed: September 30, 1994
Selected remedy: Excavation and Treatment of contaminated soils
via a Thermal Desorption Process
Estimated Construction Completion: 1 year
Capital cost: $14,839,000 (in 1994 dollars)
Annual O & M cost: Not Applicable
Present-worth cost: $14,839,000
Lead: EPA, remedial
Primary Contact: Carlos R. Ramos, (212) 637-4276
Secondary Contact: Doug Garbarini, (212) 637-4263
Main PRPs: Harris Goldman
Waste;
Waste type: PAHs
Waste origin: On-site (spills)
Estimated waste quantity: 36,100 yd3
Contaminated medium: Soil
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