EPA Superfund
Record of Decision:
PB95-963814
EPA/ROD/R02-95/260
March 1996
Warwick Landfill,
Warwick, NY
9/29/1995
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RECORD OF DECISION
WARWICK LANDFILL SITE
TOWN OF WARWICK
ORANGE COUNTY, NEW YORK
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION II
NEW YORK, NEW YORK
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DECLARATION FOR THE RECORD OP DECISION
SITE NAME AND LOCATION
Warwick Landfill, Town of Warwick, Orange County, New York
STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected remedy for the
second operable unit (OU-2) for the Warwick Landfill site (the
Site), located in the Town of Warwick, Orange County, New York,
which was chosen in accordance with the requirements of the
Comprehensive Environmental Response, Compensation and Liability
Act (CERCLA), 42 U.S.C. §§ 9601-9675, as amended, and to the
extent practicable, the National Oil and Hazardous Substances
Pollution Contingency Plan (NCP) , 40 CFR Part 300. This decision
document explains the factual and legal basis for selecting the
remedy for the Site. The information supporting this remedial
action decision is contained in the administrative record for the
Site. The administrative record index is attached (Appendix
III) .
The New York State Department of Environmental Conservation
concurs with the selected remedy (Appendix IV).
DESCRIPTION OF THE SELECTED REMEDY - NO FURTHER ACTION
This operable unit represents the second of two operable units
for the Site. It addresses the fate and transport of the
contaminants in the groundwater emanating from the Site. The
United States Environmental Protection Agency (EPA) in
consultation with the State of New York has determined that site-
related groundwater contamination is limited and does not pose a
.significant threat to human health or the environment; therefore,
remediation is not appropriate. This determination is based on
the Operable Unit Two (OU-2) Remedial Investigation and the fact
that the Operable Unit One (OU-l) remedy will be implemented.
The major portions of the OU-l remedy include the construction of
a landfill cap to further reduce infiltration and/or leaching of
contaminants into the groundwater and/or wetlands and the
implementation of a residential well monitoring program.
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DECLARATION
In accordance with the requirements of CERCLA, as amended, and
the NCP, it has been determined that no further remedial action
protects human health and the environment at the Site, complies
with federal and state requirements that are legally applicable
or relevant and appropriate to the remedial action and is cost-
effective. The principal threats at the Site are being addressed
through the OU-1 remedial action, which includes the installation
of a landfill cap to further reduce infiltration or leaching of
contaminants into the groundwater and wetlands and the
implementation of an environmental monitoring program.
A review of the remedial action pursuant to CERCLA 121(c), 42
U.S.C. §9621(c), will be conducted five years after the
commencement of the remedial action for OU-1 to ensure that the
remedy continues to provide adequate protection to human health
and the environment, since the OU-2 remedy will result in
hazardous substances remaining on-site above health-based levels.
Jeanne ^
Regional" Adm
9/sr/rr
Date1
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RECORD OF DECISION
DECISION SUMMARY
WARWICK LANDFILL SITE
TOWN OF WARWICK
ORANGE COUNTY, NEW YORK
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION II
NEW YORK, NEW YORK
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TABLE OF CONTENTS
SITE NAME, LOCATION AND DESCRIPTION 1
SITE HISTORY AND ENFORCEMENT ACTIVITIES 2
HIGHLIGHTS OF COMMUNITY PARTICIPATION 5
SCOPE AND ROLE OF OPERABLE UNIT 5
SITE CHARACTERISTICS .6
SUMMARY OF SITE RISKS ...... 15
SUMMARY OF THE SELECTED NO FURTHER ACTION REMEDY 18
DOCUMENTATION OF SIGNIFICANT CHANGES 19
ATTACHMENTS
APPENDIX I. FIGURES
APPENDIX II. TABLES
APPENDIX III. ADMINISTRATIVE RECORD INDEX
APPENDIX IV. NYSDEC LETTER OF CONCURRENCE
APPENDIX V. RESPONSIVENESS SUMMARY
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SITE NAME, LOCATION AND DESCRIPTION
The Warwick Landfill site (Site) is located approximately one and
one-half miles northeast of the Village of Greenwood Lake in the
Town of Warwick, Orange County, New York (see Figure 1). The
Site is approximately three-fourths of a mile north of State
Route 17A and fronts Penaluna Road on its western boundary
between Old Tuxedo Road and Old Dutch Hollow Road. No buildings
exist on the landfill property except for the remnants of a brick
structure. The landfill mound transects a small valley and
occupies approximately 19 acres of a former 26-acre leasehold
area. This leasehold is a portion of a 64-acre parcel of
property.
The Village of Greenwood Lake is a semi-rural residential
community located approximately forty miles northwest of New York
City. Total population of the Village of Greenwood Lake is
estimated to be 3,000. The Town of Warwick has a population of
approximately 25,000. The majority of the population around the
Warwick landfill is on private wells.
Elevations within one mile of the Site range from 700 feet to a ,
little more than 1300 feet above mean seal level (msl). Broad
upland areas are generally underlain by massive rocks. Valleys
represent zones of less resistant bedrock and shearing along
faults. The dominant features comprising the Site consist of a
north-south trending wetlands valley spanned by the northeast
trending landfill mound. Maximum relief throughout the Site is
approximately 60 feet. A review of existing flood insurance maps
indicated that no portions of the Site are located in either the
100- or 500-year flood zone.
The area surrounding the Site is generally wooded with clusters
of residential homes, all of which utilize private wells as their
source of drinking water. The two homes closest to the Site are
approximately 250 feet south of the landfill boundary and 300
feet northeast of the landfill boundary, respectively.
The landfill mound is sparsely vegetated with grasses and small
shrubs supporting small mammals (rats, cottontail rabbits and
opossum) and some avifauna (bluebirds, robins). Contiguous to
the landfill mound are two wetland areas: an emergent
marsh/scrub-shrub wetland, approximately nine acres in size, in
the southeast; and a smaller, palustrine, forested scrub-shrub,
deciduous wetland, approximately three to four acres in size, to
the northwest. Upland habitats surround both wetlands.
An unnamed intermittent stream drains the small wetlands area on
the northwest side of the Site and flows north into a creek
(named North Brook for convenience) that flows westward and then
southward into Greenwood Lake. An unnamed perennial stream
(named South Brook for convenience), located along the perimeter
of the landfill's southeast side, flows southward into the larger
wetlands area, eventually flowing south and west into Greenwood
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Lake (see Figure 2). Greenwood Lake is designated a Class "A"
(potable drinking water source) water body by the New York State
(NYS) Department of Environmental Conservation (DEC). The
wetlands and streams draining the site area do not support
fishing or other recreational activities. However, they are a
suitable habitat for small aquatic wildlife, such as frogs and
turtles.
Two aquifers exist beneath the Site. The overburden aquifer is
comprised of two major components: unstratified till deposits,
consisting of a mixture of clay, silt, sand, gravel, and boulders
of varying size, shape, and permeability and stratified drift
deposits or sandy outwash. The bedrock aquifer generally
consists of moderately fractured quartz-plagioclase gneiss,
hornblende-feldspar gneiss, and amphibolite.
SITE HISTORY AND ENFORCEMENT ACTIVITIES
The Site was owned and farmed by the Penaluna family from 1898 to
the mid-1950s, when the Town of Warwick leased the property from'
the Penaluna family and utilized it as a refuse disposal area.
The facility accepted waste from the Town of Warwick, which
includes the Villages of Florida, Warwick and Greenwood Lake, and
other surrounding towns in Orange County. Evidence indicates
that there was some disposal of hazardous waste materials at the
landfill during this time. The Town of Warwick operated the
landfill until 1977.
In April 1977, the Site was leased from the property owner, Mrs.
Millie Mae Penaluna, by Grace Disposal and Leasing, Ltd. (Grace
Disposal), Harriman, New York. On July 15, 1977, Grace Disposal
was granted a permit to operate the refuse disposal area by the
Orange County Department of Health. Under Grace Disposal's
operation, municipal wastes and industrial hazardous
wastes/sludges were disposed of in the landfill.
In 1978, the State of New York took over the regulation of
landfills from the counties. In February 1978, Grace Disposal
submitted an application to NYSDEC to operate the Warwick
Landfill. A Draft Environmental Impact Statement (DEIS) was
compiled for a NYSDEC Solid Waste Management Facility operation
permit at the Site by P. Joseph Corless, Consulting Engineers,
Inc. on December 27, 1978. The DEIS findings indicated that
approximately 300,000 cubic yards of refuse per year were handled
at the landfill for an unspecified duration. It also concluded
that leachate and surface run-off generated at the Site did not
measurably affect surface water and groundwater in the area, and
also, that the water quality of the stream which drains the
wetland "area south of the Site was in compliance with NYS surface
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water standards. However, the DEC requested additional
information from the applicant which included the drilling and
water sampling of on-site monitoring wells and boring and
analyses of on-site soils.
In 1979, in response to concerns of local citizens who had
reported observations of suspicious dumping activities at the
landfill, DEC and EPA collected and analyzed two leachate samples
at the Site. The results indicated the presence of heavy metals,
phenols, and various volatile organic compounds (VOCs), some of
which exceeded the NYS drinking water standards and EPA maximum
contaminant levels. Based on the results of these samples and
the fact that Grace Disposal did not perform the additional tasks
necessary for the submittal of an adequate DEIS within a
reasonable time period, the application to operate the landfill
was denied.by DEC on September 4, 1979, and the landfill was
ordered to be closed. Pursuant to a New York State court order,
the Site was covered, graded, and closed by Grace Disposal. On
June 11, 1980, DEC was notified that a Certificate of Dissolution
had been filed by Grace Disposal.
In 1984, ownership of the property was transferred to Orange
County for nonpayment of back taxes. It was conveyed from Orange
County to Newburgh, New York Developers in November 1986.
In March 1985, a preliminary assessment/site inspection,
including a field investigation, was performed by Woodward-Clyde
Consultants, Inc. for DEC. The information generated was
utilized to prepare a Hazard Ranking System (HRS) assessment of
the Site. Based upon the HRS score, the Site was proposed for
inclusion on EPA's National Priorities List (NPL) of uncontrolled
hazardous waste sites in 1985 and was added to the NPL in March
1989.
In 1987, the property was transferred to the current owners, L&B
.Developers, Inc. On March 22, 1991, a notice of federal lien was
filed at the Orange County Courthouse in Goshen, New York, which
provides a lien in favor of the United states against the
property comprising the Site for all costs and damages for which
L&B Developers, Inc. is liable to the United States pursuant to
Section 10.7 (a) of CERCLA, 42 U.S. C. § 9607 (a).
On December 28, 1988, EPA sent special notice letters to a number
of potentially responsible parties (PRPs) at the Site, namely
parties that EPA had determined were responsible for contributing
to the contamination found at the Site. These PRPs included:
All County Environmental Services Corporation, All County
Resource Management Corporation, Ford Motor Company, Grace
Disposal & Leasing, Ltd., Instrument Systems Corporation/Lightron
Corporation, International Paper, I.S.A. of New Jersey, Inc., L&B
Developers, Jones Chemicals, Nepera, Inc., New York University
Medical Center, Reichhold Chemicals, Inc., Round Lake Sanitation
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Corporation^ and Union Carbide Corporation. The special notice
letters informed these parties of their potential liability at
the Site and afforded them the opportunity to undertake the
remedial investigation and feasibility study (RI/FS) for the
Site.
Subsequently, on February 27, 1991, based on newly received
information, EPA sent general notice letters to Georgia Pacific
Corporation and the Town of Warwick, informing them of their
status as PRPs.
Since EPA did not receive any good faith proposals from the PRPs
to undertake or finance the RI/FS, EPA contracted Ebasco
Services, Inc. to perform this work, using Superfund monies.
Field work for the RI/FS began in August 1989 and was completed
in February 1991.
From September 1989 until November 1990, as part of the RI,
residential well sampling was conducted by EPA and NYS Department
of Health (DOH), which indicated levels of VOC contamination
above NYS and federal drinking water standards. As a result, DOH
and DEC fitted those affected households with granular activated
carbon units. Four residential wells are currently fitted with
these units which are regularly sampled by DEC.
In June 1991, EPA signed a Record of Decision (ROD) for OU-1,
which included a landfill cap as a source control measure, gas
venting and provision of granular activated carbon filters on
certain residential wells as an interim measure. In addition,
because some VOCs and metals were identified in the groundwater
above federal and NYS drinking water standards, the ROD also
specified a supplemental investigation of the fate and transport
of the contamination, designated as OU-2.
On February 28, 1992, after failing to receive any good faith
offers to undertake the OU-1 remedial work, EPA issued a
Unilateral Order to six PRPs [Ford Motor Company, Georgia-Pacific
Corporation, I.S.A. in New Jersey, Inc., Round Lake Sanitation
Corporation, Union Carbide Corporation and Town of Warwick] to
perform the remedial design and remedial action (RD/RA) called
for in the OU-1 ROD. Certain of the PRPs formed a ^roup known as
the Warwick Administrative Group (WAG) to perform the remedial
work at the Site. The WAG hired Geraghty and Miller, Inc. (G+M)
to perform the remedial design work.
On September 28, 1992, EPA issued an Administrative Order on
Consent to four PRPs [Ford Motor Company, Georgia-Pacific
Corporation, Reichhold Chemicals, Inc. and Union Carbide
Corporation] to perform the supplemental RI groundwater
investigation. The OU-2 RI was also conducted by G+M.
On April 9, 1993, EPA issued a second UAO for the OU-1 RD/RA to
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five additional PRPs [International Business Machines
Corporation, International Paper Company, Nepera, Inc., Reichhold
Chemicals, Inc. and Revere Smelting and Refining Corporation],
requiring that they cooperate and coordinate with the other PRPs
in conducting the work.
HIGHLIGHTS OP COMMUNITY PARTICIPATION
The RI report and the Proposed Plan for Operable Unit Two (OU-2)
were released for public comment on July 28, 1995. These
documents were made available to the public in the EPA Docket
Room in Region II, New York and the information repositories at
the NYSDEC in Albany, New York, the Warwick Town Hall, Warwick,
New York and Greenwood Lake Village Hall, Greenwood Lake, New
York. A press release announcing the availability of these
documents was issued on July 28, 1995. The 30-day public comment
period was set by EPA to end on August 27, 1995.
An extension to the public comment period was requested by the
Dutch Hollow Homeowners Association (DHHA) which is the Technical
Assistance Grant (TAG) recipient at the Site. An extension has
been granted to afford the DHHA's technical advisor sufficient
opportunity to review and comment on the RI, the risk assessment
and the Proposed Plan. The public comment period closed on
September 26, 1995.
During the public comment period, EPA held a public meeting to
present the RI, the risk assessment report and the Proposed Plan,
to answer questions, and to accept both oral and written
comments. The public meeting was held at the Greenwood Lake
Middle School, Greenwood Lake, New York on August 15, 1995. At
this meeting, representatives from EPA and DOH answered questions
about the Site and the proposed no further action remedy and
received comments from the local citizens. Comments and
responses to those comments received during the public meeting
and public comment period are included in the Responsiveness
Summary (see Appendix V).
SCOPE AND ROLE OF OPERABLE UNIT
EPA has divided the remedial work necessary to mitigate both off-
site and on-site contamination stemming from the Site into two
operable units. The first operable unit addresses the control of
the source of contamination at the Site. The June 1991 ROD for
OU-1 selected the capping of the landfill as the appropriate
source control response action. The purpose of this action is 1)
to minimize the infiltration of precipitation into the landfill,
thus reducing the quantity of water percolating through the
landfill materials which will minimize the leaching 'of
contaminants and reduce the downgradient migration of
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contaminants and 2) to minimize any further contamination of the
wetlands and drainage channels, which ultimately drain into
Greenwood Lake.
OU-1 also provides for 1) point-of-use treatment, as aji interim,
precautionary measure, for four nearby residential wells which
exhibited low levels of contamination to eliminate the risk to
area residents and 2) an ongoing residential well monitoring
program, including septic tank sampling. In addition, the
impacts of the Site on the adjacent wetlands, groundwater and air
will be monitored as part of the OU-1 operations and maintenance
plan.
The OU-1 RD for the cap was recently completed. The subsequent
construction and installation of the cap should begin in the
Spring of 1996.
The objective of the RI and risk assessment for OU-2 was to
characterize further the fate 'and transport of the contaminants
in the groundwater and, specifically, to: .
- define the hydrogeologic and hydraulic characteristics of
the landfill
- sample the monitoring wells
- define potential contamination sources
- implement a residential well monitoring program
- determine human health risks at the Site
Also, during the OU-2 RI, additional sampling of surface water
and sediments was performed to characterize the landfill
contamination further.
The selected remedy for OU-1 and the OU-2 RI, risk assessment and
Proposed Plan serve as the basis for the OU-2 groundwater remedy.
SITE CHARACTERISTICS
Between March 1993 and September 1994, various sampling events
were conducted by G+M. These investigative events, which were
performed as" part of both the OU-1 RD and OU-2 RI, included:
installation of landfill piezometers, monitoring wells-, and
borings; groundwater monitoring well and residential well
sampling; landfill seep surveying and mapping; off-site seeps and
surface water bench marking; leachate sampling; wetlands1 surface
water and sediment sampling; landfill gas and ambient air
sampling; and residential septic tank sampling.
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Topography
The Site is located in the Hudson Highlands, consisting
primarily of Precambrian-age gneiss. Elevations across the Site
range from approximately 890 feet above mean sea level (msl) in
the northeast to approximately 860 feet above msl in the
southwest. Along the northwestern and southeastern boundaries of
the landfill, the site topography slopes downward to
approximately 825 and 820 feet above msl, respectively.
Elevations within I mile of the site range from approximately 650
to 1,300 feet above msl.
North Brook and South Brook originate along the northwestern and
southeastern boundaries of the landfill (see Figure 2). The
upper reaches of both brooks are intermittent. The landfill
comprises a small portion of these drainage basins and
contributes runoff to both North Brook and South Brook. Wetlands
flank the landfill along its northwestern and southeastern
boundaries. Fill soil and some refuse are present in the
wetlands adjacent to the Site and will be addressed in the OU-1
remedy.
Geology
The geology of the Site area is complex and consists of three
significant units: (1) competent, massive, crystalline bedrock;
(2) sandy, glacial outwash, i.e., stratified drift or the layered
deposits emplaced by glacial streams; and, (3) dense, silty,
glacial till, i.e., primarily an unstratified deposit emplaced '
down-wasting of sediment-laden ice. The manmade landfill
material consists of refuse, silt and daily and final cover soil.
The bedrock in the Site area is a fairly continuous, massive
igneous body, consisting of various gneiss formations. The
bedrock has high concentrations of iron, magnesium and calcium
minerals. As a result of the natural movement of groundwater
through the bedrock formation, numerous minerals dissolve out of
it; this action is referred to as chemical-weathering. Pockets
of chemically-weathered bedrock exist within and to the northeast
of the Site area. The variability in depth to the top of the
weathered bedrock suggests that it is isolated in areal extent.
In addition, a 16-foot interval of predominantly physically
weathered rock exists both in the Site area and south of the
landfill. The weathered bedrock consists of fractured gneiss,
overlain by sandy outwash. Bedrock is present west of the
landfill where silty till directly overlies the bedrock.
The overburden deposits in the Site area are glacial in origin
and vary greatly in composition and thickness and consist of
sandy outwash and silty till. Overburden thickness north of the
landfill is approximately 70 feet. To the east and north of the
landfill, overburden is either absent or it occurs in thin
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pockets because competent bedrock either outcrops or occurs a few
feet below ground surface in that area. Overburden thickness
increases to the west with greater than 90 feet of silty till.
Sandy outwash is present north and south of the landfill. The
thickness of the sandy outwash south of the landfill ranges from
approximately 25 to 40 feet. A wedge of dense, silty till is
also present west of the landfill. The silty till rests on
bedrock.
The landfill material, in most areas, overlies bedrock. At one
location, a 4-foot thick pocket of physically weathered bedrock
occurs between the landfill material and the lower bedrock. The
maximum thickness of refuse is approximately 50 feet and occurs
in the southern section of the landfill. In the northern section
of the landfill, the maximum thickness of refuse is approximately
30 feet. The landfill soil cover is approximately 2 feet thick.
The cover soil typically consists of a poorly sorted silt with
varying percentages of clay, sand, and gravel. The entire
landfill is capped with this cover soil, which was also placed
over the area that is currently the northern section of the
southern wetlands.
Hydrogeology
The hydrogeologic regime of the Site area is complex. Groundwater
occurs within fractures in massive, crystalline rock, isolated
pockets of chemically-weathered bedrock, dense, silty till, sandy
outwash, and landfill material (refuse and silty soil).
Topographic relief and the variable transmissivity of the
geologic media combine to produce a complex groundwater flow
system in the site area.
Groundwater flow in the shallow bedrock is mostly towards the
southwest, moving from the residential area northeast of the
landfill towards the landfill. Continuous water-level
monitoring, which was conducted in monitoring wells located
between the Site and the northeast residential area (see Figure
2), did not indicate any influences on the groundwater flow in
the shallow bedrock from residential well pumping. The
residential areas in other locations did not have any
contamination above NYS drinking water standards in their wells,
including those in the southwest of the landfill.
The downward vertical gradients in the bedrock located northeast
of the Site would facilitate the movement of groundwater from the
shallow bedrock to the deep bedrock, if they were connected by an
open borehole. As a result of the open borehole method of
construction, some of the residential wells, located northeast of
the land'fill, may act as a conduit for contaminant migration from
the shallow bedrock to the deep bedrock. Often in these mostly
open hole wells, the shallow bedrock would not be isolated (cased
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off) from-the deep bedrock, thus groundwater could flow downward.
Downward flaw could also be enhanced by well-pumping, especially
in low-yield, high-drawdown wells.
A summary of the hydrogeologic conditions for the Site are as
follows:
> The landfill is situated in a groundwater discharge
environment, i.e., perched leachate and lower leachate
primarily flows to North and South Brooks and their
associated wetlands.
* Shallow bedrock groundwater moves from the residential, area
northeast of the landfill towards the landfill.
> There is limited hydraulic connection between the shallow
bedrock groundwater and the deep bedrock groundwater.
" The hydraulic properties (i.e., hydraulic heads and lower
hydraulic conductivity) of the shallow bedrock minimizes th,e
movement of leachate to the north and northeast.
> The bedrock beneath the Site will tend to limit the vertical
movement of leachate, because of its low vertical hydraulic
conductivity. The well yield, hydraulic conductivity,
boring logs, and downhole geo'physical well log data indicate
that groundwater flow at depth is limited.
> The natural hydrogeologic conditions combined with the
construction techniques [well casing extending only a few
feet into competent rock] of deep residential wells
(typically 300 feet or greater) produce conditions that
allow for the downward vertical migration of shallow bedrock
groundwater to depths of 300 feet or more. Since the
residences are serviced by septic systems near the surface,
the existence of this pathway is further supported by the
presence of coliform bacteria, which is not usually found at
depth, in upgradient residential well samples. In addition,
the existence of this pathway is further supported by the
distribution of chlorinated organic compounds in the
upgradient bedrock groundwater, i.e., the highest
concentrations of chlorinated organics detected upgradient
were in the shallow bedrock groundwater.
Groundwater Sampling and Analytical Results
As part of the OU-1 RI/FS, fifteen groundwater monitoring wells
were installed, eight wells in the overburden aquifer and seven
in the bedrock aquifer (see Table 1); a number of piezometers
were also installed. Three rounds of groundwater samples were
collected from the monitoring wells. Residential wells in the
area were also sampled (see Table 2).
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As part of the OU-1 RI/FS, sampling and analyses of both the
monitoring and residential wells indicated that various organic
and inorganic contaminants exceeded federal and NYS drinking
water standards.
The OU-1 ROD, as an interim remedy, specified that certain
residential wells be provided with activated carbon filtration
units on an as needed basis. The OU-1 ROD also specified that a
supplemental groundwater investigation be conducted in order to
define better the hydrogeologic and chemical conditions at the
Site and, ultimately, to ensure that area residents are protected
from any potential site-related contaminants, particularly those
in the groundwater.
As part of the OU-2 RI, ten additional monitoring wells (shallow,
intermediate and deep) were installed on-site and off-site to
monitor both upgradient and downgradient groundwater quality at
the Site (see Table 1). As indicated above, the hydrogeologic
investigation revealed a complex scenario. In the overburden,
the downgradient flow is southeasterly, southwesterly and
northwesterly from the landfill; this stems primarily from the
geometry of the aquifer formation and the configuration of the
landfill itself. The actual discharge of the overburden aquifer
to adjacent wetlands and streams, however, occurs mainly in the
"northwesterly and southeasterly directions, since the
groundwater, moving in the southwesterly direction, meets a till
layer which acts as a dam and forces it along the front to the
northwest or the southeast. For the shallow bedrock, the
majority of the groundwater flow is in the southwesterly
direction. The hydrogeologic conditions indicate that areas
northeast and northwest of the landfill proper are upgradient of
the landfill proper. Downgradient locations in the shallow
bedrock can generally be defined as south and southwest of the
landfill. From the selective zone yield tests indicate that
water transmission decreases with depth. The deep bedrock was
not determined not be a high yield aquifer and was not the
subject of the OU-2 RI. Information from local drillers indicate
that some residential wells may be in the bedrock aquifer, but
there are indications that the yields for these wells is not as
high as for those which are located in the more water-producing
shallow bedrock.
Two rounds of groundwater sampling (upgradient and downgradient)
were conducted in December 1993 and August/September 1994. On-
site and off-site monitoring wells were sampled for a broad
spectrum of contaminants, including VOCs, semi-VOCs, pesticides,
PCBs, and inorganics. Also, during September 1994, as specified
under the OU-1 ROD, a residential well sampling program was
initiated; twenty-four homes were sampled for VOCs and inorganics
(see Table 2). .
Various VOCs were detected above the federal and NYS standards in
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seven monitoring wells during the two rounds of sampling (see
Table 3) . Maximum concentrations are reported here. During the
first round, 2-butanone was estimated at 100 ng/1 (upgradient) ,
1, 1-dichloroethene was detected at 6.8 ng/1 (upgradient), 1,1-
dichloroethane was detected at 7.2 vg/1 (upgradient), 1,1,1-
trichloroethane (TCA) was detected in two wells at 17 and 65
/j.g/1, respectively (upgradient). During the second round, 1,1-
dichloroethylene was detected at 12 ng/1 (upgradient), 1,1-
dichloroethane was detected at 8 ng/1 (upgradient) , 2-butanone
was detected at 31 M9/1 (upgradient) , toluene at 6 ng/l
(upgradient), TCA was detected at 5, 9 and 75 ng/l (upgradient)
and chloromethane was detected at 28 p.g/1 (downgradient) .
Benzene was detected in two wells at 4 M9/1 (downgradient) and
one well at 2 M9/1 (downgradient); these levels are above the NYS
Class GA standard of 0.7 ng/1. The detection and quantification
limit for benzene varied for each sampling round but were
generally less than 1
For the residential well sampling, only two wells had any VOCs
detected above NYS standards (see Table 4) . Chloroform was
detected in one residential well at 7 M9/1 (the NYS Class GA
standard is 5 ng/l) . TCA was detected in one of the residential
wells at 32 Mg/1 (NYS standard is 5 fj,g/l) . However, this well is
fitted with a carbon filter unit; the TCA was not detected in the
drinking water after treatment with the carbon filter unit. With
the exception of benzene and chloromethane, VOC contamination was
not found in downgradient wells above federal and NYS drinking
water standards. Available data and information indicate that
the low level VOC-contamination present in four residential wells
(all upgradient) is not landfill-related. These wells were
determined to be situated upgradient of the landfill.
Various inorganic compounds were detected at or above federal and
NYS primary drinking water standards in both upgradient and
downgradient monitoring and residential wells (see Table 3) .
During the first round of sampling, chromium was detected above
the NYS Class GA standard of 50 ng/1 at eight monitoring wells:
three upgradient wells had levels of 85 > 205 and 442 /Ltg/1 with an
average concentration of 244 jug/1/ and five downgradient wells
had levels ranging from 58 to 1250 ng/1 with an average
concentration of 384 ng/l. During the second round of sampling,
chromium was detected above the NYS standard at five monitoring
wells. Two upgradient wells had levels of 75 and 148 M9/1 with
an average concentration of 111 Mg/l» three downgradient wells
had levels of 60, 99 and 216 ng/1 with an average concentration
of 125 pg/1. For each sampling round, the filtered data showed
levels well below the NYS standard. In all but one case, the
chromium levels decreased in the second round of sampling. The
residential well sampling identified only two detections of
chromium, both well below NYS standards. These levels seem to
indicate that chromium is naturally occurring in the formation,
-------
12
i.e., background levels, since it is found at comparable levels,
both upgradient and downgradient of the landfill. The levels of
metals detected in the samples tend to directly depend on the
amount of suspended sediment (turbidity) in the samples. Since
this excessive turbidity is believed to be an artifact of
sampling, these higher levels are not representative of true in-
situ levels in the aquifer or levels which would be found at the
tap of a residential well.
Lead was also detected in both upgradient and downgradient
monitoring well samples. During the first round of sampling,
lead was detected above the federal action level of 15 M9/1 in
five monitoring wells: three upgradient wells (ranging from 36.7
to 290 M9/1) and two downgradient wells (20.5 and 32.5 M9/1)
During the second round of sampling, lead was detected above the
federal standard at four monitoring wells: three upgradient wells
(ranging from 37.2 to 80.5 Mg/1) and one downgradient well (35.4
Mg/1). During the residential well sampling, lead was also
detected above the federal action level in six wells (17.3 to
88.4 Mg/1) i all of which are located upgradient of the landfill.
DOH has resampled those residential wells previously identified
with lead levels above the federal action level and has
determined that the presence of lead is related to household
plumbing sources. DOH has advised jarea residents to run their
tap water prior to use for potable purposes.
In both sampling rounds, manganese was detected in almost all
monitoring wells above the NYS secondary drinking water standard
of 300 ^g/1. Manganese ranged between 2.2 fj.g/1 and 19,700 M9/1;
comparable levels were found in both upgradient and downgradient
monitoring wells. These levels appear to be representative of
background conditions in the area. The subsequent risk
discussion further explains that the manganese does not present a
health risk.
Iron was also detected in numerous upgradient and downgradient
wells above the secondary drinking water standard of 300 M9/1-
The range of levels was 32.8 to 414,000 M9/1 for upgradient
groundwater and 78.4 to 79,700 M9/1 for downgradient groundwater.
w
As indicated above, some of the monitoring and residential wells
showed somewhat elevated levels of iron and manganese; however,
the federal and NYS secondary standards for iron and manganese
are based on aesthetic properties and are intended to prevent
potential problems, such as poor taste, odor and staining of
plumbing fixtures and do not specifically present a health
hazard.
Since most of these contaminants presented here have isolated
hits at or above NYS standards, no plumes could be delineated for
.grganic or inorganic contaminants. A summary of the contaminants
-------
13
in the downgradient wells that exceeded NYS standards and
upgradient concentrations is presented in Table 5.
As discussed in the section below, sampling data from privately-
owned septic systems, which identified numerous VOCs, including
toluene and 1,1-dichloroethane, indicate that the septic systems
are a likely source of the contamination that is present in the
residential wells.
Surface Water. Sedimentf Leachate and Septic System Sampling and
Analytical Results
As part of the OU-1 RD, G+M conducted two rounds of surface water
and sediment sampling in June 1993 and April 1994; the data is
further identified in the Ecological Reports (August 1994). The
sampling was segregated into three zones with respect to the
landfill: upstream, adjacent and downstream. The surface water
sampling showed VOCs, semi-VOCs and metals, as well as numerous
non-detects among all contaminants. The maximum VOC levels
included chlorobenzene (2 ng/I-adjacent) and ethylbenzene (16
Mg/1-adjacent); no VOCs were detected downstream. The maximum
semi-VOC levels included bis(2-ethylhexyl)phthalate (15
upstream, 9 ng/1-adjacent and 5 ^g/l-downstream) and 4-
methylphenol (2 /ug/1 -upstream, 29 M9/l-adjacent) . The maximum
metal levels included aluminum (3660 M9/1-upstream,. 4160 ng/l-
adjacent and 172 ;ug/l-downstream) , iron (5630 ng/1 -upstream,
40,900 M9/l-adjacent and 1800 M9/1-downstream), magnesium (4320
Atg/1-upstream, 33,800 Mg/1-adjacent and 12,800 ng/1 -downstream),
manganese (317 fJ.g/1 -upstream, 2960 ^g/1-adjacent and 1800 M9/1-
downstream) and sodium (7550 M9/1 -upstream, 145,000 /ng/1-adjacent
and 22,200 /zg/1-downstream). In general, the detected levels for
all contaminants, except for iron and manganese, were within NYS
standards.
The sediment sampling indicated the presence of VOCs, semi-VOCs
.and metals. The maximum VOC levels included 2-butanone (0.044
mg/kg-upstream, 0.57 mg/kg-adjacent and 0.005 mg/kg-downstream)
and methylene chloride (0.004 mg/kg-upstream and 0.63 mg/kg-
adjacent) . The maximum semi-VOC levels included various PAHs,
chrysene at 9.2 mg/kg-downstream, fluoranthene at 20 mg/kg-
upstream, 5.7 mg/kg-adjacent and 26 mg/kg-downstream and bis(2-
ethylhexyl)phthalate at 0.16 mg/kg-upstream, 1.3 mg/kg-adjacent
and 0.3 mg/kg-downstream. Various metals were detected in all
three zones of sediment sampling and, in general, were at levels
within NYS criteria.
In December 1993, one round of leachate sampling was performed
from the landfill piezometers. The maximum VOC levels included
benzene (24 ng/1) , ethylbenzene (42 M9/1) / xylene (200 /ug/1),
toluene (34 Mg/1) and chlorobenzene (32 Mg/1) The maximum semi-
VOC levels included various PAHs: fluoranthene-0.2 ng/1 and
pyrene-170 M9/1- The maximum metal levels included barium (3630
-------
14
Mg/1), chromium (616 Mg/1), cobalt (289 Mg/1)/-iron (1.94 x 106
Mg/1), lead (4870 Mg/1) , manganese (9750 Mg/1) and nickel (591
Mg/1). The maximum pesticide levels included alpha-chlordane
(0.76 Mg/1)/ gamma-chlordane (0.51 Mg/1), 4,4'-DDE (0.14 Mg/1)
and 4,4-DDT (0.083 Mg/1)- Aroclors 1242 and 1254 (PCBs) were
detected at 2.5 and 5.2 Mg/1/ respectively.
Eleven residential septic systems were sampled, several of which
were found to contain very high levels of VOCs (see Table 6).
Concentrations of contaminants in some systems were so high that
the certain contaminants could not be analyzed at reasonable
detection limits (e.g., the detection limit for 1,1,1-TCA in RS-
29 was 92,000 Mg/kg). The maximum concentrations of VOCs
detected included: PCE at 1400 Mg/1/ 1,1-DCA at 17,000 Mg/1/
chlorobenzene at 1,200,000 Mg/kg and toluene at 160,000 Mg/kg.
These concentrations were several orders of magnitude higher than
any other levels collected in any other media during the study.
An effort was made to compare the levels found in the septic
systems with the levels found - in the residential wells in this
same neighborhood. It is noted, however, that the levels of
contaminants found in the residential wells were very low; aside'
from 32 Mg/1 of 1,1,1-TCA found in PW-11 and 7 Mg/1 of chloroform
found in RW-5, none of the other residential wells had levels of
contaminants at concentrations greater than 4 Mg/1* Nonetheless,
this comparison indicated that several of the septic system
contaminants or their breakdown products were also present in
some of the residential wells. For example, septic system RS- 37
contained 1400 Mg/1 of PCE (breakdown products 1,1-DCE and 1,1
DCA) while nearby residential well PW-11 contained 3 Mg/1 of 1,1-
DCE and 4 Mg/1 of 1,1-DCA. RW-37, which is located on the same
property as RS-37, contained 1 Mg/1 of 1,1-DCA. These data
suggest that the septic systems are the likely cause of the
contamination in the residential wells. This is further
supported by the presence of coliform bacteria in several
residential wells, including RW-37. Coliform bacteria often an
indicator of human waste, is typically found in septic systems.
Consistent with the implication that the septic systems are the
cause of the contamination in the overburden aquifer and
resulting contamination of the residential wells, is the fact
that MW-10S contained the highest level of contaminants of any of
the residential or monitoring wells located upgradient of the
Site (round 2 sampling results: 75 Mg/1 of 1,1,1-TCA, 12 Mg/1 of
1,1-DCE, 8 Mg/1 of 1,1-DCA). This shallow well is screened about
20-30 feet below grade, across the street and downgradient of RS-
37.
In addition, as a result of concerns expressed during the comment
period of the OU-1 Proposed Plan regarding sample analysis for
the presence of glycol ethers in groundwater, samples obtained
from four residential wells, six monitoring wells and eleven
septic systems were analyzed for these compounds, specifically 2-
-------
15
methoxy ethanol and 2-methoxy ethanol acetate. These compounds
were selected because of their high tpxicity relative to the
glycol ether group of compounds. EPAs National Exposure
Research Laboratory/Characterization Research Division, formerly
known as the Environmental Monitoring Systems Laboratory/Las
Vegas, developed an analytical method to analyze for glycol
ethers. The analyses showed that the two glycol ether compounds
were not detected (detection limit of 60 M9/1) in any of the ten
groundwater samples or the eleven septic system samples.. In
addition, further analysis of the septic system samples detected
phenols, chlorinated benzenes, e.g., chlorobenzene (4000 ng/1),
polynuclear aromatics and toluene (350 Mg/1) As indicated by
the previous septic system sampling, some of these compounds were
detected in nearby residential wells. These results further
indicate that the septic systems present a potential source of
contaminants to the private residential drinking water wells.
SUMMARY OF SITE RISKS
Based upon the results of the RI and the Baseline Ambient Air
Monitoring Program Report, a Baseline Risk Assessment was
conducted to estimate the risks associated with current and
future site conditions. The baseline risk assessment estimates
the human health and ecological risk which could result from the
contamination at the site if no remedial action were taken..
Human Health Risk Assessment
A four-step process is utilized for assessing site-related human
health risks for a reasonable maximum exposure scenario." Hazard
Identification identifies the contaminants of concern at the site
based on several factors such as toxicity, frequency of
occurrence, and concentration. Exposure Assessment estimates the
magnitude of actual and/or potential human exposures, the
frequency and duration of these exposures, and the pathways
(e.g., ingesting contaminated well-water) by which humans are
potentially exposed. Toxicity Assessment determines the types of
adverse health effects associated with chemical exposures, and
the relationship between magnitude of exposure .(dose) and
severity of adverse effects (response). Risk Characterization
summarizes and combines outputs of the exposure and toxicity
assessments to provide a quantitative assessment of site-related
risks.
The baseline risk assessment began with selecting contaminants of
concern which would be representative of site risks. These
contaminants included benzene, isopropylbenzene, chloromethane,
aluminum, antimony, chromium, cobalt, manganese, nickel, and
vanadium in the groundwater and benzene and methylene chloride in
-------
16
the ambient air. Several of the contaminants are known to cause
cancer in laboratory animals and are suspected or known to be
human carcinogens.
Current federal guidelines for acceptable exposures are an
individual lifetime excess carcinogenic risk in the range of 10"4
to 10"6 which can be interpreted to mean that an individual may
have a one in ten thousand to a 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.
Four exposure pathways were evaluated for OU-2 under possible on-
site present and future land use conditions, i.e., exposure.to
groundwater and air emissions to individuals residing at the
perimeter of the landfill. No scenario was evaluated for
residing on the landfill. These exposure pathways were evaluated
separately for adults and children. The exposure pathways
considered under both current and future uses include inhalation
of ambient air, ingestion of groundwater from the overburden and
bedrock aquifers, dermal contact with groundwater while
showering, and inhalation of chemicals while showering. Risks
calculated for these pathways do not take into account any
reductions in air and groundwater chemical concentrations which
are expected to result from the OU-1 capping. It should also be
noted that the residential well data was not utilized in the risk
calculations, because wells in which contaminants were found were
all considered to be upgradient of the Site.
No unacceptable carcinogenic risks, either for adults or
children, were found for exposure to groundwater. The greatest
risk for adults and children would result from groundwater
ingestion at 3.2 x 1CT7 and 1.1 x 10°, respectively (see Tables 7
and 8). Cancer risks from exposure to groundwater in the bedrock
aquifer are attributable primarily to benzene through direct
ingestion.
For ambient air, the primary contaminant of concern is methylene
chloride. No unacceptable carcinogenic risks, either for adults
or children,.,were calculated. The greatest risk for adults and
children are 2.2 x 10's and 8.6 x 10"6, respectively (see Table
9).
To assess the overall potential for noncarcinogenic effects posed
by more than one contaminant, EPA has developed a hazard index
(HI) . The HI measures the assumed simultaneous subthreshold
exposures to several chemicals which could result in an adverse
health effect. When the HI exceeds 1.0, there may be concern for
potential noncarcinogenic health effects.
Noncarcinogenic risks for adults and children are attributable
primarily to manganese through direct ingestion (see Tables 10
-------
17
and 11) . .JThe non-carcinogenic risk shows a total HI from the
bedrock groundwater pathway is 0.7 for an adult and 1.4 for a
child. For the overburden groundwater pathway, the total HI for
an adult is 0.08 and for a child is 0.2. For the air pathway,
the total HI for an adult is 0.4 and for a child is 0.9 (see
Table 12).
As indicated above, the results of the baseline risk assessment
show that, for all exposure pathways evaluated, the only total
noncarcinogenic risk with a calculated HI greater than 1.0 is for
the child receptor through ingestion of bedrock groundwater (see
Table 11); this HI is directly related to manganese, which is
considered an essential nutrient. The manganese dose received by
the child from consumption of bedrock groundwater is lower 'than
that which would be supplied by a common over-the-counter
multivitamin supplement.
The overall summary results for carcinogenic and non-carcinogenic
risks are presented in Table 13.
»
Ecological Risk Assessment
The results of the ecological investigations performed under the
OU-1 RD and the OU-2 RI support the conclusions identified in the
OU-1 RI. The environmental assessment evaluated potential
exposure routes of the Site contamination to terrestrial wildlife
and aquatic life. However, because of the low concentrations of
contaminants detected, lack of potential bioaccumulation, absence
of fishing and other recreational activity, and absence of known
endangered species, it was concluded that potential environmental
impacts were minimal and, as a result, the environmental.
assessment was not quantified. The wetlands in the vicinity of
the Site were delineated.
The need to minimize the disturbance of these wetlands habitats
via migration of contaminants from the landfill, as well as, via
any future remediation activities, was identified as an important
factor that was considered in the selection of the OU-1 landfill
capping remedy. It is noted that the capping remedy will, in
general, significantly reduce leachate generation.and will
eliminate leachate seeps, which are the most significant source
of contamination to the adjacent streams and wetlands.
Uncertainties
The procedures and inputs used to assess risks in this
evaluation, as in all such assessments, are subject to a wide
variety of uncertainties. In general, the main sources of
uncertainty include:
environmental chemistry sampling and analysis
» environmental parameter measurement
-------
18
» fate and transport modeling
» exposure parameter estimation
> toxicological data
Uncertainty in environmental sampling arises in part from the
potentially uneven distribution of chemicals in the media
sampled. Consequently, there is significant uncertainty as to
the actual levels present. Also, environmental chemistry
analysis error can stem from several sources including the errors
inherent in the analytical methods and characteristics of the
matrix being sampled.
Uncertainties in the exposure assessment are related to estimates
of how often an individual would actually come in contact with
the chemicals of concern, the period of time over which such
exposure would occur, and in the models used to estimate the
concentrations of the chemicals of concern at the point of
exposure.
Uncertainties in toxicological data occur in extrapolating both ,
from animals to humans and from high to low doses of exposure, as
well as from the difficulties in assessing the toxicity of a
mixture of chemicals. These uncertainties are addressed by
making conservative assumptions concerning risk and exposure
parameters throughout the assessment.
As a result, the baseline risk assessment provides upper bound
estimates of the risks to populations near the Landfill and is
highly unlikely to underestimate actual risks related to the
Site. More specific information concerning public health risks,
including a quantitative evaluation of the degree of risk
associated with various exposure pathways, is presented in the
OU-2 Risk Assessment Report.
SUMMARY OF THE SELECTED NO FURTHER ACTION REMEDY
Based on the findings of the OU-2 RI performed at the Site, EPA
and DEC have determined that site-related groundwater
contamination is very limited in extent, was not found to be the
probable source of contamination in wells located northeast of
the Site and does not pose any significant risk to human health
and the environment.
The OU-1 remedial action, a landfill cap, will be constructed
during 1996. Upon construction completion, the principal threats
of the Site will have been addressed. The cap will further
reduce infiltration or leaching of contaminants into the
groundwater and wetlands. The implementation of an environmental
monitoring program, which will include sampling of the
-------
19
groundwater, ambient air, surface water, sediments and landfill
gas will further ensure that the OU-1 and OU-2 remedies remain
protective of human health and the environment.
DOCUMENTATION OF SIGNIFICANT CHANGES
There are no significant changes from the preferred remedy
presented in the OU-2 Proposed Plan.
-------
APPENDIX I
FIGURES
-------
'00GE
_y
- J s //./"'/.<
.
WARWICK/
LANDFILL
SOURCE USGS GREENWOOD LAKE. NY NJ (1954). AND USGS WARWICK. NY (1976).
SCALE i 24000
SITE LOCATION
WARWICK LANDFILL SITE
WARWICK. NEW YORK
FIGURE
1
-------
:,l^iiMONITORING WELLS
"
PIEZOMETERS
REGIONAL GROUNDWATER FLOW
WARWICK LANDFILL
FIGURE
2
-------
APPENDIX II
TABLES
-------
TABLE 1
GROUNDWATER MONITORING WELLS
Zone/Flow Designation of Sampled Wells
Bedrock Downgradient
Bedrock Upgradient
Overburden Downgradieot
Overburden Upgradient
ou-z
MW-09D
MW-12
MW-13
MW-14
WL-02D
WL-04D
WL-05D
WL-06D
WL-08D
MW-10D
MW-10I
MW-10S
MW-1LD
MW-11S
WL-03D
WL-02S
WL-04S
WL^)5S
WL-06S
WL-07SA
WL-07SB
OU-I
WL-GW01-02
WL-GW01-12
WL-GW01-22
WL-GW02-02
WL-GW02-I2
WL-GW02-22
WL-GW04-02
WL-GW04-12
WL-GW04-21
WL-GW04-22
WL-GW05-02
WL-GW05-12
WL-GW05-22
WL-GW06-02
WL-GW06-12
WL-GW06-22
WL-GW08-02
WL-GW08-12
WL-GW08-22
WL-GW03-02
WL-GW03-12
WL-GW03-22
WL-GW02.01
WL-GW02-11
WL-GW02-D (dup)
WL-GW02-21
WL-GW04-01
WL-GW04^)3 (dup)
WL-GW04-11
WL-GW05-01
WL-GW05-11
WL-GW05-21
WL-GW06-01
WL-GW06-11
WL-GW06-21
WL-GW07-01
WL-GW07-11
WL-GW07-12
WL-GW07-21
WL-GW07-22
NTW-09S
VVL-08S
WL-GW01-01
WL-GW01-21
WL-GWOS^I1
WL-GW08-11
WL-GW08-21
-------
TABLE 2
RESIDENTIAL WELLS
Zone/Flow Designation of Sampled Wells
Bedrock Dowagradient
Bedrock Upgredient
Overburden Downgndient
Overburden Upgradient
ou-z
PW-01
PW-02
RW-06
RW-18
PW-06
PW-07
PW-08
PW-11_RAW
PW-13
PW-19
PW-22
PW-30
RW-04_RAW
RW-05
RW-19
RW-23
RW-27
RW-29
RW-31
RW-32
RW-37_RAW
RW-39
RW^O
RW^tl
OU-1
WL-RW06-01
WL-RW07-01 (dup)
WL-RW10-01
WL-RW11-01
WL-RW12-01
WL-RW13-01
WL-RW16-01
WL-RW17-01
WL-RW18-01
WL-RW02-01
WL-RWM-01
WU-RW05-01
WL-RW08-01
WL-RW09-01 (dup)
WL-RW1-M31
WL-RW15-01
WL-RW01-01
WL-RW03-01
-------
Page 1 of 2
Table 3. Summary of Residential Well and Monitoring Well Groundwater Quality. Warwick Landfill Site, Warwick, New York.
Upgradient Upgradient Groundwater
Groundwater Concentration Range
Constituent Detection Frequency Minimum
Detects/Total (ug/L)
VOCs
1.1,1 -Tf ichloroethane
1,1-Dichloroethane
1 . 1 -Dichloroethene
1.2-Oichloroethane
2-Butanone
Acetone
Benzene
Bromomelhane
Carbon disulfide
Chlorobenzene
Chloroethane
Chloroform
Chloromethane
cis-1 ,2-Dichloroethene
meta and/or para-Xylenes
ortho-Xylene
Tetrachloroethene
Toluene
BNAs
1 ,2-Dichlorobenzene
1 ,4-Dichlorobenzene
4-Methylphenol
Napthalene
Phenanthrene
Fluoranthrene
Pyrene
Chrysene
Di-n-octylphthalate
bis(2-Ethylhexyl)phthalate
Dimelhylphthalate
Butyl benzyl phthalatc
Pesticides/PCBs
Methoxychlor
15/35 0.3
9/35 0.3
7/35 0.4
ND
2/2 31
1/2
1/35
ND
2/35 0.1
ND
ND
1/31
1/35
ND
1/35
1/35
1/35
4/35 0.3
ND
ND
ND
1/15
2/15 0.4
ND
ND
ND
3/15 0.1
ND
2/15 0.4
1/15
1/15
Maximum
(ug/L)
75
8
6.8
100
35
0.5
2
...
7
0.6
0.3
0.5
0.3
8
...
...
...
0.5
0.9
...
...
...
0.5
0.8
0.2
0.5
Downgradient Downgradient Groundwater
Groundwaler Concentration Range
Detection Frequency Minimum
Detects/Total (urj/L|
ND
1/33
ND
1/33
ND
ND
3/33 2
1/33
2/33 1
3/33 2.9
3/33 0.6
ND
4/33 1
1/33
1/36
1/30
ND
3/33 0.1
1/29
3/29 1
1/29
1/29
ND
1/29
1/29
1/29
5/29 0.1
2/29 10
2/29 0.5
ND
ND .
Maximum
(ug/L)
...
0.4
...
4
...
4
0.6
1
5
1
...
28
0.3
1
0.3
0.6
0.5
3
0.6
2
0.8
0.8
0.5
0.9
10
2
NYSDEC
Standards and
Guidance Values
(ug/L)
i
5
5
5
5
50 GV
50 GV
0.7
5
NA
5
5
7
5
5
5 for each
5
5
5
4.7
4.7
NA
10 GV
50 GV
50 GV
50 GV
0.002 GV
50 GV
50
50 GV
50 GV
35
USEPA
MCL
(un/D
200
NA
7
5
NA
NA
5
NA
NA
NA
NA
NA
NA
70
10.000 (total)
10.000 (total)
5
1.000
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
40
See footnotes last page
-------
Page 2 of 2
Table 3. Summary of Residential Well and Monitoring Well Groundwater Quality, Warwick Landfill Site. Warwick, New York.
Constituent
Upgradient
Groundwater
Upgradient Groundwater
Concentration Range
Detection Frequency Minimum Maximum
Detects/Total
(ug/L)
(ug/L)
Downgradient
Groundwater
Detection Frequency
Detects/Total
Downgradient Groundwater
Concentration Range
Minimum
(ufl/LI
Maximum
(ug/L)
Metals: Total
Aluminum
Antimony
Arsenic
Barium
Beryllium
Cadmium
Calcium
Chromium
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Mercury
Nickel
Potassium
Sodium
Silver
Vanadium
Zinc
Selenium
Thallium
Cyanide
ug/L
VOCs
BNAs
PCBs
NA
GV
NO
NOC
NYSDEC
MCL
USEPA
AL
16/34
4/35
6/35
11/35
5/35
NO
35/35
10/35
8/35
27/34
27/35
20/35
35/35
21/35
1/35
7/35
34/35
35/35
2/35
6/35
28/28
1/35
2/35
NO
Micrograms per liter.
Volatile organic compounds.
u 47.1
0.4
1
7.8
J
4.850
6
3
9
32.8
1.3
1.250
2.2
13.8
593
1,950
2
9.2
9.2
...
1
229.000
1.4
59.2
1,290
17
361.000
442
277
653
414,000
290
130.000
19,700
0.61
830
68,000
124.OOO
2.4
315
1,470
5.0
1.3
...
30/33
6/33
7/33
29/33
3/33
1/33
33/33
23/33
16/33
23/33
32/33
25/33
33/33
28/33
ND
17/33
33/33
33/33
3/33
9//33
27/28
ND
ND
2/27
49.3
0.44
1.2
6.2
1.5
ND
6.480
3.2
4
4.9
78.4
1.0
1.910
4.1
...
12
608
1.730
2.1
5.4
5.0
...
15.6
24.600
35.0
7.3
1,160
6.8
3.5
287,000
1.250
59.7
77.3
79,700
35.4
106.000
17.100
177
8,860
336.000
3.4
51.0
140
ND
20.5
NYSDEC
Standards and
Guidance Values
(ug/L)
i
NA
3 GV
25
1.000
3 GV
10
NA
5O
NA
200
300
25
35.000 GV
3OO
2
NA
NA
20.000
50
NA
300
10
4 GV
100
USEPA
MCL
(ug/L|
NA
6
50
2.000
4
5
NA
1OO
NA
NA
NA
15 AL
NA
NA
2
100
NA
NA
NA
NA
NA
50
2
200
Base/neutral acid extractable compounds.
Polychlorinated biphenyls.
Not applicable.
Guidance value.
Not detected.
Non-detectable concentration.
Values apply to the sum of the
New York State Department of
Maximum contaminant level.
isomers.
Environmental Conservation.
U.S. Environmental Protection Agency.
USEPA action level.
Standards and guidance values are for NYSOEC Class GA
Groundwater.
Dissolved metal concentrations are shown in parentheses.
-------
Table 4. Summary of Residential Well Ground water Quality. Warwick Landfill Site. September 1994. Warwick
Landfill Site. Warwick, New York.
Residential Well
Constituent Groundwater
Detection Frequency
Metals: Total in uo/L
Aluminum
Antimony
Calcium
Copper
Iron
Lead
Magnesium
Manganese
Potassium
Sodium
Vanadium
Zinc
Volatile Organic Compounds in
1,1,1 -Trichloroethane
1 . 1 -Dichloroethane
1 , 1 -Oichloroethene
Carbon disulf ide
Chloroform
Tetrachloroethane
Toluene
Detects/Total
2 /23
3 724
24 /24
22 123
17 /24
22 /24
24 /24
8 /24
24 /24
24 /24
1 /24
20 /20
ug/L
8 /24
4 /24
1 /24
1 /24
1 /24
1 /24
1 /24
Residential Well
Concentration Ranoe
Minimum
(ug/L)
47.1
0.4
4,850
7.4
32.8
1.3
1,250
3.4
593
1.730
...
7.4
0.1
0.3
...
...
...
(ug/L)
59.6
0.53
55,600
533
1450
88.4
20.100
57.5
2630
35,900
9.2
347
32
4
3
2
7
0.3
3
NYSDEC
Standards and
Guidance Values
(ug/L)
NA
3 GV
NA
200
300
25
35.000 GV
300
NA
20.000
NA
300
5
5
5
NA
7
5
5
USEPA
MCL
(ug/Ll
NA
6
NA
NA
NA
15 AL
NA
NA
NA
NA
NA
NA
200
NA
- 7
NA
NA
5
1.000
ug/L Micrograms per liter.
NA Not applicable.
GV Guidance value.
NYSDEC New York State Department of Environmental Conservation.
MCL Maximum contaminant level.
USEPA U.S. Environmental
AL USEPA action level.
Protection Agency.
Standards and guidance values are for the NYSDEC Class GA Groundwater.
-------
Pane
Table: 5 Summary ol Consliloenls Detected in Downgradient Groundwalcr Samples that Exceed New York Slate Clnss GA G'oundwatcr Standards
and Guidance Values and Maximum Upgradient Concenlralions. Warwick Inndlill Silp. Warwick. New York.
Constituent
VOCs
Downgradient Groundwaicr Downgradienl Grnunrtwaler
Detection Frequency: Concentration Range:
Greater Than Standards Greater Than Standards
' , or Guidance Values or Guidance Values
DetectSfTotal Minimum Maximum
luo/LI lug (11
Chlornmelhane 1/33 -- 28
Benjene
BNA$
Chryscnc
2/33 2 4
1/29 0.5
NYSDEC
Standards
and
Guidance
Values
(ug/LI
5
07
0.002 GV
Maximum
Upgradient
Concentration
lug/U
06
05
ND
Number of Samples
that Exceed
Maximum
Upgradient
Concentration
and Standard or
Guidance Value
1
2
1
Wells that
Exceed Maximum
Upgradienl
Concentration
and Standard
or Guidance
j Value'
WL 5S
WL 8D. WL 20
WL7Sa
Metals (Dissolved!
Antimony
Iron
Magnesium
5/33 10.9 35.4
6/33 398 26.600
11/33 44.700 105.000
3 GV
300
35.000 GV
32
983
23.800
2
4
11
Wl 2S. WL 4D
WL 4S. WL-2D
WL 2S. WL 4S. WL
-2D.
Wl-4D.MW-9D.MW 13
Manganese
Sodium
ug/L
VOCs
BNAs
GV
ND
6/33 671 17.200
6/24 20.200 308.000
Micrograms per liter.
Volatile organic compounds.
Base neutral/acid extractable organic compounds.
Guidance values.
Not detected.
300
20.000
212
64.200
-
6
3
WL-2S. WL-4S. WL
WL 2S. WL 4S. Wl
20
2D
NYSDEC
Constituents thai exceed standards or guidance values and average upgradient concentrations were Hricr.ted only in monitoring wells.
New York State Department ol Environmental Conservation.
Standards and guidance values are lor NYSDEC Class GA Groundwater.
-------
Page 2 ol 2
Table 5 Summary ol Constituents Detected in Downgradienl Groundwalcr Samples that Exceed New York Stnle Class GA Groundwaler Standards
and Guidance Values and Maximum Upgradient Concentrations. Warwick Landfill Site. Warwick. New York.
Number ol Samples
Downgradient Groundwaler Downgradient Groundwater NYSDEC thai Exceed
Constituent
Detection Frequency:
Greater Than Standards
or Guidance Values
Detects/Total
Conr.enlrntion Range: Standards Maximum
Greater Than Standards and Maximum Uporadient
or Guidance Values Guidance Upgradient Concentration
Minimum Maximum Values Concentration and Standard or
(UO/L) (UO/L) liifi/U (ug/LI Guidance Value
Wells that
Exceed Maximum
Upgradieni
Concentration
and Standard
' or Guidance
Value '
Metals IToiall
Antimony
Chromium
Sodium
ug/L
VOCs
BNAs
GV
NO
3/33
8/33
12/33
Micrograms per liter.
Volatile organic compounds.
Base neutral/acid extractable organic compounds
Guidance values.
Not detected.
28.5 35 3 GV 1.4 3
58.2 t.250 50 442 1
20,100 336.000 20.000 124.000 6
MW-9D. WL 4D.
WL 2S
WL 7SA
WL-2D. WL 4S.
WL 2S
Constituents that exceed standards or guidance values and average Upgradient concentrations were detected only in monitoring wells.
NYSDEC New York State Department ol Environmental Conservation.
Standards and guidance values are (or NYSDEC Class GA Groundwater.
-------
Page 1 of J.
Table 6 Summary of Organic Constituents Detected in Leachate. Upgradient Monitoring Well, Upgradient Residential Well, and Residential Septic
System Samples, Warwick Landfill Site, Warwick, New York.
Constituent
Range of Leachate
Concentrations'
(ug/U
Range of Upgradient
Groundwater Concentrations7
(ug/L)
Range of Residential
Septic System Concentrations3
(ug/L and/or ug/kg)
Volatile Organic Compounds
Methylene chloride
2 Butanone
Benzene
Toluene
Chlorobenzene
Ethylbenzene
Xylene (total)4
2-Hexanone
4 -Methyl-2-pentanone
1.2 Dichloroethene (total)'
Acetone
1,1,1 -Trichloroethane
1,1 -Dichloroelhene
1.1 -Oichloroethane
Chloroform
Carbon disulfide
Tetrachloroethene
Chloromethane
2 to 5
7 to 55
2 to 24
1 to 33
13 to 32
2 to 42
10 to 200
3
25
2
15
ND
NO
ND
ND
ND
ND
ND
ND
31 100
0.5
0.3 10 8
ND
ND
0.8
ND
ND
ND
35
0.3 to 75
0.4 to 6.8
0.3 to 8
7
0.1 to 2.0
0.3
0.6
ND |2U (ug/L) to 92.000U (ug/kgll
6 (ug/kg) to 110 (ug/kg)
72000 (ug/kg)
15 (ug/kg) to 160.000 (ug/kg)
960 (ug/kg) to 1.200,000 (ug/kg)
15 (ug/kg)
42 (ug/kg)
ND |13U (ug/kg) to 92.000U (ug/kg|)
ND |5U (ug/kg| to 92.000U (ug/kg||
ND (0.5 U (ug/L) to 92.000U (ugflcgU
4 (ug/L) to 280 (ug/kg)
ND (0.5U (ug/L) to 92.000U (ug/kg))
ND (0.5U (ug/L| to 92.000U (ug/kg||
17 000 (ug/L)
200 (ug/U to 17^000 (ug/kgl
27 (ug/kg) to 130 (ug/kg)
1400 (ug/L)
ND (0.5U (ug/L) to 92.000U lug/kg))
See last page for footnotes.
-------
Paoe t of t
Table 6 Summary ol Organic Constituents Detected in Leachate, Upgradient Monitoring Well. Upgradient Residential Well, and Residential Septic
System Samples. Warwick Landfill Site, Warwick, New York.
Constituent
Range of Leachatr
Concentrations'
(ug/U
Range of Upgradient
Groundwater Concentrations*
(ug/U
Range of Residential
Septic System Concentrations3
(ug/L and/or ug/kg)
ug/L
ug/kg
II
U
Leachate concentrations include the results for aqueous samples collected from landfill piezometers and landfill seeps.
Sampling was conducted in 1990 and 1993.
Upgradient groundwater concentrations include the results for aqueous samples collected from residential wells and off site monitoring wells.
Sampling was conducted in 1993 and 1994.
Residential septic system concentrations include the results for non-aqueous and aqueous samples collected from the sludge at the bottom of the
septic tanks. Sampling was conducted in 1994.
When applicable, individual xylene results were added together to make total xylene.
When applicable, results for cis- and trans-1,2-dichlorethene were added together to make total 1,2-dichlorelhene.
Residential wells and residential septic systems were not sampled and analyzed for semivolatile organic compounds or pesticides
and polychlorinated biphenyls. ''
Micrograms per liter.
Micrograms per kilogram.
The range ol non-detected values is shown in brackets.
Constituent analyzed but not detected above the indicated detection limit.
ND
Not detected.
-------
TABLET
Adult Cancer Risks from Exposure to Un filtered Ground Water
Compound
Ground Water Ingestion
Dose
(mg/kg-
-------
TABLE: e
Child Cancer Risks from Exposure to Unfiltercd Ground Water
Compound
Ground Water Ingeslion || Ground Water Dermal || Ground Water Inhalation
Dose
(mg/kg-day)
Oral
Slope Factor
(mg/kg-day) '
IDose
(mg/kg-day)
Oral
Slope Factor
(mg/kg-day)1
IDose
(mg/kg-day)
Inhalation
Slope Factor
(mg/kg-day)1
Risk
Bedrock ,
Bcn/cnc
lsopropyll>cnzcne
Aluminum
Antimony
Chromium
Coball
Manganese
Nickel
Vanadium
3.66e-06
1.46e05
1.27e-02
l.37e-06
2.74c-04
6.74C-05
9.04e-03
1.89e-04
5.03C-05
2.90c-02
NA
NA
NA
NA
NA
NA
NA
NA
].06e-07
--
--
--
--
--
--
--
--
TOTAL 1.06C-07
1.12c-07
1.70c-08
1.4Mc-05
l.riOc-09
7.97c-07
3.93e-08
1.05e-05
2.75c-08
5.R6c-08
2.90c-02
NA
NA
NA
NA
NA
NA
NA
NA
3.25c-09
--
--
-
-
-
--
--
-
3.25C-09
2.20e-07
8.76e-07
0.00
0.00
0.00
0.00
0.00
0.00
0.00
2.91C-02
NA
NA
NA
NA
NA
NA
8.40e-01
NA
6.39e-09
-
--
--
-
-
--
0.00
«
6J9e-09
Overburden
Chloromclhanc
Antimony
Chromium
3.00e-05
7.44e-07
1.36e-03
NA
NA
NA
-
~
--
1.83C-07
8.66e-10
3.%c-06
NA
NA
NA
II l.SOc-06
0.00
I o.oo
3.90c-03
NA
NA
7.02C-09
--
-
TOTAL O.OOe+00 II O.OOe+00 II 7.02e-09
Notes:
NA Not available.
- Slope Factor Is not available, thus, risk Is not calculated.
-------
T/\BI_E
Adult Cancer Risks from Exposure to Contaminants in Ambient Air
Compound
Dose
(mg/kg-day)
Inhalation Slope Factor
(mg/kg-day)'
Risk
Benzene
2.62e-04
2.91 e-02
7.61c-06
Mclhylcne Chloride
8.44c-03
l/>4c-03
1.38e-05
TOTAL
2.l5e-05
Child Cancer Risks from Exposure to Contaminants in Ambient Air
Compound
Benzene
Mclhylcne Chloride
Dose
(mg/kg-day)
1.05e-04
3.38c-03
Inhalation Slope Factor
(mg/kg-day)'
2.91c-02
1.64e-03
Risk
3.04e-06
5.54e-06
TOTAL BSte-06
-------
TABLE 1 0
Adult Hazard Quotients and Hazard Indices from Exposure to Unfiltered Ground Water
Compound
Ground Water Ingestlon || Ground Water Dermal
Dose
(me/kfdar)
Oral
Reference Dose
(mg/kg-day)
IDose
(mg/kg-day)
Oral
Reference Dose
(mg/kg-day)
HQ
Ground Water Inhalation
Dose
(mg/kg-day)
Bedrock
Benzene
hopropylbenzcne
Aluminum
Antimony
Chromium
Cobalt
Manganese
Nickel
Vanadium
2.566-05
1.026-04
8.87e-02
9.59C-06
1.92e-03
4.72e-04
6J3e-02
1326-03
3.52e-04
NA
4.00C-02
l.OOe+00
4.006-04 '
l.OOe+00
6.00e-02
1.40c-01
2.00C-02
7.00e-03
-
2.55e03
8.87e-02
2.40e-02
1.92e-03
7.87c-03
4.52e-01
6.60e-02
5.03e-02
Hazard Index 6.93e-01
1.086-06
1.63e-07
1.42e-04
1.53e-08
7.666-06
3.78e-07
l.Ole-04
2.64e-07
5.64e-07
NA
4.00e-02
l.OOc+00
4.006-04
1.00e+ 00
6.00e-02
1.406-01
2.006-02
7.006-03
-
4.09e-06
1.42e-04
3.84e-OS
7.66e-06
6.29e-06
7.236-04
1.326-05
8.056-05
l.OJe-03
7.69e-07
3.06e-06
0.00
0.00
0.00
0.00
0.00
0.00
0.00
Inhalation
Reference Dose
(mg/kg-day)
HQ
1
1.71e-03
NA
1.43e-03
NA
NA
5.71e-06
1.436-05
NA
NA
4.50e-04
--
0.00
"
-
0.00
0.00
-
"
4JOC-04
Overburden
Cblorometbane
Antimony
Chromium
2.10e04
S.21e-06
9.52e-03
4.00C-03
4.00c-04
l.OOe+00
5.25e-02
1.30e-02
9J2e-03
Hazard Index 7.50*02
1.76e-06
8.33e09
3.81e-OS
4.006-03
4.006-04
l.OOe+00
4.41e-04
2.086-05
3.81e-05
S.OOe-04
6.306-06
0.00
0.00
NA
NA
NA
"
-
-
O.OOe+00
Notes:
HA Hazard Quotient
NA Not available.
- Reference Dose Is not available, thus HQ Is not calculated.
-------
TABLE 1 1
Child Hazard Quotients and Hazard Indices from Exposure to Unfiltercd Ground Water
Compound
Bentcnc
Isopropylbenzene
Aluminum
Aolimooy
Chromium
Cobalt
Manganese
Nickel
Vanadium
Ground Water Ingestlon Q Ground Water Dermal
Dose
(mg/kg-day)
5.13e-05
2.04e-04
1.77e-01
1.92e-05
3.83e-03
9.44e-04
1.276-01
2.64e-03
7.046-04
Oral Reference
Dose
(mg/kg-day)1
IDose
(rag/kg-day)
Oral Reference
Dose
(mg/kg-day) '
HQ
Bedrock
NA
4.00e-02
l.OOe+00
4.00e-04
1.00e +00
6.00e-02
1.40c-0l
2.00e-02
7.00C-03
-
S.lle-03
l.TTe-Ol
4.79e-02
3.83e-03
lJ7e-02
9.04e-01
1.32e-01
l.Olc-01
Hazard lade* U9e+00
1.57e-06
2.38e-07
2.07e-04
2.23e-08
1.126-05
5.50e-07
1.47e-04
3.84e-07
8.21C-07
NA
4.006-02
l.OOc+00
4.00e-04
1.006400
6.00e-02
1.406-01
2.006-02
7.006-03
5.95e-06
2.07e-04
5.58e-05
1.126-05
9.176-06
1.056-03
1.92C-05
1.176-04
1.48e-03
Ground Water Inhalation
Dose
(mg/kg-day)
Inhalation
Reference Dose
(mg/kg-day)1
HQ
3.086-06
1.23e-05
0.00
0.00
0.00
0.00
0.00
0.00
0.00
1.71e-03 j
NA
1.43C-03
NA
NA
5.7le-06
1.43e-05
NA
NA
l.BOe-03
--
0.00
-
~
0.00
0.00
-
lJOe-03
Overburden
Chloromethaoe
Antimony
Chromium
4.20e-04
1.04e-05
1.90C-02
4.00c-03
4.00C-04
1.00e + 00
1.05e-01 II 2.57e-06
2.60c-02 H 1.21e-08
1.90e-02 R 5.55c-05
4.006-03
4.006-04
1.00e+ 00
6.42e-04
3.03e-05
5.55e-05
Haunt Indei l.SOe-01 || 7JRc-04
2.526-05
0.00
0.00
NA
NA
NA
~
-
O.OOe+00
Notes:
HQ Hazard Quotient
NA Not available.
Reference Dose Is not available, thus HQ Is not calculated.
-------
TX\.OL_E:
Adult Hazard Quotients and Hazard
Index from Exposure to Contaminants in Ambient Air
Compound
Benzene
Melhylcnc Chloride
Dose
(rag/kg-day)
6.11c-04
1.97c-02
Inhalation Reference Dose
(mg/kg-day) '
1.71e03
8.60e-01
Hazard Quotient
3.57e-01 i
2.29c-02
Hazard Index 3.80e-01
Child Hazard Quotients and Hazard
Index from Exposure to Contaminants in Ambient Air
Compound
Dose
(ng/kg-day)
Inhalation Reference Dose
(mg/kg-day)
Hazard Quotient
Benzene
1.47e-03
1.71e-03
8.58e-01
Mclhylcne Chloride
4.73c-02
8.60C-01
Hazard Indei
9.13e-01
-------
1 3
Summary of Total Excess Lifetime Caocer Risks*
Ingestioo of Bedrock Ground Water
Dermal Contact with Bedrock Ground Water While Showering
Inhalation of Volatile* from Bedrock Ground Water While
Showering
Total Cancer Risk from Bedrock Ground Water Pathways
Ingtstion of Overburden Ground Water
Dermal Contact with Overburden Ground Water While
Showering
Inhalation of Volatile* from Overburden Ground Water While
Showering
Total Cancer Risk from Overburden Ground Water Pathways
Inhalation of Air
Total Cancer Risk from Air Pathway
Adult
3xio-7
1x10*
1x10*
3x10-'
-
ixitr*
1x10*
2xnr5
2xi
-------
APPENDIX III
ADMINISTRATIVE RECORD INDEX
-------
WARWICK LANDFILL SITE
OPERABLE UNIT TWO
ADMINISTRATIVE RECORD FILE
INDEX OF DOCUMENTS
1.0 SITE IDENTIFICATION
1.5 Operable Unit One Information
P. 100001 - Plan: final Residential Well Monitoring Program
100028 Work Plan. Warwick Landfill Site. Warwick. New
York, prepared by Geraghty & Miller, Inc.,
prepared for The Warwick Administrative Group,
February 1994.
P. 100029 - Letter to Mr. Damian Duda, New York/Caribbean
100039 Superfund Branch I, Emergency and Remedial
Response Division, U.S. EPA, Region II, from Mr.
Christopher J. Motta, C.P.G., Principal
Scientist/Project Manager, Geraghty & Miller,
Inc., and Mr. Gregory K. Shkuda, Ph.D., Senior
Associate/Project Officer, Geraghty & Miller,
Inc., re: Residential Well Monitoring Program,
Warwick Landfill Site, Warwick, New York, March
31, 1994. (Attached: Table 1: Summary of
Residential Well and Septic System Reconnaissance
Activities as of March 29, 1994, Warwick Landfill
Site, Warwick, New York, prepared by Geraghty &
Miller, undated.) (Note: Pages 100031 - 100039
are CONFIDENTIAL and are located in the Superfund
Records Center located at 290 Broadway, 18th
Floor, N.Y., N.Y. 10007-1866.)
P. 100040 - Report: Baseline Ambient Air Monitoring Program
100126 Report. Operable Unit One Remedial Design. Warwick
Landfill Site. Warwick. New York, prepared by
Geraghty & Miller, Inc., prepared for The Warwick
Administrative Group, September 1994.
P. 100127 - Letter to Mr. Damian Duda, New York/Caribbean
100128 Superfund Branch I, Emergency and Remedial
Response Division, U.S. EPA, Region II, from Mr.
Christopher J. Motta, C.P.G., Principal
Scientist/Project Manager, Geraghty & Miller,
Inc., and Mr. Gregory K. Shkuda, Ph.D., Senior
Associate/Project Officer, Geraghty & Miller,
Inc., re: Remedial Design, Warwick Landfill Site,
Warwick, New York, September 2, 1994.
-------
100129 -~ Letter to Mr. Damian Duda, New York/Caribbean
100130 Superfund Branch I, Emergency and Remedial
Response Division, U.S. EPA, Region II, from Mr.
Scott W. Golla, Staff Scientist, Geraghty &
Miller, Inc., Mr. Christopher J. Motta, C.P.G.,
Principal Scientist/Project Manager, Geraghty &
Miller, Inc., Mr. Gregory K. Shkuda, Ph.D., Senior
Associate/Project Officer, Geraghty & Miller,
Inc., and Mr. David L. Trozzo, Associate/Program
Technical Director, Air Quality Services, Geraghty
& Miller, Inc., re: Remedial Design, Warwick
Landfill Site, Warwick, New York, September 16,
1994.
100131 - Letter to Mr. Damian Duda, New York/Caribbean
100138 Superfund Branch I, Emergency and Remedial
Response Division, U.S. EPA, Region II, from Mr.
John E. Messinger, Staff Scientist, Geraghty &
Miller, Inc., Mr. Christopher J. Motta, C.P.G.,
Principal Scientist/Project Manager, Geraghty &
Miller, Inc., and Mr. Gregory K. Shkuda, Ph.D.,
Senior Associate/Project Officer, Geraghty &
Miller, Inc., re: Warwick Landfill Site, Warwick,
New York, Residential Well Monitoring Program,
March 9, 1995. (Attached: 1. Table l: Summary
of Residential Well Ranking .for the First Round of
the Residential Well Monitoring Program, Warwick
Landfill Site, Warwick, New York, prepared by
Geraghty & Miller, Inc., undated; 2. Table 2: New
York State and Federal MCLs for Constituents
Detected in Residential Well Samples, Warwick
Landfill Site, Warwick, New York, prepared by
Geraghty & Miller, Inc., undated; 3. Table 3:
Residential Wells Scheduled to be Sampled During
the Second Round of the Residential Well
Monitoring Program, Warwick Landfill Site,
Warwick, New York, prepared by Geraghty & Miller,
Inc., undated.) (Note: Pages 100136 - 100138 are
CONFIDENTIAL and are located in the Superfund
Records Center at 290 Broadway, 18th Floor, N.Y.,
N.Y. 10007-1866.)
100139 - Letter to Mr. James Petty, from Mr. Michael J.
100139 Kadlec, Public Health Specialist II (Env.), Bureau
of Environmental Exposure Investigation, Office of
Public Health, State of New York Department of
Health, re: Water samples collected from veil,
July 18, 1995.
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100140 - -Letter to Ms. Bernice Patterson, -from Mr. Michael
100140 J. Kadlec, Public Health Specialist II (Env.),
Bureau of Environmental Exposure Investigation,
Office of Public Health, State of New York
Department of Health, re: Water samples collected
from well, July 18, 1995.
100141 - Letter to Ms. Carol Munsey-Strawder, from Mr.
100141 Michael J. Kadlec, Public Health Specialist II
(Env.), Bureau of Environmental Exposure
Investigation, Office of .Public Health, State of
New York Department of Health, re: Water samples
collected from well, July 18, 1995.
100142 - Letter to Ms. Alice Dolson, from Mr. Michael J.
100142 Kadlec, Public Health Specialist II (Env.), Bureau
of Environmental Exposure Investigation, Office of
Public Health, State of New York Department of
Health, re: Water samples collected from well,
July 18, 1995.
100143 - Letter to Ms. Carol Munsey-Strawder, from Mr.
100143 Michael J. Kadlec, Public Health Specialist II
(Env.), Bureau of Environmental Exposure
Investigation, Office, of Public Health, State of
New York Department of Health, re: Water samples
collected from well, August 2, 1995.
100144 - Letter to Ms. Alice Dolson, from Mr. Michael J.
100144 Kadlec, Public Health Specialist II (Env.), Bureau
of Environmental Exposure Investigation, Office of
Public Health, State of New York Department of
Health, re: Water samples collected from well,
August 2, 1995.
100145 - Letter to Mr. James Petty, from Mr. Michael J.
100145 Kadlec, Public Health Specialist II (Env.), Bureau
of Environmental Exposure Investigation, Office of
Public Health, State of New York Department of
Health, re: Water samples collected from well,
August 2, 1995.
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3.0 REMEDIAL INVESTIGATION - OPERABLE UNIT TWO
3.1 Sampling and Analysis Plans
P. 300001 - Plan: Final Field Operations Plan. Operable Unit
300135 Two. Remedial Investigation/Feasibility Study.
Warwick Landfill Site. Warwick New York. Volume I
of III. Field Sampling and Analysis Plan, prepared
by Geraghty & Miller, Inc., prepared for The
Warwick Administrative Group, February 1993.
P. 300136 - Plan: Final Field Operations Plan. Operable Unit
300255 Two. Remedial Investigation/Feasibility Study.
Warwick Landfill Site. Warwick New York. Volume II
of III. Quality Assurance Project Plan, prepared
by Geraghty & Miller, Inc., prepared for The -
Warwick Administrative Group, February 1993.
P. 300256 - Plan: Final Field Operations Plan. Operable Unit
300337 Two. Remedial Investigation/Feasibility Study.
Warwick Landfill Site. Warwick New York. Volume
III of III. Health and Safety Plan, prepared by
Geraghty & Miller, Inc., prepared for The Warwick
Administrative Group, February 1993.
3.3 work Plans
P. 300338 -
300450
P.
P.
Plan: Final Work Plan. Operable Unit Two.
Remedial Investigation/Feasibility Study. Warwick
Landfill Site. Warwick. New York, prepared by
Ebasco Services Incorporated, prepared for U.S.
EPA, January 1992.
3.4 Remedial Investigation Reports
P. 300451 -
300588
300589
300602
300603
300740
Report: Ecological Reports. Operable Unit One
Remedial Design, and Operable Unit Two Remedial
Investigation. Warwick Landfill Site. Warwick. New
York, prepared by Geraghty & Miller, Inc.,
prepared for The Warwick Administrative Group,
August 1994.
Report: ENVIRON Corporation Qualifications
statement. prepared ENVIRON Corporation, prepared
for U.S. EPA, November 1994.
Report: Final Remedial Investigation Report.
Operable Unit Two. Warwick Landfill Site. Warwick.
New York. Volume I of II. prepared by Geraghty &
Miller, Inc., prepared for The Warwick
Administrative Group, July 1995.
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P. 300741 - Report: Final Remedial Investigation Report.
301044 Operable Unit Tvo. Warwick Landfill Site. Warwick.
New York. Volume II of II. prepared by Geraghty &
Miller, Inc., prepared for The Warwick
Administrative Group, July 1995.
3.5 correspondence
P. 301045 - Memorandum to Mr. Ken W. Brown, Manager,
301046 Technology Support Center, Technology Transfer and
Technical Support Branch, U.S. EPA, from Mr.
Steven M. Pyle, Chemist, Methods Research Branch,
QAD, U.S. EPA, Office of Research and Development,
re: Transmittal of Letter Report, Feasibility of
Using Direct Aqueous Injection (DAI) for the
Determination of Cellosolves in Aqueous Samples,
February 12, 1992.
P. 301047 - Letter to Mr. Doug Garbarini, Eastern New
301053 York/Caribbean Superfund Section I, Emergency and
Remedial Response Division, U.S. EPA, from Mr.
Christopher J. Motta, Senior Scientist/Project
Manager, Geraghty & Miller, Inc., and Mr. Bruce S.
McClellan, Project Director/Project Officer,
Geraghty & Miller, Inc., re: Field Operations
Plan, Operable Unit Two, Remedial
Investigation/Feasibility Study, Warwick Landfill
Site, Warwick, New York, October 26, 1992.
P. 301054 - Memorandum to Ms. Julie Allen, Remedial Project
301054 Manager, U.S. EPA, Region II, from Mr. Kenneth W.
Brown, Manager, Technology Support Center, U.S.
EPA, Office of Research and Development, re:
Analytical Support for the Warwick Landfill,
February 17, 1993.
P. 301055 - Letter to Ms. Julia Allen, Eastern New
301056 York/Caribbean Superfund Section I, Emergency and
Remedial Response Division, U.S. EPA, from Mr.
Christopher J. Motta, C.P.G., Principal Scientist,
Geraghty & Miller, Inc., and Mr. Gregory S.
.. Shkuda, Ph.D., Senior Associate, Geraghty &
Miller, Inc., re: Warwick Landfill Site, Warwick,
New York, Submission of the Final Field Operations
Plan (Final FOP) for Operable Unit Two of the
Warwick Landfill site, March 1, 1993.
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P. 301057 - Letter to Mr. Paul Montney, Georgia-Pacific, from
301060 Ms. Julia E. Allen, Project Manager, Eastern New
York/Caribbean Section I, U.S. EPA, re:
'Groundwater Samples for Glycol Ether Analyses at
Warwick Landfill Superfund Site, Warwick, New
York, May 13, 1993. (Attached: Feasibility of
Using Direct Aqueous Injection (DAI) for the
Determination of Cellosolves in Aqueous Samples,
undated.)
P. 301061 - Letter to Ms. Janet Cappelli, New York/Caribbean
301066 Superfund Branch I, Emergency and Remedial
Response Division, U.S. EPA, Region II, from Mr.
Christopher J. Motta, Principal Scientist/Project
Manager, Geraghty & Miller, Inc., and Mr. Gregory
K. Shkuda, Ph.D., Senior Associate/Project
Officer, Geraghty & Miller, Inc., re: Warwick
Landfill Site, Warwick, New York, Proposed
Modifications for the OU-2 Remedial Investigation
and the OU-1 Remedial Design, August 25, 1993.
P. 301067 - Memorandum to Regional Administrators, Regions I-
301076 X, from Mr. Richard J. Guimond, Assistant Surgeon
General, USPHS, Acting Assistant Administrator,
U.S. EPA, Washington, D.C., re: New Policy on
Performance of Risk Assessments During Remedial
Investigation/ Feasibility Studies (RI/FS)
Conducted by Potentially Responsible Parties
(PRPs), September 1, 1993.
P. 301077 - Letter to Mr. Mark Granger, Project Manager,
301078 Eastern New York/Caribbean Section II, U.S. EPA,
Region II, from Mr. William P. Eckel, Senior
Chemist, Disposal Safety Incorporated, re:
Threshold Concentrations of Glycol Ethers in
Ground Water, March 22, 1994. (Attached:
Drinking Water Threshold Concentrations Based on
Subchronic and Chronic Oral Reference Doses for
Glycol Ethers (all doses in Micrograms pre liter:
ppb), prepared by Disposal Safety Incorporated,
March 22, 1994.)
P. 301079 - Memorandum to Mr. Damian Duda, Remedial Project
301079 Manager, U.S. EPA, Region II, from Mr. Kenneth W.
Brown, Director, Technology Support Center, U.S.
EPA, Office of Research and Development, re:
Warwick Sample Analyses Results, February 3, 1995.
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5.0 RECORD OF DECISION
5.1 Record of Decision
P. 500001 - Record of Decision, Warwick Landfill Site, Town of
500096 Warwick, Orange County, New York, prepared by U.S.
EPA, Region II, June 27, 1991.
7.0 ENFORCEMENT
7.2 Endangerment Assessments
P. 700001 - Report: Baseline Risk Assessment for Operable
700112 Unit Two. Warwick Landfill. Warwick. New York.
prepared by ENVIRON Corporation, prepared for
Pitney, Hardin, Kipp & Szuch, July 1995.
P. 700113 - Report: Addendum A to Baseline Risk Assessment.
700218 prepared by Ms. Cindy F. Kleiman, Senior
Consultant, ENVIRON Corporation, and Mr. Stephen
T. Washburn, Principal, ENVIRON Corporation,
prepared for Mr. Doug Garbarini, Chief, Eastern
New York/Caribbean Section I, U.S. EPA, Region II,
July 25, 1995.
7.3 Administrative Orders
P. 700219 - Administrative Order on Consent for Remedial
700256 Investigation/Feasibility Study, Operable Unit No.
2, Index No. II CERCLA-20214, prepared by U.S.
EPA, Region II, September 28, 1992.
P. 700257 - Amendment to Administrative Order on Consent,
700264 Index No. II-CERCLA-20214, prepared by U.S. EPA,
Region II, May 16, 1995.
P. 700265 - Administrative Order Directing Compliance with
700270 Request for Access, Index No. II CERCLA-94-0201,
prepared by U.S. EPA, Region II, date illegible.
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7.8 Correspondence
P. 700271 -_ Memorandum to Mr. Stephen D. Luftig, Acting
700273 ~ Director, Office of Emergency and Remedial
Response, U.S. EPA, Region II, from Ms. Kathleen
C. Callahan, Director, Emergency and Remedial
Response Division, re: PRP Performance of Risk
Assessment During the Operable Unit 2 Remedial
Investigation/Feasibility Study at the Warwick
Landfill Superfund Site, Orange County, New York,
December 9, 1994.
P. 700274 - Memorandum to Ms. Kathleen C. Callahan, Director,
700274 Emergency and Remedial Response Division, U.S.
EPA, from Mr. Stephen D. Luftig, Acting Director,
Office of Emergency and Remedial Response, re:
Acknowledgment of Region II Consultation for PRP
Request to Perform the Baseline Risk Assessment at
the Warwick Landfill Superfund Site, December 28,
1994.
P. 700275 - Letter to Mr. Damian Duda, Emergency and Remedial
700276 Response Division, U.S. EPA, Region II, from Mr.
Stephen T. Washburn, Principal, ENVIRON
Corporation, and Ms. Cindy F. Kleiman, Senior
Consultant, ENVIRON Corporation, re: Warwick
Landfill Risk Assessment, May 5, 1995.
10.0 PUBLIC PARTICIPATION
10.9 Proposed Flans (SOP,FOP)
P. 10.00001- Plan: Superfund Proposed Plan. Warwick Landfill
10.00009 Site. Town of Warwickr Oranae County. New York.
prepared by U.S. EPA, Region II, July 1995.
P. 10.00010- Letter to Ms. Kathleen Callahan, Director,
10.00010 Emergency & Remedial Response Division, U.S. EPA,
Region II, from Mr. Michael J. O "Toole, Jr.,
Director, Division of Hazardous Waste Remediation,
New York State Department of Environmental
Conservation, re: Proposed Remedial Action Plan,
Warwick Landfill Site, July 26, 1995.
8
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APPENDIX IV
NYSDEC LETTER OF CONCURRENCE
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HEW YORK STATE DEPAHTIIEKT OF HmROUKIirAL CONSERVATHMI
mt WiM eM AftMf. § ** 12133
SEP 29 1985
M*. Kathleen Callahan
Director
Emergency A Remedial Response Division
U.S. Environment*) Protection Agency
Region 11
290 Broadway
New York, NY 10007.1866
Re: Warwick Landfill Site Operable Unit 2 ID No. 336014
Record of Decision
DearMs.CaJlahan:
The New York State Department of Environmental Conservation has reviewed the record of
decision for the Warwick Landfill tito. The Department concurs wilh the selected remedy of no further
action as it is detailed in the above-referenced document.
If you have any questions, please contact Mr. Jonathan Greco, of my staff, at (518)
457-3976.
Sincerely,
Michael J. O'Toole. Jr.
Director
Division of Hazardous Waste Remediation
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APPENDIX Y
RESPONSIVENESS SUMMARY
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APPENDIX V
RESPONSIVENESS SUMMARY
WARWICK LANDFILL SUPERFUND SITE
INTRODUCTION
A responsiveness summary is required by.Superfund regulation. It
provides a summary of citizens' comments and concerns received
during the public comment period, and the United States
Environmental Protection Agency's (EPA's) and the New York State
Department of Environmental Conservation's {NYSDEC's) responses
to those comments and concerns. All comments summarized in this
document have been considered in EPA's and NYSDEC's final
decision for the selected remedy for the Warwick Landfill 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 Proposed Plan for the Site was* released to the public for
comment on July 28, 1995. This document, together with the
Remedial Investigation report, the Baseline Risk Assessment and
other reports, was made available to the public in the
Administrative Record file at the EPA Docket Room in Region II,
New York, and in the information repository at the Warwick Town
Hall, 132 Kings Highway, Warwick, New York and the Greenwood Lake
Village Hall, Church Street, Greenwood Lake, New York. The
notice of availability for the above-referenced documents was
published in the Sunday Times Herald Record on August 13, 1995
and the Greenwood Lake and West Milford News on August 9, 1995.
The public comment period on these documents was open from July
28, 1995 to August 27, 1995. At the public meeting, the Dutch
Hollow Homeowners Association (DHHA) requested a thirty (30) day
extension to the public comment period. This extended the
comment period until September 26, 1995.
A meeting with town officials was held on August 15,' 1995 to.
discuss EPA's preferred remedy. That evening, EPA conducted a
public meeting at the Greenwood Lake Middle School, Greenwood
Lake, New York to discuss the Proposed Plan for Operable Unit Two
and to provide an opportunity for the interested parties to
present oral comments and questions to EPA.
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Attached to the Responsiveness Summary are the following
Appendices:
Appendix A - Proposed Plan
Appendix B - Public Notices
Appendix C - August 15, 1995 Public Meeting Attendance
Sheets (Not Available)
Appendix D - August 15, 1995 Public Meeting Transcript
Appendix E - Letters Submitted During the Public Comment
Period
SUMMARY OF COMMENTS AND RESPONSES
Comments expressed at the August 15, 1995 public meeting and
written comments received during the public comment period hav.e
been categorized as follows:
Operable Unit Two (OU-2) Remedy Selection
Hydrogeology/Groundwater
Alternate Water Supply
Residential Well Monitoring Program
Nature and Extent of Contamination
Risk and Health Assessment
Property Values
A summary of the comments and EPA's responses to the comments is
provided below.
A. Operable Unit Two Remedy Selection
Selected Remedy
Comment #1: One commenter expressed concern that EPA cannot
guarantee that groundwater problems will not occur in the future.
The commenter, as well as DHHA's Technical Assistance Grant (TAG)
advisors, also insisted that the residential wells are vulnerable
to contamination regardless of the source.
EPA's Response: EPA has determined that the low levels of
contamination found in residential wells northeast of the
landfill are not landfill-related because these homes are
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hydraulically upgradient of the landfill. Also, residential
wells located downgradient of the Site did not show any
contamination. Once the landfill is capped, the amount of
precipitation-induced leachate will be significantly reduced,
which will further diminish any likelihood that these homes will
be impacted by Site-related contaminants in the future. While
EPA cannot guarantee that residential wells in the vicinity will
not be impacted by groundwater contamination, the Agency believes
that it is unlikely that any potential future contamination would
be site-related.
Comment #2: One commenter was concerned that the installation of
a landfill cap will only serve to slow down generation/production
of the rainwater-induced leachate from the landfill and will not
prevent the migration of contamination already present in the
water table.
EPA's Response: Upon construction of the landfill cap under OU-1,
the principal threats, namely, precipitation-induced leachate and
leachate seeps, of the Site will have been addressed. While the
groundwater beneath the Site will not be contained, the landfill
cap will be very effective in significantly reducing the amount
of infiltration (and subsequent production of leachate) and be
protective of the adjacent wetlands. Furthermore, groundwater
sampling results indicate that groundwater contamination is not
significant enough to warrant groundwater containment, collection
or treatment.
Comment #3: One commenter inquired if EPA had a contingency plan
with respect to future contamination in place. Another commenter
inquired if the landfill will be monitored.
EPA's Response: After construction of the landfill cap, an
operations and maintenance (0+M) plan for the Site will be
implemented. Part of the post-construction activities will
include a sampling program for air, groundwater, sediment,
surface water and landfill gas to ensure that the remedy remains
protective of human health and the environment over the long
term.
Comment #4: Some Commenters expressed concern that" the placement
of the landfill cap could cause a change in the direction of
groundwater flow, thus redirecting the flow of contamination into
areas which were previously uncontaminated. They also expressed
concern that there is no guarantee that all wells around the
landfill will be safe in the future.
EPA's Response: The installation of the cap will not affect the
direction of groundwater flow, since the hydrogeologic gradients
will not change (See also EPA's response to Comment #1).
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Comment #5: DHHA's TAG advisors, as well as many commenters,
expressed concern that the preferred remedy of No Further Action
was not cost-effective. They indicated that connection to a
public water supply (at a cost of $2 million) should have
priority over the $16 million that EPA is willing to spend on the
cap, which includes $2.5 million for the groundwater monitoring
program. The installation of the public water supply would
eliminate the need for groundwater monitoring. The TAG advisor
had previously recommended, during the public comment period for
remedy selection for OU-1, that an alternate water supply would
be the most comprehensive, cost-effective, risk-free, permanent
solution to groundwater contamination in the community.
EPA's Response: As a result of the OU-1 RI, EPA determined that a
landfill cap would be required to protect human health and the
environment. In addition, the data generated as part of the OU-1
RI did not support the action of providing an alternate water
supply to homes in the vicinity of the Site where low levels of
VOCs were detected in residential wells. As a precautionary
measure, however, carbon filters were put on certain residential
wells. Based on the results of the OU-2 RI, EPA determined that
no groundwater remediation would be required at the Site. The
latest capital construction cost estimate for the cap is
approximately $4 million. The estimated present worth value of
the cap, including operation and maintenance, is approximately
$14 million. The estimated present worth of the groundwater
monitoring and the residential wells is approximately $3.5
million. Irrespective of whether homes in the vicinity of the
landfill are connected to a public water supply,, groundwater
monitoring would be required to ensure that the landfill cap is
protective of human health and the environment because hazardous
waste materials will remain on-site.
Remedial Investigation
Comment #6: Some commenters expressed concern that the EPA has
engaged the cooperation of the potentially responsible parties
(PRPs) during the investigations of the Site and that, as a
result, these investigations were not conducted in a
scientifically valid manner. According to the commenter, a valid
study would have recommended the installation of an alternate
water supply for the area.
EPA's Response: In applying an enforcement-first policy, in an
effort to conserve federal funds, EPA.negotiated an
Administrative Order on Consent (AOC) with the PRPs to conduct
the OU-2 RI and permitted them to hire their own contractor to
perform the work. Attached to the AOC is a Statement of Work
(SOW) which was prepared by EPA to ensure that the work would be
performed in a scientifically valid manner. Based on the SOW, a
Work Plan, a Quality Assurance/Quality Control (QA/QC) plan, and
a Field Operations Plan were developed to ensure a comprehensive
RI which would define the extent of groundwater contamination at
-------
the Site. The PRPs employed a reliable contractor to conduct the
investigation, whom EPA approved based on the contractor's
technical expertise and experience.
EPA, including hydrogeologists and experts in the fields of risk
assessment, wetlands, air and landfill caps, with the assistance
of NYSDEC, reviewed and approved all plans and reports regarding
the OU-2 RI. As part of their effort, EPA, with the assistance
of NYSDEC, directed all aspects of the work by the PRPs and their
contractor. EPA also hired its own contractor to oversee the
work of the PRPs' contractor. EPA personnel and Agency
contractors were in the field overseeing the PRPs' work during
all the major field activities. EPA's contractor split samples
with the PRPs' contractor to verify the accuracy of their
results. All data generated during the study was'validated
according to EPA guidelines. These aforementioned activities are
typically followed by EPA at sites where the Agency oversees PRPs
implementation of work.
Refer to EPA's previous response with regard to this comment that
a valid study would have recommended an alternate water supply.
Comment #7: Some commenters expressed concern regarding the
adequacy of the locations, numbers and depths of wells installed
for the study.
EPA'B Response: The decision to install an additional ten
monitoring wells as part of the OU-2 RI, in addition to the
twelve wells installed as part of the OU-1 RI, was based on the
recommendations of EPA and NYSDEC hydrogeologists. As part of
the OU-2 RI, all 22 monitoring wells, at depths varying from 10
to 324 feet, most of which are located in the shallow bedrock
aquifer, were sampled. EPA believes that the number, location
and depth of wells were adequate to determine the hydrogeologic
nature of the Site area.
Comment #8: One cotnmenter inquired if the monitoring wells and
test results have been properly protected from contamination.
EPA's Response: All the monitoring wells installed during OU-1
and OU-2 were constructed in accordance with EPA guidelines for
monitoring well construction to ensure that the wells were not
contaminated when they were installed. In addition, all
monitoring wells are kept locked to protect against any vandalism
and tampering. The groundwater samples were collected,
transported and analyzed according to strict EPA QA/QC and chain-
of-custody procedures to ensure the environmental sampling data
accurately reflect the contaminants present in the samples.
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Other/miscellaneous
Comment #9: The DHHA was concerned that the public meeting was
scheduled during peak vacation season, giving only two weeks
advanced notice.
EPA's Response: EPA usually schedules a public meeting two weeks
after the start of the public comment period; this allows the
public 1) time to review the documents prior to the public
meeting and 2) time to respond and submit additional comments
after the public meeting presentation. In addition, in response
to the DHHA request for additional time to review the technical
documents and EPA's preferred remedy, EPA granted a 30-day
extension to the public comment period. Although the public
meeting was held during the summer, over sixty people were in
attendance.
Comment #10: The DHHA expressed concern that its TAG advisors did
not have sufficient time to review the OU-2 documents prior to
the meeting and, thus, were not able to prepare or participate' a£
the public meeting.
EPA's Response: EPA sent DHHA's TAG advisor the RI prior to the
opening of the public comment period which began on July 28,
1995. The public meeting took place two weeks later on August .
15, 1995. EPA offered to meet with the DHHA and its TAG advisors
to discuss the OU-2 RI findings on EPA's OU-2 proposed No Further
Action remedy. In addition, as noted above, EPA granted a 30-day
extension to the public comment period at the DHHA's request.
Comment #11: The DHHA expressed concern that EPA has not been
responsive to its needs and has delayed the processing the
extension of project period of the TAG.
EPA's Response: For the past two years, EPA made significant
efforts to provide the DHHA and its TAG advisors with as much
information as they required with respect to understanding the
Site. These efforts included numerous telephone conversations
and letters, transmitting technical data and information about
the Site.
^
In December 1994, the DHHA had submitted a payment request to
EPA. It was apparent from the payment request that-the DHHA's
TAG advisors had.performed work after the expiration of the
project period of the TAG. Prior to its December submittal, the
DHHA had been notified by EPA through several telephone
conversations that its TAG project period would need to be
extended. In January 1995, EPA notified the DHHA by letter that
a request for extension to its TAG was necessary in order to
process payments. Subsequently, the DHHA submitted the request
for extension; however, the request was incomplete >and more
information was necessary before EPA could grant approval. After
the supplemental information was received, EPA approved the
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extension request, and processed the related payment request.
EPA had received no indication from the DHHA that its TAG
advisors were not working on the project while EPA processed the
TAG extension.
Comment #12: One commenter inquired if the landfill will be
removed from the National Priorities List (NPL) after the
capping, how long after capping would this take and if this is
performed for all sites.
EPA's Response: The Site will likely be deleted from the NPL
within a few years after construction of the cap. Ultimately,
all sites will be deleted from the National Priorities List.(NPL) .
Once a site has been deleted, however, EPA still has the
authority to take remedial action if it is deemed' necessary. EPA
first proposes a site for deletion from the NPL, solicits
comments on the proposed deletion, responds.to those comments,
and then recommends the Site for final deletion from the NPL.
Comment #13: DHHA's TAG advisors expressed concern that the OU-2 ,
Proposed Plan does not consider possible future development.
EPA's Response: Future residential development was not evaluated
for the landfill, since the OU-1 cap remedy precludes residential
development of the landfill itself. Future residential
development of the areas adjacent to the Site was evaluated in
the risk assessment to determine the risks posed if potential
future residents drilled wells in areas around the Site. The
groundwater sampling results from the Site were used to represent
the groundwater a hypothetical resident living adjacent to the
landfill would consume. The future on-site and off-site .
residents were evaluated as if each were drinking two liters of
the on-site/off-site groundwater for each year for 30 years out
of a 70-year lifetime. For this scenario, the risk was
determined to be within EPA's acceptable risk range. There is no
indication that any contaminant plume (organic or inorganic) is
occurring off-site.
B. Hydrogeology/Groundwater
Comment #14: Some commenters inquired about the direction of
groundwater flow and the potential impacts to the wetlands.
EPA's Response: The direction of groundwater flow varies,
depending on which aquifer is being discussed. For the most
part, the shallow bedrock aquifer contains the majority of the
water used in the area and the direction of groundwater flow is
to the southwest. The groundwater in the overburden aquifer
flows in many directions as a result of complex hydrogeology.
Impacts to the wetlands from the Site can be described as
minimal, because of low concentrations of contaminants measured
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8
in the wetlands, lack of evidence of potential bioaccumulation of
contaminants, absence of fishing and other recreational
activities, and absence of any known endangered species.
Comment #15: Some commenters expressed concern regarding the pump
test; their concern was specifically related to whether the use
of only two wells northeast of the landfill was sufficient from a
statistical perspective to make an assessment of groundwater
flow, particularly the potential for flow to the northwest or
northeast, and whether the wells were appropriately located,
(i.e., the wells may not have been installed in the same portion
of the aquifer from which the residential wells draw their
water).
EPA's Response: Although only two deep bedrock monitoring wells
were utilized, information gathered from these wells was just a
small portion of the data used to determine the direction of
groundwater flow. Numerous monitoring wells and piezometers were
installed and sampled, and numerous residential wells to the
northeast were sampled. This information indicates that the
groundwater moving to the southwest would have to overcome a
significant gradient in order to flow north. The data generated
from both the OU-1 RI and the OU-2 RI indicate that the landfill
is not the source of the low levels of contamination found in the
residential wells.
Comment #16: One commenter inquired as to the difference between
a shallow well and a deep well.
EPA's Response: For the Site, the shallow wells range from 6 to
45 feet, and the deep wells range from 45 to 324 feet.
C. Alternate Water Supply
Comment #17: Most commenters and DHHA's TAG advisors expressed
strong support for the implementation of an alternate public
water supply system, since they believe it would be cost-
effective and would be beneficial for health.
EPA's Response: The OU-2 RI indicates that the low levels of
site-related groundwater contamination do not pose unacceptable
risks to human health and the environment and fully supports the
preferred No Further Action remedy. The limited groundwater
contamination, the direction of groundwater flow away from the
residences in the northeast and the fact that contamination does
not appear to be migrating off-site confirm that there is no
technical basis for selecting an alternate water public supply
system as a remedy.
Comment #18: Some commenters were concerned that the Superfund
program, as related to the Site, could not protect the Village of
Greenwood Lake's (VGL's) public water supply system.
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EPA's Response: EPA believes that it is unlikely that the Site
could have a negative impact on the VGL aquifer system, which is
situated nearly 1& miles downgradient of the Site. As part of
the OU-2 RI, ten downgradient monitoring wells were sampled. The
resulting data indicated very low levels of VOCs and some levels
of inorganics above New York State (NYS) standards; there is no
indication of a contaminant plume migrating off-site. The risks
posed by the Site were within EPA's acceptable risk range. The
VGL's public water supply is monitored for a variety of
parameters by the New York State Department of Health (NYSDOH)
under the state public water supply standards, as are all public
water supplies serving more than 25 persons. Some of these wells
will be included in the monitoring program to be conducted after
the construction of the cap to ensure that contamination is not
migrating from the Site.
D. Residential Well Monitoring Program (RWMP)
Comment #19: The DHHA expressed concern that the residential well'
program was not complete, that everyone within the radius of the
study was not properly contacted and that registered letters were
not sent to the residents.
EPA's Response: EPA believes that the RWMP is a comprehensive
effort to obtain residential well quality data from all homes in
the vicinity of the Site. The RWMP was developed by the PRPs's
contractor and was reviewed and approved by EPA and NYSDEC. The.
study area was defined as one-quarter mile from the landfill
boundary in all directions. One of the activities conducted as
part of the RWMP was a thorough canvassing of the residents
within the study boundary. The canvassing effort involved door-
to-door interviews with residents, telephone calls, and mailings
which included a well survey, access agreement and a stamped
return envelope, to those property owners who could be contacted
and were within the study area. Prior to sampling the
residential wells, an access agreement was executed by the
homeowner.
However, in an effort to further expand the number of
participants in the program, EPA and the PRPs' contractor
recently performed a follow up door-to-door survey of many of the
residents in the area and transmitted registered letters. The
response to this latest effort to contact residents will be
reflected by expanding the number of residential wells to be
included during the third sampling event. EPA and the PRPs have
also contacted the Town of Warwick to secure tax and ownership
information about properties which have been abandoned or are
seasonally occupied.
Comment #20: Two commenters expressed concern that they were
contacted, but their well was not sampled.
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EPA's Response: EPA assured these residents that they would be
contacted in the future to arrange for the sampling of their
wells. EPA also requested at the public meeting that if any
other residents within the one-quarter mile radius were not
contacted, or if anyone had knowledge of others within the one-
quarter mile area that had not been contacted, to provide that
information to EPA. (Note: As of the date that this ROD is being
issued, EPA has not been contacted by any additional parties.)
Comment #21: Two commenters expressed concern that their wells
would not be sampled, since they were outside of the one-quarter
mile radius. They requested information on companies that
perform residential well sampling and analysis, and the fee for
these activities. These commenters also expressed concern
regarding groundwater filters and their effectiveness.
EPA's Response: NYSDOH has indicated that it has a list of
various companies which test private well water; this information
can be accessed by calling NYSDOH's Environmental Laboratories
Approval Program at (518) 447-4197. Also, NYSDOH indicated that
it may perform some isolated sampling for those residents who ar"e
concerned about their drinking water supply.
Carbon filter units are very effective in removing VOCs from
residential water supplies; reverse osmosis units are effective
where metals contamination is a concern. Sampling for lead is
also suggested in homes with children and pregnant women. The
costs of such sampling can range from $500 to $2000, depending on
the number and type of contaminants analyzed.
Comment #22: One commenter inquired if EPA will notify the
residents if their drinking water is contaminated and what the
time frame was for the receipt of the sampling results.
EPA's Response: EPA transmitted the first round of residential
well data with a letter to each resident; the letters and data
were also transmitted to NYSDOH. The letter outlined the
specific details of the data, and identified any contaminant that
was detected above NYS or federal standards. In such cases, the
NYSDOH would assess the necessity for any remediation of the
water supply. For example, during the first round of the RWMP
sampling, lead was detected above the federal action level; the
NYSDOH subsequently resampled those wells to verify the presence
of lead above standards in those wells. The subsequent data
showed lead levels below the federal action level. EPA will
follow these procedures for all future rounds of the RWMP. The
validated data should be received by EPA within two to three
months after the sampling event and be mailed to residents
shortly thereafter.
Comment If23 : One commenter expressed concern over an unpleasant
odor in her drinking water.
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EPA's Response: EPA and the PRPs' contractor visited the
resident; the hot water did have an odor, the cold did not. It
is noted, however, that the resident's well is currently
connected to a carbon filter unit, and the RWMP sampling showed
no contamination above NYS standards. EPA contacted the NYSDOH
to follow up on the matter.
Comment #24: One commenter and the DHHA's TAG advisors expressed
concern that the carbon filter units would be removed from the
affected residential wells.
EPA's Response: NYSDEC has indicated to EPA that the Department
does not intend to remove the units.
E. Nature and Extent of Contamination
Comment #25: Commenters inquired as to the number of septic
systems sampled, the kind of chemicals that were found in the
septic systems, and how these chemicals got into the septic
systems.
EPA's Response: Eleven septic systems were sampled. Numerous
VOCs were detected in the septic systems, including toluene,
chlorobenzene and 1,1-dichloroethane. While it is uncertain how
these chemicals got into the septic systems, these and other
compounds are typically found in household products such as
polish/polish removers, paints, paint thinners, automotive
degreasers, etc. Also, past practices for cleaning septic
systems utilized products, such as solvents and degreasers, which
contained the contaminants detected in the septic systems.
Comment #26: Some commenters inquired as to the correlation
between septic systems and well contamination, and expressed
concern that the septic systems are not the sole source of
contamination in residential wells. They suggested that the
septic systems discharges would be small in comparison to the
vast quantity of material disposed in the landfill.
EPA's Response: On some properties the well and septic system
are fairly close together providing conditions which are
potentially conducive to cross contamination. Wells, need not be
on the same property as a contaminated septic system to be
impacted. A septic system could contaminate several wells on
neighboring properties. It is also noted that the residential
wells in the area draw water from the bedrock aquifer. These
wells are typically cased only for a portion of their depth to
allow as much water to infiltrate into the well as possible so
that the well yield is adequate. However, this construction can
also serve as a potential conduit for transport of contaminants
across one area of the bedrock into a deeper portion of the
bedrock where the well is screened.
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While EPA agrees that septic systems may not be the sole source
of contamination in residential wells, EPA has determined,
through the RI hydrogeologic study, that groundwater impacting
the residential wells flows away from the northeast residential
area. Although it is believed that significant quantities of
waste may have been disposed at the landfill, groundwater beneath
and downgradient of the landfill has shown limited contamination,
and there is no direct correlation shown between landfill
contaminants and the residential well contamination. In
addition, contamination of an aquifer at the low levels detected
in the residential wells can result from the discharge of very
small quantities of contaminants. Given the levels of
contaminants found, in the septic systems to the northeast of the
landfill, it would be quite reasonable to find low level
groundwater contamination in this area.
Comment #27: One commenter inquired as to how one could
differentiate if the septic system contaminated the groundwater
or if the groundwater contaminated the septic system.
EPA's Response: Both liquids and sediments in the septic systems'
were sampled. The levels of contamination found in the septic
system sediments were extremely high in comparison to groundwater
monitoring well data or residential well data.
Cross-contamination from septic systems to residential wells is a
common problem. Coliform bacteria, which is found in waste
produced by the human body, was also detected in residential
wells, and, by its nature, is always found in septic systems.
This fact provides additional evidence that septic discharges
have migrated into residential wells.
Comment #28: One commenter inquired if the residents received
questionnaires regarding the use of their septic systems and the
possible discharge of any contaminants into the systems.
EPA's Response: No formal survey was performed. EPA does not
have information on the types of materials residents have added
to their septic systems or if outside contractors have cleaned
out their septic systems. EPA did provide some of the residents
with a fact sheet on septic system maintenance and did caution
the residents- regarding the impacts of disposal of inappropriate
liquids to their septic systems.
Comment #29: One commenter expressed concern about whether the
residential wells were located a safe distance from septic
systems, assuming that 100 feet was the required distance between
a private water supply well and a septic system, including the
leach field.
EPA's Response: In this case, it appears as though the spacing
may not have been adequate. However, regardless of the spacing,
residents that have both a residential well and a septic system
should be cautious about the types of materials that they dispose
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13
of via their plumbing system, as well as the types of materials
they use to maintain these systems. The sanitary codes that have
been set up in local communities or states identify how far the
wells should be from the septic system. The original intent of
this sanitary code buffer zone was to prevent bacteria, e.g., E.
coli, from migrating from the septic tanks to the wells; these
concerns pre-dated concerns regarding organic solvent
contamination of groundwater and residential wells. EPA is not
responsible for establishing these codes. The local health
department should be able to provide additional information
regarding best management practices for the installation of
residential wells and septic systems.
Comment #30: One commenter suggested that since the solvents
showing up in the septic systems are highly evaporative, they
would tend to volatilize before showing up in a residential well,
unless large quantities were placed in the septic systems.
EPA's Response: While it is true that VOCs such as those found in
the septic systems due tend to volatilize, they also adsorb to
suspended or fixed organic materials, dissolve in water, and
dissolve in other solvents. Since the presence of very low
concentrations of these contaminants in drinking water present a
health concern, even small quantities of these solvents can cause
significant groundwater contamination problems. The levels found
in the septic systems appear to have been high enough to cause
the problems found in the residential wells northeast of the
landfill.
Comment #31: One commenter expressed concern that benzene was
detected in monitoring wells sampled as part of the OU-1 RI.
EPA's Response: Benzene was detected in two on-site monitoring
wells in OU-1 above the NYS drinking water standard of 0.7 /xg/1.
The carcinogenic risks identified, in the OU-1 risk assessment
were within EPA's acceptable risk range. During OU-2, benzene
was detected in three downgradient wells and one upgradient well;
all detected levels were well below the NYS drinking water
standard. The OU-2 risk assessment showed that risks posed from
benzene and other contaminants are within EPA's acceptable risk
range.
F. Risk and Health Assessment
Characterization and Scope of the Risk Assessment
Comment #32: DHHA's TAG advisor expressed concern that the risk
assessment ignores the fact that actual residents are close to
the Site.
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EPA's Response: The remedial investigation report, based on
extensive hydrogeologic investigations, determined that the VOC-
contaminated residential wells present near the Site are
upgradient of the landfill, and, therefore, are not affected by
any landfill contamination. The downgradient residential wells
showed no VOC contamination. Ambient air and soil/gas sampling
results indicated that residents would not be exposed to
significant levels of VOCs.
Comment #33: DHHA's TAG advisor expressed concern that combined
exposures to contaminated water and air that may potentially
occur in the future were not taken into account. They also
expressed concern of the likelihood of receptors being impacted
by both VOCs in the ambient air and VOCs volatilizing during the
use of contaminated groundwater (e.g., ingestion and showering).
EPA's Response: For carcinogenic risk, ambient air pathways were
used in calculating potential cancer risks. Assuming that the
same individuals were exposed 'through all exposure pathways at
chemical concentrations identified, the addition of groundwater-
derived cancer risks to the ambient air risks would not affect
the conclusions of the risk assessment.
For noncarcinogenic risks, the Hazard Indices (His) from the
overburden exposure pathways are minor relative to the His from
ambient air and thus combining pathways would not affect the
overall risk. The overall His from bedrock groundwater and
ambient air are similar in magnitude; however, it is not
appropriate to add the two values, since the contaminants of
concern do not affect the same target organs.
Selection of Data on Chemical Contamination
Comment #34: DHHA's TAG advisor expressed concern that the risk
assessment relied solely on OU-2 RI data rather than data from
both the OU-2 and the OU-1 RIs.
EPA's Response: EPA felt it appropriate to represent existing
Site conditions and, therefore, utilized the most recent sampling
data as used in the baseline risk assessment. The OU-1 data was
not entirely dismissed, since it was used to assist in
determining 1:he list of chemicals of concern (COCs) for the risk
assessment. Any chemical that was found more than once in the
OU-1 and OU-2 data sets was included in the initial list of COCs.
As a conservative measure, if the most recent OU-2 sampling did
not detect a chemical that showed up previously in the OU-1 data,
it was included as a chemical of concern at one half the
detection limit. The practice of using one half the detection
limit when a chemical is not detected in a sampling event to
calculate exposure point concentrations is recommended in the
EPA's Risk Assessment Guidance for Superfund (RAGS) document and
is discussed in the Guidance for Data Useability in Risk
Assessment (Part A).
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Comment #35: DHHA's TAG advisor expressed concern that the
trimming of chemicals found at the Site to a small list of
indicator chemicals was contrary to EPA .guidance.
EPA'e Response: The bedrock aquifer sampling detected 50
compounds and the overburden sampling detected 29 compounds. The
procedures utilized in preparing the risk assessment to reduce
the list of COCs are recommended in the RAGS guidance and are
used in the majority of risk assessments prepared by and for EPA.
These procedures direct the risk assessment to concentrate on the
chemicals that are contributing the majority of the risks and
recommend the elimination of chemicals that are considered
essential nutrients such as calcium and magnesium, or which are
indicative of background conditions or are detected infrequently.
Comment #36: DHHA's TAG advisor expressed concern that the
elimination of chemicals that were detected below regulatory
standards is not clear.
EPA's Response: This comment was also expressed by EPA during the
preparation of the risk assessment.' In order to clarify this,
the risks including the chemicals that were eliminated were
recalculated based on their presence below MCLs. As a result,
the revised total excess lifetime cancer risk for adults remained
essentially unchanged (3 x 10'7 vs. 4 x 10'7) and for children the.
risk remained the same (1 x 10'7) . For adults and children
exposed to the overburden groundwater, the risk remained the same
at 1 x 10'8. As such, the revised assessment showed that the
risks would still fall within the acceptable risk range.
Comment #37: DHHA's TAG advisor expressed concern that chemicals
were eliminated as a result of selective zone sampling and were
in conflict with EPA guidance.
EPA's Response: The OU-1 and the OU-2 risk assessments determined
that the overburden and bedrock aquifers were separate and
distinct. These aquifers are not considered "zones" but two
separate entities with different hydrogeologic characteristics,
chemistry and contaminants. If a compound was not detected more
than once in the overburden aquifer in both the OU-1 and OU-2
RIs, it was not considered a COC for the overburden aquifer. The
same holds true for the bedrock aquifer. This approach is
consistent with EPA guidance.
Comment #38: DHHA's TAG advisor expressed concern that the no-
observed-adverse-effect-level (NOAEL) identified in the risk
assessment should not be expressed as a conservative estimate of
a threshold dose for the exposed population.
EPA's Response: EPA scientists responsible for verifying
noncarcinogenic toxicity information evaluate all risk studies to
determine the viability of the NOAEL for use in determining a
safe RfD for the general population. However, when deriving the
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related RfD, EPA divides the NOAEL by one or more conservative
uncertainty factors to account for the variation in the general
population, i.e., sensitive subpopulations. This is particularly
important when extrapolating from animals to humans or when a
NOAEL is derived from a subchronic study.
Comment #39: DHHA's TAG advisor expressed concern that the use of
a dietary Reference Dose (RfD) for manganese is not justified and
misleads the information presented in EPA's integrated risk
information system or IRIS.
EPA's Response: The most up-to-date EPA guidance relating to the
systemic toxicity of manganese was used at the time the risk
assessment was prepared (July 1995). At that time, it was
standard practice to use the dietary RfD instead of the water RfD
for the groundwater ingestion pathway, based on the reevaluation
of a critical study (Kondakis) for the water RfD. The
information regarding the use of the dietary RfD for the
ingestion of groundwater was recommended by EPA's National Center
for Environmental Assessment in Cincinnati. The risk assessment,
used the dietary RfD in the noncancer risk calculations. After
this risk assessment was finalized, a revised methodology for
evaluating manganese was developed. A review of this methodology
indicates that dietary sources of manganese should be separated
from nondietary sources, such as contaminated groundwater and
soil. The dietary RfD remains viable with a modifying factor to
account for the nondietary intakes of manganese. 2,000 /ig/1 of
manganese in drinking water remains a potential concern as
expressed by EPA scientists responsible for assessing manganese
toxicity in groundwater. (Some monitoring well samples did
indicate manganese levels above this concentration.) However, it
is critical to note that there are currently no residents
consuming site-related groundwater, nor at levels above the NYS
standards of 300 p.g/1. The groundwater samples taken from the
private wells showed manganese levels ranging from approximately
3 to 60 M9/1- AH °f these samples were below the NYS's Class GA
groundwater standards of 300 M9/1 f°r manganese. Manganese has
been found in the groundwater both upgradient and downgradient of
the site, indicating that it is an element occurring naturally in
the underlying aquifers, resulting from the geologic conditions
in the formations. Manganese is also a landfill leachate
component that is contributing to the high levels found in the
groundwater at the edges of the landfill. Under regular
conditions, the levels expected in downgradient wells would be
well below this level, since the set of circumstances to warrant
this have not been realized at the Site, i.e., there is no
apparent off-site migration. EPA's long-term monitoring program
will include sampling and analysis of downgradient residential
wells; manganese will be one of the contaminants evaluated in
that monitoring program.
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Comment #40: DHHA's TAG advisor expressed concern that RfDs were
used to evaluate inhalation exposures -instead of the.more recent
reference concentration (RfC) values.
EPA's Response: As recommended in RAGS, the RfCs were used in the
evaluation of inhalation exposures and were converted to RfD
units for convenience. The RAGS Part A guidance states that RfD
values for inhalation exposures expressed as inhaled intakes
(mg/kg-day) are converted to a concentration in air (mg/m3) using
a human body weight of 70 kg and an inhalation rate of 20 m3/day.
Selection of Exposure Pathways for Analysis
Comment #41: DHHA's TAG advisor expressed concern that the
discussion of exposure pathways ignores the potential ingestion
of VOCs in household air, in particular exposure to benzene.
EPA's Response: The contamination of household air, including
inhalation, by the VOC pathway was evaluated in this risk
assessment and was assessed according to Part A of RAGS. Benzene
was included as a COC in all of the groundwater pathways,
including inhalation. The inhalation of volatiles while
showering exposure pathway evaluated the potential risks from the
inhalation of volatile organic compounds found in both the
overburden and bedrock groundwater/ the evaluation indicated that
the resultant risks were well within EPA's acceptable risk range.
Even if it were assumed that an individual showered for 24 hours
a day, the risk would increase by two orders of magnitude and
still remain within EPA's acceptable risk range. In addition,
ambient air and soil/gas sampling results indicated that
appreciable quantities of VOCs would not migrate off-site into
residences. Ambient air and landfill gas monitoring will be
conducted after the construction of the cap to ensure protection
of human health and the environment.
Comment #42: DHHA's TAG advisor expressed concern that the
disaggregation of His by toxic effects is not clear.
EPA's Response: The risk assessment shows the His are segregated
by health effects across the network of major body organs/systems
and do consider the entire set of toxic effects. For example,
chromium is shown to affect each of the four organ systems
identified in the risk assessment.
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G. Property Values
Comment #43: Some commenters expressed concern that property
values were being reduced as a result of the landfill presence,
yet taxes were increasing.
EPA's Response: The eventual deletion of the Site from the NPL,
once the landfill cap is installed, should alleviate the stigma
that a Superfund Site may create in communities with the
resulting negative effect on property values. The results of
EPA's investigation with respect to the groundwater should also
help to alleviate concerns.
Comment #44: On a related matter, one commenter expressed concern
that the Site was located in a Toxic Waste Zone and that, as the
distance from the Site increases, property values should
increase.
EPA's Response: The landfill itself is part of the Superfund
Hazardous Waste Site. EPA defines a "site" based upon any
contamination that has emanated from the site. Since no plume of
contamination has been defined, the landfill is the only part
classified as the Site. A Superfund Hazardous Waste Site relates
directly to an "area of contamination"; the term "Toxic Waste
"Zone" is not employed by EPA in the Superfund Program. The OU-2
ROD will affirmatively address the issue that there are no
impacts from the landfill on the surrounding community. This
information will be available onto the real estate and banking
community.
Comment #45: Some commenter expressed concern that, although some
property across Penaluna Road from the Site is being offered for
public use, the Town of Warwick will not consider the proposal as
a result of its proximity to the Site. This is contrary to EPA's
assessment that no contamination, airborne and groundwater, is
coming from the Site.
EPA's Response: EPA is aware of capped landfills which have been
put back into public use. EPA is unaware that the property being
offered has any hazardous waste issues associated with it
although EPA^suggests that the area should be investigated prior
to its reuse. EPA has determined through sampling, however, that
this property has not been impacted by the Site. Assuming that
the property has also not been impacted by current activities
being conducted there, EPA's risk assessment, showing no
unacceptable risks, indicates that it could be available for any
use that the Town deems appropriate. However, EPA does not
recommend that the property be developed for recreational use
until construction of the cap has been completed.
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APPENDIX A
PROPOSED PLAN
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Superfund Proposed Plan
Warwick Landfill Site
Town of Warwick, Orange County, New York
EPA - Region II
July 1995
PURPOSE OF PROPOSED PLAN
This Proposed Plan identifies a no further action remedy
for the second operable unit (OU-2) at the Warwick
Landfill Superfund site (the Site), located in the Town of
Warwick, Orange County, New York. The Proposed Plan '
was developed by the U.S. Environmental Protection
Agency (EPA), as the lead agency, with support from the
New York State (NYS) Department of Environmental
Conservation (DEC). EPA is issuing the Proposed Plan
as part of its public participation responsibilities under
Section li7(a) of the Comprehensive Environmental
Response, Compensation, and Liability Act (CERCLA) of
1980, as amended, and Section 300.430(0 of the National
Contingency Plan (NCP).
This Proposed Plan is being provided as a supplement to
the Remedial Investigation (Rl) report to inform the public
of EPA's and DEC'S preferred no further action remedy
and to solicit public comments on this action. As a result
of the Rl and risk assessment findings, no other remedial
alternatives were considered; therefore, a Feasibility Study
was not necessary.
The no further action remedy, as described in the
Proposed Plan, is the preferred remedy for the Site.
Changes to the preferred remedy or a change from the
preferred remedy to another remedy may be made, if
public comments or additional data indicate that such a
change will result in a more appropriate remedial action.
The final decision regarding the selected remedy will be
made after EPA has taken into consideration all public
comments. Therefore, we are encouraging public
comment on this Proposed Plan and the Rl report.
Copies of the Rl report, croposed Plan, and other
supporting documentation are available at the following
repositories:
Warwick Town Hall
132 Kings Highway
Warwick, New York 10990
Tel. (914) 986-1120
Greenwood Lake Village Hall
Church Street
Greenwood Lake, New York 10925
Tel. (914) 477-9215
U.S. Environmental Protection Agency
Emergency and Remedial Response Division
290 Broadway
New York, New York 10007-1866
New York State Department of
Environmental Conservation
50 Wolf Road
Albany, New York 12233
Dates to remember:
MARK YOUR CALENDAR
July 28 to August 27, 1995
Public comment period on proposed remedy
selected.
August 15, 1995
Public meeting to be held at 7:00 PM at the
Greenwood Lake Middle School, Greenwood
Lake, New York.
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COMMUNITY ROLE IN SELECTION PROCESS
EPA relies on public input to ensure that the concerns of
the community are considered in selecting an effective
remedy for each Superfund site. To this end, the Rl
report has been made available to the public for a public
comment period which concludes on August 28, 1995.
Pursuant to Section 117(a) of CERCLA, a public meeting
will be held during the public comment period at the
Greenwood Lake Middle School, Orange County Highway
5, Lakes Road, Greenwood Lake, New York on August
15, 1995 at 7:00 P.M. to present the conclusions of the
Rl, to further elaborate on the reasons for recommending
the preferred remedial alternative, and to receive public
comments.
Documentation of the final remedy selection will be
presented in the Record of Decision (ROD) after
consideration of all the public comments. Comments will
be summarized in the Responsiveness Summary section
of the ROD.
All written comments should be addressed to:
Damian J. Duda
U.S. Environmental Protection Agency
Emergency and Remedial Response Division
290 Broadway, 20th Floor
New York, New York 10007-1866
SITE BACKGROUND
The Site is located approximately one and one-half miles
northeast of the Village of Greenwood Lake in the Town
of Warwick, Orange County, New York. The Site is
approximately three-fourths of a mile north of State Route
17A and fronts Penaluna Road on its western boundary,
just north of Old Tuxedo Road (see Map). No buildings
exist on the landfill properly, except for a small partially
demolished brick structure. The landfill mound transects
a small valley and occupies approximately 19 acres of a
64-acre parcel. An unnamed intermittent stream drains a
small wetlands area on the northwest side of the Site and
flows north into a creek that flows westward and then
southward into Greenwood Lake. Another stream is
located on the landfill's southeast side and flows
southward into a large wetlands area which is drained by
an unnamed perennial stream that flows south and west
into Greenwood Lake. Tne area surrounding the Site is
generally hilly with clusters of houses and wooded areas.
WARWICK LANDFILL SITE MAP
The Site was owned and farmed by the Penaluna family
from 1898 to the mid-1950s, when the Town of Warwick
leased the property from the Penaluna family and utilized
it as a refuse disposal area. The facility accepted
municipal wastes from the Town of Warwick, which
includes the Villages of Florida. Warwick and Greenwood
Lake, and other surrounding towns in Orange County.
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The facility also accepted waste materials from industries
in the areas; some of these_ materials contained
hazardous substances. The Town of Warwick operated
the landfill until 1977.
In April 1977, the Site was leased from the property
owner, Mrs. Millie Mae Penaluna, by Grace Disposal and
Leasing, Ltd. (Grace Disposal), Harriman, New York. On
July 15, 1977, Grace Disposal was granted a permit to
operate the refuse disposal area by the Orange County
Department of Health. Information, available to EPA,
indicates that large volumes of industrial waste materials,
containing hazardous substances, were disposed of in the
Jandfill at this time.
In the Spring of 1979, in response to concerns of local
citizens who had reported suspicious dumping activities,
DEC collected and analyzed leachate samples from the
Site; the analysis showed some heavy metals, phenols
and volatile organic compounds (VOCs). Shortly
thereafter, Grace Disposal was issued a temporary
restraining order by the New York State Supreme Court,
pending a town request for an injunction to close the
JandfiU until state and town ordinances were satisfied.
Pursuant to a DEC order, the Site was covered, graded,
and closed by Grace Disposal. On June 11, 1980, DEC
was notified that a Certificate of Dissolution had been filed
by Grace Disposal. Examination of aerial photographs
indicated that the landfill had increased significantly in
size during the late 1970s.
In September 1983, DEC contracted with Woodward-
Clyde Consultants, Inc. to perform a preliminary
investigation of the landfill. Subsequently, in March 1985,
a field investigation program was performed; surface
water, sediment, soil and groundwater samples were
analyzed. The results indicated that the groundwater was
relatively free of contaminants and that some phenols
were found in the surface water. The complete results of
this investigation are summarized in the Rl report for the
first operable unit (OU-1) for the Site, located in the Site
repository.
In 1984, ownership of the property was transferred to
Orange County for non-payment of back taxes. The title
was transferred from Orange County to the Newburgh,
New York Developers in November 1986. In 1987, the
property was transferred to the current owners, L and B
Developers.
In 1985. the Site was proposed for inclusion on EPA's
National Priorities List (NPL) of uncontrolled hazardous
waste sites and was added to the NPL in March 1989.
On December 28, 1988, EPA sent 'special notice" letters
to a number of potentially responsible parties (PRPs),
namely, parties that EPA had determined were
responsible for contributing to the contamination found at
the Site. The letters afforded the PRPs the opportunity to
conduct an RI/FS. EPA did not receive any good faith
proposals from the PRPs to undertake or finance the
study. Therefore, the necessary work was performed by
EPA's contractor, Ebasco, Inc., beginning in August 1989.
From August 1989 until May 1990, the field investigation
for the OU-1 Rl was performed, which included air
monitoring, a radiological survey, geophysical survey,
surface water, sediment and leachate sampling,
monitoring well and residential well sampling and a
hydrogeologic survey of the aquifers below the Site.
From September 1989 until November 1990 during the Rl
for OU-1, residential well sampling, conducted by EPA
and NYS Department of Health (DOH). indicated levels of
VOC-contamination above NYS and federal drinking water
standards. As a result, DOH and DEC fined those
affected households with granular activated carbon units.
Four residential wells are currently fitted with these units
which are regularly sampled by DEC.
In June 1991, EPA signed a Record of Decision for OU-1,
which included a landfill cap as a source control
measure, gas venting and provision of granular activated
carbon filters on certain residential wells as an interim
measure. In addition, because some VOCs and metals
were identified in the groundwater above federal and NYS
maximum contaminant levels (MCLs), the ROD also
specified a supplemental investigation of the fate and
transport of the contamination, designated as OU-2.
On February 28, 1992, after failing to receive any good
faith offers to undertake the OU-1 work, EPA issued a
Unilateral Order to six PRPs to perform the remedial
design and remedial action called for in the OU-1 ROD.
The PRPs hired Geraghty and Miller, Inc. (G-t-M) to
perform the remedial design work.
On April 9, 1993, EPA issued a second UAO for the OU-1
remedial design and remedial action to five additional
PRPs, requiring that they cooperate and coordinate with
the other PRPs in conducting the work.
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On September 28, 1992, EPA issued an Administrative
Order on Consent to four PRPs to perform the
supplemental groundwater investigation. The Rl for this
supplemental groundwater study was also prepared by
G-t-M and is discussed in subsequent sections of this
Proposed Plan.
SCOPE AND ROLE OF OPERABLE UNIT ONE AND
OPERABLE UNIT TWO
EPA has divided the remedial work necessary to mitigate
contamination stemming from the Site into two operable
units. The major component of OU-1 is landfill capping
which addresses the source of contamination at the Site.
Currently, the remedial design phase of the cap is nearing
completion; the remedial action to construct and install
the cap should begin within the next few months. As an
interim, precautionary measure, OU-1 also provides for
point-of-use treatment for four nearby residential wells
which had exhibited low levels of contamination, as well
as, an ongoing residential well monitoring program. OU-2
is the subject of this Proposed Plan and addresses the
further characterization of the fate and transport of the
contaminants in the groundwater. The remedial action
identified as the selected remedy for OU-1 and this
Proposed .Plan serve as the basis for the no further action
remedy for the groundwater.
REMEDIAL INVESTIGATION SUMMARY
Between March 1993 and September 1994, various
sampling events were conducted by G + M. These
investigative events performed under both the OU-1 RD
and the OU-2 RI/FS included: installation of landfill
piezometers, monitoring wells, and borings; groundwater
monitoring well and residential well sampling; landfill seep
surveying and mapping; off-site seeps and surface water
bench marking; leachate sampling; wetlands' surface
water and sediment sampling; landfill gas and ambient air
sampling; and residential septic tank sampling.
Topography
The Site is located in the Hudson Highlands, consisting
primarily of Precambrian-age gneiss. Elevations across
the Site range from approximately 890 feet above mean
sea level (msl) in the northeast to approximately 860 feet
above msl in the southwest. Along the northwestern and
southeastern boundaries of the landfill, the site
topography slopes downward to approximately 825 and
820 feet above msl, respectively. Elevations within 1 mile
of the site range from approximately 650 to 1,300 feet
above msl.
Two streams, North Brook and South Brook, originate
along the northwestern and southeastern boundaries of
the landfill. The uppe.r reaches of both brooks are
intermittent. The landfill comprises a small portion of
these drainage basin areas; therefore, the landfill runoff
contributes to the water in North Brook and South Brook.
Wetlands flank the landfill along its northwestern and
southeastern boundaries. Fill soil and some refuse are
present in the wetlands adjacent to the Site.
Geology
The geology of the Site area is complex and consists of
three significant units: (1) competent, massive, crystalline
bedrock; (2) sandy, glacial outwash; and, 13) dense, silty,
glacial till. The manmade landfill material consists of
refuse, silt and daily and final cover soil.
The bedrock in the Warwick Landfill Site area is a fairly
continuous, massive igneous body, consisting of various
gneiss formations. The bedrock has high concentrations
of iron, magnesium and calcium minerals. As a result of
the natural movement of groundwater through the
bedrock formation, numerous minerals dissolve out of it;
this action is referred to as chemical-weathering. Isolated
pockets of chemically-weathered bedrock exist within and
to the northeast of the Site area. The variability in depth
to the top of the weathered bedrock suggests that it is
isolated in area! extent. In addition, a 16-foot interval of
predominantly physically weathered rock exists both in
the Site area and south of the landfill. The weathered
bedrock consists of fractured gneiss, overlain by sandy
outwash. Bedrock is present west of the landfill where
silty till directly overlies the bedrock.
The overburden deposits in the Site area are glacial in
origin and vary greatly in composition and thickness and
consist of sandy outwash and silty till. Overburden
thickness.north of the landfill is approximately 70 feet. To
the east and in some areas north of the landfill,
overburden is either absent or it occurs in thin pockets
because competent bedrock either outcrops or occurs a
few feet below ground surface in that area. Overburden
thickness increases to the west with greater than 90 feet
of silty till.
Sandy outwash is present north and south of the landfill.
The thickness of the sandy outwash south of the landfill
ranges from approximately 25 to 40 feet. A wedge of
dense, silty till is also present west of the landfill. The
silty till rests on bedrock.
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The landfill material, in most areas, overlies bedrock. At
one location, a 4-foot thick-pocket of physically
weathered bedrock occurs between the landfill material
and the lower bedrock. The maximum thickness of
refuse is approximately 50 feet and occurs in the
southern section of the landfill. In the northern section of
the landfill, the maximum thickness of refuse is
approximately 30 feet. The landfill soil cover is
approximately 2 feet thick. The cover soil typically
consists of a poorly sorted silt with varying percentages
of clay, sand, and gravel. The entire landfill is capped
with this cover soil. The cover soil was also placed over
the area that is currently the northern section of the
southern wetlands.
HvdroQeoloav
The hydrogeologic regime of the Site area is complex.
Groundwater occurs in competent, massive, crystalline
rock; isolated pockets of chemically-weathered bedrock;
. dense, silty till; sandy outwash; and landfill material
(refuse and silty soil). Topographic relief and the variable
transmissivity of the geologic media combine to produce
a complex groundwater flow system in the site area.
Groundwater flow in the shallow bedrock is mostly
towards the southwest, moving from the residential area
northeast of the landfill towards the landfill. Continuous
water-level monitoring, which was conducted in
monitoring wells located between the Site and the
northeast residential area, did not indicate any influences
on the groundwater flow in the shallow bedrock from
residential well pumping.
The downward vertical gradients in the bedrock located
northeast of the Warwick Landfill would facilitate the
movement of groundwater from the shallow bedrock to
the deep bedrock, if they were connected by an open
borehole. As a result of the open borehole method of
construction, some of the residential wells, located
northeast of the landfill, may act as a conduit for
contaminant migration from the shallow bedrock to the
deep bedrock. Often in these mostly open hole wells, the
shallow bedrock would not be isolated (cased off) from
the deep bedrock, thus groundwater could flow
downward. Downward flow could also be enhanced by
well-pumping, especially in low-yield, high-drawdown
wells.
A summary of the hydrogeologic conditions for the Site
are as follows.
The landfill is situated in a groundwater discharge
environment, i.e., perched leachate and lower leachate
flows to North and South Brooks and their associated
wetlands.
Leachate that potentially could flow to the sandy
outwash, which is present north and south of the landfill,
is intercepted by North and South Brooks.
Shallow bedrock groundwater moves from the
residential area northeast of the landfill towards the
landfill.
There is limited hydraulic connection between the
shallow bedrock groundwater and the deep bedrock
groundwater.
« The hydraulic properties (i.e., hydraulic heads and lower
hydraulic conductivity) of the shallow bedrock prevent the
movement of leachate to the north and northeast.
* i
The bedrock beneath the Site will tend to limit the
vertical movement of leachate, because of its low vertical
hydraulic conductivity and decreasing horizontal
conductivity with depth. The potential for widespread
landfill-related impacts to groundwater is low.
« The natural hydrogeologic conditions combined with
the construction techniques [well casing extending only a
few feet into competent rock] of deep residential wells
(typically 300 feet or greater) produce conditions that
allow for the downward vertical migration of shallow
bedrock groundwater to depths of 300 feet or more.
Since the residences are serviced by septic systems near
the surface, the existence of this pathway is further
supported by the presence of coliform bacteria, which is
not usually found at depth, in upgradient residential well
samples. In addition, the existence of this pathway is
further supported by the distribution of chlorinated
organic compounds in the upgradient bedrock
groundwater, i.e., the highest concentrations of
chlorinated organics detected upgradient, as well as at
the Site, were in the shallow bedrock groundwater.
The well yield, hydraulic conductivity, boring logs, and
downhole geophysical well log data demonstrate that
groundwater flow at depth is limited.
Antimony, iron, magnesium, manganese and sodium are
naturally occurring in the crystalline rocks and the
overburden of the Hudson Highlands area. As a result of
-------
chemical and physical weathering, these metals can be
transmitted to groundwater in dissolved and paniculate
form.
Groundwater Sampling and Analytical Results
As part of the OU-1 RI/FS, fifteen groundwater monitoring
wells were installed, eight wells in the overburden aquifer
and seven in the bedrock aquifer. Three rounds of
groundwater samples were collected from the monitoring
wells. Residential wells in the area were also sampled.
Sampling and analyses of both the monitoring and
residential wells indicated that various organic and
inorganic contaminants exceeded federal and NYS
drinking water standards. As an interim remedy, the OU-
1 ROD specified that certain residential wells be provided
with activated carbon filtration units on an as needed
basis. The OU-1 ROD also specified that a supplemental
groundwater investigation be conducted in order to define
better the hydrogeologic and chemical conditions at the
Site and, ultimately, to ensure that area residents are
protected from any potential site-related contaminants,
particularly those in the groundwater.
As part of the OU-2 Rl, seven additional monitoring wells
(shallow, intermediate and deep) were installed on-site
and off-site to monitor both upgradient and downgradient
groundwater quality at the Site. The hydrogeologic
investigation indicated a complex scenario. In the
overburden, the downgradient flow is southeasterly,
southwesterly and northwesterly from the landfill; this
stems primarily from the geometry of the aquifer
formation and the configuration of the landfill itself. The
actual discharge of the overburden aquifer to adjacent
wetlands and streams, however, occurs mainly in the
northwesterly and southeasterly directions, since the
groundwater, moving in the southwesterly direction,
meets a till layer which acts as a dam and forces it along
the front to the northwest or the southeast. For the
shallow bedrock, the majority of the groundwater flow is
in the southwesterly direction."' The hydrogeologic
conditions indicate that areas northeast and northwest of
the landfill proper are upgradient of the landfill proper.
Downgradient locations can generally be defined as south
and southwest of the landfill.
Two rounds of groundwater sampling were conducted in
December 1993 and August/September 1994. On-site
and off-site monitoring wells were sampled for a broad
spectrum of contaminants, including VOCs, semi-VOCs,
pesticides, PCBs, and inorganics. Also, during
September 1994, as specified under the OU-1 ROD, a
residential well sampling program was initiated. Twenty-
four homes were sampled for VOCs and inorganics.
Some inorganic and volatile contamination was found in
both monitoring and residential wells.
Various VOCs were detected above the federal and NYS
standards in seven monitoring wells during the two
rounds of sampling. Maximum concentrations are
reported here. During the first round, 2-butanone was
estimated at 100 ng/\ (upgradient), 1,1-dichloroethene
was detected at 6.8 «g/l (upgradient), 1,1-dichloroethane
was detected at 7.2 »g/\ (upgradient), 1,1,1-
trichloroethane (TCA) was detected in two wells at 17 and
65 jjQ/l, respectively (upgradient). During the second
round, 1,1-dichloroethytene was detected at 12 ng/\
(upgradient), 1,1-dichloroethane was detected at 8 «g/l
(upgradient), 2-butanone was detected at 31 «g/l
(upgradient), toluene at 6 /ig/l (upgradient), TCA was
detected at 5. 9 and 75 «g/l (upgradient) and
chloromethane was detected at 28 jig/1 (downgradient).
Benzene was detected in two wells at 4 «g/l .
(downgradient), one well at 2 «g/l (downgradient),'one
well at 0.5 ug/\ (upgradient) and was estimated in a third
well at 0.2 «g/l (downgradient). These levels are above
the NYS Class GA standard of non-detect for benzene;
the detection and quantification limit for benzene varied
for each sampling round but were generally less that 1
ug/\. For the residential well sampling, only two wells
had any VOCs detected above NYS standards.
Chloroform was detected in one residential well at 7 /ig/l
(the NYS Class GA standard is 5 «g/l). TCA was
detected in one of the residential wells at 32 ng/l (NYS
standard is 5 «g/l). However, this well is fitted with a
carbon filter unit; the TCA was not detected in the
drinking water after treatment with the carbon filter unit.
With the exception of benzene and chloromethane, VOC
contamination was not found in downgradient wells above
federal and NYS drinking water standards.
Various inorganic compounds were detected at or above
federal and NYS primary drinking water standards in both
upgradient and downgradient wells. During the first
round of sampling, chromium was detected above the
NYS Class GA standard of 50 «g/l at eight monitoring
wells: three upgradient had levels of 85. 205 and 442 «g/l
with an average concentration of 244 »g/\, and five
downgradient wells had levels, ranging from 58 to. 1250
ng/l with an average concentration of 384 <«g/l. During
the second round of sampling, chromium was detected
above the NYS standard at five monitoring wells. Two
upgradient wells had levels of 75 and 148 «g/l with an
average concentration of 111 ug/l; three downgradient
wells had levels of 60, 99 and 216 «g/l with an average
-------
concentration of 125 ng/l."For each sampling round, the
filtered data showed levels-well below the NYS standard.
In all but one case, the chromium levels decreased in the
second round of sampling. The residential well sampling
identified only two detections of chromium, both well
below NYS standards. These levels seem to indicate that
chromium is naturally occurring in the formation, i.e.,
background levels, since it is found at comparable levels,
both upgradient and downgradient of the landfill. These
levels also relate directly to turbidity and high suspended
solids in the samples and are not necessarily
representative of the quality of the groundwater.
Lead was also detected in both upgradient and
downgradient monitoring well samples. During the first
round of sampling, lead was detected above the federal
action level of 15 ug/l in five monitoring wells: three
upgradient wells (ranging from 36.7 to 290 «g/l) and two
downgradient wells (20.5 and 32.5
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detected in all three zones of sediment sampling and, in
general, at levels were withirrNYS criteria.
In December 1993, one round of leachate sampling was
performed from the landfill piezometers. Maximum
concentrations included: VOCs-benzene (24 jig/I).
ethylbenzene (42 ^g/l), xylene (200 ng/l), toluene (34
ug/l) and chlorobenzene (32 jig/I); semi-VOCs-PAHs,
fluoranthene-0.2 «g/l and pyrene-170 ng/\; metals-
barium (3630 «g/l), chromium (616 «g/l), cobalt (289
ug/\), iron (1.94 x 10* yg/l), lead (4870 jig/I), manganese '
(9750 (ig/l) and nickel (591 «g/l); pesticides-alpha-
chlordane (0.76
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Current federal guidelines for acceptable exposures are
an individual lifetime excess-carcinogenic risk in the range
of 10"* to 10'6 which can be interpreted to mean that an
individual may have a one in ten thousand to a 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.
No unacceptable carcinogenic risks, either for adults or
children, were found for exposure to groundwater. The
greatest risk for adults and children would result from
groundwater ingestion at 3.2 x 10'7 and 1.1 x 10"7.
respectively. Cancer risks from exposure to groundwater
in the bedrock aquifer are attributable primarily to
benzene through direct ingestion.
For ambient air, the primary contaminant of concern is
methylene chloride. No unacceptable carcinogenic risks,
either for adults or children, were calculated. The
greatest risk for adults and children are 2.2 x 10'5 and 8.6
x 10"*, respectively.
The results of the baseline risk assessment indicate that,
for the exposure pathways evaluated, no unacceptable
carcinogenic risks were calculated. All risks fell within
EPA's acceptable risk range of 10"* to 10'6.
To assess the overall potential for noncarcinogenic effects
posed by more than one contaminant, EPA has
developed a hazard index (HI). The HI measures the
assumed simultaneous subthreshold exposures to several
chemicals which could result in an adverse health effect.
When the HI exceeds 1.0, there may be concern for
potential noncarcinogenic health effects.
Noncarcinogenic risks are attributable primarily to
manganese through direct ingestion. The non-
carcinogenic risk shows a total HI from the bedrock
groundwater pathway for an adult of 0.7 and 1.5 for a
child. For the overburden groundwater pathway, the total
HI for both an adult and a child is less than 1.0. For the
air pathway, the total HI for both an adult and a child is
less than 1.0.
The results of the baseline risk assessment indicate that,
for all exposure pathways evaluated, the only total
noncarcinogenic risk with a calculated HI greater than 1.0
is for the child receptor through ingestion of bedrock
groundwater, related directly to manganese, which is
considered an essential nutrient. The manganese dose
received by the child from consumption of bedrock
groundwater is lower than that which would be supplied
by a common over-the-counter multivitamin supplement.
Ecological Risk Assessment
The results of the ecological investigations performed
under OU-1 and OU-2 by G + M support the conclusions
identified in the OU-1 Rl. The environmental assessment
evaluated potential exposure routes of the Site
contamination to terrestrial wildlife and aquatic life.
However, because of the low concentrations of
contaminants detected, lack of potential bioaccumulatioa
absence of fishing and other recreational activity, and
absence of known endangered species, the
environmental assessment was not quantified. The
wetlands in the vicinity of the Site were delineated. The
need to minimize the disturbance of these wetlands
habitats via migration of contaminants from the landfill, as
well as, via any future remediation activities, was identified
as an important factor that was considered in the
selection of the OU-1 landfill capping remedy.
SUMMARY OF THE PREFERRED NO FURTHER
ACTION REMEDY
Based on the findings of the OU-2 Rl performed at the
Site, EPA and DEC have determined only limited
contamination present appears to be the result of sources
other than the Warwick Landfill and that a no further
action remedy is protective of human health and the
environment.
The OU-1 remedial action, a landfill cap, will be . .
constructed during 1996. Upon completion, the cap will
reduce the groundwater and leachate contaminant levels.
The associated operation and maintenance plan will
include groundwater, ambient air and landfill gas
monitoring to ensure further that the existing population
are protected from any future contamination and that the
OU-1 remedy remains protective of human health and the
environment.
Based on the findings on the OU-2 Rl, the contamination
of the residential wells upgradient of the Site was
determined not to be site-related. It is noted, however,
that the NYSDOH is currently resampling some
residences to confirm the presence of lead, most likely
related to household plumbing sources.
It is important to note that the remedy described above is
the preferred remedy for OU-2 for the Site. The final
selected remedy will be documented in the ROD, only
after consideration of all comments on the preferred
remedy addressed in the Proposed Plan and Rl report.
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APPENDIX B
PUBLIC NOTICES
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THE UNITED STATES
ENVIRONMENTAL PROTECTION AGENCY
' : announces
PREFERRED REMEDY
- i. -i "nl-; - ' :.( ":': \^...-''' for the
'V>1 ?; WARWICK LANDFILL SITE
VILLAGE OF GREENWOOD LAKE,TOWN OFWARWICK,
,:;"; ; ORANGE COUNTY; NEW YORK
!\'tt'-;L-=..:' '.;.''. -.-'
The U.S. Environmental Protection Agency (ERA) recently completed a Remedial
Investigation (Rl) for the Second Operable Unit (OU-2) for the Warwick Landfill
site (Site) in Warwick, New York. The OU-2 addresses the groundwater at the
f-Site. Based on the previous work conducted at the Site to date, ERA is announc-
ing a preferred remedy for No Further Action.
'",'Before selecting a final remedy, ERA will consider written and oral comments on
'this, preferred remedy. All comments must be received on or before August 27,
1995. The final decision document will include a summary of public comments
and EPA responses.
hold an informational public meeting on August 15,1995, at 7:00 p.m., at
of the Greenwood Lake Middle School located on Lakes Road in Greenwood Lake,
,m New York, to discuss the findings of the Rl and the preferred remedy.
'The, Remedial Investigation report, Proposed Plan, and other site-related docu-
ments cari be consulted at the information repositories listed below:
.' .".< '=:£:; ?i Warwick Town Hall
-- v-- - 132 Kings Highway
Warwick, New York 109*0
ievi i:£ ju*
otup.§3« .n:
: Gr»*nwood Lake VUlag* Hal)
.'v; v-;. ChwchStrttl '-...'
. H^
DtmianJ. Ouda, Remedial Project Manager
- \)&. Environmental Protection Agency
»OBio«iw«y>20thFtoor
New Yortt, New Yortc 10007
.Written comment* muet be received at the above addrees on or before
August 27, 1995.
GREENWOOD LAKE AND WEST MILFORD NEWS
8/9/95
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- (
.-*:
£'':-. THE UNITED STATES
ENVIRONMENTAL PROTECTION AGENCY
announces
PREFERRED REMEDY
for the
WARWICK LANDFILL SITE
VILLAGE OF GREENWOOD LAKE, TOWN OF WARWICK,
ORANGE COUNTY, NEW YORK
The U.S. Environmental Protection Agency (EPA) recently completed a Remedial
Investigation (Rl) for the Second Operable Unit (OU-2) for the Warwick Landfill
site (Site) in Warwick, New York. The OU-2 addresses the groundwater at the
Site. Based on the previous work conducted at the Site to date, EPA is announc-
ing a preferred remedy for No Further Action.'
Before selecting a final remedy, EPA will consider written and oral comments on
this preferred remedy. -All comments must be received on or before August 27,
1995. The final decision document will include a summary of public comments
and EPA responses.
EPA will hold an informational public meeting on August 15,1995, at 7:00 p.m., at
the Greenwood Lake Middle School located on Lakes Road in Greenwood Lake,
New York, to discuss the findings of the Rl and the preferred remedy.
The Remedial Investigation report, Proposed Plan, and other site-related docu-
ments can be consulted at the information repositories listed below: .
Warwick Town Hall
132 Kings Highway
Warwick, New York 10990
Greenwood Lake Village Hall
Church Street
Greenwood Lake, New York 10925
Written comments on the preferred remedy should be sent to:
Oamlan J. Duda, Remedial Project Manager
U.S. Environmental Protection Agency
^j ;- 290 Broadway, 20th Floor
'*. New York, New York 10007
&.;.: ' :<-..:. / . .....
.'iWritten comments must be received at the above addresa oh or before
i August 27,1995.
>* *.''« ' - - .......,,.-
SUNDAY TIMES HERALD RECORD
8/13/95
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APPENDIX C
AUGUST 15,1995 PUBLIC MEETING
{NO ATTENDANCE SHEETS AVAILABLE}
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APPENDIX D
AUGUST 15,1995 PUBLIC MEETING TRANSCRIPT
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ORIGINAL
.UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
AGENDA
Public meeting for the
Warwick Landfill Superfund Site
at the Greenwood Lake Middle School
Greenwood Lake, New York
Tuesday, August 15. 1995
7:00 P.M.
I. INTRODUCTION by STEVE KATZ,
Community Relations Coordinator
U.S. EPA, Region II
II. SUPERFUND OVERVIEW by DOUG GARBARIN1,
Superfund Section Chief
Eastern NY Section
U.S. EPA, Region II
III. SITE BACKGROUND by DAMIAN DUDA,
Remedial Project Manager
U.S. EPA, Region II
IV. HYDROGEOLOGIC SUMMARY
by GREGORY SHKUDA, Ph.D.,
Geraghty & Miller, Inc.
V. RESULTS OF THE REMEDIAL INVESTIGATION
by DAMIAN DUDA,
VI . QUESTIONS AND ANSWERS
ALSO PRESENT: MICHAEL J. KADLEC,
Department of Health
MEISTER REPORTING SERVICE
11 Raymond Avenue
Poughkeepsie, New York 12603
(914 ) 473-5656
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(HEARING) 2
MR. KATZ : Thank you for coining
this evening. My name is Steve Katz, I
am Community Relations Coordinator of
U.S. EPA Region II.
We are here tonight to discuss
the Warwick Landfill Superfund Site,
specifically the second part of the
operable unit dealing with groundwater
and investigation into that.
With me tonight at my far rig-ht-
is Mike Kadlec, he is with the New York
State Departmen,t of Health. He will be
talking a little bit about some lead
problems that you heard about in the
proposal. To his left is Doug Garbarini;
he is a Superfund supervisor. To my
immediate right is Damian Duda, the
engineer for the EPA that is in charge of
the landfill.
As you see, at some point tonight
there are background materials that we
have. There is also a sign-in sheet. If
you haven't already done so, just print
your name and address on it* That's how
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(HEARING) 3
we continue to get more information about
the site.
There is also other, more
detailed, in-depth background information
about how we came to a proposal for the
Warwick Landfill. That information is
available at local repositories. .Those
documents are being maintained at the
Warwick Town Hall and at the Greenwood
Lake Town Hall and also, I believe, at
the New York State Department of
Environmental Conservation in Albany.
All of the materials all the
pub.lic documents that EPA does is
released locally, so you can take a look
and purview them if you have more
gue stions.
As part of this hearing, a public
comment period that goes with the EPA's
proposal is due on August 27th. This
meeting is part of that public commentary
tonight. It is part of the proposal to
solicit public comment and feedback.
As you see, there is a
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stenographer here at the end of the
table. What you say here tonight are
considered comments as part of that
public comment period. We can also use
this to be more informed about it and you
can write in your comments until the 27th
of August.
I would ask that you save all
your questions until after the
presentation. It will probably take
about 35 minutes or 40 minutes. Just
come to the front, one at a time, and
just state your name into the microphone.
You just have to speak clearly so that
the stenographer can get you on tape.
That's about it for the ground
rules. I would like to move things along
quickly, so I will turn things over to
Doug Garbarini who will just talk a
little bit about how the Superfund
process works.
MR. GARBARINI: Thank you, Steve,
and thank you everyone for coming out
here tonight. I just want to give a ten-
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or fifteen-minute background of the
Superfund process and the program. A
number of you have been following the
Warwick site for years out here, and you
are probably somewhat familiar with it.
Just to start off, Superfund was
enacted in Albany in 1980 with the
passage of the Comprehensive
Environmental Response, Compensation, and
Liability Act which is a mouthful --
and that's why it is always wise to say
Superfund. And basically Congress passed
CERCLA as a result of various hazardous
waste sites and their potential impacts
coming to national attention, most
notably with the Love Canal which was one
of the big ones that was in the press
quite a bit at that time.
Now, the federal government or
state government really had no means of
dealing with these sites, so Congress
passed Superfund. And basically what it
does is it gave EPA a means of dealing
with these sites, and it gave us a
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Superfund or super pot of money that
could be used to investigate and cleanup
various hazardous waste sites that were
on the EPA National Priorities List
around the country. It also gave EPA
some enforcement tools to force the
parties that are responsible for the
contamination to clean up -- either clean
up the contamination, to pay for the
cleanup of the contamination, or give EPA
the ability to go back after them and
recoup costs that EPA had expended in
evaluating or cleaning up a site.
So, back in 1980, Congress and a
lot people thought that that was going to
be a relatively quick program. It wasn't
going be complex. They thought we might
be dealing with a few hundred sites.
They thought perhaps they might be
picking up a few drums, maybe putting a
cap over contaminated areas, and
basically the program may last a number
of years, maybe five years or something
like that.
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As time arose, we began to see
how complex the process was and that we
had thousands of those sites to deal
with, and a lot of these areas had never
really been dealt with before in terms of
cleanups.
So, in 1986, Congress
reauthorized Superfund, recognizing the
complexity of the program. Whereas in
1980 Congress passed a five-year program
with a funding level of approximately 1.6
billion dollars, in 1986 Congress
realized the program was more complex,
that it was going to last for a long
time; and they passed Superfund for
another five years, this time at a
funding level of about 1.5 billion
dollars a year.
They also gave us some more
effective enforcement tools to try get
those parties, the potentially
responsible parties, to undertake more of
the cleanups, and these enforcement tools
have been very helpful for us in the last
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few years. Close to 70 percent of the
actions that have been initiated have
been initiated by the responsible
parties.
Now, if we were just dealing with
this Superfund or pot of money, we
wouldn't have enough money to go around
for the cleanups, so it is very important
that we get.the responsible parties to
pay for their fair share.
Currently, Superfund is up for
reauthorization. Congress has been
dealing with trying to reauthorize the
program for the last couple of years.
We're hoping that it will be reauthorized
this year, but there are no guarantees.
The important thing is that Congress
continues to give us money to implement
the program. If it is not reauthorized
this year, as long as we have money, we
can continue with the program. And there
is a bill before the House that the House
is putting through right now that would
give us a billion dollars for next year.
8
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Now, a billion dollars is not a
whole lot of money in Superfund terms, so
there wouldn't necessarily be enough
money to handle all the studies and all
the cleanups. So what we are doing now
is going through the process of
prioritizing all of our sites so t.hat the
worst sites can be dealt with first.
Take care of the risks that present the
most significant problems first and then
work your way down the list.
Hopefully, Congress will give us
enough money so that we can handle the
screening that's ongoing right now. This
really shouldn't impact on the Warwick
Landfill, because the responsible parties
are currently paying for both the
remedial investigation that we are here
to discuss tonight as well as the capping
of the landfill, which the design we
expect to be finalized in the next week
or so.
So how does a site get to become
a Superfund National Priorities List
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site? The first step in the process is
basically to go through what we call the
remedial phase. We discover signs and
then rank them and use what is called the
Hazard Ranking System. If a site scores
a certain level, it is deemed to pose a
significant enough hazard to warrant more
federal investigation.
There are approximately 35,000
sites that are on the EPA preliminary
list or Superfund list. We've looked at
over 30,000 of those to date across the
country, and there are currently 1,287
that are on the National Priorities List.
Today we have already deleted
that means completed all action and
basically given a stamp of approval to
77 sites. We actually removed those from
the National Priorities List.
When a site is on the National
Priorities List, it is then eligible for
EPA to utilize the Superfund pot of money
to investigate or cleanup the site, and
it's also now eligible for EPA to utilize
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enforcement tools in trying to get the
responsible parties to cleanup the site.
We go through an established
report determining whether there are any
acute health threats associated with the
site, and if there are, we do what's
called the remedial removal action.
Now, removal action is a lesser
known portion of a program which has been
highly, highly successful. We've
conducted a removal action on the
National Priorities List sites, and they
were conducted anywhere there were acute
health threats. We've conducted them for
more than 3,500 sites, as I've said, and
a number of those have been on the
National Priorities List sites.
Now, what we do subsequently, we
get into the remedial phase of the
program. And in certain circumstances,
what we do is divide the site up into
what we call separate operable sites, as
Steve had relayed to you before. If we
think the program should be on an
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(HEARING) 12
expedited basis, we try and move forward
with that portion of the site rather than
letting another area slow down our
remedial efforts.
In the case of the Warwick
Landfill cap, we selected a remedy for
that cap. And rather than slow that
decision down, we decided that we would
move the hydrogeological groundwater
remedial investigation portion of the
study onto another track or another
operable unit, and we're here tonight to
discuss the followup results from that
investigation.
Now, back a few years ago, we had
conducted a whole lot of groundwater
work, and we had come to some preliminary
conclusions and felt relatively
comfortable with those conclusions, but
we decided that we would come back out
here and do more significant
investigation just to confirm the
preliminary conclusions that we had
reached back then. We collected samples,
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we tried to determine the nature and
extent to the contamination at the site,
we looked at the levels of the
contaminants/ the toxicity of those
contaminants, we looked at the exposure
to the contamination, and we put this all
together in what's called the Risk
Assessment, and we decided whether the
risks that were posed by the site are
acceptable or unacceptable. And in cases
where the risks are unacceptable, we have
to figure out a way to alleviate those
risks so that they are now acceptable.
And we undertake what's called a
Feasibility Study where we look at
different alternatives and different
technologies for cleaning up various
median sites so that they no longer
present a threat to human health or the
environment.
Following the Feasibility Study,
we come out with a proposed plan with
preferred alternatives. I should mention
that in certain instances we will not
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conduct a Feasibility Study if the
Remedial Investigation reveals that the
risks are already at acceptable levels.
There would be no need to conduct a
Feasibility Study.
In either instance, we would then
move forward with the proposed plan, and
we are here to discuss the proposed plan
for the Walkill Landfill site tonight.
The proposed plan just basically'
lays out some of the Remedial
Investigation re'sults and says, Here's
EPA's proposed alternative for
remediating the site, whether that be an
active alternative or whether we say that
we don't think any further action is
neces sary.
We have a 30-day public comment
period, we hold a public meeting, we
solicit your comments, whether they be in
writing or verbally. We go back to our
offices at the end of the comment period
and basically respond to all comments
that we received in writing in a summary
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(HEARING) 15
that's called the Responsiveness Summary.
This Responsiveness Summary
becomes part of a larger document which
is called a Record of Decision. It's
signed by the highest ranking official in
the EPA's Region II Offices, that being
the Regional Administrator.
In cases where we do select an
active remedy, we would move into the
construction phase. So, for instance,
for the first operable unit, we selected
the capping of the landfill.
The construction phase includes
the remedial design. So, for instance,
for the landfill, we would determine the
area to be capped, we would look to see
if there are impacts to wetlands and how
to mitigate the potential impacts to the
wetlands. We decide what kind of
materials we want to cap the site with
and how thick those materials should be.
We look at the grading of the cap of the
landfill, we look at the drainage off the
landfill, those sorts of things.
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Finally, we get into the remedial
action where you actually start moving
the dirt around and actually implementing
the remedy. Subsequent to the remedial
action, we go through phases that are
basically called the site close out and
monitoring.
If there is continued monitoring
necessary at the site, we will do that on
a periodic basis for as long as it is
necessary. And finally we go through
site deletion.
Just to give you a general feel
for time frames and costs, it's taking on
the order of about 11 years for EPA to
move from the start of the Remedial
Investigation through completion of
construction on Superfund sites. And we
really don't have a standard or typical
Superfund site either. Some of them are
a half-acre planning facilities, some of
them could be 200-square-mile mining
facilities located somewhere -- are
located in urban areas or are located in
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rural areas.
In general, the average costs for
remediating a Superfund site is on the
order of 25 to 30 million dollars.
Again, there may be some sites where we
don't need to take action/ there may be
some sites where our action runs a few
hundred thousand dollars. But/ on
average, we are looking at 25 to 30
million dollars.
We have to date in New York
State -- I think we spent about 400
million dollars of fund money for
activities in New York State/ and we've
recovered or settled with responsible
parties for about 800 million dollars in
costs for a total of about 1.2 to 1.3
billion dollars of money have been bumped
into the program from various sources in
New York State. And in New York State,
just as an overview, we're dealing with
about 87 National Priorities List sites
now. The National Priorities List sites
were the ones on the federal list. The
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(HEARING) is
State of New York also deals with several
hundred sites in their own program.
So, with that closing, I will
turn it over to Damian to give an
overview of the Remedial Investigation.
MR. DUDA: My name is Damian
Duda, and I work for the New York
Superfund program in New York City.
I am here to talk about the
proposed plan for Operable Unit Two to .
the Warwick Landfill.
I just put up here an overview of
the landfill itself, which is in orange,
and some properties in the northwestern
section and Nelson Road, just to give
you an idea of the area, and there are
two wetlands as identified here
(indicating).
The Warwick Landfill, also known
as the Penaluna Landfill, is located one
and a half miles northeast of the
Village of Greenwood Lake in the Town of
Warwick. It basically occupies about 19
acres on a. 64-acre parcel with Penaluna
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Road on the western boundary.
Wetlands, as I have indicated,
are in the northwestern and southeastern
parts of the landfill -- and there are
two streams which I showed there are
two streams that I showed on the previous
map that are unnamed, but they represent
two landfill runoff areas that actually
drain into the Greenwood Lake area.
The geology of this site is
complex and consists mostly of bedrock;
sandy, glacial outwash; and dense, silty,
clay.
The manmade landfill material,
the refuse some of it was actually
dumped in the landfill overlining the
bedrock basically is refuse, silt, and
daily and final cover soil with bedrock
outcropping in the northwest area of the
landfill. The maximum thickness of the
refuse is about 30 feet in the northern
section of the landfill and 50 feet in
the southern section.
The entire landfill itself is
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capped up by about two feet of soil cover
consisting of silt, clay, sand, and
gravel.
Until the '50s, the Warwick
Landfill area was owned in part by the
Penaluna family. From the mid-50s until
1977, the Town of Warwick leased the
property as a refuse disposal area for
municipal and industrial wastes.
In 1978, the Grace Disposal
Company leased the site for continued
landfill operations. But in 1979, the
New York DEC collected and analyzed
leachate samples from the site which
showed some contamination of metals and
volatile organic compounds.
Later in 1979, subject to a DEC
order, the landfill was closed and graded
and covered.
In September 1983 to '85,
Woodward-Clyde performed a preliminary
investigation of the landfill which
showed some limited contamination, and
that's per what Doug Garbarini spoke
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earlier.
In '85 it was proposed for the
National Priorities List; and in 1989 it
was formally listed. And the current
owners of the property are the L & B
Developers.
I would like to just go on. and
do a brief overview of Operable Unit One.
And it was decided back in 1991 that the
major component of that remedy was a
landfill cap which addressed the source
of contamination of the site.
Currently, the Remedial Design is
nearing completion, which should be
completed within the next couple of
weeks. The EPA expects that a
construction contract will be on board by
the end of the year or the beginning of
next year. That's nonspecifically
identified at this point.
There are pbint-of-use treatments
for four affected residences in the area
and is ongoing. There is a residential
well monitoring program, which includes
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septic tanks sampling which is also
ongoing and -- (brief interruption).
And one thing that the Operable Unit Two
also identified was that we would further
characterize the hydrology and the
groundwater in the area.
The current activities under
Operable Unit Two -- which this proposed
plan addresses as Doug spoke of
earlier addresses the groundwater
investigation. It also further defines
the hydrogeologic and hydraulic
charateristics of the landfill and
further sampling of 22 monitoring wells,
to be exact. It further defines
potential contamination sources, it
further examines the groundwater quality
for glycol ethers, and it also determines
the human health risks at the site.
I just wanted to go over a few
enforcement activities that we've done on
the site regarding PRPs, the potentially
responsible parties. In December '88,
the EPA sent special notice letters to a
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number of potentially responsible par-
ties -- known as PRPs -- giving them the
opportunity to conduct an RI/FS at the
site or a Remedial Investigation Study.
In August '89, with no PRP
offers, the EPA used Superfund monies --
as Doug spoke of earlier to proceed
with the Remedial Investigation
Feasibility Study for Operable Unit One
with our contractor, Ebasco,
Incorporated.
From August '89 until May of '90,
Ebasco conducted a field investigation
for Operable Unit One. And from
September '89 to November '90, EPA and
the Department of Health, New York State
Department of Health, also sampled 42
residential wells. With respect to that,
as an interim measure, four wells
required point-of-use treatment systems,
and they were fitted with those activated
carbon filters.
Now, I would like to ask Greg
Shkuda from Geraghty & Miller, the PRPs
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contractor, to discuss the hydrogeologic
investigation at this site.
MR. SHKUDA: Okay. As Damian
said, the object of the Operable Unit Two
investigation was to further define the
groundwater flow in the area surrounding
the landfill. As Damian mentioned/ there
are 22 wells that were installed; and
additionally, there were a number of
residential wells that were sampled as '
part of this program. I believe it is in
excess of 24 residential wells that were
sampled.
And just not to bore everybody,
but to make sure we all understand how
groundwater moves, groundwater moves
similar to water moving through a hose;
that is, from high pressure to low
pressure. We determine the pressure of
the amount of force that water is under
by installing a well.
This blue line here represents a
well (indicating). The .well is
installed, it's developed; that is, we
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pump water out of the well to make sure
that we are sampling the groundwater. We
have a surveyor come out to measure the
top of that well with respect to sea
level, and then we measure the depth of
the water.
So we take all 20 wells, and we
repeat that for each and every one of the
wells, and then map out where there are
»
places that are high pressure, and where
there are areas where there are low
pressures or lower heads of water. Water
then flows from that high-pressure area
to the low-pressure area.
Now, as Damian described, this is
a fractured rock system, so the water
flows in between the fractures and the
rock, not in the pores of the rock or in
between the pores in the soil, but in
between the individual fractures.
If you do that for the Warwick
Landfill, you can determine the way the
water generally moves in the upper
portion of the bedrock formation. This
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is where the majority of our wells are
completed. We have some that are
completed deeper, and I will show you
that later. But in general, measuring
the water elevation in each of those 20
wells that were installed during Operable
Unit One and Operable Unit Two, you can
determine that the water generally flowed
from the northeast to the southwest .
across the landfill.
How, that was one of the objects
of this study. "Now, in order to confirm
that, there was a chemical sampling done.
Samples were collected from, as I said,
residential wells as well as the
monitoring wells that were installed.
Now, from studies that were
completed by the United States Geologic
Survey Map in 1980, landfills are known
to produce a number of contaminants that
are associated with landfills. These
contaminants are ammonia, because we have
a lot of food that contains amino acids
and it's reduced to ammonia; they produce
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a lot of iron; they produced a lot of
sulfate; they produce a lot of chloride.
So if we are to collect samples
and look at the concentration of what are
called leachate indicators and this is
an overhead demonstrating the results
from this study (indicating) we can
compare the results from wells that were
upgradient in the northwest to wells that
are downgradient in the southwest to test
whether our understanding of the flow
system is correct.
As you can see here and you
can focus on anyone of these
(indicating); but let's focus on ammonia
since it is very common to landfills of
this type. The ammonia concentrations in
the groundwater to the northeast are not
detected. When we get onto the landfill
itself, the ammonia concentration if
you look at PZ 1, for example, which is
on the landfill itself -- it jumps up to
83 milligrams per liter. As we go down
to the southwest, the ammonia again is
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nondetectable.
You do look at similar things.
You can look at cloride, you can look at
IDSf which total dissolved solids, and
they tell the same story. The water is
uncontaminated by these materials or it
has been at a low level. It gets higher
as you go passed the landfill. And as
you get downgradient to the landfill, the
contaminants are, again, reduced to near*
background levels. This, we believe, is
a confirmation of our understanding of
the flow system based upon the
groundwater elevation.
Now, finally, we talk about a
number of wells that were installed, and
we just want to look at the wells that
were installed in relationship to the
overall flow system. And when we install
the wells, we collected geologic samples,
and we are able to define what's rock and
what's overburdened and what's refuse.
The top picture is a view from
the northeast to the southwest through
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the access of the landfill; the bottom
picture is a shot from east to west
across the landfill. Most of the
wells -- and most of the wells that we
completed are through the refuse or just
into the top.
We have completed two wells that
are in excess of 300 feet deep to the
northeast of the landfill.
The typical household well in
this area, according to the local
drillers, is in excess of 300 feet.
Those wells tested clean. As so if you
look at this in relation to the end of
the scale here (indicating), you can see
that a well that's 300 feet is going to
be somewhere in this vicinity
(indicating)/ well below any possible
interaction between the fill material and
the groundwater.
MR. DUDA: I would like now to
talk about the overview of the Remedial
Investigation that was done.
Between March '93 and September
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'94, basically, a contractor performed
groundwater monitoring well and
residential well sampling, landfill seep
survey and mapping, leachate sampling,
surface water and sediment sampling in
the wetlands, landfill gas and ambient
air sampling which had to do with the
landfill itself, and residential septic
tank sampling.
The sampling results for the
surface water sediment and leachate
sampling indicated that in June 1993 and
April '94, two rounds of surface water
and sediment samplings were conducted.
Three zones of the surface water was
sampled with respect to the landfill, and
basically it was upstream with the
landfill adjacent stream and downstream
in the landfill.
In general, the surface water
sampling results indicated that the
levels were within New York State
standards, although iron and manganese
where a little higher as to be expected,
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and there were volatile organic compounds
detected downstream.
In general, the sediment and
wetlands sampling indicated levels within
New York State criteria.
In December '93, leachate
sampling was performed from the landfill
piezometers; and, in general, levels were
detected within New York State standards.
»
It is important to note that the
landfill cover, the landfill cap, will
prevent any further contamination.
There was also septic system
sampling in September '94 as part of a
residential well monitoring program. And
the residential septic tank systems were
sampled and analyzed, and numerous VOCs
were detected. The contaminants found
there were similar to those found in
nearby residential wells, and these
results indicated a possibility or
potential septic systems presenting a
source of contaminants to the private
residential drinking water wells.
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With respect to the groundwater
sampling for Operable Unit One, there
were 15 groundwater monitoring wells
installed: Eight in the overburder
aquifer and seven in the bedrock. And
three rounds of groundwater samples were
collected from these wells during
Operable Unit One.
Some limited exceedances of the
New York State federal drinking water
standards were found. And also, this is
one of the reasons that we did the 42
residential wells in the area sampling
and activated carbon filters were
supplied for those affected residences,
and they are currently being used.
The residential well monitoring
program, which is part of Operable Unit
One, was -- the first sampling round was
conducted in September '94, and 24 homes
within a quarter mile radius of the
landfill were sampled for VOCs and
inorganic or metals.
It is important to note the
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construction type for these residential
wells is mostly open hole, and, as Greg
indicated, most of them are over 300 feet
deep .
The results of this sampling
indicated that only two wells upgradient
of the landfill had VOC contamination
slightly above New York State standards,
and one of those wells had a carbon
filter unit on it which prevented it from
any further contamination.
In the first round of the
residential well monitoring sampling,
lead was detected in six wells,
upgradient of the landfill, above the
federal action level. Detection of this
lead is most probably related directly to
contamination of the household plumbing
sources.
Specifically related to this lead
issue, I would like to have Mike Kadlec
from the New York State DOB speak a
little bit about that.
MR. KADLEC: My name is Mike
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Kadlec, I'm with the New York State
Department of Health and Bureau of
Environmental Disclosure Investigation.
And what we do is we look at a Superfund
investigation and work plan and make sure
that the information that's being
collected at these sites is going to give
us the information that we need to make
sure the public is not coming into
contact with any sort of chemicals from'
the landfill.
Now that I'm a public health
specialist, it's my job to make sure that
the chemicals are not getting from the
landfill to the people around the
landfill. And we do this by looking at
the samples that were collected, at the
results that were obtained, and we
compare them to New York State drinking
water standards, for example.
Now, there's two issues at this
landfill that sort of brought me into
this whole process. The first one was
volatile orgainic chemicals that were
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found in some of the homeowner wells
around the landfill.
Now, the geologist at the New
York State Cooperative Environmental
Conservation explained to I'm not a
geologist -- explained to me how the
groundwater was moving away from these
houses/ and how there are some septic
tanks in the area that have contaminated
these wells with volatile organic
chemicals.
Now/ I want everybody to know
that the filters that were placed on
these wells will not be removed until it
can be shown in four monitoring events
over a year that the levels of the
chemicals in the wells are below 50
percent of the drinking water standards.
Now/ another problems that had
arisen was that lead was found in some of
these houses. Now/ it's a common problem
for water to leach lead out of a plumbing
system in the older houses that used lead
sodder and stuff like that. And the way
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that we determine if the lead is actually
in the groundwater or if it's coining from
the houses is we take a first-draw sample
after the water has been sitting in the
pipes/ test that for lead; and then we
take a sample after the water has been
flushed for 10 minutes, you let the water
run for 10 minutes, and take another
sampling.
Now, the difference between these
two will give you an idea of how much
lead is coming from the pipes in the
houses. Now, we did these tests on the
houses that had lead levels above
drinking water standards, and what we
found out is that in doing these flush
samples, we found out that lead was
coming from the plumbing in these houses,
not from the landfill.
So, looking back at the
investigation that I did, I can say that
the volatile organic chemicals in the
wells may not be coming from the landfill
at all. According to what the geologist
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told me, it's coining from the septic
tanks in the area.
Now, I want you to be assured
that the filters will stay in place as
long as drinking waters are exceeded.
And concerning the lead issue, now, this
is a common problem in New York State for
lead to be leached out of the plumbing.
And the only thing that we could
recommend for those people who have lea'd
sodder in the plumbing in their houses is
to let the water run for about 10 minutes
before using it.
I think that's all that I have to
say
MR. DUDA: I would like to talk a
little bit about the actual groundwater
monitoring well sampling that was
conducted during the Remedial
Investigation. I had indicated there
were 15 wells originally; we also
included another 10 additional monitoring
wells monitoring the upgradient and
downgradient groundwater quality in
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December '93. And in August/September
'94, two rounds of groundwater sampling
were conducted at 22 monitoring wells for
volatile organic compounds, semi-volatile
organic compounds, pesticides, PCBs and
inorganics, a wide range of compounds.
We found limited exceedances of
the New York State VOC standards in seven
monitoring wells, all of them upgradient
of the landfill during the two rounds o'f
sampling. The result of the groundwater
sampling indicated that the majority of
contamination was found in the upgradient
bedrock aquifer. And volitale organic
compounds were found at comparable levels
in upgradient and downgradient monitoring
wells I mean various inorganic
compounds those are metals, not
volitale organic compounds.
Also, since we really didn't find
any major contamination at the site, it
basically indicated isolate hits here and
there. There were no flumes or large
swathes of contamination that could be
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(HEARING) 39
found for both organic or inorganic
contaminants at the site.
I would now like to talk a little
bit about the summary of site risks that
were determined in the health risk
assessment. Basically, a Baseline Risk
Assessment estimates the human health and
ecological risk which could result in
contamination there were no remedial
action done at the site. So that's the
worst-case scenario.
Current guidelines for acceptable
exposure for an individual for cancer
risk can be interpreted as basically one
in ten thousand to one in one million
o~
increased of developing cancer as a
result of site-related exposure over a
70-year life span.
There is a four-step process for
assessing site-related human health risks
for reasonable exposure scenario.
Basically/ this is the way risk
assessments are done. We collect data
and evaluate it/ and then we do an
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(HEARING) 40
exposure assessment which analyzes which
pathways residents are being expected;
then a toxicity assessment of the
contaminants of concern and an overall
risk characterization. Based on this
risk assessment, the Baseline Risk
Assessment was conducted to estimate
those risks with respect to current
future conditions, and the overall risks
9
at the site were all determined to be
acceptable.
The exposure pathway that was
determined were four different ones:
Four for groundwater -- or three for
groundwater, ingestion, dermal contact,
and inhalation while showering. And then
we also had an air risk exposure pathway.
The carcinogenic risks or cancer
risks for the adult and child for all of
them were all acceptable within EPA
acceptable risk range. And then
noncarcinogenic risk was acceptable for
all of them. There is a caveat on the
ingestion for children on the
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(HEARING) 41
noncarcinogenic risks because with
basically related to ingestion through
manganese, and the noncarcinogenic risks
shows a hazard index for children at 1.5,
and the level that we normally try to
find is 1.0. But this particular risk is
related directly to manganese, which is
considered an essential nutrient, and in
which case the manganese dose received by
child drinking bedrock groundwater is
actually lower than which would be
supplied by a common over-the-counter
multivitamin supplement.
So, in summary, I'd like to just
go over the no-further-action remedy
which is proposed for this meeting.
Basically, based on the findings of the
OU-2 RI formed at the site, EPA and the
New York Department of Environmental
Conservation returned a no-further action
is protective of human health in the
environment.
The low-level contamination of
the residential wells from the site are
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(HEARING) 42
determined not to be landfill related.
And/ once again, I would just like to
show you on the map that the groundwater
flow determination was definitely in the
southwest. And most of the area of
sampling was up in the northeast corner
(indicating), which is in the upgradient
portion of the site.
The sampling data from the
privately-owned septic system indicated'a
potential for contamination associated
with residential wells. And the OU-1
remedial action, which is the landfill
cap, should be constructed during next
year, and that should prevent any further
potential contamination to the
groundwater or adjacent wetlands. And
continued ongoing monitoring, once the
landfill is in place, the groundwater,
ambient air, landfill gas, surface water,
and sediments will insure that the
existing population are protected from
any future potential contaminations.
That's pretty much my
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(HEARING) 43
presentation.
MR. KATZ: We will keep the
overhead. Some people had problems
hearing, so we will keep the overhead up
another moment or two.
Obviously, there is no point in
comimg up to a microphone that's not
plugged in, but if we just take your
questions one at a time and state your
name for the lady at the end.
We are required to respond to
your comments, and we want to respond to
your comments, but it's difficult unless
we get them down.
MR. GEORGE WEBER: My name is
George Weber, I am co-chair of the
environmental group of the Dutch Hollow
Homes.
We would like to read a formal
statement. Everybody has got a copy of
this, so we will go on the record with
it.
Dutch Hollow Homeowner's
Association's complaints and concerns
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(HEARING) 44
with the EPA1s handling of the Warwick
Landfill Superfund case.
One: The remedial report which
the EPA is basing their final decision
upon has been conducted by a company
hired by the parties responsible for the
dumping.
The company, Geraghty & Miller,
Incorporated, works for the Warwick
administrative group for the parties
named in the EPA suit taking part in the
dumping of the Warwick Landfill. Based
upon Geraghty & Miller's work, the EPA
has concluded that no further action is
necessary to protect groundwater in our
Community. We strongly question the
wisdom of this decision. We believe that
an alternate water supply is the only
solution to guarantee a safe supply of
water.
Two: The EPA scheduled this
meeting during peak vacation season,
giving only two weeks advanced notice.
Many families in the community are away
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(BEARING) 45
during this time. The minimum amount of
time for advanced notice should have been
at least one month.
Three: Under the Superfund
system, the EPA allows PRPs -- that's
potentially responsible parties -- to
play a much larger role in the
decision-making process than it does the
residents of the affected community.
PRPs and their consultants
negotiated in private with the EPA all
aspects throughout the entire process.
This includes investigation, cleanup,
remedial designs, et cetera.
The residents and their advisors
have very limited access to this process.
PRPs get to agree on proposal before the
residents or their advisors are given
access. This has giving the PRPs an
enormous amount of influence and
advantage.
Our TAG -- which stands for
Technical Assistance Grant -- advisors
have not been given adequate time to
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(HEARING) . 46
thoroughly evaluate these reports.
The remedial report was sent to
our TAG advisor just 20 days prior to
this meeting and just before he was due
to leave for a week's vacation. The Risk
Assessment Report was sent to the
groundwater TAG advisor and did not
arrive in his hands until Friday p.m.
this August llth. Consequently, the risk
assessment TAG advisor did not receive
the report until Monday P.M./ August
14th, which is yesterday afternoon.
Five: The EPA's oversight of the
entire testing procedure has been spotty.
The amount of direct oversight on their
part is questionable.
In the latest round of testing
within the one-quarter mile radius of the
landfill, only approximately 20 wells
have been tested. Notification of well
testing was attempt by telephone and/or
posting of notices on homeowner doors
rather than by certified mail. Some
homeowners had stated that they had never
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(HEARING) 47
received notification. Consequently,
homeowners who have desired testing of
their wells have not received it.
Six: The EPA has been less than
responsive in dealing with Dutch Hollow
Homeowner's Association officers and our
TAG advisors.
Many phone calls to the EPA have
gone unreturned. An EPA administrative
snafu delayed the renewal of our TAG
grant depriving us of the services of our
TAG advisors for approximately six
months.
Seven: The EPA's priorities are
wrong, both from an economic and an
environmental standpoint.
The EPA has designated the solid
waste aspect of the cleanup is Operable
Unit One, and the groundwater aspect is
Operable Unit Two.
The EPA is emphasizing the wrong
aspect of its plan. The alternate water
supply initiative -- at an estimated cost
of 1.5 to 2 million dollars -- should
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(HEARING) 48
have been given top priority to the
landfill cap at an estimated cost of 16
million dollars implemented as a followup
remedy. Instead, they have given the
landfill cap priority and have given the
alternate water supply no consideration
whatsoever .
Eight: The EPA, the PRPs, and
Geraghty & Miller, Incorporated, cannot
guarantee that other groundwater problems
will not occur in the future.
Some wells northeast of the ,
landfill are contaminated. This shows
that other wells in the area are
vulnerable to contamination, regardless
of the source .
The installation of a landfill
cap will only serve to slow down the
rainwater-induced leachates from the
landfill. It will do nothing to stop
contamination already present in the
water table, and its installation may
very well redirect the flow of
contamination into areas which were
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(HEARING) 49
previously uncontaminated.
There is no guarantee that all
wells around the landfill will be safe in
the further. This includes any new wells
that are installed.
The final Baseline Risk
Assessment does not give a clean bill of
health in its present form. Our advisors
are studying it carefully, having just
received it, and they have already
identified some serious mistakes in
calculations.
I received a FAX today from my
TAG advisor; it has limited information
based on the amount of time that it's had
to evaluate the report, but I can read it
to you.
(Reading from document) The
Baseline Risk Assessment for Operable
Unit Two embodies serious technical
errors. Moreover, EPA's characterization
of the risks to children from consumption
of contaminated groundwater is misleading
and improperly dismissive of a risk that
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(HEARING) 50
EPA's own procedures as well as
scientific consensus indicates to be an
appropriate focus of the concern.
Many chemicals that are essential
nutrients at tiny doses, such as
manganese/ are toxic at higher doses.
Moreover, the fact that the sale of
dietary supplements is essentially
unregulated by FDA means that one can
t
easily become poisoned by consuming doses
of vitamins and minerals that are
commonly sold over the counter.
Numerous cases of such poisoning
have been documented/ and children are
particularly at risk for such a
poisoning.
Recent legislation has
specifically attempted to address this
gap with regulatory protections as a
safeguard.
Basically/ what the TAG advisor
had told me was they're comparing apples
to oranges. They're using food-grade
levels to measure contaminants in the
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(HEARING) 51
groundwater.
And now we would like to say
something about the alternate water
supply process.
The alternate water supply
proposal: In 1991 our TAG again,
Technical Assistance Grant advisors
recommended an alternate water supply as
the most comprehensive and cost-effective
solution to groundwater contamination iii
the community.
A study conducted by Geraghty &
Miller, Incorporated, for the Town of
Warwick has shown an alternate water
supply initiative to be feasible.
The Village of Greenwood Lake
Board of Trustees has expressed its
support for us to tie into their
municipal water supply when their water
infiltration plant goes on line. The EPA
has refused to consider this alternative.
Advantages and the disadvantages
of an alternate water supply. The
advantages are: The measure is
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(HEARING) 52
conceptually simple. The measure is 100
percent effective in reducing the risk of
being exposed to landfill contamination
via the residential water supply. The
measure would provide community peace of
mind and help to resource property values
which have suffered a reduction due to
the presence of the landfill. The
measure is permanent. The measure
provides the greatest amount of
protection to the community for the least
amount of expenditure.
Disadvantages: The homeowner or
landlord would be required to pay the
cost and time and property into the new
system; that cost is yet unknown. And
the homeowner or landlord will then have
a regular water bill to pay of anywhere
from $.50 to $1.00 a day.
It should be noted that if the
PRPs would have agreed to provide our
community with an alternate water supply
up front when our TAG advisor recommended
it four years ago, they probably would
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(HEARING) 53
have saved money on legal fees and
investigative work.
We do not concede that the sole
source of the threat to our wells are a
septic system. We believe the landfill
will continue to pose a threat. We,
therefore, demand that the PRPs agree to
provide an alternate water supply, if
this is the wish of the majority of the
people in the community. We ask them to
do this regardless of whether they think
this is technically necessary. We think
the PRPs owe it to us, considering all
the hardship which the presence of this
landfill has put us through.
One thing is clear, they owe this
community something. The EPA obviously
thinks that the PRPs have lived up to the
letter of the law. We disagree and
believe that they have fallen far short
of living up to the spirit of the law as
well.
Thank you.
MR. GARBARINI: Thank you,
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(HEARING) 54
George. You said a lot there. I don't
know if I can responded to each and every
comment. But I certainly appreciate your
concerns, and I think one of the things
I'm hearing loud and clear are, and aside
from concerns about health risks, is
property values. And if I was in your
situation, I think I would also have
similar concerns. But I think one of the
f
other more important points that you did
make is that regardless of whether this
was necessary or not, you think it should
be done. And unfortunately the way the
Superfund program is done, we need to
have a scientifically-sound study that's
been conducted, and we need to rely on
sound science in order to make such
decisions or expend such money.
MR. GEORGE WEBER: We understand.
All we are asking is, Can you guarantee
us that we are not going to have a
problem in the future with this? Can you
offer us a guarantee? Can you guarantee
that our property values aren't going to
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(HEARING) 55
continue to drop? You can't. You can't.
What we're asking you to do is
give us something that will guarantee
that at a pitance of what you're spending
on that cap. Okay. The very fact that
you're putting the cap in, okay,
scientifically could cause a shift in the
direction of the water. That in itself
should be a.reason to put in an alternate
water supply. We don't understand the '
logic involved here.
Our TAG advisors asked you four
years ago for this. Be stated it, it's
is his reports. I don't -- from my
standpoint as a homeowner, I don't
understand the logic.
We are not interested in
bureaucracy. We have to live here. We
are the ones that put our homes up for
sale, we drink the water. It's always
there, and we don't care -- you know, you
can throw every scientific study in our
face, but the fact is that that stuff is
there. And I defy anybody here to tell
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(HEARING) . 56
me really what's under there and how much
is there. And anybody here that can get
up and give me a guarantee that that's
not going to leach into our ground
eventually, get up and tell me that now.
Is anybody here willing to take
risk? Put it in writing?
(No response)
i
MR. GEORGE WEBER: I rest my
case .
MR. GARBARINI: I think you
already realize that you do have a
problem with certain wells, and the
indications that we have is that that
contamination is likely coming from
septic systems in the area.
MR. GEORGE WEBER: I think --
MR. GARBARINI: Just to respond.
I think we heard you loud and clear back
in 1991, and we had conducted a
ground/air investigation back in 1991,
and we had reached some preliminary
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(HEARING) 57
conclusions. And we had heard all of you
very loudly and clearly, and we decided
at that point in time that we should do
additional investigatory work before we
reached a decision on this operable unit.
And we've gone through that, and we spent
a whole lot we haven't spent a whole
lot of money, but the responsible parties
have, and they've done this work under
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significant oversight.
The New York State Department of
Health and New York State Department of
Environmental Conservation at varies
groups within EPA all review the plans
that are necessary before we can go out
into the field, before the PRP goes out
into the field to conduct his studies.
We've all reviewed those and made
sure that they were up to snuff. And
then when we go out into the field, we
hire another contractor, our own
contractor, Ebasco Services, to oversee
the work that's done. When samples are
collected, we split samples with the
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(HEARING) 58
responsible parties, and those results --
we see their sampling results. Then when
we get their results, we compare them,
and everything looks as good as you can
expect from that perspective.
MR. GEORGE WEBER: You can't give
us a guarantee?
MR. GARBARINI: You already have
some contamination in the wells, and we
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believe that contamination is likely due
to the septic tanks. I can't guarantee
it.
AUDIENCE PARTICIPANT: "Likely."
That's the key word, "likely."
MR. GARBARINI: As I said, we
came out, we spent a couple of more years
investigating the groundwater flow and
the whole hydrogeologic regime, and we
concluded that the direction of
groundwater flow is away from those homes
in the northeast.
We spent a whole lot of money
investigating this. And I hear your
concerns. I would very much like to be
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(HEARING) 59
able to say, Sure, we'll put in an
alternate water supply. It's only 2
million dollars. We spending billions of
dollars on Superfund. The problem is,
the law doesn't allow us to do that
unless we have evidence
MR. GEORGE WEBER: How many
monitoring wells did you use?
MR. GARBARINI: We have 22
monitoring wells that were --
MR. GEORGE WEBER: How deep are
they?
MR. GARBARINI: They are at
various depths. Some of them are at deep
bedrock, most them are in the overburden,
in the shallow bedrock in the overburden.
MR. JAMES STRAWDER: My name is
James Strawder, I live on 786 Nelson
Road. (Inaudible from the audience).
MR. KADLEC: That was the New
York State Department of Environmental
Conservation. They are the ones that
basically pay for the monitoring wells.
I want to assure you that if your
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(HEARING) 60
drinking water is above drinking water
standards for less than a year,
monitoring it four times in that year, I
will not let them remove the filters from
the well.
MR. JAMES STRAWDER: You state
that -- (inaudible from the audience).
MR. KADLEC: Yeah, the DEC is
running into a problem. There's a big
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problem with this. Who's going to pay
for the filter? If the pollution isn't
coming form the landfill, then the State
has to absorb that cost. And that's a
big problem right now, considering the
political climate. But, I can assure you
that if your water is above drinking
water standards, I will not let them
remove those filters.
MR. JAMES STRAWDER: (Inaudible)
They even stopped the service on it about
two years ago. (Inaudible from the
audience)
MR. KADLEC: This is a problem
that New York State is running into.
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(HEARING) 61
There is nobody really to pay for them
now, but -- I'm sorry/ go ahead.
You're complaining the water
smells like?
MS. ALICE DOLSON: My water
smells like fish.
MR. KADLEC: That's
hydrogensulfide. That can be a problem
in some natural aquifers, most likely.
MS. ALICE DOLSON: I can't drink
that water.
MR. KADLEC: That's a common
problem with some wells it's hydrogen
sulfide.
MR. GARBARINI: The stenographer
is having some problems hearing. Please
come down and talk.
MR. JOHN MESSINGA: My name is
John Messinga. I would like to
correspond with what George Weber said.
The Dutch Home Association, members of
the community, many, many people express
doubts over the Superfund's .ability to
cleanup and maintain the integrity of the
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(HEARING) 62
water supply system. I read from your
own journal, "Uncertainty: Risk
assessment is not an exact science.
While EPA tries to estimate risks as
accurately as possible, there are many
sources of uncertainty in a risk
assessment."
We have to live here. We have
children here. I hope that your people
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are safe, your loved ones are safe when
you go home tonight. But these people
here are living here every single day.
You say you do monitoring once
every six months, once every three
months. Does that guarantee that the
water supply is continuously clear?
Gentlemen, we are worried. We
are asking for one-and-a-half to 2
million dollars to protect the community
permanently. I can't see that as being
such a problem when you say to us the
average cost of the Superfund cleanup is
20 or 25 million dollars.
And thank you.
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(HEARING) 63
MR. GARBARINI: Just to respond
to your question, we are in the
unfortunate position of having volumes of
data before us that are indicating that
the groundwater is flowing in the
opposite direction, that the impacts to
the residential wells are from the septic
tanks. And unfortunately we need to
have -- we can't have documentation like
that on the record if we're going to
offering to implement an alternate water
supply. We need to have documentation
and information that you have been
impacted or you will be impacted in the
future. And all the data that we have
indicates just the opposite.
I can understand your concern,
but that's as much as I can offer you at
this point, and I appreciate you
comments.
MR. ROBERT ELY: My name is
Robert Ely. Let me just get this
straight. You said you found the
contamination away from where these wells
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are contaminated?
64
MR. GARBARINI: We have found the
direction of the groundwater flow -- as
Damien had on the map, and we will put it
back up there --is towards the southwest
rather than the northeast.
MR. ROBERT ELY: Where the wells
are contaminated?
MR. GARBARINI: That's correct.
MR. ROBERT ELY: The southwest
wetland is contaminated where it's
flowing?
MR. GARBARINI: There is some
limited contamination there, yes.
MR. ROBERT BLY: And nobody's
well is going to be contaminated by those
people living down there?
MR. GARBARINI: There is no
indication that that that would be true.
MR. ROBERT BLY: Is the
contamination flowing that way?
MR. GARBARINI: The sampling that
we have done, there is no way we could
let that happen.
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(HEARING) 65
MR. ROBERT BLY: Where is that
going?
MR. GARBARINI: When it flows in
that direction, the wetlands serve as a
natural cleansing material, and that's
why we try to preserve it in some
instances. So contamination in the
wetlands
MR. ROBERT BLY: It is all going
to the wetlands?
MR. GARBARINI: It is not all
going to the wetlands, we haven't found
significant levels leaving the site.
MR. ROBERT BLY: Thank you.
MR. ROY PIATELLA: My name is Roy
Piatella.
Number one, the groundwater flow
in the town water supply is through the
aquifer in the village area. I don't see
that delineated on the map. Can you
please explain where it is in reference
to this land in the aquifer? And number
two, is it just some firm's sampling of
the town water supply?
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(HEARING) 66
MR. DUDA: I can address the
public water supply sampling. Are you
asking if there was sampling done?
MR. ROY PIATELLA: I'm asking:
Where is the aquifer in relation to
groundwater flow?
MR. DUDA: I wouldn't know that.
MR. ROY PIATELLA: Does anyone
know that?
MR. SHKUDA: (Inaudible) It
fills up the valley.
MR. ROY PIATELLA: Okay.
MR. SHKUDA: To the best of my
knowledge/ it is about a mile away with
the closest well that we have
downgradient.
MR. ROY PIATELLA: What type of
scientific evidence do we have of the
boundaries of that access?
MR. SHKUDA: That's in the
literature.
MR. ROY PIATELLA: Okay. So, is
there potential for contamination to flow
to that aquifer and potentially
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(HEARING) 67
contaminate the village drinking water?
Can someone comment on that?
MR. SHKUDA: First of all, you
have more than a mile of space in between
that. May I finish?
MR. ROY PIATELLA: Yes, sir.
MR. SHKUDA: In that mile there
is going to an enormous amount of water
moving into .the town. At this point
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we're not detecting contaminants involved
in the New York State or federal drinking
water standards. So, if there are low
levels already, and I add clean water to
that intervening mile, the concentration,
by anybody's determination, has to go
down. They will degraded, they will be
absorbed.
So the chances of that happening
are very small. That will be part of
this remediation. It calls for continued
monitoring to make sure that it is indeed
the case, and that will be carried out.
MR. ROY PIATELLA: One point I
would like to make. As you say, it's a
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(HEARING) 68
mile to a mile and a quarter to the
aquifer. Just to let you know, it has
been leaching for 20 years we assume,
generally. My question is for this
gentleman, are the residents to spend a
thousand dollars sampling the town water
supply?
MR. KADLEC: I would like to
comment on that. The public water supply
is monitored quarterly. Every few months
a sample is taken and sent off to the
Department of Health to make sure that
none of the chemicals are in the
groundwater.
MR. ROY PIATELLA: Can you
explain what they are monitored for?
MR. KADLEC: They're monitored
for volatile organic compounds, which is
a wide variety. Actually, New York State
uses more stringent standards than the
federal guidelines. They have their own
chemical guidelines that are followed
that are actually more stringent than the
methods that we have.
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(HEARING) 69
MR. ROY PIATELLA: You take those
samplings on a quarterly basis?
MR. KADLEC: Yes. The Division
of Water is responsible for that.
MR. ROY PIATELLA: One more
question I have is: I heard you talk
about the ambient air sampling.
Secondly, in the 1992 report put out by
the New York Department of Health, they
talk about the potential for VOC fumes '
going into residential basements. Do you
have any type of sampling in residential
basements of the BOCs in the household
and in the air?
MR. SHKUDA: There was a gas
sampling a subsurface gas sampling
that was completed and it is part of this
investigation. We went around the
landfill to determine whether there was
gas coming towards any of residences,
especially in the northeast which is the
closest to the proximate ones. There was
no gas detected in the rock, and there is
no pathway from the landfill to those
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(HEARING) 70
residences at this time, as far as we ,
could see.
MR. KADLEC: I would like to make
just a quick statement too. At other
sites around the state where this is a
problem with the vapors going into the
basements, normally that's in a case of
where there is an actual free product
flume, when there is so much of a
chemical present that it actually creates
its own liquid aquifer or whatever that
you would call it. It has t.o be very
concentrated in a liquid form for the
vapors to get into basements.
MR. ROY PIATELLA: It sounds like
we are very confident that there are no
problems with fumes in the residential
areas ?
MR. KADLEC: I'm pretty confident
about that.
MR. ROY PIATELLA: Were you doing
confirmation sampling? Can I go on the
record with that? I think there may be
something we can do for the residents.
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(HEARING) 71
Thank you.
MR. DUDA: Thank you.
MR. JAMES RILEY: Hi, my name is
James Riley, I am a homeowner on
Alexander Road. I don't know if anybody
on our road -- we have about 20 homes
that have deep wells. I didn't see any
indication that they were there.
MR. DUDA: The residential well
monitoring program was within a
quarter-mile boundary of the landfill,
and that particular location is outside
that quarter mile, and that was
determined as a result of the OU-1
Remedial Investigation. We decided that
the quarter mile would be an appropriate
response area to monitoring the
residential wells.
MR. JAMES RILEY: The
determination of the hydrolic gradient
that was done -- this gentleman here is
the geologist -- was there any
consideration taken into the.fact that
the test wells that were created were for
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(HEARING) 72
a very short duration attempting to
determine whether there were contaminated
wells and some of the others are pumped
on a daily basis and this might interfere
with the pathways deep in those wells as
to where the hydrolic gradient might
actually occur?
MR. GARBARINI: That was
certainly considered, and I'll let Greg
address that.
MR. SHKUDA: The map that is
there is naturally under pumpage. We
didn't look into the question that you
are asking, whether the people that were
on Nelson Road could change that gradient
by pumping their wells.
We conducted a study for three
days, and we recorded more levels in the
monitoring wells that are between the
landfill and Nelson Road. There were two
sets of monitoring wells, they're at the
top of the bedrock (Inaudible) deep zone.
During that three-day period, there was
no impact from pumping and no change in
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(HEARING) 73
.the water levels in those wells from any
pumpage on Nelson Road. So, it is clear
to us there is no induced gradient to
flow from the landfill to Nelson Road
when residents are pumping their wells.
MR. JAMES RILEY: The other point
is, just like -- my assumption is that
the monitoring wells and testing the
wells have been properly protected. In
other words, you establish the possible '
deep aquifer for the shallow pollutants
that are in that landfill. Are they
properly grounded and protected and going
to be protected from a long period of
time so that it doesn't go off into the
deep aquifer where it necessarily has a
chance to seep into there?
MR. DUDA: Yes. All the wells
that where put into the Operable Unit One
and Operable Unit Two were all instructed
under EPA guidelines for the proper
grouting and casing, and they are all
under lock and key. And during the
future monitoring, they will be protected
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(HEARING) 74
against any damage.
MR. JAMES RILEY: Where was that
monitoring program?
MR. DUDA: We don't have that
setup at the moment. That's part of the
operation and maintenance plan for the
cap, and we'll basically get into .the
monitoring plan as a result of that. And
EPA and New York State DEC and the TAG
advisors will all have a chance to
comment on that as well.
I am not quite sure when that
will be coming into effect, but that
probably won't be until we get the design
completed and the remedial action out of
the way.
Also, the existing monitoring
with respect to the residential wells,
which is currently ongoing, and we will
be getting the results of the second
round of sampling is it 27 homes now?
and the monitoring and the program itself
will be continued, if there is
contamination.
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(HEARING) 75
Also, with respect to that, I
know that you indicated that all the
people within the quarter-mile
boundary -- I think there were 67
properties -- there was a very serious
attempt to contact all of those
individuals. There were some individuals
who did decline to participate in the
plan. And the 24 individuals 27
individuals we currently have are all
fairly responsive. And for anyone
else -- we have a list of properties; if
anyone else would like to be on that list
that is in that quarter-mile boundary,
please let me, and I will make sure that
you will be in our next sampling.
MR. JAMES RILEY: From the
results of the sampling that are shown
here, even in the landfill site itself,
as a result of those samplings, is this
landfill going to be removed from the
Superfund site after the capping?
MR. GARBARINI: Yes. The site
would be deleted. There would be
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(HEARING) . 76
continued monitoring. And when you go
through the deletion process, it doesn't
mean that EPA no longer has the ability
to take action on the site. Even though
you deleted a site from the list, it sort
of removes the stigma of the site on the
surrounding community, but we are .still
able to take action if it is deemed
neces sary.
MR. JAMES RILEY: How long after
that capping is done?
MR. GARBARINI: It would probably
be a few years after the capping is done.
MR. JAMES RILEY: A few years
based on continued monitoring?
MR. GARBARINI: Well, we
basically have to get through the
deletion procedure. Given the fact that
we have been studying the site for so
long we have to go through the process
of writing a close-out report, then we
have to propose the site for deletion
from National Priorities List, and then
we have to finally delete it. So that
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(HEARING) 77
process could be as short as a year. So
perhaps maybe within a year after that,
we would sign off on the capping.
MR. JAMES RILEY: Do you do that
with all sites?
MR. GARBARINI: Ultimately with
all sites , yes.
MR. JAMES RILEY: And this
particular site?
MR. GARBARINI: We would like to
cap it and then have it deleted from the
National Priorities List, yes, so that
people could say, We had a hazardous
waste site in our community, it has been
investigated, it's been capped, it's been
handled, and it has been deleted from the
National Priorities List.
MR. JAMES RILEY: As far as the
TAG advisors, are they going to be given
time for written-comment period? What's
the period for written comments?
MR. GARBARINI: We originally had
a comment period that was due to expire
on the 30th, I believe -- August 27th,
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(HEARING) 78
I'm sorry -- and we have had a request
from the TAG group of the Dutch Hollow
Homeowner's Association that we extend
the comment period. And I think we will
be extending it. We would like to talk
to them about the length of the
extension.
MR. JAMES RIELY: Thank you.
MR. GARBARINI: Thank you.
i
MR. BOB ZIMMER: My name is Bob
Zimmer, I am a resident of the community.
I wanted to followup a little bit with
something to increase my understanding
about the groundwater flow in the area.
I was wondering if you might be able to
answer this: Before it was presented
that most of the residential wells in the
area were greater than 300 foot in depth,
and also Geraghty & Miller stated that
they had two wells about that depth. Is
most of the study of the potential for
groundwater flow from the landfill to the
residential wells based on those two
wells?
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(HEARING) 79
MR. SHKUDA: No, it is based on
all 20 wells. The statement that I made
regarding the wells is what the local
drilling contractors have told us. We
have asked the residents and required as
part of the work plan to try to determine
residential well caps. No one was able
to provide us with specific information.
Wells are too old, they weren't
there when they were constructed, people
weren't aware of how deep the well was,
but that's what the local drillers have
told us. The flow system that we
determined is the shallow bedrock, that's
where most of the wells are.
MR. BOB ZIMMER: What's the
difference between a shallow well --
MR. SHKUDA: It varies.
Within -- let's say within the upper
hundred feet of the bedrock surface.
Most of the wells are there, most of the
water is there. That's where most of the
water occurs in this formation
(indicating). Most of the fractures are
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(HEARING) 80
present and therefore the greatest
potential for water movement and action
as a source of water.
The work we did on the two deep
wells that we installed indicated that
there was very, very little water down as
deep as 300 feet. And as little as in
certain areas as a tenth of a gallon a
minute, which is well below any useful
amount of water that you could use for a
residence.
We have determined --. as I said,
this is a shallow flow system.
MR. BOB ZIMMMER: It is a deep
flow system that I'm most considered, but
especially Greenwood Lake as a community.
MR. SHKUDA: Our study area is
the area surrounding the landfill,
specifically in this case. The issue for
OU-2 was the residences was for more
detail, after the focus of our study in
question. That was the focus of our
study. We were not asked to study
Greenwood Lake or Greenwood Lake supply
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(HEARING) 81
system. I can't answer those questions,
I don't know.
MR. BOB ZIMMER: Focusing on the
map to the northeast. Understood, it is
not known at this time, but given the
fact that some of the wells might be that
deep, and being it's -a fractured bedrock
flow system, couldn't contaminants travel
or migrate from the landfill to those
residential wells?
MR. SHKUDA: Again, water doesn't
flow up hill.
MR. BOB ZIMMER: A pumping
condition is not necessarily uphill.
MR. SHKUDA: As I explained
previously to the other gentleman who
asked the question, we studied that very
issue.
MR. BOB ZIMMER: Using two wells.
MR. SHKUDA: That's correct. But
if they are the closest wells to that
community, if I do not observe the
effect --
MR. BOB ZIMMER: There is very
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(HEARING) 82
few fractures that deep in the bedrock.
MR. SHKUDA: That's correct.
MR. BOB ZIMMER: The wells that
you tested might not be the ones that
feed those residences.
MR. SHKUDA: That's correct, they
may not be.
MR. BOB ZIMMER: So there is a
possibility that the land could affect
deep wells into the northeast?
MR. SHKUDA: We have no data to
indicate that.
MR. BOB ZIMMER: No, you don't
need any data, but the potential is
there.
MR. SHKUDA: Yes. And there is
also a potential that the book can fall
off the table, but until I realize that
potential, it has no potential.
MR. BOB ZIMMER: I just want to
know if the potential is there or not.
MR. SHKUDA: I can't disagree
with you, there is a potential. But
think about this: I have a shallow flow
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(HEARING) 83
system where most of my water is
traveling to the southwest --
MR. BOB ZIMMER: Do you have
figures ?
MR. GARBARINI: Could you just
give him a chance to finish up his
response..
MR. SHKUDA: For water to move
against that gradient, I have to overcome
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that. I don't see how that's possible.
MR. BOB ZIMMER: Materials don't
necessarily travel even against the
gradient?
MR. SHKUDA: That's correct, but
there is no evidence whatsoever that they
are present.
MR. BOB ZIMMER: Allow me to
change topics slightly. Did you do I
saw in the Remedial Investigation that
some work was done on the continuous
monitoring of the wells. Did any of that
encompass what groundwater flow patterns
might change or what might happen in a
rainstorm, a heavy type-storm situation?
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(HEARING) 84
MR. SHKUDA: In this setting,
groundwater levels in all the wells are
going to be impacted the same. It is not
going to selectively rain on the landfill
in one area and omit raining on the
northeastern residence. So, certainly,
in the three-day tests -- I don't recall
if there was a rain storm there -- it
wasn't, it was dry. So there certainly
is an impact on water levels as we get
less rain, they do fall, but they fall
uniformly.
MR. BOB ZIMMER: Well, you don't
know that. You don't have any data to
support that. You don't know if the
system acts uniformally under a storm?
MR. SHKUDA: That's in the
literature. I don't have to study that.
You can look at the USGS studies of
aquifers throughout the country. That's
just a fact. (Inaudible) That's
literature information.
MR. BOB ZIMMER: I disagree.
MS. CATHY MARCHESE: My name is
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(HEARING) 85
Cathy Marchese, I live on 799 Nelson
Road. I just wanted to know what you
based your survey on? I live behind the
dump, and I'm just looking at how many
people you had tested, and out of 20 --
it was 20 people out of how many people
were you supposed to test in the
beginning in a quarter-mile radius?
MR. DUDA: I think it was 67
potential properties.
MS. CATHY MARCHESE: And how many
did you test?
MR. DUDA: Twenty-four.
MS. CATHY MARCHESE: Because I
was live behind it, and I was never
tested. I was notified once.
MR. GARBARINI: What did you do
when you were notified?
MR. JOE MARCHESE: Actually,
somebody came to the house to take the
test, and they never got back to us. He
said he wanted the first sample in the
morning, they never got to us, they never
came back.
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(HEARING) 86
I have two children. What would
I lose by having this man come in to test
my water? Believe me, I deal with it
every day. There is no way you're going
to tell me if there is contamination in
the ground, and you can prove that there
is contamination in the ground, there is
no way you can tell me that it is not
going down into the ground.
This gentleman mentioned that .
there is not that much water that deep.
My well is 290 feet deep, and we get four
gallons a minute. This gentleman over
here stated that he saline I don't
know in his water. I live right
across the street, two houses down. If
there is something that critical in the
well, don't you come out and send
somebody to test your well?
I feel that you guys already made
iip your mind, and anything we say is not
going to influence that.
MS. CATHY MARCHESE: Before this
meeting, I had talked to some of my
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(HEARING) 87
neighbors and asked them if they were
tested, and they said no, they said they
wasn't.
MR. GARBARINI: As was mentioned
before, we did go through a notification
process, we went door to door, flyers
were handed out, notices were given. And
unfortunately, in this situation -- well,
we will have to take alook into.
MS. CATHY MARCHESE: I had spoken
to you the other day.
MR. GARBARINI: Right.
MS. CATHY MARCHESE: How did you
make your conclusion when you don't have
all the facts?
MR. JOE MARCHESE: What would
people have against knocking at your door
and saying you're going to test the water
so your kid might not or you might not
get sick?
MR. GARBARINI: Believe it or
not, 10 or 15 people said they did not
want their homes sampled.
MR. JOE MARCHESE: This should be
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(HEARING) 88
something that is controlled. This is
drinking water. This is something that
should be controlled by the State. What
are you going to say? When you know it
is contaminated water, you are not going
to let me test it? I'm going to says
that's okay? You are going to let that
person drink that water?
It seems that nobody is making an
effort. The decision was already made;
and all this -- because there is no
fingers to point to, who is going to pay
up for the cleanup? There will be no
cleanup.
MR. GARBARINI: No, that's not
the case. First of all, there was a
program that was done. We can't force
people to let us sample their wells.
They own their properties. We can't
force them to allow us to sample.
As far as not being able to point
the fingers at anyone to have a cleanup,
I mean, we have got some responsible
parties on the line, currently, to cap
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(HEARING) 89
the landfill and to cleanup the site. So
there are people paying for the cleanup.
But in order for us to put in an
alternate water supply in, we need to
have an indication that the residential
wells up in that area are being impacted
by the landfill. And we don't have that
evidence at this point in time.
MR. JOE MARCHESE: There is no
»
way that you can tell me that there was
someone down to test our wells, there is
no way. That is false. I would have
been all over that caller.
I have had my water tested
privately. We never tested for the right
thing. You get a result back, and there
are certain things, and people spend
$200. You know what to test for, we
don't know what to test for. You get the
tests, you know what's in the ground, not
us; if we don't pinpoint, we don't see
it.
MR. GARBARINI: We can take a
look into what happened to your
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(HEARING) 90
residence, and you can be sure that we
will pull a sample up. If you are within
that quarter-mile radius, which you are
saying you are, we will make sure we get
a sample from your well.
MS. CATHY MARCHESE: And also my
neighbor, she wasn't notified.
MR. JOE MARCHESE: There are
houses being built.
MR. DUDA: If there was a new '
owner, we wouldn't know about it.
MS. CATHY MARCHESE: Well, what
about the survey?
MR. DUDA: Well, the survey is
based on the quarter-mile radius within
the landfill.
MS. CATHY MARCHESE: I am in --
MR. DUDA: The property owners
that we have on the list, we have
contacted them. Some of them we can't
even get the contact to, because there is
no one there. It is a summer residence,
there is nobody around to contact. But
the group of people that we've gotten
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(HEARING) 91
have been cooperative, and we have
sampled their wells, and we have
presented their data, and we have sent
them letters regarding their sampling,
and we have been very responsive with
respect to the sampling of their homes.
We're not trying to segregate
anybody out of the system. If there was
some sort of an error that you should be
on the list and you're not or that you
were contacted and there was no followup,
then that will be looked into.
MR. JOE MARCHESE: It seems like
the less people, the better the odds; the
less people you take --
MR. DUDA: That wasn't done here.
We didn't deliberate go out and take a
limited number of homes. We went through
the entire list of properties that we
had, which was 67 properties, and we have
found 24 recipients. It wasn't like we
took an isolated grouping of people and
said we want to sample your well and not
yours.
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(HEARING) 92
MR. GARBARINI: That's the idea
behind the quarter mile too.
MR. DUDA: We wanted to sample
everyone within that quarter mile. And
like Doug Garbarini said, we can't force
people to do that.
MR. GARBARINI: We will look into
your situation, and we will make sure
that we collect a sample.
MS. CATHY MARCHESE: Before you'
make a decision?
MR. GARBARINI: I can't promise
you that.
MS. CATHY MARCHESE: I have two
small children. What's not to guarantee?
I want clean drinking water.
MR. GARBARINI: We will look into
it, and we will make sure that we collect
a sample from your residence. I promise
you that.
MR. JOHN HUNTER: Good evening.
My name is John Hunter, and I am a
potential home buyer in this area, maybe
potential home buyer, I am not sure at
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(HEARING) 93
this point.
A couple of things that were
mentioned that I would like to talk
about. In your risk assessment, have you
done any political assessment of the
cancer rates within this area within the
last 20 years ?
MR. GARBARINI: Has EPA done
that? No, I don't believe so. I don't
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believe anyone has, but I can't say for
sure that that hasn't been done. But
none have been conducted for the Warwick
Landfill.
We do the risk assessment process
and we also conduct what's called a
health assessment, which is done by the
New York State Department of Health and
the federal agencies of Toxic Substances
and Diseases Agency. Those two things
have been done.
MR. JOHN HUNTER: As a government
employee, I am ashamed that that hasn't
been done. We have had 11 years to do
that. I'm not here to banish you.
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(HEARING) 94
MR. GARBARINI: It is not
something that we would typically do. If
there is a request, sometimes the State
Health Department will perform those
studies, but there is a long request for
different communities that are looking to
have those studies conducted.
MR. KADLEC: Right now the list
is somewhere between two and six years
for a cancer study.
MR. JOHN HUNTER: There is
something that has been mentioned
initially is that there's been a lot of
money spent on this issue, and we know
that there are guidelines that you
gentlemen must follow. But the action to
bring this to a resolve is to bring in an
alternate water source. It seems, based
on my short knowledge here, that there
has been work with agencies or with the
people involved in this, possibly the
agencies responsible for bringing this
waste into the site at midnight -- and I
just have this perception about this.
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(HEARING) 95
When you talk about perceptions, property
values around here are a reality, and it
should be part of their decisionmaking
process, whether that's a scientific
basis or not. The fact that there is a
firm engaged in this that has something
to do with the responsible parties, I
think that is a poor judgment on the part
of the United States government.
MR. GARBARINI: I think that's a
pretty flagrant comment.
MR. JOHN HUNTER: I think that
was poor judgment. It may be allowed
within the law, but on the basis that it
doesn't appear that the homeowner's
association had has adequate response or
participation to alleviate that
perception, I think that's something that
in hindsight you gentlemen may have to
live with.
The fact remains is that a
reasonable alternative is the alternate
water source that has been proposed that
seems to be an economical issue for all
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(HEARING) 96
of us, for current homeowners and future
homeowners. And the fact that the
agency, whether it says that you have to
wait for a request to do a clinical study
of cancer rates within an given area --
and that is something that came out of
the Love Canal issue, the increased
cancer rates, I believe.
I would think that the agencies
would be talking to each other, and aft'er
11 years, this data would have been
presented. Again, some of my comments
may be viewed harshly. I'm not here to
banish you. I think those statistics are
out there, they just hadn't been done.
MR. GARBARINI: I think just to
respond to your first comment about using
we are not using a potential
responsible parties to conduct the work,
we are using a contractor that relies on
various parties to pay their bills,
basically. Geraghty & Miller, they are a
highly reputable consultant, especially
in the field of groundwater
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(HEARING) 97
investigation.
And as I said before, we have a
contractor that we hire that directly
oversees their work. There are numerous
state and federal agencies that review
all the plans and direct the contractors
to how the study is to be conducted, and
then we go and we validate everything.
As I mentioned, we split samples
with the contractor to make sure that
their sample results are coming back
similar to ours. We are out there in the
field checking up on their work. And
this is the way we do business.
MR. JOHN HUNTER: Just one last
question. I don't believe two homes to
the northeast is a statistical valid
number to make an assessment of whether
there is any flows going in the
upgradient direction or to the northwest
or northeast.
Though it may seem odd what the
gentleman said, that there were only two
wells that were tested to the northeast.
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(HEARING) g
I don't know based on just those limited
samples -- I just don't have a good
feeling. I have more of a sense that you
got 30 percent of the wells within the
quarter-mile area, but to the northeast
of the area, I don't feel that those two
wells -- at least that was my
understanding.
MR. SHKUDA: There are many more
wells that were tested. There are just-
two at depth that were monitoring wells.
But residential wells to the northeast,
with the responses that we were able to
locate, there were samples collected from
those wells, and they were tested. So
there are many more than two. I can't
recall offhand how many, but we tested as
many as would allow us. We can only do
what we are allowed.
MR. JOHN HUNTER: And my last
question: You stated earlier that you
may not be able to go onto the property.
Isn't it reasonable that there is a
health concern, which I believe there is
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(HEARING)
here, that the state or the federal
government can mandate testing in the
area without approaching the rights of
the homeowners'?
MR. GARBARINI: It is certainly
not with the level of concern that we
99
have .
MR. JOHN HUNTER: I think that's
the concern here.
MR. GARBARINI: I imagine if
there is significant enough concern that
the Health Department could say that we
should go in there and collect a sample,
but I think the level of concern would
have to be much, much, much higher than
the level of concern that we have here.
That's not to say that we aren't
concerned about all those residential
wells up to the northeast of the site.
MR. JOHN HUNTER: Thank you.
MR. GARBARINI: Thank you.
MR. ROY PIATELLA: Roy Piantella.
Just one last thing. The wells for the
residents that were not there, I want to
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(HEARING) 100
~ know, is it at all possible for you to
state that you will do that survey again
for those poor unfortunate people that
are not here right now to talk about
sampling? Can you at least do that, is
it possible?
MR. GARBARINI: You're talking
about the residential well monitoring?
MR. ROY PIANTELLA: Can you just
go back and review those 40-some odd
people that weren't contacted or didn't
re spond?
MR. DUDA: We can't get into the
well unless there is someone on the
property.
MR. ROY PIATELLA: I am asking if
you can try and contact the residents.
MR. DUDA: We could try and
contact the residents again, yeah. And I
think we have gotten some more residents
from the last round of sampling. I am
not quite sure how many more residents,
but we have gotten a few more people.
MR. ROY PIATELLA: Was that
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(HEARING) 101
people by telephone call or certified
letter?
MR. DUDA: We did a personal
canvasing around the entire neighborhood,
and it would probably be by letter or
phone call, that type of thing.
MR. ROY PIATELLA: Thank you.
MR. DUDA: Sure.
MR. JOE MARCHESE: You said that
you would look into the testing?
MR. GARBARINI: We will test your
well.
MR. JOE MARCHESE: Okay. How
long does it take?
MR. GARBARINI: How long does it
take to get the results back?
MR. JOE MARCHESE: Yeah.
MR. GARBARINI: The test itself,
it would be a short period of time on a
given day, actually, to collect the
sample. I am not sure how much we could
have it, but generally we give 30 to have
45 days to analyze the sample and then we
have to validate the data, so it could
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(HEARING) 102
take a couple more weeks after that. So
it will probably be a couple-month
process.
MR. JOE MARCHESE: Isn't there a
chance you could send it out certified
mail to those people that weren't there
or the new houses on the block? This was
in '91. The house was built before that
and the well was sitting, they weren't
living in the house. The wells where
sitting there. So this was, again, a
Catch-22. There was no one really to
test the well, but now there are some.
MR. GARBARINI: If you know of
people that are in the quarter mile -- if
you take a look at the map and you know
people that are within the quarter-mile
radius, they can contact us, and we'll
give it some consideration.
MR. ROY PIATELLA: You said you
will consider it, or you will contact
them?
MR. KATZ: These are people that
we might not have included in this
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(HEARING) 103
before, these are additional people that
we might have not included. So,
obviously, what we are hearing is that
there are people we don't even know about
that do exist.
MR. DAVID DUCKWORTH: My name is
David Duckworth, I live on 716 Nelson
Road. I am not within the quarter mile.
I have a wife that's pregnant with two
kids. In order 'to figure out what is
being done on this site, what type of a
test can I do on my water at my own
expense? Where is the cheapest place to
go to have it tested? And what am I
testing for?
MR. KADLEC: I'm sorry, I missed
your question. I was talking to Rich
here about sampling. Could you repeat
it?
MR. DAVID DUCKWORTH: I have a
pregnant wife and two young children. I
am probably three-eighths of a mile away
from this dump site at 716 Nelson Road.
At my own expense, if I have to, what do
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(HEARING) 104
I test for and where can I have it done?
MR. KADLEC: The tests that you
would probably be looking for would be
lead, that would be a major issue if your
wife is pregnant, heavy metals and stuff
like that. Some of the problems that
were in other wells were VOCs, volatile
organic compounds they're called.
Now£ you have to understand all
the wells that were sampled, only four 6f
them had shown that the levels were above
drinking water standards. Now, over time
those levels have been decreasing also of
these wells that were taken.
Now, You can seek out private
individual labs that would do it. I
can't really give you the name or
recommend any labs to do it for you,
being from the State, but if you look in
a big city yellow pages under
"Environmental," they may be able to do
something.
MR. DUDA: You might want to
contact the Orange County Department of
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(HEARING) 105
Health, they will be able to help to
identify some people that could come in
and take samples of your well.
MR. DAVID DUCKWORTH: Will it
cost $1,400 like I am hearing?
MR. KADLEC: I don't know the
cost of it, personally.
MR. GARBARINI: You would
definitely be talking about a couple of
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hundred dollars, anyway.
MR. DAVID DUCKWORTH: The other
alternative is to just get the filter.
Is the carbon filter going to guarantee
that my water is going to be safe?
MR. GARBARINI: The carbon filter
is affective for organic contaminants,
but would not necessarily be effective
for heavy metals --
MR. KADLEC: Like lead. It is
usually a reverse osmosis along with a
chelating agent. What they do is they
put in sodium hydroxide or some sort of
salt that would cause the metal to
percipitate out. But that is very
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(HEARING) 106
expensive and you can't really do it a
homeowner basis really.
The only thing that I could
recommend is if you are worried about
heavy metals in your drinking water, run
the water for a while.
MR. DAVID DUCKWORTH: What about
the filters?
MR. KADLEC: The volatile organic
chemicals are taken out with the carbon '
filters.
MR. DUDA: I just want to
reiterate that any volatile organic
compound contamination we found is very
low/ and it only exceeded New York
standards in two wells/ one of which
already has a filter on it. So we really
feel that the contamination is
exceedingly minimal, and in most of the
homes were basically not detected for
those compounds.
As Mike indicated before with
respect to the lead/ those homes have all
been resampled and have shown exceedingly
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decreased levels of lead within the
107
federal standards, which is a very, very
small number, so...
MR. GARBARINI: Also, just to
reiterate, the lead can be a particular
problem for pregnant women and for
children. You may just want to take a
sampling for the lead.
MR. DUDA: We are going to take a
two-minute break for the stenographer
here .
(Brief break)
MR. KATZ: We are ready to start.
Again, whoever has a question, feel free
to address us.
MR. KEVIN CAPBION: I have been
attending the homeowner's association
meetings for several years, and a few
years ago, if my memory serves me
correctly and a few folks here
confirmed that tonight --the EPA itself
drilled wells on and off the landfill
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(BEARING) 108
site. I understood at the meeting that
an EPA person presented themselves that
traces of benzene and other chemicals
were dectected in the EPA-drilled wells.
First of all, I would like to know
whether or not that was correct or not.
Second of all is that it's 1995,
and we're looking at 1.5 to 2 million
dollars to put in an alternate water
supply for potentially contaminated wells
either now or in the future. I don't
understand what the problem is with the 2
million dollars compared with the 16
million dollars.
I don't know about anybody else
here, but taxes have not gone down in the
Town of Warwick in this particular zone
that we're talking about, and I don't see
that changing. It is probably only going
to go up. They are talking about coming
out and reassessing the values of the
homes, taxes are more likely to go up.
Everytime I go for a refinancing
of my home, the surveyors come out, and
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the topic of the toxic landfill keeps
popping up, which is not helping the
value at all or the resale value. An
alternate water supply is not only going
to benefit everyone's health in the
future and the community, but it
improvements everyone's home values.
I don't understand/ if the board
here is to address any of those issues
and the home values themselves, but more
so than the home values/ it is the health
now of the participants in the community
and in the future of all of those living
here .
MR. GARBARINI: Damian is taking
a look to see if he finds any benzene
results.
MR. KEVIN CAPBION: It was
benzene.
MR. DUDA: That contamination was
part of the first study you're talking
about; right?
MR. KEVIN CAPBION: This was very
early on.
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(HEARING) no
MR. GARBARINI: If he can't find
it now, we will just respond to it in our
Responsiveness Summary.
MR. KEVIN CAPBION: I realize I
am not within the quarter mile of the
dump, but we are pretty much, in my area,
which is towards the school here getting
down towards Lowe man. We have not been
approached at all to have our wells
tested in any shape or form. I get my
own personal testing done, but the type
of chemicals that you're looking at, I
understand those tests cost well into the
thousands of dollars to have them tested,
which I imagine the EPA has the funds
allocated to do. I personally do not, so
I don't know personally what you can do
to test for certain traces of chemicals
that could be contaminants to my home.
MR. GARBARINI: I don't know what
more I can say about the alternate water
supply. I am beginning to sound like a
broken record. There is really nothing
that we can do about it without evidence
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(HEARING) 111
that the contamination is moving in that
direction and the contamination that had
been found in the wells, that it is
actually from the Superfund site. All
indications are that the levels that were
found in those wells are dropping* There
are carbon filters, as we mentioned here.
MR. KEVIN CAPBION: Did you just
indicate that the wells have been
" »
contaminated from the Superfund site?
MR. GARBARINI: No, they have not
been.
MR. KEVIN CAPBION: I thought
that's what you said.
MR. GARBARINI: I might have said
that, but that's not what I intended.
No, we have no indication that the
contamination in those wells is from the
Superfund site. If we had that
knowledge, then we would be able to take
action and propose that we implement an
alternate water supply.
MR. KEVIN CAPBION: Are you
talking about the 24 wells that you
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(HEARING) 112
tested yourselves, or are you talking
about the wells that were tested
previously?
MR. GARBARINI: Both.
MR. KEVIN CAPBION: Both. They
have found traces of chemicals that are
naturally found in the area itself?
MR. GARBARINI: That's right.
MR. KEVIN CAPBION: There is no
indication as to where they came from? '
MR. GARBARINI: There was septic
sampling done.
MR. KEVIN CAPBION: Does benzene
come from chemicals that are associated
with cleaning materials?
MR. GARBARINI: Absolutely. Very
significant levels were found in the
septic systems themselves, very
significant levels. And a lot of the
solvents in the past, too, have been used
to clean out septic systems, or for
different home remedy products that were
utilized for cleaning out septic systems
in the past, solvents and degreasers to
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(HEARING) 113
make the systems work more effectively.
MR. KEVIN CAPBION: I have
nothing further to say, other than what I
do remember hearing at previous meetings,
that EPA presented and examined the
results themselves.
MR. GARBARINI: Yeah. And that
there was some benzene found?
MR..KEVIN CAPBION: Benzene is
the one that stuck out in my mind, I
think right off the bat.
MR. GARBARINI: We aren't saying
that there isn't contamination in some of
the monitoring wells. We aren't saying
that at all. And we did have some exceed
the state and federal standards in some
of the monitoring wells. But the
contamination is spotty, and it's
infrequent, and we can't delineate any
further contamination.
MR. KEVIN CAPBION: What does the
EPA consider the number 1 issue at hand?
Is it the contamination of drinking
water? I can't imagine exactly what the
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(HEARING) 114
other concerns might be for the residents
in the community itself, but an
alternative water supply does sound like
the most aggressive situation to be
taken to remedy any situation that could
occur.
MR. GARBARINI: Yeah. If we knew
that the landfill was impacting
residential .water supplies, we would be
t
able to take such an action, but we don't
have that information.
MR. KEVIN CAPBION: You don't
have the information that the landfill
has contributed to those chemicals?
MR. GARBARINI: That's right. I
don't know what more I can say.
MR. KEVIN CAPBION: Thank you.
MR. GEORGE WEBER: I have another
question. This is the New York State
Department of Health 1992 Health
Assessment for the Warwick Landfill. In
here it says that originally that there
were nine wells in the area that were
contaminated, and I'm assuming that the
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(HEARING) 115
reason that we are not mentioning the
nine wells now but the four is that four
of them there is only four that's
above New York State drinking water
samples; correct?
MR. KADLEC: Yes.
MR. GEORGE WEBER: Okay. Now, of
those nine wells/ assuming that each home
has a septic system; from your testing,
*
how many septic systems are contaminated?
MR. GARBARINI: We will check
that for you. Do you have a followup
question also?
MR. GEORGE WEBER: Yes. How many
are contaminated? Is the contamination
coming from one septic system
contaminating four wells or four septic
systems contaminating individual wells?
MR. GARBARINI: We could say that
there were several septic systems that
did have significant levels of orgainic
contaminants.
MR. GEORGE WEBER: Can you trace
that directly -- I mean --
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(HEARING) 116
MR. GARBARINI: Can we point?
No, we can't point.
MR. GEORGE WEBER: Do you have an
idea where the contamination is coining
from?
MR. GARBARINI: Well, we have
some septic systems that do have very
significant levels of contaminants up in
that northwest area, yes, so we have an
idea .
MR. GEORGE WEBER: Right. I am
not arguing that. Let me rephrase the
question. Basically, what I am asking,
okay, is that you're saying that there
was contamination coming from the septic
systems, okay, and originally there were
nine wells that were contaminated from
the septic systems
MR. GARBARINI: Well, I'm not
sure -- you're basing your statement that
we have nine contaminated wells based on
the 1992 report. We're dealing a couple
of data sets from 1994, I believe.
MR. GEORGE WEBER: I'm not
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(HEARING) 117
arguing that. But what I'm saying is
that is originally, though, that there
were nine wells that were contaminated.
Okay.
I'm trying to see the correlation
between the septic systems and the well.
Whether you -- (brief pause) -- the other
thing is, how can you be sure that the
contamination is not coming from the
#
landfill into the septic system?
When you say "the septic system,"
are you talking about a leach field? Are
you talking about an old septic system?
MR. GARBARINI: You're using the
term "septic system" as a generic
catagory. Some of those are just
basically cesspools, I guess. And some
of them may have active septic systems.
AUDIENCE PARTICIPANT: How can
you tell if it is the septic system
contaminating the water, or the water
contaminating the septic system?
MR. 6ARBARINI: Because as you
know, you just looked at some of the
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(HEARING) us
levels of contamination found in those
septic tanks, and they are extremely high
in comparison to groundwater sampling or
anything that was found in residential
wells .
MR. KADLEC: And they're -- I
think they're above the ground too, the
septic systems.
MR. GARBARINI: You have to
understand that cross-contamination from
septic systems to residential wells is a
very, very common problem. Speaking
from -- years ago, when you were about to
purchase a residence, you had to
analyze -- if you had a septic system and
a residential well, you had to analyze
the well for bacteria, E. coli, things
like that. This is before we really saw
solvents and organic toxic contaminants
as being most of your problem.
And, in fact, some of the
sampling that we did last year in the
septic tanks and in the wells indicated
bacteria in the wells. You may ask,
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(HEARING) 119
Well, where in the heck IB the bacteria
coining from? Probably from the same
place that the organic compounds are
coming from, from the septic systems.
MR. GEORGE WEBER: Are you saying
that you're absolutely certain that those
wells are contaminated from septic
systems ?
MR. .GARBARINI: I would say that
that's a likely source, and it is a much
more much likely -- much, much more
likely source.
MR. GEORGE WEBER: But you're not
sur e ?
MR. GARBARINI: I can't be sure
of that.
MR. GEORGE WEBER: That's all I
wanted to know.
MR. ROY PIATELLA: One followup
question that I have. On the septic
systems, when you did find the solvents,
and assuming that's the DCE and TCA
was that the solvent that was found in
the septic systems?
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(HEARING)
MR. KADLEC: What?
120
MR. ROY PIATELLA: DCE? TCA?
MR. KAKLEC: All of the above.
MR. ROY PIATELLA: All of the
above. Okay. Was there any type of
questionnaire put to those residents as
to how that may have gotten there? I am
not aware that those solvents would be in
a septic system. What would the source
of the solvents be? Unless they flush a'
particular solvent down their toilet
and I don't know how many people
generally would do that. I know I have
never dumped a solvent down my toilet.
Did you do any type of survey or
investigation on that?
MR. GARBARINI: Well, just
generally, going back years ago, people
used to use solvents to clean out septic
systems to remove a lot of the grease
that was impacting on the fields and
things like that. So someone could have
had a contractor come in and clean out
their septic when they were having some
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(HEARING) 121
problems. I don't know. Maybe they
didn't necessarily just flush it down the
toilet.
MR. ROY PIATELLA: What kind of
solvents ?
MR. GARBARINI: Degreasers, I
believe they were, and they could be
found in some Rid-X yeah, Rid-X was
one of those. And if those contaminants
themselves were in the cleaning mixture,
those contaminants may be daughter
products or breakdown products of
contaminants that were used. So as these
things decay or they reacted to other
compounds, they can breakdown into other
products. So there is that link for
those contaminants.
MR. ROY PIATELLA: Was that
question asked of the residents?
MR. DUDA: We didn't do a septic
tank survey specifically on the
residents.
MR. GARBARINI: What we did do is
we did send literature out to the
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(HEARING)
122
res idents.
MR. ROY PIATELLA: Just to put on
the record, does that mean this may be
something you may want to think of, a
simple question to the residents and then
followup with the people, Did have a
cleaning service? I'm sure they know,
and that question could be asked, and
then maybe that could help delineate
whether it's from a landfill or from som'e
cleaning products.
MR. GARBARINI: Just to add to
that too, we've heard other stories about
people doing auto repair work and things
like that up in that area too, and
obviously repair shops do use a lot of
degreasers and solvents also.
MR. ROY PIATELLA: Exactly. And
I think if you pose some type of question
or survey of the residents, you may be
able to actually find that out.
MR. GARBARINI: Thank you. Maybe
we will followup with that.
MS. BRIDGET ENRIGHT: My name is
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(HEARING) 123
Bridget Enright. Of the wells that were
contaminated, what type of septic systems
do they have? Did you determine that?
Whether it was a closed system or
cesspool system?
MR. DUDA: We don't know that.
MR. GARBARINI: What do you mean
by a "closed system?"
MS. BRIDGET ENRIGHT: Were they a
contained system? And where was the
location of the septic system in relation
to the well? Could you actually
determine that?
MR. GARBARINI: By the "contained
system," you mean the tank itself?
MS. BRIDGET ENRIGHT: Yes.
MR. GARBARINI: They wouldn't be
contained, necessarily, because they
don't have a field, so there would still
be discharged.
MS. BRIDGET ENRIGHT: So you
would have to determine whether it was a
cesspool that they were using in the old
houses ?
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(HEARING) 124
MR. GARBARINI: We're not sure
whether it would make that much of a
difference, but, no, that wasn't
determined. We could look into that.
MS. BRIDGET ENRIGHT: Would that
make a difference?
MR. DUDA: We didn't make a
determination of how close the well was
to the individual homeowner's septic tank
or another homeowner's septic facility. '
They are fairly close together on some of
those homes, and, you know, it's not
guaranteed that one septic tank is only
going to affect one well, it could affect
other wells.
We sampled 11 septic systems.
Whether they were cesspools or tanks, I'm
not sure. We could certainly look into
how the samples were taken. I think most
of them were sediment-type samples from
the actual septic tank or cesspool
facility. And in most cases we did find
some organic contamination in those
septic tanks, which can relay back to the
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(HEARING) 125
water supply, because we're not sure
exactly what the drainage system is for
those septics tanks either.
As far as the drain fields, when
they were put and how functional they
are; you have to understand, too, that a
lot of that area is rather hilly and high
terrain, so there's not going to be a
lot -- I mean, things are going to drain
pretty well off those people's homes from
some of the area up there. I am not sure
exactly of all the values, but it is
much higher area up there than the
landfill.
MR. GARBARINI: When you are
dealing with tanks, like Damian said, if
you're sampling the septic tank, you
obviously have a pretty good idea of
where the tank is itself. You may not
not know where the fields are, that's a
little bit harder to discern.
And the other thing, too, that
comes into play here is the actual
construction of the residential wells
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(HEARING) 126
themselves, because sometimes if they
generally aren't cased the full length of
the well -- because you want to allow as
much water to infiltrate into the well as
possible so you have a good yield. So
that also serves as an increased conduit
or a possibility of transporting
contaminants across the shallow bedrock
into the deeper bedrock into the well.
MS. BRIDGET ENRIGHT: Okay.
Thank you.
MR. THOMAS WINKLER: My name is
Thomas Winkler. I would like to know
what the EPA's contingency is. Maybe you
can share that with us.
MR. GARBARINI: The contingency
plan? I guess what we will be doing is
there will be ongoing monitoring after
the cap is put in place, there will be
monitoring operation maintanence and a
monitoring program in place.
If we find any problem, we can
always come back and take corrective
action as necessary.
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(HEARING) 127
MR. THOMAS WINKLER: That was my
next question. I think we have learned
in this town is what is uphill must come
downhill, and we learned that in the
septic systems you found benzene and you
also you found dichloroethene and
trichloroethene at acceptable levels.
And I would like to know what happens
when those low levels exceed acceptable
levels, what is your plan?
MR. GARBARINI: What would the
corrective action be?
MR. THOMAS WINKLER: Yes.
MR. GARBARINI: Well, there is no
indication that those levels ever will
exceed groundwater or drinking water
standards, nor will that they will exceed
them to the extent that there will be any
action required. It's very unlikely that
we would ever dig up the landfill.
You could understand, we are
dealing with a 19-acre landfill, quite a
bit of material. In the last operable
unit we selected a remedy for the
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(HEARING) 128
landfill itself. We did do a lot of work
to try and look for any hot-spot
contamination, buried drums or whatnot.
That's what our guidance calls for us to
do .
We did geophysical work/ we put
borings through the landfill, we put in
test-bit trenches, and we didn't find
anything. That doesn't necessarily mean
that there isn't anything there, but we '
did a good, sound scientific job and we
followed the EPA guidelines as to how we
are to evaluate landfills.
MR. THOMAS WINKLER: Is it
possible that you have contaminants
sealed in drums?
MR. GARBARINI: I would think
that most of the drums would have
corroded by now, but that's also a
possibility, yes.
MR. THOMAS WINKLER: You are
saying there's nothing to worry. It's
not going to exceed?
MR. GARBARINI: We don't foresee
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(HEARING) 129
a problem at this point. There will be
monitoring of the landfill.
MR. THOMAS WINKLER: There will
be?
MR. GARBARINI: Yes, there will
be monitoring of the landfill.
Thank you.
MR. THOMAS WINKLER: Thank you. .
MR. DUDA: Does anyone have any
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further comments?
MR. ED MATEA: My name is Ed
Matea/ I live on Alexander Road. The
testing for wells for individual
monitoring of wells, testing basically
for E. coli bacteria/ things like that,
if you want to test it for the type of
contaminants that you guys are talking
about, it is very costly. I was
wondering if I might suggest that for a
continued monitoring, perhaps the EPA can
provide the local residents with sterile
containers and then they can collect
their own samples periodically for
testing of their own wells.
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(HEARING) 130
I would very much like to have my
well tested. 1 took the samples, but
when I saw the price tag, it just wasn't
in the budget. I sure there are some
other people like myself just outside the
quarter-mile radius that have concerns
about our wells.
MR. GARBARINI: I understand your
concern. There are generally/ if
you're going to get the full gamut of
testing done, you're right, it will run
you a thousand dollars or so.
MR. ED MATEA: Whereas, most of
us are well acquainted with having tests
on our own wells through the due process
of collecting the sterile containers and
having all different types of water tests
on our wells testing for E. coli bacteria
and septic contaminants.
MR. GARBARINI: Unfortunately,
just to answer your question directly, I
don't think that would be something that
we would be able to do.
MR. KADLEC: You run into a lot
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(HEARING) 131
of liability, also, when it comes to
chain of custody and having an officer
take the sample.
MR. ED MATEA: Basically, what
you would do is you would provide us with
an indication that if we did get a
positive result
MR. KADLEC: That is true.
MR. ED MATEA: And it would give
the homeowners a lot of peace of mind.
It might be a little costly, but it would
calm the fears that a lot of people have.
Basically, when I sat back there and
listened and I understand your
position, but I am not at all convinced
that your study is conclusive at all.
I am in the construction
business, and I am somewhat familiar with
well drilling, and what I heard
earlier I have heard assertions made
here about water not running uphill,
except that is just not so, water does
travel uphill.
It is virtually impossible to
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(HEARING) 132
predict the flow of water. If you have
12 wells here, the only thing that we
could all manage to agree on is that you
cannot predict what's going on with the
water underground.
I just had a well drilled on my
property. It's 400 feet deep. I had it
drilled within the year, it's maybe
three-quarters of a mile from the site.
There was no bedrock detectable at all,,
no subbedrock, no detectable bedrock of
any kind. All we had was unformed rock
at 400 feet. This is vitually an
unusable well. We couldn't find any
water at all. Three feet away, you can
get an entirely different result.
You can drill a well one way
under the ground and then ten feet away
drill another well and get a totally
different composition. It's a complete
roll of the dice.
There are some generalities, but
I think 20 holes in the ground over an
18-acre area is really not sufficient to
I
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(HEARING) 133
determine anything.
Again, not to say that it's not a
difficult task, but the problem is that
you're about to close the door on this
issue. We had some dealings with EPA and
DEC and it strikes me that you are about
to close the doors on this issue.
For instance, you're talking
about are you aware of the fact that
BOCA (phonetic) has established
regulations for separations for
minimum separations, land area
separations for individual septic and
well?
MR. GARBARINI: I knew that there
were some requirements.
MR. ED MATEA: The separations
are a result of people who are equally
qualified, like yourselves, to determine
how far a well has to be from a septic
field to avoid contamination. Now,
you're saying that all the cases you've
tested where there was contamination in
the well, that it originated from the
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(HEARING) 134
septic field? Either every system that
you tested was a noncompliant system or
there was something wrong.
MR. GARBARINI: Bow long have
those regulations been in effect?
MR. KADLEC: The sanitation
regulations are for E. coli bacteria, and
the distance away from the wells --
MR. ED MATEA: That's for
cross-contamination fluids?
MR. KADLEC: Right. But, in this
case/ we're looking at volatile organic
chemicals which are very different, they
travel though the groundwater very
differently than the reason septic
tanks are supposed to be a certain length
away --. the sanitation codes do not take
into consideration --
MR. ED MATEA: I know for a fact
that the separations are specific, I know
they are to avoid E. coli contamination.
MR. KADLEC: I think that was in
terms of bacteria.
MR. ED MATEA: If you tested the
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(HEARING) 135
number of systems, and in every case that
you had contaminants in the well casing,
you also found contaminants in the septic
tank, then there is something amiss.
Either all the systems you tested were
not complying or the codes were
insufficient.
MR. GARBARINI: I don't think we
are even saying that the contamination
that we found in a given well was related
necessarily to a septic system from that
same property. , That's not what we are
saying. We are not pinpointing
contamination of one property.
MR. ED MATEA: Looking at your
map up on the screen I see 18 acres, 50
feet deep, millions of cubic feet -- I
was 42 years old, and I remember having
seen that site when it was open, when it
was still active. The material they went
in there was unbelievable to anybody.
And for you to guys to draw the
conclusion that the millions of cubic
feet of material are in close proximity
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(HEARING) 136
to the well shaft, and you draw the
conclusion that the contaminants came
from a little tiny septic tank a few
hundred feet away
MR. GARBARINI: We are talking
about contaminants in those wells to the
northeast. And I don't think you should
really belittle the site, because we felt
back in 1991 that we had a database that
indicated the very conclusions that we
are presenting here today. And we went
out and we made sure that we did a couple
of years of pretty intense investigation
from that before we came out here, and we
told that, Hey, we're arriving at the
same conclusion. And we have a lot of
people who have looked at the data who
are hydrogeologists who are trained in
this field, and we haven't heard anyone
tell us anything different.
MR. ED MATEA: I don't think
there is a person in this room that
doesn't have some reservations with
regard to the conclusions.
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(HEARING) 137
MR. GARBARINI: I am not talking
about having reservations. I mean, there
is always an element of doubt.
MR. ED MATEA: I am not try to
belittle it at all. What I am trying to
say is that it is inconceivable to me
that someone as knowledgable about the
area can sit here and look at that map
and come to the conclusion that the
contamination of the well was the result
of somebody dumping a bottle of paint
thinner down histoilet.
MR. GARBARINI: We are talking
about levels of contamination that we're
finding on site, we are talking about
groundwater flow, we are talking about
people cleaning things in their home with
paint thinner, we are talking about other
allegations that we've have about
different types of home repair shops that
have been in business up here.
MR. ED MATEA: What I am driving
at is why do you feel that this is unique
to this area?
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(HEARING) 138
MR. GARBARINI: Because of
several years and several million dollars
of study that have gone into this.
MR. ED MATEA: That all these
people in the northeast section are given
to throwing paint thinner in their
toilets?
MR. GARBARINI: No. If you would
have listened to what we had said and if
»
you read the reports, you can thoroughly
examine what our conclusions are.
MR. ED MATEA: And there were no
wells that you found were contaminated
where there was not contamination in the
septic system on that site as well? Are
are you saying that they all could have
been contaminated from certain systems
that are originated on other properties
but not from the landfill?
MR. GARBARINI: That's right.
That's what all the data has indicated.
Thats correct.
MR. ED MATEA: I am surprised you
can say that and look at the map.
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(HEARING) 139
MR. GARBARINI: I rely on
hydrogeologists that are experts, and
this is what they are telling me, and I
feel confident.
MR. ED MATEA: And your experts
are telling you that water doesn't travel
up hill.
MR. GARBARINI: I am not talking
just about -- I am not talking about
people -- I am not here to debate with '
you. I have to rely on hydrogeologists
to tell me what the story is, people
trained in that field.
MR. ED MATEA: I don't blame you
for putting some stock in the reports
that you have been handing out. What I
am saying is that you seem to disregard a
great source of other input here when it
comes to balancing your assessment.
MR. GARBARINI: I appreciate
that. I think I just want to add one
thing there. As I said, the
investigation that we conducted back in
1991 and completed in 1991 basically lead
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(HEARING) 140
us to the same conclusions that were
drawn. But we did not feel comfortable
drawing the conclusions back then.
As I said before, we decided to
go forward with another investigation and
focus in on not just the the
contamination that's found in and around
the site, but also the movement of
groundwater just so we could feel
comfortable at arriving at what we're ,
proposing tonight.
It was not something that was
just done overnight at all.
MR. JERRY SUMMER: My name is
Jerry Summer, I live in Warwick. And I
have a. few questions that you may or may
not be able to answer, but they seem to
be festering over the 20-odd years.
You telling these people here
that the contaminants that are flowing in
their septic systems seemed to be
destroying their drinking water somewhat.
Twenty years of looking back and
seeing 18-wheeler trucks coming up
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(HEARING) 141
dripping with sludge and contaminants
from Ford Motor and whatever other places
that they were picked up from and dumping
them in the site there/ and 24 hours a
day of this kind of thing happening/ day
after day after day. And the EPA at that
particular time said they didn't want
anything to do with it. This is not you
fellows, because you're much to young for
that/ you don't go back that far. But,'
nevertheless, this was happening and the
people in the town were responsible.
They looked to you, but you people didn't
seem to feel that this was something that
you could address. So the years passed
and somebody said we are going to close
it and seal it. Of course/ in your own
records I'm sure you'll see that the
liners are leaking just like the one in
Wallkill is going to be leaking. We
don't want to secure that one, because,
after all/ we took the politicians out of
here, sent them to the county to do the
same thing with Wallkill/ and we are
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(HEARING) . 142
going to wind up with the same problem.
We are going to blame the benzene
on the people that paint their cars with
or a cup of paint thinner or something
like that, but the tons and tons of stuff
that's in the landfill has absolutely
nothing to do with it.
And I will tell you a secret
about the Easter Bunny and the guy in the
red suit, because if you believe in that,
then you believe in this. And I think
it's I pretty unfair that you should
address these people here in a way that
you are doing without giving them the
opportunity to give them at least to get
a you're spending 16 million dollars
on gobbledygook and you wouldn't give
these people an opportunity to test their
water free.
After that, another 2 million
dollars -- I know it's not within your
realm because, after all, if we put our
blinders on, we don't have to see the
other agencies and this is what makes a
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(HEARING) 143
bureaucracy a bureaucracy.
Sixteen million dollars is fine;
2 million dollars on water, that's not
good. And these people here are going to
suffer with it, whether it is their land
value, or whether it is their home
resale, or whether they are going to
build another house, or their children
have to drink contaminated water because
perhaps they can't afford the thousand
dollars that are necessary to test it.
Thank you.
MR. KATZ: Any other questions or
comments? Okay, I think if there are no
other questions or comments, I think we
could just sort of close.
MR. GEORGE WEBER: I am
requesting that formally that we get a
30-day extension on the comment period?
And I would like also to get a copy of
the minutes of this meeting for the Dutch
Hollow Homeowner's Association, and a
copy of the list of people that came
here .
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(HEARING) 144
MR. KATZ: Yes. v
MR. GARBARINI: As I mentioned
earlier to Bob, I was hoping that maybe
we could have some discussions about the --
extension of the comment period. If you.
wouldn't mind
MR. GEORGE WEBER: I am going by
what our TAG advisors said. I'm pretty
sure that they are going to need 30 days,
plus the fact, we would like to give^ the"-
opportunity for everybody in the
community to have a say.
As I said, this took place at the
worst possible time in the summer. It is
peek vacation time. Give people a chance/
to get back from vacation, so that
everybody can have a say.
Thanks. . ,
MR. GARBARINI: You can talk with
your TAG advisor and see if there is
something we can work out. We will give
an extension, but we would like to see if
we have the time.
MR. GEORGE WEBER: Like I said,
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(HEARING) 145
it is for the people in the community who
are away on vacation.
MR. GARBARINI: Any other
comments or questions?
AUDIENCE PARTICIPANT: Is there a
document or summary of the wells that
were tested, when they were tested,, the
dates thereof?
MR. DUDA: All of that
information on the recent testing was in
the Remedial Investigation Report, which
is in the repository. It's Appendix D of
the second volume, and it does indicate
when the wells were sampled. It doesn't
indicate who the homeowner is, and that
was done for obvious reasons.
AUDIENCE PARTICIPANT: Did you
happen to find out through your documents
there the previous EPA findings? Is that
a follow-up that you are willing to
provide to us?
MR. GARBARINI: I don't know that
I understood the question.
AUDIENCE PARTICIPANT: As I
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(HEARING) 146
mentioned earlier, I had been attending
the meeting/ and EPA said they tested
wells and found chemicals. I would like
to know if you are going follow that up
to say what were the contaminants?
MR. DUDA: I'm sure thats in the
repository. That was in the 42 well
sampling that was done back in '92, and
that's the filtration systems that were
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put on the homes that were as a result of
that sampling. That information is in
the repository.
AUDIENCE PARTICIPANT: Does that
say that the findings were from any wells
in the area or the EPA-drilled wells?
MR. DUDA: Those would be
residential wells. The EPA-drilled
wells, that information is also in the
respository in the Operable Unit One
Final Investigation Report, which is in
the page report back in 1991. The data
from the monitoring wells taken then is
in that report. That's.all documented.
MR. ROGER LIDDLE: My name Roger
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(BEARING)
Liddle, I live 717-A Nelson Road. I
would like to know just how far would I
have to live from this toxic waste zone
not to be considered in a toxic waste
147
zone?
MR. GARBARINI: We don't
necessarily prescribe toxic waste zones,
but as we have been saying, we don't see
any evidence of contamination leaving the
landfill heading in the northeast
direction.
MR. ROGER LIDDLE: So, what you
are saying, then, is the wells that you
drilled within a quarter mile radius are
in this toxic waste zone; outside of
that, we are not in a toxic waste zone?
MR. GARBARINI: The landfill site
itself is part of the Superfund Hazardous
Waste Site, and the way we define "site"
is based upon any contamination that has
emanated from the site. So if
groundwater is flowing in a south west
direction, and there is a flume of
contamination there, that would be
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(HEARING) 148
~ considered part of site. But we don't
define a toxic waste zone.
As far as we can tell, none of
the residences up in that area have been
impacted by the landfill.
MR. ROGER LIDDLE: The problem is
that it leaves me in a Catch-22
situation, because the Town of Warwick
wants their" taxes from people, whether I
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live in a toxic waste zone or not.
Number two, there is a stigma to
the property and it lowers the property
values .
And number three, there are no
guidelines as to how far this really
extends .
I spoke to realtors, and they are
not going to take chances, so they allow
beyond what this contamination area might
be in order to protect themselves.
I was told personally that we're
not going to take a chance. So now they
are going out two or three miles or four
miles, it depends upon the realtor
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(HEARING) 149
because, he doesn't want to be sued if he
sells a piece of property to something.
So he is four miles away from the site,
and he is going to tell perspective
buyers that, Well, you're in toxic waste
zone and that adds a stigma to the
property and lowers the value. So now
nobody is making a commitment here and
the homeowners are stuck with this. They
are also stuck with the concerns about '
contamination recently in their wells.
I hate to repeat what other
people have said, but it certainly seems
that it would solve everybody's
problems -- whether you lived a quarter
of a mile away or five miles away is
to put in water from the Town of
Greenwood Lake. If they are willing to
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do it, spend the 2 million dollars on
that. It would solve everybody's
problems and bring everybody's property
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values up to where they belong, and
everybody would walk away happy.
I know I'm repeating what other
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(HEARING) 150
people said, but that Is the solution.
That is very simple. You don't have to
be a rocket scientist or anything like
that. It's a simple solution.
MR. GARBARINI: I hear what
you're saying. If you were able to do it
by law, I woujld be happy to do it, but
we're aren't.
I think -- your concerning about
the property values. If you have real
estate agents that are saying this to
you, tell them to give us a call, and
we'll tell them that -- I think there's a
good story to be told from our
investigation. Aside from not getting an
alternate water supply, we're saying that
the landfill is not impacting the homes
to the northeast. You can tell the real
estate agents that. They can.call us,
and we'll tell them the same thing.
We'll tell them what our study involves
here and that's what our study reveals.
I think the sooner that the site
is capped and it is deleted from the
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(HEARING) 151
National Priorities List site, the last
stigma you will have associated with the
site in terms of property values and
things like that.
MR. ROGER LIDDLE: How far would
I have to be from site -- a mile, a half
a mile --for you to say this?
MR. GARBARINI: We'll say it for
any of the those homes that are to the
northeast of the.landfill. If you live .
up in that are, regardless of whether you
are a quarter of a mile, three-eights of
a mile, have the real estate agent call
us. We'll vouch for that.
MR. ROGER LIDDLE: Is your phone
number included on this piece of paper?
Because that's the problem. Everybody
want their piece of the pie and we are
struck with the stigma and our home
values are done. And the realtors aren't
going to take a chance and say that
you're not in a toxic waste zone, because
they're going to get sued.
MR. DUDA: Actually, I have
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(HEARING) 152
received numerous phone calls from real
estate agents inquiring about property
and inquiring about the landfill, and
basically I've indicated that what Doug
had said is that we don't see that the
landfill is impacting the residential
wells in your area, and they're asking us
for that information.
And we don't make political --
this area isn't a political area, it is'a
hazardous waste site, and it's not really
a political zone of that sort. The real
estate agents may take that and amplify
it to create a zone of some sort, but
when we speak with them and I speak with
them, I don't really talk in those terms,
"hazardous waste site" as to the extent
of contamination. And that's basically
what we will tell them, if they have
further questions.
MR. ROGER LIDDLE: Now, the
realtor told me was they were not going
to commit from any how far away is far
enough. They are going to draw their own
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(HEARING) 153
conclusion, and they are making that rate
probably what it should be.
MR. GARBARINI: I think when we
finally arrive at a record decision,
assuming that it's the same thing that we
are proposing tonight, you will be able
to tell the real estate developers, the
EPA spend how many years studying this,
they went back and studied the
groundwater again they; are saying thatf
there are no impacts to residential wells
in the northeast. And they're going to
cap the landfill, it should be capped by
the end of 1996, and then they are going
to go through the process of weening the
site from the National Priorities List.
So there is sort of a positive story that
you can start telling them at this point,
assuming the conditions stay the same.
MR. ROGER LIDDLE: You have a
very nice map up here. Couldn't we get
some sort of a map to give the
professional people. We can have all get
a map of the zone marked where the toxic
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(HEARING) 154
waste area is and then put zones out from
that as to maybe Zone A, Zone B a little
bit closer to the toxic waste area, and D
maybe could possibly become contaminated,
and work it so that we have a safe zone.
Say zone C is now a safe zone, and we
know that homes in that area are not
affected by this and give this to the
realtor, because they have no guidelines.
They come to me telling that you
made the commitment. You wouldn't tell
you them anything, so it is left up to
their own judgment, and their judgment is
let's make a big an area as possible so
we don't get sued, and that's where we
are at.
MR. GARBARINI: I think, now that
our study is complete and we are going
through the proposed plan process -- now
obviously, if the situation stays the
same, we will be able to affirmatively
tell them that we don't see any impacts
from the landfill on the surrounding
community.
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(HEARING) 155
We will be moving forward with
this proposed plan as it is, and the TAG
advisor doesn't uncover some horrible
mistake that we have made.
MR. ROGER LIDDLE: You keep
saying that it's outside your
jurisdiction of whatever to have water
brought in to Greenwood Lake spending 2
million dollars. Where could we get it
up in that area?
MR. GARBARINI: I think it would
have to be Greenwood Lake, the village,
or the Town of Warwick that comes for it.
That would be f unneled ..through the
village?
MR. GIL SHAPIRO: Through the
State of New York. (Inaudible)
MR. GARBARINI: From the federal
government to the State of New York.
MR. GIL SHAPIRO: The Orange
County Health Department sent me a
survey.
MR. GARBARINI: The Orange County
Health Department sent you a survey.
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(HEARING) 156
MR. DUDA: Orange County Health
Department has been involved in with this
site over the years. They were one of
the first organizations to indicate that
there was some problem out there.
MR. ROGER LIDDLE: The only
problem is in the groundwater.
MR. GIL SHAPIRO: (Inaudible)
MR. GARBARINI: It is not that
there are no airborne contaminants, but'
the levels that are found are acceptable.
MR. ROGER LIDDLE: (Inaudible)
MR. DUDA: Once the landfill cap
is in place, those are probably if
there are potential airborne
contaminants, those will be addressed in
the section of the landfill with respect
to landfill gas vents and that type of
thing.
MR. GARBARINI: If I could ask
you one favor. She missed what you said
before.
MR. GIL SHAPIRO: My name is Gil
Shapiro, and I am from Greenwood Lake. I
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(HEARING) 157
know there are going to be monitors put
in place supposedly between the
aquifer -- between the landfill and
Greenwood Lake itself. Will there be
monitoring one and a half miles
supposedly between the landfill and
Greenwood Lake itself.
MR. GARBARINI: We had not
envisioned a need for putting in
additional wells in that area.
MR. GIL SHAPIRO: I am asking
about monitoring wells in that area. I
think it's important. One mile away and
one and a half miles, that it will filter
out any impurities supposedly before it's
too late.
I remember in 1991 we discussed
what came into the lake at that point,
and we looked at the report on it. At
the time, I was the Mayor of Greenwood
Lake, so I had no way of receiving it.
I feel that monitoring should be
done for the sake of the people of the
Village of Greenwood Lake and for the
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(HEARING) 158
._ aquifer that would environmentally supply
you water to the rest of the town.
And the only discussion I said
before that would be missing was the six/
seven months ago we engaged in a survey
and we requested the Department of Health
for a revolvong fund monies that has been
coining in from government and raising one
billion dollars a year for any easement
that there might go to the state, and the
state would give it to the communities
that would need it. And there was
roughly 3,000 communities across the
country that would be included in that,
and I know Greenwood Lake is one of them.
Thank you
MR. GARBARINI: Thank you. I
understand that there was some sort of
study done for Orange County in terms of
water supply?
MR. GIL SHAPIRO: That's for
another night.
MR. DUDA: Just as another little
response. This area here (indicating),
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(HEARING) 159
which is in the southwest section of the
landfill (indicating), there are three
deep wells which basically would
intercept part of the landfill to the
Greenwood Lake acquifer, and all three of
those wells showed little or no
contamination. Just for your
information.
There are wells that are south of
the landfill, a direct path through the
Greenwood Lake area.
MS. KAREN BLOCK: My name is
Karen Block, I live in Old Dutch Hollow
Street. This is, I think, indicative of
the sort of problem that this landfill
has created in this area; that is, there
was a piece of property it was one of
these it came it was local newspaper,
and it seems that somebody wanted to
donate a sizable piece of land to be used
for recreational purposes in this
community. And it seems like a dying
issue. Rumor has it, the reason it is
dying and propably will remain a dead
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(HEARING) . 160
issue is that nobody wants to take the
responsibility of the potential liability
of having play space that might be
contaminated or, you know, the children
either eat dirt and they die, or they
will drill a well and children will be
poisoned.
You can tell people that it's
okay, you can live here, you can build
here, you can continue to drink the water
here. But what happens in a small
community that has practically no land
that's usable, usable space? If the
local community, Warwick, is not willing
to take the responsibility for this
tainted piece of property, because
they're refusing to accept your judgments
as so definitive that they don't fear a
future liability. We're stuck with it.
Once again, we have no place to go and
nothing to do.
And you can -- your tests and
your studies are not protective enough
for this community. You are not
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(HEARING) 161
definitive enough. You are not saying,
Okay, everything we do now is absolutely,
perfectly safe, nobody in the future can
ever claim that it's the fault of this
landfill, it's the fault of the water,
the dirt. Unless you're willing to take
the responsibility, we're stuck with it
and, you know, we just going around in
circles, and we're getting nowhere fast.
And you can go home to your safe homes,,
or perhaps you will find a landfill that
has hidden in your backyard.
MR. GARBARINI: Just to respond
to that, as you were talking about
recreational space and things like that,
I was just thinking about the town that I
live in, which is down in Westchester
County, Croton-on-the-Hudson. We have a
couple of state hazardous waste sites in
our community, and one of them, the
Croton Point Landfill, was recently
capped, and it has been seated there are
and bike paths and walking paths and
everything else on top of it. And the
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(HEARING) 162
way it was planned is that it is going to
be bringing a lot of different species of
birds and things like that. But having
walked that site a couple of times now,
I was very impressed that people were
willing to put something like that into
recreational use.
MS. CATHY MARCHESE: Would you
tell Warwick -- would you accept this
piece of property and turn it into
recreational use?
MR. DUDA: It is here where there
is a wood chipping facility now
(indicating).
MS. CATHY MARCHESE: Yes.
MR. DUDA: Would Warwick be
willing --
MS. CATHY MARCHESE: Would you
tell Warwick, Yeah, it is a good idea,
you can take it, don't worry? If anybody
sues you 15 years from now, tell them to
send them to us. We will tell them it's
okay.
MR. GARBARINI: There has been no
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(HEARING) 163
use of the property, that we know of,
that would be any reason for concern.
MS. CATHY MARCHESE: Would you
put it that on the record?
MR. GARBARINI: I would want to
know a little bit more about what's
going on there right now, because o.f the
wood chipping I would be willing to
talk to the town and ask them to talk to
to the folks maybe they were involved in
the Croton Point Landfill Restoration,
just say, hey, there's has been a very
positive response to what's been done
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down there, and that's part of the county
park system. So I would be willing to
talk to them.
MR. DUDA: Also, we don't have
any information that the landfill ever
went across Penaluna Road. So, that
property -- we really don't know much
about that property, and currently there
is a somewhat industrial facility on that
property now. So I'm not quite sure what
the situation is with respect to possible
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(HEARING) 164
contamination from that facility that's
there now.
MS. CATHY MARCHESE: Oh, so, now
it is contaminated -- it is there from --
MR. DUDA: I'm just saying, we
don't know anything about that property,
and we can't make any judgment on that
property.
MR. GARBARINI: Based upon its
proximity to the landfill, obviously, you
would want to be cautious. But would
that be a reason not to use the property
at all? I don't see any reason for that.
MS. CATHY MARCHESE:
Unfortunately, that's what Greenwood Lake
has been in the mist of. As the young
gentleman pointed, a few years I bought a
house, and I was told by the real estate
agent, Oh, by the way, I can't sell you
this property until I tell you that you
happen to be in a mile and a half of a
toxic waste dump. And it is like, oh, am
I?
And then I had my lawyer check
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(HEARING) 165
with somebody in the EPA four years ago
who told my lawyer, oh, don't worry
about, this is not a big thing. So four
years ago the EPA was already deciding
that this wasn't even though it was
still on the Superfund list. And before
whatever testing you did, EPA had already
made up its mind that the landfill wasn't
a big issue* So, it seems to me that it
being on the list and off the list have
more to do with politics than the studies
that come afterwards, several million
dollars later, it is whether or not
people should keep it on the list,
whether or not choose to keep it on list.
That's my perception.
MR. GARBARINI: No. We have
standards and procedures and guidance
that we need to follow in conducting site
investigations and determine what sort of
cleanups are necessary in deleting sites,
so it's not political.
There may be some force at some
point in time where people are really
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(HEARING) 166
concerned about a hazardous waste site in
their community and they drum up a lot of
political support to get it on the list
so that it can be cleaned up. I'm not
saying that doesn't happen or hasn't
happened in the past. But once the site
is on the list, we have procedures that
we have follow before we can do it
MR. DUDA: And, also, one other
thing. There is landfill cap that's
going to be on that property. So
obviously it's going to be in a much
better place once the landfill cap is on.
MR. GARBARINI: Yeah, I would not
recommend that anybody do anything
necessarily for recreational purposes on
the property that you have been talking
about until the cap is done.
MS. CATHY MARCHESE: You did
feel, unless the property has been
despoiled through activities on that
piece of property, you don't feel that
across the street would impact on that
piece of property, and you could tell
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(HEARING) 167
that Warwick and whoever the lawyers are
in charge of that?
MR. GARBARINI: Yes,
MR. CATHY MARCHESE: Okay. Thank
you .
MR. GARBARINI: Thank you.
MR. TONY HOUSTON: My name is
Tony Houston as in Houston. I am a
resident of the Town of Warwick. I live
in the Hamlet of Bell Vail (phonetic) . .1
am the supervisor of the Town of Warwick.
And just for the record, there is
no Town of Greenwood Lake.
A while ago there was a map on
the screen and someone I think it may
have been Damian was pointing to an
area. Could we recreate that now, the
map? And then pointing to the area.
MR. DUDA: (Complies).
MR. TONY HOUSTON: Don't lose
that picture. Now, there is a map with a
tan area that is the Warwick Landfill,
and the arrow is the direction of what,
exactly?
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(BEARING) 168
MR. DUDA: Groundwater flow.
MR. TONY HOUSTON: Now, pointing
to this wood chipping lot, this potential
recreation site?
MR. DUDA: (Complies)
MR. TONY HOUSTON: Where he
pointed very briefly, for the second
time -- he didn't want to stick around
too long -- was right of the point of the
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arrow, which is the water flow from the
tan landfill.
Thank you.
MS. CATHY MARCHESE: Where people
were drinking their water in their homes,
you can't have a recreation site. You
can't have it both ways. You cannot tell
a community it is okay to drink the water
from the well, but it is not okay to put
a recreation site there. It is one or
the other. Okay. Either it is okay to
put the recreation site and drink the
water --
MR. KADLEC: In a recreation
site, the exposure that you are going to
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(HEARING) 169
have is to the soil and to the grass; but
in a groundwater situation your drinking
something being drown up from that depth.
MS. CATHY MARCHESE: You are
saying the groundwater is fine?
MR. KADLEC: I'm saying that the
wells that were sampled, the groundwater
is fine.
MS. CATHY MARCHESE: So you're
saying that the groundwater is fine and'
that the topsoil is okay/ because there
is nothing airborne; correct? So,
therefore, you're saying that it is all
safe. That's your basis, that's the
basis of your -- that's what your telling
Greenwood Lake.
The bottom line is don't worry
about it, it's all okay. Therefore you
shouldn't be telling us it is a bad
choice for a recreation site because it's
polluted, and in the same breath, Warwick
shouldn't be supporting the claim that it
is not necessary to take water from
Greenwood Lake wells to supply homes.
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(HEARING) 170
~ There should be an alternate water
source. You can't argue both cases.
It's one or the other. It is either it
is okay to have wells in the area, or you
need an alternate water source.
MR. GARBARINI: I think what we
could say is that from what we could tell
there aren't unacceptable risks that
would be posed by such use of the
property, but we have no idea as to what
has been going on in there the last
couple of years with the wood chipping
and everything else.
MS. CATHY MARCHESE: It has
nothing to do with activities on that
site?
MR. GARBARINI: There are a lot
of other considerations that go into
decisions to whether a town would like to
use that property for whatever use. And
that's not something that we are speaking
about, we are just telling you what the
risks that are posed from the Superfund
s it e .
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(HEARING)
I don't want to comment on
171
whether or not that would be appropriate,
but from what we could tell is that there
wouldn't be a problem with that.
MS. BETTY QUICK: My name is
Betty Quick, I live in Warwick; not in
the Dutch Hollow section.
I can't match the people that
have spoken before in knowledge or
elloquence, but I can ask a question
which, based on research you've done,
might be useful to all of usin W ar wi c k.
Now, I understand that there was
contamination in the septic systems to
the northeast, correct? And that you
believe that the contamination in the
wells in that area came not from the
landfill but from septic systems; is that
correct?
MR. GARBARINI: That's correct.
MS. BETTY QUICK: Okay. Now, I
worked in a civil engineers office for
about a year doing drafting, and I
remember we had rules. A hundred feet
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(HEARING) 172
between the septic system, including the
leach field and the wells, and it was
greater than that if the well -- where
the well was drilled, a little bit down
was a better place for the septic system.
And, of course, then there were buffers
between any bodies of water, streams, or
ponds, as I recall, at least a hundred
feet.
And my question which you
should be able to answer, based on your
research .-- is how far were these septic
system from the wells? Obviously, it
wasn't far enough for a safe
drinking-water supply. And now it seems
to me that this is knowledge that would
be useful. It would be useful to our
building inspector.
Maybe the standards should be
changed. If these were not built
according to standards, or if they were
built according to standards and there
was contamination from septic systems to
wells, then I would like to know and have
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(HEARING) 173
other people in the Town of Warwick and
Orange County to know what is a safe
distance? Bow can this be avoided?
I might mention, I'm not assuming
that this is true that that's were the
contamination came/ but whether it is or
not, this would be very useful
information.
MR. KADLEC: I can answer that.
The sanitary codes that were setup tells
you how far the wells should be from the
septic system. , It was setup to try to
prevent bacteria from going from the
septic tanks to the wells.
Mow, in this case, we have
organic solvents, which are very mobile
across the top of the groundwater table.
Now, the standards do not take into
consideration what organic solvents would
do if they left the septic tank and
traveled towards a well. Because
normally you wouldn't really expect to
find organic solvents inside the septic
tanks.
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(HEARING) 174
A lot of people used that to
clean the septic tanks out and maybe dump
solvents down the drain or something like
that. But it's not something that is
normally considered when you established
these codes.
MS. BETTY QUICK: It would seem
to me that your job, I think, is to
protect the environment, and it seems to
me a good task for you would be to say,
Look, these standards aren't good enough.
This is what you need. Maybe a hundred
years ago, if they had standards then,
all they had to worry about was E. coli.
MR. KADLEC: Right. It's kind of
hard to do, because in a community
situation, how far is acceptable? The
most common problem with contamination
from a septic system is with bacteria.
But solvents, organic solvents, isn't
really a common problem. So, you have to
sort of have a trade off.
MS. BETTY QUICK: Maybe what I am
hearing is that we need a public water
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(HEARING) 175
supply.
MR. KADLEC: Maybe, but the only
problem is, the contamination in the
wells, the four wells -- there were only
four wells that had levels higher than
New York State standards -- that's it --
at any time. And those levels have been
decrease over the last four or five
years. They've come way down. Now ,
MS. BETTY QUICK: Does that mean
that the people stopped dumping solvents
down their toilets?
MR. KADLEC: It may be.
MS. BETTY QUICK: Do you have any
way of knowing?
MR. KADLEC: By looking at the
decreasing levels in the drinking water,
I may make an asumption that, perhaps,
nobody using the solvents in the septic
tanks anymore, but I can't really prove
it.
MS. BETTY QUICK: It's nice that
it's decreasing, but I'm wondering why
people changed their habits. Did you
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(HEARING)
176
educate them?
MR. KADLEC: The EPA sent out a
fact sheet educating the people about not
disposing of solvents in this septic
tanks, and stuff like that, if I am
correct.
MR. GARBARINI: I think people
are generally more aware of the problems
associated with the uses of organic
solvents and things like that in general.
We have all the warnings on the labels
these days. It says "Appropriate
Disposal" and such and such, and do not
dump down septic systems and things like
that.
MS. BETTY QUICK: I would like to
know what those distances are, which I
assume you would have, based on your
research. And I also would like to say,
the more I think about it, it seems as
though publicly-supplied water would ;
eliminate a lot of problems and can be^an
inexpensive way to deal with.what may Be
a dump that's contaminating groundwater.
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(HEARING) 177
because of either present or future
problems for wells in the area.
MR. GARBARINI: Thank you very
much.
MR. GEORGE KLUWE: My name is
George Kluwe, I live in the Village of
Greenwood Lake. My concern is the
integrity of the wells in the village.
Naturally, they are talking about a
viable alternate to the water supply.
What guarantees do you have that our
water supply in the village is not going
to be contaminated? The contaminatiuon
by the landfill is going to put us in a
serious situation. Now, can you
guarantee me that we are not going to be
affected by it?
MR. GARBARINI: It's always tough
when you put people in the position of
making a guarantee. But based upon all
the evidence we have and what all the f
v-
hydrogeologists looked at and are telling
us, I can say that it's highly unlikely.
What we do have is we have the wells that
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(HEARING) 178
Damian pointed that should intercept any
contamination that's coining off site.
MR. GEORGE KLUWE: You're just
making the statement that you are not
going to
MR. KADLEC: But the water is
tested, the water supply is tested.
MR. GEORGE KLUWE: That's
wonderful. I am not sure we will be very
happy five years from now.
MR. GARBARINI: What I started to
mention before is that there someone --.
the planner from your office. I forget
his name now. Ron Water. He had
mentioned a study that had been done back
in it was done back in January that
looked at the aquifer. It was done for
the Orange County Water Supply.
MR. GEORGE KLUWE: Yeah.
MR. GARBARINI: What I am saying
is, perhaps, if he feels that he would
like to see us do some additional work,
maybe he can make some recommendations,
maybe in the initial monitoring wells or
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(HEARING) 179
something like that.
MR. GEORGE KLUWE: He is the
chairman of the planning board.
MR. GARBARINI: He seemed to be
familiar with the study, and I'm just
raising it because he had raised it to us
this afternoon.
MR. GEORGE KLUWE: Are you
guaranteeing us that we are not going to
have a water supply contamination?
MR. GARBARINI: I don't think
that's a fair question. I can tell you
that indications are enough that I would
be willing to wager on it. Can I
guarantee it? I am not willing to answer
that, I guess.
MR. GEORGE KLUWE: These people
have to live in this community, and they
want to go to sleep at night and wake up
in the morning with a clear mind.
MR. GARBARINI: If you have some
technical concerns that you would like us
to address, or if you feel you would like
us to put in a monitoring well in a
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(HEARING) j.83)
certain location, we could give that,
consideration. If you give us seme
of sound approach to try to alleviate
further concerns that you might have, we
would be willing to address that.
MR. GIL SHAPIRO: On the report
that came through from the Orange County
Water Authority (inaudible) organization
using county monies to continue their
so-called work. They did a groundwater
study of the county. It was done through
various engineering firms, and it was
done such as, Hello, Mayor, what well are
you using now and what capacity? Thank
you.
MR. GARBARINI: I guess,
regardless, we are proposing a monitoring
program here.
MR. GIL SHAPIRO: (Inaudible)
MR. GARBARINI: If you had some
suggestions, we definitely would be
willing to address them. I am not making
any guarantees, but if there is
something -- say, if there is another
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(HEARING) 181
monitoring well that we could put in
close the landfill that you fell would do
the trick, something like that, we would
give it some consideration.
MR. GIL SHAPIRO: I thank you for
your time.
MR. GEORGE WEBER: The solvents
that you're talking about that are
showing up in the septic systems,
wouldn't these solvent be highly
evaporative?
MR. GARBARINI: A lot of them are
volatile.
MR. GEORGE WEBER: What kind of
concentration are we talking about that
you are detecting in the septic system?
MR. GARBARINI: Very high.
MR. GEORGE WEBER: How much
volume of the materials would you say
would have to go into a septic system to
cause that kind of contamination?
MR. KADLEC: You would have to
know what kind of solvent that was put
into it and we don't know that.
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(HEARING) 182
MR. GEORGE WEBER: Well, what
kind of solvents are you detecting?
MR. KADLEC: TCA, DCE,
dichloroethane , tolune.
MR. GEORGE WEBER: What's the
level of one of those chemicals? What
level would you have to find? In your
estimation, would it be like gallons or
several gallons?
MR. GARBARINI: We would have* to
take a look at the data. We can take a
look at the data and answer that question
for you.
MR. DUDA: What exactly is your
question?
MR. GEORGE WEBER: You say that
you are finding these substances in the
septic system. Now/ if they are
volatile, they would tend to evaporate;
right?
MR. GARBARINI: They don't just
tend to evaporate, they tend to absorb
organic materials, they tend to dissolve
in water, and they tend volatilize .
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(HEARING) 183
MR. GEORGE WEBER: Is it like
somebody going over and pouring a cup of
it down the septic system, or more likely
are you talking about gallons or larger
amount s ?
MR. GARBARINI: We just can't
answer that. We need to know more
information, what the volume of the
system is.
MR. KADLEC: They measure in
parts per million, which means it's like
say one hundred parts one hundred
atoms of this compound for a million of
other atoms of other compounds.
Now, if you don't know the total
volume of the septic tank, then it is
hard to calculate how much of the
original solvent actually went in,
because you're just measuring a small
volume of this. And you can't really
calculate, unless you know the complete
volume of the septic tank. So unless
some sort of survey was done to figure
out exactly what the volumes of each
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(HEARING) . 184
these septic tanks were, it would be kind
of almost possible to tell how much of
the solvent was was originally dumped in.
MR. GARBARINI: We would have to
know when it was dumped it, what else is
there .
MR. GEORGE WEBER: I will take it
up with TAG advisor. Thank you.
MR. DUDA: Any further comments
or questions?
( No response )
MR. DUDA: At this time, I think
we will close the meeting, but just be
aware that any comments that you have can
be sent directly to myself, Damian Duda,
and the information is in the proposed
plan with my address. And the comment
period is until August 27th, if it is not
extended .
MR. GARBARINI: It's likely that
we will extend the comment period, we
just need to determine the length of that
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(HEARING) 185
extension at this point.
Please feel free to get your
comments in to Damian as soon as
possible. I would appreciate that.
We appreciate you all coming out
tonight. Thank you very much.
(The Hearing was concluded at
10:40 p.m.)
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186
CERTIFICATION
I, KATHERINE DiLORENZO, A
Shorthand Reporter and Notary Public in
and for the State of New York, do hereby
certify that I recorded stenographically
the proceedings herein at the time and
place noted in the heading hereof, and
that the foregoing is an accurate and
complete transcript of same to the best
of my knowledge and belief.
KATHERINE DiLORENZO Q
Dated: August 25, 1995
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APPENDIX E
LETTERS SUMITTED DURING THE PUBLIC COMMENT PERIOD
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Disposal
Safety
Incorporated
To: George Weber, Dutch Hollow Homeowners Association
From: Steven Amter, Disposal Safety Inc.
John Young, Hampshire Research Institute
Dale: September 16, 1995
Subject: Comments on USEPA's Proposed Plan for Operable Unit 2
Notice: This report has been prepared solely for the guidance of the Dutch Hollow
Homeowner's Association in interpreting information available to them. Other users should
satisfy themselves independeruty as to facts and conclusions contained herein. In particular,
such users should refer to original sources of information rather than to this report. This
report is not intended for use in any real estate or other transaction, and should not be used
or relied upon for such purposes.
Summary
The Baseline Risk Assessment for the Warwick Landfill seriously underestimates the
risks posed by the ingestion of ground water contaminated with manganese.
Contrary to EPA's statement in the proposed plan, the elevated manganese
concentrations detected in certain monitoring wells should not be attributed to
background conditions.
The aquifer that provides the sole source of ground water for residents around the
Warwick Landfill is vulnerable to contamination.
EPA OSWER Directive No. 9355.7-04 states that appropriate remedies for Superfund
sites should consider reasonably anticipated future residential development. The
proposed plan fails to do this.
EPA's proposed no-further-action remedy is not cost effective when compared to the
option of providing an alternative source of water.
The four activated carbon water treatment units installed on residential wells northeast
of the landfill should not be removed.
1660 L Street NW. Suite 5!0
Washington. DC 2C036
(202) 293-3993
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G. Weber, September 16, 1995 Page 2
Introduction
In July, 1995, EPA released Superfund Proposed Plan, Warwick Landfill Sire, which
proposes that no further action be taken for Operable Unit 2. The proposed plan is based on
the results of the Remedial Investigation (RI) and Baseline Risk Assessment (RA).
The proposal for no further action is based on two major conclusions in the remedial
investigation for OU-2 performed by the PRP's consultant, Geraghty & Miller. The first
finding is that the source of contamination in residential wells northeast of has not been
caused by the landfill. The second is that although the landfill does degrade local ground-
water quality, the RA prepared by Environ Corp, for the PRPs shows that ground water
poses only a low level of risk to neighbors of the landfill.
Based on our review, we conclude that the RA is deeply flawed and underestimates
risk to present and future users of ground water. Therefore, EPA's proposed
no-further-action remedy is not sufficiently protective of human health. Protective measures
are necessary, and providing an alternative source of drinking water remains the most cost
effective approach.
The Risk Assessment underestimates risk
As discussed in detail in the accompanying comments (attached) by Dr. John Young
of the Hampshire Research Institute, the RA contains serious technical errors and highly
questionable judgements. It cannot be considered conservative, or even realistic for the
Warwick Landfill Site.
The key flaw is the inappropriate use of procedures for estimating risks from
ingestion of high levels of manganese found in the ground water at the site. The study is
consistent with neither current nor upcoming EPA guidance, and it inappropriately assumes
that residents do not have other sources of manganese exposure. Most critically, it has been
firmly established from human epidemiological data that the levels of manganese found in
some of the monitoring wells are associated with increased neurological disorders in human
beings. Dr. Young contacted current and former EPA scientists responsible for assessing
manganese risks; they expressed concern over ground water contaminated with greater than 2
mg/f, as is the case at the Warwick Landfill. Dr. Young concludes that the hazard index
calculated in the RA is underestimated by a two to three times.
The Risk Assessment calculated a hazard index of 1.5 for ingestion of ground-water.
EPA regulations generally require that remedial actions be considered whenever the Hazard
Index exceeds a value of 1. The proposed plan dismisses this finding, stating that elevated
manganese is "representative of background conditions." This conclusion is poorly
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G. Weber, September 16, 1995 Page 3
supported. As shown in Figure 2-12 of the RI, the highest manganese concentrations were
found in leachate seeps at the landfill. Furthermore, the monitoring wells with the highest
dissolved manganese (wells MW-2S, MW-2D, and MW-4S) were all located in areas
downgradient of the landfill. There is no doubt that these wells are tapping ground water
that flows from the landfill.
Residential well water is vulnerable to contamination
Whatever the origin of the chemicals in the residential wells northeast of the landfill -
- septic tanks, the landfill, or some other source - the very fact that a number of wells
around the landfill have shown measurable quantities of a variety of organic and inorganic
contaminants proves that residential wells tapping the bedrock aquifer are exiremely
vulnerable to contamination. This means that current or potential threats to ground water
must not be taken lightly. Given that non-negligible risks are associated with contaminated
ground water from the landfill (see Dr. Young's attached comments), EPA's
no-further-action remedy is insufficiently protective of the only local source of potable water.
Future residential development needs to be considered
Although EPA has concluded that the contamination found in existing residential
drinking water wells is not derived from the landfill, the proposed no-further-action remedy
does not consider possible future residential development. An appropriate remedial plan
must also provide for the reasonable anticipated future development in other areas around the
landfill. For example, if residential wells were drilled between monitoring well clusters
MW-2 and MW-8 (east of Penaluna Road along the northwest portion of the landfill), they
would likely contain elevated manganese.
EPA OSWER Directive No. 9355.7-04 states that future land use should be
considered in Superfund remedy selection. The directive states (page 7):
In general, remedial action objectives should be developed in order to develop
alternatives that would achieve cleanup levels associated with the reasonably
anticipated future land use over as much of the site as is possible [underline in
original].
The OU-2 remedy should explicitly address reasonably anticipated future residential
development because portions of the site have ground water which poses an unacceptable
(Hazard Index greater than 1) risk under a residential use scenario, and there is currently no
other water supply. In failing to consider future development, EPA's proposed remedy is not
sufficiently protective of human health.
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G. Weber, September 16, 1995 Page 4
The OU-2 proposed no-further-action remedy Is r.ot cost effective,
EPA recognizes that engineered solutions to environmental problems often result in
some degree of uncertainty as to whether the solutions are effective over time. A standard
way to mitigate residual uncertainty is to perform on-going environmental monitoring after
the remedy is in place. Since it often lasts for years, even decades, a ground-water
monitoring program can be quite costly.
The Record of Decision for Operable Unit 1 provides for ground-water quality
monitoring as part of the remedy. The proposed plan for Operable Unit 2 states (page 9)
that the "operation and maintenance plan [for the landfill cap] will include ground-water...
monitoring to ensure further that the existing population are protected from any future
contamination and that the OU-1 remedy remains protective of human health and the
environment"
According to Table B-8 of the OU-1 Final Feasibility Report. Warwick Landfill Site
(Ebasco Services Incorporated, February, 1991), the 30-year cost of ground-water
monitoring, excluding residential wells, is approximately $2.5 million dollars. The present
value cost is approximately 50% less. Monitoring costs would be substantially higher if
some residential wells were also included; we would argue that under a no-further-action
remedy, residential monitoring would be absolutely required, particularly for new residential
wells in vulnerable areas.
Providing an alternative source of drinking water by connecting with the Greenwood
Lake water system would be more cost effective than EPA's proposal. We estimate that this
option would cost approximately $1-2 million dollars, but would virtually eliminate the
need for costly ground-water monitoring. Furthermore, an alternative water system is more
effective than on-going monitoring:
It would completely eliminate all uncertainty concerning the safety of the present and
future water supply.
It is an immediate and permanent solution that does not require continued regulatory
oversight.
The measure maximizes community peace-of-mind and acceptance of the remedy.
Additional comment
It has come to our attention that NYSDEC intends to remove the granulated activated
carbon units that have been treating ground water at four residential wells northeast of the
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G. Weber, September 16, 1995 Page 5
landfill because it believes that the contamination originates from ?. source or sources other
than the landfill. This is a misguided decision. If there remains even a trace of uncertainty
concerning the origin of some or all of the contaminants - and we believe such uncertainty
exists - then EPA, NYS, or the PRPs should continue to fund the units.
If all parties refuse to support the necessary water treatment, then other arrangements
should be made to minimize the financial burden to the residents. This can be done at no
cost to NYSDEC. NYSDEC State should offer to sell the units to the residents at an
appropriate depreciated price, minus the cost State's estimated cost of removal (which it
would have to pay if it removed the units). This would prevent a disruption of service, and
drastically reduce the cost to the residents from what it would be if they had to pay a private
company to install a new treatment systems.
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HAMPSHIRK RESKARCH INSTITUTE
1600 CAMIK'ON SIRfctl
SUITE 100
ALEXANDRIA, VIRGINIA 22314
From: John S. Young, Ph.D., Scientific Director ~X~y
To: Steven Amtcr, Disposal Snfcly Incorporated
Pale: September 15,1995
Re: Comments on Baseline Risk Assessment for Operable Unit Two, Warwick
l, 'Warwick, New York, prepared by ENVIRON Corporation, and dated July 1995.
Notice
The following comments are provided to Disposal Safety, Inc., for the use of the Dutch
Hollow Homeowners' Association in interpreting information available to it. Other users
should satisfy themselves independently as to the facts and conclusions contained herein.
Such users should refer to original sources of information, rather than to this document.
This document is not intended for use in any real estate or other transaction, and should
not be used or relied upon for such purposes.
General Comment
This document contains numerous scientific and technical errors, some of which are
documented below. The correction of some of these errors would not substantially alter
the conclusions of the document. Other errors, however, lead the document to
substantially underestimate the risks associated with this site. In particular, the use or
groundwatcr from ibis site as a source of drinking water could pose a substantial risk to
human health.
Specific Flaws in the Analysis:
Characterization and Scope of Hie Risk Assessment Problem
The assessment claims to address "hypothetical" residents (pp. ES-1,11-9,11-12, VJ11-1),
but ignores the fact that there are actual residents in veiy close proximity the site
perimeter, who may be exposed to any air releases and who arc simultaneously
consuming groundwatcr from contaminated aquifers. There is no justification for the
authors' asserting conservatism on this basis. A prudent approach, given the facts of this
site, would be to consider combined exposures to contaminated air and water. Neither is
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)JR1 Review of ENVIRON Risk Assessment Warwick. NY
Hbasco data). FPA guidance slates explicitly a series of criteria that must all be met to
exclude a chcmieal from analysis based on detection frequency:
Consider lite chemical us u candidate for elimination from llie quantitative risk
assessment if: (J) it is delected infrequently in one or perhaps l\vo environmental media,
(2) it is not detected in any oilier sampled media or at high concentration.1!, and (3) there
is no reason to believe the chemical may be present (RAGS 5.9.3)
This language clearly does not support the elimination of chemicals based on a low
frequency of detection within a particular medium, and especially not within a/;ar/ of a
medium.
The elimination of chemicals where downgradicnt concentrations are Jess than upgradicnt
concentrations (1V-2 - 1V-3) is only appropriate to the extent that a clear gradient can be
delineated with confidence in this admittedly complex groundwater regime.
In terms of the number of chemicals affected, KN VJKON's trimming of the list of
indicator chemicals is extreme. For example, in bedrock groundwatcr, 25 of 26 organic
chemicals have been eliminated, as well as 11 of 23 inorganic chemicals. In the
overburden aquifer, 5 of 6 organic*, and 20 of 23 inorganics, have been dropped from the
analysis.
The elimination by ENVIRON of chemicals that were detected at levels below regulatory
standards confuses two parts of Supcrfund process, compliance with substantive ARARs
and risk assessment. Jn some cases, chemical present at regulatorily accepted level may
be associated with non-trivial risks.
For example (Table IV-2): In the bedrock aquifer, of 50 chemicals, 36 were eliminated
from consideration. Only eight of those were eliminated because the downgradienl
concentrations were less than upgradient concentrations. Many of the eliminations arc
based upon selective reliance on the data of Geraghty and Miller, rather than considering
the entire history of sampling at the site. It is clearly inappropriate to use the data of
Geraghty and Miller, in preference to earlier work, for selecting chemicals, simply
because they arc more recent. A cogent discussion indicating clear superiority of the of
Gcraghty and Miller data needs to be presented, if indeed it is possible to develop such an
argument. As the authors note (VI-2), the data are variable.
This deficiency in addressing sitcrrclatcd chemicals was apparently also noted in EPA's
comments, and is addressed in the letter from Kleiman and Washburn to EPA dated July
25,1995 (comment #4).
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J:.\VlKUi\ Uisk ANM:SSIIU-'.III Warwirk. NY
hsiijiiaiion of Toxic Ha/a.id Jjata
The document makes the unwarranted statement thai the NOAliL is a conservative
estimate of H thresh- Jrt dust- .'»;. the popui.uion under study (V-3). Thio ib com^lcicly
unjustified. The judgment of the conservatism of the NOAlil. requires ;\ detailed
consideration of the entire design of the study, including tlic spacing of doses, the
statistical power of the experimental design, and the sensitivity of ihe measure of toxiciiy
employed.
The use of a dietary, rat her than water-based Reference Dose (RfD) lor manganese is not
justified, and has the (admitted) effect of significantly decreasing, risk estimates (ES-3; V-
4, VIT1-9 VI11-1 )). As noted (ITS 3 - liSM), exposure levels from groiindwaiernloni-
(discouniiiig the many other sources of manganese in the diet) may exceed recommended
intakes for adults. Kxposurc (dose) levels in children arc significantly higher than those
for adults (nearly double). Indeed, oral manganese doses from groundwaicr thai were
lower than those predicted in Tables A-3, andA-4, and less than one half of those
reported in Table A-7, and Table A-Sfor children, were found to be associated with a
significant increase in neurological impairments in humans, as is quite clearly noted in
IRIS. Indeed, the concentration of manganese in groundwater noted in this risk
assessment (Table VI- 1) is higher than thai found lobe associated wilh neurological
impairments in humans.
KNVJRON's discussion in Section Vlll is at best a misleading presentation of the
information in 1RJS. It ignores the fact that the study by Kondakis et al found not only a
NOABL but also a LOAliL. and thai exposures at Warwick exceed the IjOAEL for human
beings found in that study. The suilcincnt on age-related effects gives the impression that
the populations were not adequately matched, which is not correct; non-specific age-
related effects would not be expected id differ between the populations in the study, and
the effects of manganese are still significant when age and sex are controlled for.
ENVIRON also selectively reports the decreased sensitivity of children, while ignoring
the increased sensitivity of infants. Similarly, discussion of acceptable total manganese
intakes ignores the fact that this population, like most Americans, would be expected to
receive substantial doses of manganese, from their diet.
It is true thai EPA has determined that the extent of the difference between the water and
dietary RfDs for manganese may not be as large as the 28-fold ratio reported in IRIS. The
Agency has determined that there are problems with setting a .separate, water RfD on the
basis of the study by Kondakis et al., because concomitant dietary exposure levels were
not precisely known. However, there is no evidence that dietary exposures differed
between the groups studied by Kondakis, nor that their dietary exposures were in excess
of those that would be expected in the population at Warwick.
UPA's current proposal (which should be entered in IRIS in October, 1995) is that for
water-based exposures, one would modify the dietary RfD for manganese by a factor of
three. In the present study, if appropriate standard exposure factors are used (rather than
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HR1 Review of ENV1KON Risk Assessment Warwick. NV
the idiosyncratic^/alues applied by ENVIRON), this would yield a Hazard Quotient for a
child for Manganese alone of more than three. For a child who remains on site 10 bo
exposed after the age of six, ihe total hazard quotient is approximately five.
ll is also important to note that both the (former) IIP A employee contacted by ENVIRON,
and the current 12PA Manager lor the manganese RfD indicated that they would be
concerned about exposure to a walcr supply containing two milligrams of manganese per
liter, as is the case at Warwick.2
It bears stressing that this is not a mailer of extrapolation from animal studies, or of the
application of unreasonable safely factors. People who have consumed groundwater with
levels of manganese comparable 10 those seen at this site have an elevated incidence of
neurological impairment. This can not be considered a reasonable risk by any
toxicological standard.
For inhalation exposures, RfDs are used to evaluate inhalation exposures, instead of the
more current Reference Concentration (RfC) values. In some cases, RfD values were
derived from RfCs. This non-standard practice is nowhere explained or justified
Selection of Exposure Pathways for Analysis
The discussion of exposure pathways ignores significant exposure pathways that arc
commonly evaluated for domestic use of groundwaler. For example, it ignores
contamination of household air by volatiJes (liS-1, JI-2, III-l, VM), a common path of
exposure to contaminants in household water. (The work of Andclman and others has
shown that exposures and risks from general contamination of household air may be as
much as 10-fold higher than the shower inhalation risk or the iugcstion risk for volatilcs.)
In this, the asscssmcni repeats an error of the OU-1 assessment, noted at that time.
This major oversight is particularly notable as benzene ingcslion was a key source of
carcinogenic risk; standard methods would indicate that risks at this site have therefore
been underestimated, perhaps by an order of magnitude.
The atmospheric dispersion model ISC-LT2 was apparently used to model air emissions
(G&.M). While this modeling is not the responsibility of the authors of the present
document, they should be aware that the user manual for 1SC2 contains explicit cautions
on use of the model within 100 meters of a point source, and notes that for area sources,
the algorithm does not adequately represent source-receptor geometry if the separation
between a source and a receptor is less than the length of the side of Ihe area source.
Thus, the air modeling is not appropriate to support any conclusion that exposures to air
emissions will be acceptable.
1 Telephone conversations between J.S. Young (J)Rl). S. Vclarxjuor. (formerly liPA) and R.
Benson (EPA), 9/12/95.
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iiiv! Ui-vio»' ol ) ;w.'K<;N Ui>); As.si-ssiiu:m Warwick.
Quantification of Exposure and kisk
As noted above, a highly luincyiec! li;;l of chemicals was used for the calculation of
exposure point concentrations, exposures, and risks. This constriction of the analysis, in
direct contradiction of LiPA guidance, means that silc-related risks may be significantly
underestimated.
The caleuluiion of exposures and doses from concentrations contains fundamental errors
thai are quite startling. Also, as noted above, it ignores the explicit policy of EPA thai
inhalation exposures should be calculated in terms of inhaled concentration, which is then
compared to a reference concentration. The simple calculation of an inhaled close, as
poformed here, ignores critical issues of pulmonary physiology that underlay EPA's
decision to switch to the use of RfCs in evaluating inhalation exposures.
More importantly, the calculations use for exposure to shower air are flatly wrong, and
the procedure employed by ENVIRON ignores fundamental principles of chemistry and
physics (Table Vl-5). ENVIRON appeal's to be assuming that persons arc simply inhaling
the shower water. In reality, exposure 10 volatile chemicals in a shower, as well as in
general household air, reflects a transfer of mnss, and concentrations in air will be
critically dependent upon the water flow rate through the shower and ihe volume of the
bathroom (as well as time spent in the bathroom after showering). This fundamental error
is completely unacceptable in any risk assessment.--Simple, well-validated models of
shower volatilization are readily available.
The consequences of BNVIRON's bizarre approach to evaluating inhalation exposures in
the shower can be found in Table A-2, where the shower inhalation risks from bcn/cne
arc determined to be only one thirty-third of those from direct ingcstion. This is a radical
departure from the normal pattern found in dozens, if not hundreds, of risk assessments.
Using reasonable models of showering exposure, inhalation in the shower has generally
been found lo produce risks essentially equal to those of direct ingestion.
Even further, these risks (both those from ingesiion and from inhalation in the shower)
arc typically found to be an order of magnitude lower than risks associated with general
contamination of household air (see numerous publications by T. McKonc. or
J. Andclman).
The procedure used lo disaggregate Hazard Indices by toxic effects (pp. Vll-2 - VTJ-3,
Table Vll-3) arc not made adequately explicit; but appear to be based solely upon the
critical effect for each compound, which is not a scientifically justified procedure. Rather,
the entire set of toxic effects caused by a chemical must be considered in developing
organ-specific hazard indices.
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11R1 Review of LiNVJRQN Risk Assessment Warwick. NY
Implications ol'Mclhodological Deficiencies for Risk ICstimales
The combination of inappropriate exclusion of chemicals, and the use of non-standard,
non-conservative exposure parameters, tend to lead JiNVlRON's rcpon lo underestimate
hazard quotients by 30%, and cancer risks by 60%, as indicated by the leiter from
Kidman and Washburn to HP A.
The inappropriate calculation of shower inhalation exposures, and the failure to consider
contamination of household air, have more significant consequences on risk estimates
from ground water contamination. The former would lead to underestimating cancer risks
by approximately one-half, while the latter results in cancer estimates that are
underestimated by approximately an order of magnitude.
The most significant departure from acceptable scientific practice is the use of the dietary
RfD for manganese. As noted above, concentrations of manganese in ground water
comparable lo, and even less than, those found at this site, appear to cause significant
neurological impairment in a human population drinking the water. It is neither
scientifically justified nor prudent to ignore the high levels of manganese contamination
in an aquifer that is currently bciiu^ used as a source of drinking water by nearby
residents.
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*
i./
*
***
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September 22, 1995
EPA Emergency Response and Remedial Division
Mr. Damian J. Duda, Remedial Project Manager
290 Broadway, Floor 20
NY, NY 10007-1866
RE: Warwick Landfill
Mr. Duda:
Is my water safe? I don't know - and neither will you 10
years from now! Despite your attempts to study this issue
to death, I live here and must use this water! The same
contaminants you say are coming from septic tanks were
dumped into the landfill by the PRPs. Why should I believe
your new studies and not your old studies?
Along with my neighbors, I demand an alternate water supply!
Our Technical Assistance Grant Advisor outlines valid points
to substantiate this demand. I want safe water. The only
way I can be assured of this is with an alternate water
supply - requested 6 years ago and a much cheaper way to
answer everyones concerns now and in the long run.
' '^A^^L -t^j-
Robert and Margi Ley
RR 4 Box 505
Monroe, NY 10950
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September 22,1395
Mr. Damian J. Duda
EPA Remedial Project Manager
Emergency Response and Remedial Division
230 Broadway, Floor 20
NY, NY 10007-1866
RE: Warwick Landfill Superfund Site
Mr. Duda:
! live on Penaiuna Road. While my water has been tested twice (I am still
waiting for the results of the second test taken FIVE months ago), I am still
unsure about the quality of rny water. I must resort to buying water for
consumption - an extra expense that is not welcome. I am also a homeowner
who has taken a great loss on the value of my home due to this landfill and
suffer with my neighbors the stigma of living near the "Penaiuna Dump". I have
tried putting my home on the market only to have real estate people tell me
"...but of course you live near the dump... people don't want to come to look at
your house...". I have also been told that I would have to take much less than
the home is worth if I want to get someone interested.
I do not agree with your findings. The report by our Technical Assistance Grant
Advisor outlines my reasons. I totally agree with the other members in my
homeowners association in demanding my rights to safe water. The only way
we can be assured of this is with an alternate water supply. This has been our
demand from the beginning. During this time of economic upheaval in the
government, wouldn't it be wise to propose a plan to your EPA Heads that would
save the government a great deal of money? i am sure we all agree that
government rules and regulations are not always the most beneficial to the
government or the beneficiaries. The alternate water supply is the best answer
for us. Please do not shut us out!!
Mary B. Sutphin
RD 4 Box 506
Monroe, NY 10950
914-986-5673
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September 13, 1995
Angela Geehern
Box 430, R.D.04
Old Dutch Hollow Road
Monroe, New York 10950
Damian Duda
Remedial Project Manager
U.S. E.P.A., Region 2
290 Broadway
New York, N.Y. 10007-1866
Dear Mr. Duda,
I am extremely upset and disappointed by the E.P.A's decision
concerning the Penaluna - Warwick Landfill in Warwick, New York. As
a resident of Warwick and a homeowner whose residence is less than a
mile and a half from this toxic dump I am outraged by my government's
lackadaisical attitude towards this time-bomb in our backyard that
threatens the health and well-being not to mention the property values
of this small community.
Is that the problem Mr. Duda? Is this community too small
to warrant our government's concern? Although millions of dollars are
spent to protect the Spotted Owl, human beings, far from an endangered
species, cannot expect the same protection. Would the clean-up have
been different if the dump was in an upper-class community, or in close
proximity to the White House? You and I both know the answer to this
question.
As for your experts who claim that groundwater contaminates
detected in area wells are caused by septic systems - because everyone
knows us country bumpkins like to flush paint thinner down our toilets-
we have experts that call your claims ludicrous. Why do your experts
opinions carry clout whereas our experts in-depth studies of the groundwate
carry no weight what-so-ever?
An alternate water supply is the only solution to any possibility
of present or future groundwater contamination,yet the E.P.A. will not
even consider this $2 million expenditure when they're ready to spend
$15 million + to cap the dump, which will only slow the spread of toxins.
This is governmental bureaucracy at it's best!
I have worked hard to have this dump cleaned up since I first
moved into this community 17 years ago. You've spent millions of our
tax dollars already with all your studies over the past 11 years, since
we were placed on the Superfund list, and this present E.P.A. plan for
clean-up is the best you can come up with? Other communities beware!
The two biggest lies in this country are " The check is in the mail" and
" I'm from the government and I'm here to help you".
If you think we will accept your decision, forget it. I for
one will continue to fight for an alternate water supply because I'm tired
of being afraid to have my children wash with or drink from my well. My
family has spent thousands of dollars on bottled water and water filters
over the years.
Please restore my faith in our government and reconsider your
decision in this matter. We are working class people who thought we had
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-2-
obtained the American dream when we bought our home. This dream has
turned into a nightmare.
Sincerely,
Angela Geehern
cc; President William Clinton
Governor George Pataki
Honorable Ben Gilman
Senator Alfonse D'Amato
Robert Gaydos- Times Herald Record
Ron Nowak- Greenwood Lake News
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September 20, 1995
Mr. Damian Duda
Remedial Project Manager
U.S. EPA Region 2
290 Broadway
Xew York, XV 10007-1866
Dear Mr. Duda:
I feel compelled to express my disappointment with your recent
presentation on August 15, 1995 regarding the Warwick Landfill and
your probable intent not to go forward with plans to provide a
guaranteed safe water supply for deserving residents.
Let rue tell you why:
First, I have had similar experiences with various environmental
agencies, i.e. EPA, DEP, BCL'A, etc. I can assure you that your not
the first persons to discover strategic scheduling of meetings and
announcements. This is a common ploy and a thinly veiled attempt
to preempt the TAG group's contradictory point of view.
Second, any school child could see that your study was bound to
produce a false-negative. Had you truly been interested in
determining actual risk, you could have simply brought in a track
hoe excavator, exposed several areas and analyzed the unearthed
material. This could have'been done for a fraction of the cost and
may have also provided physical evidence of liability i.e. labeled
vessels, etc.
Last, to have involved the allegedly liable parties in any way is
hopelessly naive. Xo so called PRP should have been privy to any
info regarding intent or design. They have already demonstrated
their flagrant lack of concern for the "little guy".
This executive impotence is precisely the sort of thing that will
bring about an end of the EPA.
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I have always supported you folks in- principal . Please reconsider
your ill-fated position.
Regards ,
Ed Mateo
144 Alexander Road
Monroe, XV 10950
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Damian Duda September 21, 1995
Remedial Project Manager
U.S. EPA Region 2
290 Broadway
New York, NY 10007-1866
Dear Mr. Duda,
I went on record at the EPA meeting of 8-15-95, stating my
reservations of the EPA's handling of the Warwick Landfill
Superfund Site, as well as my support for our TAG advisor's
recommendation of an alternate water supply as the most
comprehensive and cost effective solution to the threat of
contamination from the landfill.
EPA and Geraghty & Miller Inc. insist that septic systems
are responsible for the contaminated wells near the landfill.
However, when I questioned representatives of the EPA and
Geraghty & Miller 'Inc. as to which septic systems were believed
to be fouling which wells, they claimed that they did not have
the data available to answer the question. You stated that
the EPA had not made a determination as to how far the septic
systems are from the wells.
The critiques of Geraghty & Miller's study of the landfill
by Steven Amter of Disposal Safety Inc., and Dr. John Young
of Hampshire Research Institute, strengthen my reservations
of the EPA decision.
Dr. Young criticizes Geraghty & Miller's study for it's
inappropriate exclusion of chemicals, and the use of
non-standard, non-conservative exposure parameters, which lead
the report to underestimate the hazard quotients by 30%, and
cancer risks by 60%. This alone should be enough to call
Geraghty & Miller's study into serious question, however our
TAG advisor's critiques reveal additional faults in the report,
too numerous to mention in this letter.
Under present circumstances, it is little wonder why citizens
have lost confidence in their government. We have been told
that the law will not permit EPA to give our community an
alternate water supply, because in EPA's opinion, the
contaminated wells are not site related. The Dutch Hollow Home
Owners Association Inc. strongly contests this assertion. Based
upon our TAG advisor's critique, and our own common sense, we
find Geraghty & Miller's report, as well as the EPA decision,
to be tragically flawed.
Eight years ago, my wife and I left New York City and
purchased our home in Warwick. We thought that we had found
the American dream. What we found was a nightmare. All that
we wish to do now is to sell our home, and move back to New
York City. We have been told by Realtors that our property
is worth considerably less due to the presence of the landfill.
The EPA decision not to provide our community with an
alternate water supply, has confirmed our opinion that our
property values will never fully recover, and that we will not
find peace of mind until our home is sold and we have left the
area.
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I do not suffer under the illusion that my letter will cause
the EPA to reconsider it's decision. I must however, exercise
my democratic right to express my opinion.
Respectfully,
George S. Weber
Chairman-Environmental Committee
Dutch Hollow Home Owners Association Inc. - Warwick, NY
RD 4, Box 545
Old Dutch Hollow Road
Monroe, NY 10950
914-986-8290
cc:
President William J. Clinton
Vice President Al Gore
Honorable Daniel Patrick Moynihan
Honorable Alfonse D'Amato
Honorable Benjamin A. Gilman
EPA Administrator Carol M. Browner
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ROD FACT SHEET
SITE
Name: Warwick Landfill
Operable Unit: OU-2 (groundwater)
Location/State: Warwick, Orange County, New York
EPA Region: II
HRS Score (date): 29.41 (March 1989)
NPL Rank (date): 1022 (February 1991)
EPA I.D. : NYD980506679
ROD
Date Signed: September 29, 1995
Selected Remedy:No Further Action
LEAD: Potentially responsible party:
Warwick Administrative Group
Primary EPA Contact:Damian J. Duda (212) 637-4269
Secondary EPA Contact:Douglas Garbarini (212) 637-4269
Primary PRP Contact: Christopher J. Motta *
Geraghty and Miller, Inc.
(201) 909-0700
WASTE
Type and media:
Soils/leachate: VOCs - benzene, chlorobenzene, ethylbenzene, xylenes
Inorganics - aluminum, arsenic, barium, cadmium, chromium,
lead, manganese.
Groundwater: VOCs - 1,1,1-trichloroethane, benzene, toluene.
Inorganics - aluminum, antimony, arsenic, chromium,
manganese.
Origin: Contamination originated from illegal disposal of hazardous materials at this
landfill.
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