United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R02-8&M*-
September 1988
&EPA
Superfund
Record of Decision
Ludlow Sand & Gravel, NY
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REPORT DOCUMENTATION
PAGE
L RCPOrTT NO.
EPA/ROD/R02-88/
>. Recipients Accession No.
4. TNI* end Subtitle
SUPERFUND RECORD OF DECISION
Ludlow Sand & Gravel, NY
First Remedial Action
Report
09/30/88
^ ^r J.L s>(-
^^•Authorfe)
I 9. IHrrorml
t. Performing Organization Rept. No.
9. IHrformlnt Organization Name and Address
10. ProJect/Task/Work Unit No.
It. Contract(C) or Gr«nt(G) No.
(C)
(G)
12. Sponsoring Organization Nam* and Addr»»»
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
13. Type of Report & Period Covered
800/000
14.
IS. Supplementary Note*
16. Abstract (Limit: 200 words)
The Ludlow Sand and Gravel site is located approximately six miles south of Utica, in
the town of Paris, Oneida County, New York. The site consists of.a gravel pit and
landfill on a 130-acre tract of land, owned and operated by Mr. James Ludlow. It is
surrounded by rural residential and agricultural land and includes a New York State
designated wetland south and east of the fill area. The landfill, which is the focus of
this ROD, is in a ground water recharge zone to the principal aquifer along Sauquoit
Creek. Fill material is in contact with the ground water in some locations in the
andfill. Sauquoit Creek serves as a major discharge point for ground water flowing
rom this aquifer. Various organizations and individuals have disposed of waste at the
site since 1966. This waste included domestic wastes, septic tank effluent, industrial
wastes such as dyes, waste oils and metallurgical cooling oils, and animal parts from a
meat processing plant. In late 1982, sampling revealed traces of PCB contamination in
the leach.ate pools on the southern portion of the property. In July 1987, the District
Court of Binghamton ordered Mr. -Ludlow to cease operations at the site. Mr. Ludlow
complied with the court order and closed the landfill by February 15, 1988. The primary
contaminants of concern affecting soil, sediments and ground water are VOCs including
benzene and toluene and organics including PCBs and phenols.
(See Attached Sheet)
17. Document Analysis a. Descriptors
Record of Decision
Ludlow Sand & Gravel, NY
First Remedial Action
Contaminated Media: gw, sediments, soil
Key Contaminants: organics (PCBs, phenols),~ VOCs (benzene, .toluene)
It. Identlfiers/Open-Cnded Terms
e, COSAT1 Field/Group
r
Availability Statement
19. Security Clan (This Report)
None
20. Security Class (This Page)
None
21. No. of Pages
71
22. Price
(See ANSI-Z39.J8)
See /ntlruct/oni on Reverse
OPTIONAL FORM 272 (4-77)
(Formerly NTIS-35)
Department of Commerce
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EPA/ROD/R02-88/064
dlow Sand & Gravel, NY
irst Remedial Action
16,. ABSTRACT (continued)
The selected remedial action for this site includes: consolidation and onsite
disposal into the landfill of approximately 10,000 yd^ of contaminated soil and
sediment adjacent to the landfill, and installation of an impermeable cover over the
landfill; collection of leachate from seepage areas formed from the landfill and
dewatering of the landfill through use of a passive drain system or an active well
system with onsite treatment of the collected leachate/ground water and offsite
discharge of the effluent, or, if dewatering is not implemented, collection and
transportation of leachate offsite to a permitted disposal facility; implementation of
upgradient ground water controls to lower and prevent the ground water table from coming
in contact with the waste material; access restrictions; imposition of deed restrictions
governing future use of the property; and implementation of a long-term water quality
monitoring program including both onsite and offsite ground water, surface water and
potable water supply wells. A second remedial action will address ground water
remediation, if necessary. This remedial action is a combination of three alternative
remedies. The present worth is estimated to be between $3,727,200 and $14,548,900 with
an annual O&M between $58,900 and $364,900.
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DECLARATION STATEMENT
RECORD OF DECISION
SITE NAME AND LOCATION
Ludlow Sand & Gravel Site
Town of Paris
Oneida County, New York
STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected remedial action for
the Ludlow Sand and Gravel Site in the Town of Paris/ developed in
accordance with the Comprehensive Environmental Response, Compen-
sation, and Liability Act of 1980 (CERCLA), 42 U.S.C. § 9601, et.
seq., as amended by the Superfund Amendments and Reauthorization
Act of 1986 (SARA), and to the extent practicable, the Nationa-1
Oil and Hazardous Substances Pollution Contingency Plan. This
decision is based on the administrative record for this site. The
attached index identifies the items that comprise the administrative
record upon which the selection of the remedial action is based.
The State of New York has concurred with the selected remedy.
DESCRIPTION OF THE REMEDY
The remedial alternative presented in this document is the first
operable unit of the Ludlow Sand and Gravel Site. It consists
of control of the landfill materials, leachate seeps, soil and
sediment around the landfill and groundwater which may be currently
in contact with the fill materials. These activities constitute
the first Operable Unit at this site; subsequent operable units
will deal with off-site contamination in the groundwater, wetlands
and gravel pit.
This Record of Decision calls for the following actions:
1. Approximately 10,000 cubic yards of contaminated soil and
sediment adjacent to the landfill will be consolidated into
the landfill. During design, a soil/sediment sampling program
will be implemented to fully define the extent of soils to
be consolidated.
2. An impermeable cover will be installed over the landfill
to control runoff and minimize infiltration of water. This
cover will comply with closure requirements of RCRA Subtitle C
(40 CFR Section 264.310).
3. Leachate from leachate seepage areas and residual leachate
formed from the landfill will be collected (see Figure 3).
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-2-
4. Dewatering the landfill by using either a passive drain system
or an active extraction well system. Details of the dewatering
system will be determined during pre-remedial design activities.
If it is determined during the pre-design field activities
that there is no groundwater mound in the landfill or if the
water in contact with the fill material is not contaminated,
the dewatering may not be implemented.
5. Upgradient groundwater controls will be implemented to lower
and maintain the ground water table from being in contact with
the waste material. The details of a passive or active ground
water table lowering system will be determined during the
pre-remedial design field activities. If the cap alone lowers
the groundwater table below the fill material, upgradient
control of the groundwater may not be implemented.
6. If dewatering of the landfill is implemented, treatment of
the collected contaminated leachate/ground water will be
performed a't an on-site facility. Alternatively, if dewatering
is not necessary and the volume of water is small, the leachate
will be collected and transported off-site to a permitted
disposal facility that will accept the waste. The effluent
from an on-site treatment plant would be discharged to an
intermittent stream.
7. Perimeter fencing (including the wetlands)' will be installed.
8. In accordance with New York State Law, deed restrictions
governing future use of the property will be duly filed.
9. A long-term water quality monitoring program will be implemented
which will include quarterly monitoring of on-site and off-site
groundwater, surface water and potable water supply wells.
DECLARATION
Consistent with, the Comprehensive Environmental Response, Com-
pensation, and Liability Act of 1980 as amended by the Superfund
Amendments and Reauthorization Act of 1986, and the National Oil
and Hazardous Substances Pollution Contingency Plan, 40 CFR Part
300, I have determined that the selected remedy is protective of
human health and the environment, attains Federal and State
requirements that are applicable or relevant and appropriate to
the remedial actions and is costeffective. This remedy utilizes
permanent solutions and alternative treatment technologies to the
maximum extent practicable for this site. Because treatment of
the principal threats at the site was not found to be practicable,
this remedy does not satisfy the statutory preference for treatment
as a principal element of the remedy.
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Because this remedy will result in hazardous substances remaining
on-site/ a review will be conducted within five years after com-
mencement of the remedial action to ensure that the remedy continues
to provide adequate protection of human health and the environment.
Date
William J. fcdszynski, P.E.
Acting Regional Administrator
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SUMMARY OF REMEDIAL ALTERNATIVE SELECTION
LUDLOW SAND AND GRAVEL SITE
.TOWN OF PARIS, ONEIDA COUNTY, NEW YORK
SITE LOCATION AND DESCRIPTION
This remedy addresses source control of the Ludlow Sand and
Gravel Site as the first operable unit. It consists of source
control of the landfill and surficial leachate seeps/ management
of the soils and sediments around the landfill, management of
the groundwater which may be in contact with the fill materials,
and control of residual leachate.
The Ludlow Sand and Gravel Site'is located about six miles south
of Utica in Oneida County, New York. The small community of
Clayville in the Town of Paris is approximately 2 miles southeast
of the landfill, (see Fig. 1) The Ludlow Sand and Gravel Site
includes a gravel pit and landfill on a 130 acre block of land
owned and operated by Mr. James Ludlow. Surrounding the landfill
is an extensive gravel pit also operated by Mr. Ludlow and rural
residential and agricultural land. A smaller area to the north
and west of Holman City Road includes the operator's office,
maintenance buildings, and a smaller construction debris disposal
site. The Ludlow Sanitary Landfill property also includes a
New York State designated wetland south and east of the fill area.
The landfill is in a groundwater recharge zone to the principal
aquifer along Sauquoit Creek. The Creek serves as a major discharge
point for groundwater flowing from the uplands. Soils in the over-
burden underlying the site have been characterized as a complex
sequence of unconsolidated glacial sediments that vary in composition
Three types of glacial sediments have been identified at this site:
till, glaciofluvial deposits, and lacustrine deposits. To the east
and south of the site, the glacial deposits are overlain by deposits
from a marsh which consist of silts, clay and peat. The bedrock
underlying the glacially deposited overburden consists of limestone
dolomites, and shale. These plates are part of the Remedial
Investigation [RI] report and are available•for viewing at the
EPA Region II office, Clayville Library and City of Utica Library.
Water supplies in the area are mainly used for domestic and
agricultural purposes with two (2) municipally owned public
water supplies within two miles of the site. The Sauquoit Valley
Water District is a spring source located approximately one (1)
mile upgradient of the Site's groundwater flow patterns. The
Village of Clayville's water system is located approximately
three quarters of a mile northwest of the landfill. This system
consists of a supply well 81 feet deep that has a capacity of
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-2-
or rue U»GI CASsvxttwr ouAO«ANcafrs MKJTT semes.
TX wear »i*ici_o, «r ou»o*w*cu (75 MINUTE st*t£s, 1*45, COWTDUH WTCRVA*. • 201
SOURCE: NUS Corp
COM
engineers, scientists
planners & management consultants
Figure 1
Geographic Location Plan
Ludtow Sanitary Landfill Sit«, Town of Paris. New York
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-3-
about 70 gallons per minute. The only individual water supply
wells within 1000 feet of the landfill are three (3) homeowner
wells along Mohawk Street located upgradient to groundwater flow
around the landfill. Eight (8) additional homeowner wells are
located between 1000 and 3000 feet from the landfill.
SITE HISTORY
Disposal at the Ludlow Sand and Gravel Site has occurred for the
past 20 years. The earliest records are from 1966, when there
were complaints from local residents of dumping in the area.
Various organizations and individuals have been involved in
disposal at the site during these years. Since the late 1960s,
the site has been owned and operated as a landfill and gravel pit
by Mr. James Ludlow of Holman City Road, Clayville, New York, or
corporations of which he is president and chief executive officer.
The gravel pit is quite extensive. It occupies about 30 acres
north of the landfill area. Gravel from the pit is sold for use
as well as used on the landfill for refuse cover. In the past,
notoriety of the landfill was largely based on aesthetic con-
siderations. Large areas of the landfill were left uncovered,
and a strong .landfill odor could be detected at a considerable
distance. Truck haulage records have been well kept since the
late 1970s. These records document a diversity of wastes disposed
of in the landfill. This documented waste consists of both
domestic wastes and septic tank effluent. In addition, a variety
of industrial wastes including, but not limited to, dyes, waste
oils, metallurgical cooling oils and animal parts from a meat
processing plant were disposed at the landfill.
Complaints continued about the site with a variety of legal actions
taken against Mr. Ludlow. In late 1982, trace quantities of
PCBs were detected in the leachate pools located at the southern
portions of the property. These samples were used in the develop-
ment of a Hazard Ranking Score (HRS) for the landfill. A HRS score
was assigned to this site which placed it on the United States
Environmental Protection Agency's (USEPA) list of priority
hazardous waste sites known as the Superfund National Priorities
List (NPL).
In July 1987, Federal Judge McAvoy (Binghamton District Court)
executed a Federal Court Order requiring operations to cease
at the landfill on or before February 15, 1988 at 2:00 pm.
Mr. Ludlow ceased operation of the landfill as scheduled and
is presently negotiating final closure requirements with New
York State.
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-4-
ENFORCEMENT STATUS
The Ludlow Sand and Gravel NPL site has an extensive history
of legal response actions. In spite of this, Mr. Ludlow has
never operated with a permit in compliance with New York State
Regulations. As early as 1966, Ludlow was cited by State inspectors
for a variety of improper or illegal waste disposal practices.
To bring this landfill into compliance with State regulations,
Mr. Ludlow has signed numerous administrative consent orders with
the New York State Department of Environmental Conservation
(NYSDEC) to perform the necessary work. Non-compliance with
the requirements of these orders resulted in enforcement through
the New York State Department of Law. The site became an NPL site
in 1982. In 1984, a draft cooperative agreement was written to
request funds from the USEPA to perform a Remedial Investigation/
Feasibility Study (RI/FS) at the site. Prior to submission of
this agreement to the USEPA, the New York State Department of Law
(NYSDOL) and the NYSDEC made a last attempt to negotiate with Mr.
Ludlow for site investigation and remedial action.
Although negotiations again failed with Mr. Ludlow, Special
Metals, Inc. of Utica agreed to pursue th£ necessary RI/FS
at the site. Special Metals, a potentially responsible party at
the site entered into negotiations with the State to perform
the work requested. On September 10, 1984 negotiations were
concluded and an Administrative Consent Order was executed with
this third party to accomplish the required RI/FS. O'Brien and
Gere Consulting Engineers were engaged to perform the work necessary
to fulfill this Administrative Consent Order. The final document
was prepared and submitted to the State during June, 1986. The
State commenced a CERCLA enforcement action against Ludlow that
same year.
The State of New York reviewed and commented on the documents
submitted by O'Brien & Gere in a response to Special Metals, Inc.
dated September 16, 1986. The document presented by O'Brien and
Gere recommended remedial alternatives for closure of the landfill
which were less stringent than Federal and State requirements.
Subsequently, Mr. Ludlow's attorney engaged Dunn Geoscience to
perform additional investigations to refine the O'Brien and Gere
investigatory work. A second investigation report with a final
closure plan was submitted to NYSDEC for review. In July 1987,
Federal District Court Judge Thomas McAvoy ordered the landfill
to close effective February 15, 1988 at 2:00 p.m. and ordered the
partial payment of response costs to the State. Final closure
would be required pursuant to Federal and State regulations.
Concurrent with the PRP's additional investigations, the USEPA
engaged Camp, Dresser and McKee, Inc. (COM) to evaluate and
perform a supplemental RI/FS at the site in response to New York
State's request to assist in evaluating the cost of alternatives.
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The supplemental RI/FS was then conducted due to the USEPA's
decision that more information was needed concerning the remedies
as presented by the State and the responsible parties. This
supplemental RI/FS report .was released to the public during the
public comment period in August 1988.
SCOPE OF DECISION
As with many Superfund sites, the problems at the Ludlow Sand
& Gravel site are complex. As a result, EPA and NYSDEC have
divided the work into two smaller units or phases referred to as
"operable units."
Currently defined operable units at the Ludlow site are:
0 Operable Unit One: Source control of contaminated soils,
sediment, leachate seeps and ground water in contact with
wastes.
0 Operable Unit Two: Off-site migration of ground water,
potential contamination of wetlands and gravel pits.
This decision document defines the remedial activities to be
conducted as part of Operable Unit One.
REMEDIAL INVESTIGATION
An RI/FS was performed from October 1984 to June 1986 by O'Brien
and Gere, contractor of Special Metals Inc., pursuant to a NYSDEC
Consent Order. The study area for the RI/FS concentrated on the
landfill where wastes were obviously disposed. A supplemental
Site Investigation (SI) was conducted by the firm of Dunn GeoScience
Corp., Mr. James Ludlow's consultant, at the landfill and at the
gravel pit north of the landfill. EPA also tasked its technical
support contractor, CDM, to perform a supplemental RI/FS in
compliance with SARA. Figure 2 summarizes the locations of the
monitoring wells and borings installed during the field activities.,
During the RI and subsequent Site Investigation, a number of
field activities and laboratory analyses (i.e. geophysical tech-
niques, monitoring well installation, ground water sampling and
analyses, soil boring analyses, surface water and sediment sampling
and analyses, leachate sampling and analyses) were implemented.
A. Contaminant Distribution
1. Landfill Material
Ten borings distributed in a circular configuration were drilled
within the landfill to determine the depth and chemical composition
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of waste material (O'Brien & Gere 1986) (see figure 2). On the
average, two samples per boring were submitted for analysis.
Samples were analyzed for volatile organics/ benzene, toluene
and xylene (BTX), polychlorinated biphenyls (PCBs), and seven
extractable metals.'
A number of volatile organic compounds (VOCs) were detected
throughout the landfill. VOCs encountered included methylene
chloride, 1,1-dichloroethane, I,1-dichloroethene, 1,2-dichloroethene,
1,1,1-trichloroethane, benzene, trichloroethene , tetrachloroethene,
toluene, chlorobenzene, ethylbenzene and xylene. Total VOCs
ranged in concentration from .012 ppm to 657 ppm. Areally, VOCs
were well distributed throughout the landfill, and vertically within
the subsurface. Total VOCs at location 51, 52, 53, 55, 56, 57, 58
and 59 were above 1 ppm. At location 55, the highest concentration
of VOCs was detected at 11 feet below grade; however, VOCs were
still detected at 25 feet below grade. (See tables 1A-B).
Detectable concentrations of PCBs were found in boring locations
54 and 57 on the southeast portion of the fill. PCBs were detected
at 19 feet in boring 54 at a concentration of 6100 ppm. This
boring is located in the northwest portion of the landfill (O'Brie-n
& Gere, 1986). Concentrations of total phenols varied across
the landfill from less than 0.1 ppm to 89 ppm (O'Brien & Gere
1986). Phenols were widely distributed throughout the landfill,
both areally and vertically.
2. Leachate .
Leachate samples were collected from five leachate pools or seeps
surrounding the base of the landfill. Three seeps on the south
and east side of the fill were sampled twice and analyzed for
conventional parameters (BOD, chloride, COD, pH, Conductivity, TC
TIC, TOC and TOX) PCBs, total phenols and metals. One sample was
composited from four small seeps areas off the north base of "the
fill and analyzed for the full hazardous substance list (HSL)
compounds (except PCBs and pesticides), TKN, COD and sulfate by
Dunn GeoScience.
The pool directly south of the fill exhibited the highest con-
centrations of chloride, COD, conductivity, total carbon and TOX.
The two pools south of the fill also contained PCBs in concen-
trations ranging from 0.0004 ppm to 0.0036 ppm. The pH of the
leachate ranged from 7.2 to 7.5 (O'Brien & Gere and Dunn GeoScience).
(see table 2)
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DB-/0 DB-8«\
E-6t
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TABLE 1A
SUBSURFACE SOIL BORING SAMPLES FROM LUDLOW LANDFILL
—Organic Analysis*
Samples Collected by O'Brien & Gere Engineers
1984
Chemicals1
fug/kg wet weight)
B-50
B-51
& I 19'
B-52
22'
B-53
41
12'
B-54
12' i 19'
Volatiles
Benzene
Bromodichloromethane
<100
<'100
17,000
170.000
<100
<100
<100
<100
<100
Bromoform
Bromomethane
<100
<100
<100
<100
<100
<100
<100
<100 <100
Carbon lelrachloride
Chlorobenzene
NA
NA
<100
<100
NA
NA ! NA
NA
NA
Chloroelhane
Chloroform
2-Chloroethyl vinyl ether
Chlpromethane
<100
<100
<100
<100
<100
<100 i <100
<100 <100
Oibromochloroethane
1,1 -Dichloroelhane
46
17
1,2-Dichloroethane
1,1-Dichloroethene
trans-1,2-Dichloroethene
1.2-Dichloropropane
cvs-i ,3-Dichloropropene
trans-1.3-Dichloropropene
<10
<10
Ethylbenzene
Freon 113
<100
180 i 1.900
13.000 <100
850 i <100
<100
Methylene. chloride
1.1.2.2-Tetrachloroelhane
12
550
39
1.200 : 13
<10 20
Tetrachloroeihene
1.1.1 -Tnchlproethane
51
r.l.2-Trichlorpethane
Trichloroethene
97
Toluene
Vinyl chloride
<100
900
27.000
5.900
<100
<100 <100
<100 <100
Xyienes
Phenols (total)
PCS"
<100
<200
<2000
300
3.300
3.000
NA
<2000 <2000
4.300
<100
<1000
<100
<100
<1000
<100
<100
<1000
150
<200
<2000
<100 , 240
2.200 ! 1.500
<2000 6.100,000
Inorganics' (mg/1)
Cadmium
Chromium
Iron
Lead
Manganese
Nickel
Zinc ;
. NL
<.01
0.13
0.06
NL
<.01
2.2
0.06
4.1
NL
<.01
0.06
0.13
NL
<.01
0.32
0.06
2.0
NL
0.1
NL
<.01
0.01
0.04
0.02
NL
<.01
0.48
0.21
0.33
NL
NL
<.01
0.12
<.01
0.15
Footnotes:
• Source: Remedial Investigation/Feasibility itudy-Ludlow Sanitary Landfifl. O'Brien a Gere. June 1966.
• The number presented under each boring location (i.e. B-SO) is the depth of the bottom of the split ban-el sample
below grade.
' OB 4 G analyzed the soil borings for volatile organ
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TABLE IB
SUBSURFACE SOIL BORING SAMPLES FROM LUDLOW LANDFILL
—Organic Analysis-
Samples Collected by O'Brien & Gere Engineers
1984
Chemicals'
(ug/kg wet weight)
B-55
1V I 25'
B-56
7'
13'
B-57
14' I 22'
B-58
8'
16'
B-59
IV ! 22'
Volaliles .
Benzene
Bromodichloromethane
<100
<100
* \0
34.000
* 10
39,000
<100
<100
* to
160 <100
<100 I <100
Bromoform
Bfomomethane
<100
<100
<100
<100
<100
<100
<100
<100
<-100
<100
Carbon tetrachloride
Chlorobenzene
<100
<100
<100
<100
<100
. NA
3.300
<100
<100 ! <100
Chloroethane
Chloroform
2-Chloroethyl vinyl ether
Chloromethane
<100 i <100
<100
<100
<100
<100
<100
<100
<100 i <100
Oibromochloroethane
1.1-Dichloroelhane
1.2-Dichloroethane
1,1-Dichloroethene
fans-1.2-Oichloroethene
1.2-Dichloropropane
2.500
43
1.70
o
to
IO
1C
< to
•< 10
24
13
-.1C
44
<. id
Toluene
Vinyl chloride
260.000: <100
370
2.000
210 I <100
1.300 j 2,600
850 290
Xylenes
Phenols (total)
PCS'
300.000
<700
<3000
<100
500
1.700
<100
2.500
<1000
520
89.000
<1000
240
700
3.500
370
1,200
4,700
2,700
2.500
3,700
<100
<2000 I <3000
330 | 460
<200 | <100
<2000 i <2000
Inorganics' (mg/I)
Cadmium
Chromium
Iron
Lead
Manganese
Nickel
Tine
NL
<.01
0.3
NL
0.02
NL
<.01
0.92
0.03
0.02
NL
0.15
NL
<.01
0.23
0.1
0.02
NA
NA
NA
NA
NA
NA
NA
NL
<.01
0.14
0.08
NL
<.01
0.02
0.05
NL
<.01
0.64
0.04
0.05
NL
0.02
Footnoin:
• Sowrn: Remedial lnv«$tigatJon/raasibility study^.udiow Sanitary LandfiH. O'Britn & Gere. Jun* 1986.
• Th« number presvnttd under eacrt boring location (!•• B-50) is the depth of the bottom of trie split barrel sample
beW* grade.
' OB 4 G analyzed tne soil borings (or volatile organics. phenols. PCBs and 7 eflracia&t* metals.
* PCBs were reponed on a dry weight bases.
' The inorganic analyses are based on samples from an extract utilizing the *0 CFR 261 Extraction Potential procedure.
NA — The cftemcal was noi analyzed tor in tne sample.
NC — The data has been crossed out in tne O'Brien & Gere P.I/FS Appendix and is therefore not
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TABLE . 2
LEACHATE ANALYSES
Samples Collected by O'Brien & Gere Engineers and Dunn Geoscience*
1984-1987
Parameters
(UC")
Volatile*
Acetone
2-Butanone
Toluene
Xyfenes (total)
Phenols (toUl)
PCB's
BODS (mg/I)
COO (mg/I)
TC (mg/I)
TIC (mg/l)
TOC(mg/l)
TOX* (mg/I)
TKN (mg/l)
Sulfate (mg/l)
Chloride (mg/l)
PH
Inorganics (mg/l)
Ar$«mc
Barium
Calcium
Chromium
Iron
Magnesium
Manganese
Nickel
Potassium
Sodium
Zinc
Cyanide
North Seep
5/13/87
430
540
34
3.5
188
NA
NA
2.900
NA
NA
NA
NA
116
<10
NA
NA
0.012
0.21
180 '
0.011
10
89
34 .
0.044
200
380
0.62
0.075
East
10/25/84
NA
NA
NA
NA
<1
0.1
15
108
78
20
58
90.100
NA
NA
52
7.2
NA
NA
NA
<.01
67
NA
0.33
<.01
NA
NA'
<.0l
NA
Seep
5/17/85
NA
NA
NA
NA
7
<0.1
12
83
60
25
35
54.64
NA
NA
51
7.2
NA
NA
NA
<.01
0.99
NA
2.2
<.01
NA
NA
0.02
NA
SouttlL
10/25/84
NA
NA
NA
NA
2
1.7
3
88
84
37
47
180.190
NA
NA
121
7.6
NA
NA
NA
<-01
0.35
NA
0.13
<.01
NA
NA
<.01
NA
BtSeep
5/17/85
NA
NA
NA
NA
<1
3.6
18
132
82
36
46
180.230
NA
NA
101
7.5
NA
NA
MA
<.01
2.11
NA
0.7
<.01
NA
NA
0.02
NA
South
10/25/84
NA
NA
NA
NA
2
0.4
21
142
'180
130
50
350.360
NA
NA
210
7.5
NA
NA
NA
-------
-11-
Four volatile organic compounds were detected in seeps north of
the fill. The compounds detected included acetone (0.43 ppm), 2-
butanone (0.54 ppm), and toluene (0.034 ppm). In addition, con-
centrations of cyanide, total recoverable phenolics, iron and
manganese (10 and 3.4 ppm) exceeded NYSDEC surface water standards.
Values for TKN and COD were elevated.
Leachate and associated sediments were collected and analyzed by
CDM's field team in 5 pools surrounding the landfill in January
1988. Organic concentration were elevated in the north seep
area. The east, southeast and southern seep areas which are
mixed with surface/ground water have less than .050 ppm of organic
contamination. The north side seeps exhibited the greatest concen-
tration of contamination with 17.6 ppm detected. Conventional
parameters were elevated in the seeps. PCBs were only detected
in the sediments on the south seep. Metals concentrations were
elevated for iron and manganese in all samples, (see tables 3A-K)
3. Surface Water
During the course of the remedial investigation and site inves-
tigation, conducted by O'Brien & Gere and Dunn GeoSeience res-
pectively, a cumulative total of nine surface water samples were
collected in three phases at three locations. Samples collected
during the first two phases were analyzed for conventional parameters
(6005, COD, pH, conductivity, chloride, TOC, TIC, total carbon,
TOX), PCBs, phenols, and metals (Cd, Cr, Fe, Hg, Mn, Ni, Pb, Zn).
Sample results revealed a slight degradation in surface water
quality across the site. Concentrations of 8005, COD, iron
and manganese increased adjacent to and downstream of the site.
In addition, PCBs were detected at a.concentration of 0.0005 ppm
downstream of the site, west of Holman City Road. Concentrations
of all HSL volatile organics were below the method detection
limit, (see table 4)
4. Ground water
During the course of the RIs, nine monitoring well clusters were
installed upgradient and downgradient of the landfill.
Only wells located directly adjacent to the landfill exhibited any
negative impact from the landfill on groundwater quality with
the exception of PCBs in well 5D and 6S. Organic concentrations are
very low and restricted to the shallow aquifer. Low concentrations
of metals appear in both aquifers. A further characterization of
the groundwater will be performed during a subsequent RI/FS, which
will constitute the second operable unit for this site.
-------
-12-
TABLE 3A_.
LEACHATE AND ASSOCI." TED SEDIMENT-ORGANIC ANALYSIS
Samples Collected by Camp Dresser & McKee Inc.
January 19,1988
Chemical
Votatlles
Methylene Chloride
Acetone
2 - Butanone
Chloromethane
Ohtoroethane
1 ,1 - Dichloroethane
1,2- Dichloroethene
Chloroform
4 - Methyl • 2 pentanone
'2-Hexanone
Toluene
Ethylbenzene
Xylene (total)
Chlorobenzene
Semlvolatiles .
Benzole acid
Pentachlorophenol
4 - Methyl phenol
N-Nitrosodiphenylamine
Phenol
Di-n-butyl phthalate
Butyl benzyl phthalate
Bis (2-ethylhexyl) phthalate
1 ,4 • Dichlorobenzene
1 .3 • Dichlorobenzene
1.2- Dichlorobenzene
Naphthalene
2 • Methyl naphthalene
Phenanthrene
Fluoranthene
Pyrene
Benzo (b) fluoranthene
Benzo (k) fluoranthene
PCB'S
PH
South Seep
LE-5
BP 740
(ug/l)
R
R
ND
ND
ND
ND
ND
ND
ND
ND
ND
.ND
ND
. ND
15 J
ND
ND
ND
ND
ND
ND
ND
3 J
ND
ND
4 J
ND
ND
ND
ND
ND
ND
ND
6.7
South Seep
LE-5 duplicate
BP741
fog/i)
R
R
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
South Seep
SD-5
BP 749 •
(ug/kg)
R
2.100 B
370
ND
ND
ND
ND
ND
ND
ND
ND
South Seep
SD-5 duplicate
BP 7.48
• (us/kg)
R
1
2,600 B
610
ND
ND
ND
ND
ND
ND
ND
ND
ND i ND
ND | 420
ND
25 J
ND
ND
ND
ND
ND
ND
3 J
ND i
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
6.9
220
510
320
ND j ND
ND
ND
ND
ND
ND
ND
5,900
1.300 J
720 J
800 J
670 J
ND
540 J
•580 J
390 J
390 J
350 J
19.000
7.2
ND
ND
ND
ND
ND
940 J
910 J
1,200 J
730 J
920 J
ND
ND
ND
ND
ND
ND
ND
2,200
7.4
-------
-13-
TABLE ju
LEACHATE AND ASSOCIATED SEDIMENT-ORGANIC ANALYSIS
Samples Collected by Camp Dresser & McKee Inc.
January 19,1988
*
Chemical
Volatlles
Methylene Chloride .
Acetone
2 - Butanone
Chtoromethane
Chloroethane
1,1 • Dichloroethane
1.2- Dichloroethene
Chloroform
4 • Methyl • 2 pentahone
2 - Hexanone
Toluene
Ethylbenzene
Xylene (total)
Chlorobenzene
Semlvolatlles
Benzole acid
Pentachlorophenol
4 - Methyl phenol
N-Nitrosodiphenylamine
Phenol
Di-n-butyl phthalate
Butyl benzyl phthalate
Bis (2-ethylhexyl) phthalate
1 ,4 - Dichlorobenzene
i ,3 - Dichlorobenzene
1 ,2 - Dichlorobenzene
Naphthalene
2 - Methyl naphthalene
Phenanihrene
Fluoranthene
Pyrene
Benzo (b) fluoranlhene
Benzo (k) fluoranthene
PCB'S
PH .
East Seep
LE-3
BP738
.(no/I)1
R
R '
5 J
ND
ND
ND
ND
ND .
ND
ND
11
ND
ND
ND
20 J
ND
ND
ND
ND
ND
ND
15
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
7.6
East Seep
SD-3
BP746
frig/kg)
R
R
ND
ND
ND
ND
ND
51
ND
ND
ND
Southeast Seep
LE-4
BP739
(HQ1)
R
R
ND
, ND
ND
ND
ND
ND
ND
ND
ND
ND j >ND
ND
Southeast Seep
SD-4
BP747
tug/kg)
R
R
ND
ND
ND
ND
ND
ND
ND
ND
500
200
ND j- 1.300 E
ND ! ND
I • *
I.
.
ND
ND
ND
ND
ND
91 J
430 J
310 J
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
7.0
,
ND
i
ND | ND
ND | ND
ND ! ND
II
ND
ND
ND
ND
16
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
7.0
ND
ND
8.700 J
100.000
R
45.000
8.800 J
8,100 J
38.000
180,000 .
ND
ND
ND
ND
ND
ND
9.8
-------
TABLE 3C '
LEACHATE AND ASSOCIATED SEDIMENT-ORGANIC ANALYSIS
Samples Collected by Camp Dresser & McKee Inc.
January 19.1988
Chemical
Vofatlles
Methylene Chloride
Acetone
2 • Butanone
Chloromelhane
Chtoroethane
1,1 • Dichloroelhane
1,2-Dichloroethene
Chloroform
4 - Mejhyl - 2 pentanone
2 - Hexanone
Toluene
Ethylbenzene
Xylene (total)
Chlorobenzene
Semlvolatlles
Benzoic acid
Peniachlorophenol
4 - Methyl phenol
N-Nrtrosodiphenylamine
Phenol
Di-n-butyl phthalate
Butyl benzyl phthalate
Bis (2-ethylheryl) phthalate
1 .4 • Dichlorobenzene
1,3 • Dichlorobenzene
1,2- Dichlorobenzene
Naphthalene
2 - Methyl naphthalene
Phenanthrene
Fluoranthene
Pyrene
Benzo (b) fluoranthene
Benzo (k) fluoranthene
PCB
PH
North Seep
LE-1
BP 736
0»0/l)
R
R
45 J
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
410
12 J
17 J
ND
ND
ND
ND
NO
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
7.7
North Seep
SD-1
BP744
fog/kg)
R
R
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
North Seep
LE-2
BP737
3.500 B
2.200 B
2,700
26
16
17
4 J
22
22
13
400
3
ND 12
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
7.4
ND
3.300 J
ND
4.900
ND
510 J
ND
ND
NO
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
6.7
North Seep
SD-2
BP745
(pg/kg)
R
290 B
620 E
ND-
ND
ND
ND.
ND
ND
ND
130
. ND
ND
ND
980 J .
ND
930
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
7.6
-------
-15-
TABLE 3D._
LEACHATE AND ASSOCIATED SEDIMENT-INORGANIC ANALYSIS
Samples Collected by Camp Dresser & McKee Inc.
January 19.1988
Inorganics
(ug/l)
Aluminum
Antimony
Arsenic
Barium
Beryllium •
Cadmium
Calcium
Chromium
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Mercury
Nickel
Potassium
Selenium
Silver
Sodium
Thallium
Vanadium
Zinc
Cyanide
South Seep
LE-5
mBM 975
unflltered
56.7 B
ND
ND
175 B.
ND
ND
143.000
ND
ND
South Seep
LE-5 duplicate
mBM 976
unflltered
, 63.3 B
4
ND
4.1 B
238
ND
ND
154.000 .
5.4 B
ND
ND ND
24,800
3.1 BW
38,000
465
ND
20.4 B
89.800
ND
ND
131.000
ND-
ND
30
ND
45,600
5.7 S
41.400
507
ND
21.7 B
97,800
ND
ND
142.000
ND
ND
.42.5
ND
South Seep
LE-5
mBM 216
filtered
39.6 B
•4
ND
ND
129 B
ND
ND
139,000
6.6 B
ND
ND
13.700
3.3 BW
365.000
444
ND
17.8 B
86.700
1.5 BW
ND
125.000
ND
ND
27.6
NR
South Seep
LE-5 duplicate
mBM 217
filtered
41.5 B
ND
ND
131 B
ND
ND
144,000
6.6 B
ND
Field Blank
mBP246
unflltered
40.4 B
ND
ND
3.1 B
1.2 B
ND
320 B
ND
ND
ND 28.5
14.100 ; 76.7 B
1.6 BW
38.300
463
ND
21.7 B
91.400
ND
ND
133.000
ND
2.4 B
25.3
NR
ND
94.2 B
ND
ND
ND
324 B
ND
ND
ND .
ND
ND
ND
ND
-------
TABLE "3E
LEACHATE AND ASSOCIATED SEDIMENT-INORGANIC ANALYSIS
Samples Collected by Camp Dresser & McKee Inc.
January 19.1988
Inorganic
(mg/kg)
dry weight
Aluminum
Antimony
Arsenic
•
Barium
Beryllium
Cadmium
Calcium
Chromium
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Mercury
Nickel
Potassium
Selenium
Silver
Sodium
Thallium
Vanadium
Zinc
Cyanide
-
South Seep
SD-5
mBP244
"8.150 E
ND
ND
212 BEJ
1.9 B
ND
27.200 *
26.5
South Seep
SD-5 deep
mBP 245
8.680 E
ND
ND
252 EJ
1.6 B
7.8 *
62.000 *
49.1
ND | 16.7 B
R !. R .
1
|
I
I
J
i
;
• -i ;
26.400 ! 53,200 i ;
j i
29.5 * j 24.2 *
4,620 B
331 *
ND
29.7 B
R
4.0 BWJ
ND
R
ND
15.8 B
249 E*
ND
9.640
865 *
1.1
98.7
R
2.7 BWJ
ND
R
ND
22.9 B
726 E*
ND
!
1
I
i
.
1
j
!
i
i
i
i
i
i
-------
-17-
TABLE 3F
LEACHATE AND ASSOCIATED SEDIMENT-INORGANIC ANALYSIS
Samples Collected by Camp Dresser & McKee Inc.
January 19,1988
Inorganics
(PS/I)
Aluminum
Antimony
Arsenic
Barium
Beryllium
Cadmium
Calcium
Chromium
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Mercury
Nickel
Potassium
Selenium
Silver
Sodium
Thallium
Vanadium
Zinc
Cyanide
North Seep
LE-1
mBM 971
unfiltered
1,190
ND
ND
110 B
ND
ND
65.800
7.3 B
6.2 B
18.5 B
• 8,750
6.6 S
43,900
945
0.2
52.9
125.000
ND
ND
201.000
ND
4.7 B
76.0
ND
I
North Seep
LE-1
mBP 247
filtered
1,150
ND
4.1. BW
104 B
ND,
ND
62,800
8.5 B
ND
.
14.1 B
6,330
4.9 BS
42.600
869
0.2
44.2
122,000
ND :
ND
196.000
ND
4.5 B
68
NR
North Seep
LE-2
mBM 972
unfiltered
584
* i
ND
10 S
611
ND
ND
. 549.000
North Seep
LE-2
mBP 497
filtered
259
'ND
8.5 B
552
ND
ND
518,000
55.2 i 48.2
i
23.5 B i 22.2 B
i-
33.3
'
183.000
ND
20.5 B
157,000
6.9 S
99.400 j 94,800 .
I
16.700 • 15,900
I
I
ND ! ND
85.2
214.000
. ND
ND
380.000
ND
7.9 B
483
79.9
202,000
ND
ND
359,000
ND - .
5.8 B
414
i
ND | NR
1
l
i
-------
-1B-
TABLE 3G
LEACHATE AND ASSOCIATED SEDIMENT-INORGANIC ANALYSIS
Samples Collected by Camp Dresser & McKee Inc.
January 19,1988
Inorganics
-------
-19-
TABLE 3H
LEACHATE AND ASSOCIATED SEDIMENT-INORGANIC ANALYSIS
Samples Collected by Camp Dresser & McKee Inc.
January 19,1988
Inorganic
(mg/kg)
dry weight
Aluminum
4
Antimony
Arsenic
Barium
Beryllium
Cadmium •
Calcium
Chromium
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Mercury
Nickel
Potassium
Selenium
Silver
Sodium
Thallium
Vanadium
Zinc
Cyanide
North Seep
SD-1
mBP 240
10,200 E
ND
9.5 SNJ
44.8 BEJ
0.74 B
ND
3.840 *
14.7
10.1 B
59
27,000
7.1 S*
4,480
690 *
ND
23.7
R
ND
ND
R
ND
17.2
117 E*
ND
North Seep
SD-2
mBP 241
6.410 E
ND
15.1 SNJ
•
33.9 BEJ
0.45 B
1.3 *
. 115,000 *
9:5
6.7 B .
38.1
18,700
'
7.7 *
12.200
508 *
ND
17.5
R
ND
ND
R
ND
12.5 B
80.1 E*
ND
East Seep
SD-3
mBP 242
14.400 E
ND
20.6 SNJ
188 EJ
1.3 B
ND
5.950 *
East Seep
SD-4
mBP 243
9.350 E
ND
7.4 'SNJ
30 BEJ
ND '
ND
43,200 *
17.7 j 57.3
6.5 B 14.2 '
33.5 81.8
28,300 9,350
25.6 * 30.6 S*
3,470 " 224.000
2.050 * 242 *
0.2
22.1
R
0.38 BWJ
ND
R
ND
26.4
97.3 E*
ND
0.3
95.5
R
ND
5.0 NJ
R .
ND
8.5 B
57.5 E*
ND
-------
-20-
TABLE 31 -
LEACHATE AND ASSOCIATED SEDIMENT-CONVENTIONAL ANALYSIS
Samples Collected by Camp Dresser & McKee Inc.
January 19.1988
Conventional
Parameters
Hardness (mg/I)
Alkalinity (mg/I)
TDS (mg/I)
TSS (mgl)
Sulfates (mg/I)
Nitrates (mg1)
Ammonia (mg'I)
TKN (mgl)
TOX (ug1) .
Total petroleum
Hydrocarbons (rog/I)
Oil and grease (mg/I)
BOD5(mg'l)
COD (mg/1)
TOC (mg/1)
North Seep
LE-1
3557-01 3557-01 F
unfiltered filtered
* *
i
341 NR
798 NR
1,390 NR
113 NR
14.7 NR
1.2 <0.1
75 NR
72.9 74.8
333 J 370 J
<1 NR
2.1J NR
88.5 67.2
2,280 940
116 107
North Seep
LE-2
. 3557-02 3557-02F
unflltered filtered
1,640 ' NR
2,000 NR
4,900 ' NR
406 NR
<5 NR
0.19 0.22
166 NR
180 180
369 J 359 J
7.9 NR
273 • NR
703 J 637 J .
3,500 J 5,600 J
1,920 1910
East Seep
LE-3
3557-03 5557-03F
unflltered filtered
49.8 NR
37.9 NR
126 NR '
9.5 NR
12.5 NR
"1.2 J 1.4
0.84 ' NR
1.2J 1.7J
14.5 J' 6S.1J
<1 NR
<1 NR
13.9 7.6
380 372
6.9 7.7
-------
-21-
TABLE 3J
LEACHATE AND ASSOCIATED SEDIMENT-CONVENTIONAL ANALYSIS
Samples Collected by Camp Dresser & McKee Inc.
January 19.1988
Conventional
Parameters
Hardness' (mg/I)
Alkalinity (mg/I)
TDS (mg/I)
TSS (mg'l)
Sulfates (mg'l)
Nitrates (mg/I)
Ammonia (mg'l)
TKN (mgl)
TOX (ugl)
Total petroleum
Hydrocarbons (mg/1)
Oil and grease (mg/I)
BOD5 (mg/I)
COD (mg'l)
TOC (mg/I)
Southeast
LE-4
Seep
3557-04 3557-04F
unflltered filtered
399
492
550
J12
14.8
0.17J
32.5
27.4
85 J
<1
<1
3.0
56
17.6
NR
NR
NR
NR
NR
0.51J
NR
. 26.8
94.9 J
NR
NR
3.4
56
17.6
LE-
3557-05
unflltered
•
482
924
1,150
125
15
0.53 J
78.5
R
236 J
<1
<1
17.3
164
43.2
South
5 •
,
3557-05F,
filtered
NR
NR
NR
NR
NR
0:91 J
NR
136
238 J
NR
NR
12.3
144
41
Seep
LE-5
duplicate
3557-06 5557-06F
unfiltered filtered
563
1,060
1.270
151
13
0.3 J
101
R
142 J
<1
<1
13.6
136
41.3
NR
NR
NR
NR
NR
1.1J
NR
482
152J
NR
NR
10.3 '
144
38.8
NR - The analysis was not requested by COM
R - Data was rejected. It did not pass EPA QA requirements
J - Data has been qualified as an estimated value
-------
-22-
TABLE 3K
Footnotes:
. R - Data was rejected. It did not meet EPA QA requirements.
LE • Aqueous portion of the leachate seep area.
SD - Sediment from the leachate seep area.
ND - Sample was not detected at the method detection limit.
B - The analyte was also detected in the blank.
• .
J - Data has been qualified as an estimated value.
E - Indicates an estimated value due to the presence of interferences.
S • Indicates the value was determined by Method of Standard Addition.
W - Indicates spike sample recovery is not within control limits.
N - Indicates matrix spike sample recovery is not within control limits.
* - Indicates the laboratory duplicate analysis is not within control limits.
-------
-23-
TABLE
Surface Water Samples - Organic and Inorganic Analyses
Samples Collected by O'Brien & Gere Engineers
Parameter
BOOS
Cadmium
Chloride
COD
Chromium
Iron
Mercury
Manganese
Nickel
Lead
PCB
pH
Phenol
Conductivity
Total Carbon
TIC
TOC
TOX-1
TOX-2
Zinc
Units
mg/l
mg/l
mg/l
mg/l .
mg/l
mg/l
mg/l
mg/l
mg/l
mg/l
mg/l
s.u.
mg/l
umhos/cm
mg/l
mg/l
mg/l
mg/l
mg/l
mg/l
Location
10/25/84
It 1
It 0.01
4
15
It 0.01
0.38
It 0.0005
0.12
It 0.01
It 0.01
It 0.0001
8.0
It 0.001
250
24
9
15
It 10
It 10
It 0.01
62
5/17/85
11
It 0.01
6
44
It 0.01
0.81
It 0.001
0.16
It 0.01
It 0.01
0.0005
7.1
It 0.001
240
24
4
20
It 10
12
It 0.01
Location 65
10/25/84 5/17/85
It 1 It 1
It 0.01 It 0.01
5 9
It 1 12
It 0.01 It 0.01
0.34 0.11
It 0.0005 It 0.001
0.10 0.06
It 0.01 It 0.01
It 0.01 It 0.01
It 0.0001 It 0.0001
8.1 7.2
It 0.001 It 0.001
440 370
24 28
12 16
12 12
It 10 It 10
It 10 It 10
It 0.01 It 0.01
Location 70
10/25/84 5/17/85
It 1 2
It 0.01 It 0.01
2 4
It 1 9
It 0.01 It 0.01
0.25 0.05
It 0.0005 It 0.001
0.14 0.02
It 0.01 • It 0.01
It 0.01 It. 0.01
It 0.0001 It 0.0001
8.1 7.2
It 0.001 It 0.001
430 370
14 34
10 15
4 !9
It 10 It 10
It 10 It 10
It 0.01 It 0.01
-------
-24-
5. Subsurface Gases
The lack of vents or manholes within the landfill precluded
sampling gases emanating from decomposing waste within the fill.
The detection of volatile organics within the landfill soils and
leachate leads to a preliminary hypothesis that gases may be
emanating from the landfill. There is a definite landfill odor
associated with the site. Sanitary landfills are known to contain
methane, a product of the decomposing waste. Limited air moni-
toring performed during the field activities did not detect volatile
organic compounds. A potential landfill gas problem has not been
identified to date.
EXPOSURE SCENARIOS FOR THE SITE
The following exposure scenarios have been developed to address
site conditions:
EXPOSURE TO CONTAMINATED SOILS
PCBs and VOCs were detected in the landfill borings and the
leachate. sediments. .PCBs were detected in the soils adjacent to
the south seeps. In the wetland areas, soil/sediment samples
were only analyzed for PCB contamination. The principal routes
of exposure to PCBs absorbed to soils at this site would be
through inhalation and ingest ion. Dermal adsorption may also
occur, however, PCBs sorb to soil particles thereby reducing
the dermal adsorption rate significantly. Because exposure to
subsurface soils In the landfill is highly unlikely, only exposure
to the PCBs in surface soils adjacent to the landfill and sediments
in the seep areas were considered in this assessment. As seen in
tables 5A-C, PCB concentrations at the site (excluding the landfill)
range from 2 to 482 ppm. It has been assumed for purposes of
this assessment that children who may enter the area through the
wetlands would be exposed to these areas. The daily exposure
over a lifetime was calculated using the frequency of contact
(10 events per year) and the duration of contact (6 years) averaged
over a 70 year lifetime. The lifetime intake was used to calculate
the incremental lifetime cancer risks. A risk of 4 x 10"? (4 out
of ten million) exists under the most probable case from dermal
contact with the PCB contaminated soil with a 5 x 10~5 risk
calculated for the worst case scenario. For ingestion of PCB
contaminated soil for the most probable and worst case scenarios,
the risks are 2 x 10"7 and 9 x 10~6, respectively.
-------
TABLE 5A
SOIL SAMPLES COLLECTED BETWEEN THE LANDFILL AND THE
PONDED WETLANDS1
Samples Collected by O'Brien & Gere Engineers
1984-1985
Sample No.
62
63
64
65
66
67
68
69'
76
76
77
77
78
78 .
79
79
80
80
82
82
83
83
83
86
86
87
87
88
88
89
89
90
Depth (inches)
c
C
c
c
c
c
c
21
0
52
0
20
0
39
0
21
0
20
•0
12
0
20
20 dup
0
58
0
21
0
0 dup
0
0 dup
0
«
PCS (total)*
(mg/kg wet weight)
"<1
19
7
<1
23
3
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
.<1
<1
<1
<1
<1
42
<1
<1
<1
<1
<1
<1
<1
52
»
Pets
total solids
,' 71.29
21.85
19.00
38.31
46.37
53.11
68.27
62.35
27.79
78.58
27.37
85.21
39.16
£2.37
26.00
61.45
22.41
42.38
45.01
72.12
37.82
82.99
81.17
15.43
56.89
80.33
82.58
79.73
86.62
59.80
81.59
NA
Calculated
PCB (total)
(mg/kg dry weight)
. , <1
87
37
<1
51
6
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1 '
<1
<1
<1
<1
<1
<1
<1
27
<1
<1
<1
<1
<1
<1
<1
NA
-------
-26-
TABLE 5B
SOIL SAMPLES COLLECTED BETWEEN THE LANDFILL AND THE
PONDED WETLANDS'
Samples Collected by O'Brien & Gere Engineers
1984-1985
Sample No.
90
90
91
91
91
92
92
93
93
94
94
96 •
96 i . •
97
97
98
98
99
99
99
100
100
100
101
102
102
103
103
104
104
105
105
Depth (inches)
0 dup
' 8
0
. , 0 dup
9
0
36
0
6
0
53
0
8
0
21
0
17
0
0 dup
17
0
0 dup
16
0
0
9
0
9
0
8
0
26
PCB (total)"
(mg/kg wet weight)
97
9.4
14
25
1.5'
<1
<1
<1
<1
<1
<1
4.2
<1
<1
<1
<1
<1
11
2.1
<1
3.1
1.1
<1
<1
2.6
<1
<1
<1
<1
<1
<1
<1
Pets
total solids
52.82
71.99
NA
63.18
78.22
70.79
83.75
89.33
87.29
29.66
49.11
35.39
73.75
62.85
76.93
87.14
85.35
17.36
NA
78.38
17.18
NA
85.50
26.05 .
53.18
60.41
39.53
46.12
50.55
72.65
23.41
65.32
Calculated
PCB (total)
(mg/kg dry weight)
184
13
NA
40
2
<1
<1
<1
<1
<1 .
<1
12
<1
-------
-27-
TABLE 5C
SOIL SAMPLES COLLECTED BETWEEN THE LANDFILL AND THE
PONDED WETLANDS'
Samples Collected by O'Brien & Gere Engineers
1984-1985
Sample No.
106
106
107
107
108
108
109
109
110
111
112
113
114
115
116
117
118
119
120
121
132
133
134
•
Depth (inches)
0
29
0
47
0
55
0
51
d
d
d
d
d
d
d
d
d
d
d
d
d
d
d
PCS (total)b
(mg/kg wet weight)
<1
<1
90
<1
<1
<1
<1
<1
2-7
-------
-28-
EXPOSURE TO LEACHATE SEEPS/SURFACE WATER
Children who access the site or wildlife which are in the
vicinity could come in contact with the leachate seeps located
around the landfill. Due to the type and concentration of the
contaminants detected in the leachate seeps, dermal absorption of
or inhalation of volatilized contaminants would not necessarily
by itself be expected to cause a risk to children or wildlife.
However/ activity in the seeps could release contaminants or
suspended contaminated sediments. Release of contaminants or
suspension of contaminated sediments could present a risk to -
children or wildlife who come in contact with the seeps. Because
the north side seep is not diluted by groundwater, this seep is
the most contaminated and risks from activity in this seep could
potentially be greater.
EXPOSURE TO AIR
There is a risk from inhalation of PCBs which volatilize from
the surface soil. This risk ranges from 8 x 10~7 to 2 x 10"^.
As expected, as the depth of PCS concentration increases, the
risks due to volatilization decrease.
EXPOSURE TO GROUND WATER
Currently the fill material is in contact with the groundwater
in some locations at the landfill. This presents a potential for
contaminants to leach from the fill to the groundwater and
migrate offsite. Presently, very few contaminants have been
detected in the monitoring well downgradient from the site.' It
may be possible that the plume may have skirted the present moni-
toring wells. Off-site groundwater contamination will be addressed
in the next operable unit and will include the possible installation
of additional monitoring wells for further groundwater investigations.
To determine the total risk to a child from the site the risks
from each exposure route can be added to obtain the total risk.
Adding the risks from dermal absorption, ingestion and inhalation
of PCBs from contact with the site gives a total risk of 1 x 10~6
for the most probable case and 6 x 10~5 for the worst case for the
assumption presented.
-------
-29-
Private wells located downgradient of the site were sample by the
New York State Department of Health (NYSDOH) and O'Brien & Gere.
They did not indicate contamination by the landfill, therefore/
no potential public health risk presently exists. An off-site
groundwater study will be conducted as part of the second operable
unit.
ENVIRONMENTAL ASSESSMENT
Under present conditions, infiltration of precipitation into the
landfill will continue. The potential migration of contaminants
within .the landfill will also continue. The leachate seeps would
remain. PCBs would remain in sediments where they would be bio-
accumulated within benthic organisms as well as transient organisms
inhabiting the areas surrounding the landfill and the wetlands.
Biota sampling conducted by the NYSDEC Division of Fish and
Wildlife has indicated the presence of PCBs in the biota in the
area.. Additional studies need to be performed to adequately
characterize the extent of PCB contaminants in the local biota.
In addition, the leachate seeps located north of the landfill
contain volatile organics which have leached from the landfill.
These contaminants may have an adverse impact on the local biota
which inhabit these areas. Fencing will minimize site access and
decrease the likelihood of either large domestic or wild terrestial
vertebrates contacting the leachate seep areas and PCB-contaminated
soils adjacent to the wetlands. However, it will not be effective
in preventing the wildlife from contacting the areas, or preventing
exposure in the food chain. Leachate seeps present at the site
have the potential to. be disturbed during activity around the
site or during heavy rainfall. Disturbance of these areas may
cause release of contaminants from the sediments to the water
column. Because the leachate areas east, southeast and south of
the landfill are flooded with surface and/or groundwater,
degradation of these water bodies could occur. This would result
in an adverse impact to aquatic life, vegatation and wildlife
that may use these areas as a water source.
Infiltration of precipitation would also increase the likelihood
of contaminants entering groundwater. Because part of the land-
fill is in contact with the groundwater, there is an additional
potential for contaminants to migrate into groundwater* Evidence
to date from monitoring wells located downgradient of the landfill
does not indicate contamination of groundwater. However, addi-
tional information is needed to determine if groundwater in the
area is being adversely impacted by the landfill. The impacts of
the landfill on off-site groundwater will be addressed in the
second operable unit.
-------
-30-
HEALTH ASSESSMENT
To assist in determining the impact of the site on public health
and the environment, the Agency for Toxic Substances and Disease
Registry (ATSDR) prepared a Health Assessment for the Ludlow
landfill. Human exposure pathway and public health implications
were defined accordingly:
.HUMAN EXPOSURE PATHWAYS
The contamination of the site may result in human exposure via
the following exposure pathways:
1. PCBs were detected in leachate from the landfill and in
sediment from the wetlands area. No PCBs were detected in
surface soils from the landfill area. Human contact with
PCB-contaminated sediments and leachate could result in PCB
exposures by ingestion or by dermal absorption. The uptake
•of PCBs by plants and animals in the wetlands area could also
result in human exposure, if biota from the wetlands were used
as food.
2. Residents near the site rely on private wells for their
potable water supply. Although these wells currently do not
contain detectable contamination, the potential migration of
contaminated groundwater from the landfill and wetlands
areas may result in contamination of these wells.
PUBLIC HEALTH IMPLICATIONS
PCBs were detected in leachate samples from the landfill and
in sediment samples from the wetlands at concentrations as
high as 482 ppm. On one occasion, PCBs were also detected
in water from two groundwater monitoring wells located
downgradient of the landfill.
Trespassers or children who play in the unfenced wetlands could
ingest small amounts of contaminated sediments or could absorb
PCBs through dermal contact with the sediments. There is
considerable uncertainty in estimating the amount of soil a child
ingests or the amount of soil-skin contact. Furthermore, PCBs are
strongly attracted to the organic matter in soil, and this
attraction would reduce their bioavailability. Because of these
uncertainties, it is not possible to accurately quantify the
health risks resulting from exposure to PCB-contaminated soil.
However, it is possible that long-term exposure to PCB-contaminated
sediments could increase an individual's lifetime risk of cancer.
-------
-31-
PCBs are lipophilic and are resistant to chemical and biological
degradation. Therefore, PCBs can bioaccululate significantly in
organisms living in a PCB-contaminated environment.
There were several potable, private wells located downgradient of
the landfill. Analyses of water samples from these wells did not
demonstrate any contamination. However, low concentrations of
PCBs (0.2 ppb and 0.3 ppb) were detected, on one occasion, in
water from two monitoring wells located hydraulically downgradient
from the landfill. In addition, several VOCs (methylene chloride,
1,1-dichloroethane) were detected in on-site soil borings and at
low concentrations (1 ppb) in monitoring wells. Water from
monitoring wells also contained chlorides, total dissolved solids,
total organic halides, and conductivity in excess of background
concentrations. These findings demonstrate that groundwater
downgradient from the site has been impacted by the landfill and
that future contamination of off-site private wells is possible.
Monitoring may be needed to detect this contamination, since low
level contamination of the wells might not be detectable by, odor
or by taste.
COMMUNITY RELATIONS HISTORY
Local government officials were informed of the investigations to '
be performed by the responsible parties after the original Admi-
nistrative Consent Order for the RI/FS was executed. During the
study, residential water, supplies were sampled and analyzed.
Routine questions from the local government officials were generally
handled through the NYSDEC, NYSDOH and NYSDOL. Public comment
has also been performed on the Final RI/FS report prepared by
Camp, Dresser and McKee. During the public comment period, a
public meeting was held on September 15, 1988 at the Sauquoit
High School located in the Town of Paris, Oneida County, New
York. The public comment period was extended to September 21,
1988. All pertinent documents were provided to the public in two
repositories located near the site. •
-------
-32-
Development of Remedial Action Alternatives
The objective is to develop alternatives that protect human
health and the environment and encompass a range of hazardous
waste management options for the Ludlow site.
Thirteen alternatives are presented in this section organized
into five catergories:
8 Category I - Limited-action alternative.
0 Category II - Source control/containment with little or
no treatment.
0 Category III - Alternatives that contain treatment as a
major component.
0 Category IV - Alternatives that lower the groundwater
table with little or no associated treatment and collect
water in contact with the fill material.
0 Category V - Alternatives that collect leachate for
treatment in an on-site treatment facility*
Table 6 presents these alternatives and their subcategories.
-------
-33-
TABLE 6
Remedial Action
Alternatives:
IIA
I IB
I IIA
IIIB
IIIC
Cost:
Description:
Limited Action with Restricted
Site access and land use
and water quality
monitoring.
Containment of contaminated
soil, sediment and leachate
from the landfill and seep
areas.
On-site consolidation of
contaminated soil and
sediment from the seep
followed by contain-
ment of contaminated soil
and sediment, leachate on
the landfill.
On-site thermal treatment of Capital $17,170,600
contaminated soils and sediment Ann. O&M $364,900
in the seep areas, off-site Pres. $22,780,000
disposal of treated soils
and sediments., off-site
treatment of wastewater and -
passive venting of landfill
gas.
Capital $350,700
Ann. O&M $ 81,100 *
Pres. $1,597,400 **
Capital $9,281,600
Ann. O&M $396,100
Pres. $15,370,600
Capital $8,939,500
Ann. O&M $364,900
Pres. $14,548,900
On-site thermal treatment of
contaminated soils and sedi-
ments from the seep areas,
on-site disposal of treated
soils and sediments, off-
site treatment of wastewater
and passive venting of land-
fill gas.
On-site thermal treatment of
contaminated soils and
sediments from the seep areas,
off-site disposal of treated
soils and sediment, on-site
treatment of wastewater
and passive venting of
landfill gas.
Capital $14,906,000
Ann. O&M $364,900
Pres. $20,515,400
Capital $15,883,200
Ann. O&M $364,900
Pres. $21,492,300
* Annual operation and maintenance costs
** Present worth: current value of capital expenditure and
operation and maintenance
-------
Remedial Action
Alternative:
-34-
TABLE 6 (continued)
Description:
Cost:
HID
IVA
IVB
VA
VB
On-site thermal treatment
of contaminated soils and
sediments from the seep
areas, on-site disposal
of treated soils and sedi-
ments, on-site treatment
of wastewater and passive
venting of landfill gas.
Initial landfill dewatering
with groundwater table
lowering using a passive
system with discharge to
the intermittent stream.
Initial landfill dewatering
with groundwater table
lowering using an active
system with discharge to
the intermittent stream.
Passive leachate collection
and treatment with discharge
to the intermittent stream.
Active Leachate collection
and treatment with discharge
to the intermittent stream.
Capital: $13,617,900
Ann. O&M: $364,900
Pres. $19,227,300
Capital: $4,404,000
Ann. O&M: $58,900
Pres. $4,945,400
Capital: $2,688,000
Ann. O&M: $67,600
Pres. $3,727,200
Capital: $1,877,500
Ann. O&M: $370,000
Pres. $9,777,400
Capital: $1,877,500
Ann. O&M: $370,000
Pres. $7,565,300
-------
-35-
SCREENING OF REMEDIAL ALTERNATIVES
The objective of Alternative Screening is to narrow the list of
potential alternatives (based on their effectiveness, implement-
ability, and cost) that will be evaluated in detail. The screening
process preserves a range of the most promising alternatives that
includes treatment as a major component, as well as the no-action
and containment alternatives.
EFFECTIVENESS
Alternatives are evaluated in terms of their effectiveness in
permanently reducing the toxicity, mobility and volume of hazardous
substances and in the expected degree of protection afforded to
human health and the environment.
IMPLEMENTABILITY
Alternatives are evaluated in terms of their technical feasibility
and the location, reliability and availability of technologies
considered. Included in this criterion are the ability to monitor,
maintain or replace technologies over time (operation and
maintenance) and the administrative feasibility of implementing
the alternative.
COST . ' •
Cost is an important factor when comparing alternatives which
provide similar results in terms of effectiveness and implementa-
bility. It provides a basis for discriminating among remedial
alternatives that contain treatment as a major component. Both
construction and long-term operation and maintenance costs are
evaluated. Alternatives that provide similiar treatment but require
substantially greater costs may be eliminated from further evalua-
tion. Cost is not used as a basis of comparision between the
no-action (Category I) or containment (Category II) alternative
and the (Category III) alternatives which involve treatment as a
major component.
Innovative technologies are carried through the screening process
if there is a reasonable assurance of better treatment performance
or implementability, fewer or less environmental impacts or
lower costs than other technologies for a similar level of perform-
ance.
Remedial Alternatives HIE and IIIF are not judged to be cost
effective, since they are substantially more costly than the
other category III alternatives while providing no greater level
of waste treatment or protection of public health and the en-
vironment.
-------
-36-
DETAILED ANALYSIS OF REMEDIAL ACTION ALTERNATIVES
As a result of the screening process, a total of five Remedial
Action alternatives are addressed, with four of these containing
subcategories, i.e., Alternatives II, III, IV and V. Listed
below is a description of each of the 5 alternatives and their
subcategories evaluated in the FS. This is followed by an evalu-
ation and comparison of the alternatives in terms of nine criteria
which relate directly to factors mandated by SARA including
512Kb) (d) (A-G). The nine criteria are:
1. Overall protection of human health and the environment
2. Compliance with applicable or relevant and
appropriate requirements (ARARs),
3. long-term effectiveness and permanence,
4. Reduction of toxicity, mobility or volume,
5. short-term effectiveness,
6. implementability,
7. cost-,
8. community acceptance,
9. state acceptance
-------
-37-
ALTERNATIVE I - LIMITED ACTION; RESTRICTED ACCESS AND LAND USE
AND WATER QUALITY MONITORING
This alternative consists of the following:
0 No on-site remediation;
0 Implementation of site security measures which include a
six-foot high chain link fence, and warning signs to
restrict access;
0 Air and water quality monitoring which includes quarterly
sampling and analysis of surface water, groundwater and
private and public potable water supply wells for Target
Compound List (TCL) compounds;
0 Property deed restrictions to limit future site development;
0 The estimated total present worth cost is $1,597,400.00.
Alternative IIA - CONTAINMENT OF WASTE AND CONTAMINATED SOIL AND
SEDIMENT, TREATMENT OF LEACHATE AND PASSIVE
VENTING OF LANDFILL GAS
This alternative consists of the following:
0 Implementation of all activities required for Alternative I;
0 Site preparation including removal of existing vegetation,
regrading the site and applying the final cover layer;
0 Installation of surface and shallow groundwater drainage
diversion systems.
0 Pumping and collecting leachate from seepage pools;
0 Transportation of leachate to an off-site facility for
treatment and disposal;
0 Implementation of a soil boring program to more accurately
determine the boundaries of contamination and volume of
soil remediation;
0 Installation of a passive landfill gas venting system;
0 Installation of a low permeability landfill -cap;
0 The estimated total present-worth cost is $15,370,600.
-------
-38-
ALTERNATIVE IIB - ON-SITE CONSOLIDATION OF CONTAMINATED SOIL AND
SEDIMENT FROM THE LEACHATE SEEP AREAS FOLLOWED
BY CONTAINMENT OF CONTAMINATED SOIL AND SEDIMENT,
TREATMENT OF LEACHATE AND PASSIVE VENTING OF
LANDFILL GAS
This alternative consists of the following:
0 Implementation of all activities required for Alternatives I
and IIA
0 Consolidation of the contaminated soils and sediment from
the leachate seep areas on the landfill surface prior to
installation of a RCRA Subtitle C low permeability cap;
0 The estimated total present-worth cost is $14,54-8,900.
The difference in this alternative is that the landfill cap would be
extended to the graded landfill boundary, but would not extend
over the leachate seep areas. Contaminated materials would be
consolidated with the existing landfill surface. The leachate
seepage areas would be cleared prior to consolidation. The
excavated areas would be backfilled with clean soil , regraded
and seeded.
ALTERNATIVE IIIA - EXCAVATION AND ON-SITE-THERMAL TREATMENT OF
CONTAMINATED SOILS AND SEDIMENTS FROM LEACHATE
SEEP AREAS, OFF-SITE DISPOSAL OF TREATED
' SOILS AND SEDIMENTS, OFF-SITE TREATMENT OF
WASTEWATER AND PASSIVE VENTING OF LANDFILL
GAS.
This alternative consists of. the following:
0 Implementation of all activities required for Alternative I;
0 Implementation of Alternative IIA except the cap would be exten-
ded only to the graded landfill, and not over the leachate
seepage areas;
0 Initiation of a soil boring program to more accurately determine
the boundaries of contamination and volume of soil requiring
remediation;
0 Excavation of contaminated soil and sediment in the seep areas;
0 Backfilling of excavated seepage areas;
0 Construction of a storage lagoon to receive leachate and runoff
from the soil staging area;
0 On-site thermal treatment of contaminated soil and sediment;
-------
-39-
0 Off-site disposal of treated soil and sediment and water;
0 Decontamination of all excavation and processing equipment on
site;
0 The estimated total present-worth is $22,780,000.
ALTERNATIVE IIIB - EXCAVATION AND ON-SITE THERMAL TREATMENT OF
CONTAMINATED SOILS AND SEDIMENTS FROM LEACHATE
SEEP AREAS, ON-SITE DISPOSAL OF TREATED SOILS
AND SEDIMENTS, OFF-SITE TREATMENT OF WASTEWATER
AND PASSIVE VENTING OF LANDFILL GAS.
This alternative is essentially identical to the Alternative IIIA
with the exception that the disposal of treated soil would be done
on-site.
The estimated total present-worth cost is $20,515,400
ALTERNATIVE IIIC - EXCAVATION AND ON-SITE THERMAL TREATMENT OF
CONTAMINATED SOILS AND SEDIMENTS FROM LEACHATE
SEEP AREAS, OFF-SITE DISPOSAL. OF TREATED SOILS
AND SEDIMENTS, ON-SITE TREATMENT OF WASTEWATER
• AND PASSIVE VENTING OF LANDFILL GAS
This alternative is essentially, identical to Alternative IIIA with
the exception that treatment of leachate and surface runoff would
be performed on-site.
The estimated total present-worth cost is $21,492,300
ALTERNATIVE HID - EXCAVATION AND ON-SITE THERMAL TREATMENT OF
CONTAMINATED SOILS AND SEDIMENTS FROM LEACHATE
SEEP AREAS, ON-SITE DISPOSAL OF TREATED SOILS
AND SEDIMENTS, ON-SITE TREATMENT OF WASTEWATER
AND PASSIVE VENTING OF LANDFILL GAS
This alternative is essentially identical to Alternative IIIC with
the exception that disposal of treated soils and sediments would be
done on-site.
The estimated total present-worth cost is $19,227,300
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ALTERNATIVE IVA- INITIAL LANDFILL DEWATERING WITH GROUNDWATER
TABLE LOWERING USING A PASSIVE SYSTEM WITH
DISCHARGE TO THE INTERMITTENT STREAM
This alternative consists of the following:
0 Installation of a landfill leachate dewatering
system;
0 On-site treatment of leachate/ground water;
0 Installation of subsurface drains to maintain
the separation of the groundwater from the
waste;
0 Discharge of collected and treated groundwater
to the intermittent stream;
0 The estimated total present-worth cost is $4,945,400.
ALTERNATIVE IVB- INITIAL LANDFILL DEWATERING WITH GROUNDWATER
TABLE LOWERING USING AN ACTIVE SYSTEM WITH
DISCHARGE' TO THE INTERMITTENT STREAM~~7
This alternative is essentially identical to IVA with the exception
that extraction wells would be used to lower the groundwater table
to prevent the water from contacting the waste. The extraction
system would then be used to maintain this lower groundwater
table.
The estimated present-worth cost is $3,727,200.
ALTERNATIVE VA- PASSIVE LEACHATE COLLECTION AND TREATMENT WITH
DISCHARGE TO THE INTERMITTENT STREAM
This alternative consists of the following:
0 Installation of subsurface leachate collection
drains (trench or pipe subsurface drains);
0 On-site treatment of leachate and groundwater;
e Discharge to the intermittent stream;
0 The estimated total present-worth cost is $9,777,400.
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ALTERNATIVE VB- ACTIVE LEACHATE COLLECTION AND TREATMENT WITH
DISCHARGE TO THE INTERMITTENT STREAM
This alternative consists of the following:
0 Installation of subsurface leachate collection
wells (extraction well system);
0 On-site treatment of leachate and groundwater;
0 Discharge to the intermittent stream;
0 The estimated total present-worth cost is
$7,565,300.
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SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
Overall Protection of Human Health and the Environment
The limited action alternative (I) is not considered to be
protective of human health and the environment, except for the
added protection that would be afforded by limiting site access by
the use of site security measures. The public health threat
would still exist from exposure to the contaminated soil, sediments
and leachate seep areas. No control would be instituted to
minimize groundwater contact with the waste, therefore, contaminants
would be transported to the principal aquifer below the site.
Installation of a high quality impervious/multi-layer cap over
the landfill and the leachate seep areas (IIA) or installation
of a cap coupled with consolidation of sediments and soils from
the seep area to an area under the cap (IIB) will reduce the
amount of potential leachate generated by infiltration of rain
water through the landfill.
»Restriction of site access and installation and maintenance of
the impervious cap will.substantially decrease direct contact
with landfill soils and sediment. Potential adverse impacts will
also be reduced by eliminating landfill leachate seeps by reducing
the infiltration of rainfall into the landfill, and the venting of
landfill gas.
The public health impacts for treatment of contaminated soil/sediment
from the seeps area (Alternative IIIA-D) are similar to those
described above. Under these alternatives, contaminated
soils/sediment from the seepage areas and near the wetland will be
treated instead of capped in place (IIA) or consolidated and put
under the cap (IIB). Dermal contact of soil/sediment from
the landfill and seep areas will be eliminated.
If capping alone does not depress the water table below the lowest
point of refuse deposition, further lowering of the groundwater
table through the use of upgradient groundwater controls (Alternatives
IVA-B) will reduce the mechanism for transport of contamination
from the landfill.
If additional field studies confirm the presence of a groundwater
mound beneath the landfill surface, initial dewatering of the
landfill will reduce the risk of future groundwater contamination
at the site by controlling the release of potentially contaminated
leachate from the landfill. Rather than allowing uncontrolled
flow of the mounded groundwater from the landfill into the under-
lying aquifer, dewatering will remove the material in a controlled
and environmentally sound manner. Combined with capping of the
landfill, which would eliminate dermal contact of contaminated
soil, the impacts on public health and the environment will be
greatly reduced in an effective, controlled manner.
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Installation of a leachate collection system (Alternative VA and
VB) will achieve a similar reduction of risk to the public and
the environment as the dewatering and groundwater table lowering
option. Combining this alternative with the capping option
will reduce the potential for dermal contact and inhalation of
the contaminants.
Compliance with ARARs
The limited action Alternative (I) does not meet the ARARs for
the site nor fulfill the requirements which would apply to the
site for source control action as it does not eliminate the
potential for exposure due to dermal contact, inhalation and
ingestion of the contaminated material.
The containment alternatives (IIA and IIB) would meet the ARARs
for this site. They consist of New York State Hazardous Waste
Management System (6 NYCRR Part 370-373) and RCRA Subtitle C
closure requirements. Treated effluent from on-site or off-site
treatment facilities would meet all ARARs (ie., NYCRR Part 703.6 •
703.7, TOG 1.1.1, 6 NYCRR Parts 750-757 and 700-705) prior to
discharge.
•Alternatives IIIA-D will meet all ARARs. The ARARs required •
for land disposal of treated soil and sediment are the RCRA
treatment standards applicable at the time of remedial action.
Thermally treated materials at the site would be in compliance
with the set standards.
Dewatering, groundwater table lowering and leachate collection
system options will meet ARARs established for the site. These
include the New York State Pollution Discharge Elimination
System (SPDES), Ambient Water Quality Standards and Guidance
Values and Freshwater Wetlands Act for the treated effluent
from the treatment plant.
Long-Term Effectiveness and Permanence
Capping and treatment of the contaminated soil/sediment from
the seep areas are expected to substantially, reduce the volume
and mobility of contaminated leachate emanating from the landfill
resulting from rain water permeating the cap. However, capping
alone may not prevent leachate generation resulting from ground-
water passing through the waste. Therefore, dewatering followed
by groundwater table lowering (Alternatvie IVA-B) will ensure the
mounded groundwater currently saturated in the waste will be ex-
tracted and treated. The groundwater table lowering will ensure
that any lateral flow to the landfill will be intercepted. The
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groundwater table lowering system would also maintain the
groundwater table so it would not be in further contact with
the waste.
A leachate collection system (Alternative VA and B) will provide
a moderate level of long-term effectiveness because waste will
remain as a potential source of contamination. The leachate
collection system will be operating indefinitely because
the waste will always be in contact with the groundwater
as opposed to dewatering the existing contaminated ground-
water and maintaining the groundwater table so it will not
be in contact with the waste.
The integrity and longevity of the landfill cap, dewatering
system and/or leachate collection system should be assured
under the required 30-year post-closure operation and maintenance
plan. Long term monitoring and maintenance includes a 30-year
post closure groundwater monitoring program, inspection and
repair of security access-control and vegetative cover as
necessary. Monitoring of surface water, groundwater and re-
sidential wells will ensure detection of potential threats to
human health.
Reduction of Toxicity, Mobility and Volume
The evaluation criterion dealing with the reduction of toxicity,
mobility or volume of contaminants is applied only to alternatives
having waste reduction/treatment components. Alternatives IIA
and IIB do not include any treatment. Alternatives IIIA-D would
involve thermal treatment of the contaminated soil/sediment in
the seep areas. Thermal treatment would reduce toxicity, since
organics would be destroyed and it would also reduce mobility.
Depending on the organic content of the sediments in the seep
areas, the volume of soil could also be reduced. Alternatives
IVA-B and VA-B would involve treatment of leachate extracted
groundwater before discharge. These alternatives involve treat-
ment which would significantly reduce toxicity/ mobility and
volume of the contaminants.
Short-Term Effectiveness
If the presence of a groundwater mound within the landfill is
confirmed by additional field studies, a dewatering system
(i.e. Alternatives IVA or IVB) would be more effective in the
short term. Active dewatering would lower the water table
more quickly, which would enable the remedy to be effective
within a shorter time frame.
There are some short-term risks posed with Alternatives IIA-B and
IIIA-D during construction. Grading the landfill could result
in releases of dust to the atmosphere. Traffic flow along the
neighboring roads would increase because trucks would carry
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materials for construction of the cap, etc. However, dust
suppression techniques can be implemented. Construction impacts
to on-site workers who come in direct contact with contaminated
soils or wastes during construction activities can be minimized
through the use of personal protection equipment.
Short-term risks associated with Alternatives IVA-B and VA-B
occur during the installation of the landfill dewatering system,
and leachate collection system. Both consist of drilling into
the landfill which might pose an unknown hazardous situation to
the workers. However, these risks can be mitigated by imple-
mentation of a comprehensive site health and safety plan and
use of proper construction techniques and engineering controls.
Implementability
The implementability of each alternative is based on the technical
feasibility, administrative feasibility and the availability of
services and materials for the alternative. All of the alterna-
tives are technically feasible. Although the alternatives are .
technically feasible, the characteristics of the intermittent
stream may present design problems relative to the amount and
quality of water that can be discharged to the stream. All
alternatives involve technologies which have been used regularly
in the past for hazardous waste landfills and have demonstrated
performance records. All the alternatives are administratively
feasible. Treated effluent from the dewatering, groundwater
table lowering system and leachate.collection system is expected
to meet SPDES requirements for discharge to the stream. An
on-site thermal treatment unit will have a destruction efficiency
of 99.9999%. (This is based on destruction of PCBs). Redisposal
of the treated materials would comply with RCRA standards.
Cost
A summary of the costs for each alternative is provided in
Table 6.
Alternative IIIA-D are not expected to offer significant increases
in protectiveness to public health and the environment or short-
term efectiveness or long-term effectiveness for the increased
cost.
State Acceptance
The New York State Department of Environmental Conservation
concurs with the selected remedy.
Community Acceptance
The community supports the selected remedy. During the public
comment period, only the Potentially Responsible Parties (PRPs)
submitted written comments; these comments are addressed in the
attached Responsiveness Summary.
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Selected Remedy
The selected remedial alternative for operable unit one was
arrived at by evaluating the remedial alternatives presented in
the feasibility study prepared by COM as the most appropriate
solution for meeting the requirements established in the Comp-
rehensive Environmental Response/ Compensation/ and Liability Act
of 1980 (CERCLA), 42 U.S.C. Section 9601 et seq. / as amended by
the Superfund Amendments and Reauthorization Act (SARA)/ and the
requirements of its governing regulations/ the National Oil and
Hazardous Substances Pollution Contingency Plan (NCP) 40 C.F.R.
Part 300.
The selected remedy for the Ludlow Sand & Gravel site consists of
a modification of Alternative IIB combined with Alternative IVA
or IVB. This remedy consists of the following components:
1. Prior to installation of the landfill cover, approximately
10,000 cubic yards of contaminated soil and sediment adjacent
to the landfill will be consolidated into the landfill.
During design, a soil/sediment sampling program will be
implemented to fully define the area to be consolidated
under the landfill cover.
2. An impermeable cover will be installed over the landfill
to control runoff and minimize infiltration of .water.
This cover will comply with closure requirements of RCRA
Subtitle C (40 CFR Section 264.310).
3. Leachate from leachate seepage areas and residual leachate
formed from the landfill will be collected (see Figure 3).
4. Dewatering the landfill by using either a passive drain
system or an active well system. Details of the dewatering
system will be determined during pre-remedial design
field activities. If it is determined during pre-design
field activities that there is no groundwater mound
in the landfill or if the water in contact with the fill
material is not contaminated, the dewatering may not be
implemented.
5. Upgradient groundwater controls will be implemented to
lower and maintain the groundwater table from being in
in contact with the waste material. The details of a
passive or active groundwater table lowering system will
be determined during the pre-remedial design field
activities. If the cap alone lowers the groundwater
table below the fill material, upgradient groundwater
control of the groundwater may not be implemented.
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Site Properly Boundary
Landfill Boundary
LEGEND:
L_J Ponded Wetland
Iteachale Seepage Area
lOOOlOO
Security Fence
scale feet
SOURCE: O'Brien And Gere
I
•C-
^J
I
COM
environmental «rqin^«it
planner* A mtnttgatniini
Figure 3-
Area Of Restricted Access
Ludlow Sanitary Landfill Site, Town Of Paris. New York
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6. If dewatering of the landfill is implemented / treatment
of the collected contaminated leachate/groundwater will be
performed at an on-site facility. Alternatively,
if dewatering is not necessary and the volume of water
is small, the leachate .will be collected and transported
off-site to a permitted disposal facility that will
accept the waste. The effluent from an on-site treatment
plant will be discharged to an intermittent stream.
7. Perimeter fencing (including the wetlands) will be installed.
8. In accordance with New York State Law, deed restrictions
governing future use of property will be duly filed.
9. A long-term water quality monitoring program will be
implemented which will include quarterly monitoring of
on-site and off-site groundwater, surface water and
potable water supply wells.
10. Since this remedy will result in hazardous substances
remaining on-site, a review will be conducted every
five years after commencement of the remedial action
to ensure that the remedy continues to provide adequate
protection of human health and -the environment.
STATUTORY DETERMINATION
Protection of Human Health and the Environment
The selected remedy will protect the public health and the en-
vironment primarily by separating the source .of contamination
from potential routes of exposure. Installation of the
multi-layer impermeable cap will effectively prevent exposure
of the public to the landfill materials. The cap, in conjunction
with the control of the groundwater/leachate in the landfill,
is expected to be effective in stopping further leachate seeps
and groundwater contamination. The cap also prevents infiltration
of precipitation into the landfill which is the major contributing
source of water to the landfill. Other potential routes of
exposure (i.e. dermal contact, ingestion, inhalation of contaminants)
from the Ludlow site will be mitigated by this remedy.
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There will be short-term risks involved in this remedy during the
on-site consolidation of contaminated soil, construction of the
cap, construction of the dewatering system and groundwater/residual
leachate controls. During the construction period, traffic flow
and fugitive dust will increase. These potential risks will be
reduced by the implementation of a comprehensive health and
safety plan that addresses the safety of workers and receptors
during remedial activites at the site.
Attainment of ARARs
The selected remedy will attain all applicable or relevant and
appropriate Federal and State requirements.
New York State Hazardous Waste Management System (6 NYCRR Part
370-373) and RCRA Subtitle C are considered relevant and ap-
propriate for the closure of the Ludlow site. These regulations
affect all aspects of hazardous waste management for the site.
They involve treatment, storage, or disposal of .hazardous wastes
originating from the Ludlow site.
Treated effluent will be discharged to the stream unless there is
an impact to the wetland. Treated effluent for discharge will be
designed to meet substantive requirements of the New York State
Pollution Discharge Elimination System (SPDES) (6 NYCRR Parts
750-757 and 701.5), Technical Operations Guidance Series (700
1.1.1.) Ambient Water Quality Standards and Guidance Values
(April 1987) and all groundwater and surface standards, and
Freshwater Wetlands (6 NYCRR Part 663-665). An environmental
assessment wil.l be performed to help meet the substantive require-
ments of SPDES.
Air emissions will comply with the New York State Air Pollution
Control Regulations (6 NYCRR Part 201,202 and 219).
Although not an ARAR, the TSCA PCB Spill Cleanup Policy Final Rule
(40 CFR 761) provides useful guidance for remediating sites with
PCB contamination. The TSCA policy established requirements for
decontaminating spills in both restricted and nonrestricted access
areas. A cleanup level of 10 ppm of PCBs is established for this
area. Soil will be excavated to a minimum of 12" and replaced
with clean fill and vegetated.
Cost Effectiveness
The selected remedy will provide an overall effectiveness pro-
portionate to its cost such that it represents a reasonable value
for the money.
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RESPONSIVENESS SUMMARY
LUDLOW SAND AND GRAVEL SUPERFUND SITE
TOWN OF PARIS, NEW YORK
September 29, 1988
Prepared by:
U.S. Environmental Protection Agency
Region II
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RESPONSIVENESS SUMMARY
FOR THE PROPOSED REMEDIAL ACTION
AT THE LUDLOW SAND AND GRAVEL SITE
TOWN OF PARIS, NEW YORK
I. Introduction
In accordance with U.S. Environmental Protection Agency's (EPA)
Community Relations policy and guidance, EPA's Region II Office
held a public comment period from August 31, 1988 to September 21,
1988 to solicit comments on remedial alternatives for the Ludlow
Sand and Gravel Superfund site. As part of the selection process,
Region II published a proposed remedial action plan (PRAP) describing
EPA's preferred alternative and issued a public notice announcing a
public meeting.
EPA, in conjunction with the New York State Department of Environ
mental Conservation (NYSDSEC) on the New York State Department of
Law (NYSDOL) held the public meeting to present the PRAP on September
15, 1988 at the Sausquoit Valley Central School. Aprroximately 50
community members attended, along with several State and local
officials. Copies of Uie PRAP were distributed at the meeting and
were available in the two information repositories. Before receiving
public comment, the Agency provided a brief overview of the Ludlow
Sand and Gravel Superfund.site, the decision-making process, the
findings of the Remedial Investigation/Feasibility Study, and the
preferred alternative. Community members were then invited to
submit comments and questions to the officials present at the meeting.
The purpose of this Responsiveness Summary is to document EPA
responses to comments and questions raised during the public comment
period. EPA officials were joined in some of the responses at the
public meeting by State and local officials.
II. The Proposed Remedy
A. Containment
1. A local official asked if there would be any problems with
consolidation of PCB-contaminated soils and sediments
on the landfill.
EPA Response; No. One reason for consolidating these
materials on the landfill itself is cost. The con-
solidated materials actually have lower levels of PCB
contamination than the landfill material.
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2. A local official asked for the expected duration of the
intermediate cap.
EPA Response: The exact time has not been established
yet because it is necessary to determine how much the
intermediate cap sinks. Use of the intermediate cap
will prevent the permanent cap from being damaged due to
anticipated sinking. (Note: Dean Sommers stated the
final cap would be constructed within 1 year)
3. One citizen asked if the percentages of leachate from
precipitation versus groundwater were known. .H_e>,-. -•-
expressed concern that a landfill cap may not completely
stop migration of contaminants.
EPA Response: A water budget has been developed for
the landfill and approximately 24,000 gallons per day is
entering the 18 acre landfill. In addition to capping
the landfill, the PRAP also calls for a "groundwater
cut-off" to divert or actively pump upgradient groundwater
to further lower the water table, if necessary to eliminate
contact of the groundwater with the landfill. The
specific methodology to be used will be determined in the
upcoming pre-design stage.
B. Groundwater
1. A local official asked if the information in the Proposed
Remedial Action Plan (PRAP) was correct concerning the
lower cost and better reliability of the active system
for lowering the groundwater table level relative to the
passive system. He stated that the community preferred
the active system. He also asked if there was
flexibility in locating an on-site treatment facility.
EPA Response; The answers to both questions are yes.
EPA believes that the active system is less costly and
more reliable than a passive system. This does not mean
that a passive system would not be effective in dewatering
the groundwater in the landfill.
The location of the treatment system shown on the PRAP
is conceptual; the actual location will be based on the
design and field conditions.
2. A resident asked if the dewatering which could occur
during remedial activities for this operable unit would
affect studies for the second operable unit.
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_ "7 _
EPA Response; This situation is currently being addressed.
There will be close coordination among the parties
performing both operations to minimize any effects. It
is highly likely that the groundwater studies for the second
operable unit will be completed prior to the dewatering
operation.
3. One resident asked how deep the groundwater diversion
would extend.
EPA Response; At its highest elevation, the landfill is
approximately 40 feet deep. Any diversion would extend
at least below the landfill bottom. Specifics will be
worked out in the design stages and will be based upon
additional subsurface investigations.
C. On-Site Treatment
1. One attendee asked for a description of thermal treatment.
EPA Response; Thermal treatment is high temperature
treatment, (e.g. incineration) one of the ways employed
to destroy PCBs. Thermal treatment will decrease the
quantity, toxicity and mobility of PCB contamination.
2. A citizen asked where wells 5D and 6S (cited in the PRAP)
are located. He also asked where the intermittent stream
cited in Alternatives IIIC and HID is located, and for
more details about potential discharges.
EPA Response; The location of the wells was indicated
on a map from the CDM Supplemental Remedial Investigation/
Feasibility Study Report, which is available to the public
at the information repositories. The intermittent stream
was also identified on the same map and described as
flowing through the wetlands. Pre-design studies will
determine the volume to be discharged for each alter-
native. If the volume of water was determined to be too
large for the stream to handle then the discharge would
not be allowed through the wetlands. Rather, the dis-
charge will be diverted or circumvented around the
ponded wetlands to ensure that contaminated sediments
in this pond would not be disturbed.
A local resident asked whether on-site treatment facilities
might compromise safety, especially if additional wastes
were generated.
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EPA Response: Treatment systems are designed to have
minimal environmental effects. In addition, all con-
taminants resulting from the treatment process will be
disposed of off-site (the exact destination to be deter-
mined by the nature of the contaminants) and effluents
will meet minimum quality standards. Only the surrounding
soils and sediments which are less contaminated than
the landfill material will remain on site.
D. Other
1. A resident expressed concern about the Clayville Public
Water Supply, which is hydraulically downgradient from
the site, and asked if there were any plans to monitor
this supply.
EPA Response: The Oneida County Health Department and
the New York Department of Environmental Control have taken
a "broad look" at local water supplies and found them to
be unaffected. A plan currently under consideration would
have monitoring wells installed between the landfill and
nearby residences which would detect off-site migration
of contaminants.
2. A local official asked if time frames could be provided
for remedial activities. He also questioned whether the
set-aside fund established roughly 1 year prior to the
landfill's closure could be used to initiate action as
soon as possible.
EPA Response; If EPA undertakes remediation, the design
• work will start in January, 1989; actual construction
would begin in approximately Spring of 1990. DEC Response;
It is estimated that if the responsible parties undertake
remediation, design work would begin in April 1989 with
construction starting in Summer or Fall 1989. The final
decision as to whether or not the responsible parties
will undertake the response should take place within
the next 4 weeks. Use of the set-aside fund would not
noticeably speed up the process since more information
and design work is needed before actual construction
begins (if all information needs" were currently satisfied,
EPA could use Superfund monies to initiate remedial
activities). In addition, the fund only contains roughly
$500,000, which will not cover many of the costs involved.
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III. Contamination Concerns
A. Groundwater
1. A local official requested that EPA monitor municipal
wells for all chemicals of conern, which may not be
included in current testing regimes.
2. A resident who lives within a mile of the site expressed
concern over the frequency of well testing and asked
what levels of contamination are "acceptable."
EPA Response: A private well survey was conducted by the
Oneida County Health Department in 1984, with more tests
done in 1986, 1987 and 1988 (the Health Department is
not involved with "monitoring", i.e., continual sampling).
Survey results have not indicated any groundwater
problem. Some residential samples had elevated levels
of iron and manganese, but the results could be due to
natural processes. No volatile organic compounds (VOCs)
were found. Acceptable levels are guidelines below
which treatment is not required by law. County Health
Department Response; Residents with an indiction of a
problem are urged to contact their County Health Depart-
ment.
B. Extent of Contamination
1. A local resident asked if the extent of contamination
below the site was known.
EPA Response; No, it is not known how far down the
contamination extends. A separate study (Operable Unit
2) will be performed to establish how far any contaminated
groundwater has migrated from the site. If additional
field studies confirm the presence of a groundwater
mound beneath the landfill surface, initial dewatering
of the landfill will reduce the risk of future ground-
water contamination at the site by controlling the release
of potentially contaminated leachate from the landfill.
Rather than allowing uncontrolled flow of the mounded
groundwater from the landfill into the underlying aquifer,
dewatering will remove the material in a controlled and
environmentally sound manner. Combined with capping of
the landfill, which would eliminate dermal contact of
contaminated soil, the impacts on public health and the
environment will be greatly reduced in an effective,
controlled manner.
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2. One citizen and a local official asked if contaminants
left on the site a long time ago would be detected.
EPA Response; There is a possibility that contaminants
that left the site a long time ago may not have been
detected. Usually these materials leave a trace of
contamination that would be detected in the monitoring
wells. PCBs, in particular, tend to adsorp to soil,
and do not migrate very far.
C. Air Pollution
1. An attendee asked if there was any indication of air
pollution.
EPA Response; Air monitoring performed during the
Remedial Investigation found no off-site contamination
using HNu and/or OVAs. Elevated levels were found at the
soil borings immediately after boring in the landfill.
However, at the breathing zone these values were signi-
ficantly reduced. A survey of the site with a HNu did
not detect levels of gross contamination. No Air
have been collected to date. '
D. Health Effects
1. A citizen requested more detailed information on the
health effects of the volatile organic compounds (VOCs)
mentioned in official opening statements.
EPA Response; Both carcinogenic and non-carcinogenic
compounds were found in the leachate seeps and the land-
fill. Camp, Dresser & McKee Inc. (CDM, a contractor for
EPA) has performed an endangerment assessment to evalu-
ate health risks associated with these compounds. At
present the seeps do not pose a risk due to limited
potential for contact. There is a potential for risk
should the sediments be disturbed and resuspended into
the water column or should the seeps become more
accessible.
E. Off-Site
1. A citizen asked whether off-site contamination had been
found in the gravel pit. Because gravel is still being
sold commercially, he expressed concern about possible
off-site transportation of contaminated materials.
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DEC Response; Gravel is not being sold from the pit in
question. Commercially sold sand and gravel come from
an area located farther north on Holman City Road. At
this time, there has been no indication of PCB-contam-
inated deposits in the gravel pit and the responsible
parties are conducting further investigations. PCBs have
been found in an area north of the gravel pit. This area,
along with the wetlands and gravel pit, will comprise
the second operable unit. The present meeting, however,
focuses on remedial alternatives for the first operable
unit — source control management of the landfill.
2. A member of the community asked if there has been any
indication of wetlands contamination. In addition,
since the wetland is located between the landfill and
the surrounding community, he questioned why remediation
efforts were not directed from the "outside in."
EPA Response: PCBs have been found in the wetland and a
fence surrounding the wetland is included in the plans for
the first operable unit. The division of tasks into
operable units allows the government to undertake certain
activities before information is obtained on all aspects
of the site. The PRPs are currently conducting addit-
ional studies in order to better determine the degree
of contamination in the wetlands. This'additional
information will be incorporated into plans for the second
operable unit. Remediation efforts are being directed
to eliminate the continuing source of contamination as
a first step. Once the source is eliminated conditions
should not deteriorate "outside" and efforts to define
and correct "outside" problems can be .implemented.
3. One local resident wanted to know how the landfill's
location on a groundwater recharge zone relates to the
quality of Sauquoit Creek; more specifically, is it
still safe to fish in the creek?
DEC Response; A groundwater recharge zone is a geo-
logical statement. A principal aquifer is composed of
sand and gravel deposits of considerable depth with the
ability to hold and release water. New York State
keeps track of all aquifers which could provide drinking
water and monitors land use for their protection. PCBs
were found in two samples taken next to the landfill,
but the results could not be duplicated. If PCBs are
not found, it is unlikely they have traveled one mile
away to Sauquot Creek. Furthermore, PCBs tend not to
migrate very far through soil. Therefore, it is still
safe to fish in the creek.
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4. A resident inquired about the contents of the Kehoe Road
Dump.
EPA Response; The Kehoe Road Dump is located near the
Ludlow complex and was used for construction and demo-
lition debris. Although the Kehoe Road Dump hasn't been
tested, there is no evidence that hazardous substances
were disposed of at this location.
5. A community member wanted to know who has jurisdiction to
"spot check" a nearby ravine for illegal dumping, and if
anyone has checked this particular location.
EPA Response; The NYSDEC has enforcement officers in
every region of the State. If anyone knows of or suspects
illegal dumping, they are urged to contact the appro-
priate DEC region. The ravine in question was checked
on May 11, 1988 by a NYSDEC regional inspector.
IV. General Questions and Comments
A. Responsible Parties
1. A lawyer representing the Ludlows asked that the status
of legal actions be explained.
State Response; New York State commenced a lawsuit
against the Ludlows following the principle of joint/
several liability. The Ludlows, in turn, sued other
Potentially Responsible Parties (PRPs) including
Chesebrough Ponds, Utica Cutlery, and Special Metals.
Because Superfund deals with hazardous substances and
wastes, anyone who generated hazardous substances at the
Ludlow site can be a PRP.
2. A lawyer representing the Ludlows asked about the policy
on household hazardous waste.
EPA Response; The Ludlow site is listed on the NPL
because of the disposal of hazardous wastes and hazardous
substances by industrial generators. CERCLA defines
PRPs as that individuals who generate, or transport
hazardous substances to the site, along with current
and past owners and operators. EPA does not currently
consider municipalities generating solely household
waste to be responsible parties at the Ludlow site.
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B. Other
1. One attendee asked if migration problems detected in
the future would be- addressed and what sort of timetable
would be ivolved?
EPA Response; Yes, operable unit 2 is designed to
address problems relating to contaminant migration by
going through the same process as operable unit 1:
i.e. remedial investigation, alternatives identification
and selection of remedy. The timetable for action
depends on the nature of the contamination found. If
a substance of a very threatening nature is identified,
an emergency removal would be initiated under Superfund
authorities. Otherwise it is estimated that one year
to eighteen months will be required for the studies
relating to the second operable unit.
2. A citizen wanted to know if a copy of the transcript
would be made available.
EPA Response; Yes. The transcript of the meeting will
become part of the public .record when finished and
placed in the information repositories listed in the
PRAP. Citizens may also call Lisa Peterson, EPA
Region II Public Affairs Specialist for the Ludlow site,
at (212) 264-2515 and request a copy.
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RESPONSE TO WRITTEN COMMENTS
Detailed technical comments were received from a number of
Potentially Responsible Parties.
The NYSDEC, USEPA and Dunn GeoScience, consultant to Ludlow were
in agreement on several of the main components require for
remediation of the Ludlow NPL site. Those items which are agreed
on conceptually include:
- capping the landfill
- consolidation of contaminated soils back onto the landfill
prior to capping
leachate management (surficial)
- upgradient groundwater control
long-term monitoring
In addition, EPA has proposed to dewater the landfill either
actively or passively based on further pre-design work to
determine which method will be most effective. The primary
difference between the DUnn 9 GeoScience proposal and EPA proposed
plan is the technology to be implemented for detwatering'the
landfill. Dunn GeoScience proposes to let the landfill naturall
dewater where EPA proposes to implement either a passi
(trenches, drains) or active (wells) system to dewater the
landfill in a controlled manner. Further discussions are
presented in the text that follows under response to dewatering.
Technical Questions/Concerns
1.. Comments received by Whiteman, Osterman & Hanna (WOH) ,
attorney for James and Kevin Ludlow, owners and operators of
Ludlow Sand & Gravel, Inc. and Ludlow Sanitary Landfill,Inc.
and Bond, Schoeneck and King (BSK), attorney for Special
Metals Corporation (SMC) expressed concern about dividing the
site into two operable units. They feel that certain remedial
alternatives for other areas may be precluded if the source
control remedial alternative is implemented prior to
completing the second operable unit RI/FS.
EPA Response;
Various studies performed at the Ludlow Sand and Gravel Site
have provided the data to enable the EPA to determine that the
site poses a significant threat to the public health and the
environment and would require at least a source control
remedy. Regardless of the findings of subsequent
investigations, source control measures need to
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implemented. Dividing the remedial action into operable units
will allow the source control work to begin without further
delay. Failure to control the source could lead to the
continued spread of contamination potentially requiring more
extensive remedial measures.
The selected remedy will be designed prior to implementation
of the remedial measures. The time required for this design
phase may be sufficient for the completion of remedial
investigation activities in the wetlands and in the gravel
pit.
In general, any initial operable unit remedy selected by EPA
should be consistant with overall remedial activities at the
site. EPA has often implemented source control measures at
landfills as a first operable unit. In these cases, as is the
case with the Ludlow site, EPA cannot envision any
circumstance where the control of the source would be
inconsistant with the final remedy.
2. Concerns were raised by BSK and Beveridge & Diamond, P.C.
(B&D) attorney for Chesebrough Ponds, Inc. on EPA selecting
6NYCRR Part 370 to 373 and RCRA Subtitle C Closure instead of
6NYCRR Part 360, Closure for Solid Waste Landfills.
Comments were received by Dunn GeoScience, consultant to
Ludlow in the Conceptual Site Remediation and Closure Plan and
its Amendments regarding the proposed cap.
EPA Response;
RCRA Subtitle C and 6NYCRR Part 373-3 are considered relevant
and appropriate for the Ludlow Sand & Gravel Site. Since the
presence of PCBs and hazardous substances have been
identified as being present in the landfill and leachate seep
areas and under New York State regulations PCBs are classified
as a hazardous waste, RCRA Subtitle C and 6NYCRR Part 370-3
are to be use closure of the landfill.
EPA fully agrees with Dunn GeoScience that caps other than
that presented in the Supplemental RI/FS report prepared by
COM may be appropriate for implementation at this site as long
as the cap meets the performance criteria stated in 40 CFR
264.310. The composition of the RCRA Subtitle C cap must meet
the regulatory requirements and performance criteria. The
final cover must be designed and constructed to:
*
1) Provide long-term minimization of migration of liquids
through the closed landfill.
2) Function with minimum maintenance.
3) Promote drainage and minimize erosion or abrasion of the
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cover.
4) Accommodate settling and subsidence so that the cover's
integrity is maintained; and
5) Have a permeability less than or equal to the permeability
of any bottom liner system or natural subsoils present.
Recommended guidance has been developed for EPA meeting these
five (5) regulatory requirements. Although alternative
designs could also meet the five regulatory requirements,
these designs must be able to demonstrate that they meet the
requirements prior to approval of the cap design. The RCRA
guidance for covers for uncontrolled hazardous waste sites
specifies that covers should as a minimum consist of the
following :
— vegetated top cover
— middle drainage layer
— low permeability bottom layer
— > 20 mil synthetic liner - upper component (may
Be optional)
— >_ 2 feet clay layer - lower component
Dunn GeoScience proposes to use 24 inches of clay and does not
propose to use a synthetic liner. As stated above, as long
the requirements and the performance criteria are met,
composition of the cover can be varied.
The conceptual cap presented in the Supplemental RI/FS report
prepared by Camp, Dresser & McKee, Inc. was produced on a
planning level for EPA and cannot be compared to the closure
plan which is written for a different purpose. The cost
generated for the cap presented in the Supplemental RI/FS
followed the available guidance on preparation of cost
estimates for feasibility studies. The guidance states that
typically the study estimated costs provide an accuracy of
+50% to -30% and are prepared using data available from the
RI. Sources of cost data include vendor's quotation and Means
Cost Estimating Indices and relevant experience at other
sites. In no way is this estimate to be considered final.
The use of this number is to allow EPA to budget for the
remedial alternative should EPA have to implement the remedy
at this site and for analysis of cost effectiveness among the
other alternatives.
3. Comments were received that management of leachate
around the perimeter of the landfill should be included in the
landfill closure. However, CDM's method is not technically
feasible.
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EPA Response;
EPA proposes to pump and collect the 5 surficial leachate
seeps surrounding the landfill. In order to place the cap
over the site and excavate the contaminated sediments in the
seeps, these areas should be free of water. If after pumping
and collecting the leachate in the seeps, the area
accumulates water from off site , some sort of diversion
ditching may be necessary. We are in agreement that if the
volume to be discharged into the intermittent stream is
large, the stream may need to be diverted from entering
through ponded wetlands (as proposed by O'Brien & Gere in the
June 1986 RI/FS). Prior to any ditching operation additional
work would need to be performed to evaluate the depth • of the
ditches and its impact on the wetlands.
4. Comments were received that incorporation of a boring
program during preliminary design will needlessly delay
implementation of the selected remedy.
EPA Response;
The purpose of the boring program is to collect additional
information to better define the volumes to be excavated in
the seeps areas. This program could occur during pre-design
activities and can be performed quickly so implementation of
the remedy will not be delayed.
5. Comments received from BSK, WOH and B&D regarding the cost
effectiveness of EPA's selected remedy.
EPA Response;
As stated above, the estimated costs in the Supplemental RI/FS
report provide an accuracy of +50% to -30% and are prepared
using data available from the RI. These costs are to provide
a basis for differentiating among remedial alternatives that
achieve similar objectives. However, the final( ) will
reflect the flexibility in the design of the remedy. Costs
are used as a basis of comparison between alternatives within
each category (i.e. no-action, containment, treatment as a
major component, dewatering and groundwater table lowering and
leachate collection). These estimates cannot be compared on
an equal basis to the plan prepared by Dunn GeoScience. In
addition, the cost estimates prepared in the O'Brien & Gere
RI/FS report dated June 1986 have not been updated to reflect
1988 costs.
6. Dunn GeoScience agrees with upgradient groundwater
controls however they prefer the passive system. O'Brien &
Gere disagrees with the upgradient groundwater controls
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because only a small percentage of the refuse is in contac
with the groundwater.
EPA Response:
EPA feels that upgradient active or passive groundwater
controls are necessary to maintain the separation of the
groundwater from contact with the waste. This groundwater
table maintenance system will prevent groundwater from flowing
laterally allowing any waste material to remain in contact
with the groundwater and which allow a potential release of
contaminants into the aquifer. EPA agrees with Dunn
GeoScience that a passive system may meet the remedial
objectives. Based upon data obtained during the pre-design
field activities, this groundwater table maintenance system
can be done passively or actively. If it can be determined
after installation of the cap, that the upgradient groundwater
table is below the fill material, then upgradient controls may
not be necessary because the objective of lowering the
groundwater table below the waste is already met.
Comments received from WOH and BSK state that 40 CFR Part
264 and 6NYCRR Part 373 do not require an existing landfill to
be dewatered as part of closure. In addition, groundwater
sampling indicated virtually no groundwater contamination or
extremely low concentrations of contaminants at the landfill.
EPA Response;
EPA does not dispute the fact that the levels of contaminants
detected in the groundwater monitoring wells are relatively
low at the present time. However, the information available
regarding the nature of hazardous substances found in the
landfill dictates a conservative approach for the protection
of public health and the environment.
EPA proposes to dewater the landfill by an active or passive
system. Based on volatile organics and PCB data collected
from soil borings in the landfill and the leachate seeps
surrounding the landfill which show evidence of contamination,
EPA believes the mound of groundwater in contact with the
waste is contaminated. EPA is concerned that this mound of
leachate/contaminated groundwater may discharge into the
underlying aquifer. Once the cap is placed on the site, the
leachate may become more concentrated since infiltration,
which may be diluting the contaminants, is cut off.
Dewatering is felt to be necessary to minimize potential
degradation of the underlying aquifer and to ensure protection
of public health and the environment.
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As part of this alternative, extracted water will be treated
at an on-site treatment plant and the treated water will be
handled and discharged in an appropriate manner.
However, additional testing will be performed prior to
construction of the cap and if it is determined that there is
no mound in the landfill or the water in contact with the fill
material is not contaminated, then dewatering will not be
implemented. If dewatering of the landfill is not necessary
then an on-site treatment facility will probably not be
necessary or cost effective. Therefore, off-site treatment
and disposal will be implemented in its place.
Although low levels of contaminants have been found in the
groundwater to date, EPA believes that, due to the complex
geology at the site, the groundwater has not been properly
characterized. A separate RI/FS for the second operable unit
will be performed to further investigate off-site migration.
It should be noted that Dunn GeoScience, consultant to Ludlow
has proposed enhanced monitoring at the site to ensure that
any potential contamination which may leave the landfill after
the cap is placed will be detected. They have proposed
during the first two years to perform quarterly monitoring.
If during sampling the data indicates a problem, they
proposed these wells could double as recovery wells to
"capture contaminated groundwater and abate off-site
migration". They propose to add "additional recovery wells"
if necessary "at the appropriate time". Onsite treatment
would be used for treatment of extracted water.
Unfortunately by the time the contamination is detected in
these wells and if necessary, additional wells are installed
and the on-site treatment system is designed and installed
upgradient, the contamination will be migrating downgradient
towards the residential wells and the Clayville municipal
water supply wells. The off-site migration of contaminated
groundwater is the focus of the second operable unit. EPA
proposes that the extraction of water presently in the fill in
a controlled manner is a more prudent approach then allowing
the potential contaminated groundwater to leave the landfill
and enter the underlying aquifer.
8. A comment was raised as to whether treatment and disposal
would occur on-site or off-site.
EPA Response;
If during pre-design, it is determined that dewatering the
landfill is not necessary and passive upgradient groundwater
control versus active control is selected, then the volume of
water generated during the remedial action will be small
enough to be treated and disposed of off-site at an approved
location. If dewatering of the landfill leachate generates
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-16-
large volumes of water, then onsite treatment and disposal
will be cost effectiveness. The decision for onsite versus
offsite treatment and disposal will occur after the pre-design
tests are completed.
9. A comment was received that the treatment schematic for
leachate will not meet the desired effluent quality for
discharge to the wetlands due to oxygen-demanding organics
present in the leachate.
EPA Response;
EPA does not agree that this treatment concept presented in
the FS would not meet the desired effluent quality although
the exact process may require modification. As stated in the
Supplemental RI/FS report prepared by COM, a treatability
study will be performed to determine the most efficient method
of treatment, which will then be designed and implemented.
The treatment plant must produce effluent capable of
maintaining groundwater and surface water standards. .6NYCRR
Part 700 groundwater and surface water would apply.
10. There are inaccuracies in the PRAP on the concentrations of
substances in the groundwater and surface water.
EPA Response;
1,1- dichloroethane was incorrectly reported in the PRAP as
0.023 ppm. The correct value was 0.0023 ppm. The
concentration of PCBs in the surface water downgradient of
the site was 0.0005 ppm.
11. Comments received from B&D stated that the criteria and
data were improperly used or applied in arriving at
conclusions and in calculating risks associated with the site
and that the health risks and potential environmental impacts
associated with exposure to constituents has been grossly
exaggerated.
EPA Response;
No further information was provided by B&D to determine which
data was used improperly and why they considered risks
exaggerated. EPA used the data supplied by O'Brien & Gere,
Dunn GeoScience, the NYSDEC and samples collected by COM,
contractor to EPA to develop the feasibility study (FS).
Based on the available data , alternatives were developed to
provide for source control of the landfill materials.
Additional studies identified in the FS need to be performed
to refine assumptions made and further define the methods to
be used to achieve the objectives of source control, (i.e.
passive versus active upgradient control of the groundwater
lower the groundwater table below the landfill material).
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EPA does not believe the risks are overstated nor exagerrated.
The Ludlow landfill contains hazardous substances which pose a
direct contact, ingestion and inhalation threat to the
public. There is both a release and a potential for further
release to the environment. The remedy selected controls the
release by isolating the waste materials preventing exposure
through direct contact or release to groundwater. EPA
believes the risk assessment to be sound and has received no
information to the contrary.
12. Comments were received from BSD stating that a substantial
increase in risks would exist in drilling borings through the
landfill.
EPA Response;
It has not yet been determined if an active or passive
dewatering system will be used at the site. If an active
system is selected to achieve these objectives and it is
determined that the wells need to be put into the landfill,
worker health and safety becomes a concern. There are ways to
mitigate these potential hazards and drilling wells into
landfill has been accomplish at a number of hazardous waste
sites (i.e. LiPari Landfill, Kin-Buc, and Lone Pine in New
Jersey).
13. One PRP commented that there would be a potential for
contaminants in the landfill to enter the underlying aquifer
if wells were.installed into the landfill.
EPA Response;
These potential problems can be mitigated by installing
double-cased or triple-cased wells if it is determined to be
necessary.
14. BSK and BSD stated that the public comment period was too
short and fails to comply with statutory requirements of
CERCLA and SARA. B&D also stated that " CERCLA requires that
the notice of the . PRAP must be given to all potentially
affected parties", and notice should have been given to those
municipalities which used the landfill as they may be PRPs
under CERCLA.
EPA Response;
Section 117 of CERCLA requires EPA to provide a reasonable
opportunity for submission of written and oral comments and an
opportunity for a public meeting at or near the facility. EPA
has complied with this section of the statute; both a public
meeting and a reasonable opportunity for submission of
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meeting and a reasonable opportunity for submission of
comments were provided.
No specific length of comment period is mandated by the
statute itself. The National Contingency Plan at 40 CFR Part
300.67(d), requires a comment period, following the release
of the Feasibility Study, of "not less than 21 calendar days."
EPA believes a 22 day period is reasonably adequate to allow
for public comment.
EPA sent a copy of the PRAP to each of the named defendants
(including third-party.defendants) in New York State's pending
suit seeking remediation of this site. In addition, public
notice was published in a newspaper of general circulation
near the site. The PRAP and the studies done were placed in
two publicly accessible document repositories near the site.
EPA made a good faith effort to seek out comments of all
affected members of the public, and allowed adequate time for
comments to be submitted.
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Response to letter from Hans G. Arnold, Commissioner,
Department of Solid Waste Management to Caroline Kwan, USEPA,
dated June 22, 1988
North Gravel Pit; Questions la to Id
Response: The North Gravel pit is not part of this operable
unit source control study and will be addressed under the
second operable unit RI/FS. It has come to EPA's attention
that Dunn GeoScience, consultant to Ludlow, has performed
additional investigations in this area. We suggest you
contact the NYSDEC and NYSDOL to obtain additional
information.
Wetland Areas; Question 2a
Response: The wetlands area (Ponded area) is not part of this
operable unit. The soils adjacent to the south end of the
landfill will be consolidated on top of the landfill and
capped to prevent direct contact. Leachate management will
also be implemented to eliminate further migration of
contaminants from the site. During heavy rains or high water
flow, there is a potential for the sediments to be disturbed
and the PCBs adsorbed to the organic matter in the ponded
wetlands to become suspended in the water column and
potentially migrate with the water. It is our understanding
that the culvert at the Holman City road adj'acent to the
ponded wetlands has prevented water from leaving this area.
Soils Under Landfill; Questions 3a and 3b
Response 3a: Such a pathway is possible but not likely. It
is more likely that contamination is moving towards existing
seeps, which are mostly in the southern end of the landfill
and along a portion of the northern face. Also, downward
movement may be occurring throughout a wide portion of the
landfill, although there are no wells in the geological units
below the landfill to demonstrate whether a downward gradient
exists or not. Evidence of a downward gradient however is
strong in the western portion of the landfill where
monitoring well pair (#6) is located just beyond the edge of
the landfill.
Response 3b: There are sufficient data points to know that
there is a potential off-site groundwater quality problem.
Contaminants in the leachate collected at the landfill have
been mobile enough to move from the edge of the landfill.
They may be mobile enough to move into the groundwater below
the landfill. To date, insufficient information on off-site
groundwater quality exists to state whether contamination has
moved in the groundwater away from the landfill and into the
surrounding aquifer materials. Vertically arranged
monitoring wells in and surrounding the landfill are needed to
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the wetlands. This would limit access to the site where PCBs
and other hazardous substances are present.
- Excavation of contaminated soil needs to be performed in any
area identified as having a concentration of 10 ppm or greater
of PCBs, and not just area C and D as stated in the closure
plan.
- The cap must meet RCRA Subtitle C, 40 CFR 264 and 6NYCRR
Part 370-373 regulations and performance criteria.
- The cap should include gas venting.
- Surficial leachate must be collected from all 5 seeps areas.
- Area designated by the PRP as A, B, C & D do not adequately
depict all the areas of contamination. Additional areas
include the north side seeps and the soil adjacent to the
southern seep which is contaminated with PCBs above 10 ppm.
- A 3 year phased closure is not acceptable. This point is
moot since NYSDEC closed the landfill on February 15, 1988
pursuant to a Federal Court Order.
- A location for discharge of treated water was not
identified. The treatment system should be relooked at- based
on additional data collected by COM at each seep location.
- The proposed perimeter leachate collection system will only
collect lateral flow. The proposed passive groundwater
control system will prevent upgradient lateral flow from
entering the landfill. However the closure plan allows for
natural dewatering of the water in contact with the landfill
materials. EPA believes that this water may be contaminated
and therefore must be collected in a controlled environment
and treated appropriately.
- No provisions are made for rainfall runoff from the cap.
Specific Comments
- While the PRPs have agreed to grade the landfill to a
minimum of 5% slope on top and 33% on the sides, it appears
that no calculations have been performed to determine what
amount of settlement and subsidence will occur. EPA/540/2-
85/002 recommends that the slope after settlement and
subsidence should be between 3% to 5%. This will be
important if groundwater is lowered to an elevation below the
bottom of the landfill materials.
- The Closure Plan Amendment indicates that the filter fabric
between the lateral drainage layer (B-2) and the underlying
hydraulic barrier (C) may be deleted pending laboratory
testing. The filter fabric between these two layers
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testing. The filter fabric between these two layers should
not be eliminated, in fact additional filter fabric should be
placed between the hydraulic barrier and the overlying
drainage barrier (D-l) and between the drainage layer {D-l)
and the filter layer (D-2) to prevent clogging of the higher
permeability drainage layers.
- Design parameters should be provided for the clay layer
during design which meet the performance standards of 40 CFR
Part 264 and 6NYCRR Part 373.
- The clay should have a maximum permeability of 10-7 cm/sec.
Nuclear densitometer readings should be taken as per ASTM
D2922. The frequency of testing will be determined in design,
however, it is suggested that 9 reading per acre per lift be
used. The results of each test should be compared to the most
recent moisture density curve to assure that the proper
percent compaction and the required permeability are being
obtained. The calibration of each nuclear densitmeter reading
should be checked daily by comparsion to density measured on
the same material by ASTM methods.
Shelby tube samples from undisturbed samples should be used to
measure clay permeability. At least one per acre per lift
(but no fewer than one per lift) should be reported.
»
- the filter layer proposed in the Closure Plan should be
increased to meet the minimum vegetative layer thickness of
24 inches as recommended by EPA/540/2-85/002.
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