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

                                7

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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

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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

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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

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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

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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

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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

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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

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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

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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

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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

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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

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APPENDIX I




 FIGURES

-------
      FIGURE 1.  GCL TIE & TREATING SITE LOCATION MAP
',  *••/AV/I
    : A. . • ! i V •


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                                        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









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                                             ENLARGED VIEW

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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
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 I
                                                   20
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                                                                                                                           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

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                        SOUTHWEST
                   STATION     J6
                   NUMBER      |_
30
                                                            GCL  TIE &  TREATING  SITE
                                                                  TRENCH LINE  B
             25
                         20
                                      15
                                                  10
                                                                                                                NORTHEAST
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   <

   3
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        990-
        985-
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    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

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                     STATION
                     NUMBER
                            WEST

                             JO
                                               GCL  TIE  &  TREATING  SITE
                                                     TRENCH  LINE  C
25
             20
                          15
                                                                                 10
                                                            EAST

                                                               I
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 3
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 I
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    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

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  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

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                                                  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.

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                                                            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

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                                                             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.

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        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

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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

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-?-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

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      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.

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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.

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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

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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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                                              10

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
                  Empire Court Reporters
                 One Marine Midland Plaza
                  Binghamton, NY  13901

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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
                        Empire  Court Reporters
                       One  Marine Midland Plaza
                        Binghamton, NY   13901

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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

                        Empire Court  Reporters
                      One Marine Midland Plaza
                        Binghamton, NY  13901

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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
                                  %
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
                                                   •'
 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

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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
                                                   V
 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
\

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
expensive.   It would cost around $40  million  to go  that
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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.
                                        *'

      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
                                  »
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
                                                   •'

 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
                                             %

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
                                                  **

 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
                                                  •

 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
                                                  •'
 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
                                        *'

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
 '"•-'                                     V


 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
                                              »


 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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design phase.


      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
                                        •

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?
                                                  •

 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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the EPA.
      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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with performance-based specifications.

      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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                                               67


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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