EPA Superfund
Record of Decision:
Richardson Hill Road
Landfill/Pond
Sidney Center, NY
9/30/1997
PB97-963817
EPA/541/R-97/109
January 1998
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RECORD OF DECISION
Richardson Hill Road Landfill Site
Towns of Sidney and Masonville, Delaware 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
Richardson Hill Road Landfill
Towns of Sidney and Masonville, Delaware County, New York
STATEMENT OF BASIS AND PURPOSE
This Record of Decision (ROD) documents the U.S. Environmental
Protection Agency's (EPA's) selection of a remedial action for the
Richardson Hill Road Landfill site (the Site), which is chosen in accor-
dance with the requirements of the Comprehensive Environmental
Response, Compensation and Liability Act of 1980, as amended
(CERCLA), 42 U.S.C. §9601 et seq. 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 (see 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
Actual or threatened releases of hazardous substances from the Site,
if not addressed by implementing the response action selected in this
ROD, may present an imminent and substantial endangerment to public
health, welfare, or the environment.
DESCRIPTION OF THE SELECTED REMEDY
The selected remedy includes:
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Excavation of contaminated waste material and soil exceeding
NYSOEC's Soil Cleanup Objectives1 in the North and South Areas
(other than the landfill). Clean fill will be used as backfill in the
excavated areas;
In the area to be capped (primarily, in the vicinity of the former
waste oil disposal pit), soil with polychlorinated biphenyl (PCB)
concentrations which equal or exceed 500 milligrams per kilogram
(mg/kg) will be excavated and sent off-Site for treatment/disposal
at a Toxic Substances Control Act (TSCA)-compliant facility;
Excavation and/or dredging of sediments exceeding 1 mg/kg PCB
from South Pond and all areas downstream for approximately 2,400
feet. The need for remediation in areas further downstream will
be evaluated based on an assessment of sediment concentrations
and biological receptors. All excavated/dredged sediments will be
dewatered, as necessary. Any wetlands impacted by remedial
activities will be fully restored; .
Installation of an outlet control/sediment trap downgradient of
South Pond to minimize migration of contaminated sediment
further downstream from the main beaver pond;
All excavated/dredged waste materials, soils, and sediments will
be subjected to Resource Conservation and Recovery Act (RCRA)
hazardous waste characteristic testing. Those waste materials,
soils, and sediments that do not pass the RCRA characteristic
testing will be sent off-Site for treatment/disposal at a RCRA-
compliant facility (or a TSCA-compliant facility, if applicable).
Those waste materials, soils, and sediments that pass the RCRA
characteristic testing and have PCB concentrations which equal or
exceed 500 mg/kg will be sent off-Site for treatment/disposal at a
TSCA-compliant facility. Those waste materials, soils, and
sediments that pass the RCRA characteristic testing and have PCB
concentrations less than 50 mg/kg will be consolidated at the on-
Site landfill; those with PCB concentrations between 50 and 500
mg/kg will be placed in a TSCA-compliant landfill constructed
adjacent to the existing landfill. The on-Site TSCA landfill, which
will include a double composite liner and a final cover equivalent
to a RCRA cap, will meet the requirements of 40 CFR 761.75,
except that it will not be in strict compliance with the requirements
1 NYSDEC's soil cleanup objectives are specified in NYSDEC Technical Administrative Guidance
Memorandum No. 94-HWR-4046.
ii
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of 40 CFR 761.75(b)(3), as the bottom of the landfill will not be
located at least 50 feet higher than the nearest high groundwater
elevation. Therefore, a waiver of this requirement will be
necessary pursuant to 40 CFR 761.75(c)(4). It is EPA's
assessment that, considering the nature of the waste, the design
and operation of the landfill will be sufficient to prevent migration
of PCBs from the landfill. Consequently, a waiver of this
requirement is justified;
• Following the consolidation of the excavated/dredged waste
materials, soils, and sediments with PCB concentrations less than
50 mg/kg onto the existing landfill, a New York State 6 NYCRR
Part 360 or equivalent closure cap will be constructed;
• Construction of a chain-link fence around the landfill;
• Construction of a shallow leachate collection trench, keyed into
the top of the bedrock, on the downgradient edge of the cap that
will be installed on the existing landfill, and installation of vertical
overburden and bedrock extraction wells in the North Area;
• Extraction of contaminated groundwater from the overburden and
shallow bedrock in the South Area utilizing the downgradient
interceptor trench, and in the North Area utilizing the extraction
wells, and treatment of the extracted groundwater by air-stripping
and activated carbon (or other appropriate treatment), followed by
discharge to surface water;
• Taking steps to secure institutional controls (the placement of
restrictions on the installation and use of groundwater wells at the
Site and restrictions on the future use of the Site in order to
protect the integrity of the new TSCA landfill and the cap installed
on the existing landfill); and
• Long-term monitoring of groundwater, surface water, fish and
sediments to ensure the effectiveness of the selected remedy.
In addition, the water treatment systems that were installed on the
contaminated wells at two residences will continue to be maintained.
DECLARATION OF STATUTORY DETERMINATIONS
The selected remedy meets the requirements for remedial actions set
forth in CERCLA §121, 42 U.S.C. §9621 in that it: 1) is protective of
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human health and the environment; 2) attains a level or standard of
control of the hazardous substances, pollutants and contaminants,
which at least attains the legally applicable or relevant and appropriate
requirements-(ARARs) under federal and state laws; 3) is cost-effective;
and 4) utilizes permanent solutions and alternative treatment (or
resource recovery) technologies to the maximum extent practicable. In
keeping with the statutory preference for treatment as a principal
element of the remedy, the contaminated groundwater will be collected
and treated. The landfill material other than the hot-spot area (PCB
contamination equal to or greater than 500 mg/kg), however, cannot be
excavated and treated effectively, because of the size of the landfill and
the cost associated with the excavation and treatment.
A review of the remedial action pursuant to CERCLA §121 (c), 42 U.S.C.
§9621 (c), will be conducted within five years after the commencement
of the remedial action, and every five years thereafter, to ensure that
the remedy continues to provide adequate protection to human health
and the environment, because this remedy will result in hazardous
substances remaining on the Site above health-based levels.
Jeanne M^&ox \/ Date
Regional
IV
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RECORD OF DECISION
DECISION SUMMARY
Richardson Hill Road Landfill
Towns of Sidney and Masonville, Delaware 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 NAME, LOCATION AND DESCRIPTION 1
SITE HISTORY AND ENFORCEMENT ACTIVITIES 1
HIGHLIGHTS OF COMMUNITY PARTICIPATION 2
SCOPE AND ROLE OF OPERABLE UNIT 3
SUMMARY OF SITE CHARACTERISTICS 3
SUMMARY OF'SITE RISKS :. 7
REMEDIAL ACTION OBJECTIVES 12
DESCRIPTION OF REMEDIAL ACTION ALTERNATIVES 13
SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES 19
SELECTED REMEDY 26
STATUTORY DETERMINATIONS 29
DOCUMENTATION OF SIGNIFICANT CHANGES 33
ATTACHMENTS
APPENDIX I. FIGURES
APPENDIX II. TABLES
APPENDIX III. ADMINISTRATIVE RECORD INDEX
APPENDIX IV. STATE LETER OF CONCURRENCE
APPENDIX V. RESPONSIVENESS SUMMARY
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SITE NAME, LOCATION AND DESCRIPTION
The Site, located in the Towns of Sidney and Masonville, Delaware
County, New York, approximately 3.3 miles south-southwest of Sidney
Center, is situated on the western side of Richardson Hill Road,
adjacent to the Sidney Landfill1. The Site consists of two sections
designated as the North Area and the South Area. (See Figures 1 and
2).
The South Area is comprised of an 8-acre landfill (which contains a
former waste oil disposal pit approximately 25 ft wide by 105 ft long by
14 ft deep), South Pond, and a portion of Herrick Hollow Creek. Surface
water from the landfill drains into a marsh and South Pond through a
drainage ditch. Water from South Pond drains through a sediment trap
weir system and a beaver dam into Herrick Hollow Creek, which
eventually flows into the Delaware River, which flows into the
Cannonsville Reservoir on the west branch of the Delaware River. The
Cannonsville Reservoir is part of the Delaware watershed system,
supplying drinking water to the New York City metropolitan area. There
are numerous springs around the Site, some of which eventually
discharge into the wetlands. (See Figure 3.)
The North Area, located about 1,000 ft northeast of the landfill, includes
two disposal trenches (approximately 70 ft by 70 ft) and a man-made
surface water body called North Pond. The North Area is situated on a
drainage divide between the Susquehanna and Delaware River basins,
with the primary drainage toward the Delaware basin. Water from North
Pond drains through a series of beaver dams into Carr's Creek, a
tributary to the Susquehanna River.
SITE HISTORY AND ENFORCEMENT ACTIVITIES
The land on which the Richardson Hill Road Landfill is located was
purchased by Devere Rosa, Jr. in 1964 for the purpose of operating a
refuse disposal area. Devere Rosa, Sr. was issued a permit from the
New York State Department of Health (NYSDOH) to operate the landfill.
In July 1964, the Town of Sidney entered into a contract with Devere
Rosa, Jr. for the disposal of town wastes at the landfill, including spent
oils from the Scintilla Division of Bendix Corporation. While operating
the Richardson Hill Road Landfill, Mr. Rosa, Sr. also disposed of wastes
in the Sidney Landfill, located on the east side of Richardson Hill Road.
1 The Sidney Landfill Superfund Site, also a National Priorities List site, is being remediated
separately.
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According to NYSDEC and NYSDOH, the Richardson Hill Road Landfill
was poorly operated, with the improper compaction of waste, poor daily
covering, no supervision, and uncontrolled access to the Site.
Based on continuing violations at the landfill, NYSDOH sought to close
it. On October 31, 1968, Mr. Rosa, Sr. signed an order issued against
him by NYSDOH to close the landfill, however, waste disposal did not
cease until 1969. In 1968, the ownership of the property containing the
landfill was transferred to Joseph Del Vecchio and Robert Pacelli. In
1969 and 1970, the properties comprising the North Area were sold to
John Spizziri, Sr. and Sandra S. Spizziri. In 1972, these properties
were transferred to John Spizziri, Sr. and Alexandra Vitale Spizziri.
Based upon the results of an EPA-performed site investigation and a
New York State-performed Phase II site investigation, the Site was
listed on the National Priorities List on July 1, 1987.
On July 22, 1987, EPA entered into an Administrative Order on Consent
(AOC), Index Number II CERCLA-70205, with Amphenol Corporation and
AlliedSignal, Inc. (formally Bendix Corporation), requiring them to
perform a remedial investigation and feasibility study (RI/FS) to
determine the nature and extent of the contamination at and emanating
from the Site and to identify and evaluate remedial alternatives.
In 1993, in response to a fish kill in South Pond attributable to the seep
of contaminants from the oil disposal pit, EPA issued an AOC, Index
Number II CERCLA-93-0214, and a Unilateral Administrative Order
(UAO), Index Number II CERCLA-93-0217, to Amphenol Corporation and
AlliedSignal, Inc. The work performed pursuant to these orders
included the excavation of approximately 2,200 cubic yards of
contaminated sediments from South Pond (the excavated sediments are
being temporarily stored on-Site in lined storage cells), the installation
of seep interceptor collection basins upgradient of South Pond, and a
sediment trap weir system at the outlet of South Pond to prevent the
downstream migration of contaminated sediments, and the installation
and maintenance of two whole-house supply water treatment systems.
HIGHLIGHTS OF COMMUNITY PARTICIPATION
The remedial investigation (Rl) report, feasibility study (FS) report, and
Proposed Plan for the Site were released to the public for comment on
July 28, 1997. These documents were made available to the public in
the administrative record file at the Superfund Records Center in the
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EPA Region II, New York City office and the information repository at
the Sidney Memorial Public Library, Main Street, Sidney. The notice of
availability for the above-referenced documents was published in the
Press and Sun Bulletin on July 28, 1997. The public comment period
related to these documents was held from July 28, 1997 to August 26,
.1997.
On August 13, 1997, EPA conducted a public meeting at the Sidney
Civic Center 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 and to respond to questions from
area residents and other interested parties.
Responses to the comments received at the public meeting and in
writing during the public comment period are included in the
Responsiveness Summary (see Appendix V).
SCOPE AND ROLE OF OPERABLE UNIT
This response action applies a comprehensive approach, therefore only
one operable unit is required to remediate the Site.
SUMMARY OF SITE CHARACTERISTICS
The purpose of the Rl, conducted from 1988 to 1996, was to determine
the nature and extent of the contamination at and emanating from the
Site. The results of the Rl are summarized below.
Surface and Subsurface Soils
Contaminants detected in the surface soils were predominantly PCBs,
with the highest concentrations found near the former waste oil disposal
pit (the highest surface soil PCS concentration near the former waste oil
disposal pit was 950 mg/kg, based upon field screening data).
The subsurface soils are predominantly contaminated with volatile
organic compounds (VOCs) and PCBs. The most prevalent VOCs and
their corresponding maximum detected concentrations are. 1,2-
dichloroethene (1,2 DCE) (23 mg/kg), trichloroethene (TCE) (220
mg/kg), toluene (110 mg/kg), ethylbenzene (3.9 mg/kg), and xylene (5.2
mg/kg), with the highest concentrations detected in the vicinity of the
former waste oil disposal pit. In the original Rl samples collected in
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1990, the maximum PCS concentration detected in the subsurface soil
was 14,000 mg/kg, located southwest of the former waste oil disposal
pit. In the former waste oil disposal pit itself, PCS concentrations
ranged up to 7,000 mg/kg. Soil samples collected in the former waste
oil disposal pit and its vicinity in 1994 (following the excavation of the
contaminated sediments from South Pond pursuant to the UAO) showed
a substantial reduction in contaminant levels. In the location where the
14,000 mg/kg PCB was detected previously, a maximum PCB
concentration of 79.9 mg/kg was detected in the subsequent sampling.
Samples collected from the former waste oil disposal pit showed PCB
concentrations had dropped from a maximum concentration of 7,000
mg/kg to a maximum concentration of 480 mg/kg in the subsequent
sampling. The significant reduction in PCB concentrations in the former
waste oil disposal pit and the surrounding soils, in conjunction with the
presence of high levels of PCB-contaminated sediments in South Pond
before they were excavated, appears to indicate that the former waste
oil disposal pit, although previously a significant source of free-phase
PCB-contaminated oil, which caused significant contamination of South
Pond sediments, is now a less significant source of contamination.
PCBs were also detected in surface and subsurface soils in the North
Area (field screening concentrations ranged up to 42.2 mg/kg and 0.14
mg/kg, respectively) and in the vicinity of the landfill (field screening
concentrations ranged up to 155.6 mg/kg and 3.9 mg/kg, respectively).
Elevated inorganic contaminants were detected in subsurface soil
samples in an area south/southwest of the former waste oil disposal pit,
the former waste oil disposal pit itself, and the North Area. Iron, nickel,
lead, and zinc were detected, with highest levels of 53,100 mg/kg, 37.6
mg/kg, 136 mg/kg, and 413 mg/kg, respectively. The concentrations of
the remaining inorganics were within the New York State background
levels.
Tables 1 and 2 summarize surface and subsurface soil data,
respectively.
Groundwater Quality and Residential Wells/Springs
Groundwater samples have been collected from site monitoring wells
between November 1988 and February 1995. The most prevalent VOCs
present in the overburden groundwater are TCE, PCE, 1,1,1-
trichloroethane (1,1,1-TCA), and their breakdown products, 1,2-DCE,
1,1-dichloroethene (1,1-DCE), 1,1- dichloroethane (1,1-DCA) and vinyl
chloride. In addition, PCBs were detected in the groundwater.
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The VOC concentrations in overburden groundwater exceeded the New
York State Class GA standards for each detected compound. The range
of total VOCs detected in the overburden groundwater is from 1
microgram per liter (//g/l) to 29,860 //g/l, with the highest concentrations
being located adjacent to and downgradient of the former waste oil
disposal pit. Concentrations of TCE, 1,1,1-TCA, and 1,2-DCE ranged
up to 8,400 //g/l, 1,300^g/l, and 26,000 ^9/1, respectively. The
distribution of VOCs within the overburden groundwater indicates that
a VOC plume about 1,200 feet wide and 400 feet in length extends from
the landfill to South Pond.
Concentrations of total VOCs in the North Area groundwater ranged up
to 373 M9/I. The compounds with the highest concentrations consisted
of TCE (340 //g/l), 1,1,1-TCA (23 ^9/0, 1,2-DCE (3 M9/I), and
tetrachloroethene (PCE) (7 //g/l).
All overburden wells in the vicinity of the landfill exhibited PCB
concentrations, with the highest concentration (1,400 //g/l) being
detected in close proximity to and downgradient of the former waste oil
disposal pit. The PCB plume is less extensive aerially than the VOC
plume, and is centered around the former waste oil disposal pit.
The groundwater quality data collected in the past six years shows a
historic similarity in plume geometries and magnitude of concentrations,
suggesting that the VOCs and PCBs are in equilibrium.
The shallow bedrock groundwater at the landfill contains similar VOC
and PCB constituents as in the overburden groundwater. (The primary
VOCs in the shallow bedrock groundwater are 1,2-DCE and TCE.)
Generally, VOC concentrations in the shallow bedrock groundwater are
an order of magnitude less than the concentrations detected in
overburden groundwater. The total VOCs located downgradient of the
former waste oil disposal pit and downgradient of the southern portion
of the landfill have ranged from 2,510/zg/l to 7,770//g/l. PCBs were
detected in the shallow bedrock groundwater at concentrations ranging
up to 1 .
VOCs and PCBs were not detected in the deep bedrock groundwater
downgradient of the landfill, indicating that this zone is probably
isolated from the overburden and shallow bedrock groundwater.
Two private water supplies (springs) located in the North Area show
chemical contamination above drinking water standards. Both springs
have whole-house treatment systems, which are being maintained by the
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potentially responsible parties, pursuant to an AOC. As a result of the
treatment systems, the water supplies show no contamination at the
point of use.
Table 3 summarizes groundwater quality data.
Surface Water and Sediment Investigations
The objectives of the surface water, leachate, and sediment
investigations were to determine if site-generated contaminants have
migrated to North Pond, South Pond, the adjacent wetlands, and
downstream, and to determine site-specific background contaminant
concentrations.
Table 4 summarizes surface water data.
Surface water samples collected from South Pond contained total VOCs
ranging from 3/u.gll to 1,982 #g/l. The highest VOC concentrations
were detected adjacent to a leachate seep area along the western shore
of South Pond. PCBs in South Pond ranged in concentration from non-
detectable to
VOCs detected in surface water samples collected downstream of South
Pond include 1,2-DCE (1^9/1 to 4 //g/l), methylene chloride (0.9/^9/1 to
8 A*g/l), and carbon disulfide (10//g/l to12^g/l). PCBs were detected
at concentrations ranging from 0.15^g/l to 0.42 ^9/1- PCBs were not
detected at sampling points beyond approximately 2,600 ft downstream
of South Pond.
Surface water in North Pond contained TCE (4 /zg/l) and 1,2- DCE (1
Mg/l). PCBs in North Pond surface water ranged from nondetectable to
0.3/ig/l. A sample collected from a small pond in the North Area
contained TCE at 9 //g/l, but did not contain PCBs.
Prior to the excavation of contaminated sediments, the total VOCs in
South Pond sediments ranged from 0.013 mg/kg to 4.96 mg/kg. The
most prevalent VOCs were 1,2-DCE (3.5 mg/kg) and toluene (1.4 mg/kg).
South Pond sediments also contained low concentrations of methylene
chloride, acetone, 2-butanone, xylene, ethylbenzene, chlorobenzene,
1,1-DCE, 1,1,1-TCA, TCE, chloromethane, carbon disulfide, and vinyl
chloride. PCB concentrations in South Pond sediments ranged up to
1,300 mg/kg. Post-excavation sediment sampling results showed
maximum concentrations of methylene chloride at 0.003 mg/kg, carbon
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disulfide at 0.002 mg/kg, toluene at 0.003 mg/kg, xylenes at 0.06 mg/kg,
and PCBs at 0.37 mg/kg.
During the downstream investigations, sediments in the Herrick Hollow
Creek, the southern portion of the South Pond, and the floodplain
located downstream of South Pond showed PCB concentrations ranging
up to 180 mg/kg, 150 mg/kg, and 24 mg/kg, respectively.
Chloromethane (0.008 mg/kg) was the only VOC detected (in one
sample) downstream of South Pond. PCB levels exceeding 1 mg/kg were
not detected at sampling points beyond approximately 3,600 ft
downstream of South Pond. (See Figure 4 and Table 5.)
SUMMARY OF SITE RISKS
Based upon the results of the Rl, a baseline risk assessment was
conducted to estimate the risks associated with current and future site
conditions. The baseline risk assessment estimates the human health
and ecological risk which could result from the contamination at the
Site, if no remedial action were taken.
Human Health Risk Assessment
A four-step process is utilized for assessing site-related human health
risks for a reasonable maximum exposure scenario: Hazard
Identification—identifies the contaminants of concern at the Site based
on several factors such as toxicity, frequency of occurrence, and
concentration. Exposure Assessment—estimates the magnitude of
actual and/or potential human exposures, the frequency and duration of
these exposures, and the pathways (e.g., ingesting contaminated
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 assessments to provide a quantitative assessment of
site-related risks.
The baseline risk assessment began with selecting contaminants of
concern that would be representative of site risks. The contaminants
included 18 VOCs, 11 metals and PCBs. Several of the contaminants,
including vinyl chloride, benzene, and arsenic, are known to cause
cancer in laboratory animals and are suspected to be human
carcinogens. (See Table 6).
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The baseline risk assessment evaluated the health effects which could
result from exposure to contamination as a result of ingestion, dermal
contact, and inhalation of groundwater; ingestion and dermal contact
with surface and subsurface soils; ingestion and dermal contact with
surface water and sediment; dermal contact with leachate; and
inhalation of chemicals on respirable particles. The potential receptor
population includes current and future adolescent trespassers and
recreationalists, on-site utility/maintenance workers, and resident
children and adults.
Current federal guidelines for acceptable exposures are an individual
lifetime excess carcinogenic risk in the range of 10'4 to 1C6 (e.g., a
one-in-ten-thousand to a one-in-a-million excess cancer risk) and a
maximum health Hazard Index (HI) (which reflects noncarcinogenic
effects for a human receptor) equal to 1.0. (An HI greater than 1.0
indicates a potential of 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 the ingestion of drinking water in the current-use scenario
represents a total cancer risk of 6.4x10'8 for adults and 3.7x10'8 for
children and in the future-use scenario represents a total cancer risk of
1x10'4 for adults and 5.9x10'5for children. (See Table 7).
Concerning the noncarcinogenic risks, the results of the baseline risk
assessment indicate that the ingestion of drinking water in the
current-use scenario (an HI of 1.3 for adults and 5.6 for children) and
in the future-use scenario (a HI of 2.2 for adults and 7.9 for children)
result in His greater than 1.0. These elevated values are caused,
primarily, by volatile organic compounds, especially TCE. The potential
child trespasser showed a noncancer HI of 1.4 for ingestion of site soil,
an HI of 10 for dermarcontact with site soil, an HI of 1.6 for ingestion
of South Pond sediment, an HI of 12 for dermal contact with South Pond
sediment, and an HI of 4.5 for dermal contact with South Pond surface
water. Aroclor 1248 is the predominant contributor to all of these high
HI values. Ingestion of and dermal contact with subsurface soils by
utility/maintenance workers showed HI values greater than 1.0 (HI of 28
and 41, respectively), with Aroclor 1248 as the predominant contributor.
For the North Pond, the total HI for recreationalist exposure to the
chemicals of potential concern from dermal contact and ingestion of
surface water and dermal contact with sediment is 0.2. An HI of less
than 1.0 indicates that adverse, noncarcinogenic health effects from
such exposures are unlikely. (See Table 8).
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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.
Habitats which presently exist at the Site include palustrine emergent
marsh wetlands, open water areas (ponds and streams), successional
shrub land and mixed hardwood forest upland. Surface soils on the Site
may provide a source of exposure for wildlife through direct contact,
ingestion, and uptake of contaminants by vegetation or biota and
subsequent dietary ingestion. Surface runoff may transport soil
contaminated particles into the various streams and wetland areas,
potentially contaminating surface water and sediments in these areas.
If contaminants are discharged into the wetland areas, fish and wildlife
can be exposed to them through dietary ingestion via bioaccumulation
of contaminants into plant or biota tissues. Also, direct contact with
water and sediments can occur during feeding and nesting activities of
waterfowl and on a constant basis for fish and other aquatic organisms
inhabiting open water areas of the wetlands. Terrestrial wildlife may
also be exposed to contaminants via ingestion of water, aquatic
vegetation, and organisms, such as fish.
The risk assessment evaluated the potential risks to several indicator
species through exposure to the contaminants of concern. The control
pond was found to be dominated by a mixed-age sunfish population and
also contained fathead minnow, creek chub and blacknose dace.
However, only fathead minnow were found in the South Pond Area.
Therefore, the fathead minnow is used as an indicator of conditions in
the ponded areas in the vicinity of the Site. For assessment of risks
from exposure to surface soils and through the terrestrial food chain,
the deer mouse was used as an indicator. The mink and the great blue
heron were chosen as indicators for analysis of risk through potential
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exposures from the aquatic food chain, since these species may inhabit
the vicinity of the landfill, the South Pond and its downstream areas.
The hazard quotient (HQ) method is used to evaluate the potential risk
to wildlife by comparing estimated total daily intakes of chemicals of
potential concern (COPCs) from environmental media to toxicologic
endpoints or benchmarks shown to cause adverse ecological effects.
The HQ is expressed as the ratio of the estimated exposure levels to the
benchmarks. An HQ which exceeds 1.0 is interpreted as a level at which
deleterious effects may occur.
HQ results
COPCs in surface water, sediment, and soil that could bioconcentrate
through the food chain were modeled for exposures to the great blue
heron, mink and deer mouse using mean media concentrations detected
in South Pond Area. The chosen receptors are representative of trophic
levels potentially exposed to site-related releases, and therefore,
calculated risks are representative of risks to other receptors at the
same trophic level. The results of the HQ modeling show that PCB
Aroclor 1248 and zinc resulted in a calculated HQ of greater than 1.0 for
the great blue heron (HQ = 2.8 and 1.2, respectively) in South Pond.
Aluminum, arsenic, and PCB Aroclor 1248 resulted in a risk to the mink
(HQ = 93, 9.1; and 3.2, respectively). Cadmium (HQ = 2.7) and PCB
Aroclor 1248. (HQ = 8.6) pose a risk to the deer mouse.
Site-related chemicals are present in surface water at concentrations
that exceed ecological screening criteria. A chronic bioassay conducted
on fathead minnow larvae using surface water from the western portion
of South Pond indicated effects on survival and growth which may
suggest that conditions in the western portion of South Pond may be a
factor in the mortality of fish fry. The results of a caged fish study
indicate that PCBs in the surface water and sediments of South Pond
and outlet pond are bioavailable to fish residing in these areas.
Although resident fish would not be limited to constant exposures in a
specific area of the pond, uptake of PCBs is likely. Young-of-the-year
fish sampling exhibited PCB concentrations between 6.2 mg/kg and 8.4
mg/kg. Adult fish collected from South Pond and downstream water
bodies indicated PCB body burdens ranging from 5.6 mg/kg to 33 mg/kg.
A food chain exposure model indicates that fish with elevated PCB body
burdens present a risk to the piscivorous wildlife.
The presence of PCBs and inorganic compounds in environmental
media, at concentrations which present a potential risk based on HQs,
10
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are likely to have some adverse effect on wildlife utilizing the Site and
its vicinity. If the Site is unremediated, contaminants may continue to
be released (e.g., via leachate, surface runoff, groundwater discharge)
into the environment. Effects of contaminants could be more
pronounced over time as a result of increasing concentrations in the
media of concern and bioaccumulation through the food chain.
For North Pond, mink and osprey were chosen as indicators for analysis
of risk through exposure to contaminants in fish tissue. Based on the
HQs, it appears that aluminum, bis[2-ethylhexyl]phthalate, cadmium,
copper, iron, and manganese in the surface water of North Pond pose
a potential risk to aquatic biota. Based on the average DDT, DDE, and
ODD concentrations, there appears to be no potential risk to benthic
organisms in North Pond (HQ = 0.08). Based on the HQs for these
compounds, the presence of DDT, endrin, and nickel in fish tissue
presents no potential risk to wildlife consumers of fish from North Pond.
Potential risk to the ecological receptors impacted by North Pond will be
minimized when the Site (and the Sidney Landfill Site) are remediated,
thereby limiting future contaminant releases and allowing the affected
media to recover over time through natural processes, such as dilution,
sedimentation, and biodegradation.
Uncertainties
The procedures and inputs used to assess risks in this evaluation, as in
all such assessments, are subject to a wide variety of uncertainties. In
general, the main sources of uncertainty include:
• environmental chemistry sampling and analysis
• environmental parameter measurement
• fate and transport modeling
• exposure parameter estimation
• toxicological data
Uncertainty in environmental sampling arises in part from the potentially
uneven distribution of chemicals in the media sampled. Consequently,
there is significant uncertainty as to the actual levels present.
Environmental chemistry analysis uncertainty can stem from several
sources including the errors inherent in the analytical methods and
characteristics of the matrix being sampled.
Uncertainties in the exposure assessment are related to estimates of
how often an individual will actually come in contact with the chemicals
of concern, the period of time over which such exposure will occur, and
11
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in the models used to estimate the concentrations of the chemicals of
concern at the point of exposure.
Uncertainties in toxicological data occur in extrapolating both from
animals to humans and from high to low doses of exposure, as well as
from the difficulties in assessing the toxicity of a mixture of chemicals.
These uncertainties are addressed by making conservative assumptions
concerning risk and exposure parameters throughout the assessment.
As a result, the Risk Assessment provides upper bound estimates of the
risks to populations near the Site, and is highly unlikely to
underestimate actual risks related to the Site.
In summary, actual or threatened releases of hazardous substances
from this Site, if not addressed by the preferred remedy or one of the
other active measures considered, may present a current or potential
threat to public health, welfare and the environment.
REMEDIAL ACTION OBJECTIVES
Remedial action objectives are specific goals to protect human health
and the environment. These objectives are based on available
information and standards such as applicable or relevant and
appropriate requirements and risk-based levels established in the risk
assessment.
The following remedial action objectives have been established for the
Site:
• reduce/eliminate contaminant leaching to groundwater;
• control surface water runoff and erosion;
• mitigate the off-Site migration of contaminated groundwater;
• restore groundwater quality to levels which meet state and federal
drinking-water standards;
• prevent human contact with contaminated soils, sediments, and
groundwater; and
• minimize exposure of fish and wildlife to contaminants in surface
water, sediments, and soils.
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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, comply with other statutory laws, and utilize permanent
solutions and alternative treatment technologies and resource recovery
alternatives to the maximum extent practicable. Section 121(b)(1) also
establishes a preference for remedial actions which employ, as a
principal element, treatment to permanently and significantly reduce the
volume, toxicity, or mobility of the hazardous substances, pollutants and
contaminants at a site. 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).
This ROD evaluates in detail six remedial alternatives for addressing
the contamination associated with the Richardson Hill Road Landfill
site. Various processes are considered and are assembled into
remedial alternatives which can accomplish the remedial action
objectives. Cost and construction time, among other criteria, were
evaluated for each remedial alternative. The time to implement a
remedial alternative reflects only the time required to construct or
implement the remedy and does not include the time required to design
the remedy, negotiate with the responsible parties, procure contracts for
design and construction, or conduct operation and maintenance (O&M)
activities at the Site.
The remedial alternatives are:
Alternative 1A: No Action
Capital Cost: $0,
Annual O&M Cost: $0
Present-Worth Cost: $0
Construction Time: 0
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
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remedial measures that address the problem of contamination at the
Site. This alternative assumes no additional activity takes place beyond
the previously-implemented activities and the continued maintenance of
the two residential water treatment systems.
Because this alternative would result in contaminants remaining on-Site
above health-based levels, CERCLA requires that the Site be reviewed
every five years. If justified by the review, remedial actions may be
implemented to remove or treat the wastes.
Alternative 1B: Institutional Controls
Capital Cost: $83,000
Annual O&M Cost: $56,000
Present-Worth Cost: $821,000
Construction Time: 3 months
Alternative 1B includes the installation of a chain-link fence around the
landfill and the North Area, the implementation of institutional controls
(the placement of restrictions on the installation and use of groundwater
wells at the Site and limitations on the future use of the Site), and a
long-term groundwater monitoring program and monitoring of sediment
related media such as fish and surface water.
This alternative also includes the development and implementation of
a public awareness and education program for the residents in the area
surrounding the Site. This program would include the preparation and
distribution of informational press releases and circulars and convening
public meetings. These activities would serve to enhance the public's
knowledge of the conditions existing at the Site. This alternative would
also require the involvement of local government, various health
departments, and environmental agencies.
Because this alternative would result in contaminants remaining on-Site
above health-based levels, CERCLA requires that the Site be reviewed
every five years. If justified by the review, .remedial actions may be
implemented to remove or treat the wastes.
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Alternative 2: Contaminated Soil Excavation, Contaminated
Sediment Dredging/Excavation, Consolidation, On- and/or Off-Site
Disposal, Disposal Cell Construction, and Installation of Landfill
Cap
Capital Cost: $5,116,000
Annual O&M Cost: $206,000
Present-Worth Cost: $7,725,000
Construction Time: 12 months
This alternative includes excavating waste material and contaminated
soil in the North and South Areas (other than the landfill) which exceed
TAGM limits and excavating and/or dredging sediments exceeding 1
mg/kg PCB from South Pond and downstream areas. All
excavated/dredged sediments would be dewatered, as necessary. Clean
material would be used as backfill in the excavated areas. Any wetlands
impacted by remedial activities would be fully restored. This alternative
would also address the disposition of the contaminated sediments
previously excavated from South Pond. .
All excavated/dredged waste materials, soils, and sediments would be
subjected to RCRA hazardous waste characteristic testing. Those waste
materials, soils, and sediments that do not pass the RCRA characteristic
testing would be sent off-Site for treatment/disposal at a RCRA-
compliant facility (or a TSCA-compliant facility, if applicable). Those
waste materials, soils, and sediments that pass the RCRA characteristic
testing and have PCB concentrations which equal or exceed 500 mg/kg
would be sent off-Site for treatment/disposal at a TSCA-compliant
facility. Those waste materials, soils, and sediments that pass the RCRA
characteristic testing and have PCB concentrations less than 50 mg/kg
would be consolidated at the on-Site landfill; those with PCB
concentrations between 50 and 500 mg/kg would be placed in a TSCA-
compliant landfill constructed adjacent to the existing landfill. The on-
Site TSCA landfill (estimated volume of 8,500 cubic yards), which would
include a double composite liner and a final cover equivalent to a RCRA
cap, would meet the requirements of 40 CFR 761.75, except that it would
not be in strict compliance with the requirements of 40 CFR
761.75(b)(3), as the bottom of the landfill would not be located at least
50 feet higher than the nearest high groundwater elevation. Therefore,
a waiver of these requirements would be necessary.
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In the area to be capped (primarily, in the vicinity of the former waste
oil disposal pit), soil with PCB concentrations which equal or exceed
500 mg/kg would be excavated and sent off-Site for treatment/disposal
at a TSCA-compliant facility. Following such excavation and after the
excavated/dredged waste materials, soil, and sediments with PCB
concentrations less than 50 mg/kg are consolidated onto the existing
landfill, a New York State 6 NYCRR Part 360 or equivalent closure cap
would be constructed. A shallow leachate collection trench would be
installed on the downgradient edge of the landfill cap. In addition, a
chain-link fence would be constructed around the landfill.
An outlet control/sediment trap would be installed downgradient of
South Pond to minimize migration of contaminated sediment further
downstream from the main beaver pond.
Prior to the construction of the landfill cap, the landfill mound and the
consolidated sediments, soil, and waste materials would have to be
regraded and compacted to provide a stable foundation for the
placement of the various layers of the cap and to promote runoff. A
landfill cap meeting these requirements of New York State 6 NYCRR
Part 360 regulations would consist of a filter fabric, 6 inches of top soil
and vegetation, 2 feet of soil barrier protection layer, a 40-mil
geomembrane, and geonet (or equivalent).
This alternative would also include the implementation of institutional
controls (the placement of restrictions on the installation and use of
groundwater wells at the Site and restrictions on the future use of the
Site in order to protect the integrity of the new TSCA landfill and the cap
installed on the existing landfill), the implementation of a public
awareness program to ensure that the nearby residents are familiar with
all aspects of this response action, and long-term monitoring of the
groundwater, surface water, fish, and sediments.
Because this alternative would result in contaminants remaining on-Site
above health-based levels, CERCLA requires that the Site be reviewed
every five years. If justified by the review, remedial actions may be
implemented to remove or treat the wastes.
Alternative 3A: Contaminated Soil Excavation, Contaminated
Sediment Dredging/Excavation, Consolidation, On- and/or Off-Site
Disposal, Disposal Cell Construction, Installation of Landfill Cap,
and Groundwater Extraction (North Area via Extraction Wells and
South Area via an Interceptor Trench) and Treatment
16
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Capital Cost:, $7,871,000
Annual O&M Cost: $479,000
Present-Worth Cost: $13,864,000
Construction Time: 16 months
This alternative is identical to Alternative 2, except that it also includes
extraction and treatment of the contaminated overburden and weathered
bedrock interface groundwater exceeding federal and state Maximum
Contaminant Levels (MCLs) in the North and South Areas. This would
be accomplished by the installation of a downgradient interceptor trench
keyed into the top of the bedrock in the South Area and vertical
overburden and bedrock extraction wells in the North Area. Following
pretreatment for solids and inorganic constituent removal, the extracted
groundwater would be treated by air-stripping and activated carbon (or
other appropriate treatment) and then discharged to surface water.
Because this alternative would result in contaminants remaining on-Site
above health-based levels, CERCLA requires that the Site be reviewed
every five years. If justified by the review, remedial actions may be
implemented to remove or treat the wastes.
Alternative 3B: Contaminated Soil Excavation, Contaminated
Sediment Dredging/Excavation, Consolidation, On- and/or Off-Site
Disposal, Disposal Cell Construction, Installation of Landfill Cap,
and Groundwater Extraction (via Extraction Wells for both North and
South Areas) and Treatment
Capital Cost: $6,990,000
Annual O&M Cost: $469,000
Present-Worth Cost: $12,858,000
Construction Time: 16 months
This alternative is identical to Alternative 3A, except that the
groundwater extraction would be accomplished by vertical overburden
and bedrock extraction wells for both the North and South Areas. In
addition, hydro-fracing would be performed to enhance weathered
bedrock groundwater recovery. In hydro-fracing, water and other fluid
mixtures are injected under sufficient pressure to open existing
17
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fractures and induce new fractures along areas of bedrock weakness to
increase the specific yield of the well. Hydro-tracing will not shatter the
bedrock, since significantly higher pressures than those attainable
during hydro-fracing are required. The hydro-tracing pressures are
sufficient to part the rock matrix at bedding planes, existing, fractures
.or. other weak points in the bedrock.
Because this alternative would result in contaminants remaining on-Site
above health-based levels, CERCLA requires that the Site be reviewed
every five years. If justified by the review, remedial actions may be
implemented to remove or treat the wastes.
Alternative 4: Contaminated Soil Excavation, Contaminated
Sediment Dredging/Excavation, Consolidation and/or Off-Site
Disposal, Installation of Landfill Cap, and Groundwater Extraction
(North Area via Extraction Wells and South Area via an Interceptor
Trench) and Treatment
Capital Cost: $9,791,000
Annual O&M Cost: $462,000
Present-Worth Cost: $15,564,000
Construction Time: 16 months
This, alternative is identical to Alternative 3A, except that there would
be no on-Site construction of a TSCA-compliant landfill. Instead, those
excavated/dredged waste materials, soils, and sediments that pass the
RCRA hazardous waste characteristics testing and have PCB
concentrations between 50-500 mg/kg—that would have been disposed
of in the on-Site TSCA-compliant landfill under Alternative 3A—would,
under this alternative, be sent off-Site for treatment/disposal at a TSCA-
compliant facility.
Because this alternative would result in contaminants remaining on-Site
above health-based levels, CERCLA requires that the Site be reviewed
every five years. If justified by the review, remedial actions may be
implemented to remove or treat the wastes.
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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 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 or relevant and appropriate
requirements of other 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 trade-offs between alternatives:
3. Long-term effectiveness and permanence refers to the ability of a
remedy to maintain reliable protection of human health and the
environment over time, once cleanup goals have been met. It also
addresses the magnitude and effectiveness of the measures that
may be required to manage the risk posed by treatment residuals
and/or untreated wastes.
4. Reduction of toxicity, mobility, or volume through treatment is the
anticipated performance of the treatment technologies, with
respect to these parameters, a remedy may employ.
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 period until cleanup goals are achieved.
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6. Implementability is the technical and administrative feasibility of
a remedy, including the availability of materials and services
needed to implement a particular option.
7. Cosf includes estimated capital and O&M costs, and net present
worth costs.
8. State acceptance indicates whether, based on its review of the
RI/FS and Proposed Plan, the State concurs with, opposes, or has
no comment on the selected remedy at the present time.
9. Community acceptance will be assessed in the ROD and refers to
the public's general response to the alternatives described in the
Proposed Plan and the RI/FS reports.
A comparative analysis of these alternatives based upon the evaluation
criteria noted above, follows.
Overall Protection of Human Health and the Environment
Since Alternative 1A (no action) would not address the risks posed
through each exposure pathway, it would not be protective of human
health and the environment. Alternative 1B, which would include
installing a fence around the waste disposal areas, would prevent or
reduce the likelihood of trespassers from entering the waste disposal
areas. Institutional controls would limit the intrusiveness of future
activity that could occur on the Site. However, this alternative would
not provide any protection to the ecological receptors.
Alternatives 2, 3A, 3B, and 4 would be significantly more protective than
Alternatives 1A and 1B, in that the risk of incidental contact with waste
by humans and ecological receptors would be reduced by excavating
the contaminated soil and waste material, excavating and/or dredging
the contaminated sediments from South Pond and downstream areas,
consolidating the excavated waste material and soils and
excavated/dredged sediments on the landfill, placing it in a new TSCA
landfill (Alternatives 2, 3A, and 3B only), and/or transporting it off-Site
for treatment/disposal, and installation of a cap on the existing landfill.
Additionally, sediment traps would provide effective restriction of
sediment migration and impact to the environment. Collecting and
treating the contaminated groundwater under Alternatives 3A, 3B, and
4 would reduce the possibility of additional groundwater contamination
originating from this area and would restore water quality in the aquifer.
Also, Alternatives 2, 3A, 3B, and 4 would provide for overall protection
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of human health and the environment in that the capping of the
landfilled materials would reduce infiltration, thereby reducing the
migration of contaminants of concern from the landfill to the
groundwater.
Compliance with ARARs
A 6 NYCRR landfill cap is an action-specific ARAR for landfill closure.
Therefore, Alternatives 2, 3A, 3B, and 4 would satisfy this action-
specific ARAR. Alternatives 1A and 1B would not meet this ARAR, since
they do not include any provisions for a landfill cap.
Since Alternatives 2, 3A, 3B, and 4 would involve the
excavation/dredging of PCB-contaminated waste material, soils, and
sediments, their disposition would be governed by the requirements of
TSCA., Under Alternatives 2, 3A, and 3B, those excavated/dredged
waste materials, soils, and sediments which equal or exceed 500 mg/kg
PCB would be sent off-Site for treatment/disposal at a TSCA-compliant
facility. Under Alternative 4, all excavated/dredged waste materials,
soils, and sediments which equal or exceed 50 mg/kg PCB would be sent
off-Site for treatment/disposal at a TSCA-compliant facility. Under
Alternatives 2, 3A, and 3B, those excavated/dredged waste materials,
soils, and sediments with PCB concentrations between 50-500 mg/kg
would be placed in an on-Site TSCA-compliant landfill constructed
adjacent to the existing landfill. The TSCA landfill would meet the
requirements of 40 CFR 761.75, except that it would not be- in strict
compliance with the requirements of 40 CFR 761.75(b)(3), as the bottom
of the landfill would not be located at least 50 feet higher than the
nearest high groundwater elevation. Therefore, a waiver of this
requirement would be necessary, pursuant to 40 CFR 761.75(c)(4).
Considering the nature of the waste, the intended design and operation
of the TSCA landfill would be sufficient to prevent the migration of PCBs
from the landfill.
To comply with RCRA land disposal restrictions, under Alternatives 2,
3A, 3B, and 4, only those excavated/dredged waste materials, soils, and
sediments which pass RCRA hazardous waste characteristic testing
could be disposed of on-Site without treatment.
Alternatives 1A and 1B do not provide for any direct remediation of
groundwater and would, therefore, not comply with chemical-specific
ARARs. Similarly, Alternative 2 does not include any active
groundwater remediation and it would not meet groundwater MCLs
(chemical-specific ARARs) in a reasonable time. These alternatives,
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therefore, are not considered protective with regard to groundwater.
Alternatives 3A, 3B, and 4 would, however, be the most effective in
reducing groundwater contaminant concentrations below MCLs because
not only would the lower precipitation infiltration rate associated with
placing an impermeable cap over the landfilled area significantly reduce
the generation of additional groundwater contamination, but these
alternatives include the collection and treatment of contaminated
groundwater.
Lona-Term Effectiveness and Permanence
Alternative 1A, no action, would not provide reliable protection of human
health and the environment over time. The institutional controls
associated with Alternative 1B would provide some protection of human
health, but would not be as reliable as the remaining alternatives.
Alternatives 3A, 3B, and 4 would be more effective over the long term
than Alternative 2, because they include the collection and treatment of
the contaminated overburden and bedrock groundwater. Excavating the
contaminated soil and waste material from the North Area, excavating
and/or dredging the contaminated sediments from South Pond and
downstream areas, consolidating the excavated waste material and soils
and excavated/dredged sediments on the landfill and/or off-Site
treatment/disposal, and the installation of a landfill cap would
substantially reduce the residual risk of untreated waste on the Site by
essentially isolating it from contact with human and environmental
receptors and the mobility caused by infiltrating rainwater. The
adequacy and reliability of the cap on the existing landfill (Alternatives
2, 3A, 3B, and 4) and the new TSCA landfill (Alternatives 2, 3A, and 3B)
to provide long-term protection from waste remaining at the Site should
be excellent.
The 6 NYCRR Part 360 cap or equivalent closure cap and the TSCA
landfill would require routine inspection and maintenance to ensure
long-term effectiveness and permanence. Routine maintenance of the
two caps, as a reliable management control, would include mowing,
fertilizing, reseeding and repairing any potential erosion or burrowing
rodent damage.
While a large volume of contaminated groundwater would be treated
during remediation,. Alternatives 3A, 3B, and 4 may not be completely
effective in removing all of the groundwater contamination, because
some of the contamination may remain in the fractured bedrock at the
completion of remediation. The long-term effectiveness would also be
affected by any on-going migration of contaminants from the source
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areas. In the existing hydrogeological conditions, Alternatives 3A and
4 would be more effective than Alternative 3B, because the interceptor
trench would be more effectual in collecting contaminated groundwater
at the South Area than groundwater recovery wells would be.
Reduction in Toxicitv. Mobility, or Volume through Treatment
Alternatives 1A and 1B would not actively reduce the toxicity, mobility,
or volume of contaminants through treatment. These alternatives would
rely on natural attenuation to reduce the levels of contaminants.
While excavating the contaminated soil and waste material from the
North Area, excavating and/or dredging the contaminated* sediments
from South Pond and downstream areas, consolidating the excavated
waste material and soils and excavated/dredged sediments on the
landfill, placement in an on-Site TSCA landfill, and/or off-Site
treatment/disposal, and the installation of a landfill cap under
Alternatives 2, 3A, 3B, and 4 would prevent further migration of and
potential exposure to these materials and would nearly eliminate the
infiltration of rainwater into the waste disposal areas and the associated
leaching of contaminants from these areas, the reduction in mobility
would not be accomplished through treatment.
Collecting and treating contaminated groundwater under Alternatives
3A, 3B, and 4 would reduce the toxicity, mobility, and volume of
contaminants through treatment and it would also reduce the possibility
of additional groundwater contamination. Alternative 2 would rely on
natural attenuation to reduce the levels of groundwater contamination.
Short-Term Effectiveness
Alternatives 1A and 1B do not include any physical construction
measures in any areas of contamination and, therefore, do not present
a risk to the community as a result of their implementation. Alternatives
2, 3A, 3B, and 4 involve excavating, moving, placing, and regrading
waste. Alternatives 3A and 4 involve the installation of an interceptor
trench and extraction wells and Alternative 3B involves the installation
of extraction wells, through potentially contaminated soils and
groundwater. While all of the action alternatives present some risk to
on-Site workers through dermal contact and inhalation, these exposures
can be minimized by utilizing proper protective equipment. The vehicle
traffic associated with landfill cap construction, TSCA landfill
construction, and the off-Site transport of contaminated soils/sediments
could impact the local roadway system and nearby residents through
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increased noise level. While Alternative 4 would not require the
delivery of materials for the construction of TSCA landfill (Alternatives
2, 3A, and 3B), this alternative would require the off-Site transport of a
considerable amount of contaminated waste material, soils, and
sediments. Disturbance of the land during construction could affect the
surface water hydrology of the Site. There is a potential for increased
stormwater runoff and erosion during excavation, dredging, and
construction activities that must be properly managed to prevent
excessive water and sediment loading.
Implementabilitv
Fencing the Site, performing routine groundwater monitoring, and
effecting institutional controls are all actions that can be readily
implemented. These actions are technically and administratively
feasible and require readily available materials and services.
Excavating and relocating the contaminated soil and waste material from
the North Area to the landfill, excavating and/or dredging and relocating
the contaminated sediments from South Pond and downstream areas to
the landfill and/or to an off-Site treatment/disposal facility, and the
installation of a landfill cap over the waste disposal area (Alternatives
2, 3A, 3B, and 4), the construction of a TSCA landfill (Alternatives 2,
3A, and 3B), and installing interceptor trenches and extraction wells
(Alternatives 3A, 36, and 4), although more difficult to implement than
the no-action alternative, can be accomplished using technologies
known to be reliable and can be readily implemented. Equipment,
services and materials for this work are readily available. These
actions would also be administratively feasible.
Air stripping is a process through which volatile contaminants are
transferred from the aqueous phase to an air stream. Air stripping has
been effectively used to remove over 99 percent of volatile organic
compounds from groundwater at numerous hazardous waste and spill
sites.
The use of blasted trenches (Alternatives 3A and 4) is technically
feasible. Additionally, the use of an experienced blasting firm would be
required during the design and the implementation of the trenches.
Hydro-fracing (Alternative 3B) is a common method used to open
existing fractures in bedrock and increase hydraulic conductivity. The
equipment used for hydro-fracing is readily available throughout the
drilling industry. All of the components for the treatment system are
readily available.
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Cost
The present-worth costs are calculated using a discount rate of 7
percent and a 30-year time interval. The estimated capital, a-nnual
O&M, and present-worth costs for each of the alternatives are presented
below.
Alternative
1A
1B
2
3A
3B
4
I Capital Cosfs
$0
$83,000
$5,116,000
$7,871,000
$3,990,000
$9,791,000
•Annual 0 & M
;![;%: :;-/.Coste;:.:-"- -:
$0
$56,000
$206,000
$479,000
$469,000
$462,000
Present Worth
ff.i ••;,'" . Cosfs
$0
$821,000
$7,725,000
$13,864,000
$12,858,000
$15,564,000
As is indicated from the cost estimates, there are no costs associated
with the no action alternative, Alternative 1A. The costs associated with
Alternative 1B are for fencing, institutional controls and monitoring.
The major cost component of Alternative 2 is for the
excavation/dredging of contaminated waste material, soils, and
sediments and the construction and maintenance of the landfill cap and
TSCA compliant landfill. The capital and present-worth costs related to
the construction of an on-Site TSCA landfill would be approximately
$391,000 and $611,000, respectively. If the TSCA landfill is not
constructed, the excavated/dredged waste material, soils, and
sediments containing PCBs at concentrations greater than 50 mg/kg
would have to be treated or disposed of at an off-Site TSCA-compliant
facility (Alternative 4), which would increase the implementation cost by
about $1.7 million. Alternatives 3A, 3B, and 4 include the collection and
treatment of contaminated groundwater. The more expensive of these
options are Alternatives 3A and 4, which utilize interceptor trenches in
the South Area and extraction wells in the North Area rather than
extraction wells for both North and South Areas (Alternative 3B).
State Acceptance
NYSDEC concurs with the selected alternative.
25
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Community Acceptance
While the majority of the public in attendance at the public meeting
accepted the preferred remedy, a petition signed by 18 individuals
requesting the complete excavation and off-site disposal of the 8-acre
landfill was mailed to EPA. Comments received during the public
comment period are summarized and addressed in the Responsiveness
Summary, which is attached as Appendix V to this document.
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 Alternative 3A is the appropriate remedy, because
it best satisfies the requirements of CERCLA §121, 42 U.S.C. §9621 and
the NCP's nine evaluation criteria for remedial alternatives, 40 CFR
§300.430(e)(9). The selected remedy involves:
• Excavation of contaminated waste material and soil exceeding
NYSDEC's Soil Cleanup Objectives2 in the North and South Areas
(other than the landfill). Clean fill will be used as backfill in the
excavated areas;
• Based upon pre-design sampling of soil in the area to be capped
(primarily, in the vicinity of the former waste oil disposal pit), soil
with PCB concentrations which equal OF exceed 500 mg/kg will be
excavated and sent off-Site for treatment/disposal at a TSCA-
compliant facility;
• Excavation and/or dredging of sediments exceeding 1 mg/kg PCB from
South Pond and all areas downstream for approximately 2,400 feet.
A monitoring plan for those areas further downstream will be
developed during the design phase. The need for remediation in
areas further downstream will be evaluated based on an assessment
of sediment concentrations and biological receptors (i.e., fish tissue
concentrations over the 5-year time period subsequent to the
completion of upstream remediation activities). Baseline data for this
evaluation will be collected prior to the commencement of upstream
remedial activities. Removal of sediment "hot spots" may be
conducted in conjunction with upstream remedial activities, if
NYSDEC's soil cleanup objectives are specified in NYSDEC Technical Administrative Guidance
Memorandum No. 94-HWR-4046.
26
-------
warranted, subsequent to an evaluation of the baseline data. Further
remediation may be required in the downstream areas if it is
determined through monitoring that the remedial activities conducted
upstream were not effective in addressing the ecological risk. All
excavated/dredged sediments will be dewatered, as necessary. Any
wetlands impacted by remedial activities will be fully restored.
Ambient PCB monitoring will be conducted during the sediment
excavation/dredging and handling in compliance with the
Occupational Safety and Health Administration standard of 1,000
micrograms per cubic meter time-weighted average (8 hour day/40
hour work week);
Installation of an outlet control/sediment trap downgradient of South
Pond to minimize migration of contaminated sediment further
downstream from the main beaver pond;
All excavated/dredged waste materials, soils, and sediments will be
subjected to RCRA hazardous waste characteristic testing. Those
waste materials, soils, and sediments that do not pass the RCRA
characteristic testing will be sent off-Site for treatment/disposal at a
RCRA-compliant facility (or a TSCA-compliant facility, if applicable).
Those waste materials, soils, and sediments that pass the RCRA
characteristic testing and have PCB concentrations which equal or
exceed 500 mg/kg will be sent off-Site for treatment/disposal at a
TSCA-compliant facility. Those waste materials, soils, and sediments
that pass the RCRA characteristic testing and have PCB
concentrations less than 50 mg/kg will be consolidated on the on-Site
landfill; those with PCB concentrations between 50-500 mg/kg will be
placed in a TSCA-compliant landfill constructed adjacent to the
existing landfill. The on-Site TSCA landfill (estimated volume of
8,500 cubic yards), which will include a double composite liner and
a final cover equivalent to a RCRA cap, will meet the requirements of
40 CFR 761.75, except that it will not be in strict compliance with the
requirements of 40 CFR 761.75(b)(3), as the bottom of the landfill will
not be located at least 50 feet higher than the nearest high
groundwater elevation. Therefore, a waiver of these requirements
will be necessary pursuant to 40 CFR 761.75(c)(4). It is EPA's
assessment that, considering the nature of the waste, the design and
operation of the landfill will be sufficient to prevent migration of PCBs
from the landfill. Consequently, a waiver of this requirement is
justified;
Following the consolidation of the excavated/dredged waste
materials, soils, and sediments with PCB concentrations less than 50
27
-------
mg/kg onto the existing landfill, a New York State 6 NYCRR Part 360
or equivalent closure cap will be constructed;
• Construction of a chain-link fence around the landfill;
• Construction of a shallow leachate collection trench, keyed into the
top of the bedrock, on the downgradient edge of the cap that will be
installed on the existing landfill, and installation of vertical
overburden and bedrock extraction wells in the North Area;
• Extraction of contaminated groundwater from the overburden and
shallow bedrock in the South Area utilizing the downgradient
interceptor trench, and in the North Area utilizing the* extraction
wells, and treatment of the extracted groundwater by air-stripping and
activated carbon (or other appropriate treatment), followed by
discharge to surface water;
• Taking steps to secure institutional controls (the placement of
restrictions on the installation and use of groundwater wells at the
Site and restrictions on the future use of the Site in order to protect
the integrity of the new TSCA landfill and the cap installed on the
existing landfill); and
• Long-term monitoring of groundwater, surface water, fish and
sediments to ensure the effectiveness of the selected remedy.
In addition, the water treatment systems that were installed on the
contaminated wells at two residences will continue to be maintained.
Under the selected remedy, the source of the bedrock groundwater
contamination is expected to be significantly reduced or possibly
eliminated due to the reduction of infiltrating precipitation by the
capping, of the landfill and the extraction and treatment of the
contaminated groundwater.
The selected remedy is believed to be able to achieve the ARARs more
quickly, or as quickly than the other alternatives. Therefore, the
selected remedy will provide the best balance of trade-offs among
alternatives with respect to the evaluating criteria. EPA and the
NYSDEC believe that the selected remedy will be protective of human
health and the environment, be cost-effective, and utilize permanent
solutions and alternative treatment technologies or resource recovery
technologies to the maximum extent practicable. The selected remedy
will meet the statutory preference for the use of treatment as a principal
28
-------
element (for the groundwater) and is generally consistent with landfill
closure requirements applied to municipal landfills in the State of New
York. However, since the landfill's contaminant source areas cannot be
effectively excavated and treated due to its size, none of the
alternatives considered satisfied the statutory preference for treatment
as a principal element of the remedy with respect to the sources of
contamination.
The selected remedy will comply with all the ARARs except that it will
not be in strict compliance with the requirements of 40 CFR
761.75(b)(3), as the bottom of the on-Site TSCA landfill will not be
located at least 50 feet higher than the nearest high groundwater
elevation. Therefore, a waiver of this requirement will be necessary,
pursuant to 40 CFR 761,75(c)(4). It is EPA's assessment that,
considering the nature of the waste, the design and operation of the
landfill will be sufficient to prevent migration of PCBs from the landfill.
Consequently, a waiver is justified.
STATUTORY DETERMINATIONS
As was 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 establish.es 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).
For the reasons discussed below, EPA has determined that the selected.
remedy meets the requirements of CERCLA §121, 42 U.S.C. §9621.
Protection of Human Health and the Environment
The selected remedy protects human health and the environment by
reducing levels of contaminants in the groundwater, soil and sediment
through extraction/treatment and excavation, respectively, as well as
the implementation of institutional controls. The risk of incidental
contact with waste by humans and other ecological receptors will be
29
-------
reduced by the landfill cap. Capping of the landfill will also reduce
infiltration, thereby reducing the migration of contaminants of concern
from the landfill to the groundwater and to the sediment. The selected
remedy will also provide overall protection by reducing the toxicity,
mobility, and volume of contamination, through extraction/treatment of
the contaminated groundwater and the effluent will meet surface water
discharge requirements.
Compliance with Applicable or Relevant and Appropriate Requirements
of Environmental Laws
While there are no federal or New York State soil and sediment ARARs,
one of the remedial action goals is to meet NYSDEC soil cleanup
objectives. The selected remedy will be effective in reducing
groundwater contaminant concentrations below MCLs (chemical-specific
ARARs) because the lower precipitation infiltration rate associated with
placing low-permeability caps over the landfilled areas will significantly
reduce the generation of additional groundwater contamination. The
extraction of the contaminated groundwater at this location, combined
with the capping of the waste disposal area, should significantly reduce
the source of the overburden and bedrock groundwater contamination.
The on-Site TSCA landfill will meet the requirements of 40 CFR 761.75,
except that it will not be in strict compliance with the requirements of 40
CFR 761.75(b)(3), as the bottom of the landfill will not be located at
least 50 feet higher than the nearest high groundwater elevation.
Therefore, a waiver of this requirement will be necessary, pursuant to
40 CFR 761.75(c)(4). However, considering the nature of the waste,
the design and operation of the landfill will be sufficient to prevent
migration of PCBs from the landfill and, therefore, a waiver will be
justified.
A summary of action-spectific, chemical-specific, and location-specific
ARARs which will be complied with during implementation is presented
below. A listing of the chemical-specific ARARs is presented in Tables
9 and 10.
Action-specific ARARs:
• National Emissions Standards for Hazardous Air Pollutants
• 6 NYCRR Part 257, Air Quality Standards
• 6 NYCRR Part 212, Air Emission Standards
30
-------
• 6 NYCRR Part 373, Fugitive Dusts
• 40 CFR 50, Air Quality Standards
• State Permit Discharge Elimination System
• Resource Conservation and Recovery Act
Chemical-specific ARARs:
• Safe Drinking Water Act Maximum Contaminant Levels and Maximum
Contaminant Level Goals (MCLs and MCLGs, respectively, 40 CFR
Part 141)
• 6 NYCRR Parts 700-705 Groundwater and Surface Water Quality
Regulations
• 10 NYCRR Part 5 State Sanitary Code
Location-specific ARARs:
• Clean Water Act Section 404, 33 U.S.C. 1344
• Fish and Wildlife Coordination Act, 16 U.S.C. 661
• National Historic Preservation Act, 16 U.S.C. 470
• New York State Freshwater Wetlands Law ECL, Article 24, 71 in Title
23
• New York State Freshwater Wetlands Permit Requirements and
Classification, 6 NYCRR 663 and 664
• New York State Endangered and Threatened Species of Fish and
Wildlife Requirements, 6 NYCRR 182
Other Criteria, Advisories, or Guidance To Be Considered:
• Executive Order 11990 (Protection of Wetlands)
• Executive Order 11988 (Floodplain Management)
31
-------
• EPA Statement of Policy on Floodplains and Wetlands Assessments
for CERCLA Actions
• New York Guidelines for Soil Erosion and Sediment Control
• New York State Sediment Criteria, December 1989
• New York State Air Cleanup Criteria, January 1990
• SOWA Proposed MCLs and MCL Goals
• NYSDEC Technical and Operational Guidance Series 1.1.1, November
1991
• EPA Ambient Water Quality Criteria (Federal Register, Volume 57,
No. 246, December 22, 1992)
• Technical Guidance for Screening, Contaminated Sediments
(November 1993, NYSDEC, Division of Fish and Wildlife, Division of
Marine Resources).
• Soil cleanup objectives specified in NYSDEC Technical Administrative
Guidance Memorandum No. 94-HWR-4046.
Cost-Effectiveness
The selected remedy provides for overall effectiveness in proportion to
its cost. The estimated cost for the selected remedy has a capital cost
of $7,871,000, annual operation and maintenance of $479,000, and
present-worth costs of $13,864,000.
Utilization of Permanent Solutions and Alternative Treatment
Technologies to the Maximum Extent Practicable
•
Given the size of the landfill, containment of the waste mass is the only
practical means to remediate the Site. By constructing a cap over the
landfill which is consistent with New York State NYCRR Part 360 for
landfill closure, hazardous wastes will be isolated from the environment
and their mobility will be minimized. The closure cap is a permanent
technology that must be maintained at regular intervals to ensure its
structural integrity and impermeability. The extraction and subsequent
treatment of groundwater from the bedrock aquifer will permanently and
significantly reduce the toxicity, mobility, and volume of contaminants
in the ground water.
32
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Preference for Treatment as a Principal Element
The statutory preference for remedies that employ treatment as a
principal element cannot be satisfied for the landfill itself, since
treatment of the landfill material is not practicable due to its size.
However, the statutory preference for remedies that employ treatment
as a principal element is satisfied by treating the contaminated
groundwater.
DOCUMENTATION OF SIGNIFICANT CHANGES
There are no significant changes from the selected alternative
presented in the Proposed Plan.
33
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APPENDIX I
FIGURES
Figure 1 Regional Site Location Map
Figure 2 Site Location Map
Figure 3 Site Map
Figure 4 Downstream Sediment Map
-------
LAKE ems I/MM*
RICHARDSON HILL/
ROAD LANDFILL
SITE
RICHARDSON HILL ROAD LANDFILL
SIDNEY. NEW YORK
REGIONAL LOCATION MAP
FIGURE 1
-------
FIGURE 2 RICHARDSON HILL ROAD MUNICIPAL LANDFILL SITE
Site Location Map
-------
FICURC
RICHARDSON iwi ROAD
UUMOPAL IAIOLL SHE
SIIC MAP
UCCHO
.1 StCriOll
•ASIC ni MICA
IRCC U«
ROAOWAT
ROAO MUACClll SIOIC MAIL
0 _JOO COO
SCAIC M rcci
o onicM 6 oono
. IK .
-------
13 1211 1Q
21 20 -
817 15 15
SEGMENT NUMBERS
MMPTCO mOH. USC.S. TROUT CRtEM N.Y.. WLTON WtST N.
•/'I/"
FIGURE A
. ' .. '<•'•=
Downsfcrean
jL.mtm ,;=;
KOCNT UOCAnOH
. — PMUSIMC MCIIAMO
.";*.. • FuxxmA
. ; •' snwc race
RICHARDSON HILL ROM)
MUNICIPAL LANOfia SHE
PCB CONCENTRATIONS
IN SEDIMENT
-------
APPENDIX II
TABLES
Table 1 Summary of Surface Soil Data
'Table 2 Summary of Subsurface Soil Data
TableS Summary of Groundwater Data
Table 4 Summaiy of Surface Water Data
TableS Summary of Sediment Data -
Table 6 Summaiy of Exposure Pathway -
Table? Summary of Carcinogenic Risks
Table 8 Summary of Non-carcinogenic Risks
Table 9 Federal and State Maximum Contaminant
Levels fotDrinking Water -
Table 10 NYSDEC TAGM Objectives for Soil
/ - • . ' - • . '
-------
Richardson Nil? Road Landfill Site
TABLE 1
SUMMARY OF SURFACE SOIL DATA
Number of Number
Analyte Detections Analyzed
ECBSI
Aroclor1248
INORGANICS:
Aluminum
Arsenic
Barium
Beryllium
Cadmium
Calcium
Chromium
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Nickel
Potassium
Vanadium
Zinc
29
3
3
3
1
1
2
3
3
3
3
3
3
3
3
2
3
2
34
3
3
3
2
3
3
3
3
3
3
3
3
3
3
3
3
2
Min. Cone. Mean Cone. Max. Cone. Background Cone.
mg/kg mg/kg mg/kg mg/kg
0.016
12000
9
63
0.35
0.19
295
15
10
39
22000
24
2600
728
18
630
16
81
39
13000
11
83
0.575
0.413
1198
22.4
12
62
25133
35
3457
909
23
803
18
90
480
15000
11.5
110
0.8
0.7
2100
37.2
14
.76.4
28400
46
3970
1200
26.6
750
20
91
32200
28
165
1.03
0.69
31
17
31
59400
i62
4480
681
28
1335
55
154
Notes:
1. Background levels based on tow times the main background concentration
2. Source of table from OB&GR) tables.
3. These data are the laboratory dates, it does not include the IteU testing data*.
-------
Richardson HiH Road Landfill Site-
TABLE 2
SUMMARY OF SUBSURFACE SOIL DATA
Number of Number Min. Cone. Max Cone Background Cone.
Analyte Detections Analyzed mg/kg mg/kg mg/kg
ECJBa;
Arocfor 1246
PCB
VOLATILES:
1.1.1-Trichtoroethane
, i ,2,2-Teiracnioroetnane
1,1-Dichloroethene
1 T r^intllnvrtattlMnA
i ,^
-------
Richardson Hill Road Landfill Site
TABLES
SUMMARY OF GROUNDWATER DATA
NunMrcf Numtov Min. C«nt Mm. Cone Scram^Conc.
AnMyK MMim Aralyad ugA ugfl ugr)
eca*
Anew 1248
ur»i AT* BS-
1.1.1-TifcNoreiMM
1.1-OMtoMM*
1.1-OfchlantOim
1 ,2*OicfttafOVlnBfW
1.2-Ofcttora»Mni(MiN)
AcMm
toon*
Mncyt AtoQnol
CflfenMmw
CNoraMra .
CNgrefem
B^Ai^m
MApMhitW
T*Mn»
T(t>*^W*^^^M^
i rvnBravoniww
Vv^cMoriBB
Xytan.
SEMMQL^^&£ftl
BK,tniimrt*^«i
OMvMylpNMMi
DMh*nMMi
44Mhyfetvnal
bM2-etiii»ijilK
-------
Richardson Hill Road Landfill Site
TABLE 3 cont
SUMMARY OF GROUNDWATER DATA
NORTH AREA
Number of Number Min. Cone. Max. Cone. Screening Cone.
Analyte Detections Analyzed ug/l ug/l ug/l
RGBs:
Aroclor 1248
VOLATILES-
1,1,1 -Trichloroethane
Tetrachloroethene
Trichlorethene
SEMIVOLATILES-
Butylbenzyl phthalate
Di-n-butyl phthalate
trans- 1 ,2-Dichloroethene
INORGANICS
Aluminum
Arsenic
Chromium
Copper
Manganese
Nickel
Zinc
3
3
2
7
1
1
4
1
2
1
1
2
1
2
10
13
10
7
1
1
10
2
4
2
2
2
2
2
0.1
0.008
3
2
1
1
2
6.46
• 3
0.14
0.03
0.1
0.1
0.012
0.29
23
7
340
1
1
8
6.46
3
0.14
0.03
0.43
0.1
0.05
0.0087
130
1.1
1.6
730
370
12
3700
1.1
18
140
18
73
1100
Notes:
1. Background levels based on tow times the main background concentration
2. Source of table from OB&G Rl tables.
-------
Richardson Hill Road Landfill Site
TABLE 4
SUMMARY OF SURFACE WATER DATA
Number of Number Min. Cone. Mean Cone. Max. Cone. Background Cone.
Analyte Detections Analyzed ug/l ug/l ug/1 ug/l
ECBsi
Aroclor 1248
VOLATILES:
1,1,1-Trichloroethane
1,1-Dichloroethane
1 ,2-Dichloroethylene(total)
Acetone
Carbon Disulfide
Dichloromethane
Tetrach loroethy lene
Toluene
Trichlorethylene
Vinyl chloride
SEMIVOLATILES
di-n-Butylphthalate
cis-1 ,2-Dichloroethene
INORGANICS:
Aluminum
Barium
Calcium
Copper
Iron
Lead
Magnesium
Manganese
Mercury
Potassium
Zinc
26
2
1
25
3
7
8
1
1
6
2
2
4
7
3
8
1
8
1
5
8
3
4
3
43
39
39
33
18
18
38
39
39
40
39
3
6
7
3
8
1
8
2
5
8
8
6
3
0
0.5
0.5
0.5
5
1
0.5
0.5
0.5
0:5
0.5
1
2
43.5
42.8
7
25
2
0.5
2
1
0.05
1
12.1
1.77
3.01
2.59
56.53
5.556
6.8
0.105
1.95
1.61
3.13
7.6
2.6
5.83
265
44.3
4818
25
2934
1.95
3
848.9
0.105
167
26.7
4.6
65
48
1600
9
29
0.17
0.7
10
59
200
2
23
723
88
15800
25
11600
7.4
4640
3010
0.17
1090
38
225.05
28.45
9015
10.05
1090
3.5
3152
158.25
Notes:
1. Background levels based on tow times the main background concentration
2. Source of table from OB&G Rl tables.
-------
Richardson Hill Road Landfill Site
TABLE 5
SUMMARY OF SEDIMENT DATA
Analyte
PCBs:
Arodor.1248
VOLATILES-
1,4-Oichlorobenzene
1,1-Oichtoroelhane
1.2-Dicrtloroetfiylene
-------
Richardson Hill Road Landfill Site
TABLES
EXPOSURE PATHWAY SUMMARY
Medium «;;/•••
Surface Water
Sediments
Soil
Aquatic biota
Receptors;'.,.' . • ::,../-.,.•
invertebrates, amphibians,
reptiles, birds, mammals
amphibians, reptiles, fish,
terrestrial birds and
mammals
. '
great blue heron, kingfisher,
waterfowl, mink,
copes • •. '•'••.• .'• ;. •• . •
Al, Ba, Ca, Cu, Fe, Mg, Mn, Hg,
K,, Na, Zn, vinyl chloride, 1,1-
DCA, U-DCE, 1,1,1-TCA, TCE,
toluene, CSj, methylene chloride,
acetone, tetrachloroethene, di-N-
butylphtnalate, PCB Aroclor 1254
and PCB Aroclor 1248
Al As, Ba, Ca, Cr, Co. Cu, Fe, Pb,
Mg.Mn.Ni.IC. V, vinyl chloride,
methylene chloride, CS* 1,1-
DCA, r>DCE, 1,1,1-TCA,
TCE,tolene, emylbeazene, „
Aroclor 1254 and PCB Aroclor
1248
Cd, Ca. Cr, Cu, Pb. Mg. Mn, Ni.
Zn, PCB Aroclor 1254 and PCB
Aroclor 1248
Al, As, Cr, Cu, Fe, Pb, Mn, Ni, Zn,
1,1-DCA, U-DCE, 1,1,1-TCA,
CS» vinyl chloride,
benzo(a)pyrene, PCB Aroclor
1248
Exposure
Mechanism
dermal contact,
ingestion
dermal contact,
ingestion
dermal contact,
ingestion
ingestion
Pathway
Status
Complete
Complete'
Complete
Complete
August 9,1996
O'Brien & Gere
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Richardson Hill Road Landfill Site
TABLET
SUMMARY OF CARCINOGENIC RISKS
'^^^i^^^^^^^^^^^SS^^^^^^ss*1
Construction
Worker
Adolescent
Recreator
>
Inddantallngastkinof
Subsurface Softs
Dermal Contort .
Softs
inoneniM ingesuon or
Surface Soto
Dermal Contact with
Surface Softs
SouuiMfits ~ South Pond
Donrari Contact
with SMevnanls* Soutti Pond .
Dermal Contact
WHh Surface
Water. South Pond
A/odof-1248 7.80E-06 96E+00 6.0E-05
B*y»um ,"<: < r v ,::j ' :'< v' ;CV'VA" r. 2706.08 ;;.--Vf :HM*00 .; &!'):* 1J&07. fo?tis>^~*W&* "•• *':
Arechlort248 6.24E-08 . 9.6E+00 S.OE-05 S.OE-OS
'•'/'.•••'•'•: :--: '< • ••• -• '•'' ;-"::v:v'..'.-. •.•,;;.:-r-:.'X' ';,'>.:.'•'*•. ,'•.>.:' J^r'.^^^^';^'';! «;' .
Arsenic 7.12E-07 1.8E+00 1.2E-OS
Arador-1248 '-'-i • ..•.•.'•'.'•'•:v>.::.?;.' -.S.V;' . 1.S7&Oa.'|V..;'^"i.'7.7E»00 :-^W ^iTE-iW'iv' s^i'fe ,.:.;.
Banzo(a)pynna ' •• •'•':'.')•.' .i;"-nnr' '' 2.00E-08-j;:!:ii;.7.3E*oo ';%ii '"i.8E4)7! '-"."i.'Vi'i.V'-'r ''•
VtnytchtorkJe • ' - '•:':--^'-- •' > 1.00E«07 r' \. 1.0E*00 ;"' ••.^1.9E-08^ .'<..'•:• W*"1 ' -
BerytJum 4.10E-08 4.3E+00 1.8E-07 1.3E-05
Arsenic .. . •, ....... , . 1 .24E-08 ,, , 1.9E*OO 2.3E-08 . . >
Arodor-1248 S.4SE-OS «D.eE*00 S.2E-OS
••-.- . • ' . ••'.'-.•-:/ •.•'..•.'•-•. :V;.'^-lmV'- •Vf.-.-.'OiSv^.-r.-iV,/: jjjg^, •;
Artante . 3.70E4M 1.8E»00 6.5E-08
Arodor-l24» • . "Vj,.-"- :'•! ••;;;-1.ME-08-Vi??l^77EtOO^^°'!/;;a4E-0«v:''^;'*^-;^ -v'' '
Ba«o(a)pyrene ' :-•':«•; -^ • - ; .:9.4064W!*-;t ;" -;HA - !(-.''-'-. .'••-..• ..•:.• f . +'-:'l' ' '
Vmytdriorlda 3.00E-08 " 1.9E*OO ,. : > • 6.BE-OB . • 2.1E-07
Arsenic 2.10E-08 1.9E+00 40E-08
Arodor-1248 V : 4.98E-08 98E»00 . 4.8E-OS
TrtcMoreeBMna . • • 2.20E-06 1.1E-02 . 2.SE-08
Vinyl CWorlde 1.29E-07 1.9E»00 24E-07 4.8E-05
v Receptor
0.0
0.0
30-M-96 02:38 PM
NW_8(WtWBJ All
-------
Richardsol
Road Landfill Site
• TABLE 7 cont
SUMMARY OF CARCINOGENIC RISKS
Currant
AduR Resident
•
Future North ATM
AduR Resident
Current Chid
Resident
Future North Area
ChMResklant
(ngesltanof
Spring Water
DermatConlact
wtti Spring Water
Inhalation Vapors whftt
Showering
Water
Ingestion of North ATM
Ground Water
Ingestion Of
Spring Water
DarmalConlacl '
with Spring Water '
MiaMton Vapors while ,
Showering
Water
digestion of North Area
Ground Water
• - •,-.-. .' ._•.•.•(•• ^w;. Chw>te Oaty.,.. .Slope ..:..,.,.... .• .,, . .. .. ... Receptor
'" .""-' '!-; '- ':^ir^:i(^***»''-'$S Facto'; ;:^^C«iwrj[^::-.P«»*»*y. ;...c«noar'-
Compound1 " ' • ••' •:••', •••• •'; ' (moAiKlay) ' v (moAiHJav) '• .^Rltk'^'V J' Total •' Risk
TrteNoroelhane . .••':... .9.8E4M ... 1.1E-02 . , 0.4E-08 6A&Q6
TrtcMotoelhane .. •, 1.BE-05, .1.1E-02 , .'.,, ZOE-07 2.0E-07
TrlcHoroethane ,. .,,. . 2.0E-03 , e.OE-03 ;1^E-05 1.2E-OS
TtUacntorbethene 7.0E-05 • 6.2E-02 3.4E-06
Afodor1240 •' •••""•i'1i •'; ,V' O.OE*00 • "',7.76*00 i i" 2. IE-OS 4 •••••
Arsenic 3.0E-05 1.5E+00 4.2E-05
TricMoroattMne , 3.4E-04 1.1E-02 3.7E-Oe 3.7E-06
- •'' • -.- ••..,-. ':•.__'•. -;-.!.!'•- • •; -r.F'i-?' - ••• •'•.•)
. .•'• •-•'-: • •• • -.":••.•'; .-;-i.: ;•;••..••••!.' v'' ' - ' • •'• ' '^.-^.v; ;?-''"
TricMaroethane > 2.3E-03 8.0E-03 1.4E-OS 1.4E-OS
x- '' ' '
Tebachtoreelhane . 3.6E-OS . 6.2E-02 ., 2.0E-O6
Arodor1248 2.0E-06 7.7E»00 1.2E-OS
AnertC . 1.6E-05 1.6E»00 ' 2.5E-05
Trtchkxoethene 1 9E-03 ' 1.1E-02 2.0E-OS 5 9E-05
1.9E-OS
1.0E-04
1.BE-OS
S.9E-OS
NOTES: 1. A Hazard Index lass than one to considered to be acceptable to USEPA wtth reipecl to potential eaidnogente ettocU.
30-.M-9807MPM
NW_604t.WB2 AR
-------
Richardson Hilt Road Landfill Site
TABLES
SUMMARY OF NON-CARCINOGENIC RISKS
R-iiiSillt
UufUUUUUUli
tAfrwfcaW
'
Recrealor
. •. *J\$jj#V;fX ifc ,' •'; V-'-.' *$$' .-' V.j' •
Dermal Contact
wtth Subsurface See*
Incidental Ingeston of '
Surface Sots
Dermal Contact win
Surface Sees
Incidental tngestfon of
Sedknents • South Pond
Dermal Contact
with Sediments - South Pond <
Incidental Inpestionof '
Surface Water - South Pond
Dermal Contact
WUh Surface
Water -South Pond
i .
(
«$# ;M$l.r :; ;^X^^^^^^|SsTS ,^7^Haiard-^>^P«h«aV: / .:
i^uicraaroBinenB ^^ ^ _3.ouc.iw ^ £oE45 "; ••"-' ; 17E»01 *V i' (,< ' '-ji'iV
Beiylum . 1.90E-08 5.0E-03 3.8E-04
Uanganese " . ' 1.36E-03 " 2.3E-02 S.BE-02
ArodOr-1248 3.B7E-04 1.6E-05 2.5E+01 25
)i. .!•<•• <• .• . . •• '.rM • '• • •' • ; : . i '»!:•- '-iff J-l-..!" ..• ".'.i/yin*' -V ' •«• ••• >.' • , • .'
Afochlor1248 ' . 1.76E-05 ' ?-°E-05 8.8E-01
Manganese J '-.'•>. '•<: '':"'-''-£$?*\&*^'&AlM6M'-$j-'&'l&&^
Arochtor1248 8.1 IE-OS "2.0E-05 3.8E«00
•« W-KihtfWi* * •WW'^'flPit- ^Ji^ir'^Av^^^^^ilfiift^i^'^M! isbj ;V
Arsenic 8.31 E-08 30E-04 2.8E-02
AroctoM24a ^•'••;^^>>:HfJJ^ft'4;-,;.^;^i1.a3EH»-»frt''iVa.OEHJ5
Benzo(a)pyrene . 2.40E-07 C*
Beryllum'.-v..- •',.-••• V^V'^UIiVr'ViUJO&OT^v^
Manganese 8.7BE-O4 2.3E-02 3.0E-02
Vinyl Chloride -.- " • ',:.•• :"•.•:• :^'- 1.10E-07 ::'v:;,4"C':^ ••••i,;--«si«,v.y]..;.-./ j. . 0.97 -
Arsenic 1.4SE-05 ' 3 OE-04 a.OE-02
Arodor-i248 <'i'. !k'v\' .;:\^'fy':?f)tf If^"' e.38E-<»8i^iW2.0E-o8 :l^ift4.6Efob Vlfiff^rP-.''^ '^ '?•'
U-Ofcttoroelhene (tola!) v. 8.93E-06 9.0E-03 7.7E-04
da-1,2-OtcMorofthena r: v^vl^i'^'i''.; =,1.096-08 -^'>WlJE-02^ V^1.1E-04 $$* '•'•Mfffir -^ •>
Arsenic 4.30E-07 3.0E-04 1.4E-03
PQB/Arodor.t248 • ••..••$$%>;?•* •'(.'• 1.40E<7 -'U>.{2.0E4)5 i "^>;:'7.1E-03 ".v ;'.': .."<• •'••'
Manganese . 1.43E-04 2.3E-02 8.2E-03
WriibvnnMthafM fltUthvlMM ehbvfciat • . S IWF4)7 ( a :l ' • OP41? •• ' ^ • ASEJM*' •' '. . :i- .
Vinyl Chloride -, • •' • ' •*• '• • •'! '8.00E-08' ••.'-•;. .•••"•C*-.i;''V;">!^-'' .''r-'f. • ••^•.'6.02 v'
1.2-Otchtaroelhena 3.45E-06 C'
Arsenic 2.80E-07 3 OE-04 1.0E-03
PCB/Aroctor-1248 ••-'>'t'--'s'-*:*-W •"•>' e.7BE-08'.V-^;'t;'.XOE-05-''''i4'^)3.aE+Op^-:' "'r •' • ••
Manganese 1.68E-04 2.3E-02 1.8E-01
Vinyl Chlortde • 1.SOE-OB C* ,. 3.81
v Receptor
'^.Hazard ,
-,-:.'' -Index ; •,
52
14
• Evaluated based on carcinogenic eflects.
30-JU-B6 02:37 PU
NW_60«I.WB2 AH
-------
Richardson
oad Landfill Site
TABLEScont
SUMMARY OF NON-CARCINOGENIC RISKS
.; w\&>.m§
Receptor 'M>{| 'V
Current Adutt.
Resident
Future Norm Area
Adutt Resident
Current CMd
KOSMMlV
Future Norm AIM
Cltfd Resident
^'?%f:;! '•:••• ••i'i-':-!1:: ;V
Pathway •••'••<>. .v •;'. - •<
IngesUonof
Spring water
Dermal Contact with
spring water
MiaUional Vapors whie
CtuMMdno
mgesuon of Norm ATM
GraundWMer
IngMMonof
Spring wtier
OtfiMlCorHMlwilh
Spring WMv
totaUkmof VaponwMh
onuvwiiy
mgesiion or Norm Area
Ground W»tor
, unroncDany . Deference , . , ...,,,.,.
' ••'K'-i,v,,r> v:.V-;r'.'.V ^!.y*>:^v'lntak•:•;?^,f,;OoM(Rro)1'^lrto^rt .:,-V Irtm^ay^:1 ;
Compound "' ' (mg/lig-day) (mgAoxlay) •'• Quotient Total. ••'•:•.
1.1.1-Trichloroethane 6.48E-OS MA
Trtchloreement iV:=, '- ;: . _•:::.•.•'::,-. •!; .•i.eOE-oa-VvvJ^B.OE^W'iilH-^S.BE-br1.. \'^ \''<^>'
Naphthalene 1.14E-04 4.0E-02 2.7E-03 029
f.l.l'TitchtonMlnam ,.. .. -,-.. , 1.81E-06 NA, >,,,..:,.
Naphnatona '.' ;.;i . ';- '"' ".'• '• '.'; '; '. 1.4a&05;v'Xrt': 4.0E4«i:^f''?.V4.1E-04'. •,' V.'-..'1 o.or X=
1.1.1-TriehloRMlhaM 1.67E-04 NA
IIKMOnMOMM i .. .--i. ' '•• :•-•."..• O-Bufc-m , «.-..- i NA ' ;, . ;•;»':• .v 'p'.,1.. •, . . • • .',!•.»• - .•
Naphnatom 375E-04 4.0E-02 0.4E-03 0.01
leracnuroetnene . i.vzb-w , i.nt-oz i.st-oz
Arodor-1248 1.80E-04 1.0E-02 1.8E-02
AfMnto • 8.22E-05 J.OEXM 2.7E-01
1.1.1-Trientoroemane . 1J8E-03 NA , ;. . . , ,
Naphmtten* 2ME-04 r 4.0E-02 8.4E-03 0.67
1.1.1-Trichtoroethane 4.05E-08 NA
NapMhatona 3.29E-05 4.0E-02 9.1E-04 0.02
1.1.1-Triehtoroethana ^.i.,, S.7SE-04 NA • ,
incnoroeinerte • 2./oc-oz NA
Naphthaline ' USE-OS :' 4.0E-02 • 4.4E-02 0.04
letracnoroeinene 4.aot-O4 i.ot-oz . 4.st-o2
Arodor-1248 2.00E-05 ' 2.0E-05 9.3E-02
Anente 1 90E-O4 3.0E-04 8.4E-01
Receptor
Hazard
Index
-
0.3
0.1
• Evaluated based ori carcinogenic effects. •
NA-Not Available
30-M-0S 02:37 PU *
NW.6Mt.WB2 All
-------
Richardson Hill Road Landfill Site
. TABLES
EPA and NEW YORK STATE MAXIMUM CONTAMINANT LIMITS
Compound
Arodor 1248
1.1,1-Trichloroethane
1,1-Dichloroethane
1,1-Dichloroethene
1 ,2-Dichtoroethene(tetal)
Acetone
Benzene
Benzyl Alcohol
Bromodichloromethane
Chtorebenzene
Chloroethane
Chloroform
Dlchlorotnethane
Ethylbenzene •
Naphthalene
Toluene
Tetrechloroethene
Trichtoroethane
w * ._• ..
T ncruoroeoiBne
Vinyl chloride
Xytene(total) ,
Butylbenzyl phtnalato
DMvbutyl phthalato
Diethytphthalata
bi8(2-EttiylnexyOohthatate
cis-l ,2-Olchtoroethene
d»-1 ,3-Oichloropropytene
trana-1 ^-Otchloreethene
Aluminum
Antimony
Arsenic
Barium
Beryfflum
Cadmium
Calcium
uhrornium
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Mercury
Nickel
Potassium
Silver
Sodium
Vanadium
Zinc
EPA New York State
ug/1 ug/l
0.5
200
-
7
70
5
«
5
700
1000
5
5
2
/ 10.000
6
70
100
8
50
2000
4
5 .
100
1
5
5
5
5
50
5
100
5
5
100
.
5
50
5
5
5
5
5
50
50
50
50
1000
10
50
•
1000
300
SO
*
300
. 2
50
5000
-------
TMLC 10
•oil cUmup objective* (oa/kg or pt»)
Volatile Organic Contaalnants
• ' •
ContaoiMnt Partition QroundMkter Mlawablt
coefficient Standards/ ' toil cane.
' Koc Criteria CM ppo.
ug/l or ppb. Ca
Acatem . .
tontone
tonnic Acid
2-Outanone
Carbon Oiaulf id*
Carbon Tetrachlarld*
Cfelarobanaana
Cnloroothans
ailorofora) .
OibroMchleroBtthan*
1.2-OlcMorobonzeno
1,3-Olcalorobonien* .'
1,4*0ldilorobofttono
1.1-ftlchloroothano.
1.2-Olcblorottlttne
1,1-Oichlorocthem
1.3-dicMeropr opens
Cthytbanuna
113 FreonC1.1,2 Trldiloro-
1,2,2 Trifluoroothana)
Mathylana chloride
4*Nethyl*2*Pontenono . .
Tetrachloroethone
1,1,1-TrUMoroethane
1,1,2,2-Tetrachleroethane
1.2.3-triehloreprepana
1,2.4-Tridilorobonxeno .
Teluana
Trichloroethono
Vinyl chlorido
lylene*
2.2 • SO 0.0011
O 0.7 ' O.OOOi
34» SO 0.027.
4.5* SO 0.005
S4» SO 0.027
110* S , OvOOik
330 5 0.017
37* SO 0.01*
31 7 0.003
•/* 90 «>»
1,700 4.7 O.OTf
310 •
1.708
30
14
AS
99
SY
1.100
1.230-
21
W-
277
132
111
M
«70»
300
12* •
sr
24*
0.01SS
o.oe
o.ooa
0.001
0.004
0.003
0.003
o.oss
. 0.060
0.001
0 0.01
0.014
0.007*
0.00*
0.0034
0.034
0.01S
0.007
0.0012
0.012
b •• USK»A MMlth taMd
Sail Claanv« (R»)
objactlv** to
•rotact GU Carcinogan* Syvtwle
Quality (ppa) Toxicant*
0.11
0.06
2.7
0.3
2.7
0.6
1.7.
l.f
0.30
•/»
7.9
1.SS
B.S
0.2
0.1
0.4
0.3
0.3
s.s
6.0
0.1
1.0
1.4
0.7*
' 0.6
0.34
3.4
1.5.
0.70
0.12 -
1.2
•/A
24
•/A
•/A
•/A
S.4
•/A
H/A
114
I/A-
•/A
•/A
•/A
K/A
7.7
11
•/A
•/A
. «/A
•/A
. 93
•/A
14
•/A
33
•VA
•/A
•/A
64
•/A
•7A
•,000
•/A
.» 300.000
4.000 .
•.000
60
2.000
•/A
too
•/A
•/A
•/A
•7A
•/A
•VA
700
2.000
•/A
' 1,000
200,000
s.ooo
.•/A
•. .MO
7.000
•/A
M
•/A
20.000
- VA
•/A
. 200.000
•*•
IK. tall
nu. cinup Objc
of 100 Is wed at per TAON ftOtt .
•~ A* per TAON K046. Total VOC* < 10 ppau
note: toll eleenup abjective* or* developed for toil organic carbon content (f) of It .
and should b* adjusted for the actual soil organic carbon content If It ie known.
-------
S«B<
TAIU 10
Cloon* Objectives UB/kg or
Volet Ue Ortenfc ContOMinente
CentoBlnent *ertltlon
coefficient
Koe • .
AcoMphthene
Aeenephthylene
Aniline
Antfcrocene
Mnxotojontni ecene
6onse<*)pyrene
Berao(b)fluoronttMne
Bonso<»,h,l)perylene ;
• ^M»f it! ft I M*>OMh4l4^M»A
•WVOC K) f i UBnVitlMnv
M*«-et»iy the*yl >phth»Ute
•vtrlbonzrtphtfctete
Chryeone
4-Oiloroenlline
4-ttlore-3-eet»rytphenol
2-Oilorophenol
nfttOMIta fl eTOMl
PtaViXiTfUrVl
4,400
2.054-
13.8
14,000
1,380.000
5.500,000'
550,000
1.600,000
CCA MMI
990, Owl
8,704*
2.430 ;
- 208.000
43 •**
47
15*
1,230*'
Oibenxo(t,h)onthrecone 33.000.000
3,3'-01eMeroben*Jdlne
2.4-Bpyrene
liophorone
2-*Bthylnephtlielene>
2-NetfcYlphenal
4-flethytphenel
taphtftelene
nitrobenzene 1
2-»ltroenUlne
2-Hltrophonal
4'Dttrophenot '
3-11 trooni line
PfJflt KA I OPflplWnOl
wwiCnrfnt
**noi
BUO*^MBA
FJT? •§>•
2.4,5-TrUhloronhenol
•/A
380
38
i«e«
142
40
142*.
2,344*
3»,000
7,300
3.908
1.400.081
88J1*
727» *
a
• ir
\.>^«
*^-S*
«J^- M
•^•%.. 14
45
21
93
1.022
4.345*
27
13,295*
89*
treundwotir
ttendordi/
"Criterle CM
uo/t or ppb.
20
20
5
SO
0.002
0.002(10)
0.002
S
Olttf9
• VwC
so
50
.0.002
•5
5 ' -
50
. S
50
< «/A
1
S
S
50
50
50
SO
so
so
0.35
0.082
50 •
SO
5
50
10
S
5
S
. S
S
1
SO
' 1
so
1
0
AlloMoble
Soil cone.
Cs
0.9
0.41
0.001
7.00
0.03
0.110
0.011
8.0
On«« ,
•^•1
4.35
1.215
0.004
0.0022
0.0024
0.008
0.042
1,450
•/A
0.004
0.002
0.01
0.071.
0.020
0.081
1.2
19
3.3
o.ou
0.032
0.044
0.344
0.001
0.009
0.130
0.002
0.0043
0.0033
0.001
0.005
. 0.01
2.28
0.0063
4.45
0.601
b *• UKM Hoolttl Booed
Soil Cleonve (ppe)
abjective* to
Protect CU CArelnoBeno Syoteaic
Quell ty (ppo) To*leoj«n
90.0
41.0
0.1
700.0
3.0
11.0
1.1 -
800
If
• 1
435.6
122.0
».4
0.22
0.24
0.8
4.2
145,000
•/A
0.4
0.2
1.0
7.1
2.6
8.1
120.0
1900.0
350.0
1.4
3.2
4.40
. 34.4
0.1
' 0.9
13.0
0.2
0.43
0.33
0.1
0.5
1.0
220.0
.0.63
445.0
0.1
»/A
•/A
123 -
*/A
0.224
0.0409
•/A
H/A
M/tt
•/A .
50
•/A
•/A
206
8/A
•/A
•/A
0.0143
•/A
•/A
H/A
1.83
H/A
H/A
H/A
H/A
. H/A
H/A
0.41
H/A :
1.787
•/A
H/A
H/A
H/A . .
I/A
H/A
I/A
H/A •
• I/A
I/A
I/A
. " H/A
H/A
•/A
5,000
I/A
•/A. •.
20,000
H/A
•/A
•/A
H/A
....
0/A
2.000
20,006
•/A
300
•/A
400
H/A
I/A
H/A
266
200
H/A
40,000
80,608
8.086
2.606
3.006
3.600
' 40
H/A
20.066
H/A
. H/A
4,606
366
48
I/A
8/A
H/A
H/A
2.866
H/A
56,666
2.000
8,066
aot
(ppb)
330
330
3»'
330
330
330
330
330
TtA
33O
330
330
• 336
336
336
338
336
330
H/A
330
1,400
330
330
330
330
330
330
330
330
330
330
330
330
330
330
330
1,400
330
1.400
1.400
1.400
330
330
330
330
lee.ioil
Clrut. Objc
(ppe>
50.0"
41.0
0.1
so.or
0.224 or »
0.061 or I
1.1
50.0-
14
.1
50.0*
50.0-
0.4
0.220 or
0.240 or
0.8
6.2
0.014 or
•/A
0.4
0.200 or
1.0
7.1
2.0
8.1
50.0
50.0"
50.0*
0.41
3.2
4.4C
34.4
0.100 or
0.$
13.C
.200 or
.430*
.330 or
.100 01
.SOOo
1.0 or i
50.
0.03 or
SO-
0.
-------
TAIIB 10
tocosMnded soil eltm^ objective* tSftVkg or ppa)
Organic Pesticides / Nerbicidea and rCta
ContMinent Partition
coefficient
toe
Aldrin
alpha -INC .
beta -IMC
delta • SMC
CMordane
2.4-0
4.4'-DOO
4.4' -DOC
4.4--OCT
P ibaruo-P-dl oxins(POO)
2.3,7.8 TCOO
Dleldrin
Endowlfan I
tndosulfan II
Cndosulfan Swlfat*
Entfrin
Indrin keytono '
gaoM • INC (Undone)
OOM • cM order*
Heptachlor
Reptachlor epoxide
Methoxychlor
Nftetane
•arathion
PCI*
Polychlorinatod dibenxo-
furanofPCDf)
Silvex
2.4,5-T
96,000
3,800
3.800
6,600
21.305*
104*
770,000*
440.000*
243.000*
1709800
10.700*.
8.168*
•,031*
10,038*
9.137-
N/A
1.080
140,000
12.000
220
23,637
N/A
760
17.310*
N/A
2,600
ss •
Gr'ounowelei
Standard*/
Criteria Cu
u«/l or ppb.
N0(«0.01)
ND(<0.05)
N0«0.05)
N0(<0.05)
0.1
4.4
W(«0.01)
N0(<0.01)
ND(<0.01)
0.000035 '
ND<<0.01)
0.1 .
0.1
0.1
ND(<0.01)
N/A
N0«0.05)
0.1
N0(<0.01)
N0(«0.01>
35.0
N/A
1.3
0.1
N/A
0.2*
35
a
. Soil cone.
Ca
0.005
0.002
0.002
0.003
0.02
0.005
0.077
0.0440
O.*023
0.000*
0.0010
0.009
0.009
0.01
0.001
/ N/A
0.000*
0.14
0.0010
O.Q002
9.0
N/A
0.012
0.1
N/A
0.007
0.019
b — USCPA Neolth aasod
objectives to
Protect 6V Carcinogens Systeaic
Quality Toxicants
0.3
0.2
0.2
0.3
. 2.0
0.3
7.7
4.4
2.S
0.0*
0.1
0.9
0.9
1.0 .
0.1
N/A
0.0*
14.0
. 0.1
0.02
900
N/A
1.2
10.0
.
N/A
0.7
1.9
0.041
. 0.111 -
3.89-
N/A
0.54
N/A -
2.9
2.1
2.1
N/A
o.ott
N/A
N/A
N/A'
N/A
N/A
5.4
0.54
0.16
0.077
N/A
N/A-
N/A
1.0
1 t
N/A '.
N/A '
N/A
2
«/A
N/A
N/A
. 50
800 •
N/A
N/A
40
.'
N/A
•4
N/A
N/A
N/A
20
N/A
20
5-
40
O.I .
•400
N/A
500
N/A
;
N/A
600
200
oral tec.soit
Clnwp Obje-
(ppb) (pp.)
. 8
8 '
8
a
80
800
16
16
16
.N/A
16
16
16
16
8
N/A
a
80
8
' 8
80
N/A
B
160
N/A
330
330
0.041
L o.:i
3.2
0.3
0.54
0.5
2.9
2.1
2.1
•
N/A
• o.ou
0.9.
.0.9
1.0
0.10
N/A
0.06
0.54'
0.10
0.02
9+m
N/A
1.2
I.OCSurf*
N/A
0.7
1.9
a. A((otM6(e toll Connntratfan O • 1 * CM « Coe
b. Soil clama> obJactiM • Ct • Correction factor (»)
N/A la not availobio
Partition eoeffieient Is ealeulatod by ucina th* follawina aquttloni
log toe • -0.55 lot S * 3.44. tfmra S U aoliAUIty In uoter In \
All other tee valuat ar» «Mt«r!aam»l value*.
Correction factor (CM of 100 l» uaod a* par TAOI C404*
As per TAOI «4046, Tent raticide* < 10
Note: Soil el*on« objoetivw are develop^ for Mil organic carbon content (f) of IX (5X for
PCIt a* per »O guidonco docuaont), and should be adjusted far the actual soil organic
Carbon content if.it Is knoun.
-------
APPENDIX m
ADMINISTRATIVE RECORD
INDEX
-------
7/28/97
RICHARDSON HILL ROAD LANDFILL SITE
ADMINISTRATIVE RECORD FILE
INDEX OF DOCUMENTS
1.0 SITE IDENTIFICATION
1.1 Background - RCRA and other Information
P. 100001- Letter to Mr. John Frisco, U.S. EPA, Hazardous
100020 Waste Site Branch, from Mr. Irving L. Bonsel,
P.E., Associate Sanitary Engineer, Region IV, New
York State Department of Environmental Protection,
re: Enclosed Report, April 1, 1983. (Attachment:
Report: Investigation and Removal of Contaminated
Soil at the Hill Site. Sidney. New Yorkr prepared
by Geraghty & Miller, Inc., prepared for the
Bendix Corporation, March 30, 1983.
1.2 Notification/Site Inspection Reports
P. 100021- Report: Potential Hazardous Waste Site; Site
100033 Inspection Reportr Richardson Hill Road Landfill,
prepared by Mr. Walter E. Demick, June 20, 1984.
1.4 Site Investigation Reports
P. 100034- Report: Richardson Hill Road landfill. TDD 02-
. .1.00.059 .8Q^l-27Ar .Draft Final .Reportr prepared.by. Fred .C.
Hart Associates, Inc., prepared for the U.S. EPA,
Region II, March 12, 1982.
P. 100060- Hazardous Ranking System Package, reviewer
100215 Mr. Sui Leong, prepared for U.S. EPA, July 17,
1985.
3.0 REMEDIAL INVESTIGATION
3.3 Work Plans
P. 300001- Report: Draft Site Operations Planf Richardson
300272 Hill Road Landfill Site. Remedial Investigation.
prepared by O'Brien and Gere Engineers, Inc.,
prepared for Amphenol Corporation, Sidney, New
York, October, 1987.
-------
P. 300273-
300380
Report:
Road Landfill
Health and Safety Plan Richardson Hill
Site,. Remedial Investigation.
P. 300381-
300422
prepared by O'Brien and Gere Engineers, Inc.,
prepared for Amphenol Corporation, Sidney, New
York, July, 1988.
Report: Human Health Risk Assessment,. Richardson
Hi).l Road Municipal Landfill Site. Work Planf
prepared by O'Brien and Gere Engineers, Inc.,
prepared for Amphenol Corporation, Sidney, New
York, October 1993.
3.4 Remedial Investigation Reports
P. 300423-
300461
P. 300462-
300587
P. 300588-
300801
P. 300802-
300954
P. 300955-
301376
P. 301377-
301682
Report: Richardson Hill Road Water Supply
System. Amphenol Corporation Bendix Connector
Operations,. Sidneyr New Yorkr prepared by O'Brien
and Gere Engineers, Inc., August, 1987.
Report: interim Technical Memorandum — Phase I.
Field Investigations,. Richardson Hill Road
Municipal Landfill Site, prepared by O'Brien and
Gere Engineers, Inc., prepared for Amphenol
Corporation, Sidney, New York, May 1989
Report: Interim Technical Memorandum — Phase II,
Field Investigations,. Richardson Hill Road
Municipal Landfill Site, prepared by O'Brien
and Gere Engineers, Inc., prepared for Amphenol
Corporation, Sidney, New York, June 1991
Report: Laboratory Data Report. Richardson Hill
Road Municipal Landfill Siter prepared by O'Brien
•and Gere Laboratories:Inc.,.prepared.for.Amphenol
Corporation, Sidney, New York, February 25, 1992.
Report: Unilateral Administrative Order (UAO).
Index No. TT-CERCIA-93-0217. Richardson Hill Road
Municipal Landfill Site, prepared by O'Brien
and Gere Engineers, Inc., prepared for Amphenol
Corporation, Sidney, New York, November 1994.
Report: Administrative Order on Consent (AOC).
Index No. IT-CERCLA-93-214. Whole House Treatment
System Installation, prepared by O'Brien and Gere
Engineers, Inc., prepared for Amphenol
Corporation, Sidney, New York, July 1995.
-------
P. 301683- Report: Remedial Investigation Report.
301862 Richardson Hill Road Municipal Landfill, Sidney,
New York, prepared by O'Brien Engineers, Inc.,
March 1997.
P. 301863-^ Report: Remedial Investigation Report - Tables,.
302038 Richardson Hill Road Municipal Landfill, Sidney,
New York, prepared by O'Brien Engineers, Inc.,
March 1997.
P. 302039- Report: Remedial Investigation Report - Figures
302291 1-44 and Appendices A-E. Richardson Hill Road
Municipal Landfill, Sidney, New York, prepared by
O'Brien Engineers, Inc., March 1997.
P. 302292- Report: Remedial Investigation Report -
303070 Appendices F-Rr Richardson Hill Municipal
Landfill, Sidney, New York, prepared by O'Brien
Engineers, Inc., March 1997.
4.0 FEASIBILITY STUDY
4.3 Feasibility Study Reports
P. 400001- Letter to Reviewer, from Ms. Young S. Chang,
400157 Remedial Project Manager, U.S. EPA,'Region II, re:
Richardson Hill Road Landfill Feasibility Study
Report, June 27, 1997. (Attachments: (1)
Report; Draft Final Report. Feasibility Study.
Richartjson Hill Road Municipal Landfill,, prepared
by O'Brien & Gere Engineers, Inc., prepared for
Amphenol Corporation, Sidney, N.Y., May 1997, and
• (2) Addendum -(w/-attachments}-to the-May 1997
Draft Final Feasibility Study Report, Richardson
Hill Road Landfill Superfund Site, undated).
7.0 ENFORCEMENT
7.1 Enforcement History
P. 700001- Report: Richardson Hill Road Landfill,.
700061 Responsible Party Search,. Revised Final Sitq
Reportf prepared by Mr. Jay B. Eidson and Ms.
Susan O'Rourke, Alliance Technologies Corporation,
prepared for Planning Research Corporation,
September 1987. (NOTE: This document is
CONFIDENTIAL. It is located at the U.S. EPA
Superfund Records Center, 290 Broadway, 18th
Floor, N.Y., N.Y., 10007-1866.)
-------
7.3 Administrative Orders
P.
P.
700062
700077
700078
700102
P. 700103
700122
P. 700123-
700146
Administrative Order on Consent, Index No. II-
CERCLA-70205, In the Matter of Allied Corporation,
as successor to The Bendix Corporation and
Amphenol Corporation, Respondents, July 22, 1987.
(Note: Remedial Investigation/Feasibility Study)
Unilateral Administrative Order (Removal) , Index
No. II-CERCLA-93-0217, In the Matter of the
Richardson Hill Road Landfill Site, Sidney, New
York, Amphenol Corporation and AlliedSignal,
Inc., Respondents, September 30, 1992. (Note:
LNAPL Migration Control)
Unilateral Administrative Order (Removal) , Index
No. II-CERCLA-93-0212, In the Matter of the
Richardson Hill Road Landfill Site, Sidney, New
York, Amphenol Corporation, Respondent, June 21,
1993. (Note: To Deploy and Maintain Absorbent
Booms in South Pond)
Administrative Order on Consent for Removal
Action, Index No. II-CERCLA-93-0214, In the Matter
of the Richardson Hill Road Landfill Site, Sidney,
New York, Amphenol Corporation , and
AlliedSignal, Inc., Respondents, September 22,
1993. (Note: For Residential Water Supply)
10.0 PUBLIC PARTICIPATION
10.9 Proposed Plan
P. 1000001- Plan: Superfund Proposed Plan
1000015 Road Landfill Site.
Richardson Hill
Town of Sidney. Delaware
County f New York-, prepared by U.S. EPA, Region II,
July 1997.
-------
APPENDIX IV
STATE LETTER OF
CONCURRENCE
-------
New York State Department of Environmental Conservation
SO Wolf Road, Albany, New York 12233-7010
SEP 26 1997
John P. Cabill
Commissioner
Mr. Richard Caspe
Director
Emergency & Remedial Response Division
U.S. Environmental Protection Agency
Region 11
290 Broadway
New York, NY 10007-1866
Dear Mr. Caspe:
Post-It* Fax Note
Re: Richardson Hill Road Landfill ID No. 413008
The New York State Department or Environmental Conservation has reviewed the draft Record
of Decision (ROD) for the Richardson Hill Road Landfill site. The Department concurs with the selected
remedy of Alternative 3 A, as it is detailed in the draft ROD for the site.
If you have any questions, please call Mr. Jeffrey McCullough, of my staff, at (518) 457-3976.
Sincerely,.
Director
Division of Environmental Remediation
c: J. Singennan/Y. Chang, USEPA
-------
APPENDIX V
RESPONSIVENESS
SUMMARY
-------
RESPONSIVENESS SUMMARY
Richardson Hill Road Landfill Superfund Site
INTRODUCTION
A responsiveness summary is required by Superfund regulation. It provides a summary
of citizens' comments and concerns received during the public comment period and the
United States Environmental Protection Agency's (EPA's) 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's
and NYSDEC's final decision for selection of a remedial alternative to address the
contamination at the Richardson Hill Road Landfill Site.
SUMMARY OF COMMUNITY RELATIONS ACTIVITIES
The July 1997 Proposed Plan, which identified EPA's and NYSDEC's preferred remedy
and the basis for that preference, and remedial investigation and feasibility study (RI/FS)
reports were made available to the public in the administrative record file at the EPA
Superfund Records Center in the Region II New York City office and at the Sidney
Memorial Public Library. The notice of availability for these documents was published in
the Binghamton Press & Sun Bulletin on July 28,1997. The public comment period was
held from July 28,1997 through August 26,1997 to give interested parties the opportunity
to comment on the Proposed Plan. On August 13,1997, a public meeting was held at the
Sidney Civic Center to inform local officials and interested citizens about the Superfund
process, to review current and planned remedial activities at the site, to receive and
discuss comments on the Proposed Plan, and to respond to questions from area residents
and other interested parties. Approximately 40 people, consisting of local businessmen,
residents, representatives of the media, the potentially responsible parties and their
contractor, and state and local government officials, attended the public meeting.
OVERVIEW
The preferred remedy includes, among other things, excavating/dredging of contaminated
soil and sediment, consolidating, installing a landfill cap, on-site and/or off-site disposal,
constructing a disposal cell, and extracting contaminated groundwater followed by air-
stripping, activated carbon, and discharge to surface water. While the majority of the
public in attendance at the public meeting accepted the preferred remedy, a petition
signed by 18 individuals requesting the complete excavation and off-site disposal of the
8-acre landfill was mailed to EPA.
V-l
-------
SUMMARY OF COMMENTS AND RESPONSES
The following correspondence (see Appendix V-a) was received during the public
comment period:
• Letter to Young S. Chang, dated August 12,1997, from John A. Spizziri, Sr, Esq.,
P.A.
t
• Petition, dated August 25,1997, from Tianaderha Alliance.
• Letter to Young S. Chang, dated July 17, 1997, from Patrick R. McElligott,
Tianaderha Alliance.
• Letter to Young Chang, dated July 22,1997, from Patrick R. McElligott, Tianaderha
Alliance
• Letter to Young S. Chang, dated August 25,1997, from Karen L. Radner, the City
of New York Department of Environmental Protection.
• Letter to Young Chang, dated August 25,1997, from S. K. Sen Gupta, Ph.D.
• E-mail to Young Chang, dated August 26, 1997, from Edward Szymkowiak,
Delaware County E-Mail News.
A summary of the comments contained in the above letters and the comments provided
at the August 13,1997 public meeting, as well as EPA's and NYSDEC's response to those
comments, follows.
Groundwater Remediation
Comment #1: Alternative 3A states that the contaminated overburden and
weathered bedrock groundwater exceeding the federal and state
Maximum Contaminant Levels will be extracted in the North Area by
extraction wells and in the South Area by installation of a
downgradient interceptor trench. Please explain why these two
methods are being used to address the groundwater contamination
in the two different areas of the site.
Response #1: Groundwater contamination in the North Area is restricted to a
localized hot spot, which can be efficiently removed with extraction
wells. In the South Area, because the contaminated groundwater is
in both overburden and bedrock aquifers and because the plume is
much more expansive, a downgradient interceptor trench keyed into
the bedrock will be more effective in capturing the contaminated
V-2
-------
groundwater than a series of extraction wells.
Comment #2:
Response #2:
Are the contaminants in the groundwater in the North Area
attributable to the Sidney Landfill, which is located directly across the
road from the North Area of the Richardson Hill Road Landfill site?
Based upon the presence of two disposal trenches, surface and
subsurface soil contamination, and surface debris in the North Area
and higher concentrations of groundwater contamination in this area
than in a monitoring well between the North Area and the Sidney
Landfill, EPA believes that this groundwater contamination is
attributable to disposal activities in the North Area, not the Sidney
Landfill.
Comment #3:
Response #3:
Site Cleanup
The cleanup of the site should include the elimination of all PCBs,
volatile organic compounds (VOCs), and metal contamination. The
remediation of the site should begin immediately.
To eliminate all of the PCBs, VOCs, and metals at the site would
require the complete excavation and off-site disposal of the 8-acre
landfill's contents. This action, while technically feasible, would
consume a considerable amount of limited off-site disposal facility
capacity at a substantial cost, yet would provide only a marginal
increase in protectiveness, as compared to the selected remedy.
The source containment portion of the selected remedy is consistent
with EPA's Presumptive Remedy for CERCLA Municipal Landfill
S/fes1, which calls for a landfill cap, measures to control landfill
leachate, source area groundwater control to contain the plume, and
institutional controls to supplement engineering controls.
The selected remedy, which includes excavating the contaminated
waste material and NYSDEC's Soil Cleanup Objectives2 in the North
EPA Publication 9203.1-021, SACM Bulletins, Presumptive RemeOos for Municipal Landfill
Sites, April 1992, Vol. 1, No. 1, and February 1993, Vol. 2, No.1, SACM Bulletin Presump-
tive Remedies, August 1992, Vol.1, No. 3. and EPA Directive No. 9355.0-49FS, Presump-
tive Remedy for CERCLA Municipal Landfill Sites, September 1993.
NYSDEC's soil cleanup objectives are specified in NYSDEC Technical Administrative
Guidance Memorandum No. 94-HWR-4046.
V-3
-------
and South Areas (other than the landfill) and excavating and
disposing off-site the heavily-contaminated PCB soils in the area to
be capped (primarily, in the vicinity of the former waste oil disposal
pit), will be fully protective of public health and the environment.
Excavated contaminated soils will either be disposed of in the existing
landfill, a newly constructed on-site disposal cell, or an off-site facility,
depending upon how contaminated the soils are. The selected
remedy also includes capping the landfill and extracting and treating
contaminated groundwater.
It is EPA's intention to remediate the site as quickly as possible.
Once the remedy is selected, EPA will commence negotiations
related to the performance of the remedial design (RD) and
construction of the selected remedy with the potentially responsible
parties (PRPs). Should these negotiations result in a settlement, the
PRPs will perform the RD. If the negotiations do not result in a
settlement, EPA can order the PRPs to undertake the work. After the
RD is completed, remedial construction can begin. It is anticipated
that remedial construction will commence in the summer of 1999 or
the spring of 2000.
Comment #4:
Response #4:
Since EPA does net propose complete excavation of the
contamination, it appears that EPA is more concerned about the
interests of the PRPs (i.e., saving them money) than the interests of
the people of Sidney Center.
Not selecting complete excavation and off-site disposal of the entire
landfill contents is not motivated by a desire to save the PRPs money.
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.
The selected remedy is protective of public health and the
environment, is consistent with landfill closure requirements applied
to municipal landfills in the State of New York, and is consistent with
EPA's Presumptive Remedy for CERCLA Municipal Landfill Sites (a
V-4
-------
landfill cap, measures to control landfill leachate, source area
groundwater control to contain the plume, and institutional controls to
supplement engineering controls).
Comment #5:
Response #5:
What has been done at this site since it was listed on the Superfund
National Priorities List? Why has the RI/FS taken so long to
complete.
The site was listed on the National Priorities List on July 1,1987. On
July 22,1987, EPA entered into an Administrative Order on Consent
(AOC) with the PRPs, requiring them to perform an RI/FS to
determine the nature and extent of the contamination at and
emanating from the site and to identify and evaluate remedial
alternatives.
After property access agreements were obtained in September 1988,
site investigative work commenced. This work, which included the
sampling of on- and off-site soil, surface water, and groundwater was
completed in June 1991. Because the extent of the site-related
groundwater contamination was found to be much more expansive
than originally thought, EPA determined that additional groundwater
monitoring wells needed to be installed and sampled to better
quantify the horizontal and vertical extent of the groundwater
contamination.
In 1993, while the final phase of the Rl was being conducted, a fish
kill in South Pond attributable to the seep of contaminants from the
former waste oil disposal pit prompted EPA to issue an AOC and a
Unilateral Administrative Order (UAO) to the PRPs. The work
performed pursuant to these orders included the excavation of
approximately 2,200 cubic yards of contaminated sediments from
South Pond (the excavated sediments are being temporarily stored
on-site in lined storage cells), the installation of seep interceptor
collection basins upgradient of South Pond, and a sediment trap
weir system at the outlet of South Pond to prevent the downstream
migration of contaminated sediments, and the installation and
maintenance of water supply treatment systems on two contaminated
private wells.
During this effort, the RJ was further delayed because of the need to
reassess the extent of the contamination in light of the release of
contaminants from the former waste oil disposal pit and the
contaminated sediment excavation work. As part of this effort,
V-5
-------
successive rounds of sediment sampling were undertaken to
characterize the downstream migration of site-related contaminants.
This effort was completed in summer of 1996.
Following the completion of an Rl report, risk assessment, and FS
report, EPA prepared a Proposed Plan and released all of these
documents for public review in July 1997.
Comment #6:
Response #6:
A well defined post-closure monitoring plan should be implemented
for both surface and groundwater routes to determine how far the
landfill-derived water quality impacts extend.
A plan for the long-term monitoring of the groundwater, surface water,
fish, and sediments will be prepared as part of the remedial design.
Comment #7:
Response #7:
What is the purpose of the landfill cap and what is involved in
capping the landfill?
Capping the landfill will prevent direct contact with the wastes and
leachate seeps and will eliminate the infiltration of rainwater into the
waste disposal area (which will significantly reduce the leaching of
contaminants to the groundwater).
Before the construction of the landfill cap, test pits will be excavated
to determine the actual limits of the waste disposal area. Following
the consolidation of the excavated/dredged waste materials, soil, and
sediments with PCB concentrations less than 50 mg/kg onto the
existing landfill, the landfill will be regraded and compacted to provide
a stable foundation for placement of the various layers of the cap and
to provide rapid runoff of rainwater. Since decomposing wastes
produce methane gas, a gas-venting layer will be installed. A 40-mil
plastic cap, which will be thermally seamed so that it's a continuous
sheet, will then be installed over the entire waste area. Vents will be
installed through the cap into the gas-venting layer. On top of the
cap, a drainage layer will be installed so that precipitation that does
not run off the surface can drain off the cap. On top of this, six inches
of top soil will be placed to support grass, which will be mowed and
maintained. The grass prevents erosion of the surface of the cap and
draws moisture out of the cap.
V-6
-------
Comment #8:
Response #8:
Public Health Concerns
After the remedial action is completed, who will test the water at the
homes with the water treatment systems?
Under the terms of an AOC with EPA, the PRPs are responsible for
maintaining the water treatment systems on the two private wells.
Since the two impacted private wells with the treatment systems are
only used intermittently (the residents are not present year-round),
the PRPs test the water after the treatment system is turned on after
a period of inactivity. The PRPs will continue to test the water until the
groundwater meets state and federal drinking water standards.
Comment #9:
Response #9:
Is it safe to eat deer and turkey caught on or near the site?
Since deer and turkey eat only vegetation and because they have
large feeding areas, it's unlikely that they would obtain most of their
food from contaminated areas of the landfill. Since the levels of site-
related contaminants in their tissues should be low, EPA believes that
it is safe to eat these wildlife.
Comment #10:
Response #10:
One resident who lives northwest of the site inquired whether there
was any danger of their well becoming contaminated.
The groundwater from this site moves southeast toward South Pond.
Therefore, the subject well would not be contaminated by the site.
Comment #11:
Response #11:
A resident raised a concern about two small ponds on her property.
Since the ponds had never been sampled, on September 11,1997,
the New York State Department of Health (NYSDOH) sampled the
surface water and sediments in the ponds. NYSDOH will inform the
resident of the results of the sampling once they become available
in October 1997. Should contaminated sediments be present, the
need to take remedial action will be evaluated.
Comment #12:
A commenter voiced concern that the Sidney Center reservoir was
dosed twenty-five years ago because of the contamination from the
site.
V-7
-------
Response #12:
According to NYSDOH, the reservoir was closed because of high
bacterial levels, not because of contamination from the site.
Comment #13:
Response #13:
Several residents expressed concern that their drinking wells have
not been sampled on a routine basis.
In 1985, NYSDOH sampled all operating private wells that were
located in the vicinity of the site as a baseline. At that time, two wells
were found to have contamination. Since the two impacted private
wells were only used intermittently (the residents were not present
year-round), they were subsequently provided with bottled water by
the PRPs. In 1993, at EPA's request, the PRPs installed water
treatment systems at both of the homes.
Although private wells in the area were subsequently sampled, but
not on a routine basis, several monitoring wells were installed
upgradient of private wells in the path of the contaminated
groundwater flow to serve as early warning indicators.
In July 1997, NYSDOH discovered contamination in a private well
that was not previously sampled because it was not being utilized. (It
was sampled at this time because the resident wanted to start using
this well.) The PRPs are currently providing bottled water to the
residence and are presently designing a treatment system for the
well.
In response to requests made at the August 13,1997 public meeting,
on September 11, 1997, NYSDOH sampled three residential wells
located near the well where contamination was detected in July.
NYSDOH also sampled one residential well downgradient of the site,
which previously had shown high levels of lead (unrelated to the site).
The water in each of the three wells was found to be within the New
York State's drinking water standards; the downgradient residential
well, however, was contaminated with VOCs3. The PRPs offered
bottled water to the people living in the residence with the
contaminated well. They, however, declined to accept the bottle
water and are presently obtaining water from a neighbor. EPA and
the PRPs are currently assessing what long-term measures should be
taken to provide potable water to this residence.
The sample was analyzed for lead; the laboratory results are not currently available.
V-8
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Comment #14:
Response #14:
Who is liable for the health damage that has already been done to
local residents from exposure to contamination from the site since
1964 (when waste disposal activities commenced at the site)? The
remediation of the site should provide full coverage for health
problems relating to exposure to site contaminants.
The purpose of Superfund actions is to protect public health and the
environment from current and future exposure to hazardous
substances. There is no provision in the Superfund statute for
providing monetary compensation for health problems relating to past
exposure to site contaminants.
NYSDOH has indicated that they looked for cancer clusters and
unusual health problems in this area and did not find any. There are,
however, a few residents that were exposed to site-related
groundwater contamination before they were provided with bottled
water and treatment units were installed on their wells. Residents
who were exposed to site-related VOCs in their drinking water will be
considered for inclusion in NYSDOH's VOC Registry. Residents of
eligible households will be contacted by NYSDOH to obtain detailed
information on water use and health history.
Comment #15:
Response #15:
Property-Related Concerns
The remediation of the site should provide for compensation of
homeowners for property value losses.
There is no provision in the Superfund statute for providing
compensation for loss of property value. Once the site is remediated,
any property value losses should be minimized.
Comment #16:
Response #16:
Federal Emergency Management Agency (FEMA) funding should be
utilized to buy out the Richardson Hill Road area landowners wishing
to sell their land.
For FEMA relocation funds to be utilized, there must be an
unacceptable heath threat posed to the residents if they continue to
live in their homes. With the provision of bottled water and the
installation and maintenance of water treatment systems on
contaminated private wells, area residents are not at risk by
continuing to live in their homes, since exposure to the contaminated
groundwater has been eliminated. Therefore, it would not be
V-9
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appropriate to use FEMA monies to buy Richardson Hill Road area
properties.
Comment #17:
Response #17:
Once the work is complete at the site, will the residents get a
certificate saying the whole area around us is clean so that they can
sell their land?
The groundwater remediation portion of the work may take 30 or more
years to complete. However, once the landfill has been capped and
the groundwater extraction and treatment systems are in place, upon
request, EPA can issue a letter indicating that the source control
measures in combination with the groundwater remedy and
institutional controls (related to the placement of restrictions on the
installation and use of groundwater wells at the site) are protective of
public health and the environment.
Comment #18:
Response #18:
Extent of Contamination
How deep is the soil contamination?
The deepest soil contamination was found at approximately 15 feet
deep.
Comment #19:
Response #19:
What is the estimated total volume if all contaminated areas,
including the landfill were excavated? What is the total volume of the
medium to high range contamination (PCB contamination of 50 mg/kg
and over)? What is the estimated cleanup cost to excavate all
contaminated areas (including the landfill) and take it off-site?
The rough estimated volume of excavating all contaminated areas,
including the landfill, is 155,700 cubic yards. Approximately 9,200
truck loads would be required to transport the excavated materials
off-site. For just the medium and high range PCB-contaminated soils,
the total estimated volume is 7,200 cubic yards (approximately 425
truck loads).
The estimated cost for excavating all contaminated areas is $55
million. Adding in the cost of groundwater extraction and treatment,
the estimated present-worth cost for this remedy would be $61
million.
V-10
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Comment #20:
Response #20:
Drums were present on the site. Weren't hazardous substances
disposed of at the site in the drums?
There is no indication that drums were buried at the site and no
drums related to hazardous waste disposal activities were found on
the site. During the Rl and the removal actions, drums were used to
temporarily store monitoring well soil cuttings, development water,
spill absorbent pads and booms, glassware, and personal protective
equipment worn by on-site workers. After the completion of the Rl,
these drums were taken off-site and disposed of properly.
Comment #21:
Response #21:
What will be done with the former waste oil disposal pit that is located
on the landfill?
Contaminated oils were disposed of in the 25 ft. wide by 105 ft. long
by 14 ft. deep former waste oil disposal pit located on the landfill.
Samples collected from the former waste oil disposal pit in 1990
indicated significant levels of PCBs. After contaminated oils from
the former waste oil disposal pit seeped out and contaminated South
Pond sediments (requiring the excavation of a significant volume of
contaminated sediments), samples collected in the former waste oil
disposal pit showed a substantial reduction in contaminant levels.
Since it appears that the bulk of the contents of the former waste oil
disposal pit have seeped out, it will be capped with the rest of the
landfill. However, prior to capping, any soils with PCB concentrations
which equal or exceed 500 mg/kg in this area (i.e., those soils which
pose a principal threat) will be excavated and sent off-site for
treatment/disposal.
V-11
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•1
APPENDIX V-a
RESPONSIVENESS
SUMMARY
Letters Submitted During the Public Comment Period
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LAW OFFICES OF John A. Spizziri, Sn, Esq. P. A.
"A Professional Corporation"
Site
August 12,1997
Young S. Chang, Project Manager
Central New York Remediation Sec.
Emergency and Remedial Response Div
U. S. Environmental Protection Agency
290 Broadway, 20th Floor .
New York, NY 10007-1866
RE: Richardson Hill Road
Dear Mr. Chang:
I am a property owner in Sidney Center, New York on Richardson H31
Road and directly affected by the Superfund Proposed Plan for the
Richardson Hfll Road Landfill She.
At the outset I wish to correct certain misinformation contained in your she
background description with specific reference to 'the she history. The she
history indicates *K** in "1969 and 1970 the properties ^ompruring the-
North Area were sold to John Spizziri, Jr.. In 1972 these properties were
transferred to- John Spizziri, Sr." Please note that this is inco^ect In 1969
said igti^t *n^ premises with my former spouse w ^ddra. S.
Spizziri. In 1972 these properties were conveyed by Deed, signed by both
she and I to mysdf and then new spouse. I thuik this important to the she
history tuat this be rectified in your records, if you wifl refer to the Deeds
of Conveyance you will note there is no reference to a John Spizziri, Jr. in
the 1969 Deed whatsoever.
With respect to the balance of the remedial investigation summary, I am
unfortunately unable to attend the hearing on August 13, 1997 in the .
Sidney Civic Center in Sidney, New York since I am a resident of New
Jersey and as a practicing attorney, will be engaged in Court on the 13th
thereby precluding me from attending. However I wish to make th«
following comments:
..J. .»,,.,j»ir-.^
'(201) 891V
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Page 2
August 12, 1997
Young S. Chang
I have thoroughly read and believe I understand what is contained in the
summary of remedial alternatives. With respect to the preferred
alternative, Alternative 3 A, it states that the contaminated overburden and
weathered bedrock interface groundwater exceeding the federal and state
Maximum Contaminant Levels (MCLs) in the North and South Areas
would be accomplished by the installation of a downgradient interceptor
trench keyed into the top of the bedrock in the South Area and vertical -
overburden and bedrock extraction wells in the North Area. I do not
understand what this means and how this is to be accomplished* since the
Richardson Hjll Road Landfill is south of the north area.
• *
I assume when I read Alternative 2 that the alternative proposed would not
only take care of the contamination in the Richardson Hill Road Landfill
Site, but also in the North as delineated on Figure 1 Site Location Map,
which is my property. In essence what is being proposed here is a remedial
alternative, including not only the Richardson Hill Road Landfill Site,
which is south of my home in the South Area, but also the North Area
which is on my property and north of my home.
I also wish to know whether or not the wetlands impacted by any remedial
activities would be restored in Alternative 3 A as it would be in Alternative
2. ...
I also wish you to respond as to the effect of Alternative 3 A with respect to
the North Area without a remediation plan with respect to the Sidney
Landfill, which is directly across the road from the North Area and which
contaminants seem to leach from and onto my property in the North Area.
Looking forward to a prompt response to these questions.
Very truly yours,
JAS:am
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TIANADERHA ALLIANCE
Young Chang
USEPA
290 Broadway
20th Floor
New York, NY 10007-1866
July 22, 1997 *
re:Richardson Hill
• • .
Dear Ma. Chang: :
I am writing as a follow-up to our 8-21 telephone
conversation. You stated that you believe the residents
of Richardson Hill in Sidney Center voiced support for
the^EPA proposals at the 8-13 meeting in Sidney; Enclosed
please find two newspaper articles, (Binghamton Press &
Sun-Bulletin, and Oneonta Daily Star),which report.on-the
meeting. These articles clearly show that to the contrary,
the EPA has na support from area residents.
It seems that Allied does support your proposal. I
think that it is important for the EPA to distinguish
the difference between local residents and ;Hied. Please
recognize that Allied is looking out for its own interests,
and not for Sidney Center's. And, that Allied does not
speak for our community. •
I have been looking through the 15 volume, 200,006-
page report that the EPA sent to the Sidney Library. I
RR#1 BOX250-D Mount Upton, NY 13809
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-2-
find it curious that there is not a single paragraph, much
less a page,.that voices the very real concerns of the
local residents. What is evident is that the entire dialogue
is between the EPA, DEC, DOH, and Allied.
As we discussed, I do not presently live in Sidney
Center. I did for a decade. My two sons were born there.
They go to school there, and have family and friends in
Sidney Center. I founded the hamlet's historical society,
was president of the school's PTA, and still speak "to their
classes about local history.
Sidney Center was this countries' "western front" at
the time of the Revt>lutionary*"War. Local residents were
involved in the Anti-Rent War in the mid-1800s. They, served
their country in WW1, WW2, and Korea. And, in the Vietnam
War, this tiny hamlet, with a population of under 500, lost
8 sons. And so, while Sidney Center is representative of
every small community, it does have its own, unique history.
'•** . . •
Sidney Center has been a typical farming community.
Some of the families from Richardson Hill have been there
for generations. However, as small farms went out of buishess,
people from NYC, Long Island, and New Jersey bought property
here for summer and retirement homes. This is why there have
been.two distict "neighborhood" groups concerned with the
five toxic waste dump sites on Richardson Hill.
It is unfortunate that, in the past, the two groups did
not enjoy good communication: However, today, they do. They
recognize that they have common interests, and common goals.
They want to have the poison cleaned out of their neighbor-
hood. They do not want to live with PCS, VOC, or other
industrial pollutants in their land, water, or air. They
want their health concerns addressed, not ignored. And they
want to be compensated for the loss in value of theif homes
and properties. .
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-3-
Both groups are convinced that neither Allied nor the
EPA represents their best interests. Hov could they feel
otherwise? How could they trust Allied, when the industry
claims that it stopped dumping on Richardson Hill in 1969,
when they know the industry continued to illegally dump
there until 1974 ?
The EPA uses a "do nothing" policy as a baseline for
\
proposed options, yet fails to consider a total clean-up,
because "it is too expensive." Think about that. Is it
evident why residents are convinced the EPA is representing
Allied, at the expense of the people of Sidney Center?
» • * ' •
At the 8-13 meeting, Richard Weintrap asked about a
document missing from your 15 volume report. But, in a
phone conversation on 8-20, he was told that there was no
record of his request. Can you see why residents are concerned
that their voices are not being heard?
'* • • ' . •
More and more, this inability of government-and buisness
to hear the voices of people such as, the Richardson Hill
f
residents has resulted in our looking for leadership in
other directions. Hence, we are looking to the original
people from this land to represent our interests. The
Onondaga Nation, which is part of the Haudenosaunee, or
Six Nations Iroquois Confederacy, once lived here. Chief
Paul Waterman, who is a Wisdom Keeper on the Grand Council
of Chiefs, advises our alliance of enviromentally concerned
groups along the Susquehanna and Delaware Rivers.
You stated that if we oppose your plan, it will hold- •
up any clean-up for perhaps years. While I am certain you
were saying this out of a shared concern that action needs
to be taken very soon, I hope you can appreciate how from
our position, it sounds like a threat. "Agree with me, or
else," is a type of hold-up in itself.
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-4-
But why hold work up? Indeed/ don't we all agree that
immediate action is needed? Isn't it clear that the.
inexcusable delays have only resulted in the contaminants
doing more extensive damage? •
The only question is, how far do clean-up efforts go?
How diligent are we going to be in insuring this illegal
and life-threatening pollution will be removed?
. • *
From our conversation, I am convinced that you as an
individual are sincere in wanting to understand our concerns
I hope this letter is helpful. I am also enclosing another
article, "In the Name of the Father," which I hope is of
use to you. Let me' know if it is.
Yes, please do come to see us, in a more informal
setting. We would welcome that. .
Sincerely,
Patrick R. McE^ligjott
RR#1 Box 250-D
Mt. Upton, NY 13.809
cc: Chief Paul Waterman
David Gorden
Robert Kennedy, Jr.
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TIANADERHA ALLIANCE
Young S. Chang/ Projest Manager
Central Nev York Remediation Section
Emergency and Remedial Response Division
USEPA
290 Broadway, 20th Floor
Nev York, NY 10007-1866
July 17, 1997
Re; Richardson Hill Dump Site
Dear Ms. Chang:
I am writing in regard to the on-going controversy
concerning the proposed "clean-up* of the Richardson
Rill toxic vaste dump site in Sidney Center, NY. It vas
apparent at the 8-13 meeting in Sidney that none of the
EPA's six options vere acceptable to area residents. Hence,
it is necessary for you to consider Alternative 7, a complete
clean-up of the entire site.
I note that your six options ranged from "do nothing,"
to various partial cleanings. However, your panel said that,
due to cost, a complete clean-up was not being considered.
Still, we strongly believe that Alternative 7 is the
only acceptable option. We have contacted the Natural Resources
Defense Fund for help.Our contacts at this time are David
RR#1 BOX 250-D Mount Upton. NY 13809
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-2-
Gorden from the River Keeper, and Robert Kennedy,Jr.,
from Pace Law School.
We are requesting a copy of 1.10 (pg. 100556), the
Endangerment/Risk Assessments, per the Wildlife Kill
Investigation from Richardson Hill.
Further, I am requesting y9ur estimate of the cost of
Alternative 7, the removal of all PCP and VOC contaminated
soils.
Finally, I am requesting documents concerning the
responsible party,•(Bendix-AlliedrAmphenol), and their
willingness or unwillingness to pay for this clean-up.-
I cannot,stress the importance of the health concerns
of the people residing near the Richardson Hill and related
toxic dump sites in the Sidney area. I find it curious that
this most important component remains unaddressed by the
EPA or NYSDOH. I suggest that you reconsider this as part
of the clean-up. • . • ,
Thank you for your attention to this matter.
Sincerely,
Patrick R. McElligofct
cc: Chief Paul Waterman, Onondaga Nation
David Goren, River Keeper
Robert Kennedy/ Jr., Pace Law School
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JOEL A. Mini, SVP.E. Commiuiomr
PHONE (914) 657-6972
FAX (914) 657-6976
WIUIAM N. STASIUK, P^PhJ).
Dtputy CommiuiofMr
Bureau of Water Supply,
Quality and Protection
August 25,1997
Young S. Chang, Project Manager
Central New York Remediation Section . . "*
Emergency and Remedial Response Division
United States Environmental Protection Agency
290 Broadway, 20* Floor
New York, NY 10007-1866
••
Re: Richardson HJfl Road Landfill
(T) Sidney, Delaware County
NYCDEP Log #3685
Dear Ms. Chang:
Enclosed please find the New York City Department of Environmental Protection's (DEP's)
commention the United States Environmental Protection Agency's (EPA's) proposed cleanup
plan for the rignaifiing contamination located at the Richardson HiD Landfill Federal Superfimd
site located in Sidney, New York. .
Thank you for your consideration of these comments. We look forward to having the opportunity
to comment on the upcoming Remedial Work Plan and associated project specifications, the
Erosion and Sediment Control Plan, in addition to the Stormwater Plan. If you have any
questions, please fed free to contact me at (914) 657-5770. Please keep the Chy ap. ised of any
&QU ul ucvdopmcoxs OK. UD9 nutttcr.
Very truly yours,
Karen L. Radner
Project Manager
cc: Drake/Rider
West/Baxter
rhlJetlet
WOH Engneering Sectksn, P.O. Box 370, Shotan, New York 12481
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TM OIT OP MW Torn DEPMTMENT OP ENvnioimENra.
JO£L A. MELE, WL, P.E Commissiomr
WILLJAM N. STASIUK. P.E.PH.D.
Deputy Commtsskxter
PHOME (914) 657-6972 Bureau of Water Supply,
FAX (914)6574976 Quality and Protection
Richardson Hul Road
Town of Sidney, Delaware County
NYCDEP Comments on Soperfund Proposed Plan
August 25,1997
New York City Department of Environmental Protection (DEP) has reviewed the remedy
described in the July- 1997 Superfund ProposedPlan for the Richardson Hjtt Road Landfill Site, in
addition to attending the August 13, 1997 public information meeting at the Sidney Civic Center.
Herrick Hollow Creek and South Pond, in addition to its downstream, fioodplain are in close
proximity to the Cannonsvflte Reservoir. These three areas have been found to contain both PCB
and VOC contamination. Therefore, DEP's main concern is the ultimate removal, containment,
and remediation of these surface waters and sediments that contribute to the drinking water
supply of New York City. . ' ' .
* ' • . " • ' •
Of the proposed alternatives. OEP agrees that Alternative 3 A, which was also chosen by EPA and
NYSDEC seems to be the preferred alternative, as a remedy for she cleanup/remediation. In
addition, the following should also be implemented as part of those proposed activities outlined in
this Jury 1997 Plan:
. . k ' . - •'•....
• During the above excavation and consolidation efforts of the contanriniitrd waste material
and any soil eareeding TAGM limits from these, areas of concern, including the
excavated/dredged sediments from the South pond and other downstream areas, efforts
should also be taken to install a leachate collection system.
The installation of a reliable leachate collection system, installed within the wastemass
and not necessarily "a shallow system keyed into the top of bedrock" as discussed in the
proposed plan, will further ensure the interception and containment of leachate for proper
off-she disposal in conjunction with the already proposed interceptor trench.
During the construction phase of this plan, all erosion and «**<'"^> control practices
should be developed utilizing the standards and specifications in the "New Yoric
fluidaKnga for Ufbun F.msion anrl Syfinwnt f!ontroln. This Office looks forward tO
commenting on the sediment and erosion control plan for this project DEP staff are
available, upon request, to provide assistance in reviewing the proposed erosion and
sediment control plan or to conduct on-she inspections.
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• Any leachate seeps that are evident, should be addressed by field locating and
documentation by mapping and then remediated by pumping and treating or by the
implementation of another EPA approved technology.
* • ' »
• A well defined post-closure monitoring plan should be implemented for both surface and
groundwater routes to ensure and determine how far the landfill-derived water quality
impacts extend. . - '
WOH Engineering Section, P.O. Box 370, Shokan, New York 12481
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DR. 3. K. Sen Gu
Member of the American Society of
MECHANICAL ENGINEERS
C *t. Box 9*'
Bovina Center, KY 131
•-••$$•:• (607)837-4480
Ms. Young- Chang
Project Manager. US EPA
290 Broadway. FLOOR 20 '. .
New York. New York 10007 ' -• August 23, 1997
RICHARDSON HILL : THE 'LOVE CANAL' OF DELAWARE COUNTY
Dear Ma. Changt , .
Thank you tor your- telephone call of tod-ay. HeVe are my
written comments -following the EPA Public Hearinff» held on
August 13, 1997. Th» 'original' is in mat) „ ! "
• . • . '*•..:?••• •• :- '
' /%-.: -
According to historicaV. information,. many many, years ago
Bendix. Perry She 1 ton's •former employer, mer :> '
Devere Rosa under contract with-th* TOWN OF SIDNKVir Thet-;..,L-'r
toxic material was carted away by Rosa frowBendiwC and • >v^
deposited in the dumps. Although in theory not responsible;
•for dumping. Amohenol.-accepted responsibilty for?.'they . ."
clean-up and according to" available in-formation>.tne^OoeAany:
has always cooperated. They have currently agreedlttv pay -*
$13.9 million -for the 3O year* clean-up prograor. £rddbs«dt bit
the EPA. However, th» EPA progra* i* inherently faulty* Ther
whole idea seems to basically be to dtg- up. soaei jpo.ftuted>'.'.'*•.
earth and dump it on someone ,else-'s> land.9^,. f>;.-•r.-'i^'.^:!—?'* •'>£•""
-• *•$,,: .
On August 22, 1?97/Ed-SzyoKdwia* and
Richardson HfrVr-'arem ah* sook*^tffr TocaJ re«iden1^i|'SlMMf-.
Smith, who wasv 'born ane> brotwh't: up t deal:|V^-to^ d'Sisv-tha.%.
WATER WAS LAST. TESTED ABOUT 3r.YEARS AGOh Wev>«r» &lSO ,to.1 d' :
that the EPA hadf;*J-ways^lragge* its reet.^ and-.6overn«s«i%>: _ '
Agencies aTway* ilooftp to everyone"«1>» ex ceo t the* locaf--' "
resident*. Snith- toJd1 us>- that 2 years' ag».some^ SoVernme«t-'•*:.'
Agency drained » pond on Jtis -land and: deposited* tn*'pal luted
water and earth in plastic sheet* in trenche»^.«-few hundred
yards away, on* th» higher^ stooe* of th» htTl; ove» th« ro«Tl>\
The seeoaq* is *o highly inflammable- tha« S«ith.^feH^ttear«\ of
peopl e 1 ighting the- hitT»io> with* 4. nakvdi torch
through the heavily polluted marshy- bo9S| and*martt»t'«|idJt
undergrowth , *\ V THREE* of us- inspected^ tn^r
The pond had filled up again-and Spitn
•full within about two month*, of the) df«>*fKrai£-
There was. a 'metal dam'» caoouf VagecC^bv^stone
heavily corroded. He-avity poTTuted- 'oily' wateryud. by
migratory birds, was trickl In
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RICHARDSON HILL 'DUMP'
-2-
August.25. 1997
According to Richard Merely..a 30 year long resident.
HIS WATER WAS LAST TESTED ABOUT 6 TO 8.YEARS AGO! Merely
says that property prices have nosedived. He believes that
the "Responsible Parties" should buy out their properties.
Devere Rosa is now deceased: the Town of Sidney and its
retiring Supervisor Walter Johnson don't want to talk about
it: the,EPA is not in the business of buying out properties:
Amphenol's responsibility extends only up to paying for the
clean-up program. A part of the^area is not in the--NYC
Watershed: so NYC will not be interested in buying out
properties in that region. In the Watershed portion. NYC can
NOT buy HOUSES according to the MOA. Some residents even
have objections, on principles, to sel1 ing out to NYC.
Morely is now holding regular meetings of the local
-residents "to realise his goa^i '. ;.
My proposal is that the. Town of- Sidney, Delaware County
Board of Supervisors. Assemblyman Crouch. NYS Senator Cook,
Congressman Boehlert, US Senators Movnihan and D'Amato
should press for the EtJYING OUT OF THE RICHARDSON HILL AREA-
PROPERTIES BY FEMA MONEY. After the clean-up of th* LOVE .
CANAL LAND OF DELAWARE COUNTY, it should be re-sold, with
the current owners having the FIRST OPTIONS to buy back.
Thank vou. , •••/••' ... •'.'-*.
ShvacnasJK. Sen Suota. Ph. D.vjMem. ASME*
HC 65 Box 90C, Boyina Center, NY 13740:: 607-832-4480
*Member of the American Society of Mechanical Engineers
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DELAWARE COUNTY E-MAIL NEWS
cgO67@freenet.buffalo.edu
73 East Front Street
Hancock, NY 13783
607-637-2330
Aug. 26, 1997
Young Chang, Project Manager Also by fax: 212-637-3966
U.S.E.P.A., 29O Broadway, Floor 20 & e-mail:
New York, NY 10007 chang.young@epamail.epa.gov
RE: Richardson Hill Toxic Dump in Delaware Co., NY -.
Dear Ms. Chang: .
Thank you for discussing this matter with me on the telephone.on
Aug. 25, 1997. I wish to file the following two comments.
1) I request that the ,E.P. A,, do everything in its power to insure
that the well of Samuel Smith is tested on a more regular basis,
especially after periods of significant rainfall. Mr. Smith and his
family live immediately south of the site .on Richardson Hill Road.
On Aug. 22, 1997 Mr. Smith showed me the well they use for drinking
water. This well-is about 10 ft. from the roadside drainage ditch
which flows downhill from the dump, site perhaps 200 to 300 yards
above the well. Mr. Smith indicated that his water was tested about
jthree years ago and that he was''told it would be tested every year.
According to Mr. Smith such yearly testing has not occurred.
2) Residents near the dump site whose property values have
fallen due to the .presence of the dump site need to be properly
compensated. I request the E.P.A. to do everything in its power to
provide federal funds to buy but landowners wishing to sell their
land for what it would have been worth if the toxic dump was not
nearby. ' -
Thank you. I hope to hear from you soon.
Sincerely,
Edward Szymkowiak, Editor
DELAWARE COUNTY E-MAIL NEWS
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RECORD OF DECISION FACT SHEET
EPA REGION II
Site:
Site name: Richardson Hill Road Landfill
Site location: Towns of Sidney and Masonville, Delaware County, New York
MRS score: 34.86 on July 17,1985
Listed on the NPL: July 1,1987
EPAID#: NYD980507735
Operable Unit #: 01
Record of Decision:
Date signed: September 30,1997
Selected remedy: Contaminated Soil and Sediment Excavation/ Dredging, Consolidation,
On- and/or Off-Site Disposal, Disposal Cell Construction, Installation of Landfill Cap
consistent with 6 NYCRR Part 360, and Groundwater Extraction (North Area via Extraction
Wells and South Area via an Interceptor Trench) and Treatment
Capital cost: $7,871,000
Construction Completion -16 months
Annual O & M cost - $479,000
Present-worth cost - (7% discount rate for 30 years): $13,864,000
Lead:
Site is enforcement lead - EPA is the lead agency
Primary Contact: Young S. Chang, Project Manager, (212) 637-4253
Secondary Contact: Joel Singerman, Chief, Central New York Remediation Section
Main PRPs: Amphenol Corporation and AlliedSignal, Inc.
Waste:
Waste type: volatile organics, semi-volatile organics, metals, and PCBs
Waste origin: Hazardous waste
Contaminated medium: soil, sediment, groundwater, and surface water
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