PB97-963803
EPA/541/R-97/011
November 1997
EPA Superfund
Record of Decision:
Plattsburgh Air Force Base,
(Former Landfill LF-024),
Plattsburgh, NY
3/25/1997
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FORMER LANDFILL LF-024
RECORD OF DECISION
PLATTSBURGH AIR FORCE BASE
PLATTSBURGH, NEW YORK
FINAL
MARCH 1997
PLATTSBURGH AIR FORCE BASE
INSTALLATION RESTORATION PROGRAM
PREPARED BY:
URS GREINER. INC.
0
o
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TABLE OF CONTENTS
Page No.
DECLARATION FOR THE RECORD OF DECISION ]
1.0 SITE NAME. LOCATION, AND DESCRIPTION 3
20 LAND USE AND RESPONSE HISTORY 4
3.0 COMMUNITY PARTICIPATION 8
4.0 SCOPE AND ROLE OF RESPONSE ACTION 9
5.0 SUMMARY OF SITE CONTAMINATION 9
5.1 Contaminant Pathways 9
5.2 Soil/Fill Contamination 10
5.3 Surface Water/Run-off and Sediment Contamination 13
5.4 Groundwater Contamination 13
6.0 SUMMARY OF SITE RISKS 16
6.1 Human Health Risk Assessment 16
6.2 Ecological Risk Assessment 20
~ (i DEVELOPMENT OF REMEDIAL ALTERNATIVE 20
7.1 Selection of The Presumptive Remedy 20
7.2 Remedial Action Objectives 22
7.3 Development of the Remedial Alternative 23
S n COMPARATIVE ANALYSIS OF ALTERNATIVES SUMMARY 26
9.0 THE SELECTED REMEDY 31
100 STATUTORY DETERMINATIONS 32
10.1 The Selected Remedy is Protective of Human Health and the Environment ... 32
10.2 The Selected Remedy Attains ARARs 33
10.3 Other Criuna, Advisories, or Guidances to be Considered for This
Remedial Action 34
10.4 Cost-Effectiveness 35
10.5 Utilization of Permanent Solutions and Alternative Treatment Technologies
(or Resource Recovery Technologies) to the Maximum Extent Practicable .... 35
10.6 The Selected Remedy Does Not Satisfy the Preference for Treatment
Which Permanently and Significantly Reduces the Toxicity, Mobility.
or Volume of the Hazardous Substances as a Principal Element 35
11.0 DOCUMENTATION OF NO SIGNIFICANT CHANGES 36
12.0 STATE ROLE 36
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LIST OF TABLES
Table No. Page No.
1 Character of Soil/Fill Contamination 12
2 Character of Surface Water Run-off and Leachate Seeps 14
3 Character of Groundwater Contamination , 15
4 Chemicals of Potential Concern Summary Table 17
5 Cancer Risks and Hazard Indices for Multiple Pathways 19
6 Evaluation Criteria 27
7 Cost Estimate Summary For The Selected Remedy 30
LIST OF FIGURES
Figure No.
1 Vicinity Location Map 3
2 Site Location Map 4
3 Site Features 5
4 Site Conceptual Model II
5 Presumptive Remedy Decision Framework 21
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LIST OF PHOTOGRAPHS
Photorah
View from the north centra] perimeter of LF-024 toward the southeast showing the
generally good cover of grasses and small trees on the upper landfill surface ......
Photo of an area of sparsels vegetated sandy soil near the center of the landfill
View from southeast to northwest along the southern sideslope of LF-024
(just north of MW-4) showing a cover of small to medium size trees
View from the southeast to northwest along the toe of the southern sideslope
showing exposed construction/demolition and shop debris
Page
No.
6
6
REFERENCES ....
GLOSSARY
37
39
APPENDIX A
APPENDIX B
APPENDIX C
APPENDIX D
APPENDIX E
LIST OF APPENDICES
Chemicals Detected in Environmental Media at LF-024
Human Health Risk - Toxicity Values
Declaration of Concurrence
Public Meeting Transcripts
Responsiveness Summary'
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DECLARATION FOR THE RECORD OF DECISION
SITE NAME AND LOCATION
Pittsburgh Air Force Base (AFB)
Former Landfill LF-024
Pittsburgh, New York
STATEMENT OF BASIS AND PURPOSE
This Record of Decision (ROD) presents a selected remedial action for soil and groundwater at site
LF-024 on Pittsburgh AFB in Pittsburgh, New York. It has been developed in accordance with the
Comprehensive Environmental Response, Compensation, and Liability Act of 1980 (CERCLA) as amended
by the Superfund Amendments and Reauthorization Act of 1986 (SARA), and to the extent practicable, the
National Oil and Hazardous Substances Pollution Contingency Plan (NCP)._This decision is based on the
Administrative Record for this site, a copy of which is located at the Information Repository at the Feinburg
Library on the campus of the State University of New York at Pittsburgh.
The remedy has been selected by die US Air Force (USAF) in conjunction with the US Environmental
Protection Agency (USEPA) and with the concurrence of the New York State Department of Environmental
Conservation (NYSDEQ pursuant to the Federal Facilities Agreement among the parties under Section 117(a)
of CERCLA, dated July 10, 1991.
ASSESSMENT OF THE SITE
Hazardous substances present in fill and soil at LF-024, and contamination of the. underlying
groundwater, if not addressed by implementing the response action selected in this ROD, may present a
potential endangerment to human health and the environment.
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DESCRIPTION OF THE REMEDY
This action addresses die principal threat posed by LF-024 by preventing endangerment to human
health and the environment, through containment of die landfill to minimize exposure to contaminants in die
soil, waste and groundwater. The proposed source control remedy includes a re-establishment and upgrade
of the native soil cap over die landfill; institutional controls to restrict site development, maintenance to protect
die integrity of die cap, restrictions preventing die use of groundwater as a potable supply source on, and
immediately downgradient of die site; periodic groundwater monitoring for 30 years; site reviews to be
conducted every five years; and development of a post-closure plan specifying inspection, maintenance, and
monitoring programs to be conducted over 30 years.
STATUTORY DETERMINATIONS
The selected remedy is protective of human health and die environment, complies with federal a
state Applicable or Relevant and Appropriate Requirements, and is cost-effective. The remedy is based
die presumptive remedy approach developed by die USEPA for military landfill sites. Using die presumptive
remedy for this site, treatment of waste, soil and groundwater contamination is considered impractical and
consequently, die remedy does not satisfy statutory preference for treatment as a principal element of
remediation.
Because this remedy will result in hazardous substances remaining on site, die USAF, USEPA,
and NYSDEC will conduct site reviews every five years to ensure that die source control remedy continues
to provide adequate protection of human health and die envirotii.nent.
Signature THOlvIAS W.L. McCALL, JR. Date
Deputy Assistant Secretary of die Air Force
(Environment, Safety and Occupational Health)
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1.0 SITE NAME. LOCATION AND DESCRIPTION
Pittsburgh AFB is located in Clinton County in northeastern New York State, bordered on the north
by the City of Plattsburgh. on the east by Lake Champlain. and on the north and south by the Saranac and
Salmon Rivers. It lies approximately 26 miles south of the Canadian border and 167 miles north of Albany.
(Figure I). As pan of the USAFs IRP. Plattsburgh AFB initiated activities to identify, evaluate, and restore
identified hazardous waste sites. The IRP at Plattsburgh AFB is being implemented according to a Federal
Facilities Agreement (Docket No.: II-CERCLA-FFA-10201) signed between the USAF, USEPA. and
NYSDEC on July 10. 1991. Plattsburgh AFB was placed on the National Priorities List on November 21,
1989
N Plattsburgh AFB was closed on
A September 30, 1995 and its reuse is being
administered by the Air Force Base
Conversion Agency in conjunction with the
Plattsburgh Airbase Redevelopment
Corporation (PARC). Land use for the
southwestern section of the base (including the
area of LF-024), has been designated as either
open space with light industrial use (Final
Comprehensive Reuse Plan, September 1995),
or as mixed aviation/industrial use with open
space (Final Environmental Impact Statement.
October 1995). It is the intent of the Base
Conve.sion Agency to limit use of LF-024 as
specified in the Environmental Impact
Statement.
>'£»' MM
STATE
NcwYort
Approximate Seal* in Mites
'EESif
8 0
t 19"! Dtltrr.t Mippm|
Figure 1: Vicinity Location Map
LF-024 is an approximate!) I-acre
landfill located southwest of the Plattsburgh
AFB Flightline, between the southern edge of
the Explosive Ordnance Disposal Range and
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cttrat.
N
A
{.<*
the Salmon River (Figure 2). Pedestrian
access to the landfill is limited due to the
presence of 1-87 to the west, the Salmon
River to the south, and woods to the north
and east. A four-strand barbed wire fence
c/>ampte/n encompasses LF-024. but is absent along
the northern portion of the site (Figure 3).
In general, the landfill is in a remote section
of the base not frequented by maintenance
personnel.
The site is a flat-topped mound with
steep sides covered by grass and surrounded
by a ring of woods and brush (Photos 1 and
2). The southern sideslope is tree-covered
and debris protrudes from the toe of slope
(Photos 3 and 4). Soil surrounding the
sandy fill of the landfill consists primarily
of silty sand. Beneath the landfill, an upper
Figure 2: Site Location Map
sand aquifer overlies a clayey silt layer which appears to serve as a confining layer for the underlying bedrock
aquifer. The groundwater surface lies near the base of the landfill, where it appears to be confined by the
underlying clayey silt layer which occurs near or at the base of the landfill. The Salmon River is assumed to
serve as a discharge point for local groundwater which flows toward the southeast. Residents in the
surrounding areas are located at least 3,000 feet from the site.
2.0 LAND USE AND RESPONSE HISTORY
From 1980 to 1986, LF-024 was used for the disposal of construction and demolition debris. Landfill
wastes were end dumped, dozer compacted, and covered with sandy soil from surrounding areas. E.G. Jordan
Co. reported that oil from transformers may have been disposed of in the landfill (1989); however,
polychlorinated biphenyls (PCBs) were not detected in any of the media during subsequent sampling and
H2-2T-91 17:04
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N
LF-024
CONSTRUCTION
SPOILS LANDFILL
LEGEND
INSET
LEGEND
GROUNDWATER USE
i- RESTRICTION AREA
N
i SALMON RIVER
I I APPROXIMATE LIMITS
L.J OF LF-024
I I APPROXIMATE LIMITS
I | OF SS-026IEOD RANGE)
FEDERALLY REGULATED
WETLAND
TOPOGRAPHIC CONTOUR
w(FEET AMSL)
> .- EDGE OF WOODED AREA
BARB WIRE FENCE
200 0 200
SCALE IN FEET
URS
CONSULTANTS, INC.
LF-024 PROPOSED PLAN
SITE FEATURES
FIGURE 3
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1-
the generally good cover o
trees m the left
central perimeter of LF-024 toward the southeast showing
and small (trees 01 the upper landfill surface. Larger pine
tie easterly landfill limits.
landfill.
landfill surface is generally well vegetated, some bare areas are
am area of sparsely vegetated sandy soil near the center of the
SITE PHOTOS -LF-024
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PHOTO 3 - View from southeast to northwest along the southern sideslope of LF-024 (just
north of MW-4) showing a cover of small to medium size trees.
PHOTO 4 - View from the southeast to northwest along the toe of the southern sidcslopc
showing exposed construction/demolition and shop debris. This view is typical of the
southern and western landfill lower sideslopcs.
SITE PHOTOS - LF-024
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analysis. During field investigations 18 drums were observed protruding from the fill at the toe of the landfill,
many of which were crushed or without lids. Drums that appeared to be intact sounded hollow and were
presumed to be empty. Efforts to sample the drums during the SI were not undertaken, though a sediment
sample was collected from the area of several drums and did not reveal the presence of contamination.
Subsequent inspection of the landfill by LJRS Consultants, Inc. (URS) personnel failed to identify any drums.
The USAF has no records indicating that drums were disposed of at the landfill, and it is believed they were
used for trash collection.
A site investigation (SI) was performed at LF-024 in the summer of 1993 which included the
following: I) terrain conductivity, magnetometer, and soil gas surveys; 2) excavation of three test pits; 3)
installation and sampling of one monitoring well and three well points; and 4) analysis of eleven soil, four
sediment, and two surface water samples. Samples were analyzed for the full target compound and target
analyte lists. Based on the results of the investigation, the SI report (Malcolm Pimie 1994) concluded that no
further investigation or remedial action was necessary. The database compiled as part of the SI was utilized
to quantify potential risk posed to human health (URS I995a).
3.0 COMMUNITY PARTICIPATION
Pittsburgh AFB has kept the community and other interested parties informed of the activities at LF-
024 through informational and public meetings, holding a 30-day public comment period from January 6, 1997
to February 6, 1997 to solicit public input During this period, the public was invited to review the Proposed
Plan, the LF-024 SI and to comment on the remedial alternative being considered. These documents, which
comprised the Administrative Record for the LF-024 site, available at the Information Repository located at
the Feinberg Library on the campus of the State University of New York at Pittsburgh.
Pittsburgh AFB also hosted a public meeting on January 16, 1997 at the City of Pittsburgh Old
Court House to discuss the data gathered at the site, the preferred alternate, and the decision-making process.
Immediately after the information presentation, Pittsburgh AFB held a formal Public Hearing to accept
comments about the remedial alternative being considered for the LF-024 site. Public comments were
recorded and transcribed, and a copy of the transcript was added to the Administrative Record and Information
J .":«' «r final' I-iROD'im
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Repositor> and are a part of this Record of Decision (Appendix D). A response to the comments included in
the responsneness summary is part of this Record of Decision (Appendix E).
4.0 SCOPE AND ROLE OF RESPONSE ACTION
This ROD addresses all of the principal threats posed by LF-024 to human health and the environment.
The primary threat is risk associated with potential human inhalation of exposed fill material as fugitive dust
and physical hazards posed by exposed construction debris. Metals contamination (principally manganese)
also occurs in groundwater at the site. There is no impact on surface water or air quality associated with the
landfill
The USAF has utilized the USEPA's containment presumptive remedy for military landfills to help
determine an appropriate remedy for LF-024. Because of the large amount and heterogeneous nature of the
material within the landfill, and the fact that the local land reuse authority (PARC) currently has no plans for
the future use of the site, treatment is not considered practical. Containment, therefore, is considered the
appropriate response action, or the presumptive remedy, for LF-024. The remedy recommended in this Plan
addresses the principal threats through the removal of exposed debris, capping (containment), monitoring of
groundwater. and institutional controls to protect the integrity of the cap and prohibit the use of groundwater
as a potable supply source on. and immediately downgradient from the site.
5.0 SUMMARY OF SITE CONTAMINATION
5.1 Contaminant Pathways
Potential pathways by which contaminants might leave LF-024 are evaluated based on results of the
SI investigation. Air pathways appear to be insignificant because dust generation is limited by the landfill
vegetation and soil cover. Volatile organic compounds (VOCs) were detected infrequently and at lou
concentration1; in the soil cover and waste, although elevated levels of metals in the fill do present an inhalation
risk where the waste is exposed. Inspection of the landfill indicates that surface run-off from the landfill is
confined to the landfill perimeter with rapid infiltration and evaporation of run-off at the margins of the landfill
following heavy rain events. The only potentially significant contaminant migration pathway is vertical
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leaching of contaminants (i.e., metals) by percolating precipitation, with eventual transport downgradient
through groundwater. The site conceptual model is shown in Figure 4. Groundwater flow at the site is shallow
and vertically confined by underlying silty sediments which occur at or near the base of the landfill.
Contaminant movement downgradient of the site (which will be monitored) is expected to be limited due to
the relative immobility of metals. Chemicals detected in the various environmental media at LF-024 are listed
and mapped in Appendix A.
5.2 Soil/Fill Contamination
Eleven soil/fill samples were analyzed during the SI including two subsurface soil samples from the
upgradient monitoring well location (depths 0 to 2 feet and 5 to 7 feet), three near surface soil samples
obtained from the three downgradient well point locations (1 to 3 feet depth), and six fill samples taken from
the three test trenches (two per trench). The six fill samples, which were obtained at depths up to 12 feet.
consisted of soil backfill that was mixed with the landfill debris composed of assorted trash, construction
materials including corrugated steel, and wood.
In general, organic compounds were detected infrequently in soil/fill samples (Tables A-2. A-3, and
A-4). Metals were detected much more frequently, as would be expected, since metals occur naturally in soil,
are non-volatile, and do not biodegrade. The level of contamination in soil/fill was evaluated by comparing
the detected concentrations to NYSDEC guidelines for soil cleanup (TAGM #4046, January 1994). This
comparison is summarized in Table 1. One of the nineteen organic compounds (benzo(a)pyrene), and seven
of the nineteen metals (antimony, magnesium, manganese, mercury, potassium, selenium, and thallium) were
detected above the guideline values with most exceedances occur.^ng in one sample (fill sample 02 at 5 feet)
from TP24-001 (see Figures A-2, A-3, and A-4). As shown on Table 1, detection of these analytes above the
guideline values was infrequent and in most cases marginally above guidance values. Low level exceedances
of the guideline criteria for manganese, nickel and potassium also were found in near surface soil samples from
the well point locations. In general, the metals contamination observed in the soil/fill samples is likely
attributable to the leaching of metals from C&D debris constituting the landfill.
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SAND/
SILTY SAND
Groundwaler
^ Flow v^ .
CLAYEY
SILT LAYER
BEDROCK
NOT TO SCALE
URS
SITE CONCEPTUAL MODEL
PLATTSBURGH AIR FORCE BASE LF-024
FIGURE 4
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TABLE I
CONSTRUCTION SPOILS LANDFILL (LF-024)
CHARACTER OF SOIL/FILL CONTAMINATION
Analyte
Benzo(a)pyrene
Antimony (mg/kg)
Magnesium (mg/kg)
Manganese (mg/kg)
Mercury
Nickel (mg/kg)
Potassium (mg/kg)
Selenium (mg/kg)
Thallium (mg/kg)
Guidance
Values
61*
12.6 (SB)
3,340 (SB)
474 (SB)
o.r
13*
929 (SB)
2*
Nun
Detection
Frequency of
Detection Above
Guidance Value
1/14
1/14
2/14
3/14
1/14
1/14
3/14
2/14
1/14
Detected
Maximum
Concentration
74
15.4
5,459
5.455
0.17
28
1,160
655
104
Source of
Guidance
ExL'c?edance
Test Trench
Test Trench
Test Trench
Test Trench
Test Trench
Near Surface Soil
Test Trench &
Near Surface Soil
Test Trench
Test Trench
Organic results reported in ng/kg. Inorganic results reported in mg/kg.
* - NYSDEC Soil Cleanup Objectives and Cleanup Levels, TAGM #4046, January 1994.
SB- Site background value. Based on base-wide background study (URS 1995b).
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5.3 Surface \Vater/Run-off and Sediment Contamination
Surface water and sediment samples were collected at the toe of the landfill where water from run-off
was observed to pool after heavy rains. Flowing seeps were not observed during the SI. Since these pools
subsequently infiltrate into the underlying soil or evaporate within a few days, the sediment samples can be
considered to belong to the soil medium.
The level of contamination from run-off and possible seeps was evaluated by comparing sediment/soil
sample analytical data to NYSDEC soil cleanup guidelines (NYSDEC 1992) and the water data to NYSDEC
standards for Class A surface water quality (6 NYCRR 703.5). These comparisons are summarized in Table
2 and shown on Figure A-l (Appendix A). Two of thirteen organic compounds and three of seventeen metals
detected in sediment (soil) samples exceeded the soil cleanup guidelines (Table A-l). None of the four organic
compounds detected and three of fourteen metals detected exceeded surface water quality standards.
5.4 Groundwater Contamination
Groundwater samples were collected from one upgradient monitoring well and three downgradient
well points that were installed using hand-driven well points. Well points were installed during the SI instead
of monitoring wells because of safety concerns in maneuvering drilling equipment to the sample locations and
in conducting drilling activities. Hence, hand driven well points were installed because of the relative ease
of driving well points to monitor shallow groundwater. Since the monitoring well was installed with a sand
filter around the well screen (whereas the well points were not), the sample from the well contained less
suspended fines which probably accounts for the lower concentration of total metals reported in the monitoring
well sample.
Three organic compounds, twenty metals, and cyanide were detected in groundwater. The level of
groundwater contamination was evaluated by comparing unfiltered and filtered groundwater samples to
N'YSDEC standards (6 NYCRR 703.5 and 703.6) and USEPA drinking water standards established by 40 CFR
141 and 14.V Results of the comparison are summarized in Table 3, One of the three organic compounds
delected and eleven of twenty metals detected in the unfiltered groundwaier were present at concentrations
above groundwater standards (Table A-5), The concentrations of metals detected in the filtered groundwater
.nptfin.iliiN ROD'im
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TABLE 2
CONSTRUCTION SPOILS LANDFILL (LF-024)
CHARACTER OF SURFACE WATER RUN-OFF AND LEACHATE SEEPS
Analyte
Acetone
Benzo(a)pyrene
Antimony (mg/kg)
Manganese (mg/kg)
Mercury (me/kg)
SEDIMENT (SOIL) SAMPLES
Guidance Value
200'
61'
12.6 (SB)
474 (SB)
0.1*
Frequency of
Detection Above
Guidance Value
1/4
2/4
2/4
1/4
1/4
Detected
Maximum
Concentration
300
130
20.5
542
0.18
WATER SAMPLES
Analyte
Aluminum (Me/I)
Iron (Mg/l)
Manganese (fig/0
Water Quality
Standard"
100
300
300
Frequency of
Detection Above
Guidance Value
I/I
2/2
I/I
Detected
Maximum
Concentration
1.960
15.100
1,310
Organic soil results reported in Mg/kg. Inorganic soil results reported in mg/kg. Aqueous inorganic results
reported in ug/l.
* - NYSDEC Soil Cleanup Objectives and Cleanup Levels. TAGM #4046. January 1994.
SB - Site background value. Based on base-wide background study (URS I995b).
** - NYSDEC Surface Water and Groundwater Quality Standards, 6 NYCRR 703.5.
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TABLE 3
CONSTRUCTION SPOILS LANDFILL (LF-024)
CHARACTER OF GROUNDWATER CONTAMINATION
A/ialyte
2-Methylphenol
Antimony
Barium
Bervllium
Chromium
Iron
Lead
Macnesmm
M Milanese
Sodium
Thallium
Zinc
ARAR
Value*
1
3
1.000
3
50
300
15"
35.000
300
20.000
4
300
Unfiliered Samples
Frequency or"
Detection Above
Guidance Vnlue
1/4
1/4
1/4
1/4
3/4
4/4
3/4
3/4
3.4
1/4
2/4
3/4
Delected
Maximum
Concent rat ion
2
87.6
1.790
10.3
338
250.000
85.9
65.600
15.100
31.300
9.3
2.770
Filtered Samples
Frequency of'
Detection Above
Guidance Value
..
0/4
0/4
0/4
0/4
1/4
0/4
0/4
1/4
1/4
1/4
0/4
Delected
Maximum
Concentration
..
ND
195
ND
ND
82.700
ND
33.700
3.970
28.900
6.8
96
All results reported in jtg/1.
* - Unless otherwise noted. ARARs arc NYSDEC Amhient Waicr Quality Standards (6 NYCRR 703.5 and
703.6).
" - USEPA Drinldna Water Standards 40 CFR 141.
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samples were considerably less than concentrations reported in the urifikered samples, reflecting the effect of
sample turbidity on the total metals concentration. In the filtered samples, only four metals (iron, manganese,
sodium, and thallium) exceeded groundwater standards at one well point location. In the groundwater sample
from the upgradient monitoring well, only one metal (an unfiltered iron sample) exceeded groundwater
standards. In addition, the concentrations of metals in the upgradient unfiltered sample were significantly lower
than concentrations reported in the well point samples (see Figure A-5, Appendix A).
6.0 SUMMARY OF SITE RISKS
A human health risk assessment was conducted to estimate current and future risks at the site if no
Remedial Action was taken. Chemicals selected for use in evaluation of risks are indicated on.Table 4.
Compounds were chosen based on frequency of detection, chemical-specific toxicity information, and
exceedance of background levels (for inorganics only).
6.1 Human Health Risk Assessment
Five steps are followed in assessing site-related human health risks: Hazard Identification - determines
the contaminants of concern at the site based on 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., dermal contact with soil) by which humans potentially are
exposed. Toxicity Assessment - determines adverse health effects associated with chemical exposures, and the
relationship between magnitude of exposure (dose) and severity of adverse effects (response). Toxicity values
used for analytes of concern in this study are provided in Appendix B. Risk Characterization summarizes
and combines outputs of the exposure and toxicity assessments to provide a quantitative assessment of site-
related risks. Uncertainty Analysis - qualifies the quantitative results of the risk assessment based upon the
uncertainty associated with the assumptions made in the analysis. Generally, assumptions made in the
assessment process are conservative, so that actual risk is unlikely to be greater than the estimated risk. For
example, groundwater total metal results were used to assess risk associated with groundwater ingestion as
opposed to the filtered metals data. However, groundwater used for drinking water would be better represented
by filtered (no solids) data, hence risks are overestimated. Consequently, the HRA for LF-024 is not to be
taken as a characterization of absolute risk, but rather, as an overestimation of the actual risk.
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Page '
TABLE 4
CONSTRUCTION SPOILS LANDFILL (LF-024)
CHEMICALS OF POTENTIAL CONCERN
SUMMARY TABLE
CHEMICAL
Methyiene Chloride
Acetone
2-Butanone
Acenaphthylene
Anthracene
Benzoic Acid
Benzo(a)anthracene
Benzo(a)pyrene
Benzo(t»fluoranthene
Benzo(k)nuoranthene
Benzofg.h.Operyiene
bis(2-Ethythexy1)phthalate
Butyl benzytphthalate
Chrysene
Olethytphthalate
Di-n-butylphthalate
Fluoranthene
:luorene
lndeno(1 ,2.3-cdlpyrene
2-Methylnaphthaiene
2-Methytphenol
Naphthalene
4-Nitroamline
Phenanthrene
Pyrene
Aluminum
Antimony
Arsenic
Janum
Jefyllium
Chromium (III)
Chromium (VI)
Cobalt
Cyanide
Lead
Manganese
Mercury
Nickei
Selenium
Thallium
Vanadium
Zinc
TOXICITY
C
C
C
C
C
C
C
C
C
C
C
C
C
C
GROUNOWATER
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
SURFACE SOIL
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
SOIL
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Notes
X - indicates chemical of potential concern
C - Chemical is classified as a carcinogen
-17-
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Two human exposure scenarios were evaluated as part of the risk assessment at LF-024.
1) Current Site Conditions - This scenario assumes that the site will remain undeveloped and will be
accessible to trespassers. Potentially exposed populations include teenage (ages 13 through 18) and
adult (ages 18 and over) trespassers. Potential exposure pathways include dermal contact with and
incidental ingestion of soil.
2) Future Site Conditions - This scenario assumes that the site will be remediated and developed for
industrial use. Potentially exposed populations include construction workers during site development
and industrial workers after site development. Potential exposure pathways include dermal contact
with and incidental ingestion of soil, inhalation of fugitive dust, and ingestion of groundwater.
Current federal guidelines for acceptable exposures are expressed as an individual lifetime excess total
cancer risk in the range of 10" to 10"6 and a maximum total hazard index (which reflects noncancer risks) equal
to one. A hazard index (HI) greater than one indicates a potential for adverse health effects.
The results of the HRA are summarized in Table 5. For current site conditions, cancer risks and
hazard indices for potentially exposed populations are below federal guidelines, and risks to human health
posed by site contaminants are acceptable. For projected future site conditions, cancer risks fall near the upper
end of the acceptable range specified by federal guidelines; however, hazard indices for both construction and
maintenance workers (HI = 20 for the inhalation of fugitive dust) and industrial workers (HI = 10 for the
ingestion of groundwater) are above federal guidelines. Therefore, there is a potential for adverse health
effects. Inhalation of fugitive dust is the pathway of conrem for construction workers, and ingestion of
groundwater is the pathway of concern for industrial workers. Manganese is the primary constituent driving
the unacceptable health risk for both soil and groundwater, with minor contribution from aluminum, antimony,
barium, and vanadium in groundwater.
Groundwater at the site currently is not used as a source of drinking water and is unlikely to be used
in the future given the extremely limited yield capacity of the shallow water-bearing zone. The assumptions
concerning risks associated with groundwater ingestion are also conservative given that the analysis was
performed using total metals data from turbid groundwater samples.
J U < 29 H» pVfiiuH>24 ROD/jm
i>:.:?.971.1 yi
-18-
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TABLE 5
CONSTRUCTION SPOILS LANDFILL(LF-024)
CANCER RISKS AND HAZARD INDICES FOR MULTIPLE PATHWAYS
EXPOSURE PATHWAY
CURRENT USE
TRESPASSER
ADULT
CANCER RISK
HAZARD INDEX
(CHRONIC)
TEENAGER
CANCER RISK
HAZARD INDEX
(SUBCHRONIC)
FUTURE USE
CONSTRUCTION
WORKER
CANCER RISK
HAZARD INDEX
(SUBCHRONIC)
INDUSTRIAL
WORKER
CANCER RISK
HAZARD INDEX
(CHRONIC)
Dermal contact with soil
NV
NV
NV
NV
NV
NV
NV
NV
Ingeslion of soil
BE-07
2E-02
2E-07
2E-02
1E-07
8E-01
5E-07
4E-O2
Inhalation of fugitive dust
NA
NA
NA
NA
2E-08
2E»01
NA
NA
Ingeslion of groundwater
NA
NA
TOTAL EXPOSURE CANCER RISK
TOTAL EXPOSURE HAZARD INDEX
2E-04
1E»01
ABBREVIATIONS:
NV - No Value (Dermal absorption factors were not available for CPCs)
NA - Not Applicable
-------
6.2 Ecological Risk Assessment
/
An ecological risk assessment was not performed for LF-024 as part of the SI. Also, the ecological
risks to potentially impacted terrestriaJ organisms exposed to contaminated fill and groundwater are expected
to be negligible. Because of the limited area of the landfill (approximately 1 acre), effects orr populations of
small burrowing mammals (e.g., the meadow mouse) are expected to be minimal and likely to impact only
animals with a home range restricted to the fill limits. Contaminants associated with groundwater also are
unlikely to affect area ecology significantly, since exposure to groundwater is limited and the metals plume
is confined to the area immediately downgradient of the landfill.
7.0 DEVELOPMENT OF REMEDIAL ALTERNATIVE
7.1 Selection of the Presumptive Remedy for Military Landfills
-i
Based on information acquired as a result of past experience with the Superfund Program, the USEPA
has developed the presumptive remedy approach to accelerate the remediation process. Presumptive remedies
are preferred technologies for common categories of sites (e.g.. landfills) that are based on historical patterns
of remedy selection and on scientific and engineering evaluations of technology performance. The
presumptive remedy approach is a tool for expediting of the remedial process developed by the Office of
Federal Facilities Restoration and Reuse.
In keeping with this approach, a remedial investigation/feasibility study (RI/FS) was not prepared for
LF-024. Instead, existing site data have been used to perform a risk assessment which provides the basis for
the development of a remedial approach that analyzes the various components of the presumptive remedy.
The presumptive remedy for CERCLA landfills meeting the criteria specified by the USEPA's
guidance is source containment (USEPA 1996). The decision whether the containment presumptive remedy
applies to a specific military landfill is subject to a step-by-step analysis of site-specific conditions with respect
to the USEPA guidance criteria. The decision framework for evaluating the applicability of the presumptive
remedy is provided in Figure 5. Specific-site circumstances which dictate the appropriateness of this approach
include the types of waste present, volume of landfill contents, land use plans, and hydrogeologic and safety
-20-
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Highlight 4: Decision Framework
Coueci Avaiiapie intormation
Waste Types
Operating History
Mbnitonn; Data
Slate Permit'Ciosu'e
Una Reuse Plan
S.ze'Voiume
Numoe' ol Facility Landfills
Consider Elects o» Lano
Reuse Plans on Remedy
Selection
Note Mjnicipai-type waste
can include lesser Quantities
of inausma! or Hazardous
waste m prooonion 10 total
voume ot wasie Out not
inc:jO>ng, military-specific
wastes
Mete Sue-specific (actors
sue-, as nyorogeoiogy.
volume, cost, ana safety
a-tect me oracticantv ol
eicavation ol lanolin
conte'ts
MiNttry-Spaeific Wastes
An Present: Consufl Witn
MliwryEictns
Contents Meet
Municipal-Type
waste
Definition
is
Excavation
ot Contents
Practical
is
Containment
me Most
Appropriate
Remedy
\
r
1
YES
r
Don't Uae
Containment
Presumptive
Remedy
(Although otner
remedial
alternatives are
consioe'eo. source
containment still
may oe selected)
}
f
1
USE CONTAINMENT PRESUMPTIVE REMEDY
(No Action and Presumptive Remedy are me only
alternatives considered. The Presumptive Remedy
allows tor treatment ot not spots)
Note: Site
investigation or
attempted treatment
may not be
appropriate: mese
activities may cause
greater nsk tnin
leaving waste in
place
URS
CERCLA MILITARY LANDFILL
PRESUMPTIVE REMEDY DECISION FRAMEWORK
FIGURE 5
-------
considerations. Within the decision framework, the effects of land use are considered first followed by a
determination of whether the landfill contents meet the definition of municipal-type waste. Municipal wastes
are defined to include household and commercial and industrial solid waste, with less quantities of hazardous
waste. Military-specific waste which may pose unique safety risks are afforded special consideration.
Based on information presented in the SI report and summarized in Sections 2.0 and 3.0. and land use
plans for the site, the containment presumptive remedy is an appropriate remedy for remediation of LF-024.
Currently, PARC has no plans for the development of the property. In addition, restrictions on future use of
the property will be enforced to prevent any adverse actions leading to the deterioration of the landfill cap.
thereby ensuring source containment. Although the landfill is relatively small (approximately I acre in size),
excavation and consolidation would not be preferred given the difficulties associated with the disposal of .the
waste. Excavation is impractical for several reasons. The excavation and incorporation of the waste within
other onsite landfills is not an option since these landfills either have been closed or placement of the waste
would impinge on existing wetlands. Excavation and removal of the waste to an offsite landfill also would
not be beneficial from a cost perspective. Finally, the contents of the landfill meet the guidance definition for
municipal-type waste, and includes a high proportion of nonhazardous C&D debris. The presence of military-
type waste in LF-024 has not been documented, and was not observed during SI activities. Levels of
contamination associated with the fill indicate a low level of risk commensurate with source containment.
7.2 Remedial Action Objectives
Remedial action objectives are medium-specific goals for protecting human health and the
environment, and provide the basis for selection of an appropriate remedial action. Results of the HRA
indicate that there is no risk of adverse health effects from direct contact (either incidental ingestion or skin
contact) with contaminated soil/fill. However, there is a potential health risk to construction workers from the
inhalation of fugitive dust during site remediation operations which include excavation and earth-moving
activities. A comparison of analytical results from soil/fill samples with New York State guidelines indicates
the onsite soil/fill contamination is minimal. Manganese is the primary constitute driving the fugitive dust
hazard index as discussed in the risk assessment (Section 3.1). On this basis, the following remedial action
objective has been established:
/ .<5:|)li»p-.r'irair04 ROD/;m
M2-:?.J? I) 22
-22-
-------
Prevent construction workers from inhaling contaminated fugitive dust resulting from earth-moving
activities during site remediation and post-closure maintenance operations.
The HRA also indicates that there is a potential health risk if a groundwater well is installed on. or
immediately downgradient of. the site and utilized for drinking water. At present, there are no drinking water
wells on site. The potential risk is attributed primarily to the presence of manganese at elevated concentrations
in groundwater. with antimony, barium, and vanadium contributing to a lesser degree to the hazard index. On
this basis, the following remedial action objective has been established:
Prevent human ingestion of contaminated groundwater on and immediately downgradient of the site.
In addition to the potential, chemically-related health-risks described above, the presence of exposed
C&D debris which protrudes from the surface of the landfill poses a potential safety hazard. Consequently.
the following remedial action objective has been established:
Eliminate potential physical hazards to onsite workers and maintenance personnel.
7.3 Development of the Remedial Alternative
The containment presumptive remedy consists of five remedial response actions which are evaluated
separately with respect to LF-024. The five component parts of the presumptive remedy include:
Landfill cap
Source area groundwater control to contain plume
Leachate collection and treatment
Landfill gas collection and treatment
Institutional controls to supplement engineering controls
According to USEPA guidance, response actions for individual sites are required to include only those
components that are necessary, based on site-specific conditions. An evaluation of each of the remedial
components is provided below.
124 ROD/jm
-23-
-------
A landfill cap is a necessary component of the remedial action for LF-024. It is required in
conjunction with the removal of exposed surface C&D debris which presents a physical safety hazard and is
a remedial action objective for this site. The landfill cap will serve to separate further the fill and debris from
surface exposure. The cap will incorporate erosion control measures to reduce the effects of rain and wind:
and will provide a growth medium for the long-term maintenance of the landfill cover.
Groundwater contamination at the site is limited to the presence of metals which were detected in
turbid groundwater samples. Groundwater control and leachate collection are unnecessary components of the
remediation since the dissolved contaminants, which form the greatest concern to groundwater ingestion. are
readily absorbed by sediments and immobile in groundwater. Therefore the metals contamination would have
an insignificant impact on the nearby Salmon River. Preventing the ingestion of groundwater at the site (a
major remedial action objective) will be addressed by institutional controls to prohibit the local use of
groundwater. Landfill gas collection and treatment is an unnecessary component of the remediation, since air
monitoring results indicate that there is no appreciable landfill gas emissions.
Institutional controls are a necessary component for remediation at LF-024 and are required to: (1)
restrict groundwater use and limit site development, (2) provide for the continued protection and maintenance
of the landfill cap, and (3) provide notice of potential health risks associated with remediation and development
of the site.
Specific alternatives for the two remedial components considered appropriate for LF-024 (i.e.. landfill
cap and institutional controls), are discussed below.
Landfill Cap: Three potential options for the landfill cap include: 1) a double barrier (RCRA-based)
cap; 2) a single barrier (NYSDEC Pan 360-based) cap and 3) native soil cover (i.e.. naturally occurring).
Individual components of these caps are described below. Each option was evaluated with respect to
effectiveness (i.e., the ability to meet the remedial action objectives and to protect human health and the
environment), implementability (both administrative and technical), and cost.
All three landfill caps are expected to be effective. Any of the caps, if properly designed and
maintained, would prevent direct contact by humans with onsite soil/fill, gradually diminish leachate
I .'52l)Hwp.rmjl(i:4 ROD/jm
H;.;?..)'' i.i 22
-24-
-------
generation and groundwater contamination, and reduce risks associated with physical hazards and the
inhalation of fugitive dust.
The technical implementability (i.e.. constructability) of the three caps is related to the components
summarized below:
Double Barrier Cap includes a gas collection, clay layer, flexible membrane liner, sand drainage layer.
filter fabric, soil layer for frost protection, topsoil. and vegetative cover.
Single Barrier Cap includes a gas collection layer, a low permeability layer (or flexible membrane
liner), a soil layer for frost protection, topsoil. and vegetative cover.
Native Soil Cap includes a soil layer, topsoil. and vegetative cover.
Based on the components required, the double barrier cap and single barrier cap would be more
difficult to construct, whereas the native soil cover would be comparatively easier to construct. Both barrier
caps would be particularly difficult to construct on LF-024 because a portion of the surface is heavily forested.
Complete clearing and grubbing of the site prior to cap construction is undesirable, since the significant
\egetation protects the surface against erosion.
Cap costs depend largely on the number of components and total cap thickness. A native soil cover
is the least costly landfill cap. An order of magnitude estimate for the construction of a 12-inch native soil
cover is 559.000 for this 1 -acre site. The construction cost for a single barrier cap (without a gas collection
layer) is estimated to be over four times greater ti.an the native soil cover. The construction cost of the double
barrier cap is estimated to be significantly (approximately 20 to 40 percent) greater than the single barrier cap.
Operations and maintenance (O&M) costs for the double barrier cap are expected to be the highest. O&M
co-tv for a single barrier cap are expected to be lower than the double barrier, but significantly higher than for
a native soil cover.
Institutional Controls: Appropriate institutional controls to be implemented for LF-024 include
restrictions that limit site development and protect the integrity of the cap. In addition, institutional controls
I «:'>! »n'lirul'iM ROD'im
-25-
-------
are necessary to address remedial action objectives including water use restrictions that prohibit the use of
groundwater as a potable water source on and immediately downgradient of the site. These institutional
controls will be implemented by PARC which is responsible for management of the property.
Implementation of these remedial measures will require continued groundwater monitoring, including
five-year site reviews to evaluate the effectiveness of the remedial measures. These remedial measures and
the rationale for their selection are supported by USEPA guidance.
8.0 COMPARATIVE ANALYSIS OF ALTERNATIVES SUMMARY
Nine criteria are utilized for the evaluation of an alternative as specified in the NCP and discussed in
detail in the RI/FS guidance (USEPA 1988). These nine criteria are listed and described in Table 6. The
evaluation of the recommended remedial alternative at LF-024 with respect to these nine criteria is presented
below.
Overall Protection of Human Health and the Environment - The remedial alternative selected for LF-
024 will reduce human health risk to acceptable levels. The construction of a landfill cap. in conjunction with
the removal/realignment of protruding construction debris, will eliminate physical hazards while protecting
onsite industrial workers from the possible inhalation of fugitive dust. In addition, the landfill cap effectively
will reduce long-term leaching impacts on groundwater quality, reducing risks associated with groundwater
ingestion.
The implementation of institutional controls (including deed and lease provisions to limit site
development,-protect the integrity of the cap, and prohibit groundwater use) would ensure continued
protection. Notice of potential inhalation risks and, health and safety measures required during earth moving
activities, will further protect site construction workers. Regular inspection of the cap will ensure that the cap
remains effective in meeting the remedial objectives. The groundwater monitoring program will assist in
evaluating the adequacy of controls to protect downgradient receptors.
Compliance with Applicable or Relevant and Appropriate Requirements (ARARs) - In general,
exceedances of groundwater ARARs (see Section 2.4.4) are minimal and are believed to be due to the high
I '-:)! »p.fmali£J ROD;jm
-26-
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TABLE 6
CONSTRl CTION SPOILS LANDFILL (LF-024)
EVALUATION CRITERIA
Criteria
No.
1
2
3
4
5
6
7
8
9
Description
Overall Protection of Human Health and the Environment - Protectiveness is the primarv
requirement of remedial action at hazardous waste sites. Evaluation of this criterion
involves an assessment of how an alternative achieves protection over time and how site
risks are reduced.
Compliance with ARARb - Compliance with ARARs includes compliance with chemical-
specific, action-specific, and location-specific requirements.
Long-term Effectiveness and Permanence - This criterion requires an assessment of: (a)
the magnitude of residual risk after remediation; (h) the adequacy of controls to meet
required performance specifications, both initially and into the future; and (c) the reliability
of controls from an operational standpoint.
Reduction of Toxicity Mobility or Volume fTM,Y^ - This criterion addresses the statutory
preference, expressed in the Superfund Amendments and Reauthorization Act (SARA).
for remedies that employ treatment as a principal element. It includes an assessment of
the magnitude, significance . and irrcvcrsihility of treatment, as well as an evaluation of the
type and quantitv of residuals remaining after treatment.
Short-term EftCL'QY^ntiSS - This criterion includes the short-term impacts of an alternative
(i.e., during implementation) upon the surrounding community, onsite workers, and the
environment. It also addresses .the time required for the alternative to satisfy remedial
action objectives.
Implememabiliiy - Implementahiliry includes many of the practical aspects associated with
implementation of the remedial alternative, such as the ability to construct and operate
remedial technologies, the reliability of the technologies, ease of undertaking additional
remedial actioas if necessary , ability to monitor the alternative's effectiveness, availability
of required materials and services, permit requirements, and need to coordinate with other
agencies.
Cost - This quantitative evaluation criterion includes the capital and operation/maintenance
costs associated with each alternative, as well as its total present worth.
State Ac.Cjjrtia.Qi;e. - This criterion evaluates the technical and administrative issues and
concerns the State mav have reeardins an alternative.
Community .A.c.cs.n.Mn.kC This criterion evaluates the issues and concerns the public ma\
have regarding an alternative.
N! --t. -AnalON ROD-;
-------
turbidity of the ground water samples. Human health can be protected adequately by preventing groundwater
use on and immediately downgradient of the site until such time as groundwater quality is confirmed or.
leaching effects are sufficiently diminished. Construction of the cap with proper drainage control and
continued monitoring will protect against a release of contaminants exceeding ARARs in near-surface soil and
fill. It is anticipated that acceptable levels of metals will be obtained in groundwater within the first year of
cap construction.
NYSDEC regulations, namely 6NYCRR Pan 360 Solid Waste Management Facilities (effective
January 14, 1995), are the most important action-specific ARARs for LF-024. They regulate closure and final
design for landfills. The recommended remedial alternative is compliant with these regulations and complies
with all action- and location-specific ARARs.
Long-Term Effectiveness and Performance - The remedial action objectives established for LF-024
will be addressed by the remedy. Health risk associated with the future inhalation of fugitive dust and physical
hazards related to protruding debris will be eliminated by surface contouring and capping. Risks associated
with the ingestion of groundwater will be controlled by implementing institutional controls on groundwater
use. In addition, the gradual reduction in groundwater contamination will be achieved by diminished landfill
leaching overtime and. ultimately, by the natural attenuation of the groundwater contaminants.
The site monitoring program and five-year site reviews represent additional components that will be
used to evaluate the effectiveness of remedial measures and, consequently, to protect human health and the
environment.
Reduction of Toxicitv. Mobility, and Volume (TMVt - A treatment technology to reduce TMV is not
included in the alternative. Groundwater contamination at the site is limited to metals which are relatively
immobile in groundwater due to the high affinity of dissolved metals for solid surfaces. Consequently the
metals contamination would have an insignificant impact on the Salmon River. Health risks associated with
the ingestion of metals (primarily manganese) will be controlled by limiting infiltration and landfill leaching.
and by restrictions on groundwater use on and immediately downgradient of the landfill.
I ."5:i>l vtpvliiulON ROD/jm
'>::>
-------
Shon-Term Effectiveness - Construction of the alternative will require some earth-work for site
grading. Dunne the construction period including intrusive activities during site development, short-term
impacts to workers and the environment is possible via inhalation of fugitive dust. However, these impacts
can be mitigated easily by instituting conventional health and safety measures. It is estimated that
construction/implementation of remedial measures will require less than one year. The remedial action
objectives will be met upon completion of construction and the incorporation of deed restrictions on the use
of groundwater.
Implementabilitv - The technologies proposed for the alternative are conventional and are expected
to be constructed with little, if any. difficulty. Cap construction and grading in wooded areas is expected to
present the greatest difficultly during construction. Materials required for construction (i.e.. topsoil and
common borrow) are available.
Cost - The capital cost includes the cost of cap construction and implementation of deed restrictions.
The capital cost estimate for this alternative is 559,000. O&M costs include annual monitoring, and cap
inspection and repair. The estimated annual O&M cost is 56,000. The present worth cost of the annual O&M
COM. based on a 30-year period at an interest rate of 6 percent, is 577,000 (Table 7).
State Acceptance - The NYSDEC has provided input during the preparation of the SI and HRA and
concurs with the remedial alternative.
Communit\ Acceptance - Community acceptance of the recommended alternative has been obtained.
Public comments solicited from the community during the public comment period and responses to these
comment'- are provided in Appendices D and E.
In accordance w ith the NCP. the recommended alternative is protective of human health and the
cm iii'nnuMit. will compi\ with ARARs and is cost effective. The recommended alternative is not a permanent
solution since it does not include treatment. However, it follows the NCP and USEPA guidance which
specifies containment as the presumptive remedy for landfills.
-29-
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TABLE 7
COST ESTIMATE SUMMARY FOR THE SELECTED REMEDY
< APII Al. COSTS:
1 VEGETATIVE COVER
2 TOP SOU. INCLUDING SPREADING
1 SOU. I10RROW (.AVER INCH 'DING COMPACTION
-1 REGRAUINUOFSOIL
« ITERATION AND MAINTENANCE COST:
1 1 ANDIII 1 CAP
INSPECTION Ol: CAT
MAINTENANCE (Cl'T GRASS)
REPAIR (REPLACEMENT 01 TOPSOII '
:\NI)Ki:SLI DING)
ToUl Yearly C'tisl 1 ot Cap Ins|vi1ion . Maniliiuikv And Kquir
2 CiKOI'NDW.VirR MONITOKIMi
SAMI'I ,IN(t- QUARTERLY
ItiROIiNDWATER ' 2 QAQC SAMPLES
2 WORKERS \ 1 5 u,\\s \ x MUS D \v
AN \l VTICAI TESTINCJOI S AMI'I 1 S (Mculs Only)
(. S AMI'I IS -1 TIMES A VEAR
\l l)IIIN(iorSAMPIIN(iKISl 1 ISAM)
I'KI PAKATIONOE A REI'OR'I HHAI Ol
t IIKS KOI 'NO \ ^ i:\ EN i s \ i \K
UNIT
ACRE
ACRE
CY
CY
Ilk
NO YR
NO
MR
NO
UK
QUANTITY
10
10
xvo
890
ID
7
2
12
2-1
I).
UNIT COST
% 2.100 00
IK.OOOOO
21 50
2250
S 50 00
75.00
500.00
S 50.00
V (>5.00
I (.1)0(1
InlalC'osl nl (irouixluaUf Miuiiloting IVi \\-.\i >HI J Oujilcih lljbi.slin Ilk- In si > \cji>
lulul C'oM »l (mmiiduaUl Mimitinini; mi .in Aniiuiil HJSIS lix ^ ojl
-------
9.0 THE SELECTED REMEDY
Plattsburgh AFB has selected for remediation of LF-024 the presumptive remedy designated by the
USEPA for military landfills consisting of containment with a native soil cap and institutional controls.
USEPA approval and NYSDEC concurrence are expected. The selected remedy is protective of human health
and the environment, and is cost effective. The alternative includes the following elements:
Native Soil Cap - A 12-inch native soil cap consisting of naturally occurring soils with a 9-inch layer
of inorganic soil, a 3-inch topsoil layer, and a vegetative cover, will be established at LF-024 as a supplement
to the existing soil cap to ensure fugitive dust control. Soil for capping will be chemically analyzed before it
is utilized at LF-024. Large trees (i.e., those over 6 inches in diameter) may be left in place during soil cover
establishment provided the trees do not interfere with the attainment of the remedial goal or the maintenance
of positive surface water run-off and erosion control. Soil layers will be compacted to reduce permeability and
the sue cap will be constructed to control surface water run-off and control erosion. The soil cover will be
inspected on an annual basis with repairs/replacement of the cap as required.
Institutional Controls - Restrictions will be imposed to limit development of any structure on the
landfill site which would adversely effect human health and safety. Deed and lease agreements will include
appropriate restrictions to prevent any adverse action leading to the deterioration of the landfill cap to include
prohibition from installing any wells for drinking water or any other purpose which could result in the use of
the underlying groundwater and the prohibition against any excavation of the landfill cap without prior
approval of New York State Department of Environmental Conservation. In addition, notice is to be provided
in deed and lease agreements to warn of potential short-term health risks from inhalation of dust during site
construction activities. Area groundwater use will be restricted as shown on Figure 3 a.id includes the area
encompassing the landfill and groundwater pathway between the landfill and the Salmon River.
Monitoring - Long-term groundwater monitoring will be performed and analyzed to evaluate
groundwater quality during the post-closure period (30 years). Groundwater samples will be collected using
a low-flow pump from three shallow downgradient monitoring wells, which will be installed near the
respective locations of the SI well points (See Figure A-5 - Appendix A). An additional well will be located
100 feet farther downcradient. between the landfill and the Salmon River to serve as a sentrv well to monitor
I .":9|.»p-fmali':4RODiini
' I " ' ! : II
-31-
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plume containment. A groundwater sample also will be collected from the existing upgradient monitoring
well to provide a background comparison. Samples will be collected following well purging and analyzed for
total metals (i.e., target analyte list inorganics). Sampling will be conducted semi-annually for the first five-
years after the cap is constructed, and annually thereafter. Monitoring results will be reviewed by the USAF.
USEPA, and NYSDEC. Detailed instructions for the conduct of the groundwater monitoring program will
be included in the site's Operation and Maintenance Plan and implemented as pan of the Record of Decision
(ROD).
Five-Year Site Review - Every five years, data generated by the monitoring program will be reviewed
to evaluate the effectiveness of remedial measures. Modifications to the extent of site monitoring efforts will
be recommended at that time.
10.0 STATUTORY DETERMINATIONS
The remedial action selected for implementation at LF-024 is consistent with CERCLA and. to the
extent practicable, the NCP. The selected remedy is protective of human health and the environment, attains
ARARs, and is cost effective. The selected remedy uses permanent solutions and alternative treatment
technologies or resource recovery technologies to the maximum extent practicable for this site. However, it
does not satisfy the statutory preference for treatment which permanently and significantly reduces the
mobility, toxicity, or volume of hazardous substances as a principal element.
10.1 The Selected Remedy is Protective of Human Health and the Environment
The remedy at LF-024 will permanently reduce the potential future risk posed to human health and
the environment through engineering controls (i.e.. construction of a native soil cap), as well as institutional
controls (i.e., restrictions on the future development of the site and the use of groundwater as a potable supply
source). The construction of the cap, as well as its inspection every five years and any required repair, will
effectively eliminate the risks posed by the inhalation of fugitive dust and physical hazards associated with
protruding construction debris.
1114 ROD'jm
-32-
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The site cap will be constructed so that soil layers are compacted to reduce permeability, and to control
surface water runoff and erosion. These features will reduce offsite migration of contaminants by surface
runoff and groundwater. Finally, implementation of the selected remedy will not pose unacceptable short-term
risks thut cannot be mitigated easily by instituting conventional health and safety measures. In addition, no
adverse en\ ironmental impacts are expected from implementation of the remedy.
10.2 The Selected Remedy Attains ARARs
The remedy will comply with all applicable or relevant and appropriate chemical-, action-, and
location-specific requirements (ARARs). Compliance with the chemical-specific ARARs will be achieved
gradually through the process of natural degradation and attenuation. Federal and state ARARs are presented
below .
Chemical-specific
RCRA Hazardous Waste Toxiciry Characteristic Limit. 40 CFR 26] - Establishes standards for
soil.
6 ,\'YCRR 700-705 Water Quality Regulations - Establishes standards for groundwater.
L'SEPA Safe Drinking Water Act. National Primary and Secondary Drinking Water Regulations (40
CFR Parts 141 and 143) - Establishes standards for potable sources.
Action-specific
\VSDEC Solid Waste Management Facility Rules 6 NYCRR Part 360 Effective January 14. 1995 -
Establishes criteria for solid waste landfills and specifies closure and post-closure procedures
.\'YSDEC Division of Air Resources Regulation (6NYCRR Parts 200-202, 257) - Establishes
regulations applicable to paniculate matter (e.g., fugitive dusts) entrained in air during clearing,
grading, and coyer system construction activities.
-33-
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Clean Air Act (40 CFR Part 50) - Establishes regulations applicable to paniculate matter (e.g..
fugitive dusts) entrained in air during clearing, grading, and cover system construction
activities.
Occupational Safety and Health Administration Regulations (29 CFR Parts 1904, 1910. and 1916) -
Establishes regulations applicable to all work conducted on site.
Location-specific
National Environmental Policy Act of1969 (NEPA) (40 CFR Pan 1501) - The Department of the Air
Force revised their protocols to be in compliance with NEPA. The revision provides policy
and guidance for consideration of environmental matters in the Air Force decision-making
process.
Section 404 of the Clean Water Act and 40 CFR 230 Protects waters of the United States, including
aquatic and wetland habitats.
. New YorkState Use and ProtectionofWaters (6 NYCRR 608) - Protects streams including Class A.
B, and C(T) from disturbances or adverse impacts through a permitting process.
New York State Water Quality Classifications (6 NYCRR 701-703) Classifies and protects
groundwater, streams, and other water bodies.
10.3 Other (Criteria,. Advisories, or Guidance to be Considered for this Remedial Action
NYSDEC soil TBCs (TAGM #4046. 1994) will not be met since treatment is not included in the
alternative. However, the NYSDEC concurred with the recommended alternative since TBCs are guidance
rather than promulgated standards and the remedy adequately protects human health and the environment.
In addition, surface water and groundwater results were compared with NYSDEC ambient water quality
guidance values (TOGS 1.1.1, 1993). Overall, contaminant levels in groundwater are considered to be
'.«pu'in3U)24 ROD/jm
1.1::
-34-
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minimal; therefore, human health can be protected by prohibiting its use on, and immediately downgradient
of the site Construction of a cap with proper drainage controls and continued monitoring will protect surface
water and sediment quality.
10.4 Cost-Effectiveness
The selected remedy is cost-effective, in that, it provides an effective remedy at a significantly lower
cost than the other capping alternatives evaluated. In selecting this remedy, the overall effectiveness of each
capping alternative was evaluated by assessing three relevant criteria: ability to protect human health and the
environment, implementability. and cost. Including the cap construction and implementation of deed
restriction, the capital cost is estimated to be 559,000. O&M costs include groundwater monitoring, and cap
inspection and repair. The estimated annual O&M cost is $6,000. The present worth cost of the annual O&M
cost, based on a 30-year period at an interest rate of 6 percent, is 577,000.
10.5 Utilization of Permanent Solutions and Alternative Treatment Technologies (or Resource
Recovery Technologies) to the Maximum Extent Practicable
The selected remedy uses permanent solutions and alternative treatment technologies to the extent
practicable for this site. The remedy will eliminate the risks associated with inhalation of fugitive dust and
groundwater. Monitoring and five-year site reviews will be used to measure its long-term effectiveness in
protecting human health and the environment. However, the remedy will not reduce the toxicity, mobility, and
volume of contaminated site media. Regular inspection of the cap will ensure that the cap remains effective
in meeting the remedial objective.
10.6 The Selected Remedy Does Not Satisfy the Preference for Treatment Which Permanently and
Significantly Reduces the Toxicitv. Mobility, or Volume of the Hazardous Substances as a
Principal Element
Because treatment of the principal threats at the site was found to be impracticable, this remedy does
not satisfy the statutory preference for treatment as a principal element of the remedy. Treatment technologies
were considered during the identification, development, and initial screening of alternatives, but were
) 1.1.':|)r.»p>/ma1ii:4 ROD/im
-35-
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considered to be infeasible for the LF-024 landfill site. The fact that there are no definable onsite hot spots
that represent the major sources of contamination preclude a remedy in which contaminants could be excavated
and treated effectively.
11.0 DOCUMENTATION OF NO SIGNIFICANT CHANGES
Plattsburgh AFB presented a Proposed Plan for the preferred alternative for remediation of LF-024
in November 1996. The preferred alternative includes:
Clearing the site
Establishing a continuous soil cover
Managing surface water runoff to minimize erosion of the cover and minimize maintenance
requirements
Establishing vegetation to minimize erosion of the final cover and enhance evapotranspiration
Placing institutional controls in property deed an lease agreements to prevent adverse actions
leading to deterioration of the cap and prohibitions on local use of groundwater.
Developing a post-closure plan development to monitor, maintain, and inspect the site
Monitor groundwater
Conducting five-year reviews
The chosen remedial action does not differ from the preferred alternative presented in the Proposed
Plan.
12.0 STATE ROLE
The NYSDEC, on behalf of the State of New York, has reviewed the various alternatives and has
indicated its support for the selected remedy. It also has reviewed the SI and Proposed Plan to determine if
the selected remedy complies with applicable or relevant and appropriate New York State environmental laws
and regulations. The NYSDEC concurs with the selected remedy for the LF-024. A copy of the declaration
of concurrence is attached as Appendix C.
J '-':oi'.*p>jlnaln:-l ROD/jm
II2-27-1}"7 I.1 22
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REFERENCES
E. C. Jordan Co. 1989. Installation Restoration Program. Final Site Inspection Report. Plattsburgh
Air Force Base. Plattsburgh. AV u York.
New York State Department of Environmental Conservation (NYSDEC). 1994. Bureau of Hazardous
Waste Remediation. Determination of Soil Cleanup Objectives and Cleanup Levels. TAGM #4046.
Albany.
. 1993. Ambient Water Quality Standards and Guidance Values. TOGS I.I.I. Albany:
Division of Water.
PARC. 1995. Comprehensive Reuse Plan for Plattsburgh Air Force Base. 15 September (subject to
revision).
Radian Corporation. 1985. Installation Restoration Program. Phase I - Records Search. Plattsburgh
Air Force Base. Plattsburgh. New York.
URS Consultants. Inc. 1994. Former Landfill (LF-021), Remedial Investigation Report. Plattsburgh
Air Base. Installation Restoration Program. Plattsburgh, New York.
U.S. Environmental Protection Agency (USEPA). 1988. Guidance for Conducting Remedial Investigations
and Feasibility Studies Under CERCLA, October. Cincinnati, OH: USEPA.
. 1989a. Risk Assessment Guidance for Superfund, Vol I: Human Health Evaluation Manual
i Pun A i. Interim Final, (EPA/540/1-89/002). Cincinnati, OH: USEPA.
. 1989b Risk Assessment Guidance for Superfund. Vol. II: Environmental Evaluation Manual
(EPA/540/1-89/001). Cincinnati. OH: USEPA.
. 1989c. Guidance on Preparing Superfund Decision Documents: The Proposed Plan. The
Record of Decision, Explanation of Significant Differences, The Record of Decision Amendment.
Interim Final. July. Cincinnati. OH: USEPA.
. 1990a. Streamlining the Rl/FSfor CERCLA Municipal Landfill Sites. Cincinnati. OH: USEPA
. 1990b. "National Oil and Hazardous Substance Pollution Contingency Plan;" 40 CFR Part
300: Washington, D.C. March 8, 1990.
. 1991 a. Summary- Report on Issues in Ecological Risk Assessment. EPA/625/3-91-018. Risk
Assessment Forum. Cincinnati, OH: USEPA.
. 1991b. Ecological Assessment of Superfund Sites: An Overview, ECO Update. Vol. l.No
2. Publication 934.0-051. Cincinnati. OH: USEPA.
1991c. Conducting Remedial Investigations/Feasibility Studies for CERCLA Municipal Landfills.
EPA/540/P-91/001. Cincinnati. OH: USEPA.
J >.'<:01\«-ptfiiuH>24 ROD'jm
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REFERENCES - Cont'd
.. 1993. Presumptive Remedy for CERCLA Municipal Landfill Sites. Cincinnati. OH: USEPA.
_. 1996. Application of the CERCLA Municipal Landfill Presumptive Remedy to \filirar\- Landfills
{Interim Guidance). EPA/540/F-96/007, April. Washington. D.C.
>! »pMinjlllM ROD/jm
> p::
-38-
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GLOSSARY
Administrative Record: A file established and maintained in compliance with Section 113(K) of CERCLA.
consisting of information upon which the lead agency bases its final decisions on the selection of remedial
method!si for a Supertund site. The Administrative Record is available to the public.
Applicahle or Relevant and Appropriate Requirements (ARARs). ARARs include any state or federal statute
or regulation that pertains to protection of public health and the environmental in addressing certain site
conditions or using a particular remedial technology at a Superfund site. A state law to preserve wetland areas
is an example of an ARAR. USEPA must consider whether a remedial alternative meets ARARs as pan of
the process for selecting a remedial alternative for a Superfund site.
Aquifer: A water-bearing formation or group of formations.
Carcinogenic: Exposure to a particular level of a potential carcinogen may produce cancer.
Comprehensive Environmental Response. Compensation, and Liability-Act (CERCLA): A federal law passed
in 1980 and modified in 1986 by the Superfund Amendments and Reauthorization Act (SARA). The act
requires federal agencies to investigate and remediate abandoned or uncontrolled hazardous waste sites.
C&D Debris. Building waste resulting from construction and demolition activities.
Ecological Receptors: Fauna or flora in a given area that could be affected by contaminants in surface soils.
surface water, and/or sediment.
Gmiindwater: Water found beneath the earth's surface that fills pores within materials such as sand. soil.
gravel, and cracks in bedrock, and often serves as a source of drinking water.
HOPE: High Density Polyethene. plastic material often used to cover municipal and hazardous waste landfills.
Inorganic Compounds: A class of naturally occurring compounds that includes metals, cyanide, nitrates.
sulfates. chlorides, carbonate, bicarbonate, and other oxide complexes.
Installation Restoration Program (IRP): The U.S. Air Force subcomponent of the Defense Environment
Restoration Program (DERP) that specifically deals with investigating and remediating sites associated with
suspected releases of toxic and hazardous materials from past activities. The DERP was established to clean
up hazardous waste disposal and spill sites at Department of Defense facilities nation-wide.
Landfill Cap: A cover system for the landfill.
Leadune: Solution produced by percolating liquid in contact with contaminated matter.
\CP: \ati<>i:ti.' OH and Hti:urdntis Suhsnince Contingency Plan. A federal law governing hazardou>
substances (40 CFR Pan 300. I99()i.
\(itiomi! Priorities List: USEPA's list of the most serious uncontrolled or abandoned hazardous waste sites
identified for possible long-term remedial action under the Superfund program.
\t>ncarciiit>t>enic:- Exposure to a particular level of a potential noncarcinogen may produce adverse health
effects.
' I* iin.ii -.4 Ki t(j im
-39-
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Organic Compound*. Any chemical compound huilt on the carbon atom. (i.e.. methane, propane, etc.)
PAHs: Pulynuclear Aromatic Hydrocarbons, often associated with combustion process and distillation tars.
PCBs: Polychlorinated Biphenyls. formerly used as a lubricant and transformer coolant.
ppb: Parts per billion.
ppm: Parts per million.
RCRA: Resource Conservation and Recovery Act.
Record of Decision (ROD): A public document that explains the remedial alternative to he used ut a National
Priorities List (NPL) site. The ROD is based on information and technical analysis generated during the
Remedial Investigation, and on consideration of the public comments and community concerns received on
the Proposed Plan. The ROD includes a Responsiveness Summary of public comments.
Remedial Action: A long-term action that stops or substantially reduces a release or threat of a release of
hazardous substances that is serious but not an immediate threat to human health or the environment.
Remedial Alternatives: Options evaluated to address the source and/or migration of contaminants to meet
health-based or ecology-based remediation goals.
Remedial Investigation (Rl): The Remedial Investigation determines the nature, extent, and composition of
contamination at a hazardous waste site, and directs the types of remedial options that are developed in the
Feasibility Study.
SACM: Superfund Accelerated Cleanup Model.
SARA: The Superfund Amendments and Reauthorization Act of 1986 amended the 1980 CERCLA. The
amendments that re-authorized the federal Superfund which had expired in 1985 and established the preference
for remedies that permanently reduce toxicity, volume, or mobility of hazardous constituents.
Sediments: Soil material found in water.
Semivolatile Organic Compounds: (SVOCs) Organic constituents which are generally insoluble in water and
ai £ not readily transported in ground water.
Source: Area at a hazardous waste site from which contamination originates.
Superfund: The trust fund, created by CERCLA out of special taxes, used to investigate and clean up
abandoned or uncontrolled hazardous waste sites. Out of this fund L'SEPA either: (I) pays for site remediation
when parties responsible for the contamination cannot be located or are unwilling or unable to perform the
work or (2) takes legal action to force parties responsible for site contamination to clean up the site or pay back
the federal government for the cost of the remediation. Federal facilities are not eligible for Superfund
monies.
TBC: Non-promulgated standards "To"Be Considered" for consideration a> AR.ARs.
Volatile Organic Compounds: (VOCs) Organic constituents which tend to volatilize or to change from a liquid
to a gas form when exposed to the atmosphere. Many VOC's are readily transported in groundvvater.
£>::?.«': 14 x)
-40-
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APPENDIX A
CHEMICALS DETECTED
IN ENVIRONMENTAL MEDIA
AT LF-024
I o.<2vi »pjiiuli'U ROD'jm
-------
APPENDIX A
CHEMICALS DETECTED IN ENVIRONMENTAL MEDIA AT LF-024
TABLE/FIGLR
E NUMBER
TABLE A- 1
FIGURE A- 1
TABLE A-2
FIGURE A-2
TABLE A -3
FIGURE A-3
TABLE A -4
FIGURE A -4
TABLE A-5
FIGURE A-5
TITLE
CONSTRUCTION SPOILS LANDFILL (LF-024) SITE INVESTIGATION -
SUMMARY OF ANALYTES DETECTED IN SEDIMENT SAMPLES
CONSTRUCTION SPOILS LANDFILL (LF-024) SITE INVESTIGATION -
CHEMICALS DETECTED IN SURFACE WATER AND SEDIMENT
SAMPLES
CONSTRUCTION SPOILS LANDFILL (LF-024) SITE INVESTIGATION -
SUMMARY OF ANALYTES DETECTED IN NEAR SURFACE SOIL
CONSTRUCTION SPOILS LANDFILL (LF-024) SITE INVESTIGATION -
CHEMICALS DETECTED IN NEAR SURFACE SOIL SAMPLES
CONSTRUCTION SPOILS LANDFILL (LF-024) SITE INVESTIGATION -
SUMMARY OF ANALYTES DETECTED IN FILL SAMPLES TAKEN
DURING TEST TRENCHING
CONSTRUCTION SPOILS LANDFILL (LF-024) SITE INVESTIGATION -
CHEMICALS DETECTED IN FILL SAMPLES
CONSTRUCTION SPOILS LANDFILL (LF-024) SITE INVESTIGATION -
SUMMARY OF ANALYTES DETECTED IN SUBSURFACE SOIL SAMPLES
CONSTRUCTION SPOILS LANDFILL (LF-024) SITE INVESTIGATION -
CHEMICALS DETECTED IN SUBSURFACE SOIL SAMPLES
CONSTRUCTION SPOILS LANDFILL (LF-024) SITE INVESTIGATION -
SUMMARY OF ANALYTES DETECTED IN GROUNDWATER
CONSTRUCTION SPOILS LANDFILL (LF-024) SITE INVESTIGATION -
CHEMICALS DETECTED IN GROUNDWATER
riiui'-:j ROD-UK
-------
TABLE A-1
CONSTRUCTION SPOILS LANDFILL(LF-024) - SITE INVESTIGATION
SUMMARY OF ANALYTES DETECTED IN THE SEDIMENT (SOIL) SAMPLES
ANALYTE
Methylene Chloride
Acetone
2 Butanone
Diethytphthalate
Phenanthrene
Di-n-butylphthalale
Fluor anlhene
Pyrene
Rutytbenzylphthalate
bis(2-Ethylhexyl)phthalate
Benzo(a)pyrene
Naphthalene
2 Melhylnaphthalene
TBC
Values'
too
200
300
7.100
50.000
8.100
50.000
50.000
50.000
50.000
61
13.000
36.400
LEVEL IV
FREQUENCY
OF
DETECTION
2 / 4
1 / A
2 / 4
1 / 4
1 / 4
4 / 4
2 / 4
2 / 4
2 / 4
2 / 4
2 / 4
1 / 4
1 / 4
DETECTED
MINIMUM
CONCENTRATION
7
300
22
15
10
39
10
6
13
32
67
7
2
DETECTED
MAXIMUM
CONCENTRATION
10
300
98
15
10
5300
13
B
15
43
130
7
2
All results reported in pg/kg
- Unless otherwise noted, To Be Considered (TBC) values are NYSOEC Soil Cleanup Objectives and Cleanup Levers.
TAGM HWR 94-4046. January 1994
Note:
Due to Nmited area! extent and intermittent subaqueous nature, these samples were used
in the HRA to evaluate risks associated wHh soil
-------
TABLE A-1 (confd)
CONSTRUCTION SPOILS UVNDFILL(LF 024) - SITE INVESTIGATION
SUMMARY OF ANALYTES DETECTED IN THE SEDIMENT (SOIL) SAMPLES
ANAI.YTE
Aluminum
Antimony
Arsenic
Barium
Befyffium
Calcium
Chromium
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Mercury
Nickel
Potassium
Vanadium
Zinc
TBC
Values'
8.510 (SB)
126 (SB)
75
300
074 {SB|
30,200 (SB)
195 (SB)
30
441 (SB)
36.700 (SB)
79.4 (SB)
3.340 (SB)
474 (SB)
01
13
929 (SB)
150
634 (SB)
LEVEL IV
FREQUENCY
OF
DETECTION
4 / 4
2 / 4
1 / 4
4 / 4
I / 4
4 / 4
4 / 4
4 / 4
3 / 4
4 / 4
4 / 4
4 / 4
4 / 4
1 / 4
1 / 4
4 / 4
4 / 4
4 / 4
DETECTED
MINIMUM
CONCENTRATION
2450
153
35
251
07
2390 \
39
16
1.4
6760
4.6
679
189
018
85
363
105
161
DETECTED
MAXIMUM
CONCENTRATION
3490
205
35
321
07
3220
! 6.4
52
58
15600
115
1090
542
018
85
588
124
391
All results reported in mg/kg.
* - Unless otherwise noted. To Be Considered (TBC) values are NYSDEC Soil Cleanup Objectives and Cleanup Levels.
TAGM HWR-94-4046, January 1994
SB - Site background values (or metals were used when less stringent than the regulatory value. Site Background was
based on a basewide background study (URS 1995)
Note
Due to limited areal extent and intermittent subaqueous nature, these samples were used
in the HRA to evaluate risks associated with sod
11 l'..«nvjl>|
-------
\
"Y
SAM'tl *'
»0
144.
M '
WATCR
SAMPtf |PO<;SIBtE ICOCHAII in
i All SAMPICS AND (Mr.TAI i AIION',
MAOT DURING MALCOIM PlRNK
FALL. !<)<>? INVf SIIGAIION PRORRAM
? SFOIMfNI SAMPIF RF/,111 IS IN
fOB nROAMC COMPOUNDS ANIi
mq/kq t OR INOHOAN1C5 SUR( ACf
WAIF I) fllMH I', IN u«/L
(On
IFO24 SITE INVESTIGATION
CHEMICAI S OTTECTED IN SURF ACf
WATER AM) SEDIMENT SAMPLE T,
URS I FrGURf A I
-""'-' 1
-------
I'.ifjn t
TABLE A-2
CONSTRUCTION SPOILS LANDFILL(LF 024) - SITE INVESTIGATION
SUMMARY OF ANALYTES DETECTED IN NEAR SURFACE SOIL
ANAI YMi
Organic Compounds:
Acetone
bis(2-Elnytnexyl)plilhalate
Inorganic Compounds:
Aluminum
Banum
Calcium
Chromium
Iron
Magnesium
Manganese
Mercury
Nickel
Potassium
Vanadium
Zinc
TBC
Values'
200
50.000
8.510 (SB)
300
30.200 (SB)
195 (SB)
36.200 (SB)
3.340 (SB)
474 (SB)
01
13
929 (SB)
150
634 (SB)
IRFQUt NCY
or
OETFCTION
2 / 3
3 / 3
3 / 3
3 / 3
3 / 3
3 / 3
3 / 3
3 / 3
3 / 3
1/1
1 / 3
1 / 3
3 / 3
3 / 3
I.FVELIII
nr iFCH-n
MINIMUM
CONCENTRATION
2
21
4715
41
1948
79
13200
1141
307
001
28 '
1160 '
143
88
m IHCTCD
MAXIMUM
CONCFNIRATION
6
42
6752
120
2467
107
15414
1853
2481
001
28 '
1160 '
242
137
All results reported in ug/kg for organic anatytes and in mg/Kg for inorganic analytes
NO - Not Detected
SB Soil background value Based on basewide background study (URS 1995)
Notes
- Unless otherwise noted. To Be Considered (TBC) values are NYSOEC Soil Cleanup Objectives and Cleanup Levels. TAGM
HWR-94 404S. January 1994 Site Background (SB) values for metals were used when less stringent than the regulatory value
Site Background was based on a basewide .background study (URS 1995)
- Fxceeds TBf. values
jl'l/f -it I n M'M'.4; WM1»-
-------
V- no
\
APPROXIMATE LMirS Of IF O?4
Y
LEGEND:
MONITORING WFI I
SURFACE WATCR/SmMF.NI SAMP) I
IPOSSBI F lEAOIATF IOCAIIONI
MM TEST PIT TREND)
~ IF>0 TOPOGRAPHIC CONTOUR
X X CXISTINC FENCE
FXCtfDANCE Or SOU CRITERIA
NO TtS
I All SAMPIES AND MSTAHATIONr.
i« '1 MAOC DURMr, MAICOLM PIRNIF
FALl. 199? INVCSTICADON PROGRAM
? SAMPIC Pf SUITS M o«/>.<)
FOR OHGAMC COMPOUNDS ANT)
mq/tq I OH INORr.ANKS
SC«I I 'IN IF.CI
LFO24 SITE INVESTIGATION
CHEMICALS DETECTED
NEAR SURFACE SO*. SAMPLES
URS
FIGURE A 2
-------
TABLE A-3
CONSTRUCTION SPOILS LANDFILL(LF-024) - SITE INVESTIGATION
SUMMARY OF ANALYTES DETECTED IN FILL SAMPLES TAKEN DURING TEST TRENCHING
ANALYTF
Acetone
Beraoic Acid
2 Methylnaphthalene
Acenaphlhytene
1 luorene
4 Nitroaniltne
Phenanthrene
Anthracene
Oi-n butytphthalate
Fluor ant hene
Pyrene
Benzo(a)anthracene
Chrysene
bis(2-EtovthCTyl)phlhalate
Benzo
-------
TABLE A-3 (confd)
CONSTRUCTION SPOILS LANDFILL(LF 024) - SITE INVESTIGATION
SUMMARY OF ANALYTES DETECTED IN FILL SAMPLES TAKEN DURING TEST TRENCHING
ANALY7E
Aluminum
Antimony
Aisenic
[taiium
Calcium
Chiomium
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Mercury
Nickel
Potassium
Selenium
Thallium
Vanadium
Zinc
Solids. Total (%W/W)
TBC
Values
8510 (SB)
126 (SB)
75
300
30200 (SB)
195 (SB)
30
441 (SB)
36700 (SB)
794 (SB,
3340 (SB)
474 (SB)
0.1
13
929 (SB)
2
ND (SB)
150
634 (SB)
FREQUENCY
OF
DETECTION
6 / 6
0 / 6
0 / 6
2 / 6
6 / 6
6 / 6
0 / 6
3 / 6
6 / 6
1 / 6
5 / 6
5 1 6
0 / 6
2 / 6
3 / 6
0 / 6
0 / 6
5 / 6
6 / 6
NA
LEVEL III
DflECiri)
MINIMUM
CONCENTRATION
2847
ND
ND
43
1344
36
ND
36
4670
33
752
50
NO
66
691
ND
ND
68
57
NA
Df-.TFCTFI)
MAXIMUM
CONCENTRATION
0103
ND
ND
210
10213
99
ND
6
27295
33
5459 '
5455 '
ND
86
1043
ND
ND
181
22
NA
FREQUENCY
OF
DETECTION
2 / 2
1 / 2
1 / 2
2 / 2
2 / 2
2 / 2
2 / 2
0 / 2
2 / 2
2 / 2
2 / 2
2 / 2
1 / 2
1 / 2
1 / 2
2 / 2
1 / 2
0 / 2
2 / 2
2 / 2
IFVFt IV
nF.IFCI'EO
MINIMUM
CONCENTRATION
2530
154
3
11 4
1180
43
19
ND
6730
23
667
651
017 *
017
57
299 '
104
ND
104
73
DETICKO
MAXIMUM
CONCENTRATION
40GO
154
3
344
6620
7
52
ND
21500 '
28
3870 *
201
017 '
017
57
655 '
104
ND
14
167
All results repotted In mg/kg
ND Not Detected
NA - Not Analyzed
SB - Soil background value
Notes
' - Unless otherwise noted. To Be Considered (TBC) values are NYSDEC Soil Cleanup Ohfectives and Cleanup Levels. TAGM
MWR 94-4046. January 1094 Srte Background (SB) values for metals were used when less stringent than the regulatory value
Site Background was based on a basewide background study (URS 1995)
' Exceeds TBC values
-------
NV
V'H>
i>.
<»' 1
a,
(. ii
bj.
K. O
160
X X
LEGEND:
MONITORING WEI I
SURFACE WATER/SEDIMENT SAMPI (
(POSSIBLE IfACMATE LOCATION)
TEST PIT TRENCH
- TOPOGRAPMC CONTOUR
EXISTING FENCE
L...L>J EXCEfOANCE OF SO*. CRITFRIA
NOTES
I ALL SAMPLES AND INSTALLATION1;
MADE PORING MALCOLM PWWE
FALL. 199? INVESTIGATION PROGRAM
7 SAMPLE RFSUITS M ug/kg
FOR ORGANIC COMPOUNDS ANO
nig/kg FOR INORGANICS
scAir IN FEET
LFO24 SITE INVESTIGATION
CHEMICALS DC TEC TED
M FILL SAMPLES
URS
FIGURE A-3
-------
TABLE A-4
CONSTRUCTION SPOILS LANDFILL(LF-024) - SITE INVESTIGATION
SUMMARY OF ANALYTES DETECTED IN SUBSURFACE SOIL SAMPLES FROM BORINGS
ANAIYTE
Organic Compounds:
AcHone
Di-ii butytphlhalale
1 luoianthene
1 'yi one
his(? Ethylheayljphlhalate
Inorganics (metals):
Aluminum
Barium
Calcium
Chromium
Cobalt
Iron
Lead
Magnesium
Manganese
Nickel
Potassium
Sodium
Vanadium
/.me
me
V.ilues*
200
8.100
SO.OOO
50.000
r>o.ooo
8.510 (SB)
300
30.200 (SB)
195 (SB)
300
35.700 (SB)
794 (SB)
3.340 (SB)
474 (SB)
13
929 (SB)
520 (SB)
150
634 (SB)
FRFQUFNCY
OF
DETECTION
1 / 2
2 / 2
1 / 2
1 / 2
2 1 2
2 / 2
0 / 2
1 / 2
2 / 2
ND
2 / 2
ND
ND
2 / 2
ND
ND
ND
1 / 2
2 / 2
LEVFI III
DETF.CTFO
MINIMUM
CONCENTRATION
5
9
16
16
110
2723
ND
1228
32
ND
3813
ND
ND
52
ND
ND
ND
168
81
DETECTED
MAXIMUM
CONCENTRATION
5
14
16
16
140
7151
ND
1228
94
ND
10250
ND
ND
91
ND
NO
ND
168
11 9
FREQUENCY
OF
DETECTION
1 /
0 /
0 /
0 /
0 /
/
/
/
/
/
/
/
/
/
/
/
/
/
1 /
LEVEL IV
DETECTED
MINIMUM
CONCENTRATION
11
ND
ND
ND
ND
3090
168
955
5.2
16
6540
26
732
624
52
424
106
97
99
DETECT! n
MAXIMUM
CONCENTRATION
11
ND
ND
ND
ND
3090
168
955
52
16
6540
26
732
624
52
424
106
97
99
All organic results reported in pg/kg All inorganic results reported rn mg/kg
ND Not Dptpr.led
r.p Soil background value Based on basewide background study (URS 1995)
Notn?;
- (intess otherwise noted. To Be Considered (TBC) values are NYSDEC Soil Cleanup Objectives and Cleanup Levels. T AGM
I IWR-n-l -10'tO. January 1994 Site Background (SB) values for metals were used when less strinqonl lhan the regulatory value
'.ile BacHqmiinrf was based on a b.ispwide background study (URS 1995)
I Me listed I PC value for organirs is Ilir most Mrmgent regulatory value
l I n.'4''".M *ll
-------
\
X..
Y
c
APPROKIMATC IIMITS OF IF 0?4
LEGtNO:
MONUORINK WFI I
WAFrR/stDAirNi SAMPI F
r iiarnaic loiflnom
TfSI PI1 IRfNCM
- tOPOKRAPHIf CONIOUR
tXISTING FTNCI
I ALL ; A writs ANO MSIAI I AIION'.
MADC DtHilNO MAI COIU PIIINIF
FALI. I19? INVfMIGATION PnnRRAM
? SAMPI I Rf Silt IS M ug/kq
I OR Oltr.ANK. cnMPQUNDS AND
mq/ko | OR MOnr.AMICS
^ NO I xr.f fftAN'I S OF ^Mll
rniiFiiiA rn ii i it n
.I Al F IN I FF I
IF024 SITE INVESTIGATION
CHEMICALS OETECTfO
IN SUBSURFACE SOIL SAMPLES
URS I FIGURE A.4
f ..>,' I * tat- *' I
-------
TABLE A-5
CONSTRUCTION SPOILS LANDFILL(LF-024) - SITE INVESTIGATION
SUMMARY OF ANALYTES DETECTED IN GROUNDWATER
(UNFILTERED SAMPLES)
ANM tir.
Organic Compounds:
MelhyteneClilonde
2-Mrthytptipnnl
bis( :>-E thyllii-xyl )phlhalale
Inorganics (motals):
Aluminum
Antimony
Arsenic
Barium
BetylKum
Calcium
Chromium
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Mercury
Nickel
Potassium
Sodium
Thallium
Vanadium
Zinc
Cyanide
AI'AR
V.ilues'
T>
1
50
3
?5
1.000
3
-
50
200
300
15 "
35.000
300
2
--
1 20.000
4
-
300
100
mrourNCY
or
or TEC HON
4 / 4
1 1 4
1 1 4
3 / 4
1 / 4
1 / 4
4 / 4
3 / 4
4 / 4
3 / 4
3 / 4
3 / 4
4 / 4
3 1 4
4 / 4
4 / 4
1 1 4
3 / 4
4 / 4
4 / 4
2 / 4
3 / 4
3 / 4
2 / 4
IFVfl IV
m H c 1 1 n
MINIMUM
CONCF.NI RATION
3
NO
NO
999
Nl)
ND
44
ND
16600
ND
ND
ND
1530 '
NO
3990
37
ND
ND
1880
1700
ND
ND
ND
ND
ni ir.cun
MAXIMUM
CONCrNIRAIION
J
T »
1
109000
876 '
51
1790 '
103
247000
33B *
975
709
250000 '
859 '
65600 '
15100
071
232
19500
31300
93
189
2770
80
All results reported in ug/l
Notes
Unless otherwise noted, the ARAR values are NYSDEC Water Quality Standards and Guidance Values. TOGS 111. October 1993
The listed ARAR value is the most stringent regulatory value Minimum concentrations and non-dotects were reported from the upgtadwnt well
* F.PA Dunking Water Standards 40 CfR 141
NP - No Optfflion
K A PAR value
-------
LEGEND
MO*TORINO «rri t
pROPosro POST r.i OSIWE
MOM I OPING Will I OCA IION
SimraCE WATCR/StCVMCNI SAMPLf
IPOSSIBIE Lt«CHAIt UOf.AtlONI
TEST PIT IRfNCH
TOPOCRAPMIC CONTOUR
CXISTMG FtNCC
cxcceoANcc or GHOUHO*«IFR CRITERIA
OIRECTIOM or OROUNOWATER FLOW
NOTES
I ALL SAMPLES AMD INSTALLAIIONS
MADE DUPING MALCOLM PWME
TALL. 199? INVESIir.ATIQN PRnnRAM
? ALL RESULTS IN ug/L
LF024 SITE INVESTIGATION
CHEMICALS Oe TEC TED
IN GROUND*ATER SAMPLES
URS
FIGURE A 5
-------
APPENDIX B
HUMAN HEALTH RISK - TOXICITY VALUES
J:\3SM1WT LPOU.ROD/aOniXcpXmm)
-------
TABLE B l
CONSTRUCTION SPOILS LANDFILL(LF-024) - HEALTH RISK ASSESSMENT
TOXICITY VALUES: POTENTIAL CARCINOGENIC EFFECTS
Chemical
2 Melhylphenol
Benzo(a)pyrene
Ben/o(a)anthracene
Chrysena
Benzo(b)fluoranthene
Benzo
-------
TABLE 82
CONSTRUCTION SPOILS LANDFILL(IF-024) - HEALTH RISK ASSESSMENT
TOXICITY VALUES: POTENTIAL NONCARCINOGENIC EFFECTS
rherncal
A. wiapntiiriene
At clone
AnMacene
6enlOK Ar.rt
Bento(a)an*e«cene
B«n»o<»)pyi«na
Beniolbinuorarthene
Benio(k)nuorant>ene
Benrofg h ilperytene
b.«2 CViylwifOpMluM*
28Mtanone
BulyejeruylpMMMe
Clm/sene
DwfltylaMhalele
Qi n-bmjrM*ieiele
Fluarenlfiene
Fborene
ideno(l.?.^cd^PfTerie
Mffiylene CMonde
2 UetirtoapNMene
2Uet.y»*enol
NuiNhetiie
Neroeflrhne
PheoeneVene
Pyrene
Reference note (mgftg day I
Subchranic
MhaMan
RID
NO
NO
NO
NO
NO
NO
NO
NO
NO
57IEOJ
266E-01
NO
NO
NO
NO
NO
NO
NO
IS7E-01
NO
NO
I.16E-M
NO
NO
NO
Of*
RID
NO
inoc«ao
jooe-oo
4ooE*ao
NO
NO
NO
NO
NO
200607-
2006*00
200E«00
NO
IOOEHM
1006*00
400601
400E-Ot
NO
OOE-02
NO
S 006 4)1
400E«2*
JOOE-03-
NO
J 006 01
Chrarac
MuMim
mrt
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
2 ME -01
NO
NO
NO
NO
NO
NO
NO
eS7£-OI
NO
NO
NO
NO
NO
NO
Or«
MD
NO
IOOE-01
100EOI
400E<00
NO
NO
NO
NO
NO
7 OOE-02
« 006-01
2006-01
NO
006-01
1. ODE -01
4 OOE-02
4 ODE -02
NO
OOF -.2
NO
5006-02
4 OOE-02
300E-03
NO
J 006 -02
cmcai r nedis)
Subchronc
ln»>»Wioo
-
Ptrtdt. *rtrirmpl>«lo>v
tflMU
OtcraiMd t*r «l.
UwtaMy
Null Marts
-
Dial
btc Wei tlndneywl .
ncphraloiioly
No obwrved effects
Nootnecvedeflecls
-
-
Ine Iweto)
OeerMMtfbrlxM
AMradkMi*!
OwruMd grovrth ma )
Inc mortaMy
dungt*
DrcrMMd rad btoatf cats
LlMrloiidly
Dee ) grin. iMwotoiloty
Reduced MM
-------
TABLE B-2
CONSTRUCTION SPOILS LANOFILL(LF-024) HEALTH RISK ASSESSMENT
TOXKITY VALUES: POTENTIAL NONCARCINOGENIC EFFECTS
< h~avcal
AnlMihmr
Alien*
Bjutum
HMyHum
O«.im«jnXI1l>
ChionMunKVI)
Cnball
damda
Irad
Manoanc^UMMi)
Mangancu- (taodi
Mooirv
Nckct
SHenium
Thaaun
Vanadum
7.ic
Rffef encr 1 >nt» (mo/kg day)
Sut» Krone
mhaWBn
Rin
NO
NO
NO
NO
NO
NO
S Til W
NO
NO
NO
I43t OS*
8S7E4S
NO
NO
NO
NO
NO
<>00
SOOE-O)
NO
2 ODE 01
NO
240C-02
I40£-0t
NO
200E-O}
S ODE 03
NO
7 DOE -03
300EOI
CKitaTirmdi
Sutvtiionic
InltaUInn
F«Mh»Ke»u>e
No ariMf M «mdl
No Hteoh objerMd
No e*edi obttfwd
VM tou. mrrtni><>(»Bne«ation
CNSXtaeti
CNSeflKtl
O«c body and of gan frt
Cknical Mtonota
NOfM OlKWMl
Oeoeaied blood wuym*
ClwoniC
IntialalKxi
~
fetoloiK
IRIS 11/96
IRIS 11/96
IRIS H/96
HEASTFYtt
IRIS 1lr96
HEASI-FY9S
EPA REG H
IRIS 1 f96
_
IRIS 11(98
MIS-II'W
-.
IRIS 11/96
IRIS 1 1/96
NO No Data
rCAO EmtranmenlalC'M'Mand AstMsmamOfKe Oala ndieam date °» ca«i«spondenc«
IHIS ImegjaMd Risk Monnalkin Sinlam Dale mfccatoi access to IRIS
MtASI ilaa*iFfl*cii Aimsmanl Summary lat>ir< Dale ndcalts » fiscal yaai irwy v*re puoMwd
C.hionc raaxanre dos«> «ara uwd ahcn iubrhi
-------
APPENDIX C
DECLARATION OF CONCURRENCE
-------
John P. Cihill
Acting Commissioner
New York State Department Of Environmental Conservation
50 Wolf Road, Albany, New York 12233-7010
Mr. Thomas W. L. McCall, Jr.
Deputy Assistant Secretary of the Air Force
SAF/ MI
1660 Air Force, Pentagon
Washington, DC 20331-1660
Dear Mr. McCall:
Re: Record of Decision - Landfill 024
Pittsburgh Air Force Base, ID No. 510003
In response to the Record of Decision (ROD) for Landfill 024 (LF 024) submitted and signed by
yourself. I wish to concur with the remedial action plan as put forth in the ROD. This remedy includes:
- A 12-inch thick cover over the landfill consisting of a 9-inch borrow layer, a 3-inch topsoil
layer and a vegetative cover.
- Deed restrictions to prevent any adverse action leading to the deterioration of the landfill cap,
to prohibit the installation of any wells for drinking water or any other purpose which could
result in the use of the underlying groundwater and to prohibit the excavation of the landfill
cap without prior approval of the New York State Department of Conservation. Restrictions
will also be imposed to limit development of any structure on the landfill site which would
adversely effect human health and safety.
- Establishment of a groundwater monitoring system.
- Conducting five-year site reviews.
if you have any questions please contact Mr. Lister at (518)457-3976.
Sincerely,
t
. ' . ..<*:.- ' .
c: J. Fox. USEPA-Region II
A. Lowas
M. Sorel, PAFB
Michael J. OToole, Jr.
Director
Division of Environmental Remediation
-------
APPENDIX D
PUBLIC MEETING TRANSCRIPTS
1:05291 >wp .LFO24. RODnaOmMcpMflim)
02-J4-9?:1I.12
-------
1 PUBLIC HEARING FOR REMEDIAL ACTIONS AT FORMER
2 LANDFILL LF-021 AND FORMER LANDFILL LF-024
3 JANUARY 16, 1997
4 OLD COURTHOUSE, 133 MARGARET STREET, 2ND FLOOR
5 PLATTSBURGH, NEW YORK.
6 This proceeding was stenographically reported by Susan
7 Bretschneider, Certified Shorthand Reporter, and
8 commenced at 7:00 p.m. at the above-mentioned location.
9
10 MR. SOREL: Okay, I guess we'll go ahead and
11 get started. This is the public meeting for Landfill 21
12 and Landfill 24. I'd like to begin the public meeting
13 for the remedial actions at the Former Landfill LF-21
14 and LF-24. For those who don't know me, I'm Mike Screl,
15 the BRAC Environmental Coordinator working for the Air
j
16 Force Base Conversion Agency at Plattsburgh. I will be
17 presiding over the meeting, the main purpose of which is
18 to allow the public the opportunity to comment on the
19 Air Force's action for this site.
«.0 Assisting me tonight in this presentation are
21 the following people: Steve Gagnier, the project
22 manager for these actions, and Brady Baker, the project
23 engineer, both with the Air Force Base Conversion
24 Agency, and Bruce Przybyl, the project manager with UR£
25 Greiner. These individuals are here to provide answers
CAPITOL COURT REPORTERS - (802) 863-6067
-------
1 to technical questions you might have about the
2 alternatives available to the Air Force for cleaning up
3 the site.
4 Tonight's agenda will consist of a description
5 of the remedial action and an explanation of how it will
6 ' improve the environment. After that, we will move to
7 the most important part of this meeting, the part where
8 you provide your comments on the remedial action.
9 First, however, I would like to take care of
10 several administrative details.
11 - As you can see, everything being said here
12 tonight is being taken down word for word by a
13 professional court reporter. The transcript will become
14 part of the administrative record for the sites.
15 We would like everyone to complete the sign-in
16 sheet at the door. We will use the sheet to review our
17 mailing list for the site.
18 At the conclusion of the presentation, we will
19 open the floor up to comments and questions. I would
20 ask that you hold your questions until the presentation
21 for both sides is complete. If you have a prepared
22 statement, you may read it out loud or turn it in
23 without reading it. In any case, your comments will
24 become part of the record. Also, we have cards at the
25 front, desk for your use for any written comments. If
CAPITOL COURT REPORTERS - (802) .863-6067
-------
1 you turn in any written comments, please write your name
2 and address on them.
3 If you later decide to make comment or add
4 something that you said here, you may send additional
5 comments to us at this address. The public comment
6 period ends today on Landfill 21 and on February 6th for
7 Landfill 24. I will show this address slide again at
8 the end of the meeting.
9 The final point is that our primary purpose
10 . tonight is to listen to you. We want to hear your
11 comments on any issues you are concerned about at these
12 sites, and we will try to answer any questions you may
13 have. We want you to be satisfied with the action we
14 take will properly address and fully address the
15 problems at this site.
16 Now, I would like to turn the meeting over to
17 Bruce Przybyl.
18 MR. PRZYBYL: Good evening. We'd like to talk
IS to you today about the Air Force's recommended
20 alternatives for remedial action at two landfills at the
21 Plattsburgh Air Force Base. The first I'd like to talk
22 about is Landfill 21. Landfill 21 is located in the
23 northwest corner of the base outside the perimeter fence
24 and north of Route 22. The area is designated as open
25 space for land use planning.
CAPITOL COURT REPORTERS - (802) 863-6067
-------
1 I would first like to go through the process
2 by which the decisions were made in reaching the
3 conclusions in coming to the recommended alternative.
4 The process started by preparation of a
5 preliminary assessment or records search which looked at
6 the history of the site and the disposal practice of the
7 site. At that time, a recommendation was made, further
8 investigation was necessary, a site investigation was
9 undertaken.
10' The site investigation showed it is a
11 relatively small site, and the conclusions of that were
12 to recommend a larger scale investigation, a remedial
13 investigation.
14 The. remedial investigation assessed health
15 (sic) to human health --to humans and the environment
16 in addition to collection of many samples. From that a
17 preferred alternative was determined and documented in a
\
18 proposed plan which is available at the Feinberg Library
19 and has been for a period of time.
20 Throughout this period, the New York State
21 Department of Environmental Conservation and United
22 States Environmental Protection Agency have provided
23 review and comment to each document along the way and
24 have concurred in principle with the remedial
25 alternative.
CAPITOL COURT REPORTERS - (802) 863-60S7
-------
1 We are at this stage, the public meeting and
2 comment, and we're here to answer your questions and
3 incorporate your comments into the record of decision
4 which is the legal instrument for the remediation.
5 The Landfill 21 is about six acres in size.
6 It was active from 1956 to 1959. It accepted domestic
7 waste and sludge from the industrial wastewater
8 treatment plant at the base. The other area is adjacent
9 to some wetland areas and is located 500 feet from the
10 Saranac River.
11 The character of the site is generally --
12 currently generally vegetative with mature trees and
13 grasses covering the site, but there is locations where
14 debris is protruding from the landfill surface. One
15 such location is depicted in the lower of the two
16 photographs.
17 The remedial investigation included the
18 excavation of many test trenches to determine the extent
19 of the fill and to sample the subsurface materials and
20 fill, b-xring, well installation and groundwater
21 sampling.
22 A variety of chemicals were detected in
23 : subsurface soil or fill materials. Polycyclic aromatic
24 hydrocarbons were detected. These were the products of
25 incomplete combustion of fossil fuels, metals.
CAPITOL COURT REPORTERS - (802) 863-60-67
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I :
1 Pesticides such as DDT and PCBs were also detected.
2 These were not detected in any particular pattern. The
3 pattern of contamination is somewhat heterogenous in the
4 landfill.
5 In groundwater, only three compounds were
6 detected that exceeded the New York State standards, and
7 those were two polycyclic aromatic hydrocarbons and
8 DDT. It was worthy to note that there was an absence of
9 volatiles, which are quickly moving compounds, in
10 groundwater. There were none of those compounds.
11 We also examined contaminant migration
12 pathways at the site. Since few volatiles were found,
13 we consider the volatilization pathway for contaminant
14 migration is insignificant.
15 In addition, since the site is vegetated,
16 there's a limited potential for dust generation and,
17 therefore, we considered contaminant transport via dust
18 pathway as insignificant.
19 Also, we consider run-off pathways to be
20 negligible because of the high permeability of the
21 landfill. Most of the precipitation will infiltrate
22 into the landfill and, also, topographic constraints --
23 and actually the overhead here we have is somewhat
24 misleading, this slope somewhat kind of rises again
25 before it drops again into the Saranac River. All of
CAPITOL COURT REPORTERS - (802) 863-6067
-------
l the precipitation will infiltrate into the ground before
2 it gets to the river.
3 One pathway that is potentially significant is
4 the percolation of rainwater through the landfill
5 picking up contaminants along the way and then transport
6 through the groundwater.
7 Again, the contaminants detected in
8 groundwater were of the type that do not move very
9 quickly or very far in groundwater.
10 We conducted a human health risk assessment to
11 determine the potential risk to human health posed by
12 the site, and that was broken down into two scenarios,
13 including a current use scenario in which we assessed
14 potential impacts to utility workers -- there was a
15 right-of-way, utility right-of-way adjacent to the site
16 -- and also to trespassers.
17 The calculations indicated no significant
18 carcinogenic or noncarcinogenic risk to these potential
x
19 receptors.
20 The second scenario was a future use scenario
21 in which we assessed the risk to a campground populated
22 by campers who were utilizing the groundwater for
23 showering and potable water, camping right on the
24 landfill. We considered this to be a conservative
25 hypothetical scenario. It's not something that's
CAPITOL COURT REPORTERS - (802) 863-6067
-------
I ;
1 envisioned; however, this is a conservative benchmark ij
2 which we can assess t'he potential of contaminant risk.
3 The future use scenario yielded no
4 noncarcinogenic risk to campers; however, there was a
5 significant risk represented by this five times 10 to
6 the minus four due to exposure to soils on the
7 landfill. This is a carcinogenic risk.
8 It's significant to note that there was no
9 risk calculated -- or no significant risk calculated for
10 groundwater ingestion pathways despite the fact that
11 three New York State standards were exceeded. They were
12 exceeded but not to a great extent, enough to yield
13 risks in our calculations.
14 It also should be noted we performed an
15 ecological risk assessment and determined a potential --
16 potentially a slight potential risk to mammals that come
.17 into contact with the soil and fill of the landfill.
18 Based on the risk assessment, we came up with a
19 remediation or remedial goal to the site.
20 The goal is to prevent direct contact with
21 on-site soil, fill materials by human or ecological
22 receptors basically as a response to the carcinogenic
23 risk calculated in the risk assessment and the minor
24 ecological risk that was indicated in the ecological
25 risk assessment.
CAPITOL COURT REPORTERS - (802) 863-6067
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1 Using the U.S. EPA Superfund Accelerated
2 Cleanup Model, we then developed the basic components of
3 our remedial alternative. And these include a landfill
4 cap and institutional controls. There were three types
5 of landfill caps looked at, and they were examined for
6 their ability to achieve the goal that we set for
7 this -- this remediation, and all three of these
8 landfill caps accomplish the goal adequately.
9 Therefore, we looked at cost and picked the
10 most cost effective cap, which is a native soil cover as
11 our selected remedial component.
12 Also, a basic component remedy is
13 institutional controls in which we propose site
14 development restrictions to protect the integrity of the
15 cap once it's established and also to restrict water
16 use, although that's not one of -- it's not reflected in
17 our goal, there are three exceedances of New York State
18 Groundwater Quality Criteria and then, therefore, we
19 thought it would be prudent to restrict the use of the
20 groundwater.
21 Therefore, our remedial alternative includes
22 the following elements: A native soil cover to prevent
23 direct contact of human and ecological receptors with
24 contaminated soil and fill materials and development
25 restrictions which include restrictions to prevent any
CAPITOL COURT REPORTERS - (802) 863-6067
-------
l adverse action leading to the deterioration of the
2 landfill cover and prohibition against any excavation of
3 the landfill cover without prior appropriate approvals,
4 and this will be implemented to protect the integrity of
5 the cap over the long term.
6 We are also going to prohibit the installation
7 of any wells for drinking or any other purposes which
8 could result in the use of the underlying groundwater.
9 And this is in response to the exceedances of New York
10 State Groundwater Quality Criteria in groundwater.
11 We are also -- two other elements of the
12 remedy that are necessary, one is groundwater
13 monitoring. We'll supplement our existing groundwater
14 monitoring network and sample it routinely in order to
15 ensure that the slow-moving compounds that we have
16 detected will not migrate off site. We don't expect
17 them to, but the routine groundwater monitoring will
18 ensure that that will not happen in the future.
19 And, finally, there's a five year site review
20 process in which the Air Force, the United States
21 Environmental Protection Agency and the New York State
22 Department of Environmental Conservation will review all
23 the data collected throughout the five years and ensure
24 that the remediation is being effective in protecting
25 human health and the environment.
CAPITOL COURT REPORTERS - (802) 863-6067
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11
1 The second landfill I am going to talk about
2 today is the construction spoils landfill or Landfill
3 LF-24. This landfill is located to the --in the
4 southeast corner of the base about 200 feet north of the
5 Salmon River as indicated on this figure right here.
6 This area has been designated as open space for light
7 industrial use for land use planning purposes, either
8 or.
9 Once again, I'm showing an overhead showing
10 the process by which we reached our remedial
11 alternative, and it's similar to that for LF-.21 in which
12 we are soliciting public comments at this time, and
13 we've received New York State Department of
14 Environmental Conservation input and United States
15 Environmental Protection Agency input along the way and,
16 again, comments received today will be incorporated into
17 the record of decision.
18 Landfill 24 is less than one acre in size and
19 accepted construction and demolition debris, concrete
20 rebar, things of that nature, metals, from the period of
21 1980 to 1986. The landfill is covered generally with
22 brush and trees. There are very few sparse areas. One
23 of them is indicated in the lower of the two photographs
24 here but generally well covered with brush and trees.
25 To the south near the toe of the slope, the landfill
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~ - - - '
l steepens considerably, and construction and demolition
2 debris is protruding from the landfill cover as
3 indicated by the lower of the two photographs.
4 The upper photograph is the top of the slope,
5 southern slope, and the lower photograph depicts the toe
6 of the slope, the southern slope. The Air Force
7 considers this to be a general physical hazard to
8 trespassers and people walking in this area.
9 The landfill was investigated and site
10 investigation in which test trenching was conducted to
11 determine the extent of the fill and determine its
12 character. We also did boring and monitoring wells and
13 looked at groundwater samples.
14 The nature of the fill material is essentially
15 free of organic contaminants; however, metals were
16 elevated above background in the fill materials.
17 Again, groundwater was examined, and it was
18 also found to be essentially free of organic materials,
19 organic contaminants; however, several metals were
20 detected in exceedance of New York State Groundwater
21 Quality Criteria.
22 I also should note that there were several
23 drums found during test trenches at the site; however,
24 none of these drums were found to be intact, many of
25 them had no lids, we're empty or just crushed prior to
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1 being in the landfill.
2 We also looked at the potential contaminant
3 migration pathways. And very similar to LF-21, there
4 were no volatiles found and, therefore, the
5 volatilization pathway was considered insignificant.
6 Since the landfill is heavily vegetated, there
7 is limited potential for dust migration and
8 contamination transport through that mechanism. Also,
9 once again, this doesn't quite depict the slope
10 correctly. It's much flatter there, and the run-off
11 pathways are also considered to be insignificant. All
12 of the rainfall will percolate into the landfill surface
13 or be captured by topographic constraints and not reach
14 the Salmon River directly.
15 However, again, we -- we have a potentially
16 significant groundwater migration pathway, again, where
17 rainwater percolates through the fill, picks up metal
18 contaminants and transports them through the
19 groundwater. And it should be noted again that the
20 metal contaminants are also very slow-m->ving compounds.
21 Again, we conducted a human health risk
22 assessment to determine potential risk to the receptors,
23 and two scenarios were examined including current use
24 scenario, which is basically no one is being exposed at
25 the site except for trespassers, and the assessment
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1 indicated no potential for carcinogenic risk,
2 unacceptable carcinogenic risk or unacceptable
3 noncarcinogenic risk.
4 A future use scenario was also examined. It
5 was a bi-phased scenario in which the site would
6 hypothetically be developed, and there would be a
7 construction phase in which excavation would occur and
8 building would be constructed, and then a second phase
9 in which the buildings were already constructed and the
10 area were landscaped and the industrial workers were
11 using the facility routinely.
12 There were no unacceptable cancer risks
13 indicated by the analysis. However, there were
14 unacceptable noncarcinogenic risks indicated for
15 inhalation of fugitive dust to construction workers.
16 During construction there's considerable dust excavated,
17 and there's a potential for exposure and adverse effects
18 to these construction workers through inhalation of the
19 fugitive dust with manganese adhered to it. Also, if
20 groundwater were to be used at the site, there is a
21 potential for adverse effects again from the compound
22 manganese, and there is also potential for future
23 problems from barium, vanadium and antimony.
24 One thing to note is that currently there is
25 no risk to receptors via carcinogenic or noncarcinogenic
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1 risk; however, there is a physical hazard posed by
2 protruding debris along the steep southern slope and a
3 couple other places in the landfill.
4 Based on the HRA, we determined some
5 remediation goals. The first is to prevent construction
6 workers from inhaling contaminated fugitive dust
7 resulting from earth moving activities, and that's in
8 response to the risk calculated for the inhalation of
9 fugitive dust.
10 Second would be to prevent human ingestion of
11 contaminated groundwater immediately down gradient of
12 the site, and that's in response to the risk calculated
13 for the ingestion of groundwater.
14 And, third, we would like to eliminate
15 potential physical hazards to on-site workers and
16 maintenance personnel.
17 Again, using U.S. EPA guidance, we determined
18 the basic components of a remedy for the site. The
19 landfill cap is necessary to -- to accomplish the third
20 goal, and that is to eliminate potential physical
21 hazards on site. There is no -- there is no potential
22 chemical hazards due to direct contact with the fill.
23 So the cap is only to eliminate the physical hazards.
24 Therefore, all three caps -- since the area
r
25 will be regraded and debris covered and the potentially
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1 unstable slopes eliminated, all three caps will be
2 equally effective and cost is, therefore, looked ac as
3 the deciding factor between the caps, and we selected
4 the least expensive of the three options, and that is a
5 native soil cover.
6 Second we -- the -- the second basic component
7 is institutional controls which includes site
8 development restrictions, and that is to protect the
9 integrity of the cap, water use restrictions to address
10 our second remediation goal which is to prevent human .
11 ingestion of contaminated groundwater and, third, a
12 cautionary notice concerning inhalation risks during
13 earth moving activities, and that is to address our
14 first remediation goals, to prevent construction workers
15 from inhaling fugitive dust.
16 To recap, our recommended alternative consists
17 of the native soil cap, to limit -- eliminate potential
18 physical hazards from debris and also develop
19 restrictions including restrictions to prevent any
20 adverse action leading to the deterioration of the cap,
21 prohibition against excavation of the landfill without
22 prior appropriate approval and prohibition from
23 installing any wells that could result in the use of the
24 underlying groundwater.
25 Also, we are going to issue a notice
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1 concerning potential site risk which is a notice
2 provided concerning potential short-term health risks
3 from inhaling dust during construction activities.
4 Also, groundwater monitoring is a part of that. Also,
5 metals in groundwater will move very slowly and will not
6 get very far. We want to install a groundwater
7 monitoring network to track that through time and make
8 sure that the groundwater contaminants are not getting
9 far off site and, also, in LF-21, it will be reviewed
10 every five years by the U.S. EPA and the New York State
11 Department of Environmental Conservation and the Air
12 Force to determine whether it has continued to be
13 effective, and that concludes my discussion.
14 MR. SOREL: At this time, I'd like to open up
15 the meeting for questions. Since everything that is
16 being said here tonight is being taken down, please
17 state your name for the record before you make a
18 statement.
19 Do we have any questions? Mr. Booth?
20 MR. BOOTH: Robert Booth. In each of your
21 sites, we reach a conclusion about where you are headed
22 next with a list of prohibitions, for instance, to
23 prevent activities that would destroy the cap, prevent
24 the drilling of wells that would tap groundwater,
25 prevent excavation without a permit. Who or what sees
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1 that these limitations are carried out, who gives the
2 permit to excavate, how long is this oversight as to
3 permits and prohibitions to continue, who's got the
4 responsibility?
5 MR. SOREL: Good question. It's actually one
6 that's come up in our discussions with the regulator
7 that they have the very same concerns that you do.
8 There will be a transfer by deed, and when we
9 start talking about transfer by deed, what we are going
10 to do, in fact, if you look in the proposed plan,
11 there's a paragraph in there that deals with that, and '
12 let me read what we put in there. It says: The deed
13 will include appropriate restrictions to prevent any
14 adverse action leading to the deterioration of the
15 landfill cap to include prohibition from installing any
16 wells for drinking water or any other purpose which
17 could result in use of the underlying groundwater and
18 the prohibition against any excavation of the landfill .
19 cap without prior approval of the New York State DEC.
20 So, essentially, we are saying at that point
21 there will indeed be restrictions and, of course, the
22 Air Force at that point would no longer be the owner of
23 the property, so some of that will rely on the -- the
24 local agencies having jurisdiction in that area.
25 For instance, if we are in the town of
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1 Plattsburgh, then I would assume if there were
2 construction, there would be issues of the building
3 permit and at that time, those prohibitions would be
4 noted. So through that process, we believe that that's
5 how these prohibitions would be controlled.
6 MR. BOOTH: That makes sense that there would
7 be public records that follow the land that way and will
8 the restrictions mention that DEC is a reference point?
9 MR. SOREL: Correct. In fact, we have already
10 coordinated that with them. They have agreed to be that
11 reference point.
12 MR. BOOTH: And that also if interested, why,
13 the township or the city or the county also could step
14 in, but at least there's a list of restrictions and
15 restrictive covenants really?
16 MR. SOREL: Right, right.
17 MR. BOOTH: And who to refer to to start
18 complying or finding out the answers?
19 MR. SOREL: And there would also be a notice
20 of any hazardous materials present that would follow
21 this as well, so anybody that would be issuing that
22 building permit or whatever.
23 MR. BOOTH: In 25 years, that will all be
24 forgotten, and I was just wondering.
25 MR. SOREL: We will file a deed.
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1 MR. BOOTH: And you have got it if there are
2 recorded documents.
3 MR. SOREL: Sure.
4 MR. BOOTH: Thank you.
5 MR. SOREL: Any other questions?
6 Okay, since everybody seems to have made their
7 . comments, we would like to conclude this meeting.
8 I would like to add that the proposed plans
9 and other documents relating to these sites are
10 available for review at the information repository
11 located in Special Collections at the Feinberg Library,
12 SUNY-Plattsburgh.
13 Thank you very much for coming.
14 (This hearing was concluded at 7:37 p.m.)
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1 CERTIFICATE
2
3 STATE OF VERMONT )
4 COUNTY OF CALEDONIA )
5 I, Susan BretSchneider, a Notary Public within and
6 for the State of Vermont, do hereby certify that I
7 stenographically reported the proceedings of the public
8 hearing in re: Remedial Actions at Former Landfill LF-21
9 and Former Landfill LF-24 on January 16, 1997 beginning
10 at 7:00 p.m., at the Old Courthouse, 133 Margaret
11 Street, 2nd Floor, Plattsburgh, New York.
12 I further certify that the foregoing proceeding was
13 taken by me stenographically and thereafter reduced to
14 typewriting, and the foregoing 20 pages are a full, true
15 and correct transcription of the proceedings.
16 I further certify that I am not related to any of
17 the parties thereto and that I am in no way interested
18 in the outcome of said proceedings.
19 Dated at Barre, Vermont, this 23rd day of January,
20 1997. My commission expires February 10, 1999.
21
22
23
24 SUSAN BRETSCHNEIDER, Notary Public
25
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ERRATA SHEET
TO: Marcia G. Wolosz
DATE: February 14, 1997
RE: 1-16-96 Public Hearing
FROM: Capitol Court Reporters, P.O. Box 329,
Burlington, Vermont 05402
Please read through the enclosed transcript. If you
wish to make any corrections, please do so below
referring to page and line number followed by the
correction.
Page
2
3
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Line No,
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2-3
Change
"sides" should be "sites"
insert "a" before "comment"
"with" should be "that"
"small site" should be "low contamin-
ation site"
"other area" should be "site"
place a colon after materials:
"fuels. Metals,"
"Pesticides" should be "pesticides"
place a comma after DDT,
before the word "enough" put "not"
before the words "in LF-021" put
"as with"
change "regulator" to "regulators."
(period at end of word)
"They" starts a new sentence
i_ - tt . it » *
change do, to do
replace "Issues of the building
permit" with "a building permit
issued"
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TO: Marcia G. Wolosz
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ERRATA SHEET
DATE: February 14, 1997
RE: 1-16-96 Public Hearing
FROM: Capitol Court Reporters, P.O. Box 329,
Burlington, Vermont 05402
Please read through the enclosed transcript. If you
wish to make any corrections, please do so below
referring to page and line number followed by the
correction.
Page Line No. Change
3 5 & 6 Sentence beginning "the public comment..'
should read, "The public comment period
ends on January 23rd for LF 21, as
stated in the public notice advertised
in the Plattsburgh Press-Republican on
Monday, December 23, 1996."
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PUBLIC MEETING LF-021/LF-024
January 16, 1997
ORGANIZATION
PHONE NUMBER
"i 7{
2-
.'.C A-. L Jc^ /j^- r>
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APPENDIX E
RESPONSIVENESS SUMMARY
):OS291\«p\LraU.ROD/ia(j(aXcpXmai)
02-24-77:11:43
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DEPARTMENT OF THE AIR FORCE
AIR FORCE BASE CONVERSION AGENCY
25 Feb 97
MEMO FOR RECORD
SUBJECT: Responsiveness Summary: Public Comment Period for Remedial Action at
LF-024
A. OVERVIEW
LF-024 is a former landfill located in the southeast comer of the former
Pittsburgh Air Force Base, about 200 feet north of the Salmon River. The less-than-
one-acre-sized landfill accepted construction and demolition debris from the period of
1980 to 1986. Evidence of this can be seen in the debris protruding from the landfill
cover. The Air Force considers this to be a general physical hazard to trespassers and
people walking in the area. The fill material and groundwater were found to be
essentially free of organic contaminants, but metals were detected at levels elevated
above background in the fill materials and in exceedance of New York State Groundwater
Quality criteria in the shallow aquifer.
The BRAC Cleanup Team reviewed a number of presumptive remedies (as
defined by the U.S. Environmental Protection Agency) for remediating the contamination
at LF-024. Based on the nature of the contamination and knowledge of site conditions
obtained from the site investigation, the Air Force selected a combined approach of
landfill capping and institutional controls for containing the site. This was found to be
the most technically and economically acceptable alternative for achieving the BRAC
team's goals, which are to prevent direct contact with on-site soil/fill and groundwater by
human or ecological receptors. The remedial action is detailed in the proposed plan dated
December 1996.
B. PUBLIC MEETING & PUBLIC COMMENT PERIOD
A Public Meeting was held on the remedial action for LF-024 on 16 January 1997
at 7:00 p.m. It was held at the Old Court House in the City of Pittsburgh. County of
Clinton. NY. A prepared statement was read by Mr. Michael D. Sorel. PE, the BRAC
Environmental Coordinator for the Air Force Base Conversion Agency (AFBCA). Mr.
Bruce Przybyl of URS Greiner, Inc., detailed the proposed remedial action for the
audience. The floor was then opened to the public for questions and comments.
Concluding the meeting was a statement by Mr. Sorel that additional comments could be
sent to the Air Force. As advertised in the Plattsburgh Press-Republican, the public
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Responsiveness Summary - Remedial Action LF-024 2
comment period ran from 6 January 1997 to 6 February 1997. The Public Meeting was
recorded by a court reporter, Ms. Susan Bretschneider of Vermonrville, NY.
C. SUMMARY OF COMMENTS RECEIVED DURING THE PUBLIC
COMMENT PERIOD AND AGENCY RESPONSES
Mr. Robert Booth, a member of the Pittsburgh AFB Restoration Advisory' Board,
wanted to know who would be responsible for seeing that any limitations on site
development are carried out.
Mr. Sorel replied that this has been the subject of discussion with the U.S.
Environmental Protection Agency (USEPA) and the New York State Department of
Environmental Conservation (NYSDEC). Mr. Sorel read a paragraph from the proposed
plan that deals with the wording in the future transer deed. Included will be restrictions
of any activities leading to the deterioration of the landfill cap, and use of the underlying
groundwater. Since the Air Force will no longer own the property, the local agency
responsible for issuing building permits will need to make written reference to the
prohibitions. All of these documents will remain on file. Also, the NYSDEC has agreed
to act as the reference agency for oversight.
From the time of the Public Meeting until the deadline of 6 February 1997, no
further questions or comments were received by the Air Force regarding this subject.
:L,PE
BRAC Environmental Coordinator
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ROD FACT SHEET
SITE
Name : Plattsburgh Air Force Base
Landfill LF-024
Location/State : Plattsburgh, New York
EPA Region : 2
HRS Score(date): 30.34 (9/22/88) Basewide score, not landfill
Site ID # : NY4571924774
ROD
Date Signed: 3/25/97
Remedy/ies: Native Soil Cover, Institutional Controls
Operating Unit Number: OU-8 (IRP Site LF-024)
Capital cost: $ 59,000 in 1997 dollars)
Construction Completion: April 1998
O & M in 1998: $ 4,120 (in 1997 dollars)
1999: $ 4,120
2000: $ 4,120
2001: $ 4,120
Present worth: $ 136,585 (6% discount rate, 30 years O&M,
O & M drops to $ 1,030/yr in 6th year)
LEAD
Remedial - Federal Facility Lead
Primary contact - Bob Morse (212) 637-4331
Secondary contact - Bob Wing (212) 637-4332
Main PRP(s) - U.S. Air Force
PRP Contact - Mike Sorel (518) 563-2871
WASTE
Type - Metals (mainly manganese)
Medium - Soil and Groundwater
Origin - Construction and Demolition (C & D) Landfill
Est. quantity - One acre
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