United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R02-90/121
September 1990
&EPA
Superfund
Record of Decision
Hooker Chemical/Ruco
Polymer, NY
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50272-101
REPORT DOCUMENTATION
PAGE
1- REPORT NO.
EPA/ROD/R02-90/121
3. Recipient • Acceeeion No.
4. Title lind Subtitle
SUI'ERFUND RECORD OF DECISION.
Hooker Chemical/Ruco Polymer, NY
First Remedial Action
5. Report Oil*
9/28/90
6.
7. Author(i)
B. Performing Organization R«pt No.
t. Performing Organization Name and Addrea*
to. Project/Teak/Worti Unit No.
11. Conlract(C) or Crant(G) No.
(C)
(O
11 Sponsoring Organization Nam* and Add»M
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
1J. Typt of Report & Period Covered
800/000
14.
15. Supplementary Note*
18. Atamct (Limit: 200 word*)
The 14-acre Hooker Chemical/Ruco Polymer site is an active polymer production facility
in Hicksville, Nassau County, New York. Surrounding land use is primarily industrial
and commercial, and a residential area is located near the site. Since 1946, the
facility has produced various plastics, polymers and resins, including polyvinyl
chloride, styrene/butadiene latex, vinyl chloride/vinyl acetate copolymer, and
polyurethanes. From 1956 to 1975, plant wastewater containing VOCs and heavy metals was
discharged into six onsite ground water recharge basins, which has led to contamination
of the onsite ground water. From 1946 to 1978, the onsite plant utilized a heat
transfer fluid that contained PCBs. Since 1984, site investigations have identified
four onsite areas of PCS contamination. These include a direct spill area where
releases of heat transfer fluid escaped through a relief valve at the pilot plant, a
transport area contaminated by PCBs spread from the direct spill area by onsite truck
traffic, the recharge basin that was contaminated by surface runoff, and soil
contamination around an underground fuel storage tank, which was disposed of offsite in
1989. Contaminated soil from the tank excavation is currently stored onsite. This
Record of Decision (ROD) addresses remediation of Operable Unit 2 (OU2), the
(See Attached Page)
17. Document Analyele a. DMcriptora
P.ecord of Decision - Hooker Chemical/Ruco Polymer, NY
First Remedial Action
Contaminated Media: soil, debris
Key Contaminants: organics (PCBs)
b. M*nd(l*ra/Op*n-End*d Ttnm
c. COSATI Flew/Group
18. Avelllbllty Statement
19. Security d««* (Thi* Report)
None
20. Security Cl*** (Thi» P»g«)
None
21. No. of Page*
72
22. Price
(See ANSI-Z39.18)
SM Intlructioni on rbtwnw
OPTIONAL FORM 272 (4-77)
(Formerly NTIS-35)
Department of Commerce
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EPA/ROD/R02-90/121
Hooker Chemical/Ruco Polymer, NY
First Remedial Action
Abstract (Continued)
PCB-contaminated soil at the above locations. Remediation of remaining site areas,
VOC--contaminated soil, and ground water will be addressed as OU1 in a subsequent ROD.
The primary contaminants of concern affecting the soil and debris are PCBs.
The selected remedial action for this site includes excavating all soil contaminated with
greater than 10 mg/kg PCBs from the direct spill and transport areas, and the soil from
the recharge basin to a depth of 10 feet; disposing of approximately 1,100 cubic yards of
soil contaminated with 10 to 500 mg/kg PCBs at an offsite landfill along with the
stockpiled soil from the earlier tank excavation; treating approximately 36 cubic yards
of :;oil contaminated with PCB levels greater than 500 mg/kg offsite using incineration,
followed by offsite disposal of the residual ash; and backfilling and paving all
excavated areas, except for the recharge basin. The estimated present worth cost for
this remedial action is $995,650. There are no O&M costs associated with this remedial
action.
PERFORMANCE STANDARDS OR GOALS: The excavation level, PCBs greater than 10 mg/kg, and
treatment level, PCBs greater than 500 mg/kg, are based on the TSCA Spill Cleanup Policy
and EPA's "Guidance on Selecting Remedies for Superfund Sites with PCB Contamination,"
respectively.
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DECLARATION FOR RECORD OF DECISION
SITE NAME AND LOCATION
Hooker Chemical/Ruco Polymer Site
Hicksville
Nassau County, New York
STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected remedial action for
Operable Unit 2 for the Hooker Chemical/Ruco Polymer site located
in Hicksville, Nassau County, New York, developed in accordance
with the Comprehensive Environmental Response, Compensation, and
Liability Act of 1980 (CERCLA), as amended by the Superfund
Amendments and Reauthorization Act of 1986 (SARA), and the
National Oil and Hazardous Substances Pollution Contingency Plan
(NCP). This decision document summarizes the factual and legal
basis for selecting the remedy for this site.
The State of New York has concurred with the selected remedy; a
letter of concurrence is attached. The information supporting
this remedial action decision is contained in the administrative
record for this site.
ASSESSMENT OF THE SITE
Actual or threatened releases of hazardous substances from this
site, if not addressed by implementing the response action
selected in this Record of Decision (ROD), may present an
imminent and substantial threat to public health, welfare or the
environment.
DESCRIPTION OF THE SELECTED REMEDY
The remedy selected for this Operable Unit at the Hooker
Chemical/ Ruco Polymer site is a final remedy for the PCB-
contaminated soils that surround the pilot plant at the site.
The remaining portion of the site, the groundwater and soils
contaminated by volatile organic compounds, will be addressed in
a future ROD.
The major components of the selected remedy include the
following:
o Excavation of PCB-contaminated soils in excess of 10 ppm in
the direct spill area and the transport areas surrounding
the pilot plant. Soils at the bottom of the recharge basin
(Sump 3) will be excavated to ten feet from the existing
surface. Confirmatory sampling will be performed to ensure
soils that remain after the excavation will have PCB
concentrations that do not exceed 10 ppm.
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o Excavated soils with PCB concentrations between 10 ppm and
500 ppm, approximately 1100 cubic yards, will be shipped for
disposal to an off-site chemical waste landfill permitted
under TSCA.
o Stockpiled soils, which were previously excavated during the
removal of the underground fuel oil tank, will be included
in the disposal of PCB-contaminated soils at an off-site
chemical waste landfill.
o Soils with PCB concentrations exceeding 500 ppm,
approximately 36 cubic yards, will be shipped off-site to a
TSCA-permitted incineration facility. Residuals will be
disposed of, as appropriate, by the incineration facility.
o Excavated areas will be backfilled with clean soil, and
these areas, excluding the recharge basin, will be paved
with asphalt as appropriate.
o The PCB contamination in former Sump 5 will be left in-
place.
DECLARATION OF STATUTORY DETERMINATIONS
The selected remedy is protective of human health and the
environment, complies with Federal and State requirements that
are legally applicable or relevant and appropriate to the
remedial action, and is cost-effective. This remedy utilizes
permanent solutions and alternative treatment technologies to the
maximum extent practicable for this site. Because treatment is
being used to address the principal threats at the site, this
remedy satisfies the statutory preference for treatment as a
principal\ element of the remedy.
As the remedy for this Operable Unit will not result in hazardous
substances remaining above health-based levels in the areas it
addresses, the five year review will not apply to this action.
'Constantino Sidamon-Eristoff/ Date /
Regional Administrator
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ROD FACT SHEET
SITE
Name:
Location/State:
EPA Region:
HRS Score (date):
NPL Rank:
ROD
Date Signed:
Remedy/ies:
Capital Cost:
O&M/Year:
Present Worth:
LEAD
Remedial/Enforcement:
Primary Contact:
Secondary Contact:
PRP Contact:
Hooker Chemical/Ruco Polymer - Operable Unit Two -
PCS Contamination Surrounding Pilot Plant
Hicksville, Nassau County, New York
USEPA Region II
41.6 (Final 6/86)
450 (8/90)
September 28, 1990
Excavation of PCB-contaminated soil exceeding 10 ppm.
Soils with concentrations between 10 to 500 ppm disposed
of at an off-site TSCA-approved hazardous waste landfill.
Over 500 ppm, (approx. 40 cu. yds.) off-site incineration.
$995,650
$0
$995,650
Enforcement - Occidental Chemical Corporation (OCC)
Raymond Slizys, Project Manager, EPA, (212) 264-8742
Douglas Tomchuk, Previous RPM, EPA, (212) 264-7508
Dr. Alan Weston, OCC, (716)-286-3607
WASTE
Type (metals, PCB, &c): PCBs (Operable Unit Two)
Medium (sofl, g.w., &c): Soil
Origin: Relief valve to heat transfer system in pilot plant
Est. Quantity cu.yd.: 1100 cu. yds. soil
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DECISION SUMMARY
HOOKER CHEMICAL/RUCO POLYMER SITE
HICKSVILLE, NEW YORK
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION II
NEW YORK
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TABLE OF CONTENTS
DECISION SUMMARY PAGE
I. SITE LOCATION AND DESCRIPTION 1
II. SITE HISTORY AND ENFORCEMENT ACTIVITIES 2
III. HIGHLIGHTS OF COMMUNITY PARTICIPATION 3
IV. SCOPE AND ROLE OF OPERABLE UNIT 3
V. SUMMARY OF SITE CHARACTERISTICS 4
VI. SUMMARY OF SITE RISKS , 5
VII. DESCRIPTION OF ALTERNATIVES 8
VIII. SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES 12
IX. SELECTED REMEDY 18
X. STATUTORY DETERMINATIONS 19
ATTACHMENTS
APPENDIX A - FIGURES
FIGURE 1. REGIONAL LOCATION MAP
FIGURE 2. SITE LOCATION MAP
FIGURE 3. DETAILED SITE MAP - DELINEATING AREA ADDRESSED
BY OPERABLE UNIT 2
FIGURE 4. ^DETAILED MAP OF AREA ADDRESSED BY OU 2
FIGURE 5.- LOCATIONS AND RESULTS OF SURFACE SOIL SAMPLES
FIGURE 6. LOCATIONS AND RESULTS OF SUBSURFACE SOIL SAMPLES
APPENDIX B - TABLES
TABLE 1. RESULTS OF SOIL SAMPLING IN PCB AREA
TABLE 2. CONCENTRATION RANGE, DETECTION FREQUENCY AND MEAN VALUE
FOR AROCLOR 1248
TABLE 3. CALCULATIONS OF CHRONIC DAILY INTAKES (GDIs)
TABLE 4. SUMMATION OF CANCER RISKS POSED BY PCBs AT THE SITE
APPENDIX C - NYSDEC LETTER OF CONCURRENCE
APPENDIX D - RESPONSIVENESS SUMMARY
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I. SITE LOCATION AND DESCRIPTION
The Hooker Chemical/Ruco Polymer site (the "Site") is located on
a 14 acre tract of land off of New South Road, in Hicksville,
Town of Oyster Bay, Nassau County, New York. (See Figures 1 and
2) The Site is bordered by the Long Island Railroad to the south,
the Grumman Aerospace Corporation facilities to the east, and
various commercial and industrial facilities to the north. A
residential area is situated directly across New South Road, to
the west of the Site, which is approximately 800 feet away from
the area addressed in this Record of Decision (ROD). According
to 1989 estimates, the population of Hicksville is 42,400
persons.
The Site is relatively flat with a gentle slope toward the south.
There are several recharge basins or sumps, between ten and
twenty feet deep, which recharge the groundwater underlying the
Site. The uppermost aquifer, the Upper Glacial aquifer, is
approximately 40 feet thick in this area, and is mostly
unsaturated. The water table is approximately 50 feet below the
ground surface. Below the Upper Glacial aquifer, is the
unconfined Magothy aquifer, which is the primary source of
drinking water for Long Island residents. The Magothy aquifer is
designated as a sole-source aquifer. In the area surrounding the
site, water is supplied by public purveyors, so residents do not
use private wells to supply their potable water. There are six
public supply wells within a 1-mile radius of the Site. These
wells should not be impacted by the Site because they are not
situated to the south of the Site, which is the direction of
regional groundwater movement. There are no significant surface
water bodies in the vicinity of the Site.
The area where the Site is located is not known to contain any
ecologically significant habitat, wetlands, agricultural land,
historic or landmark sites, which are impacted by the Site.
Major site features include two main production plants (See
Figure 3), a pilot plant located between these plants, a
warehouse building, an administration and laboratory building,
numerous above-ground chemical storage tanks and associated
piping, and several recharge basins.
II. SITE HISTORY AMD ENFORCEMENT ACTIVITIES
The Site has been used for industrial purposes since 1946, at
which time two companies occupied the site; the Insular Chemical
Company and the Rubber Company of America. Although two separate
corporations, they shared the same pilot plant. In 1956 the two
companies merged into the Rubber Corporation of America. In
1965, the company was purchased by the Hooker Chemical and
Plastics Corporation and was known as the Ruco Division. Hooker
has undergone several name changes and is currently known as the
Occidental Chemical Corporation. In March 1982, the employees
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bought the company and it became known as Ruco Polymer
Corporation. Ruco Polymer currently owns the property, and the
facility is still active.
Since 1946, the facility was used for the production of various
polymers, including polyvinyl chloride (PVC), styrene/butadiene
latex, vinyl chloride/vinyl acetate copolymer, and polyurethane,
as well as ester plasticizers. The facility is currently active,
and manufactures such products as polyester, polyols and powder
coating resins.
During site operations between 1956 to 1975, industrial
wastewater from the facility was discharged to six (6) on-site
recharge basins or sumps. This wastewater contained, among other
things, vinyl chloride, trichloroethylene, barium and cadmium
soap, vinyl acetate, organic acids, and styrene condensate. As a
result of these releases, groundwater downgradient from the site
has been contaminated. Currently, only non-contact cooling water
is discharged into Sump 4. Since 1975, a concrete settling basin
has been used to store ester waste prior to being incinerated on-
site. Hazardous wastes are stored in drums on-site until they
are disposed of at a permitted off-site facility.
From 1946 to 1978, the pilot plant, which is used for small scale
and trial production, utilized a heat transfer fluid called
Therminol, which contained PCBs. During the operation of the
facility, there was a release of PCBs to the soil adjacent to the
pilot plant. Some of this contaminated soil was spread to
surrounding areas by surface water run-off and truck traffic.
Occidental has conducted several investigations, since 1984, to
determine the extent of PCB contamination around the pilot plant.
In 1989, an underground fuel oil storage tank adjacent to Plant 1
was removed, and the soils surrounding the tank were excavated,
sampled, and found to be contaminated with PCBs. These excavated
soils have been covered with plastic sheeting, pending the
remediation of the other PCB-contaminated soils on the site.
The site was placed on the National Priorities List (NPL) in
1984. Initially, negotiations by NYSDEC and EPA failed to reach
a settlement with the potentially responsible parties (Occidental
Chemical and Ruco Polymer) to conduct the Remedial Investigation
and Feasibility Study (RI/FS) for the site. Therefore, EPA
issued a work assignment to its contractor, Ebasco Services,
Inc., to prepare a work plan and conduct the RI/FS. However, in
September 1988, after the work plan was finalized. Occidental
agreed to perform the work. In September 1989, field work
commenced for the RI/FS. Field work was completed in February
1990 and a draft Remedial Investigation Report was submitted in
April 1990. This report is currently under review by EPA and
NYSDEC.
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Given that the PCB-contaminated areas had been defined by
previous investigations, Occidental proposed to perform an early
action to remediate these areas. To support such an action,
Occidental prepared a Focused Feasibility Study (FFS) which
analyzes alternatives to address the PCB-contaminated areas on
the site (See Figure 4), and which is the subject of this ROD.
III. HIGHLIGHTS OF COMMUNITY PARTICIPATION
The FFS Report, the Risk Assessment and the Proposed Plan for the
Hooker Chemical/Ruco Polymer site were released to the public for
comment on July 31, 1990. These documents were made available to
the public in information repositories which are maintained at
the EPA Region II offices, the Hicksville Public Library and the
Town of Oyster Bay Town Hall. The notice of availability for
these two documents was published in the Nassau County edition of
Newsday on July 31, 1990. A public comment period on the
documents was held from July 31, 1990 to August 30, 1990. In
addition, a public meeting was held on August 7, 1990. At this
meeting, representatives from EPA presented the Proposed Plan,
and later answered questions concerning such Plan and other
details related to the RI/FS reports. Responses to comments and
questions received during this period are included in the
Responsiveness Summary, which is part of this ROD.
IV. SCOPE AND ROLE OF OPERABLE UNIT OR RESPONSE ACTION WITHIN
SITE STRATEGY
As with many Superfund sites, the problems at the Hooker
Chemical/ Ruco Polymer site are complex. At this point in time,
EPA does not have enough information to select a remedy for the
entire Site. As a result, EPA has organized the remedial work
into two phases, or Operable Units. This ROD addresses the first
planned remedial action at the site.
The two Operable Units are divided as follows. Operable Unit One
includes the majority of the Site, such as the contaminated
groundwater and soil resulting from previous disposal activities,
other than the previous release of PCBs to soils surrounding the
pilot plant. Operable Unit Two addresses the PCB-contaminated
soils surrounding the pilot plant.
As stated above, the draft Remedial Investigation for Operable
Unit 1 was submitted in April 1990 and is under review by EPA and
NYSDEC.
Operable Unit Two, which this ROD addresses, includes a portion
of the Site which had been characterized by previously completed
studies, and can be addressed at this time. This Operable Unit
addresses PCBs, while the rest of the Site and the groundwater is
contaminated mainly by volatile organic chemicals. By dividing
the Site into two Operable Units, remediation can be started,
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thereby alleviating the threat from PCBs at the Site, while the
studies for the other portion are being completed. The
remediation for this portion of the Site will not interfere with
the final remediation for the Site.
V. SUMMARY OF SITE CHARACTERISTICS
The PCB contamination to be addressed by this ROD was caused by
releases of heat transfer fluid, Therminol, from a relief valve
located on the south side of the pilot plant. Therminol
contained PCBs; more specifically, Aroclor 1248. Studies
conducted to define the extent of PCB contamination found that
the PCBs were concentrated in a "direct spill area" adjacent to
the pilot plant. Soils surrounding the pilot plant have PCB
contamination which is believed to have been caused by truck
traffic spreading PCBs from the direct spill area. These soils
are referred to as the "transport areas." In addition, there is
PCB contamination in the nearby recharge basin (Sump 3) which is
believed to have been conveyed from the direct spill area and
transport area via surface water runoff. A fourth area of PCB
contamination was discovered when an underground fuel oil storage
tank, adjacent to Plant 1, was excavated after it failed a
pressure test. Some of the soils surrounding the tank were also
excavated, sampled, and found to be contaminated with PCBs.
These soils have been stored on-site and covered with plastic
sheeting while they await remediation for the other PCB-
contaminated soils from the Site. The data from the soil samples
collected to characterize the extent of PCB contamination at the
Site are shown on Figures 5 and 6, and listed in Table 1.
In the direct spill area, the soil has been found to be
contaminated with PCBs in concentrations as high as 23,000 parts
per million (ppm). In this area, contamination has been found as
deep as 10 feet below the ground surface. The most highly
contaminated soil is found near the ground surface, but it should
be noted that this area is paved with asphalt. The asphalt
pavement is helpful in that it lessens the probability for
exposure and limits further migration of the contamination.
The soil in the transport related area is generally less contam-
inated the further it is from the direct spill area. Again, the
most highly contaminated material is found near the ground
surface, with the contamination reaching as deep as 3 feet below
the surface in several areas. Concentrations range from over 500
ppm to below the analytical detection limit (the EPA Contract Lab
Program contract required detection limit is 0.08 ppm) in this
area. A large portion of the transport related area is paved
with asphalt.
It is believed that the contamination in the recharge basin, Sump
3, is due to contaminated soil from the direct spill area and the
transport related area being carried into the sump via stormwater
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run-off. PCB concentrations in the recharge basin have been
measured as high as 176 ppm, and as deep as 10 feet from the
surface of the recharge basin.
The soils which were previously excavated during the fuel oil
tank removal are being stored on plastic sheeting, with a plastic
sheeting cover in an area to the east side of the pilot plant.
These soils, approximately 70 cubic yards in volume, range up to
420 ppm in concentration.
Data collected and analyzed for the Operable Unit 1 RI/FS confirm
the PCB concentrations from the previous studies. In addition,
the data from the RI/FS show that there is no significant
contamination from other chemicals, in the soils to be addressed
by this ROD, which would influence the treatment alternative
selected in this ROD.
One sample taken during the RI/FS from a boring in former Sump 5
had a PCB concentration of 24 ppm. This sample was taken at a
depth of 10 to 12 feet below the existing grade, which is
believed to correspond with the surface of that sump before it
was filled.
The volumes of PCB-contaminated soils associated with specific
concentration ranges are as follow:
10 ppm - 25 ppm = 410 cubic yards
25 ppm - 500 ppm = 664 cubic yards
above 500 ppm = 36 cubic yards.
Thus, the total volume of PCB-contaminated soils with PCB-
concentrations exceeding 10 ppm is estimated to be 1,110 cubic
yards. For; an action level of 25 ppm, it is estimated that a
total of 700 cubic yards would need to be excavated.
VI. SUMMARY OF SITE RISKS
EPA conducted a risk assessment, also referred to as an Endanger-
ment Assessment (EA), to evaluate the potential risks to human
health and the environment under the "no-action" alternative,
which would be the risk presented if the Hooker/Ruco site was
left in its current state. In addition, the risk assessment
evaluated the risk for future use scenarios associated with
different cleanup levels. The only chemical evaluated in the
risk assessment, the indicator chemical, was PCBs, since this ROD
is only addressing the soils contaminated with PCBs surrounding
the pilot plant. Samples collected from the direct spill area
have been found to contain PCBs in concentrations as high as
23,000 ppm. Table 2 includes the range, frequency of detection
and mean value for PCBs in surface and subsurface samples. No
other contaminants were found in significant concentrations in
the soils in this area.
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It should be noted that the EPA guidance document, "Guidance on
Selecting Remedies for Superfund Sites with PCB Contamination,"
based on the TSCA Spill Cleanup Policy, states that a 10 inch
cover of clean soil will reduce risks by approximately one order
of magnitude. in Sump 5, PCBs were detected in one sample at a
concentration of 24 ppm at a depth of approximately 10 feet. The
risk from this relatively low concentration is therefore reduced
by approximately ten orders of magnitude. Such a risk is below
EPA's acceptable risk range, and therefore does not warrant
remediation.
Contaminant Identification and Exposure Assessment
EPA has identified several potential exposure pathways by which
the public may be exposed to PCB contamination from the Site.
These pathways are: 1) the ingestion of soil; 2) direct contact
with the soil; and, 3) inhalation of suspended site soil.
As of the date that the EA was prepared, there was no cancer
potency factor, or slope factor (described below), available for
inhalation exposure to PCBs. The most current EPA risk
assessment guidance does not allow the oral slope factor to be
used in the place of an inhalation slope factor. Therefore, the
calculation for inhalation of suspended site soils calculated a
Chronic Daily Intake (GDI), but did not calculate a risk number.
(The risk number is the product of the slope factor and the GDI).
The inhalation GDIs calculated are generally several orders of
magnitude lower than the GDIs from oral intake, so if the slope
factors were assumed to be similar, the risk from the inhalation
route would be negligible.
Exposure to PCBs via groundwater was not evaluated because PCBs
will notxreadily migrate to groundwater and no PCBs have been
found in the samples from the groundwater monitoring wells on-
site. Exposure to PCBs via the inhalation of volatile fractions
were not examined because a screening level model indicated
minimal amounts of volatile flux. The inhalation pathway, was
also not evaluated in the future-use scenario because of the
unavailability of inhalation cancer slope factors.
The potentially exposed populations evaluated include: 1) site
workers; 2) trespassers; 3) residents; and, 4) construction
workers.
Toxicity Assessment
PCBs have been associated with non-carcinogenic effects, however,
there are no Reference Doses (RfDs) available in the Integrated
Risk Information System (IRIS) for PCBs, so non-carcinogenic
risks were not quantified for this site. Comparing the Rfd to
the expected contaminant intakes from the Site indicates the
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potential for adverse health effects from that contaminant.
PCBs are considered to be potential human carcinogens, and
therefore will be evaluated against EPA's acceptable risk range
for additional cancer incidents. Cancer potency factors (CPFs),
or slope factors, have been developed by EPA's Carcinogenic Risk
Assessment Verification Endeavor for estimating excess lifetime
cancer risks associated with exposure to potentially carcinogenic
chemicals. CPFs, which are expressed in units of (mg/kg-day)',
are multiplied by the estimated intake of a potential carcinogen,
in mg/kg-day, to provide an upper-bound estimate of the excess
lifetime cancer risk associated with exposure at that intake
level. The term "upper bound" reflects the conservative estimate
of the risks calculated from the CPF. Use of this approach makes
underestimation of the actual cancer risk highly unlikely.
Cancer potency factors are derived from the results of human
epidemiological studies or chronic animal bioassays to which
animal-to-human extrapolation and uncertainty factors have been
applied. The cancer potency factor for PCBs is 7.7 (mg/kg-day) '.
Human Health Risk Characterization
Excess lifetime cancer risks are determined by multiplying the
intake level, or GDI (calculated in Table 3), with the cancer
potency factor for PCBs, 7.7 (mg/kg-day) '. These risks are
probabilities that are generally expressed in scientific notation
(e.g., IxlO"6 or 1E-06) . An excess lifetime cancer risk of IxlO6
indicates that, as a plausible upper bound, an individual has a
one in one million chance of developing cancer as a result of
site-related exposure to a carcinogen over a 70-year lifetime
under the specific exposure conditions at a site. EPA considers
a cancer risk range of 104 to 10* to be acceptable, with 10* used
as a point of departure.
The risk assessment determined that under a present-use scenario,
the risk was greatest for employees that work on the Site, and
that the Reasonable Maximum Exposure was estimated to be 5.2 x
103. The average case exposure scenario (a more realistic
scenario) estimated the risk to be 3.7 x 104.
Table 4 presents a summary of the total carcinogenic risks and
the carcinogenic risks posed by each exposure pathway for various
potentially exposed populations.
Uncertainties
The risk assessment process is subject to uncertainty from
multiple sources including environmental chemistry sampling and
analysis, fate and transport modelling of site contaminants,
estimates of exposures to nearby populations, and toxicological
data used for the development of CPFs of RfDs of the indicator
contaminants. Additional uncertainties are addressed by making
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8
conservative assumptions concerning risk and exposure parameters
throughout the assessment. As a result, the EA provides upper
bound estimates of the risks to populations near the Site, and is
highly unlikely to underestimate the risks related to the Site.
Risk Summary
Actual or threatened releases of hazardous substances from this
site, if not addressed by implementing the response action
selected in this ROD, may present an imminent and substantial
endangerment to public health, welfare, or the environment.
VII. DESCRIPTION OF ALTERNATIVES
Common Elements. Except for the "No Action" alternative, all of
the alternatives have a number of common components.
Alternatives 3 through 14 all involve excavating PCB-contam-
inated soils, in excess of a specified cleanup level, prior to
treatment or off-site disposal. Confirmatory sampling will be
conducted to ensure that the cleanup level has been achieved.
Excavation in the direct spill area will probably require the use
of sheet piling. In addition, in alternatives 3 through 14,
excavated areas will be backfilled with clean fill, and then
these areas, except for the recharge basin, will be paved with
asphalt. In alternatives that include off-site thermal
treatment, the incineration facility will be responsible for the
disposal of residual material.
The time to implement the remedial alternatives below, are
estimated from the start of Remedial Design. Implementation time
does not include long-term (30 year) operation and maintenance
(O&M) costs, if any.
Alternative l:
NO ACTION, (RESTRICTED ACCESS)
Capital Cost: $49,000
Annual O&M Costs: $3,000
Present Worth: $139,000
Time to Implement: 12 months
CERCLA requires that the "no-action" alternative be evaluated at
every site to establish a baseline for comparison. Under this
alternative, fencing would be installed to limit access to
contaminated soils. Deed restrictions would be obtained to
maintain industrial restricted use for this and adjacent land (up
to 330 feet from the contaminated areas). Monitoring would be
conducted to assess the migration of contamination.
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Alternative 2:
IN-8ITU CONTAINMENT
Capital Cost: $75,640
Annual O&M Costs: $1,000
Present Worth: $105,640
Time to Implement: 12 months
All soils containing in excess of 10 ppm of PCBs (approximately
7,700 square feet) would be covered with twelve inches of clean
soil, and then would be paved with a three-inch layer of asphalt.
The recharge basin would be filled and capped similarly. A new
recharge basin would be constructed to replace the existing one.
The costs above include replacement of the asphalt after 15
years. Bi-annual inspections would be performed for a 30-year
period to ensure that the cap is maintained in good condition.
Deed restrictions would be obtained to maintain adjacent property
as an industrial restricted area.
Alternative 3:
OFF-SITE LANDFILLING OF SOILS IN EXCESS OF 25 PPM
Capital Cost: $639,914
Annual O&M Costs: $1,000
Present Worth: $669,914
Time to Implement: 13 months
All soils in excess of 25 ppm of PCBs would be excavated from the
site and hauled to a chemical waste landfill permitted under the
Toxic Substances Control Act (TSCA). Soils in excess of 10 ppm
would be contained in-place as in Alternative 2. Deed
restrictions would be required to maintain adjacent property as
an industrial restricted area.
\
Alternative 4:
OFF-SITE LANDFILLINQ OF SOILS IN EXCESS OF 25 PPM; OFF-SITE
THERMAL DESTRUCTION OF SOILS IN EXCESS OF 500 PPM
Capital Cost: $717,734
Annual O&M Costs: $1,000
Present Worth: $747,734
Time to Implement: 13 months
This alternative is similar to Alternative 3, except that soils
containing concentrations of PCBs greater that 500 ppm would be
hauled off-site and thermally destroyed in an incineration
facility permitted to burn PCBs. Soils in excess of 10 ppm would
be contained in-place as in Alternative 2. Deed restrictions
would be required to maintain adjacent property as an industrial
restricted area.
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10
Alternative 5:
ON-SITE BIOREMEDIATION OF SOILS IN EXCESS OF 25 PPM
Capital Cost: $1,230,220
Annual O&M Costs: $1,000
Present Worth: $1,260,220
Time to Implement: 36 months
Soils with PCB concentrations exceeding 25 ppm would be excavated
and placed on leaching beds to be constructed on-site. These
soils would then be washed with detergents, and the leachate
collected. The leachate would then be introduced into a
bioreactor, and the leached soil would then be fed into the
bioreactor. Soils exceeding 10 ppm that remain on site would be
contained in-place, as in Alternative 2. Deed restrictions would
be required.
Alternative 6:
ON-SITE BIOREMEDIATION OF SOILS IN EXCESS OF 25 PPM; OFF-SITE
THERMAL DESTRUCTION OF SOILS IN EXCESS OF 500 PPM
Capital Cost: $1,288,494
Annual O&M Costs: $1,000
Present Worth: $1,318,494
Time to Implement: 24-36 months
This alternative is very similar to Alternative 5, with the
exception of soils containing concentrations of PCBs greater that
500 ppm, which would be hauled off-site and thermally destroyed
in an incineration facility permitted to burn PCBs. Soils in
excess of 10 ppm would be contained in-place as in Alternative 2.
Deed restrictions would be required.
Alternative 7:
ON-SITE THERMAL DESTRUCTION OF SOILS IN EXCESS OF 25 PPM
Capital Cost: $1,376,170
Annual O&M Costs: $1,000
Present Worth: $1,406,170
Time to Implement: 19 months
Soils exceeding 25 ppm would be excavated and treated by a mobile
thermal destruction unit which would be set up on-site. Soils
above 10 ppm that remain on-site will be contained in-place as in
Alternative 2. Deed restrictions would be required.
Alternative 8:
OFF-SITE THERMAL DESTRUCTION OF SOILS IN EXCESS OF 25 PPM
Capital Cost: $2,160,130
Annual O&M Costs: $1,000
Present Worth: $2,190,130
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11
Time to Implement: 13 months
This alternative is similar to Alternative 7, however, instead of
bringing a mobile thermal treatment unit on-site, the excavated
materials would be sent off-site to a facility permitted to
incinerate PCBs. Soils- above 10 ppm that remain on-site will be
contained in-place as in Alternative 2. Deed restrictions would
be required.
Alternative 9:
OFF-SITE LANDFILLING OF SOILS IN EXCESS OF 10 PPM
Capital Cost: $917,830
Annual O&M Costs: $0
Present Worth: $917,830
Time to Implement: 13 months
Soils with PCB concentrations above 10 ppm would be excavated and
shipped to an off-site TSCA-permitted landfill. Clean fill would
be placed in excavated areas, and the area would be paved.
Alternative 10:
OFF-SITE LANDFILLING OF SOILS IN EXCESS OF 10 PPM; OFF-SITE
THERMAL DESTRUCTION OF SOILS IN EXCESS OF 500 PPM
Capital Cost: $995,650
Annual O&M Costs: $0
Present Worth: $995,650
Time to Implement: 13 months
Soils that exceed a PCB concentration of 10 ppm would be
excavated. Soils below 500 ppm would be shipped to an off-site
TSCA-permitted chemical waste landfill. Soil with concentrations
above SOOxppm would require treatment at an off-site thermal
destruction facility, which is permitted to burn PCBs. Excavated
soils would be replaced with clean fill and then the excavated
areas, except for the recharge basin would be repaved.
Alternative 11:
ON-SITE BXOREMEDIATION OF SOILS IN EXCESS OF 10 PPM
Capital Cost: $1,726,310
Annual O&M Costs: $0
Present Worth: $1,726,310
Time to Implement: 42 months
Soils that exceed 10 ppm would be excavated and placed on
leaching beds to be constructed on-site. These soils would then
be washed with detergents, and the leachate collected. The
leachate would then be injected into the bioreactor, and the
leached soil would then be fed into the bioreactor for treatment
by biological breakdown of the contaminants.
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12
Alternative 12:
ON-SITE BIOREMEDIATION OF SOILS IN EXCESS OF 10 PPM; OFF-SITE
THERMAL DESTRUCTION OF SOILS IN EXCESS OF 500 PPM
Capital Cost: $1,784,584
Annual O&M Costs: $0
Present Worth: $1,784,584
Time to Implement: 36 - 42 months
This alternative is very similar to Alternative 11, however,
soils exceeding 500 ppm would be segregated and shipped off-site
to a facility permitted to incinerate PCBs.
Alternative 13:
ON-SITE THERMAL DESTRUCTION OF SOILS IN EXCESS OF 10 PPM
Capital Cost: $1,955,660
Annual O&M Costs: $0
Present Worth: $1,995,660
Time to Implement: 20 months
Soils exceeding 10 ppm would be excavated and treated by a mobile
thermal destruction unit which would be set up on-site.
Alternative 14:
OFF-SITE THERMAL DESTRUCTION OF SOILS IN EXCESS OF 10 PPM
Capital Cost: $3,306,740
Annual O&M Costs: $0
Present Worth: $3,306,740
Time to Implement: 13 months
This alternative is similar to Alternative 13, however, instead
of bringing a mobile thermal treatment unit on-site, the
excavated materials would be sent off-site to a facility
permitted to incinerate PCBs.
VIII. SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
In accordance with the National Contingency Plan (NCP), a
detailed analysis of each alternative is required. The purpose
of the detailed analysis is to objectively assess the
alternatives with respect to nine evaluation criteria that
encompass statutory requirements and include other gauges of the
overall feasibility and acceptability of remedial alternatives.
This analysis is comprised of an individual assessment of the
alternatives against each criterion and a comparative analysis
designed to determine the relative performance of the
alternatives and identify major trade-offs, that is, relative
advantages and disadvantages, among them.
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13
The nine evaluation criteria against which the alternatives are
evaluated are as follows:
Threshold Criteria - The first two criteria must be satisfied in
order for an alternative to be eligible for selection.
1. Overall Protection of Human Health and the Environment
addresses whether a remedy provides adequate protection
and describes how risks posed through each pathway are
eliminated, reduced, or controlled through treatment,
engineering controls, or institutional controls.
2. Compliance with Applicable, or Relevant and Appropriate
Requirements (ARARs) is used to determine whether each
alternative will meet all of its federal and state
ARARs. When an ARAR is not met, the detailed analysis
should discuss whether one of the six statutory waivers
is appropriate.
Primary Balancing Criteria - The next five "primary balancing
criteria" are to be used to weigh major trade-offs among the
different hazardous waste management strategies.
3. Long-term Effectiveness and Permanence focuses on any
residual risk remaining at the Site after the
completion of the remedial action. This analysis
includes consideration of the degree of threat posed by
the hazardous substances remaining at the Site and the
adequacy of any controls (for example, engineering and
institutional) used to manage the hazardous substances
remaining at the Site.
4. Reduction of Toxicity, Mobility, or Volume Through
Treatment is the anticipated performance of the
treatment technologies a particular remedy may employ.
5. Short-term Effectiveness addresses the effects of the
alternative during the construction and implementation
phase until the remedial response objectives are met.
6. Implementability addresses the technical and
administrative feasibility of implementing an
alternative and the availability of various services
and materials required during its implementation.
7. Cost includes estimated capital, and operation and
maintenance costs, both translated to a present-worth
basis. The detailed analysis evaluates and compares
the cost of the respective alternatives, but draws no
conclusions as to the cost-effectiveness of the
alternatives. Cost-effectiveness is determined in the
remedy selection phase, when cost is considered along
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14
with the other balancing criteria.
Modifying Criteria - The final two criteria are regarded as
"modifying criteria," and are to be taken into account after the
above criteria have been evaluated. They are generally to be
focused upon after public comment is received.
8. State Acceptance reflects the statutory requirement to
provide for substantial and meaningful State
involvement.
9. Community Acceptance refers to the community's comments
on the remedial alternatives under consideration, along
with the Proposed Plan. Comments received during the
public comment period, and the EPA's responses to those
comments, are summarized in the Responsiveness Summary
which is a part of this ROD.
The following is a summary of the comparison of each
alternative's strengths and weaknesses with respect to the nine
evaluation criteria.
1. Overall Protection of Human Health and the Environment.
Alternatives which would require the excavation and removal or
treatment of PCB contamination in excess of 10 ppm are the most
protective of human health and the environment. When soils
exceeding this concentration are removed, risks from direct
contact, ingestion, and inhalation of PCB-contaminated soil are
reduced to acceptable levels for any future land-use. It should
be recognized that all excavated areas would be backfilled with
clean soil and these areas, except for the recharge basin would
be repaved with asphalt. This would further reduce the potential
for exposure and make the remedy more protective.
Alternatives that excavate and remove soils in excess of 25 ppm
would be within EPA's acceptable risk range of 104 to 10*, but
the remedy would be less protective than a 10 ppm cleanup level.
In addition, soils between 10 ppm and 25 ppm would have to be
contained and deed restrictions placed on the property to
maintain it, as well as property adjacent to it, as an industrial
area.
In-place containment of the contaminated soils, although reducing
the overall risk, would not be protective of employees who work
at the Site and come into direct contact with the material below
the cap while working on utilities. In addition, the
contaminated soil which was previously excavated and the soil in
the recharge basin would not be contained and would therefore
still present a risk.
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15
2. Compliance with ARARs.
The Toxic Substances Control Act (TSCA) is applicable for the
current disposal of soil with PCB concentrations in excess of 50
ppm. Under the TSCA regulations, this material must be
incinerated, treated by a method equivalent to incineration, or
be disposed of in a chemical waste landfill. The soil that was
excavated during the underground fuel oil tank removal is in
excess of 50 ppm, and therefore, the no-action and in-place
containment alternatives would not comply with this ARAR for this
material. In the other alternatives, during the remediation
process, TSCA would apply to the disposal of any excavated
material with PCB contamination in excess of 50 ppm.
The TSCA PCB Spill Cleanup Policy outlines the measures to
address spills of PCBs after its effective date of May 4, 1987.
Because the disposal or spills of PCBs at the Site occurred prior
to this date, the TSCA PCB Spill Cleanup Policy is not
applicable. However, as a codified policy representing
substantial scientific and technical evaluation, the TSCA PCB
Spill Cleanup Policy is used as a "To Be Considered" (TBC)
criterion. As such, the cleanup standards set in the policy, 10
ppm for residential areas and 25 ppm for industrial area, were
used in the FFS to evaluate remedial actions at the Site.
The EPA guidance document, "Guidance on Selecting Remedies for
Superfund Sites with PCB Contamination" is also a TBC criterion.
This document suggests that in most cases, in an industrial
setting, all material with PCB concentrations exceeding 500 ppm
should be treated. In cases where remaining material can be
safely contained, containment is the remedy recommended.
However, there is an exception for small volumes, which is
suitable for this site. By using this exception and selecting
full treatment, the guidance recommends cleanup of all material
with PCB concentrations exceeding 10 ppm, in an industrial area.
Such a cleanup would require no long-term management controls,
and no access restrictions.
Alternatives 4, 6, 7, 8, 10, 12, 13 and 14 all require the
incineration of some portion of the PCB-contaminated material.
Any incinerator that is used must comply with TSCA requirements
that the incinerator achieve a destruction and removal efficiency
of 99.9999 percent. Only incinerators that could achieve this
destruction and removal efficiency could be used in order to
comply with this ARAR.
Treatability studies would be necessary to ensure that
bioremediation could treat the contamination to levels that could
be considered to be equivalent to incineration.
Land Disposal Restrictions are not ARARs for the soil at the Site
because the material is not a restricted waste regulated under
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16
the Resource Conservation and Recovery Act (RCRA).
3. Long-Term Effectiveness and Permanence
Alternatives 9 through 14, which would remove or treat contam-
inated soils with PCB contamination in excess of 10 ppm would
leave the smallest residual risk at the Site, therefore, these
alternatives would be considered to have a very high degree of
permanence. However, the effectiveness of bioremediation would
have to be confirmed through pilot testing before its implementa-
tion. No long term monitoring, deed restrictions, or five-year
review would be required with alternatives 9 through 14, because
the Reasonable Maximum Exposure in a residential future-use
scenario is calculated to be 1.8 x 10'5, which is within EPA's
acceptable risk range of 10"" to 106.
Alternatives 1 through 8 would leave residual contamination in
excess of 10 ppm, and therefore would require the use of deed
restrictions to maintain the property within 0.1 kilometers
(approximately 330 feet) of the contamination as industrial
property. Any of these alternatives would be less permanent than
one which cleaned up to a concentration of 10 ppm. Long-term
monitoring and a five-year review would be required for the no-
action alternative.
One sample from former Sump 5 detected PCBs, at a concentration
of 24 ppm, which is above the action level of 10 ppm. This
sample was at a depth of 10 feet which is presumably the surface
of the sump prior to being filled. With 10 feet of soil on top
of a relatively low concentration of PCBs, the long-term risk
from this area is minimal.
4. Reduction of Toxicity, Mobility or Volume Through Treatment
Alternatives which would provide for treatment, thermal
destruction or bioremediation, of all the PCB-contaminated soils
would be preferred under this criterion because they destroy the
PCB contamination, thereby reducing the toxicity, mobility and
volume of all the PCB contamination through treatment.
Alternatives that provide for thermal destruction of soils
contaminated in excess of 500 ppm would reduce the toxicity,
mobility and volume of the most highly contaminated material.
Off-site landfilling options, while reducing the volume of the
contamination on-site, does not provide for treatment, and is
therefore not preferred under this criterion.
5. Short-Term Effectiveness
All alternatives that involve the excavation of PCB-contaminated
soils would increase the short-term risk. Similarly, on-site
treatment alternatives would require materials handling that
would increase the short-term risk. These risks could easily be
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17
kept to acceptable levels by using construction techniques that
control dust emissions. Off-site alternatives would present the
lowest risk because the contaminated material would be handled
on-site for a shorter period of time. The off-site alternatives
would simply require excavation and then shipping of the material
from the Site. These alternatives could be accomplished within
approximately one to two months of work on-site. Alternatives
which involve on-site treatment would involve between 7 and 23
additional months before the remedy would be completed.
On-site incineration would require a mobilization period and,
most likely, test burns to ensure that an acceptable destruction
and removal efficiency could be achieved. This, as well as the
treatment period, lengthens the overall time for remedial
activities occurring at the Site. Bioremediation alternatives
would require pilot studies to evaluate the effectiveness of the
process. This would also lengthen the time until the Site was
remediated. In addition, it is estimated that the bioremediation
process, because it is temperature dependent, would take several
summer seasons to treat the soil down to acceptable levels.
6. Implementability
Off-site landfilling alternatives are probably the most
implementable of all the alternatives, assuming that there would
be capacity for the 700 to 1100 cubic yards of soil in a chemical
waste landfill. Off-site incineration of the soils that exceed
500 ppm of PCBs would probably not be a problem because there are
only approximately 36 cubic yards of soils at this concentration.
On the other hand, capacity at an off-site incinerator for the
entire volume of contaminated soil may be difficult to find.
On-site alternatives may be difficult to implement because the
Site is an active facility. In addition, pilot scale testing for
bioremediation or test burns for on-site incineration would be
impractical due to the small volume of material to be treated. A
large percentage of the material would be treated in the pilot
study before the remedy could be officially approved.
Accordingly, the time for the testing, mobilization and
demobilization would be close to that for the actual treatment.
7. COSt
The estimated costs for the alternatives range from a current
value cost of $105,640 for in-situ containment, to $3,306,740 for
off-site incineration of all soils over 10 ppm. Capital costs
include fixed costs (costs associated with equipment mobilization
and site preparation) and non-fixed costs associated with
treatment of a specific disposal area). There are no operation
and maintenance (O&M) costs for remedies which remove the soil
contaminated in excess of 10 ppm from the Site. The O&M costs
are very low for the alternatives 2 through 8, requiring only bi-
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18
annual inspections of the asphalt cap. The no-action alternative
would require long-term, monitoring which would actually make this
alternative more expensive than the in-situ containment alterna-
tive.
8. State Acceptance
The State of New York concurs with the selected remedy.
9. Community Acceptance
The community accepts the selected remedy. The public generally
approved of the any remedial action, but expressed concern over
dust emissions from the Site during excavation. All comments by
the community that were received during the public comment period
are addressed in the attached Responsiveness Summary.
IX. THE SELECTED REMEDY
Based on the results of the RI and FFS, as well as a detailed
evaluation of all comments submitted by interested parties during
the public comment period, EPA has selected Alternative 10. This
alternative includes:
1. Excavation of PCB-contaminated soils in excess of 10 ppm in
the direct spill area and the transport areas surrounding the
pilot plant. Soils at the bottom of the recharge basin will be
excavated to ten feet from the existing surface. Confirmatory
sampling will be performed to ensure soils that remain after the
excavation will have PCB concentrations that do not exceed 10
ppm.
2. Soils with PCB concentrations between 10 ppm and 500 ppm,
approximately 1100 cubic yards, will be shipped for disposal to
an off-site chemical waste landfill permitted under TSCA.
3. Stockpiled soils, which were previously excavated during the
removal of the underground fuel oil tank, will be included in the
disposal of PCB-contaminated soils at an off-site chemical waste
landfill.
4. Soils with PCB concentrations exceeding 500 ppm, approx-
imately 36 cubic yards, will be shipped off-site to a TSCA-
permitted incineration facility. Residuals will be disposed of,
as appropriate, by the incineration facility.
5. Excavated areas will be backfilled with clean soil, and these
areas, excluding the recharge basin will be paved with asphalt as
appropriate.
6. The PCB contamination in former Sump 5 will be left in-
place.
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The selected alternative provides the best balance among the nine
criteria used by EPA to evaluate remedial action alternatives.
The capital cost of this alternative is approximately $1,000,000.
There is no operation and maintenance cost associated with this
alternative. It should take approximately 13 months to implement
the remedy from the date that the design is initiated. Actual
field work should be accomplished in about one to two months.
The 10 ppm cleanup level was selected based on the TSCA PCB Spill
Cleanup Policy for residential areas, and the current EPA
guidance, "Guidance on Remedial Actions for Superfund Sites with
PCB Contamination," dated August 15, 1990. The risk assessment
supported this cleanup level. The Reasonable Maximum Exposure
for a future, residential-use scenario, would be within EPA's
acceptable risk range with a 10 ppm cleanup level. Cleanup goals
higher than 10 ppm PCBs would require deed restrictions to
maintain the area around the PCB contamination for 0.1 kilometer
(about 330 feet) as industrial property. Such institutional
controls are difficult to monitor and enforce on a long-term
basis, especially since this site is located in a residential
neighborhood.
X. STATUTORY DETERMINATIONS
l. Protection of Human Health and the Environment
The selected remedy is protective of human health and the
environment. Soils with PCB concentrations exceeding 10 ppm will
be removed from the Site, and the most contaminated material will
be thermally destroyed. With a 10 ppm cleanup goal, the risk
assessment calculated that future-use scenarios for site workers
and residents would represent a risk of 2.7 x 10s, and 1.8 x 10s,
respectively. This is within EPA's acceptable risk range of 10*
to 10*. The short-term risk from excavating the contaminated
soil should be minimal. If it is necessary, construction
practices for dust control would reduce the short-term risk even
further.
2. Compliance with Applicable or Relevant and Appropriate
Requirements
In order to select an action level for the cleanup of the Site,
EPA and the State of New York have agreed to consider the TSCA
PCB Spill Cleanup Policy (40 CFR, Part 761, Subpart G), which is
not legally binding. The selected remedy will remove PCB-
contaminated soils in excess of 10 ppm, which is consistent with
the TSCA PCB Spill Cleanup Policy. The EPA document "Guidance on
Selecting Remedies for Superfund Sites with PCB Contamination,"
although not legally binding, was also considered in the
selection of a remedy for the site.
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Action-specific ARARs are as follow. During the remediation,
TSCA is applicable for excavated soils with concentrations
greater than 50 ppm (40 CFR 761.60). For the thermal destruction
of soils with PCB concentrations greater than 500 ppm, an
incinerator that can attain a destruction and removal efficiency
of 99.9999 percent will be an applicable requirement (40 CFR
761.70). The disposal of the soils containing less than 500 ppm
in a chemical waste landfill permitted under TSCA will comply
with 40 CFR 761.60. Even though soils with PCB concentrations
between 10 and 500 ppm will be disposed of in a landfill, the
RCRA Land Disposal Restrictions are not considered to be an ARAR
because the material is not a RCRA-restricted waste.
3. Cost-Effectiveness
The selected alternative has a cost proportionate to its
effectiveness. Off-site landfilling is the lowest cost
alternative which removes the contamination from the Site, and
the selected remedy calls for such disposal of the bulk of the
material. However, due to the preference for treatment under
CERCLA, the most highly contaminated material at the Site
requires treatment. Off-site incineration is the most cost-
effective method for the treatment of this small volume of highly
contaminated material.
4. Utilization of Permanent Solutions and Alternative Treatment
Technologies or Resource Recovery Technologies to the Maximum
Extent Practicable
EPA and the State of New York have determined that the selected
remedy utilizes permanent solutions to the maximum extent
practicable. Of those alternatives that are protective of human
health and the environment and comply with ARARs, EPA and the
State of New York believe that the selected remedy provides the
best balance of trade-offs in terms of the five balancing
criteria; long-term effectiveness and permanence, reduction of
toxicity, mobility, or volume through treatment, short-term
effectiveness, implementability, and cost. The modifying
considerations of State and community acceptance also play a part
in this determination.
The long-term effectiveness and permanence of the selected
alternative is very high in that the soils with the highest
concentration of PCBs are being thermally destroyed, which is the
most effective proven technology for treating PCBs. In addition,
soils with concentrations greater than the 10 ppm action level
and less than 500 ppm will be removed from the Site and disposed
of in a chemical waste landfill. Therefore, residual
contamination at the Site will be low enough that no long-term
monitoring, deed restrictions, or five-year review would be
required.
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As stated above, the most highly contaminated soils will be
thermally destroyed, so the selected remedy follows the statutory
preference for remedies which utilize treatment to reduce the
toxicity, mobility, or volume of the contamination. However, the
bulk of the material will not be treated. Rather, it will be
disposed of in an off-site chemical waste landfill. This
remedial option is justified by the other balancing criteria.
On-site treatment alternatives would require pilot studies which
are expensive and add to the overall remediation time. Because
of the relatively small volume of soil to be remediated at the
Site, the on-site alternatives would not be effective in the
short-term or with respect to cost. The implementation of off-
site thermal treatment for all of the PCB-contaminated soil might
be difficult because of limited capacity at TSCA permitted
facilities. In addition, off-site incineration of soils
contaminated with 10 to 500 ppm concentration PCBs would not be
cost effective because of the great expense to incinerate soil
with relatively low concentrations of PCBs.
The cost of the selected remedy is the least costly of the
remedies that are protective of human health and the environment
and that provide for treatment of the most hazardous material.
5. Preference for Treatment as a Principal Element
The selected remedy provides for the thermal destruction of the
PCB-contaminated soils that represent the principal threat: i.e.,
the soil with concentrations over 500 ppm. This is only a small
portion of the total volume of soils to be remediated. There are
36 cubic yards of soil with concentrations exceeding 500 ppm,
compared to roughly 1100 cubic yards of soil with concentrations
between 10 ppm and 500 ppm. However, treatment of all of the
soil is not cost-effective for the reduction of risk that would
be achieved. Off-site thermal destruction would be very costly,
while on-site remedies would be impractical due to the relatively
small volume of material to be treated. Therefore, the statutory
preference for remedies that employ treatment as a principal
element is satisfied.
The contamination in former Sump 5 is at a relatively low level,
and has approximately 10 feet of cover material over it, so that
it does not warrant inclusion in this remedial action.
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APPENDIX A
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I • IU4IIUUIIII I
FIGURE 1
HOOKER/RUCO SITE
HICKSVIUE. NEW YORK
REGIONAL LOCATION
HOOKER/hUCO
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M
U
HOOKER/RUCO
SITE
Grumma
Bethpa
HOOKER/RUCO SITE
HICKSVILLE. NEW YORK
SITE LOCATION
FIGURE 2
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FIGURE 3
AREA ADDRESSED BY
OPERABLE UNIT 2
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PLANT
• SOIL BORING
O TEST HOLE
10.4 CONCENTRATION IN
(2 91 SAMPLE DEPTH
FIGURE 4
/ I \
440 jj /J Vs'
' '• • . /'4 \
J>• - \ •- -L ^ S..MT\
-IA- ; . /A s-..j r T •
t--b' I/" "'
•"•* * «AL so i
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NOIti ALI
PPM.
FIGURE 5
US I NVIKONMI N I Al CKOIICIION Al.l
HOOKI K KUCO SlU
Mill SAHI'I INI i ANAI Ylllftl
kl jUl IS I UK AKIILI IIK 1.-4U
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I
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APPENDIX B
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TABLE 1
Hooker/Ruco Site
Tabulation of LEG Data
SOURCE : LBG FFS (1989) , PLATE 2 ; LEG RI (1990)
Location ; Sampling Range ; Aroclor-1248 Concentration;
(feet) (ppm)
Soil Borings
AA l.i 19.00
BB 0.9 14.50
CC 1.0 15.80
DD 1.0 12.90
EE 1.0 10.40
EE 2.4 0.20
FF 0.9 2.50
FFF-1 0.6-1.0 25.00
FFF-2 1.6-3.0 1.50
FFF-3 3.0-4.5 NDO.l
FFF-4 4.5-6.0 NDO.l
GG-1 1.0 192.70
GG-2 2.2 11.30
GG-3 2.6 26.00
H 0.7 23.00
HH-1 1.1 562.00
HH-2 2.3 105.30
II 0.9 4.30
J 1.0 59.00
JJ-1 1.0 21.50
JJ-2 2.5 16.00
K-l N 0.9 61.00
K-2 1.7-1.8 0.20
KK 0.9 0.70
L 1.1 - 0.70
H 1.7 15.00
MB 0.6 4.90
MM-1 0.6 8.30
MM-2 0.9 7.40
N 0.9 8.00
0 1.9 0.80
00 1.0 25.10
00 3.0 6.60
P 1.0 4.40
PP-1 1.0 36.40
PP-2 2.9 10.40
Ql 0.8 14.00
Page 1
-------
TABLE 2
HOOKER/RUCO SITE
AROCLOR-1248 CONCENTRATION RANGE, FREQUENCY OF
DETECTION AND MEAN VALUE
Aroclor-1248
Surface Soils (0-3 feet)
Range of
Detected
Values
0.17-23000
Frequency of
Detection
116 of 116
Upper 95%
Confidence
Interval
2188
Aroclor-1248
Subsurface Soils (<3 feet)
Range of
Detected
Values
0.10-1900
Frequency of
Detection
32 of 42
Upper 95%
Confidence
Interval
692
Note: All units in ppm.
-------
6/6/90
TABLE 3
Hooker/Ruco Site
Surf are Soil Inge* lion Present-Use Pathu.iy Model
RISKS TO Silt WORKERS
CARCINOGENS •
Chronic Daily
Chronic Daily
Croup
AVERAGE SURFACE SOIL INGEST ION EXPOSURE
Intake (••/«• -day)
Intake (mg/kg-day)
Compound
Adults MOCK* -12*8
CARCINOGENS • REASONABLE MAXIMUM
Chronic Daily
Chronic Dally
Group
Intake (mg/kg-day)
Intake (mg/kg-day)
Compound
« Soi 1 X
Cone'
• mg/kg X
Soil
Cone.
(•g/kg)
Soil
Intake
100 mg/dny
Intake
dag/day)
X Bioavail . X
factor
X 0.15 X
Bio-
avail abil ity
Factor
2.19E»03 100 0.15
SURFACE SOIL INGEST ION EXPOSURE
Soil X
Cone
•g/kg x
Soil
Cone.
(•g/kg)
Soil
Intake
100 ng/day
Intake
(mg/day)
X 8 i oava i 1 . X
factor
X 0.15 X
Bio-
availability
Factor
1 X
Hotly Ut .
1 X
70 kq
Body
Weight
(kg)
70
1 X
Body Ut.
1 X
70 kg
Body
Weight
(kg)
Days Exposed X
Days/Tear
IBS days X
365 days
Pays Exposed
Days/Tear
5.07E-01
Days Exposed X
Days/Tear
195 days X
365 days
Days Exposed
Days/Tear
Years Exposed X
Tears lifetime
9 yrs X
75 yrs
Tears Exposed
Tears lifetime
1.20E-01
Tears Exposed X
Tears lifetime
30 yrs X
75 yrs
Tears Exposed
Tears lifetime
1kg
10 6 tng
1kg
10 6 mg
RISK
COI SF Sf'COl
2.B5E 05 7.70E»00 2.20E 04
1kg
10 6 mg
1kg
10 6 mg
RISK
COI Sf SF'COI
Adults AROCLOR-12«S
2.19E«OJ
100
0.15
70
5.J4E-01
4.0W 01
1.00E 04 7.70E«00 7.71E 04
Pnge 1
-------
6/6/90
Hookor/Ruco Site
Surface Soil Ingesf.on Present Use Pathway Nodol
RISKS 10
CARCINOGENS - AVERAGE SURFACE SOIL
hronic Daily Intake (mg/k«-4*y) »
hronic Daily Intake (mg/kg-day) *
Croup Compound
INGEST ION EXPOSURE
soi i ,
Cone
mg/kg
Soil
Cone.
(mj/kg)
X Soil X Bioavail. X
Intake Fartor
X 100 mg/day X 0.15 X
Bio-
Intake availability
(mg/day) factor
1
Body Ut .
1
56 kg
Body
Weight
(kg)
X Days Exposed
Days/fear
X 80 days
365 days
Days Exposed
Days/Year
X Tears Exposed X
Tears Lifetime
X 5 yrs X
75 yrs
Tears Exposed
Tears Lifetime
1kg
10 6 mg
1kg
10 6 mg
COI SF
RISK
SF'CDI
Adults AROaOR-1248
2.19E«03
100
0.15
56
2.19E-01
6.67E-02
8.56E 06 7.70E»00 6.59E 05
CARCINOCEIIS • REASONABLE HAXIUM S«t»Cf «nU |MctSTIni( rtDnflmc
hronie Daily Intake (mg/kg day) . soil x s»ii ...
.£1 * • rr • *w*-* ^^^d x T^E^ , lkg
Hronic D.My ,ntak. ^..^ . .,,,, „ 200 ^^ „ '"J* , "^ ^ t °^r ^TaTsTipe -TToV
Croup Compound
Soil
Cone.
(•9/kg)
Intake
(mg/day)
56 kg
•io- Body
availability Height
factor (kg)
365 days
Days Exposed
Days/Tear
75 yrs 10 "6 mg
Tears Exposed
Tears Lifetime CDI
RISK
Sf Sf'CDI
Adults AROCIOR-1248
2.19E«03
200
0.15
56
4.38E-01
6.67E-02
3.43E-05 7.70E»00 2.64E-04
Page
-------
ft/6/90
Hootrrr/fluro Site
Surface Soil Direct Coolnct Present -Use P.ilhu.iy Model
BISKS 10 Sift WOBKtBS
CMC IMOGENS - AVERAGE SUREACE SOU. COMTACT EXPOSURE
Chronic Daily Intake («g/kfl-day Soil X Skin XBioavail.X Skin XIX Days Exposed X fears Exposed X t kg
Cone Sur'face Area fnctor Deposition Body Ut Days/Year rears lifetime 10 6 ng
.hronic Daily Intake (•g/kf-day «g/kf X 3510 en 2 X 6.00E 03 X 0.5 mg/rra 2 XI X 185 day; X 9 yrs X 1 kg
TO kg 365 days 75 yrs 10 6 mg
Soil Skin Bio- Skin Body
Cone Surface availability Deposition Weight Days Exposed Tears Exposed
Croup Compound (ao/kg) Area (cm ? ) Factor (mg/cm ?) (kg) Pays/Tear Tears lifetime COI
Sf
«ISK
sr«coi
Adults AROCLOM-1248
2.19E»03
3.5U»03
6.00E-03
0.5
70
5.07E-01
1.ZOE-OI
2.00E-05 7.70£«00 1.54E-04
CAHCIMOGENS - tEASOHABU MKIMUH
Chronic Daily Intake (ng/kf-day
Chronic Dally Intake (ng/kf day
SuHfACC SOU CONTACT EXPOSURE
Soil X Skin X Bioavail. X
Cone Surface Area factor
•g/kf X 8)20 cm 2 X 1.20E-02 X t.O ng/cia'2 X
Skin XI X Days Exposed X Teari Exposed X 1 kg
Deposition Body Ut Days/Year Tears Lifetime 10 6 mg
1 X 195 days X 30 yrt X 1 kg
Croup
Compound
Soil
Cone
(«9/kg)
Skin
Surface
Area (cm 2 )
Bio-
availability
factor
Skin
Deposition
(mg/cnT2>
70 kg
Body
Weight
(kg)
365 days
Days Exposed
Days/Year
75
Years
Years
i yrs 10 '6 ng
Exposed
lifetime CDI
RISK
sr SE*CDI
Adults AROCUM-12«8
2.19E»03 8.32E*03
1.20E 02
1.0
70
5.34E 01
4.00E 01
6.67E-04 7.70E«00 5.UE-03
-------
6/6/90
Mooker/Ruco Site
Surface Soil Direct Contnct Present-Use Pathu.iy Hodel
RISKS FO TRESPASSERS
CARCINOGENS • AVERAGE SURFACE SOIL CONTACT EXPOSURE
Chronic Daily Intake (mg/kg-day)
Soil X Skin KBioavail. X Skin X 1 X Days Exposed X Years Exposed X 1 kg
Chronic
Group
Adults
Daily Intake (mg/kg-day)
Compound
AROCLOR-1248
C..RC IMOGENS - REASONABLE MAXIMUM
Chronic
Chronic
Group
Daily Intake (mg/kg-day)
Dally Intake (lag/kg-day)
Compound
Cone
•g/kg X
Soil
Cone
(•g/kg)
2.19E»03
Surface Area
3510 cm 2
Skin
Surface
Area (cm 2 )
3.51E«03
factor
X 6.00E 03 X
Bio-
avail abil ity
factor
6.00E-03
Deposit inn
0.5 mq/cm ?
Skin
Depos i t i on
(mq/cm 2)
0.5
Body Ut
X 1 X
70 kg
Body
Ueight
(kg)
70
Days/Year
80 days
365 days
Days Exposed
Days/Year
2.19E 01
Years Lifetime
X 5 yrs X
75 yrs
Years Exposed
Years lifetime
6.67E 02
10 6 mg
1 kg
10 6 mg
CDI
4.81E 06
RISK
SF SF*CDI
7.70E«00 3.70E-05
SURFACE SOU CONTACT EXPOSURE
Soil X
Cone
•g/kg N
Soil
Cone
(•g/kg)
Skin
Surface Area
6320 cm 2
Skin
Surface
Area (cm'2 )
X Bioavail. X
Factor
X 1.20E-02 X
Bio-
availability
Factor
Skin
Deposition
1.0 mg/cm 2
Skin
Deposition
(mg/cm 2)
X 1 X
Body Ut
X 1 X
70 kg
Body
Ueight
(kg)
Days Exposed
Days/Year
160 days
365 days
Days Exposed
Days/Year
X Years Exposed X
Years lifetime
X JLyrt X
75 yrs
Years Exposed
Years lifetime
1 kg
10 6 mg
1 kg
10 6 mg
COI
RISK
SF SF'CDI
Adults AROCKJR-1248
2.19E«03 8.32E«03
1.20E-02
1.0
4.3BE 01
6.67E-02
9.12E-05 7.70E»00 7.02E-04
-------
6/6/90
Hookrr/Ruco Site
Subsurface Soil Ingest ton Future-Use Pathway Modrl
RISK5 fO COM5IRUCIIOM WORKERS
CARCINOGENS - AVERAGE
Chronic Daily Intake
(mg/kg-day)
Chronic Dally Intake
(mg/kg-day)
Compound
SUBSURFACE
• Soil
Cone
Soli
Cone
(mg/kg)
IROCLOR 1248 6.92E«02
CARCINOGENS • REASONABLE FMXIMUN
tnronic Dally Intake
(mg/kg-day)
Chronic Dally Intake
(Mg/kg-day)
Compound
» Soil
Cone
Soil
Cone
(mg/kg)
SOIL INGEST ION EXPOSURE
K Soil
Intake
K 100 fig/day
Intake
(mg/day)
100
SUBSURFACE SOU
X Soli
Intake
R 100 Mg/day
Intake
(mg/day)
X Bioavall. X
Factor
X 0.15 X
Bio-
availability
Factor
1
Body Ut .
1
70 kg
Body
Ueight
(kg)
0.15 70
INGEST ION EXPOSURE
X Bioavail. X
Factor
X 0.1S
Bio-
avail ability
Factor
1
Body Ut.
1
70 kg
Body
Ueight
(kg)
X Days Exposed X
Dnys/Yoar
X 185 days X
365 days
Days Exposed
Days/Tr
5.07E-01
X Days Exposed X
Days/Tear
X 195 days X
365 days
Days Exposed
Days/Tr
Tears Exposed X
To.irs I i fet ime
1 yrs X
75 yrs
Tears Exposed
Tears I i fet ime
1.33E-02
Tears Exposed X
Tears Lifetime
J yrs X
75 yrs
Tears Exposed
Tears lifetime
1kg
10 6 mg
1kg
10 6 mg
COI
1.00E-06
1kg
10 o mg
10 6 mg
COI
RISK
SF SF'CDI
7.70E»00 7.72E-06
RISK
SF SF*OH
AROCLOR-1248
6.92E«02
100
0.15
70
5.34E-01
4.00E-02
3.17E-06
7.70E»00
2.44E-05
Page
-------
6/6/90
Hooker/Rueo Site
Suburfitce Soil IngMtion Future-Use Pathway Model
RISKS TO RFSIDFNIS
CARCINOGENS - AVERAGE SUKUtMCE SOIL INCEST ION
Chronic
Chronic
Croup
Daily Intake (a«/kff-4ay)
Daily Intake
Compound
Adults AROQOR-124B
CARCINOGENS - REASONABLE NAXIMM
Chronic
Chronic
Group
Daily Intak* (mg/kg-diy)
Dally Intake (mg/kg day)
Compound
• Soil / X
Cone
• nig/kg X
Soil
Cone.
EXPOSURE
Soil
Intake
100 nig/day
Intake
(mg/day)
X Bionvail. X
Factor
X 0.15 X
Bio-
avail abil ity
Factor
100 0.15
INGEST ION EXPOSURE
Soil
Intake
100 nig/day
Intake
(ng/day)
X Bioavall. X
Factor
X 0.15 X
Bio-
availability
Factor
1 X
Body Ut.
1 X
70 kg
Body
Weight
(kg)
70
1 X
Body Ut.
1 X
70 kg
Body
Weight
(kg)
Days Exposed X
Days/Tear
43 days X
365 days
Pays Eiiposed
Days/Tear
1.18E-01
Days Exposed X
Days/Tear
150 d»y» X
365 dnys
Oay« Exposed
Days/Tear
Tears Exposed X
Tears Lifetime
9 yrs X
75 yrs
Tears Exposed
Tears Lifetime
1.?0£ 01
Tear* Exposed X
Tears lifetime
30_yr« X
75 yrs
Tears Exposed
Tears Lifetime
1kg
10 6 mg
1kg
10 6 mg
COI
2.10E-06
Tkg
10 6 mg
1*9
10 6 mg
COI
RISK
SF SF'COI
7.70E«00 1.61E-05
RISK
SF SF-COI
Adults AROtlOR-Wd
6.9ZE«02
100
0.15
3.56E 01
4.00E-01
2.HE-OS 7.70t»00 1.63E-04
^^wje
-------
6/6/90
Hooker/Ruro Site
Subsurface Soil Direct Contnct Future-Use Pathway Node)
DISKS 10 COMSIBUCMOM WORKERS
CARCINOGENS • AVERAGE
Chronic Daily Intnke
-------
6/6/90
Hooker/Ruco Sit*
Subsurface Soil Direct Contact Future-Use Pathway Modol
RISKS 10 WtSIOFNIS
CARCINOGENS -
Chronic
Chronic
Group
AVERAGE SUBSURFACt
Daily Intake (mg/kg-day)
Dally Intake (mg/kg-day)
Compound
Adults AROCLOR-1248
CARCINOGENS - REASONABLE NMIHUN
Chronic
Chronic
Group
Daily Intake (mg/kg-diy)
Daily Intake (jag/kg-day>
Compound
5011 CONTACT EXPOSURE
Soil X
Cone
"9/kg X
Soil
Cone
(•9/k9)
6.92E«02
SUBSURFACE
Soil X
Cone
•g/kg X
Soil
Cone
fug/kg)
Skin
Surface Area
J510 cm 2
Skin
Surface
Area (cm 2 )
3.51£«03
SOIL CONTACT
Skin
Surface Area
8)20 CM 2
Skin
Surface
Area (caT2 )
X 8 i onvii i 1 . X
Factor
X 6. ODE -03 X
Bio
availabil ity
Factor
6.00F.-OJ
EXPOSURE
X Bfonvail. X
Factor
X T.20E-02 X
8io-
avai lability
Factor
Skin
Deposit ion
0.5 mq/cmV
Skin
Deposition
-------
6/A/90
Nooker/Ruco Site
Surface Soil Inflation Presrnt-Use Pathway Model
DAILY INTAKE OF SUE WORKERS
CARCINOGENS -
Chronic Dally
(wg/kg day)
Chronic Daily
(mg/kg day)
Compound
AROCIOR- 1248
CARCINOGENS -
Chronic Dally
(mg/kg day)
Chronic Dally
(mg/kg day)
Compound
AVERAGE SURFACE SOIL INHALATION EXPOSURE
Inta • S«ll I
Cone
Inta - my/kg X
Soil
Cone
(mg/kg)
2.19E«03
REASONABLE MAXIMUM
lot* -Soil X
Cone
lot* • mg/kg R
Soil
Cone
<«9/M>
fusp Soil
Cone
?.76E»00
•g/m'3
Susp Soil
Cone
(mg/m 3)
X Length of X
E«p
X 8 hrs/day X
Length of
Exp
(hrs/day)
2.76E*00 8.0
SURFACE SOIL INHALATION
Susp Soil
Cone
2.7«*00
•g/m'S
Susp Soil
Cone
(mg/m-3)
X Length of X
E«P
X 0 hrs/day X
Length of
E»p
(hrs/day)
Inhalation
Rate
1.4 m 3/hr
Inhalation
Rate
(•3/hr)
1.4
EXPOSURE
Inhalation
Rate
3.0 m'3/hr
Inhalation
Rate
(ai'3/hr)
X Bioavail. X
Factor
X 0.15 X
Bio-
avail abil ity
Factor
0.15
X Bionvail. X
factor
X 0.15 X
Bio-
aval lability
factor
1
Body Ul
1
70 kg
Body
Weight
(kg)
70
1
Body Ut
1
70 kg
Body
Weight
(kg)
X Days Exposed
Days/rear
X 185 days
365 days
Days Exposed
Oays/Tr
5.0/E-01
X Days Exposed
Days/Tear
X 195 days
365 days
Days Exposed
Days/Tr
X Tears Exposed X
Tears lifetime
X V yrs K
70 yrs
Tears Exposed
Tears lifetime
1.29E-OI
X Tears Exposed X
Tears Lifetime
X 30 yrs X
70 yrs
Tears Exposed
Tears Lifetime
1 kg
10 6 mg
1 kg
10 6 mg
COI
9.44E 06
1 kg
10 6 mg
1 kg
10 6 mg
COI
AROCIOR-1248
2.19E«03 2.76E»00
8.0
3.0
0.15
70
5.34E-01
4.29E 01
7.1 IE-05
Page 9
-------
6/6/90
Mookrr/Roco Site
Surf nee Soil Inhalation Present-Use Pathway Model
POUT INIAKE Of TRESPASSERS
CARCINOGENS -
Chronic Dally
(mg/kg-day)
Chronic Dally
(mg/kg-day)
Compound
AROUOR-1248
CARCINOGENS •
Chronic Daily
(mg/kg-day)
Chronic Dally
(mg/kg day)
Compound
AVERAGE SUMACf SOU INHALATION EXPOSURE
Inta » fell R
Cone
Inta - mo/kg X
Soil
Cone
(«9/k9)
2.I9E«03
Sutp Soil
Cone
2.74000
«9/*'3
Susp Soil
Cone
(•9/»3)
2. 76* *00
X length of X
E.p
X * hrs/day X
length of
Cup
(hrs/day)
4.0
REASONABLE NAXINIM SURMCC SOIL INHALATION
Inta •toll X
Cone
Inta • mg/kg X
Soil
Cone
(•B/kfl)
Suap Soil
Cone
2.7«f*00
•t/m-s
Susp Soil
Cone
(mg/m-3)
X length of X
Exp
X « hrs/day X
Length of
EKP
{hrs/day)
Inhalation
Rate
1.4 m J/hr
Inhalation
Rate
(m 3/hr)
1.4
EXPOSURE
Inhalation
Rate
3.0 ai'3/hr
Inhalation
Rate
(w'3/hr)
X Bioavail. X
fnctor
X 0.15 X
Bio-
availability
factor
0.15
X Bioavail. X
factor
X 0.15 X
Bio-
aval lability
factor
1
Body Wt
1
56 kg
Body
Weight
(kg)
56
1
Body Wt
1
56 kg
Body
Weight
(kg)
X Days Exposed
Days/Tear
X 80 days
365 days
Days Exposed
Days/Tr
2.19C-01
X Days Exposed
Days/Tear
X 160 days
365 days
Days Exposed
Days/Yr
X Tears Exposed X
Tears lifetime
X 5 yrs X
70 yrs
Tears Exposed
Tears lifetime
7.14E-02
X Tears Exposed X
Tears lifetime
X SJTB X
70 yrs
Tears Exposed
Tears Lifetime
1 kg
10 6 mg
1 kg
10 6 mg
COI
1.42E-06
1 k9
10 6 ng
1 »9
10 6 mg
CDI
AROCLOft-1248
2.m»03 2.76€*00
4.0
3.0
0.15
56
4.38E-01
7.14E-02
6.08E-06
-------
06/12/90
TABLE 4
Hookor/Ruco Site
SUMMATION Of RISKS POSED BY AROCIOR
PRESENT-USE SCENARIO
PATHUAY :
Ingest ion of Soil
Dire-t Contact with Soil
Total Cancer Risk
SITE WORKERS
Average Cancer Risk Reasonable Manimun Cancer Risk
2.206-04 7.71E 04
1.54E 04 S.UE-03
TRESPASSERS
Average Cancer Risk Reasonable Haxirojn Cancer Risk
6.59E-05 2.64E-04
3.70E-05 7.02E-04
3.74E-04
5.91E 03
1.03E-04
9.66E-04
FUIU.E-USE SCENARIO
PATH ;AT :
Ingest ion of Soil
Direct Contact with Soil
Total Cancer Risk
CONSTRUCTION WORKERS
Average Cancer Bisk Reasonable Max I am Cancer Risk
7.726-06 2.44E-05
5.42E-06 1.62E-04
RESIDENTS
Average Cancer Risk Reasonable Haninun Cancer Risk
1.61E-OS 1.63E-04
1.13E-05 1.08E 03
1.31E-05
1.86E 04
2.74E 05
1.24E-03
NOTE :
Target Risk Level = 10E-06
-------
APPENDIX C
-------
Now York State Department of Environmental Conservation
50 Wolf Road, Albany, New York 12233 -7010
Thomas C. Jorllng
Commissioner
M". Richard L. Caspe, P.E.
Director
Emergency & Remedial Response Division c;:~ • -, iqr
U.S. Environmental Protection Agency v"~r ' * *" '
Region II
26 Federal Plaza
New York, NY 10278
Dear Mr. Caspe:
Re: Hooker Chemical /Ruco Polymer Site - ID. No. 130004
Hicksville, Nassau County, New York
The New York State Department of Environmental Conservation (NYSDEC) has
reviewed the draft Operable Unit Two Declaration for the Record of
Decision (ROD) for the above-referenced site. The NYSDEC concurs with
the selected remedy which includes the excavation of PCB-contaminated
soil in excess of 10 ppm, disposal of 10 to 500 ppm PCB-contaminated
soil (1100 cu. yds.) in a Toxic Substances Control Act (TSCA) permitted
chemical landfill, treatment of soil contaminated above 500 ppm (36 cu.
yds.) at an off-site thermal destruction facility, backfilling with
clean soil and repaying.
Please note that our designation of Operable Unit Two for
PCB-contaminated soil is consistent with the Proposed Remedial Action
Plan, dated July 1990. On page 3, paragraph 3, of the Decision Summary
of thes Draft ROD, the designation of operable units should be corrected
accordingly.
If you have any questions, please contact Mr. Kama! Gupta, of my staff,
at (518) 457-3976.
Sincerely,
Edwart}
Deputy Commissioner
cc: R. Tramontane, NYSDOH
D. Tomchuk, USEPA, Region II
-------
APPENDIX D
-------
EPA WORK ASSIGNMENT NUMBER: 012-2PX3
EPA CONTRACT NUMBER: 68-W8-0110
EBASCO SERVICES INCORPORATED
ARCS II PROGRAM
FINAL
RESPONSIVENESS SUMMARY
FOR THE
HOOKER CHEMICAL/RUCO POLYMER SITE
HICKSVILLE, NASSAU COUNTY
NEW YORK
SEPTEMBER 1990
NOTICE
The information in this document has been funded by the United
States Environmental Protection Agency (USEPA) under ARCS II
Contract No. 68-W8-0110 to Ebasco Services Incorporated (Ebasco).
3335K
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DRAFT RESPONSIVENESS SUMMARY
HOOKER CHEMICAL/RUCO POLYMER SITE
HICKSVILLE, NASSAU COUNTY, NEW YORK
The U.S. Environmental Protection Agency (EPA) held a public
comment period from July 31, 1990 through August 30, 1990 for
interested parties to comment on EPA's Focused Feasibility Study
(FFS) and Proposed Plan (PP) for remedial action at the Hooker
Chemical/Ruco Polymer (Hooker/Ruco) Superfund Site in
Hicksville, New York.
EPA held a public meeting on August 7, 1990 at the Oyster Bay
Town Hall, Oyster Bay, New York to describe the remedial
alternatives and to present EPA's preferred remedial alternative
to clean up the Hooker/Ruco site.
A responsiveness summary is required for the purpose of
providing EPA and the public with a summary of citizens'
comments and concerns about the site raised during the public
comment period and EPA's responses to those concerns. All
comments summarized in this document will be considered in EPA's
final decision for selection of the remedial alternative for
cleanup of the site. The responsiveness summary is organized
into the following sections:
I. Responsiveness Summary Overview. This section
briefly describes the public meeting held on August 7,
1990 and includes historical information about the
Hooker/Ruco site.
II. Background on Community Involvement and Concerns.
This section provides a brief history of community
interest and concerns regarding the Hooker/Ruco site.
III. Major Questions and Comments Received During the
Public Comment Period and EPA's Responses to
\Comments. This section summarizes comments submitted
to EPA at the public meeting and during the public
comment period and provides EPA's responses to these
comments.
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I. RESPONSIVENESS SUMMARY OVERVIEW
A. PUBLIC MEETING AND SITE HISTORY
The public meeting for the Hooker/Ruco site began at 7:30 p.m.
on August 7, 1990 with presentations by EPA and was followed by
a question and answer session. Approximately 20 residents and.
local officials attended the meeting.
Melvin Hauptman, Chief, Eastern New York and Caribbean
Compliance Section; Douglas Tomchuk, Hooker/Ruco Site Remedial
Project Manager; and Ann Rychlenski, Region II Community
Relations Coordinator represented EPA. EPA contractor personnel
were represented by William Kollar, ARCS II Community Relations
Specialist.
Ms. Rychlenski opened the meeting and explained that the purpose
of the meeting was to discuss the results of the FFS and to
present EPA's preferred remedial alternative for cleanup of the
Hooker/Ruco site. Members of the community were encouraged to
actively participate and express concerns regarding the site
which would be factored into EPA's final Record of Decision
(ROD) for the Hooker/Ruco site. They were also informed that
EPA would accept comments throughout the remainder of the public
comment period, which ended on August 30, 1990. Ms. Rychlenski
then introduced Mr. Hauptman.
Mr. Hauptman provided an overview of the Superfund program and
explained how a site may be placed on EPA's National Priorities
List (NPL) through the Hazardous Ranking System (HRS) process.
Placement on the NPL makes a site eligible for federal funding
for site remediation. He explained that the initial examination
of a site is called the Remedial Investigation (RI) wherein the
nature and extent of site contamination is determined. Samples
of soil, air, sediment, surface water, and groundwater are
collected and analyzed by EPA-approved laboratories. The
contaminants detected through this analysis are then evaluated
regarding^ their potential risk to human health and the
environment; and the potential routes through which flora or
fauna may come into contact with these contaminants are
identified. The next stage of the investigation is known as the
Feasibility Study (FS). EPA develops a number of alternatives
to remediate site contamination based on established criteria.
Once these cleanup alternatives are developed and evaluated, EPA
prepares a Proposed Plan which presents EPA's preferred remedial
alternative(s) for cleanup of the site. This preferred remedial
alternative is then presented to state agencies and the public
for review and comment. Upon receipt of public and state agency
comments, EPA evaluates the responses and factors them into its
final selection for a site remedy. A responsiveness summary
addressing public comments is then prepared and becomes part of
the ROD. The next stage of site cleanup is known as the
Remedial Design (RD) phase where the design of the selected
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remedy is detailed. This is followed by the final, or Remedial
Action (RA), phase where the selected remedy is implemented and
site cleanup actually occurs. Upon completion of the RA, site
closure occurs, and, if necessary, continuing site monitoring
may be conducted to ensure the effectiveness of the remedy. The
RI/FS can encompass a time frame from 18-24 months; the RD takes
12-18 months; and the RA can take as long as 30 years if the
remedy includes the pumping and treatment of contaminated
groundwater. If the remedy is as simple as removing items such
as drums, remediation can take as little as six months to
complete. Mr. Hauptman also discussed EPA enforcement
activities under Superfund, including the role of the
potentially responsible party (PRP) in assuming responsibility
for site remediation. The PRPs for the Hooker/Ruco site are the
Occidental Chemical Corporation and the Ruco Polymer
Corporation. Mr. Hauptman then introduced Mr. Tomchuk.
Mr. Tomchuk provided a brief site history and a description of
past investigative activities conducted by EPA at the site. The
Hooker/Ruco site is located on New South Road in Hicksville, an
unincorporated community in the Town of Oyster Bay, New York.
The site is located within an industrialized area of Hicksville
immediately adjacent to Grumman Aerospace Corporation, the
largest industrial facility in the area.
Plant operations at Hooker/Ruco began in 1946 when two firms,
Insular Chemical Company and Rubber Corporation of America,
shared facilities at the site. In 1956 Insular Chemical Company
was bought out by Rubber Corporation of America and in 1965
Rubber Corporation of America was purchased by Hooker Chemical
Corporation, a subsidiary of the Occidental Chemical
Corporation. On March 1, 1982 site ownership was transferred to
the Ruco Polymer Corporation, which is the present owner of the
site. The site is currently an active manufacturing facility.
Manufacturing processes at the Hooker/Ruco site involve
production of polyurethanes, plasticizers, polyvinyl chloride
(PVC) and polyesters. Wastewater from manufacturing processes
were at one time discharged to open recharge basins.
Wastewaters were not monitored and contaminants were not
identified until the 1970's. Permits for discharges, i.e.,
State Pollution Discharge Elimination System (SPDES) permits,
were obtained by 1978, although PVC production ceased by 1975
and the sumps were not used for PVC waste water thereafter.
Wastes from ester manufacturing were either incinerated or
disposed off-site after 1975. Air quality permits were issued
as far back as 1968.
County, state and federal sampling of soils and groundwater at
Hooker/Ruco has occurred sporadically since the early 1970's.
Potential contaminant substances identified within soil and
groundwater samples include vinyl chloride, trichloroethylene,
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tetrachloroethylene and 1,2-dichloroethylene, which are volatile
organic compounds, and cadmium, a heavy metal. These substances
were used in the manufacture of various polymers at the site.
Sampling and monitoring to determine the extent of contamination
at the Hooker/Ruco site was initially undertaken by the Nassau-
County Department of Health (NCDH) in the early 1970's. In.
1976, vinyl chloride contamination was confirmed in wells on the
adjacent Grumman Aerospace Corporation properties by the Nassau
County Department of Health. At this time Hooker/Ruco was found
to be the only site in Nassau County producing vinyl chloride.
The nature of the contamination associated with the site was the
subject of several public hearings that were held from 1976 to
1979. It was disclosed during the hearings that Hooker/Ruco had
been disposing of its wastes in local landfills (Bethpage,
Syosset, and Brentwood) and at other locations. The Hooker/Ruco
site was eventually listed by the New York State Department of
Environmental Conservation (NYSDEC) as a generator of hazardous
waste in 1979. Negotiations between the NYSDEC and Hooker/Ruco
were initiated in 1981 and concerned site soil and groundwater
sampling and cleanup activities. Sample analysis resulted in
NYSDEC conducting a more extensive investigation in November
1983 for preliminary characterization of hazardous substances at
the site. The site was subsequently placed on EPA's National
Priorities List in 1984.
Occidental Chemical and Ruco Polymer have conducted
investigations at the site since 1984, as a result of a series
of negotiations between NYSDEC and EPA and the PRPs. The two
principal studies, both performed by Occidental, were the
Remedial Investigation/Feasibility Study (RI/FS) and the Focused
Feasibility Study (FFS). The RI/FS addressed soil and
groundwater contamination for the majority of the site. RI
field investigations were completed in February 1990. A draft
RI report was prepared and submitted in April 1990, and is
currently xbeing reviewed by EPA and NYSDEC. The FFS was
completed in November 1989 and centered on polychlorinated
biphenyl (PCB)-contaminated soils surrounding an on-site pilot
plant and an adjacent storm water recharge basin. Results of
the FFS were incorporated into the Proposed Plan, which was
released in July 1990 and analyzes cleanup alternatives for the
PCB-contaminated soils. This contamination resulted from
manufacturing processes conducted at the pilot plant from 1946
to 1978 which employed Therminol, a heat transfer fluid
containing PCBs. During these operations, PCBs were released
directly into soils adjacent to the pilot plant. The FFS has
determined that some of the contaminated soil was spread from
the discharge area to surrounding areas (including the impacted
recharge basin) by surface water runoff, sediment transport and
truck traffic.
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ronnnf- P°S remedial alternatives discussed in this
responsiveness summary focus on the PCB-contaminated soils
around the pilot plant, designated as Operable Unit (OU) 2 by
it is expected that some additional field work will be
e
"on^ a ,P-ri°r, t0 finalizing the FS for soil and groundwater
contamination for the remainder of the site, designated as OU 1.
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II. BACKGROUND AND COMMUNITY INVOLVEMENT AND CONCERNS
Public concern regarding pollution at the Hooker/Ruco site
first surfaced in 1976 when vinyl chloride contamination was
detected in wells at the Grumman Aerospace Corporation facility
adjacent to the site. In response to this and other potentially
harmful site conditions, environmental action groups staged
demonstrations at Hooker/Ruco in an attempt to close plant
operations. The site w.as frequently linked in media accounts to
the Love Canal Superfund site in Niagara Falls, New York, since
the Hooker Chemical Company owned both sites. Media interest
peaked when Long Island Newsday published a cover story on
contamination at the Hooker/Ruco site.
Community interest declined by the early 1980's as the public
perceived that authorities were implementing a cleanup plan and
monitoring program for the site. When citizens were
subsequently informed that an RI/FS was planned for the site,
they expressed surprise that site clean up activities were not
yet underway.* Public concerns regarding the perceived slow
pace of site remediation were again expressed upon release of
the FFS and the Proposed Plan addressing the PCB-contaminated
soils, although the overall level of public involvement among
area residents continues to be low.
A Final Community Relations Plan for the Hooker/Ruco site was
completed by EPA in July 1988. Input received at that time
indicated the following issues to be of community concern: the
potential for and extent of groundwater contamination; liability
of site owners; cleanup schedule and funding, and; potential
negative impacts on local property values.
* EPA met with citizen's groups on November 3, 1988 and March 8,
1989 to discuss the field activities to be performed during
the RI/FS.
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III. SUMMARY OF MAJOR QUESTIONS AND COMMENTS RECEIVED DURING
THE PUBLIC COMMENT PERIOD AND EPA RESPONSES TO THESE
COMMENTS
Issues and questions raised during the public comment period for
the Hooker/Ruco site are summarized below and are organized into
the following categories:
A. Groundwater Contamination
B. Technical Concerns
C. Cleanup Funding and Schedule/Other Concerns
D. Written Comment
A. GROUNDWATER CONTAMINATION
1. COMMENT: A resident asked if any groundwater
contamination has occurred at the site and, if so, has the
contamination caused any known public health effects.
EPA RESPONSE: Some contamination was detected in samples
taken from monitoring wells in 1984-85. The RI results
which are currently being reviewed by EPA and NYSDEC will
further identify the nature and extent of this
contamination. Preliminary results from RI sampling
activities indicate the presence of trichloroethylene and
vinyl chloride. Regarding potential public health
effects, the Nassau County Health Department monitors
drinking water supplies in the site area on a quarterly
basis. These supplies currently meet New York State
Department of Health Standards.
2. COMMENT: A resident asked if any PCB contamination has
been detected in groundwater or monitoring wells at the
site.
EPA RESPONSE: PCBs have not been detected in groundwater
at, -the site. The Focused Feasibility Study for
PCBx-contaminated soils around the pilot plant showed that
surface water runoff contained particulate matter which
included PCBs.
3. COMMENT: A resident inquired whether the organic
contaminants detected in the groundwater have migrated
from their original sources.
EPA RESPONSE: Some groundwater in which organic
contamination has been detected has moved downgradient
from the site. Data gathered during the RI and currently
under review by EPA and NYSDEC will more clearly define
the extent and direction of the migration.
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B. TECHNICAL CONCERNS
1. COMMENT: A resident asked how long the excavated areas
surrounding the pilot plant will need to remain capped
before they no longer present any hazard.
EPA RESPONSE: The remedial alternative proposed by EPA
will remove all PCB-contaminated soils in excess of 10 ppm
from the pilot .plant area. Therefore, the remaining
soils, with PCB levels below 10 ppm, are within acceptable
limits for an industrial land use and a cap is not
required. The primary purpose for replacing the asphalt
which currently exists in this area is to allow truck
travel during plant operations, but it will also provide
further protection from low levels of contamination that
remain. This asphalt will be maintained for 30 years.
2. COMMENT: A resident inquired about potential hazards
associated with air emissions resulting from thermal
destruction of contaminated soils.
EPA RESPONSE: PCB-contaminated soils removed from the
site will be destroyed at an EPA-approved thermal
incineration facility which complies with the Toxic
Substances Control Act (TSCA). The destruction removal
and efficiency rate of 99.9999 required under the TSCA
ensures that harmful levels of PCBs are not emitted into
the air.
3. COMMENT: A resident asked how much PCB-contaminated soil
would be removed from the site and how the removal would
be accomplished, including techniques to limit airborne
dusts during excavation.
EPA RESPONSE: Approximately 1100 cubic yards of PCB-
contamiated will be removed from the site. The material
will x be excavated using earth-moving construction
equipment and loaded onto dump trucks for transport
off-site. Dust suppression could be achieved by wetting
the exposed soils during excavation and by covering the
open dump truck trailers with tarpaulins during
transport. Details of the excavation and removal
activities will be determined in the remedial design phase.
4. COMMENT: A resident asked if EPA relied solely on
information supplied by the potentially responsible
parties regarding the location of toxic materials on the
site.
EPA RESPONSE: The areas investigated during the RI
included but were not limited to those identified by the
PRPs as waste disposal areas. The RI also extended to
areas well beyond anticipated contaminant migration
patterns and other locations on the site which were
believed by EPA to be potentially contaminated.
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5. COMMENT: A Nassau County official asked if any samples
taken in the pilot plant area indicated the presence of
contaminants other than PCBs.
EPA RESPONSE: Low levels of trichloroethylene and
perchloroethylene (estimated valves) were found in soil
samples taken from the pilot plant area. These levels do
not represent any significant contamination requiring
remediation, nor would they change the proposed
alternative.
6. COMMENT: A resident asked about the technical basis for
EPA's selection of Alternative 10 as the preferred
alternative.
EPA RESPONSE: A detailed explanation is presented in the
Record of Decision, and is also summarized in EPA's
response to Occidental's comments.
7. COMMENT: A Nassau County official asked if contaminated
soils excavated during an underground fuel oil tank
removal at the site are included in the 1100 cubic yards
to be removed under Alternative 10.
EPA RESPONSE: The soils removed during the tank removal
operation in 1989, approximately 70 cubic yards, are
included in the 1100 yards to be addressed under
Alternative 10.
C. CLEANUP FUNDING AND SCHEDULE/OTHER CONCERNS
1. COMMENT: A resident asked if Occidental would assume
financial responsibility for site remediation.
EPA RESPONSE: The Superfund process requires
negotiations with the PRP regarding the implementation of
the remedy after the Record of Decision is issued. Any
settlement reached in these negotiations is then
incorporated into a court-approved Consent Decree, which
binds the PRP to the terms of the settlement. Occidental
has thus far expressed willingness to assume financial
responsibility for costs associated with site cleanup
activities.
2. COMMENT: A resident expressed concerned about the
potential lengthy time frame for site remediation and
asked if the cleanup schedule could be accelerated.
EPA RESPONSE: The Superfund process includes provisions
for a Special Notice Letter to be sent to the PRPs, which
gives the PRP 60 days to respond with a good faith offer
to perform the remediation and an additional 60 days to
reach a comprehensive settlement with the EPA. The
additional 60 days is for negotiating the Consent Decree
for site remediation.
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However, the PRP could begin Remedial Design work during
the public comment period for the Consent Decree.
3. COMMENT: A resident asked if the cost estimate of
$995,650 for the preferred alternative would include all
costs associated with that alternative.
EPA RESPONSE: The estimate of $995,650 for the preferred
alternative is a present worth estimate based on current
costs for cleanup activities required for implementation.
Actual costs could increase if, for example, additional
contaminated soils were identified during confirmatory
sampling activities. The actual cost will be for expenses
incurred to implement the provisions of the Record of
Decision for the site.
4. COMMENT: A resident asked if the emergency notification
procedures described in the site Field Operations Plan
(FOP) would be applicable for incidents during site
remediation activities, specifically those involving the
transport of contaminated soils off-site.
EPA RESPONSE: The emergency procedures included in the
FOP were operative during RI activities conducted at the
site from September 1989 to February 1990. Similar
procedures regarding cleanup activities, including
transport of contaminated soils, will be developed once
the disposal facilities for the PCB-contaminated soils are
selected.
5. COMMENT: A resident asked which specific activities in
the preferred alternative were covered in the estimated
implementation time of 13 months.
EPA RESPONSE: Time to implement, as it is used in the
Proposed Plan, includes the estimated time for the
preparation of the remedial design, site preparation
activities, and actual on-site construction.
6. COMMENT: A resident asked if health risks associated
with plant operations had been assessed for plant workers.
EPA RESPONSE: The Endangerment Assessment (EA) conducted
by EPA in 1990 evaluated the potential health risks to
workers involved in cleanup activities at the site as a
worst-case exposure scenario. The EA found that exposure
levels for these workers in a future scenario after
remediation to 10 ppm would be within the standard
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exposure limits established for all Superfund sites. The
EA also assessed risks to plant operations workers
assigned eight-hour shifts. Risks to these workers were
also determined to be within acceptable limits.
7. COMMENT: A resident asked whether PCBs are known
carcinogens.
EPA RESPONSE: PCBs are probable human carcinogens.
There is sufficient evidence of their carcinogenicity in
animals but inadequate evidence exists regarding humans to
conclusively list PCBs as human carcinogens.
8. COMMENT: A resident noted the occasional presence of
odors in the vicinity of the Hooker/Ruco site and asked
what vapors were released during plant operations and if
there were health risks associated with them.
EPA RESPONSE: Air emissions were not addressed in the
Focused Feasibility Study regarding PCB-contaminated
soils. As far as EPA is aware, glycol is used in some
production processes at the site and may account for a
sweet odor in the site area. Studies known to EPA have
been unable to identify any detectable concentrations of
glycol in emissions from the plant, although humans may be
sensitive enough to notice it. Glycol is an ingredient in
cosmetics and is not considered a carcinogen. Ruco is
coordinating with the Nassau County Department of Health
to alleviate this problem.
9. COMMENT: A resident asked if the public could be given
assurances that prior waste disposal practices (including
direct discharge into the ground) would not be resumed by
the current owners of the site.
EPA RESPONSE: Waste disposal practices such as direct
discharge into groundwater recharge basins occurred at the
site- prior to the existence of regulations controlling
such practices. EPA, NYSDEC and NCDOH are currently
regulating waste disposal operations at the site and will
continue to enforce all applicable regulations at the
Hooker/Ruco site.
10. COMMENT: A resident asked what measures EPA was taking
to prevent hazardous wastes from being introduced into the
environment.
EPA RESPONSE: Regulations applicable to the generation
and disposal of hazardous wastes require that these
materials be treated and/or disposed of in an approved
facility. EPA, NYSDEC and NCDOH continue to enforce these
regulations.
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11. COMMENT: A resident expressed concern that she did not
receive notification of the public meeting through the
mail until three days before it was held and asked if
earlier notification was possible.
EPA RESPONSE: Notice of the August 7, 1990 meeting was
published in an area newspaper one week before the
scheduled meeting date in accordance with statutory
requirements. Follow-up notification was also sent to
interested parties compiled on the site mailing list.
12. COMMENT: A resident asked if information regarding
community relations activities for the site could be
forwarded directly to interested civic organizations for
subsequent distribution to the community-at-large.
EPA RESPONSE: In addition to fulfilling its statutory
obligations regarding public noticing, EPA will forward
appropriate community relations information to any civic
organization or interested party requesting it.
13. COMMENT: Residents asked if measures to restrict public
access to the PCB-contaminated soils had been taken and if
these soils presented any risk to public health in their
present location.
EPA RESPONSE: The majority of contaminated soils are
currently covered with asphalt or with plastic sheeting
while a small amount of soils with lower concentrations of
PCBs are exposed at the surface. EPA believes that these
soils do not pose any acute risks to the public. However,
they do pose a chronic risk that will be addressed by
their removal.
14. COMMENT: A resident asked about the circumstances which
caused PCBs to be discharged to the spill area outside the
pilot plant and in what form these discharges were made.
EPA RESPONSE: PCBs were contained in a heat transfer
fluid used in manufacturing processes at the pilot plant.
Based on EPA's historical knowledge of the 'site,
discharges were apparently the result of pressure releases
through a relief valve located to the south side of the
plant building. These discharges occurred in the form of
liquid spills.
15. COMMENT: A Nassau County official asked when the
potentially harmful properties of PCBs became known.
EPA RESPONSE: The toxicity of PCBs was first identified
in the mid-1970's. This knowledge was a cornerstone of
the Toxic Substances Control Act of 1978, which
essentially eliminated the production of PCBs.
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Occidental Chemical Corporation
August 30, 1990
Mr. Douglas Tomchuk
United States Environmental
Protection Agency
Region II - Room 747
26 Federal Plaza
New York, NY 10278
RE: Hooker/Ruco Site
Focused Feasibility Study
Public Comments
Dear Mr. Tomchuk:
In response to the Proposed Remedial Plan for the PCS
spill area at the Hooker/Ruco site, issued by the United
States Environmental Protection Agency (EPA), occidental
Chemical Corporation (OCC), submits the following comments
on both the EPA's Proposed Remedial Plan and OCC's preferred
alternative.
OCC prefers the selection of Remedial Alternative 3,
offsite landfilling of soils in excess of 25 ppm (parts per
million), rather than the EPA's proposed option, Alterna-
tive 10. The primary difference between the two remedial
approaches include revised target clean-up goals and
preferential treatment of soils which contain PCB's in
excess of 500 ppm. Spills not regulated under the Toxic
Substance Control Act (TSCA), invariably require site-by-
site evaluations. There is a certain amount of flexibility
in selecting clean-up goals, therefore, OCC believes that
Remedial Alternative 3 provides the best balance of the nine
evaluation criteria. The proposed requirements which would
require offsite thermal destruction of the PCS soils in
excess of 500 ppm would cause delays in field implementation
and require onsite storage of the material prior to inciner-
ation. The expected delays because of limited incinerator
capacity would also unnecessarily increase the potential for
acute exposure to the concentrated PCS soils, decreasing the
short term effectiveness of the remedial approach. Also, a
25 ppm target clean-up goal is just as protective from a
risk-based approach as the EPA's proposed clean-up goal of
10 ppm.
DXY
Environment, Health & Safety
C-.e.n.cs1 C^te- 350 Ra-.cow Eo.;evarc Sout.". Sox 725 N.ajjara Fens. New York 14302
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Occidental Chemical
Mr. Douglas Tomchuk -2- August 30, 1990
Applying the TBC ARAR, TSCA Subpart D Storage and
Disposal requirements, any non-liquid PCS at concentrations
of 50 ppm or greater in the form of contaminated soils, rags
or other debris shall be disposed of in an incinerator which
complies with 40 CFR §761.70; or in a chemical waste land-
fill which complies with 40 CFR §761.75. Thermal
destruction of PCB's at concentrations of 500 ppm and
greater is theoretically acceptable, however, actual field
implementation of this alternative is anticipated to cause
complications and delay the remedial process, therefore,
limiting this alternative's effectiveness.
Onsite complications would be expected to occur during
field identification and segregation of the soils which
contain PCB's in excess of 500 ppm. Because the area
containing the PCB soils in excess of 500 ppm is limited to
the direct spill area, initial removal efforts would not be
delayed. However, defining the edges of the highly impacted
soils will be problematic and time consuming. Field
sampling would be required during the segregation/
excavation to assess the extent of +500 ppro PCB's, and will
further delay soil excavation, pending laboratory confirm-
ation.
Following the excavation of PCB soils in excess of
500 ppm, the segregated soils would require temporary onsite
storage prior to transport to a permitted TSCA incinerator.
Although the projected volume of PCB material in excess of
500 ppm is relatively small, 43 tons, current incinerator
capacity at permitted thermal treatment facilities is
severely limited. Based upon estimates that several months
may be required prior to incineration of the segregated
soils, the short"term effectiveness and implementability of
this alternative would be reduced and the total remedial
process for the site extended beyond current projected
schedules.
In addition, during the expected delay period, the most
concentrated levels of PCB soils would be stored onsite for
extended lengths of time. Because these soils would be
stored on an active industrial facility, significant
increases in acute exposure risks to the onsite workers
could occur. From an implementation and short-term risk
standpoint, and to expedite the remedial process, OCC
believes thermal treatment of the PCB material is
unwarranted.
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Occidental Chemical
Mr. Douglas Tomchuk -3- August 30, 1990
Both the EPA's proposed target clean-up goal of 10 pprc
and OCC's preferred target clean-up goal of 25 ppm, meet the
substantive requirements of TSCA. Using long-term
effectiveness and permanence criteria, both clean-up
standards meet the EPA's acceptable risk range of 10"4 and
10~°. Using Alternative 3's clean-up goals of 25 ppm, the
reasonable maximum exposure (RME) to onsite workers would be
6.8 x 10"3 and in a future use residential scenario, the RMZ
would be 4.5 x 10"5. It is also anticipated for the fore-
seeable future, that the Hooker/Ruco site will remain
industrialized and meet the requirements of a restricted
access area. Under the TSCA PCB spill clean-up policy, a
to-be-considered (TBC) ARAR, in all restricted access areas,
contaminated soils must be cleaned up to 25 ppm PCB's by
weight. To prohibit future residential land use of the
Hooker/Ruco site, OCC believes deed restrictions could be
implemented to prevent the future residential use scenario.
OCC would also like to clarify several issues raised
during the August 7, 1990 public presentation meeting. The
following comments are in response to statements made by EPA
personnel during the question and answer portion of the
public meeting.
Several participants questioned the EPA regarding the
detection of compounds other than PCB's in soil samples
collected from the operable unit. Mr. Tomchuk's
response concluded that "some low levels of everything
were detected, but at non-significant levels or
concentrations." Review of the CLP results of soil
x samples collected from the direct spill area during the
1989 RI indicate that no other detectable parameters,
other than Aroclor 1248, were found to be present.
Several participants wanted an explanation regarding
the source of the PCB spill. Mr. Hauptnan stated that
the source of the spill was from a release valve on the
roof of the pilot plant and that rainwater and
vehicular traffic exacerbated the problem. Based upon
review of the historical files, the release of PCB
therminol occurred through periodic eruptions from a
relief valve on the south side of the pilot plant
approximately 6 feet above grade surface and not from a
valve on the roof of the building.
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Occidental Chemical
Mr. Douglas TomchuX -4- August 30, 1990
OCC appreciates the consideration of the aforementioned
comnents and understands that the final plan will include a
discussion of each significant comment. OCC believes that
the best balance of the evaluation criteria are satisfied in
proposed Remedial Alternative 3, and hopes the final record
of decision reflects this approach.
Very truly yours,
Alan F. Weston, Ph.D
Manager, Analytical Services
Special Environmental Programs
AFW:lms
cc: John Hanna
usepa.ltr/90-22
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D. WRITTEN COMMENT
EPA's basis for selecting Alternative 10 is described in detail
in the Record of Decision. The following is a summary of the
comments made by Occidental in a letter, dated August 30, 1990.
1. COMMENT: Occidental prefers the selection of Alternative
3, landfilling of all soils in excess of 25 ppm of PCBs.
EPA RESPONSE: EPA does not believe that off-site
landfilling of soils with PCB concentrations over 500 ppm
would meet the CERCLA statutory preference for treatment.
Alternative 10 is also supported by EPA's recent guidance
document, "Guidance on Selecting Remedies for Superfund
Sites with PCB contamination." The principal threat,
soils contaminated with PCBs at concentrations of 500 ppm
or greater, are being treated. For an industrial site
such as this, the guidance allows soils between 10 and 500
ppm to be contained; however, there is an exception for
small volumes. This exception is appropriate for this
site, so by fully remediating all the soils in excess of
10 ppm of PCBs at a relatively small increase in cost, the
site does not require any long-term management controls.
2. COMMENT: Incineration of soils with concentrations
exceeding 500 ppm would cause implementation delays, and
may present a short-term risk during storage.
EPA RESPONSE: Prior to acceptance by an incineration
facility, for soils exceeding 500 ppm of PCBs, all of the
contaminated soils could be excavated and segregated, and
those with PCB contamination between 10 ppm and 500 ppm
could be shipped to a TSCA-approved facility for
landfilling. The 36 cubic yards (43 tons) of soils with
concentrations exceeding 500 ppm could be containerized
awaiting shipment to the incineration facility. Early
coordination with such incineration facilities will
provide a minimal lag time in acceptance of this
material. Capacity for 36 cubic yards of material should
not be a significant problem.
Segregation of soils exceeding 500 ppm from those between
10 ppm and 500 ppm should be based on previous sampling
results combined with confirmatory field sampling. The
use of an on-site laboratory, with quick turn-around
confirmation by Contract Lab Program methodologies, could
provide the necessary information in a time-frame that
would not substantially delay the implementation of the
remedy.
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COMMENT: 25 ppm is just as protective from a risk based
approach as EPA's cleanup goal of 10 ppm.
EPA RESPONSE: while both cleanup goals would remediate
the site to within EPA's acceptable risk range of 10~4
to 10~6, the risk associated for site workers with a
cleanup goal of 25 ppm, is 6.8 x 10~5. The risk
associated with a 10 ppm cleanup goal is 2.7 x 10~^. Of
course, EPA's -selected cleanup level must provide
protection to both human health and the environment, but,
after that criterion has been met, the other balancing
criteria may modify the selected remedy. At the
Hooker/Ruco site, the balancing criteria lead to the
cleanup level of 10 ppm, as described in the ROD and as
summarized above.
In addition, EPA acknowledges Occidental's clarifications
of several statements made by EPA at the public meeting,
held on August 7, 1990. "Low levels of everything" were
not detected in the soil samples analyzed as part of the
1989 Remedial Investigation. However, trace amounts of
tetrachloroethylene and trichloroethylene, qualified as
estimated values, were found in some of these samples.
EPA also acknowledges that the relief valve was not on top
of the pilot plant building; rather, it was located on the
south side of the building.
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NORMAN F LENT • Allfi 9 1 'l^^Q »'.t»si *o:«i£> e;». ;;"•-;
Congress of the United States
House of Kcprcsmtariocs
IDashington, B£ 20515
3243 6«
August 16, 1990
Mr. Douglas Tomchuk
Project Manager
U.S. Environmental Protection
Agency - Region II
26 Federal Plaza
Room 747
Xe\v York, New York 10278
Dear .Mr. Tornchuk:
I am writing to you in support of concerned
citiaer.s in ny congressional district regarding pro-
posed EP.A cleanup of the Hooker-Ruco Superfund site
in Kicksville. New York.
I publicly revealed the dumping of contamina-
ted waste at the Hooker site during a June 1, 1979 bearing
of the House Energy and Commerce Committee's Subcommittee
or. Oversight and Investigation in Mineola, New York. In
addition, I have worked as the chief Republican sponsor
in the House of the Superfund legislation that has been
enacted by Congress.
I am pleased that EPA is proposing to move
forward with the cleanup of this site and urge you to
complete your task as soon as possible. I also request
extreme caution when removing contaminated soil from the
-sito avoiding whenever possible routes through residen-
areas.
Your care and concern for the views of Hicks
ville area residents in this matter is appreciated.
Sincerely
r L,
NOftMAN T. LENT
Mepber of Congress
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EPA responded to Congressman Lent in a letter dated August
30, 1990. The letter thanked the Congressman for his
support and assured him that mitigative measures will be
taken to minimize dust emissions from the site during the
remedial action.
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