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DECLARATION STATEMENT
RECORD OF DECISION AMENDMENT
SITE NAME AND LOCATION
Haviland Complex .
Hyde Park, New York
.'.. '
STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected modification to the
original remedial action for the Haviland -Complex 'site (the Site) ,
.located in Hyde Park, New York. The original remedial action was
selected in the Record of Decision (ROD) issued by the United
States Environmental Protection Agency (EPA) on September 28, 1987.
i
The modification to the original remedy was chosen in accordance
with the requirements of the Comprehensive Environmental Response,
Compensation, and Liability Act of 1980 (CERCLA), as amended by the
Super fund Amendments and Reauthorization Act of 1986 (SARA) , and
the National Oil and Hazardous Substances Pollution Contingency
Plan (NCP). This decision document .explains the fundamental
changes to the remedy previously selected for the Site.
The New York State Department of Environmental Conservation
(NYSDEC) concurs with the modification to the selected remedy. A
letter of concurrence from the NYSDEC is attached to this document
(Appendix 1).
The information supporting this remedial action decision is
contained in the administrative record for the Site. The index for
the administrative record is attached to this document (Appendix
2) .....
ASSESSMENT OF THE SITE
Actual or threatened releases of hazardous substances from the
Site, if not addressed by implementing the response actions
selected.in the September 28, 1987 ROD, as revised by this Record
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of Decision Amendment, may present an imminent and substantial
threat to the public health, welfare, or the environment.
DESCRIPTION OP MODIFICATION TO THE SELECTED REMEDY
t
The modification to the selected remedy addresses the provision of
a public water supply to site residents and the extraction and
treatment of contaminated groundwater within the study area.
*
The major components of the modification to the selected remedy
include: -'.-'
Continued use.of existing whole-house groundwater treatment
- systems on affected residences to prevent exposure to low
level groundwater contamination.
Maintenance of filters and semi-annual monitoring of homes
affected by low level contamination present, in the aquifer
until three consecutive years of sampling indicate that the
well water meets Federal and State drinking water standards.
'., . -
Elimination of the public water supply system portion of the
1987 selected remedy.
Natural attenuation of contaminants in the aquifer to below
Federal and State drinking water standards.
Elimination of the groundwater extraction and treatment
system portion of the 1987 selected remedy.
Implementation of a groundwater monitoring program.
The remaining component of the original remedy as selected in the
September 1987 ROD is not affected by this modification. This
-component is:
Removal and disposal of the contents of four septic
tanks in the study area which represent the source
control portion of the remedy. This action was
completed in 1990.
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EXPLANATION OF FUNDAMENTAL CHANGE
.. . t
This ROD Amendment describes the fundamental changes to the
September 1987 ROD issued by EPA for the Haviland Complex Superfund
Site and concurred on by NYSDEC. -,.-''
The remedy specified in the 1987 ROD included: the removal of the..
source of contamination, i.e., contaminated septic systems
.(completed in 1990) , the remediation of the aquifer through
extraction and treatment of contaminated groundwater.and discharge
to surface water, and the provision of public water to the study
area. The aquifer was to be remediated to Federal and State.
drinking water standards 1
The levels of contamination observed in the aquifer in 1987 have
now diminished to levels near or below Federal and State drinking
water standards in both monitoring wells and affected residential
wells. As a result, the extraction and treatment of groundwater
and the provision of a public water supply system, do not need to
be implemented to ensure the protection of human health and the
environment.
The modified remedy will rely on natural attenuation to reduce
contaminant levels in the groundwater to Federal and State drinking
water standards; modeling indicates these .standards will be
achieved in one to six years. The presently installed whole-house
potable water filtration systems will be maintained until three
consecutive years of semi-annual sampling demonstrates that the
influent (untreated) water is below drinking water standards. The
aquifer will also be monitored to. ensure that no other homes become
impacted by site-related contamination.
DECLARATION STATEMEl^T
this modification to the selected remedy is protective of human
health and the environment, complies with Federal and State
requirements that are legally applicable, or »relevant and
appropriate to the remedial action, and is cost-effective. This
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water standards in both monitoring wells and affected residential
wells. As a result, the extraction and treatment of groundwater
and the provision of a public water supply system, do not need to
be implemented to ensure the protection of human health and the
environment.
The modified remedy will rely on natural attenuation to reduce
contaminant levels, in the groundwater to Federal and State drinking
water standards; modeling indicates these standards will be*
achieved in one to six years. The presently installed whole-house
potable water filtration systems will be maintained until three
consecutive years of semi-annual sampling demonstrates that the
influent (untreated) water is below drinking water standards. The
aquifer will also be monitored to ensure that no other homes become
impacted by site-related contamination.
DECLARATION STATEMENT
This modification to the selected remedy is protective of human
health and the environment, complies with Federal and State
requirements that are legally applicable, or relevant and
appropriate to the remedial action, and is cost-effective. This
modified remedy utilizes permanent solutions and alternative
treatment technologies to the maximum extent practicable for the
Site.
Because the selected remedy will result in hazardous substances
remaining on the Site above health-based levels, a review will be
conducted within five years after commencement of the remedial
action to ensure that the selected remedy continues to provide
adequate protection of human health and the environment.
. s
EPA has determined that its future response at this Site does not
require additional physical construction. Therefore, the site now
qualifies for inclusion on the Construction Completion List.
Jeanne M. Fox
Regional Admin
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TABLE OF CONTENTS
Page
DECISION SUMMARY ,
I. INTRODUCTION. .1
II. HIGHLIGHTS OF COMMUNITY PARTICIPATION 3
" III. REASONS FOR ISSUING THE RECORD OF DECISION AMENDMENTS
IV. SUMMARY OF SITE RISKS 6
V. DESCRIPTION OF REMEDIAL ALTERNATIVES .'. 9
VI. SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES .13
VII. SELECTED REMEDY.. ....:...,, 20
VIII. STATUTORY DETERMINATIONS ....... 20
ATTACHMENTS '
APPENDIX I. STATE LETTER OF CONCURRENCE
APPENDIX II. ADMINISTRATIVE RECORD INDEX
APPENDIX III. RESPONSIVENESS SUMMARY
APPENDIX IV. 1987 RECORD OF DECISION
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RECORD OF DECISION AMENDMENT SUMMARY
Haviland Complex Site
Hyde Park/ New York
I. INTRODUCTION
The 275-acre Haviland Complex site consists of the Haviland Complex
Apartments, the Hyde Park Middle School, the Smith School, the
Haviland Shopping Center, and approximately 35 residences and small
businesses located east of Route 9G in Hyde Park, New York. Hyde
Park has an estimated population of 21,000 people. Approximately
20% of the population are connected to a public sewer system, and
over 50% are served by a public or private water supply system. The
remaining population, including the 35 residences and small
businesses previously mentioned, obtain water from residential
wells. Groundwater . in the study area flows southeasterly and
discharges into Fall Kill Creek. .
The Dutchess County Health Department (DCHD) began to receive
complaints concerning the groundwater quality in the site area in
October 1981. A sampling program and septic system survey of the
Haviland Complex area was initiated by DCHD in December 1981, which
indicated that the Haviland Laundromat and Dry Cleaner and the
Haviland Car Wash septic.systems were failing. Subsequently, the
car wash installed a new septic tank and the laundromat installed
a pre-treatment system and a new tile field to handle its waste-
water. .
In December 1982, the New York State Department of Health (NYSDOH)
began sampling the Haviland area groundwater. The sampling data
indicated that levels of tetrachloroethylene (PCE) and
dichloroethene (DCE) in the septic discharge from the laundromat
exceeded New York State Department of Environmental Conservation
(NYSDEC) discharge standards. As a result, in 1983, the laundromat
was ordered to disconnect the dry cleaning operation from the
septic system and to dispose of all spent dry cleaning fluids at
a permitted disposal facility,. All residents in the area were
advised to use bottled water. Water treatment units were installed
on the wells servicing the Haviland Complex Apartments and the
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laundromat in '1984 and 1985, respectively, to remove organic
contaminants. In February 1989, NYSDEC installed water treatment
systems on homes with well water which exceeded State or Federal
Maximum Contaminant Levels (MCLs), i.e., safe drinking water stan-
dards.
The site was proposed for inclusion on the National Priorities List
(NPL) in October 1984, and placed on the NPL in June 1986. NYSDEC
was designated as the lead agency for the Remedial Investigation
and Feasibility Study (RI/FS).
Based on the results of the RI/FS, a Record of Decision (ROD) was
sighed on September 30, 1987, identifying the following: 1) clean
the contaminated septic systems identified as the source of
contamination; 2) extend public water from the nearby Harbourd
Hills Water District (HHWD) to ensure a potable supply of water to
the residents; on private wells (EPA would enter into an agreement
with the Town of Hyde Park to upgrade this system to meet New York
State drinking water standards); and 3) extract and treat
contaminated groundwater.
The .cleaning of the septic systems, which represented the source
control portion of the selected remedy, was completed by EPA on
November 4, 1990. A sampling survey of the septic systems in the
study area had identified four septic tanks at the Haviland Complex
and the Hyde Park Middle School which were contaminated. These
tanks were cleaned out and the sludges were sent off-site for
treatment and disposal. ,
Since the signing of the ROD, there has been difficulty in agreeing
on the source of the alternate water supply. On numerous
occasions, Town of Hyde Park .officials have requested that EPA
evaluate sources of water other than the HHWD. In its latest
request, the Town proposed that water from the Hyde Park Fire and
Water District (HPFW) be utilized. It is also noted that since the
signing of the ROD, the levels of groundwater contamination as
measured in the monitoring wells have decreased significantly.
Residential well sampling data also indicate that levels of
contaminants entering impacted residential wells are decreasing.
Consequently, EPA and NYSDEC decided to reevaluate the need for an
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alternate supply of public water in the Site study area and the
need for ah active groundwater extraction and treatment system.
II. HIGHLIGHTS OF COMMUNITY PARTICIPATION
The Post-Decision Proposed plan (PDPP) for the Site was released
to the public on August 26, 1996. The PDPP, along with all other
Site-related documents, is available to the public at both the
administrative record and the information repository locations.
A notice to announce the public comment period on the PDPP, the
public meeting to present the PDPP and the availability of the
technical documents at the repositories was published in the
Poughkeepsie Journal on August.24, 1996.
/
The public comment period began on August 24, 1996, and was
scheduled to end on September 23, 1996. However, EPA granted a
request to extend the comment period; the comment period closed on
October 23, 1996. A public meeting was held on September 4, 1996
at the Haviland Middle School located in Hyde Park, New York. The
purpose of the public meeting was to discuss the proposed amendment
to the September 1987 ROD:
The responses .to the comments received.during the public comment
period as well as those expressed verbally at the public meeting,
are summarized in the Responsiveness Summary, . which is an
attachment to this Record of Decision Amendment. . -
This Record of Decision Amendment, presents the selected remedial
action for the contaminated aquifer and contaminated residential
wells at the Site, chosen in accordance with CERCLA as amended by
SARA, and, to the extent practicable, the NCP,140 CFR Part 300.
The decision as made for the Site, is based upon the administrative
record. An index for the administrative record is included as an
attachment to this document. This Record of Decision Amendment
will become a part of the administrative record file.
The administrative record file, containing the information upon
which the modification .to the original remedy is based, is
available at the following locations:
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Hyde Park Free Library
2 Main Street
Hyde Park, NY 12538
914-229-7791
U.S. Environmental Protection Agency
290 Broadway - Records Center
New York, New York 10007-1866
212-637-4308
Hours: Monday - Friday: 9:00 a.m. to 4:30 p.m.
Ill. REASONS FOR ISSUING TEE RECORD OF DECISION AMENDMENT
Site conditions have changed significantly since the issuance of
the 1987 ROD; the sources of contamination have been remediated,
the contaminant levels, in the aquifer and at the impacted
residential wells have decreased dramatically as have the risks
associated with the site contamination. The following summary
explains tihe changed contaminant levels and site risks.
Improvement in groundwater quality
f ,
Based on sampling data obtained from 18 monitoring wells, .the RI
report documented the presence of a low-level groundwater con-
tamination plume, consisting of numerous volatile organic compounds
(VOCs) (e.g., PCE concentrations ranging from 2.0 to 42.0 parts per
billion (ppb)) 'and metals (e.g., lead and chromium at concentra-
tions above drinking water standards). The contaminants were
believed to be emanating from "septic systems connected to the
Hayiland Shopping Center (Laundromat), Haviland Complex Apartments,
and Haviland Middle School. It was determined that the plume
generally migrated from the sources in a south-southeasterly
direction and -discharged into Fall Kill Creek. The RI also
documented that several residential wells in this area were
contaminated with VOCs. . .
Since the RI report was issued, residential and monitoring wells
in the study area have been sampled on numerous occasions, and
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computer modeling of the groundwater regime has also been
conducted. These efforts were conducted to better define the
nature and extent of groundwater contamination, and to quantify the
benefits the groundwater treatment system would provide that would
not be realized if this portion of the remedy were not implemented.
Additional sampling of the RI monitoring wells was conducted by
EPA's contractor, Ebasco Services, in October 1988 and July 1990.
These sampling results were summarized in a March 1991 .report
entitled the \wSummary of Groundwater Investigations." The report
documented the presence of a low-level volatile plume underlying
the Site, flowing tbward the Fall Kill Creek to the southeast.
Localized PCE, PCE-breakdown products, and chlorobenzene plumes
were documented in the southeastern portion of the main plume.
In June and November 1992, EPA's Environmental Response Team sam-
pled the study area monitoring wells to provide a baseline of the
levels of contamination in the aquifer at that time. Low-level
VOCs above MCLs were only observed in MW-24 (8.1 ppb PCE, 6.8 ppb
dichloroethene(DCE))and MW-27B (7.8 ppb DCE), which are located
immediately upgradient and downgradient of the affected homes. The
drinking water standard for each of these contaminants is 5.0 ppb.
Although, chromium was detected above standards in two wells during
the June 1992 sampling event; the November 1992 sampling and
additional results described below indicated that the inorganic
contamination was a natural artifact of the aquifer itself.
Also, in June 1994, a confirmatory round of groundwater sampling
data was collected by Ebasco which confirmed the continued presence
of very low-level VOC concentrations in the shallow aquifer
underlying the Site. All volatile concentrations were close to or
below the New York State MCLs of 5 ppb for PCE, DCE, and
chlorobenzene. These data indicated that the VOCs were still
present but occurred at lower concentrations than what were
observed previously. Levels of all inorganic compounds were either
not detectable or were well below safe drinking water levels. The
spreading of the plume described in the RI/FS and-ROD had not oc-
curred and the plume appears to be naturally attenuating. This
information was documented by Ebasco in its September 1994 report
entitled "Summary of Groundwater Investigations."
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In order to monitor and maintain the effectiveness of the
individual home water treatment units, NYSDEC has contracted for
the sampling of the private potable wells for organic contaminants
semiannually since 1989. NYSDOH reviews and tabulates the data,
and then sends the results to the residents. Analyses of the well
samples have demonstrated. the trend of diminishing organic
contamination.in the aquifer. While maximum concentrations of 79
ppb of PCE, 190 ppb of chlorobenzene, and 27 ppb of DCE, were
measured in some residential wells in 1985, 1983, and 1988,
respectively, the contaminant concentrations observed in all of the
private wells have'diminished to levels near or below MCLs. At the
September 1996 PDPP public meeting, some residents raised concerns
that although residential wells with home water treatment units had
been sampled frequently, other residences in the vicinity of the
site had not been sampled recently. As a result, in October 1996
NYSDOH sampled selected residential potable wells which had not
been sampled in over five years. The results of this sampling
event, which were provided to the residents in November 1996,
revealed that none of their homes had been impacted by
contamination from the Site. Additional sampling of the homes with
water treatment units in January and June of 1997 further supported
the trend of diminishing contaminant levels in the aquifer.
Maximum concentrations from the January 1997 sampling event of
untreated water were 15 ppb of PCE and 12 ppb of chlorobenzene with
no detectable concentrations of DCE or TCE. Results from the June
1997 sampling event showed maximum concentrations of 14 ppb of PCE,
9 ppb of chlorobenzene, 8 ppb of TCE, and 7 ppb DCE. In addition,
Site-related metals contamination has not been observed in any of
the potable wells in the study area.
IV. SUMMARY OF SITE RISKS
During the conduct of the RI/FS, a baseline risk assessment was
conducted to estimate the risks associated with current and future
site conditions. The baseline risk assessment, which was based on
data obtained during the RI, estimated the human health risk which
could result from the contamination at the Site, if no remedial
action were taken. ' A summary of the baseline risk assessment and
a recalculation of the risk using current data is presented below.
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Human Health Risk Assessment
The baseline risk assessment evaluated the health effects which
could result from exposure to .contamination as a result of
ingestion. An apartment complex, a middle school, a shopping
center, and approximately 35 private homes are contained within the
.site boundaries.. All are occupied and use private wells for
provision of potable water.
EPA's acceptable cancer risk range is 10'* to icr6 , which can be
interpreted to mean that an individual may have one in ten thousand
to one in a ftdllion increased chance of developing cancer as result
of site-related exposure to a carcinogen over a 70-year lifetime
under the specific exposure conditions at the Site.
The results of the baseline risk assessment conducted as part of
the 1987 RI/FS indicated that, if used as a supply of household
water, the groundwater at the Site posed unacceptable risks to
human health and the environment. The .risk assessment was indica-
tive of a worst case total lifetime exposure to maximum organic
concentrations at an assumed constant rate (drinking 2 liters of
water daily for 30 years in an adult living to the age of 70
years). It was determined that the total cancer risk exceeded
IxlO'3, or 1 case In 1000. Most of this risk was due to the presence
of vinyl chloride which has not been detected since 1987.
Eliminating vinyl chloride from the risk assessment results in a
calculated carcinogenic risk that is within EPA's acceptable risk
range. Using current data, and applying these data to present
standards (which are more stringent than those of 1987), the
carcinogenic risk is calculated to be 1.1 x 10's , which is within
EPA's acceptable range.
To assess the overall potential for noncarcinogenic effects posed
by more than one contaminant, EPA has developed a hazard index
(HI) . This index measures the assumed exposures to several
chemicals simultaneously at low concentrations which could result
in an adverse health effect. When the HI exceeds one, there may
be concern for potential noncarcinogenic effects.
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In 1987, the concentrations all noncarcinogenic contaminants were
compared with their respective subchrpnic and chronic intake levels.
and were found to be within acceptable intake levels. Using
current data, and applying these data to present toxicological
standards (which are more stringent than those of 1987), results
in a noncarcinogenic risk Hazard Index of 1.
\. .'. _
It is noted that the only exposure routes to humans at the Site are-
through ingestion and inhalation of VOCs via the contaminated
groundwater. However, those residential wells which did exceed
MCLs have been supplied with whole-house water treatment units.
Furthermore, the levels of contamination observed in 1987 have now
diminished to levels near or below MCLs in both monitoring wells
and residential wells. ;
On three successive occasions, computer modeling was used to^ better
understand the transport and fate of the groundwater contamination
in the study area. The first effort, conducted as part of the RI,
concluded that groundwater flowed from the identified sources
through the area of contaminated residential wells to the Fall
Kill. The second modeling event, which was conducted by Ebasco in
1989 to determine the optimum groundwater extraction rate for
implementation of the remedy, identified declining .levels of
contamination in the aquifer.
The third modeling event was performed by EPA's Robert S. Kerr
Environmental Research Laboratory in 1992. .This effort, which
focused on determining the fate and transport of the aquifer
contamination, was documented in a report entitled "Groundwater
Modeling Report for the Haviland Complex Superfund Site." Using
1987 and 1990 data, the report concluded that site contamination
would be below MCLs within 5 to 10 years without pumping and
treating the contaminated groundwater. The modeling also
predicted, however, that, if implemented, extraction and treatment
of the groundwater would result in the contamination declining to
concentrations below State and Federal drinking water standards
within about the same time frame of about 5 to 10 years. Since the
modeling was done in 1992, the expected range of aquifer cleanup
would be within about 1 to 6 years from today. .
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As a result of the significantly diminished groundwater
contamination and site risks, as well as the computer modeling
effort which indicates that the active groundwater extraction and
treatment remedy called for in the 1987 ROD would not remediate the
aquifer significantly more quickly than naturally occurring
processes, EPA determined that the active groundwater treatment
system was not cost-effective nor necessary to protect human health
and the environment.> Similarly, due to these changing conditions
it was determined that the provision of a permanent alternate water
supply was not cost-effective and that the maintenance of the
existing whole-house treatment units would provide similar levels
of protection at less cost. . '
.V. DESCRIPTION OF REMEDIAL ALTERNATIVES
CERCLA requires that each selected site remedy be protective of
human health and the environment, be cost-effective, comply with
other statutory laws, and utilize permanent solutions and alterna-
tive treatment technologies and resource recovery alternatives to
the maximum extent practicable. In addition, the statute includes
a preference for the use of treatment as a principal element for
the reduction of toxicity, mobility, or volume of the hazardous
substances.
This ROD Amendment evaluates two alternatives for addressing
groundwater contamination, namely, Alternatives GW-1 and GW-2, and
two alternatives addressing the alternate water supply, identified
as AW-1 and AW-2. Consistent with ROD amendment guidance, the
components of the original remedy to be amended (Alternatives GW-2
and AW-2) have been updated and are being compared to new preferred
alternatives (Alternatives GW-1 and AW-1) which were developed
based upon existing site circumstances, including the groundwater
monitoring and modeling data presented above. It should be noted
that the time to implement reflects only the time required to
construct, or implement the remedy and does not include the time
required to design the remedy, negotiate with the potentially
responsible parties, or procure contracts for design and construc-
tion.
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The remedial action objectives for addressing groundwater
contamination are to (1) protect human health by ensuring residents
are not exposed to contaminated groundwater, and (2). reduce
groundwater contamination levels to drinking water standards. The
remedial action objective for the alternate water provision portion
of the remedy is to protect human~health by ensuring residents are
not ekposed to contaminated residential Well water.
The alternatives for addressing the site groundwater contamination
are: ' ' ' . . ; ; : . -
Alternative GW-1 - No Further Action/Natural Attenuation
Capital Cost: $0
O & M Cost: $5000/year (for 7 years)
Present Worth Cost: $24,873
Time to Implement: 0 - .
This alternative does not include active treatment of the aquifer;
it relies upon natural attenuation to reduce the contamination
below State and Federal drinking water standards. Based on
groundwater modeling, it is estimated that natural attenuation
processes would reduce levels of contamination in the aquifer to
State and Federal drinking water standards within 1 to 6 years.
This alternative would include an annual groundwater monitoring
program. Five monitoring wells located in the area would be
utilized to monitor the aquifer upgradient and downgradient of the
affected homes. Analytical data obtained from these wells would
serve to demonstrate the progress of the aquifer remediation.
Groundwater samples would be analyzed for inorganic and volatile
organic parameters. . "
t * *
Alternative 6(7-2 (Existing Remedy) - Groundwater Extraction, Treat-
ment, and Discharge to Surface Haters
- Capital Cost: $626,500
O & M Cost: $116,375/year (for 7 years)
Present Worth Cost: $1,205,439
Time to Implement: One year
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This alternative includes aquifer restoration through hydraulic
containment and interception of the identified contaminant plume.
Interception of contaminated groundwater would be accomplished
using four stainless steel extraction wells, screened in the
surficial aquifer, each pumping continuously at 20 gpm. Proper
sizing and location of these wells would result in containment of
the plume through modification of the groundwater gradient caused
by the cones of depression around each well. Small areas of the
plume which are already near the Fall Kill would continue to
migrate until they enter the creek.
This alternative assumes that the extracted groundwater would
require some treatment prior to discharge. Treatment technology
for metals removal would 'consist of pH adjustment and precipi-
tation. After metals -treatment, the groundwater would be treated
through an air stripper and then would be discharged to the Fall
Kill. Worst-case emissions from the stripper were calculated- to
be insignificant in comparison to New York State standards. The
design of the groundwater treatment system would be based on SPDES
requirements which would be the more stringent of the effluent
limitations for a class C water body or the water quality limita-
tion for the Fall Kill.
Groundwater extraction and treatment offers long-range public
health protection against consumption of contaminated groundwater.
Based on site hydrogeologic conditions, the time required to
rehabilitate the aquifer to acceptable State and Federal drinking
water standards is estimated to be within 1 to 6 years.
Aquifer v rehabilitation would be accompanied by an annual
groundwater monitoring program. The sampling and analysis would
utilize selected monitoring wells located in the study area.
Analytical data obtained from these wells would serve to
demonstrate the progress of the aquifer remediation. Groundwater
samples would be analyzed for inorganic and volatile " organic
parameters.
The alternatives identified.for an alternative water supply are:
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..' " ." 12 ' . ..-
Alternative AW-1 - No Further Action/Continue to Maintain Whole-
House Water Treatment Units
Capital Cost: $0
O & M Cost: $27,053/year (for 10 years)
Present Worth Cost: $166,082 .
, Time to Implement: 0
This alternative would continue to address the low-level
contamination present in the seven affected homes by maintaining
the existing whole-house filters presently installed in these
homes. The units consist of a sediment filter, an ultra-violet
treatment unit and twin activated-carbon filtration cylinders.
These homes have been sampled semi-annually by the NYSDEC; the
sampling results indicate that the units are working quite
effectively and have provided a safe reliable source of water for
residential use while requiring minimal maintenance.
Water in these seven homes would continue to be monitored on a
semi-annual basis. The units would be .maintained by NYSDEC until
three years of consecutive semi-annual rounds of sampling
demonstrate that the well water meets Federal and State drinking
water standards indicating that treatment will no longer be
necessary.
Alternative AW-2 (Existing Remedy) - Provision of Public Water to
Study Area
. Capital Cost: $3,147,969
O & M Cost: $0
Present Worth Cost: $3,147,969
Time to Implement: 18 months
"'.»
This alternative provides for the extension of a Ipcal public water
system into the study area. The ROD originally envisioned that EPA
would enter into an agreement with the Town of Hyde Park to share
in the costs to upgrade the Harbourd Hills Water District Well
water treatment system to meet NYSDOH standards. . It is noted,
however, because of residents' concerns about incurring costs
associated with upgrading the HHWD treatment facilities, the Town
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13
passed a resolution "stating that the HHWD facilities not be
upgraded. Furthermore, the Town of Hyde Park has requested that
the HPFW be utilized as the water source. The water distribution
network would be the same as that described in the ROD. The
distribution system would be installed along the Haviland Road and
Wright Avenue, and connections would be made by EPA from this
distribution system to residences in the study area. This network
would be connected to HPFW at a point approximately one-half mile
away. ''.'''
VI. SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
During the detailed evaluation of remedial alternatives, each
alternative is assessed against nine evaluation criteria, namely,
overall protection of.human health and the environment, compliance
with applicable or relevant and appropriate requirements, long-term
effectiveness and permanence, reduction of toxicity, mobility, or
volume through treatment, short-term effectiveness,
implementability, cost, and state and community acceptance.
The evaluation criteria are described below.
o Overall protection of human health and the environment ad-
dresses whether or not a remedy provides adequate" protection
and describes how risks posed through each pathway are
eliminated, reduced, or controlled through treatment, engi-
neering controls, or institutional controls.
o Compliayice with applicable or relevant and appropriate
requirements (ARARs) addresses whether or not a remedy will
meet all - of the applicable or relevant and .appropriate
requirements of other Federal and State environmental
statutes and.requirements or provide grounds for invoking a
waiver.
o Long-term effectiveness and permanence refers to the ability
of a remedy to maintain reliable protection of human health
and the environment over time," once cleanup goals have been
met.
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o Reductiqn of toxicity. mobility, or volume through treatment
is the anticipated performance of the treatment technologies
. a remedy may employ.
o Short-tertq effectiveness addresses the period of time needed
to achieve protection and any adverse impacts on human health
and the environment that may be posed during the construction
and implementation period until cleanup goals are achieved.
o Implementability is the technical and administrative
feasibility of a remedy, including the availability of
materials and services needed to implement a particular
option. ;-.
o Cost includes estimated capital and operation and maintenance
. costs, and net present worth costs. .
o State acceptance indicates whether, based on its review of
the RI/FS reports and Post-Decision Proposed Plan, the State
concurs, opposes, or has no comment on the preferred
alternative at the present time.
o Community acceptance is assessed -by reviewing the public
comments received on the RI/FS reports,. during the public
meetings and the Post-Decision Proposed Plan.
A comparative analysis of these alternatives based upon the
evaluation criteria noted above follows.
Groundwater Contamination
o Overall Protection of Human Health and the Environment
Both Alternatives GW-1 and GW-2 would provide full protection to
human health and the environment. Modeling predicts that the
active extraction and treatment of the Site groundwater would
result in contaminant levels being reduced to State and Federal
groundwater and drinking water in 1 to-6 years. Modeling of the
natural attenuation alternative also predicts that the ARARs would
be achieved in 1 to 6 years. Nonetheless, the extraction and
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' ' ' ' ' 15
treatment of the groundwater under Alternative GW-2 may provide a
slightly more rapid removal of contamination from the aquifer than
the natural attenuation process of Alternative GW-1. The exposure
route to the people at the Site is through ingest ion of groundwater
or the inhalation of volatile contaminants' from the groundwater.
Private wells which contain levels of contaminants above drinking
water standards have been fitted with individual water-treatment
units, thereby ensuring a safe supply of .potable water. The levels
of contaminants entering these wells has been decreasing, and
sampling of.the water prior to and after treatment from these units
indicates that the.units are working effectively.
o Compliance with ARARs
t
Both alternatives would comply with ARARs in approximately the same
time frame. Modeling predicts that the no further action/natural
attenuation Alternative GW-1 and the active groundwater extraction
and treatment Alternative GW-2 would result in contaminant levels
being reduced to State and Federal groundwater and drinking water
standards in 1 to 6 years. .
o Long-Term Effectiveness and Permanence
Alternatives GW-1 and GW-2 would be equal in providing long-term
effectiveness and permanence in that the groundwater contamination
would be reduced below State and Federal drinking water standards
within 1 to 6 years.
Alternative GW-2 would potentially result in greater long-term
exposure to contaminants by workers who could come into direct
contact with the concentrated sludges from the treatment system.
However, proper health and safety precautions would be implemented
to minimize exposure to the sludges.
o Reduction in Toxicity. Mobility, or Volume Through Treatment
Under both alternatives, the volume arid toxicity of the groundwater
contaminants above ARARs would be reduced at approximately the same.
rate and would ultimately be eliminated in approximately the same
time frame.
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16 .
The' mobility of the contamination plume would be reduced by
actively extracting the groundwater under Alternative GW-2. It is
assumed that even with the active groundwater extraction,
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17
and the handling and disposal of the concentrated contaminated
treatment residuals.. -
Alternative GW-1 would be more easily implemented, as it would only
require the sampling of selected monitoring wells already in place
once a year. . . .
o Cost . .
Alternative GW-l has no direct costs associated with its implemen-
tation. The present worth of this alternative of $24,873 is for
implementation of an*annual grouhdwater monitoring program. The
capital and present worth costs of Alternative GW-2 are estimated
to be approximately $625,500 and $1,205,439, respectively.
Both alternatives would provide a similar level of protection in
a similar time frame, .however, Alternative GW-1 would, do so at a
much lower cost.
o State Acceptance .
The State of New York concurs on the modified selected remedy.
o Community Acceptance
The community generally seemed to be in favor of the modified
selected remedy.
Alternate Water Supply
o Overall Protection of Human Health and the Environment
Both Alternatives AW-1 and AW-2 would provide full protection of
human health. Both alternatives would prevent the potential expo-
sure of residents at the Site through ingestion or inhalation of
contaminants present in selected residential wells. Data from the
sampling of the impacted residential wells has shown that the
whole-house treatment units installed at these residences are fully
effective and provide sustained protection with minimal
maintenance.
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18 ' . _ .
The provision of public water to the site area described in
Alternative AW-2 would not be more protective to the residents than
what presently exists, but would preclude the need for future
sampling of the impacted wells and maintenance of the whole-house
treatment units.
o Compliance with ARARs
Alternatives AW-1 and AW-2 would both comply with ARARs, the
primary ARARs of concern being State and Federal drinking water
standards. Neither .Alternative AW-1 nor AW-2 would provide a
significant advantage over the other with respect to ARARs.
Compliance with ARARs under Alternative AW-1 would be demonstrated
via the home sampling and filter maintenance program. Compliance
with ARARs under Alternative AW-2 would be demonstrated by the
water supplier via regular sampling of the water distribution
system as required by the State of New York. .
. o Long-Term Effectiveness and Permanence
Because groundwater contamination is estimated to be completely
attenuated within 1 to-6 years, Site-related contaminants would not
be expected to impact the residential wells over the long term.
Therefore, both alternatives would provide long-term protectiveness
and permanence. .
o Reduction in Toxicity. Mobility, or Volume Through Treatment
A comparison of the two alternatives' abilities to satisfy this
criterion is not necessarily applicable since the goal of the
alternate water supply is to provide a potable supply of water and
does not require that the toxicity, mobility or volume of
contaminants be reduced to do so. Nonetheless, Alternative AW-1
would reduce the toxicity, mobility and volume of contaminants in
the residential well water, and to a limited extent the aquifer.
Alternative AW-2 would not provide any reduction of contaminants.
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. .- ' 19 ' .-. . . '
o Short -Term Effectiveness
There would be virtually no short-term impacts to human health and
the environment -by continuing to. maintain, the residential water
treatment units under Alternative AW-1. Also, because the
residential water treatment units are already installed, no time
would be required to implement this alternative. However,
construction activities associated with Alternative AW-2 (e.g.,
installation of an underground water distribution system) would
have potentially negative impacts on residents in the study area.
While efforts would be made to minimize these impacts, some dis-
turbances to residents would result from disruption of traffic,
excavation activities on public and private land, noise, and
fugitive dust emissions. It is estimated that the construction
activities for Alternative AW-2 would take approximately 18 months
to complete.
. o Implement ability
i . * '"
Alternative AW-2 would require the design and construction of a
public potable water distribution system and its connection to
HPFW. The system would take approximately 18 months to construct.
The technologies necessary for implementing this alternative are
proven .and reliable. '
The implementation of Alternative AW-1 would require the continued
monitoring and maintenance of the home filtration units.
Alternative AW-1 provides a similar level of protection as
Alternative AW-2 but at a much lower cost. AW-l has no direct
capital costs associated with its implementation. The present
worth cost of AW-1 is $166,082 is based on annual costs of $27,053
per year for the semi-annual sampling and maintenance of the whole -
house treatment systems. .
The total cost of Alternative AW-2 is estimated to be approximately
$3,147,969. The capital cost is based on the cost of connecting
to HPFW which is (estimated to be $848,969 and construction of the
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20
distribution system which is estimated to be $2,299,000. While EPA
and the NYSDEC would not incur any operating or maintenance
expenditures under Alternative AW-2, residents connected to the
system would have to pay for the water received, which is estimated
to be approximately $200 to $400 per year.
o State Acceptance
The State of New York concurs on the modified selected remedy.
i
o Community Acceptance
While local officials clearly favored the original remedy,
Alternative AW-2 (Provision of Public Water to the study area),
residents in the area seemed to be divided in their preferences.
VII. SELECTED REMEDY
Based upon an evaluation of the various alternatives, EPA and
NYSDEC have determined that Alternative GW-1, No Further Ac-
tion/Natural Attenuation, and Alternative AW-1, No-Further
Action/Continue to Maintain Whole-House Filter Systems are the
appropriate modified remedies for the Site.
These alternatives provide the best balance of trade-offs among
alternatives with respect to the evaluating criteria in that they
are protective of human health and the environment, comply with
ARARs, are cost-effective, and utilize permanent solutions and
alternative treatment technologies or resource recovery technolo-
gies to the maximum extent practicable.
VIII. STATUTORY DETERMINATIONS
Under its legal authorities, the EPA's primary responsibility at
Superfund sites is to undertake remedial actions that achieve
adequate protection of human health and the environment. In
addition, Section 121 of CERCLA establishes several other statutory
requirements and preferences that the selected remedy must meet.
Section 121 of CERCLA specifies that when complete, the selected
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21
remedial action for the Site must comply with ARARs established
under Federal and State environmental laws unless a statutory
waiver is justified. The selected remedy also must be cost-
effective and utilize permanent solutions and alternative treatment
technologies or resource recovery technologies to the maximum
extent practicable. Finally, the statute includes a preference for
remedies that employ treatment that permanently and significantly
reduce the volume, toxicity, or mobility of hazardous wastes'as
their principal element. The following sections discuss how the
selected remedy meets these statutory requirements.
i
Protection of Human Health and the Environment:
The modified selected remedy ensures that affected residences are
protected from contaminants in the aquifer through the maintenance
and monitoring of the whole house treated systems and is fully
protective of human health and the environment.
Compliance with Applicable, or Relevant and Appropriate Require-
ments (ARARs):
Groundwater modeling predicts that the modified selected remedy
for groundwater contamination will achieve ARARs, specifically the
Safe Drinking Water Act (SDWA) Maximum Contaminant Levels (40CFR
141.11-141.16), 6NYCRP Groundwater Quality Regulation (Parts 703.5,
703.6, 703.7) and NYS Sanitary Code 10 NYCR Part 5 for contaminants
in drinking water within six years.
Cost-Effectiveness:
The modified selected remedy is cost-effective and provides the
greatest overall protectiveness proportionate to costs.
Utilization of Permanent Solutions and Alternative Treatment
Technologies (or Resource Recovery Technologies) to the Maximum
Extent Practicable;
The modified selected remedy represents the maximum extent to which
permanent solutions and treatment technologies can be utilized in
a cost-effective manner at the Site.
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22
Preference for Treatment as a Principal Element:
The modified selected remedy utilizes point-of-use treatment of the
Site groundwater. Treatment of the aquifer-at-large is determined
to not be cost-effective at this Site.
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APPENDIX 1
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New York State Department Of Environmental Conservation
50 Wolf Road. Albany. New York 12233-7010
JohnP.Cahill
MAY I 9 I997 Acting Commissioner
Mr. Richard Caspe
Director
Emergency & Remedial Response Division
U.S. Environmental Protection Agency
Region n
290 Broadway
New York, NY 10007-1866
Dear Mr. Caspe:
Re: Draft Record of Decision
Haviland Complex She ED No. 314059
The New York State Department of Environmental Conservation and the New York State
Department of Health have reviewed the above-referenced document The amendment calls for reducing
the current remedy of a) installation of a public water supply and b) pumping/treating of the
contaminated groundwater as specified in the original ROD of September 1987. The only remedy under
the amendment will be natural attenuation of residual contamination in the aquifer and continued use of
carbon filter systems at homes with affected wells.
We concur with the amendment as proposed. If you have any questions, please coi ct
Sal Ervotina at (518) 457-4349.
Sincerely,
Ichaen. O'Toole, Jr.
Director
Division of Environmental Remediation
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APPENDIX 2
Index for the Administrative Record
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HAVILAND COMPLEX SITE
ADMINISTRATIVE RECORD FILE AMENDMENT
INDEX OP DOCUMENTS
4.0 FEASIBILITY STUDY
4.3 Proposed Plan
P. 005 0051- Plan: Superfund Post-Decision Proposed Plan,.
005 0058 Haviland Complex, Hyde Park. Putehess County. New
Yorkf prepared by U.S. EPA, Region II, August
1996.
5.0 REMEDIAL DESIGN/REMEDIAL ACTION
5.7 Reports
P. 005 0059- Report: Haviland Wells Site. Hyde Park. New York,.
005 0368 Groundwater Flow and Transport Modeling Fina").
Report. prepared for U.S. EPA, Region II, prepared
by Ebasco Services Incorporated, September 13,
1989.
P. 005 0369- Report: Haviland Complex Wells Site. Summary
005 0400 Report of Groundwater Investigationsf prepared by
Ebasco Services Incorporated, March 1991..
P. 005 0401- Letter to Mr. Kevin Willis, Remedial Project
005 0444 Manager, U.S. EPA, Region II, from Mr. Frank A.
Cavacini, Site Manager, Ebasco constructors Inc.,
re: ARCS II Program - EPA Contract No. 68-W8-0110,
Work Assignment No. 033-2RE5, Haviland Wells
'Complex-Hyde Park, New York, Final Report,
September 23, 1991. (Attachments: Attachments 1 -
3).
P. 005 0445- Report: ftaviland Complex Sitef Hyde Parkr New
005 0478 York,. Groundyat;er and Water Iicvel Data Report.
prepared for U.S. EPA, Region II, prepared by
Environmental Response Team, Environmental
Response Branch, U.S. EPA, June 1992.
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005 0479- Report: Groundwater Modeling at the Haviland
005 0541 Complex Site. Hvde Parkf New York, prepared by
Milovan S. Beljin, Ph.D., HydroLink, and Randall
R. Ross, EPA Robert S. Kerr Research Laboratory,
December 1992.
005 0542- Memorandum to Mr. Kevin Willis, Remedial Project
005 0649 Manager, U.S. EPA, Region II, from Royal J.
Nadeau, Ph.D., Environmental Response Team,
Environmental Response Branch, U.S. EPA, Region
II, re: Report on Groundwater Chemistry and Water
Level Determinations at Haviland Complex NPL Site
- Hyde Park, New York - November Sampling, January
19, 1993. ,.
005 0650- Letter to Mr. Kevin Willis, U.S. EPA, Region II,
005 0681 from Mr. Richard Rienzo, Site Manager, Ebasco
Environmental, re: Haviland Complex Site Remedial
Design, Summary Report of Groundwater Investi-
gation, September 28, 1994. (Attachment: Haviland
Complex Wells Site, Hyde Park, New York, Summary
Report of Groundwater Investigation, prepared by
Ebasco Services Incorporated).
10.0 PUBLIC PARTICIPATION
10.4 Public Meeting Transcripts
P. 005 0682- Public Meeting Transcript: U.S. EPA, Public
005 0796 Meeting, Haviland Complex Superfund Site, Haviland
Middle School, 'Hyde Park, New York, Wednesday,
September 4, 1996.
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APPENDIX 3
Responsiveness Summary
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APPENDIX 3
RESPONSIVENESS SUMMARY
HAVILAND COMPLEX 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 the selected remedy for the Haviland Complex site
(Site).
SUMMARY OF COMMUNITY RELATIONS ACTIVITIES
Community involvement at the Site has been strong. EPA has
served as the lead Agency for community relations and remedial
activities at the Site.
The Post-Decision Proposed Plan (PDPP) for the Site was released
to the public for comment on August 24, 1996. This document,
together with the Remedial Investigation/Feasibility Study
reports, two reports entitled "Summary of Groundwater
Investigations," "Groundwater Modeling Report for the Haviland
Complex Site," and others were made available to the public in
the Administrative Record file at the EPA File Room in Region II,
New York, in the information repository at the Hyde Park Town
Hall, Route 9, Hyde Park, New York and in the Hyde Park Free
Library, Hyde Park, New York. The notice of availability for the
above-referenced documents was published in the Poughkeepsie
Journal on August 24, 1996. The public comment period on these
documents was open from August 24, 1996 to September 23, 1996.
At the public meeting, Paul Prentice, a citizen, requested a
thirty (30) day extension to the public comment period. This
extended the comment period until October 23, 1996.
EPA conducted a public meeting on September 4, 1996 at the
Haviland Middle School, Hyde Park, New York to discuss the Post-
Decision Proposed Plan for the site and to provide an opportunity
for the interested parties to present oral comments and questions
to EPA.
Attached to the Responsiveness Summary are the following
Appendices:
Appendix A - Post-Decision Proposed Plan
Appendix B - Public Notices
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Appendix C - September 4, 1996 Public Meeting Attendance
. Sheets
Appendix D - September 4, 1996 Public Meeting Transcript
Appendix E - Letters Submitted During the Public Comment
Period
SUMMARY OF COMMENTS AND RESPONSES
Comments expressed at the September 4, 1996 public meeting and
written comments received during the public comment period have
been organized as follows:
Post-Decision Proposed Plan
Hydrogeology/Computer Model
Residential Well Sampling Data
Monitoring Well Sampling Data
Future Aquifer and Residential Well Monitoring Program
Miscellaneous
A summary of the comments and EPA's responses to the comments is
provided below:
I. Post-Decision Proposed Plan
A. Groundwater Remedy
The community generally accepted the proposed No Further Action
Remedy for the Site groundwater. For the most part, the comments
raised with respect to this portion of the PDPP did not focus on
the remedy itself, but rather on the analytical results and
computer modeling activities which supported the proposed remedy;
these comments are addressed in Sections II and IV below.
B. Alternate Hater Supply Remedy
Comment #1: Many commenters, particularly representatives from
the Town of Hyde Park and the local water providers/districts,
expressed concern that the preferred remedy of No Further Action
did not provide a permanent solution to the problem. They
expressed a preference for a connection to a public water supply
(i.e., Alternative AW-2) and indicated that it would be more
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protective and would eliminate the need for groundwater
monitoring.
EPA's Response: Since the issuance of the ROD, EPA has conducted
several widespread groundwater investigations of the study area
to reestablish a baseline of groundwater quality data.
Monitoring data showed that the levels of contamination in the
aquifer have exhibited a dramatic decrease to the present levels
near or below State and Federal drinking water standards. In
addition to groundwater monitoring of the affected homes and
approximately 15 other wells in the Site area, three successive
groundwater computer modeling efforts have been conducted to
predict the future concentrations of contaminants in the aquifer.
The groundwater monitoring data support the computer modeling
predictions which estimate that the contamination in the aquifer
will decrease to levels below standards in 1 to 6 years; as the
sources of these contaminants have been remediated, this decrease
in contaminant concentrations will represent a permanent
reduction in contaminant levels.
Given the fact that the existing activated carbon filters
reliably protect the seven serviced residences from the Site
contamination, and the fact that modeling predicts that
contaminant levels will reach drinking water standards within a
few years, EPA and New York State believe that the levels of
contamination observed in the aquifer no longer warrant the
implementation of the public water supply and groundwater
extraction portions of the 1987 ROD. Therefore, EPA has decided
to amend the ROD and rely on the activated carbon filters, until
it is confirmed that the levels of contaminants in the
groundwater have permanently declined to levels below drinking
water standards. This approach will provide an equivalent level
of protection to the residents at far less cost than the remedy
specified in the ROD.
It should be noted that although the officials from the Town and
various water districts which serve the Town were in favor of the
installation of a public water supply, it was apparent at the
public meeting that there is a difference of opinion among the
local residents in their desire to have a public water system.
EPA received only two letters, both form letters, from residents
which indicated a preference for public water. Some residents
at the meeting indicated that they were not in favor of the
public water, citing increased costs to them and possible
elevation of the wafer table which could impact their residences.
EPA's own door-to-dbor survey of residents whose homes are
supplied with carbon filters also indicated that they were split
on their desire for an alternate water supply.
Comment 2: The consulting engineer for the Harbourd Hills Water
District stated that the emphasis of the 9/6/96 presentation was
centered on seven homes along Haviland Road and wanted to know
what assurances would be made to ensure the protection of other
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entities in the study area, including the Haviland Middle School,
and the Haviland Shopping Center and Haviland Complex Apartments.
EPA'a Response: Alternative AW-i is considered to be fully
protective of all entities currently impacted or potentially
impacted by the limited contamination present at the Site. The
levels of contamination in the plume have naturally attenuated to
the present levels which are near or below drinking water
standards. Monitoring of the plume for the past 10 years has
shown little deviation from the originally determined pathway.
It should be noted that any further migration of the plume would
result in further dilution of the contaminant levels in the
plume.
Systems are or will be in place to ensure that each of the
entities continue to have a potable water supply. Site-related
contamination has never been observed in the Haviland Middle
School water supply and none is expected to be observed in the
future as the school's supply well is located in a separate and
distinct aquifer than the aquifer which supplies the affected
residents. Also, the school is required to perform annual
sampling of its water supply. The Haviland Complex has been
providing potable water to its residents and businesses since
1985, via its own water supply and its own water treatment
facility, which is required to be sampled on a quarterly basis.
The sampling of both facilities is required under New York State
Sanitary Code Subpart 5-1, Public Water Systems, Public Health
Law Sec. 225. The more frequent monitoring of the Haviland
Complex Supply is due to the continued presence of trace organic
contamination.
Finally, the modified selected remedies require the
implementation of a routine monitoring program; homes along
Haviland Road and Wright Avenue will be monitored as part of this
aquifer monitoring.
Comment 3: Numerous commenters stated that they felt that the
decision to not install the public water system was purely
economically based. One commenter acknowledged that EPA has
spent approximately $1.3 billion on environmental cleanups in New
'York State, but wanted to know why such a relatively small sum as
the approximately $3 million could not be spent putting in the
public water system.
EPA's Response: EPA utilizes nine criteria, one of which is cost
to evaluate remedial alternatives. Two of the nine criteria,
overall protection of human health and the environment, and
compliance with applicable or relevant and appropriate
requirements, must-be satisfied before an alternative can be
given further consideration; these two criteria are called the
threshold criteria. Alternatives AW-l and AW-2 both satisfy the
threshold criteria and provide an equivalent level of protection
of human health and the environment. The comparison of the two
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alternatives provided in the PDPP and the"Decision Summary of
this ROD Amendment indicates that they are also similar with
respect to most of the other criteria, however, Alternative AW-1
is much less expensive to implement than Alternative AW-2 and was
therefore identified as EPA's. preferred alternative. Furthermore,
as stated previously, EPA did try to implement Alternative AW-2
for many years without success.
Comment 4: The Dutchess County Water and Wastewater Authority
expressed their preference for the installation of the public
water system, stating that the water pressure would be better,
there would be no need for monitoring, and that a clean water
supply would be available for all.
EPA's Response: Under the Superfund program, EPA must evaluate
risks posed by a site and determine the best means of protecting
human health and the environment from any risks deemed to be
unacceptable. As noted above, EPA uses nine criteria to evaluate
various options for remediating sites; in this case, the
evaluation indicated that Alternative AW-1 is fully protective of
human health and the environment and provides the best balance of
trade-offs with respect to the evaluation criteria.
Comment 5: The Dutchess County Water and Wastewater Authority.
stated that the Hyde Park Fire and Water System has a significant
excess of capacity which is creating a financial hardship to its
district residents which would be somewhat relieved by expanding
its district into the Haviland Complex area.
EPA's Response: As mentioned previously, EPA is required under
the Superfund statute and the NCP to utilize nine specific
criteria in evaluating remedial alternatives. As such, EPA is
precluded from considering the Dutchess County Water and
Wastewater Authority's development of excess capacity in its
evaluation.
Comment 6: Two commenters stated that they were distressed as to
the length of time it has taken to come to this decision.
EPA's Response: Since the ROD was issued, -efforts to implement
the design of the alternate water supply have been interrupted or
delayed for a number of reasons, including some internal EPA
contractual issues. The primary reasons for delays, however,
were a result of the changes in the Town's desire as to the
source of public water for the affected area. Since the ROD was
signed, different administrations have indicated a desire to use
water supply sources other than the HHWD supply wells, as well as
recurring requests to reconsider HHWD. In fact, EPA has received
eight written requests to change the source of water since the
preparation of the 1987 ROD. These other sources included the
Hyde Park Fire and Water District and the City of Poughkeepsie.
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As explained in the response to comment #1, during the 10 years
since the ROD has been signed, EPA has continued to monitor
groundwater quality. Because contaminant levels have decreased
to near or below drinking water standards, EPA has determined
that no further remedial action is necessary at the Site to
protect human health and the environment.
Comment 7: One commenter expressed that in October 1995, the Town
of Hyde Park had held a public meeting and said that there was a
firm plan to install the public water system into the study area
and was wondering why this plan was not being carried out.
EPA's Response: At that time, EPA was still intending to
implement the public water supply portion of the 1987 Record of
Decision. EPA attempted for many years to implement the
installation of the public water supply, but was unable to do so
for many reasons, the most important being the frequent requests
by the Town of Hyde Park to consider various and changing sources
for the potable water. Also see EPA's response to Comment 1 for
an explanation of EPA'8 decision not to install the public water
system.
Comment 8: One commenter was concerned with the situation where
his home at 16 Haviland Road was 'located between homes with
State-maintained filters but his well was not augmented. He
wanted to know how his well was to be protected.
EPA's Response: All homes with potable wells where VOC
contamination was detected above drinking water standards were
fitted with activated carbon filters. The well at 16 Haviland
Road is unique relative to the other wells in that it has never
been contaminated. This well is deeper than the wells at
neighboring homes and is not drawing water from the contaminant
plume. ;
Additionally, occasional sampling of this well will continue in
the future as part of the monitoring program conducted by NYSDEC.
Comment 9: One commenter inquired as to what guarantee will be
provided to the residents that their government-instailed home
filters be maintained in the future.
EPA's Response: The ROD Amendment requires that EPA and NYSDEC
maintain the filters until three years of consecutive semi-annual
sampling shows that contaminant levels in the affected wells are
below drinking water standards. EPA and NYSDEC could only be
relieved of this obligation through a subsequent amendment to the
ROD; such an amendment would require notification of homeowners
and other parties in the area, as well as a public meeting for
citizens to comment on the proposed amendment.
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7 -
Comment 10: The Harbourd Hills Water District Engineer inquired
if there would be an impact to the selected remedy if the
community insisted on being connected to the Hyde Park Fire and
Water District.
EPA's Response: As noted above, EPA utilizes nine criteria to
evaluate remedial alternatives, one of which is community
acceptance. EPA fully considers community opinions and concerns
before selecting or modifying a remedial action. Community
acceptance was given full consideration during this process.
II. Hydrogeology/Computer Model
Comment 11: One commenter inquired as to the accuracy of the
pathways of contaminant migration depicted as output from the
computer modeling of the study area.
EPA's Response: The flow-migration pathways shown during the
public meeting were produced as part of the last computer
modeling effort done by EPA in 1993. The flow lines drawn on the
map were computer-generated and were calculated utilizing water-
level measurements taken on one day. Together, they depict the
general flow patterns within the aquifer.
The pathways shown approximate the path a molecule of water would
likely follow in a system with invariable conditions. The
pathway would fluctuate slightly in response to changing
conditions within the aquifer (seasonal, precipitation, etc.),
but would generally follow the projected path, EPA believes that
the model's projected path is reasonably reliable and accurate
because the model has been verified by comparing actual site
conditions to what was generated by the computer.
Comment 12: One commenter expressed the opinion that the number
of samples collected within the contamination plume needs to be
increased to more accurately define the leading edge of the
plume.
EPA's Response: EPA believes that the number of monitoring
locations is more than adequate. The number of monitoring
locations for this plume is actually greater than is typically
the case for a plume of this size and levels of contaminants.
Comment 13: A commenter expressed concern that there could be a
change in the direction of groundwater flow in the future, thus
redirecting the flow of contamination into areas which were
previously uncontaminated and opening up liabilities for entities
performing development.
EPA's Response: EPA does not expect any significant change in
the direction of groundwater flow. The direction of flow has not
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8
changed significantly in the 10-years during which EPA has been
observing the groundwater contamination at the Site. In the
unlikely event that the direction of flow does change, EPA will
be able to observe this change through its monitoring program and
could take appropriate action, if any were required.
Comment 14: One commenter wanted to know how close the modeled
degradation of the contaminant plume compared to the actual
degradation of the plume.
EPA's Response: A computer model, is verified by comparing the
calculated results to data from the Site. If the anticipated
computer-generated numbers correspond with actual field
conditions, the model is considered to be accurate.
The results of the computer modeling were compared to the data
gathered from potable and monitoring wells. The contamination in
the aquifer appears to be attenuating at a more rapid rate than
was anticipated by the computer model. EPA has continued to use
the time frames described by the computer model, as a
conservative means of predicting the attenuation of the plume."
Comment 15: One commenter referred to Figure 20 in the December
1992 report "Groundwater Modeling at the Haviland Complex Site,
Hyde Park, NY" noting the following statement, "Figure 20
indicates that even after 10 years, concentration levels of
Tetrachloroethene will not decrease below 10 ppb level" and
asked if EPA believed in this computer prediction.
EPA's Response: As is often the case in modeling efforts,
several retardation factors were evaluated. The retardation
factor used in Figure 20 was more conservative than others used
in the same modeling effort. Consequently, this retardation
factor predicted higher levels of residual contamination than
were predicted when using the other less conservative retardation
factors. The text from which the commenter extracted the quote
continues on to describe the relation of the retardation factors
used in the modeling effort: nlf the value of the retardation
factor was reduced to a more reasonable factor of 6, after 10
years the concentration of Tetrachloroethene would significantly
decrease (figures 24 through 26)". The data gathered since the
modeling effort indicates that the contamination in the aquifer
is attenuating at an even more rapid rate than was projected by
the model and that retardation factors utilized to generate
figures 24 through 26 are more representative of actual
conditions than the retardation factors used to generate figure
20. Data collected from the potable well water also supports and
confirms the model's accuracy.
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III. Residential Well Sampling Data
Comment 16: One commenter inquired if the data used in
determining the trends of contaminant concentrations in the
residential well samples were from filtered or unfiltered
samples. *
EPA's Response: All of the residential well data used in
determining the trends were of water collected prior to, or
upstream of, home filtration units.
Comment 17: Numerous commenters expressed concern with the
fluctuations of contaminant concentrations in the raw (pre-
filtered) potable water samples.
EPA's Response: Fluctuations of the magnitude observed in the
semi-annual residential well sampling data are not unusual. This
variation is due to the dynamic conditions which occur in an
aquifer, such as seasonal changes or annual rainfall differences.
Although minor fluctuations have occurred, the sampling results
from 1987 to date indicate that the concentrations of
contaminants in the study-area aquifer have dropped by an order-
of-magnitude to concentrations near or below drinking water
standards. Given this significant decrease in contaminant
concentrations, and the fact that the sources of contamination
have been addressed, EPA feels confident that this trend will
continue, and that a significant increase in contaminant levels
will not be observed in the future.
Comment 18: A commenter raised concern that the homes along the
western end of Haviland Road weren't tested between 1990 and
1992.
EPA's Response: NYSDOH sampled potable wells along the western
end of Haviland Road in October 1996 and confirmed that there is
no Site-related contamination in this area. This study confirmed
the results of the last comprehensive study in the Site area
conducted by NYSDOH in 1993. The outcome of that effort showed
no Site-related contamination. Additional sampling of these
wells will be performed by NYSDOH in mid-1997.
Comment 19: Three commenters raised the concern that the Haviland
Middle School water supply well may be contaminated by Site-
related contamination.
EPA's Response: The Haviland Middle"School maintains its own
potable water supply well and samples this well on an annual
basis in accordance with New York State requirements. This well
has never shown any indication of Site-related contamination. It
is important to note that unlike the shallow wells in homes along
Haviland Road which have been impacted by contamination in the
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10
shallow aquifer, the Middle School well is a very deep bedrock
well which draws water from a different aquifer than the aquifer -
utilized by the homes along Haviland Road.
Comment 20: The Dutchess County Water and Wastewater Authority
expressed concern that the fluctuations in the potable well
sampling results may have impacted the reliability of the
computer modeling effort.
EPA's Response: The fluctuations in semi-annual sampling data
for the residential wells are not unusual. The general trend of
the contaminant levels in the aquifer is a more accurate
indicator of the fate of contaminants in the aquifer. Computer
modeling is used to predict a future trend given an initial set
of conditions. Field data are collected and compared to the
predicted trends in order to verify the model. The minor
fluctuations in the home sampling data have no impact on the
reliability of the computer model.
Comment 21: One commenter inquired as to why the graphs of
residential well data presented at the meeting on September 4,
1996 were more recent than those published in the August 1996
report.
.EPA's Response: The graphs presented at the public meeting did
contain some new information. New York State monitors the
affected residential wells on a semi-annual basis, typically
every January and July. The week before the September 1996
public meeting, EPA received data from the July 1996 sampling of
the residential wells. In order to make the latest information
available to the public, EPA incorporated these data into its
presentation'that evening. These latest data represent a small
addition to the previously existing data compiled from twelve
rounds of sampling over six years, and are important in that they
confirm the continuing decline of volatile organic contaminants
in the groundwater underlying the Site.
IV. Groundwater Monitoring Hell Data
Comment 22: A commenter expressed concern that EPA has apparently
discontinued the sampling of some of the monitoring wells in the
study area.
EPA's Response: EPA has only discontinued sampling of those
monitoring wells which are no longer suitable for sampling; most
of these wells were damaged by vehicles. During the development
of the monitoring plan for the Site, EPA will assure that the
aquifer is sampled in appropriate locations. If. the integrity of
a well has been compromised at any of these locations, or if a
well was never present in one of these locations, new monitoring
wells will be constructed in these locations. Any compromised
wells will be appropriately decommissioned at that time.
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Comment 23: The Harbourd Hills Water District Engineer inquired
as to the status of VOC contamination in the remainder of the
study area aquifer outside of the plume.
EPA's Response: Only one well outside of the defined plume has
shown groundwater VOC contamination above drinking water
standards; this well is located immediately north of the affected
homes (MW-24). MW-24 showed contamination decreasing to near or
below drinking water standards up until the time the well was
destroyed in the winter of 1992-1993. A replacement well will be
installed at an appropriate location immediately upgradient of
the effected homes as part of the future monitoring program.
Comment 24: Three commenters expressed concern that levels of
chromium and nickel detected in 1992 were in excess of NYSDEC
standards and wanted to know how EPA had addressed this
contamination.
EPA's Response: In an effort to reestablish a baseline of
groundwater quality data at the Site, EPA sampled existing
monitoring wells in June 1992 and observed elevated levels of
inorganic constituents in two wells in the aquifer immediately
south of the Middle School. EPA had requested that the New York
State Department of Health (NYSDOH) sample local residential
wells to assure that there was no human exposure to these metals.
NYSDOH sampling of the residential wells showed that there were
no Site-related elevated levels of inorganic contamination in
these residential wells. EPA resampled the monitoring wells in
November 1992 and the results indicated that the inorganic
contamination was a natural artifact of the aquifer itself. In
June 1994, a comprehensive sampling of monitoring wells was
conducted by EPA's contractor Ebasco, Inc. utilizing state-of-
the-art sampling techniques (low-flow environmental sampling
pumps to minimize induced turbidity). The results from this
investigation were documented in the September 1994 "Summary
Report of Groundwater Investigations," and indicated that the
levels of all inorganic compounds in the groundwater were either
not detectable or were below safe drinking water levels. This
study again determined that the metals previously detected in the
1992 study were related to naturally occurring substances which
were mobilized into the groundwater by the agitation from the
sampling method. This report is available in the Site repository
established at the local library.
V. Future Aquifer and Residential Monitoring Program
Comment 25: Commenters inquired about the scope of the monitoring
program; one commenter wanted to know if all the homes in the
study area would be sampled prior to the delisting of the Site in
the future.
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12
EPA's Response: NYSDOH has agreed to conduct a comprehensive
sampling of homes throughout the study area in the near future.
In addition, EPA and the State have already initiated discussions
regarding the scope of the monitoring program and expect that
this plan will be completed in the next few months.. As indicated
in the PDPP, the seven residences which have whole-house
treatment units will be sampled on a semi-annual basis, until
each round of sampling results over the course of three years
indicates that all Site-related contaminants are below federal
and State drinking water standards. Additional residential wells
in the area will be monitored on a less frequent basis. A series
of monitoring wells, some of which are existing and some which
may be added as necessary to provide adequate information on the
fate of contaminants in the aquifer, will also be sampled on an
annual basis.
Comment 26: Two commenters inquired as to what would happen if
contamination was released into the aquifer.in the future. They
insisted that the residential wells are vulnerable to
contamination from future releases.
EPA's Response: As a result the elimination of the original
discharges of hazardous substances to the aquifer, as well as
EPA's 1990 remediation of the septic systems (these septic
systems served as a continuing source of contamination of the
aquifer) the levels of contamination in the aquifer have declined
to close to drinking water standards. EPA has no reason to
believe that the Site-related contaminant levels will increase in
the future; however, if additional Site-related contamination
were observed, EPA could install additional whole-house treatment
units or move forward with additional investigation of.the
contamination, or if necessary, amend the ROD to allow for
alternative remedial measures.
If non-Site related contamination were observed, for example
originating from a residential septic system, EPA would work with
the other appropriate government agencies such as the NYSDOH,
NYSDEC or the County Health Department to determine the most
appropriate course of action.
VI. Miscellaneous
Comment 27: One cbmmenter wanted to know if the "Haviland Complex
Site" will be reduced in size considering that, the contamination
appears to be isolated to the southeastern quadrant of the study
area.
EPA's Response: Although EPA is capable of deleting portions of
sites, EPA has no current plans to do so at this site. Due to
the characteristics of this site, it is likely that the Site
would be deleted in its entirety, rather than in a piecemeal
fashion.
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13
Comment 28: A commenter inquired if EPA was trying to recover its
expenditures from the Potentially Responsible Parties (PRPs) and
whether a settlement was being sought with the school district
and its governing State agencies.
EPA's Response: EPA is attempting to recover its expenditures at
the Site from the PRPs who own the Haviland Complex. EPA had
issued notice letters to the PRPs at the Site offering them the
opportunity to implement the remedies specified in the 1987 ROD;
the PRPs declined this offer. As is the case on most sites where
PRPs decline to implement remedial activities, EPA is attempting
to reach a settlement with the PRPs for recovery of the Agency's
past costs by engaging in settlement discussions whereby the PRPs
would voluntarily offer to reimburse EPA. It is anticipated that
these negotiations will come to closure in the near future. If
the settlement negotiations fail, EPA is prepared to refer the
case to the U.S. Department of Justice for litigation.
EPA is not currently seeking a settlement with the school
district.
Comment 29: One commenter stated that the Harbourd Hills Water
District has spent in excess of $29,000 because of EPA
involvement at the Haviland Site which would not have otherwise
been spent and inquired about reimbursement.
EPA's Response: EPA acknowledges that .HHWD may have expended as
much as $29,000 during the last few years of this project.
Because of the difficulty in selecting the water source, EPA has
also utilized considerable resources in an attempt to implement
the public water supply portion of the ROD. As discussed
previously, however, we believe that significant additional funds
will not be required to ensure that the residents have a potable
supply of water.
EPA cannot reimburse Harbourd Hills for its past expenditures
because such costs are not reimbursable under the Superfund
statute.
Comment 30: The Harbourd Hills Water District Engineer asked for
an accounting for the funding spent at the Haviland Site.
EPA's Response: Approximately $2.1 million has been expended at
the Site. Over $1.4 million was expended for the following
contracted services: the RI/FS; the design and implementation of
the septic tank cleanout and associated site restoration; the
preliminary design for the provision of a public water supply;
and groundwater sampling, analysis, and modeling, and associated
reports. In addition, over $600,000 was expended for EPA
services including payroll, groundwater sampling, analysis, and
modeling, NYSDEC oversight, and indirect costs.
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14
Comment 31: One conunenter expressed concern that the public
comment period started on August 24, 1996 for a report that was
not available until two days later on August 26, 1996.
EPA's Response: EPA had expected to have the PDPP available to
the public on August 24. During the public meeting, EPA
acknowledged that the PDPP was not available in the Town Hall
until Monday, August 26. EPA considered this in the Agency's
decision to extend the public comment period an additional 30
days, allowing sixty days in all for public comment.
Comment 32: A commenter wanted to know why all of the appropriate
documents were not available at the designated repository (Hyde
Park Free Library).
EPA's Response: Following the public meeting, EPA contacted the
library and was informed that most of the information was in the
repository with the exception of a few documents; EPA forwarded
the additional documents and confirmed that they were received by
September 20, 1996. The fact that these documents were not
available at an earlier date was considered by EPA in its
decision to extend the public comment period an additional 30
days to October 23, 1996.
Comment 33: One commenter was concerned with the fact that the
notice of the 9/4/96 public meeting which was published in the
Poughkeepsie Journal was placed in the middle of the sports
section.
EPA's Response: EPA cannot always control the location of its
newspaper notices. EPA had, in fact, requested that the Public
Notice be put in the front section of the newspaper.
Unfortunately, the notice did not appear in EPA's preferred
location, and there was insufficient time to meet the
newspaper's deadline for republication prior to the public
meeting. It should be noted that EPA used other mechanisms to
make the community aware of the comment period and meeting date
including a press release, and mailing notices to each addressee
on EPA's extensive mailing list for the Site.
Comment 34: A commenter wanted to know if a ROD expires.
EPA's Response: A ROD does not expire. A ROD describes the
remedial activities required to be performed at a Site in order
to protect human health and the environment. These activities
must be implemented unless it is documented through a ROD
amendment that the actions are no longer necessary to protect
human health and the environment, or that other measures are more
appropriate to achieving protection of human health and the
environment.
Comment 35: A commenter inquired as to the source of the
information stated on page 5 of the PDPP - "...the Town recently
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15
passed a resolution stating that the Harbourd Hills Water
District facilities not be upgraded."
EPA's Response: Although the October 13, 1995 Town Resolution
(10:13-1) did not specifically state that HHWD facilities should
not be upgraded, it is implied as the following excerpt from the
resolution indicates:
"...Whereas, the upgrade to the Harbourd Hills Water
District needed to supply potable water to the Haviland
Complex will result in an undue financial burden on the
residents of the Harbourd Hills Water District" and,
"Therefore, be it resolved, that this Board urgently
requests that the United States Environmental Protection
Agency immediately proceed with the design and construction
of the water mains and appurtenances needed to provide a
reliable, potable water supply to the Haviland Complex a
connection to the Hyde Park Fire and Water District."
Comment 36: A commenter inquired if the NYSDOH and NYSDEC both
concurred with the PDPP.
EPA's Response: NYSDEC and NYSDOH had reviewed and concurred with
the PDPP prior to its release to the public. The first paragraph
of the PDPP indicates that NYSDEC concurred on the PDPP; the last
page of the PDPP indicates that the State of New York concurs on
the proposed modified remedy. During the public meeting Geoff
Lacetti, a representative from NYSDOH, reiterated NYSDOH's
concurrence with the PDPP.
Comment 37: The Harbourd Hills Water District Engineer inquired
as to what economic impact the "site" designation has upon
properties within the study area.
EPA'a Response: While EPA does not have information as to the
specific impact the designation of a Superfund site has had on
the community, in general, the value of property in the vicinity
of many Superfund sites depreciates prior to site remediation.
Fortunately, the elimination and remediation of the sources of
contamination at the Haviland Complex Site has resulted in levels
of contaminants declining to levels which approach drinking water
standards; modeling predicts that all contaminant levels will
meet drinking water standards within 1 to 6 years. As a result,
EPA will also be able to move forward with the deletion of the
Site from the NPL in the next few years. The fact that EPA and
NYSDEC are specifying in this ROD amendment that no further
remedial action is warranted at the Site, and that the Site
should be deleted in the next few years should have a positive
impact in restoring property values, assuming they had been
affected.
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APPENDIX A
Superfund Post-Decision Proposed Plan
\
Haviland Complex
Hvde Park
Dutchess County, New York
EPA
Region 2
August 1996
PURPOSE OF POST-DECISION PROPOSED PLAN
This Post-Decision Proposed Plan describes proposed fun-
damental changes to the September 1987 Record of
Decision (ROD) issued by the United States Environmental
Protection Agency (EPA) with respect to the Haviland
Complex Superfund Site and concurred on by the New York
State Department of Environmental Conservation
(NYSDEC).
The remedy specified in the 1987 ROD included the removal
of the source of contamination, i.e., contaminated septic
systems, extraction and treatment of contaminated
groundwater and the provision of public water to the study
area The source control portion of the remedy was complet-
ed in 1990.
As described in this Post-Decision Proposed Plan, EPA is
proposing that the extraction and treatment of groundwater,
and the provision of a public water system do not need to be
implemented to ensure the protection of human health and
the environment
COMMUNITY ROLE IN SELECTION PROCESS
EPA and NYSDEC rely on pubOc input to ensure that the
concerns of the community are considered in selecting an
effective remedy for each Superfund site. Similarly, EPA and
NYSDEC also rely on public input when proposing
fundamental changes to a remedy previously selected. To
this end, this Post-Decision Proposed Plan, the EPA
Groundwater Modeling Report for the Haviland Complex
Superfund Site, and the May 1995 Summary of Groundwater
Investigations Report have been made available to the public
for a public comment period which begins on August 16,
1996 and concludes on September 16,1996.
A public meeting will be held during the public comment
period at the Haviland Middle School on August 28.1996 at
7:00 PM to present the basis for the proposed amendment
to the ROD and to receive public comments.
Figure 1 - Haviland Site Map
Comments received at the public meeting, as well as written
comments, will be documented and addressed in the
Responsiveness Summary Section of the ROD amendment
All written comments should be addressed to:
Kevin Willis
U.S. Environmental Protection Agency
290 Broadway 20th Floor
New York, NY 10007-1866
Dates to remember
MARK YOUR CALENDAR
August 24,1998 - September 23,1996
Public comment period on this Post-Decision Proposed
Plan, and remedies considered
September 4,1996
Public meeting at the Haviland Middle School at 7:00 PM
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SITE BACKGROUND
The 275-acre Haviland Complex site (see Figure 1) consists
of the Haviland Complex Apartments, the Hyde Park Junior
High School, the Smith School, the Haviland Shopping
Center, and approximately 35 residences and small busi-
nesses located east of Route 9G in Hyde Park, New York.
Hyde Park has an estimated population of 21,000 people.
Approximately 20% of the population are connected to a
public sewer system, and over 50% are served by a public
or private water supply system. The remaining population,
including the 35 residences and small businesses previously
mentioned, obtain water from residential wells. Groundwater
in the study area flows southeasterly and discharges into Fall
Kill Creek,
The Dutehess County Health Department (DCHD) began to
receive complaints concerning the groundwater quality in the
site area in October 1981. A sampling program and septic
system survey of the Haviland Complex area was initiated by
DCHD in December 1981, which indicated that the Haviland-
Laundromat and Dry Cleaner and the Haviland Car Wash
septic systems were faffing. Subsequently, the car wash in-
stalled a new septic tank and the laundromat installed a pre-
treatment system and a new tile field to handle its waste-
water.
In December 1982, New York State Department of Health
(NYSDOH) began sampling the Haviland area groundwater.
The sampling data indicated that levels of tetrachloro-
ethylene (PCE) and dichloroethene (DCE) in the septic dis-
charge from the laundromat exceeded NYSDEC discharge
standards. As a result, in 1983, the laundromat was ordered
to disconnect the dry cleaning operation from the septic
system and to dispose of all spent dry cleaning fluids at a
permitted disposal facility. AD residents in the area were
advised to use bottled water. Water treatment units were
installed on the wells servicing the Havitand Apartments and
the laundromat in 1984 and 1985, respectively, to remove
organic contaminants. In February 1989, NYSDEC installed
water treatment systems on* homes with well water which
exceeded State or Federal Maximum Contaminant Levels
(MCLs). i.e., safe drinking water standards.
The site was proposed for inclusion on the National
Priorities List (NPL) in October 1984, and placed on the NPL
in June 1986. NYSDEC was designated as the lead agency
for the Remedial Investigation and Feasibility Srudy (RI/FS).
Based on the results of the RI/FS, a ROD was signed on
September 30.1987, identifying the following: 1) dean the
contaminated septic systems identified as the source of
contamination 2) extend public, water from the nearby
Harbourd Hills Water District (HHWD) to ensure a potable
supply of water to the residents en private wells (EPA would
enter into an agreement with the Town of Hyde Park to
upgrade this system to meet New York State dr.;
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standard for each of these contaminants is 5.0 ppb.
Also, in June 1994, a confirmatory round of groundwater
sampling data was collected by Ebasco which confirmed the
continued presence of very low-level VOC concentrations in
the shallow aquifer underlying the site. AB volatile concentra-
tions were dose to or below the New York State MCLs of 5
ppb for PCE, DCE, and chlorobenzene. These data indicated
that the VOCs were still present but occurred at lower
concentrations than what were observed previously. The
occurrence of the spreading of the plume described in the
Rl/FS and ROD had not occurred and the plume appears to
be naturally attenuating. This information was documented
by Ebasco in its September 1994 report entitled 'Summary
of Groundwater Investigations.*
On three successive occasions, computer modeling was
used to better understand the transport and fate of the
groundwater contamination in the study area. The first effort,
conducted as part of the Rl, concluded that groundwater
flowed from the identified sources through the area of
contaminated residential wells to the Fan KM. The second
modeling event, which was conducted by Ebasco in 1989 to
determine the optimum groundwater extraction rate for
implementation of the remedy, identified declining levels of
contamination in the aquifer.
The third modeling event was performed by EPA's Robert S.
Kerr Environmental Research Laboratory in 1992. This
effort, which focused on determining the fate and transport
of the aquifer contamination, was documented in a report
entitled 'Groundwater Modeling Report for the Haviland
Complex Superfund Site." Using 1987 and 1990 data, the
report concluded that site contamination would be below
MCLs within 5 to 10 years without pumping and treating the
contaminated groundwater. The modeling also predicted,
however, that, if implemented, extraction and treatment of
the groundwater would result in the contamination declining
to concentrations below State and Federal drinking water
standards within the same time frame of about 5 to 10 years.
Since the modeling was done in 1992, the expected range of
aquifer cleanup would be within about 2 to 7 years from
today.
In order to monitor and maintain the effectiveness of the
individual home water treatment units, NYSDEC has
contracted the sampling of the private potable wells for
organic contaminants semiannuaUy since 1989. NYSDOH
reviews and tabulates the data, and then sends the results
to the residents. Analyses of the well samples have
'demonstrated the trend of diminishing organic contamination
in the aquifer. While maximum concentrations of 79 ppb of
PCE. 190 ppb of chlorobenzene, and 27 ppb of DCE, were
measured in some residential wells in 1985.1983. and 1988,
respectively, the contaminant concentrations observed in all
of the private wells have diminished to levels near or below
MCLs. The residential well data from 1990 to the present are
summarized in Figure 2. Maximum concentrations from the
January 1996 sampling event were 15 ppb of PCE and 12
ppb of chlorobenzene with no detectable concentrations of
DCE. In addition, site-related metals contamination has not
been observed in any of the potable wells in the study area.
SUMMARY OF SITE RISK
During the conduct of the Rl/FS, a baseline risk assessment
was conducted to estimate the risks associated with current
' and future site conditions. The baseline risk assessment
which was based on data obtained during the Rl, estimated
the human health risk which could result from the contamina-
tion at the site if no remedial action were taken. A summary
of the baseline risk assessment and a recalculation of the
risk using current data is presented below.
Human Health Risk Assessment
The baseline risk assessment evaluated the health effects
which could result from exposure to contamination as a
result of mgestion. An apartment complex, a junior high
school, a shopping center, and approximately 35 private
homes are contained within the site boundaries. An are
occupied and use private wells for provision of potable
water.
EPA's acceptable cancer risk range is 10^ to 10*. which can
be interpreted to mean that an individual may have one in
ten thousand to one in a million increased chance of
developing cancer as result of site-related exposure to a
carcinogen over a 70-year lifetime under the specific
exposure conditions at the site.
The results of the baseline risk assessment conducted as
part of the 1987 Rl/FS indicated that, if used as a supply of
household water, the groundwater at the site posed unac-
ceptable risks to human health and the environment The
risk assessment was indicative of a worst case total lifetime
exposure to maximum organic concentrations at an assumed
constant rate (drinking 2 liters of water daily for 30 years in
an adult living to the age of 70 years). It was determined that
the total cancer risk exceeded 1x10°, or 1 case in 1000.
Most of this risk was due to the presence of vinyl chloride
which has not been detected since 1987. Eliminating vinyl
chloride from the risk assessment results in a calculated
carcinogenic risk that is within EPA's acceptable risk range.
Using current data, and applying these data to present
standards (which a * more stringent than those of 1987). the
carcinogenic risk is calculated to be1.1 x 10J. which is within
EPA's acceptable range.
To assess the overall potential for noncarcinogenic effects
posed by more than one contaminant EPA has developed
a hazard index (HI). This index measures the assumed
exposures to several chemicals simultaneously at low
concentrations which could result in an adverse health effect.
When the HI exceeds one. there may be concern for
potential noncarcinogenic effects.
All noncarcinogenic contaminants were within acceptable
intake levels in 1987. based on their respective subchronic
and chronic intakes. Using current data, and applying these
data to present standards (which are more stringent than
those of 1987), results in a noncarcinogenic risk Hazard
Index of 1.
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It is noted that the only exposure routes to humans at the
site are through ingestion and inhalation of VOCs via the
contaminated groundwater. However, those residences
which did exceed MCLs have been supplied with whole-
house water treatment units. Furthermore, the levels of
contamination observed in 1987 have now diminished to
levels near or below MCLs in both monitoring wells and
residential wells.
REMEDIAL ACTION OBJECTIVES
Remedial action objectives are specific goals to protect
human health and the environment These objectives are
based on available information and standards such as
applicable or relevant and appropriate requirements
(ARARs) and risk-based levels established in the risk as-
sessment
The objective of the feasibility study was to identify and1
evaluate a cost-effective remedial action alternative which
would minimize the risk to public health and the environment
resulting from groundwater contamination at the site. The
F5 report had evaluated in detail 5 remedial alternatives for
addressing tiie contamination associated with the site. The
remedy which EPA selected included contaminant source
control, provision of public water to the site area, and extrac-
tion and treatment of contaminated groundwater. As noted
above, the source control portion of the remedy was
completed in January 1990.
Given the decrease in site-related groundwater contaminant
levels, EPA has decided to reevaluate components of the
remedy specified in the 1987 ROD. This Post-Decision
Proposed Plan addresses the groundwater extraction and
treatment and the provision of an alternate water supply
portions of the remedy. The remedial action objectives for
the groundwater remedy are to (1) protect human health by
ensuring residents are not exposed to contaminated
groundwater, and (2) reduce groundwater contamination
levels to drinking water standards. The remedial action
objective for the alternate water provision portion of the
remedy is to protect human health by ensuring residents are
ret exposed to contaminated residantial well water.
SUMMARY OF REMEDIAL ALTERNATIVES
CERCLA requires that each selected site remedy be protec-
tive of human health and the environment be cost-effective,
comply with other statutory laws, and utilize permanent
solutions and alternative treatment technologies and
resource recovery alternatives to the maximum extent
practicable. In addition, the statute includes a preference for
the use of treatment as a principal element for the reduction
of toxicity, mobility, or volume of the hazardous substances.
Tne alternatives 'or addressing groundwater contamination
are provided below and are identified as GW-1 and GW-2.
These alternatives are followed by the alternate .vater supply
alternatives which are identified as AW-1 and AW-2.
Consistent with ROD amendment guidance, the components
of the original remedy proposed for amendment (alternatives
GW-2 and AW-2) have been updated and are being
compared to new preferred alternatives (alternatives GW-1
and AW-1) which were developed based upon existing site
circumstances, including the groundwater monitoring and
modeling data presented above. It should be noted that the
time to implement reflects only the time required to construct,
or implement the remedy and does not include the time
required to design the remedy, negotiate with the responsible
parties, or procure contracts for design and construction.
The alternatives developed for the site orounowater
-------
would be discharged to the Fall Kill. Worst-case emissions
from the stripper were calculated to be insignificant in
comparison to New York State standards. The design of the
groundwater treatment system would be based on SPDES
requirements which would be the more stringent of the
effluent limitation for a class C water body or the water
quality limitation for the Fall Kill.
Groundwater extraction and treatment offers long-range
public health protection against consumption of contaminat-
ed groundwater. Based on site hydrogeologic conditions,
the time required to rehabilitate the aquifer to acceptable
State and Federal drinking water standards is estimated to
be within 2 to 7 years.
Aquifer rehabilitation would be accompanied by an annual
groundwater monitoring program. The sampling and
analysis would utilize selected monitoring wells located in the
study area. Analytical data obtained from these wens would
serve to demonstrate the progress of the aquifer
remediation. Groundwater samples would be analyzed for
inorganic and volatile organic parameters.
The alternatives developed for an alternative water suootv
(AW are:
Alternative AW-1 - No 'Further Action/Continue to
Maintain Whole-House Water Treatment Units
Capital Cost $0
O & M Cost S27,053/year (for 10 years)
Present Worth Cost $166,082
Time to Implement immediate
This alternative would continue to address the low level
contamination present in the seven affected homes by
maintaining the existing whole-house filters presently
installed in these homes. The units consist of a sediment
fitter, an ultra-violet treatment unit and twin activated-carbon
filtration cylinders. These homes have been sampled semi-
annually by the NYSDEC; the sampling results indicate that
the units are working quite effectively and have provided a
safe reliable source of water for residential use. These units
have operated effectively while requiring minimal mainte-
nance.
Water in these seven homes would continue to be monitored
on a semi-annual basis. The units would be maintained by
NYSDEC until three years of consecutive semi-annual
rounds of sampling demonstrate that the well 'water meets
Federal and State drinking water standards indicating that
treatment will no longer be necessary.
Alternative AW-2
Area
Provision of Public Water to Study
Capital Cost S3.147.969
O & M Cost SO
Present Worth Cost 53,147.969
Time to Implement 18 months
This alternative provides for the extension of a local public
water system into the study area. The ROD originally
envisioned that EPA would enter into an agreement with the
Town of Hyde Park (THP) to share in the costs to upgrade
the Harbourd Hills Water District Well water treatment
system to meet NYSDOH standards. It is noted, however.
because of residents' concerns about incurring casts
associated with upgrading the Harbourd Hills Water District
(HHWD) treatment facilities, the Town recently passed a
resolution stating that the HHWD facilities not be upgraded.
Furthermore, the Town of Hyde Park has requested that the
Hyde Park Fire and Water district (HPFW) be utilized as the
water source. The water distribution network would be the
same as that described in the ROD. The distribution system
would be installed along the Haviland Road and Wright
Avenue, and connections would be made by EPA from this
distribution system to residences in the study area. This
network would be connected to HPFW at a point
approximately one-half mite away.
EVALUATION OF ALTERNATIVES
During the detailed evaluation of remedial alternatives, each
alternative is assessed against nine evaluation criteria.
namely, overall protection of human health and the envi-
ronment, compliance with applicable or relevant and
appropriate requirements, long-term effectiveness and
permanence, reduction of toxicity, mobility, or volume, short-
term effectiveness, imptementabilrty. cost, and state and
community acceptance.
The evaluation criteria are described below.
o Overall protection of human wealth and the envi-
ronment addresses whether or not a remedy pro-
vides adequate protection and describes how risks
posed through each pathway are eliminated, reduc-
ed, or controlled through treatment engineering
controls, or institutional controls.
o Compliance with applicable or relevant and appro-
priate requirements (ARARsl addresses whether or
not a remedy will meet all of tht applicable or
relevant and appropriate requirements of other
federal and state environmental statutes and re-
quirements or provide grounds for invoking a waiver.
o 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
0 Reduction of toxicitv. mobility, or volume through
treatment is the anticipated performancs of the treat-
ment technologies a remedy may employ.
o 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 imple-
mentation period until cleanup goals are achieved.
-------
o Imolementabilitv is the technical and administrative
feasibility of a remedy, including the availability of
materials and services needed to implement a
particular option. .
o Cost includes estimated capital and operation and
maintenance costs, and net present worth costs.
o State acceptance indicates whether, based on its
review of the RI/FS reports and Post-Decision Pro-
posed Plan, the state concurs, opposes, or has no
comment on the preferred alternative at the present
time.
o Community acceptance wiO be assessed in the
Record of Decision (ROD) following a review of the
public comments received on the RI/FS reports and
the Post-Decision Proposed Plan.
A comparative analysis of these alternatives based upon the
evaluation criteria noted above follows.
Groundwater
o Overall Protection of Human Health and the Envi-
ronment
Both Alternatives GW-1 and GW-2 would provide fuO
protection to human health and the environment Modeling
predicts that the active extraction and treatment of the site
groundwater would result in contaminant levels being
reduced to State and Federal groundwater and drinking
water in 2 to 7 years. Modeling of the natural attenuation
alternative also predicts that the ARARs would be achieved
in 2 to 7 years. Nonetheless, the extraction and treatment of
the groundwater under Alternative GW-2 may provide a
slightly more rapid removal of contamination from the aquifer
than the natural attenuation process of Alternative GW-1.
The exposure route to the people at the site is through
ingestion of groundwater or the inhalation of volatile
contaminants from the groundwater. Private wells which
contain levels of contaminants above drinking water
standards have been fitted with individual water-treatment
units, thereby ensuring a safe supply of potable water. The
levels of contaminants entering these wells has been
decreasing, and sampling of the water prior to and after
treatment from these units indicates that the units are
working effectively.
O Compliance with ARARs
Beth alternatives would comply with ARARs in approximately
the same time frame. Modeling predicts that the no further
action/natural attenuation Alternative GW-1 and the active
groundwater extraction and treatment Alternative GW-2
would result in contaminant levels being reduced to State
and Federal groundwater and drinking water standards in 2
to 7 years.
Long-Term Effectiveness
Permanence
Alternatives GW-1 and 3W-2 would be equal in providing
long-term effectiveness and permanence in that trie
groundwater contamination would be reduced below State
and Federal drinking water standards within 2 to 7 years.
Alternative GW-2 would potentially result in greater long-term
exposure to contaminants by workers who could come into
direct contact with the concentrated sludges from the
treatment system. However, proper health and safety
precautions would be implemented to minimize exposure to
the sludges.
o Reduction in-Toxicitv. Mobility or Volume
Under both alternatives, the volume and toxicity of the
groundwater contaminants above ARARs would be reduced
at approximately the same rate and would ultimately be
eliminated in approximately the same time frame.
The mobility of the contamination plume would.be reduced
by actively extracting the groundwater under alternative GW-
2. It is assumed that even with the active groundwater
extraction, some contamination would migrate into the FaB
Kill, but a lesser amount than under the natural flushing
conditions of Alternative GW-1. It is noted that sampling of
the Fall Km indicates that levels of the contaminants
reaching the creek do not pose a threat to human health and
the environment
0 Short-Term Effectiveness
There would be virtually no short-term impacts on human
health and the environment by continuing to maintain the
residential water treatment units under Alternative GW-1.
Also, because the residential water treatment units are
already installed, no time would be required to implement
this alternative. However, construction activities associated
with Alternative GW-2 (e.g., installation of extraction wells
and underground piping, and construction of the treatment
unit) would have potentially negative impacts on residents in
the study area. While efforts would be made to minimize
these impacts, some disturbances to residents would result
from disruption of traffic, excavation activities on public and
private land, noise, and fugitive dust emissions. It is
estimated that the construction activities for Alternative GW-
2 would take approximately one year to complete.
o Implementabflttv
The technologies proposed for extracting and treating
contaminated groundwater in Alternative GW-2 are proven
and reliable in achieving the specified cleanup goals.
however. Alternative GW-2 would be much more complex
than Alternative GW-1 to implement The design and
construction of the grcundwater extraction system would
take approximately 2 years to complete. Alternative GW-2
would require that property be acquired/leased for the
treatment unit and that access/easements be obtained from
private and public property owners for the installation of
piping and extraction wells. The operation and maintenance
of the system would include the monitoring of the aquifer for
system effectiveness, monitoring of the system emissions
to determine compliance with permit equivalencies, and the
handling and disposal of the concentrated contaminated
treatment residuals.
-------
Alternative GW-1 would be more easily implemented, as it
would only require the sampling of selected monitoring wells
once a year.
Alternative GW-1 has no direct costs associated with its
implementation. The present worth of this alternative of
S24.873 is for implementation of an annual groundwater
monitoring program. The capital and present worth costs of
Alternative GW-2 are estimated to be approximately
$625,500 and S1.2Q5.-i39 respectively.
Both alternatives would provide a similar level of protection
in a similar time frame, however. Alternative GW-1 would do
so at a much lower cost
o State Acceptance
4
The State of New York concurs on the proposed modified
remedy.
0 Community Acceptance
Community acceptance of the preferred alternative wiB be
assessed in the ROD amendment following review of the
public comments received on this Post-Decision Proposed
Plan. '
Alternate Water Supply
o Overall Protection of Human Health and the Envi-
ronment
Both Alternatives AW-1 and AW-2 would provide full pro-
tection of human health. Both alternatives would prevent the
potential exposure of residents at the site through ingestion
or inhalation of contaminants present in selected residential
wells. Data from the sampling of the impacted residential
wells has shown that the whole-house treatment units
installed at these residences are fuDy effective and provide
sustained protection with minimal maintenance.
The provision of public water to the site area described in
Alternative AW-2 would not be more protective to the
residents than what presently exists, but would preclude the
need for future sampling and maintenance of the impacted
wells.
o Compliance with ARARs
Alternatives AW-1 and AW-2 would both comply with
ARARs, the primary ARARs of concern being State and
Federal drinking water standards. Neither Alternative AW-1
nor AW-2 would provide a significant advantage over the
other with respect to ARARs.
Compliance with ARARs under Alternative AW-1 would be
demonstrated via the home sampling and filter maintenance
crogram. Compliance with ARARs under Alternative AW-2
would be demonstrated by the water supplier via regular
sampling of the water distribution system as required by the
State of New York.
o Long-Term Effectiveness and Permanence
Because groundwater contamination is estimated to be
completely attenuated within 2 to 7 years, site-related
contaminants would not be expected to impact the residential
wells over the long term. Therefore, both alternatives would
provide long-term protectiveness and permanence.
o Reduction in Toxidty. Mobility, or Volume
A comparison of the two alternatives' abilities to satisfy this.
criterion is not necessarily applicable since the goalof the
alternate water supply is to provide a potable supply of water
and does not require that the tenacity, mobility or volume of
contaminants be reduced to da so. Nonetheless. Alternative
AW-1 would reduce the tenacity, mobility and volume of
contaminants in the residential weD water, and to a limited
extent the aquifer. Alternative AW-2 would not provide any
reduction of contaminants.
o Short-Term Effectiveness
There would be virtually no short-term impacts to human
health and the environment by continuing to maintain the
residential water treatment units under Alternative AW-1.
Also, because the residential water treatment units are
already installed, no time would be required to implement
this alternative. However, construction activities associated
with Alternative AW-2 (e.g., installation of underground
piping) would have potentially negative impacts on residents
in the study area. WhBe efforts would be made to minimize
these impacts, some disturbances to residents would result
from disruption of traffic, excavation activities on public and
private land, noise, and fugitive dust emissions. It is
estimated that the construction activities for Alternative AW-2
would take approximately one year to complete.
o Imolementabifihf
Alternative AW-2 would require the design and construction
of a public potable water distribution system and its connec-
tion to HPFW. The system would take approximately 18
months to construct The technologies necessary for
implementing this alternative are proven and reliable.
The implementation of Alternative AW-1 would require the
continued monitoring and maintenance of the home filtration
units.
o Cost
Alternative AW-1 provides a similar level of protection as
Alternative AW-2 but at a much tower cost AW-1 has no
direct capital costs associated with its implementation. The
present worth cost of AW-1 is $166,082 is based on annual
costs of 527,053 per year for the semi-annual sampling and
maintenance of the whole-house treatment systems.
The total cost of Alternative AW-2 is estimates to be
approximately 53.147.969. The capital cost is based on the
-------
cost of connecting to HPFW which is estimated to be
$848,969 and construction of the distribution system is
estimated to be S2.299.000. White EPA and the NYSDEC
would not incur any operating or maintenance expenditures
under Alternative AW-2. residents connected to the system
would have to pay for the water received, which is estimated
to be approximately $200 to $400 per year.
o State Acceptance
The State of New York concurs on the proposed modified
remedy.
o Community Acceptance
Community acceptance of the preferred attemative wiB be
assessed in the ROD amendment following review of the)
public comments received on this Post-Decision Proposed
Plan.
PREFERRED ALTERNATIVE
Based upon an evaluation of the various alternatives. EPA
and NYSDEC recommend Alternative GV\M. No Further Ac-
tion/Natural Attenuation, and AW-1. No-Further
Action/Continue to Maintain Whole-House Filter Systems.
The Post-Decision preferred attemative provides the best
balance of tradeoffs among alternatives with respect to tf»
evaluating criteria. EPA and the NYSDEC befeve that the
preferred alternative win be protective of human health and
the environment, will comply with ARARs. win be cost-
effective, and win utilize permanent solutions and alternative
treatment technologies or resource recovery technologies to
the maximum extent practicable.
-------
8 Haviland Road
lOHaviland Road
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40
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12 Haviland Road
. 14 Haviland Road
50
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-------
20 Haviland Road
22 Haviland Road
50
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6.0
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24 Haviland Road
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-------
From: P. N. Prentice To: EPA in NYC Date: 8/30/96 Time: 10:48:12 Page 1 of 1
P.N. Prentice
29 Lawrence Rd.
Hyde Park, NY 12538-2429
August 30,1996
Mr. Kevin Willis
US-EPA 20th Floor
290 Broadway
New York, NY 1007-1866
Dear Sir:
The Harbourd Hills Water Advisory Committee is composed of 8 members who live
in the district and are appointed to the committee by the Hyde Park Town Board.
The members monitor the affairs of the district and advise the Town Board on
matters related to the operation of the district when the occasion demands that.
The notice for the 9/4 [Haviland Area in Hyde Park] meeting appeared in the
Poughkeepsie Journal on 8/26 in the middle of the sports section. The committee
feels that this was a poor choice of location [some people don't read the sports
section] and asks that the notice be repeated before the 9/4 meeting to insure that
residents and other interested parties are properly notified.
The committee also noted that there has been previously published data on heavy
metals in the water samples, but no information appeared in your report at a detail
level given to VOC's. We ask that a graphical representation of heavy metals over
time be given the same presentation as VOC's were given.
It was also interesting to note that your report appeared in the Hyde Park Town
Clerk's office late in the day on 8/26 and announced that the comment period
started on 8/24.
Sincerely yours,
ftt
P. N. Prentice
Executive Secretary to the Committee
914-229-2995 Fax by prior arrangement [I have to turn the computer on]
cc/ Hyde Park Town Board..
-------
P.M. Prentice
29 Lawrence Rd.
Hyde Park, NY 12538-2429
Septembers, 1996
Mr. Kevin Willis
US-EPA 20th Floor
290 Broadway
New York, NY 1007-1866
Dear Sir:
Following the advice you gave last night I went to the Hyde Park Free Library to
search out he documents you said were deposited there. With the help of the
Librarian we found the large report dated 1987 (I think July) and the report which
was a copy of that given to the Hyde Park Town Clerk on 9/26/96.
Where is the information for the period between 1987 and 1996? Please advise
soonest as the comment period ends 9/23.
Sincerely yours,
P. N. Prentice
Executive Secretary to the Committee
cc/ Hyde Park Town Board..
Mr. Soya
Mr. Cain
HPF&W
Hyde Park School District Buildings and Grounds
-------
P.N. Prentice
29 Lawrence Rd.
Hyde Park, NY 12538-2429
September 7, 1996
Mr. Kevin Willis
US-EPA 20th Floor
290 Broadway
New York, NY 1007-1866
Dear Sir:
Please include this letter and my letter of 9/5/96 in the matter of record on the
Haviland site Hyde Park NY.
When your 8 page report became available at the Hyde Park Town Clerk's office
I obtained a copy and noted what I then believed to be an inaccurate statement
on page 5 [copy enclosed] which I quote in part..."... the Town recently passed a
resolution stating that the HHWD facilities not be upgraded."
I faxed a request to the Hyde Park Town Hall on 8/29/86 [copy enclosed] and
received pages from the official minutes of the meetings on 10/13/96 [page 245 -
note resolution 10:13-1 of 1995] and meeting 2/26/96 [page 63 - note resolution
2:26-14 of 1996]. These resolution do not support your statement.
This is all of the record I am aware of which would have any relevance to your
statement quoted above. I continue to believe your statement is inaccurate.
Can you support your statement "... the Town recently passed a resolution
stating that the HHWD facilities not be upgraded?"
Sincerely, yours,
P. N. Prentice
Executive Secretary to the Committee
cc/ Hyde Park Town Board-
Mr. Soya
Mr. Cain
HPF&W
Hyde Park School District Buildings and Grounds
HH Advisory Committee
-------
From: P. N. Prentice To: EPA in NYC Oate: ansiao time: io.-«<...
P.M. Prentice
29 Lawrence Rd.
Hyde Park, NY 12538-2429
September 15,1996
Mr. Kevin Willis
US-EPA 20th Floor
290 Broadway
New York, NY 1007-1866
Dear Sir:
Got your notice about comment period being extended until Oct. 23rd in the matter
of the Haviland Area of Hyde Park, NY. Thank you.
Would you please advise when you will place additional materials in the Hyde Park
Free Library so that I will not have to bother the library every day to find out when
these "new" materials are available?
914-229-2995
Thank you.
Sincerely yours,
P. N. Prentice
Executive Secretary to the Committee
cc/ Hyde Park Town Board..
Mr. Soya
Mr. Cain
HPF&W
Hyde Park School District Buildings and Grounds
-------
P.M. Prentice
29 Lawrence Rd.
Hyde Park, NY 12538-2429
added September 24,1996
Note my letter of Sept. 15,1996 following.
I visited the library today and was told no information has been added to the 1987
material discovered before.
What are your intention and when are your intentions. I note the comment period
ends 10/23/96
Please add all of this to the record as a comment.
September 15,1996
Mr. Kevin Willis
US-EPA 20th Floor
290 Broadway
New York, NY 1007-1866
Dear Sir:
Got your notice about comment period being extended until Oct. 23rd in the matter
of the Haviland Area of Hyde Park, NY. Thank you.
Would you please advise when you will place additional materials in the Hyde Park
Free Library so that I will not have to bother the library every day to find out when
these "new" materials are available?
914-229-2995
Thank you.
Sincerely yours,
P. N. Prentice
-------
Harbourd Hills Water Advisory Committee
Hyde Park, NY 12538-2429
Octobers, 1996
Mr. Kevin Willis
US-ERA 20th Floor
290 Broadway.
New York, NY 1007-1866
Dear Sir:
RE: Your report titled "Superfund Post-Decision Proposed Plan Haviland
Complex Hyde Park Dutchess County, NY" dated "August 1996."
The Harbourd Hills Water Advisory Committee is composed of 8 members who
live in the district and are appointed to the committee by the Hyde Park Town
Board. The members monitor the affairs of the district and advise the Town Board
on matters related to the operation of the district when the occasion demands
that.
When the Harbourd Hills Water District was formed [and the Harbourd Hills Water
Advisory Committee established] it did not include the Haviland Road and
Haviland Shopping center. A short time later, the discovery of pollution in that
area caused the Town of Hyde Park to expand the Harbourd Hills Water District to
include these two areas in anticipation of providing water to these residents.
The ROD [Record of Decision] when published established the EPA as a source
of help and funding to expand water system distribution and refurbish the water
plant to accommodate the new area. The committee hired [[with the approval of
the Town of Hyde Park] an engineer to work with the district and the EPA on the
best method to accomplish this task. Since the existing well/plant site was too
small to accommodate the needed water treatment facility other alternatives were
investigated and this finally culminated in the concept of an association [a tenant
would be accurate] with Hyde Park Fire and Water (HPF&W) as a source of
supply. This was also the least expensive.
Part of this decision was predicated on the late understanding of the restrictions
on the EPA funding which would have placed a considerable burden on the
existing 250 families in our district who would have to sustain the bond debt of the
expansion while exempting the Haviland Road expansion. The most reasonable
course of action to our district would have been to take advantage of the
connection to Hyde Park Fire and Water at the Haviland Road area and build
supporting facilities in our district such as a storage tank. Haviland Road would
also benefit from this improvement as it would level the demand for water which
would also make the water less costly to our district as well as the Haviland Road
area.
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Harbourd Hills Water Advisory Committee
Hyde Park, NY 12538-2429
A water supply from Hyde Park Fire and Water would also enable the Haviland
Middle School to purchase water rather than sustain a significant capital expense
to replace and refurbish equipment in the school which is at or near the end of
life. Further a public supply would enable the school district to avoid the expense
of maintenance and testing of its supply. The existing school well furnished not
only Haviland Middle School, but also Ralph R. Smith Elementary School [near
by] and the bus garage complex [also near by]. It should be noted that the well
used by the school is deep, and while historically isolated from the pollution
above, the school officials still worry about possible future contamination. (The
undersigned is an ex- member of the Hyde Park School Board whose three year
term expired last July 1 st and thus has knowledge of this subject.)
The committee has noted that if the present Harbourd Hills water district is
required to service our existing service area as well as the Haviland Road,
possibly some Wright Ave., Haviland Apartments and shopping center, and the
Haviland school complex then our well yield capacity would be strained. An
alternate source would be much preferred. The yield test for Harbourd Hills
Wells has not been recently done to establish safe yield plus reserve. The
wells are close together with one shallow and one deep. There has been
observed interaction between them in that pumping one causes the cone of
depression on the other to draw down. No tests have been done to establish
the safe yield when both are pumping at maximum capacity.
The committee notes there has been a long history of reports, letters, meetings,
which have all been supportive in a general way of EPA funding for this area. Our
district has formulated our plans and done our engineering work with the
underlying assumption of EPA funding and involvement. Our Engineer estimates
our district has spent something in excess of $29,000 because of EPA
involvement that would have otherwise not been spent or spent for other work.
Can we be reimbursed? It was noted at the meeting on Sept. 4th that the $2.1
million dollars you claim to have spent would have been sufficient to connect to
HPF&W and thus end the matter.
The committee has several questions:
The graphs [pollution levels at various Haviland Road houses] presented at
the meeting on 9/4 were more recent.than those published in the August 1996
report. Why were these not made available to our committee and the public?
The heavy metals report circa 1992 had elevated levels of Cr. and Ni. in
excess of NYS DOH standards. At the meeting you claimed to have done later
analysis. Where are those reports? If heavy metals are in the background soil
why not sample the soil to determine if this is so and clear up the matter
regarding heavy metals?
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Harbourd Hills Water Advisory Committee
Hyde Park, NY 12538-2429
Why did the comment period start on 8/24 for a report that was not available
until two days later on 8/26?
The Hyde Park Free Library was announced at the 9/4 meeting as being a
source of information. When we visited the library the most recent information
was 1987 and the report caption above. Where is the rest of the data?
The statement on page 5 of the above captioned report which I quote in part...
"...the Town recently passed a resolution stating that the Harbourd Hills Water
District facilities not be upgraded." The official minutes of the meetings on
10/13/96 [page 245 - note resolution 10:13-1 of 1995] and meeting 2/26/96
[page 63 - note resolution 2:26-14 of 1996] do not support your statement.
Where did you get your information from?
Why was the EPA notice of the 9/4 meeting published in the Poughkeepsie
Journal placed in the middle of the sports section [not read by all] and why did
you not publish a second notice when this was brought to your attention? The
announcement should have been placed in the legal notices.
When the Town councilman for our district and the secretary to the committee
visited all the homes on Haviland Road and Wright Ave. we were informed that
some of the houses had not been tested in years. This is curious because your
foil of the computer model showed the pollution plume extending to Wright and
yet there were no plans to test again. What plans do you have for a
comprehensive test before electing to abandon support for the area? Further,
we obtained selected pages from a report titled "Groundwater Modeling at the
Haviland Complex site, Hyde Park, NY" prepared by Milovan S. Beljin, Ph.D.
and dated Dec. 1992. The Hyde Park Free Library was not the source of this
report access. Page 14 of this memo states, "Figure 20 indicates that even
after 10 years, concentration levels of tetrachloroethene will not decrease
below 10 ppb level." [this was for one set of assumptions] Figures 20-31 show
projections of various other organic compounds at contour levels of 5 and 10
ppb after 2, 5, and 10 year intervals. All tend to show concentrations near or
at the east end of Haviland and Wright Ave-. [just before Bill Reynolds Blvd.]
Do you believe this computer simulation and if so why have you not tested in
this area?
The NYS DOH and the DEC all signed the ROD. The committee has not seen
any documentation from those parties relative to your information that they
support the EPA position. Can you supply this?
At the 9/4/96 EPA meeting in response to the question about the ROD, EPA
claimed that it did not expire. The ROD itself has language suggesting it
expires in 1997. Please explain this apparent discrepancy?
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Harbourd Hills Water Advisory Committee
Hyde Park, NY 12538-2429
Why did you fail to respond to the secretary's letters of 8/25/96 [[newspaper
notice], 8/30/96 [request for recent analysis data], 9/5/96 [Hyde Park Free
Library not a source], and 9/7/96 [inaccurate statement in above captioned
matter]?
It would be reasonable to provide interested parties with up-to-date
documentation and hold another information meeting before a final decision is
made.
You must have learned from the meeting on 9/4/96 that the residents of Haviland
Road and Wright Ave. are still concerned about their water. Their concern could
be closed by a connection to HPF&W with your support. The remaining part of the
district would also benefit.
Please reconsider your pending action.
Sincerely yours,
P. N. Prentice
Executive Secretary to the Committee
cc/ Hyde Park Town Board-
Mr. Soyka District Engineer
Mr. Cain System Operator
Hyde Park Fire and Water District
Hyde Park School District Buildings and Grounds
Scott Chase Dutchess County Water and Waste Water
NYS DEC
NYS DOH
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J^D. F. WhEElER EwqiNEERS, RC.
55 NoBri BaoAdwAy Red Hook, New Yoik 12571 (914) 75&-J926 FAX (914) 758-J768
September 19, 1996
Kevin Willis
US-EPA
290 Broadway, 20th Floor
New York, NY 10007-1866
RE: Haviland Superfund Site
96-200.3
Dear Mr. Willis:
This office in its capacity as a Town Engineer for several
municipalities and as a former Town Engineer for the Town of
Hyde Park, has some viable experience with this site. There
are, however, several issues that in our opinion remain
open. They are: ,
* The heavy metal question. This area was a very
significant question from zhe inception of the project
inception, through the ROD development, and up until
several months ago. This office would recommend
split-spoon soil sampling to determine the accuracy of
the statement of the pre-existence of heavy metals. A
soil analysis would be required in our opinion to
eliminate any doubt about the existence of 'the heavy
metals.
.* Small statistical sampling population. The sample
population for the poillution plume needs to be
expanded to find the real edge of the pollution pluae.
It is our opinion that the sample size needs to be
substantially increased.
* The question of the contribution of the Eaviland Road
School to the pollution. It is our understanding that
the School District has been formally notified that it
is a PRP. Has the EPA changed it's view of the
responsibility of the School District.
Finally, while there has been a certain amount of avoidance
cf responsibility on all sides of this issue, we believe it
would be fair to say that the Town of Hyce Park in the past
several years has taken the lead in addressing and attacking
-------
D.F. WHEELER ENGINEERS, P.C.
Haviland Superfund Site
this problem. Also, we feel that while nature has
remediated some of the materials (i.e. VOC's), the heavy
metals remain a serious and enduring health concern. We
also feel that a.cursory review of the metals question does
not support the contention that they are pre-existing.
It is our position that the situation has not changed
substantially at the Haviland complex and that the
obligation to the residents remains. Therefore, the ROD
should be executed.
Should you have any questions,
contact this office.
please do not hesitate to
Very truly yours,
D.F. WHEELER ENGINEERS, P.C.
F. Wheeler, P.E'
Consulting Engineer
DFW\cb .
cc: Supervisor Spence and Town Board
-------
ATCR AND
ASTEWATER AUTHORITY
October 22. 199$
27 High Street
Poughkeepsie
New VWc 12601"
(914)486-3601
Fax (914)486-3610
E-mafc dc29mhv.net
Mr. Kevin Willis
U.S. Environmental Protection Agency
290 Broadway, 20th Floor
New York. NY'10007-1868
Vto
Beg»rPAk*er.
R2: Haviland Complex
Superfund Post-Decision Proposed Plan
Dear Mr. Willis:
The Dutchess County Water and Wastewater Authority
is a public benefit corporation formed in 1992 by the
New York State Legislature and the Dutchess County
Legislature. The Authority's charge is to address
issues of adequacy of water supply and wastewater
treatment throughout the County.
Authority staff has reviewed available materials
«nagnm. KE_ us. regarding the Haviland Complex Superfund Post-Decision
Proposed Plan, and attended the ZPA's Public Hearing on
this proposed plan, held on September 4, 1996. Our key
concern with the proposed plan is to what degree the
proposed alternatives (GW-l and AW-i) provide adequate
protection for snail businesses and homes east of Route
96 which are not currently supplied with whole house
treatment systems, particularly the additional hcmes on
Haviland Avenue and those homes on the eastern end of
Wright Ave.
MncMC.Panga.CPA
Sag
SC3BC-Ch»3«
The evaluation of the alternatives and the
justification for selecting Alternatives AW-l and GW-l,
focus on the homes with whole house treatment system,
to the exclusion- of those homes with out treatment
systems:
The evaluation of Alternative GW-l regarding
Overall protection of human health and tho
environment" assumes actual human exposure will not
occur in the 2-7 years until groucdwater meets MCL's
due to Tiyggencg of fygat^Tngnr iir^ig- The evaluation
does not address the possibility of contamination of
other wells in residences not presently equipped with
treatment systems.
The evaluation of AlLemative AW-l regarding "Oversll
protection of human health and the environment" would
. . .prevent the potential exposure of residents at the
site through ingestion of contaminants present in
gl w»\is« (emohaais added) , based on
-------
effectiveness of whole house treatment units. Once again, the
evaluation appears to not address the residences with out
treatment systems.
The exclusion of the additional residences within the
Haviland Complex site seems to be based on an assumption that,
since these residential wells did not show contamination in the
past, they will not do so in the future. The Validity of this
assumption seems open to question for the following reasons; lack
of current sampling data, variability of the sampling data,
accuracy of modeling and the lack of.future monitoring.
Lack of monitoring data for additional residences: If a low
level volatile plume is in fact moving south easterly from the
Haviland Shopping Center and Haviland Complex Apartments area, it
seems possible that additional homes on Haviland Avenue and homes
on Wright Avenue may be at risk of contamination. It is unclear
when the last time residential wells of homes without treatment
units were sampled, but it -appears that many have not been
sampled in over three years.
Variability in sampling data: The concern regarding the
lack of recent sampling data for residential wells without
treatment units is heightened by the high variability in sampling
results for the residential wells on Haviland Road, which have
been sampled semi-annually since 1989. Specifically:
- At 10 Haviland Road PCE levels went from 3 ppb to 11 ppb
in 4 months (1990),
- At 14 Haviland Road CBZ levels went from 0 to 21 ppb in 6
months (1995),
- At 20 Haviland Road PCE level went from 10 to 41 ppb in 9
months (1991), and CBZ levels went from 8 to 35 ppb in 9
months (1991) and from 0 to 13 ppb in 4 months (94-95),
- At 22 Haviland Road DCE levels went from 0 to 5.6 ppb in 4
months (93-94), and CBZ levels went from o to 11 ppb in 4
months (93-94),
- At 24 Haviland Road PCE levels went from 0 to 27 ppb in 4
months (93-94), and CBZ levels from 0 to 10 ppb in 6
months (1995).
lu appears from this data that distribution of contamination
levels within the plume are far from uniform, and that levels of
contamination at any particular point can easily vary from non-
detectable to above MCLs in a relatively short time period. This
raises questions as to whether the limited testing done on
additional residential wells is adequate to support an assumption
that they are not currently, and will not in the future, be
impacted by contamination.
!
In contrast to the amount of sampling data upon which EPA is
basing a decision to take no further action on homes without
treatment units, Alternative AW-1 anticipates maintenance of the
-------
treatment units until 3 years of consecutive semi-annual rounds
of sampling (i.e. 6 samples over 3 years) meet MCLs.
Accuracy of modeling: Modeling based on 1987 and 1990 data
predicts that the contamination .plume will not impact additional
residential wells. However, modeling is not an exact science; it
predicts a range of future outcomes based on current conditions.
But conditions can change; for example, changes in water table
conditions or water withdrawals could change the direction of
groundwater flow. As stated above, there is a great deal of
variability in the sampling results,- how might this impact the
reliability of the modeling?
For these reasons, it would seem prudent for EPA to conduct
at least one more round of. testing of all of the residential
wells with in the Haviland Complex site and downgradient of the
aource prior to making a final decision regarding appropriate
remedies.
4
In the event that EPA determines to select remedies GW-l and
AW-i, we recommend ongoing monitoring, at least annually, of
residential wells which do not have home treatment units as part
of the monitoring plan. Currently, Alternative AW-l anticipates
semi-annual monitoring of all homes with treatment units, and
maintenance of units, until 3 years of consecutive semi-annual
rounds'of sampling meet MCLs. No additional monitoring is
recommended for the "non-treatment" homes.
In addition, monitoring wells should be sited both
upgradient and down gradient of homes on Haviland Avenue and
Wright Avenue to insure the detection of any contaminant plume
that may impact the non-treatment homes. Alternative GW-l calls
for 5 monitoring wells upgradient and downgradient of "affected"
homes - it is not clear whether "affected" homes includes all 35
homes in site area, or just the homes with treatment units. If
the latter/ EPA should evaluate whether 5 monitoring wells is
adequate to cover the entire area.
Benefits of providing public water supply: There are
overall benefits to the community of providing public water to
the Haviland Area (Alternative AW-2} . These issues are relevant
to the issue of "Community Acceptance":
- a greater guarantee of clean water for all businesses and
residents in the Haviland Complex,
- the elimination of the need for ongoing monitoring of
all water supply wells in the impacted area,
- the elimination of the inconveniences and impacts on water
pressure currently being experienced by those residents
with whole home treatment systems,
-------
- the resolution of the area residents' concerns that the
water contamination problems (real and perceived) are
negatively impacting their property values, and
- the ability of the Haviland Middle School and Ralph R.
Smith Elementary School to purchase water rather than
continue to bear the ongoing operation, maintenance and
monitoring expenses, and future capital improvement
expenses for their on site supply system.
There are additional benefits to the community at large of
providing public water. A connection to the Hyde Park Fire and .
Water District would also benefit the other residents of the
Harbourd Hills Water District who are outside of the Haviland
Complex Area. The Hyde Park Fire and Water District currently
has significant excess capacity compared to its service
population. This has created a financial hardship on district
residents (regarding both operation and capital costs) that can
only be resolved by expanding the service area.
Connection of the Haviland Complex area to the Hyde Park
Fire and Water District would be an effective alternative that
would satisfy the criteria of; Overall Protection of Human Health
and the Environment, Compliance with ARAR's, Long-Term
Effectiveness and Permanence, Implementability, and Community
Acceptance. EPA should reconsider this alternative.
Respectfully Submitted,
Bridget ^Barclay,
Planner
cc: Thomas Spence, Supervisor, Hyde Park t
Paul Prentice, Harbourd Hills Water Advisory Board
-------
HYDE PARK
FIRE AND WATER DISTRICT
P.O. Box 2007 588 Albany Post Rood Hyde Park, New York 12538-0707 (914)229-2686
12 September 1996
Kevin Willis, Project Manager
Eastern New York Remediation Section
United States Environmental Protection Agency
Region 2
290 Broadway 20th Floor
New York, N.Y. 10007-1866
Re: Haviland Complex Superfund Site in Hyde Park, New York
Dear Mr. Willis:
The Superfund Post-Decision Proposed Plan, dated August 1996, has come to the attention of the Hyde
Park Fire and Water District and wishes that this letter be considered by you as part of the public record
on this matter. The Hyde Park Fire and Water District wishes to again reiterate to all parties concerned.
that the District is ready, able, willing and interested in supplying the quantity, quality and reliability of
water that the residents of the above mentioned site desire. The District, having just completed its own
major water improvement project and being located near this Superfund Site, also, believes that it is in the
best position to provide the quantity, quality and reliability of water at a competitive cost that the residents
so rightly expect.-
I and District representatives are very willing to met and discuss the availability of high quality water with
the Environmental Protection Agency, the Tcwn of Hyde Park and representatives of the interested
affected residents so as to inform all of them of what is available from the District to help provide relief to
the residents of the Haviland Complex Superfund Site.
yours,
Paul F. Eckelman
President
cc: Thomas Spence, Town of Hyde Park Supervisor
Robert Kampf, Hyde Park Councilman
Paul Prentice, Harbourd Hills Advisory Committee Secretary
-------
ROHDE, SOYKA D
' Poughkeepsie, NY 12601
& ANDREWS (9I4)452.75I5
Consulting Engineers, P.C. Fax: (914) 452-8335
Wilfred A. Rohde, P.E. Michael W. Sayka. P.E. John V. Andrews. Jr., P.E. "
September 13, 1996
Kevin Willis
US Environmental Protection Agency
290 Broadway 20th Floor
New York, NY 10007-1866
Re: Superfund Post-Decision Proposed Plan
Haviland Complex
Dear Mr. Willis:
As you know, I am the Engineer who represents the Harbourd Hills Water District for the Town
of Hyde of Park. The Advisory Board to the District has requested that I contact you about their
concerns regarding the subject matter. Therefore, I offer the following comments for your
consideration:
1. The emphasis of the presentation and the subject plan was placed on the seven homes
which have been identified in the past as having contaminated wells, and have
subsequently received treatment systems for their water supply. However, the Haviland
Complex also consists of a school campus with up to 1,300 students and staff; 86 homes
and apartments; and over 15 businesses. These entities represent a probable water
consumption of about 37,000 gallons per day. There was very little information
presented as to the size and potential consumption for this important part of the Haviland
Complex. What assurance is there that contamination of these remaining parcels is not
a problem? During my discussion with Mr. John Glass of the Dutchess Count Health
Department on September 4, 1996, I was informed that the system supplying the 61
apartments is still using their air stripper to treat the water being provided to these
people. Please provide test data that shows the condition of the water quality for each
and every potential user within the Haviland Complex.
2. A graphical representation of the decrease in the VOC's was shown for selected
properties on Haviland Road. What is the data from all of the remaining monitoring
wells concerning the status of VOC's? Show this information in the same graphic
format.
3. The subject plan states on page 3: "In addition, site-related metals contamination has not
been observed in any of the potable wells in the study area." Does metals contamination
exist within any of the monitoring wells? If so, what is the potential for migration to the
potable wells? Please prepare a graphical presentation of the change in metals
contamination for all wells tested, similar to that for the eight wells on Haviland Road.
-------
Kevin Willis
September 13, 1996
Page 2 of 2
4. The subject plan states that community acceptance of the preferred alternative will be
assessed in the ROD amendment. What is the impact if the community still insists on
a connection to the Hyde Park Fire and Water District?
5. At the public meeting held on September 4, 1996, it was stated that the EPA has spent
$2. 1 million on this project. Please provide an accounting of these expenditures.
6. If the subject plan is accepted, will the Haviland Complex be reduced in size? If the
Haviland Complex is not reduced in size by an official declaration, what will the
economic impact be on properties that are deemed to be safe, yet are still located within
a declared Super Fund site?
I thank you for the time given to me during the public comment period at the September 4th
public meeting, and for your consideration of the above matters.
Very truly yours,
ROHDE, SOYKA & ANDREWS
CONSULTING ENGINEERS, P.C.
Michael W. Soyka, P.E.
cc: Thomas Spence, Supervisor
Town Board Members
Town Clerk
Harbourd Hills Advisory Committee
96-069-06
KOHDF. SOYVCA & ANDREWS CONSl'l.TINi; KNUINKI-KS. I».C.
-------
HYDE PARK
FIRE AND WATER DISTRICT
P.O. Box 2007 588 Albany Post Road Hyde Park, New York 12538-0707 (914)229-2686 ,
12 September 1996
Kevin Willis, Project Manager
Eastern New York Remediation Section
United States Environmental Protection Agency
Region 2
290 Broadway 20th Floor
New York, N.Y. 10007-1866
Re: Haviland Complex Superfund Site in Hyde Park, New York
Dear Mr. Willis:
The Superfund Post-Decision Proposed Plan, dated August 1996, has come to the attention of the Hyde
Park Fire and Water District and wishes that this letter be considered by you as part of the public record
on this matter. The Hyde Park Fire and Water District wishes to again reiterate to all parties concerned,
that the District is ready, able, willing and interested in supplying the quantity, quality and reliability of
water that the residents of the above mentioned site desire. The District, having just completed its own
major water improvement project and being located near this Superfund Site, also, believes that it is in the
best position to provide the quantity, quality and reliability of water at a competitive cost that the residents
so rightly expect.
J and District representatives are very willing to met and discuss the availability of n'gh quality water with
the Environmental Protection Agency, the Town of Hyde Park and representatives of the interested
affected residents so as to inform all of them of what is available from the District to help provide relief to
the residents of the Haviland Complex Superfund Site.
yours,
Paul F. Eckelman
President
cc: Thomas Spence, Town of Hyde Park Supervisor
Robert Kampf, Hyde Park Councilman
Paul Prentice, Harbourd Hills Advisory Committee Secretary
-------
HYDE PARK CENTRAL SCHOOL DISTRICT
Building and Grounds Department
HavBandRoad
Hyde Partc. New York 12538
Douglas R. Mayen. C.D.F. ' Tel. (914) 229-4064
Director of Facilities & Operations Fax. (914) 229-4033
September 25, 1996
Mr. Kevin Willis, Project Manager
U.S. Environmental Protection Agency
Emergency & Remedial Response Division
290 Broadway 20th Floor
. New York, New York 10007
Dear Mr. Willis:
I would like to reiterate, for the written record, the Hyde Park Central School
District's position as I stated in your meeting at the Haviland Middle School on
September 04,1996.
The School District takes exception to your "Superfund Post-Decision
Proposed Plan" statement, Page 2, Paragraph 1, under Summary of Site
Investigations. The Haviland Junior High School never emitted contaminants into
the ground water, thereby, contributing to the contamination of the shallow
residential wells on Haviland Road.
As a matter of fact, the only contaminants found in our septic tanks were
heavy merals which, by your own admission on Page 3 of the Post-Decision Plan,
you state that "site-related metals contamination has not been observed." It has
never been proven that the heavy metals have ever left our septic tanks,
contaminating any soil or water.
Furthermore, your Figure 33, dated September 1992, of Ebasco's Summary
Report of Groundwater Investigations is erroneous and misleading. This shows the
"Path Lines from Potential Pollution Sources" which, again, says the District is a
potential source when the known pollutants of the residential wells do not exist in
our septic systems. Also, the third point from the left on this figure is not a septic
system but a rock ledge, and your sampling point there has always been dry.
-1-
-------
To: Mr. Kevin Willis, Project Manager September 25, 1996
Re: Superfund Post-Decision Proposed Plan
The District would also like to go on record as being in favor of alternate
AW-2, die installation of a Public Water System. The Haviland (Middle) Junior
High School's deep well has never been polluted and, hopefully, will not be
anytime in die future. But, our fifty-year old system is at the end of its useful life,
and we would like to get out of me water supply business. It seems inefficient and
uneconomical for the School District to maintain a water plant when the Hyde Park
Fire and Water and Harbour Hills Water Systems could serve our needs, as well as,
the residents of the area.
Thank you again for taking these facts under consideration in your final
analysis.
Yours truly,
Douglas R. Mayen
DRM/jam
cc: Mr. Paul F. Eckelman, Hyde Park Fire and Water
Mr. Clifford J. Ong, Support Services Administrator, HPCSD
Mr. Paul N. Prentice, Harbourd Hills Advisory Committee Secretary
Mr. Daniel W. Stone, Chazen Engineering
Dr. Stephen H. Urgenson, Superintendent of Schools, HPCSD
Dk.9.SprfhdPrpsdPln
-2-
-------
August 26, 1996
rffit Historic lorum of
Jfyde fPar£
627 Albany Post Road
Hyde Park, New York 12538
Phone (914) 229 -51 11
Fax (9 14) 229 -0349
Thomas Spence
Supervisor
Kevin Willis
US-EPA 20th Floor
290 Broadway
New York, NY 10007-1866
RE: Haviland Road Tests
Dear Mr. Willis:
I ask that you comply with Mr. Prentice's request
please send an additional copy to this office.
I thank you.
In addition
Sincerely,
Tom Spepte
Supervisor
cc: Town Board
P. Prent-ice
-------
*Z7ie ^Bstonc Vvum of
fyde.
627 Albany Post Road
Hyde Park, New York 12538
Phone (914) 229 -51 11
Fax (9 14) 229 -0349
September 16, 1996
Kevin Willis, Project Manager
US-EPA Emergency & Remedial Response Division
290 Broadway, 20th Floor
New York, NY 10007-1866
Re: Haviland Road Site
Dear Mr. Willis:
The town takes issue with the EFA's proposal which was presented in
a public hearing in Hyde Park on September 4, 1996.
The ROD had three signatories; the EPA should not unilaterally have
the power to declare that its provisions have been satisfied or to
nullify it.
For at least nine years, heavy metal contamination was considered
to be a serious problem. Now it is decreed that this is no longer
a problem. There should be extensive test boring of the soil near
to the existing wells to ensure that traces of heavy metals are not
present. I saw no evidence presented at the public hearing to in-
dicate that such tests have been performed.
The amount of sampling is not sufficient to justify the abandonment
of a plan to connect the Haviland area to an assured water source.
It appears that the only consistent ongoing sampling has been at the
faucets of seven afflicted homes. This modest list of points has been
used to drive a computer model, the results of which is used to project
that all will be fine in a few years. At a bare minimum EPA should
sample all the houses on Haviland Road and Wright Avenue in addition
to sampling the schools and the shopping center.
Remarks from the floor indicated that the water in the schools may not
be safe for drinking. There should be n£ question about this before
EPA decides to abandon the idea of connecting to a good water source.
-------
The previous town board passed a resolution in the fall of 1995
asking that the EPA adopt a solution of connecting the Haviland
Road site to the Hyde Park Fire & Water District. The present
town board passed a similar resolution in January of this year;
the intent of this second resolution was to demonstrate that the
town's position on this question is grounded in reason, not politics.
I call to your attention Mr. Eckelman's letter to you of September 12,
1996.
Sincerely,
Thomas Spence f/
cc: Town Board
T. Mahar
P. Eckelman
D. Wheeler
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TOWN OF HYDE PARK, NEW YORK
.
c _. r 1^"i--' r ,f. Uargaresta Aadersan
Jaoes Scua.. v».«^*'-. ; Councils-Oman - *ss Ward
Counc:.l3i22. - 2aa ward .-V - ' '
Thomas S penes
Supervisor 8 Putnam Road
Hyde Park, N.Y. 12538
October 15, 1996 .
Mr. Kevin Willis
. US-EPA 20th Floor
' 290 Broadway
Hew York, New York 10007-1866
Dear Mr. Willis,
I thank you for the opportunity to respond to the Environmental
Protection Agency's Post-Decision Proposed Flan concerning the Haviland
Complex Superfund site in Hyde Park. As the Third Ward Councilman, I
represent this area on our Town Board.
Several years. ago, in 1984, 1 was on the Town Board when the subject of
Superfund support originated. During the past twelve years, we waited
patiently for a proper solution to the pollution problems affecting the
residents of the Haviland Road area.
By October, 1995, it appeared that the AW-2 Alternative in the EPA report
was ready to be implemented. The Town Board, at that rime, held a public
hearing and advised the community that EPA would assist the Haviland Road
area by funding a water distribution network connection to the Hyde Park
Fire and Water District to the north along Route 9G.
Then, in August, 1996, the EPA, in its Proposed Plan advises the
community that Alternative AW-1, No Further Action, is its preferred
Alternative. Inspite cf the drop in tested pollutants, this Alternative
does not provide a permanent solution for the residents of Haviland. It is
my feeling, and the expressed desire of the residents of Haviland, that the
EPA should reconsider Alternative AW-2, as previously proposed in October,
1995 , since it is a more viable permanent solution to the problem, which
could become a concern in the future.
Secondly, if the Town indicates its support, as our Board has done by
resolution in early 1996, and if funding is still available for this project
in order to insure environmental protection into the long-range future , why
not make the hook-ups to the Hyde Park Fire and Water District now and
eliminate future concerns? .
All parties involved in this project have been guilty of some lapses. Had
all parties done their jobs over the past d*ecade, we would have been looking
at the proper AW-2 solution as a completed act. It is now time to implement
AW-2 in order to finalize what all of us originally set out to do. In doing
o, we will also benefit the Hyde Park Central School District, which could
hook up to this new source of water. You have heard from our Engineer and
our ADVISORY BOARD IN HARBOURD HILLS. We all agree that this is the better
alternative. Thank you once again and I look forward to working vith you,
and the EPA, in order to create, this more positive solution in our area.
Sincerely yours, ff
lobert Kampf , Councilman 3r
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P. 01
Historic Toum of
627 Albany Post Road
Hyde >ark. New York 12538
Phone (914) 229-SI 11
Fix (914)229-0349
Mr.
u.s
Erne:
290
New
Kevin Willis, Project Manager
Environmental Protection Agen
gency & Remedial Response Divi
Broadway 20th Floor
York. N.Y. 10007
Thomas Spence
Supervisor
October 23, 1996
y
lion
Dear Kevin,
We are sending this letter on the EPA Post-Decision Proposed Plan
to you in full support of the Harbc urd Hills Water Distrist Advisory
Committee comments and letters sent to you recently by its Secretary,
Peu Prentice.
Ve understand that the public c
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Kevin Willis
U.S. Environmental Protection Agency
290 Broadway 20th Floor
New York, NY 10007-1866
Dear Mr. Willis, September 22,1996
At the September 5th Superfund Post-Decision Proposed Plan informational
meeting on the Haviland Complex, held at the Haviland Middle School, I and other
concerned residents were informed that the "Preferred Alternative" to the ongoing water
problem was to continue with the plan already in place. I strongly oppose this decision. I
feel the testing has been insufficient, with the test wells not being tested as frequently as
needed or not at all. Our home was the first to have pollution in the water supply. As a
result we were left to ensure our own personal safety by installing a water purifer filter at
our own expense, and have been maintaining this system throughout the years that this
problem has been on the negotiating table. I feel the Preferred Alternative Plan is
inefficient, short and long term, and consider this problem to be a major health concern
for all the residents involved.
Furthermore on October 13,1995 during the special meeting of the Hyde Park
Town Board, the Resolution 10:13-1 if 1995 was put forth and voted upon requesting
"The United States Environmental Protection Agency immediately proceed with the
design and construction of the water mains and appurtenances needed to provide a
reliable, potable water supply to the Haviland Complex a connection to the Hyde Park
Fire and Water District", with the role call vote unanimously in favor. During the
February 26,1995 Public Hearing and Regular Meeting of the Hyde Park Town Board
another Resolution (2:26-1 of 1996) was carried unanimously and states as follows: "BE
IT RESOLVED, that the current Town Board does hereby reaffirm the Town's
commitment to cooperate and work with the United States Environmental Protection
Agency toward the goal set forth in the Hyde Park Resolution Number One of
October 13,1995."
In conclusion it is my belief that the EPA, NYSDEC, and the public officials that
represent my district need to be more conscious of the seriousness and urgency of this
matter. There are »lso two public schools involved, one of which the children are
instructed NOT to drink the tap water! I am outraged at the slow progress that has been
taken to rectify this situation to ensure all residents have clean healthy water. I appreciate
your prompt attention to this matter.
Sincerely,
±*A*-£~4 '
/
Mr. & Mrs. Frank Guglielmo
3 Haviland Rd.
Hyde Park, NY 12538
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Kevin Willis
U.S. Environmental Protection Agency
290 Broadway 20th Floor
New York. NY 10007-1866
Dear Mr. Willis, September 12,1996
At the September 5th Superfund Post-Decision Proposed Plan informational
meeting on the Haviland Complex, held at the Haviland Middle School, I and other
concerned residents were informed that the "Preferred Alternative" to the ongoing water
problem was to continue with the plan already in place. I strongly oppose this decision. I
feel the testing has been insufficient, with the test wells not being tested as frequently as
needed or not at all. In the past six years my well has not been tested by the County or
State at all, leaving me no alternative but to personally take on this responsibility. I feel
the Preferred Alternative Plan is inefficient, short and long term, and consider this
. problem to be a major health concern for all the residents involved.
Furthermore on October 13,1995 during the special meeting of the Hyde Park
Town Board, the Resolution 10:13-1 if 1995 was put forth and voted upon requesting
The United States Environmental Protection Agency immediately proceed, with the
design and construction of the water mains and appurtenances needed to provide a
feliable, potable water supply to the Haviland Complex a connection to the Hyde Park
Fire and Water District", with the role call vote unanimously in favor. During the
February 26,1995 Public Hearing and Regular Meeting of the Hyde Park Town Board
Another Resolution (2:26-1 of 1996) was carried unanimously and states as follows: "BE
IT RESOLVED, that the current Town Board does hereby reaffirm the Town's
commitment to cooperate and work with the United States Environmental Protection
Agency toward the goal set forth in the Hyde Park Resolution Number One of
October 13,1995."
In conclusion ft is my belief mat the EPA. NYSDEC, and the public officials that
tepresent my district need to be more conscious of the seriousness and urgency of this
matter. There are also two public schools involved, one of which the children are
instructed NOT to drink the tap water! lam outraged at the slow progress that has been
token to rectify this situation to ensure all residents have clean healthy water. I appreciate
your prompt attention to this matter.
Sincerely,
Mr. & Mrs. Horton Tucker
4 Haviland Road
Poughkeepsie,NYI2601
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cc: Sen. Alfonse M. D'Amato
Sen. Daniel Patrick Moynihan
Rep. Gerald B. Solomon
Sen. Stephen Saland
Assemblyman Joel Miller
Thomas Spence, Hyde Park Supervisor
Geoffrey J. Tacietti & G. Anders Carlson, NYS EPI, NYSDOH
Douglas Gaborini, USEPA
Dutchess County Health Commissioner
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GOSJUTV
'ATER AND
ASTEWATER AUTHORITY
October 22. 1996
27 High Street
Poughkeepsie
New York 12601"
(914)486-3601
Fax (914)486-3610
E-mail: dc2Omhv.net
Mr. Kevin Willis -' .
U.S. Environmental Protection Agency
290 Broadway, 20th Floor
New York, NY'10007-1866
Authority Board Mambaii
Daniel J. Donovan
Edwart E. Downey
Nicftotatt S. Johnson
P«te» N. Anagnos. P.E~ LS.
Smnqr
VtncwitC.Pangia.CPA
Ex offioo Mtfnbtfs
Sot M W
Rogtr P. Akalcy, Co
O.C.O«ti«Pmng4
Staff
ScaaQ.ChaM
RE: Haviland Complex
Superfund Post-Decision Proposed Plan
Dear Mr. Willis: .
The Dutchess County Water apd Wastewater Authority
is a public benefit corporation formed in 1992 by the:
New York State Legislature and the Dutchess County
Legislature. The Authority's charge is to address
issues of adequacy of water supply and wastewatetf
treatment throughout the County. v
Authority staff has reviewed available materials
regarding the Haviland Complex Superfund Post-Decision
Proposed Plan, and attended the EPA's Public Hearing on
this proposed plan, held on September 4, 1996. Our key
concern with the proposed plan is to what degree the*
proposed alternatives (GW-1 and AW-l) provide adequate
protection for small businesses and homes east of Route
9G which are not currently supplied with whole house
treatment systems, particularly the additional homes on
Haviland Avenue and these homes on the eastern end of
Wright Ave. ....
The evaluation of the alternatives and the
justification for selecting Alternatives AW-l and GW-1,
focus on the homes with whole house treatment, system,
to the exclusion of those homes with out treatment
systems.:
The evaluation of Alternative GW-l regarding
"Overall protection of human health and the
environment* assumes actual human exposure will not
occur in the 2-7 years until groundwater meets MCL'a
^o nresence of^tr^atment units. The evaluation
does not address the possibility of contamination of
other wells in residences not presently equipped with
treatment systems. ' '
The evaluation of Alternative AW-l regarding "Overall
protection of human health and the environment" would
"...prevent the potential exposure of residents at the
site through inge'stion of cc-taminants present in
selected residential wplls" (emphasis added), based' en
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effectiveness of whole house treatment units. Once again, the
evaluation appears to not address the residences with out
treatment systems.
The exclusion of the additional residences within the
Haviland Complex site seems to be based on an assumption that,
since these residential wells did not show contamination in the
past, they will not do so in the future. The validity of this
assumption seems open to question for the following reasons; lack
of current sampling data, variability of the sampling data,
accuracy of modeling and the lack of.future monitoring.
Lack of monitoring data for additional residences: If a low
level volatile plume is in fact moving south easterly from the
Haviland Shopping Center and Haviland Complex Apartments area, it
seems possible that additional homes on Haviland Avenue and homes
on Wright Avenue may be at risk of contamination. It is unclear
when the last time residential wells of homes without treatment
units were sampled, but it appears that many have not been
sampled in over three years.
Variability in sampling data: The concern regarding the
lack of recent sampling data for residential wells without
treatment units is heightened by the high variability in sampling
results for the residential wells on Haviland Road, which have
been sampled semi-annually since 1989. Specifically:
- At 10 Haviland Road PCE levels went, from 3 ppb to 11 ppb
in 4 months (1990) ,
- At 14 Haviland Road CBZ levels went from 0 to 21 ppb in 6
months (1995),
- At 20 Haviland Road PCE level went from 10 to 41 ppb in 9
months (1991), and CBZ levels went from 8 to 35 ppb in 9
months (1991) and from 0 to 13 ppb in 4 months (94-95),
- At 22 Haviland Road DCE levels went from 0 to 5.6 ppb in 4
months (93-94), and CBZ levels went from 0 to 11 ppb in 4
months (93-94),
- At 24 Haviland Road PCE levels went from 0 to 27 ppb in 4
months (93-94), and CBZ levels from 0 t.o 10 ppb in 6
months (1995).
It appears from this data that distribution of contamination
levels within the plume are far from uniform, and that levels of
contamination at any particular point can easily vary from non-
detectable to above MCLs in a relatively short time period. This
raises questions as to whether the limited testing done on
additional residential wells is adequate to support an assumption
that they are.not currently, and will not in the future, be
.impacted by contamination.
In contrast to the amount of sampling data upon which EPA is
basing a decision to take no further action on homes without
treatment units, Alternative AW-1 anticipates maintenance of the
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treatment units until 3 years of consecutive semi-annual rounds
of sampling (i.e. 6 samples over 3 years) meet MCLs.
Accuracy of modeling: Modeling based on 1987 and 1990 data
predicts that the contamination plume will not impact additional
residential wells. However, modeling is not an exact science; it
predicts a range of future outcomes based on current conditions.
But conditions can change; for example, changes in water table
conditions or water withdrawals could change the direction of
groundwater flow. As stated above, there is a great deal of
variability in the sampling results; how might this impact the
reliability of the modeling?
For these reasons, it would seem prudent for EPA to conduct
at least one more round of testing of all of the residential
wells with in the Haviland Complex site and downgradient of the
source prior to making a final decision regarding appropriate
remedies.
In the event that EPA determines to select remedies GW-l and
AW-1, we recommend ongoing monitoring, at least annually, of
residential wells which do not have home treatment units as part
of the monitoring plan. Currently, Alternative AW-1 anticipates
semi-annual monitoring of all homes with treatment units, and
maintenance of units, until 3 years of consecutive semi-annual
rounds of sampling meet MCLs. No additional monitoring is
recommended for the "non-treatment" homes.
In addition, monitoring wells should be sited both
upgradient and down gradient of homes on Haviland Avenue and
Wright Avenue to insure the detection of any contaminant plume
that may impact the non-treatment homes. Alternative GW-l calls
for 5 monitoring wells upgradient and downgradient of "affected"
homes - it is not clear whether "affected" homes includes all 35
homes in site area, or just the homes with treatment units. If
the latter,- EPA should evaluate whether 5 monitoring wells is
adequate to cover the entire area.
Benefits of providing public water supply: There are
overall benefits to the community of providing public water to
the Haviland Area (Alternative AW-2). These issues are relevant
to the issue of "Community Acceptance":
- a greater guarantee of clean water for all businesses and
residents in the Haviland Complex,
- the elimination of the need for ongoing monitoring of
all water supply wells in the impacted area,
- the elimination of the inconveniences and impacts on water
pressure currently being experienced by those residents
with whole home treatment systems,
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- the resolution of the area residents' concerns that the
.water contamination problems (real and perceived) are
negatively impacting their property values, and
- the ability of the Haviland Middle School and Ralph R.
Smith Elementary School to purchase water rather than
continue to bear the ongoing operation, maintenance and
monitoring expenses, and future capital improvement
expenses for their on site supply system.
There are additional benefits to the community at large of
providing public water. A connection to the Hyde Park Fire and
Water District would also benefit the other residents of the
Harbourd Hills Water District who are outside of the Haviland
Complex Area. The Hyde Park Fire and Water District currently
has significant excess capacity compared to its service
population. This has created a financial hardship on district
residents (regarding both operation and capital costs) that can
only be resolved by expanding the service area.
Connection of the Haviland Complex area to the Hyde Park
Fire and Water District would be an effective alternative that
would satisfy the criteria of; Overall Protection of Human Health
and the Environment, Compliance with ARAR's, Long-Term
Effectiveness and Permanence, Implementability, and Community
Acceptance. EPA should reconsider this alternative.
Respectfully Submitted,
Bridget Barclay,
Planner
cc: Thomas Spence, Supervisor, Hyde Park t
Paul Prentice, Harbourd Hills Water A'dvisory Board
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