PB97-963816
EPA/541/R-97/108
January 1998
EPA Superfund
Record of Decision:
Pollution Abatement Services, OU 4
Oswego, NY
9/30/1997
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RECORD OF DECISION
Pollution Abatement Services
City of Oswego, Oswego County, New York
United States Environmental Protection Agency
Region II
New York, New York
September 1997
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DECLARATION FOR THE RECORD OF DECISION
SITE NAME AND LOCATION
Pollution Abatement Services
City of Oswego, Oswego County, New York
STATEMENT OF BASIS AND PURPOSE
This Record of Decision (ROD) documents the U.S. Environmental
Protection Agency's (EPA's) selection of a remedial action to address
the polychlorinated biphenyl (PCB)-contaminated sediments in the
wetlands and creeks in the vicinity of the Pollution Abatement Services
(PAS) Superfund site, in accordance with the requirements of the
Comprehensive Environmental Response, Compensation and Liability
Act of 1980, as amended (CERCLA), 42 U.S.C. §9601 et sea, and to the
extent practicable, the National Oil and Hazardous Substances Pollution
Contingency Plan (NCP), 40 CFR Part 300. This decision document
explains the factual and legal basis for selecting the remedy for the site.
The attached index (Appendix III) identifies the items that comprise the
Administrative Record upon which the selection of the remedial action
is based.
The New York State Department of Environmental Conservation
(NYSDEC) has been consulted on the planned remedial action in
accordance with CERCLA §121(f), 42 U.S.C. §9621(f), and it concurs
with the selected remedy (see Appendix IV).
ASSESSMENT OF THE SITE
The levels of PCBs that are present in the sediments in the depositional
areas of White and Wine Creeks adjacent to the site do not pose a
significant human health risk. The levels of PCBs that are present in
the sediments in the depositional areas of White Creek in the vicinity of
the site may pose an unacceptable risk to ecological receptors that may
use the creek and adjacent wetlands as foraging areas.
DESCRIPTION OF THE SELECTED REMEDY
The selected remedial action represents the fourth remedial phase or
operable unit at the PAS site. The first operable unit dealt with removal
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actions taken from 1973 to 1982 by EPA and NYSDEC. The remedy for
the second operable unit, which involved the containment of the landfill,
was described in a ROD issued in 1984. A ROD for the third operable
unit, issued in 1993, defined a remedy for contamination found in the
groundwater outside of the containment system.
The selected remedy for the fourth operable unit will involve no further
action with long-term monitoring. While the other remedial alternatives
that were evaluated, namely, in-place containment and excavation,
would actively address the PCB-contaminated sediments, they would
significantly disturb productive and diverse wetland habitats located in
the vicinity of the site. Therefore, as the risk levels are relatively low
and PCB sediment concentrations appear to be declining over time, the
no further action with long-term monitoring alternative appears to be the
most appropriate remedial option at this time.
Because the selected alternative may result in sediment contamination
concentrations remaining above ecologically protective levels, long-
term monitoring (including biota sampling) results will be used to assess
this threat on a periodic basis. If justified by this assessment, remedial
actions may be implemented to address the sediment contamination.
DECLARATION OF STATUTORY DETERMINATIONS
The selected remedy meets the requirements for remedial actions set
forth in CERCLA §121, 42 U.S.C. §9621.
EPA has determined that no further physical construction is necessary
at this site; therefore, the site now qualifies for inclusion on the
Construction Completion List. \
Because hazardous substances will remain on-site, the site is subject
to five-year reviews. Long-term monitoring results will be assessed for
this remedy during the five-year reviews related to the other operable
units at the site.
Jean/e M/JFGx , / Date
Regional
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RECORD OF DECISION
DECISION SUMMARY
Pollution Abatement Services
City of Oswego, Oswego County, New York
United States Environmental Protection Agency
Region II
New York, New York
September 1997
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TABLE OF CONTENTS
page
SITE HISTORY AND ENFORCEMENT ACTIVITIES 1
HIGHLIGHTS OF COMMUNITY PARTICIPATION 4
SCOPE AND ROLE OF OPERABLE UNIT 4
SUMMARY OF SITE CHARACTERISTICS 5
SUMMARY OF SITE RISKS 6
REMEDIAL ACTION OBJECTIVES 9
DESCRIPTION OF REMEDIAL ACTION ALTERNATIVES 9
SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES 13
SELECTED REMEDY 19
STATUTORY DETERMINATIONS 20
DOCUMENTATION OF SIGNIFICANT CHANGES 20
ATTACHMENTS
APPENDIX I. FIGURES
APPENDIX II. TABLES
APPENDIX III. ADMINISTRATIVE RECORD INDEX
APPENDIX IV. STATE LETTER OF CONCURRENCE
APPENDIX V. RESPONSIVENESS SUMMARY
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SITE NAME, LOCATION AND DESCRIPTION
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The Pollution Abatement Services (PAS) site, located on 15 acres near
the eastern edge of the City of Oswego, New York, is bounded on the
south by East Seneca Street, and on the east, north, and west by
wetlands formed along the stream channels of White and Wine Creeks
(see Figure 1). Just to the north (downstream) of the PAS site is the
confluence of White and Wine Creeks. Wine Creek flows approximately
1,800 feet beyond the confluence (northward) to a wetland adjacent to
the community of Smith's Beach, and then into Lake Ontario. Prior to
passing through the PAS site, White and Wine Creeks originate in and
flow through farmland to the south. Both White and Wine Creeks are
proximate to the East Seneca Street Dump (also referred to and
operated as the Oswego County Landfill), and White Creek is proximate
to the Niagara Mohawk Fire Training School. The Oswego Castings site
is upstream of the wetland adjacent to Smith's Beach (see Figure 2).
The area between the PAS site and Lake Ontario (to the north) is mostly
undeveloped and currently includes three land uses. These uses (from
west to east) include a cemetery, a wetland, and a residential com-
munity. The residential community, Smith's Beach, consists of
approximately 25 dwellings and is located on the shore of Lake Ontario,
about 1/2 mile north of the PAS site. A public water supply is available
in Smith's Beach.
SITE HISTORY AND ENFORCEMENT ACTIVITIES
The PAS facility, a high-temperature, liquid chemical waste, incineration
facility, operated from 1970 through 1977. Beginning in 1973, a series
of incidents, including liquid waste spills and the overflow of liquid
wastes from lagoons into White Creek, led to the involvement of the
Environmental Protection Agency (EPA) and New York State Department
of Environmental Conservation (NYSDEC) at the site. Response actions
taken from 1973 to 1982 by EPA, NYSDEC, and the Coast Guard
resulted in an oil spill cleanup, the removal of the incineration facilities,
drummed wastes, bulk liquid wastes, and contaminated soils and the
closure of two on-site lagoons. In 1981, the PAS site, which was ranked
number seven on the original National Priorities List (NPL), was
selected as one of the first sites in the nation to receive the
Comprehensive Environmental Response, Compensation, and Liability
Act, as amended, 42 U.S.C. §9601 et seq. (CERCLA) Trust Fund monies
for cleanup actions.
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From 1982 to 1984, NYSDEC performed a Site Investigation and
Remedial Alternatives Evaluation of the PAS site which was the initial
Remedial Investigation/Feasibility Study (RI/FS)conducted at the site.
Based on the results of this study, EPA signed a Record of Decision
(ROD) in 1984, which specified the following remedial actions: limited
excavation and off-site disposal of contaminated materials, installation
of a perimeter slurry wall, site grading and capping in accordance with
Resource Conservation and Recovery Act (RCRA) requirements,
installation of a leachate collection and treatment system, and ground-
water monitoring. NYSDEC implemented the remedial actions identified
in the ROD, with the exception of the on-site treatment system. Rather
than installing an on-site treatment system, the leachate was collected
by NYSDEC from 1986 through 1991 and transported off site to an
approved RCRA treatment and disposal facility.
In October 1991, EPA and a group of potentially responsible parties
(PRPs) entered into a groundwater (leachate) removal Administrative
Order on Consent (AOC). This AOC required routine removal of'leachate
from within the containment system. This AOC was extended by a
second AOC entered into in 1994. The extracted (eachate
(approximately 20,000 gallons every two weeks) is currently transported
to an approved RCRA treatment, storage, and disposal facility.
From 1984 to 1986, NYSDEC performed an environmental assessment
of the area in the vicinity of the PAS site, which included White and
Wine Creeks. Based on the results of the environmental assessment,
NYSDEC determined that no remediation of the creeks was required.
The long-term monitoring program, which was commenced in 1989 by
NYSDEC, includes routine monitoring of the groundwater, and sediments
in the vicinity of the PAS site.
The results of soil gas, groundwater sampling, and down-hole camera
investigations of the existing monitoring wells at the site, conducted
between 1987 and 1990, indicated the presence of VOC contamination
in the groundwater outside the slurry wall containment system.
In September 1990, an AOC was entered into between EPA and a group
of PRPs to conduct a supplemental RI/FS to evaluate the integrity of the
existing containment system at the site, to determine the nature; extent,
and source of contamination and any threat to the public health or the
environment caused by the release of hazardous substances outside the
containment system, and to identify and evaluate remedial alternatives.
The supplemental Rl concluded that the contamination that was detected
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in the groundwater outside the containment system was attributable to
insufficient leachate removal from within the containment system (i.e.,
there had been an outward hydraulic gradient through the slurry wall).
Based upon the results of the supplemental RI/FS, EPA signed a ROD
on December 29, 1993. The 1993 ROD incorporated all of the existing
components of the 1984 ROD, as well as, several additional
components. The selected remedy, as modified by a 1996 Explanation
of Significant Differences (ESD) (described further below) includes: 1)
enhancing the present source control system by optimizing the leachate
extraction rate and other operating parameters in order to achieve, to
the degree practicable, inward horizontal gradients in the overburden
and upward vertical gradients from the bedrock toward the containment
system; 2) off-site treatment of the extracted leachate; 3) connecting
downgradient residents in the Smith's Beach area, who were using
residential wells, to the public water supply to ensure that potential
future exposure to contaminants in the bedrock groundwater does not
occur; and 4) institutional controls on groundwater usage through deed
restrictions at the PAS site and downgradient from the site to and
including the Smith's Beach area.
The 1993 ROD also called for several investigations related to the
enhancement of the source control system. In addition, since there was
some uncertainty related to the source of the polychlorinated biphenyl
(PCB) contamination detected in the sediments in the adjacent wetlands
and White and Wine Creeks, and the source of pesticides detected in
the surface water of Wine Creek1, the ROD called for a study to
determine the sources of PCB and pesticide contamination.
In July 1994, an AOC was entered into by EPA and a group of PRPs to
conduct a supplemental pre-remedial design study (SPRDS) (which was
completed in 1996) related to the investigations called for in the 1993
ROD. In September 1994, an AOC was entered into between EPA and
a group of PRPs to extend the routine groundwater (leachate) removal
called for in the 1991 AOC, and, among other things, to connect down-
gradient residents in the Smith's Beach area, who were using residential
wells, to the public water supply.
PCBs were not detected in the surface water located adjacent to the site and
pesticides were not detected in the sediments located adjacent to the site.
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In September 1996, an ESD was issued. The ESD explained the results
of the additional investigations called for in the 1993 ROD, and modified
the contingent remedy for the treatment of the groundwater (leachate)
to provide for continued off-site treatment and disposal.
On September 26, 1997, EPA and the PRPs executed a Consent Decree
for the performance of the remaining components of the 1993 ROD.
Based upon the results of the 1996 SPRDS, a Focused Feasibility Study
(FFS) was completed in June 1996 to identify and evaluate remedial
alternatives for the PCB-impacted sediments in the vicinity of the PAS
site.
HIGHLIGHTS OF COMMUNITY PARTICIPATION
The FFS report and the Proposed Plan for the site were released to the
public for comment on August 22, 1997. These documents were made
available to the public in the administrative record file at the EPA
Docket Room in Region II, New York and the information repository at
the Oswego City Hall. The notice of availability for the above-
referenced documents was published in the Oswego Palladium Times on
August 22, 1997. The public comment period related to these documents
was held from August 22, 1997 to September 21, 1997.
On September 11, 1997, EPA and NYSDEC conducted a public meeting
at Oswego City Hall to inform local officials and interested citizens
about the Superfund process, to review current and planned remedial
activities at the site, to discuss the Proposed Plan, to receive comments
on the Proposed Plan, and to respond to questions from area residents
and other interested parties. Public interest related to the fourth
operable unit for the site is low. No written comments were submitted
during the public comment period and only two people attended the
public meeting. Responses to questions asked at the public meeting are
included in the Responsiveness Summary (see Appendix V).
SCOPE AND ROLE OF OPERABLE UNIT
The primary objective of this action is to minimize any potential human
health and ecological impacts related to the exposure to contamination
in the creeks and wetlands adjacent to the site.
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SUMMARY OF SITE CHARACTERISTICS
The supplemental Rl and the SPRDS investigated the PCB
contamination in the sediments in the adjacent wetlands and White and
Wine Creeks, and the pesticide contamination in the surface water of
Wine Creek (see Figure 1).
The results of supplemental Rl and the SPRDS indicate that PCBs are
present in the sediments in both creeks, upstream, adjacent to, and
downstream of the PAS site. Total PCB concentrations detected range
from 0.014 to 190 milligrams per kilogram (mg/kg), with the highest
concentration being detected upstream of the PAS site. Only four of the
36 sediment samples collected in the vicinity of the site showed PCB
concentrations exceeding 1 mg/kg2 (the maximum concentration was
11.4 mg/kg; all five of these samples were from White Creek. The only
other sample which exceeded 1 mg/kg was White 1A, which is located
upstream of the PAS site and adjacent to the East Seneca Street Dump.
(See Table 1.)
An analysis of the long-term monitoring sediment data, collected
between 1991 and 1996, revealed that there has been an overall decline
in PCB concentrations in the creeks. The decline in the PCB levels over
time is believed to be due to natural processes, which may include the
deposition of clean sediments over contaminated sediments and/or the
downstream migration and subsequent dilution of contaminated
sediments. A summary of the sediment sampling results is provided in
Table 2.
Trace levels of pesticides, including methoxychlor, endrin, ketone, 4,4'-
DDE, and 4,4'-DDT were detected in upstream White Creek sediment
samples, but not in sediment samples collected adjacent to the site3.
During the Phase II SPRDS, trace levels of dieldrin, beta-BHC, 4,4'-
DDE, and 4,4'-DDT were detected in Wine Creek sediment samples
collected upstream and adjacent to the site. Dieldrin and 4,4'-DDE were
detected (at trace levels) in three of the six surface water samples
collected from Wine Creek upstream and adjacent to the site, and it was
found that pesticides were generally absent from the surface water in
White Creek adjacent to the site.
2 NYSDEC's Technical Guidance for Screening Contaminated Sediments.
3 See the 1993 Supplemental Remedial Investigation Report.
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Based upon the above results, the SPRDS concluded that, while it was
a source of PCB contamination before the construction of the
containment facility in 1986, the PAS site is not a present source of PCB
contamination in the sediments in the adjacent wetlands and Wine and
White Creeks4. The SPRDS also concluded that the PAS site is not the
source of the pesticides in the surface water of Wine Creek. This
conclusion is supported by the historical presence of pesticides, in the
surface water and sediment in Wine Creek upstream of the PAS site, at
greater concentrations than those found adjacent or downstream of the
site.
SUMMARY OF SITE RISKS
Based upon the results of the Supplemental Rl and SPRDS, a baseline
risk assessment was conducted to estimate the risks associated with
current and future site conditions. The baseline risk assessment
estimates the human health and ecological risk which could result from
the contamination at the site, if no remedial action were taken.
Human Health Risk Assessment
A four-step process is utilized for assessing site-related human health
risks for a reasonable maximum exposure scenario: Hazard Identifica-
tion—\denitf\es the contaminants of concern at the site based on several
factors such as toxicity, frequency of occurrence, and concentration.
Exposure ^ssessmenf—estimates the magnitude of actual and/or
potential human exposures, the frequency and duration of these
exposures, and the pathways (e.g., ingesting contaminated well-water)
by which humans are potentially exposed. Toxicity Assessment—
determines the types of adverse health effects associated with chemical
exposures, and the relationship between magnitude of exposure (dose)
and severity of adverse effects (response). Risk Characterization—
summarizes and combines outputs of the exposure and toxicity assess-
ments to provide a quantitative assessment of site-related risks.
PCBs, the contaminant of concern in the sediments, are known to cause
cancer in laboratory animals and are suspected to be human
The SPRDS also identified two additional potential sources of PCBs in the sediments
in the wetlands and creeks in the vicinity of the PAS site—the East Seneca Street
Dump and the Niagara Mohawk Fire Training School (see Figure 2). The State of
New York is responsible for overseeing activities at these non-NPL sites.
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carcinogens. The baseline risk assessment evaluated the health effects
which could result from exposure to PCBs as a result of ingestion of
fish and sediments and dermal contact with the sediments. The receptor
population evaluated included resident children and adults.
Current federal guidelines for acceptable exposures are an individual
lifetime excess carcinogenic risk in the range of 10'4 to 10"6 (e.g., a
one-in-ten-thousand to a one-in-one-million excess cancer risk) and a
maximum health Hazard Index (which reflects noncarcinogenic effects
for a human receptor) equal to 1.0. (A Hazard Index greater than 1.0
indicates a potential for noncarcinogenic health effects.)
All of the carcinogenic risks calculated were within the acceptable
cancer risk range. The results of the baseline risk assessment indicate
that sediment ingestion and dermal contact represent a total cancer risk
of 1.4x10'6 for adults and 8.8x10'6 for children.
Concerning the noncarcinogenic risks, the results of the baseline risk
assessment indicate that the total Hazard Index for exposure to
PCB-contaminated sediments is 0.23 and 1.08 for adults and children,
respectively. A Hazard Index less than 1.0 indicates that adverse,
noncarcinogenic health effects from such exposures are unlikely. The
greater the Hazard Index above 1.0, the greater the level of concern.
Since the Hazard Index value of 1.08 for children is only minimally
above the target Hazard Index value of 1.0, adverse health effects are
not likely to occur. (A summary of the results of the baseline human
health risk assessment is provided in Tables 3 and 4.)
Ecological Risk Assessment
A four-step process is utilized for assessing site-related ecological risks
for a reasonable maximum exposure scenario: Problem Formulation—a
qualitative evaluation of contaminant release, migration, and fate;
identification of contaminants of concern, receptors, exposure
pathways, and known ecological effects of the contaminants; and
selection of endpoints for further study. Exposure Assessment—a
quantitative evaluation of contaminant release, migration, and fate;
characterization of exposure pathways and receptors; and measurement
or estimation of exposure point concentrations. Ecological Effects
/Assessment-literature reviews, field studies, and toxicity tests, linking
contaminant concentrations to effects on ecological receptors. Risk
Characterization—measurement or estimation of both current and future
adverse effects.
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The ecological risk assessment began with evaluating the PCB contami-
nation present in the vicinity of the site in conjunction with the site-
specific biological species/habitat information. A qualitative field survey
and habitat characterization of the PAS site identified potential on-site
habitats of concern—a grassy field overlying the capped area of the
landfill and two wetland habitats (White Creek stream run and the White
Creek ponded marsh).
Following a biological characterization of the resident species
associated with the site, a list was developed for the purpose of
assessing actual or potential risks that may accrue to these receptors
(and other similar species) when exposed to site-related contaminants.
Consideration was given to the economic and/or cultural value of
species, statutory concerns (e.g., threatened or endangered status),
and representation of different species feeding levels, habitats, and
foraging areas. The selected receptor list consisted of the short tail
shrew and mink (as terrestrial fauna), and the mink, green-backed
heron, and spring peeper (as organisms dependent upon the aquatic
environment, i.e., surface water and sediment). In the qualitative
ecological assessment, literature-based values, indicative of
contaminant concentrations that are known to produce adverse effects
to the receptors, were used to screen the affected site media.
Individual toxicity endpoints, such as survival, reproductive effects, and
growth impacts were considered.
The qualitative ecological assessment found that the higher level
aquatic and terrestrial species may be at risk due to the potential for
PCBs to bioaccumulate. Adverse effects related to contaminant toxicity
may be occurring at the site. As PCBs bioaccumulate, affected aquatic
invertebrates may be posing a risk to higher trophic level species who
use them as a food source. The potential for transmitting PCB
contamination through the food chain is present at the site, as PCBs
have been detected in fish (i.e., the fathead minnow, a resident
species). Detected sediment levels are within the range of values
reported to cause the green-backed heron reproductive impairment and
mortality, via their diet. The shrew, typifying small mammals at the site,
is expected to have relatively low exposures to sediments. While the
low exposure may not present a significant adverse health risk to the
shrew, those animals that feed on the shrew (e.g., mink), would be
expected to accumulate PCBs in their tissue. Reproduction or survival
of these higher forms could be impacted via this PCB transfer. Based
upon the results of the qualitative ecological assessment, a potentially
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significant impact may occur to mink if present at the site because of
their sensitivity to PCBs.
In summary, 1) the levels of PCBs that are present in sediments in the
depositional areas of Wine Creek in the vicinity of the site do not pose
a significant human health or ecological risk; 2) the levels of PCBs that
are present in the sediments in the depositional areas of White Creek
in the vicinity of the site do not pose a significant human health risk; 3)
the levels of PCBs that are present in the sediments in the depositional
areas of White Creek in the vicinity of the site may pose an
unacceptable risk to ecological receptors, as represented by the green-
backed heron and mink, that might use the creek and adjacent wetlands
as foraging areas; and 4) while the PAS site was a source of PCB
contamination before the construction of the containment facility, at
present, there are several potential current sources of PCB contamina-
tion located upstream of the site.
REMEDIAL ACTION OBJECTIVES
Remedial action objectives are specific goals to protect human health
and the environment. These objectives are based on available
information and standards such as applicable or relevant and
appropriate requirements (ARARs) and risk-based levels established in
the risk assessment.
In order to address the PCB contamination that is present in the
sediments in White Creek and adjacent wetlands, the following remedial
action objective has been established:
• minimize exposure of fish and wildlife to PCB-contaminated
sediments in White Creek and adjacent wetlands.
DESCRIPTION OF REMEDIAL ACTION ALTERNATIVES
CERCLA §121(b)(1), 42 U.S.C. §9621(b)(1), mandates that a remedial
action must be protective of human health and the environment, cost-
effective, and utilize permanent solutions and alternative treatment
technologies or resource recovery technologies to the maximum extent
practicable. Section 121(b)(1) also establishes a preference for
remedial actions which employ, as a principal element, treatment to
permanently and significantly reduce the volume, toxicity, or mobility of
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the hazardous substances, pollutants and contaminants at a site.
CERCLA §121(d), 42 U.S.C. §9621(d), further specifies that a remedial
action must attain a level or standard of control of the hazardous
substances, pollutants, and contaminants, which at least attains ARARs
under federal and state laws, unless a waiver can be justified pursuant
to CERCLA §121(d)(4), 42 U.S.C. §9621(d)(4).
Since residual PCBs from the PAS site may remain in the sediments in
the vicinity of the site and, therefore, may act as a continuing source of
contamination, an FFS was conducted to identify and evaluate remedial
alternatives to address the PCB-contaminated sediments. This ROD
evaluates, in detail, three remedial alternatives for addressing the PCB-
contaminated sediments associated with the PAS site.
The present-worth costs are calculated using a discount rate of 7
percent and a 30-year time interval. The time to implement reflects only
the time required to construct or implement the remedy and does not
include the time required to design the remedy, negotiate the
performance of the remedy with the responsible parties, or procure
contracts for design and construction.
The remedial alternatives are:
Alternative 1 - No Further Action with Long-Term Monitoring
Capital Cost: $0
Annual Operation & Maintenance Cost: $20,500
Present Worth Cost: $254,400
Estimated Construction Time: 0 months
The Superfund program requires that the "no-action" alternative be
considered as a baseline for comparison with the other alternatives.
The no-action remedial alternative does not include any physical
remedial measures that address the problem of PCB-contaminated
sediments. This alternative would, however, include annual, long-term
monitoring of PCB levels in the sediments and biota in White and Wine
Creeks and the adjacent wetlands in the vicinity of the site.
In light of the fact that this alternative may result in sediment
contamination concentrations remaining at levels that may not be
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ecologically protective, long-term monitoring results would be used to
assess this threat on a periodic basis. If justified by'this assessment,
remedial actions may be implemented to address these sediments.
Alternative 2 - Stream Channel Relocation and In-Place Containment
Capital Cost: $677,200
Annual Operation & Maintenance Cost: $30,000
Present Worth Cost: $1,121,600
Estimated Construction Time: 1 year
This alternative involves the construction of a one-foot vegetated, soil
cover over depositional areas where sediments in White Creek in the
vicinity of the site exceed 1 mg/kg PCBs. Also included is the relocation
of a portion of White Creek where periodic flooding and scouring would
make constructing a soil cover infeasible. The new channel would be
rip-rapped to prevent erosion.
Impiementation of this alternative would require clearing and grubbing
activities, construction of temporary access roads and staging areas,
and implementation of soil erosion and sediment controls.
Once the construction activities are completed, maintenance of the soil
cover and new stream channel would be necessary on a routine basis.
Maintenance of the soil cover would include long-term routine
inspection and repair, and re-vegetation, as necessary. Similarly,
long-term routine inspection of the stream channel would be conducted;
any severe stream bank erosion would have to be addressed.
The implementation of these activities would result in adverse impacts
to the existing wetland, upland habitats and biota. Long-term alteration
of vegetated habitats may decrease the value of a particular area by
reducing wetland functions. Disturbances in wetland habitats may also
allow invasive plant species with relatively low wildlife value to colonize
affected wetlands and establish monocultures, thereby reducing plant
species diversity and eliminating plant species with higher wildlife
value. Capping may alter the water depth and hydrology of the wetland
which may result in changes to the plant and animal communities in the
wetland. Thus, wetland mitigation for this alternative would likely
require some combination of off-site locations or on-site locations
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outside of the remediated area to replace the lost wetland functions.
Further, the restoration of the forested wetland and scrub-shrub wetland
(dominated by willow and alder) may require a time frame of 35-50
years, if at all, as the complete success of any restoration process is
uncertain. Mitigation would be conducted for any wetlands impacted by
remedial activities. The mitigated wetlands would require routine
inspection for several years to ensure adequate survival of the planted
vegetation. Replanting would be performed, if necessary.
Long-term monitoring would be conducted to make sure that there are
no releases from the contained PCB-contaminated sediments.
Alternative 3 - Sediment Excavation
Capital Cost: $1,022,800
Annual Operation & Maintenance Cost: $15,000
Present Worth Cost: $1,410,000
Estimated Construction Time: 1 year
This alternative involves the excavation of sediments exceeding 1 mg/kg
PCBs in White Creek in the depositional areas in the vicinity of the site.
It is estimated that 6,500 cubic yards of PCB-contaminated sediments
would be removed. Clean material would be used as backfill in the
excavated areas. The excavated sediments would be dewatered, as
necessary, prior to being sent off-site for treatment/disposal.
Implementation of this alternative would require clearing and grubbing
activities, construction of temporary access roads and staging areas,
and implementation of soil erosion and sediment controls.
The implementation of these activities would result in adverse impacts
to the existing wetland, upland habitats and biota. Long-term alteration
of vegetated habitats may decrease the value of a particular area by
reducing wetland functions. Disturbances in wetland habitats may also
allow invasive plant species with relatively low wildlife value to colonize
affected wetlands and establish monocultures, thereby reducing plant
species diversity and eliminating plant species with higher wildlife
value.
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SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
In selecting a remedy, EPA considered the factors set out in CERCLA
§121, 42 U.S.C. §9621, by conducting a detailed analysis of the viable
remedial alternatives pursuant to the National Oil and Hazardous
Substances Pollution Contingency Plan, 40 CFR Part 300 (NCP), 40
CFR §300.430(e)(9) and OSWER Directive 9355.3-01. The detailed
analysis consisted of an assessment of the individual alternatives
against each of nine evaluation criteria and a comparative analysis
focusing upon the relative performance of each alternative against those
criteria.
The following "threshold" criteria are the most important and must be
satisfied by any alternative in order to be eligible for selection:
1. Overall protection of human health and the environment addresses
whether or not a remedy provides adequate protection and describes
how risks posed through each exposure pathway (based on a
reasonable maximum exposure scenario) are eliminated, reduced, or
controlled through treatment, engineering controls, or institutional
controls.
2. Compliance with ARARs addresses whether or not a remedy would
meet all of the applicable (legally enforceable), or relevant and
appropriate (pertaining to situations sufficiently similar to those
encountered at a Superfund site such that their use is well suited to
the site) requirements of federal and state environmental statutes
and requirements or provide grounds for invoking a waiver.
The following "primary balancing" criteria are used to make comparisons
and to identify the major tradeoffs between alternatives:
3. Long-term effectiveness and permanence refer to the ability of a
remedy to maintain reliable protection of human health and the
environment over time, once cleanup goals have been met. It also
addresses the magnitude and effectiveness of the measures that
may be required to manage the risk posed by treatment residuals
and/or untreated wastes.
4. Reduction of toxicity, mobility, or volume via treatment refers to a
remedial technology's expected ability to reduce the toxicity,
mobility, or volume of hazardous substances, pollutants or
contaminants at the site.
13
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5. Short-term effectiveness addresses the period of time needed to
achieve protection and any adverse impacts on human health and
the environment that may be posed during the construction and im-
plementation periods until cleanup goals are achieved.
6. Implementability refers to the technical and administrative feasibility
of a remedy, including the availability of materials and services
needed.
7. Cosf includes estimated capital and operation and maintenance
costs, and the present-worth costs.
The following "modifying" criteria are considered fully after the formal
public comment period on the Proposed Plan is complete:
8. State acceptance indicates whether, based on its review of the FFS
report and the Proposed Plan, the State supports, opposes, and/or
has identified any reservations with the selected alternative.
9. Community acceptance refers to the public's general response to the
alternatives described in the Proposed Plan and the FFS report.
Factors of community acceptance to be discussed include support,
reservation, and opposition by the community.
The following is comparative analysis of the remedial alternatives based
upon the evaluation criteria noted above.
• Overall Protection of Human Health and the Environment
While Alternative 1 (no further action) would not actively address the
potential ecological risks posed by the contaminated sediments in White
Creek, these risks appear to be relatively low. In addition, the PCB-
contaminated sediments do not pose a significant human health risk.
PCB levels in the sediments in White Creek appear to be declining over
time, this decline is believed to be caused by the deposition of clean
sediments, and/or the downstream migration and subsequent dilution of
contaminated sediments. Despite the deposition of clean sediments,
and/or the downstream migration, and subsequent dilution of
contaminated sediments, there is the potential for this area to become
recontaminated by the transport of PCB-contaminated sediments from
known upstream sources.
14
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Although Alternatives 2 and 3 would provide lower residual risks to the
environment relative to the no further action alternative, they would
involve significant disturbance of 1.5 to 2 acres of productive and
diverse wetland habitats, as well as, additional areas of upland habitats
for staging areas, access roads, and other support facilities. In addition,
it would take a considerable amount of time before a diverse and fully
functioning plant community would be reestablished5. Furthermore,
although exposure to PCB-contaminated sediments would be reduced
initially, there is the potential for this area to become recontaminated
by the transport of PCB-contaminated sediments from known upstream
sources.
• Compliance with ARARs
Since Alternative 3 (excavation) would involve the excavation of PCB-
contaminated sediments, their disposition would be governed by the
requirements of the Toxic Substances Control Act.
Alternatives 2 (in-place containment) and 3 (excavation) would result in
significant short-term and long-term impacts to existing wetland habitats
located within the floodplain and the coastal zone from PCB
contamination. Therefore, mitigation of the impacts to the wetlands,
floodplains, and the coastal zone in compliance with the respective
ARARs would be required. No further action, on the other hand, would
not impact the wetlands, floodplains, and the coastal zone.
• Long-Term Effectiveness and Permanence
Since the PCB-contaminated sediments do not pose a significant human
health risk, Alternative 1 (no further action) would provide reliable
protection of human health over time. Sediment sample data from 1991
to 1996 show a decrease in PCB sediment concentrations over time.
This decrease is presumably due to the deposition of clean sediments
and/or the downstream migration and subsequent dilution of
contaminated sediments.
The restoration of the forested wetland and scrub-shrub wetland (dominated by
willow and alder) may require a time frame of 35-50 years, if at all, as the complete
restoration process is uncertain.
15
-------
The excavation alternative (Alternative 3) would be much more effective
and permanent than the in-place containment alternative (Alternative 2)
in terms of reducing ecological exposure to PCB-contaminated
sediments, because the sediments would be removed.
Although both intrusive alternatives would provide lower residual risks
to the environment than the no-action alternative, the implementation of
these activities would result in adverse impacts to the existing wetland
and upland habitats and biota. In addition, it would take a considerable
time before a diverse and fully functioning plant community would be
established. Furthermore, although exposure to PCB-contaminated
sediments would be reduced initially under these alternatives, the
potential exists for this area to become recontaminated by the transport
of PCB-contaminated sediments from known upstream sources.
• Reduction in Toxicitv. Mobility, or Volume Through Treatment
Alternative 1 (no further action) would not actively reduce the toxicity,
mobility, or volume of contaminants through treatment. This alternative
would rely on the deposition of clean sediments to reduce the levels of
contaminants.
While in-place containment (Alternative 2) or excavation (Alternative 3)
of the contaminated sediments would prevent further migration of and
potential exposure to these materials, the reduction in mobility would
not be accomplished through treatment.
• Short-Term Effectiveness
Alternative 1 (no further action) does not include any physical
construction measures in any areas of contamination. Therefore, the
implementation of this alternative would not present any short-term,
adverse ecological or human health risks. Alternative 2 involves
relocation of the stream channel and covering contaminated sediments
and Alternative 3 involves excavating and transporting contaminated
sediments off-site.
While Alternative 2 presents some risk to on-site workers through
dermal contact, and Alternative 3 presents some risk to on-site workers
through dermal contact and inhalation, these exposures can be
minimized by utilizing the proper protective equipment. The traffic
16
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associated with transporting cover materials (Alternative 2) and the off-
site transport of contaminated sediments (Alternative 3) could impact
the local roadway system and nearby residents through increased noise
levels. Although silt curtains could be used to contain suspended solids
during excavation activities, there could be some releases of PCB-
contaminated sediments, which might increase ecological exposures in
the short term. Disturbance of the land during construction could affect
surface water flow at the site. In addition, there would be a potential for
increased stormwater runoff and erosion during construction activities
that must be properly managed.
Although both intrusive alternatives would provide lower residual risks
to the environment than the no further action alternative, they would
involve significant disturbance of 1.5 to 2 acres of productive and
diverse wetland habitats, as well as, additional areas of upland habitats
for staging areas, access roads, and other support facilities.
In-place containment, relocation of the stream channel, and excavation
would seriously damage the productive and diverse ecological
community that currently exists in the vicinity of the site, resulting in a
loss of habitats. While Alternatives 2 and 3 would both seriously impact
the wetlands, the potential impacts would be much greater for the in-
place containment alternative than for the excavation alternative, due
to the permanent changes to the wetland hydrology and the resulting
higher elevations associated with placing a one-foot vegetated soil
cover over the depositional areas.
Although exposure to PCB-contaminated sediments would be reduced
initially under Alternatives 2 and 3, there is the potential for this area
to become recontaminated by the transport of PCB-contaminated
sediments from known upstream sources.
• Implementabilitv
In-place containment, creation of a new stream channel, excavation of
the contaminated sediments, and off-site transportation of the
sediments, although implementable, would be more difficult to
implement than the no further action alternative. Alternatives 2 (in-
place containment) and 3 (excavation) can be accomplished using
technologies known to be reliable, and equipment, services and
materials for this work would be readily available. These actions would
also be administratively feasible.
17
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• Cost
The estimated capital, annual operation and maintenance (O&M), and
present-worth costs for each of the alternatives are presented below.
Alternative
No Further Action
In-Place Containment
Excavation
.. V'.papiUi^iM;;
$0
$677,200
$ 1,022,800
Annual
O&M
$20,500
$30,000
$15,000
Present Worth
$254,400
$ 1,121.600
$ 1,410,000
Under the no further action alternative, no remedial activities would be
conducted; thus, no capital costs would be expected to be incurred.
Annual monitoring of PCB levels in sediments would be conducted to
ensure that concentrations are not increasing; PCB levels in biota would
also be monitored. The cost of the monitoring is expected to be
approximately $24,000 per year; the present-worth cost of this
alternative is estimated to be approximately $370,0006, significantly
below the $1,164,700 and $1,414,000 present-worth cost estimates for
the in-place containment and excavation alternatives, respectively.
• State Acceptance
NYSDEC concurs with the selected alternative.
• Community Acceptance
Public interest related to the fourth operable unit for the site is low. No
written comments were submitted during the public comment period and
the public meeting was sparsely attended. No comments related to the
preferred remedy were provided by the public. Responses to questions
asked at the public meeting are included in the Responsiveness
Summary, which can be found in Appendix V of this document.
For cost-estimating purposes, a 30-year time frame for monitoring was used.
18
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SELECTED REMEDY
Based upon consideration of the requirements of CERCLA, the detailed
analysis of the alternatives, and public comments, EPA and NYSDEC
have determined that no further action with long-term monitoring is the
most appropriate remedy for this operable unit, because it best satisfies
the requirements of CERCLA §121, 42 U.S.C. §9621 and the NCR's nine
evaluation criteria for remedial alternatives, 40 CFR §300.430(e)(9).
The selected remedy involves no further remedial action, with long-term
monitoring of the sediments and biota in the creeks and wetlands
adjacent to the site.
Because this alternative may result in sediment contamination
concentrations remaining at levels that may not be ecologically
protective, long-term monitoring (including biota sampling) results will
be used to assess this threat on a periodic basis. If justified by this
assessment, remedial actions may be implemented to address these
sediments.
While the no further action alternative does not actively address the
contaminated sediments, data collected between 1991 and 1996 suggest
that PCB sediment concentrations are decreasing, presumably due to
the deposition of clean sediments, and/or the downstream migration and
subsequent dilution of contaminated sediments.
While the other remedial alternatives that were evaluated, namely, in-
place containment and excavation, would actively address the PCB-
contaminated sediments, they would involve significant disturbance of
1.5 to 2 acres of productive and diverse wetland habitats, as well as,
additional areas of upland habitats for staging areas, access roads, and
other support facilities. This would outweigh the benefits of remediating
the low-level contamination. In addition, it would take considerable
time before a diverse and fully functioning plant community would be
established. Furthermore, although exposure to PCB-contaminated
sediments would be reduced initially under these alternatives, there is
the potential for this area to become recontaminated by the transport of
PCB-contaminated sediments from known upstream sources. Therefore,
as the risk levels are relatively low and the PCB sediment
concentrations appear to be declining over time, the no further action
with long-term monitoring alternative appears to be the most appropriate
remedial option at this time. Long-term monitoring will be conducted to
ensure that contaminant concentrations in the sediments and biota
19
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continue to be reduced over time and that further contamination of the
area from upstream sources is not occurring.
The selected remedy will provide the best balance of tradeoffs among
alternatives with respect to the evaluating criteria. EPA believes that
the selected alternative will be protective of human health and the
environment, comply with ARARs, and be cost-effective.
STATUTORY DETERMINATIONS
As previously noted, CERCLA §121(b)(1), 42 U.S.C. §9621(b)(1),
mandates that a remedial action must be protective of human health and
the environment, cost-effective, and utilize permanent solutions and
alternative treatment technologies or resource recovery technologies to
the maximum extent practicable. Section 121(b)(1) also establishes a
preference for remedial actions which employ treatment to permanently
and significantly reduce the volume, toxicity, or mobility of the
hazardous substances, pollutants, or contaminants at a site. CERCLA
§121(d), 42 U.S.C. §9621(d), further specifies that a remedial action
must attain a degree of cleanup that satisfies ARARs under federal and
state laws, unless a waiver can be justified pursuant to CERCLA
§121(d)(4), 42 U.S.C. §9621(d)(4).
The selected remedy meets the requirements for remedial actions set
forth in CERCLA §121, 42 U.S.C. §9621.
EPA has determined that no further physical construction is necessary
at this site; therefore, the site now qualifies for inclusion on the
Construction Completion List.
Because hazardous substances will remain on-site, the site is subject
to five-year reviews. Long-term monitoring results will be assessed for
this remedy during the five-year reviews related to the other operable
units at the site.
DOCUMENTATION OF SIGNIFICANT CHANGES
There are no significant changes from the selected alternative
presented in the Proposed Plan.
20
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APPENDIX I
FIGURES
-------
EAST SENECA
STREET Dt'P
OSWEGO CASTINGS
FACILITY
Figure 1-Area Map
-------
Sccle in Feet
•7H= SMfTH-S BEACH WETLANDS ANO TnlELTAPIES SOUTH (UPSTR£*M) QF THE PAS SITE ARE OUTSBE TXE SCOPE CF 7KE F?3
Figure 2- SPRDS Phase II Study Area
-------
APPENDIX II
TABLES
-------
TABLE 1
Total PCB Sediment Concentrations • SPRDS Phase 2
Reach1
2
2 .
2
3
3
3
4
5
6
7 •
8
8 .
8
9
9
9
9
10
10
10
-12
12
12
12
13
13
13
14
14
Sample ID*
Whito-lA
White-IB
White-lC
Whhe-2
White-3
Wttte-4
White-S
White*
9
White-7
While-8
Whhe-9A
White-9B
White 9C
White-10
{| Whte-llA
White-llB
White-llC
White-12A
White-12B
White-12C
White-13A
White-13B
White-ISC
White-13D
Wme-lA
Wine-IB
Wme-lC
Wioe-2A
Wine-2B
Total PCB Concentration (mg/k*
190.0
0.950
0.170
ND (0.027)k .
0.052 '
0.460
ND (0.024)
0.027
0.161
ND(0.02S)
0.095
0.014
0.043
0.035
11.40 • .
0.052
0.059
i.6-;o
5.860
0.052
0.880
0.740 .
0.051
0.260
ND (0.029)
0.036
1.320
0.046
0.160
Note: Upstream=Reaches 1-5; On-Site=Reaches 6-13; Downstream=Reaches 13 and 14
-------
TABLE 1
Total PCB Sediment Concentrations - SPRDS Phase 2
Reach*
14
15
15
15
* See Figure 1 for the location
k Not Detected (Detection Lim
Sample ID*
Wine-2C
Wine-3A
Wine-3B
Wine-3C
i of rc&chcs &od f nf^pHnff stAtiou r
it).
Total PCB Concentration
-------
TABLE 2
PCS Concentration Trends in Sediments at LIMP Locations*
Adjacent to or Immediately Upstream of the PAS Facility
Sample Date
11/89
11/90
5/91
11/91
11/92
5/94
11/94
11/96
Total PCB Concentration (mg/kg)h
Station SS-1
(immediately
upstream of the
PAS Facility)
Ndd
ND
ND
ND
ND
ND '
ND
0.074
Station SS-3
(in Reach 9 near
SPRDS location
White 11A)
ND
—
3.700
1.900
0.720
.1.400
0.740
0.540
Station SS-4A*
(at confluence of
White and Wine
Creeks)
*
.ND
—
1.400
0.140
ND
0.039
0.159
* LTMP sampling locations are shown in Figure 2 of the URS report (1997)
k Data from URS (1997)
e . Location SS-4 was replaced by location SS-4A in November 1990
d Not Detected
-------
TABLE 3 Summary of Carcinogenic Risks
Exposure Pathway
Sediment Ingestion
Dermal Contact
Total Risk
Adult
2.0x10'6
1.2X10'5
1.4x10'*
Child
3.6x1 O'6
5.2x1 O'e
8.8X10'6
TABLE 4 Summary of Noncarcinogenic Health Effects
Exposure Pathway
Sediment Ingestion
Dermal Contact
Total Risk
Adult
0.08
0.15
0.23
Child
0.75
0.33
1.08
-------
APPENDIX III
ADMINISTRATIVE
RECORD INDEX
-------
4 . 0
4 . 3
POLLUTION ABATEMENT SERVICES
OPERABLE UNIT FOUR
ADMINISTRATIVE RECORD FILE
INDEX OF DOCUMENTS
FEASIBILITY STUDY
Feasibility Study Reports
400001-
.400134
Report :
Stud for
Focused Feasibility
PCB-Impacted Sediments
the Vicinity o f t he Pollution
Abatement Services Superfund Site.
Oswego. New York, prepared by
Environ International Corporation,
prepared for Parties to the PAS
Oswego Site Participation
Agreement, August 20, 1997.
5 . 0
5 . 1
RECORD OF DECISION
Record of Decision
500001- Record of Decision, Appendix V-a,
500035 Responsiveness Summary, Letters
submitted during the public
comment period, Pollution Abatement
Services, City of Oswego, Oswego
County, New York, December 29,
1993. (Note: The Record of
Decision, including Appendices I-V,
is in the Pollution Abatement
Services Operable Unit Three
Administrative Record
Update, p. 500045-500169.)
Supplemental Pre-Remedial Design - Phase 2
Report: Phase 2 Supplemental
Pre-Remedial Design Study Report —
Surface-Water/Sediment Quality
Source Investigation. Volume I of
III, Pollution Abatement Services
Site, Oswego, New York, prepared
for Parties to the PAS Oswego Site
Participation Agreement, prepared
by Roux Associates, Inc., April 25,
1996. (Note: This document is in
the Pollution Abatement Services
-------
Operable Unit Three Administrative
Record Update, p. 501911-501980.)
Report: Phase 2 Supplemental
Pre-Remedial Design Study Report —
Surf ace-Water/Sediment Quality
Source I nvestigation, Volume II of
III, Appendices A through H,
Pollution Abatement Services Site,
Oswego, New York, prepared for
Parties to the PAS Oswego Site
Participation Agreement, prepared
by Roux Associates, Inc., April 25,
1996. (Note: This document is in
the Pollution Abatement Services
Operable Unit Three Administrative
Record Update, p. 501981-502241.)
Report: Phase 2 Supplemental
Pre-Remedial Design Study Report —
Surface-Water/Sediment Quality
Source Investigation. Volume III of
III, Appendices I through M,
Pollution Abatement Services Site,
Oswego, New York, prepared for
Parties to the PAS Oswego Site
Participation Agreement, prepared
by Roux Associates, Inc., April 25,
1996. (Note: This document is in
the Pollution Abatement Services
Operable Unit Three Administrative
Record Update, p. 502242-502622.)
Explanation of Significant Differences
Explanation of Significant
Differences, Pollution Abatement
Services Site, City of Oswego,
Oswego County, New York, prepared
by U.S. EPA, Region II, September
1996. (Note: This document is in
the Pollution Abatement Services
Operable Unit Three Administrative
Record Update, p. 502630-502633.)
500036- Technical Memorandum: Development
500084 of Remedial Action Objectives for
PCB-Impacted Sediments in the
Vicinity of the Pollution Abatement
Services Superfund Site, Oswego,
New York, prepared by Environ
International Corporation, prepared
for Parties to the PAS Oswego Site
-------
Participation Agreement, March 6
1997 .
7.0 ENFORCEMENT
7.2 Endangerment Assessments
Report: Final Endangerment
Assessment. PAS Oswego Site.
Oswego. New York. Volume I of II.
prepared by CDM Federal Programs
Corporation, May 26, 1993. Note:
This document is in the Pollution
Abatement Services Operable Unit
Three Administrative Record p.
700001-700421. )
Report: Final Endangerment
Assessment, PAS Oswego Site.
Oswego. New York. Volume II of II.
prepared by CDM Federal Programs
Corporation, May 26, 1993. Note:
This document is in the Pollution
Abatement Services Operable Unit
Three Administrative Record p.
700422 - 700536 .)
P. 700001- Addendum to the Final Endangerment
700006 Assessment, Pollution Abatement
Services Site, Oswego, New York,
August 5, 1997.
-------
APPENDIX IV
STATE LETTER OF
CONCURRENCE
-------
New York State department of Environmental Conservation
50 Wolf Road, A bany, New York 12233-7010
Mr. Richard Caspe
Director
Emergency and Re
United States Emi
Region fl Floor 1!
290 Broadway
New York, NY 10(
nedial Response Division
onmental Protection Agency
#£38
07-1866
Dear Mr. Caspe:
RE:
In -esponse
youroffic;, Iwish
John P. CahiU
Commissioner
SEP 29 1997
Pott-if Pax Note
7671
"
CO./DM.
00
Record of Decision for the Pollution Abatement Services Site
Site ID. No. 738001
o the draft Record of Decision for the PAS Site ID No. 738001, submitted by
concur with the remedial action plan as put forth in the document
The selected] remedy as described on page 18 of the draft ROD includes the following
elements:
No Action w tth a long-term monitoring program of surface wafer, sediments and including
biota sampli ig. This monitoring will be conducted to ensure that the PCB concentrations in
the wetlands are act increasing. This data will be used to assess the site conditions on a
periodic basi;. If justified by this assessment, remedial actions may be implemented to
remove or tr at the sediments.
Concurrence with this remedy recognizes the numerous remedial actions taken to date as a
result of the
cc: J. Singennan
984 ROD, 1993 ROD and the 1996 Explanation of Significant Differences.
Sincerely,
Michael J.OToole, Jr.
Director
Division of Environmental Remediation
-------
APPENDIX V
RESPONSIVENESS
SUMMARY
-------
APPENDIX V
RESPONSIVENESS SUMMARY
Pollution Abatement Services Superfund Site
INTRODUCTION
A responsiveness summary is required by Superfund policy, ft provides
a summary of citizens' comments and concerns received during the
public comment period, and the United States Environmental Protection
Agency (EPA) and the New York State Department of Environmental
Conservation's (NYSDEC's) responses to those comments and concerns.
All comments summarized in this document have been considered in
EPA and NYSDEC's final decision for selection of a remedial alternative
to augment the previously implemented remedial actions and to address
the contamination detected outside the containment system at the
Pollution Abatement Services (PAS) site.
OVERVIEW
Public interest related to the fourth operable unit for the site is low. No
written comments were submitted during the public comment period and
the public meeting was sparsely attended. No comments related to the
preferred remedy, no further action with long-term monitoring, were
provided by the public.
SUMMARY OF COMMUNITY RELATIONS ACTIVITIES
The Supplemental Pre-Remedial Design (SPRDS) report, focused
feasibility study (FFS) report, and Proposed Plan for the site were
released to the public for comment on August 22, 1997. These
documents were made available to the public in the administrative
record file at the EPA Docket Room in Region II, New York and the
information repository at the Oswego City Hall. The notice of
availability for the above-referenced documents was published in the
Oswego Palladium Times on August 22, 1997. The public comment
period related to these documents was held from August 22, 1997 to
September 21, 1997.
On September 11, 1997, EPA and NYSDEC conducted a public meeting
at Oswego City Hall to inform local officials and interested citizens
about the Superfund process, to review current and planned remedial
-------
activities at the site, to discuss and receive comments on the Proposed
Plan, and to respond to questions from area residents and other
interested parties. Only two people attended the public meeting.
SUMMARY OF COMMENTS AND RESPONSES
No written comments were'submitted. A summary of questions asked by
the public at the public meeting, as well as EPA and NYSDEC's
responses, follows.
Question #1: Who will be responsible for the costs related to the
implementation of the remedy that is ultimately selected for the site?
Response #1: Under the Superfund statute, the parties that generated
the hazardous wastes that were disposed of at the site, the parties that
transported it to the site, and the parties that owned and/or operated the
site (collectively called potentially responsible parties) are responsible
for conducting or financing any necessary investigatory or remedial
work at the site.
The SPRDS and FFS were conducted by a group of potentially
responsible parties. EPA intends to negotiate the implementation of the
selected remedy with the potentially responsible parties responsible for
the PCB contamination at the site.
Question #2: No further action with long-term monitoring is the least
costly alternative. What role does cost play in the identification of a
preferred remedy?
Response #2: Cost was only one of the nine criteria that was
considered in the evaluation of the various alternatives. Under the
Superfund regulations, EPA is required to consider eight other
evaluation criteria. The primary criteria are the ability of the various
remedial alternatives to protect human health and the environment and
compliance with applicable or relevant and appropriate requirements.
Other factors that are considered include long-term effectiveness and
permanence, reduction of toxicity, mobility, or volume through
treatment, short-term effectiveness, implementability, state acceptance,
and community acceptance.
V-2
-------
While the other remedial alternatives that were evaluated, namely, in-
place containment and excavation, would actively address the PCB-
contaminated sediments, they would involve significant disturbance of
productive and diverse wetland habitats. Therefore, as the risk levels
are relatively low and PCB sediment concentrations appear to be
declining over time, EPA determined that the "No Further Action with
Long-Term Monitoring" alternative is the most appropriate remedial
option at this time.
Question #3: Are the PCBs that were detected in the sediments in White
and Wine Creeks and the adjacent wetland areas attributable to the PAS
site? Are there other potential sources of PCBs?
Response #3: Based upon the results of the SPRDS, it was concluded
that, while the PAS site was a source of PCB contamination before the
construction of the containment facility in 1986, the site is not a present
source of PCB contamination in the sediments in the adjacent wetlands
and Wine and White Creeks.
The SPRDS also identified two additional potential upstream sources of
PCBs in the sedim.ents in the wetlands and creeks in the vicinity of the
PAS site—the East Seneca Street Dump and the Niagara Mohawk Fire
Training School. The State of New York is responsible for overseeing
activities at these non-NPL sites.
Question #4: Will the long-term monitoring program include monitoring
of the two upstream sources?
Response #4: In addition to collecting samples in the creeks and
wetlands located in the vicinity of the PAS site, the long-term monitoring
program will include upstream sampling locations to monitor any
contamination that may be migrating from upstream sources.
Question #5: At what frequency will the PCB levels in the sediments be
monitored under the "No Further Action with Long-Term Monitoring"
alternative?
Response #5: The "No Further Action with Long-Term Monitoring"
alternative will include annual monitoring of PCB levels in the sediments
in White and Wine Creeks and the adjacent wetlands in the vicinity of
the site. For planning purposes, EPA has estimated that the long-term
V-3
-------
monitoring will be conducted for 30 years. It is anticipated that the
duration of the monitoring will be adjusted, as necessary, based upon
the results of the sampling.
V-4
-------
APPENDIX V-a
RESPONSIVENESS
SUMMARY
TRANSCRIPT
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u
z
N
k.
n
1
2
3
4
5
6
7
8
9
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U.S. ENVIRONMENTAL PROTECTION AGENCY
PUBLIC MEETIN3
POLLUTION ABATEMENT SERVICES SUPERFUND SITE
THURSDAY, SEPTEMBER 11, 1997
7:00 P.M.
OSWEGO CITY HALL, OSWEGO, NEW YORK
APPEARANCES:
PATRICIA SIMMONS,
REMEDIAL PROJECT MANAGER
U.S. EPA
CLAY McCLARNON,
DE MAXIMIS, INC.
GINA FERREIRA
ENVIRONMENTAL SCIENTIST
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as well as any written comments will be documented
and addressed in the response summary section
of the record of decision.
Can you hear me? No?
REPORTER 31: A little louder.
MS. SIMMONS: All right. The comment
period on the proposed plan, -- Can you hear
me now? -- began August 23rd. Everybody set?
Okay. The commentary begsn on August
22nd, and it ended on September 21st. If you
have any additional questions or comments that
are not covered here tonight, you can send
•
them to me in writing by September 21st. My
address is in the proposed plan. Since there
are only two of you, I have copies for you,
if you need them. What I'm going to do is
present a brief overview of the site here to
bring you up to date on the status of the site.
And then, as I said, Clay will present the
results of the studies. Then, I'll give the
preferred alternative.
PAS, or Pollution Abatement Services
was a high temperature liquid chemical waste
incineration facility that operated from 1970
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through 1977. Beginning in 1977, a series
of incidents, including liquid waste spills
and the oveflow of liquid wastes from lagoons
into White Creek, led to the involvement of
EPA and NYSDEC at the site. Response actions
taken from 1973 to 1982 by EPA and NYSDEC resulted
in the removal of the incineration facilities,
drummed wastes, bulk liquid wastes, and
contaminated soils and the closure of an on-site
pond. In 1981, the PAS site, which was ranked
number seven on the original National Priorities
List (NPL), was selected as one of the first
sites in the nation to receive CERCLA Trust
Fund monies for cleanup actions.
From 1982 to 1984 NYSDEC performed a
Site Investigation, was the initial RI/FS
conducted at the site. Based on the results
of this study, EPA signed a Rod "in 1984, which
specified the following remedial actions:
limited excavation and off-site disposal of
contaminated materials, installation of a perimeter
slurry wall, site grading and capping in
accordance with Resource Conservation and Recovery
Act (RCRA) requirements, installation of a
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leachate and groundwater collection and treatment
system and groundwater monitoring.
REPORTER f2: Can I ask a question, please?
MS. SIMMONS: Sure.
REPORTER #2: From the information on
there, is this being given to us?
MS. SIMMONS: The proposed plan?
REPORTER #2: Yes.
MS. SIMMONS: Yes.
REPORTER f2: Okay.
MS. SIMMONS: Actually, there are, --
Thanks, Mike. There are copies of the handouts
too.
The second ROD which was issued in 1993
for Operable Unit Three involved the enhancement
of groundwater extraction to address contamination
that was found outside the container system
constructed in 1986.
The 1993 ROD also called for several
investigations related to the enhancement of the
source control system. In addition, since
there was some uncertainty related to the source
of the PCS contamination detected in the sediments
in the adjacent wetlands and White and Wine
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Creeks, and the source of pesticides detected
in the surface water of Wine Creek, the ROD
called for a study to determine the sources
of PCB and pesticide contamination.
I just want tc mention that EPA and the
responsible party have reached agreement on
a consent degree related to the real activities
called for in the first two RODS.
Presently, EPA is waiting for signature
pages from the responsible parties on the consent
decree, so that's basically all wrapped up.
And, the consent decree will address among
other things the continuation of the pumping
and excavation of the ground from the containment
system, and the continuation of the long-term
monitoring, and operation, and maintenance
at the site.
The Fourth Operable Unit which we're
here to discuss tonight relates to the PCRs
surrounding the site.
In accordance with the 1993 Supplemental
Design, study was conducted to determine the
source of the PCRs P.O's, and this year, 1
believe it was May, a focus feasibility study
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was conducted to identify real alternatives
for the PCS impact sediment.
Now, Clay will come up and present the
find ways of these studies.
MR. McLARNON: Thank you, Patricia.
As Patricia said, I was asked to go over
the two studies, that would be the '96 Supplemental
Pre-Remedial Design, and the Supplemental Remedial
Investigation.i
The Supplemental Remedial Design Study
was proposed in '96. There is also the Supplemental
Pre-Remedial Design Study. The acronym is
SPRDS. I may fall into the use of acroryms
in dealing with one of these for many years.
You end up trying to reduce down as many words
as you can, so you can get the things said
quickly.
But anyway, the SPRDS was performed by
ROD, and it was to, as the objectives were
listed in the ROD, to determine whether the
PCB's present in the sediments in both creeks,
Wine Creek and White Creek, was a source of
PCS contamination.
The SPRDS concluded, among other things,
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that the PAS site is not the source of the
pesticides in the surface water of Wine Creek
and, while it was a source of PCB contamination
before the construction of the containment
facility in 1986, PAS is not a present source
of PCB contamination in the sediments in the
adjacent wetlands and Wine and White Creeks.
Unfortunately, we don't have a map, but
White and Wine Creeks border the site, and second
to that is to determine whether the PAS Site
is the source of PCBs detected in sediment
disposal both in the creeks and the wetlands.
North of the wetlands is, basically borders
the two creeks, and that's basically where
the two creeks merge.
Anyway, the results that ROD came up
within this investigation involved the research
involved going back through historical reports
as well as taking samples and doing a site
investigation at that time period.
And, the results on the pesticides are
that the pesticides were detected in low level,
at low levels. And, surface water at Wine
Creek and upstream of the site adjacent and
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downstream of the site.
On the PCB issue which was completed
in the Phase Two of the SPRDS, the PAS Site
was noted to may have been a source of PCBs,
-- Excuse me. Let me talk about the slide
up there first, because that's the result.
Pesticides were in low levels. The results
of supplemental RI and the SPRDS indicate that
PCBs are present in the sediments in both creeks,
upstream, adjacent to, and downstream of the
PAS site. Total PCB concentrations detected
range from 0.014to 190 milligrams per kilogram
with the highest concentration being detected
upstream of the PAS site. Only five of the
36 sediment samples collected in the vicinity
of the site showed PCB concentrations exceeding
1 mg/kg (the maximum concentration was 11.4
mg/kg; all five of these samples were from
White Creek.
The data appears to show that there was
a decline of those PCB concentrations. So,
that's what the results of the Phase Two study
showed.
Now, the conclusions of the Phase Two
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SPRDS study show that PAS is not the source
of the oesticides in surface water of Wine
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Creek, and on the PCB issue, the PAS Site may
have been the source of PCBs prior to the
construction of the containment system that
we talked about in 1886. The PAS Site is not
presently a source of PCBs from White Creek
or adjacent wetlands. And, they also identify
that there with upstream sources of PCBs along
White Creek.
REPORTER fl: Do any of the studies identify
where the sources are?
MR. McCLARNON: There's a variety of
samples, and they are upstream north of East
Seneca Street, and adjacent to White Creek.
That information is available in the repository
and in a variety of different studies. But,
the SPRDS is available. This led to the decision
that a focus feasibility study needed to be
completed for the site. The focus of the
feasibility study was performed by Environ
on behalf of the performing parties. And,
thatwas performed and completed April-May time
frame of this year. . In performing a focus
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feasability study Environ involved a hundred
steps of reviewing the earlier studies as well
as the SPRDS studies. They developd remedial
action objectives, and remedial action of this
site was to evaluate the impact to ecological
species. And, the last step is to evaluate,
develop, and evaluate remedial alternatives
to meet that remedial action objective.
The findings that Environ came to evaluate
those items there was a previous assessment
back in 1993 that showed adverse human health
effects, such as the PCS sediments were not
likely, and shows that relative ecological
risks were associated with the PCB impact.
Based on that, three alternatives were evalauted.
The three alternatives were: no further action
with long-term monitoring; stream channel
relocation and containment in place, an
environmental term following that would mean
capping, and sediment removal. So, that evaluation
was to monitor to cover any impact areas,
or for removal of any impacted areas.
This chart at the bottom shows the present
value cost for each one of those alternatives,
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and a brief discussion of what would take place.
Part of that evaluation includes evaluating
alternatives, and providing the information
necessary to come up with appropriate final
decisions, and I think Patricia will go into
that.
MS. SIMMONS: Thanks. I just want to
make one point before I got the preferred remedy.
While the Phase Two Supplemental Remedial Design
Study states that PAS may have been a source
of the PCB contamination at the site prior
to construction of the containment system,
it's EPA's belief that PAS was definitely a
source prior to the construction of the containment
system.
Now, in selecting a preferred remedy we
used a variety of criteria. Included in that
criteria are the overall protection of human
health and the environment, compliance with
applicable or relevant and appropriate requirements.
If you want more detail to those, look to Pages
7 and 8 of your proposal plan.
EPA and the New York State Department
of Environmental Conversation have selected
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no further action with long-term monitoring
as the preferred alternative. The basis of
this election is that its adverse human health
effects are unlikely. Ecological risks are
relatively low. The PCB levels appear to be
low.
At this point I'd like to open it up.
If you have any questions, feel free to ask.
REPORTER fl: I have a question regarding
the monitoring. How f quently is i , quarterly
you monitor?
MR. McCLARNON: Twice a year. It will
fall along with presently, the State is doing
a long-term program, and that is, and it will
follow the same timetable as their stiff monitoring
which I believe in May and November.
REPORTER fl: So, basically, it's going
to stay the same?
NR. McCLARNON: Yes.
REPORTER f2: When you talk about costs,
to whom would that be a cost, the City of Oswego,
or would it be, you know, would there be federal
funding for that?
MS. SIMMONS: For the monitoring?
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REPORTER #2: No, for any of these
solutions.
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MS. SIMMONS: No, the responsible party
is being covered.
REPORTER #1: Do you know what parties
that may turn out to be?
MS. McCLARNON: International- There
are over one hundred. There are over two hundred,
actually.
REPORTER #2: Over two hundred?
MR. McCLARNON: Over two hundred.
REPORTER #1: Basically, whoever dumps
water, then?
MR. McCLARNON: Yes.
REPORTER #2: Do you have a list of who
those people are, or the companies?
MS. SIMMONS: I don't have the list with
me, but if you v/ould like them, --
MR. McCLARNON: I think it's part of
the public record.
MS. SIMMONS: Yes, it's part of the public
record. I don't have it with me though.
REPORTER #2: Are those local companies,
or companies in just the Central New York
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area?
MR. McCLARNON: I believe the regional
companies. It's more than regional companies.
It's all over.
REPORTER fl: You talked about soms
advantage to cost, being the lowest cost,
but is cost necessarily the biggest concern?
MS. SIMMONS: Cost is not only the reason
for choosing the no further -action alternative. It
was based on the destruction to wetlands that
would be caused with the alternatives.
REPORTER fl: Getting back co the r-onitoring,
has anything been detected since it was a
slurry wall?
MS. FERRERIA: We put a slurry wall
in the cap in 1986, --
REPORTER fl: Has anything shown --
MS. FERRERIA: -- and after that, it
was monitoring, which had some low level PCBs,
and that is what the study was, our monitoring
program. And, what we've seen is we had five
hits greater than our sediment breaker. And,
that's what spurred the investigation. The
decision was msde on the minimal and environmental
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risk which exists from these sediments is
less than what would happen if you removed
the wetlands. That would be a greater ecological,
removing our tap from the wetlands than is
presented by some of the low level PCB found.
REPORTER #1: I guess my question was,
is: You know PCBs that were detected, they
could have been there before the slurry wall?
NS. FERRERIA: Oh, they were.
REPORTER #1: So, is this a migrating
MS. SIMMONS: We did groundwater sampling
around the slurry wall and found there were
no PCBs.
REPORTER #1: How many others? It says
there were other earlier studies, UTSPRDS,
how many others?
MR. McCLARNON: Whereas the initial,
that was 84.
MS. FERRERIA: 84 was the first record,
so prior to that, --
MR. McCLARNON: So, there was one there,
there was a second supplemental remedial
investigation, feasability study. That was
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performed by Goldberg, and that went to the
'S3 pond, and in the SPRDS Phase One study,
and the SPRDS Phase Two study, and focus
feasability study we just talked about, during
this whole time, the New York State was operating
the monitoring program for the site, and produced
a great deal of information. There were also
other studies in the area that reviewed some
of the data.
MS. FERRERIA: They should be available
at City Hall, here.
REPORTER #1: They couldn't even find
the documents for this meeting, so I had a
hard time finding, you know, the paper saying
the documents were available for review.
I came down a week after they were supposed
to be available, and no one knew what I was
talking about. I went to the Mayor's Office,
the City Clerk.
MR. McCLARNON: The City Clerk should
know, but they didn't.
REPORTER #2: Now, will the observation
of this site also include an observation of
the site that seems to be the source of the
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PCBs, Will the observation over tims of the
PAS also involve observation of what appears
to be the source?
MS. SIMMONS: The upstream sources?
REPORTER #2: Yes.
MS. SIMEONS: I believe those sites
are state.
MR. McCLARNON: One was completed, I
believe last year, and the other, we're working
on a closure plan right now. To answer your
question, no, th3 monitoring you're talking
about would be on the PAS site is state.
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We would have one on the upstream, immediately
upstream, and some sample locations within
the watlands. And, that's what is envisioned
in monitoring the locations of concern for
future impact.
I want to go back to the topic of decision,
as far as the preservation of the wetlands.
When we talk about removal of the impact of
sediment, we are talking about all productive
methods .
Going back to costs, so part of these
costs are the more extensive alternatives
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which would include recreation of wetlands
that would be damaged. I do think that's
envisioned in these costs. That is the actual
effort of going in and removing. That would
be an additional cost.
Just a little history on remedial focus.
Over tine, is basically a couple of lagoons,
no controls, on the government focus at first
was to control the site, and then do an
investigation, seems how it was transferred
to an environmental problem. Once we had
the human help, and that's how things are,
we dealt with the elements to the site first.
That's why this has gone all these stages
over years. The governments' first focus
was to get the site itself under control,
and magnitude, of the contamination of the
site, slurry wall capping was really the only
logical alternative. So, as long as that
system is maintained, then the site is under
control and focus on additional risk.
REPORTER #2: And, she mentioned to
me that actually the newspaper had made a mistake
Actually, I misspoke on that. I thought you
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were talking, referring to the transfer station
like a landfill. You're talking about the
old City Dump that the county was using as
a hardfill for construction.
MR. NcCLARNON: The transfer Station.
REPORTER #1: That's actually correct.
REPORTER #2: So, this was not a transfer
station. This was an actual dumping ground.
MR. McCLARNON: It was a common dumping
ground. That's on the west side.
On the west side of Wine Creek? I said
White. In between. It's in between the two.
Yes, it's in between the two creeks,
and on the south side.
REPORTER #2: I guess the last question
I have is: Do any of you have cards where
you would be available later tonight, with
you? I'm writing this up.
MS. SIMMONS: I have a card.
MR. McCLARNON: You will?
MS. SIMMONS: Sure.
REPORTER #2: I don't have any other
questions.
MS. SIMMONS: If you have any additioanl
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questions write them down and send them to
me.
If there are no further questions, we'll
close the hearing.
(End of hearing)
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I certify that the foregoing is a true, accurate,
and complete transcript of the proceedings held in
this matter which /vas taken on Thursday, September
11, 1997 at 7:00 p.m.
it
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RECORD OF DECISION FACT SHEET
EPA REGION II
Site:
Site name: Pollution Abatement Services EPA ID #: NYD000511659
Site location: Oswego, Oswego County, New York
MRS score: 70.80 Date of MRS scoring: December 1982
Listed on the NPL September 1983
Record of Decision:
Date signed: September 30,1997
Operable Unit no.: Four
Selected remedy: No Further Action with Long-Term Monitoring
Capital Cost: $0
Construction Completion: N/A
Annual 0 & M Cost: $20,500
Present-Worth Cost: $254,400 (7% discount rate for 30 years)
Lead:
Site is enforcement lead - EPA is the lead agency
Primary Contact: Patricia Simmons, Project Manager, Central New York Remediation
Section (212) 637-3865
Secondary Contact: Joel Singerman, Chief, Central New York Remediation Section
Main PRPs: General Motors Corporation, Niagara Mohawk Power Corporation, and
Alcan Aluminum Corporation
Waste:
Waste type: PCBs
Waste origin: Hazardous waste
Contaminated medium: Sediments
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