PB97-963131
EPA/541/R-97/106
January 1998
EPA Superfund
Record of Decision Amendment:
Preferred Plating Corp.
Farmingdale, NY
9/30/1997
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RECORD OF DECISION AMENDMENT
Preferred Plating Corporation
Farmingdale, Suffolk County, New York
UNITED STATES ENVIRONMENTAL PROTECTION.AGENCY
REGION II
NEW YORK, NEW YORK
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DECLARATION STATEMENT
RECORD OF DECISION AMENDMENT
SITE NAME AND LOCATION
Preferred Plating Corporation
Farmingdale, Suffolk County, New York
STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected modification to the
original remedial action for the first operable unit of the Preferred
Plating Corporation site (Site), located in Farmingdale, New York.
The original remedial action was selected in the Operable Unit 1
(OU1) Record of Decision (ROD) issued by the United States
Environmental Protection Agency (EPA) on September 22, 1989.
The modification to the original OU1 remedy was chosen in accordance
with the requirements of the Comprehensive Environmental Response,
Compensation, and Liability Act (CERCLA) of 1980, as amended, 42
U.S.C. ง 9601 et seq.. and to the extent practicable, the National
Oil and Hazardous Substances Pollution Contingency Plan (NCP), 40
C.F.R. Part 300. This decision document explains the fundamental
changes to the OU1 remedy previously selected for the Site.
*x
The New York State Department of Environmental Conservation (NYSDEC)
concurs with the modification to the selected OU1 remedy. See
attached letter (Appendix I). The information supporting this
remedial action decision is contained in the administrative record
for the Site. The index for the administrative record is attached to
this document (Appendix II)..
DESCRIPTION OF MODIFICATION TO THE SELECTED REMEDY
The modification to the OU1 remedy reassesses the need for a pump and
treat system to address groundwater contaminated with cadmium,
chromium, and chlorinated organics. This operable unit, one of three
phases of remedial activity for the Site, addresses contaminated.
groundwater underlying the Site. The second operable unit addressed
contaminated sediments and soils in underground leaching pits located
on the former PPC property; the excavation and off-site disposal of
these materials were completed ife June 1994. The third operable unit
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investigated a potential upgradient source of groundwater
contamination which resulted in a September 1993 ROD to take no
further action.
The major components of the modification to the selected remedy
include: '
Elimination of the groundwater extraction and treatment system
portion of the 1989 selected remedy, and
Implementation of -an annual groundwater monitoring program to
ensure that the remedy remains protective of human health and the
environment.
This ROD Amendment describes fundamental changes to the September
1989 OU1 ROD issued by EPA for the Site and which was concurred on by
NYSDEC.
The remedy specified in the 1989 OU1 ROD included the remediation of
the underlying aquifer through extraction and treatment of
groundwater contaminated with heavy metals and chlorinated organics,
followed by reinjection of the treated water. The aquifer was to be
remediated to federal and state drinking water standards.
The 'levels of contamination observed in the aquifer in 1989' have
declined significantly. Presently, only cadmium still exists above
its federal and state drinking water standard. Therefore, because of
the change in Site conditions, the extraction and treatment system is
no longer necessary to ensure the protection of public health and the
environment.
The modified remedy will rely on natural attenuation to continue to
reduce contaminant levels, particularly cadmium, in the groundwater.
The aquifer will be monitored on an annual basis to evaluate the
continued effectiveness of the natural attenuation processes.
DECLARATION STATEMENT
This modification to the selected OU1 remedy is protective of human
health and the environment, complies with federal and state
requirements that are legally applicable or relevant and appropriate
to the remedial action, and is cost-effective. This modified remedy
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utilizes permanent solutions and alternative treatment technologies
to the maximum extent practicable for the Site.
Because the selected remedy will result in hazardous substances
remaining on the Site above health-based levels, a review will be
conducted within five years after issuance of this ROD Amendment to
ensure that the selected amended remedy continues to provide adequate
protection of human health and the environment.
EPA has determined that no further physical construction is necessary
at this Site and, therefore, it now qualifies for inclusion on the
Construction Completion List.
Regional Adm^mist
Jeanne M . Fox /Mr / Da
m^mi
ill
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RECORD OF DECISION AMENDMENT SUMMARY
Preferred Plating Corporation Site
Farmingdale, Suffolk County, New York
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TABLE OF CONTENTS
Section Page
I. Introduction 1
II. Highlights of Community Participation 3
III. Reasons for Issuing the Record of Decision
Amendment 4
IV. Summary of Site Risks 7
V. Description of Remedial Alternatives 10
VI. Summary of Comparative Analysis of
Alternatives 12
VII. Selected Remedy 16
VIII. Statutory Determinations 1 16
Attachments
Appendix I State Letter of Concurrence
Appendix II Administrative Record Index
Appendix III Responsiveness Summary
Appendix IV Table of Groundwater Sampling Data
Appendix V 1989 Record of Decision
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I. INTRODUCTION
The Preferred Plating Corporation (PPC) site (Site) includes the
former PPC facility located at 32 Allen Boulevard in Farmingdale,
Town of Babylon, Suffolk County, New York. The Site, approximately
one acre in size, is situated in a light industrial area one mile
east of the Nassau-Suffolk County line.
The Site is almost entirely covered by a building and pavement with
two small grassy areas on the southern end and a gravel and grass
strip located along the west side of the building. Most of the
homes and businesses in the vicinity of the Site are served by a
public water supply from the East Farmingdale Water District.. The
nearest public water supply well field is within one mile south, or
hydraulically downgradient, of the Site.
Between September 1951 and June 1976, PPC conducted metal-plating
operations to increase the corrosion resistance of metal parts and
to provide a more cohesive base for painting. The primary activi-
ties at the PPC facility included degreasing, cleaning, and
chemically treating the surface of metal parts. These processes
involved the use of various chemicals which resulted in the genera-
tion, storage, and disposal of hazardous substances. Untreated
wastewater was discharged into four below-grade concrete storage
pits located directly behind the original building.
Groundwater contaminated with heavy metals was detected, in the
immediate vicinity of the Site as early as June 1953. During that
period an inspection of the PPC facility by the Suffolk County
Department of Health Services (SCDHS) discovered that the storage
pits were cracked and leaking. Samples taken from the pits
revealed the major contaminants to be heavy metals. From 1953 to
1976, SCDHS instituted numerous legal actions against PPC in an
effort to stop discharges to the pits and to institute an 'on-site
treatment system. PPC prepared an engineering report in May 1974
in order to apply for a State Pollutant Discharge Elimination
System (SPDES) permit which was issued in June 1975. PPC claims to
have chemically treated the wastewater in the pits and have had the
waste material removed from the Site, but no documentation
supporting these assertions exists. The facility was never in full
compliance with the terms and conditions outlined in the SPDES
permit.
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In June 1976, PPC declared bankruptcy. Since then, several firms
have occupied the Site, none of which conducted similar operations.
In 1982, the original building was extended to the north by 200
feet, and the four waste storage pits were filled and covered by
the newly constructed extension.
In September 1984, the New York State Department of Environmental
Conservation (NYSDEC) issued a Phase I Investigation Report which
summarized past investigations and included a Hazard Ranking System
score for the Site. Based on that score, the Site was proposed for
inclusion on the National Priorities List of hazardous waste sites
in October 1984 and was placed on the List in June 1986, which
brings the Site under the purview of the Federal Superfund Program.
From June 1987 to June 1989, Ebasco Services, Inc., EPA's
contractor, conducted the initial remedial investigation and
feasibility study (RI/FS) of the Site. The study detected heavy
metals and chlorinated organics in the groundwater underlying the
Site; however, it did not completely identify the source and the
extent of contamination within the soils underlying the former
storage pits. Therefore, the remedy which resulted from the first
operable unit study (OU1) focused only on the treatment of the
contaminated groundwater. The study resulted in the OU1 ROD which
was signed on September 22, 1989. The major components of that
remedy included extraction of the contaminated groundwater,
treatment of heavy metals and chlorinated organics, and reinjection
of the treated groundwater. The design for this treatment- system
was completed in March 1992. The construction of the groundwater
treatment system was postponed while EPA completed its
investigation of the contaminant source areas.1
EPA undertook a second RI/FS, which was conducted by Malcolm
Pirnie, Inc., to study the contaminant source areas, i.e., the
soils within and directly beneath the former leaching pits. A
second operable unit (OU2) ROD for excavation and off-site
treatment and disposal of the contaminated soils and sediments was
signed on September 28, 1992. In June 1993, EPA issued an'
lln March 1992, EPA recognized that the contaminant source areas would need
to be addressed prior to the construction of the groundwater treatment system and
the likely approach to remediating the source areas would involve excavation
beneath the existing building on the Site. The postponement of the construction
of the groundwater treatment system was necessary because the limited space on
the former PPC property would not permit source area excavation and groundwater
treatment system construction to occur simultaneously.
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Administrative Order to the property owners requiring them to
implement this remedy. The remediation, resulting in the removal
and off-site disposal of approximately 1,500 tons of contaminated
soils and sediments, was performed by the property owners through
their consultant, Eder Associates, with EPA oversight. The
excavated areas were backfilled with certified clean fill. All
construction activities associated with OU2 were completed by June
1994 in accordance with OSWER Directive 9320.2-09, "Close Out
Procedures for National Priorities List Sites," dated August 1995,
and were done in accordance with the OU2 ROD and the approved
remedial design.
The OUl RI/FS also indicated contamination in monitoring wells
located upgradient of the PPC facility source area. Therefore, a
third RI/FS was conducted to address a potential source of
groundwater contamination upgradient of the PPC facility. The
upgradient property owner, Del Laboratories, Inc., initiated an
RI/FS in September 1990, pursuant to an Administrative Order on
Consent, to determine if its operations had impacted the
groundwater quality beneath the PPC Site. The third operable unit
(OU3) ROD, signed in September 1993, documented the determination
that no remedial action was necessary at the Del Laboratories, Inc.
property based in part on the fact that prior actions had been
taken to address environmental conditions at the Del Laboratories,
Inc. facility.
II. HIGHLIGHTS OF COMMUNITY PARTICIPATION -
The Post-Decision Proposed Plan (PDPP) for the Site was released to
the public on July 31, 1997. The PDPP, along with all other Site-
related documents, is available to the public at both the
administrative record and the information repository locations
presented below. A notice was published in the Farmingdale
Observer on August 1, 1997, and again on August 8, 1997, to
announce the public comment period on the PDPP, the date of the
public meeting to present the PDPP, and the availability of the
technical documents at the repositories.
The public comment period began on July 31, 1997 and concluded on
August 30, 1997. A public meeting was held on August 7, 1997 at
the W.E. Howitt Jr. High School located in Farmingdale, New York.
The purpose of the public meeting was to discuss the proposed
amendment to the September 1989 ROD.
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The responses to the comments expressed verbally at the public
meeting are summarized in the Responsiveness Summary, which is
attached to this Record of Decision Amendment as Appendix III. No
objections to the proposed remedy were voiced at the public meeting
and no written comments were received during the public comment
period. Public interest in this Site has always been relatively
low.
This Record of Decision Amendment presents the selected remedial
action for the grouridwater underlying the Site, chosen in
accordance with the requirements of the Comprehensive Environmental
Response, Compensation, and Liability Act (CERCLA) of 1980, as
amended, and to the extent practicable, the National Contingency
Plan (NCP). The amendment to the remedial decision for the Site is
based upon the administrative record. An index for the
administrative record is attached to this document'as Appendix II.
This Record of Decision Amendment will become a part of the
administrative record file.
The administrative record file, containing the information upon
which the modification to the original remedy is based, is
available at the following locations:
Babylon Town Hall
Town Clerk's Office
200 East Sunrise Highway
Lindenhurst, New York 11757
516-957-3005
U.S. Environmental Protection Agency
290 Broadway - Records Center
New York, New York 10007-1866
212-637-4308
III. REASONS FOR ISSUING THE RECORD OF DECISION AMENDMENT
Site conditions have changed significantly since the Issuance of
the 1989 ROD. The on-site sources of contamination have been
excavated and removed for off-site disposal, and the use of
improved sampling techniques and resultant analytical data indicate
that the contaminant levels in the underlying groundwater have
decreased dramatically as have the risks associated with the Site
contamination. The following summary explains the changed
contaminant levels and Site risks.
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Improvement in Groundwater Quality
Based on two rounds of sampling data, obtained in August and
September of 1988, from nine wells on the former PPC property and
two wells located downgradient from the former PPC property, the
OU1 RI documented the presence of heavy metals and chlorinated
organic compounds in the groundwater underlying the Site. The
primary contaminants of concern were chromium and cadmium; chromium
was detected at 5850 parts per billion (ppb) and cadmium at 399
ppb. Lead, nickel, and 1,1,1-trichloroethane (TCA) were also
identified as contaminants of concern.
Subsequent sampling activities focused on metals contamination,
particularly cadmium and chromium. The maximum concentrations of
cadmium and chromium detected during these subsequent sampling
events are provided in Table 1. The results clearly indicate a
significant decrease in the concentration of the primary
contaminants of concern. The first round of samples collected
after issuance of the OU1 ROD was obtained from the wells on the
former PPC property in February 1991 during performance of a
treatability study for the groundwater treatment system remedial
design. The levels of contamination had decreased significantly to
1850 ppb of chromium and 254 ppb of cadmium. In August 1993, prior
to implementation of OU2 construction activities for the source
removal, another round of samples was collected. The levels of
contamination detected in this sampling event had decreased further
to 560 ppb of chromium and 123 ppb of cadmium. In July 1994, after
the OU2 remediation activities were implemented, all wells were
sampled to monitor the effect of source removal. The levels of
contamination detected had increased to 1630 ppb for chromium and
136 ppb for cadmium. However, the chromium concentration of 1630
ppb was measured in a sample collected from monitoring well MW1SP;
the water from this well was extremely turbid. The same sample
upon filtering yielded a much lower concentration of chromium at 35
ppb, indicating that the higher unfiltered reading was mostly a
result of sample turbidity. This high concentration was not
expected since MW1SP is located upgradient of the source area.
Additionally, this result was not consistent with previous data
collected from this well. In the next round of sampling in April
1995, a technique using a low-flow pump was utilized in an effort
to collect representative samples of the aquifer while minimizing
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sample turbidity.2 The levels of contamination detected in these
samples decreased to 83 ppb for chromium and 43 ppb for cadmium.
The low-flow technique was also utilized in sampling conducted in
August 1996; the detected concentrations, 57 ppb for chromium and
60 ppb for cadmium, were very similar to those found in the April
1995 sampling.
Throughout the sampling events, organics were detected infrequently
and at low levels. The most frequently detected contaminant was
TCA. Concentrations of TCA ranged from 1.9 to 17 ppb. The last
round of samples, collected in August 1996, detected TCA ranging
from 2 to 5 ppb, and one detection of trichloroethene at 19 ppb;
the drinking water standard for both of these contaminants is 5
ppb.
The two monitoring we*lls> MW-7 and MW-8, are located 1200 and 2400
feet, respectively, downgradient of the former PPC property. Both
are deep wells, screened at the bottom of the Upper Glacial
aquifer. MW-7 was only sampled in August and September of 1988.
Neither cadmium nor chromium was detected above standards. Lead
was detected at 30.3 ppb. MW-8 was sampled in August and September
1988, July 1994, and May 1995. Tetrachlproethene and TCA were
detected slightly above MCLs in this well, but no heavy metal
contamination has ever been detected.
The only surface water body in the Site vicinity is an unnamed,
intermittent tributary to Massapequa Creek.. It is located about
6,000 feet west, or side-gradient, of the Site.. During the first
sampling period in 1988, this creek was dry. Since it is not in
the direction of groundwater flow, no impact to the creek is
believed to exist as a result of Site contaminants.
Over the past several years, the sampling results have indicated a
significant decrease in concentrations of the primary contaminants
of concern, cadmium and chromium. The decline is most directly
attributable to the removal of the on-site source. Better sampling
2Groundwater typically occurs naturally in the Upper Glacial Aquifer at low
turbidity levels. Elevated sample turbidity may be an artifact of sample
collection and well construction techniques. The high turbidity associated with
samples collected in 1988 raises the question of whether the reported results
were representative of the metals contamination in the aquifer. EPA believes
that the detected contaminant levels, especially for chromium, were uncharacter-
istically high and a result of highly turbid samples rather than representative
of actual metals contamination in the aquifer.
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techniques which have minimized the turbidity of the groundwater
have also resulted in providing a more accurate measurement of
contamination. At present, only cadmium exceeds both its federal
and State drinking water standards. Chromium does not exceed
either the federal or state drinking water standard of 100 ppb, but
does slightly exceed the state groundwater quality standard of 50
ppb. TCA, the only organic contaminant consistently detected
throughout the sampling activities, slightly exceeded its State
drinking water standard in three of ten wells sampled during the
April 1995 sampling round. However, TCA was not detected above
federal or state standards in any of the samples collected in
August 1996.
IV. SUMMARY OF SITE RISKS
During the performance of the OU1 RI/FS, a baseline risk assessment
was conducted to estimate the risks associated with current and
potential (future) Site conditions. The baseline risk assessment,
which was based on data obtained only during the OU1 RI/FS,
estimated the human health and ecological risk which could result
from the contamination at the Site if no remedial action were
taken. A summary of the baseline risk assessment and a recalcula-
tion of the risk using current data are presented below.
There were no risks associated with the current uses of the Site.
Because the Site is covered by a building and pavement, the only
potential pathway which represents a potential risk to the- public
was determined to be ingestion of contaminated groundwater.
Although the 1988 OU1 groundwater sampling did indicate high levels
of heavy metal contamination, there was no direct human exposure to
contaminants because the surrounding population was presumed to be
supplied by public water. However, the Upper Glacial Aquifer is
classified as lib, or a potential drinking water source, and
therefore, a potential risk to human health would exist in the
event that this aquifer was developed for use. The baseline risk
assessment evaluated the health effects which could result from
exposure to contamination as a result of ingestion for a future-use
scenario.
An analysis, in 1989, of the concentrations of chemicals present in
the groundwater with applicable or relevant and appropriate
requirements (ARARs) indicated that numerous inorganic and organic
compounds exceeded those ARARs. Based on this analysis, the
inorganics cadmium, chromium, lead, nickel, and cyanide were
evaluated in the risk assessment. Although not all of the organic
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contaminants of concern exceeded ARARs, they were carried through
the risk assessment in order to obtain a collective assessment of
risk frpm concurrent exposure to multiple contaminants. At
present, an analysis of the concentration of chemicals present in
the 1995 and 1996 groundwater samples with ARARs indicates that
only cadmium, chromium, TCA, and one detection of trichloroethene
exceed their respective ARARs.
Human Health Risk Assessment
EPA's acceptable cancer risk range is 10'* to 10~s, which can be
interpreted to mean that an individual may have one in ten thousand
to one in a million increased chance of developing cancer as result
of site-related exposure to a carcinogen over a 70-year lifetime
under the specific exposure conditions at a site.
The results of the baseline risk assessment conducted as part of
the 1989 RI/FS indicated that if, in the event that the groundwater
was to be used as a source of drinking water, the Site posed unac-
ceptable risks to human health and the environment. The risk
assessment was based on a worst case total lifetime exposure to
maximum organic concentrations at an assumed constant rate
(drinking 2 liters of water daily for 30 years in an adult, living
to the age of 70 years). Utilizing the data from the 1995 and 1996
sampling events, it was determined that the total cancer risk for
the future-use scenario was 1 x 10"5 (i.e., an excess lifetime
cancer risk of one-in-one-hundred thousand), which is within EPA's
acceptable cancer risk range.
To assess the overall potential for noncarcinogehic effects posed
by more than one contaminant, EPA has developed a hazard index
(HI). This index evaluates the potential adverse health effects
resulting from exposures to several chemicals simultaneously. The
HI is the sum of the hazard quotients (HQ); the HQ being a
representation of the chronic daily intake (GDI) divided by the
reference dose (RfD) for a specific compound within a particular
exposure pathway (i.e., HQ = CDI/RfD). The RfD is a measure of a
chemical's threshold for causing effects to which many safety
factors have been added (i.e. a safe exposure dose). When the HI
exceeds one, there may be concern for potential noncarcinogenic
effects. The 1989 OU1 RI/FS calculated the HI under a worst case
scenario for cadmium and chromium as 22.8 and 170, respectively.
However, the significant decrease in contaminant levels over the
past several years has resulted in a significant decrease in
associated potential risk levels. Under present conditions, using
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the sampling data from 1995 and 1996, the recalculated HI for
cadmium and chromium is 2.2 and 0.06, respectively.
While there was once a significant noncarcinogenic risk from
potential future consumption of the Upper Glacial Aquifer because
of the previous high incidence of cadmium and chromium
contamination, such a risk no longer exists. The HI is currently
only slightly above the acceptable HI of 1 because of the presence
of cadmium. Furthermore, any risk is associated with an unlikely
future-use scenario because the Upper Glacial Aquifer at the Site
is not used as a drinking water supply and downgradient levels of
cadmium are below the federal and state drinking water standards.
Ecological Assessment
The ecological risk assessment considered potential exposure routes
of Site contamination to terrestrial wildlife. The only potential
route of exposure to wildlife in the Site vicinity is if
contaminants were transported through groundwater and discharged
via groundwater into surface waters, particularly Great South Bay.
The potential effects of contaminated groundwater on aquatic life
were discussed in the 1989 ecological risk assessment performed for
the first operable unit. It was determined that no significant
effect on aquatic organisms in the Great South Bay or creeks in the
vicinity of the Site would occur if contaminants were transported
from the Site through groundwater and discharged into surface
waters. .
Uncertainties
The procedures and inputs used to assess potential human health
risks in this evaluation are subject to wide uncertainties. In
general, the main sources of uncertainty include:
environmental chemistry sampling and analysis;
environmental parameter measurement;
fate and transport modeling;
exposure parameter estimation; and
toxicological data.
Uncertainty in environmental sampling arises in part from the
potentially uneven distribution of chemicals in the media sampled.
Consequently, there is significant uncertainty as to the actual
levels present. Environmental chemistry-analysis error can stem
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from several sources including the errors inherent in the
analytical methods and characteristics of the matrix being sampled.
Uncertainties in the exposure assessment are related to estimates
of how often an individual would actually come into contact with
the chemicals of concern, the period of time over which such
exposure would occur, and in"the models used to estimate the
concentrations of the chemical "of concern at the point of exposure.
Uncertainties in toxicological data occur in extrapolating both
from animals to humans and from high to low doses of exposure, as
well as from the difficulties in assessing the toxicity of a
mixture of chemicals. These uncertainties are addressed by making
very conservative assumptions concerning risk and exposure
parameters throughout the assessment. As a result, the risk
assessment provides upper bound estimates of the risks to
populations near the Site, and is highly unlikely to underestimate
actual risks related to the Site.
Actual or threatened releases of hazardous substances from this
Site, if not addressed by implementing the response action selected
in the ROD Amendment, may present a potential threat to the
environment through the groundwater pathway.
V. DESCRIPTION OF REMEDIAL ALTERNATIVES
CERCLA requires that each selected site remedy be protective of
human health and the environment, be cost-effective, comply with
other statutory laws, and utilize permanent solutions and alterna-
tive treatment technologies and resource recovery alternatives to
the maximum extent practicable. In addition, CERCLA includes a
preference for the use of treatment as a principal element for the
reduction of toxicity, mobility/ or volume of the hazardous
substances.
This ROD Amendment evaluates two alternatives for addressing
groundwater contamination, namely, Alternatives GW-1 and GW-2.
Consistent with EPA's ROD amendment guidance, the original OU1
remedy, GW-2, is being.compared to the new preferred Alternative
GW-1, which was developed based upon existing Site conditions,
including the groundwater monitoring data presented above. It
should be noted that the time assumed to implement the remedy
reflects only the time required to construct and the already
designed remedy, and does not include the time required to design
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the remedy, negotiate with any potentially responsible parties, or
procure contracts for design and construction.
The remedial action objectives for addressing groundwater
contamination are (1) to protect human health by ensuring future
residents are not exposed to contaminated groundwater, and (2) to
reduce groundwater contamination levels to drinking water stand-
ards.
The alternatives for addressing the Site groundwater contamination
are:
Alternative GW-1: No Further Action/Natural Attenuation
Capital Cost: $ 0
0 & M Cost: $ 5,000/year (for 5 years)
Present Worth Cost: $19,588
Time to Implement: immediate
This alternative does not include active treatment of the aquifer;
it relies upon natural attenuation to reduce the contamination
below federal and state drinking water standards and/or groundwater
quality standards. A monitoring program would be implemented on an
annual basis to demonstrate the effectiveness of the naturally
occurring mechanisms. Since contaminants will remain on the Site
above health-based risk levels, EPA would conduct a five-year
review to ensure that the remedy is protective of human health and
the environment. If the natural- attenuation of contaminants in the
groundwater at the Site has not improved groundwater quality to
federal drinking water standards and State drinking water and .
groundwater standards, EPA and NYSDEC would reevaluate the need for
an active treatment remedy for the Site.
Alternative GW-2: Extraction/Precipitation of Divalent Metals/
Ion Exchange/Activated Carbon/Reinjection
Capital Cost: $ 1,923,900
0 & M Cost: $ 920,900/yr
Present Worth Cost: $ 9,327,400
Time to Implement: 1 Year
This alternative consists of the extraction and on-site treatment
of contaminated groundwater. Groundwater would be extracted from
one on-site collection well. The extracted groundwater would first
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go through a 2-stage precipitation and clarification/filtration
unit for the removal of divalent metals, followed by an ion
exchange process for the removal of the chromate ion, and if
necessary, a carbon adsorption unit for removal of volatile organic
compounds. The metals treatment would generate hazardous waste
residuals requiring ultimate disposal in a Resource Conservation
and Recovery Act Subtitle C facility. The treatment scheme is a
proven technology capable of removing the contaminants of concern
from the groundwater. The extracted groundwater would be treated
through this process to satisfy all federal and state standards for
Class lib waters, i.e., potential drinking waters, prior to
reinjection. The treated groundwater would be discharged to a
reinjection well installed east of the former PPC property and
upgradient of both the extraction well and former leaching pits. A
groundwater monitoring program would be required to evaluate the
effectiveness of this remedial action.
VI. SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
During the detailed evaluation of remedial alternatives, each
alternative is assessed against nine evaluation criteria, namely,
overall protection of human health and the environment, compliance
with applicable or relevant and appropriate requirements, long-term
effectiveness and permanence, reduction of toxicity, mobility, or
volume through treatment, short-term effectiveness, .
implementability, cost, and state and community acceptance.
The evaluation criteria are described below.
Overall protection of human health and the environment ad-
dresses whether a remedy provides adequate protection and
describes how risks posed through each pathway are eliminat-
ed, reduced, or controlled through treatment, engineering
controls, or institutional controls.
Compliance with applicable or relevant and appropriate
requirements (ARARs) addresses whether a remedy will.meet all
of the applicable or relevant and appropriate requirements of
other Federal and State environmental statutes 'and require-
ments or provide grounds for invoking a waiver.
Long-term effectiveness and permanence refers to the ability
of a remedy to maintain reliable protection of human health
and the environment over time, once cleanup goals have been
met.
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Reduction of toxicity. mobility, or volume through treatment
is the anticipated performance of the treatment technologies
a remedy may employ.
Short-term effectiveness addresses the period of time needed
to achieve protection and any adverse impacts on human health
and the environment that may be posed during the construction
and implementation period until cleanup goals are achieved.
Implementability is the technical and administrative
feasibility of a remedy, including the availability of
materials and services needed to implement a particular
option.
Cost includes estimated capital and operation and maintenance
costs, and net present worth costs.
State acceptance indicates whether, based on its review of
the RI/FS reports and Post-Decision Proposed Plan, the State
concurs, opposes, or has no comment on the preferred
alternative at the present time.
Community acceptance is assessed by reviewing the public
comments received on all relevant reports and the Post-
Decision Proposed Plan during the public comment period.
A comparative analysis of these alternatives based upon the
evaluation criteria described above follows.
Overall Protection of Human Health and the Environment
Both alternatives are similar in their abilities to protect human
health and the environment. As noted above in the risk assessment
section, there are no current use risks associated with the
contamination at the Site. The groundwater on the Site is not
being used as a source of drinking water. In addition, no
significant impacts to ecological receptors have been observed.
The future use carcinogenic risks at the Site are within EPA's risk
range, and the noncarcinogenic risks are just slightly above EPA's
acceptable level; however, these risks assume that the Site
groundwater will be utilized as a potable water supply, an event
that is highly unlikely.
As there are no current or anticipated future users of the
groundwater on the Site, and since the levels of contaminants in
13
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the groundwater have decreased dramatically in the last few years
and are expected to drop below drinking water and groundwater
quality standards in the future, EPA believes that both GW-2 and
GW-l would provide full protection of human health and the
environment.
Compliance with ARARs
Since the impacted groundwater underlying the Site is' a potential '
future source of drinking water, federal and state drinking water
standards, as well as State groundwater quality standards, are
ARARs. For Alternative GW-l, EPA believes that ARARs would be
achieved over time through natural attenuation; compliance with
ARARs would be demonstrated through an annual monitoring program.
For Alternative GW-2, compliance with ARARs for the aquifer would
be achieved through extraction and active treatment for removal of
metals. The treated groundwater would meet appropriate standards
prior to being reinjected. Residual sludges from the treatment
system would be treated and disposed of in accordance with RCRA
regulations.
Long-Term Effectiveness and Permanence '
Both Alternatives GW-l and GW-2 are expected, over time, to provide
the same degree of long-term effectiveness and permanence.
Reduction in Toxicity. Mobility or Volume Through Treatment
Alternative GW-2 would reduce the toxicity, mobility and volume of
contaminated groundwater through extraction and .subsequent
treatment. Alternative GW-2 would potentially achieve this
reduction in a shorter time frame than Alternative GW-l,. which
relies solely on natural attenuation and does not actively reduce
the toxicity, mobility or volume of contaminants in the
groundwater.
Short-term Effectiveness .
Although Alternative GW-2 would potentially achieve cleanup goals
in a shorter time frame than Alternative GW-l, this is not expected
to be significant. This is supported by the fact that groundwater
contaminant levels have decreased so significantly over the past
several years.
14
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Alternative GW-1 presents virtually no short-term impacts to human
health and the environment since no construction is involved. The
construction activities required to implement Alternative GW-2
would have potentially negative impacts on Site workers and nearby
residents. While efforts would be made to minimize these impacts,
some disturbances would result from disruption of traffic,
excavation activities on public and private land, and noise. It is
estimated that the construction activities for Alternative GW-2
would take approximately 12 months to complete.
Implementability
The technologies proposed for extraction and treatment of
contaminated groundwater in Alternative GW-2 are proven and
reliable in achieving the specified cleanup goals, however,
Alternative GW-2 would be much more complex than Alternative GW-1
to implement. Alternative GW-1 does not involve any construction
and is much easier to implement as it only requires a monitoring
program utilizing existing monitoring wells.
Cost
Alternative GW-1 has no direct costs associated with its implemen-
tation. The present worth of this alternative of $19,588 is for
implementation of an annual groundwater monitoring program. For
cost-estimating purposes, a duration of 5 years was assumed. The
capital and present worth costs of Alternative GW-2 are estimated
to be approximately $1,923,900 and $9,327,400, respectively.
State Acceptance
The State of New York concurs on the proposed modified remedy. A
letter of concurrence is attached as Appendix I.
Community Acceptance
No objections from the community'were raised regarding the.selected
remedy. A responsiveness summary, which addresses all comments
pertaining to the amended groundwater remedy received at the
August 7, 1997 public meeting, is attached as Appendix III.
15
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VII. SELECTED REMEDY
Based upon an evaluation of the various alternatives, EPA and
NYSDEC have determined that Alternative GW-1, No Further Ac-
tion/Natural Attenuation, is the appropriate modified remedy for
the Site.
This alternative provides the best balance of trade-offs among
alternatives with respect to the evaluating.criteria in that it is
protective of human health and the environment, complies with
ARARs> is cost-effective, and utilizes permanent solutions and
alternative treatment technologies or resource recovery technolo-
gies to the maximum extent practicable.
VIII. STATUTORY DETERMINATIONS
Under its legal authorities, the EPA's primary responsibility at
Superfund sites is to undertake remedial actions that achieve
adequate protection of human health and the environment. In
addition, Section 121 of CERCLA establishes several other statutory
requirements and preferences that the selected remedy must meet.
Section 121 of CERCLA specifies that when complete, the selected
remedial action for the Site must comply with ARARs .established
under federal and state environmental laws unless a statutory
waiver is justified. The selected remedy also must be cost-
effective and utilize permanent solutions and alternative treatment
technologies or resource recovery technologies to the maximum
extent practicable. Finally, the statute includes 'a preference for
remedies that employ treatment that permanently and significantly
reduce the volume, toxicity, or mobility of hazardous wastes as
their principal element. The following sections discuss how the
selected remedy meets these statutory requirements.
Protection of Human Health and the Environment:
Since the levels of contaminants in the groundwater have decreased
dramatically in the last few years, it is anticipated that.the
natural attenuation component of the modified selected remedy will
continue to reduce the concentration of cadmium and chromium in the
groundwater at the Site. As contamination above federal and state
standards is limited to the area of the Site and there are no
current or future users of the groundwater at the Site, the remedy
will provide full protection of human health and the environment.
16
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It is EPA's belief that the groundwater natural attenuation remedy
will eventually provide for unlimited use of the groundwater at
this Site. EPA has determined, as a matter of policy, that policy
reviews of the remedies should be conducted when ongoing remedial
actions will not allow for unlimited use within five years of the
initiation of the remedial action. The remedies previously
selected for this Site have been reviewed as part of this ROD
amendment and have been found to remain protective of human health
and the environment. This review was conducted pursuant to the NCP
Section 300.430(f) (4) (ii). The next five-year review will be
conducted within five years of this Decision. At that time, the
monitoring results will be reviewed to determine if drinking water
standards have been met. In addition, a review of standards or
ARARs will be performed.
Compliance with ARARs:
The selected remedy will achieve ARARs, specifically the Safe
Drinking Water Act (SDWA) Maximum Contaminant Levels (40CFR 141.11-
141.16), 6NYCRR Groundwater Quality Regulation (Parts 703.5, 703.6,
703.7) and NYS Sanitary Code 10NYCRR Part 5 for contaminants in
drinking water, over time through natural attenuation. Compliance
with ARARs would be demonstrated through an annual groundwater
monitoring program.
Cost-Effectiveness:
The modified selected remedy is cost-effective and provides'the
greatest overall protectiveness proportionate to costs.
Utilization of Permanent Solutions and Alternative Treatment
Technologies (or Resource Recovery Technologies) to the Maximum
Extent Practicable: .
The modified selected remedy represents the maximum extent to which
permanent solutions and treatment technologies can be utilized in a
cost-effective manner at the Site.
'Preference for Treatment as a Principal Element:
Treatment of the aquifer-at-large is determined not to be cost-
effective at this Site.
17
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APPENDIX I
Concurrence Letter from the NYSDEC
-------
of EnTiปปซ'ซ' Couservation
Albany, New York 12233-7010
Hit uur
SEP 23 1997
Mr. Richard Caspe
Director
Emergency*: Remedial Response Division PoaW Fax Note 7671
U.S. Environmental Protection Agency
Region n
290 Broadway
New York, NY 10007-1866
John P. Cahlll
Commissioner
Covo.pt
PhonM
Co.
Fwt
Dear Mr. Caspe:
Re: Preferred Plating Corporation ID No. 152030
decision^dm Yฐ* *** ^P**"1"* <* Environmental Conservation approves of the record of
amendment, the major modification to the origin^Tedy wW beT*'" *** fTOfOK* RฐD
1. elimination of the groundwater extraction and treatment system portion of the 1989
selected remedy;
2. implementation of an annual groundwater monitoring program to ensure that the rcmedv
remains protective of human health and the environment. X
Please contact Sal Ervolina at (518) 457-4349 if you have any questions.
Sincerely,
Michael J.OTooleljr
Director
Division of Environmental Remediation
c: D. Garbarini, USEPA-Region II
be:
J. Cahill
M. O'Toole (2)
T. Quinn
S. Ervolina
M. Chen/File
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APPENDIX II
Index for the Administrative Record
-------
PREFERRED PLATING CORPORATION
OPERABLE UNIT ONE
ADMINISTRATIVE RECORD FILE UPDATE
INDEX OF DOCUMENTS
RECORD OF DECISION
Amendments to the Record of Decision
903-961 Report: Superfund Support Sampling Inspection
Report. Preferred. Plating. Farmingdale. New York.
August 17-18. 1993. prepared by Mr. David Dugan,
Environmental Scientist, Source Monitoring
Section, U.S. EPA, approved for the Director by
Richard D. Spear, Ph.D., Chief, Surveillance and
Monitoring Branch, U^S. EPA, December 16, 1993.
962-1023 Report: Superfund Support Sampling Inspection
Report. Preferred Plating. Farmingdale. New York.
July 13-14. 1994f prepared by Mr. David Dugan,
Environmental Scientist, Source Monitoring
Section, U.S. EPA, approved for the Director by
Richard D. Spear, Ph.D., Chief, Surveillance and
Monitoring Branch, U.S. EPA, October 5, 1994.
1024-1106 Report: Superfund Support Sampling Inspection
Report. Preferred Plating. Farmingdale. New York.
April 3-6. 1995. prepared by Mr, Michael A.
Mercado, Environmental Scientist, U.S. EPA,
approved for the Director by Richard D. Spear,
Ph.D., Chief, Surveillance and Monitoring Branch,
U.S. EPA, August 22, 1995.
1107-1185 Report: Sampling Report and Data Presentation.
Preferred'Plating. Farmingdale. New York.
Groundwater Sampling Event. August 27-29.- 1996r
prepared by Mr. Michael A. Mercado, Environmental
Scientist, Hazardous Waste Support Branch
(DESA/HWSB), U.S. EPA, approved by Mr. Robert
Runyon, Chief, Hazardous Waste Support
Branch(DESA/HWSB), U.S. EPA, undated.
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P. 1186-1192 Plan: Superfund Proposed Plan. Preferred Plating
Corporation Superfund Site. Farmingdale. New York.
prepared by U.S. EPA, July 1997.
-------
APPENDIX III
Responsiveness Summary
-------
APPENDIX III
RESPONSIVENESS SUMMARY
PREFERRED PLATING CORPORATION SUPERFUND SITE
INTRODUCTION
A responsiveness summary is required by Superfund regulation. It
provides a summary of citizens' comments and concerns, which in
this instance were raised at the August 7, 1997 public meeting. It
also includes the responses of the United States Environmental
Protection Agency (EPA) and the New York State Department of
Environmental Conservation (NYSDEC) to those comments and concerns.
All comments summarized in this document have been considered in
EPA and NYSDEC's final decision for the selected remedy for the
Preferred Plating Corporation site (Site).
SUMMARY OF COMMUNITY RELATIONS ACTIVITIES
Community interest in the Site has been low throughout the remedial
investigation and feasibility study (RI/FS) process during all
three operable units.
The Post-Decision Proposed Plan (PDPP) for the Site was released to
the public for comment on July 31, 1997. This document, together
with the Sampling Inspection Reports and the original operable unit
1 (OU1) RI/FS, was made available to the public in the Administra-
tive Record file at the EPA File Room in Region II, New York, and
in the information repository located at the Babylon Town Hall,
Town Clerk's Office, 200 East Sunrise Highway, Lindenhurst., New
York. The notice of availability for the above-referenced
documents was published in the Farming-dale Observer on August 1,
1997 and again on August 8, 1997. The public comment period on
these documents was open from July 31, 1997 to August 30, 1997.
EPA conducted a public meeting on August 7, 1997 at the W.E. Howitt
Jr. High School in Farmingdale, New York to discuss the PDPP for
the Site and to provide an opportunity for the interested parties
to present oral comments and questions to EPA. Three individuals
attended the public meeting. Comments raised at the public meeting
reflected public support of the proposed amended remedy. No
written comments were received by EPA.
Attached to the Responsiveness Summary are the following
Appendices:
Appendix A - Post-Decision Proposed Plan
Appendix B - Public Notice
Appendix C - August 7, 1997 Public Meeting Attendance Sheet
Appendix D - August 7, 1997 Public Meeting Transcript
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SUMMARY OF COMMENTS AND RESPONSES
Comments expressed at the August 7, 1997 public meeting and EPA's
responses to them are summarized below.
Comment fll: A representative from Suffolk County Department of
Health Services (SCDHS) asked about the possibility of a plume of
contamination leaving the former PPC property.
EPA7 s response #1: There has been no evidence indicating that a
plume of contamination is migrating from the former PPC property.
EPA installed two separate deep groundwater monitoring wells
downgradient of the former PPC property in an attempt to identify a
potential plume. Monitoring well MW7DP, installed approximately
1/4 mile southeast of the former PPC property, was screened at a
depth of 60 to 70 feet below grade. Monitoring well MW8DP,
installed approximately 1/2 mile south-southwest of the former PPC
property, was also screened at a depth of 60 to 70 feet below
grade. Both wells were sampled in 1988 and no heavy metal
contaminants were detected above drinking water standards. Only
two organic compounds were found to exceed standards slightly. '
Additionally, data provided to EPA by SCDHS regarding a shallow
well sampled in 1994, located approximately 50 feet south of the
former PPC property, showed the presence of only chromium at 63
ppb, well below its drinking water standard of 100 ppb. No cadmium
was found in this well. Based on the preceding, EPA concluded that
a contaminated plume is not migrating from the former PPC property.
Comment ft 2: A representative from SCDHS asked whether the annual
groundwater monitoring and data evaluation would be performed
utilizing only the wells on the former PPC property, or could
additional data from other wells be included?
EPA7 s response #2: While the annual monitoring program would focus
on the wells installed on the former PPC property, additional
commercial or residential wells in the vicinity of the former PPC
property could be included. <
Comment #3: A local property owner inquired as to the identity of
the Site's potentially responsible parties (PRP), whether the PRPs
had funded any of the studies or remediation activities, and
whether EPA had attempted to recover costs from the PRPs. '
EPA's response #3: The names of the PRPs for the Site are Joseph
Gazza and George Paro, who are the current owners of the property
formerly occupied by the Preferred Plating Corporation. In June
1993, EPA issued an Administrative Order to the property owners to
excavate the underground leaching pits and associated contaminated
soils and sediments. This work was successfully completed in June
1994. To date, EPA has not recovered any costs from these property
owners.
Comment #4: A representative from SCDHS asked whether the soil
remediation involved the dismantlement of the existing on-site
building.
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EPA's response #4: A large section of the existing on-site
building was dismantled during the implementation of the soils
remedy to allow for complete excavation of the underlying leaching
pits and soils/sediments beneath them.
Comment #5: A local property owner questioned how the contaminants
could leach to underlying groundwater without infiltration of rain
water since the original pits were beneath the on-site building.
EPA's response #5: Originally, the leaching pits were not covered
by a building, but exposed to infiltration of rainwater and runoff.
Even with the building extension covering the pits, the underlying
watertable was found to fluctuate as much as eight feet depending
on the season. The bottoms of the concrete pits were cracked,
allowing groundwater associated with a high water table to enter,
thereby contaminating the underlying groundwater.
Comment #6: A representative of the Town of Babylon asked whether
it was unusual to see such a dramatic drop in contaminant
concentration levels after the source removal given the fact that a
plume does not seem to be migrating from the former PPC property.
EPA's response #6: It is EPA's belief that the original two rounds
of sampling contained very turbid water and were not completely
representative of the true concentrations in the underlying
groundwater. As our sampling techniques improved, specifically the
use of low-flow pump technology, the turbidity of the samples
decreased and the contaminant concentrations for heavy metals
decreased as well. That, together with the source removal,
accounts for the significant decline in concentrations detected in
the latest two rounds of sampling.
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APPENDIX A
POST-DECISION PROPOSED PLAN
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Superfund Proposed Plan"
PREFERRED PLATING CORPORATION
SUPERFUND SITE
Farmingdale, New York
EPA
Region 2
July 1997
PURPOSE OF POST-DECISION PROPOSED PLAN
This Post-Decision Proposed Plan describes proposed
fundamental changes to the September 1989 Record of
Decision (ROD) issued by the United States
Environmental Protection Agency (EPA) with respect to
the Preferred Plating Corporation (PPC) Superfund site
(Site) and concurred on by the New York State
Department of Environmental Conservation (NYSDEC).
The remedy specified in the 1989 ROD required the
extraction and treatment of groundwater contaminated
mainly with cadmium and chromium.
As described in this Post-Decision Proposed Plan, EPA is
proposing that the extraction and treatment of ground-
water is no longer necessary to ensure the protection of
human health and the environment
COMMUNITY ROLE IN SELECTION PROCESS
EPA and NYSDEC rely on public input to ensure that the
concerns of the community are considered in selecting an
effective remedy for each Superfund site. Similarly, EPA
and NYSDEC also rely on public input when proposing
fundamental changes to a remedy previously selected. To
this end, this Post-Decision Proposed Plan and the
Sampling Inspection Reports have been made available to
the public for a public comment period which begins on
July 31,1997 and concludes on August 30,1997.
A public meeting will be held during the public comment
period at the W.E. HowittJr. High School on Thursday,
August 7,1997 at 7:00 p.m. to present the basis for the
proposed amendment to the 1989 ROD and to receive
public comments. Comments received at the public
meeting, as well as written comments, will be documented
in the Responsiveness Summary Section of this ROD
amendment.
All written comments should be addressed to:
Janet Cappelli
U.S. Environmental Protection Agency
290 Broadway - 20th Floor
New York, NY 10007-1866
DATES TO REMEMBER
July 31,1997 to August 30,1997
Public comment period on
Post-Decision Proposed Plan
- Thursday, August 7,1997 - 7:00 p.m.
Public meeting at the W.E. Howitt Jr. High School
Vancott and Grant Avenues '
Farmingdale. New York .
Copies of the Sampling Reports, the Post-
Decision Proposed Plan and supporting
documentation are available at the following
locations:
West Babylon Library
211 Route 109 -
West Babylon, New York 11704
TeL (516) 669.5445
Hours:Mon-Thurs., 10:00 a.m. to 9:00 p.m.
Fri-SaL, 10:00 a.m. to 5:00 p.m.
Babylon Town Hall
Town Clerks Office
200 East Sunrise Highway
Lindenhurst, New York 11757
Tel. (516) 957-3005
Hours: Mon-Fri.. 9:00 a.m. to 4:00 p.m.
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SITE BACKGROUND
The PPC site includes the former PPC facility located at
32 Allen Boulevard in Farmingdale, Town of Babylon,
Suffolk County, New York. The PPC site, approximately
one acre in size, is situated in a light industrial area one
mile east of the Nassau-Suffolk County line.
The Site is almost entirely covered by a building and
pavement with two small grassy areas on the southern
end and a gravel and grass strip located along the west
side of the building. Most of the homes and businesses in
the vicinity of the Site are served by a public water supply
from the East Farmingdale Water District The nearest
public water supply well field is within one mile south of the
Site, which is hydraulically downgradient
Between September 1951 and June 1976, PPC conducted,
metal-plating operations to increase the corrosion
resistance of metal parts and to provide a more cohesive
base for painting. The primary activities at the PPC facility
included degreasing, cleaning, and chemically treating the
surface of metal parts. These processes involved the use
of various chemicals which resulted in the generation,
storage, and disposal of hazardous substances.
Untreated wastewater was discharged into four below-
grade concrete storage pits located directly behind the
original building.
Groundwater contaminated with heavy metals was
detected in the immediate vicinity of the Site as early as
June 1953. During an inspection of the PPC facility by the
Suffolk County Department of Health Services (SCDHS), it
was discovered that the storage pits were cracked and
leaking. Samples taken from the pits showed the major
contaminants to be heavy metals. From 1953 to 1976,
SCDHS instituted numerous legal actions against PPC in
an effort to stop discharges to the pits and to upgrade the
on-site treatment system. PPC prepared an engineering
report in May 1974 in order to apply for a State Pollutant
Discharge Elimination System (SPDES) permit which was
issued in June 1975. PPC claims to have chemically
treated the wastewater in the pits and had the waste
material removed from the Site, but no documentation
supittrting this action exists. The facility was never in full
compliance with the terms and conditions outlined in .the
SPDES permit . ป
In June 1976, PPC declared bankruptcy. Since then,
several firms have occupied the Site, none of which
conducted similar operations. In 1982, the original building
was extended to the north by 200 feet and the four waste
storage pits were filled and covered by the newly
constructed extension.
In September 1984. the NYSDEC issued a Phase I
Investigation Report which summarized past investigations
and included a Hazard Ranking System (HRS) score for
the Site. Based on the HRS score, the Site was proposed
for inclusion on the National Priorities List (NPL) of
hazardous waste sites in October 1984 and was placed on
the NPL in June 1986, which brings the Site under the
purview of the Federal Superfund Program.
From June 1987 to June 1989, Ebasco Services, Inc.,
EPA's contractor, conducted the initial remedial
investigation/feasibility study (RI/FS) of the Site. The
study detected heavy metals and chlorinated organics in
the groundwater underlying the Site, however, it did not
completely identify the source and the extent of
contamination within the soils underlying the former
storage pits. Therefore, the first operable unit study (OU1)
focused only on a remedy for the treatment of the
contaminated groundwater. The study resulted in a ROD
which was signed on September 22,1989. The major
components of that remedy included extraction of the
contaminated groundwater, treatment of heavy metals and
chlorinated organics, and reinjection of the treated
groundwater. The design for this treatment system was
completed in March 1992. The construction of the
groundwater treatment system was postponed while EPA
completed its investigation of the contaminant source
areas.1
EPA undertook a second RI/FS, which was conducted by
Malcolm Pimie, Inc., to study the contaminant source
areas, i.e., the soils within and directly beneath the former
leaching pits. A second operable unit (OU2) ROD for
excavation and off-site treatment and disposal of the
contaminated soils and sediments was signed on
September 28,1992. The remediation, resulting in the
removal and off-site disposal of approximately 1500 tons
of contaminated soils and sediments, was performed by
the site owners with EPA oversight and was completed in
June 1994.
The OU1 RI/FS also indicated contamination in monitoring
wells located upgradient of the PPC facility source area.
Therefore, a third RI/FS was conducted to address a
potential source of groundwater contamination upgradient
of the PPC facility. The upgradient property owner, Del
Laboratories, Inc., initiated an RI/FS in September 1990 to
determine if its operations had impacted the groundwater
quality beneath the PPC Site. The third operable unit
(OU3) ROD, signed in September 1993, determined that
no remedial action was necessary based on prior actions
which had been taken to address environmental conditions
at the Del Laboratories, Inc. facility.
'//> March 1992. EPA recognized that the contaminant
source areas would need to be addressed prior to the
construction of the groundwater treatment system and the likely
approach to remediating the source areas would involve
excavation beneath the existing building on the Site. The
postponement of the construction of the groundwater treatment
system was necessary because the limited space on the Site
would not permit source area excavation and groundwater
treatment system construction to occur simultaneously.
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SUMMARY OF GROUNDWATER SAMPLING
Based on two rounds of sampling data, obtained in August
and September of 1988, from 9 on-site and 2 off-site
monitoring wells, the OU1 Rl documented the presence of
heavy metals and chlorinated organic compounds in the
groundwater underlying the Site. The primary
contaminants of concern were chromium and cadmium;
chromium was detected at 5850 parts per billion (ppb) and
cadmium at 399 ppb. Lead, nickel, and 1,1,1-
trichloroethane (TCA) were also identified as contaminants
of concern.
Subsequent sampling activities focussed on metals
contamination, particularly cadmium and chromium. The
maximum concentrations of cadmium and chromium
detected during these subsequent, sampling events are
provMed in Table 1. The results clearly indicate a
significant decrease in the concentration of the primary
contaminants of concern. The first round of samples
collected after issuance of the OU1 ROD was obtained
performance of a treatabilrty study for the groundwater
treatment system remedial design. The highest levels of
contamination had decreased significantly to 1850 ppb of
chromium and 254 ppb of cadmium. In August 1993, prior
from the on-ste wells in February 1991 during to
implementation of OU2 construction activities for the
source removal, another round of samples was collected.
The highest levels of contamination detected in this event
had decreased further to 560 ppb of chromium and 123
ppb of cadmium. In July 1994, after the OU2 remediation
activities were implemented, all wells were sampled to
monitor the effect of source removal. The highest levels of
contamination detected had increased to 1630 ppb for
chromium and 136 ppb for cadmium. However, the
chromium concentration of 1630 ppb was measured in a
sample collected from Well 1SP; the water from this well
was extremely turbid. The same sample upon filtering
yielded a much lower concentration of chromium at 35
ppb, indicating that the higher unfiltensd reading was
mostly a result of the sample turbidity. In the next round of
sampling in April 1995, a technique using a tow-flow pump
was utilized in an effort to collect representative samples
of the aquifer while minimizing sample turbidity.2 The
highest levels of contamination detected decreased to 83
ppb for chromium and 43 ppb for cadmium. The low-flow
technique was also utilized in sampling conducted in
August 1996; the highest detected concentrations, 57 ppb
FIGURE 1-SITE MAP
^Groundwater typically occurs naturally in the Upper
Glacial Aquifer at low turbidity levels. Elevated samplf
turbidity may be an artifact of sample collection and veil
construction techniques. The high turbidity associated with .
samples collected in 1988 raises the issue of whether the
reported results were representative of the aquifer. EPA
believes that the detected contaminant levels, especially for
chromium, were uncharacteristically high and indicative of
highly turbid samples rather than representative of the aqvtfer.
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TABLE 1 - MAXIMUM CONTAMINANT CONCENTRATIONS (ppb)
DATE OF SAMPLING EVENT
AUGUST 1988
SEPTEMBER 1988
FEBRUARY 1991
AUGUST 1993
JULY 1994
. APRIL 1995
AUGUST 1996
CADMIUM
399
348
254
123
136
43
48
CHROMIUM
5850
3390
1850
560
1630 (35 filtered)
83
57.
for chromium and 60 ppb for cadmium, were very similar
to those found in the April 1995 sampling.
Throughout the sampling events, organics were detected
infrequently and at low levels. The most frequently
detected contaminant was TCA. Concentrations of TCA
ranged from 1.9 to 17 ppb. The last round of sampling,
collected in August 1996, detected TCA ranging from 2 to
5 ppb and one detection of trichloroethene at 19 ppb; the
drinking water standard for both of these contaminants is
5 ppb.
The two off-site monitoring wells, MW-7 and MW-8, are
located 1200 and 2400 feet, respectively, downgradient of
the Site. Both are deep wells, screened at the bottom of
the Upper Glacial aquifer. MW-7 was only sampled in
August and September of 1988. Neither cadmium nor
chromium were detected above any standards. Lead was
detected at 30.3 ppb. MW-8 was sampled in August and
September 1988, July 1994, and May 1995. Tetra-
chloroethene and 1,1,1-trichloroethane were detected
slightly above MCLs in this well, but no heavy metal
contamination was ever detected.
The only surface water body in the Site vicinity is an
unnamed, intermittent tributary to Massapequa Creek. It is
located about 6,000 feet west, or side-gradient, of the Site.
During the first sampling period in 1988, this creek was
dry. Since it is not in the direction of groundwater flow, no
impact to the creek is believed to exist due to Site
contaminants.
Over the past several years, the sampling results have
indicated a significant decrease in concentrations of the
primary contaminants of concern, cadmium and chromium.
The decline is most directly attributable to the removal of
the on-site source. Better sampling techniques to
minimize the turbidity of the groundwater have also been
helpful in providing a more accurate measurement of
contamination. At present, only cadmium exceeds both its
federal and state drinking water standards. Chromium
does not exceed either the federal or state drinking water
standard of 100 ppb, but does very slightly exceed the
state groundwater quality standard of 50 ppb. TCA, the
only organic consistently detected throughout the sampling
activities, slightly exceeded its state drinking water
standard in 3 out of 10 wells from the April 1995 sampling
round. However, TCA was not detected above standards
in any of the samples collected in August 1996.
SUMMARY OF SITE RISK
During the performance of the OU1 RI/FS, a baseline risl
assessment was conducted to estimate the risks
associated with current and potential (future) site
conditions. The baseline risk assessment, which was
based on data obtained only during the OU1 RI/FS,
estimated the human health and ecological risk which
could result from the contamination at the Site, if no
remedial action were taken. A summary of the baseline
risk assessment and a recalculation of the risk using
current data are presented below.
There were no risks associated with the current uses of
the Site, because the Site is covered by a building and
pavement, the only potential pathway with a risk to the
public was determined to be ingestion of contaminated
groundwater. Although the 1988 OU1 groundwater
sampling did indicate high levels of heavy metal
contamination, there was no direct human exposure to
contaminants since the surrounding population is supplied
by public water. However, the Upper Glacial Aquifer is
classified as lib, or a potential drinking water source, and
therefore, a potential risk to human health would exist in .
the event that this aquifer were developed for use. The
baseline risk assessment evaluated the health effects
which could result from exposure to contamination as a
result of ingestion for a future-use scenario.
A comparison, in 1989, of the concentrations of chemicalj
in the groundwater with applicable or relevant and
-------
appropriate requirements (ARARs) indicated that
numerous inorganic and organic compounds exceeded
those ARARs. Based on this comparison, the inorganics
cadmium, chromium, lead, nickel and cyanide were
evaluated and modeled in the risk assessment. Although
not all of the organic contaminants of concern exceeded
ARARs, they were carried through the risk assessment in .
order to obtain a collective assessment of risk from
concurrent exposure to multiple contaminants. At present,
a comparison of the concentration of chemicals in the
1995 and 1996 groundwater samples with ARARs
indicates that only cadmium, chromium, TCA, and one
detection of trichloroethylene exceed their respective
ARARs, with TCA only slightly above its ARAR.
EPA's acceptable cancer risk range is 10"4 to 10"6, which
can be interpreted to mean that an individual may have
one in ten thousand to one in a million increased chance of
developing cancer as result of site-related exposure to a
carcinogen over a 70-year lifetime under the specific
exposure conditions at a site.
The results of the baseline risk assessment conducted as
part of the 1989 RI/FS indicated that if, in the unlikely
event that the groundwater were used as a source of .
drinking water, the Site posed unacceptable risks to
human health and the environment. The risk assessment
was based on a worst case total lifetime exposure to maxi-
mum organic concentrations at an assumed constant rate
(drinking 2 liters of water daily for 30 years in an adult,
living to the age of 70 years). Utilizing the data from the
1995 and 1996 sampling events, it was determined that
|he total cancer risk for the future-use scenario was
Tx lO^i.e., one-in-one-hundred thousand), which is within
EPA's acceptable cancer risk range.
To assess the overall potential for noncarcinogenic effects
posed by more than one contaminant, EPA has developed
a hazard index (HI). This index measures the assumed
exposures to several chemicals simultaneously at low
concentrations which could result in an adverse health
effect. When the HI exceeds one, there may be concern
for potential noncarcinogenic effects. The 1989 OU1
RI/FS calculated the HI under a worst case scenario for
cadmium and chromium as 22.8 and 170, respectively.
However, the significant decrease in contaminant levels
over the past several years has resulted in a significant
decrease in associated risk levels. Under present
conditions, using the sampling data from 1995 and 1996,
the recalculated HI for cadmium and chromium is 2.2 and
0.06, respectively.
The significant noncarcinogenic risk from potential future
consumption of the Upper Glacial Aquifer because of the
previous high incidence of cadmium and chromium
contamination no longer exists. The HI is currently only
slightly above the acceptable HI of 1 because of the
presence of cadmium. Furthermore, any risk is associated
with an unlikely future-use scenario, since the Upper
Iplacial Aquifer is not used as a drinking water supply.
REMEDIAL ACTION OBJECTIVES
Remedial action objectives are specific goals to protect
human health and the environment. These objectives are
based on available information and standards such as
applicable or relevant and appropriate requirements
(ARARs) and risk-based levels established in the risk as-
sessment.
The objective of the OU1 feasibility study was to identify
and evaluate a cost-effective remedial action alternative
which would minimize the risk to public health and the
environment resulting from groundwater contamination at
the Site. The FS report had evaluated in detail 7 remedial
alternatives for addressing the contamination associated
with the Site. The remedy which EPA selected included
extraction and treatment of contaminated groundwater.
Given the significant decrease in site-related groundwater
contaminant levels over the past several years, EPA has
reevaluated the groundwater extraction and treatment
remedy specified in the 1989 OU1 ROD. The remedial
action objectives for the groundwater remedy are to (1)
protect human health by ensuring future residents are not
exposed to contaminated groundwater, and (2) reduce
groundwater contamination levels to drinking water stan-
dards.
SUMMARY OF REMEDIAL ALTERNA TIVES
CERCLA requires that each selected site remedy be
protective of human health and the environment, be cost-
effective, comply with other statutory laws, and utilize
permanent solutions and alternative treatment technolo-
gies and resource recovery alternatives to the maximum
extent practicable. In addition, the statute includes a
preference for the use of treatment as a principal element
for the reduction of toxicity, mobility, or volume of the
hazardous substances. .
The alternatives for addressing groundwater contamina-
tion are provided below and are identified as GW-1 and
GW-2. Consistent with ROD amendment guidance, the
components of the original remedy (described below as
Alternative GW-2) which has been proposed for
amendment have been updated and are being compared
to a newly designed Alternative, GW-1, which was
developed based upon existing Site conditions, including
the groundwater monitoring data presented above.
Alternative GW-1 - No Further Action/Natural
Attenuation
Capital Cost:
O & M Cost:
Present Worth Cost:
Time to Implement:
$0
$5000/year (for 5 years)
$19,588
immediate
This alternative does not include active treatment of the
aquifer; it relies upon natural attenuation to reduce the
contamination below federal and state drinking water stan-
-------
dards and/or groundwater quality standards. A monitoring
program would be implemented on an annual basis to
demonstrate the effectiveness of the naturally occurring
mechanisms. Since contaminants will remain on the Site
above health-based risk levels. EPA will conduct a five-
year review to ensure that the remedy is protective of
human health and the environment. If the natural
attenuation of contaminants in the groundwater at the Site
has not improved groundwater quality to federal drinking
water standards and state drinking water and groundwater
standards, EPA and NYSDEC will reevaluate the need for
-an active treatment at the Site.
Alternative GW-2: Extraction/Precipitation of Divalent
Metals/Ion Exchange/Activated Carbon/Reinjection
Capital Cost:
O & M Cost:
Present Worth Cost:
Time to Implement:
$1.923.900
$ 920.900
$ 9,327,400
1Year
This alternative consists of the extraction and on-site
treatment of contaminated groundwater. Groundwater
would be extracted from one on-site collection well. The
extracted groundwater would first go through a 2-stage
precipitation and clarification/filtration unit for the removal
of divalent metals, followed by an ion exchange process
for the removal of the chromate ion, and if necessary, a
carbon adsorption unit for removal of volatile organic
compounds. The metals treatment would generate
hazardous waste residuals requiring ultimate disposal in a
Resource, Conservation and Recovery Act Subtitle C
facility. The treatment scheme is a proven technology
capable of removing the contaminants of concern from the
groundwater. The extracted groundwater would be treated
to satisfy all federal and state standards for Class lib
waters, i.e., potential drinking waters, prior to reinjection.
The treated groundwater would be discharged to a
reinjection well installed east of the Site and upgradient of
both the extraction well and former leaching pits. In order
to evaluate the effectiveness of this remedial action,
periodic sampling for metal and volatile organic
concentrations in the groundwater would be required prior
to reinjection.
EVALUATION OF ALTERNATIVES
During the detailed evaluation of remedial alternatives,
each alternative is assessed against nine evaluation
criteria set forth in Federal Regulation. The nine criteria
are overall protection of human health and the envi-
ronment, compliance with applicable or relevant and
appropriate requirements, long-term effectiveness and
permanence, reduction of toxicity, mobility, or volume,
short-term effectiveness, implementability, cost, and state
and community acceptance.
The evaluation criteria are described below.
A . Overall protection of human health and the envi-
ronment addresses whether or not a remedy pro-
vides adequate protection and describes how risks
posed through each pathway are eliminated, reduced, or
controlled through treatment, engineering controls, or
institutional controls.
* Compliance with applicable or relevant and
appropriate requirements addresses whether a
remedy will meet the applicable or relevant and
appropriate requirements of other federal and
state environmental statutes and requirements
or provide grounds for invoking a waiver.
A Long-term effectiveness and permanence refers
to the ability of a remedy to maintain reliable
protection of human health and the environment
over time, once cleanup goals have been met.
* Reduction of toxicitv. mobility, or volume through
treatment is the anticipated performance of the
treatment technologies that a remedy may
employ.
A Short-term effectiveness addresses the period of
time needed to achieve protection and any ad-
verse impacts on human health and the
environment that may be posed during the
construction and implementation period until
cleanup goals are achieved.
A Implementabilitv is the technical and administra-
tive feasibility of a remedy, including the avail-
ability of materials and services needed to impl^jj
ment a particular option.
A Cost includes estimated capital and operation
and maintenance costs, and net present worth
costs.
A State acceptance indicates whether, based on
its review of the RI/FS reports and Post-Decision
Proposed Plan, the state concurs, opposes, or
has no comment on the preferred alternative at
the present time.
A Community acceptance will be assessed in the
Record of Decision (ROD) following a review of
the public comments received on the RI/FS
reports and the Post-Decision Proposed Plan.
A comparative analysis of these alternatives based upon
the evaluation criteria noted above follows.
A Overall Protection of Human Health and the
Environment
Both Alternatives are similar in their abilities to protect
human health and the environment. As noted above in the
risk assessment section, there are ho current use risks
associated with the contamination at the Site. The Site
groundwater is not being used as a source of drinking
water. In addition, no significant impacts to ecological
-------
receptors have been observed. The future use
carcinogenic risks at the Site are within EPA's risk range,
and the noncarcinogenic risks are just slightly above
EPA's acceptable level; however, these risks assume that
the Site groundwater will be utilized as a potable water
supply, an event that is highly unlikely.
As there are no current or anticipated future users of the
Site groundwater and since the levels of contaminants in
the groundwater have decreased dramatically in the last
few years and are expected to drop below drinking water
and groundwater quality standards in the future, EPA
believes that both GW-2 and GW-1 would provide full
protection of human health and the environment.
Compliance with ARARs
*
Since the impacted groundwater underlying the Site is a
potential future source of drinking water, federal and state
drinking water standards, as well as state groundwater
quality standards, are ARARs. For Alternative GW-1,
ARARs would be achieved over time through natural
attenuation; compliance with ARARs would be
demonstrated through an annual monitoring program. For
Alternative GW-2, compliance with ARARs for the aquifer
would be achieved through extraction and active treatment
for removal of metals. The treated groundwater would
meet appropriate .standards prior to being reinjected.
Residual sludges from the treatment system would be
treated and disposed of in accordance with RCRA
regulations.
Long-Term Effectiveness and Permanence
Alternative GW-1 is expected, over time, to provide the
same level of long-term effectiveness and permanence as
Alternative GW-2. Alternative GW-2 would potentially
result in greater long-term exposure to contaminants by
workers who would come into contact with the
concentrated sludges from the treatment system.
However, proper health and safety precautions would
minimize any adverse impacts through treatment.
A Reduction in Toxicity. Mobility or Volume Through
Treatment
Alternative GW-2 would reduce the toxicity, mobility and
volume of contaminated groundwater through extraction
and subsequent treatment. Alternative GW-2 would
potentially achieve this reduction in a shorter timeframe
than Alternative GW-1, which relies solely on natural
attenuation, and does not actively reduce the toxicity,
mobility or volume of contaminants in the groundwater.
* Short-term Effectiveness
Although GW-2 would potentially achieve cleanup goals in
a shorter time-frame than GW-1, this is not expected to be
significant. This is supported by the fact that groundwater
bontaminant levels have decreased so significantly over
the past several years.
Alternative GW-1 presents virtually no short-term impacts
to human health and the environment since no
construction is involved. The construction activities
required to implement Alternative GW-2 would have
potentially negative impacts on site workers and nearby
residents. While efforts would be made to minimize these
impacts, some disturbances would result from disruption of
traffic, excavation activities on public and private land,
noise, and fugitive dust emissions. It is estimated that the
construction activities for Alternative GW-2 would take
approximately 12 months to complete.
* Implementability
The technologies proposed for extraction and treatment of
contaminated groundwater in Alternative GW-2 are proven
and reliable in achieving the specified cleanup goals,
however, Alternative GW-2 would be much more complex
than Alternative GW-1 to implement. Alternative GW-1
does not involve any construction and is much easier to
implement as it only requires a monitoring program
utilizing existing monitoring wells.
* Cost
Alternative GW-1 has no direct costs associated with its
implementation. The present worth of this alternative of
$19,588 is for implementation of an annual groundwater
monitoring program for a duration of 5 years. The capital
and present worth costs of Alternative GW-2 are estimated
to be approximately $1,923,900 and $9,327,400,
respectively.
* State Acceptance
The State of New York concurs on the proposed modified
remedy.
* Community Acceptance
Community acceptance of the preferred alternative will be
assessed in the ROD amendment following review of the
public comments received on this Post-Decision Proposed
Plan.
PREFERRED ALTERNATIVE
Based upon an evaluation of the various alternatives, EPA
and NYSDEC recommend Alternative GW-1, No Further
Action/Natural Attenuation.
The Post-Decision preferred alternative provides the best
balance of trade-offs between alternatives with respect to
the evaluating criteria. EPA and the NYSDEC believe that
the preferred alternative will be protective of human health
and the environment, will comply with ARARs, will be cost-
effective, and will utilize permanent solutions and alterna-
tive treatment technologies or resource recovery technolo-
gies to the maximum extent practicable.
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APPENDIX B
PUBLIC NOTICE
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Public Meeting
The U.S. Environmental Prelection Agency Will hold a public
meeting on the Post-Decision Proposed Plan for the Preferred Plating
Superfund Site in Farmingdale, New York. Based on samples collected
after the cleanup of site soil, EPA is proposing tp modify the original
groundwater remedy chosen for this site '-< 1989 to no farther action/
natural attenuation. The new proposed cleanup plan will be protective
of human health and the environment.
Pliblk Meeting
Thursday, August 7.1997
7,00 p.m. - 9iOO p.m.
W.E. Howitt Junior High School
Vancott A Grant Avenues
Farmingdale, New York
A 30iday public comment period begins July 31, 1997 and ends August
30, 1997. All written/oral comments may be submitted by August 29 to:
Janet Cappelli, Project Manager, U.S. EPA, 290 Broadway, 20th Fl., New
York. NY 10007 or call (212) 637-4270.
Copies of the Post-Decision Proposed Plan are available for
review at the Babylon Town Hall and the West Babylon Library.
For more information, contact Cecilia Echols
US. EPA Community Involvement Coordinator
1-800-346-5009
Public Meeting
The U.S. Environmental Protection Agency will hold a public
meeting on the Post-Decision Proposed Plan for the Preferred Plating
Superfund Site in Farmingdale, New York. Based on samples collected
after the cleanup of site soil, EPA is proposing to modify the original
groundwater remedy chosen for this site in 1989 to no further action/
natural attenuation. The new proposed cleanup plan will be protective
of human health and the environment.
Public Meeting
Thursday, August 7,1997
7:00 p.m. - 9:00 p.m.
W.E. Howitt Junior High School
Vancott & Grant Avenues
Farmingdale, New York
A 30-day public comment period begins July 31,1997 and ends August
30,1997. All written/oral comments may be submitted by August 29 to:
Janet Cappelli, Project Manager, U.S. EPA, 290 Broadway, 20th Fl., New
York, NY 10007 or call (212) 637-4270.
Copies of the Post-Decision Proposed Plan are available for
review at the Babylon Town Hall and the West Babylon Library.
For more information, contact Cecilia Echols
US. EPA Community Involvement Coordinator
1-800-346-5009
"Faroingdale Observer" August 1, 1997 and August 8, 1997
-------
APPENDIX C
AUGUST 7, 1997 PUBLIC MEETING ATTENDANCE SHEET
-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION II
Public Meeting
Preferred Plating Superfund Site
Parmingdale, New York
Thursday, Auguat 7, 1997
ATTENDEES
(Please Print Clearly)
NAME
STREET
-
-ฃjr*M' J*/ PUrt LA.
CT
CITY
ZIP
PHONE
[17f(
REPRESENTING
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APPENDIX D
AUGUST 7, 1997 PUBLIC MEETING TRANSCRIPT
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1
2 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION II
3
4
Public Meeting - Post-Decision Proposed Plan
5 for the Preferred Plating Corporation Superfund Site
Farmingdale, New York
6
7
8 August 7, 1997
7:00 p.m.
9
10
W. E. Howitt Jr. High School
11 Vancott and Grant Avenues
Farmingdale, New York
12
13 PRESENT:
Introduction Cecilia Echols
15 Community Involvement Coordinator
U.S. EPA, Region 2
16
17
18
Superfund Overview Doug Garbarini
19 Superfund Section Chief
Eastern NY Section
20 , U.S. EPA, Region 2
21
Site Background Janet Cappelli
22 Remedial Project Manager
U.S. EPA, Region 2
23
24
25
FINK & CARNEY
COMPUTERIZED REPORTING SERVICES
24 West 40th Street, New York, N.Y. 10018 (212) 869-1500
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MS. ECHOLS: Good evening, I'm
Cecilia Echols and I'm the Community
Involvement Coordinator for the
Preferred Plating Corporation Superfund
. /
Site. We are here to discuss the
Post-Decision Proposed Plan for the
site. This Proposed Plan is to modify
the original groundwater remedy that was
chosen back in 1989.
We have on our. agenda today, Doug
Garbarini, who will give an overview of
the Superfund process; and Janet +
Cappelli, she will give an overview of
the site background, a summary of
groundwater sampling activities 'and the
proposed amended remedy.
After everyone's presentation, we
will open up for questions and answers
and then we shall close. And .here's
Doug.
MR, GARBARINI: Since everybody
who is in the audience really knows the
.Superfund process pretty well, I'm not
going to spend the time giving an
FINK & CARNEY
COMPUTERIZED REPORTING SERVICES
24 West 40th Street, New York, N.Y. 10018 (212) 869-1500
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1 . . . . .
2 overview of the Superfund process or
3 outline any history of the process.
4 Unless there are any objections.
5 I think Jefry will hear this again
6 Monday night.
7 If there are no objections, I'll
8 just turn it over to Janet,
9 ' ' MS. CAPPELLI: I'll show you my
10 overheads.
11 .1 think everybody here knows a
12 ' lot about the site, so I think I can
13 skip most of the background. Let*me put
14 up the chronology of events and refresh
15 everyone's memory.
16 Preferred"is a pretty small site,
17 it is just under an acre, on Allen
18 Boulevard,* just off of Route 110. It is
19 in pretty much a light industrial
20 commercial area. The residential
21 " section starts about a third of a mile
22 southwest of the site.
23 Preferred began operating back in
24 1951, using mainly cadmium and chromium
25 in their process. The wastewater was
FINK & CARNEY
COMPUTERIZED REPORTING SERVICES
24 West 40th Street, New York, N.Y. 10018 (212) 869-1500
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1 ' .
2 discharged to four concrete underground
3 pits, sort of constructed like a
4 swimming pool, below ground swimming
5 . - , pool, behind the old building.
6 Allen Boulevard is down at the
7 bottom. The old building ended pretty
8 much right around here (indicating), and
9 here is where.the four pits were below
* ' , '
10 .the ground, that is where they
11 discharged.
12 Back starting in 1953, the county
13 . . health department started sampling the
14 sludges in those pits and also some
15 local wells, and started to find a
16 problem with elevated levels pf metals.
17 ' Between 1953 up to 1976, until Preferred
18 closed, they had numerous violations
19 that the county tried to get them to
20 ' clean up the sludges in those pits.
21 ' . They did some sort of remediation with
22 the sludge that was left in the pits.
23 However, the pits themselves were
24 cracked and leaking into the underlying
25 soils and groundwater.
FINK & CARNEY
COMPUTERIZED REPORTING SERVICES
24 West 40th Street, New York, N.Y. 10018 (212) 869-1500
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2 In 1983,'the state came in
3 ' through the Department of Environmental
4 Conservation,' and started to investigate
5 the site and recommended that it be
6 added to the National Priorities List,
7 . which is our listing of Superfund sites.
8 In 1984, it was added to the NPL and
9 . that sort of kicked off EPA's official
10 involvement in the site.
11 The site-itself has been, over
12 ' the years, split up into three separate
13 operable units: <-
14 The first operable unit dealt
IS with off-site and downgradient
16 . groundwater investigation. A ROD that
17 selected a pump and treat remedy based
18 on data tha't showed pretty high levels
19 of cadmium and mostly chromium, was
20 selected back-in 1989. The design for
21 that pump and treat system was completed
22 in 1992.
23 In the meantime, we had begun our
24 second operable unit, which concentrated
25 on the source for the groundwater
FINK & CARNEY
COMPUTERIZED REPORTING SERVICES
24 West 40th Street, New York, N.Y. 10018 (212) 869-1500
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1
2 contamination, which by this time the
3 property owners, the property had been
4 sold. Preferred went out of business,
5 the. new property owners had extended the
6 building.
7 ' So now those four underground
8 pits were covered by a building. So the
9 second operable unit focused on soils
10 that were inside of those pits, plus the
11 soils that were beneath the pits before
12 the water table. The ROD for that site,
13 for the second operable unit, was'issued
14 in 1992. That selected excavation and
15 .off-site disposal for the source area.
16 We decided, because the site is '
17 pretty small, we decided that we ..
>
18 couldn't do both construction activities
19 at the same time, there really wasn't
20 enough space. Since it made more sense
21 " to get the source out of there before we
22 started to do any kind of pump and
23 treat, we put in the remedial design, we
24 finished that, we put that on hold, .
25 implementation of that, for the
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COMPUTERIZED REPORTING SERVICES
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1 .
2 groundwater system.
3 . And we waited until the
4 remediation of the source area was
5 completed. And that happened about
6 1994. We ended up taking about 1,500
7 tons of materials out from that site.
8 While this was going on, we also
9 started another operable unit, which was
10 No. 3. That investigated what we
11 thought might have been a possible
12 ' " source of upgradient groundwater
13 contamination, dealing with the Del Lab
14 that was north of the site. It was
15 found that there was no problem there
16 contributing to groundwater -;
17 contamination. Del Lab was taking care
18 of the well' water th'at was on site, they
19 weren't adding to the groundwater
20 problem, there was no ROD that was
21 issued in .1993.
22 During this whole time that the
23 implementation was put on hold, we kept
24 sampling'the groundwater. We have nine
25 monitoring wells that are on the site
FINK & CARNEY
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i .''..
2 itself. We also have two monitoring
3 - wells that are off the site.
4 I'll move this around so you can
5 see it. We have a cluster at the
6 southern end, a single small shallow
7 well, and shallow wells in the middle of
8 the property. And going up to the
9 . north, we have a cluster of shallow and
10 deep.
11 We also have two off-site wells,
12 ' one is about a quarter of a mile south
13 . . to southeast of the site, where t-he old
14 Army Nike base was. The other one is
15 - about a half mile south to southwest
16 just off of the'the Southern-.State
17 Parkway. Those two are deep wells.
18 They are 70.feet deep, they are at the
19 bottom of the Upper Glacial.
20 We have seven rounds of 'data.
21 The original RI/FS for OU1 had two.
22 rounds from August and September of
23 1988. The round in February of 1991, we
i
24 collected as part of our treatability
25 study, while we were doing the design
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COMPUTERIZED REPORTING SERVICES
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1 ''-. . ' . .
2 for the groundwater pump and treat
3 system.
4 ' We then collected a round right
5 before the remediation of the source
6 area started, in 1993. We collected
7 another round after that was finished,
8 in 1994. As you can see, for the
9 cadmium and the chromium, we started
10 seeing a pretty dramatic decrease in the
11 concentrations. At that point, we
12 ' . decided that instead of going forward
"13 with the groundwater pump and treat
14 system, we wanted to collect a couple
15 rounds of more samples to see if that
16 decrease was going .to continue. ' -'And at
17 that point, then we would reevaluate the
18 data. ' " ' :.
19 Which brings us through April of
20 1995 and August of 1996, which is when
21 we reevaluated the data and basically
22 came up with this conclusion which we've
23 documented in this Post-Decision
24 Proposed Plan, that we no longer think
25 the pump and treat is necessary because
FINK & CARNEY
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24 West 40th Street, New York, N.Y. 10018 (212) 869-1500
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1 . . . .
2 of the significant decrease in the
3 concentrations for cadmium and chromium.
4 Lead and nickel pretty much in the last
5 . '. four and five rounds of sampling, have
6 always been coming up as non-detect.
7 . In the original OU RI/FS back in
i
8 1988, lead and nickel were in there also
9 as contaminants of concern, but to a
10 much lesser extent than cadmium and
11 chromium. Those have been our two big
12 . players all along. Chromium as it
13 stands now at 57, is below the drinking
14 water standard of 100, although slightly
15 above the New York State Groundwater
16 Quality Standard, which is still' 'at 50.
17 The cadmium, though, is above the
ซ - ;
18 drinking water standard, which is 10.
19 But it has come down on an order of
20 magnitude from a high of 399, along with
21 ' the decrease in the concentrations/the
22 risk number, the associated
23 non-carcinogenic risk for metals, has
24 also decreased significantly. Right
25 now, we use a Hazard Index for
FINK & CARNEY
COMPUTERIZED REPORTING SERVICES
24 West 40th Street, New York, N.Y. 10018 (212) 869-1500
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2 non-carcinogenic risk. When the Hazard
3 Index goes above 1.0, we consider there
4 to be a problem.
5 . ' In the past, the numbers for
6 cadmium and chromium were 22, and I
7 think chromium at the time was 170.
8 Right now the Hazard Index for chromium
9 is below 1.0, it is 0.6. And for
10 cadmium, it is a little bit above one,
11 it is 2.2 .
12 MR. ROBBINS: I presume-these are
13 maximum values. '
14 MS. CAPPELLI: These are the
15 maximum values. For the last round,
16. cadmium is Well No. 5. I'll have to
17 pull out the data for you, Five is at
18 the southern end of the property, down
19 here. You see that right there.
20 And the chromium, I'll check on,
21 " .1 think it was from Well .No. 3, which
22 was more to the side.
23 .That Hazard Index value for
24 " cadmium now is at 2.2. When we
25 originally calculated it back in 1988,
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i ' ' .
2 for the first two rounds in the first
3 -issuance of the ROD, it was 22. So it
4 has come down an order of magnitude.
5 . Basically, based on this data
6 coupled with the risk assessment, which
7 again you have to remember, that the
8 risk assessment is only based on a
9. future use scenario. For a current use,
10 there is no risk. For a future use,
11 that a resident would be drinking this
12 over a 70 year lifetime, that is where
13 you get the Hazard Index value of"'that
14 2.2, which is a pretty unlikely
15 scenario, that we would have somebody
16 drinking the Upper Glacial for that
17 length of time. . .
18 MR. GARBARINI: I think it is.
19 probably 30 years of exposure over a 70
I
20 year lifetime. ' ,
21 ' " MS. CAPPELLI: I'm sorry, it is.
22 Drinking two liters of water a day. So
23 the risk numbers coupled with this data
24 is what prompted us to reevaluate the
25 system, the groundwater pump and treat
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1 -.-
2 system, and to issue this Post-Decision
3 Proposed Plan. As part of the remedy
4 . that 'we are proposing, we'would continue
5 ' annual monitoring.
6 We have, under the Superfund
i
7 Program, we need to reevaluate the site
8 ' .over a -five year period. So we are
9 proposing to do the annual monitoring
*
10 for the five years, and then at that
11 point do our five year review' and
12 compare it, in case the MCLs have
13 changed, compare it to see whether the
14 concentrations have increased,
15 decreased, or whether natural
16 , attenuation will- add to the scenario and
17 bring the levels down lower..
18 Based on this, we really didn't
19 feel that a full-blown pump and treat
20 was necessary for this problem. -.
21 " That is basically my
22 presentation.
23 MS. ECHOLS: Do you have any
24 questions? State your name, sir.
25 MR. ROBBINS: . Sy Robbins, I'm
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1 . ' ' .
'2 from the Suffolk County Department of
3 Health Services. One question that
4 . might arise, is concentrations at the
5 site have decreased. Is it possible
6 that this contamination has moved?
7 MS. CAPPELLI: We have looked at .
8 our downgradient wells. One well in the
9 Nike base in the last couple of years
10 has been removed. So we have sampling,
11 I believe for 1991 and 1993, that had
12 ' non-detect for both cadmium and chromium
13 in it. The other well, which is *
14 further, a half mile south to southwest,
15 which was off of the Southern State
16 Parkway, that one we've still been
17 sampling that was part of the last
18 sampling round, and'that always has been
19 nondetectable.
20 MR. ROBBINS: Do you have a
21 " graphic that shows the location of those
22 two wells?
23 MS. CAPPELLI: I don't have
24 anything that great. I can point out
25 - where they are?
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1 ; '/''.
2 Here is the old Army Nike base.
3 Our first deep well off-site was here,
4 that was the one that was a quarter of a
5 - mile away. And that is between .60 to 70
6 'feet.
7 . The next well is down right off
8 the easement of the Southern State
9 .Parkway. So we are about a half mile at
10 that point. And that also is screened
11 60 to 70. That was a little deeper.
12 The wells that are on-site, the
13 shallows, are screened between I0x.and 25
14 feet. .
15 The deep wells that are on-site,
16 there are two deep wells, those'-are
17 screened at 40 to 60.
18 MR."ROBBINS: ' From land surface
19 or from the water table.
20 . MS/ CAPPELLI: From below grade.
21 MR. ROBBINS: Now, both those
22 downgradient wells are aligned with the
23 assumption that groundwater 'below is in
24 a south southwesterly direction.
25 MS. CAPPELLI: The one that is %
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1 ' ' '. . ;
2 ' closer to the site that is on the old
3 Army Nike base was put in a more south,
4 southeast. The one that is off of the
5 Southern State Parkway was put in more
6 south southwest. Because at the time,
7 . we were using those wells also to try to
8 determine which way the flow was going.
9 So .we put them off side-gradient a
10 * little bit.
11 MR. ROBBINS: And the periodic
12 monitoring that you are going to do, and
13 review of the data, is that strictly on
14 the basis of the well that you've shown
15 us the results from? Or if additional
16 data came in, would that have to/be
17 considered also.
'
18 MS. 'CAPPELLI.' I think we would
19 consider additional data also if there
20 were wells that we could also sample
21 from, we could include that in our
22 sampling data base, include those wells.
23 MR. GARBARINI: We would consider
24 any data you might have.
25 MS. CAPPELLI: The one well that
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1
2 is at the Faber's office building, we
3 could include that.
4 MR. GARBARINI: We are required
5 . to do a five year review by the statute.
6 If the level of contaminants are above
7 health risk levels, until they drop
8 below. We could even do the reviews
9 before five years. But we have to do it
10 in; five. Whenever we take samples,
11 we'll do some sort of evaluation at that
12 ' part.
13 MS. CAPPELLI: The first round '
. . x.
14 for annual monitoring would begin this
15 fall.
16 -MS. ECHOLS: Anymore questions?
17 Sir, go ahead. State your name.
18 : MR. -ROSMARIN:- Jefry Rosmarih. I'
19 was curious, what was the size of the
20 plume? .
21 . MS. CAPPELLI: We haven't
22 documented a plume leaving the site.
23 The off-site wells have always turned
24 out nothing above health base levels.
25 .MR. GARBARINI: We actually
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1 '
2 designed a groundwater remedy for the
3 site. Maybe you can just touch on that.
4 MS. CAPPELLI: We did. When we
5 . selected the Record of Decision in 1989,
6 when we chose the pump and treat, we
7 actually went ahead and did the entire
8 design. It is complete. The capture
9 - zone basically for that pump and treat,
10 only went to the southern edge of the
11 property boundary. It would probably
12 extend a little bit more, but we
13 designed it just to go where we were
14 finding our contaminant levels. That
15 , design was approved by the state, as
16 well as the EPA..
17 MR. ROSMARIN: The search for the
18 source of the upgradient contamination
19 is?
20 MS. CAPPELLI: We began that
21 - because our upgradient cluster on our
22 site property, had some hits that we
23 thought were too high to serve as
24 background. So we looked north orf us,
25 and we found a manufacturing facility
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2 who had some was.tewater. in pits on their
3 facility. So we thought that we had
4 , enough reason to look there. They put
5 . in a host of 'monitoring wells. There is
6 an empty wooded lot about an acre in
7 size between our site and their
8 manufacturing facility. They put in a
9 host of wells, and they did not find
iO anything.
11 At the same time, the county was
12 working with them, I believe, on their
13 own facility. And they were taking care
14 of some problems that they had.
15 MR. ROBBINS: They were
16 remediating the-cesspools, this".is Del
17 Labs, on their property. I don't know
18 if it was under consent order or whether
19 it was voluntary.
20 MS. CAPPELLI: I believe there
21 - was a consent order.
22 ' MR. ROBBINS: You represented the
23 data collected by Del Labs 'as indicating
24 there wasn't contamination of
25 groundwater.
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;-.'.. 20
l ,
2 I think it did indicate
3 '" contamination of groundwater.
4 " MS. CAPPELLI: It probably had
5 organics, but we were looking in terms
6 ..'.-. of heavy metals. We found heavy metals
7 in our upgradient wells, which we
8 assumed couldn't be from our source
9 area.
10 MR.'ROBBINS: There were metals
l
11 . above background in some of their wells,
12 ' nothing to indicate remediation, nothing
13 to indicate a continuing source on their
14 site. But it certainly could have been
15 indicative of prior discharges that
16 might have moved on.
17 ' MS. CAPPELLI: :Something that
18 came off of their property, and that is
19 what we picked up. We pretty much went
20 ahead with that operable unit, because
21 we knew that we would be designing a
22 groundwater pump and treat. . And if
23 there was a problem coming onto our
24 site, we needed to know about that and
25 make sure that we could capture that and
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2 bring it into our treatment system.
3 MR. ROSMARIN: Is this . an orphan
4 site?
5 - MS. CAPPELLI: An orphan site?
6 MR. GARBARINI: No. The PRP'S
7 actually implemented the soil remedy.
8 .MS. CAPPELLI: Second operable
9' . unit.
10 MR. ROSMARIN: Who are the PRPs?
11 'MS. CAPPELLI: Joseph Gazza
12 (ph)and George Paro (ph) , current owners
13 of the site, bought the property ^in
14 1976, so they were not part of Preferred
15 Plating. They sort of walked into a
16 problem, unfortunately. But. they did
17 step in and under --is it in a
18 unilateral* order?
19" MR. GARBARINI: Downgradient
20 there is some overlap. They are the
21 owners, but there is some overlap.
22 MS. CAPPELLI: Yes, there' was a
23 short period of time after they bought
24 the property and Preferred wasn't
25 totally out yet, so they actually leased
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2 ' back to Preferred for some time.
3 MR. GARBARINI: It was a
4 unilateral order, but it was something
5 - sort of negotiated. They were very
6 . .cooperative. It worked out .that we were
7 'going to implement the remedy quicker if
8 it were a unilateral order.
9 . MR. ROSMARIN:, But .they paid for
10 the remedy.
11 MS. CAPPELLI: They paid for the
12 soil. .
13 MR. ROSMARIN: The soil and the
14 studies, the studies to do groundwater
15 pump and treat.
16 MS. 'CAPPELLI: No, that was under
17 EPA, funded by the EPA. .
18 MR. ROSMARIN.' By;the Super fund.
19 . - . MR. GARBARINI: Yes'.',
20 MR. ROSMARIN: And there..was no
21 . attempt to recover from the property
22 owners?
23 MR. GARBARINI: . We haven't closed
24 out the case yet.
25 MS. CAPPELLI:' This is still with
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23
1
2 our regional counsel. The decision
3 hasn't been made whether or not we are
4 going to pursue that.
5 - .MR. ROBBINS: The remediation of
6 the waste pits, did that involve
7 ' dismantling part of the building?
8 MS. CAPPELLI: Yes, actually the
9 middle section of the building pretty
10 " much from here to here, this whole
11 section of the building was torn down,
12 because there was no way to get to those
13 pits without taking the middle part' of
14 - that building down. So that is what
15 they did. And we went to-visit it,
16 actually it has since been put up
17 exactly the way it was before.
18 " MR.-ROBBINS: ' Just for the
19 record, the statements in the Proposed
20 Action Plan, will be -- relative to the
21 - availability or the use of public water
22 at all downgradient locations, will be
23 modified reflecting there are some, and
24 maybe some additional downgradient wells
25 in use.
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.1
2 . MS. CAPPELLI: 'It will be
3 modified in terms of the Record of
4 Decision. If you submit that as a
5 comment, we'll respond to it in the
j
6 Responsiveness Summary section, which is
7 \ . an appendix to the Record of Decision,
. 8 and we'll make sure that it is reflected
9 correctly within the text of the Record
10 of Decision. Pretty much, this document
11 is now a public document. So if there
12 is something that is wrong in this, that
13 is how we will correct it, througja the
14 Responsiveness .Summary.
15 MR. ROSMARIN:" I'm.a little
16 confused. The-pits were underneath the
17 buildings and then Preferred Plating at
18 some point-moved out. '
19 So how did the contaminants leach
20 into the soil without rainwater.
21 - MS. CAPPELLI: The old building
22 right here where you see the indentation
23 going in? This is where Preferred
24 Plating's building ends.
25 Pipe's went out of the buildings,
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1 '-..
2 and discharged into those pits that look
3 like a swimming pool, they are level
4 with the ground, and went down about 10
5 . feet into the ground. They had baffles
6 built into .them. They were actually
7 sectioned off into four quadrants.
8 . After -- Preferred Plating did some kind
9 of remediation of the sludge material
^ -
10 that was left in those pits, but nobody
11 . ever went underneath the pits.
12 The pits had been cracked and
13 leaking so nothing ever was done jabout
14 the soils that were underneath the pits
15 before you encountered 'the water.
16 When the :new owners came'in, not
17 knowing really, I guess, about 'the
18 problem, filled in those pits and
19 decided to-extend the building. Now we
20 have the situation where we knew the
21 - pits were there, but access to them was
22 pretty hard.
23 MR. GARBARINI: The-other problem
24 too is similar to what we have been
25 talking about a couple of years ago at
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1 ' ._-.'.
2 Liberty, actually. The fluctuation in
3 the groundwater table would result in
4 . some of those contaminants that were
5 below the pits, again contacting the
6 groundwater and then moving out.
7 . MR. ROSMARIN: Assuming they were
8 in the saturated season and assuming
9 that what is happening in Nassau County
10 . isn't happening in Suffolk County, which
11 is that the fluctuations in groundwater
12 ' are off by over 5 feet these days.
13 MR. GARBARINI: This is bark in
14 1992.
15 MS. CAPPELLI: We measured that
16 too through historical data, and'-data we
17 found. The measurable water .table was
18 anywhere from 10 to'18 feet. the pits
19 . " were about 10 feet down. During pretty
20 wet seasons, the water table was
21 actually encountering the bottom of
22 those pits. If they had been leaking,
23 they were going into the soils below the.
24 bottom of the pits.
25 MR. GARBARINI: I think I know
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1 '
2 this a little better than you do.
3 The situation wasn't the same
4 , necessarily. In the last few years,
5 . noticed a much larger difference in the
6 groundwater fluctuation. So there was
7 still some contact, we believe there to
8 be some contact of the groundwater with
9 the contaminants that were just below
10 . the leaching pits themselves. That is
11 why we needed to go in and remove the
12 ' soils.
13 MS. ECHOLS: Brian, do you*have
14 any questions?
15 MR. ZITANI: Brian Zitani, Town
16 of Babylon. Out of curiosity, since the
17 . initial studies didn't seem to indicate
18 that .there"was a plume migrating
19 off-site, and after the remediation of
20 - the soils, with the removal, is .it
21 unusual that the numbers should drop so
22 quickly since it. doesn't appear to be
23 that much material moving through the
24 site?
25 ' MS. CAPPELLI: There is a part
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1 - .-.
2 that you asked me to include, and I
3 forgot to mention.
4 Part of the reason for that, I
5 . don't really think that the source
6 . removal brought the levels down that
7 dramatically on its own. In the last
8 two rounds of our sampling, we started
9 to use a technique which we pretty much
i
10 commonly use now when we are sampling
11 for metals, using a low-flow pump to get
12 the turbidity down-. Pretty much we are
13 seeing a big decrease in metals x.
14 concentration. I went back and checked
15 the turbidity samples for the previous
16 sample round. ' We usually try to -get
17 them below 50 NTUs. They were pretty
18 high, in th'e hundreds, some of them. .
19 I think that is really more of a
20 . reason.
21 - MR. ZITANI: Methodology change
22 that brought the number down.
23 MS. CAPPELLI: The first two
24 rounds are not representative of what
25 was there. If we had that low-flow
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,. - - 29
1
2 . technique -- because this next round.,
3 you see the decrease here, the source
4 was still there. Those pits weren't
5 ' . remediated yet, and that is still quite
6 a drop from the original round of
7 sampling. It might have something to do
8 with the water table fluctuations, if it
9 was a wet season, carrying more down
10 with it. But I think the low-flow
11 technique really gave us a much truer
12 reading of what was in that water.
13 MS. ECHOLS: Any more questions?
14 MS. CAPPELLI: The comment period
15 . goes until August 30th. If you want to
16 jot down my phone number, my .address,
17 you can write with any comments, that's
- ซ '
18 fine. If you want to call with any
19 comments, -it is 212,' 637, 4270. And the
20 comments will all be responded to in the
21 " appendix to the Record of Decision that
22 we call the Responsiveness Summary
23 Section.
24 MR. ROBBINS: I will send you
25 copies of the private well samples that
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1
2 - " we took in the area of the survey.
3 MS. CAPPELLI: I appreciate that.
4 MS. ECHOLS: If you want to reach
5 . me, there is an 800 number you can reach
6 me at.
7 MS. CAPPELLI: Thank you very
8 much.
9 MS. ECHOLS: Thank you for
10 .. coming
11 - (Whereupon, at 7:41 p.m., the
12 ' proceedings were adjourned)
13
14
15
16
17
18
19
20
21
22
23
24
25
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31
1
2 CERTIFICATE
3 STATE OF NEW YORK )
) SS.
4 COUNTY OF SUFFOLK )
5 I, JENNIFER MAUE, a Registered
6 Professional Reporter, do hereby certify
7 that the foregoing Matter, taken at the
8 time and place aforesaid, is a true and
9 ' correct transcription of my shorthand
10 notes.
11 . I further certify that I am
12 neither counsel for nor related to any
13 party to said action, nor in any .wise
14 interested in the result or outcome
15 thereof.
16 IN WITNESS WHEREOF, I .have
17 hereunto set my hand this llth day of
18 August, 1997.
19
20
21
22 .
23 S/ JENIFER' MAUE
24
25
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APPENDIX IV
Table of Groundwater Sampling Data
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GROUNDWATER SAMPLING DATA
MAXIMUM CONTAMINANT LEVELS (ppb)
DATE OF
SAMPLING
AUGUST 1988
SEPTEMBER 1988
FEBRUARY 1991
AUGUST 1993
JULY 1994
APRIL 1995
AUGUST 1996
CADMIUM
399
348
254
123
136
43
60
CHROMIUM
5850
3390
1850
560
163Q (35 FILT)'
83
57 '
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Appendix V
1989 Record of Decision
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DECLARATION FOR THE RECORD OF DECISION
SITE NAME AND LOCATION
Preferred Plating Corporation, Farmingdale, Suffolk County, New York
STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected remedial action for the
Preferred Plating Corporation Site developed in accordance with the
Comprehensive Environmental Response, Compensation, and Liability
Act, 42 USC ง 9601, et seq., and to the extent applicable, the
National Oil and Hazardous Substances Pollution Contingency Plan , 40
CFR Part 300. This decision is based on the administrative record
for the Site. The attached index identifies the items that comprise
the administrative record upon which the selection of the remedial
action is based.
The State of New York has concurred with the selected remedy.
ASSESSMENT OF THE SITE
Actual or threatened releases of hazardous substances frort this Site,
if not addressed by implementing the response action selected in this
Record of Decision, may present an imminent and substantial
endangerment to public health, welfare, or the environment.
DESCRIPTION OF SELECTED REMEDY
This operable unit represents the first of two planned for the Site.
It addresses the treatment of ground water contaminated primarily
with heavy metals and volatile organics. The second operable unit
will involve the continued study and possible remediation of soils
located beneath the building on the Site if the study so indicates.
These soils could not be adequately characterized during the first
operable unit. The second operable unit will also investigate
potential sources of upgradient contamination.
The major components of the selected remedy include:
A Extraction and treatment, via metal precipitation, ion
exchange, and activated carbon, of ground water in the Upper
Glacial Aquifer to restore the ground water quality to cleanup
levels identified in the decision summary; and
* Disposal of treatment residuals at a RCRA subtitle C facility.
-------
Treatability studies will be undertaken to confirm the effectiveness
of the selected remedy. If these studies indicate that the ion
exchange process used in the selected remedy is ineffective in
reducing the chromate ion to the required levels, a contingency
remedy, which utilizes a separate precipitation unit for the removal
of the chromate ion, will be implemented.
STATUTORY DETERMINATIONS
Both the selected remedy and the contingency remedy are protective of
human health and the environment and are cost-effective. The total
remedial action, consisting of both this first operable unit and a
future second operable unit, when fully completed will comply with
Federal and State requirements that are legally applicable or
relevant and appropriate. Both the selected remedy and the
contingency remedy utJLlize permanent solutions and alternative
treatment technologies to the maximum extent practicable and satisfy
the statutory preference for remedies that employ treatment that
reduce toxicity, mobility, or volume as a principal element. Due to
the existence of an upgradient source area, neither the selected nor
the contingency remedy, by itself, will meet chemical-specific ARARs
and be capable of restoring the area ground water to applicable
ground water quality standards until that upgradient source area is
removed. The upgradient source area will be addressed as part of the
second operable unit. Although the remedial action selected, the
first operable unit, will not meet chemical-specific ARARs, it is
only part of a total remedial action that will attain clean-up levels
when fully completed. In the event the second operable unit fails to
identify or control the source area, a waiver for technical
impracticability will be sought.
The need for conducting a five-year review will.be evaluated upon
completion of the second operable unit. :
William J. Mustyrfskl,,&& Date
Acting Regional Administrator
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DECISION SUMMARY
PREFERRED PLATING CORPORATION
FARMINGDALE, NEW YORK
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION II
NEW YORK
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TABLE OF CONTENTS
SECTION
I. Site Location and Description 1
II. Site History and Enforcement Activities 2
III. Community Relations History 3
IV. Scope and Role of Operable Unit
Within Site Strategy 3
V. Summary of Site Characteristics 4
VI. Documentation of Significant Changes 5
VII. Summary of Site Risks 5
VIII. Description of Alternatives 6
IX. Summary of Comparative Analysis
of Alternatives 10
X. Selected Remedy 13
XI. Statutory Determinations 14
ATTACHMENTS
Appendix I
Appendix II
Appendix III
Appendix IV
Appendix V
- Figures
- Tables
- Adminstrative Record Index
- NYSDEC Letter of Concurrence
- Responsiveness Summary
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SITE LOCATION AND DESCRIPTION
The Preferred Plating Corporation Site (the "Site") is located at 32
Allen Boulevard in Farmingdale, Town of Babylon, Suffolk County, New
York. This 0.5-acre Site is situated in a light industrial area
approximately 1 mile west of the Nassau-Suffolk County border. Route
110 passes just west of the Site (see Figure 1).
The land to the east and west of the Site is occupied by commercial
or light industrial properties. Immediately north of the Site is a
large wooded area followed by various industrial facilities further
north of that. To the south are a residential community and a U.S.
Army facility.
The 1980 census records a population of greater than 10,000 within a
3 mile radius of the Site. The population density in the area is
estimated to be 3,000 to 6,000 persons per square mile. All homes
and businesses, in the area surrounding the Site, are supplied by two
public water companies. Ground water is the source of water supplies
for the entire population of both Nassau and Suffolk Counties. All
public water supply wells in the Site area draw water from the deeper
aquifer, the Magothy Aquifer. The nearest public water supply well .
fields are located approximately 1 mile east and 1 mile south of the
Site.
The nearest body of surface water is an unnamed intermittent
tributary of Massapequa Creek which is approximately 6000 feet west
of the Site. There is no designated New York State Significant
Habitat, agricultural land, nor historic or landmark site directly or
potentially affected. There are no endangered species or critical
habitats within close proximity of the Site. The Site is located
more than 2 miles from a 5-acre coastal wetland and more than 1 mile
from a 5-acre fresh-water wetland.
The Site is situated in the south-central glacial outwash plain of
Long Island, which constitutes the Upper Glacial Aquifer, estimated
to be 90 feet in thickness under the Site. The naturally occurring
surface soil is a sandy loam which promotes rapid infiltration to the
ground water. On the Site proper and throughout much of the region,
soils have been classified as urban. This is primarily due to the
development and pavement which promote greater run-off of
precipitation. The Upper Glacial Aquifer overlies the Magothy
Aquifer and the two may act as distinct aquifers, or as one,
depending upon the degree of hydraulic connection between the two.
In the Site area, it is believed that the two are not hydraulically
connected.
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SITE HISTORY AND ENFORCEMENT ACTIVITIES
The Preferred Plating Corporation (PPC) conducted operations
beginning in September 1951 through June 1976. The primary
activities at the Site were to chemically treat metal parts to
increase their corrosion resistance and provide a cohesive base for
painting. The plating processes included degreasing, cleaning, and
surface .finishing of the metal parts. These processes involved the
use of various chemicals which resulted in the generation, storage,
and disposal of hazardous waste. Untreated waste water was
discharged to four concrete leaching pits directly behind the
original building.
Ground water contaminated with heavy metals was detected in the Site
area by the Suffolk County Department of Health Services (SCDHS) as
early as June 1953. SCOHS indicated that the leaching pits on the
Site were severely cracked and leaking. Samples taken from the pits
showed the major contaminants to be heavy metals. From 1953 to 1976,
SCDHS instituted numerous legal actions against PPC in an effort to
stop illegal dumping of wastes and to install or upgrade the on-site
treatment facility. PPC prepared an engineering report in May 1974
in order to apply for a State Pollutant Discharge Elimination System
(SPDES) permit which was issued in June 1975. PPC chemically treated
the waste water in the pits and, allegedly, then had the treated
waste water removed. Whether the treated ground water was ever
removed has not been confirmed by EPA. The facility was never in
full compliance with the terms and conditions outlined in the permit.
In 1976, PPC declared bankruptcy. Since then, several firms have
occupied the Site, none conducting similar operations to PPC. In
1982, the original building was extended by 200 feet, thereby burying
the concrete leaching pits. Nearly the entire Site is covered either
by the one existing building or paved driveways and parking areas.
In September 1984, Woodward-Clyde Consultants, Inc. performed a Phase
I-Preliminary Investigation of the Preferred Plating Site for NYSDEC
for the purpose of computing a Hazard Ranking System (HRS). score
needed to evaluate whether to place the Site on the National
Priorities List (NPL). In the Phase I report, an HRS score of 33.76
was documented, thereby enabling the Site to be included on,the NPL.
On October 15, 1984, (49 FR 1984), the Site was proposed for the NPL
and was added with a ranking of 500 on June 10, 1986,.(51 FR 21054).
At EPA's direction, a remedial investigation (RI) was initiated in
1987. The RI consisted of a field sampling and analysis program
followed by validation and evaluation of the data collected. The
field work was initiated in June 1988 and completed in February 1989.
The work was conducted by EPA's REM III contractor, Ebasco Services,
Inc. The soil sampling program involved the determination of lateral
and vertical extents of contamination by obtaining samples from six
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on-site monitoring wells, two off-site monitoring well locations/ six
surface soil locations, and seven angle borings which extended
underneath the on-site building overlying the former leaching pits.
The groundwater sampling program involved the installation of nine
on-site and two off-site monitoring wells. In addition, two storm
water run-off samples and two sediment samples were collected from
on-site storm sewers.
The potentially responsible parties (PRP's) were notified in writing
on February 12, 1988 via a special notice letter and given the
opportunity to conduct the RI/FS under EPA supervision. However,
none elected to undertake these activities.
In July 1989, Ebasco's remedial investigation (RI) and feasibility
study (FS) reports were released to the public along with the
Proposed Remedial Action Plan (PRAP) developed by EPA. A 28-day
public comment period was provided, ending on August 18, 1989.
COMMUNITY RELATIONS ACTIVITIES
A Community Relations Plan for the Preferred Plating Site was
finalized in March 1988. This document lists contacts and interested
parties throughout government and the local community. It also
establishes communication pathways to ensure timely dissemination of
pertinent information. Subsequently, a fact sheet outlining the RI
sampling program was distributed in June 1988. The RI/FS and the
Proposed Plan were released to the public in July 1989. All of these
documents were made available in both the administrative record and
two information repositories maintained at the Babylon Town Hall and
the West Babylon Library. A public comment period was held from July
19, 1989 to August 18, 1989. In addition, a public meeting was held
on August 3, 1989 to present the results of the RI/FS and the
preferred alternative as presented in the Proposed Plan for the Site.
All comments which were received by EPA prior to the end of the
public comment period, including those expressed verbally at the
public meeting, are addressed in the Responsiveness Summary which is
attached, as Appendix V, to this Record of Decision.
SCOPE AND ROLE OF OPERABLE UNIT ONE WITHIN SITE STRATEGY
The objective of this operable unit is to address the overall
groundwater contamination attributable to the Site. The selected
remedy will treat ground water until the influent contaminant
concentrations equal the upgradient concentrations. When this has
been achieved, the saturated soils underlying the Site will have been
essentially flushed of any contaminants, thereby resulting in no net
contribution of contaminants from the Site to the aquifer below.
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The results of the RI failed to detect evidence of soil contamination
in any of the samples collected. However, since the
downgradient groundwater contaminant concentrations were, on the
average, an order of magnitude greater than the upgradient
concentrations, a source of contamination is believed to exist in the
saturated soils beneath the Site. Due to fluctuating water table
levels, the zone of saturated soils beneath the building varies.
Directly, the selected remedy will be cleaning the ground water.
Indirectly, it will be flushing contaminants out of the saturated
soils.
If the source of contamination in those saturated soils could be
located and controlled, the restoration time frame for cleaning the
ground water would be greatly reduced. Therefore, a second operable
unit will be undertaken to more fully characterize and identify any
contaminated soils, both saturated and unsaturated, located beneath
the building and to investigate potential upgradient sources of
contamination.
SUMMARY OF SITE CHARACTERISTICS
The purpose of the RI conducted at the Preferred Plating Site was to
identify the nature and extent of contamination in environmental
media on-site, including soil, sediment, ground water, and storm
water run-off. To accomplish this, two rounds of ground water
samples were collected from the nine on-site monitoring wells as well
as the two off-site wells. In addition, various soil samples were
collected, including samples from seven sub-surface angle borings
drilled beneath the building. (See Figure 2 for on-site sample
locations). All samples were subjected to complete Target Compound
List analyses. The results of the investigation indicate the
following:
A Ground water underlying the Site is contaminated with high
levels of heavy metals. Low levels of chlorinated hydrocarbons
and cyanide were also detected in a few samples. Upgradient
ground water also showed high levels of heavy metals, though
significantly lower than on-site levels.
* The soils sampled on-site, including those collected from
beneath the building, failed to detect any sources of
contamination.
t
Chemical analysis of the 24 groundwater samples collected from the
Upper Glacial Aquifer detected concentrations of cadmium, chromium,
lead, and nickel above the allowable maximum contaminant levels
(MCLs) in numerous samples. The highest value for a contaminant was
that of chromium at 5,850 ppb. On-site wells, installed downgradient
of the former leaching pits, showed the highest levels of
contamination. Upgradient wells also showed levels of contamination
above allowable MCLs, however, at an order of magnitude lower than
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the downgradient wells. Low levels of chlorinated organics,
predominantly 1,1,1-trichloroethane; trichloroethylene; 1,2-
dichloroethane; 1,1-dichloroethane; and tetrachloroethylene were
detected in a few samples. In addition, three samples indicated the
presence of cyanide above allowable MCLs. Concentrations for all
inorganic and organic contaminants and their frequency of detection
are shown in Table 1.
The sub-surface soil analyses collected from both the seven angle
borings and the eleven monitoring well borings showed normal
background levels for contaminants. Since the downgradient wells
have much higher levels of contaminants than the upgradient wells, it
is assumed that a source of contamination exists in the saturated
soils located beneath the building that was not identified during
this investigation. This will attempt to be identified as part of
the second operable unit.
Surface soil samples collected from six separate locations indicated
contamination to be generally below normal background levels.
Storm water run-off showed no significant contamination. Storm sewer
sediments showed the presence of organics currently being used on-
site.
DOCUMENTATION OF SIGNIFICANT CHANGES
The Proposed Plan for the Preferred Plating Site was released to the
public in July 1989. The Proposed Plan identified Alternative 3 as
the preferred remedy and Alternative 2 as ..the contingency remedy.
EPA reviewed all comments submitted during the public comment period.
Upon review of these comments, it was determined that no significant
changes to the selected remedy, as it was originally identified in
the Proposed Plan, were necessary.
SUMMARY OF SITE RISKS
The National Contingency Plan requires that a Risk Assessment (RA) be
conducted to document and justify whether an imminent and substantial
risk to public health or the environment may exist at a Superfund
site. The risk assessment for the Preferred Plating Site is
contained in the RI report dated July 1989.
The baseline RA defines the actual and potential risks to human
health and the environment from the presence of the hazardous
substances on and around the Site if no action is taken. The
baseline RA determined that the contaminants in the ground water and
the Site soils have no major negative impact on the environment.
Since the Site is presently covered by a building and pavement, the
only potential pathway with a risk to the public was determined to be
ingestion of contaminated ground water. Although the groundwater
sampling did indicate high levels of heavy metal contamination, there
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is no present direct human exposure to contaminants since the
surrounding population is supplied by public water. However, the
Upper Glacial Aquifer is classified as lib, or potential drinking
water, and therefore, a potential risk to human health would exist in
the event that this aquifer is developed for use. Also, the
potential for off-site downward migration of contaminants exists due
to a possible connection off-site between the Magothy and Upper
Glacial Aquifers.
A comparison of the concentrations of chemicals in the ground water
with applicable or relevant and approriate requirements (ARARs)
indicated that numerous inorganic and organic compounds are in
exceedance of those ARARs. Based on this comparison, the inorganics
cadmium, chromium, lead, nickel and cyanide were evaluated and
modeled in the RA. Although not all of the organic contaminants of
concern exceeded ARARs, they were carried through the RA because they
are potential carcinogens.
Based on the review of available data, the Site geology and the
results of the public health evaluations, a significant non-
carcinogenic risk from consumption of the Upper Glacial Aquifer
ground water exists at the Preferred Plating Corporation Site. Given
the potential risk posed by the contribution of metal contamination
by the Site, the following Remedial Objective was developed for the
first operable unit (OU I):
A Reduce the groundwater contaminant concentrations in the Upper
Glacial Aquifer underlying the Site to upgradient
concentrations. .
The second operable unit (OU II) will attempt to identify and control
the upgradient source area. The selected remedy,for OU I is only a
portion of a total remedial action, including OU II, and will attain
all clean-up levels when fully completed.
The quantitative clean-up levels for remediating the ground water are
presented in Table 2. In removing contaminated ground water, any
contributing sources of contamination in the saturated soils beneath
the building will be indirectly removed.
Actual or threatened releases of hazardous substances from this Site,
if not addressed by implementing the response action selected in this
ROD, may present an imminent and substantial endangerment to public
health, welfare, or the environment.
DESCRIPTION OF ALTERNATIVES
This section describes the remedial alternatives which were
developed, using suitable technologies, to meet the objectives of the
National oil and Hazardous Substances Pollution Contingency Plan
(NCP), 40 CFR Part 300, and the Comprehensive Environmental Response,
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Compensation, and Liality Act (CERCLA),' 42 USC ง 9601, et seq. These
alternatives were developed by screening a wide range of technologies
for their applicability to site-specific conditions and evaluating
them for effectiveness, implementability, and cost.
A comprehensive list of remedial technologies was compiled for
remediation of the ground water. These technologies were screened
based on the characteristics of the Site. Those technologies which
were retained after the preliminary screening process were assembled
to form seven groundwater alternatives. The alternatives developed
for the Preferred Plating Site are detailed below. The restoration
time frames provided below assume that a source of contamination
exists in the saturated soils located beneath the building and will
continue to exist and contribute to ground water contamination. The
findings of the second operable unit may affect the following time
frames.
Alternative 1 - No Action
Construction Cost: $ 12,700
Annual O&M Costs: $ 11,600
Present Worth Cost: $ 175,300
Construction Time: 1 month
Restoration Time: 19 years
The no-action alternative is required by the NCP to be considered
through the detailed analysis. It provides a baseline for comparison
of other alternatives. Under this alternative, a public awareness
program will be developed describing the risks associated with the
Site. In addition, existing monitoring wells will be used to conduct
long-term monitoring of the contaminant concentrations in the Upper
Glacial Aquifer underlying the Site until such time that the
downgradient contaminant concentration levels reach upgradient levels
due to natural attenuation.
Alternative 2 - Pumping/Precipitation of Metals/Activated Carbon/
Reinjection
Construction Cost: $ 2,286,900
Annual O&M Costs: $ 1,071,300
Present Worth Cost: $ 10,899,600
Construction Time: 18 months
Restoration Time: 12 years
This alternative consists of one on-site collection well for the
extraction of contaminated ground water to be sent for treatment.
Groundwater modelling predicts that the extraction system will
capture essentially all the ground water in the Upper Glacial Aquifer
over a capture radius of 150 feet by providing a continual flow of
300 gallons per minute to the treatment plant. The influent ground
water will enter the treatment plant where it will first go through a
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2-stage precipitation and clarification/filtration unit for the
removal of all heavy metals/ followed by a carbon adsorption unit for
removal of volatile organic compounds. The metals treatment will
generate 4, 55-gallon drums of wet cake per day to be ultimately
disposed of in a Resource, Conservation and Recovery Act (RCRA)
subtitle C facility. The treatment scheme is a proven technology
capable of removing the contaminants of concern from the ground
water. The ground water pumped from the Site shall be treated to
satisfy all federal and state standards for class lib waters,
potential drinking waters, prior to reinjection." The treated ground
water will be discharged to a reinjection well installed east of the
Site and upgradient of both the extraction well and former leaching
pits. In order to evaluate the effectiveness of this remedial
action, periodic sampling for metal and volatile organic
concentrations in the ground water prior to reinjection will be
required.
Alternative 3 - Pumping/Precipitation of Divalent Metals/Activated
Carbon/Ion Exchange/Reinjection
Construction Cost: $ 1,923,900
Annual O&M Costs: $ 920,900
Present Worth Cost: $ 9,327,400
Construction Time: 18 months
Restoration Time: 12 years
Under this alternative, the same extraction system is used to
withdraw the contaminated ground water as that of Alternative 2. The
treatment scheme differs in that only the .divalent metals will be
treated by a precipitation unit, whereas the chromate ion will be
treated with an ion exchange unit. The ion exchange process is a
proven technology, however, a treatability study must be performed to
demonstrate if the concentrations of chromium can be reduced to the
necessary levels. The equipment used in the treatment scheme
occupies less space and, therefore, the treatment plant will 'be
smaller than that needed for Alternative 2. The reinjection scheme
will be identical to that of Alternative 2.
Alternative 4 - Pumping/Precipitation of Metals/Activated Carbon/
Discharge to Recharge Basin
Construction Costs: $ 2,547,700
Annual O&M Costs: $ 1,071,300
Present Worth Cost: $ 11,160,500
Construction Time: 18 months
Restoration Time: 12 years
The collection and treatment systems in this alternative are both
identical to Alternative 2. The discharge system differs in that the
treated ground water will be pumped approximately 2,000 feet south of
the site, through an underground pipeline, to a recharge basin.
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Alternative 5 Pumping/Precipitation of Divalent: Metals/Activated
Carbon/Ion Exchange/Discharge to Recharge Basin
Construction Costs: $ 2,184,800
Annual O&M Costs: $ 920,900
Present Worth Cost: $ 9,588,300
Construction Time: 18 months
Restoration Time: 12 years
The collection and treatment systems in this alternative are both
identical to Alternative 3. The discharge system is identical to
Alternative 4.
Alternative 6 - Pumping/Precipitation of Metals/Activated Carbon/
Discharge to Surface Water
Construction Costs: $ 4,333,300
Annual O&M Costs: $ 1,071,300
Present Worth Cost: $ 12,946,100
Construction Time: 18 months
Restoration Time: 12 years
This alternative is essentially identical to Alternative 4 except
that the treated ground water will be discharged at the headwater of
the Amityville Creek, through a 9,000 foot underground pipeline. The
concentration levels required for discharge to surface water are
lower for certain chemicals than the levels for discharge to ground
water. The more stringent surface water discharge limitations are
technically impossible to achieve using available technologies.
Alternative 7 - Pumping/Precipitation of Divalent Metals/Activated
Carbon/Ion Exchange/Discharge to Surface Water
Construction Costs: $ 3,970,400
Annual O&M Costs: $ 920,900
Present Worth Cost: $ 11,373,900
Construction Time: 18 months
Restoration Time: 12 years
The collection and treatment systems of this alternative are both
identical to Alternative 3 and the discharge system is identical to
Alternative 6.
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SUMMARY OF THE COMPARATIVE ANALYSIS OF ALTERNATIVES
All alternatives were evaluated in detail utilizing nine criteria.
These criteria were developed to address the requirements of Section
121 of the Superfund Amendments and Reauthorization Act (SARA) of
1986. The nine criteria are as follows:
Threshold Criteria A Overall protection of human health and the
environment; and
A Compliance with applicable or relevant and
appropriate requirements.
Primary Balancing A Long-term effectiveness and permanence;
Criteria A Reduction in toxicity, mobility, or volume
through treatment;
A Short-term effectiveness;
A Implementability; and
A Cost.
Modifying Criteria A State/support agency acceptance; and
A Community acceptance.
The discussion which follows provides a summary of the relative
performance of each alternative with respect to the nine criteria.
Overall Protection of Human Health and the Environment
This criterion addresses whether or not a remedy provides adequate
protection and describes how risks are eliminated, reduced or
controlled through treatment, engineering controls, or institutional
controls.
Protection of human health and the environment is the central mandate
of CERCLA. Protection is achieved primarily by taking appropriate
action to ensure that there will be no unacceptable risks to human
health or the environment through any exposure pathways. No direct
risk to human health or the environment presently exists because the
ground water in the immediate vicinity of the Site is not currently
used as a potable water source.
Alternatives 2-7 will require 12 years, while Alternative 1 will
require 19 years, to achieve downgradient contaminant concentration
levels equal to upgradient levels. When this has been achieved, the
saturated soils underlying the Site will have essentially been
flushed of any contaminants, thereby resulting in no net contribution
of contaminants to the aquifer below. All treatment alternatives,
aside from the no-action alternative, will result in permanent
protection of the environment and human health through the reduction
in toxicity, mobility, and volume of the contaminants.
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Coropllance with ARARs
This criterion addresses whether or not a remedy will meet all
applicable or relevant and appropriate requirements and/or provide
grounds for invoking a waiver. ARARs can be chemical-specific,
location-specific, or action-specific.
Alternatives 2- 5 achieve ARARs to a similar degree and more so than
Alternatives 6 and 7. None of the alternatives will achieve
chemical-specific ARARs for ground water rated lib, potential
drinking water, unless off-site upgradient sources are removed.
Although the selected remedial action, the first operable unit, will
not meet chemical-specific ARARs, it is only part of a total remedial
action that will attain such clean-up levels when fully completed. A
second operable unit will be conducted in an attempt to identify
upgradient sources of contamination. In the event the second
operable unit fails to identify or control upgradient sources, a
waiver for technical impracticabilty will be sought.
Alternatives 2-7 will meet action-specific ARARs. Under
alternatives 2-5, treated ground water will meet pertinent federal
and state ARARs for either reinjection or discharge to the recharge
basin. Under Alternatives 6 and 7, ground water will be treated as
close as technically possible to the Class C surface water body
ambient standards for parameters of concern since it is technically
impracticable to meet all of these standards. A technical
impracticability waiver would also be needed for discharge to surface
waters if Alternatives 6 or 7 were selected.
Reduction of Toxicitv. Mobility, or Volume
This evaluation criterion relates to the anticipated performance of a
remedial technology, with respect to these parameters, that a remedy
may employ.
Alternatives 2-7 will control the mobility of the contaminants,
contributed by the Site, by extraction within the Upper Glacial
Aquifer over a 150-foot radius capture zone. These alternatives will
also significantly reduce or eliminate the toxicity and volume of the
contaminated ground water by treating to remove metals and volatile
organics. Alternative 1 will gradually reduce the toxicity1and
volume of the contaminated ground water by natural attenuation but
will do nothing to prevent the migration of contaminants.
Short-term Effectiveness
This criterion involves the period of time each alternative needs to
achieve protection and any adverse impacts on human health and the
environment that may be posed during construction and implementation
of the alternative.
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Alternative 1 will take approximately 1 month to implement and
presents no short-term risks to on-site workers or the community.
Alternatives 2-7 present minimal short-term risks to workers
through direct contact pathways and normal construction hazards
during remedial action. Each of these alternatives will take
approximately 12 years to achieve remediation goals, with their
respective construction phases being completed in two years or less.
Long-term Effectiveness and Permanence
This criterion refers to the ability of a remedy to maintain reliable
protection of human health and the environment over time, once clean-
up levels have been met. It also addresses the magnitude and
effectiveness of the measures that may be required to manage the risk
posed by treatment residuals and/or untreated wastes.
Alternatives 2-7 present no long-term threat to public health
because these alternatives are designed to reduce contaminant
concentrations in the ground water to levels that are health
protective prior to discharge. Alternative 1 may present a long-term
risk because it relies on natural attenuation of ground water to
reduce contaminant concentrations to action levels.
Implementability
This criterion involves the technical and administrative feasibility
of a remedy, including the availability of materials and services
needed to implement the chosen solution.
Alternative 1 will require a public awareness program and groundwater
monitoring which can be easily implemented. Alternatives 2-7 may
require off-site property procurement for construction of a treatment
plant if the plant cannot be placed on-site. Equipment used in the
treatment schemes are readily available. The differences in
implementability between Alternatives 2-7 depend upon the degree' of
access needed for the discharge system involved in each and the need
for treatability studies. Alternatives 2 and 3 will require the
installation of one reinjection well which will require property
rights for the well placement and a 500 foot underground pipeline.
Pipelines, totaling 2,000 feet, needed for discharge to the recharge
basin under Alternatives 4 and 5 will be installed beneath public
roads. Pipelines, totaling 9,000 feet, needed for discharge to
surface water under Alternatives 6 and 7 will be installed beneath
both public and private properties.
Alternatives 3, 5, and 7 require a treatability study to ensure the
effectiveness of the ion exchange process involved in each and,
therefore, their respective implementation time frames are 6 months
longer than Alternatives 2, 4, and 6.
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Cost
This criterion includes both capital and operation and maintenance
(O&M) costs. Cost comparisons are made on the basis of present worth
values. Present worth values are equivalent to the amount of money
which must be invested to complete a certain alternative at the start
of construction to provide for both construction costs and O&M costs
over time. Present cost estimates for all of the alternatives are as
follows:
Alternative 1: $ 175,300
Alternative 2: 10,899,600
Alternative 3: 9,327,400
Alternative 4: 11,160,500
Alternative 5: 9,588,300
Alternative 6: 12,946,100
Alternative 7: 11,373,900
Alternative 1, no-action, will be the least costly to implement
followed by Alternatives 3, 5, 2, 4, 7, and 6.
State Acceptance
The State of New York, through the New York State Department of
Environmental Conservation (NYSDEC), has concurred with EPA's
selected remedy and contingency remedy. The NYSDEC letter of
concurrence is attached as Appendix IV.
Community Acceptance
No objections from the community were raised regarding the selected
remedy or the contingency remedy. Community comments can be reviewed
in the August 3, 1989 public meeting transcript, which has been
included in the Administrative Record. A responsiveness summary
which addresses all comments received during the public comment
period is attached as Appendix V.
THE SELECTED REMEDY
Based upon all available data and analyses conducted to date, EPA has
selected Alternative 3: Pumping/Precipitation of Divalent Metals/
Activated Carbon/Ion Exchange/Reinjection as the most appropriate
solution for meeting the goals of this remedial investigation. This
alternative does involve a treatability study to ensure that the ion
exchange unit can meet all necessary treatment level requirements for
the chromate ion. In the event the treatability study indicates that
the ion exchange process is ineffective in reducing the chromate ion
to the necessary levels, Alternative 2: Pumping/Precipitation of
Metals/Activated Carbon/Reinjection will be selected as the
contingency remedy.
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For both the selected remedy and the contingency remedy, ground water
within a capture zone radius of approximately 150 feet will be
extracted and treated to remove heavy metals and chlorinated
hydrocarbons. The treated ground water will be reinjected to the
underlying aquifer, the Upper Glacial Aquifer. The treatment
residuals will be disposed of in a RCRA subtitle C facility. The
major components of the selected remedy and the contingency remedy
are depicted in Figures 3 and 4, respectively.
The purpose of this response action is to control risks posed by the
ingestion of contaminated ground water by addressing the following
issues:
* The divalent metal concentrations (cadmium, lead, and nickel)
will be reduced through a metals precipitation process
involving a clarification/filtration unit.
.A The chlorinated organic concentrations (1,1,1-trichloroethane,
trichloroethylene, 1,2-dichloroethane, 1,1-dichlorpethane, and
tetrachloroethylene) will be reduced using carbon adsorption.
A The chromate ion will be reduced using an ion exchange process
as stated in the selected remedy, or a precipitation process as
stated in the contingency remedy.
During the remedial design phase of the project, additional sampling
will be conducted to check for any changes in contaminant levels. If
this sampling indicates concentrations of'cyanide above the allowable
state and federal standards, a treatment process for cyanide removal
will be added to the selected alternative. This treatment process is
known as alkaline chlorination. The process is depicted in Figure 5.
All contaminant concentrations will be reduced until they are equal :
to or less than their respective federal or state standards'prior to
reinjection. The treated effluent will be tested to ensureithat the
treatment system is operating efficiently. Any waste residuals
generated by the treatment processes will be disposed of in
accordance with applicable disposal standards. Although the remedial
action selected, the first operable unit, will not meet chemical-
specific ARARs, it is only part of a total remedial action that will
attain such cleanup levels when fully completed.
STATUTORY DETERMINATIONS
EPA believes that both the selected remedy as well as the contingency
remedy will satisfy the statutory requirements of providing
protection of human health and the environment, being cost-effective,
utilizing permanent solutions and alternative treatment technologies
or resource recovery technologies to the maximum extent practicable,
and satisfying the preference for treatment as a principal element.
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Protection of Human Health and the Environment
The selected remedy and the contingency remedy eliminate all
outstanding threats posed by the site. Both remove any contribution
of contaminants in the saturated zone to the underlying aquifer and
reduce contaminant concentration levels in that aquifer to upgradient
levels.
Compliance with ARARs
The following ARARs and considerations apply to both the selected
remedy and the contingency remedy:
Action-specific ARARs:
A SDWA Maximum Contaminant Levels (40 CFR 141.11 - 141.16), 6 NYCRR
Part 703, and 10 NYCRR Part 5 provide standards and goals for
toxic compounds for public drinking water systems. The
reinjection process for the treated ground water will meet
underground injection well regulations by its status as a
Superfund remedial action under 40 CFR 147. The extracted
ground water will be treated to meet all standards prior to
reinjection.
A Spent carbon from the groundwater treatment system for removal
of organics will be disposed of off-site, as well as any
treatment residuals, consistent with applicable RCRA land
disposal restrictions under 40 CFR 268.
Chemical-specific ARARs:
A Since the ground water at the site is classified as lib,
drinking water standards are relevant and appropriate. Again,
these include SDWA MCLs, 6 NYCRR Groundwater Quality Regulations
and/or limitations of discharges to Class GA waters, and 10 NYCRR
Part 5 standards.
Location-specific ARARs:
none
other Criteria, Advisories/ or Guidance To Be Considered:
A NY TOGS 2.1.2 and l.l.l provide standards for reinjection of
treated ground water and are to be considered. SDWA MCL Goals
(40 CFR 141.50 - 141.51) provide goals for toxic compounds for
public drinking systems and are also to be considered.
-------
-16-
Neither the selected remedy nor the contingency remedy, by itself,
will meet all chemical-specific ARARs and be capable of restoring
area ground water to groundwater quality standards until upgradient
source areas are removed. The second operable unit will attempt to
identify and control the upgradient sources. Although the selected
remedial action, the first operable unit, will not meet chemical-
specific ARARs, it is only part of a total remedial action that will
attain such cleanup levels when fully completed. In the event the
second operable unit fails to identify those sources, a waiver of
ARARs for technical impracticability will be sought. In this case,
treatment of the ground water will continue until the concentration
of contaminants in ground water downgradient of the Site is less than
or equal to concentrations in ground water upgradient of the Site.
At that time, groundwater recovery and treatment will be discontinued
even though area ground water may not meet applicable groundwater
quality standards.
Cost Effectiveness
The preferred alternative, Alternative 3, provides overall
effectiveness proportionate to its cost. It is $1.5 M less costly
than the contingency remedy, Alternative 2, and offers comparable
performance, requires construction of a smaller treatment plant, and
has a lower possibility of initiating secondary pollution problems.
Utilization of Permanent Solutions and Alternative Treatment
Technologies or Resource Recovery Technologies to the Maximum
Extent Possible
EPA has determined .that the selected remedy as well as the
contingency remedy represents the maximum extent to which permanent
solutions and treatment technologies can be utilized in a cost-
effective manner for the Preferred Plating Site. The selected remedy
represents the best balance of the nine evaluation criteria used to
judge all alternatives.
The groundwater treatment used in both the selected and contingency
remedies will reduce the contaminants of concern to health protective
levels prior to reinjection. After treatment is complete, the Site
will no longer be contributing contaminants to the underlying
aquifer.
Preference for Treatment as a Principal Element
The statutory preference for treatment is satisfied by both the
selected remedy and contingency remedy which employ on-site treatment
of the ground water through different precipitation technologies and
carbon adsorption. These treatment methods effectively reduce the
toxicity, mobility, and volume of the contaminants.
-------
APPENDIX I
FIGURES
-------
PREFERRED
PLATING
PREFERRED PLATING SITE RI/F8
SITE LOCATION MAP
FIGURE 1
SCALE 124000
40*45'
-------
B>
t
MWIOf
i ', ป
ill 3{l I TJA AUTO SALES
j ' I " 4 ' j ! 32 ALLEN BLVD. .
! i ^ ! ' PTK AUTO MEPAIK MWซ8P[
! FOHMEH LEACHINO nil
!ii . Mwass
j CRK ELECTRIC
I j 1 1 1 MW6(
^MW48P pi J, (51 4
SSI 8B4Q SB> MW28P
8 A trOIIM PMM* III
(*) iNntnwnoN mmm 1*1
HUMIUMNU MILS :
1 ฎ tHMUONWIUin
*B n ML ANOLI MMMM 1(1 MerENREO KAIINO VIE
ICAlCINrCET ^=3 OANAOC DOOMS FIOUMI I
^^ DOORS (MSItlMOMITOIimatMtlS
AMO lAUri INO IOCAIIONS
-------
FIGURE 3
PROCESS FLOW SCHEME FOR ALTERNATIVE 3
CROUNDWATER
SODIUM SULFIDE
SODIUM HYDROXIDE
EQUALIZATION
TANK
TREATED CROUNDWATER
TO DISCHARGE
CONCENTRATED SOLUTION
TO DISPOSAL
COAGULANT
POLYMER
RAPID MIXING TANK
SLUDGE CAKE
TO DISPOSAL
ION EXCHANGE
SYSTEM
CARBON
ADSORBER
BACKWASH
LAMELLA
CLARIFIER
{ SLUDGE
FILTER PRESS
SYSTEM
SAND
FILTER
SYSTEM
DISCHARGE
PUMP
COLLECTION
TANK
NOTATION
INTERMITTANT'
OPERATION
-------
FIGURE 4
PROCESS' FLOW SCHEME FOR ALTERNATIVE 2
CROUNDWATER
I
EQUALIZATION
TANK
SODIUM SULFIDE
SODIUM HYDROXIDE
FEED
PUMP
COAGULANT
POLYMER
l T
RAPID MIXING TANK
t
LAMELLA
CLARIFIER
FILTRATE
JSLUDGE
SLUDGE CAKE
TO DISPOSAL
FILTER PRESS
SYS7FM
BACKWASH
,POLYMER AND COAGULANT
SODIUM
HYDROXIDE
TREATED
CROUNOWATER
TO DISCHARGE
SAND
FILTER
SYSTEM
SULFURIC
ACID
t T
SULFUR
I DIOXIDE
T
CHROMIUM
REDUCTION
TANK
DISCHARGE
PUMP
SLUDGE CAKE
TO DISPOSAL
FILTER PRESS
SYSTEM
FILTRATE
NOTATION
INTERMITTANT
OPERATION
-------
FIGURE 5 .
PROCESS FLOW SCHEME FOR CYANIDE REMOVAL BY AKLALINE CHLORINATION
CROUNDWATER
CAUSTIC
I
SODIUM HVPOCHLORITE
vv
CONTACT
TANK
FEED
PUMP
1
EQUALIZATION
TANK
TO DOWNSTREAM
PROCESS STEPS
FEED
PUMP
COMMENT;
THE CONTACT TANK IS USED FOR THE
FIRST-STAGE CHLORINATION, AND THE
EQUALIZATION TANK IS USED AS THE
SECOND-STAGE CHLORINATION.
-------
APPENDIX II
TABLES
-------
TABLE 1
PRIMARY CONTAMINANTS IN GROUNDWATER
PREFERRED PLATING
Comoonent Ranoe
Cadmium 8 .
Chromium 56.
Lead 4.
Mercury 0.
Nickel 39.
Silver 1.
Zinc 30.
Cyanide 10.
1, 1, 1-trichloro-
ethane
Trichloroethylene
1,2-dichloroe thane
Benzene
1, 1-dichloroethane
Tetracljloroethylene
Toluene
4-399
3-5,850
6-437
27-0.40
9-358
1-18.5
3-1,330
5-830
2-13
1-8
2-5
1-12
1-3
1-17
3-11
CORPORATION SITE
Median
79
479
143
0
212
12
573
82
3
2
2
2
1
1
2
.
.5
.36
.8
.7
.3
.8 . ''
.0
.3
.2
.9
.4
Frequency of
.1 Detection
18/24
23/24
22/24
7/24
15/24
10/24
22/24
7/24
: 9/24
11/24
6/24
4/24
4/24
6/24
3/24
-------
TABLE 2
CLEAN-UP LEVELS
FEDERAL ARARi
MAXIMUM RCRA MAXIMUM SOWA HCL'S CLEAN WATER ACT
CONTAMINANT CONCENTRATION CONCENTRATION LIMIT WOC
Cadoilun
Chromium
Iron
Ltid
Mercury
Nickel
Sliver
Zinc
Cyanide
Toluene
Bcnieni
1,2-nichloro-
elhane
1,1-Olchloro-
e thane
Tetrachloro-
eihylne
Trlehloro-
thylnt
1,1,1-Trleh-
loroethane
399 10
5850 50
81,000 NC
398 50
4 2
358 NC
18.5 SO
133ซ
830
11
'2
5
3
17
a -
13
10 10
SO SO
NC
50 50
2 10
NC 15.4
SO 50
5,000
200
143
5 4Q
5 243
.
0.8
2.7
18.4
NY ArBlENT WATER QUALITY
STANDARDS/GUIDANCE VALUES
DRINKING
WATER
10
50
300
50
2
NC
50
-
-
' 5
5
, 5 /
5
5
5
5
G.W. FOR CLASS "C
DRINKING WATER SURFACE WA
10
50
300
25
-
.NO
50
5,000
200
50
NO
0.8
50
0.7
5
50
1.1
11
300
i 3.2
-
95.6
0.1
30
5.2 (ai
free
cyanide)
-
6
-
-
1
II
-
-------
APPENDIX IV
NYSDEC LETTER OF CONCURRENCE
-------
New York State Department of Environmental Conservation
50 Wolf Road, Albany, New York 12233 ~ 701ฐ
Thomas C. Joriing
Commissioner
Mr. Stephen D. Luftig, P.E.
Director orn 0 0 1G
Emergency & Remedial Response Division OCi L L Is/
U.S. Environmental Protection Agency
Region II
26 Federal Plaza
New York, NY 10278
Dear Mr. Luftig:
Re: Record of Decision (ROD)
Preferred Plating Corp. #152030
The New York State Department of Environmental Conservation (NYSDEC) has
reviewed the draft Record of Decision and its modifications (September
5, 1989) for the referenced site. I am pleased to advise you that the
NYSDEC concurs with the selected remedy.
Since the short schedule will not allow a review of the final ROD before
the September 29, 1989 deadline, my acceptance of the remedy is based on
our reading of the draft copy. In an effort to avoid a misunderstanding
between our offices, the remedy that will.appear in the final"ROD should
be as follows:
DESCRIPTION OF SELECTED REMEDY . .
This operable unit represents the first of two planned for the
site. It addresses the treatment of groundwater contaminated
primarily with heavy metals and volatile organics. The second
operable unit will involve the continued study and possible
remediation of soils located beneath the building on the.site if
the study so indicates. These soils could not be adequately
characterized during the first operable unit. The second operable
unit will also investigate potential sources of upgradient
contamination.
The major components of the selected remedy include:
Extraction and treatment, via metal precipitation,
ion exchange, and activated carbon, of groundwater
in the Upper Glacial Aquifer to restore the
groundwater quality to cleanup levels identified in
the decision summary under the section entitled
Compliance with ARARs; and
Disposal of treatment residuals at a RCRA subtitle C
facility.
-------
Mr. Stephen D. Luftig, P.E. Page 2
Treatability studies will be undertaken to confirm the
effectiveness of the selected remedy. If these studies indicate
that the ion exchange process used in the selected remedy is
ineffective, a contingency remedy, which utilizes a separate
precipitation unit for the removal of the chromate ion, will be
implemented. I
STATUTORY DETERMINATIONS
Both the selected remedy and the contingency remedy are protective
of human health and the environment, are cost-effective, and comply
with Federal and State requirements that are legally applicable or
relevant and appropriate to the remedial action. Both the selected
remedy and the contingency remedy utilize permanent solutions and
alternative treatment technologies to the maximum extent
practicable and satisfy the statutory preference for remedies that
employ treatment that reduce toxicity, mobility, or volume as a
principal element.
Existing groundwater quality data suggests that another source of
groundwater contamination may exist upgradient of the Preferred
Plating Site. If an upgradient source exists, this proposed remedy
may not, by itself, be capable of restoring the area groundwater to
applicable water quality standards. A second operable unit at this
site will attempt to identify and control the apparent upgradient
source. In the event the second operable unit fails to identify
and control the upgradient source, a waiver for technical
impracticability will be sought. In this event, treatment of the
groundwater will continue until the concentration of .-contaminants
in groundwater downgradeent of the Preferred Plating Site is less
than or equal to those contaminants found in groundwater upgradient
of the site. At that time, groundwater recovery and treatment due :
to the Preferred Plating Site will be discontinued even though area
groundwater may not meet applicable groundwater quality standards.
The need for conducting a five-year review will be evaluated upon
completion of the second operable unit.
Additionally, a correction to the section Compliance with ARARs was
agreed on between our staffs. The corrected version is to read:
COMPLIANCE WITH ARARs
At the completion of response actions, both the selected remedy and
the contingency remedy will have complied with the following ARARs
and considerations:
-------
Mr. Stephen 0. Luftig, P.E.
Action-specific ARARs:
Page 3
The reinjection process for the treated groundwater will
meet underground injection well regulations by its status
as a Superfund remedial action under 40 CFR 147.. The
extracted groundwater will be treated to meet all standards
(SDWA Maximum Contaminant Levels [40 CFR Part 141], SDWA
MCL goals [40 CFR Part 141]), 6 NYCRR Part 703 and 10 NYCRR
Part 5, prior to reinjection.
Spent carbon from the groundwater treatment system for
removal of organics will be opposed of off-site, as well
as any treatment residuals, consistent with applicable RCRA
land disposal restrictions undei 40 CFR 268.
Chenl cal -Sped f 1 c ARARs :
Since the groundwater at the site is cla^c
-------
ROD AMENDMENT FACT SHEET
SITB_
Name:
Location/State:
EPA Region:
HRS Score (date):
Site ID #:
Preferred Plating Corporation
Farmingdale, Suffolk County, New York
II
33.76 (Sept. 1984)
NYD980768774
ROD
Date Signed:
Remedy:
Operable Unit #:
Capital Cost:
O & M/Year:
Present Worth:
September 30, 1997
No Further Action/Natural Attenuation
01
$ -0-
Construction Completion: N/A (ROD Amendment served as a
construction completion for site).
$ 5,000/yr (for monitoring)
$ 19,588 (5 yrs O&M assumed)
LEAD
Agency/Type:
Primary Contact:
Secondary Contact:
Main PRP(s):
USEPA/Remedial
Janet Cappelli (212-637-4270)
Doug Garbarini (212-637-4263)
Joseph Gazza & George Paro (prop owners)
(516) 694-1640
WASTE
Type:
Medium:
Origin:
Est. Quantity;
Cadmium
Groundwater
Contamination resulted from improper
storage of wastewater during plating
operations.
N/A (Very little cd remains above MCLs
in groundwater - no plume detected)
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