United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R02-90/129
September 1990
&EPA
Superfund
Record of Decision
Kentucky Avenue Wellfield, NY
-------
50272-101
REPORT DOCUMENTATION
PAGE
REP
F
K«
1. REPORT NO.
EPA/ROD/R02-90/129
3. Recipient's Accession No.
iUe and Subtitle
UPERFUND RECORD OF DECISION
Kentucky Avenue Wellfield, NY
Second Remedial Action
5. Report Date
9/28/90
7. Author(e)
8. Performing Organization Rept No.
9. Performing Organization Name and Address
10. Project/Taskwork Unit No.
11. ControcUC) or Grant(G) No.
(C)
(G)
12. Sponsoring Organization Name and Addreaa
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
13. Type of Report & Period Covered
800/000
15. Supplementary Notes
16. Abstract (Limit: 200 words)
The Kentucky Avenue Wellfield site is an inactive municipal water supply in Horseheads,
Chemung County, New York. The site is in a low-relief area, part of which lies within a
100-year floodplain. In addition, several wetland areas are onsite. Surrounding land
e is mixed residential, commercial, and industrial. The site overlies the Newtown
eek Aquifer, a major source of water in the area. The wellfield was established in
1962, when a water supply was needed for a food processing plant. In 1980, elevated
levels of TCE were discovered in ground water, and the wellfield was closed. Subsequent
onsite investigations by the State and EPA identified additional onsite contamination by
VOCs and metals. In 1985 and 1986, a removal action by EPA required the connection of
56 homes that were served by the wellfield to the public water distribution system as an
alternate water supply. A 1986 Record of Decision (ROD) documented the selection of
ground water monitoring, identification of contaminant sources, and the provision of
public water to 46 additional residences as part of the remedy for this site. The
primary source of this contamination was determined to be from the disposal of
industrial wastes in lagoons or land areas and from industrial spills, including ones
from a nearby Westinghouse facility. This ROD addresses management of migration of
(See Attached Page)
NY
17. Document Analysis a. Descriptors
Record of Decision - Kentucky Avenue Wellfield,
Second Remedial Action
Contaminated Medium: gw
Key Contaminants: VOCs (TCE, xylenes), metals (arsenic, chromium, lead)
b. Identifiers/Open-Ended Terms
V
C. COSATI Field/Group
Availability Statement
19. Security Class (This Report)
None
20. Security Class (This Page)
None
21. No. of Pages
343
22. Price
(See ANSI.Z39.1B)
See Instructions on Reverse
OPTIONAL FORM 272 (4-77)
(Formerly NTIS-35)
Department of Commerce
-------
EPA/ROD/R02-90/129
Kentucky Avenue Wellfield, NY
Second Remedial Action
Abstract (Continued)
ground water contaminants. A subsequent ROD will address source and final ground water
cleanup activities. The primary contaminants of concern affecting the ground water are
VOCs including TCE and xylenes; and metals including arsenic, chromium, and lead.
The selected remedial action for this site includes restoring the Kentucky Avenue
wellfield as a public drinking water supply well by constructing two treatment plants,
one near the well and one between the well and the adjacent Westinghouse facility;
pumping and treatment of ground water using filtration to remove inorganics and air
stripping/carbon adsorption or UV-oxidation to remove organics; disposing of any
treatment residuals offsite; discharging the treated water to the public water supply, to
surface water, or reinjecting the treated water onsite; ground water monitoring; and
investigating an additional possible source of onsite contamination. The estimated
present worth cost for this remedial action is $14,963,900, which includes an annual O&M
cost of $905,300 for 30 years.
PERFORMANCE STANDARDS OR GOALS: Goals for discharge of treated ground water were chosen
as the most stringent of Federal or State MCLs or MCLGs, or other State ground water
standards. Chemical-specific goals for ground water include TCE 5 ug/1 (MCL), arsenic 25
ug/1 (State), chromium 50 ug/1 (MCL), and lead 25 ug/1 (State).
-------
DECLARATION
KENTUCKY AVENUE WELLFXELD SITE
TOWN OF HORSEHEADS
CEEMUNG COUNTY, NEW YORK
United States Environmental Protection Agency
Region II
-------
DECLARATION FOR THE RECORD OF DECISION
Site Name and Location
Kentucky Avenue Wellfield Site
Town of Horseheads
Chemung County, New York
Statement of Basis and Purpose
This decision document presents the selected interim remedial action
for the Kentucky Avenue Wellfield site (the "Site"), in Chemung
County, New York, which was chosen in accordance with the
requirements of 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 explains the factual and legal basis
for selecting the remedy for the Site.
The New York State Department of Environmental Conservation concurs
with the selected remedy.
The information supporting this remedial action decision, is
contained in the administrative record for the Site.
Assessment of the Bite
Actual or threatened releases of hazardous substances from the 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
This operable unit is the second operable unit of three operable
units for the Site.
The first operable unit ROD called for the following actions: 1) An
investigation to identify all residences in the study area currently
using private wells, and upon completion of the investigation, all
private well users would be connected to the public water supplies.
2) Further investigation of potential source areas identified during
the RI/FS, and 3) Installation of monitoring walls upgradient of the
Sullivan Street Wells.
The third operable unit for the site will be for source controls at
the Westinghouse Electric Corporation facility, and a final aquifer
restoration operable unit.
-2-
-------
The major components of the selected remedy for the second operable
unit include the following:
The interim remedial action selected for the Site, and the remedial
objectives for the contaminated groundwater in the vicinity of the
Kentucky Avenue Wellfield are as follows:
Restore the Kentucky Avenue Well as a public drinking water
supply well. If evaluation of the well condition indicates that
the well should be replaced, then the well will be reconstructed
in order that the Kentucky Avenue Well can provide approximately
700 gallons per minute (gpm) potable water.
« Prevent further spread of contaminated groundwater within the
Newtown Creek Aquifer with the installation of ground water
recovery wells between the Westinghouse Electric Corporation
facility and the Kentucky Avenue Well. The exact location and
pumping rates will be determined during the design stage.
Construct two treatment plants, one located near the Kentucky
Avenue Well, and one located between the Westinghouse facility
and the Kentucky Avenue Well which will treat all the
recovered ground water to Federal and New York State
Standards for public drinking water systems. The selected
treatment will include the following:
Filtration to remove any suspended solids with adsorbed
inorganic contamination.
Air Stripping to remove volatile organic contaminants.
Vapor Phase Carbon Adsorption to eliminate volatile organic
vapor emissions at the air stripper.
Discharge the treated ground water to the public water supply.
In addition, engineered provisions to allow for testing
reinjecting ground water to evaluate the feasibility of
expanding the ground water remediation effort will be
provided for.
« Install a limited number of monitoring wells to monitor
contaminant migration and to evaluate effectiveness of the
interim remedial action. The location and specifications for
these monitoring wells will be determined during the design
phase.
Conduct a limited investigation in order to determine if the
contamination detected at the Horseheads Automotive Junkyard
contributes to the contamination at the Kentucky Avenue
Wellfield.
-3-
-------
Active restoration of the ground water is appropriate for the
Kentucky Avenue Wellfield Site. The ground water cleanup levels at
the Site are based primarily upon the classification of the ground
water as a potential drinking water source. Therefore, the Maximum
Contaminant Levels promulgated under the Safe Drinking Water Act are
relevant and appropriate requirements, and the non-zero Maximum
Contaminant Level Goals are relevant and appropriate requirements
for aquifer remediation. Reaching the cleanup levels in the aquifer
upgradient of the Kentucky Avenue Well will not be possible until
effective source control measures are in place at the Westinghouse
Facility, and possibly at the Horseheads Automotive Garage.
Declaration of Statutory Determinations
The selected interim 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, and it satisfies the statutory preference for
remedies that employ treatment that reduce toxicity, mobility, or
volume as their principal element. Because this remedy will result
in hazardous substances remaining on-site above health-based levels,
a review will be conducted within five years after commencement of
remedial action to ensure that the remedy continues to provide
adequate protection of human health and the environment.
'Cchistantine Sidamon-Eristoff // Date/
Regional Administrator
-4-
-------
ROD FACT SHEET
SITE-
Name: Kentucky Avenue Wellfield
Location: Chemung County
Town of Horseheads, New York
HRS Score: 39.65
NPL Rank: 508
ROD-
Date signed: September 28, 1990
Remedy: Restore public water supply well, treat ground
water by filtration, air stripping, and carbon
adsorption of air emmissions. Installation of
ground water recovery wells to prevent
migration of ground water contaminants,
treatment by filtration, air stripping, and
carbon adsorption of air emissions.
Distribution of treated ground water to public
water supply.
Capital Cost: $2,106,500.
O&M/Year: $905,300.
P-W Cost: $14,963,900.
LEAD-
Federal Lead
Primary contact:.. J. Jeff Josephson (212) 264-4183
WASTE-
Type: trichloroethylene, chromium (particulate)
Media: ground water
Origins: lagoon disposal and land disposal of industrial
waste, industrial spills
Est. Quantity:.... widespread aquifer contamination
-------
DECISION SUMMARY
TABLE OF CONTENTS
l.SITE NAME, LOCATION, AND DESCRIPTION ............................ 2
2 . SITE HISTORY [[[ 3
3. ENFORCEMENT HISTORY ............................................. 5
4 .COMMUNITY PARTICIPATION ......................................... 7
5 . SCOPE AND ROLE OF RESPONSE ACTION ............................... 7
6 . SUMMARY OF SITE CHARACTERISTICS ................................ 10
7 . SUMMARY OF SITE RISKS .......................................... 20
8 . DESCRIPTION OF ALTERNATIVES .................................... 27
9 . SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES .............. .'.34
10 . THE SELECTED REMEDY ............................................ 42
11 . STATUTORY DETERMINATIONS ....................................... 44
12 . DOCUMENTATION OF SIGNIFICANT CHANGES ........................... 46
ATTACHMENTS
APPENDIX
APPENDIX
1 - TABLES
2 - FIGURES
APPENDIX 3 - NYSDEC LETTER OF CONCURRENCE
-------
Decision Summary for the Kentucky Avenue Wellfield site
The Kentucky Avenue Wellfield is located within the Town of
Horseheads, Chemung County, New York. The Kentucky Avenue Well is
located east of NY Route 14 and approximately 1 mile south of the
intersection of NY Route 14 and 17. The Kentucky Avenue Wellfield
Site includes the wellfield, the contaminated portion of the
underlying valley-fill aquifer locally known as the Newtown Creek
Aquifer, and the sources of the contamination. The Newtown Creek
Aquifer in the Elmira area is a drinking water supply that currently
provides approximately 30 percent of the drinking water to the
Elmira Water Board (EWB) .
The area in the vicinity of the Kentucky Avenue Wellfield site is
characterized by a terrain of low relief with residential and
commercial areas occupying more than half of the overall valley
floor. The area has extensive industrial developments, and is
crossed by major transportation routes, including highways and
freight railroad lines. In the 1980 census, Chemung County reported
a population of 97,656. Between 1980 and 1984, the population of
Chemung County reportedly dropped by 1.2 percent. Figure 1 is an
area map.
Figure 2 illustrates areas within the Kentucky Avenue Site boundary
delineated by the Federal Emergency Management Agency as being
within the 100-year flood plain boundaries, and/or the 500-year
flood plain boundaries. Figure 3 indicates wetland areas regulated
by the New York State Department of Environmental Conservation
(NYSDEC) .
The Newtown Creek Aquifer is classified by EPA as a Class II a
aquifer, and the New York State Department of Environmental
Conservation classifies this aquifer as Class GA. Both of these
classifications indicate that the Newtown Creek Aquifer is a
potential or currently used source of drinking water. Figure 4
indicates the limits of the aquifer and provides a contoured map of
ground water elevation data collected in 1990 by EPA at monitoring
wells screened in the Newtown Creek Aquifer. The water level
elevation data indicate that the direction of ground water flow
within the Newtown Creek Aquifer west of the Newtown Creek is
generally in a south, southeasterly, or easterly direction within
the aquifer depending on location within the aquifer. In addition,
the data collected indicate that both upward and downward gradients
within the aquifer exits, although away from the Newtown Creek the
gradient was generally downward and near the Newt own Creek the
gradient is generally upwards.
Prehistoric occupation of the Horseheads region is indicated by the
reported discovery of a Paleo-Indian fluted point (circa 9000 BC) .
The Archaic period (8000-1000 BC) is represented by several Lamoka-
style beveled adzes, dateable to approximately 2500 BC, found in the
Horseheads area. Parker (1922) reported three archaeological sites
-2-
-------
in the area. Two of these contained pottery, indicating Woodland
occupations (1000 BC to 1600 AD). One of Parker's sites, located
a mile southeast of Horseheads, contained graves that yielded glass
beads, indicative of the Contact period (17th-18th century).
2. Site History
The Kentucky Avenue Wellfield is part of the EWB public water supply
system. The 1.0 million gallon per day (mgd) municipal well was
developed to provide water directly to a local food processing
plant. Constructed in 1962, the Wellfield provided about 10 percent
of the water produced by the EWB until the wellfield was closed in
1980 following the discovery of elevated levels of trichloroethene
(TCE). The Wellfield, which overlies the Newtown Creek aquifer,
includes three test wells and a production well. The food
processing plant closed its operations, prior to the closing of the
Kentucky Avenue well.
Contamination of the Kentucky Avenue Wellfield with TCE was first
detected in May 1980, during a "hot spot" inventory of local wells
initiated by the New York State Department of Health (NYSDOH).
Further sampling of the area by the Chemung County Health Department
(CCHD) in July 1980 showed elevated levels of TCE detected in the
Kentucky Avenue Well, and several private residences and commercial
facilities. In September 1980, the Kentucky Avenue Well was closed.
In July 1982 the Kentucky Avenue Wellfield Site was proposed for
inclusion on the National Priorities List (NPL), and was finalized
on the NPL in September 1983.
Results of continued ground water sampling conducted by CCHD,
NYSDOH, New York State Department of Environmental Conservation
(NYSDEC), and EPA of private residential wells through June 1985
showed that TCE was present throughout the Newtown Creek Aquifer.
Volatile organic compounds such as trans-l,2-dichloroethene,
tetrachloroethane,1,1,1-trichloroethane, trans-1,2-dichloroethane,
benzene, and chloroform were also found to be sporadically present
in private well samples, but at lower concentrations.
EPA began providing alternative water supplies to impacted
residences not connected to the public water distribution system in
March 1985. Phase I of this response action connected 20 homes to
the public water supply. In May 1986, a Phase II response action
connected 26 affected homes identified in the area bounded on the
north by Denver Street, on the west by Oakwood Avenue, on the South
by Lenox Avenue, and on the east by South Main Street to the
municipal water supply.
A Remedial Investigation/Feasibility Study was conducted by the
NYSDEC under a cooperative agreement with EPA. The RI/FS involved
the installation of 12 cluster wells, and 7 point sampling devices,
collection and analysis of surface water and sediment samples, a
preliminary evaluation of potential sources, evaluation of remedial
alternatives, and performance of a risk assessment. A total of 36
-3-
-------
ground water samples were collected from monitoring wells and
analyzed. In addition, 14 surface water samples and 11 sediment
samples were collected.
The cluster wells were installed to evaluate upgradient ground water
quality, regional ground water quality, impact from potential
sources identified and evaluated in the RI, and downgradient water
quality. Analytical results from samples collected from these
monitoring wells confirmed the presence of a ground water
contamination plume in several potential source areas, and
downgradient or southern perimeter wells. Analytical results of
ground water collected from monitoring wells upgradient of the
potential source areas did not indicate organic contaminant
presence.
A Record of Decision (ROD) for the Kentucky Avenue Wellfield Site
was issued by EPA on September 26, 1986. The ROD outlined the
following actions to address the contamination at the Kentucky
Avenue Wellfield:
a. Installation and sampling and analysis of ground water
monitoring wells upgradient of the Sullivan Street Wellfield.
b. Identification of all private wells in the study area. After
identification of all private wells, users were to be connected to
the public water supply.
c. Further investigation of potential source areas identified
during the RI/FS in order to develop an effective program of
source control and contaminated ground water migration control.
To date EPA and the NYSDEC have conducted the following actions at
the Kentucky Avenue Wellfield site in fulfillment of the 1986 ROD:
The NYSDEC under a cooperative agreement with the EPA completed.
installation of the monitoring wells upgradient of the Sullivan
Street Wellfield in July, 1989. These monitoring wells were sampled
in January 1990 by EPA, and the results are presented in the
Supplemental RI/FS. The monitoring wells were installed in order
to monitor regional ground water quality downgradient of contaminant
source areas.
An additional forty-six residences were identified as using private
drinking water wells in the area affected. Of this total, forty-
five residences were connected to the public water supply provided
by the EWB. One residence refused to be connected. Regrading of
lawns and resurfacing of roads have been completed. Overall a total
of ninety-one residences have been connected to the public water
supply in the Elmira-Horseheads area.
During the Spring of 1990, EPA issued an Explanation of Significant
Difference (BSD) to the 1986 ROD in order that design and
construction of an air stripper for the Sullivan Street Wells could
be implemented. As explained in the BSD, this action is taken by
-4-
-------
EPA because of information supplied to EPA by the CCHD, the NYSDOH,
and the EWB indicating that TCE contamination at the public water
supply provided to residences exceeded the maximum contaminant level
allowed by EPA of (5 ppb) for TCE.
EPA has conducted and completed a Supplemental RI/FS for the purpose
of investigating potential source areas, to evaluate an effective
method of source control, and to develop a program of ground water
migration control. The results of the Supplemental RI/FS are
presented in this ROD.
3. Enforcement History
In November 1982, Westinghouse Electric Company and Koppers Company,
two industrial facilities in the Elmira-Horseheads area, were
identified by EPA as potentially responsible parties for sources of
volatile organic ground water contamination at the Kentucky Avenue
Wellfield Site. LRC Electronics has been identified as a potential
source of aquifer contamination by the NYSDEC. One additional
facility, Facet Enterprises, Inc., located downgradient of the
Kentucky Ave well is within the study area. This facility is listed
on the NPL. Each of these facilities is discussed below.
In 1983, Facet Enterprises, Inc. entered into a consent agreement
with EPA under Section 3013 of the Resource Conservation and
Recovery Act (RCRA) as amended, 42 U.S.C. §6934. This consent
agreement required Facet Enterprises, Inc. to conduct a limited
investigation of the geology and hydrogeology at the facility." On
May 16, 1986, Facet Enterprises, Inc. entered into an Administrative
Order on Consent with EPA pursuant to Section 106 of CERCLA. This
investigation requires Facet Enterprises to investigate the nature
and extent of the ground water, surface water, and soil/sediment
contamination at its facility, and to evaluate remedial alternatives
for it. The RI/FS is scheduled for completion during the Spring of
1991.
On February 22, 1985, LRC Electronics entered into an Order on
Consent with the NYSDEC in order to determine the nature of wastes
and the areal extent and vertical distribution of the wastes at the
facility, to determine the extent and the impact, or the potential
impact, on natural resources, and if necessary after completion of
the field activities, to provide for the development and
implementation of an inactive hazardous waste disposal facility
remedial program.
-5-
-------
On February 25, 1985 pursuant to Section 104(E) of CERCLA, EPA sent
out "Request for Information" letters to the following
establishments:
The Great Atlantic and Pacific Tea Company
Westinghouse Electric Corporation
Town of Horseheads
Fairway Spring Company
LRC, Inc.
Leprino Foods
MacMillian-Bloedel Containers, Inc.
Wickes Lumber
Village of Horseheads
Horseheads Central School District
Chemung County Highway Department
Horseheads Automotive
Koppers Company, Inc.
American Bridge Division
Bendix Corporation
Facet Enterprise, Inc.
Allied-Signal Corporation
On September 30, 1985 pursuant to the Environmental Conservation Law
(ECL) 27-1313, NYSDEC sent the "Chemung County Chemical Survey" to
the following organizations to request specific information
regarding the use of hazardous substances at each facility.
Newtown Die & Tool
Horseheads Automotive
Koppers Company
New York State Electric and Gas
Diamond-Bathurst, Inc.
Army Navy Reserve Center
The Great Atlantic and Pacific Tea Company
MacMillian Bloedel Containers Inc.
United States Steel
American Dry Cleaning
The responses to the "Requests for Information" and the Chemical
Survey are included in the Administrative Record File.
On May 22, 1986, Westinghouse Electric Corporation entered into a
consent agreement with EPA, under Section §3013 of RCRA to perform
ground water and soil investigations to determine the nature and
extent of any contamination at the Westinghouse facility.
On September 27, 1989, EPA sent Westinghouse Electric Company a
notification demanding payment of $2,160,817.51 for rec-ponse costs
incurred by EPA at the Kentucky Avenue Wellf ield Site and documented
as of March 31, 1989.
-6-
-------
4. Highlights of Community Participation
The RI/FS Report and the Proposed Plan for the Kentucky Avenue
Wellfield Site were released to the public for comment on July 21,
1990 . These two documents were made available to the public in
information repositories maintained at the EPA Docket Room in Region
II and at the Town of Horseheads, Town Hall, respectively. The
notice of availability for these two documents was published in the
Elmira Star Gazette on July 21, 1990. A public comment period on
the documents was held from July 21, 1990 to September 18, 1990.
In addition, a public meeting was held on August 1, 1990. At this
meeting, representatives from EPA and the NYSDEC answered questions
about problems at the Site and the remedial alternatives under
consideration. A response to the comments received during this
period is included in the Responsiveness Summary, which is part of
this ROD.
5. Scope and Role of Operable Unit or Response Action Within Site
Strategy
As with many Superfund sites, the problems at the Kentucky Avenue
Wellfield Site are complex. As a result, EPA has organized the
remedial work into three operable units. In addition, EPA
anticipates that the investigations conducted by Facet Enterprises,
Inc. at its facility and an investigation completed by Westinghouse
Company will result in RODs for these facilities. This ROD
addresses the second planned remedial action at the Site.
«'
The three operable units are described below:
First Operable Unit - Nature and Extent of Contamination
The RI/FS for the first operable unit determined the nature and
extent of contamination at the Kentucky Avenue Wellfield. The ROD
for this operable unit was issued by EPA on September 30, 1986.
The response actions conducted pursuant to this ROD are described
below.
a. Installation and sampling and analysis of ground water monitoring
wells upgradient of the Sullivan Street Wellfield.
Monitoring wells were installed by the NYSDEC under a cooperative
agreement with EPA. The monitoring well installation was completed
during the summer of 1989. During January 1990 the monitoring wells
were sampled by EPA, and the analytical results of this sampling are
presented in the Supplemental RI/FS.
b. Identification of all private wells in the study area. After
identification, all private well users were connected to the public
water supply, except two who refused service.
c. Further investigation of potential source areas identified
during the RI/FS in order to develop an effective program of source
control and contaminated ground water migration control. EPA
-7-
-------
completed the Supplemental Remedial Investigation and Feasibility
Study in July 1990.
During the Spring of 1990, EPA issued an ESD to the 1986 Record of
Decision. The ESD provides for the construction of an Air Stripper
for the Sullivan Street Wellfield.
Second Operable Unit - Source Identification Operable Unit
This ROD results from the data collected during the Supplemental
RI/FS conducted pursuant to the first operable unit ROD. The
results of this investigation are provided in the Supplemental RI/FS
Report for the Kentucky Avenue Wellfield Site, Chemung County, New
York 1990. The Supplemental RI indicates that the primary source
of TCE contamination in the Newtown Creek Aquifer in the area of the
Kentucky Avenue Wellfield is the Westinghouse Facility whose
property is bounded by State Route 17 on the north, State Route 14
on the East, a Conrail track on the south, and property of the New
York State Electric and Gas company to the west. In addition, data
collected at the Horseheads Automotive by the NYSDOH indicate that
TCE is present in the aquifer below this facility and therefore this
may also be a source of TCE contamination at the Kentucky Avenue
Wellfield.
This operable unit will restore the drinking water supply at the
Kentucky Avenue Well and will provide for the active plume
containment in order to prevent the worsening of ground water
quality of the Newtown Creek Aquifer. This operable unit will not
address the threats (if any) posed by the areas identified in the
Supplemental RI as contributors to the ground water contamination.
In addition, this operable unit will provide the necessary data to
establish the technical feasibility of restoring the Newtown Creek
Aquifer to its beneficial use as a drinking water aquifer.
This operable unit remedy will not address the risk posed by direct
exposure to sediment in the industrial outfall drainageway used by
Westinghouse Electric Corporation. Cadmium levels in the
drainageway sediments south of the Westinghouse facility 002 outfall
are contaminated with metals at levels resulting in excess lifetime
hazard index of >1. EPA anticipates that this will be addressed as
a part of the Westinghouse investigation.
Third Operable Unit - Source Control and Aquifer Restoration
Operable Unit
This operable unit will be for source control at the Westinghouse
Electric Corporation and will be the final ROD for the ground water
remediation.
The Facet Enterprises, Inc. facility is currently undergoing an
RI/FS. EPA expects to select a remedy for remediating the Facet
facility and affected areas next year. The Westinghouse facility
and the LRC Electronics facility are undergoing investigations under
different federal and state authorities. Remedies for these
-8-
-------
facilities including sources of aquifer contamination are expected
to be selected within two years.
-9-
-------
6.Summary of Site Characteristics
Chapter Four of the Supplemental RI Report presents the data
collected during this source identification investigation and also
presents the data collected by private parties who have conducted
investigations pursuant to orders on consent with EPA or the NYSDEC.
Tables summarizing the data are attached to the ROD. The type of
hazardous substance or compound and the maximum concentration
detected at each area investigated is provided in the following
text.
NATURE AND EXTENT OF GROUND WATER CONTAMINATION
A ground water investigation was completed in order to evaluate the
nature and extent of the contamination. Eight monitoring wells were
installed at locations upgradient, downgradient and in possible
source areas. Monitoring wells were sampled, and the analytical
data obtained from these samples was used in conjunction with soils
data obtained from the seven areas investigated by EPA to determine
the extent that each area investigated contributes to the ground
water contamination. In addition, regional monitoring wells
installed by either EPA or NYSDEC were sampled.
Figure 5 illustrates the location of each monitoring well where
ground water samples were collected and analyzed.
Table 1 summarizes the chemicals detected in background monitoring
wells that are hydraulically upgradient of identified potential
source areas. This table indicates that low levels of the organic
contaminants occur sporadically in the Newtown Creek Aquifer. Table
1 indicates that barium (174 ppb), calcium (111,000 ppb), magnesium
(22,300 ppb), potassium (2,790 ppb), and sodium (66,200 ppb), and
possibly zinc (22 ppb) occur naturally or possibly as a result of
road salt entering the Newtown Creek Aquifer.
Table 1 also indicates that the other metals that were detected;
namely beryllium (1.3 ppb), copper (18.0 ppb), lead (4.2 ppb),
manganese (231 ppb), nickel (19.3 ppb), and vanadium (11.0 ppb) are
present in the ground water sporadically, and they occur at levels
that are below Federal and New York State drinking water standards.
Table 2 summarizes the ground water quality from all monitoring
wells sampled and analyzed by EPA.
Table 2 and Figure 6 indicate that the ground water contamination
with TCE is widespread throughout the Newtown Creek Aquifer. A
ground water sample coJlected from monitoring well CW-7D screened
at the bottom of the Newtown Creek Aquifer north of the Kentucky
Avenue Well indicates the presence of TCE at 110 ppb. In addition,
the one monitoring well (CW-3R) open to the bedrock is contaminated
-10-
-------
with TCE. Table 2, in addition to the information provided by
private party ground water investigations including the Westinghouse
Electric Corporation, Facet Enterprises, Inc. and LRC Electronics,
Inc. confirms that the TCE contamination in ground water has the
highest concentration at source areas and is at lower concentrations
away from the sources. In addition to TCE, other organic compounds
and the highest concentrations detected include trans-1,2-
dichloroethene (12 ppb), methylene chloride (4 ppb), acetone (2,200
ppb), and 1,1,1-trichloroethane (5.4 ppb) were detected.
Table 2 indicates that there is a widespread presence of inorganics
in the ground water at levels above drinking water standards.
During the Supplemental RI, eleven metals were detected in the
ground water at levels above New York State Class GA Water Quality
Standards. The metals detected, and the highest concentrations,
are aluminum (281,000 ppb), arsenic (55 ppb), barium (2690 ppb),
beryllium (13.1 ppb), chromium (49,100 ppb), iron (654,000 ppb),
lead (321 ppb), magnesium (557,000 ppb), manganese (21,300 ppb), and
thallium (8.5 ppb). Nickel (8,880 ppb), and antimony (668 ppb) were
also present at elevated levels. Figures are located in the
Supplemental RI which indicate the monitoring wells where the levels
of the inorganics contamination exceed NYS Class GA water Quality
Standards, and the concentrations of the inorganics at each
monitoring well where the drinking water standard is exceeded.
The Supplemental RI Report presents the results of sampling and
analyzing monitoring wells for dissolved inorganic constituents.
The following inorganics, and the highest levels detected, are:
aluminum (2,980 ppb), chromium (439 ppb), nickel (797 ppb). The
results of the sampling for dissolved inorganics are presented in
Table 3.
Hexavalent chromium was detected at the monitoring wells PS-4 (267
ppb), and at CW-2D (11 ppb).
The contamination in the aquifer is believed to occur by downward
vertical migration of contaminants. Source areas identified during
the Westinghouse Investigation, the Facet Enterprises Investigation,
and the LRC Investigation are the primary contributors to the
aquifer contamination, and the contaminants are believed to have
originated by waste disposal in lagoons, waste spills at storage and
handling areas, disposal in dry wells, and possibly downward
migration at industrial discharges. The fact that the water table
aquifer is the drinking water source indicates that this aquifer is
vulnerable to spills and disposal. Lateral movement of contaminants
occurs, by flow of contaminants either dissolved within the aquifer
or as inorganic contaminants adsorbed to particulates. The ground
water elevation data presented in Figure 4 indicate that the Facet
Enterprises, Inc. facility is hydraulically downgradient of the
Kentucky Avenue Wellfield.
-11-
-------
Ground Water Quality Investigation West of Westinghouse Conducted
bv the NYSDOH and the CCHD
Ground water sampling and analysis at the Horseheads Automotive
Junkyard located on Sears Road indicates the presence of TCE at 95
ppb, and 1,1,1-trichloroethane present at 50 ppb. Figure 7
illustrates the residential wells sampled and the data collected by
the NYSDOH, and CCHD in the Fisherville area west of the
Westinghouse Facility.
Ground Water Investigation at Westinghouse Electric Corporation
Table 4 summarizes analyses from ground water samples collected at
monitoring wells on the Westinghouse Corporation property.
Analytical results indicate the presence of volatile organic, semi-
volatile organic, and inorganic compounds. TCE is present in
concentrations up to 430 ppb. The highest concentrations occur
downgradient of Disposal Area F. Figure 8 illustrates the TCE
distribution in the area of Disposal Area F. Other volatiles
detected in ground water at the Westinghouse Electric Corporation
Facility include: 1,1,1-trichloroethane (7 ppb), methylene chloride
(29 ppb), chloromethane (20 ppb). The following maximum
concentrations of semi-volatile organic compounds were detected:
bis(2-ethylhexyl)phthalate (180 ppb), and 2-chlorophenol (14 ppb).
EPA collected "split samples" during the investigation carried out
at the Westinghouse facility in 1987-1988. The results of the TCE
analysis of ground water are presented below:
TCE Concentration in Ground Water Sample in parts per billion
Monitoring Well EPA
Number Data provided by Westinghouse Split Sample Data
2S nd nd<5
2D nd nd<5
4 nd 4.18J
6 8 9.24
10 210 187
11 14 13.3
5 13 14
6 13 13
nd = TCE not detected (<"5" denotes detection limit)
J = TCE detected at a level below contract requirement
Ground water Investigations at Facet Enterprises Inc.
Table 5 summarizes the analyses of ground water samples collected
-12-
-------
at the Facet Enterprises, Inc. facility in 1986. The data was
provided by Facet Enterprises to EPA pursuant to the requirements
of their 1986 Administrative order.
Ground water analyses from monitoring wells collected in 1983 and
1986 located at the Facet Enterprises facility indicate the
following contaminants are present at the following maximum levels:
TCE (800 ppb), 1,1,1- trichloroethene (268 ppb), trans-1,2-
dichloroethylene (189 ppb) vinyl chloride (14 ppb). Lower levels
of fluorocarbons and methylene chloride were also detected in
samples analyzed. Phenolics were detected at levels up to .37 ppb
at this property.
The following semi-volatiles and the maximum concentrations were
detected in 1986 follows: bis(2-ethylhexyl)phthalate (7 ppb), and
pentachlorophenol (300 ppb).
The results of the 1986 sampling at Facet Enterprises Inc. indicate
that the following maximum levels of chromium (280 ppb), lead (69
ppb), and thallium (38 ppb) all exceed New York State Water Quality
Standards for drinking water.
Ground water Investigations at LRC Electronics
Table 6 summarizes the analytical data from ground water samples
collected at the LRC facility. This data was provided by LRC
Industries to the NYSDEC pursuant to the requirements of their
Order.
The results of sampling in 1988 indicate the presence of, among
other organics, TCE (27 ppb), xylene (234 ppb), 1,1,1-TCA (4 ppb),
1,1-dichloroethane (3 ppb), chloroform (16 ppb), methylene chloride
(14 ppb).
The inorganic compounds detected in ground water included cadmium
(35 ppb), chromium (190 ppb), and lead (300 ppb).
RESULTS OF SOIL BORING INVESTIGATION
A soil boring investigation was completed at areas identified in the
Remedial Action Master Plan (RAMP) or the RI/FS as potential sources
of ground water contamination. The location of the soil borings is
presented in Figure 9. The location of each of the borings was
determined by review of historical photographs and the results of
a soil gas survey at each area. At one of the potential fill areas
identified (area 18) , the soil gas survey showed no anomalous
results, therefore, no soil borings were completed. The results of
the soil boring investigation at the remaining areas are summarized
below. The data collected during this soil boring investigation was
used to determine if, and if so, the extent to which a particular
area is contributing to the widespread aquifer contamination
-13-
-------
problem, and to collect data to support the baseline risk
assessment.
Any organic compound detected during the soil boring investigation
is considered to be a contaminant. Table 7 presents concentrations
of inorganic compounds that may normally occur in soils. The
widespread occurrence of calcium, iron, magnesium, potassium, and
sodium at levels above these reported ranges indicates that,
regionally, these inorganic compounds occur at levels above
published data for average soil concentrations. A list of
polyaromatic hydrocarbons that typically occur in rural,
residential, or urban areas for comparison with data collected
during this investigation is presented as Table 8.
Chemung County Department of Highways (Area 2)
Table 9 and 10 presents the summary results of the surface and
subsurface soil boring investigation at this area. Full details
are presented in Chapter Four of the Supplemental RI/FS.
Four soil borings were completed at this area in order to
characterize the subsurface geology and in order to collect boring
samples for analysis. A total of 13 samples were analyzed. TCE was
detected at a maximum concentration of 8 ppb in one boring at 15-
17 feet below grade. The water table was encountered at 13.1 feet
below grade at this area.
Semi-volatile constituents were detected at each boring, and one or
more semi-volatiles were detected at all sampling depths. The total
semi-volatile estimated concentrations range from 137 to 4229 ppb.
The highest estimated total semi-volatile concentrations were
detected in soil borings collected from within two feet of the
surface. Phthalates were detected in all four borings with
estimated concentrations ranging from 43 to 1100 ppb.
Polychlorinated biphenyls (PCBs) were detected at 0.34 ppm in one
soil sample collected from within two feet of the ground surface.
One soil boring contained inorganic constituents above normal
background concentrations. Thallium (3.4 ppm) and arsenic (123 ppm)
were detected in the sample collected from the upper two feet of
soil; lead (79 ppm) was detected in the sample collected at 5 to 7
feet below grade.
The analytical data from soil samples collected at the Chemung
County Department of Transportation Garage during the Supplemental
RI do not indicate that a source of TCE exists at this facility.
The presence of TCE in ground water upgradient of the area indicates
the primary source is upgradient.
-14-
-------
Old Horseheads Landfill (Area 3)
Eight soil borings were completed in order to establish the area
geology at and in the vicinity of the Old Horsehead Landfill, and
thirty three soil samples were collected from these borings and
analyzed in order to determine if contaminants are present and are
contributing to the TCE ground water contamination problem at the
Kentucky Avenue Wellfield. The data is presented in Tables 11 and
12.
TCE was detected at concentrations ranging from 2 ppb to 3 ppb in
two soil samples. The two soil samples were collected at a depth
of 20-22 feet below grade, and were collected from below the water
table (approximately 16 feet). 1,2-dichloroethylene was detected
in two soil borings at 5 -45 ppb. The samples were collected at or
below the water table. In addition the following organic compounds
were detected at the following maximum concentrations: 2-butanone
(2-25 ppb), ethylbenzene (2-180 ppb), toluene (2-12 ppb), methylene
chloride (1-45 ppb), total xylenes (5-220 ppb), vinyl chloride (140
ppb).
Semi-volatiles were detected in soil samples. Bis(2-ethylhexyl)
phthalate (BEHP) was detected in ten soil borings at various depths.
The highest concentration of BEHP was at 520,000 ppb detected in a
soil sample collected at a depth of 5-7 feet. Di-n-butyl phthalate
was also detected in four borings with a range of 53-77,000 ppb.
The highest levels of semi-volatiles occurred in the southeastern
portion of the landfill near the surface soils. Besides the BEHP
and Di-n-butyl phthalate, the compounds detected are typical of
compounds detected in soils where oil or other petroleum products
have spilled.
PCBs were found in five soil borings at depths ranging from 0-2 feet
to 15-17 feet below grade. The PCB concentration ranged from 20
ppb to 300 ppm. The highest concentration was detected in a soil
sample collected at a depth of from 10 feet to 12 feet below grade.
Arsenic (25.6 ppm), cadmium (15 ppm), chromium (118 ppm), copper
(1360 ppm), lead (1,520 ppm), magnesium (37,600 ppm), nickel (200
ppm), and zinc (7120 ppm) have been detected at this area in levels
abova normal background concentrations.
Former Sand and Gravel Pit (Area 4)
Three soil borings were completed at this area and one boring was
collected in the immediate vicinity of the area in order to
characterize the subsurface geology. A total of 20 soil/sediment
samples were collected for chemical analysis. The data is presented
-15-
-------
in Tables 13 and 14. TCE was detected at levels ranging from 1 to
7 ppb in two of the samples. Both of these sample were collected
at or below the water table. Acetone was also detected in two soil
borings, however it is also present in the field and laboratory
blanks, therefore and the acetone is likely a result of field and/or
laboratory contamination.
The following semi-volatile was detected with the following maximum
concentration in soil samples collected from the sand and gravel
pit: bis(2-ethylhexyl)phthalate (890 ppb).
Magnesium was the only inorganic detected in the soil borings at
above background levels for soils at this area. The highest level
detected was 37,700 ppm in a sample collected at a depth of 5-7 feet
below grade.
Koppers Company Disposal Area (Area 15)
The data collected during the soil boring investigation at this
source area are presented in Table 15 and 16.
Three soil borings were completed and 15 samples were analyzed from
the Koppers Disposal Area. TCE was detected in two soil borings at
11 ppb and at 2 ppb. The TCE was detected in split spoon samples
collected from at or below the water table. The relatively low
concentrations (<11 ppb) found in soil do not indicate that this is
a source of ground water contamination.
Most semi-volatile compounds which were detected were in the upper
five feet of soil suggesting that semi-volatile contamination is
restricted to the surface. Bis(2-ethylhexyl)phthalate (39-2900 ppb)
and di-n-octyl phthalate (DNOP) (91 ppb) were detected. Polynuclear
aromatic hydrocarbons (PAHs) totaled a maximum in one sample of
2,280 ppb.
Lindane was detected in one sample at a concentration of 8.0 ppb
which was obtained from within 7 feet of grade, and chloroform was
detected at 20 feet below grade at 4 ppb.
Above background concentrations of magnesium (22,900 ppm), calcium
(93,400 ppm), and zinc (153 ppm) were detected.
Koppers Company Waste Oil Lagoon Area (Area 17)
The data collected for the soil boring investigation in this area
are presented in Tables 17 and 18.
Six soil borings were completed in or adjacent to the investigation
area 17. TCE (1-15 ppb) was detected in soil borings. All
concentrations were detected in samples collected at or below the
water table. The concentrations of TCE at less than or equal to 15
ppb indicate that the soil in this area is not a likely source of
TCE contamination in the ground water.
-16-
-------
Other volatile organic compounds detected in the soil samples were
toluene (5 ppb), acetone (590 ppb), benzene (3 ppb), and methylene
chloride (33 ppb).
Semi-volatile contamination was most commonly detected in soil
samples collected from the surface to five feet below grade.
The semi-volatile contaminants detected were Bis(2-
ethylhexyl)phthalate (740 ppb), and Di-n-octyl phthalate (62 ppb).
Polynuclear aromatic hydrocarbons (PAHs) totaled a maximum in one
sample of 5,586 ppb.
The pesticide 4,4 DDT was detected in one sample at 18 ppb collected
15-17 feet below grade.
The inorganics magnesium (33,400 ppm), calcium (118,000 ppm), and
zinc (120 ppm) were detected in soil samples at levels above normal
background soils.
Koppers Company Open Storage Are (Area 16)
One soil boring was completed in this area, and 4 soil boring
samples were analyzed from this boring. The data is presented in
Tables 19 and 20. PAHs totalling 0.37ppm were detected. Di-n-
butylphthalate (80 ppb) was the only other organic chemical
detected. The D-n-butylphthalate was detected in samples collected
at 5 and at 10 feet below grade.
Cadmium (1.4 ppm), calcium (26,400 ppm), and zinc (86.6 ppm) were
detected in the soil boring collected in this area.
Soil Investigation at the Westinghouse Electric Company Facility
Soil samples were collected from 22 soil borings from 5 potential
source areas located at the Westinghouse facility. The soil samples
were composited and analyzed for priority pollutant volatile
organics and inorganics. The data in Table 21 was provided by
Westinghouse to EPA pursuant to the requirements of the consent
order.
Composite soil samples were collected from various depths in the
runoff basin area, and a single sample collected from a former
solvent storage tank area exhibited concentrations of a number of
volatile and semi-volatile organic compounds. TCE was detected in
a composited soil sample at 40 ppb, and the polyaromatic
hydrocarbons fluoranthene, phenanthrene, and pyrene were also
detected. In the former storage tank area, chloroform (96,000),
toluene (5r-">00 ppb), 1,2-dich.loroethene (1,600 ppb),
tetrachloroethene (PCE) (700 ppb), and trichloroethylene (120,000
ppb) were detected in the upper three feet of soil.
Results from composite soil analysis at the coal pile storage area
indicated that three priority pollutant volatile organics
-17-
-------
tetrachloroethylene (12 ppb), TCE (19 ppb) and Bis(2-
ethylhexyl)phthalate (400 ppb) were detected.
A single soil sample and three composite soil samples collected at
the fluoride disposal area indicate the presence of PCE (15 ppb),
as well as the polycyclic aromatic hydrocarbons totalling 6200 ppb
(anthracene (400 ppb), benzo(a)pyrene (420 ppb) benzo(a)anthracene
(540 ppb), benzo(b)fluoranthene (380 ppb) , benzo(k)fluoranthene (340
ppb), chrysene (530 ppb) fluoranthene (1300 ppb), phenanthrene (1100
ppb) and pyrene (1200 ppb)).
Composite soil samples collected from the "Area F Disposal Area"
indicate the presence of benzene (38 ppb) , and TCE (108 ppb) .
Nickel was detected at a concentration of 38.4 ppb.
Composite soil samples collected during monitoring well installation
indicate the presence of PAHs totalling 33,370 ppb (acenapthhene
(890 ppb), anthracene (1200 ppb) benzo(a)anthracene (3900 ppb),
benzo (a)perylene (3200 ppb) benzo(b)fluorenthene (4000 ppb),
benzo(g,h,i)perylene (1900 ppb), fluorene (4680 ppb), benzo
(k)fluorenthene (1400 ppb) chrysene (4300 ppb), and pyrene (7900
ppb)). Pesticides were detected in these soil samples including the
following: (aldrin 150 ppb), gamma-BHC (72 ppb), 4,4'-DDT (800 ppb),
4,4'-ODD (150 ppb), dieldrin (1500 ppb), heptachlor (130 ppb), and
methoxychlor (490 ppb)).
Facet Enterprises. Inc. Studies
*'
Fifty-two soil boring samples were collected by Facet Enterprises
at various depths at the Facet Enterprises facility. Soil samples
from twenty-nine locations were analyzed by Facet Enterprises for
TCE and other volatile organics. Two samples were analyzed for
priority pollutants. The data is presented in Table 22. Based on
the results of the analysis, Facet Enterprises reported :to EPA that
TCE (at concentrations up to 253 ppb) was detected in 17 of the 29
soil borings collected west of the plant building. PCE (150 ppb)
was detected at 9 of the 29 shallow soil borings. Other volatile
organic compounds detected in the soils were 1,1,1-trichloroethane
(48 ppb), 1,1-dichloroethane (13 ppb), trichlorofluoromethane (29
ppb), methylene chloride (15.8 ppb), trans-l,2-dichloroethene (22."6
PPb).
Two soil samples were analyzed for semi-volatile organics and
inorganic metals. Di-n-butyl-phthalate (3600 ppb) and bis (2-
ethylhexyl)phthalate (800 ppb) were detected south of the plant
buildings. A soil boring sample collected during monitoring well
installation from the southwest corner of the plant revealed the
following: naphthalene (170 ppb), phenanthrene (605 ppb), anthracene
(190 ppb), di-n-butyl phthalate (230 ppb), fluoranthene (550 ppb),
pyrene (350 ppb), chrysene (370 ppb), chromium (288 ppm), lead (429
ppm), and zinc (1070 ppm).
Shallow soil samples collected at the waste oil lagoon had PCBs
detected in concentrations up to 24 ppm.
-18-
-------
LRC Electronics
In 1981, 1 soil borings was obtained and analyzed by LRC Electronics
for chromium, lead, nickel, silver, cyanide, oil and grease, and
fluoride. The highest concentration of metals were detected in one
sample that had the following concentrations cadmium (58 ppm),
chromium (374 ppro), lead (124 ppm), cyanide (6.2 ppm) and silver (41
ppm). Table 23 summarizes data collected from the LRC facility.
Sediment and Surface Water Investigation
Table 24 presents a summary of surface water and sediment samples
collected in the drainageway which flows south of the Westinghouse
facility, discharges into the pond south of the Old Horseheads
Landfill, and then continues to flow south-east to the Newtown
Creek. Figure 10 illustrates the drainage way which flows south.
from the Westinghouse facility to the pond south of the Old
Horseheads Landfill.
Five surface water and sediment samples were collected from the
drainageway during the Supplemental RI. TCE was detected in two of
the five surface water samples at 2-3 ppb. One sediment sample had
TCE detected at 8 ppb. PCB's were detected in one sample at-3.9
ppm. One sediment sample contained cadmium at 2,660 ppm.
The pond surface water samples contained no organic contamination,
and all inorganics were below New York State Water Quality
Standards.
Westinghouse Investigation
1,1,1-Trichloroethane was detected in surface water at 6 ppb from
flume 001W. TCE was detected at 6ppb in a surface water sample at
outfall 001W. Cadmium was detected at 9 ppb, and copper was detected
at 32 ppb.
Organics detected in sediments include 5 ppb of TCE and 6 ppb of
1,1-trichloroethane.
Inorganics detected in sediments at levels considered to be above
background include cadmium (729 ppm), chromium (72 ppm), copper (445
ppm), lead (373 ppm), mercury (1 ppm), nickel (90 ppm), silver (6.9
ppm), and zinc (20,450 ppra). This data is presented in Figure 11.
The data collected during the Supplemental RI do not indicate that
areas investigated by EPA, including the Chemung County Garage, the
Old Horseheads Landfill, the former Koppers Company disposal areas,
a sand and gravel pit, and a fill area, contribute to the ground
water contamination at the Kentucky Avenue Well. Although these
-19-
-------
areas do contain some contaminants, neither the concentration nor
distribution of the contaminants indicate they are sources of the
aquifer contamination at the Kentucky Avenue Wellfield. In
addition, based on the baseline risk assessment for current Site use
conditions, these above referenced areas do not pose a threat to
human health or the environment.
7,Summary of Site Risks
A Risk Assessment was prepared by EPA as a part of the Supplemental
RI/FS, and the results are used to evaluate the ramifications of the
no-action remedial alternative and in order to determine if an
actual or threatened release of a hazardous substance from the Site
may present an imminent or substantial endangerment to public
health, welfare, or the environment. The Risk Assessment is
presented as Chapter 6 of the Supplemental RI Report.
Contaminants of Concern
A list of chemicals of concern for each area investigated, and for
the ground water, was developed based on the toxicity, mobility,
concentration, frequency of detection, and persistence of the
contaminants detected. The list for each area and medium
investigated, and for the ground water, are provided in Table 25.
The range of concentrations for each contaminant in each medium
investigated are presented in the Tables in the Summary of Site
Conditions section of this ROD.
«'
Exposure Assessment
In this assessment, both current and potential future exposure
pathways are considered. Current activity patterns at the Site are
examined to identify current exposure potential to residents and
workers from the Site as it presently exists. In developing future
exposure pathways, it is assumed that no further remedial actions
will be undertaken.
The exposure pathways evaluated for current Site use conditions are:
1) Ingest ion of ground water in the area of the Kentucky Avenue
Wellfield. Inhalation of volatile chemicals released from tap water
into indoor air is qualitatively discussed.
2) Incidental ingestion and dermal absorption of chemicals from
surface soil by children and teenagers using source areas
recreationally. (This was evaluated for each of the areas
investigated separately).
3) Incidental ingestion and dermal absorption of chemicals from
sediments by children and teenagers using source areas
recreationally.
The exposure pathway evaluated for future use given the Site
condition is:
-20-
-------
1) Incidental ingestion and dermal absorption of chemicals from
surface and subsurface soils by future residents living at source
areas. (This was evaluated for each of areas investigated
separately).
To quantitatively assess the potential risks to human health
associated with the exposure scenarios considered in this
assessment, estimates of chronic daily intakes (GDIs) are developed.
GDIs are expressed as the amount of a substance taken into the body
per unit body weight per unit of time, or mg/kg/day. A GDI is
averaged over a lifetime for carcinogens and an exposure period for
noncarcinogens. An average case and a maximum case are considered.
The average case is based on average (but conservative) conditions
of exposure and the average exposure point concentrations. The
maximum case is based on upper-bound conditions of exposure and the
maximum exposure point concentration, and as such represents the
extreme upper limit of potential exposure.
The following are exposure parameters and assumptions used to
estimate residential ground water ingestion exposures; direct
contact with surface soil and sediments by children and teenagers
under current Site use conditions; and direct contact with surface
soil by residents under future Site use as presented in Tables 26
through 28. The tables indicate each parameter and or assumptions
for the average case and the maximum case.
Toxicity Assessment Summary
Cancer potency factors (CPFs) have been developed by EPA's
Carcinogenic Assessment Group for estimating excess lifetime cancer
risks associated with exposure to potentially carcinogenic
chemicals. CPFs, which are expressed in units of (mg/kg-day)"1, 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.
For known or suspected carcinogens, the EPA considers excess upper
bound individual lifetime cancer risks of between 1E-04 to 1E-06 to
be acceptable with 1E-06 being the point of departure, (i.e., the
probability of cne excess cancer is one in 10,000 or 1,000,000,
respectively, under the conditions of exposure).
Noncarcinogenic risks were assessed using a hazard index (HI)
computed from expected daily intake levels (subchronic and chronic)
and reference doses (RfDs) representing acceptable intakes.
Potential concern for noncarcinogenic effects of a single
-21-
-------
contaminant in a single medium is expressed as the hazard quotient
(HQ). This is the ratio of the estimated intake (derived from the
contaminant concentration in a given medium) to the contaminant's
RfD. By adding the HQs for all contaminants within a medium or
across all media to which a given population may reasonably be
exposed, the HI can be generated. The HI is useful as a reference
point for gauging the potential effects of environmental exposures
to complex mixtures. In general, His which are less than one are
not likely to be associated with any health risk, and are therefore
less likely to be of concern than His greater than one.
In accordance with EPA's guidelines for evaluating the potential
toxicity of complex mixtures, it was assumed that the toxic effects
of the site related chemicals would be additive. Thus, lifetime
excess cancer risk and the CDI:Rfd ratios were summed to indicate
the potential risks associated with the mixtures of potential
carcinogenic and noncarcinogens, respectively.
Under current EPA guidelines, the likelihood of carcinogenic and
noncarcinogenic effects as a result of exposure to Site chemicals
are considered separately.
The summary of health effects criteria for chemicals of potential
concern at the Kentucky Avenue Wellfield site are presented in Table
29 and are discussed below.
Human Health Risk Characterization "
The risk calculation characterization quantifies present and/or
potential future threats to human health that result from exposure
to the contaminants of concern at the seven areas investigated and
the ground water. The specific risk values are estimated by
incorporating information from the toxicity and exposure
assessments. Tables 30 and 31 summarize carcinogenic and
noncarcinogenic risks for the site.
The results of the Risk Assessment are presented in Tables 32 thru
45. The results indicate that long-term exposure to contaminated
ground water poses the greatest human health concern. Ground water
contaminants at the Site include relatively water soluble volatile
organics and metals detected primarily (with the exception of
chromium, calcium, magnesium) in the particulate phase. Chlorinated
straight-chain hydrocarbons (e.g. TCE, PCE, TCA) constitute the
predominant organic ground water contaminants. All potential
carcinogenic substances detected in ground water were included as
indicator compounds, regardless of their frequency of occurrence or
concentration,
A detailed discussion of the results of the risk assessment
conducted for each area investigated, including ground water, is set
forth below:
-22-
-------
1. Current Ground Water and Land Use Scenarios
Ground Water
Risks to public health were estimated by combining information on
exposure at possible exposure points with toxic potency of the
ground water contaminants. Drinking water from ground water wells
in the vicinity of the Kentucky Avenue Well for a lifetime
(estimated at 70 years) would be associated with an upperbound
excess lifetime cancer risk for the average case of 5E-05, and a
plausible maximum of 1E-03. These risks are primarily attributable
to the presence of arsenic, trichloroethylene, and vinyl chloride
in unfiltered ground water.
Risks in terms of the hazard index associated with ingestion of
unfiltered ground water attributable to non-carcinogenic
contaminants for the average case is 2E+01, and for the maximum case
the hazard index is 9E+01. The hazard index value greater than one
is due to the presence and concentrations of antimony, barium,
cadmium, chromium, manganese, nickel, thallium, and vanadium in
unfiltered ground water samples. Although barium, chromium,
manganese, and nickel were detected in unfiltered ground water
samples, only the concentration of nickel in one filtered ground
water sample resulted in a hazard index greater than one.
The chemical concentration in ground water from unfiltered ground
water samples which exceed federal and state drinking water
standards are arsenic, barium, cadmium, lead (maximum concentration
detected only), total chromium, (average and maximum concentrations
exceed the federal MCL and proposed MCL, the maximum concentration
exceeds the state standard for chromium VI) , iron, manganese
(average and maximum concentrations exceed the state standard and
the federal secondary drinking water standards), and TCE (average
and maximum concentrations exceed the federal MCL and the state
standard). The average and maximum lead concentrations exceed the
proposed MCL. The maximum concentration exceeds the federal
secondary drinking water standard.
Exposure to Lead
Potential exposures to lead at the site were evaluated. The
evaluation indicated that ingestion of the maximum detected level
of lead in the unfiltered ground water would result in blood lead
levels exceeding the EPA range of concern. If ground water is
filtered prior to ingestion, the blood lead range of concern would
be exceeded in one case.
Direct Contact With Surface Soils by Children and Teenagers
The potential risks associated with exposure to carcinogens in the
surface soil at each of the areas investigated are as follows: At
the Chemung County Garage, the excess lifetime cancer risks range
from 2E-06 for the average case to 5E-05 for the maximum case. At
-23-
-------
the Old Horseheads Landfill the excess lifetime cancer risks range
from 1E-06 for the average case to 2E-05 for the maximum case. At
the Sand and Gravel Pit, the excess lifetime cancer risks range from
4E-11 for the average case to 3E-09 for the maximum case. At the
Koppers Storage Area, none of the selected carcinogenic chemicals
of concern were detected. At the Koppers Former Waste Oil Lagoon
area, the excess lifetime cancer risks are 3E-11 for the average
case and 3E-09 for the maximum case. At each source area
investigated for exposure to surface soils, the risks estimated are
within or below the 10-6 to 10-4 target risks range used to evaluate
cancer risks at Superfund sites.
For noncarcinogens, the estimated hazard index values are less than
one for all the evaluated potential source areas. This indicates
that adverse noncarcinogenic effects are unlikely to occur as a
result of direct soil contact exposures under current Site use
conditions.
Direct Contact With Sediment By Children and Teenagers
The excess lifetime cancer risks for direct contact with sediments
in the drainageway which flows south from the Westinghouse 002
outfall adjacent to the Chemung County Department of Highways Garage
range from 3E-06 for the average case to 4E-04 for the maximum case.
For direct contact with the sediments in the same drainage way at
the Old Horseheads Landfill, the excess lifetime cancer risks are
estimated to range from 7E-07 for the average case to 6E-05 for the
maximum case.
The Hazard Index value for the drainageway adjacent to the Chemung
County Garage is less than one for the average case but greater than
one for the maximum case. The exceedance of the threshold value of
one is due to exposure scenarios which consider routine ingestion
of maximum detected concentrations of cadmium in drainage ditch
sediments. The average and maximum case hazard index values for
direct contact with drainageway sediments adjacent to the Old
Horseheads Landfill is was less than one.
2. Future Land Use Scenarios
Direct Contact with Surface Soils
The estimated risks associated with Residential Exposures by direct
contact with carcinogens in surface soil for the future use scenario
are as follows: for the Chemung County Garage, the excess lifetime
cancer risks are estimated to be 8E-07 for the average case and 4E-
05 for the maximum case. For the Old Horseheads Landfill,
the risks ranged from 6E-07 for the average case scenario to 2E-05
for the maximum case. For the average case at the Sand and Gravel
Pit, the excess lifetime cancer risks are estimated to range from
2E-11 for the average case to 4E-09 for the maximum case. None of
the selected carcinogenic chemicals were detected at the Koppers
-24-
-------
Disposal Area. At the Koppers Company former waste lagoons, the
calculated risks are estimated at 1E-11 for the average case and
2E-09 for the maximum case. The risks for all these areas are
within or below the 1E-06 to 1E-04 cancer risk range.
For subsurface soil, potential risks were also calculated in the
same manner except that subsurface soil concentrations were used
rather than the surface soil concentrations. The excess lifetime
cancer risks for the average and maximum cases, respectively were
as follows for subsurface soil collected at each of the areas
investigated: 3E-07 and 8E-06 for contaminants detected at the
Chemung County Garage; 4E-07 and 1E-03 for the Old Horseheads
Landfill (primarily a result of carcinogenic PAHs, PCBs, and
arsenic); 5E-07 and 2E-05 for the Sand and Gravel Pit; 1E-11 and
8E-9 for the Koppers Disposal Area; and 8E-8 and 3E-6 for the former
Koppers Waste Oil Lagoon. The maximum excess lifetime cancer risk
calculated for the Old Horseheads Landfill results from using the
data collected from one soil boring collected from a depth of
approximately 10 to 12 feet below the ground surface which contained
PCBs contamination at 300 ppm. Other soil boring samples collected
at the landfill had PCBs detected in concentrations ranging from
0.020 ppp to 4.3 ppra. It is most likely that the PCB concentration
of 300 ppm is restricted and confined to a small area surrounding
the sampling location.
The Hazard Index values for all the areas investigated are below one
for both surface and subsurface soils.
Environmental Risk Characterization
Impacts on aquatic life were evaluated for chemicals in surface
water and sediment. Surface water concentrations were compared with
ambient water quality standards (AWQS) developed by the State of New
York or ambient water quality criteria (AWQC) developed by EPA.
This comparison is presented in Table 46.
With the exception of PCB's and mercury, none of the chemicals
detected in near surface soils, sediments, or surface waters
accumulates to a significant degree in plants or animals, and
therefore foodchain exposures are expected to be minimal. However,
potential exposures and impacts associated with such exposures, if
occurring, are not expected to be significant because of the limited
extent of the contamination.
Mean and maximum surface water concentrations of aluminum, cadmium,
iron, lead, and zinc in the drainage way exceed Class C or Class D
AWQS. Maximum concentrations of chromium, cobalt, and mercury
exceed their respective surface water criteria.
Sediment concentrations were compared with toxicity "criteria1
derived from the available literature. Sediment "criteria" are
exceeded in the drainage way or pond by mean and maximum
concentrations of copper, lead, mercury, PAHs, PCBs, and zinc and
cadmium.
-25-
-------
For more specific information concerning public health risks,
including quantitative evaluation of the degree of risk associated
with various exposure pathways, please see the volume entitled
Public Health Evaluation for the Kentucky Avenue Wellfield Site
located at the Horseheads Town Hall, NYSDEC Region 8 Office located
in Avon, N.Y., or EPA Region II office Superfund Site file room
located in New York City.
Uncertainties
The procedures and inputs used to assess risks in this evaluation,
as in all such assessments, are subject to a wide variety of
uncertainties. In general, the main sources of uncertainty include:
-environmental chemistry sampling and analysis,
-environmental parameter measurement,
-fate and transport modeling,
-exposure parameter estimation,
-toxicological data.
Uncertainty in environmental sampling arises in part from the
potentially uneven distribution of chemicals in the media sampled.
Consequently, there is significant uncertainty as to the actual
levels present. Chemicals such as vinyl chloride contribute to
excess lifetime cancer risks greater than 1E-06 under specific
conditions of exposure addressed in the public health evaluation,
although vinyl chloride was detected infrequently and at 'low
concentrations. Environmental chemistry analysis error can stem
from several sources including the errors inherent in the analytical
methods, chain of custody procedures, and characteristics of the
matrix being sampled. Environmental parameter measurements
primarily contribute to uncertainty because little verified
information is available.
In risk assessment there are uncertainties regarding the estimates
of how often, if at all, an individual would come in contact with
the chemical of concern and the period of time over which such
exposure would occur. In particular, this applies to the future
land use scenarios.
Toxicological data error (potentially occurring in extrapolating
both from animals to humans and from high to low doses) is also a
large source of potential error in this risk assessment. There is
also a great deal of uncertainty in assessing the toxicity of a
mixture of chemicals. In this assessment, the effects of exposure
to each of the contaminants present in the environmental media have
initially been considered separately. In summary, the calculated
risks to public health from this Superfund site based on average,
but conservative, exposure assumptions primarily involve exposure
to contaminants in the ground water.
-26-
-------
Risk Summary
It is for the above stated reasons that EPA has determined that
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.
8.DESCRIPTION OF ALTERNATIVES
The alternatives chosen for detailed analysis include the
following:
MOM-1 No Action (Ground Water)
MOM-2A Water Use Restrictions/Permit Requirements
MOM-2B Pumping Kentucky Avenue Well/Filtration/Air
Stripping/Carbon Adsorption of Air Emissions/Distribution to
Public Water Supply.
MOM-2C Pumping Kentucky Avenue Well/Filtration/Carbon
Adsorption/Distribution to the Public Drinking Water Supply.
MOM-2D Pumping Kentucky Avenue Well/Filtration/UV-Ozone
Oxidation/Discharge to Drinking Water Supply
MOM-2E Pumping Kentucky Avenue Well/Filtration/Air
Stripping/Carbon Adsorption of Air Emissions/Downgradient
Reinjection
MOM-2F Pumping Kentucky Avenue Well/Filtration/Carbon
Adsorption/Downgradient Reinjection
MOM-2G Pumping Kentucky Avenue Well/Filtration/UV-Ozone
Oxidation/Downgradient Reinjection
MOM-3A Pumping at the Southern Boundary of the Site/Filtration/Air
Stripping/Carbon Adsorption of Air Emissions/Downgradient
Reinjection
MOM-3B Pumping at the Southern Boundary of the
Site/Filtration/Carbon Adsorption/Downgradient Reinjection
MOM-3C Pumping at the Southern Boundary of the Site/Filtration/UV-
Ozone Oxidation/Downgradient Reinjection
MOM-4A Pumping at Two Locations/Filtration/Air Stripping/Carbon
Adsorption of Air Emissions/Downgradient Reinjection
MOM-4B Pumping along two lines of extraction
wells/Filtration/Carbon Adsorption/Downgradient Reinjection
-27-
-------
MOM-4C Pumping at Two Locations/Filtration/UV-Ozone
Oxidation/Downgradient Reinjection
MOM-5A Pumping Downgradient of Westinghouse
Facility/Filtration/Air Stripping/Carbon Adsorption of Air
Emissions/Discharge to Surface Water
MOM-5B Pumping Downgradient of Westinghouse
Facility/Filtration/Carbon Adsorption/Discharge to Surface Water
MOM-5C Pumping Downgradient of Westinghouse
Facility/Filtration/Uv-Ozone Oxidation/Discharge to Surface Water
Alternative MOM-1 Ko Action
The No Action alternative for the contaminated ground water
aquifer underlying the Site includes a long term monitoring
program. The long-term monitoring program would consist of annual
sampling for TCL volatiles and metals at ten of the existing
monitoring wells. In addition, new wells would be constructed in
areas downgradient of the ground water contamination. A 30-year
monitoring period is used for cost estimation purposes. The data
gathered would be used to verify whether the concentrations of the
contaminants of concern have been lowered to cleanup levels
through migration of contaminants downgradient and to the Newtown
Creek. Public information meetings, workshops, and presentations
would be provided to increase public awareness. Institutional
management would also be required to review the Site every five
years as required by the NCP.
The costs associated with this alternative is indicated below:
Alternative l: No Action and Alternative
Capital cost $41,400
Operation and Maintenance (30 yrs) $22,500
Present Worth (Discount Rate 5%) $415,300
Alternative MQM-2A; Water Use Restrictions/Permit Requirements
The implementation of the limited action alternative for the
contaminated ground water aquifer includes both a long-term
monitoring program and an institutional control program to
regulate/restrict the use of the ground water. Such restrictions
would involve limited use and/or use with specially acquired
permits. The long-term monitoring program would consist of annual
sampling for TCL volatiles and metals at ten cf the existing
monitoring wells plus new wells to be constructed on-site and
downgradient of the ground water contamination. The data gathered
would be used to verify whether the concentrations of the
contaminants of concern have been lowered to cleanup levels
through natural attenuation, and to monitor potential migration of
-28-
-------
contaminants downgradient and to the Newtown Creek. Public
information meetings, workshops, and presentations would be
provided to increase public awareness.
The costs associated with this alternative are indicated below:
Alternative 2A: Water Use Restrictions/Permitting Requirements
Capital cost $55,200
Operation and Maintenance (30 yrs) $22,500
Present Worth (Discount Rate 5%) $429,100
Alternative MOM-2B-2D; Pumping Kentucky Avenue Well/Filtration/Air
Stripping/Discharge to Drinking Water Supply or Reinjection
These alternatives require pumping at the existing well, or
replacement of this well, treatment, discharge of treated ground
water, and a performance monitoring program. The existing
Kentucky Avenue Well would be restored to pump the ground water at
a rate of approximately 700 gallons per minute. The treated
ground water would be discharged to the local drinking water
supply or reinjected. The schematic diagram of the plant is shown
in the Feasibility Study.
The well head treatment system would consist of a filtration step
to remove metals in suspended solids, followed by one of the
following treatment alternatives to treat volatile emissions: 1)
an air stripping tower with a vapor phase carbon adsorption system
to control air emissions from the air stripping unit, 2) carbon
adsorption treatment of ground water, or 3) UV-Ozone oxidation.
These alternatives include the use of existing and newly installed
monitoring wells at the Site to conduct a long-term monitoring
program to track the migration and concentration of the
contaminants of concern in the aquifer underlying the Site. The
migration of ground water would be assessed every five years
utilizing the data collected during the monitoring program.
The following outline briefly discusses ground water extraction
and treatment methods for these alternatives. Other alternatives
for treating contaminated ground water discussed in the ROD would
schematically use the same types of systems, but would be scaled
appropriately for the particular ground water remedial
alternative. Any design of treatment plants for the selected
remedial action will be based solely on performance and the
ability of the treatment system to meet Federal and New York State
water quality criteria for drinking water at the tap. Detailed
discussion of tho treatment systems for each alternative can be
found in Chapter 4 of the Feasibility Study
» Pumping and collection; The ground water pumping system
would consist of the existing Kentucky Avenue Well. Extracted
ground water would be delivered to a collection tank used to
-29-
-------
equalize the ground water flow and the concentration of the
contaminated feed stream to the treatment system.
» Filtration; A pressure filtration system would consist of a
feed pump used to pump ground water to a filter. Typically the
filter would consist of one dual media filter, equipped with
backwash pumps and controls. The treated water from the filters
will be fed to the air stripper, and the backwash stream along
with coagulant, will be sent to an approximately 4200- gallon
carbon steel clarifier. The supernatant from the clarifier will
be collected in an approximately 525-gallon supernatant tank and
then fed back to the collection tank by means of a centrifugal
pump, having a flow of approximately 35 gallons per minute. The
sludge from the clarifier will be delivered to a pump. The
filtrate out of the pressure filter will also be collected into
the supernatant tank. The filter press would produce a dewatered
sludge cake of approximately 30-40 percent solids by weight. The
dewatered sludge cake is expected to accumulate at a rate of
approximately 0.70 tons per day. The sludge cake would be
collected/stored in drums or rolloffs, then removed for fixation
and ultimate disposal in a RCRA Subtitle C landfill. Land
Disposal Restriction may apply to disposal of sludge material.
This will be evaluated with Toxicity Characteristic Leaching
Procedure Test (TCLP). If the sludge material exhibits toxicity
characteristics according to the specifications of the TCLP test,
then the sludge will be handled as a RCRA waste and all
manifesting, transportation, treatment, and disposal regulations
will apply.
Air Stripping; An air stripping tower, approximately 6
foot in diameter by approximately 21 feet high, would be operated
with countercurrent flow and 1-inch polypropylene tri-packed
packing. The ground water would pass over the packing surface as
a thin film or droplets, which provide a high surface area for the
volatile organics to transfer from the water phase to the vapor
phase. The air laden with volatile organics would leave the air
stripper and enter a vapor phase carbon adsorption unit, equipped
with duct heater/dehumidifier to reduce the relative humidity to
50 percent. The exiting vapor stream from the vapor phase carbon
unit would be free of volatile organic compounds and could be
discharged to the atmosphere. The estimated annual carbon usage
would be approximately 23 pounds per day for the vapor phase
adsorption systems. The spent carbon would be collected by the
carbon supplier and shipped for off- site disposal or
regeneration and reuse. The treated ground water from the air
stripping towers would be collected into a stripped water sump.
Carbon Adsorption; An approximately 700-gpm carbon adsorber
unit, having two approximately 20,000 Ib. carbon beds would be
operating for the removal of TCE. An approximately 23,860 gallon
carbon steel tank would be used for collecting the treated water.
Spent carbon would be collected and disposed of off-site in
-30-
-------
accordance with Subtitle C requirements. Land disposal
restrictions may apply.
»UV-Ozone Oxidation; An approximately 700-gpm UV-Ozone
Oxidation Unit would be installed for the removal of volatile
organics. The UV-Ozone oxidation process includes a stainless
steel oxidation chamber with UV lamps, and a ozone generation and
feed system. The contaminated ground water would come into
contact with ozone while passing through baffled arrangements
inside the oxidation chamber. In the presence of UV light, ozone
would oxidize the volatile organic compounds to carbon dioxide,
water, and chlorine. The treated ground water from the oxidation
chamber would be collected in a sump.
Treated ground water would be discharged to the local drinking
water supply by a carbon steel centrifugal pump, having a flow of
700 gpm.
The costs associated with each of the treatment alternatives are
indicated below:
MOM-2B Pumping Kentucky Avenue Well/Filtration/Air
Stripping/Carbon Adsorption of Air Emissions/Distribution to
Public Water Supply.
Capital cost $1,089,900
Operation and Maintenance (30 yrs) $549,700
Present Worth (Discount Rate 5%) $9,137,600
MOM-2C Pumping Kentucky Avenue Well/Filtration/Carbon
Adsorption/Distribution to the Public Drinking Water supply.
Capital cost $1,435,400
Operation and Maintenance (30 yrs) $790,800
Present Worth (Discount Rate 5%) $10,084,700
MOM-2D Pumping Kentucky Avenue Well/Filtration/UV-Ozone
Oxidation/Discharge to Drinking Water Supply
Capital cost $1,703,300
Operation and Maintenance (30 yrs) $610,300
Present Worth (Discount Rate 5%) $10,666,700
MOM-2E Pumping Kentucky Avenue Well/Filtration/Air
Stripping/Carbon Adsorption of Air Emissions/Reinjection
Capital cost $1,650,200
Operation and Maintenance (30 yrs) $603,500
Present Worth (Discount Rate 5%) $10,485,600
MOM-2F Pumping Kentucky Avenue Well/Filtration/Carbon
Adsorption/Reinjection
-31-
-------
Capital cost , $1,996,300
Operation and Maintenance (30 yrs) $645,700
Present Worth (Discount Rate 5%) $11,450,300
MOM-2G Pumping Kentucky Avenue Well/Filtration/UV-Ozone
Oxidation/Reinj ection
Capital cost $2,264,200
Operation and Maintenance (30 yrs) $665,300
Present Worth (Discount Rate 5%) $12,004,400
Alternative MOM3A-MOM3C Pumping at the Southern Boundary
of the Site/Treatment and Reinjection to the Aquifer
These alternatives consist of pumping contaminated ground water
from a line of extraction wells located at the southern boundary
of the contaminant plume. A total pumping rate of approximately
4,900 gpm would be required to effectively capture all the ground
water and minimize contaminant migration. Ten wells would be
installed with pumps; each pump would operate at approximately 490
gpm. The on-site treatment would consist of filtration to remove
metals in suspended solids, and either air stripping, carbon
adsorption, or UV-Ozone Oxidation to remove volatile organics. A
vapor phase carbon adsorption system would be provided to control
air emissions from the air stripping unit. These treatment
alternatives are discussed on page 31 of the ROD. The treated
ground water would either be reinjected downgradient using
approximately 20 reinjection wells or if possible, discharged to
surface water.
The costs associated with each of these alternatives are indicated
below:
MOM-3A Pumping at Southern Boundary of Site/Air Stripping/Carbon
Adsorption of Air Emissions/Reinjection
Capital cost $5,339,100
Operation and Maintenance (30 yrs) $1,528,700
Present Worth (Discount Rate 5%) $26,654,600
MOM-3B Pumping at Southern Boundary of Site/Carbon
Absorption/Reinj ection
Capital cost $6,116,100
Operation and Maintenance (30 yrs) $1,627,100
Present Worth (Discount Rate 5%) $28,803,800
MOM-3C Pumping at Southern Boundary of Site/UV-Ozone
Oxidation/Reinjection
-32-
-------
Capital cost $7,366,700
Operation and Maintenance (30 yrs) $1,878,700
Present Worth (Discount Rate 5%) $33,561,800
Alternative MQM4A-MOM4D Pumping Ground vater from Two Lines of
Extraction Wells/Treatment/Reinjection to Aquifer
These alternatives consist of pumping contaminated ground water
from two lines of extraction wells. A total pumping rate of
approximately 4,900 gpm would be required to effectively capture
all the ground water and minimize further migration of
contaminants. Ten wells would be installed with pumps; each pump
would operate at approximately 490 gpm. The on-site treatment
would consist of filtration to remove metals in suspended solids,
and either air stripping, carbon adsorption, or UV-Ozone Oxidation
to remove volatile organics. A vapor phase carbon adsorption
system would be provided to control air emissions from the air
stripping unit. These treatment alternatives are discussed on page
31 of the ROD. The treated ground water would either be
reinjected downgradient using approximately 20 reinjection wells,
or if possible, discharged to surface water.
The costs associated with each of these treatment alternatives are
indicated below:
MOM-4A Pumping from Two Lines of Pumping Wells/Air
Stripping/Carbon Adsorption of Air Emissions/Reinjection
Capital cost $8,514,500
Operation and Maintenance (30 yrs) $1,812,900
Present Worth (Discount Rate 5%) $33,792,000
MOM-4B Pumping from Two Lines of Pumping Wells/Carbon
Absorption/Reinjection
Capital cost $9,291,400
Operation and Maintenance (30 yrs) $1,910,100
Present Worth (Discount Rate 5%) $35,924,400
MOM-4C Pumping from Two Lines of Pumping Wells/UV-Ozone
Oxidation/Reinjection
Capital cost $10,541,900
Operation and Maintenance (30 yrs) $2,156,700
Present Worth (Discount Rate 5%) $40,613,900
Alternative MOM5A-MOM5C Pumping the Aquifer Downgradient of the
ff.es ting:hpu_s_e Facility/Treatment/Discharqe to the Public Water
Supply or to Surface Water
The contaminated ground water would be extracted by installation
of extraction wells downgradient of the Westinghouse Facility. A
total pumping rate of approximately 140 gpm would be required to
effectively contain the contaminated ground water and minimize
-33-
-------
downgradient migration. Four wells with pumps are required; each
pump would operate at approximately 35 gpm. The on-site ground
water treatment scheme would consist of filtration to remove
metals in suspended solids and either air stripping, carbon
adsorption, or UV-Ozone Oxidation to remove volatile organics. A
vapor phase carbon adsorption system would be provided to control
air emissions from the air stripping unit. These treatment
alternatives are discussed on page 31 of the ROD. The treated
ground water would be discharged either to the public water supply
as needed or to surface waters. The migration of contaminated
ground water downgradient of extraction would be assessed every
five years utilizing the data collected during the monitoring
program.
The costs associated with each of the treatment alternatives is
indicated below:
MOM-5A Pumping Ground Water Downgradient of Westinghouse/Air
Stripping/Carbon Adsorption of Air Emissions/Discharge to Drinking
Water Supply or Surface Water
Capital cost $839,600
Operation and Maintenance (30 yrs) $355,600
Present Worth (Discount Rate 5%) $5,826,300
MOK-5B Pumping Ground Water Downgradient of Westinghouse/Carbon
Adsorption/Discharge to Public Water Supply or Surface Water
Capital cost $1,092,000
Operation and Maintenance (30 yrs) $378,600
Present Worth (Discount Rate 5%) $6,370,600
MOM-5C Pumping Ground Water Downgradient of Westinghouse/UV-Ozone
Oxidation/Discharge to Public Water Supply or Surface Water
Capital cost $1,016,600
Operation and Maintenance (30 yrs) $388,900
Present Worth (Discount Rate 5%) $6,466,300
9.Summary of Comparative Analysis of Alternatives
Overall Protection of Human Health and the Environment
Section 121(d) of CERCLA provides that remedial actions shall
attain a degree of cleanup of hazardous substances, pollutants,
and contaminants released into the environment and shall control
further release at a minimum to assure protection of human health
and the environment.
The remedial alternatives that restore the Kentucky Avenue Well
(MOM 2A-2G) and the alternatives which require installation of
recovery wells between Westinghouse Electric Corporation Facility
and the Kentucky Avenue Well (MOM 5A-5C) provide for overall
-34-
-------
protection of human health because they would provide for a long-
term, treated, drinking water supply. The water quality at the
tap would meet all Federal and State drinking water standards.
These alternatives would also gradually remove the contaminants of
concern from the aquifer in the vicinity of Kentucky Avenue Well.
After source controls are in place, this alternative will have a
role in restoration of the contaminated ground water aquifer by
preventing further downgradient contaminant migration in areas
influenced by the pumping well. Beyond the influence of the
capture well this alternative would not minimize the migration of
contaminated ground water.
Alternatives involving pumping ground water between the
Westinghouse Facility and the Kentucky Avenue Well (MOM5A-5C)
would prevent further deterioration of the aquifer downgradient of
the pumping wells, and they would play an active role in
remediating the aquifer between the Westinghouse facility and the
Kentucky Avenue Wellfield. After source control is effectively in
place these remedial alternatives would require approximately 30
years to restore the aquifer to drinking water standards in areas
of the aquifer actively managed by the pumping wells. Because of
the extent of the TCE and inorganics contamination in the aquifer,
an uncertainty exists as to whether the alternatives can attain
the ARARs required for final remediation of the drinking water
supply. The MOM5A-5C alternatives would provide for collecting the
data necessary for a technical evaluation to determine the
feasibility of a full aquifer remediation program for the Newto.wn
Creek Aquifer. Treated ground water from these pumping wells
would meet EPA and NYSDEC Drinking Water Standards and therefore
any risk from drinking contaminated water would be reduced to
acceptable levels.
The alternatives involving either 1) pumping at the southern
boundary of the Site with one line of pumping wells (MOM3A-C), or
2) with two lines of pumping wells (MOM 4A-C), followed by
treatment, reinjection to the aquifer, or surface water discharge
would eventually eliminate migration of ground water
contamination, and would gradually reduce the contaminants from
the aquifer if source controls were in place. Pumping at the
southern boundary of the contaminant plume would not be as
protective of the environment because it would probably require
all the contamination to flow the length of the contamination in
the entire aquifer. The remediation time for these alternatives,
assuming source controls are in place, is estimated to be 53 years
(pumping at the southern boundary of the site) or 30 years
(pumping at two lines of recovery wells and reinjecting the
treated ground water. These, alternatives are expected to
eventually result in the overall protection of human health and
the environment after a long period of time.
Both the No Action and the limited action alternatives would
entail no removal of on-site contaminants or treatment of the
contaminated ground water. At least 50 years would be required
after source control is in place for natural flow of ground water
-35-
-------
to reduce the contaminant concentrations to cleanup levels. The
volume of contaminated ground water is expected to increase due to
migration of contaminants. The No-action alternative is not
considered responsive to the remedial objectives, but, rather,
provides a "base case" for comparison with other alternatives; the
limited action alternative is also not considered responsive to
the remedial objectives, but with effective institutional controls .,
it would prevent exposure to ground water contamination. These 2
alternatives would not provide adequate protection of human health
and the environment.
Compliance vith ARARs
Section 121(d) of CERCLA requires that all final remedial actions
comply with all applicable or relevant and appropriate Federal and
State Standards, requirements, criteria or limitations that apply
to the Site.
Without source control measures in place at the areas identified
in the Supplemental RI, the attainment of Federal and New York
State drinking water standards in the ground water for the entire
aquifer cannot be attained.
The ultimate goal of EPA's Superfund Program approach to ground
water remediation as stated on the National Oil and Hazardous
Substances Pollution Contingency Plan (40CFR Part 300) is to
return useable ground water to their beneficial uses within a time
frame that is reasonable. Therefore, for the Newtown Creek
Aquifer, the final remediation goals will be the Federal and New.
York State MCLs, or non-zero MCLGs.
The alternatives that restore the Kentucky Avenue Well and provide
for management of the plume will comply with all action and
location-specific ARARs identified in this ROD. In addition, the
alternatives will comply at the tap with Federal and New York
State Drinking Water Standards which are the contaminant-specific
ARARs for drinking water. These ARARs are listed in Table 47.
Filtration and air stripping and/or carbon absorption systems are
proven methods of ground water treatment for removing metals and
organics, respectively, from ground water to contaminant-specific
ARAR levels. UV-Ozone Oxidation alternatives would require
treatability studies to ensure effectiveness. The discharge of
treated ground water to the drinking water supply system will be
conducted in accordance with New York State and Federal drinking
water standards. The air stripper tower will be designed to
release emissions in accordance with NESHAPS, NAAQS, New York
State Air Guide 1 values for volatile organics, and proposed VHAP
standards.
In addition, the alternative will comply with other action and
location-specific ARARs, which are common to all ground water pump
and treat alternatives. All pumping/treatment systems will be
designed, constructed, operated, and closed in accordance with
-36-
-------
Federal and New York State RCRA facility standards, OSHA standards
for worker protection and safety, and federal and New York Flood
Hazard and Flood Plain Regulations. All piping systems will be
installed to prevent loss of soil or the creation of sedimentation
in accordance with New York's Guidelines for Urban Erosion and
Sediment Control. The placement and location of buried Pipelines
will be reported to the NYSDEC in accordance with the New York
Industrial Code on Buried Pipelines. All Site activity will be
conducted to prevent fugitive emissions and adverse impacts to
fish and wildlife, which are required by the New York General
Prohibitions Against Air Emission, Fish and Wildlife Coordination
Act and the Endangered or Threatened Species Act. Floodplain
assessments and Cultural Resources assessments will be conducted
to ensure that site construction activities will not adversely
affect these resources. Further, all treatment residuals, such as
sludge cake or spent carbon, would be treated to comply with the
LDR requirements if appropriate. That waste which is classified
as RCRA characteristic waste or listed waste will be labeled and
marked to comply with federal and state hazardous waste
transportation requirements.
The No Action alternative would leave contaminated ground water at
the Site. The Federal and New York MCLs and ground water
standards in Table 47 are currently exceeded for the contaminants
of concern in the ground water underlying the Site. Since MCLs
and ground water standards are ARARs for ground water that either
is or may be used for drinking, the No-action alternative will.jiot
satisfy the contaminant-specific ARARs. Long-term ground water
monitoring will comply with pertinent RCRA action-specific ARARs
for ground water monitoring.
Like the No Action alternative, the Limited Action Alternative
which would restrict ground water uses at the Site would leave
contaminated ground water at the Site. The Federal and New York
MCLs and ground water standards in Table 47 are currently exceeded
for the contaminants of concern in the ground water underlying the
Site. Because MCLs and ground water standards are ARARs for
ground water that either is or may be used for drinking,
Alternative MOM-2A would not meet the contaminant specific ARARs.
This alternative will satisfy all action specific ARARs for ground
water monitoring wells.
Long-Term Effectiveness and Permanence.
Long-term effectiveness and permanence addresses the long-term
protection and reliability of an alternative and the magnitude of
residual risk.
Restoring the Kentucky Avenue Well and installing a line of
pumping wells to contain the TCE contamination, treating the water
to drinking water standards, and discharging the ground water to
the water supply will provide an effective long-term drinking
water supply that meets all Federal and New York State
-37-
-------
requirements. All the treatment technologies utilized in treating
the ground water have been demonstrated to be effective in
treating ground water to drinking water standards. By providing a
treated ground water system to supplement the existing public
water supply, the risks associated with long-term exposure to
contaminated drinking water, primarily through ingestion, are
greatly reduced.
The major benefits of pumping and treating ground water at and in
the vicinity of the Kentucky Avenue Wellfield is that this
alternative will prevent migration of the ground water
contamination. These alternatives will restore the aquifer in the
vicinity of the public water supply to drinking water standards
sooner than the other pump and treat alternatives. In addition,
these alternatives will provide data on aquifer response to pump
and treatment in order to evaluate the feasibility of remediating
the entire aquifer. The treatment would continue until TCE
concentrations in the influent to the treatment plant are equal to
or below the established cleanup levels.
Pumping ground water at the southern boundary of the plume may
minimize contaminated ground water migration beyond areas
currently contaminated, but such an approach would require all the
contamination to flow through the entire aquifer before capture.
The ground water would be treated to ground water remediation
cleanup levels prior to reinjection. The remediation would
continue until volatile organics concentrations in the influent to
the treatment plant are equal to or below the cleanup levels. All
the components of the treatment systems are commercially available
and have been used for similar water treatment processes.
Regular performance monitoring would include checking for plugging
in the filters and the air strippers. Carbon regeneration or
replacement would be required for the carbon absorption unit,and
occasional replacement of UV lamps would be required.
Long-term risks associated with the No Action alternative are
related to (1) the continuous migration of contaminants, (2) the
possibility of migration within the Site and to Newtown Creek (3)
any potential future use of the ground water for domestic,
municipal and industrial, or irrigation purposes. Adverse
environmental impacts resulting from contaminant migration would
include inorganic (mainly suspended metals) and organic (mainly
TCE) contamination of ground water which would pose hazards to
both the public and the environment. Therefore, the No Action
alternative is not considered to be effective over the long-term.
With all of the alternatives, a long-term ground water monitoring
program would be required to determine whether contaminant
concentrations are being reduced through natural flushing and to
verify that the model predictions are realistic.
-38-
-------
Reduction of Toxicitv, Mobility, or Volume through Treatment.
This evaluation criteria relates to the ability of a remedial
alternative to reduce the toxicity, mobility, or volume of
hazardous substance at a Site and to thereby control the risks
associated with such hazardous substances.
Restoring the Kentucky Avenue Well would offer reduction of
toxicity, mobility, and volume of the contaminants of concern by
collecting and treating the contaminated ground water.
Treating ground water between the Westinghouse facility and the
Kentucky Avenue Well would offer a significant overall reduction
of toxicity, mobility, and volume of the contaminants of concern
in the area of the aquifer affected by this pumping. However, the
toxicity, mobility and volume of the downgradient ground water
would be left to natural attenuation until the final remedy for
the aquifer is selected.
Pumping and treating ground water in pumping wells at the southern
boundary of the plume or from two lines of pumping wells would
treat significant quantities of contaminated ground water, but the
design of the recovery system would leave the contamination to
flow the entire length of the contaminated area. However, a
larger volume of contaminated ground water would result and would
ultimately have to be treated.
The no-action alternative would not involve any removal,
treatment, or disposal of the contaminants in the ground water
and, as such, no active reduction in toxicity, mobility, or volume
would result. A very gradual reduction in toxicity of contami-
nants would be achieved over time as natural flushing of the
ground water would transport the contaminants downgradient.
However, the volume and concentration of contaminated ground water
would probably increase with time due to the migration of
contaminants downgradient.
Short-Term Effectiveness.
The short term effectiveness criterion relates to the time
required to meet remedial objectives and the short term impacts of
the implementation of the remedy.
There are no major short-term threats to the neighboring community
or to workers during remedial actions associated with any alter-
native. The workers performing the well drilling and sampling
activities would be provided with personnel protection equipment
to minimize direct contact risks and would be health-and-safety
trained. The No-Action Alternative relies on migration of
contaminants primarily to surface water to achieve cleanup levels.
Although it is not possible to develop a time frame to achieve
cleanup levels without extensive contaminant transport modeling,
-39-
-------
it is estimated that it will take over 50 years to approach these
levels.
Potential short-term risks to workers during implementation of
pump and treat remedial alternatives would be from direct contact
and inhalation of organic vapors from contaminated ground water
resulting from piping leaks or accidental discharges and from air'
emissions from the air stripper. However, a vapor phase carbon
adsorption system would be provided to control the emissions so as
to meet the New York State air quality requirements. Exposure
risks such as these will be mitigated through proper health and
safety training and appropriate process controls. Other potential
short-term risks to on-site workers would include normal
construction hazards. The treatment plant would be fenced, and
access to this area would be restricted. Dust control measures
such as wind screens and water sprays would if necessary be used
to minimize fugitive dust resulting from excavation operations.
Minimal risk to the community from increased traffic during
construction and transportation of treatment residuals is
expected. No adverse impacts are expected from the discharge of
treated ground water to the drinking water supply.
Implementability.
Implementability addresses the ability to implement and operate
each alternative from design through construction and operation
and maintenance.
The only technical concern for the No Action alternative and the
limited action alternative is the implementation of a long-term
ground water monitoring program. Monitoring wells are already
present and new wells would be installed. The existing and
proposed new wells will be used to monitor any further spread of
contamination within the Site. The required technologies will
involve installation of new monitoring wells, collection of the
samples, analyses for contaminants of concern, and the evaluation
of the extent of contamination, which are all proven and reliable
activities.
The primary process steps of pumping and treating ground water at
the Kentucky Avenue Well and at treatment wells between
Westinghouse and the Kentucky Avenue Well (Pumping, collection,
filtration, air stripping, adsorption, and discharge) are used
extensively to treat water contaminated with organic and inorganic
contaminants. All components of these alternatives are well
developed, commercially available, and are not expected to incur
major technical problems which could lead to schedule delays. The
treated ground water would be expected to meet discharge
requirements and therefore, discharge to the existing drinking
water system should not pose any problems. Process residues would
have to be regenerated or disposed of in an approved off-site
facility. Land disposal requirements may apply.
-40-
-------
Proper operation and routine maintenance of the treatment plant
would be required to achieve treatment goals. During the
operation of the treatment system, effectiveness would be
monitored by periodic analysis of contaminant concentrations in
the treated ground water before discharge. Sufficient space,
approximately 0.5 acre, is available at the Site for construction
and operation of this alternative.
Pump and treat alternatives would require compliance with EPA,
U.S. Department of Transportation, and state regulations
regarding the transport and disposal of process residuals. Long-
term ground water monitoring would be required to measure the
performance of the treatment system. The pump and treat
alternatives would require a comprehensive management and
maintenance program to ensure the effectiveness of the treatment
and discharge system. In addition, discharge to the existing
drinking water system would require coordination with the Elmira
Water Board.
The alternatives that would require reinjection of treated ground
water would have to meet state and federal reinjection
requirements. Reinjection in general is more difficult to
implement than surface water discharge or public water
distribution and requires more operation and maintenance due to
well screen clogging.
*
COST
The cost evaluation of each alternative is based on the capital
cost (cost to construct), long-term monitoring, operation and
maintenance (O&M), and present worth costs. Table 48 presents
estimates of these cost for all alternatives evaluated.
For the alternatives evaluated, the costs ranged from $415,000 for
the "No Action" alternative to $40,613,900 for a complete aquifer
remediation program.
A comparison of capital costs and operation and maintenance costs
for air stripping versus carbon adsorption and UV-Ozone oxidation
indicates that for all of the ground water pumping alternatives,
air stripping was the least expensive treatment alternative.
For the discharge of treated ground water, discharge to surface
water was the least expensive discharge alternative evaluated.
State Acceptance.
The NYSDEC concurs with this interim remedial action at the
Kentucky Avenue Wellfield Site.
-41-
-------
Community Acceptance.
Community acceptance of the selected remedy was evaluated after
the public comment period had ended. Comments raised at the
public meeting and during the public comment period are summarized
in the attached Responsiveness Summary.
10. Selected Remedy
The interim remedial action selected for the Site, MOM 2-B and MOM
5-A, and the remedial objectives for the contaminated ground water
in the vicinity of the Kentucky Avenue Wellfield are as follows:
Restore the Kentucky Avenue Well as a public drinking water
supply well. If evaluation of the well condition indicates
that the well should be replaced, then the well will be
reconstructed in order that the Kentucky Avenue Well can
provide approximately 700 gpm of potable water.
Prevent further spread of contaminated ground water within the
Newtown Creek Aquifer with the installation of ground water
recovery wells between the Westinghouse Electric Corporation
facility and the Kentucky Avenue Well. The exact location and
pumping rates will be determined during the design stage. The
determination will be made after pump tests have been
conducted to verify the preliminary estimate that
approximately 140 gpm will be adequate to ensure an inward "
hydraulic gradient. If the ground water pumping rate at the
Westinghouse facility changes dramatically, the design pump
rate will be modified to ensure an inward gradient at the
capture wells. The interim remedial action may require
continuous pumping, and/or pulse pumping, and flexibility in
placing pumping wells in strategic locations during the
course of the interim remedial action.
« Construct two treatment plants; one located near the Kentucky
Avenue Well, and one located between the Westinghouse
facility and the Kentucky Avenue Well, which will treat all
the recovered ground water to Federal and New York State
Standards for public drinking water systems. The selected
treatment will include the following:
Filtration to remove any suspended solids with adsorbed
inorganic contamination.
Air Stripping to remove volatile organic contaminants.
Vapor Phase Carbon Adsorption to eliminate volatile organic
vapor emissions at the air stripper.
Discharge the treated ground water to the public water
supply. In addition, engineered provisions to allow for
testing reinjecting ground water to evaluate the
-42-
-------
feasibility of expanding the ground water remediation effort
will be provided for.
Conduct a limited investigation in order to determine if the
contamination detected at the Horseheads Automotive Junkyard
contributes to the contamination at the Kentucky Avenue
Wellfield.
Install a limited number of monitoring wells to monitor
contaminant migration and to evaluate effectiveness of the
interim remedial action. The location and specifications for
these monitoring wells will be determined during the design
phase.
EPA's Superfund Program uses EPA's Ground Water Protection
Strategy as guidance when determining the appropriate remediation
for contaminated ground water at CERCLA sites. The Ground Water
Protection Strategy establishes different degrees of protection
for ground waters based on their vulnerability, use, and value.
For the Newtown Creek /Aquifer, the final remediation goals will be
drinking water standards. However, EPA recognizes that the final
selected remedial action for the Newtown Creek Aquifer may not
achieve this goal because of the technical difficulties associated
with removing contaminants in ground water to ground water cleanup
levels. The monitoring results of this interim remedial action
will be evaluated carefully to determine the feasibility of
achieving this final goal. The interim remedial action may
require continuous pumping and/or pulse pumping, as well as
flexibility in placing pumping wells in strategic locations during
the implementation of the interim remedial action.
The ground water cleanup levels at the site are based primarily
upon the classification of the ground water as a potential
drinking water source. Therefore, the Maximum Contaminant Levels
promulgated under the Safe Drinking Water Act are relevant and
appropriate, and the non-zero Maximum Contaminant Level Goals and
New York State MCL's are relevant and appropriate for aquifer
remediation. Reaching the cleanup levels in the aquifer
upgradient of the Kentucky Avenue Well will not be possible until
effective source control measures are in place at the Westinghouse
Facility, and if appropriate, at the Horseheads Automotive
Junkyard.
The total capital cost of pumping the Kentucky Avenue Well, and
the recovery wells designed to prevent further migration of the
plume, filtration, a:lr stripping, carbon adsorption of emissions,
and discharge to the public water supply is $2,106,500.
The total annual operations and maintenance cost associated with
the selected remedial action is expected to be $905,300.
-43-
-------
The total present worth (1989 dollars) assuming a 5% discount for
over a thirty year period for the selected remedial action is
$14,963,900.
It is estimated that over the period of thirty years,
approximately 1.32 x 1010 gallons of ground water would be treated.
to drinking water standards. It is estimated that the treatment
of contaminated ground water will annually produce approximately
311 tons of sludge from the filtration system and approximately
5.6 tons of spent carbon from the air emissions treatment system.
Treatment wastes will be disposed of offsite, and Land Disposal
Restrictions may apply.
In addition, during the design stage a Stage I cultural resources
assessment, and a wetlands assessment will be conducted to ensure
that Site activities will not adversly impact these resources.
11.Statutory Determinations
The remedial action selected for implementation at the Site is
consistent with CERCLA, and the NCP. The selected remedy is
protective of human health and the environment. As an interim
remedy the selected remedy attains location specific, and action
specific ARARs, and will attain chemical specific ARARs at the
tap. Chemical specific ARARs will not be attained within 50 years
for the portion of the aquifer beyond the radius of the pumping
wells, and it is estimated that once source control is in place .
the selected remedial action will attain ARARs in approximately 30
years.
Protection of Human Health and the Environment.
Once an effective filtration and air stripping system for ground
water treatment, and carbon absorption of air emissions, and
connection of all private residences to the public water supply is
completed, the estimated risk to human health from consumption of
ground water will be less than 10"6. The implementation of this
remedy will not pose any unacceptable short-term risks.
The risk posed by direct contact to sediments in the industrial
outfall drainageway used by the Westinghouse Electric Corporation
will not be remedied until either the sediments are removed or the
exposure pathway is halted. The elevated levels of inorganics in
the drainageway may be the result of the permitted discharge at
the Westinghouse facility. The results of further investigation
of this drainageway may indicate that action pursuant to ether
federal and state authorities is necessary.
Compliance vith Applicable or Relevant and Appropriate
Requirements.
-44-
-------
This remedy will provide a source of drinking water that meets or
attains all applicable or relevant and appropriate Federal and
State requirements at the tap that apply to the Site. The
selected remedy will meet or attain all ARARs for the portion of
the aquifer in the vicinity of the Kentucky Avenue Well; to the
extent of the pumping wells after source control is in place in an
estimated time frame of approximately 30 years. Beyond the
hydraulic influence of the pumping wells, the remedy will not meet
all contaminant specific ARARS within a 50 year period after
source controls are in place. ARARs for the selected interim
remedial action for the Site are included in Table 47.
Cost-Effectiveness.
Each of the alternatives underwent a detailed cost analysis to
develop costs to the accuracy of -30 to + 50 percent. In that
analysis, capital and operation and maintenance costs have been
estimated and used to develop present worth costs. In the present
worth analysis, annual costs were calculated for thirty years
(estimated life of an alternative) using a five percent interest
rate factor and they were based on 1990 costs.
Of those remedial alternatives that are protective and attain
ARARs, and satisfy the preference for treatment to the maximum
extent practicable, EPA selected an interim remedy that is cost-
effective in mitigating the risks posed by the ground water wihin
a reasonable period of time. Overall, the total cost (present
worth) of the selected remedy is estimated at $14,963,000.
This cost is higher than that of some of the other alternatives;
however, none of the less expensive alternatives can ensure that
the treated ground water will reach the target cleanup levels.
Additionally EPA has determined that this remedy will yield
results that are in proportion to its cost in terms of
effectiveness. Thus, while other alternatives evaluated are
cheaper than the selected alternative, they do not provide the
same degree of effectiveness.
The cost of the selected remedial action is lower than that of
some of the other alternatives; however, implementation of the
more expensive alternatives are not cost effective until after the
reduction of contamination is observed and shown to be effective.
When source control measures are effectively in place they will be
reevaluated.
Utilization of Permanent Solutions and Alternative Treatment (or
resource recovery) Technologies to the Maximum Extent Practicable
(MEP).
The selected remedy utilizes permanent solutions and alternative
treatment technologies or resource recovery technologies to the
maximum extent practicable.
-45-
-------
The ground water extraction/treatment system provides permanent
removal and reduction of the mass of volatile organic contaminants
in ground water through ground water recovery and treatment via
air stripping and carbon adsorption. Carbon columns will remove
contaminants from the airstream before being released to the
atmosphere. Treated ground water will be discharged in compliance
with limitations required by ARARs. Figure 12 is a schematic of
the treatment systems to be employed.
Preference for Treatment as a Principal Element,
The preference for treatment as a principal element is satisfied
since treatment of the principal threat (the ground water) will be
conducted. The treatment systems will include filtration to
remove any suspended solids with adsorbed inorganic contamination,
air stripping to remove volatile organic contaminants, and vapor
phase carbon adsorption to eliminate volatile organic vapor
emissions at the air stripper.
12.Documentation of Significant Changes
There have been no significant changes in the selected interim
remedy from the interim remedy described in the Proposed Plan.
-46-
-------
APPENDIX 1
-------
Table 1
cf Cherieali Detects in
6roun*rtt»r Sit Its fer the temuckj Well Avenue Site
(All concentration! In wg/1)
Cheffiul
ea-be*.ttetr§:r.loride
th/ierkc cnionde
Inorganics :
berlai
b«'»' liji
calciir,
copper
irer.
a-*Iei'i»
M^'t^ese
nc't '
pc t a > 1 1 m
IK ^'f
,(-j; ; jr.
Zinc
Frequency cf
Detection (a)
2/4
1/4
1/4
4/4
1/4
4/4
2/4
2/4
1/4
4/4
2/4
1/4
4/4
4/4
1/4
3/4
Mean
Concentration (b)
3.3
5.4
2.7
145.1
MR
103.000
13
51
2.8
20.700
20
NR
2.6CO
30.300
NR
IS
Detected
Concentration..
^
5.0 J
7.0 J
3.0 J
174.0
1.3
lll.OOC.O
16.0
121.0
4.2
22.300.0
231.0
IS. 3
2,795.0
6£.20:.0
1' 0
22 X
kstes:
K! T*» ;ex«fi: ne«- *» n:t rewtei (W). as t^it estimated concer.tratior. *> grta'.e* than the
bc.tr.t: rii-.rvr je^*.j« sne-raM c' the detection lim-.ts tre ustd in cilculatin; the near..
(i) The "..roe- e' sa^ nc: oetectttf at a Selection liir.it at leas: t»c tiwt
j-ii-.e- :-^- *.** "Miir..r oe:e::ec csnceitration *e^e not include! in ettinatin;
we- i"ie".-a: -s^i.
Sa.--: le» :
6t-i. 5.'-!, &»'' (5e» -'se-.t ia1
-------
Table 2
Stma-y of Chemicals Detected In
er at the Kentucky A»enut Wellfield Site
(A11 concentrations in ug/1)
Chemical
Frequency of
Detection (a)
Geometric
Mean
Concentration (b)
Maximum
Detected
Concentration
Organic*:
1.1.1-tricMoroethene
2-butanone
acetsne
bis[Z-et\vlheryl]phtha1ate
Ch icref 8*TT
etr.ylene chloride
toluene
total xylenes
t r ic K I eroe t he ne
vinyl cr.lonoe
Inc'genics:
alir-.nx.
ar.fix-.y
arse* ~c
tt-iir
be-. ' 'iir.
C1X ' «T
Call'lT?.
t^~^'.\r (tete^)
C*,ry.lf [v.j
csbi It
t;j5f-
irc-
lee:
we -f! iur"
iw-.;eieje
ne'i'^'f
nicie"
p:'.£SJ iur
sac -tr
t v ' ' -sr
Vl'.tCllT
I in:
Nctes:
e/45
2/19
10/45
9/35
7/45
11/4S
1/45
3/45
1 7 / J C
17/45
34/45
4/45
46/47
6/47
24/36
45/47
25/47
4/47
47/47
45/46
1/12
31/47
35/40
31/31
40/44
46/47
47/47
7/47
40/47
41/47
42/42
1/47
34/47
41/42
2.2
NR
8.0
5.6
1.6
2.3
2.6
3.1
3«
.3
11.7
1.2
8.335
354
9.6
360
13.6
3.0
162. 951
212
3.7
33.5
76.7
20.000
20.9
37.076
957
C.I
IDS. 4
4.951
56.660
5.1
37.7
136.4
$4
4
2.200
20
9
4
4
46
1 9
12
121
2
261.000
666
55
2.690
13.1
270
1.62C.ODO
45. IOC
267
243
654
E54.0CO
321
557.000
21.300
1
6.660
2.470.000
433.000
6.5
36S
2.64D
«R The jwie'.-ic ne«* «s nc-t reacted (NR), is this est imeted concentration «as greater than the
oe:e:*.e: iws-.r,.r ae:«.'se one-half of the bete:tion lim-.ts ttrt used in calculating the mean.
(a) Tne nxie- c' te-nc'ies in w^.ish the contasinant «»s detected divided by the total nu*er of
' '
It! »"-aie-.e::trr se. lex «*-t »et tc one-half the detection 1iir.it for calculating g-eorwtric weans.
»''$: s»^'ies ir ' :' tne se-.tar-'n«-.t was net detected at a detection 1ir.it at least twc times
S'ef.t- -."A- .** MumcT of.*:tec concentration »ere not included in estimating geometric
WST. concentrations.
Sables
fiouic1 1
*
Ct-
Kt-
Kt
Ct-
CV-< U
:; (fe.
- i (5.-Z-,, C.-:i: 13.-24J. C.-ISD (C.-25), tt-£S (6V-26)
-s: (6w-27i. Ck'-12S (6»-26). Ck'-lZD (Ck-29)
-.ev Si-^lms Rejnd
Cv-W.. C.-15. PS-4:. PS-SC. W-02. WW-04. WW-CS. W-OE. Wtf-07.
-------
Table 3
SiHHART OF DISSOLVED 1NOR&AN1CS DETECTED IK WOUND WATER
AT TKi KEKTltKT AVENUE KUflELD SITE
(All concentfit ions in ug/1)
Chirr, ic*l
Itrinun
cilciift
chrBT.iifti
iron
wpesiin.
ungenese
nickel
pcttssiur.
teiiir.
zinc
Frepueney ef
Detection (t
1/11
10/11
1/11
1/11
10/11
3/11
1/11
2/11
11/11
10/11
Concent nt ion
Range
2.980
52.200 - 128.000
439
119
9.170
S3
S.300
48.300
27.9
2E.700
204
97
2.700.000
214.000
46.1
KJT£>«- ef urcles 1r. which che-icti «»» detecltd divided by
the tottl njrs^er of t»a?lei tntlyzed.
i: CV'-ISSH. CW-7sri.
PS-4:rj. PS-SSFl. W
-------
Tn!,|e
Cround Water AnalyseB f->. Wcstlngliotise Electric Corporation
SIIMM/VRY OF PHASE II WATER ANALYSES
PRIORITY POLLUTANT VOLAllll. ACID-I XIRACTAIILt. AND I1ASE/NIUTRAL ORGANIC COMPOUNDS1
.ocatlon Chloroform hlorometltam
,,:-ls
.w-is(Dup)
r-io
«-2s
rf-20
*'-3S
^-30
,1-4
J-5S
.'50
.' 5(l)3
-'6(1 1)3
.' 7S
'-70
! JS
'-30
'S
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
BMRL
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
15
NO
NO
NO
20
NO
Mpthylfne
f Chloride 1,1,
9<13)?
** 1 \ J I
Q f 1 1\
n(i?)*
10(1?)*
9(1?)*
24(16)*
20(16)*
10(1?)*
11(12)*
29
18(1?)*
24(16)*
20(16)*
19(16)*
13(1?)*
18(12)*
1-Trlchlorop thflne TrlchlorocthyTene
5
6
NO
NO
NO
NO
NO
BMRL
NO
NO
5
BMRL
BMRL
BMRL
BMRL
NO
BMRL
11
11
NO
NO
NO
NO
NO
NO
NO
NO
10
8
20
NO
62
140
210
81s(2-ethy1hexyl)
2-Chlorophenol phthatate DI-M-Buty' phthr.late
NO
ND
ND
14
ND
ND
ND
ND
NO
NO
BMRL
NO
ND
NO
ND
NO
NO
86
ND
74
NA
NA
NA
NA
NA
NA
NA
NO
NO
NO
NO
NO
NO
NO
N0(58)*
13(58)*
30(58)*
NA
NA
NA
NA
NA
NA
NA
NO(BMRL)*
N0(58)*
ND
N0(58)*
N0(58)*
11(58)*
N0(58)*
footnotes at end of table.
(Continued)
-------
Tnhlc A cnntd.
B1s(2-ethylhexyl)
Methylpnc _ ,_,_.., .*,..! 9 rhinmnhonol nhthalate 01-N-Butyl phthaj'
location Chloroform .Ihloroiwthane
MM-9S(l)np) Nf NO
MW-90 Nl NO
MW-IO(I)3 Ml? ND
MM-10(I:)3
MM-H(l)3
MW-11(!1)3
OM-1
SW-5
SM-6
SW-7
Raller-P-econ
Rlnsate Blank
Trip Blank4
Trip Blank3
fr'.p Blank6
Trip Blank7
T,-1p Blank8
T.-ip Blank9
Tr»p Blank10
.,..,11
Nil
NO
UP)
Nl
N?.
NO
NO
NO
NO
NO
NO
ND
ND
ND
ND
nu
NO
ND
NO
ND
NO
ND
ND
NO
NO
ND
NO
ND
NO
Chloride l^i,!
?0(12)2
lb(13)2
10
lJ\,if)
10
15(1?)2
7(7)2
9(I3)2
23(16)2
7(NO)2
16(7)2
?6(16)2
10(16)
20(12)2
17(13)2
9(13)2
18(13)2
13(7)2
-Iricnioroemane i
7
OMRL
BM«L
HMHL
BMHL
NO
BMRL
un
BMRL
ND
ND
BMRL
NO
BMRL
NO
ND
200
300
51
430
210
14
NO
13
14
45
NO
ND
ND
ND
ND
ND
NO
NO
5
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
ND
NO
NO
ND
NO
ND
NO
NO
1BO
ND
177
NO
BMRL
NO
11(54)2
ND
NO
250(54)*
NA
NA
NA
NA
NA
NA
NA
NA
14(bB)2
N0(59)2
ND(2Z)2
17(!9)2
NJ
BMRLf58)2
HI
64( 9)2
N0('..3)2
n
NA
. NA
r\
. r*
IK
IIA
I.A
NA
(Continued)
-------
Table 4 contd.
<..»,...., reported In )g/l.
Z( ) - Concentration In laboratory QC blank; QC concentration not shown If NO.
, 3(I) and (II) refer to Phase I and II sampling events.
^Shipped with samples from SW-6, MW-75. and MW-70.
Shipped with samples from MW-PS, 20, 3S. 30, 5S. 50, 8S, 9S. and 9S(Oup).
^Shipped with samples from MW-4. 6, and 10.
7Sh1pped with samples from MW-BD, 90, and 11.
8Sh1pped with samples from SW-5.
9Sh1pped with samples from MW-1S. IS(Oup). and 10.
10Sh1pped with sanules from SW-7. OW-1. and baller-decon rlnsate blank.
U50 FR 4GBBO (Nov, 13, 1985), Safe Drinking Mater Act.
NA * Not analyzed.
NO * Not detected at minimum reporting level.
OMRL = Present but below minimum reporting level.
-------
Table 5 Ground Water Analyses
RESULTS OF TR1CELOROETHYLENE ANALYSES
Facet Enterprises, Inc.
Concentration (yg/L)
Well
Kunber 5/25-26/831
U-2 2.0
C-l 230
D-2 800
D-3 2.0
D-4 12
D-5
D-6
D-7
D-8
Process
Veil 1
Process
Veil 3
Municipal
Supply 8.2
Sample Date
7/11/832
0.1
240, 2183
515
0.5
17
25.
7.8
7/2S/832
__
210
18.7
127
41.6
__
_r
.-
lGC-y.S, Method 624
2GC, Method 601
3Duplicate samples
-------
U.J UJ L. I I. I I
I I I
I I I ' I ' I I » I I I t I * I .
CYANIDE
ASBESTOS
Table 5 contd.
nnoiiMOVATm nrvn T
Wfc - not
S
-------
T.-iMo 3 ron Id.
ANAIVUCAI GRnuNnwAfrn nrMii TS-
MUT rMimrniM.% i)tr«tlon« S;-? In ppb (wj/1).
Source:
1l«it.
-------
Table 6. Ground Wate
SUMMAHV OF ANAtYffCAl _
l.P.C. CltCIRONICS. INC.
- ORGANIC!
C>= wound! : M9H4)
'. Ptrtitnr
I . ' , l-t rirttlni
Ir chlori el lienr
ID:
Ch I orowH hnnr
Me-'hylenf (Mori 4*
Ir < cl'lnrnfltior omethan*
1 . 1-nirMororlh.in*
1 . 1 . 1-1 rich!th«f«*
Tr tch'oroi»thrn(
Carbon T«>tr»r.h1orl(l«
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
2
2B/-W
14
6
I
3
4
27
I
1
10
58
n
24/38
55
19
6
6
109
4
17
234
; Compound Not 0*t»Ci I'd.
NA: Compound Not An»1y;'*d.
" More thm on* v«lu«> vndlcatet »«cood tawple collided In that saw* year.
_'ont»ntr»t lont «r» In ffk (2 UO/1).
iourc*: twp'r* Soli In »ttlq«tlont (19B*-19W1> ;
<
-------
^ I I I
<=
Table 6 contH.
5WW» or .H^KJi -"SKI'S1.1' * '"""^
;r£^i-"*'»""-m .._"»='»"»
41
20
4
41
100
2.5
470
42
2.7
470
<2
30
370
500
70
250
350
5
<10
<50
35
I'M)
inn
3.0
70
tn
1.7
470
6
10
470
4100
_
-
< 5
410
450
7.1
no
ft
/ n
2.3
<70
2
10
110
200
37
370
570
5
1
50
70
1/0
250
n.t
30
95
1.5
470
11
10
470
100
-
-
-
70
4 10
50
60
30
61
1.3
470
5.B
410
470
4100
20
100
200
20
57
170
15
60
200
1
470
in
2.3
470
2
20
60
300
20
90
250
« 5
410
50
4 5
60
100
< 5
10
<50
ChriMtMl
Lf.d
S««rc.:
-------
Table 7
: sou CDN:EKTMTIO« FOR IHDS&ANJC CHSKICAIS
FOR TK- KIKTUCKt AVEKUE WEUFJELD SITE
u;
it:
(.-:
(*;
Chwlcal
Alir.inuti
Ar,: imony
Ar»emc
lariuw
Be ry 1 1 1 tfB
C49?-i ^^
C* Icii/f
Chrorr inn
Cobalt
Copper
Ircr,
Ued
Kf.ctiest
He'iyry
fc ijitg '
F : 1 1 s s i itr.
Se Ic* itfti
Silver
Ssiurf
TrJ'h'ir
Ve'.sSiiff1.
2lnc
£{»e: c» »k*^»:e Jt
()' r-,'ie$ V c' sitt
To-v^.ns (3: ir.'les
T-s;t (<2 r-:ies S«)
e-: S:|-.«:i1e:te J9£
C.V.ivf.e: .£ ui:«
L-.S. Cs^s* »n: Sh
l~.:.l:-.v»te: E Hi-;
Sv^lette 1S7J).
Re;ion»1 Range
of Background
Concentrations (ng/kg) (t)
70.000
<150 500 (b)
7.2 - 16
300
1 - 1.5
«1 1 (b)
600 » 3.500
30
7 - 15
15 20
15.000 - 30,000
15 - 30
3.000 - 7.000
300 - 1.500
0.03 - 0.37
10 - 30
12.100 - 21.000
0.3 - 0.6
<0.5 - 3 (c)
3.000 - 7.000
C.C2 - 2.6 (d)
5C - 70
75 - C5
11 d**.e C8lie::ei 1r. Sttuben
), Tis;« (J£ ir.Hej $J) «nc '
N;) Cojr.ties. *e» Ycrk ani
County. Ptnr.sylvinja (Boerngen
« A
y
Ifivated E hi-iion - Eastern
aci lette 1S?£) .
xsr.-flijjouri (Connor and
S.-'«:e Sells of the U.S. («UMt«-Penii«» and
Fer.;-,is 1SW).
-------
Table 8
BA:*SRDUN: SOIL CONCENTRATIONS or TARGET COMPOUND LIST
PO.YCYCLIC ARCTIC HYDROCARBONS (PAHS)
Concent rit ion (ug/kg)
Rurjl Soil Agricultural Soil
Ci-cinojenc PAH
Beri2c(t)»nthri;ene 5-20 56 - 110
6er.zc-(b)?lucr»nihene 20-30 56 - 220
Benze{j)fluor«nth*ne
6*-zc(t>-j)f luo-«nthene 25 - 110
6*r,zs(kK^ucr»nthene 10 - 110 56 - 250
6er,«(i)pyrene 2 - 1.300 4.6 - 900
Cnrysene 36.3 76 - 120
Ir,oene1!:.2.3-cc pyrene) 10 - 15 63 100
»s..:,.:,nsB,.,s PA-
A;e-.J5V.!%e»)e 1.7 6
Acen»;rthylene 5
A':r.T«:ene 11 - 13
6*nz:'5. ^. ^ Jpe'ylene 10 - 70 66
£«.«;« )pyene 53 - 130
fiipf^yl 14.6
r-,jDr«r,:n«ne 0.3 - 75 120 - 210
Fluorene 9.7
fc» pr.t*v 1ene 46.2
Pe-ylene 14 - 16
Pner-jv.hr.ne 30.0 46 - 140
Pyene 0.1 - 64 99 - 150
UrbJn Soil
169 - 59.000
15,000 62.000
6.000 - 97.000
300 -26.000
165 - 22.000
251 - 64.000
6.000 - 61. 000
90C - 47. ODD
60 - 14.000
200 - 166.000
100 - 4,800
3.000 - 147.000
Sou-ces :
(1S77)
tf-.-.'.t in: V«nde-|lici (I960)
V-nssr- «nc *"te» (157$:
st 119*:}
os (J9E3i
E.-.le- c- '.. <19W;
v»r. «-. ' (1%5S',
e: «1. (19ES)
-------
Table 9
y of Crtemcilt Detected in Surftce Seil «t the
Kentucky Arenwt Vellftelfl
Are*: Artl-2
(All eencentritions in «6/ks)
Che*.ice1
Orjamcs:
' t ii r2-et*>»1p*ry1)prith* lite
b.". 1 b*"}»l pfitfuiite
c* Ic-c'cT'
Cei"
C'-n-octj! phthalite
»:**-.
P:E
Jrc-pir: iei:
llirmilf
l-JflC
be-nr
b* »''; i irr
ClX'ir
c< "T '.\f
C -gr jr.
e::j ';
c:r?e*
'£
l(j;
w~*e$ i.1"
BB " " t *>t S t
«:.<
r. \cu *
pet « ££i."
ft '«- ur
$ : ' ' j~
lr,t' ' ;j~
»««: ,j.~
;-,:
f r»pwtn:y of
Detection ()
3/3
1/3
1/3
3/3
3/3
1/3
3/3
3/3
3/3
3/3
1/1
3/3
3/3
3/3
I/]
3/3
2/2
3/3
3/3
2/3
3/3
3/3
3/3
3/3
1/3
3/3
3/3
fieonetrtc Mem
Concentration (b]
0.13
0.17
MR
0.87
NR
2.1
0.24
7.S20
16
82
1
1.6
40.90C
15
7.7
N:
17.60C
17
9.360
36}
0.1
IS
S70
2
2J4
1.5
16
116
lUHiu* Detected
Co ret r, trail on
0.275
0.17
0.001
1
0.074
24
0.34
9.930
123
119
1.4
1.6
77.700
20
64
176
IS. 00
2?
17.000
620
0.3
24
eci
25
eis
34
26
166
Tv :e^r«:--,: nee- us nst rtx'tri (W.J. <> trii con:e«trit (or MI f-eite* th§« the
oe-.K'.e: ffidi .- w:i.»« orie-wH ef the oetect>0f. llinti we u»»c in uleultting
tf» }e:ne:M: near.
ir. **.ieh the cor:t*wift«flt MS o>trrtetf tfivldetf by the tc:«1
(tl »:--3«:fr::e^ $»Tp''ej *«'« »*t tc o^e-h*1f the deter! lor. Hir.1t for eiletliting ^afletric «e»ni.
*'s: »*.-C'es ir, wif tn* co-ttriM . v«t net oe:ectec«t » aetestior. 1iir.1t it leu: t»e tines
f-tf.r' TV t*» (wrirur aetectef eonteitrjt
-------
Table 10
-j cf Ch»rici1s Detected 1ft Subswf*ce Soil «t the
. -2
(All concent ret ions In ap/kg)
Cher.icil
freoi/eney ef
Detection (t)
fiesnetrje Mttn
Concentration (fc)
fUrfoir Detected
Concent ret ion
ecetont
l phtfulite
tc:*1
tMch
Inorginici:
1/U
e/i?
1/12
1/12
4/12
4/12
1/12
1/12
1/12
kctcs:
0.01
0.21
O.OC3
«K
MR
2.5
D.DODE
O.OC3
C.003
'--: ne«-
(t!
(t) k:--st:t::tl
Ai$: '
re:
ir.
(«). * t»cter divlfleJ by the tetil
the detection He.it for c*1eu1it
-------
Table U
-y of &ivc«U Detect** 1n turftet Soil : the
ttntutty Avr-u
AMI: ArwJ
(Alt ccrccntritienc in
et«:
».i ~, W th.U conctc.tntfor, MM g-^Mttr than t**t
oe-.f-'.r: CBJ tj- be-:»jn or»-h»lf ef tht dt'.rctfer, lii-itt w*rt jiitf in
the i»^ « : ' i c e*.*..
(i) TSt -xx»- e' MIX In fr yf.id-, the urtia'^-.t wu dc.Ktad tfivitetf br tNt totil ru^tr ef
(t) kvx'.^te*^ t-iep'.et v*-t »*: tc ene-h»'.< the d*'»ctior t(«!t fp- e
iitc, taoc-c* ir. *-. ic1 tKe ur'.ie:r»-.t M*( nc; Oc.c<:«c ». a dt:»ctior lic-t : leist two tiatt
fe«:c '.-*. t.'e u.: ax oe'.cctetf unc.«r:r«-.ior. wtrt net inciuoec ir. c*:iHt
r i:\art,
k'^c»-:\ri>;e'.fc PAXt.
CP*.r L**
;et: tt-6, 7, I, 9, 10, 11. «ntf 12.
-------
Table 12
of C^vicilt &et*ctetf in Sufecjrfftct leil *t the
t«r,tucky Awrue Wtllfittfi
Art*: Art»-3
(All twxtfltratiens in
D.e.ic.1
acetone
alc-ir,
fattt-SKC
fcii Ic- ethyl ht*y 13 prith» late
2*b-"»-^i*
fa.tr: be-uyl pfcth«late
chie*s6f £«"*
efcie-oforc
CPAk
607
1,2'tf''c.ki!s*o«t^.e^*
ovi-r--&.ty ;pr t'.i :atc
e'i-ri-oety.prtha.ate
eroci.-lf*-. 1
enee-twita- 11
e*Ccj. '.?» *»'.fite
et.k> '.Sf.it'it
jjrr~ a- y.c
hej: »cr . ;e
Bt'rifw cMo'ide
< M t'.ytDTiC^Cl
!"*
PQ
tciuw
te'.t. rylfnet
fir*'.f9*:^f-ie
rirr,; er'te"iO*
»: ^ ' r*r
?»e-.'. e
bi* ' JT
be -y '. i i tr.
e*3- .r
e»:rijr
O-.-3-.'lJt
| ^f ; »
tocoe-
irtr
IcK
^j-»J, ( thil twx«^tr«t?0^. Mf 8"»»t«r th»* the
oc.K'.fC rji'ixr St-.tA* v*-h«lf ef the deivctiori tiriti were Mtt in etlculatine
the
?>e i_rt>f e' ifc-c'.et tr, w^ieh the cor.;ar!r»a-.t »ei cw'.etf bf the tot»l rxrt*' ef
Ct; ky-aerKtec' isrp:« **** »*r te one-h*1' the e»*.«tior lir't fn- ca'.cu'.itins je-snefi:
«.»:, vh-c.« ir. i^-.i^ the ty.:tr>*-.: «« ix-. .*.*::»: .: * o*>(t:tiert iiri: a:
ce»-.e' '^i- the r**;nx o«:*:te< esnter.'.rjtio^. »tr* net inei^iec' ir. ettiirefiris
-------
If CS
aictU Cfctwrtt* fn hrfact tefl «t the
trMueky Avet* Wcllfiitd
Artt: Art»-4
(All conctr,tr«tior» in B6/kj>
Diem'cit
fci»;< -ethyl hucyOpfcthalatt
IKPAK
Ine.r'^
ar»e*iie
Bft'iut
B»-yl t iur,
fc»!S JIT
e^'crr.iui
cobt'.t
toco*"
Ircx-.
l**J
!;"*( iur,
w^i"*i e
rc'Ctt .
ecttiiiir.
t X ' if
yr%»ci Jf.
line
:tet:
Mt t T'.e 5^y«:^c r*«- WK ret
w:^:1:^ rei 'nj- £*<»jse Of
t^« J^3».ri£ Mir,.
(i) >e -xrn- c' i»-c;« ,
whilf ef the
ef * C*a»trfc MMH
(I) Cone nit rat ion (t)
o.r
K
10,520
7.4
76
0.9
13,480
»3.9
9.8
26
23,900
14
4,600
746
22.6
40
UK
17
89
w thil e ore irtri! for M;
dctKtior, lisiti -«"» t»ttf
iitf. the cor,:»ff'-«-;r MI detectttf div!d*tf
NizfKJi D*t»et«d
Concentration
0.75
1.4
15,800
11
M
1.3
77,800
22
U.3
32
34,000
16
12,400
975
S3
1,210
92
26
121
6n*t*r than th»
In calculating
by the tettl njab»- ef
wt*e »c. tt or»-hi!f the dcttctlor. lii!t for c
».j: tare ei ir «»:£' the tor, :«-'*-,: w«( nc: bctctec *. i d*:e«tior. Ijt't ! (tit:
f-ei'.«- . -t- ft rai B_T »'.«-;.« eorctr.tr*'. (or. «t~t ne: ine!uo»i In tctiatting p» MTT ir
et- tsnc^.trttion*.
ie >A.H».
A't*
IH: JE-1J, 14. v^ 15.
-------
Table U
-y of C0tr.it* 11 ^ttctce ir. Wxu-f»et KeU *t the
(ntjcky Av**ur Weltfteld
Ar««: Arei-4
(AM carcvntrat tent 1/13
n-cke'. 13/13
pCtdtilB 9/13
t'.e'.ijt 1/12
tsc-iir 11/13
₯«::« 13/13
xire 13/13
*-
Ci 'rtc Htan
Concentration (b)
O.U
0.2
0.002
7.4
Vt
0.009
2.9
n
0.004
8,696
5.6
61
0.8
0.4
60,800
13
8.3
10
20,200
13
14,400
532
0
19
45
0.4
18£
14
91
lUxfK* Detoctod
. Concentration
56
0.89
0.005
8.7
0.085
0.46
9.3
0.001
0.06*
11,260
14
6
1.2
o.e
»9,500
21
12
79
22,000
64
57,700
722
0.3
26
1,120
2
1,000
22
110
otn:
VK Tf* $«-a-«'.-i: eei- n* ne: r*ec-t«< CM), M thii ce«x*^,trit?or. Mt s-*»tf th»r, the
6t:*::r-. aej 'or s*-:»jst ent-half ef tK* dcectier lifitt wt't u»wi in
the j«-aa;r ie »»-..
in ^,ic^i the cor/.K!r»t: MAI d»t«t»d tfiv(3«tf by tht tet«l
(b) fc3--»:»-rtf^ t*x- « «**t Mr ft er«-K»'.f tKe d
Ait:. ««es.e« ^ ie- t*« isr.'.«c;r«",t ( ne: dc.Ktttf : *:»ctior t
-------
Table 15
tir»-y ef Ch«M'c»li Detected fn Surface toil at the
Kentucky Avwx* Wetlfitlfl
Arti: Ar*» 15
(All concentration* in «B/kj)
DMiMl
"Z"'
di-n-ocry! pMhalate
t«-Tvl«:
CFAh
Inorganics:
IiRirxa
r»»>r, ic
Be i i/r.
be~yl 1 > jz
eeoriur
ca ; c i ur.
Ch'ori ji
cecxit
eepoer
ircr,
le»tf
e»7i«j iu^
a*-*>9(iese
mt'c.,"Y
nicte;
pcttttiir,
eler.ihr.
a i 1 ve
aoc^ j"
V>"i*C ll/t
line
Mete«:
IK The eeomv;: B»I- MS net M
Tracwency
Detection
5/3
1/3
1/3
5/3
4/4
4/4
4/4
4/4
1/4
4/4
4/4
4/4
2/2
4/4
4/4
4/4
4/4
2/4
4/4
4/4
1/3
1/4
2/4
4/4
4/4
wtrf (Kf>,
ef teenrtrt'e Mean
(a) Concentration (b)
0.91
NX
0.005
1.9
9,830
7.6
60
0.8
0.5
44.900
14
s.r
SC.3
23.315
u
9 90?
'577
0.1
23
766
0.4
0.6
Kit
13
113
( thii e one f.tM tier \ni
K&rfau> Detected
Concentration
1.1
0.02
0.0095
2.4
11,400
9.4
111
1.2
1.1
$4,500
ie
9.2
53
25,600
20
11, TOO
763
0.3
24
1,150
C.J
51
19
153
f-eeter than the
0>:e:tec rn rur
the
Caj The -xrw- e' »rrp:« in *.ich the tor.tarrinair MI detected di*-id»C by the teta!
cf
(t) tty-dt'.K'.fi *«rc>» **'« «e: te one-hilf th* drtecrfer d>it fe^ calewlaMi
Al»r, t«nc e-s > ifitr. the earrari'»ait we» net *r«r»tf at « *:ectio- H«:t at leatt twc limt
fi-nte- t*.i- ff ra»;ffwr wre::»< rr*:r*,v»r;er ««-i nc; irciuO»c ir, «t
-------
Table 16
of Chericili Detected 1r. Subsurface Soil at the
ter'.jctv Arenut Ytllfield
Arn . Art»-15
(All concentrations tn
Frequency ef Geometric tein Haii** Detected
Detection (a) Concentration (t) Concentration
cetene 1/11 0.008 0.5
t-.s[2-et\v1hery1]phthilate 4/11 0.18 2.9
eMe-cfonr. 1/11 0.003 0.004
CPAh 1/11 NR 0.6
C'-f.-Kty1: phthjlfte S/ll NR C.OS
her:«:Msr epsxioe 1/11 0.004 0.006
»:f*- 1/11 NR 2.28
3/11 0.003 0.01
ilir-iniir.
»-»*-,:
U-'.ir
be-»lliar,
UVf
et ": -.j-
t'.rsr-.X1
CDt< >.
CSO?f
1rtr
lei:
^pesi>r
u-.:e-ese
r.iwe'
DC'.eSSMT.
tt'lf -,X.
I'.lv«-
IX'..-
tn*".-.;r
»«^:.ir.
nx
15/15
15/15
15/15
14/15
3/15 .
15/15
15/1£
15/15
6/6
15/15
15/15
15/15
15/15
15/15
15/15
4/11
3/15
9/15
1/15
15/1 £
15/15
S.470
S.5
12
0.7
0.5
47.200
15
e.7
21
20.600
S.7
10.630
43E
23
S51
0.4
0.8
195
NR
14
77
20.400
16
253
1.2
1.1
93.400
30
17
30
36,9::
17
22.90:
949
33
3.450
0.5
0.9
455
0.3
3E
131
kc'.es:
I?. The ;w**.-i: MS- »t$ nil repe-tttf (*R). w t^i conn*,tr«t 1o-. MS gruter thif. the
de'.t.-'.e: ut-.rxr e>e:t^te cnt-ralf of the Oe'.r::io- lir-tj *t~t use: in ctlculttin;
t">t jt
; The r.j-ct- r' »a-c1*J U *t-^ch th* co--.er.1r4r/. MI cfe'-ectt£ divided by the tot»l nicbtr of
'
(fc) te--o«:e:*.t:' u.a'tt »t-t »tt te sv-hilf the be'.ectlon HiU for cilculitlnj g»3»trle mi.
A'isc. vt-rle tr. ^>c^ t"n cort*ff intr*. «i» net Of.tt\*l t". t tfetestior. IteU tt IMS', two tt«
{«:«- *.v tV Ki-r^r 5f.e:-.t: con:tr.:r«fior, »«r» net incluoti In ts'.JMtinc, geonctric
mi' tfcr.ce-.-.rit^o^.s
1! S«3C>es: SC-17. 18. t«! 23.
-------
Table 17
of Cr*r.icali Detect*^ 1n Surface Soil at the
Kentucky Avenue * Wield
Arta: Area-17
(All concentrationi in IB/kg)
Chwr.ical
Organic*:
tit [2-ethylhe»y1]prith« late
Ci-n-6i.-tylpf.tn* late
Ci-n-octyl pntnalate
Incrganici:
eltfrtnun
a*»enic
ba- tuff
b*"y1 1 ii*»
caX'.ium
ca lc lurr.
c*.-ar.iurr.
estalt
CJJJtr
i-e".
le«:
w : ie 1 1 UP.
wjjigse
r, -.cie'
pc : * > s i urt
j-; -. ji
v<*-arijB
ri:
Detection (a)
4/6
1/6
1/6
4/6
6/6
6/6
6/6
2/6
6/6
6/6
6/6
1/1
6/6
6/6
6/6
6/6
6/6
6/6
5/6
6/6
i/6
fie-avtrie Mean
Concentration (b)
0.16
KB
MR
S.930
4.6
56
0.9
0.6
49.700
11
6.9
NC
le.ooo
n
12.900
547
19
5*7
NC
12
81
Maxima Detected
Concentration
0.74
0.13
0.062
7.240
63
227
1.3
1.2
lie. ooo
is
14
22
27.900
25
26.600
1.020
26
1.390
107
120
'V eey«:'i: *« wn no: rex'tttf (KR). n thii eonstitnt'er. uti jreitt- th«n thi
Cf. t:: e: v> TJ- ^:i.it ont-MU of trai dCcctttf di»
-------
Table 18
Sireary of Chemicals Detected In Subsurface Soil «t the
Kentucky Avenue Wellf ield
Are»: Area-17
(All cenef..itrationi
r.-.«e1
p::e:siJB
se>--.jp
j- 'ive-
jsc-ir
vi-.i:iuB
Z-.nc
23/23
1/23
22/22
23/23
23/23
6/23
22/23
23/23
23/23
4/4
23/23
23/23
23/23
22/23
1/23
23/23
23/23
2/23
1/23
22/23
23/23
22/23
8.186
NR
S.I
73
1
0.6
53.100
13
7.1
27
IE, BOO
65
12.600
466
0
16
737
0.5
WR
102
12
79
17.300
4.9
86
228
1.3
1.3
117.005
26
12
29
29.200
26
33,400
1.060
0.2
25
1.790
0.6
0.8
143
24
119
hctes:
NS *** jtzmetrit n*tr. »it net reps'te* (NS). is this concentration «is greater than the
ot'.er-.e: rti-.nj- t«:i.'St one-ntH of the detection l\*:ti were useti in calculating
tnt genfic mean.
(a) The r.xt*- c' **.IT'« in which the contaminant MS detected divided by the total nunber of
'
(t) Hi-.-st'.Ktei iv^^.ti »«rt nt to ene-half the dttKt^en limit for eileulitlng B»«n«*r1e «*"»
4:se. »6.Tt'es ir. *f-.ich the cor.ta.f.ir,ant >as net ejected at a detection limit at least t«c tines
f-tt'.t- :K4- tNt H4i;rxir oetectet concent rat i or ««re net included in estiniting
content rat ion»
Area 17 Sextet: SB-IS. 20, 21. 22. 24, and 25.
-------
Tables 19
Sxxury cf C-Senlcali Detects In Surface Soil «t the
Kentucky Avenue Wellfleld
Area: 16
(An concentrations in
Chart leal
'Tl
a-.tiwny
a-senic
barlvr
b«*y' Uin
COTllfT.
caleijT.
Ch"w.}ijB
CS&ail
Iron
Iti J
w~>ei 1m
mj-.-snese
n-. rte'i
pt*. tSS irff,
j 5> jf
vt'.IClUB
2 in:
Detection (a)
1/1
1/1
1/1
1/1
1/1
1/1
1/1
1/1
1/1
1/1
1/1
1/1
1/1
1/1
1/1
1/1
1/1
1/1
Gecnetric Mean
Concentration (b)
NC
NC
NC
NC
NC
NC
NC
NC
NC
NC
NC
NC
NC
NC
NC
NC
NC
NC
Kaxfnr Detected
Concentration
16.600
6
7.7
III
1.4
1.4
1,710
21
14
29.900
14
40.000
672
27
1.600
110
23
6.6
K: Tr« ;^3ne^'.; «er. vis nst ea1si.-V.etf beci.i* that >ai or.lj- one ainple.
[i] TSe nj^e- ef »t-c'ei in »r.ich the tontaff.inav. wai M'.K'.tC dwiietf by the total n\tittr
e' ' '
us 3**.*::e: it 't! *err $e: te cne-Kt^ tKe detection Halt for eilculitinj jtTttrlc «r,i.
*'.s:. »*.-='ei m wfc<.c!'. the ec-taff'r.av. «*s nst ot'.tctetf at a 6e'.e:tSor. lw.1t it lust trt tunes
5*ette* '.v tfn Mx-.nji ot*.e:'.« tcnser.tratior- «tre nc*. inc'uaec in estimating gtatnetrie
-------
Table 20
Jiraery of Cherrieili Detected 1n Subiurf«ei Soil «t the
An*: IS
(All concentntleni in
CSer.lcil
Drear, ice
CPA.H
d '. -n-bit v Iphthi lite
K:FAH
Inorganic*:
lurlnm
a»se* ic
b«*itn
bc*y *' Iii0
Ctf'Uf'
calciui
ccsflt1*1
leli
w.jeiese
n ; «. t '
cr' til u
i?C' X
Zinc
frequency of
Detection (a)
2/3
1/3
1/3
3/3
3/3
3/3
3/3
1/3
3/3
3/3
3/3
3/3
3/3
3/3
3/3
3/3
3/3
i/3
3/3
3/3
GentHc Nun
Con:entr«tfon (6)
0.11
NR
0.19
10.700
S.6
5
0.8
0.6
S.220
14
9.3
20.600
20
S.080
480
20
1.080
2S7
IS
61
Kazine Detected
Concentration
0.12
0.06
0.25
13.900
7.8
176
1.4
0.9
26.400
17
11
26.100
40
10.600
£36
23
1.230
105
16
73
KR TV ;e-:r*:r-: net- MS nsl re?c-t»i («), «s thil ecncentrit Ion MS grtmr thin the
o«-.e:-.t: ^j--^r ^e:u»e s-.e-rulf of t^c sc'.Ktion Hit'.ti MM uttc in c«)cuT*tmj
V* ;e-:n*:ri: win.
It] The r.^rje- c' sa.Tiit In ^.ieh tht eontnvlrnr.i wtt dttKtttf tf1»1*i by the totil njit«r ef
stx'es i'
(t) h:--6f.e:t«: st-c^ei «-* »«: t: bne-h*1f t.1* **.»ct1o»i H«1t for cileulitln; gimttri: neins
*»:. ts.T'e> in w.ich the csr.-.ar.inar.t MI r»st o«:Kt»tf it i be'.Ktion 1i»n it lint t«e
£-(!'.» tv :Se wx-.ixr oe:e:te? eonctntritisr. *«rt net 9 gecraeirie
PAXt.
*-*i IE Svap'ie: S8-26
-------
Table 21
RUNOFF BASIN ARCA
SUMMARY 01 SOIL ANALYSIS
PRIORITY POLLUTANT VOLAHI.L ANII BASL/NUI1HAL ORGANIC COMPOUNDS
Borjnt) or
Well V).
RB-1,2, 4,f,
RB- 1,2,: .4,5
RB-1,2,-
RB-1,3
RB-2.4
RB-5
T-l
T-l
RB-3 (Simple
Spoon /
RB-4 (Sample
Spoon)
-
Sample
Dejilh (ft)
1.5-3.0
6.0-7.5
12.0-13.5
3.0-4.5 1
9.0-10.5 >
13.5-15.0 )
1.5-3.0
7.5-9.0
-
-
Analyzed
Sample Type
Lateral Composite'
Lateral Composite
Lateral Composite1
Composite1
Single Sample1
Single Sample1
Aqueous Field
Blank2
Aqueous Field
Blank2
Trip Blank2
Chloroform
ND
ND
ND
ND
96.000
NO
ND
ND
NO
1 ,?-Olrhloro-
elh
-------
SITES
SUMMARY OF SOIL ANALYSES
PRIORITY POLLUTANT VOLATILE. DASE/NEUTRAL, AND PESTICIDE ORGANIC COMPOUNDS
Ror inrj or
Wc'l No.
F-1,2 ,3,4,5,6
c-l '3456
r-i
i"~ 1
"-2
F-3
c-5
r6
Samp', 2 Spoon
F-3
Samp e Spoon
ScHTlpl
e
Hopth (ft)
1
6
12
3
3
3
3
3
3
.5-3.
.0-7.
.0-13
.5-5.
.0-4.
.0-4.
.0-4.
.0-4.
.0-4.
-
-
0
5
.5
0 ^
5
5
5
5
5 J
Analyzed
Sample Type
Lateral
Lateral
Single
Composite
Composite1
Sample*
Composite
Aqueous
Blank3
Aqueous
Blank3
Field
Field
Trip Blank3
Benzene
ND
ND
NO
DMRL
ND
ND
ND
Mothylene
Chloride
48
28
ND
45
ND
ND
ND
(24)2
(23)2
(24)2
(24)2
(24)2
(25)2
(25)2
Tetrachloro-
ethene
15
14
9
7
ND
11
ND
Acenaphthene
NA
NA
NA
BMRL
NA
NA
NA
Anthracen
NA
NA .
NA
400
NA
NA
NA
reported In tig/kg (dry-weight basis).
"( ) = concentration 1n laboratory QC blank; QC blank concentration not shown If ND.
Results reported In wg/1. .
NO » Not detected at minimum reporting level.
NA = Not analyzed.
BMRL = Present but below minimum reporting level.
-------
Tnhln 21 cont-l.
rinnninr OJSPOSAI SITES
SUMMARY 01 Sdll ANAI YSLS
PRIORITY POLLUTANT VOLATILE, HAsr/NLUIRAI., AND I'ESTICIDr. ORHANIC COMPOUNDS
(Continued)
Dorinq or
Well i NA NA NA NA NA NA NA NA NA NA
NA NA NA NA NA NA NA NA NA NA
TY'l-
-------
Tnble 21 contd.
COAL PUT sirr
or son. ANAI v,rs
PRIORITY POLLUTANT VOI Al ILK AND HAM./UMJJRAI. ORGANIC COMPOUNDS
Boring tr
Wnll No
'
CP- 1.2. 3 .-1.5
CP-1.2,3,',,5
CP-1.3,4 5
CP-2
Sample Spoon
CP-3
__
!i.i;np1f?
pppth (/I]
. i.r.-.i.o
6.0-7.5
3.0-4.5
10.5-12.0
! _
1
j
-
1
}
An.ilyrrd
Sample Type
~~
U'.cral tempos He'
Lv.eral Composite
tempos Ite^
Aqupoui Field
D'*nk
Trip Blank3
1?.n"*ne
nMRL
ND
BMRL
NO
NO
Mpthylrnp
Chlorldp
NO (15)2
ND (15)2
76 (24)2
NO (25)2
NO (25)2
Tptrarhloro-
plhrne
7 (num.)2
NO (nMRL)2
12
DMRl
ND
Trlchloro-
rthylpnp
9
19
9
NO
ND
Bls(2-Ethylhexyl)
phthala te
NA
NA
400
NA
NA
Naphthalene
NA
NA
BMRl
NA
NA
Phenanthrene
NA
NA
BMRL
NA
NA
Results -eport.?d In ug/kg (dry-Height basis).
( ) » ciiicenlratlon In laboratory QC blank, QC blank concentration not shown If ND.
Results reported In pg/1.
NO N : dolf?:ted at minimum reporting level.
NA « N t ana yzed.
BMRL » f esent hut below minimum reporting level.
:r..
- 1 1 HI h V7JF -t .< J "
-------
Tnhle 21 contd.
ARPA F
COH1)OUBDS
Oorinq or
Wen_to.
AF-iA,2.3,/l,5
1F-4.5
/\F-l
r 11 j
AF-1,2
"F-1,2,3
/F-5
AF-3
/ r H
/.F-4
AF-2,5
S)igot A
£ fipie Spoon
A- -3
S^mp le Spoon
A; -5
Simple Spoon
Ai-2
'».,... .1*. _.
*£& ^^^__ n_c , , ,wchlor th
-i-LLiJ^UlLcnloroethane
1.5-3.0 Lateral Composito1 ND
ND
6.0-7.5 ^
97:05:?o°5 ) Ctmpos)t
-------
-if.
TnbJ.e 21 contd.
SUMMARY OF COMPOSITE SOIL ANALYSES
PRIORITY POLLUTANT INORGANIC AND MISCELLANEOUS PARAMETERS
PJirjimeterO)
Ai.tlmor y
Arsenic
Beryl 1i urn
Cadmium
C.iromium
Copper
L?ad
Mercury
N.ckel
Selenium
S Iver
Thallljm
Zinc
Cyanida
P,;enol
? jrcen';
Solids
Boring or Hell Numbers
AF-?,3,4,5
11.5 U
20.5 N*
0.5
1.1 N
12.6
23.0
65.7 N*
0.1 U
:-'1.4
t.l U.N
9.4 N
1.1 U.N
109.7 N
0.1 U
0.1 U
RB-1,2,3,4,5
11.5 U,N
9.2 +*
0.5 U
2.8
21.4
58.2
19.2 N*
0.2 *
50.6
1.1 U,N
2.3 U,N
1.1 U.N
161.1
0.1 U
0.1 U
CP-1,2,3,4,5
11.6 U.N
11.4 N
0.5 U
1.2 U,N
43.0 N
35.1 N
24.0 *
0.1 U
43.7 *
5.8 U.N
2.3 U.N
11.6 U.N
160.7 E
0.1 U
0.1 U
F-l, 2,3, 4,5,6
11.4 U,N
6.8 U.N
0.5 U
3.4 N
28.2 N
21.6 N
24.8 N
0.1
37.0
5.7 U.N
2.3 U.N
11.4 U.N
164.5
0.1 U
0.1 U
MHV.2,3,5
11.6 U,N
1?.6 N
0.5 U.N
1.2 u.:i
27.9 N
29.1 N
24.0 N*
0.1 U
4F.8 N
1.2 IM
T.3 U,N
1.2 U.N
17P.6 N
0.3
C.I U
87
87
86
88
86
} Dry-weight basis.
2 Composite soil sample representative of background conditions, 1.5 - 3.0 feet.
E - Estimated or not reported due to presence of interference.
lj - Element was analyzed for but not detected. Reported with the Instrument detection limit value.
1 - Sr.ike sample recovery Is not within control 1-imits.
; - l)v pi icate analysis Is not within control limits.
* - Correlation coefficient for method of standard addition 1s <0.995.
-------
s
p**
i
:
i"
i1 !
CiWovru
TJLhlo
rth °i
t I
>
ethene
feS T&rachlqrnelhene
'(JW 1,1.1-TricMoro-
1 * 1 ii
1
.SOIL WRING ID:
sn-i» sn-ii
Depth]: Depth
2.5-4.5 7.5-9.5
253 f 39.7
20.5
1 i 1 1 1 i 1 1 9 1 | 1 i , » | , ,
Tnble 22
ANALYTICAL SOIL RCSULTJ -. yoi.ATn.t.jw_stHiyoiAULE
SB-12 sn-iz sn-ii sn-M SB-IS SB-IS sn-16 SB-17
Depth Depth Depth Drpth Depth Depth Depth Depth
2.5-4.5 5-7 2.5-5.5 2.5-4.5 2.5-4.5 7.5-9.5 2.5-4.5 7.5-9.5
118 65.1 7.57 - 83.9 118 - 7.13
- - 7.65
20.2 - 14.6 - 8.0 - -
' « 1 !..
t « "V
SB- 18 SB- Id
Depth Depth
2,5-4.5 5-7
156 16.9
7.83
16.5 11.2
J
SB
De
5-
14.
19,
r*vl
NOB 1.1-Oichloroethati* - ... - ........
1/41
9n THchlorof looro-
wftj nvthane - --. - .........
M Methylene
M chloride
1
~ / *
t rani- 1.2-0 Jch-
loroelhene -
.. - .....
- 5.75
«> ^
.
_
1.2-0»ch1oro~
beniene ... _ ___._. v_
H Hethylphenol-4
IM
| Naphthalene
ft
1 Nethynaphthylene
U -2 '
Tljorene
3
n pht-nanthrene
tf anthracene
w
I dl-n-butylphthalate
J
M Mouranthene
3 py^'
|
S benzo(a)
d
a t'hthal
I Chrysene
1 I2VOK
nthracene
hr1he.y1,
NA »'A
NA MA
NA NA
NA NA
NA NA
NA NA
NA NA
NA NA
NA NA
NA NA
NA NA
NA NA
NA 96 J NA NA NA NA NA NA
NA 170 NA NA NA NA NA NA
NA 140 J NA NA NA NA NA NA
NA 83 J NA NA NA NA NA NA
NA ' 605 NA NA NA NA NA NA
NA 190 NA NA NA NA NA NA
NA 230 NA NA NA NA NA NA
NA 550 NA NA NA NA NA NA
NA 350 NA NA NA NA NA NA
NA 250 J . NA NA NA NA NA NA
NA . NA NA NA NA NA NA /<
NA 370 . NA NA NA NA NA NA
NA NA
NA NA
NA NA
NA NA
NA NA
NA NA
NA NA
NA NA
NA NA
NA NA
NA NA
NA NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
-------
I I I I
1 I I I I I I
''III
till
Comounds :
Tnble 22 contd.
ANALYTICAL SOIL Rr.5UU5 -.VOI.AULC_ANO SWIVOLAJILE
f AtLI. l.Ni' '
-SOtL_BQB|N(LID;_
sn-i
Depth:
TetracMornthene
1.1.1-frlchloro-
ethane
I.1-01chlorrethane
Hethjrlene cM or I
-------
Jilt
I I I I I I
I I I I i i I I I I I I I I I I I I I
1 »
TnMc 22 contcl.
0IL "tSUtrS- VOlAr_
IAUi..LNILRrRlSt.S_lNI!UL-SlIL
CovDounds:
TrtcMoro«tl«en»
T*lracMoro*lh*n»
1.1.1-frlchloro-
ethane
SB-20
Depth:
5-7
7.59
-
sn-21
Depth
2.5-4.5_
-
SB-22
Depth
5-7
28.9
-
24.7
SO -22
Depth
7.'j-9.5
23.6
-
.
sn-71 sn-/i
D«*plh Oi>pth
7,5-9.5 i.'j-9,5
112
-
20.7 25.7
sn-24 sn-25 sn-26
Oopth Depth Depth
2.5-4.5 2.5-4.5 2.5-9.5
27.5 4.92
-
21.6
121
7.97
48.1
Sfl-26
Depth
7.5-9.5
3.46
-
12.2
SB-27
Depth
2.S-4.5
-
-
SB-27
Depth
2.5-4.5
58.5
12.7
18.1
1 . 1-Olchloroethan*
Trlchlorofluoro-
elhanc -
MrthvUn*
chloride -
lr»ni-l,2-O!cMoro-
1.2-Oichloro-
22.6
15.0
10.4
29.0
15.8
15.3
1290V
-------
Table 22 contd.
RESULTS OF FFJORJT5 POLLUTANT ANALYSES OF SOILS.
FACET ENTERPRISES. ELKIRA. NT
Sarple Location
Faraaeter
Met els (ffig/kg)
A£
As
Be
Cd
Cr
Cu
Ki
Pb
Sb
Se
Tl
Zn
Mercury (eg/kg)
Cyanide (eg/kg)
Purge able Orgar.ics (ug/kg)
E?A Method £240
cethylene chloride
tcetone
Serivcletiie Orgar.ics
(ug/kg) EPA 8270
»e thy! phenol -4
naphthalene
cetbylT,cfhtbalene-2
f iuorene
pbensntfcrene
ar.thr scene
^i-r-butylpbtbalate
flucranthene
pyrene
ber.2 o (« / an tbrscent
bis',2-etbylberyl)-
pbtnslate
cbrysene
SB-31-7
i.e
12.4
0.45
1.22
15. B
49.3
26.7
17.6
11
3.4
0.77
104
0.02 U
0.55 UN
I.E EL
5 BL
KD
KD
KD
ND
KD
KD
3600
KD
KD
KD
B'JO
KD
D-12-5
2.46 N
29.7 N*
0.47 U
31.6 K
268
996*
138 N
429
12 TO
3.7 DQN
0.77 UQ
1070
0.22
2.57 N
16 BL
6 BL
96 J
170
140 J
63 J
605
190
230
550
350
250 J
ND
370
(Continued)
-------
Table 22 contd.
Earpie Location
Parameter
SB-31-7
D-12-5
Pesticides
£?A Wetbod 8080
Phenol (ug/kg)
EPA Method 8040
PC3s (ug/kg)
EPA Kethod 8080
Asbestos
KD
KA
KD
KD
KD
3600
KD
KD
NOTE: All results reverted to highest level of accuracy possible taking into
accent detection liirits and dilution factors.
nc detected
KD
KA
BL
J
DUP
U
N
- nc
- es
- es
- d-j
er.aiyzed
ir£tec vfilue obtained after subtraction of reagent blank
iz-Eted velue less than detection iisit
icstes elere.-.t vas ar.sZyred for but not detected. Report vitb the
ir.strv^rer.t detection licit value.
Ir.:;cs:e5 spike S£=ple recovery- is net within control lisits for spiking
before c'igtstior.
Ir.c'iceres c'-jplicete analysis is not within control limits.
"r.c'icctes er.clyticsl spike (perferred at bench) recovery was not within
E5-1I5* ccr.tr:,;. lisit for values less than the CRDL.
-------
Table 22contd.
F2SIT.TS OF SOIL SAMPLE ANALYSES. FOR.MER OIL LAGOON AREA
(ErA Method BOBQ-PCBs in Soil, Bg/kg)
Coring
Location
LI
L2
L3
LA
L5
L6
L7
PCB
1016
0.12
KD
KD
KD
KD
1C'
10
PCB
1221
KD
KD
KD
KD
KD
KD
KD
PCB
1232
KD
KD
KD
KD
KD
KD
KD
PCB
1242
KD
KD
KD
KD
KD
KD
KD
PCB
1248
KD
2*.
KD
KD
4.6
KD .
KD
PCB
1254
KD
KD
KD
0.23
KD
0.15
0.053
PCB
1260
0.11
KD
KD
KD
KD
KD
KD
KD = net detected.
4-11
-------
Table 23
USCPA ;
KENTUCKY AVLMtf UFLiriCLO
SiMttRV Of CHIMICAL OAIA -
KtfflRI
IRC UECIRONICS
(CMPIRC SOUS)
(1901 - 1968)
(Cenl'd)
riCLD
128J: (6) Mils. (I) $»!
Boring
19JU: tteUr Analysis
|S) Mils «*s»U
June,
19JS: (IS) sell bcrtngs
ground Mtcr
stapling
June.
LABOHAIMV
IHVtSIIGAUQM
Cd=54.4-S8.8
Cr- 134. 3-314. 7 ppM
Pb=IS - 124.3 fpm
Aij-<\ .0 - 41. 1 HIM
CM- 1.0 - 6.26 pf>»
lor Al . C4
Cr. CN. ft. Nt indicated
II levels were
NVSOCC standards.
12fl4:
Cd (2/5). 04-. IS ffm
fluoride (3/S) I ft-26 ppa
OCC IVS) 21-3400 ppn
I.I.I-ICA (2/S) ;-IS ppa
TCE (3/S) 11-141 ppm
13D5: Meter:
CO (?/)) .06-. 72 pp«
Cr (2/9) .08-. 22 |>p«
Pb (b/9) .068-. 1611 pp«
fluoride (9/9) II. IB-IS. 0 ppi
IOC (9/9) I.O-I/'j ppn
I OK (9/9) .OS-27.SOU pp«
POC (9/9) 0.2S-/6.9 pp«
POX (6/'» 0.14-l.bb pp«
Oil 4 Grease (1/9) 101 pp«
-
Cd (S/17) .10-1.31 pirn
Cr (%/)7) .02-1.32 pp«
Pb ( IJ/I/) .01-1.20 ppa
Oil t Gre*s* ('>/»)
: (18) soil borings
fluoride (I4/I/) .M>-'J4 ppi
June. J'JOO:
ii_l: Analysis of purge-
able aroMAlics vol
tilr lialuuenati'd
n u ilirlri I ions .
Si) LI' Only Cdilmium vmreded
lUX liaili (//III I ?
2..IN ffm
07B8K
-------
Table 23 coatd.
USCfA
KtNIUCKV AVINUf WCUflUO
SiMtARV Or ClltHICAl OAIA - PHCVIOUS INVCSIIGAUQNS
flflO
IRC C1CC1RONICS
(CHPIRE SOILSI
(1981-08 (Cent'4)
JSJft: I MtlU
May. 1988: I Milt
*«»!
lAaORAIMV
Hcthylrn*
Chloride (3/7127-130 ffm
ChloroBethdnc (1/7) 42 ppfc
lrichloro(uor«elh«n«
(I/M IS ppb
I.I-OCC (1/7) Ib |i|>b
ICC 12/7) S4-7U p|>>>
I.I.I-ICA (1/7) 2'W ppb
Cthylbrniene (1/7) 19 ppb
1.2-OCt (1/7) Sb ppb
ICC (2/M 3«-4') ppb
I.I.I-ICA (1/7) 4 ppb
1 I-UCE
-------
Table 23 contd.
ANALYTICAL SOIL RESULTS - INORGANIC
L.R.C. ELECTRONICS, INC.
Compounds
Boring
Hur.be r Derth
B-l
B-2
B-3
B-5
E-6
B-7
B-8
B-9
.. .
2
4
6
6
12
0
4
6
10
±2
14
0
£
E
12
15
e
E
12
4
4
6
E
14
.0- 4
.0- 6
.0- 6
.0-10
.0-14
.5- 2
.0- e
.0- 6
.0-12
.C-14
.0-16
.5- 2
.0- E
.0-10
.0-14
.0-1"
.0- E
.0-10
.0-14
.0-
.C- 6
.0- 6
.0-10
.0-16
(ft ,
.0
.0
.0
.0
.0
.0
.0
.0
.0
.0
.0
.0
.0
.0
.0
.0
.0
.0
.0
.0
.0
.0
.0
.0
Cadmium
> M=/Ko
1.29
0.45
-
0.35
0.04
0.10
0.07
_
0.02
0.33
-
0.27
-
0.02
0.04
0.10
0.50
-
1.33
tO.02
<0.02
<0.02
-
Chromium Lead Nickel Silver Fluoride
fc* * / V M &4 M t V m* Ut / V M Ul 0* / V M ^4 PH / V **
M5/^\O MO/KQ RO ' KQ KO/JSQ MQ/J\0
0.07
<0.02
-
0.03
<0.02
<0.02
<0.02
_
<0.02
<0.02
>
<0.02
-
<0.02
<0.02
<0,02
<0.02
-
1.32
<0.02
<0.02
<0.02
-
1.20
0.07
-
<0.01
<0.01
_
<0.01
<0.01
.
<0.01
cO.Ol
-
0.06
-
0.01
0.01
<0.01
0.01
-
0.44
0.02
0.02
<0.01
1.60
0.17
0.32
cO.03
_
0.06
0.05
0.03
0.26
-
0.06
-
0.04
0.03
0.04
0.07
-
0.29
<0.02
0.65
<0.02
-
0.1B
0.04
-
0.05
0.02
».
0.02
0.02
_
0.02
0.02
-
0.03
.
0.02
0.02
0.02
<0.02
-
0.09
<0.02
tO. 02
<0.02
14
34
15
11
e
16
e
16
0
25
20
32
94
0
<0
0
.00
.00
.20
.80
.40
-
-
.00
.00
.50
.98
-
.00
-
.00 -
.00
-
.00
.66
.50
.56
_
D
V(
\\
f.
t
V
i
i
Note: - Faiarneter Not Tested For.
nig/kg pprti
Source: Er.pire Soil Ir.vestisations (15E5)
-------
Table 23 contd.
SOIL RESULTS - INORGAKIC
L.R.C. ELECTRONICS, INC.
Compounds
Boring
Nur.be r
B-10
B-ll
B-12
B-13
B-14
B-15
KW-7S
KW-9S
KW-10S
Derth (
0.
14.
4.
4 .
14.
12.
£.
.
6.
£ .
12.
.
14 .
0- 2.
0-16.
0- 6.
0- 6.
0-16.
0-14.
0-10.
0- E.
0- 6.
0- E .
0-14.
0- 6.
0-1 £.
ft ,)
0
0
0
0
0
0
0
0
0
0
0
0
0
Cadmium Chr
Ks/Ko Mo
<0.02
<0.02
<0.02
<0.02
<0.02
<0.02
<0.02
<0.02
-------
Table
J.mi-y ef Su-f*
*r»| 1 fi
(All eorctr.
Tr«,r* ef
C-wieil DttKtier, ()
0^»r. lei:
:e::->e 1/1
w.':'«i« eK'ie'ifli 1/1
trier. '.:-&<:r*:>t 1/1
lirmjt 1/1
w-ciir 1/1
er-arti» 1/1
1W. 1/1
Uii 1/1
it: JT ' 1/1
:ir.; 1/1
R" 1 » *r^0 * * * PW i p*K»A**»B4 > KAI* t* 1 ^
p * y t JK . » FiV I &» »* *'? * « n» h &fl '»
'^ i«:;?I-l?Jt^ '" 1fl ^1C" tf* e"'IS'>1
fk^ |....^*...*^ iiv'tt ^« *4 « f* P*»-K*^' *
^/ *i» ^ . r. . r. ) t^ E: ^T 11. i» ?.t ng.-
rtj-j. i'»:. jt^'es ir .": f» ::-'.t-'r.
ej.. .»: . re. ,-ti.i .4 ."« «i »vr 5«
* *" » i*-J"*- =ti ....*... r». 18.. |.
JtT'tj: Sr-i^
2k
:i Vitt* Sisrling D«ti
me- Sins »r>; 6r»»|l Fit
trttiom In ws/1)
Mtin 0»'.r:t»i
Cextr.tntior, (b) Con;tr;tr«:ion
K 57
K 2
K J
«: 270
«C M.8DO
K 7
NC 17
N: r.:t ar.tc'.K it « oc.Kt'.e*. liir.-.t «t
'. c'.K ^r,;i-trif.sr. «-| net In;iu9t£ in
-------
Table 24 contd.
y c< $y'«:i Witt* Sweline Dtti
AMI 3 01* He-it-**: Lane1 ill («}
(All conttr.trttioni in uj/1)
C»*.l
T"
c* 'i-Tvthmt
t*-»]tii :-.ic-ioe
J-'-MT
u'--.ir
CI3T '. if
Cl 'll 'X"
e*.-ar t«
CB » ' »
»W^ »
lit:
£< -- cesc
PC:I»J JT
»i-t: jt
X'BS
rr*flut*Cy Cf
Of.Ktten (i}
2/3
2/3
1/3
4/5
2/5
1/4
5/5
2/5
4/4
3/3
5/5
3/4
2/5
5/5
1/4
5/5
ficmtrlc
Mlin
20
MR
1.5
M
471
122
NR
4.89
101. ODD
t.l
KR
111
15
' 25
1 t2I
I7J4D:
MR
67
KSk
77
1
2
2
I.3E3
23S
0.2
37
11B.D5D
18
6
i.OSD
43
2C.IDC
177
2.2$:
111 ,C5D
it
Mi
Kf. *"-* :»3-«:--: rt!- »n «:*. -t:c-*.fri (Kf-!, «i tMi :ei:tv.»it1o* »! J*»»'.t' th§n tht
MM--.C: -tj-.-vx sr:i.»t 8it-u':f ef *.!i« W.K'.ior. hc'.ti *»! uttc ir, eilcuUtlnf
(i) ">» -j-cf- c' itT'.t* 'r. **.i:h tht 15r.'.ir-lr.t-.t «> 3t'.*:'.»£ tfw1d«tf by th« tct»1 nj*tr of
. err t: stt'e: ^-» »rt tc s^e-Silf t*» *:»s:<8r. llr'.t fc* eilewlitln
*'i: »t-t ii 4.~ * .:' :« i"-.i? -.!: »! r.:: a**.*-:-.*: i: i w.*ct -.
:r: : -« ;»»-.! .< tv PAJ--.J! M'.I:'.»: tsiiiv.nf.sr. «rt ns: inc'iuatC in
Rt.-.: :: c-::. P>::
st^v <: St-.:. Si-*.
-------
Table 24 contd.
0? DlSSOiVTD 1NM5AK3CS DETECTED IK
AT Tri: «KTU«r AVEW: YIUFJELD SITE
(All conttr.tr*:toni in us/1)
frtoutncy
t Iti \t.
Concer.tntion
Arti 3
cilciir.
Uȣ
wjiei ii*f>
i»*sury
oeiiir. *
line
ArM 2
cilciir.
it»;
N**ICS ilP.
tccitr
nnc
S/3
2/3
3/3
1/3
3/3
2/3
1/1
1/1
1/1
1/1
1/1
M.3SO 103.000
3 e 2E.3
H.8SO 17. BOO
0.4
31.750 1M.OOD
IS 18.1
12.000
27
17.300
es.ioo
»n»1yiti.
2 SIT It:
-------
Table 24 contd.
or SEDif.it>" sw'.in-: om
tf.it i r»*,n SAK: AK; 6R*vii
Df.ection Conitntritton Content ration
c*i"::s (»S"E)
A:e:sne 1/5
E '.t >'<».« 1r*» v * )p".tftf lite 4/4
Ci-ts- eiik^io* 2/5
C-.ne:».v :;-.tiwl»te 1/4
C'-r-s.-'.jl&'tM iite 1/4
**'.*» °*n( tn'iC'lOt 3/5
le !«»>« ' 2/5
Tni^.s-setrnne 3/5
Ce*'-' " ' 4/4
n:tt" 4/4
f:5i (A-o:1e-i 1?W. 1260) 3/4
A^-'.r.j- S/5
«-»e-i: 1/5
6f.i.- 5/5
:«a--.i- 5/5
:«':;.- 5/5
C**~ j" 5/5
:::«-. 1/5
Ccrrt- 5/5
.ej: 5/5
*t:-,esnr 2/5
>*"fseit 5/5
»«:.-.. S/5
K-.-.vt' . 5/5
S '.* 5/5
vi-.t:-.j- 2/5
:-.-. s/5
1.7
3.680
54
16
20
26
3.2
4.9
S.I
11.700
12.400
560
3.170
C.5
310
750
13S.OOD
130
2
E10
83:
530
85
1.1
170
21
2.7
11. so:
22.3
S.200
19
540
1.200
240
16
e
100
se.eoo
78.100
2.160
7. ISO
7.1
4E7
2.660
251.000
411
13.7
1.350
1.68:
5.154
16$
2 57
315
42
31
45.300
ec-'--nite-j »rr'ir>;' H-SD:V!. 1986 US
nj ''o.-*.: «f4lyie; fe* veil*.ile
:*;(-. :3^;.-.: In: e*wieiii.
-------
Table 24 contd.
T or $»!«*' SWMKS on* no*.
' wit 3 - o.: Hos.s!H£cs
e»ic,i
o*nk::s (us/kg)
/Lets-it
Kf.\»'eie chloride
T* i;* ":j*se" *nie
PCE (A-e:ler 12M)
^«--f
6t* 11^
liy.ir
ti 'i : . ;
C-or-j-
tcw I*
Cirse-
Ltt:
^',ti\\f
**~;f.tit
*«-:.*»
K-cie'
F ; || j n/r
$ '. !»(
V 1 *.l C 1 IT
2 ir.:
of *
3/6
4/6
1/6
1/6
3/6
6/6
S/6
1/6
e/6
1/6
8/6
8/6
6/6
6/6
3/6
8/6
1/6
2/6
J/6
S'6
Geometric
Conttr.tratien
11
IB
3.2
40
9.270
1.4
16:
)4
4J.60D
46
2.6
92
96
7.4o:
j;7
C.OE
K
280
2.1
17
zso
C^SrSion
130
340
11
3.900
11.300
6 «
31S
220
SI IOC
'140
10.2
360
320
16,700
120
C.5
210
i.oo:
is
31
LCD:
; St-t -it
fi: ::'-!*.:-. jt^-in;: O-SD-lt. rr..SJ.-C. KT-SO-PD
;:! k.'I »L-='-.r..; Kr:»-Si:-l. K"iV-S:D.2. «r[V-S£D-3
fc.-:« :<. :* t: ::'-.-*«:r-. »».-S"M^J »e.-i »'.»''j7e: fe*
c-;t--:» »-.: i.r.:-?i-^:» e?'«j. Tne K.'i tt-^'ei *-« «r4'iyzn fer
-i.-.c hi: e"«M
-------
Table 25
SUMMIT or snttifo ctffMitAis of tmicfPit ro»
I* MNIIfcU MI NIK MllflllO Sill
CiflHi;..!
i rtnn*
corlxm .llMiM I.U
r«r -li-xiriilc PAIte
« li lurof ttrm
.11 it htilyl pMlulat*
«ll n mityl pfiltatotO
«nlfiy|pn* c:hlnrl
»
I
..
..
_
R
..
..
R
' J
_
. -.
.
R
--
..
X
R
R
ATM 3 Arc* * Aral IS Ar«« 10 Are* If
.... 1
R R « X
.-
R R «
--
X
R
R
R R - X
..
* -- -- --
II
..
* _» _ - ~~ ~~
R R R
|
-.
.- _.
« « ^
~ -'
..
R
R R
* «
R R
R
._
R R R R
SIOINTN
VAIIR
Ar«> t
X
X
X
X
X
X
..
X
X
X
X
X
X
X R
R
R
..
X
X
X H
R
R
R
.-
R
R
.
R
--
R
rs
Ar«a 3
--
-~
..
--
--
R
--
--
R
*"
--
R
R
R
H
R
R
--
R
*"
R
SlOf ACt V
ArM t
"*
--
*.
...
--
«
"
""
.
""
-"
R
""
R
""
*-
VM
R
--
X
R
--
--
--
--
R
UCN
ArM 3
" ~
"-
- -
--
--
--
..
».
-"
--
--
*~
*
R
"""
R
""
R
X
X
X
X
X
X
R
R
--
-
R
R
(I Selected c chw»lc«l nf concern In iMrfac*
-------
-Table 26
USE: TD ESTATE RSSIDIKTUL
iKisiSTlDti EXPOSURES
F*-«meter
Injestion Rite (1/sUy) (»)
Eipsure frt:Uen:v (diys/yur)
[xpssjre Dur»tior. (ytirt) (c)
E::; ki-jv. (^/ W
Li'etime (ye»*s) («5
Average
Use
1.4
352 (t)
S
70
75
MusttH
tUnirjrr, Use
2
3E5
30
70
75
(t) Bese: o*. E^A (39S£t) v»1ues fc? «»er«9e idylt ingestion for
e-*;t »:' wntwr pliusit'ie w;.1y «:twuy levels.
(tl- Aj*.-"r.j I «eeit.! vue*. ic^. *?e-.*. «> frer hamt t»:h ytjr.
(:) Etst: D- [Et (iSSii! v»'iues fcr tvertje «nc pUusible
ri>'!;.j- c.-»tis"!i ^er res-.oer.ts in the saT« pl»:e.
; PA. (19££e; sti-.serc «$sir;: 10?. fc- «ve?«ge
- ..
(i; Edse: cr. £?A CSS6&) ilinwc ssunftSer. for * lifetime.
-------
Table 27
jf.i PARAKrifRS FOR DIRECT COm:? WITH SURFACE SOU
IT tKJIDSi:* AN: 7££NA5[RS
CURRiKT SIT£ USI
Pt-rir.e1
tcru-i
fcySIJ't
Soil Ir.jf
A-« c' S
ScH A::i
Sc-:'. Ccv
tec* *e-j
li'et-.me
fc'f we
*-«-:
I-".;-.*
e-;i-
:«-:-.:
* In < *
s ' s I t
C~. it ;
C '. it e
*«-;- ,
"'"* '
U' 6 » « E '
. &J i£-
/. »
(:! *ii.-
ij *i ;~
li teis:
(e' -'lie:
Si'.J
!/ : r . . _ .
,' !'
(. isss:
-. .'.s-.e
« " '
I;', li.-t:
?re;jer.:y (o«yt/yt«T) (»)
Ourt: icr. (ye»f») (b)
i'.isn Rete («t/6»y) (e)
*ir. £x?s»e^ (c«2/cUy)
ffi.litisr Rite (ms/otZ) (f)
i:t Rtte (WS/MV)
v. (kS) (S)
(yee-s) (ft)
t't' Aiss-p*. ion Friction:
(')
't-t (j)1'
KJ. vc'i«ti'ie erger. isj
je--.: fA-rs o
;r.;;e-.i: PAr.s (k;
" " '*>f * ''"'t "*te (k)
:"-.eV.e£'('.;
;::£ (')
..,!,, f ', \
* 'i*77 i !;
-.;-:£--,:s C)
,i::' ";. (-j^-.rr*^ cty: ireei for
't.s-.i't rei-.ri,- eese.
-; : ':-« »-.: '.te-.tje-s t1i> c* s
:t: t't-tzt v/ef.ae ir.jes: .; rjtes
; s.-:'e:e «-et ef tr* rit-;s »r,c «-
; s.*'t:e e~n cf tne h«*:j. »HM
- ;; ;:s£ *;.
V.e: 'rer ft (ISESe).
j- .fi ;;j jj' j".t*.sj*i eisj^tio^.
: tc'.-t re: e«;-:: fT4r:)c- tssj-«r
* ^ * " ^ | " 5b^ )
:"w-.I 'rr- ?tiBe-'i^ SchU'.'.e- (
c* 5**> 'a* tanr A! M SRi* fe^
vc«*r
63
10
110
2.220 (d)
0.5
1.110
40
75
0.6
0.15
1
c.oos
0*«l»
. c^
0.07
0 OrS
C.05
0.1
C.I
0
/
»e-»je*t
:,"t ttt
use: o*
TT.S Ct':;«
.r.i 1.;s.
fc* lifeti
tc tx *ts:
1S£:.)-. .
K*npur. Case
219
10
110
5.170 (e)
0.5
2. ft'O
40
75
0.6
0.5
1
0.0?
CAC
. ct
C.07
0.03
0.05
0.3
0.1
0
-/..
tse in: 7 oiyt/oeek
s fror t;es 6 tc 16.
[PA (ISEsi) .
ii'.ec frar o»ti in
Cileulitei fror
ne .
rse: fror. ingestei
*1 USE?)
e-: ::i
-------
Table 28
ro; tisir CONU:I VHK SIRFA:I sou ir RISIKKTS
FJUTi SITE USE
Use
Cxpoi^e Durr.tor. (y«-s) (t)
Stnl Ingestior. Rm (trj/dj.O (e)
*re» ef Skit Inssei (srtf/day)
Soil tecusL-V.icr. Rr.e K'etri) (f }
SoO ler.ie:-. Rr.e (w;'aejO
ledy Wfijv. (k;l (;)
'.iw (yts-sl (^)
fCJs. ft-.'.. S'.slt-e-.f.v
s".tt>ii''.e'.f ;:'
c*;f.;t. v:'.i: ,'it c*;e-.-.;s
DtTi»": lM:-::ir- rrj:'..£-.:
h:r.:e-":-r^:«--.: ?i-.t'iO
C'.nr V.:-«--:s !'ij
It) itse: - r.f =£.-s .ver **' **i-"
IK;^ siii. f: e:s.-T.; 2 oevj.
; lest:
Ul t«se:
s' |ts!:
(^, fcess:
(i) Lu-.t:
U; fctst:
9
IDE
'93 (d)
0.5
357
70
75
C.I
C.1S
1
C'.ODr
0.03
C.07
c.c::-
t.::
C.I
C.I
c
I ;.« :
j«
i-: ii
r. Ctse
219
30
IOE
2.960 (c)
0.5
1.4SD
70
75
C.E
0.5
1
0.02
C'.07
0.03
O.C-S
c.:
0.1
0
c: *»t-tjt te*e ?: "
vi'.je: *t- ivftct »r.j {'ifti'f.tle
t »CM :''t:e
.-£.« :««-.if. re-.es bese: t- £«t (19E51.
ee :' ti!"".e*:s, Le'if'if.t: '~b~ oi'.i ~>T £(
C»1iu1»'.e: try. o»'.e
s-.t"f: eisj".;*.'.c* ft* nfe*.'>«.
se--.s ^rt:-.- tjsjme: te te t£*:*se:' 'ro*1 injeitei
: S:".'f.t-- USKV
e*-j t: tV liSSit.i;. taes'.er t». «T.
»-.-.« usi::.
-------
Table 29
KLCTf EFFECTS CRITERIA FO*. CH!*;CA.:S D* POTEKTJAi CWCERK
FK 1KI KEK7IXKT AV£KUI KU.FJEi.0 SIT£
CMttT
Acetone
fc't !2-ethy1hery1)pr,!h< lite
(8£Hrj
ej4o(»Jpyrene^ ^
Ctrbsr. c*i*ulf toe
C*> "icrcf OHT.
l.?-DicMcroeth>1ene
(tram)
tiw:*/1p-;thiTite ff)
titsrtyi Pnth*)ite
Ci-n-cctylpl'.'rit ljte (f]
fnesjulfir.
ltn*1berjene
Hethy'ient CMc^lde
**?*:th» lene
(w.c»r;-.rc;e--.s **-')
JciycMorvw. tc B';*>e-»'i
(foi)
leluene
I.l.l-Tricr.lc-oetve
TTicr.lc*9Ct- *i*>e
tiny! Acnr.e
»in»T CMs--.se (j)
Ij'iene (f.xe:,
HDR&AKICS
-.Tte-y
Urier.iC
Et"iur.
Be*v11iiir
Cjasun
Cr.Tx^j* 3!* ( :?~;j. c;
Cr.-x-*. kl I Car.;:!1:'"
CebiU,
Lett*
*to*-9»neie
He-ct*y (ifie*;{--;'
Nt'tu-y (we.'*'.*"/
kickel
.ciel re'ine-y a.1*:
H'cke1 i.ss.Mioe
Se'ie-iuB
Silver
Thillur 1 Cor.5sw".i5
( ir tC >Ut 1C 14 '»S ;
Yir*t£iifr
2 «B («'.»1)
.- -:. ?.:::-« «-f t-< fs;.
re'ere'.it e:set je-e-«:"- cr
ir, the tt'.i i«< .»: >e. *<»
. .* *-- .,.... -. j;;;,-
1 1 C * s c 'd ". i tc ::;.
ID-'s'c 'e '." *.: «::.-
A If'.fp'l* '* . »**
4V'C'» e .» .. c».v.
Hccf'''^^.! fi.* *s i-( &»- -^e
fer.u.eiwg.ni
«fD '
K'kS'div)
1E-C2
2£-C2
ND
ir-ci
JE-C2
2£-02
KD
IE -01
KD^
1£-01
6[-D2
ND
3i*:i
er.jj
7.3l!-:- (e)
K:
»,-
2i-::
4:-Di
(; )
* *:2
5L-:3
:--:-C('=c:;
ii-vt («:e-;
!£::
jr . j j
N:
K:
2£-Cl
"K:
3:-..^
3:-0- (i)
21*02
KD
K*
3E-W (C)
7L-Ci
7E-C3
2£-:i
,{ ft y..;,..|rr
-s-. c' twit 'c*>
-.1-51*1 y-ct'ii
fc- the fi-nt
fs- the ir.ie*:
ft- tie tice-t
'c' t-< w-.:e".
i*. fx f.ic-e*
c Criticil Tezicny Vilues
Sifet
F«cte/(i)
1090
1000
ND
100
1000
1000
KD
1000
ND
3000
1000
ID:
100
ND
10:
10:0
ic::
KD
KD
ID:
1000
ID:
ID
10
ic::
s::
"ND
ND
it:
K"1
JO
ic::
3::
KD
KD
IS
2
3000
100
10
v f«-:e-i
e: e'"i:.
.r.'.y fn'.c'i
ier" ir. »eii'
imty 1n er'.
fr\) ir. izt
lir,:> ir ex!
ior. ef the r
Souret (b)
IRIS
IRIS
IRIS
IRIS
IRIS
IRIS
IRIS
IRIS
KD
IRIS
IRIS
IRIS
KIA
IRIS
IRIS
IRIS
HA 03/31/67
KD
ND
IRIS
IRIS
JR] J
IRIS
IRIS
ME* (i)
K[i
IRIS
IRIS
IRIS
IRIS
H£&
IRIS
M£| (j)
IRIS
IRIS
IRIS
M£A
IRIS
HLA
HEA
MLA
r.- *ci Vying fj
f. t».r. ?»::c-
>M 'wDt the T<
twit* encij *.'
*i;c1»'. ir,; i-it
«;ci«tir,j frar
-ir: U*. in; frer
e»e«e- ic csx
CA£ Cincer Potency Ficto
Potency
F«ctor
Potency
f«cter
t
We iev.
ej
(«;/if /eUy)-l Source Evidence (c)
ND
1.4E-02
1.15£*01 (d!
ND
I.1E-03
NO
NO
ND
ND
ND
ND
7.51-03
ND
7.7E*OD
ND
ND
1.1E-02 (d)
2.3!«00
KD
KD
2E-00
KD
KD
KD
KD
KD
KD
KD
'KD
KD
ND
KD
KD
ND
ND
ND
ND
ND
KD
ND
iciers. Un-,e*tiirtty f»c
r»i-e»e-.tin£ t ipecific
>11o»'.n;
* writri e* the rurar.
v' df.e tc the cise cf
IRIS
IRIS
MIA 196< (C)
IRIS
IRIS
HA 03/31 /B7
IRIS
IRIS
KD
IRIS
IRIS
IRIS
KIA
IRIS
IRIS
IRIS
ME A
N:
M£i
IRIS
IRIS
(r. )
IRIS
IRIS
IRIS
IRIS
IRIS
IRIS
IRIS
IRIS
IRIS
KD
KD
IRIS
IRIS
IRIS
M£A
IRIS
HIA
HEA
KIA
tc-» uitt tc oe
«-e» of unit 'i
posulttior.;
hjntf nt
E2
62
..
E2
D
D
D
..
0
E2
E2
C
C
E2
L
I
..
A
-
E2
..
--
--
C
E:-
c-
t
.
.
.
.
.
.
f
..
-*
rtlss
iir.:y
leiJ-'.n*---cr.-OMc NOAEu tc- chrome KDAlit: :'
' LC*.i:J tc KOAEtt.
tr 6*.he* unitrttir.tMi 1
r> the eUt».
-------
Table 29 contd.
LCn CRITERIA FW MtUlCCS 0* WEK71/U. CONIERK
FC* t«i ttK'UKT MEWE WL.lTlEiC SHE
) le^^lf n'ft-:t ocses: IF.:S \r* thrrieil filti e* £**'» Jnies'iit: ton
K[i huh* [«t::i *sstir-«". Sj^r^v Ur'itJ (Ot/Ci/65). KA » nteV.'-. fcsviiory
:1 t*t MICK*, e' tv.3tr.it s'it»s-'-.ii* ie* »:hewe for t»rcino;tr.»: »
BJ-EI' t*..-:^!. l:--f-tu:'it *ft- ^^':^rl^9^r.. ntmei
.^6''. Syittr (it of 07/01/65):
tf Drink in; W.er).
tot;ji*.t lotrirt frer .rnt' f.^:-.es; t"Fe*»'.t'ie rume- k*-im»j«-., HB-.H
Hjr*r. c*:t. C fc:t cUs^-.fie; » it hj:*- ti-cintjir.icuj', tn£ E--Evio«ri:t
ij H«»ith Effe:*.s *.jtti$T«**. ft* 6f.:c!
>r,
f>S »oe:j«:e
tuSnt »i:
ir. the »bttn;e cf
't)pyrer,i, CtwSronment»1 CrUirit tni A.ssttrntr.t Offset. C*rcirm«ti. Ohio.
*J Dtn >M3t:.nt ?e* c.'i't nt: -.vt
r\) E'»^ro^n«.^»^ f rc:t:: : i;t*.:> IE;A). 1SSS. Spe:i|1 Reptrt or.
i] Vf.fie: t«r nit-j'.t :»'' Rf:-»; t.O.i fer ?os: «ns 6.0005 fo
j) l«lt£ or. R'C
-------
Table 30
£r:eu lifetime Ctncer Rift ft}
Are-ipe M«.-iifcie
Cue
(t]
Ci-re-.t Sue tie Cr-.r-ticrj
Jr.pes'.ior. e' erjj-.3«z:er (e)
tire:: S.-f«:e £;'. C:r.:t:t (
J:.-:e A-ee 2
5£-C£
H-C3
sr-os
2i-05
3C-06
rser.it. TC£.
vinyl chloride
nenie.
ricnic.
MA
£:J;
$:.-
fiti-e £
<:."-
£:.-
ill"
c. .
. V
c- -
...
k: *
k »i :
(: Tf«
f. I
c * ct .;
e *-e« ?
t A-ec 3
t t-tt I
e ;-t: :£
» f-tt ;:
t t'ti I
t t'tl '.I
t * *c *
: »::':{; 'e t :« *.t:e
: a :.':t:t: f:t ~z~t
.it"; " ' » '*-t ' ' ;.~ .' k
»' : - - > >-* e
n. n. n.
«3£-0£ 6--D5 PC£s' '
«3f-D£ 4£-C£ *e-ij. ?:Ss
«;r- £ 2£-T£ -ier.it. CFAm
«1£- £ «):?£ »e°.ce: ts-.r.; e c^'Ve-.: i;;rst:?' tn«r. tr.e: tr.:>*-, ir. tr.-.i t«:1e (fee Se::ior. (.£.2.3).
it] i-.f.t: e-t- ;t'\ i-t :-.:s: rk ei:ers lifetime ctnser ri»k» ef J£-0£ cr fretter for e»rsin9per)» tr.C
tfttse »-tr i ::;.f'^ ;-e::j c' cr,e cr frttte1.
(e) F;- v:'er;'» »»»:»': ;-tt«-: ' te: *:«-. sc-.fti
sis frs-
nf vjletilei releisef Inte
ir.;;r- { 'j.. '. i'. '-f~! t: '.Vii t'i::-.»:e: »*.' C'-ren ir.ftstif. Arrtticn/? exsrj^res esvle
'K: p::e-:-t".. res.'.: frrr r-j-»:tr- frer ;-;i-.>t:e* thrs.';*- t.'ilemp fe^r-sttipni ir.te incstr ti
-------
of
Table 31
for
for
i (fc)
trpr$.-» ?J »J St, It, Ctf, Cr.
fcr.. Ni. 71. V
I-.*t:: S.-firt^S:-.! Cir.u:: (c):
S:I-:e A-e* 2 «1 «J NA
S;.-st A-t« A t: «) NA
5:.-:e A-t* II «) «1 NA
J;.-:e A-t* i7 <1 «] NA
Se::r*-t C:r.:i:t
$s.-n t-ti t cj »J td
:< A-ti :« .» 'ess t*.t* c-e. c* tie tctt1 etr.:e- riik ii lejj thi*. JE-OE.
N: h:: :i':'. f.t: «-:« -.; :' f* st'e::r: Cf:ir.;;e-.-.: e^ieristis e' e:r,;err, fer S:.T-e Artt
ii »ff :r.t::t: '.r s.-'t:e »:'.
k tc.ii.e'.. "' "r.d". :.-. * ke-.i:-.^r; £j Itf.f:., S: Artims-/. 6* 6**!Uff.; Cr
d! Tit -.'in' ::.-: :::.(' r»:eis V:fe::n« :t-;:f r?i» tt:-e»f-:s tV »i;:'tier,|1 p-s
a- i-.r-i--;.e' r^_, cs.«';; ;f.;t* erf i 7i-/itr Viff.ime . '*r- r-.:-,.:-- ;..;.. ;;.-....;. t: ^f.rs.'*. fc.-
-------
Table 32
RIStt ASSOCIATED VJTK JNSESTJOK Of GROUND WATER
T« KENTUCKY AVENUE VEUWID SITE
CURRENT SITE US: CONATIONS
CWONJ
J NT AXE
%-mt^m f-WM Averse
r$e-ir 2.2EE-C5
chls-c'c-r 3.6SE-DE
tr icf'C-oe'.nene 2.70E-C5
injl er.irr.se 2.77E-OE
TOTA;
C DAILY
(CCJJ
FUutible
l!o3E-04
1.3E--03
2.2SE-05
c Effects:
:e e»idt"e fr
C" ir.ese.jt.t
CANCER
POTENCY
FACTOR (l
[we ij-.t c;
£ vio»nce,
2
C.OOEJ
O.DIJ
2.3
or hum* . ftutf
l)
-J
f
w
62]
62]
P.JT4
UPPERB51
LIFETIME
Average
4.5E-OS
2.3E-08
3.0E-07
C.4E-OE
SE-05
KD EXCESS
CANCER RISK
Plausible
Kjiimjrr,
1.3E-D3 '
6.3E-07
1.5E-05
S.3E-D5
1E-03
- a..
. *oe,ut.e
f.:sr< A£j:c:*T£C y:> msEs^io*- or SROUKC WATER
r""
C.
J
K-KTJ
REN: s
TE
c«>:: DA:
J*.TA<: c:;
CHT"::*.! £»-::*>:
D*:«C>C»S:: :
j>j_j.:....-....e.^.e
(-; 1r7C-A
t*"H""
be*y" "; li,"*.
cey.u"
f ':;-;';
ct-.-or".- v:
ehrar-.jr '.'.'. (»]
ccs< It
H*:(*iese
S A
4
E
£
j
s
7
i
E
""
j-.
E:
52
^
rt
V*
o;
«
f-
e
r
t
£
f
f
*
9*
-55
.r.t
Ei
lit
r*
-C!
. ;£
S-,j
Me
1.
J.
7.
3.
7.
2.
AV-NJE ^:.LriE:0 SITE
USE COKC;TIOKS
iY
\
jsit'ie
X TlTiiTT.
WE-Ci
S:E-52
89: -02
7<:-W
73E-C3
£?£-W
E3I-D:
Rr
:
K
S.
4 .
C '
r
j
r.'
s
CDl:RfD RATIO
OCi:
/«S/*J) *"***Be
ODE-C2 - .7E-04
OC'r*04
ODE-02
00r-03
00: -0«
00: -02
00- -03
r.j-j ] 4r»OC 1.0?E»OC
£
T
:<
.;j
e-si.-,- J.S2E-OS
nicie 'i
tht ; ili/r
tetel ».- > re?
tr»*.4-1 . 2 : : i'lf.'M
t^ic^ 'ir*se"rif,t
»»n*r ikP
u«
KCAKC INC-rx
I
S
;0
{
r
5
i S£c
;-., £
j
^
'
:-e: ic-s »-e 4
3J
p5
2:
^
ss
r
r
-
j
C3
.pe.
05
Ci
?<
^ »
Si
me; te
(
t.
2.
Z
2.
j
3
i
be
54 r .53
DSE-01
B5E-C*
Wi-DJ
43E-0<
i ' -0^
4E--03
1 rr , *
ii-.-i.:
equel
2.
3.
2
7
?.
2
7.
7.
2.
to tottl
HA
OOE-C3
001-04
00: -02
00r-0£
OOE-00
0:1-02
3SE-03
.7£»o:
'.4E-02
.5E-C2
.2E-D1
.3E-03
.4E-02
.OE-03
...
.2E-02
.4E-03
.1E-01
.4E*OC
.OE-D5
.2E-03
.1!-02
ODE-:- i.0£-::
OOE-Ci J.3E-OI.
ZE*O;
Chroriir conient rations
PI
K
1
4
j
7
1
2
1
1
3
S
1
3
1
4
:
3
iL'jitle
ixinurr.
.7E-02
-BE-03
er-OC
.5E-02
.5E-C3
.6E-02
5E-OD
.4E*00
...
OE»00
.5E-02
3E»D3
5E-OD
9E-04
7E-02
7E-01
6£»00
6E-01-
9E-03
minus
-------
Table 33
EriKATic Ex»:s'j?.ES AX:< R:S« ASSOCIATED vmn CHJLWEK AND TEENASERS EXPOSED fr DIRECT
ID PDTttTIA, CARCIW3ENS Jfc SURFACE SOIL AAEA 2
AVENUE WlilFJELD SHE
C«DK:C DAI IT
INTAKE (GDI) VJA
DERMA. AESORrTlON
(mj/kj/bey)
CH'^IHA1 c EXk'*E'^]N; P'T'K'iAl
CARCINOGENIC EFFECTS " ' A,er«je
rier.ic NC
iiiU-i.thylhe».i;?r.ifMV.t 2 er. humer ctutfin.
.
fror. hjmtn studies «ni ides.uiie tvlcience from
s~;nA"c EXS:S:.-.E:
AN: TEEKASERS EXPOSED BT DIRECT COKTAC
JH suRfAcr sen AREA 2
AVEN:- WIUFJE.:
tn-.^JC Di.JlY CHRONIC CAILT
}«'t(.i ',:::} VIA INTK- ;cc: ; V:A
£;!".. A:iJ:"]OK IK::D:N:A: IN-CLSTJON
!r.;'t;/CJ;.) («!'«S/fll..)
^^Bt/L< fJ-"":*,:- F'z.sifie F'lai-siile
WE;:w3:s:: s--:-j *.«-*;e luxnur. »»e-.;e «ex,r.jrr
ti»!r-e:n..'.nt..'.;:-:-j-.i:e ;.E*:-C-r S.64--C7 E.2EF-D? 2.27E-C7
«yr.iir N: KI 7.5SI-C7 2.E.<:-OE
ele-'.uir. N: N: S.4-E-:' 4.7E--Ci
tn*11itsr. 7. IE--:? l.JC-i-SE 7.1ZE-C7 E.E:E-0£
»inc hi KC i.60E-C£ 2.74[-W
IUIAS: INC:X
trrrtruT
DDSE
(nc/Kg/oiy)
2.0E-C2
5.0E-04
3.0E-03
7.0E-CS
2.0E-CJ
AVI
c
J.
3
2
2
CO-.:
CD) :fi"i
!r»je
.6E-0?
.5E-C3
2r -D*
.OE-C2
.££0*
2E-02
!N:»-
) Ri*
Fit.-
K6X
,
t
1.
I
1.
;j
s-.f'e
-,r.jr
C:-Ci
~r .^^
6:-C2
£E-::
4E-C-3
3E-C-3
-------
Table 34
A.K: R:SU ASSOCIATED VITH CKJIME* w: TEASERS DODSED IT DIRECT CWTACT
1C PC7EK71A. CAK:iK>JEKS I* S**ACE SOIL AREA 3
KEKTUCXT AVENJE YELLFIELD SITE
EKJCJLS DHIETTIKi PCTTNTlAi
*C1K;X»EK3C EDICTS
sen 1e
-eincpenie PAni
thy lent chloride
TAL
«ct eileuV.*. Ft-
-------
U) Wr»f *re-.f-.t e' £
Uil f-i:e:'i
"
Table 35
EXPIRES we: RISKS ASSOCIATED VITK CKJLDREK AW TEENASERS EXPOSED er DIRECT CONTACT
7D P07EK71A. CAFCIOsEKS JK SURFACE SOU AREA 4
KfKTiCn AVENUE tfluriElD SITE
CHROK3C DAILY
INTAKE (CDD VIA
D£R«U: A£SW?7JON
S:i5Sfh::1Irrg?l F:TEK*IC *.,.,. '*?£!?
til(2-f.hjV%ex..;Jpv.r4if.e 5.17E-10 1.32E-07
T07AI
C*5NJC DAILY
INTAKE (CDD VIA
INCIDENT A;. INSESTJON
(TI^/KQ/OIV)
Plausible
2. SEE-OS 6. 251 -06
CANCER POTENCY
Evidence]
0.014 [B2]
"Bgjljf
Average
4.3E-1J
4E-11
gjjir
P'ieu'5 it'.e
3.0E-Dr
3E-0?
:« <: Ce-:-;r.;;e-i: £ffe:ti:
ce-:ir>:;e- fcese: or. in»3e;uete evidence fror. hjm«r, stutfies «£ *de;uite evidence fror.
AK: TEEKASERI EXP:SE: er DIRECT CDK:A:T
7c N:s:w;:;K:-i:sj it. S>"A:E «::; .
KlKTLi:^ AV-KJ; WIUF][LD SITE
t-v. KIC Di,.'LV CH59NJ
JK-*«; c:;' V;A INTAKE (
ci'-.i. AS ;;;?:: ON JNCJOENTA;
CKE»cc<..r f-
WN^R:>:»:N
fcii!r-c:^'ne
fi^cie"
Zinc
IMAR: iwrx
KC Krt ei :
R CDI ar.s
:">:
;: -WiC-E A.e-4;e
i.:;:-.:-.|-.r.« i !!-::-
N:
' ' r *~.l t. .
N:
.'.i-.er. -c- -.t--.i--.:i. S»-w'
f.i*. r,:-. :»'.;. ;i:e: te:«.s{ ;e3
f iews-.sle
KiJ 1R.T. A
J.S2E-G7 3
N: i
N: 4
its:"! 1C' *rsj*
nefic me/*, s* 1 1
""*"
S2E-OE
C7E-OS
22E-OS
**i te 6
eonjer.t
IOD'VIA
3N5ESTION
--,
H
e
i
2
« n
ra:
.39E-07
.44E-D5
.00i-0<
e.-ltpibfc.
ier. «*s ne'.
I
(m{
2
2
2
» » "»
):SE
'j/d«>)
OE-02
DE-02
OE-01
rtpsnei (see
CWriNi:
r-'.-rr !^;-"
r "i £ »' J
Ave-aje Kt»-
3.2E-:6 £ :
S.4--C: I
2.1E-0* ;.o
7E-C: *
:'ie
"
f r.
* *'
-:
Table 6-7).
-------
Table 36
tSTiKi*:: W»:£J?.ES AN: RISKS ASSOCIATE: V"K CKIIWE* AND TEENASERS EXPOSED BJ DIRECT CONTACT
*: PCTEN71A. CARCINOGENS IK SU"A:I SCJL AREA js
MNTIOCT AVENJE WlLLFIElD SITE
CARc'jib3ENJc''EFFECTs
Mont o' the if 'e:'.er ct*
C*DN;C DAILY
INTAKE (CD^l VIA'
Avtrtje Ktrimjr:,
CHRON3C DA1LT
INTAKE (CD!) VIA
IK: IDE NT A: 1N3EST10N
Average KtiimjT.
'. fOT Sou'Ct Arte ]J »trf
CANCER PCTEN:T
(ix/if/oey)-!
tvioentt]
W.titti in su^iist
COINED UPFER5DUND
LIFETIME EXCESS
CANCER RJSK
AvtT.Be 7.^e
soils .
TA£:E 6-35
tr:«.i":
KEkTUCtT AVENUE WEli-FlElD SHE
5:2Stt!K'!!:£«'!:-s
cobi It
metel
fiSnurnriSSt*'; F'rs
line
MA2ARD IN3:X
i^sri
(ri:.--»
A,e-a?e
N:
NC
2 .72: -C"
t>:
:::?'VIA
iir{.'ijDS
f^;Se
NC
KC
i.2s:-D£
NC
CHRONIC DAILY
JK-AKE (CD!) VIA
INC;D-.»> A.
(m;'i
Aver«;e
*.:s -DE
l.Or -DE
1.2: -C7
£.3t -05
J^i;SMO^
't'Ot)')
'Jtn'SJ'
1.S2E-C5
3 StI-Ct
l.S£:-0£
2.S2E-W
tw.: 1 hi ;
CD!:RFt R;
DDSE
NA
2.DE-C2
4.DE-03
2.DE-C;
A»e-«je
»
£.£E-0^
1 . OE-D£
2.7E-0<
IE-Oi
Fit
Ke
2
^
j
3D
.' S * * I C
. 1 ff.» rT
»
DE-C2
E:-D:
.::-,.;
I-C:
: tt ot
-------
Table37
EX*SSJ?.ES AKC R:S« ASSOCIATED WITH CHILDREK AN? TEENASERS EXPOSED it DIRECT COKTA:T
10 FC-ahiu;. cA; P:*EK*IA: plausible
tu(2-ethilhti»>);vt^if.e 3.07E-1D l.JOE-07
TOTAL
CK-RDN'.C DAILY
IKTAK! (C03) VIA
INCIDIKHL IK&EST1DN
Average Maximum
1.521-05 8.14E-OB
CAKCER POTENCY
FACTOR (a)
(mj/kg/dayM
[fceign*. of
Evioenie]
0.014 IB2]
CWEINED UPPERBOUK?
L1FET1HI EXCELS
CANCER RISK
Flausifie
Average Haxmjr.
2.6E-11 3.0J-OS
3E-11 St-Oi
it)
Weij-.t c' £»-.se-.:e fsr Ce-cir.sje-i: Effe:t»:
Fr::ti'n r..-.£- t»-tin;je* btse: or> u.»at5uite iv\6enee frerr. huit*r. »tudiet ani adtqutte
EE*>i": ExsC:'.s.Et AKC RISf.! A«S?C1ATEC V!TK CKJLDREK AKO TEEN«ERS EXPOSED BY DIRECT COKTACT
t.S r?"..: . , ^;
,.*.s:h.. ::. :
Zinc
KCAr.: IKC;?
kt, tt't~t".t "a r.:: t.j-',e:'ie
KR Ul a-.: r-ik -,t-. ;j ;. ,t:e:
lvE*>TUCKY AVEKJE ^I.LnE
CH:.:K:: DAILY CHS.OKIC
IK-K: (CDn_y;t IK:AX- ':
"" (^'ij^Wji * "iiS-'ij
f ItL'S it >e
A.e-t;e tu.imjtf A»t-a;t
2.2:-:-Or S.7?:-D7 1.14E-OE
*> 1.351-C7 Kn
K: KC 3.64--OS
1C SJTE
DAILY
ci )_v^t
'OJ v) '
F l»^'S'.t1e
KiX!ff^.
E.10E-C7
1.C2E-D7
1.5EE-W
ne;1 >{^b1e .
a: tor. «tt net
; '
fir rrrru'f
Rt IMn.t
DCSL
(»s/«B'8iy)
2.0J-C2
Kt
2.0E-01
re?r.lei
«!«.
Placsifcle
Average Mtxitnyr.
6.B--C7 7.SE-CJ
1.8E-0* S.4E-0*
«'W 1J-C3
-------
Table 38
«.K: F.ISKS ASS::IATED W:TK CHILD?.!* AN: TEENASERS EXPOSED IY DIRECT CONTACT
T; F:T:>:IA. CA*:]N:-:I« u SEOIK-K-J AREA 2
tfN7u:*Y AVEtiJE VEiLHELD SITE
CH*DK:C DAILY
f
IK*AI;E (CO
DE-.Mi,. AESD
) VIA
J."T30K
CW.OK3C DAILY
JK*A<£ (CD") VIA CWIfiD UPPERED'JK,
INCIDENTAL
(mj/ij/oey) (mj/k
*T*::ALS EX*;!:T:NG *:*EKW;AL Pieusitie
ARCJK:*EN;C E"-:-£
i$(2-e:h>1hexvi:r-.-.Uit-.e
(-cincae'ic PA'.s
CEs
MtMc-aethene
OTAL
itij f-cit: t -..-,< :«
tr.-.r^ . s:^:-.es.
Ave-ese K
1.1EE-DE 3
2 1 ' t - C ' 2
£ EEE-OS 4
;.":£- use: c-.
iNSESTiON CANCER POTENCY LIFETIME EXCESS
;/o«>) FACTOR (i
i) CANCER
,\_i _
R1S<
Pltasifcle [weipr.t of Pleusible
timer, A,ver»je Minuter. CviOence] Averse fUiimjr
.37E-OE
,3sE-0£
4"c-0£
.E3E-OE
.r.eot:.(te
3 4S'-OE
1.11E-07
5.32E-OS
3. IDE-ID
£.72E-07 C.034
6.47E-OE 11. £
2.40E-07 7.7
1.7SE-OS 0.011
[B2J E.5E-3D
621 2.£E-OE
'E2l 4.8E-07
[B2j S.1E-12
3E-OE
£.2E-DE
3.£E-0'
3.6E-05
2.0E-1C
4E-OX
evSri«n-.e fror hjmar. $tuiies tnt (de:»ite evidence frorr.
.
AViNj- Wi.i.?;ElD S!7E
ARIA 2
P.EC1 CONTACT
££m^ 1;iSEiSl;oN
:«CKT:AL! EX-.:::*>;
f it.-j'.sie
pi
e.'j-bie
^CC*.E:
«:... ^
DDSE P leys -.tie
HOKC4nC'NC"3;Ki I E"I": t»t*t:e Kdxir.jrr Ave-Jje Kannurf. ("£/"£/£«.>')
bi-iirr.
6ii(2-et^jlh«T . "];*.t"'» 'ite
C»S-.iiff-
ce-os-. e'iiulf ise
tMnf.r.v 'ir»'hj 'c.e
£i-n*bl'tv*i E".t'.l 'it'C
WCt'-y
nitkt'i
tilve-
t* ict^r-setheie
»inv'i *eii*c
tins
HCASC IK3EX
N
E £5
N
t ::
),
t :-:
7 f:
i .«
2.52
2 '2
3'.EJ
7.17
OE
-OS
.r.s
. -.1
-E-7
-OE
09
-Os
D5
*
N-
2.3EE-Ci
N:
2 S C'E C 7
N:
4 i2r-0£
s':£E-oe
3.52E-05
5.SSE-W
K:
2 "--07
1.22E-C7
l.£3i-06
KC
1.47E-04
2.E2E-C7
3 £E:-0<
2. SEE-OS
E.37£-0£
7.SSE-OS
S .45E-05
£.22E-C7
6.07E-D5
6.E2--07
S.S7E-OE
1.E2--0?
2.33E-0?
4.32E-05
S 4EE-S3
7
4
4
t
i
E
1
4
£
e
E
2
1
1
7
.711-04
.2SE-OE
.3SE-03
.1SE-OE
. TEE -04
.81E-07
.8EE-OE
.24E-OE
.20E-0*
44[-D£
.S3E-0£
f>t: -OE
.32E-OE
.EEE-07
.Wt-02
£
2
£
]
i
1
3
2
4
3
j
7
2
.OE-02
.OE-C2
.OE-CW
.OE-Oi
.OE-03
til
.OE-01
.OE-04
.OE-C2
.01-03
.OE-03
.OE-03
.3E-D3
NA '
-OE-D1
Avertje Ker-.r.j^.
2
1
7
E
1
1
4
4
S
3
j
e
2
.6: -03
.7E-OE
.1E-C3
.EE-DE
.2E-C2
.7E-07
.EE-03
.0:-C3
.5! -06
.3E-D3
.3E-OE
.4E-07
*r ;"'*
BE-03
1.5--02
3 <-::-
E .£-::
3.2E-D:
1.4[-:3
...
1 . 1 E 0*
3 4r-C!
2.E--02
3 7i-tJ
2.3E-C?
8.0E-C7
l.Ei-CE
...
? ?:
IWi
c te be
-------
Table 39
;*:: tx*:su?.n AN: RIS« ASSOCIATE: VITK CKUDRE- we- TEENAJERS EXPOSED er DIRECT CONTACT
1C PwaKllA, CASCltOsEKS IK SJOIMEKTS ARIA 3
KKTICKT AVENUE VEUFIELC SITE
CH*OK;C DAILY CHRONIC DAILY
INTAKE (CD'.) VIA IK'AKI (CD!) VIA
DER"A. AEsW"]ON INCIDENT A; JHSESTION
MEKTC.AI! EX*!E!~IKJ PCTEK'U: PUutible Pltutifcle
CARClNDsiKJC Er'LCTS Ave'tje H*xiirutTi Average h*ximjrr.
WBi 6.8)
'S^'
V.E3E-0«
612EE-C7
:v!3J-OE
1.E2E-OS
£. SU-03
Bf rrcrv't
DOS:
S.OE-02
S'.OE-Oi
S.OE-0*
2.01-02
3.D--03
7.3E-03
i.OE-01
CC*::i
CDl:8f:
1
1.5E-0:
3.31-02
4.6E-03
l'.6E-03
I '.5! -07
5.9E-0*
2E-02
RiV.D
'- le.'S -.
4 '.IE
2 El
1.7:
T'.SE
3.0:
er
:-e
-C2
-02
02
-c;
KC hi1. t»'i;.';f.e:
: tt be
-------
Table 40
Ex?:s'js.Es AN: R:S« ASSC:IATEC w:i« RESIDENTS EXF-OSISE Er DIRECT CONTACT
ID F:TEN:;A; CARCINOGENS IK SURFACE soil AREA 2
KENTUCKY AVENUE VluFlELD SITE
CHRONIC DAILY CHRONIC DAILY
INrA«;s (CC'.MU INTAKE (CD!) VIA
(mj/kg/Oiy) (*>S 'kg/bey)
"W7CALS tXKIE!TjK5 FCTEN'IA. Flausie'ie Plausible
RC1NOSEN3C EFFECTS Average MaxiiRjn Average Mtximinr.
ler.le NC KC t 05E-07 2 DEE-OE
itf-itttflhtijljpnthalate «.«E-!1 2.41E-OE 6.2SE-10 2.S1E-OE
is 2.E21-D- S.SiE-DE 1.15L-OS 3.S9--06
;TAL
tEEj Fr;:it''t f-.j^i- ie-:-.r.sre- btie: or. in»5e;y»ie eviotnte fror. hjmar. stu
E:"1^*;C E>::-J-E: »V'C F.:$< INCIDENTAL IN;E.STION
jNCARClKC'sENlC E:rIC"£ A»e-«:e KIXIRJ-. Avertje K*>«5jr
tis!2-r.nylht»»-;:-:-.iit-.e i.E: -:C J.flE-OE E.lSE-Or 7.27 -OE
eiar.iir. " * Kl *.2EE-C" E
-------
Table 41
EX»:SIREJ AK: RIS« ASSXIATED WITH RESIDENTIAL CPOJIRE IT DIRECT CONTACT
TC PC71KT1A. CAKC1NMENS Id SlR'ACE SOIL AREA J
KENTUCKY AVENUE YiLlFlElD SITE
.&".: :XS Dr::!:*ING PCTEKTIA1
CARCUKiltuC EFFECTS
tUU-e".\» Therv1)pv.lv lite
ethjlent ch \c-ioe
TOTA:
CHRDNi: DAILY
IN-AKI CD!) VIA
DER"X AiSOR?T10N ' IN
Miuilble
A»e"»;e PUtinjr A
NC N: 2
l.lOE-ll 4.SEE-OE 1
1.4E--OS 3.55E-07 I
5.67E-U 2.041-09 1
INTAKE (CDI) VIA -COMBINED IP
CIDEKTA. INSESTION CANCER WTENCY LIFETI*,:
(S/kB/dty) FACTOR (t) CANCER
Mauilblt [ieijr.t of
ver»je Ntitiur. t»io*nee] Aver»gc
.40E-07
.10: -OS
-71E-D9
.60E-10
2
5
c
1
87E-06 2
50E-08 0.014
45E-07 11.5
48E-09 0.0075
A] 4.8E-07
621 1.7E-11
B2l 8.4E-OE
B2j 1.IE-12
6E-07
EXCESS '
Pltusible
lUrirxr,
S
1
1
2
.7E-OE
.4E-05
.2E-05
.6E-11
2E-05
U) UJE'f %'f.s*- e' E»-.oe-.:t fc- C*-;ir,s;e-,it Eff«:ti:
[*' KJV tfi'r.sje- test: c-
[E2J Frti»:'ie +.T.A- ti-;\ns;e-
r..?*'. itucus.
tjrei to be
: o-.
ttudlts.
tvlot'ie frsr
ituilei «ni
tvldente frer.
Erin;": L>.':S^.:.C AK: R:S« ASSO:I*TE: v:Tt-: RESIOEKTIA: tx»cs'jRi BT DIRECT COKTACT
T; KDMA?.::H>;EK£ i* SIF.-X:I SOIL " . AREAS
KiKTiCX* AV-KJ: VE^LFIELD SITE
i c:n VIA
C*SK:C DAILY
IN'AKi (MI) VIA
REFERENCE
DCSE
e«':.i*:e: ft.- >n;-s*'-.:i »>;.«;: wci
denial
«ssx*^ te be
CO«5!NE:
D!:R': RiTJC
3E-03
'i» untie
bftr iujfr.
Bid 2 -et^v Iht X v 'jp^.tTiA «£*£
C*S"'illR
C^rfft.iiff,
cefetV.
d^-^.ti,'t»T t'ir.j'nte
M-.*(Thtte
e*£t'"v
t^'lifn cMt*'.w
tncitl
no^.n^cinsjer it PA-.$
(tit*, iirr
tilvt?
Jinc
E
E
' 1
t
7
N
.7£
K
K
K
.31
"K
.£«
£:
|i
_!»
"ti
K
K
1C
OS
cs
1C
-5£
N:
1.I4E-07
NC
NC
NC
1.45: -07
NC
1.4EE-07
5. 101-09
NC
1.42C-OE
NC
NC
NC
2 EJE-C5
S. 181-05
1.S3E-07
4.2EE-OE
2.6EI-OE
4.E3--OE
J.82E-W
S.3SE-OS
1.J3E-DS
I.6EE-OE
S.SSE-OE
1.33E-C7
2.1JE-07
2.72E-05
C.93E-C5
1.37E-07
C.45E-D7
1.27E-OE
7.83E-OE
2.17E-07
1.E9E-03
l.OEE-07
3.70E-OS
1. 741-05
1.03E-06
2.6D--OE
1.27E-06
8.41E-05
5
2
5
5
1
2
3
6
2
4
j
3
2
OE-02
OE-02
K-W
OE-03
HA
OE-01
OE-C1
OE-W
OE-02
OE-02
OE-01
OE-03
OE-03
OE-01
5
4
2
8
5
S
I
3
4
4
7
1
2E-CK
SE-D7
7E-0<
5E-0<
4E-C7
EE-0<
4E-CE
OE-OE
3r-0^
3E-&7
4E-OS
1E-6S
4E-W
l.BE-:3
1.3E-C-5
1.7E-C3
2.5E-C3
3.7E-OE
C . JI'C3
£
-------
Table 42
triHt": ur:iu--< uc R:SCC ASSOCIATED VHK RESIDEKTJA: EXPOSURE IT DIRECT CONTACT
; FCTihTiA^. CA?.C!NDiJEKS IK SURFACE SOIL AREA 4
KTUCn AVENUE WElLFlELD SITE
rw'CAis rxK'E'Tij; PCTE^JA:
i ( 2-**-f>jr )h*»y 1 ] p-.:ht itte
TAX
CHOKIC DAILY
INTAKE ic::i vu
DER^A. ASSORT J OK
A,ert;e M'S-S?
S.E--E-11 1.15E-07
INTAKE (CDI)'viA
INCIDENTAL 1NGEST10N
Plausible
1.29E-OS 1.39E-07
CANCER POTENCY
FACTOR (a)
[he if*.: of
Evidence]
0.014 [B2]
UFET IK-
CANCER
Average
1.9E-11
2E-11
EXCESS "
RISK
Pltt'S ib'ie
Mirimurr,
3.6E-D?
4E-OS
.t e' E.iot-:« i:- C«-cins;e-.i
[EZj Frc:t:'e rur<- ie-:ir.;:»- &est: o* ir,»3e;jtte evidence fror hunari itudiej «ntf ideQut'.e evidence from
'
-iE f.: ^isrs ASSDCIATE: V:T^ RES'.DEKTJAL EX^C-SI*: s\ DIRECT COKTACT
TC hCKCA.-OC-SEKS IK SJ-rAC: SCI: . AR£i 4
KEKTUCK^ AVEKJE «uri£;D S!T£
;:;t^ k;
i~* i»
":liiri"j*h
IK-AKE i;
INCIDENT A.
ID: ; 'VIA
IKaiSTIDN
S^CA.* IXK:£:T";' "'it.'S^t'ie Plausit'ie
MCARONOsEh'.C l"EC*!
: i ! 2-etf>» 'mex » '. j :: r.e '.i\
icke'i
iicircinofe*.".! FA-S
int
CARD iicrx
*««;«
- t^r.-;
K:
K-
KC
Ktx,r..-
t E"-:7
N:
E.54--C7
KC
Ave-ag*
l.DEE-DI
E.C2E-OE
N-
2.-7E-C5
Kl
3
1
E
1
.171-07
.CSE-C5
.4EI-C7
.12E-04
co«.-:
cr: :R?:
NE:
«-
> t te
DC-SE Fla^sif'e
(r.;,
2
2
^
2
'«B'0.y)
.OE-02
.CE-C2
C" -C1
.OE-D1
Ave-age
J.EE-C7
3.0E-OA
...
1.2E-Oi
4E-Di
fiei
;
:
>
L
.2:
t:
c:
.6-
2E
.r.t «
-D2
cc
-0*
. r,v
TV
R CC1 ai: rijk r.i: it'i.'i-.t: M:t.st jti-^'.-1.: ae«- ic'.'i conif.riticr «es net repsrtei
-------
Table 43
TE: EX^S^ES AK: RISKS ASSOCIATED WITH RESIDEKTIAI EXF-DSURJ IT DIRECT COKTACT
K ?:'EKTU; CARCWSENS H SIR'ACE SOU AREA 4
KEKTlW AVENUi YELLFJELD SITE
vCitosiNic EFFECTS
"»(2-e:.hjlheijr 1 Jev.ht 'it-it
JAl
MRjJMC^DAJLY
Dr.F.Hi*;AESO^T10N
FUjJitle
Averjje mxinum
S.E1E-11 1.15E-07
MONK DAILY
1KUKE (CD1) VIA
INCIDENTAL INuISTlON
(mg/kg/dey)
Av,,.9e %2i'
1.29E-OS 1.J9E-D7
CANCER POTENCY
FACTOR («)
(S/ks/etoyJ-1
C.OM IE2]
COMBINED W
LIFETIME
UNCER
A,,-.Be
1.9E-11
2E-11
:?ER5D'JK:
EXCESS
RISK
'£»«'
3.6E-0?
4E-OS
\ tfcrci U»{A*» <* rL *>*-» **» r>»* ,»-..; ^ r/i*****
BZl frettt'it h.-^- c
' i:-:.es.
ttse: cr. m»st;uett ividcnce fren hjmen ttuiiei »ni »titqu»t« evidence frorr,
:i!K- IK sus.r*:- SCK
K'j:\J-.
:ii:2-e:n»lne*v '.;::.« '.z-.s :.*::-:: 2.E7
'itlie* *<1 N
nD^ctxHntse'.'.c Ftr.s K". J.5<
rine. KC K
HAIAR: iicrx
, . . .
iR Ci: an: r-.i-- r.:*. it'r.'e'.i: se:t^se st"*4.^:
CHROK:: c
os I"::K^.IJ
? Ave.9e fi
-07 l.DE-.-DE 5
I.C2E-06 2
-07 « £
2.S7E-CS 1
A!LY
l.V'*
s.*'1)
tusit'ie
iximyir,
«7--C?
.OS: -OS
.4SE-D7
.J2E-M
-
isr. »ts net
fcrrrsfK""
p;tr
2.01-02
2.0--C2
4.0E-C1
2. 01-01
rest^tei («ee
C WE! NEC
Ctl:R?D Ri'IO
Ave,.5e 'K
S.6t-:7 3 2E-
3.0£-5i :.£-
... j c:.
i.ZE-w V.ii-
4E-0^ 2E-
T»tle 6-75.
F*.
f.
»
»
w'
*,
k1
r.
-------
:: EX?:S'J?.E< AK: RISKS ASSOCIATED VITK RESIDENTIAL EXPOSURE r DIRECT CONTACT
10 FC-EKUA;. uRriKssiKs i* SURFACE son ARIA is
AVENUE WELLFJEL& SHE
. .. CHRDN-C WILY
INTAKE (CD!) VIA INTAKE (CD!) VIA COKE IKED
DERiA. AESW'TION INCIDENTAL IN5ESTION CANCER POTENCY LIFETIME EXCESS
(«5''*j/bey) ("^/kg/bey) FACTOR
ARClNCiSENlC E:?£CTS Avt*a;e Htmius Average Kaxinum tviberce] Average
ane cf the sele::e: circ-.r.ste--.: chemicals ef concert, for Source Arat IS were ott*:tei in surface soils.
ES'J^": Erj:i;F.:i AS: R!S« ASSOCIATED V'.Tf. RES1CEKT1A1 EXPOSURE 8Y DIRECT COKTACT
i: lOKCARCiKc-sEKs IK swrACE so;: AREA is
KEK:UCKY AVENJE wELLTiEiD SITE
WE*!i:fc:s rsi- :*">:
*"*°-A^'ss
csbilt
fllC't'
xin:
MCA" INDEX
O-iRC-s'C DAILY
I'-'A^E ic:: '; VIA
KSi^.*"S>i10K
F'ltusitle
Avf-t;« hi^r-..-
NC N:
K: N;
t £:.».£ £ 71:. *7
K; N:
CKROhJC DAILY
INTAKE (CD:) VIA
INCIDENTAL JNSESTION
Plausible
Ave^tje Kaxiiwr.
2.52E-OE A.et:-OE
E.i2E-:-E I.27E-C:
7 ter.rit { 34r-D7
3.01E-DS 6.0EE-C5
DDSE
(mj/ij/ctyl
NA
2.DE-C2
*.OE-C-1
2.0E-C;
CW::KED%
Fit.-!
Ave.tje He>.
».» .
3 )££ { i
S.3E-:/ 3.E
l.SE-0* ^ C-
ss-w :
tie
* '"
.
-Di
C'
ti
02
Hi Re'ffit ::i« «j: .-.e-s 'e::e.
HI *:: ct';;.'.e-.t: ::- -.:-;* -.:i. oe-^*' ts*:-r:isr. tssjne: t: b«
-------
Table 45
ES'IHATEC EXPIRES AC R!S«C£ ASSOCIATED VJTH RESIDENTIAL EXPOSURE BY DIRECT COK'TACT
1C POTEKT1A. CASC JO-SENS 1* SURFACE SOU ARE* 17
KENTUCKY AVENUE WELLFJELD SITE
C*RC'iib£EMc"EFFE"S
»iiUtth,lht,,1)pW* I,-.,
TOTAL
CHSDKJC DAILY
JK1A>;; (CC!) VIA
DESKA. A5SOR?TIDN
Pliuiible
Averije K*ximjrr.
I.E3E-:i 6.47E-08
* Ci-c-inayeMC £fft:t$:
CHRONIC DAILY
iKCiDENTAi'lisESTJON CANCER POTENCY
Pl«ujiblt fheijr.t of
Average Hatinum Evidence]
7.67E-10 7.62E-06 0.0)4 [62]
COfElNEC LPTR'^UN1^
IIFETJM: EXC£SS "
CANCER RISK
Mtuiifcle
1.2E-11 2. DE-OS
1E-11 2E-D5
££*:«.": £x*:sj-E£ »»: R;S«:£ ASSDCIATE: VITK RESIDEKTJAL EX^OSJ?.; BY DIRE:* CONTACT
TC KONCA:.:!K5'Eh'£ IK SJRFACE S:\ ARE* 17
«K-:U:KY AVENJE WELLHEAD SITE
w*.::t
*CJ|||!]I
fciR:t
6i*f*CI"
xin:
KCAK: i
«: !:
K » wl
c«.s. ,..,Y CK..,s:: DA!,T
]K't<: : ;:' VIA IK-A<; (CD:> VIA
D:;.-.;. A ;::";o>< IN::DEN:A: IK-:ESTIOK
(c.; '» .-o*» ) (n"S/«.; 'se//
r^k't"^; F'lUS'it'ie P iiys'.t'ie
W«.K.. i--:. i Ave-»;e K*xWJ-. Avf-«je taxiiuir
i. 1ie» >'):: ".4 "a'.t *.?r:-lC 2.E2:-C7 C.JSE-OS 1.8H-C7
r'l pr.:r.t'f.e K: 2.2£:-D£ K J.2E--DE
KC KC 2.16E-M £.3
-------
L. W, ^ J. e::ei. Vilue rtpsrtei 1i detected v«1ue.
(dl h*-:ies5-Dt;eM5e-t cr-;te-1cn. A h*riie»s cf 101 nj C*C03/Httr vis
(e) Con:erftf.;r.j i'-e frx »4.-?'es coTle:t»S i:'iili. th< vtlue Jiver. is the chronic lowest obscrvtd
e'fe:t ie»e' (E?A
hi ke« T:rt AVCS «vi : "itflt. the vilut five*, is the Te^ertl chronic AWC (EPA 1986e).
DA Crite-io" ret *( _. .
1C Cher-.ci" net ot'.tr.e: in th>i «»es it i concentritior »bs»e the d«te:tion limn.
NK The jey«f.: f*r «! n:*. Te?:*t«: is this coxtr.'.ritior » j*eiter tMn the
oete-::e: wx-r_- 5t;»jse cne>h*U of the detection limits *f* used in eilculitlng
tht «»-..
-------
Tnhle ' 7
AC.IIONr5PCCIflCJ*«APS._CBITr,R!A AND. GLANCE FOR
V..AVI.NUI, _W.M,MI.LD_SUt
A. toroi.in to All Alterna-
t i VPS
ARARj
OSMA - General Industry Standards (29
UR 1910)
OSHA - Safety and Health Standard* (20
CFR 1926)
OSHA - Record Keeping, Reporting, and
Related Regulations (29 CIR 1904)
Groundwater Protection Strategy
US! PA Policy Statement . August 1904
RCRA - Standard* for Generators of
Ha/ardous Waste (40 CfR 262.1)
RCRA - Standards for Owners/Operators
of Permitted Hatardous Waste facilities
(40 CFR 264.10-264.10)
RCRA - Preparedness and Prevention
(40 Cm 264.30-264.31)
RCRA - Contingency Plan and emergency
Procedures (40 CfR 264.50-264.56)
RCRA - Groundwater protection (40 CFR
264.90-264.109)
RCRA - Miscellaneous Units (40 CfR
264.600-264.999)
RCRA - Closure and Post-Closure (40
264.110-164.120)
RCRA - Land Disposal Restrictions (40 CFR
260)
SIAfUS
Appl ir«tl>le
Applicahte
Applicahle
To Be Considered
Relevant and
Appropriate
Relevant and
Appropriate
Relevant and
Appropriate
Relevant and
Appropriate
Relevant and
Appropriate
Relevant and
Appropriate
Relevant and
Appropriate
Relevant and
Appropriate
Those regulations specify fl-hour time-*elghte«
avnraqp concentrations lor worker eipnsurp (o
various organic compounds. Training requirpim
lor worhprs at hararHous waste operations are
specified in 29 CfR 1910.120.
Ihese regulations specify the type of safety t
mpnt and procedures to be implemented during s
remediation.
This regulation outlines the record keeping ar
porting requirements for an employer under OSt
Identifies groundwater quality to be achieved
remedial actions based on aquifer characteris-
tics and use.
General generator requirements which outline
manifest, recordkeeping, and transporting
requirements.
General facility requirements which outline wa
analysis, security measures, inspection, and
training requirements.
This regulation outlines the requirements for
equipment and spill control.
This regulation outlines the requirements for
emergency procedures to be used following expl
sions, fires, etc.
This regulation outlines requirements for a gr
water monitoring program to be installed at a
site.
These standards are applicable to mlsce'laneou
units not previously defined under existing RC:
regulations for treatment, storage, and dispos
The regulation outlines specific requirements i
closure and post-closure of hazardous waste
management facilities.
The regulation outlines the requirements for Ih
land disposal ol certain hazardous contaminants
Ihpse regulations will be applicable to CCRtlA
and debris, including treatment residuals, as o
November 9. 1990. .
-------
Table 47 conttl.
. CWITUMA ANO cvtnANcc_fOR
KINIUtKY_AVtHWI._Wl.l.llllin_SIli,
RrnrinAI ACTION
fl. Groundwater Treatment
of Treated
Groundwater
ARARj
POT Rules for Transportation of Har.trdotis
Materials (4'i cfR Paris in;, 1/1. i-i/.'.Yi
New Yo'k Hazardous Waste Manifest System
Rules («»NV(.BB 3/2)
New York MararrfniK Wa%le Troalmenl .
Sloraqe »od Disposal latility IVrmillinq
Requirements (6 NYCRR 3/0 an.1 ^^^}
New York Industrial Code Bute *51
(12 NYCRR 753)
National Pollution Discharge
Elimination Sytten Requirenentt (NPOFS)
(10 Cr« 1ZZ.-M and 40 crR 122.41)
NPOTS
(10 CFR 125.100 and 40 CtR 125.104)
(40 Cr» 136.1-136.4)
NY $tat« Pollution Discharge
Elimination System (SPDES)
(6 NYCRR 750)
Applicable
Relevant and
Appropriate
Rplpvanl and
Appropriate
Applicahle
Relevant and
Appropriate
Relevant and
Appropriate
Relevant and
Appropriate
Applicable
This requlatlnn outlines procedures Tor the
parka^irni. label inij. manifesting, and transport
of hazardous materials.
This requlation outlines New York State manifes
requirements.
This regulation outlines general waste facility
and waste analysis requirements, security measu
and inspections and training requirements.
This regulation establishes the notification
requirements for buried pipeline.
Requirements for the Best Available Technology
to control tonic and nonconventional pollutants
of Best Conventional Technology (BCT) for convei
tional pollutants. Technology-based limitation
be determined on a case-by-case basis. Also
outlines monitoring requirements.
Requirements to develop and Implement a Rest
Management Practices program to prevent the reti
of toxic constituents to surface waters.
Addresses approved test methods for waste con-
stituents to be monitored. Outlines requirement
for analytical procedures and quality controls.
Sample preservation procedures, container naterl
and maximum allowable holding times are prescrib
Provides effluent limitations applicable to
discharges to surface waters.
-------
Table 47 contd.
rSPCiClf ItLARARj. CR|»f.R!/V ANO OUIHAfHt
f:r.nrn(Ai,_ ACTION
R.'ir.jrrl icr» of Treated
Snw/\ UnnVrnround Infection Control ((/IT)
HO CfR M/1.1?. M4. H. M4.lh, M4.2JI,
I'M.51. M.5r>. 10 t»« M
leaks and achieve at least a 95X emissioi
reduction.
The NYS general prohibition on air emissions
restricts the emission of air contaminants
associated with particulate matter, fumes, mist
and smoke, among other visible emissions.
The guidelines require the minimization of soil
erosion and sedimentation and describe various
techniques for achieving compliance.
-------
Table /i7 contrl.
ARABS. CRitr.RiA. AND
AVINIJL WUUH.I.I) Slit.
_livu
i'pdpra i
STATUS
rwA Water duality Criteria (WQC) Relevant
!or Protection itf HufMn Health and
,: lifi* Appropriate
federal
«»> «ra r
. ,'diral
RCRA Ma>«i«m.in ho.i 11 h from
pxi'iiMirp In ilrinktncj w^lpr and
iii(|<*^(pd Aquatic origin 9:i6) for protection of public
water systems. The HCLGs are non-enfnrceable
and are set at levels that would result in
no known or anticipated adverse health
effects with adequate margins of safety.
Provide standards for groundwater quality.
Certain contaminant levels are specified.
Provide standards for discharge to
surface waters.
These values were compared to the maximum
delected levpls at thp Kentucky Avenue
Wellfield Site to detprminp necessary treat
ment. Note that WIJC are also relevant and
appropriate for the evaluation of surf
water discharge acceptability.
The promulgated values are included In the
SnWA HCLs (Refer to SDWA below). The
combined standards were compared with
the maximum detected levels at Kentucky
Avenue Wellfield Site to determine the leve
of cleanup. See SDWA below.
Metallic species and organic compounds were
identified in Remedial Investigation. The
SOWA HCls. in conjunction with NY State
Water Quality Standards, HCLs, and guidance
values, were used to select indicator
chemicals and as treatment requirements.
Since the HCLGs are non-enforceable, they a
used as reference values as design points
for the treatment system performance.
The concentrations of metallic and organic
contaminants in groundwater at the Kentucky
Avenue Wellfield Site were compared to these
standards to determine treatment requirement
The concentrations of metallic and organic
contaminants in groundwater at the Kentucky
Avenue Wellfield Site were compared to
these standards to determine treatment
requirements. Discharge water will be treat'
to comply with these levels prior
discharge to a surface body.
-------
T.ible 47 contd.
ARAR5,_cpnrRiA. AW
KINII/tKY AVENUl Ml III ltll»_SHt
RtT.IM AfORV
_.U.VI.L
Now Yorfc
ARAR
New York
ftderal
N«r. York
N. ,- Yo- <
Federal
Amlitpnt W.itpr Quality
.inil CitMif.ioce. Values. Tnchoiral
.mil OpPr.it ions Guidance
(lOCiS) I.I.I. April I.
STATUS
To be con-
tidered
Priniinq V«(i>r Acl (SOWA) Relevant
MAnimnii Conljwiiianl Iwelt (HCl«) and
(10 NVIRR 51 Appropriate
National An*l»nt Air Quality
Sl^ndarcft (NAAQS)
(10 t»R "if »
York S(*t« Air Gulrf« 1, 7/flfi Applicable
RCQU I Rrnr.Nt SYNOPSIS
Air Cleanup Criteria
Alr/Superfund National
Technical Guidance Study
Series
Prnvji|i> O
(or i|i niindv.it pr c)u.ilily unit
1pvi»1* of orqanlc
and metals in drinking water
at-lhe-lap.
To be con-
sidered
To be con-
sidered
provide acceptable limits
for participate matter, sulfur dioxide.
nitrogen dioxide, carbon monoxide, o»one,
and Ipad that must not be exceeded in
ambient air.
This guidance provides acceptable ambient See above.
levels of volatile contaminants in emissions
from all sources. Thp acceptable ambient
levels for I>CC and TCC are 1116 and
900 ug/m', respectively.
Provides guidance values for emslsslon
release.
The roncenlrat ion of metallic and organic
to contaminants in the grntindwatpr at the
Kentucky Avenue Wei I Meld Site were comparee
to these standards to determine requirement1
Discharge water will be treated to thf
levels prior to discharge to a surface bod*.
The MCLs were used to determine necessary
cleanup levels for groundwater at the
Kentucky Avenue Wellfield Site.
Remediation technologies that could
release contaminants to the air will be
designed to meet these standards.
-------
_
_suiu>cE_wAj.r;R^RARi_r_0^
MCU_(ug/U
Organ icj
1.1,1 Trlehloroethane
T-1.2 Dlch1or
THchloroetheni?
Vinyl Chloride
Inorganics
Antimony
Arsenic
JlaHum
Beryllluw
Cadmlu-i
Vhrnmtu*
Cobalt
tanganv.se
.zrcur,
ticket
VanadW*
i.lnc
10
SO<->
5
-------
Table AR
KrnniriCY /ivtNiir uriiririn 51 tr
r.iiM
TOM
Total
Cnpltnl Cost
HTM-i», Htn ?A MnM-rn-rr,
llmltwl Action P«»m nnrl tn'nt
NoAclInn Unt^r-ll--.* Krnt. Avrrum
Altrrnntlvr tr*«< »ct lorw WHIflHH
Ml.too t55.?oo ?h) ti.nn9.9nn 3n>
?r) tl. 43-i. 400 3h)
?d) ti.7n3.3nn so
?o ti,65n.?nn
HIM-3A-3H
fimp ni«rl Irr.Tt
Of CMimkintrr nt
SoiMhrrn HorHrr
of Sitif
tS. 337.100
t6. 116. 100
t7. 366. 700
HOH-tA-tC
r«»ip nnd Trent
rirmnrfuntpr nt
two Mnr« of
fxtrncttoo Wells
tn) VI.5U.500 5n)
th) t7.W1.400 5b)
tc) tlO.541,900 5O
HTM-5A-5C
P|HT> f»"rl Tr«*nt
r.rwinrfwutrr
Downqrndirnt
of Wrstlrtijhoose
1839,600
-«1.09?,000
tl, 016,600
Anminl
imrl Hr>inlrnnncp
,!nd Cost
t549,700
t5°o.noo
t6io.3no
t603.500
t645.700
t665.300
3*)
3b)
30
tl
tl
tl
,578. 700 4n>
,677.100 tb)
.878.700
50
tS55,«00
378.600
1388.900
30
M15.300
M29.100 ?b)
71)
t?. 137.000 3»)
tlO.Ont.TnO 3b)
t10.66A.7nn 3c)
tio.tn5.6oo
1 11,450. 30(1
tl?. 004. 400
t?6.654.600
t?8.«03.800
t33,561.800
tc)
135.9?t,400 5b)
ttO.613.900 5c)
t5.8?6.300
t6.370.600
t6. 466, 300
-------
APPENDIX 2
-------
STUDY AREA MAP
Figure 1
60JNDARY
-------
J. *-«m WELLS
LI Hlitl 83UT" OF Me CAINS I LVD
ooo
<<''L'»5 oc u>: YE* = = WOOD--. BASE FLOOD
ELEvATiOS'S AS: rtOOS HAZARD FACTORS
DETERMINED.
A=£i,S Or 5D: YEAS FLOOD; BASE FLOOD
E.EVA.T,O>,£ A.ND FLOOD HAZARD FACTORS
DETERMINED.
yt.s».3EWEST A3ENDY (SEPTEMBER 1686)
U.S. E.NVSRDKMEKTA. PfiDTECTION
AVEN'JE K£LLci = LD b.T£
10C YEAR Aj;~- 6DC- YEAR
FtO'CD F-.AIN
-------
$:Tl
NYSStC-tl-l
LESEND:
MPA.M.TINO *OIL:
MYSOEC
DESIGNATED WEUMC
(REFtRENCE. NOTES iEtOW)
WILU»
\*> MILES SOUTH
OF bto CAINS 8LVD
ENVIR5NMEKTAL PROTECTION
AGENCY
LOCATIONS Or
A»D POORLY DRAINED SOILS
Crt
m
O
H
6
-------
Figure
r(jj£%$$$&-^^:£
*.
MVD»D3EDLOGr OF THE
.'TES IN THE ElMIRA AREA.
CH-MJN5 COUNTY, N.Y.
CONTOUB
AND FLOW D:=ECTOS IFEST MSLI
a' CW-,25'*;*I;VH
EB ELEVATIONS
JANUARY 19, 198D
-------
Figure 5
L'SiS C^EK »!.£ *E»3*T 12-110
C
£.
, N.Y.
VVBftx'l**:!*
Attt»MJ^
-^s=3P.s FOP. wsoec un.
C1
TO* :
C T
j^r 'x ^fjr!fr'
>£M^&£tS^:
u.i ENV.-S,.EK-». Ht^w^ri V^'--:^--
-------
Figure 6
U.S. EN'VJRONU=NTAL PROTECTION
S»TS
TCr DiSTRIBUTlO.i'
eta
ULUVtK
-------
Figure~Z_
BOH AJUU.TTJOU MS11TS T*y. tWiUS OT
WTLiS IK THE FlSKESVIliT AUA
MM»;.X«C or »/3t/tt
A. i:i: Hcrie>>ei£i>Bic TJitl *o»«
B. KinfMn To:: H:rtttnit-Bi5 ri»t» Re*£
C. A'jte litrtric Ice. Bcr«tht«4i-»ie
riit* SD»J
t. Lerer.z:'( Kcttiurtst KB fl
Z. 143! K-ekcr? Crc»« IS.
r. }£K $tir* Roifl
C. D»3vrrl» A«»k«'» '
cf
B. rir.tr.tt Se«ttvri
J- iSH Ee«r« Keti
J. 12C K±-i»V.>-.-
Picbtrrilit 4
rittt *o»B 7
K. 133£ Krrie.Veii»-Bic fjitf
A. J2£: K:rie.kn:i-B:t Tittt «
1. Kine.'.eeft A^tsn:ti*e Star*
ricii e;tck
(i) iHc tfet*rt«i 1 uj/J l,}-«icb}erettbiBC
(ii) »:»c Ce-.ertei } v;/: 1,1-4- ch.:ero«tb«n«
3 ug/1 1,3-fi:chloroetb§n»
1 vf/1 ci(-1.2-eichlorottb»ae
Cc.-.rert.-iticr.t er;reocf in ng/L
ef K»«)tb (BOH)
.CW3S?X;
'CW3DJS
^x
2000
4000
SCALE
000 FT
J.EGEND;
TR)C CONTOURS
(FT MSL)» FOR 1932-196B
© GRDUNDWATER SAMPJN3
LOCATION (DCH 1589)
f-scu^CE: y;:.??. «,ez v?33 c*?-\ -;LE REPORT .;., ;;,
bi'-rr:.eO:0'JY OF THE VALLEY-FILL AOUIFEft
. ^ ''^ ^-^e-1_ *C.E*.CH£M.JKG COUNTY.K.Y.
US. ENVIRONMENTAL PRO:
AGENCY
KENTUCKY AVENUE WELLFI2LD
DEPARTMENT OF HEALTH (Fi$'.WiLt.'?!
GROUND/rATER SAMPLING LOCATIONS
WITH TCE CONCENTRATIONS
-------
MAGNESIUM CHIP
BURIAL AHEA
INDIcP
MW-tS
FLUORIDE
DISPOSAL AREAS
CONRAIL HAILROAO
LEGEND:
SURFACE WATER SAMPLE
ON-SITE SUPPLY WELL
ON-SITE MONITOHIMO WELL
tS-SHALLOW. 0-OtEPI
DAMES ft MOORE BORINQ
IACPHOKIMAIEI
HEPROOUCEO
FIGURE It
CONCENTRATION (ppbl
IN WAIER. MARCH. 1t8t
(OEqiONATEO AS NO WHERE
NOT DETECTE
«TCE» DISTRIBUTION
100 tOO 300 400
ISOPLETH Ippbl
100 TCE CONCEN
«r*ir IN FFFT
-------
Figure Q
tE ELEVATIONS.
IT 0 T
ASSCC. (HID
Areas investigated by EPA during the Supplemental RI
?. Cb~;.:-jng County Department of Highways Garage
3. - Old Korseheads Landfill
4. - Sand and Gravel Pit
15.- Koppers Cor.pany Disposal Area
16.- 'Kcpr-.-:rE Cor.-ipi'iiy Lajoon Area
17. - Koppers Company Storage Area
18. - Fill Area
VS
-------
Figure 10
(TKttT
NtG" ICMOOL
KENTUCKY AVENJE WELL^IELD SITE
zi W*TE*/SE»MEKT RESJLTS-
:«U: SAI
t.- USB;
i*c
-------
Fl p,«iro 1 I
tT*f«M
ron
H CONTAINS THE SFPFS
U9. ENVIRONMEMTAL PnOTECTIOM
AGENCY
KENTUCKY AVENUE YfELLHELD SITE
SUflfACE
;Tmc conr.
-------
nitOUNWAfRR TKRATMENT PROCESS I (SIN.
Figure II
STRIPPER
t
COM re tii -.1
1ANK
1 " ''
PUMP
Ml IMA
'Mill?
.-- .
* '
rwor.i «;;
IMIIH
j.
f:f (If AMU/
Alt?
r.mipPiH
fMCKWASH
StrtRNAIAMf
ClARlTlfR
-Q
/«r? rn.nwr.n
WIAtrn
r.i IMP
(Ji/r : i
_!
Slff'f RNATAW
SIMP
PI IMC
siimct
riLITR
It IMP
CAMIMIN
W.r.iwrir.r to
TO nnr.iumr
on niiKiiciKiN
WSCMAROU
It IMP
siumx CAKC
ruin/Mr
-------
APPENDIX 3
-------
New York State Department of Environmental Conservation
Wolf Road, Albany, New York 12233
Thomas C. Jortlng
Commissioner
Mr. Richard L. Caspe, P.E. SEP 2 7 1990
Director, Emergency and Remedial
Response Division
U.S. Environmental Protection Agency
26 Federal Plaza
Room 737
New York, New York 10278
Re: Kentucky Avenue Well field Site, Chemung County,
Site No. 808012, Record of Decision
Dear Mr. Caspe:
The purpose of this letter is to confirm the New York State Department of
Environmental Conservation's concurrence with USEPA's Record of Decision (ROD)
for the Kentucky Avenue Wellfield NPL site in Hor&eheads, New York. The
selected interim remedial measure will restore an important public water
supply and will make some progress in restoring the Newtown Creek Aquifer.
As mentioned in the ROD, the problem of sediment contamination in the unnamed"
drainageway and pond near the Old Horseheads Landfill remains unaddressed by
this interim remedial measure. The NYSDEC fully supports USEPA's efforts to
include evaluation of this problem in the upcoming investigation of the
Westinghouse facility.
The NYSDEC also has concerns about New York State potentially assuming the
operations and maintenance expenses of the groundwater treatment system. It
is requested that strong efforts be made by EPA to have the responsible party
assume this expense.
Sincerely,
Sul
Deputy Commissioner
GC/kk
TOTAL P.02
-------
APPENDIX 4
-------
FINAL RESPONSIVENESS SUMMARY
KENTUCKY AVENUE WELLFIELD SITE
CHEMUNG COUNTY, NEW YORK
SEPTEMBER 1990
-------
FINAL RESPONSIVENESS SUMMARY
KENTUCKY AVENUE WELLFIELD SITE
CHEMUNG COUNTY, NEW YORK
TABLE OF CONTENTS
Subject Page
INTRODUCTION 1
I. RESPONSIVENESS SUMMARY OVERVIEW 3
A. Site Description 3
B. Site Activities 3
C. Summary of Preferred Remedial Alternatives 5
II. BACKGROUND ON COMMUNITY INVOLVEMENT AND CONCERNS 6
III. COMPREHESNIVE SUMMARY OF MAJOR QUESTIONS,
COMMENTS CONCERNS AND RESPONSES 7
A. Health and Safety 7
B. Draft Supplemental Remedial Investigation 8
C. Contamination Problem at Sullivan Street
Well 9
D. EPA's Proposed Plan 10
E. Investigation at Old Horseheads Landfill 11
F. Investigation at LRC Electronics, Inc.
Facility 12
G. Proposed Cleanup Schedule 12
APPENDICES
APPENDIX A:
APPENDIX B:
APPENDIX C:
APPENDIX D:
APPENDIX E:
APPENDIX F:
APPENDIX G:
Proposed Plan
Public Notice which appeared in the
Elmira Star-Gazette on July 21, 1990 to inform the
local community about the public meeting held
at the Town of Horseheads Town Hall,
Town of Horseheads, New York, on August 1, 1990
Public Meeting Agenda
Public Meeting Sign-In Sheets
Information Repositories which contain
technical and informational documents
pertaining to the Site
Written comments from the general public a."d
Elmira Water Board, and EPA's responses
Written comments from Westinghouse Corporation and
EPA's responses
-------
FINAL RESPONSIVENESS SUMMARY
KENTUCKY AVENUE WELLFIELD SITE
CHEMUNG COUNTY, NEW YORK
This Final Responsiveness Summary provides a summary of citizen's
comments and concerns, and the U.S. Environmental Protection
Agency's (EPA) responses to those comments and concerns, related
to the Supplemental Remedial Investigation/Feasibility Study
(RI/FS) and Proposed Plan for cleaning up and minimizing
migration of contaminated ground water associated with the
Kentucky Avenue Wellfield Superfund site ("the Site") in Chemung
County, New York. All comments received during the designated
public comment period and summarized in this document will be
considered in EPA's final selection of the remedial
alternative(s) for cleanup of the Site.
EPA held a public comment period from July 21, 1990 through
September 18, 1990 for interested parties to comment on the
Supplemental RI/FS and Proposed Plan. Although the public
comment period was originally scheduled to end on August 19,
1990, EPA extended it to September 18, 1990 at the request of an
interested party.
During the public comment period, EPA held a public meeting to
present the results of the Supplemental RI, describe the remedial
alternatives evaluated in the Supplemental FS, and to present
EPA's and the New York State Department of Environmental
Conservation's (NYSDEC) Proposed Plan for cleaning up the Site.
The meeting was held on August 1, 1990 in the Town of Horseheads
Town Hall, Town of Horseheads, New York.
In general, public comment during the public meeting was positive
as evidenced by the lack of criticism for EPA's Proposed Plan and
public encouragement to expedite cleanup of the Site. There was
some concern, however, about the health and safety of residents
growing vegetable gardens in the site area. Several residents
were also concerned about trace contamination detected in the
Sullivan Street Well and how long it would take to design and
construct an extraction and treatment system at the Sullivan
Street Well. In addition, residents expressed concern about the
length of time that the cleanup process has taken in the past,
and the length of time the proposed cleanup would take.
Residents said that they want all cleanup activities to be
implemented on an expedited basis. Additionally, a resident
expressed concern about contamination found in the Old HorsehtiuUi
Landfill, and has witnessed drums being dumped at the landfill in
the past. Several residents expressed interest in the
investigations being conducted at the Westinghouse Corporation,
LRC Electronics, Inc. and Facet Industries facilities.
-------
This Responsiveness Summary is organized into three sections and
appendices; each of these sections is described briefly below:
I. RESPONSIVENESS SUMMARY OVERVIEW
This section briefly describes the background of the Site and
outlines the proposed remedial alternatives for the Site.
IX. BACKGROUND ON COMMUNITY INVOLVEMENT AND CONCERNS
This section provides a brief history of community interest and
concerns regarding the site.
III. COMPREHENSIVE SUMMARY OF MAJOR QUESTIONS, COMMENTS, CONCERNS
AND RESPONSES
This section summarizes comments submitted to EPA by citizens at
the public meeting during the public comment period, and EPA's
responses to these comments.
APPENDICES
There are seven appendices attached to this document. They are
as follows:
APPENDIX A: Proposed Plan;
APPENDIX B: Public Notice which appeared in the Elmira
Star-Gazette on July 21, 1990 to inform the local
community about the public meeting held at the Town of
Horseheads Town Hall, Town of Horseheads, New York, on
August 1, 1990;
APPENDIX C: Public Meeting Agenda;
APPENDIX D: Public Meeting Sign-In Sheets;
APPENDIX E: A list of information repositories which
contain technical and informational documents
pertaining to the Site;
APPENDIX F: Written comments from the general public and
Elmira Water Board, and EPA's responses; and
APPENDIX G: Written comments from Westinghouse Corporation
and EPA's responses.
-------
I. RESPONSIVENESS SUMMARY OVERVIEW
A. SITE DESCRIPTION
The Kentucky Avenue Wellfield is located in the Town of
Horseheads in Chemung County, New York. The Kentucky Avenue Well
is located east of New York (NY) Route 14 and approximately one
mile south of the intersection of NY Routes 14 and 17. The Site
includes the wellfield, the contaminated ground water plume, and
the source areas. A site map can be found in the Proposed Plan,
which is attached as Appendix A.
The Kentucky Avenue Wellfield consists of three test wells and
one production well (the Kentucky Avenue Well) and overlies its
source, the Newtown Creek Aquifer. The Kentucky Avenue Well,
part of the Elmira Water Board (EWB) public water supply system,
was constructed in 1962 to provide a 1.0 million gallon per day
water supply to a food processing plant which has since closed.
In 1980, the Kentucky Avenue Well was closed due to
trichloroethylene (TCE) contamination.
B. SITE ACTIVITIES
The Site was placed on the National Priorities List (NPL) in
September 1983 as a result of investigations by the New York
State Department of Health (NYSDOH) and the Chemung County Health
Department (CCHD) which found TCE contamination in the Kentucky
Avenue Well and the wells of several residences and commercial
facilities. The results of subsequent residential well sampling
by EPA, NYSDEC and CCHD detected the presence of TCE, other
volatile organic compounds (VOCs) and inorganic compounds.
Subsequently, EPA connected 49 residential homes with private
drinking water wells to the public water supply.
In 1985, EPA funded and NYSDEC conducted an RI/FS at the Site in
order to identify the extent of the ground water contamination in
the Newtown Creek Aquifer. Based on the results of the RI/FS and
consideration of public comments and community concerns, EPA
signed a Record of Decision (ROD) on September 30, 1986.
As a result of the 1986 ROD, 44 additional residences have been
connected to a public water supply and two residences have
refused connection. In addition, EPA entered into a cooperative
agreement with NYSDEC to install strategically-placed monitoring
wells upgradient of the Sullivan Street Well, another public
water supply providing approximately 30% of the water supply to
EWB. In 1988, samples from the Sullivan Street Well revealed TCE
concentrations above 5 parts per billion (ppb), the maximum
contaminant level permitted in a public water supply.
Subsequently, EPA published an Explanation of Significant
Difference announcing an additional remedial action to be
undertaken at the Site, namely the design and construction of an
-------
air stripper at the Sullivan Street Well.
Additionally, the 1986 ROD called for a supplemental source
control RI/FS (Draft Supplemental RI/FS) to identify sources of
contamination and to determine which, if any, source control
measures would be feasible. This Draft Supplemental RI/FS was
completed in July 1990.
The results of EPA's Draft Supplemental RI/FS activities
indicated the following contamination problems:
Ground water contamination within the Newtown
Creek Aquifer is widespread and extends well
beyond the Kentucky Avenue Wellfield. The
ground water is contaminated with TCE and
inorganic compounds. The most widespread
contaminant detected in the ground water is
TCE.
The Westinghouse Corporation facility, Facet
Enterprises facility and LRC Electronics,
Inc. facility are all contributory sources to
the ground water contamination.
Chemical analysis of soil and ground water samples
collected from six other potential source areas
indicate that these areas do not contribute to the
ground water contamination.
Accumulation of heavy metals has occurred in the
drainageway south of the Westinghouse Corporation
property.
Elevated levels of TCE and 1,1,1-
trichloroethane (1,1,1-TCA) were detected in
a monitoring well at the Horseheads
Automotive Junkyard, and elevated chromium
levels were detected in the ground water
located between the Horseheads Automotive
Junkyard and the Westinghouse facility.
Elevated levels of polychlorinated biphenyls
(PCBs) were found in the soil beneath the Old
Horseheads Landfill.
-------
C. jgUXKARY OF PREFE1
EPA's selection for cleanup of the Site will be based on the
requirements of the Comprehensive Environmental Response,
Compensation, and Liability Act (CERCLA) as attended by the
Superfund Amendments and Reauthorization Act (SARA) . These
regulations require that a selected site remedy be protective of
human health and the environment, cost effective and in
accordance with other statutory requirements. Current EPA policy
also emphasizes permanent solutions incorporating on-site
remediation of hazardous waste contamination whenever possible.
Final selection of a remedial alternative(s) will be documented
in the ROD only after consideration of all comments received by
the EPA during the public comment period are addressed in this
Responsiveness Summary. The remedial alternatives evaluated in
the FS are summarized in the Proposed Plan attached as Appendix A
Of this document.
The goal of this interim remedial action is to restore the
Kentucky Avenue Well and to halt the spread of ground water
contamination within the Kewtown Creek Aquifer. Also, this
action will permit the collection of data on aquifer and
contsr.inanz response to remediation measures. After careful
consideration of all reasonable alternatives and the evaluation
criteria, EFA recommends both alternatives described below.
K*r;«g«stnt of Migration (MCK) - 2B
PU££ia? Kentucky Avenue well/riltretion/Air Stripping/Discharge
to the DrinXin? ffater Supply
Construction Period: 2 yrs.
Ijr.pier-entation Period: 30 yrs.
Capital Costs: $1,089,000
Annual Operation and
Maintenance (O&M) Costs: $550,000 (30 yrs)
Present Worth Cost: $9,100,000*
rt ₯cr^h ie the amount of money ZPA would have to invest now at a
.-.:.> of 5% ir'-erest in crcier to h-v/e the e>proj.ri«*e fund" evaii4b.ls
!/?« tlna rere-Jial action it. i-
-------
MOM - 5A
Pumping Dovugradient of Westinghouse Facility/Filtration/Air
Stripping/Discharge to Either Public Water Supply or Surface
Water
Construction Period:
Implementation Period:
Capital Costs:
O&M Costs:
Present Worth Cost:
2 yrs.
30 yrs. for affected area
53 yrs. for complete remediation
dovmgradient of extraction
by natural attenuation
$840,000
$356,000 (30 yrs.)
$5,800,000
These alternatives involve extracting, or pumping, the ground
water; filtering it to remove metals in suspended solids;
treating the water to remove VOCs; and discharging the water to
the public water supply or to surface water. Well extraction, or
collection systems, may consist of a line or circle of wells
placed around the contaminated area or in the direction of
contaminated ground water flow. The well system limits migration
by pumping. Pumping delivers the ground water to the surface
where it is treated to remove contaminants. The proposed
treatment system is air stripping, which removes, or "strips"
VOCs from contaminated ground water or surface water by forcing
an air stream through the water and causing the compounds to
evaporate.
II. BACKGROUND ON COMMUNITY INVOLVEMENT AND CONCERNS
Community awareness of the contamination in the Horseheads area
began as a result of newspaper articles describing the well
sampling program conducted by NYSDOH in 1980. Residents were
further informed about the contamination when the CCHD sent
letters to residents in the affected area that described the
result of its sampling program. The CCHD letters made
recommendations for each residence based on the level of
contamination found in the residential wells. These
recommendations included connections to the public water supply
if contamination levels exceeded NYSDOH ground water quality
guidelines, or, remaining on residential wells if contamination
levels were below these guidelines. The CCHD letter also
provided information on public health risks from consumption and
iuss of the residential wells.
Ccr^ur.lt..j< concur:, about health effects from contaminated
residential wells increased as a result of the CCHD letters and
several residents in the affected area made connections to the
public water supplies based on CCHD recommendations.
Subsequently, concerns lisclpate.d t ' a low level because
-------
residents felt that the connections had resolved the
contamination problems.
On September 17, 1986, EPA held a public meeting in the Town of
Horseheads to discuss the findings and recommendations based on
the 1986 RI/FS. Approximately 20 residents attended that
meeting. Concerns raised at the meeting included reimbursements .
for the connections made by residents, the future use of the
Kentucky Avenue Well, whether or not future sampling and
monitoring would be conducted in the area, and identification of
contamination sources. Public comments and questions received
during the meeting and three week public comment period were
included and considered in EPA's 1986 ROD.
Community concerns have also been expressed by several residents
over the last few years who have written letters and made phone
calls to EPA, NYSDEC and local officials.
III. COMPREHENSIVE SUMMARY OF MAJOR QUESTIONS, COMMENTS, CONCERNS
AND RESPONSES
Comments raised at the public meeting during the public comment
period for the Site and EPA's responses to them are summarized
below. EPA announced the commencement of the public comment
period in a public notice which was printed in the Elmira Star-
Gazette newspaper on July 21, 1990. The public comment period
was held from July 21, 1990 through September 18, 1990 to receive
comments from the public on EPA's Draft Supplemental RI/FS and
Proposed Plan for the Site. The comments received by EPA during
the public meeting are organized into the following categories:
01
A. Health and Safety;
B. Draft Supplemental Remedial Investigation;
C. Contamination Problem at Sullivan Street Well;
D. EPA's Proposed Plan;
E. Investigation at Old Horseheads Landfill;
F. Investigation at LRC Electronics, Inc. Facility; and
G. Proposed Cleanup Schedule.
Additional written questions, comments and concerns received
during the public comment period, and EPA's responses, are
attached as Appendices F and G.
A. HEALTH AMD SAFETY
Comment: A representative from the CCHD commented that EPA said
if anyone p------:t at. thp rioting knew of a resident in the Site
area who was not hooked up to the public water supply should
encourage the resident to do so. The representative asked
whether or not the map in the Proposed Plan outlines the area in
question. Ha cctMnented that the map in the Proposer. Plan extends
-------
farther than was originally surveyed.
EPA Response: Yes, the map in the Proposed Plan is the one that
EPA is referring to when it encourages residents in the Site area
to switch to the public water supply.
Comment: A resident asked if there was any possibility of
ingesting contaminants by eating vegetables grown in the soil.
EPA Response: The contaminated ground water away from source
areas is believed to be too deep below the ground surface to be
the water supply for vegetation. Therefore, the ground water is
not contaminating vegetable gardens. Based on the results of
EPA's Risk Assessment, an analysis conducted to estimate the
health or environmental problems that could result if the ground
water contamination at the Site was not cleaned up, the risks at
the Site are from drinking untreated ground water. For that
reason, EPA encourages anyone in the area who has a private well
to switch to the public water supply.
Comment: A resident commented that EPA had also found organic
compounds in the soil and ground water. The resident asked if
EPA had considered the toxic effects of metal uptake through the
ground water or through gardens growing in contaminated soil.
EPA Response: EPA responded that yes, it did consider the
effects of contamination by heavy metals in ground water and has
proposed the construction of a filtration plant to eliminate the
metals from the ground water as part of the Proposed Plan.
Similarly, there is no risk of metal uptake from the soil by
vegetable gardens because the contaminated soils are located in
the industrial sites, not in residential areas.
B. DRAFT SUPPLEMENTAL REMEDIAL INVESTIGATION
Comment: A resident asked how far below the surface the ground
water was, and what was the deepest monitoring well that EPA
sampled from.
EPA Response: EPA responded that the data it collected during
the RI indicates that the ground water is approximately 15-25
feet below the giv/.-.:d ..-.ullage. The monitoring wells installed to
sample ground water varied in depth, ranging from shallow wells
of 15-20 feet, to
-------
Comment: A resident asked whether EPA had analyzed the age of
the material found at the Westinghouse permitted discharge
outfalls.
EPA Response: EPA responded that no, it did not analyze the age
of the material found at the Westinghouse permitted discharge
outfalls.
Comment: A representative of the EWB asked if there were any
investigations being conducted at the Westinghouse Corporation
facility.
EPA Response: EPA responded that the Westinghouse Corporation
facility is undergoing an investigation under a different federal
authority. This investigation will be completed and the findings
will be made public within two years.
Comment: A resident asked if EPA had conducted soil sampling in
residential neighborhoods.
EPA Response: EPA answered that no, it did not conduct soil
sampling in residential neighborhoods. After carefully
considering area photographs and past practices in the Town of
Horseheads area, EPA found no indication that industrial or
disposal activity had occurred in the residential neighborhoods.
EPA focused the sampling on areas where industrial or disposal
activity may have occurred in the past.
C. CONTAMINATION PROBLEM AT SULLIVAN STREET WELL
Comment: A resident asked how this Draft Supplemental RI/FS and
Proposed Plan related to the contamination found at the Sullivan
Street Well. Also, the commentor asked if Facet Industries could
potentially be contributing to the contamination at the Sullivan
Street Well, especially in light of the fact that it is located
downstream of the Kentucky Avenue Wellfield but upstream of the
Sullivan Street Well. The commentor also asked how long it would
take to implement the Proposed Plan for the Site.
EPA Response: EPA explained that it has committed to building an
air stripper at the Sullivan Street Well to reduce the
contamination level to below federal and state mandated drinking
water levels. This difference xrora \,ne original remedy selected
in the 1986 ROD was announced to the public via an Explanation of
Significant Difference whicn '.;_- i/Ui?Iishe£ .Li the Elmira Star-
Gazette on April 20, 23 and 24, 1990. Presently, EPA is in the
process of procuring funds and resources to design and build the
treatment system.
-------
With regard to the Facet Industries, Inc. facility, Facet is
conducting an ongoing RI/FS on their site under EPA's oversight.
The results of that study should indicate to what extent Facet
Industries, Inc. is contributing to the contamination of the
Newtown Creek Aquifer.
As for the Proposed Plan for the Site, the remedial design and
remedial action will take approximately three years to design and
construct the treatment system, and thirty years for the actual
remediation effort.
Comment: A representative from the EWB asked for the status of
installing an air stripper at the Sullivan Street Well, and
whether there was any possibility of 1991 being a target date for
implementation of the air stripper.
EPA Response: EPA explained that it is working on obtaining
funding for the air stripping system at the Sullivan Street Well.
Once funding has been approved, EPA believes that it can design
and construct the air stripper, with the help of the EWB, in
approximately six weeks, and construct it in approximately three
months. If funding and contractual requirements proceed without
difficulty, it may be possible to construct the air stripper
during 1991.
D. EPA'S PROPOSED PLAN
Comment: A representative of the EWB asked for the pumping rate
of the proposed extraction and treatment system for the Site.
EPA Response: The proposed extraction and treatment system for
the Site has a total pumping rate of approximately 140 gallons
per minute. This is in addition to 700 gpm proposed for the
Kentucky Avenue Well.
Comment: A representative of the EWB commented that the Proposed
Plan mentioned a few alternatives for discharge of the treated-
water, one being discharge to the public water supply. The
commentor asked for the status of that discharge method and which
water system would the treated ground water potentially be
discharged tothe Village of Horseheads water system or EWB's?
EPA Response: EPA responded that as pare oi Lhe current public
comment period to solicit public comment on the Proposed Plan,
public comment on the discharge alterr.ctti:CF. *a^ r--ir.g sought.
EPA is proposing to discharge the treated ground water into the
public water supply because it believes that the extraction and
treatment system described in the Proposed Plan can effectively
treat ground water to drinking water standards. Ground water
10
-------
extraction, filtration and air stripping technologies are
commercially available and have been successfully implemented at
numerous other Superfund sites.
If the treated ground water is discharged to the public water
supply, it would be discharged to the EWB system.
E. INVESTIGATION AT OLD HORSEHEADS LANDFILL
Comment: A resident commented that he lives close to the
landfill and has often witnessed sealed barrels of liquid being
dumped at the Old Horseheads Landfill. He asked if those barrels
will be excavated and removed.
EPA Response: EPA reiterated that the focus of this Draft
Supplemental RI was to determine the nature and extent of
contamination at the Site and to identify the primary sources of
ground water contamination in the Newtown Creek Aquifer, where
possible. Therefore, a full characterization of the entire site
to determine all potential contamination problems other than
those contributing to the ground water contamination, was not
conducted. EPA has given all information that it gathered
related to the Old Horseheads Landfill to NYSDEC.
NYSDEC Response to the sane comment: NYSDEC elaborated that
there will be a Phase II RI at the Old Horseheads Landfill.
Currently, NYSDEC is gathering information about past site
practices at the landfill and would be interested in any
information that residents may have. [The representatives from
NYSDEC took the resident's name and phone number after the public
meeting for future reference]
Comment: A resident commented that he was concerned about the
ability of the investigation and cleanup project at the Old
Horseheads Landfill to be implemented in a timely manner.
NYSDEC Response: NYSDEC responded that a Phase II RI on the Old
Horseheads Landfill would probably begin in a year. If the town
wishes to initiate the investigation themselves, they should
contact NYSDEC, Division of Hazardous Waste Remediation, to make
those arrangements.
11
-------
F. INVESTIGATION AT LRC ELECTRONICS. INC. FACILITY
Comment: A resident asked if EPA had ever sampled in the
vicinity of the Agway facility when sampling the LRC Electronics,
Inc. site.
NYSDEC Response: NYSDEC explained that it is overseeing the
investigation at the LRC Electronics, Inc. facility. To date,
there has been limited sampling of existing wells, and some
monitoring wells have been installed in the vicinity of Agway.
Additional monitoring wells will be installed in the next few
months. The contamination found to date at the LRC Electronics,
Inc. site is relatively low-level. However, the investigation is
ongoing to fully characterize that area.
Comment: A resident asked if NYSDEC had conducted any water
sampling at the high school to see if that area is contaminated.
NYSDEC Response: NYSDEC responded that no, it has not sampled
the water at the high school because the upgradient wells at the
LRC Electronics, Inc. site are clean, and the school is located
much further upgradient than the wells. The contamination
problem appears to be in the immediate area south and east of the
LRC Electronics, Inc. facility.
G. PROPOSED CLEANUP SCHEDULE
Comment: A resident commented that EPA should expedite the
cleanup of the Kentucky Avenue Wellfield with the highest speed.
The resident explained that the dearest thing that people have is
water, and people cannot afford to lose it or waste it.
EPA Response: EPA recognizes this concern and within the
constraints of its regulations, intends to proceed with
implementing the selected remediation plan.
12
-------
APPENDICES
-------
APPENDIX A: Proposed Plan
-------
Superfund Proposed Plan-
Kentucky Avenue Wellfield Site
Cheraung County, New York
Region 2
July 1990
ANNOUNCEMENT OF THE
PROPOSED PLAN
This Proposed Plan identifies the U.S.
Environmental Protection Agency's (EPA's)
preferred alternative for cleaning up and
minimizing migration of con Lamina ted
groundwater associated with the Kentucky
Avenue Wellfield Superfund site (the Site)
located in Cbencuni County. New York.
COMMUNITY ROLE IN THE
SELECTION PROCESS
This Proposed Plan is being distributed to solicit
public comments regarding EPA's preferred
alternative as well as the other alternatives which
are being considered to clean up the Site. The
public comment period will begin on Jury 21,
1990 and continue until August 19, 1990.
EPA in consultation with the New York State
Department of Environmental Conservation
(NYSDEC), will select a remedy for the Site only
after the close of the public comment period,
during which time the available information may
be reviewed and considered by the public
EPA is issuing this Proposed Plan as pan of its
public participation responsibilities under section
H7(a) of the Comprehensive Environmental
Response, Compensation, and Liability Act
(CERCLA), as amended, better known as
Superfund. Detailed in/ormatioQ on all of the
material discussed here may be found in the
April 1990 Supplemental Re;-a^is.l Investigation
(RI) report, ibt A^rii 1990 :;r?f, feasibility
Study (FS) report, and other documents
contained in the record file for this Site. The
record file can be found at the following
information repositories:
New York State Department of
Environmental Conservation
Region 8 Headquarters
6274 East Avon-Lime Road
Avon, New York 14414
Phone: (716)226-2246
Hours: M-F, 830-4:45 p.m.
Town of Horsebeads Town Hall
ISO Wygant Road
Horseheads, New York 14841
Phone: (607) 739-5783
Hours: M-F, 830-430 pan.
EPA, in consultation with NYSDEC, may modify
the preferred alternative or select another
alternative presented in this Proposed Plan and
the FS report based on new information or
pubb'c comments. Therefore, the public is
encouraged to review and comment on aU the
alternatives identified here.
A public meeting will be held at the Town
of Horsebeads Town Hall located at 150
Wygant Road in HorseheaoXNew York on
Aug-nst 1,1990 at 730 pan. to present both
the findings of the RJ and FS reports and -
the proposed remedy. EPAwfl]also
opdate the public on the implementation
of the 1986 Record ofDecbiotussAII
interested persons are encouraged to
attend to ask questions and provide
comments. .^m&^tki&'-^.-tt.
-------
SUMMARY OF RATIONALE FOR
THE RECOMMENDED
ALTERNATIVE
The proposed remedy for the Site is protective of
human beaJih and the environment and affords a
high degree of long-terra effectiveness and
permanence while utilizing treatment as the
principal element. The proposed remedy would
provide the affected community with potable
water, remove contaminants from the upgradient
groundwater, and prevent further contamination
of dowogradjent groundwater. Geanup levels in
groundwater for the contaminants of concern
would comply with the most stringent federal
and state ARARs,
The proposed alternative provides the best
balance among the alternatives with respect to
the criteria used to evaluate the alternatives
(Table 1). Moreover, this combination of
alternatives would satisfy the statutory preference
fa: remedies which use treatment as a principal
element, and for permanent remedies. This
combination of alternatives is also the lowest
cost combination of alternatives which is
protective of human health and the environment
and utilizes highly effective treatment
technologies as the principal element.
13
-------
APPENDIX B: Public Notice which appeared in the
Elmira Star-Gazette on July 21, 1990 to
inform the local community about the
public meeting held at the Town of
Horseheads Town Hall, Town of
Horseheads, New York, on August 1, 1990
-------
me United States Environmental Protection Agency
W 9A ** W
Invites
Public Comment on the
Proposed Cleanup of the
Kentucky Avenue Wellfleld Site
in
Town of Horseheads, Chemung County, New York
The U.S. Environmental Protection Agency (EPA) will hold a Public Meeting to dis-
cuss the Supplemental Remedial Investigation/Feasibility Study Report (RI/FS) and
the Proposed Plan for the Kentucky Avenue Wellfield Site. The meeting will be held on
August l. 1990 at 7:30 p.m. in the Town of Horsefaeads Town Hall located at 150 Wygant
Road, Horseneads, New York.
EPA and the New York State Department of Environmental Conservation (NYSDEC)
evaluated the following options for addressing the contaminated groundwater at the
site:
MOM-1 (Management of Migration) No Action
MOM-2A Water Use Restrictions/Permit
Requirements
MOM-3B Carbon Adsorption/
Downgradient Reinfection
MOM-3C UV-Ozone Oxidation/
Downgradient Reinfection
Pumping Kentucky Avenue Well/Filtration/ Pumping at Two Locations/Filtration/
MOM-2B Air Stripping/Discharge to
Drinking Water Supply
MOM-2C Carbon Adsorption/Discharge to
Drinking Water Supply
MGM-2D UV-Oroae Oxidation/Discharge to
Drinking Water Supply
MOtt-2Js.Air Stripping/Downgradient
Reinj '
MOM-1F Carbon Adsorption/Downgradient
Reinfection
MOM-iG UV.Orone OxidationyDowngradJent
Reinjection
MOM-4A Air Stripping/Downgradient
Reinjection
MOM-4B Carbon Adsorption/
Downgradient Reinjection
MOM-4C UV-Orone Oxidation/
Downgradient Reinjection
Pnmptng at Down era dfeart of
MOM-5A Air Stripping/Discharge
to Surface Water/Public Supply
MOM-SB Carbon Adsorption/Discharge
to Surface Water/Public Supply
MOM-5C UV-Ozone Oxidation/Discharge
to Surface Water/Public Supply
Pumping at tbe Sootbern Boundary
of tbe StWFfttration/
MOM-3A Air Stripping/Downgradient
Reinjection
Based on available information, the preferred alternative at this time is MOM-2B.
Pumping Kentucky Avenue Well/FUtration/Air Stripping/Discharge to the Drinking
Water Supply; aod MOM-5A, Pumping Downgradient of Westinghouse
Facility /FiJtratJonMir Stripping/Discharge to either the public water supply or to
surface water. This proposed remedy would provide the community with portable
water, remove contaminants from the upgradient groundwater and prevent further
cootimiaatioQ of downgradient groundwater.
AJttxxLgh this is the preferred alternative at the present time, EPA and NYSDEC will
choose the final remedy after the public comment period ends and may select any one
of the alternatives after taking those comments into account.
The Proposed Plan, along with more detailed documentation of the analysis, may be
found in the Supplemental RI/FS Report and other documents contained in the record
ijir.. :v=£:ih-.:r Is U.-: l^^niation repositories at: NYSDEC Region 8 Headquarters, 6274
East Avon-Lima Road, Avon, New York 14414; and at the Town of Horsebeads. Town
Hall, 150 Wygant Road.
The public may comment in person at tbe public meeting and/or may submit written
crr-"'v:c>ent3 on tfci propow^ alternatives through August 18, 1S90 to:
J. Jeff Josephson
Remedial Project Msnsg^
U.S Environment*! Protection Agency
26 Federal PUx*, Boon 747
New York, NY llffift
-------
APPENDIX C: Public Meeting Agenda
-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
.-:C FEDERAL PLAZA
NEW YORK '.0273
AGENDA
Public Meeting
Kentucky Avenue Wellfield Superfund Site
Town of Horseheads Town Hall
Town of Horseheads, New York
August i. 1990
7:30 p.m.
I. Welcome and Introductions
II. Site History and Overview
of the Superfund Process
III. Results of the Remedial
Investigation
IV. Results of the Feasibility
Study
V. EPA's Proposed Plan
VI. Questions and Answers
Ann Rychlenski
Public Affairs Specialist
U.S. Environmental Protection
Agency, Region II
Kevin Lynch
Chief, Western New York
Compliance Section
U.S. Environmental Protection
Agency, Region II
*>
Jeff Josephson
Remedial Project Manager
U.S. Environmental Protection
Agency, Region II
K. Subburamu
Site Manager
Ebasco Services, Inc.
(EPA's Contractor)
Jeff Josephson
Other EPA Participants
James Doyle, Esq.
Office of Regional Counsel
U.S. Environmental Protection Agency
Region II
-------
APPENDIX D: Public Meeting Sign-in Sheets
-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
"EolON I :
^6 FEDERAL PLAZA
NEW YORK NEW YORK '.O278
KENTUCKY AVENUE WELL7IELD SCPERFUND BITE
Sign-In Sheet
August 1, 1990
Town of Horseheads, New York
Please be sure to print your name and address clearly so that we
can add you to our mailing list:
Address
'n
-------
I? I'..,
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
^5 FEDERAL PLAZA
NEW YORK NEW YORK 10278
KENTUCKY AVENUE WBLLFIELD SOPERPUND SITE
Sign-In Sheet
August I, 1990
Town of Horseheads, New York
Please be sure to print your name and address clearly so that we
can add you to our nailing list:
Name Address
."-2
' ie *
*-&- -Jr*>erf
-------
10 Jr«,
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
-EGION i .
_S FEDERAL PLAZA
VORK. MEW YORK :C2~?B
KENTUCKY AVENUE WELL7XELD 8UPERFUND SITE
Sign-In Sheet
August 1, 1990
Town of Horseheads, New York
Please be sure to print your name and address clearly so that we
can add you to our mailing list:
"ame Address
' '
-------
APPENDIX E: Information Repositories which contain
technical and informational documents
pertaining to the site.
-------
INFORMATION REPOSITORIES FOR THE
KENTUCKY AVENUE WELLFIELD SUPERFUND SITE
CHEMUNG COUNTY, NEW YORK
Technical and informational documents pertaining to the Kentucky
Avenue Wellfield Site can be found at the following information
repositories:
New York State Department of Environmental Conservation
Region 8 Headquarters
6274 East Avon-Lima Road
Avon, New York, 14414
Phone: (716) 226-2246
Hours: M-F, 8:30-4:45 p.m.
Town of Horseheads Town Hall
150 Wygant Road
Horseheads, New York 14841
Phone: (607) 739-8783
Hours: M-F, 8:30-4:30 p.m.
-------
APPENDIX F: Written comments from the general public
and Elnira Water Board, and EPA's
Responses
-------
228 Sunset Circle
- ;- - Hcrseheads, New York 14845
. -"-" August 15, 1990
J. Jeff Josephson ; j
Remedial Project Manager ----
U.S. Environmental Protection Agency
26 Federal Plaza Roan 747
New York, New York 10278 Re: Kentucky Ave. veil cleanup Horseheads
w
Dear Mr. Josephson:
I would like to request that this letter be entered into the official records
regarding the proposed Kentucky Avenue wellfield cleanup in Horseheads, N.Y.
I am firmly in favor of this planned method of cleanup of the contaminated well-
fields, but only if Westinghouse is made to pay for the lions share of the expenses.
I realize that whatever method of cleanup is used, it will certainly be a costly
process which should not fall on the overburdened taxpayer.
While I was president of the Chemung County TAxpayers Association, I attended a
meeting of the Susguehanna River Basin Commission on July 13, 1978 in Camp Hill, PA.
Since I was very interested and concerned about chemicals produced by Westing-
house Electric Corp. and released into a nearby swampy area which drained into Newtown
Creek, I created a "Westinghouse" file which I retained.
I have a copy of the SRBC July 13, 1978 AGENDA with my notes of discussions at
this meeting. Following are my notes of discussion:
1) Westinghouse releases radio active 100 micro curie
2) Elmira well within 600 feet of discharge into swamp
3) Elmira Water3oard people upset
4) Dept. ignored Cormission's rejection and took action and approved by EPA
At this meeting, I also remember the statement being made that Westinghouse was
not goina to be permitted to dump much longer and they were tired .of this going on
with no compliance from Westinghouse and being approved by state review.
I also have a September 15, 1978 SRBC DISPOSITION OF PROJECT APPLICATIONS
FROM JUNE 29, 1978 TO AUGUST 22, 1978:
WESTINGHOUSE ELECTRIC Ccrp. TYPE ACTION
(N.Y. -0004103) Discharge of effluent containing Accept state
U-235, Fluoride, Cadmium, Copper review
cyanide, Lead, Nickel into a
swampy area.
I have a February 14, 1980 SRBC DISPOSITION OF PROJECT APPLICATIONS FROM DECEMBER 10,1979
to JANUARY 28, 1980:
WASTINGHOUSE ELECTRIC CORP. TYPE ACTION
(N.Y.-004103) Application for renewal of permit Accept state
for existing discharge of 1.9 mgd review
of cooling vater and treated process
wastes to unnamed tributary of Nev-
tovn Creek from electroplating
facility
-------
-2-
In view of the fact that SRBC vas very upset with Westinghouse for the pollution
and toxic wastes it released into the wellfield, I am requesting that Westinghouse
Electric Corporation be held responsible for the cleanup of their own damage they
created. They dumped their wastes for many years, knowing what they were creating.
They also defied warnings to treat their wastes. This was ignored for many years.
Westinghoue went on with their determination to pollute while making millions of
dollars for themselves. Why should taxpayers be held responsible for the cleanup of
a private corporation?
As a concerned taxpayer, I insist that Westinghouse be forced to pay for the
problem they willfully and knowingly created, even if it means taking them to court!!
I have furnished you with proof of the extent of damage Westinghouse created and
the types of chemicals they admitted to, so certainly you should have a right to demand
payment from Westinghouse and NOT the taxpayer.
I respectfully request a response from you pertaining to my comments.
I thanK you in advance.
Sincerely.
Barbara Gilman-Ottey
P.S. If you wish to discuss anything with me I can be reached at 607-739-7111,.
Also, if you are not the right person to report my evidence to, kindly let
me know to whom it should be sent. Thank you.
-------
^^E^3)E3BS^3SC3S33^HHHi
FurBlstor
- CERTIFIED- RETURN RECEIPT
September IB/ 1990
Mr. Jeff Josephson
Remedial Project Manager
U.S. Environmental Protection Agency
Region II
Room 747
26 Federal Plaza
New York, NY 10278
RE: KENTUCKY AVENUE WELLFIELD SUPERFUND SITE
CHEKUNG COUNTY, NEW YORK
Dear Mr. Jcsephson:
Purolator Products Company (formerly Facet Enterprises/ Inc.)
is engaged in the production of automotive/ industrial/ and
household products. Purolator operates an automotive motor
components facility in Chemung County and has been cited
in the report as a potential contributor to the Kentucky
Avenue Wellfield Superfund Site. We would like to take this
opportunity to comment on EPA's Draft Final Remedial Investigation/
Feasibility Study (RI/FS).
Overall/ Purolator feels the report has generally presented
the available data on the site accurately/ while also discussing
other potential source areas that need additional data collection
including Purolator's Elmira facility). As part of this
ata collection activity/ as you know/ Purolator is in the
process of completing a Remedial Investigation (RI) regarding
its Elmira facility pursuant to an administrative order with
the Agency. The report of this investigation will address
the specific conditions on the Elmira facility and the impact
of those conditions upon the study area outlined by the Kentucky
Avenue Wellfield Superfund Site. We must therefore defer
our comments on the statements in the Kentucky Avenue Wellfield
RI/FS regarding Purolator's contribution to environmental
conditions in the study area until the completion of the
Purolator RI.
Motor Components Division T.O. Box 1502 Sales Fax (607) 737-8335
Elnu-a. NY 14902-1502 Purchasing Fax (607) 737-8296
(607) 737-8031 Telex 6854130 FACETMCD
-------
Mr. Jeff Josephson
September 18/ 1990
«
Page -2-
We support EPA's concern for investigating additional suspected
and/ to date/ unknown sources of contamination in and outside
the current study area. In addition/ Purolator agrees that
the assumptions used to complete the Risk Assessment have
been conservatively stated. Finally/ Purolator supports
the chosen remedial alternative outlined in the Feasibility
Study as the best available technology for this Superfund
site. However/ we do have some specific comments en the
documents/ as follows.
1. Section 1.3.I/ Page 1-14 - RI
The references at paragraph five regarding the Purolator
SPDES permit at the Elmira facility should be updated. During
1989/ Purolator's Elmira facility discontinued operating
a tin-on-carbon plating shop. Therefore/ future discharge
waters should not contain significant levels of tin. In
addition/ we are currently negotiating with the New York
Department of Environmental Conservation for a new SPDES
permit that reflects this change in operations.
2. Section 6.8/ Page 6-114 - RI
Although EPA indicates that inhalation of volatiles
from cracks in basements or from running tap water may pose
a greater health threat than ingestion of unfiltered ground
water/ no air quality data is presented to document this
condition. Purolator recommends that EPA resolve this lack
of data.
3. Section 4.0/ Inclusive - RI Organization
Several inconsistencies were found in the numerical
designation between text/ figures/ and tables in this section.
Purolator appreciates this opportunity to comment on
the Kentucky Avenue Wellfield Superfund Site RI/FS and hopes
that our input will enhance the quality of the final report.
Sincere
.~'5',-e .
Plant Engineer
RBH/pdc
-------
1415 W. Water Street
Elmira, NY 14905
17 August 1990
J. Jeff Josephson
Remedial Project Manager
U S E P A
26 Federal Plaza / Room 747
New York, NY 10278
RE: KENTUCKY AVE. RI/FS
Dear Mr. Josephson/
The RI documents which I had an opportunity to review for
a very brief period contain data and wording that appears to
be in error. Those items requiring review that I noted in my
brief perusal are as follows:
3.5..2 river (should be Newtown Creek)
Fig. 3-8 13-Horseshoe Landfill
4.3.1.4 Lake Erie and Western RR (Bother Ref's)
(Delaware/ Lackawanna & Western)
4.3.2.4 Facet connects to Halderman Hollow Creek
(May's Creek)
Other items may need review/ but time did not permit an
in-depth study of the volumes prior to the required reply
date.
Very tpuly
RBH/pdc
-------
It
F'.I
STATE OF NEW YORK
DEPARTMENT OF HEALTH
Corning Tower Trie Governor Nelson A. Rockefeller Empire Siaie Pl&za Aicany, Nevs Ycrr 12237
Of PUBLIC HEALTH
fiCj A nj-ia.-ii;'. V. I"/ Mt"
W.lhjri, I
September 18, 1990
Mr. Edward R. Belmore, Director
Bureau of Western Remedial Action
Division of Hazardous Waste Remediation
KYS Dept. of Environmental Conservation
50 Wolf Road
Albany, New York 12233
RE: Draft Kentucky Avenue Wellfield
Record of Decision (ROD)
fimira, Cherr.ung County
Site ID #808012
Desr Kr. Be 1 more:
The Department of Health has completed its review of the draft Record
of Decision (RCD) for the Kentucky Avenue Wcllfield. As a result of this
revvev: we have no comments on tae ROD.
" f tr,er-f are any questions regarding this, please feel free to contact
Ricnarc Tuers at (518) 4SS-63C0.
Sincerely,
k^^^Z^^^
F;cna!d Tramontano, P.E.
Director
Bureau of Environmental Exposure
Irvestigetlon
jlf/02600772
cc: G. Cross - DEC
J. Josephson - EPA
0. SirUr.-e
- VRO
'_'. '« a p i r - R ":)
G.A. Carlson
R. Tuers
-------
-. A ^^ ?&»
*£/<*' "4v^yIC-I Sljcrtt
\ /
-------
ELMIRA WATER BOARD
COMMISSIONERS
MLTTH G. MURRAY
(ROBERT I. PERSONIUS
ROBERT G. PROCHNOW
CHARLES A. SHAFFER
KEVIN C. MclNERNY
RUTH G. MURRAY
Pr»»id«rrt
ROBERT I. PERSONIUS
Vice-Pr«»id«nt
ROBERT W. APPLEBY
Secretary-TrtiMirvr
L EDWARD CONSIOINE, P.E.
General Manager
261 WEST WATER STREET
P. 0. Box 267
ELMIRA, NEW YORK 14902
(607) 733-9179
FAX (607) 733-2225
August 14, 1990
Mr. Jeff Josephson
Remedial Project Manager
U.S.E.P.A.
26 Federal Plaza, Room 747
New York, NY 1C278
Dear Mr. Josephson:
Re: U.S.E.P.A. Superfund Proposed Plan
Kentucky Avenue Wellfield Site
Chemung County, New York
The above referenced indicates that the ultimate goal of the E.P.A.'s
Superfund Program is to return useable groundwaters to their bene-
ficial uses within a time frame that is reasonable. The above ...
referenced further states that the final remediation goals for
the Kewtown Creek aquifer will be drinking water standards. The
Elrcira Water Board is pleased to know that the Newtown Creek aquifer
will be restored as a drinking water source of supply.
The Elmira Water Board has, over the past many years, drilled more
than forty (40) test wells in various parts of its service area.
The test wells were used to provide hydrogeological data to support
groundwater development in Chemung County. The hydrogeological
data mentioned above are on file at the Elmira Water Board. The
data indicate that the Newtown Creek aquifer is the best water
supply aquifer in the Elmira Water Board service area. The Elmira
Water Board's long range plans included and, indeed depended upon,
high water production yields from the Newtown Creek aquifer. These
long range plans were decimated by the groundwater contamination
problems which became evident in the early 1980's.
The above referenced plan gives the Elroira Water Board reason to
believe that they can once again plan on using the Newtown Creek
aquifer and its thick clean gravel deposits as a groundwater source
of suppT
v
-------
Page 2 U.S.E.P.A.
August 14, 1990 Mr. Jeff Josephson
The Elmira Water Board believes the proposed plan for the Kentucky
Avenue wellfield site and the Newtown Creek aquifer is practical
and beneficial to Chemung County.
The Elmira Water Board offers its support in whatever way possible
to assist in the restoration of the Newtown Creek aquifer as a
potable groundwater source of supply.
Thank you for allowing the Elmira Water Board the opportunity to
comment.
Respectfully submitted,
ELMIRA WATER BOARD
M£ ^"V ^J^wJyLr VJOo*-**^
L. Edward Considine, P.E.
General Manager
LEC/cs
-------
Response to Comments
Kentucky Avenue Wellfield Site
Chemung County, New York
The following summarizes the comments received by EPA from the
general public, the Elmira Water Board, and the New York State
Department of Health and provides EPA's response to these
comments.
Response to comments Submitted by Ms. Barbara Gilman-Ottey
Ms. Gilman-Ottey commented that she agrees with the proposed
remedial action at the Kentucky Avenue Wellfield site but that
she did not feel that tax payers should have to pay for the
aquifer cleanup and the restoration of the Kentucky Avenue Well.
EPA Response; EPA does not consider who will pay for the selected
remedial action during our evaluation of all of the remedial
alternatives. After final selection of the remedial alternative
EPA reviews the possible options for funding the remedial action
including funding provided by Superfund and funding by
responsible parties. In accordance with EPA Administrator Riely's
90-day Management Study, it is currently EPA's policy to proceed
with an "enforcement first" approach for funding remedial action.
Response to Comments Submitted by Purolator (formally Facet
Enterprises/ Inc.)
Purolator commented that the Supplemental RI/FS was generally
accurate, and that they support the proposed plan.
Section 1-3.1, Page 1-14 - RI
Purolator indicates that they have changed their process at the
Elmira Plant and that they are negotiating to modify their SPDES
permit referenced in the Supplemental RI.
EPA Response; EPA acknowledges this comment.
Section 6.8, Page 6-114 - RI
Purolator recommends that data to support the assessment that
volatiles from ground water may present a health risk in
basements due to volatilization through cracks be collected.
EPA Response; EPA will consider if an air pathway analysis is
necessary during design phase of the remedial action. In
addition, air pathway analysis will be considered at each
facility undergoing a Remedial Investigation.
Section 4.0, Inclusive - RI Organization
'"./rolafyvr commented that there are several inconsistencies
Between text, figures, and tables in Chapter 4.0 of the RI
report.
EPA Response; We apologize for any confusion this may cause.
-------
Response to Comments Submitted by Mr. Reeve B. Howland
Mr. Rowland commented that the following errors in the text were
made:
3.5.2 river (should be Newtown Creek)
Figure 3-8 13-8 13-Horseshoe Landfill (this should be Horseheads
Landfill)
4.3.1.4 Lake Erie and Western PR (+ other Ref's) should be
Delaware, Lackawanna, & Western Railroad)
4.3.2.4 Facet connects to Halderman Hollow Creek. This should be
May's Creek)
EPA Response; We acknowledge these editorial changes.
Response to Mr. John J . Cain
Mr. Cain indicated that he is a member of an environmental group
in CheTtmng County and he missed the Public Meeting for the
Proposed Plan for the Kentucky Avenue Wellfield. He requested
information concerning this site.
EPA Response; On September 17, 1990, EPA sent a copy of the
Proposed Plan for the Kentucky Avenue Wellfield to Mr. Cain.
Response to Comments Submitted by the Elmira Water Board
The Elmira Water Board indicated that they are pleased to know"
that the Newtown Creek Aquifer will be restored as a drinking
water source of supply.
The Elmira Water Board indicated that they were pleased that EPA
was proposing aquifer remediation for the Newtown Creek Aquifer
and that they believe that the Proposed Plan for the Kentucky
Avenue Wellfield is practical and beneficial to Chemung County.
The Elmira Water Board offered assistance during implementation
of the remedial action.
EPA Response; EPA would like to thank the Elmira Water Board for
providing Newtown Creek Aquifer data which they have collected
since the early 1960s. EPA also appreciates your offer to
provide assistance during implementation of the proposed remedy.
As explained in the Proposed Plan, although it is EPA's goal to
return useable ground water to their beneficial uses within a
reasonable time frame, there is some uncertainty as to whether
che c:nt":r«? Newt'own Cr^ak Aquifer can 1,3 cleaned up to the low
levels required by Federal and State drinking water regulations.
In addition, we believe that source control measures must be in
place before the entire aquifer can be remediated.
-------
APPENDIX G: Written comments from Westinghouse
Corporation and EPA's responses
-------
S-\'T £v:Xt-:x Te-e:r::e- 7C2: : S-'.C-s: : 10 = 43 ^"I-LI'S LY'LE. HITC-.- 2'i 2cii-:£:s 2
PHILLIPS. LYTLE. HITCHCOCK. BLAIKE S HL!BER
ATTORNEYS AT LAW
3-0: ViASj^E V.IDLASJD CEKTER. BI-MALO. NEM- YORK i-'e understand that you, Jeff Joseph-son and
representative{=) cf E3ASCO will be present.
;.s we discussed or, September 5, 1990, the neeting will
fcrus en certain technical questions '"estinghcuse has concerning
the I-raft Final Feasibility "stucy Report, July 1990 (DFFSR), for
the rite. In general, these questions pertain to the calculation
of reredistion tire relative to EPA's preferred selected alternative as
described in the "Superfund Proposed Plan," July, 1990.
tfore specifically,
(1) How is the design punp rate of 140 gprr. arrived at?
reference: DFFSK, Section 4, p. 4-S9 and
Appendix C, p. C-*0.
(2) What eo-jations were used in the Flush-Pro model?
Westir.ghcuse would like tc review and discuss the
equations.
Reference: DFFSF-, Appendix C, page C-12.
<;} Hov 5ces EFA's flushing models (as presented in
.-.: .:^;r.dix D cf the "Guidance en Remedied Actions for
Contaminated Grour.cwater at Superfund Sites,"
December 1S68J differ from the EEASCC Flush-Pro
; Ci ii- >«.!''. "IU* ^.L wi.kM>.C*2s Sll»»»ii :CS^. Tt.im>
-------
c'
t^. LYTIE. HITCHCOCK BLA;SE 6 HUBER
Jar.es F. Dcyle
September TO, 1990
Page 2
(4) Why was the Flush-Pro model used rather than EFA
flushing models?
(5) Kow vae the repcrtec kt5 of 1.76 ueea in the
flushing model derived?
Reference: D7FSR, Appendix C,: page C-12.
(6) What retardation factor was used for TCE?
(7) V:ES the rer.ediation time of 30 years for the MOM-5
design calculated using the 140 gpm extraction
rite; was the acquifer discharge not captured by
the recovery veils considered in the rer.ediation
time calculations; hov is the remediation time
effected if the natural acquifer discharge rate of
1100 gpr were substituted into the flushing model?
Sfeferer.ce: Dr?£?>, Appendix C, pace C-14, scenario 4
(MOM-5).
(c) v.'r.at amount cf acquifer volume is intended
to be remediated by the MOM-5 alternative?
Peferer.ee: TfrSR, Appendix C, Table C-1 , page C-3.
Executive Sumnary, pace 1-5,
Ve 2oc'< forward, to our meeting.
Very truly yours,
PHILLIPS, LYT-LE, KI^CHCCCK, ELAINE & HUEER
Graham'
T J I
DDDar
15980
cc: by telecopy J. Jeffrey Josephs
-------
Written Response to questions submitted to EPA by Phillips/
Lytle, Hitchcock, Elaine, t Huber, on behalf of Westinghouse
Electric Corporation, September 10, 1990. Each question was
discussed during a meeting between EPA and Westinghouse Electric
Corporation on September 12, 1990.
1. How is the design pump rate of 140 gallons per minute (gpm)
arrived at?
EPA Response: The design pump rate referenced in the FS report
was arrived at as follows:
a) A design pump rate for three representative but consecutively
smaller cross sectional areas (See Figure 1) of the aquifer was
determined. Each scenario modeled used the same generalized
aquifer properties based on data obtained during the Supplemental
RI. The depth of the aquifer was constant at 30 feet in all
three evaluations, but the length through which flow occurs was
smaller, and therefore, available ground-water flow was
approximated to be proportional to the recharge area available,
and cross sectional area through which flow could occur.
Withdrawals from the aquifer (due primarily to industrial
pumping) were evaluated for each of the three scenarios, as was
recharge due to infiltration from industrial drainageways.
A value of 140 gpm was arrived at by considering an aquifer width
of 1600 ft, and an aquifer depth of 30 feet. The cross sectional
area is, as explained in the Supplemental Feasibility Study,
modeled to be 40% of the recharge area represented in the entire
aquifer modeled, and the width of the aquifer through which flow
occurs in the area modeled is 25% of the width of the maximum
width modeled. An approximation of net withdrawal due to aquifer
pumping at the Westinghouse facility is accounted for by
considering total pumping minus a percentage returned to the
aquifer through recharge in an unlined drainage way.
Average net recharge 0.5 million gallons per day (mgd)
minus net withdrawal 0.3 mgd
Design flow rate 0.2 mgd (140 gpm)
2. What equations were used in the Ebasco "flush-pro" model?
EPA Response: In a given total volume V* there is a mixture of
solids and voids that are completely filled with water, and both
are contaminated.
Therefore M, = M, + M«
where: M, = total mass of contaminants
M, = contaminants associated with solids
M,. = contar.inants associated with water
-------
-2-
The mass of the solids is equal to the volume of the solids times
the density of solids and the mass of contaminants on the solids
is equal to the mass of solids times the concentration per unit
mass. Therefore, the total mass is equal to the following:
M, = C.V.P, + CwVwpw
where:
C, = Concentration of contaminants associated with solids
V, = Volume of solids
p, = density of solids
cC = Concentration of contaminants associated with water
Vw = Volume of water
pw = density of water
now,
The total volume V, is equal to volume of solids plus volume of
liquids. V, = Vt + Vw.
where:
Vw = volume of water
V, = volume of solids
However,
Vw = nv, and V, = (l-n)V,
where n=porosity
Therefore:
M, = C.Cl-rOV.p, + CwnV,pw
From the definition of the distribution coefficient IQ,
K,, = cycw
For organics the following relationship holds:
Kd = f« * k« / 100
where f« = percent organic carbon, and
k« = is the partition coefficient normalized for organic
carbon
3. How does EPA's flushing models (as presented in Appendix D of
-------
-3-
the "Guidance on Remedial Actions for Contaminated Groundwater at
Superfund Sites," December 1988) differ from the EBASCO Flush-
Pro model?
EPA Response: Appendix D of the EPA guidance document entitled
"Guidance on Remedial Actions for Contaminated Groundwater at
Superfund Sites," (December 1988) presents a batch flushing
model, and a continuous flushing model. The "flush pro" model
utilized by Ebasco is similar to the batch flushing model in the
December 1988 guidance but is a more simplified approach.
4. Why was the Flush-Pro model used rather than an EPA flushing
model?
EPA Response: The scope of work, and budget planning for the
Remedial Investigation/Feasibility Study was conducted during the
Summer of 1988, and a final workplan was completed during the
Fall of 1988. EPA decided the modeling approach and appropriate
budget for modeling for this project during this period. We
chose a simplified model which did not require extensive detailed
hydrogeologic investigation because the model was to be used
primarily as a tool for evaluating the relative cost
effectiveness of the various alternatives that would be
investigated. The guidance document Guidance on Remedial Actions
for Contaminated Groundwater at Superfund Sites which contains
the referenced equations in question 3 above, was finalized in
December 1988; therefore, we did not have this guidance document
during the planning stages of the project. However, as discussed
in question 3, the model that was used for the Kentucky Avenue
Supplemental FS is very similar to the batch flush model
discussed in the EPA guidance.
5. How was the reported kj of 1.76 used in the flushing model
derived?
From the definition of the distribution coefficient K^,
K, = C,/CW
For organics the following relationship holds:
K, = f, * k« / 100
where fo,. = percent organic carbon, and
ko,. = is the partition coefficient normalized for organic
carbon
£« fa a caicv., Crcr s value measures in the field during the
Kentucky Avenue Wellfield site Supplemental Remedial
Investigation. The values obtained during the Supplemental RI
are reported in Appendix I of the Supplemental RI report.
k« was obtained from a published EPA document entitled " EPA
-------
-4-
600/8-90/003 Basics of Pump and Treat Groundwater Remediation
Technologies.
EPA anticipates that additional £ data will be collected in
order to refine the estimate of 1C.
6. What retardation factor was used for TCE?
EPA Response: A "retardation factor" is implicit in the k^ value
chosen during our analysis.
7. Was the remediation time of 30 years for the MOM-5 design
calculated using the 140 gpm extraction rate; was the aquifer
discharge not captured by the recovery wells considered in the
remediation time calculation; how is the remediation time
effected in the natural aquifer discharge rate of 1100 gpm were
substituted into the flushing model?
EPA Response: Assuming that all source controls are in place at
the Westinghouse facility, and that the pumping wells at the
Westinghouse facility pump at a constant rate, a remediation time
of 30 years was calculated using the "Flush-Pro" model. With
Westinghouse and the Kentucky Avenue Well pumping, EPA does not
at this time believe the aquifer could sustain a pumping rate of
1100 gpm for an extended period of time.
8. What amount of aquifer volume is intended to be remediated by
the MOM-5 alternative?
EPA Response: As stated in the Proposed Plan, page 6, the goal of
the preferred remedial action is to halt the spread of a
contaminant plume, and to remove contaminant mass. Also, this
action will permit collection of data on aquifer and contaminant
response to remediation measures. On page 7 the Proposed Plan
states that ... a final ROD for the Newtown Creek Aquifer which
specifies the ultimate goal, remedy and anticipated remediation
time-frame, will be prepared. On page 9 of the Proposed Plan,
under the discussion "Compliance with ARARs" EPA has indicated
that this is an interim remedial action, and compliance with
ARARs is not required.
The decision to conduct an interim remedial action is based on,
among other considerations, EPA's recent guidance on aquifer
remediation which indicates a preference to initiate action as
early as feasible Actions can be taken by EFA if they will
prevent the situation from getting worse, initiate risk
reduction, and/or the operation of such a system would provide
information useful to the design of the final remedy.
-------
-5-
The action proposed by EPA is intended to meet all three basic
objectives. By implementing this interim remedial action,
contaminant spread would be reduced or stopped until source
controls are in place. This will prevent worsening of the water
quality in the aquifer. This interim action will reduce the risk
to human health and the environment by reducing the
concentrations of contaminants that will spread within the
aquifer or that may eventually discharge to the Newtown Creek.
Without source controls in place, the ground water alternative
MOM-5A will not result in ground water quality reaching
renmediation levels for any portion of the aquifer. As stated on
page 11 of the proposed plan, after sources of aquifer
contamination have been stopped, the preferred alternative will
remediate a portion of the aquifer hydraulically influenced by
the pumping wells.
-------
767 'irTN AVCNUC
MCW TO*K. N.T. lO'SS
(Jill JiO-»OOO
TtLtCO»lt»: cjijl JiO-«OO7
CAB..C: wtQOMA
TtLtX ITT «t*Cei
ITT «{J|««
01 MAIN STHCCT
»UIT£ 4100
DALLAS. TEXAS 7&ZOZ
746-77OO
«: (Zl«l 7*6-7777
WEIL, GOTSHAL & MANGES
A (AUTNtltSxl* lUClOO'nG O'C»«1O"»l. CO**O**TlONS
'. 1619 I STREET. N.W.
WASHINGTON. O.C. 2OO36
c , . .
'' T2OZ > 683-7OOO
TiLtcO»iC«:
WKlTIX-t OintCT LINE
(202) 682-7175
September 18, 1990
7OO LOUISIANA
HOUSTON. TCXAS 77OOZ
17131 »««-»OOO
TCLtCOPitH: 1713) tt«-»Sn
TCLCX: ITT ««tOl««
^
7OI IIUCKCLL AVtNUt
MIAMI. rLOmOA 1JIJI
1108 I »77-JIOO
TELCCOPItK: <»O&l J7«-7I»8
Mr. J. Jeff Josephson
Remedial Project Manager
U.S. Environmental Protection Agency
Region II
26 Federal Plaza, Room 747
New York, New York 10278
Re: Kentucky Avenue Wellfield Site
Chernung County, New York
Dear Mr. Josephson:
Enclosed please find the written Comments of
Westinghouse Electric Corporation pertaining to EPA Region II's
"Superfund Proposed Plan Kentucky Avenue Wellfield Site, Chemung
County, New York, July 1990." These Comments are hereby
submitted by Westinghouse Electric Corporation to EPA during the
period for public comment in response to the Plan, and for
inclusion and filing in the administrative record file for this
Site.
In a telephone conversation between Morgan G. Graham,
counsel for Westinghouse, and James F. Doyle, Assistant Regional
Counsel for EPA, Mr. Doyle stated that these Comments would be
considered timely filed if they were post-marked by September 18,
1990, and copies were sent to EPA by Federal Express. You
further agreed to this procedure in your telephone conference
with Morgan G. Graham today. Accordingly, these Comments are
being submitted by U.S. mail, with today's post-mark, and we are
sending copies by Federal Express. At your request, we are also
faxing you the first 10 pages of the Comments today; however,
-------
WEIL, GOTSHAU & MANGES
Mr. J. Jeff Josephson
September 18, 1990
Page 2
certain blanks appear in the faxed pages where there are cross-
references to other pages in the document. Those blanks will be
filled in on the copies you will receive by mail and Federal
Express.
Sincerely,
David B. Hird
cc: Richard L. Caspe (w/encs.)
James F. Doyle, Esq. (w/encs.)
-------
COMMENTS OF WESTINGHOUSE ELECTRIC CORPORATION
TO USEPA-REGION II JULY 1990 SUPERFUND
PROPOSED PLAN FOR KENTUCKY AVENUE
WELLFIELD SUPERFUND SITE
Westinghouse Electric Corporation ("Westinghouse")
hereby presents its written comments on the United States
Environmental Protection Agency, Region II ("EPA" or
"Agency") "Superfund Proposed Plan Kentucky Avenue Wellfield
Site, Chemung County, New York," dated July 1990 ("PRAP").
This submittal is in response to EPA's solicitation of
comments on the PRAP during the public comment period, and
is to be included and filed in the administrative record
file for the Kentucky Avenue Wellfield site, Chemung County,
New York (the "Site").
This submittal of written comments by Westinghouse
is made with full reservation of all administrative and
statutory rights or remedies under the National Oil and
Hazardous Substances Pollution Contingency Plan ("NCP"), the
Comprehensive Environmental Response, Compensation and
Liability Act ("CERCLA"), as amended by the Superfund
Amendments and Reauthorization Act ("SARA"), the Federal
Administrative Procedures Act, the National Environmental
Policy Act ("NEPA"), and other federal or state laws or
regulations.
-------
This submittal is made without making any
admissions of fact or law whatsoever with respect to EPA's
data, facts, conclusions, assumptions or other information
as set forth in the PRAP or the administrative record; of
any liability or responsibility with respect to the Site;
and does not constitute any evidence or estoppel against
Westinghouse, or a waiver of its right to challenge any
aspect of the PRAP, other information in the administrative
record, or any administrative or judicial proceedings with
respect to the Site.
* * *
I. INTRODUCTORY OBJECTIONS
A copy of the PRAP was obtained by Westinghouse on
July 23, 1990. The PRAP indicates that it was "distributed
to solicit public comments regarding EPA's preferred
alternative as well as other alternatives which are being
considered to clean up the Site." PRAP, at p. 1. The PRAP
indicates that the public comment period began on July 21,
1990 and was to continue until August 19, 1990.
On August 3, 1990, Westinghouse timely requested
an extension of time until October 18, 1990, to comment on
the PRAP, in conformance with the NCP, section
300.430(f)(3)(C). By letter dated August 9, 1990, from
Richard L. Caspe, P.E., Director Emergency and Remedial
-------
Response Division, EPA granted Westinghouse an extension of
time to comment on the PRAP until September 18, 1990. On
September 12, 1990, during a meeting with EPA representa-
tives, Westinghouse reiterated its request for an extension
of time until October 18, 1990. On September 13, 1990, EPA
notified Westinghouse that its request for an extension of
time until October 18, 1990 was denied, and that the public
comment period would continue until September 18, 1990.
A. EPA Has Not Complied With Its Public Participation
Responsibilities Under CERCLA.
Section 117(a) of CERCLA requires that the public,
of which Westinghouse is a part, be provided with a
reasonable opportunity for submission of written and oral
comments regarding the PRAP and regarding any proposed
findings under section 121(d)(4) (relating to cleanup
standards). Westinghouse sought an extension of time of the
public comment period from August 19, 1990 until October 18,
1990. Westinghouse sought this extension of time because of
the importance of this matter as it concerns Westinghouse, a
party whose facility is alleged to be a contributing source
to Site contamination; the complexity of the Site; and the
voluminous amount of technical information which had to be
reviewed and analyzed by Westinghouse prior to making this
submittal of written comments. Westinghouse believes that
the requested extension of time until October 18, 1990 was
-------
reasonable in light of all of the circumstances concerning
the Site and EPA's PRAP, and should have been granted
pursuant to EPA's statutorily mandated public participation
responsibilities under section 117 (a) of CERCLA.
1. Westinghouse Has Not Had A Reasonable
Opportunity To Consider Critical Information.
In response to receiving notice in the local
newspaper of the availability of the PRAP, Westinghouse
sought to obtain on July 23, 1990 from EPA's information
repository at the Site (Town of Horseheads, Town Hall) a
copy of the PRAP and the July 1990 Supplemental Final
Remedial Investigation and Feasibility Study ("RI/FS") for
the Site. Because Westinghouse was told by officials at the
repository that this information was not available for
copying, Westinghouse was required to seek a copy of the
RI/FS from EPA's Project Manager for the Site. In response
to Westinghouse's request to the Project Manager, a copy of
the RI/FS was made available to Westinghouse for
photocopying on July 25, 1990.
Based on Westinghouse's preliminary review of the
PRAP and RI/FS, Westinghouse concluded that additional
technical information located in the files of EPA and the
New York State Department of Environmental Conservation
("DEC"), or their consultants, had to be reviewed and
considered in order to properly evaluate the PRAP. On
-------
August 9, 1990, Westinghouse sent to the Project Manager for
the Site, requests for information pursuant to the Freedom
of Information Act, 5 U.S.C. § 552, to obtain certain
documents and technical information concerning the PRAP, the
Site and the Facet Enterprises site, an NPL site which has
been identified as a source of contamination of the Newtown
Creek aquifer.
On August 9, 1990, Westinghouse sought from DEC,
pursuant to New York Public Officers Law, information
pertaining to LRC Electronics, Inc., a facility EPA has
identified as a source of contamination of the Newtown Creek
aquifer. This DEC information was received by Westinghouse
on August 14, 1990, subject to a withholding by DEC of
certain information it claims to be privileged.
Westinghouse began receiving information in response to its
FOIA requests to EPA on August 20, 1990, with certain
information being received on August 23, 1990.
In addition, on September 12, 1990, representa-
tives of EPA and Westinghouse met to address certain
questions raised by Westinghouse in its September 10, 1990
letter to EPA with respect to the RI/FS and ground water
modeling and assessments. Because the ground water model
utilized by EPA in its study of the Site was proprietary to
its consultant Ebasco, and not generally available for
-------
evaluation, this meeting was the first opportunity for
Westinghouse to obtain critical information about EPA and
Ebasco's ground water analysis, which Westinghouse needed to
allow for an assessment of the RI/FS and PRAP.
All of the information and documentation
Westinghouse has sought from EPA and DEC is critical for an
adequate analysis and evaluation of the PRAP. Although
Westinghouse's requests for information focused only on that
information which was critical for evaluating the .PRAP, the
documentation amounted to well over 10,000 pages of
documents.
The amount of time Westinghouse has had between
the receipt of information from EPA and DEC and
September 18, 1990, has been inadequate to provide
Westinghouse with a meaningful opportunity to consider this
information as it relates to the PRAP and Westinghouse's
submittal. Because this information is critical for a
complete analysis and evaluation of the PRAP, Westinghouse
has been significantly prejudiced by EPA's decision not to
allow the public comment period to continue until
October 18, 1990.
-------
2. The Complexity Of The Site And Information
Inadequacies Require That There Be More Time
For Comment.
EPA, in the PRAP, characterizes the Site as
"complex." The PRAP indicates that the conditions at the
Site are complex due to various factors, including: ground
water contamination extending beyond the Kentucky Avenue
well and affecting a large portion of the Newtown Creek
aquifer; a separate facility on the NPL, Facet Enterprises,
is located downgradient of the Site and also contributes to
aquifer contamination; and the existence of various sources
of aquifer contamination. The identified sources of
contamination are undergoing investigations by different
federal and state authorities, with the PRAP and EPA's
characterization of the Site having been influenced by these
investigations and assumed remedial activities over the next
two years.
Because of the complexity of the Site, and
numerous interrelated investigations and assumed remediation
projects that will affect the Site, a reasonable opportunity
to comment on the PRAP would allow sufficient time to review
EPA and DEC information pertaining to the Site, the
suspected sources of contamination and the effect of their
remediation on the Site, and any other submittals from the
public pertaining to the suspected sources of contamination,
-------
e.g., LRC Electronics, Inc. and Facet Enterprises.
Westinghouse has not had a reasonable opportunity to fully
review this information, and Westinghouse has been
prejudiced thereby.
Westinghouse has also identified numerous
inadequacies and errors in the information presented in the
PRAP, RI/FS, and in documents and information received in
response to its requests for information. Westinghouse has
not had a reasonable opportunity to fully evaluate these
inadequacies and errors and their impact on the PRAP, and
has been prejudiced thereby. All of these inadequacies and
errors affect the findings, assumptions and conclusions
underlying the PRAP and EPA's selection of the preferred
remedial alternative, and will be described in detail at
pages 32-38, 49-62, 65-72, below.
B. EPA's Notice And Analysis Are Insufficient.
Section 117(a) CERCLA requires that EPA publish a
notice and analysis of the PRAP which includes sufficient
information as may be necessary to provide a reasonable
explanation of the PRAP and alternative proposals
considered. EPA's notice and analysis of the PRAP does not
include 'such information. As will be discussed in detail
below, EPA has failed to provide sufficient information
pertaining to how the PRAP differs significantly from EPA's
-------
1986 Record of Decision ("1986 ROD") for this Site; the need
to put the Kentucky Avenue well back into operation; how
implementation of the proposed remedy will achieve a more
expeditious cleanup of the ground water; the cost-
effectiveness of the proposed remedy; how the proposed
remedy satisfies the nine criteria for selecting remedies
under the NCP; why the proposed remedy is required under
EPA's Ground Water Policy; the effect of remedial activities
and source control measures at suspected sources of
contamination on the Site and the Newtown Creek aquifer; and
the effect of Westinghouse operational activities and ground
water usage on the Site. As a result, EPA has not complied
with the requirements under section 117(a) of CERCLA.
* * *
Westinghouse has been prejudiced by EPA's failure
to comply with its public participation responsibilities
under CERCLA section 117 (a) by refusing to extend the public
comment period until October 18, 1990, and by failing to
comply with notice and analysis requirements. The closure
of the public comment period after September 18, 1990 with
respect to the PRAP is inconsistent with the NCP. Under the
NCP, EPA is to automatically extend the public comment
period by a minimum of 30 additional days. The NCP
specifies the minimum level of time for public comment, but
-------
does not preclude EPA from providing additional time where
appropriate. Clearly, in light of all of the circumstances,
this is a PRAP which justified extending the public comment
period until October IB, 1990 to provide the public with a
reasonable opportunity for submission of written or oral
comments, because: there has been an inadequate amount of
time to review information which is critical to the PRAP;
the Site is complex; and there are inadequacies and errors
in Site information. In addition, EPA's notice and analysis
with respect to the PRAP are insufficient and inconsistent
with the NCP and EPA's public participation responsibili-
ties. EPA's notice and analysis provide insufficient
information necessary to provide the public with a
reasonable explanation of the PRAP and alternative proposals
considered.
II. WESTINGHOUSE REQUESTS A MEETING WITH EPA
REPRESENTATIVES.
Westinghouse hereby requests a meeting with EPA
representatives with respect to the Site and PRAP before EPA
issues a Record of Decision ("ROD") with respect to the Site
or responds to Westinghouse's comments. Westinghouse, as at
other federal Superfund sites, is willing to present to EPA
its views on the several alternatives in the FS in order to
begin a dialogue to explore creative and cooperative
10
-------
solutions for unique and complex environmental conditions.
Westinghouse believes that there is an approach to remedial
action at this Site, other than described in the PRAP, which
is equally protective of human health and the environment
and is consistent with the goals of CERCLA, SARA and the
NCP. Westinghouse requests that EPA provide Westinghouse
representatives with an opportunity to meet with EPA to
present its position.
As discussed below, at pages 27-28, Westinghouse
has proposed to implement in situ source controls at its
Horseheads plant site and to substantially enhance its
existing operational ground water capture and treatment
system. In addition, Westinghouse suggests that EPA
complete its evaluation of potential sources and use its
authority to effectively control other potential sources.
If all sources are effectively controlled, natural
attenuation can be expected to remediate the aquifer within
15 to 20 years, without the expenditure of $14 million for
an interim remedy.
III. WESTINGHOUSE HORSEHEADS FACILITY.
A. Background Of Operations.
The Imaging and Sensing Technology Division of
Westinghouse ("ISTD") began operations at the Horseheads
plant in 1952. For a time, the operations at this plant
11
-------
were also known as the Industrial and Government Tube
Division of Westinghouse.
In 1985, Westinghouse sold ISTD to Imaging and
Sensing Technology Corporation ("ISTC"), which presently
operates out of a portion of the plant. In 1985,
Westinghouse also entered into a joint venture with Toshiba
Display Devices Corporation, and operated out of a portion
of the plant until January 1989. In January 1989,
Westinghouse sold its interest in the joint venture to
Toshiba Display Devices Corporation ("TDDC"), which
continues to operate out of a portion of the plant.
Westinghouse Horseheads Operations also presently operates
out of a portion of the Horseheads plant. ISTC and TDDC are
tenants of Westinghouse at the Horseheads plant.
ISTC presently (and ISTD historically) develops
and manufactures a diverse line of electronic and electrical
components, assemblies and systems. ISTC (and ISTD)
manufactures (or manufactured) black-and-white and color
television picture tubes; power, storage, and television
camera tubes; spectral light sources, sensor and control
products; and vacuum switch products. The Westinghouse-
Toshiba joint venture, and later TDDC, manufactured color
television picture tubes. Westinghouse Horseheads
Operations manufactures vacuum interrupters, and is
12
-------
responsible as landlord for structural maintenance and
utilities at the Horseheads plant.
The plant property covers approximately
59.1 acres. Plant buildings cover over 16 acres of the
property, and include two waste water treatment plants,
various storage tanks and buildings, gas and water
buildings, and an electric power station. Paved parking
areas include over 14 acres, and additional paved areas
include perimeter roads and other smaller parking areas.
B. Ground Water Usage.
Ground water from the Newtown Creek aquifer is
currently drawn by Westinghouse by five active supply wells.
The combined average discharge from the aquifer by these
wells from 1978 through 1986 was approximately 1.04 mgd, or
about six percent of the total ground water use in the
Elmira area. Presently, total ground water discharge from
these wells approximates 2.25 mgd. The historical (through
July 1988) use of the ground water for Westinghouse
operations, and the effect of this use on surface and ground
water hydrogeology, was examined by Westinghouse and
described in the August 1988 report entitled "Draft
Investigation Report Hydrogeologic Investigation" for the
ISTD operation. The Draft Report was submitted to EPA in
August 1988.
13
-------
C. Permitted Discharges.
The Westinghouse Horseheads plant has historically
had New York State Pollutant Discharge Elimination System
Permits ("SPDES") with respect to waste water discharges.
Until 1986, all SPDES permits were in the name of
Westinghouse. With the Toshiba-Westinghouse joint venture,
a separate SPDES permit pertaining to these particular
operations was obtained in 1986. As a result of the
purchase, ISTC obtained a SPDES permit pertaining to its
operations. These SPDES permits have parameters for various
organic and inorganic compounds. In addition, the ISTD,
ISTC, Toshiba-Westinghouse joint venture, TDDC and
Westinghouse Horseheads Operations have had a series of air
permits for various air emissions relating to their
operations at the plant.1
1. To the extent that EPA has identified the Westinghouse
plant as a potential source area, it should be noted that
purported releases from that plant fall within the federal
permitted release exception under sections 101(10) and
107(j) of CERCLA, 42 U.S.C. §§ 9601(10), 9607(j). Indeed,
EPA acknowledged in the RI/FS that Westinghouse held SPDES
permits from New York State which specified metals discharge
limits. RI, at p. 4-86 and Table 4-25. The presence of TCE
in Westinghouse's permitted discharges was identified,
reviewed, and made part of the permit record with respect to
the permits issued to Westinghouse. Under section 107(j) of
CERCLA, 42 U.S.C. § 9607(j), EPA cannot hold Westinghouse
liable for these releases. Indeed, section 107(j) indicates
that if these releases are to be remediated, remediation
should be under pre-existing law, not CERCLA.
14
-------
D. RCRA Facility Investigation.
In May 1986, Westinghouse and EPA entered into an
Administrative Order on Consent ("Order") under Section 3013
of the Resource Conservation and Recovery Act ("RCRA"). The
Order was entered into to have Westinghouse conduct certain
monitoring, testing, analysis and reporting to determine the
full extent of contamination, if any, resulting from the
presence of hazardous waste at the facility and the release
of hazardous waste from the facility. The investigation was
designed to ascertain the nature and extent of any hazard to
human health or the environment.
Under the Order, the work to be performed by
Westinghouse was designed to determine, in part, the
hydrogeologic setting of the facility; character of the
soils; hydraulic gradients and direction of ground water
flow; location, pumping rates and influence of Westinghouse
pumping wells on ground water hydrogeology, and a
description of the use and disposal of water taken from such
wells; and the vertical and lateral extent of contamination
in ground water, soil and surface water.
On August 31, 1988, Westinghouse submitted to EPA
pursuant to the Order, its Draft Investigation Report
prepared by GAI Consultants, Inc. Under the Order, EPA
provided comments to Westinghouse pertaining to the draft
15
-------
Report. Amendments to the draft Report were submitted by
Westinghouse to EPA on June 1, 1989 ("Report"), addressing
EPA's comments on the previous submission. Under the Order,
EPA is to transmit a written statement to Westinghouse with
respect to whether the Report is acceptable. At this time,
EPA has not commented to Westinghouse on the Report in
writing, and Westinghouse has not received notice as to
whether the Report is acceptable.
E. Source Control At Westinqhouse And The PRAP.
It has always been assumed by Westinghouse that
certain source control measures at its Horseheads plant
would be required, depending upon the results of the
investigation under the Order. Although Westinghouse has
been prepared to begin considering, along with EPA, the
necessity of implementing source control measures at the
Horseheads plant, Westinghouse has been awaiting a response
from EPA with respect to its Report. The final Report will
be the basis upon which determinations can be made as to the
need for and the type and extent of source control measures
at the plant.
In EPA's 1986 ROD concerning the Site, EPA decided
to assess source controls before considering further
remediation. EPA identified the Westinghouse plant as one
of several sources. Considering the findings of the draft
16
-------
Report, operational activities at the plant, and the
interrelationship between- the plant operations and the Site,
Westinghouse is prepared to implement appropriate source
control measures. These measures are discussed more fully
at pages 27-28, below.
Until the PRAP was announced, Westinghouse
understood that EPA believed that any source control or
ground water usage at the Westinghouse plant would have to
be considered as part of the next phase of remediation at
the Site. This was confirmed in a meeting on November 29,
1989, between representatives of EPA and Westinghouse, where
EPA indicated that the FS for the Site would assume, for
purposes of remedy selection, that the Westinghouse source
of contamination would be eliminated; that the Toshiba-
Westinghouse plan to triple the ground water usage at the
plant would influence the ground water flow; and that the
ground water usage should be coordinated with corrective
action at the facility and/or the Site remedial action.
Westinghouse believes that remediation must be
approached from the vantage of controlling the suspected
sources of contamination. Source control at Westinghouse
and other suspected sources of contamination must be
implemented for a remedy at the Site to be successful. This
17
-------
approach is consistent with the NCP, CERCLA, RCRA, and the
goals of the PRAP for the Site.
IV. MITIGATION OF MIGRATION REMEDY IS NOT NEEDED AT THIS
TIME.
A. EPA Has Failed To Implement The 1986 ROD.
The selection of a mitigation of migration remedy
("MOM") at this time is premature and inconsistent with the
first ROD with respect to the Site, issued in September
1986. In the 1986 ROD, EPA determined that it was necessary
and appropriate to implement source control as an initial
step in the remedial process for the Site. The Agency
required that source controls be implemented and assessed
before further remedies were selected:
Source control actions, which may
include options such as treatment,
removal or containment of contaminant
sources, will be evaluated following
further investigation of potential
sources of volatile organic contamina-
tion in the aquifer. EPA has determined
that the information available on
contaminant sources is insufficient to
facilitate an adequate treatment design.
Further investigation of potential
contaminant sources is therefore neces-
sary in order to develop an effective
program of source controls and conta-
minated groundwater migration controls.
A decision of future source control
actions will be made following the
completion of several ongoing or
proposed investigations of potential
sources within the study area. Upon
implementation of any source control
measures, a reevaluation of recovery and
18
-------
treatments systems should be performed
on contaminated qroundwater migration
conrrols to choose, if warranted, a
cost-effective method of remediating the
aquifer.
1986 ROD, at p. 16 (emphasis supplied).
In approving the 1986 ROD, Regional Administrator
Daggett concluded: "I have determined that it is necessary
to undertake a Supplemental Remedial Investigation/
Feasibility Study to identify the source of contamination,
and to evaluate possible source control measures. A
determination regarding future source control actions will
be made upon completion of several proposed or ongoing
investigations of potential sources within the Kentucky
Avenue Wellfield study area." 1986 ROD preamble, at p. 2.
In the 1986 ROD, EPA properly recognized the need
to identify all potential sources and to evaluate source
control measures before undertaking any further remediation.
EPA determined in the 1986 ROD to consider additional
remedies only "[ujpon implementation of any source control
measures." 1986 ROD, at p. 16. Accordingly, the 1986 ROD
authorized the RI/FS to identify potential sources and
assess source controls. The RI/FS inadequately identified
potential sources and did not assess source controls.
Instead, the RI/FS considered a suite of MOM remedies which
would only be effective once source controls are
19
-------
implemented. At this point, however, source control has not
been implemented at any of the potential sources identified
by EPA in the 1986 ROD or in the RI/FS.2 Thus, no
"effective program of source controls" has been developed
for the Agency to assess prior to determining whether
further remediation is "warranted." Moreover, the RI/FS has
failed to identify or assess source control remedies.
Nonetheless, EPA is now planning to implement a
mitigation of migration remedy before any source control
measure has even been selected, let alone implemented.
Indeed, the MOM remedies proposed in the RI/FS, including
MOM-2B and MOM-5A endorsed in the PRAP, are all premised on
the assumption that all necessary source control measures
are in place and operating perfectly. PRAP, at p. 11. But '
nowhere in the RI/FS or the PRAP is there a discussion of
what those source control measures would be, where they
would be located and how they are expected to operate. In
other words, the entire suite of mitigation of migration
2. The 1986 ROD expressly identified certain source control
studies, then underway or anticipated, including the soil
and ground water investigation by Westinghouse under section
3013 of RCRA, the RI/FS at Facet Enterprises, a study of the
LRC Electronics, Inc. facility, and studies to identify
other potential sources. 1986 ROD, at pp. 15-17. At this
point, the Facet Enterprises RI/FS has not been completed.
Westinghouse has submitted the results of its RCRA
investigation to EPA, but has not heard any comments from
the Agency.
20
-------
remedies is premised on the implementation and perfect
operation of some unknown source control measures.3
EPA's current approach is completely inconsistent
with the decision in the 1986 ROD and not cost-effective.
As EPA recognized in the 1986 ROD, it is necessary first to
implement source control before the Agency can evaluate
whether any mitigation of migration remedy is cost-effective
or warranted. Even the PRAP admits that the mitigation of
migration remedy will not be effective unless source
controls are successfully implemented. PRAP, at pp. 6, 11.
Until source controls are implemented and the Agency has
evaluated their effectiveness, there is no way to determine
whether additional remediation is needed, and if it is
needed, what further remediation is appropriate. As
discussed in greater detail below, once all the sources of
contamination are effectively controlled, natural
3. In a meeting with Westinghouse representatives on
September 12, 1990, EPA and Ebasco personnel frequently
referred to the remedies proposed in the PRAP as source
control measures. This reference was surprising since both
the PRAP and the FS refer to the proposed remedies as
mitigation of migration remedies. These remedies do not
qualify as source control actions under 40 C.F.R. § 300.5.
(55 Fed. Reg. 8,666, 8,818 (Mar. 8, 1990)), since they are
not actions intended to "prevent the continued release of
hazardous substances or pollutants or contaminants
(primarily from a source on top of or within the ground, or
in buildings or other structures) into the environment."
Mitigation of migration is separately defined in 40 C.F.R.
§ 300.5.
21
-------
attenuation is predicted to remediate the aquifer within 15
to 20 years, without implementing any mitigation of
migration remedy, not the 53 years predicted by EPA's
contractors, Ebasco. To select a MOM remedy without first
implementing and evaluating source controls is to run an
unnecessary risk that the MOM remedy will either be
unnecessary or ineffective, and thus a wasteful expenditure
of limited Superfund dollars.
In the PRAP, EPA states that its intended goal for
the proposed MOM remedies is to achieve drinking water
standards within 30 years in the portion of the aquifer near
the Kentucky Avenue Wellfield. PRAP, at pp. 6, 11. If
EPA's approach is successful, it would only remove 5 percent
of the contaminant mass from the aquifer and would not
achieve drinking water standards in any portion of the
aquifer until the year 2022. Even assuming that it is
reasonable to spend $14 million in 1990 so that a portion of
the aquifer may achieve ground water ARARs between 2022 and
2045 -- which Westinghouse disputes -- EPA would have no way
of assuring that the proposed MOMs would be effective in
achieving that goal until source control had been
effectively implemented.
If chemical materials were continuing to enter the
aquifer without being controlled at their sources, the MOM
22
-------
remedies would be ineffective in achieving ARARs in any
portion of the aquifer. Indeed, EPA stated in the PRAP
that: "[s]ince source controls are not at this time in
place, the success of a final action for the entire aquifer
remediation would have a high degree of uncertainty." PRAP,
at p. 6. To select and implement a MOM remedy before the
successful implementation of source control is therefore not
cost-effective. No mitigation of migration remedy can be
successfully implemented until all significant sources are
controlled and the effects of source control are evaluated.
1. Failure Of The RI/FS To Identify All
Potential Sources.
The RI/FS has not adequately evaluated all
potential sources of trichloroethelyne ("TCE"), although
this evaluation was the objective of the RI, was mandated by
the 1986 ROD, and is required to successfully evaluate and
implement any ground water remedy.
Alternative potential sources (particularly those
upgradient of the Westinghouse facility and upgradient from
the Kentucky Avenue Wellfield) were not adequately evaluated
nor considered in the remedial action screening and
selection process. For example, the RI/FS did not consider
or evaluate sources of TCE found upgradient from the
Westinghouse plant, including the 95 ug/L of TCE found at
well CW-2D and at two private wells in the Fisherville area.
23
-------
RI, at p. 4-124. The RI/FS did not consider all potential
models of pollutant transport, such as TCE movement by
gravity flow at the base of the aquifer. The RI has also
not identified the source or sources of chromium contamina-
tion; or the source or sources of arsenic. Indeed, the
arsenic which was found is likely to be naturally occurring
in the soil and ground water. No source of arsenic has been
found at the Westinghouse plant. See GAI Draft Report
(1988) .
The RI/FS did not adequately evaluate the
contribution of the LRC Electronics, Inc. facility to ground
water contamination. Site investigations at the LRC
Electronics, Inc. facility indicate that approximately
60 million gallons of plating wastes (possibly containing
aluminum, cadmium, chromium, iron, nickel, silver, tin,
copper, lead, cyanide, fluoride, and various solvents) were
placed (over the period 1968 to 1981) in three seepage pits
located in the abandoned Chemung Canal along the eastern
edge of the property. The abandoned canal is oriented in a
north to south direction and extends beyond the LRC
Electronics, Inc. property boundaries. A feeder junction to
the abandoned Chemung Canal reportedly passed south of the
Westinghouse facility and joined the main portion of the
Chemung Canal near the location where N. Main Street crosses
24
-------
the Conrail tracks. The failure to evaluate this potential
pathway for contaminant migration and its relationship to
the Newtown Creek aquifer is enough in and of itself to
demonstrate the inadequacy of this RI because the presence
of this potential source may substantially affect the
performance of remedial alternatives.
Investigations at the Facet Enterprises site
indicate that on-site disposal of wastes is known to have
been conducted at least from the 1940s through 1978. From
1929 to 1976, the plant was owned by the Bendix Corporation
and manufactured bicycle parts, automobile engine
components, and small arms during World War II. Chlorinated
solvents, PCBs, as well as chromium, arsenic, cadmium, lead,
and selenium are known contaminants found in the soil and
ground water at the site. Although this site appears to be
downgradient of the Kentucky Avenue Wellfield,
investigations to date are inadequate to evaluate potential
pathways of migration via surface water runoff and via
nonaqueous phase transport within the Newtown Creek aquifer
(for example, along impermeable lacustrine deposits, bedrock
surface, interfaces, etc.).
25
-------
2. The RI/FS Did Not Assess Source Control
Measures.
The RI/FS did not even attempt to assess source
control actions, even though the 1986 ROD announced that the
assessment of source control was one of its purposes.
Instead, the RI/FS analyzed mitigation of migration remedies
without knowing how effective source control would be
implemented.
In the preceding section, Westinghouse identified
sources which were not adequately characterized.
Westinghouse does not know how these sources will be
controlled. Although Westinghouse does not admit that its
plant is a source or that its federally permitted releases
are subject to remediation under CERCLA, Westinghouse has
proposed source control measures for its plant in the GAI
report. Based on the 1986 ROD, Westinghouse anticipated
that EPA would evaluate those source control measures before
selecting a mitigation of migration remedy. EPA, however,
has not even responded to Westinghouse's proposals.
On April 21, 1989, Westinghouse sent EPA a letter
confirming a telephone conversation of April 19, 1989,
pertaining to the Horseheads facility. The letter also
confirmed that a meeting would be scheduled between
Westinghouse and EPA within two weeks after the submittal of
the report to discuss Westinghouse's response to EPA's
26
-------
comments. The letter also indicated that Westinghouse
expected to discuss possible remediation at the Horseheads
plant at that meeting. However, once Westinghouse responded
to EPA's comments, the Agency never scheduled the meeting.
Westinghouse expected that potential remedial
measures would consist of the implementation of on-site
collective action for alleged sources of TCE and the
enhancement of the present ground water pumping system to
maximize the effectiveness of the control of the movement of
ground waters from the plant site. The GAI report examined
potential source areas at the Westinghouse plant site and
identified certain areas, such as Area F, the former coal
pile area and the former runoff basin/solvent storage tank
as potential source areas amendable to in situ corrective
measures. Potentially applicable in situ corrective measure
technologies may include vapor extraction, soil flushing,
and containment. Westinghouse expected that the need for
and selection of the most appropriate corrective measure for
each of the potential sources would be completed as part of
the Corrective Measures Study ("CMS") to be completed for
this plant.
Control of the potential source areas would be
coupled with the enhancement of Westinghouse's present
operational ground water control and treatment system. The
27
-------
existing system would be enhanced in areas of the site close
to potential sources. For example, it is estimated that
pumping ground water from an area immediately downgradient
of Area F would control any residual materials emanating
from this area during and subsequent to implementation of
source control. The most effective use of source control
measures and enhanced ground water control would be
evaluated in detail in the CMS.
In addition to the relocation of pumping wells,
the enhancement of the present system may include the
addition of an air stripper to treat the collected ground
waters. Additionally, consideration would be given to the
ultimate discharge of the treated ground waters in the CMS.
3. EPA Has Not Justified Selecting A Mitigation
Of Migration Remedy Before Source Control Is
Implemented.
EPA has provided no justification for abandoning
its original proposal of implementing source control at
Westinghouse, Facet Enterprises, LRC Electronics, Inc. and
other potential sources, and then assessing the impact of
source control before taking further remedial action. Not
only is EPA acting inconsistently with the 1986 ROD, but EPA
also is unable to explain how implementing a mitigation of
migration remedy without first implementing and evaluating
source control will achieve any significant benefit.
28
-------
*B. There Is No Immediate Need To Put The Kentucky
Avenue Wellfield Back In Operation.
Part of EPA's proposed remedy, MOM-2B, calls for
putting the Kentucky Avenue Wellfield back into operation.
This aspect of the remedy cannot be justified by any
imminent public health concern or by a claim that the
current drinking water supply is inadequate.
There is no immediate public health purpose for
implementing the proposed remedy. In the 1986 ROD, EPA
stated that "private water supplies represent the only major
exposure route." 1986 ROD, at p. 16. Accordingly, EPA
determined that "the connection of all private well users to
public water supplies will eliminate the risk of VOC
exposure to the public and is believed to provide adequate
protection to public health." 1986 ROD, at p. 16. Under
the 1986 ROD, EPA has already connected all the families in
the community to water supplied by the Elmira Water Board,
except two families which have refused connection and drink
from private wells. EPA should renew its efforts to
encourage those two families to connect to City water.4 The
proposed remedy also would not protect any newcomer to the
area who sinks a well in the aquifer until the year 2022.
4. Westinghouse does not know whether these families are
located within the area affected by EPA's proposed remedy,
but suspects that they are not.
29
-------
EPA can better protect newcomers with institutional controls
by warning them not to sink wells and connecting them to
City water.
Moreover, there is no pressing water supply need
for putting the Kentucky Avenue Wellfield back in service.
EPA acknowledged in its response to comments on the 1986 ROD
that the contamination in the aquifer had already existed
for 30 to 40 years. Responsiveness Summary to 1986 ROD, at
p. 4. However, the City of Elmira and surrounding
communities have not suffered any shortages in water supply.
The Elmira Water Board has an adequate supply of drinking
water by using filtered river water. Without the Kentucky
Avenue Wellfield in operation, the Elmira Water Board still
has approximately 22 million gallons per day (mgd) capacity.
Water usage by the Elmira Water Board has
decreased in the 1980's. As shown in Table I, on page 91.,
the Elmira Water Board used 10.02 mgd in 1980; in 1988,
usage was down to 9.76 mgd. The population of the area has
also decreased in the past decade. As shown on Table 1, the
preliminary census data for 1990 indicates a decrease in
population of 3 percent since 1980. EPA also acknowledged a
decrease in population in the area in the Supplemental RI.
Supplemental RI, at p. 3-3. Based on current population
trends for the area, there is no reason to believe that
30
-------
there will be a substantial increase in population.
Accordingly, there is no need for additional water supplies.
EPA in its Explanation of Significant Difference
(April 1990) approved the installation of an air stripper at
the Sullivan Street Wellfield. This action would allow the
Elmira Water Board to use the Sullivan Street Wellfield as
reserve capacity. According to the PRAP, the Sullivan
Street Wellfield accounts for 30 percent of the Elmira Water
Board's capacity. PRAP, at p. 3. Moreover, filtered river
water has generally accounted for between 56 and 57.9
percent of the Elmira Water Board's capacity. Thus, the
Kentucky Avenue Wellfield is not needed. In the unlikely
event that the Kentucky Avenue Wellfield would be needed to
supply additional capacity, all that EPA needs to do is
install another air stripper, as it did at the Sullivan
Street Wellfield. The air stripper would remove organic
contaminants from water pumped from the well to achieve
drinking water criteria. The Elmira Water Board could
remove metals and introduce the water into the drinking
water system. This approach would cost substantially less
than the unnecessarily elaborate remedies in MOM-2B and
MOM-5A.
Accordingly, selection of EPA's proposed remedy at
this time cannot be justified on either a public health or a
31
-------
water supply basis. The population is currently supplied by
the Elmira Water Board, which has an adequate supply
available. Even if the Kentucky Avenue Wellfield were
needed for water supply purposes, the well could be put on
line more cost-effectively by EPA's installing an air
stripper and the Elmira Water Board's removing metals.
C. Implementation Of The Remedies Proposed In The
PRAP Will Not Achieve A Faster Cleanup Of The
Ground Water. _____
EPA has stated in the RI/FS and the PRAP that the
combination of MOM-2B and MOM-5A will not reduce the time of
cleanup to reach ARARs throughout the aquifer to less than
53 years. EPA further stated in the PRAP that
implementation of the proposed remedy can only affect a
portion of the aquifer, and that remediation cannot result
in a complete cleanup without source control. Actually,
once source control has been effectively implemented, the
ground water will achieve cleanup levels for TCE and other
compounds within 15 to 20 years, without implementing any of
the proposed alternatives discussed in the RI/FS.
Under EPA and its contractor Ebasco's
calculations, the proposed mitigation of migration remedy
would only remediate a portion of the aquifer in 30 years.
However, the Agency admits that it is not certain whether
this remedy could clean up the aquifer as a whole in
32
-------
53 years. Thus, if the proposed mitigation of migration
remedy were successful, only 5 percent of the mass of
contamination would be removed. Drinking water criteria
would not be met in any portion of the aquifer until the
year 2022, leaving the remainder of the aquifer, and
95 percent of the contaminant mass, to be cleaned up through
natural attenuation by the year 2045 (assuming effective
source control and no construction delays).
At the time of the 1986 ROD, EPA believed that,
with source control, the aquifer could be cleaned up within
10 to 12 years. 1986 ROD, at p. 13.5 As explained
extensively below, Westinghouse believes that EPA's original
prediction is closer to the truth, and that once source
controls are properly implemented, natural attenuation will
clean up the aquifer in 15 to 20 years. If source controls
and natural attenuation will take only 15 to 20 years to
cleanup the aquifer, then the remedy proposed in the PRAP is
completely unnecessary. However, even if EPA's current
calculation of the time to cleanup is correct, the best
EPA's proposed remedy can hope to achieve is to remove
5 percent of the contaminant mass and cleanup a portion of
5. Indeed, the Responsiveness Summary to the 1986 ROD
stated that cleanup could occur even faster; the
Responsiveness Summary predicted a cleanup time of 5 to
10 years.
33
-------
the aquifer within 30 years, as opposed to 53 years. It
would not be cost-effective to spend $14 million to achieve
such a limited result.
1. EPA And Ebasco Have Overestimated The Time
For Natural Attenuation To Clean Up The
Aquifer.
In order to calculate the cleanup time of 53 years
for the Newtown Creek aquifer, EPA's contractor used its
proprietary "Flush-Pro" batch flushing model. This model
uses a simplistic assumption that one flush of clean water
through a contaminated aquifer will remove all of the
contaminated water and then a mass of contamination will
desorb from the soils into the water. Each addition flush
will then remove additional mass until the desired
concentration (the "target" concentration) is achieved..
Multiplying the number of flushes by the time estimated for
each flush equals the time for cleanup. By using an
extraordinarily high soil/water partitioning value ("Kd"),
EPA overestimated the mass of TCE absorbed to the soils and
underestimated the mass of TCE desorbed from the soils by
each flush.
The mass of contaminant desorbed from the soils
after each flush is proportional to the soil/water
partitioning coefficient. The higher the Kd value, the more
tightly the contaminant sorbs to the soils, and therefore,
34
-------
the more flushes are required to remove the contaminant.
The easiest way to evaluate the effect of Kd upon
contaminant transport and therefore cleanup time is to
calculate the retardation factor ("Rd") for the particular
Kd used. The retardation factor is the ratio of the average
velocity of ground water to the average velocity of the
contaminant. As an example, a Rd of 10 means that the
ground water travels 10 times faster than the contaminant.
The retardation factor is calculated from the Kd
coefficient and the ratio of soil bulk density to porosity
using the equation: Rd = 1 + Pb/n x Kd, where
Rd is the retardation factor;
Pb is the soil bulk density, which EPA estimates
as (1-n) x the average mineral density of
2.65 g/cc;
n is the porosity; and
Kd is the soil/water partitioning coefficient.
Inserting EPA's value of 1.76 ml/g for Kd and 0.35 for
porosity gives a retardation factor of 9.6. Therefore, for
its estimation for cleanup time, EPA estimated that TCE
traveled approximately 10 times slower than the average
ground water flow rate. Westinghouse believes that this
retardation has been overestimated by a factor of 3 to
7 times.
35
-------
It has been extensively documented that TCE is not
well retarded. Retardation factors observed for TCE in many.
other aquifers are reported in the general literature to be
on the order of 3 or less; Ebasco used an Rd of 3.2 in their
modeling for EPA Contract No. 68-01-7250 (July 1987). EPA
uses values that result in a retardation factor of 2.9 in
its toxicological profile for TCE.
EPA's data for the Newtown Creek aquifer, show that
TCE is only slightly retarded. In the preliminary-RI, Dames
& Moore compared the migration rate of TCE to the average
ground water flow rate. Dames & Moore observed that TCE was
only slightly retarded, and therefore, in estimating .the
rate of travel of TCE, did not include retardation in its
calculations.
A very small partitioning (Kd) between soils and
ground water can be observed in the Ebasco RI data. At
those locations where TCE concentrations were measured in
both the soils (below the water table) and in the ground
water, TCE concentrations in soil were reported to be 5 to
50 times less that those observed in the ground water. If
the Kd for this aquifer were as large as the 1.76 used by
EPA, the expected concentrations in soil should have been on
the order of twice the concentrations observed in the ground
water.
36
-------
The Kd factor used by EPA is too large because it
was estimated using outdated "published" Koc (organic carbon
partitioning coefficient) values for TCE instead of measured
values. (Multiplying Koc by the organic carbon content of
the aquifer yields Kd). Published values for Koc range from
41 ml/g to 494 ml/g. EPA choose 126 and an organic carbon
content of 1.4 percent to arrive at the Kd value of
1.76 ml/g. At least three separate investigators have
directly measured Koc for TCE in several types of soil. The
Koc arrived at from these separate investigations was a
narrow range of 41 ml/g to 42 ml/g, one third of the lowest
estimated value. A Kd value of 0.6 ml/g results when a Koc
value of 42 is multiplied by EPA's estimate of 1.4 percent
organic content. This in turn yields a retardation factor
of 4.
It can be readily seen that the retardation factor
rises exponentially with the organic carbon content ("Foe")
of the aquifer. The organic carbon content was established
by measurement of Foe organic carbon in a soil sample from a
depth of 9 feet. The Foe should be obtained in the section
of the aquifer where TCE transport is primarily occurring.
Westinghouse expects that the Foe in the bulk of the lower
glacial outwash materials is significantly lower (less than
1 percent) resulting in lower retardation values.
37
-------
Accordingly, the 53 year period selected by Ebasco
is not supported by retardation factors observed in other
aquifers, by the partitioning of TCE only soils from ground
water in the Newtown Creek aquifer, or by direct measurement
of TCE partitioning onto organic carbon (Foe). Natural
attenuation will occur more quickly once effective source
control is implemented. Using EPA's own batch flushing
model, as published in EPA's Guidance on Remedial Actions
for Contaminated Ground Water at Superfund Sites (December
1988) and a more appropriate retardation factor of 3 to 4
(Kd = 0.4 ml/g), a more realistic, but still very
conservative estimate of the time for natural attenuation to
be effective is 15 to 20 years, assuming, as EPA does, that
all sources are controlled.
2. EPA Lacks Confidence That The Proposed Remedy
Will Be Successful.
Even if one accepts EPA's and Ebasco's assumptions
on their own terms, EPA does not have confidence that the
remedies proposed in the PRAP will ever achieve drinking
water standards in any part of the Newtown Creek aquifer.
The Agency stated in the PRAP that "EPA recognizes that the
final selected remedy may not achieve this goal [meeting
drinking water standards] because of the technical
difficulties associated with removing contaminants to ground
water cleanup levels." PRAP, at p. 6. EPA has only
38
-------
proposed this remedy as an interim measure, not a final
remedy with the intent to study and adjust the interim
measure in an effort to find out whether any ground water
remedy will be effective.
Given the "high degree of uncertainty" which the
Agency has about the potential success of this remedy, the
selection of this remedy at this time is unjustified. As
discussed previously, the necessary precondition for this
remedy -- effective source controls -- is not in place, and
there is no immediate need for the remedy from a public
health or water supply perspective. Accordingly, there is
no compelling reason at this time for EPA to spend
$14 million on a remedy which EPA is not sure will work. A
better course of action would be to implement source
controls and gather additional data about the aquifer before
determining whether any mitigation of migration remedy is
needed at all. If, as Westinghouse predicts, effective
source controls and natural attenuation will be sufficient
to remediate the aquifer within 15 to 20 years, no further
mitigation of migration remedy will be needed.
3. The Proposed Remedy Cannot Be Justified As An
Interim Measure.
In the PRAP, EPA attempts to justify the selection
of this remedy as an "interim" measure, a precursor of an
unidentified "final" remedial action to be selected later.
39
-------
However, selection of this remedy as an interim measure is
inconsistent with the new NCP and EPA's Guidance documents
on interim remedies.
Section 300.430 of the new NCP sets forth the
criteria for appropriate phased operable units, and provides
basic program management principles. 55 Fed. Reg. at 8,846.
The NCP provides that sites should be remedied in operable
units when any actions are necessary or appropriate to
achieve significant risk reduction quickly; when phased
analysis is necessary or appropriate given the size or
complexity of the site; or to expedite the completion of the
total site cleanup. In addition, the operable unit
(including interim actions) should not be inconsistent with
nor preclude implementation of the expected final remedy.
The preamble to section 300.435 of the new NCP
states that interim measures are acceptable for controlling
or preventing the further spread of contamination while EPA
is deciding upon a final remedy. 55 Fed. Reg. at 8,738-39.
To justify EPA's preferred alternative as an interim
measure, the NCP- requires EPA to demonstrate this
alternative is effective to control or prevent migration of
contamination prior to final remediation, and is necessary
to assure protection of human health and the environment.
See 55 Fed. Reg. at 8,739. As demonstrated above, EPA's
40
-------
proposed remedy would only remove 5 percent of the
contaminant mass. Moreover, EPA admits that even if these
remedies are implemented, contamination will spread through
to the southern edge of the aquifer.
This proposed remedy does not operate to
significantly reduce any risk. EPA has already ameliorated
any significant health risks by hooking up the population to
the public water supply. EPA's proposed remedy will not be
effective by any of the Agency's estimates, for at-least
30 years, so it will provide no immediate benefits.
Moreover, even then, the proposed remedy will only remove
5 percent of the contaminant mass and will only effect a
portion of the aquifer. Given the limited effect MOM-2B and
MOM-5A will have on preventing or controlling migration
within the aquifer, and that public health is already
addressed via hookup, the preferred alternative is not
justified as an interim measure.
EPA cannot justify this "interim remedy" as
expediting the cleanup of the Site. Under EPA's
j
calculations, even if this remedy is effective, drinking
water standards will not be achieved in any part of the
aquifer for 30 years. Drinking water levels would not be
achieved in the remainder of the aquifer for 53 years, just
as quickly as if EPA relied on source control and natural
41
-------
attenuation. Under Westinghouse's calculations, source
control and natural attenuation will be successful in 15 to
20 years.' Either way, the proposed "interim" measure will
not speed up the completion of cleanup.
EPA's Guidance on Remedial Actions for
Contaminated Ground Water at Superfund Sites at p. C-'l
(December 1988) identifies four factors to be evaluated In
determining whether it is appropriate to select an interim'
remedy.6 In this case, all four criteria are either
unsatisfied or EPA lacks sufficient information to determine
whether the criteria are satisfied.
"The interim action is necessary or
appropriate to stabilize the site,
control the source, prevent further
degradation, prevent exposure, or
otherwise significantly reduce
threats to human health and the
environment."
Implementation of the proposed interim remedy will
accomplish none of these goals. There is no immediate:need
to stabilize the Site. EPA admitted in 1986 that the ground
water contamination may have existed for 30 to 40 years.
Responsiveness Summary to 1986 ROD, at p. 4. The proposed
remedy does not control the sources of contamination, so
implementation will not reduce the influx of contaminants.
6. The Guidance also identifies five statutory criteria
which must be met by both interim and final remedies. These
criteria are discussed on pages 62-83.
42
-------
Indeed, the "interim" remedy is being selected before source
controls have been fully examined. The proposed remedy will
not prevent further degradation because it will not affect
the edge of the plume. Moreover, as discussed previously,
the proposed remedy will not significantly reduce the mass
of materials in the aquifer. Finally, the proposed remedy
does not prevent exposure or risk. As EPA stated in the
1986 ROD, EPA has already responded to the most significant
risk by connecting the residents to public water supplies.
Moreover, the Elmira Water Board has an adequate supply,
especially when the air stripper is installed at the
Sullivan Street Wellfield. Finally, according to EPA's
calculations this "interim" remedy would not be effective
for 30 years, and then in only a portion of the aquifer.
"The interim action will not
exacerbate the site problem."
EPA is unable to adequately consider this factor
because the ground water has not been completely
characterized. For example, EPA has not considered the
impact of MOM-5A on the feeder canal located where EPA
expects to place extraction wells. EPA should completely
characterize the ground water and implement source control
before selecting a mitigation of migration remedy. The
43
-------
proposed remedy may attract contamination from uncontrolled
sources into the capture zone.
"The interim action is consistent
with the final remedy."
This criterion spotlights the major failing of the
proposed "interim" remedy. The interim remedy may not only
be inconsistent with the selection of the final remedy, it-
may prove to be unnecessary. Because EPA has successfully
implemented institutional controls through hookups to public
water supplies, no further "interim" remedy is needed. The
NCP recognizes that institutional controls are appropriate,
where waste posses a relatively low long-term risk or where
treatment is impracticable. 55 Fed. Reg. at 8,846. Hence,
where an "interim" remedy is predicted to work in 30 years
if at all, institutional controls are more effective in
limiting health and environmental risk. Without adequate .
characterization of the ground water system and without ;
studying the effects of source control on the behavior of
the aquifer system, EPA is not in a position to determine
whether the implementation of this remedy will be
beneficial, let alone consistent with ground water cleanup. ,
This is particularly true where EPA has announced that there
44
-------
is "a high degree of uncertainty" whether any type of ground
water remedy will meet the cleanup standards.
"There is a commitment to evaluate
additional information and select a
final remedy within a specified
time frame."
EPA does not have sufficient data to determine
whether this remedy will be effective or whether any final
remedy would be effective. In particular, EPA has not
adequately characterized all sources and has not assessed
source controls, even though EPA admits that effective
controls are a necessary pre-condition for the remedy to
work. EPA should gather the necessary information to
evaluate the effectiveness of a ground water remedy before
embarking on a $14 million commitment without knowing
whether it will achieve any long term or short term benefit,
or will work at all.
Because none of these criteria are satisfied,
interim remedial measures are not warranted at this time.
EPA should not use a $14 million "interim" remedy as an
information gathering device. Fourteen million dollar
ground water remediation remedies should be selected only as
final cleanup options after all the information is
available, not as interim measures when there is a "high
degree of uncertainty" that they will work because of the
"technical difficulties" associated with removing
45
-------
contaminants to achieve ground water cleanup levels. There
are less costly and more effective means available to gather
the necessary data, such as additional source
characterization and assessment of source controls. The
best means for the Agency to gather additional information
is to implement source controls at currently identified
sources of contamination and then determine the effect on
the levels of contaminants in the aquifer in order to
determine whether all sources have been identified'.
D. Selecting This Remedy At This Time Is Neither
Cost-Effective Nor Consistent With The NCP.
Selection of the proposed mitigation of migration
remedy at this time is not cost-effective nor consistent
with the NCP. As Westinghouse has previously demonstrated,
effective source controls, together with natural
attenuation, should allow the aquifer to achieve cleanup
levels within 15 to 20 years, not within the 53 years which
EPA predicts. Therefore, it is unnecessary and unduly
costly to spend $14 million on a proposed remedy intended to
cleanup a portion of the aquifer in 30 years, as EPA
proposes.
Even if EPA's calculation of the time to clean up
the aquifer were correct, all that the proposed remedy could
accomplish would be to reach drinking water standards in a
portion of the aquifer by the year 2022 (estimating two
46
-------
years for construction). The proposed remedy would not
hasten the achievement of .ground water ARARs in the
remaining portion of the aquifer prior to the year 2045,
when EPA predicts natural attenuation would achieve those
levels throughout the aquifer. Moreover, the proposed
remedy would only remove 5 percent of the contaminant mass.
EPA's goal of cleaning up part of the aquifer
within 30 years, rather than 53 years, is not justified on
the basis of protecting public health or the environment.
As discussed previously, there is no public health basis for
this action since the Elmira Water Board has a sufficient
supply of drinking water. Even if this were the concern,
additional supply could be obtained by installing an air
stripper at the Kentucky Avenue well.
In addition to these concerns, there is the more
basic problem that EPA lacks the technical confidence that
the proposed remedy will work as intended. EPA's underlying
assumption in proposing this remedy is that source control
measures are operating effectively. No such measures,
however, are in place. Even if effective source control
measures were installed, EPA has admitted to a "high degree
of uncertainty" about the capability of the proposed remedy
to work, and has acknowledged "technical difficulties" in
achieving ground water cleanup levels.
47
-------
Under these circumstances, it is inconsistent with
the NCP and not cost-effective to spend $14 million on an
uncertain remedy. In the preamble to the NCP, EPA stated
that in selecting a remedy "[c]ost is considered in
determining cost-effectiveness to decide which options offer
a reasonable value in light of the results they achieve."
55 Fed. Reg. at 8,729. Here, the cost of the proposed
remedy is an unreasonable value in light of both the limited
utility of the desired results and the uncertainty that it
will achieve any of those results.
If EPA were to comply with the 1986 ROD, and
properly characterize sources and assess source controls,:
before selecting an additional mitigation of migration
remedy, EPA may determine that the successful implementation
of source controls will achieve the same or better results
as the PRAP remedy. Even if the source controls as
initially designed are not sufficient, the source control
option may be modified to improve its effectiveness at lower
cost than the PRAP remedy.
EPA should develop a better data base before
spending $14 million on a remedy which the Agency admits -may
not achieve ground water cleanup faster than natural
attenuation. EPA should proceed with the remedy selected in
the 1986 ROD. EPA should characterize sources, assess the
48
-------
impact of source control and collect further data concerning
the TCE plume. EPA should only select a remedy when source
controls have been assessed and a more complete ground water
data base is available.
V. THE REMEDY PROPOSED IN THE PRAP IS INCONSISTENT WITH
THE NCP AND NOT COST-EFFECTIVE.
A. EPA Does Not Have Sufficient Data To Select A
Remedy At This Tine.
EPA cannot select or effectively implement a
remedy at this time because sufficient information regarding
contaminant sources and migration pathways has not been
collected. Moreover, in many instances, the data collected
by EPA is of questionable quality or use. In these cases,
Westinghouse cannot determine if these data have been used
to generate conclusions leading to the preferred remedy.
1. Ineffective Source Identification And
Contaminant Pathway Characterization.
EPA has identified the drainage ditch at the
Westinghouse facility as a major source of contamination.
The surface water and sediments in this ditch exhibited
lower concentrations of TCE than in Site ground water or
from soils collected from Areas 4 and 17. Other areas,
however, were not considered as sources.
Although EPA has not identified the Old Horseheads
Landfill as a source, the Agency has located the ground
49
-------
water recovery system of MOM-5A immediately downgradient of
the landfill. EPA should not have ended investigations of
this landfill (and Areas 15, 16 and 17) based on one day of
site inspection, records review, and interviews. The
landfill, based on its previously uncontrolled nature,
should have been investigated with geophysical and/or soil
borings and monitoring wells designed to monitor it
successfully.
EPA incorrectly used soil-gas data in the
Supplemental RI to characterize several potential source
areas. At the landfill, clayey soils near the surface cause
perched water conditions, saturating near surface soils.
Soil-gas results from a shallow depth, however, were
reported as clean. First, saturated conditions will
eliminate vapor and VOCs from this zone. Second, the fine
grained materials and perched water would effectively
eliminate VOCs from deeper contamination to be detected by
the methods used.
At location SO-26, soil-gas results were likely
faulty. Soil-gas results showed nothing and the location
was identified as "background," yet the laboratory
analytical results showed contamination present.
Normally, because soil-gas investigations can be a
cost-effective method of initial source screening, enough
50
-------
locations are tested to find and localize the highest areas
of contamination. In the RI, insufficient data was
collected to locate the areas of greatest contamination and
therefore potential sources may have been missed.
Insufficient data was collected to identify the
source of TCE in ground water upgradient to Westinghouse
(95 ug/L at Horseheads Automotive). It was incorrectly
concluded in the RI that the primary source of TCE is from
Westinghouse when greater concentrations may exist
upgradient, as well as downgradient. If this is true, then
the remedy selected cannot have been chosen as the best
method for the mitigation of migration of TCE.
A major flaw in the characterization of ground
water contaminant migration pathways is the assumption of
TCE migration simply along ground water flow directions.
Because TCE has a specific gravity greater than water
(1.46), it has been demonstrated by EPA and others at other
sites that TCE often travels largely independent of ground
water flow patters. TCE can move along soil interfaces or
bedrock soil boundaries.
The rationale used to select locations for Phase
II well clusters (CW-7, CW-9, and CW-10 and point samples
PS-2, PS-3, PS-4, PS-5, PS-6 and PS-7) is based on the
premise that TCE contamination is moving only in the
51
-------
direction of ground water flow. This completely ignores
demonstrated gravity flow-characteristics of dense
nonaqueous phase liquids such as TCE. These well clusters
and point samples were installed after evaluation of data
obtained for "Regional Wells" and after evaluation of data
derived from literature and air photo reconnaissance. This
reasoning can be used to invalidate EPA's elimination of LRC
Electronics, Inc. as a potential source of contamination.
Initial RI, at pp. 4-17, 4-40. It also invalidates the
statement that background contamination of TCE is not coming
from outside the study area. Initial RI, p. 4-18.
The effectiveness of the ground water remedy,
especially MOM-5A, will depend on complete source
identification and pathway characterization. Since neither
has been sufficiently completed, the remedy could be
implemented with little or no effect. It is inappropriate
to spend $5.8 million to answer this question.
2. Data Of Unknown Or Unacceptable Quality Can
Not Be Used To Reach Conclusions Or Evaluate
Potential Remedies.
There are numerous instances where data or
information reported should not have been included in the
RI/FS, or at least should not have been used to generate
conclusions related to aquifer or contaminant
characterization or remedy selection. Although \
52
-------
Westinghouse has not been able to evaluate the effect of
this data on the final selection of a remedy, these examples
are indicative of unacceptable quality assurance/quality
control ("QA/QC") during either sampling or report
generation.
The analytical results in the Supplemental RI show
that metals are generally only present in unfiltered samples
of ground water, e.g., that they are adsorbed to fine
sediments. This may indicate one or more of the following
factors are present: (1) poor well development; (2) poor
monitoring well design (slot size selection and/or sand pack
selection); and/or (3) poor characterization of "background"
concentration of metals. The existence of one or more of
these factors would produce flawed and inaccurate analytical
results in the Supplemental RI.
Some metals such as calcium, magnesium, and iron
are reported as present, while sodium and potassium are
reported as not present; this combination is not probable
and indicates either analytical or reporting errors.
Benzo(k)fluoranthene concentration is reported as
800NA where NA represents "not analyzed." Further, numerous
examples of laboratory contaminants are present in the
samples. TCE, tetrachloroethylene (PCE), 2-butanone,
hexane, 2-hexanone, methelyene chloride, acetone, benzene,
53
-------
4-methyl-2-pentanone, xylenes, and 1,1,l-trichloroethane
were detected in lab samples and blanks, which were prepared
using municipal water. This water may have also been used
for decontamination. In addition, PCBs were reported to be
found in a duplicate samples only. Table 4-27 of the
Supplemental RI indicates non-detects for 1,1,1-
trichloroethane in Sample D-3; however, the duplicate Sample
D-8 was not analyzed for 1,1,l-trichloroethane. Each of
these examples indicates a breakdown in QA/QC procedures.
Hence, the validity of the data record is in question.
At several places in the Supplemental RI, such as
p. 4-101, reference is made to data present in Appendix A;
however, the data is not presented there. This makes review
and verification of conclusions difficult, if not
impossible.
3. EPA's Mitigation Cf Migration Analysis Fails '
To Properly Assess The Impact Of The Proposed
Remedies On The Plume.
The goals for the proposed action, as stated in
the PRAP are: (1) halt the spread of a contaminant plume
and (2) remove contaminant mass. EPA further states that
the proposed remedy will allow the collection of data on the
aquifer and contaminant response to remediation measures.
PRAP, at p. 6. These goals cannot be satisfactorily met by
the proposed MOM-5A remedy.
54
-------
The first goal of the proposed MOM-5A remedy is to
prevent further migration of TCE into the Newtown Creek
aquifer. The MOM-5A renedy will not achieve this because
the pumping rates proposed for this remedy are too small to
capture the contaminant plume alleged to originate on
Westinghouse property. In addition, the remedy does not
address other identified and unidentified sources, such as
the Facet Enterprises and LRC Electronics, Inc. facilities
and other sources of TCE.
The pumping rates for the proposed MOM-5A remedy
are underestimated because the calculations do not take into
account a major contribution of ground water into the
aquifer. EPA defines the portion of the aquifer to be
remediated by MOM-5A as 1600 feet wide, 2900 feet long and
30 feet deep. FS, at Table C-l and Figures 4-8 and C-l. A
net recharge to this portion of the aquifer (precipitation -
evapotranspiration and runoff) is estimated to range from
0.4 million gallons per day (mgd) to 0.75 mgd. An average
recharge value of 0.5 mgd is used in EPA's calculation. FS,
at Table C-5. EPA then subtracted 0.3 mgd estimated to be
the net withdrawal from pumping at Westinghouse. The
estimates for that value are presented on Table C-2. EPA
then assumes that only the remaining 0.2 mgd (which equals
140 gpm) has to be pumped to contain the plume.
55
-------
EPA has applied a technique that may have been
appropriate to a small isolated aquifer but not to a portion
of a large prolific aquifer. The MOM-5A portion of the
aquifer is only a very small portion of the larger Newtown
Creek aquifer and the interconnection and interaction with
the rest of the aquifer (termed "underflow" or "baseflow")
must be taken into consideration. As any introductory
ground water text will show, ground water underflow is very
much a part of the hydrologic cycle. In the case of the
Newtown Creek aquifer, it can be demonstrated that a very
substantial volume of ground water flows into and out of the
MOM-5A portion of the aquifer from the rest of the aquifer.
Any pumping scheme must take into account that volume of
water in order to successfully contain a plume.
The amount of ground water underflow can be
calculated using Darcy's equation (Discharge, Q = K i A) ,
the same values for hydraulic conductivity (K = 890 ft/day)-
and hydraulic gradient (i = 0.005), and a cross-sectional
area (A) of 1600 feet x 30 feet from the design aquifer
dimensions on page C-3 that EPA used for evaluating its
remedial alternatives. FS, at p. C-2.
Entering these values into Darcy's equation and
applying a conversion factor of 7.48 gallons per cubic foot
yields a value of 1.6 mgd (divided by 1440 minutes/day =
56
-------
1100 gpm). Therefore, the theoretical volume of ground
water to be removed to successfully contain the contaminant
plume must equal at least the 1.6 mgd flowing through this
portion of the aquifer.
Thus, it can be seen that the MOM-5A pumping would
capture only 12.5 percent of the water flowing through this
portion of the aquifer (0.2 mgd/1.6 mgd). The remaining
87.5 percent of contaminated ground water would bypass the
MOM-5A wells and enter either the Kentucky Avenue well, if
it were operating, or into the Newtown Creek aquifer, if the
well were not.
It can also be shown using EPA's assumptions and
equations (Draft Final Feasibility Study Report, July, 1990,
Section 4, p. 4-59 and Appendix C, p. C-10) that the MOM-5A
wells will not contain a contaminant plume because the
capture zones of the MOM-5A wells do not overlap. As EPA
notes: "The individual pumping rate, . . . governs the
capture zone width and the number of wells." FS, at p. C-l.
In Appendix C of the FS, the spacing for the
various pumping scenarios, including the MOM-5A wells, was
determined by calculating the width of the capture zone for
a single well using two equations from Keely & Tsang.
Keely, J.F. & Tsang, C.F., 1983, "Velocity Plots and Capture
Zones of Pumping Centers for Ground-Water Investigations,"
57
-------
GROUND WATER, vol. 21, no. 6. This is a generally accepted
procedure and has been incorporated into the EPA Office of
Ground-Water Protection's model for wellhead protection.7
U.S.E.P.A., Office of Ground-Water Protection, Feb. 1990,
WHPA - A Modular Semi-Analytical Model for the Delineation
of Wellhead Protection Areas.
A capture zone width of 577 feet was calculated
for a single well pumping at 400 gpm. This capture zone
width was then conservatively rounded to 500 feet. FS, at
p. C-ll. EPA then used this spacing to determine that
4 wells would be required for MOM-5A to capture the ground
water across a 1600 foot line.
The final individual well pumping rate proposed
for the MOM-5A alternative is only 35 gpm (a total.of
140 gpm for 4 wells). Entering a value of 35 gpm into the
Keely-Tsang equations would yield a maximum capture zone
width of only 50 feet per well. Assuming no overlap, the
combined capture zone for the four wells would be 200 feet
wide, or 12.5 percent of the desired 1600 foot capture zone
width. From another viewpoint, it would require 32 wells at
7. It should be noted that the constant pi was omitted from
the denominator of the Keely-Tsang equation 1 presented on
page C-10 of the FS. This does not affect EPA's calculation
of the capture zone width because it was calculated using
the correct equation.
58
-------
35 gpm each (1120 gpm total) to achieve complete capture
across a 1600 foot line. It is no coincidence that both the
Darcy's law analysis and the Keely-Tsang equations show that
the MOM-5A remedy will yield only a 12.5 percent capture
rate, and that at least 1100 gpm will be necessary for
complete capture.
The second stated goal of the proposed MOM-5A
remedy is to remove contaminant mass. The MOM-5A remedy
will remove a small mass of contaminant. However, it can be
shown the mass removed will be very small and will not
justify the $5.8 million cost to the public.
It can be shown that this remedy proposes to
remove only 5 percent of the total contaminant mass from the
Newtown Creek aquifer. EPA estimated the size of the
contaminated portion of the Newtown Creek aquifer as
6500 feet wide, 13,500 feet long, and 30 feet deep with a
porosity of 0.35 (FS, at Appendix C, Table C-l, FS Figure
1-8, and p. C-2) which equals 921 million cubic feet of
contaminated water. For estimation purposes, EPA assumes
that the aquifer is uniformly contaminated with TCE at a
concentration of 25 ug/L. The portion of the aquifer to be
remediated by MOM-5A is 1600 feet wide, 2900 feet long and
30 feet deep. At a porosity of 0.35, this equals
48.7 million cubic feet of contaminated water or only
59
-------
5 percent of the mass assumed to be contaminated. As stated
on page E-5 of the FS, the remaining 95 percent of the
contaminated aquifer is left to reach cleanup levels by
natural attenuation.
Second, it can be shown that even assuming EPA;1 s.
assumptions regarding the partitioning of TCE between water
and soil, the remedy will remove only a small mass. The
total mass to be removed by the MOM-5A remedy can -be
calculated using the average concentration of TCE observed
in the aquifer (as EPA assumes in the FS, at Table C-7), and
the equations for calculating mass on page C-12 of the FS.
EPA assumes an average TCE concentration in ground water of
25 micrograms per liter (ug/L) . Using conversion factors o'f
28.32 liters per cubic foot and 1,000,000,000 micrograms per
kilogram, the approximate mass of TCE in the 48.7 million.
cubic feet of water can be estimated at 34 kilograms.
The mass of TCE absorbed onto the soils is : .
calculated by first multiplying the concentration in the
water by a soil/water partitioning coefficient (Kd) then ;
multiplying the soil concentration by the mass of the soil.
See equations on FS, at p. C-12. EPA uses a Kd value of
1.76 liters/kilogram (L/kg). As discussed previously,
Westinghouse does not agree with this value, but, for the
sake of argument, it will be used for these calculations.
60
-------
Multiplying 25 ug/L by 1.72 L/kg equals a soil concentration
of 43 ug/kg.
The mass of the soil can be calculated from the
aquifer volume and the soil bulk density. The soil bulk
density equals 1 minus porosity times the average mineral
density of 2.65 g/cc. Using EPA's porosity of 0.35 yields a
bulk density of 1.72 g/cc. For ease of computation, this
can be converted to kilograms per cubic foot and would equal
48.7 kg/cf. The size of the MOM-5A portion of the .aquifer
equals 139.2 million cubic feet. Multiplying these two
valyes equals 6,779 million kilograms. This value can then
be multiplied by 43 ug/kg and divided by 1 billion ug/kg to
equal a mass of 297 kg TCE in soil. The total mass,
therefore, would equal 34 kilograms + 297 kilograms, or
331 kilograms.
The target water concentration for TCE is 5 ug/L.
FS, at p. 3-10. Using the above equations, this would mean
leaving approximately 66 kg of TCE in this portion of the
aquifer. With the MOM-5A remedy, EPA proposes to pump
2 billion gallons (17 billion gallons of water if the
appropriate pumping rate of 1100 gpm is used) over a period
of 30 years to remove approximately 265 kilograms or less
than one 55 gallon drum of TCE. At an estimated cost of
61
-------
$5.8 million for the MOM-5A remedy, this equals $105,455 per
gallon of TCE removed.
EPA's proposed MOM-5A alternative is technically
impractical. The solution would require treatment of
enormous volumes of water with low TCE concentration for a
period of tens of years.
B. The Remedy Proposed In The PRAP Does Not Satisfy
The Nine Criteria For Selecting Remedies Provided
In The NCP.
If the remedies proposed in the PRAP are evaluated
using the nine criteria identified in the NCP for selecting
remedies, it becomes apparent that the selection of these
remedies would not be simply inappropriate, but arbitrary
and capricious. These remedies do not satisfy any of the
criteria, except State acceptance, and many of the criteria,
such as long-term effectiveness and cost, compel another
choice.
1. Overall Protection Of Human Health And The
Environment.
a. The Proposed Remedy Does Not Provide For
Any Significant Additional Protection Of
Human Health And The Environment.
The proposed remedy does not improve overall
protection of human health and the environment. The 1986
ROD addressed the immediate public health concerns by
providing that all citizens be connected to public water
supplies, rather than using private wells. Accordingly, no
62
-------
one is exposed to the substances in the ground water plume
because all citizens are connected to the municipal water
supply, except for two families who refused connection. To
the extent EPA has or expects to identify other private well
users within the potential capture zone, those users may be
connected to public water supplies or subject to water use
advisories or restrictions, as provided in the 1986 ROD.
Moreover, under EPA's calculations, the proposed
remedy would not achieve drinking water criteria in any
portion of the aquifer until the year 2022. There is no
current need for the Kentucky Avenue Wellfield to be
reinstated because the Elmira Water Board has an adequate
supply of drinking water, using the filtered river water and
the Sullivan Street Wellfield (with the air stripper). If
additional water supplies are needed, a second air stripper
may be installed at the Kentucky Avenue Wellfield.
The proposed remedy, even if successful, would not
improve the protection of human health and the environment.
According to EPA's Risk Assessment, arsenic accounts for
87 percent of the calculated health risk in the average
exposure case, and 95 percent of the health risk in the
maximum plausible exposure case. As described below, at
page 65-68, the arsenic levels observed in ground water at
the Site are within expected background ranges. The
63
-------
proposed remedy cannot be expected to remove naturally
occurring arsenic. Moreover, under Westinghouse's
calculation, source controls and natural attenuation would
achieve ground water ARARs throughout the aquifer in 15 to
20 years. Implementation of a mitigation of migration
remedy would not result in speeding up the time to cleanup.
Using Ebasco's calculations, EPA projects that
implementation of this remedy would only achieve cleanup of
a portion of the Newtown Creek aquifer in 30 years. The
proposed remedy would not hasten the 53 years which EPA
expects it would take for the remainder of aquifer to meet
ground water ARARs through natural attenuation.
Accordingly, even if one accepted Ebasco's calculations, no
public health or environmental benefit will be achieved for
30 years, and then it will only affect a portion of the
aquifer, and will have removed only 5 percent of the
contaminant mass.
Finally, the Elrnira Water Board has an adequate
supply of drinking water without the use of the Kentucky
Avenue Wellfield. Table 1 presents census data from 1980
and 1990 for the area served by the Elmira Water Board and
compares these data to water usage from 1980, 1984, and 1988
data. While the population decreased by 3.0 percent from
1980 to 1990, water usage decreased 2.6 percent from 1980 to
64
-------
1988 (the most recent year for -which Westinghouse has data) .
Additionally, 1988 data indicates about 56 percent of the
water supplied by the Elmira Water Board came from treated
surface water. In 1981, about 57.9 percent of the water
supplied was treated and came from surface water.
Therefore, the Elraira Water Board has an adequate water
supply without implementing the proposed remedies.
b. The Risk Assessment Does Not Provide An
Adequate Foundation For The Feasibility
Study.
Because of fundamental shortcomings contained in
the RI, the risk assessment does not provide an adequate
foundation for the FS. The failure of the RI to fully
characterize all major sources of TCE and to identify a
plausible source of arsenic results in a faulty exposure
assessment.
(1) Arsenic.
Based on a review of background levels of arsenic
in soil, surface water, and ground water, it appears that
arsenic is only present at background levels. USGS and
ATSDR report natural background arsenic concentrations from
less than 10 ug/L to greater than 50 ug/L. USGS, "Study and
Interpretation of the Chemical Characteristics of Natural
Water," U.S. Geological Survey Water-Supply Paper 2254
(1985); ATSDR, "Toxicological Profile of Arsenic" (Draft),
65 .
-------
Life Systems, Inc. (Nov. 1987). The geometric mean of
concentrations found in the aquifer was approximately 10
ug/L. The maximum concentration observed was 55 ug/L. The
proposed remedy will not reduce the levels of arsenic
present in the ground water. Moreover, it will only
slightly reduce the risk to human health, because 87 percent
and 95 percent of calculated excess incremental cancer risk
for the average exposure case and plausible maximum exposure
case, respectively, are due to arsenic.
EPA appears to be aware of the weakness of the
case for arsenic since the following disclaimer is included
in the discussion of limitations of the risk assessment:
It should be noted, however, that the
measured concentrations of carcinogenic
PAHs, PCBs, and inorganic compounds in
soil and sediment may not necessarily be
solely related to contamination at the
source areas studied, but rather to
background levels. In the absence of
detailed site-specific background data,
these chemicals were conservatively
assumed to be entirely the result of
contamination in the potential source
areas evaluated.
RI, at p. 7-14.
The FS does not consider the impact of this
disclaimer in its evaluation of the risk assessment. In
addition, the current cancer potency factor for arsenic may
result in over estimates of risk by as much as an order of
magnitude. Lee Thomas memorandum as cited in USEPA,
66
-------
"Integrated Risk Information System (IRIS) Database,"
Printout for Arsenic (Aug. 1990).
Errors are noted in the toxicity assessment such
as definition of the plume, estimation of excess cancer
risk, etc. For example, the reference to "safety" factors
should be revised to "modifying and uncertainty" factors.
The cancer slope factor cited in USEPA, "Special Report on
Ingested Inorganic Arsenic: Skin Cancer; Nutritional
Essentiality," EPA/625/3-87/013 (July 1988c) is 5 x 10"5
(ug/L)"1 which is equivalent to 1.75 (mg/kg/d)"1 not 2.0
(mg/kg/d)'1 as used in the risk assessment. The draft of
this report, goes on to state that "[t]he estimates of risk
resulting from ingestion of inorganic arsenic be modified
downwards by one order of magnitude, through the use of a
modifying factor of 10 to reflect the seriousness of the
exposure, primarily the likelihood of inducing lethal
cancer." USEPA, "Special Report on Ingested Inorganic
Arsenic: Skin Cancer; Nutritional Essentiality," SAB Review
Draft, EPA/625/3-87/013A (Nov. 1987). The risk assessment
does not reflect this modification.
The maximum concentration of arsenic in the
drainage ditch sediment was 7.21 mg/kg. Arsenic was not
detected in surface water, but the geometric mean
concentration of arsenic in ground water is 9.8 ug/L.
67
-------
According to the tables presented in Chapter 6 of the RI,
the maximum concentration of arsenic found in soil samples,
excluding those from Area 2, is 25.6 mg/kg. One soil sample
from Area 2 (the Chemung County Department of Highways Area)
contained 123 mg/kg of arsenic. The maximum concentration
of arsenic detected in soil samples collected by GAI from
the ISTDP property is 20.5 mg/kg. Other than a possible
arsenic source in Area 2, the concentration of arsenic
detected in soils is consistent with background data
obtained from the literature.
(2) Trichloroethylene Source.
The average concentration of TCE in ground water
was 1-1.7 ug/L which is greater than the maximum
concentration detected in surface water from the drainage
ditch (the concluded source of TCE contamination), which was.
3 ug/L. The maximum concentration of TCE observed in ground
water was 121 ug/L. The maximum concentration of TCE
detected in sediments, from Area 3 was 0.011 mg/kg,' which, is
less than the maximum concentrations detected in subsurface
soils from Areas 4 (0.037 mg/kg) and 17 (0.015 mg/kg), and
comparable to levels detected in subsurface soils from »
Areas 2 (0.008 mg/kg) and 15 (0.01 mg/kg). A sediment
sample collected by GAI at the mouth of the ISTDP southeast
discharge contained 0.006 mg/kg of TCE. See GAI Draft
68
-------
Report (1988). Neither TCE nor its degradation products
were detected in a sample of the discharge water. See GAI
Draft Report (1983).
Although these results indicate the wide-spread
presence of TCE, they do not represent concentrations one
would expect to find at the source of the contamination.
Further, these concentrations do not suggest that the
drainage ditch sediments contain significantly more TCE than
is found throughout the area, as would be expected if the
effluent were a major source.
Further, probable field and/or laboratory
contaminants were incorrectly included as contaminants of
concern, specifically the common phthalate esters, methylene
chloride, and acetone. According to EPA guidance, "no
positive sample results should be reported unless the
concentration of the compound in the sample exceeds 10 times
the amount in any blank for the following contaminants:
methylene chloride, acetone, toluene, 2-butanone and common
phthalate esters. The amount for other volatile and
semivolatiles should exceed five times the amount in the
blank." USEPA, "Proposed Guidelines for Exposure-Related
Measurements," 53 Fed. Reg. 48,830 (Dec. 2, 1988); USEPA,
"Laboratory Data Validation Functional Guidelines for
Evaluating Organic Analysis (1988b). Based on this
69
-------
guidance, the inclusion of low level TCE concentrations in
ground water as positive detections must also be
reconsidered. The use of these data distorts the definition
of the TCE plume and therefore any selection remedy.
(3) Other Inadequacies Of The Risk
Assessment.
In addition to problems with TCE and arsenic,
there are general problems with the risk assessment that
indicate its use as a foundation to the FS is unjustified.
The risk assessment should also consider more
recent estimates of carcinogenic potency of benzo(a)pyrene,
as well as relative potency estimates for the other
potentially carcinogenic PAHs. EPA has also verified or
proposed the following oral RfDs which were not used in the
risk assessment: toluene (0.2), arsenic (0.001), manganese
(0.1), acenaphthene (0.06), anthracene (0.3), fluoranthene
(0.04), fluorene (0.04), and pyrene (0.03). Further, the :
oral cancer slope factor for beryllium is 4.3 (mg/kg/d)"1.
In addition, there are a number of problems in the
analysis of pathways of exposure. Specifically, the risk
assessment should state that, at present, the ground water
exposure pathway is not complete; therefore, the risk is
only hypothetical. However, according to EPA's definition,
potential future use of ground water is a plausible pathway.
70
-------
The exposure assessment is also flawed with
respect to the identification of five important source
areas. The RI states that "[t]he most important source area
identified in Section 4 for the contaminants of concern
include Westinghouse Electric Corporation facility, the
Facet Enterprises site, and LRC Electronics, Inc." RI, at
p. 6-54. Considering that no soil data has been considered,
collected, or evaluated in the risk assessment in any of
these areas, this sweeping statement does not have any
justification. This weakness is consistent with others such
as, a source of arsenic has not been identified and
plausible potential sources of TCE have only been partially
characterized.
In addition, EPA's risk assessment and RI contain
flaws regarding the application of ARARs. Proposed maximum-
contaminant levels ("MCL"s) are not potential ARARs, they
are only criteria to be considered ("TBC"s). Only nonzero
MCLGs are potential ARARs. Drinking water health advisories
are, at best, only TBCs. Ambient water quality criteria
must consider current toxicity data if they are used as
ARARs or TBCs.
Finally, the primary reference for risk assessment
methodology and format in the RI is the outdated Superfund
Public Health Evaluation Manual (USEPA, 1986). This manual
71
-------
is not consistent with the recent, Summer of 1989, EPA
guidance entitled Risk Assessment Guidance for Superfund
Human Health Evaluation Manual fHHEM) (USEPA, 1989) and with
the Environmental Evaluation Manual (USEPA, 1989).
2. Compliance With ARARs.
EPA has stated in the PRAP that because the
proposed remedy would be an "interim" measure, it should not
be evaluated in terms of achieving compliance with ARARs.
PRAP, at pp. 9-10. However, the stated goal of the proposed
remedy is to achieve drinking water ARARs in a portion of
the aquifer within 30 years. PRAP, at pp. 6, 11. .If
compliance with ARARs is not a relevant factor for
evaluating this interim remedy under the NCP, then the ;
proposed remedy should be rejected because it has no lawful
purpose.
Moreover, even if the remedy is evaluated in terms
of its intended goal compliance with drinking water
levels in a portion of the aquifer it is insufficient.
In the PRAP, EPA has expressed "a high degree of '
uncertainty" that the proposed remedy will achieve ground .
water ARARs in ajny part of the aquifer. As discussed above,
the Agency has not collected sufficient data to properly
characterize the sources, and source controls have not been
72
-------
implemented. Without sufficient data and effective source
controls, the proposed remedy cannot be effective.
EPA has further acknowledged that, even if
successful, the proposed remedy will not achieve compliance
with ground water ARARs throughout the entire aquifer. The
best that EPA can predict is that the remedy will achieve
compliance with ARARs in a portion of aquifer in 30 years,
and the rest of the aquifer in 53 years, the time when EPA
expects cleanup to occur through natural attenuation.
Accordingly, the remedy achieves no significant benefit over
the "no action" alternative in terms of meeting ARARs.
EPA stated in the PRAP that "the final selected
remedy may not achieve this goal [of drinking water
standards] because of the technical difficulties associated
with removing contaminants to ground water cleanup levels."
PRAP, at p. 6. The Agency further stated that it may waive
the ground water ARARs if the cleanup is technically
impracticable. PRAP, at p. 11. Thus, the EPA is proposing
to use an "interim" remedy as an experiment to see whether
ARARs are attainable. If the experiment fails, EPA then
proposes to waive ARARs. This approach is not cost-
effective.
EPA should not spend $14 million on an "interim"
remedy to determine whether remediation is practicable. EPA
73
-------
should not select any mitigation of migration remedy until
it has first adequately assessed all sources and
successfully implemented sources controls. At that point,
if the Agency determines that the attainment of drinking
water ARARs is technically practical throughout the aquifer
within a meaningful time period, it may consider whether a
mitigation of migration remedy is appropriate. EPA should
not spend $14 million on a remedy when the Agency has no
certainty whether the remedy can meet the cleanup standards
it is intended to achieve.
3. Long Tern Effectiveness And Permanence.
The proposed remedy will not be a permanent remedy
and will not achieve long term effectiveness. EPA has made
clear in the PRAP that it is uncertain whether this interim
remedy will achieve the desired cleanup levels in a portion
of the aquifer intended to be affected by the remedy within
the projected 30 years. EPA also stated that it does not
know if any final remedy will be able to achieve ground
water clean up levels, or whether it will waive ground water
ARARs.
The NCP requires that alternatives be "assessed
for the long-term effectiveness and permanence they afford,
along with the degree of certainty that the alternative will
prove successful." 40 C.F.R. § 300.430(e)(9)(iii)(C);
74
-------
55 Fed. Reg. at 8,849. Here, EPA recognizes a "high degree
of uncertainty" that the proposed remedy, or any mitigation
of migration remedies will be effective. Moreover, if the
remedy works according to EPA and Ebasco's calculation, it
would take 30 years before this remedy would be effective in
any portion of the aquifer, and it would not be effective in
the remainder of the aquifer for 53 years. The proposed
remedy MOM-5A, therefore, does not significantly reduce
risks to the public. Accordingly, EPA's own lack of
confidence in this proposed remedy demonstrates that it will
not be effective on a long term basis or be a permanent
remedy.
In addition, EPA's remedy will not be effective if
all sources have not been identified or if all contaminant
pathways have not been adequately characterized. EPA has
based the effectiveness of this remedy, in part, on the
statement that Facet Enterprises and LRC Electronics, Inc.
"could not contribute to the ground water contamination at
the Kentucky Avenue Well." PRAP, at p. 5; Supplemental
RI/FS summary point number 5. These facilities, however,
are potential sources of contamination found at the well.
Site characterization borings SB-7A, SB-ISA, and
SB-23A (Sup. RI, p. 3-13) indicate the uppermost surface of
the impermeable lacustrine silt/clay dips to the west
75
-------
immediately east of the Kentucky Avenue well. TCE sinking
through the aquifer flowing along this surface could reach
the Kentucky Avenue well from sources south and east of the
Kentucky Avenue well, such as Facet Enterprises and LRC
Electronics, Inc.
EPA does not address the natural movement of TCE
and other VOCs as dense non-aqueous phase liquids ("NAPLs")
in Section 5, yet all VOCs shown in Table 5-1, except vinyl
chloride, are heavier than water. This additional.-and
unaddressed pathway opens up the possibility of sources
other than Westinghouse and removes the justification given
for the selected remedy.
EPA has not demonstrated that the proposed remedy
would be any more effective on a long term basis than
implementing source control. Indeed, the PRAP suggests that
none of the options identified in the FS would be effective
without source control.
EPA cannot justify this proposal as either an
interim measure or a permanent remedy. The proposal is
unnecessary as an interim measure, and ill-considered and
inadequate as a permanent remedy.
76
-------
4. Reduction .Of Toxicity, Mobility And Volume.
The remedy proposed in the PRAP does not achieve
any significant reduction in the toxicity, mobility or
volume of the materials in the plume.
The remedy in the PRAP will not significantly
reduce the toxicity of the plume, since EPA's proposed
remedy would only remove 5 percent of the contaminant mass.
Moreover, under EPA's calculations, the proposed remedy
would not lower toxicity to achieve drinking water quality
for at least 30 years and then only for a portion of the
aquifer. EPA predicts that the remedy may not achieve
ground water cleanup goals throughout the aquifer for more
than 53 years, if at all. Even under Westinghouse's
calculations, the proposed remedy will not significantly
enhance the rate of cleanup which can be achieved through
source control and natural attenuation.
The proposed remedy will not reduce the mobility
of materials in the plume, since EPA has acknowledged that
materials will continue to flow through the Newtown Creek
aquifer to below Sullivan Street. Moreover, because the
identification of sources and the characterization of the
aquifer is incomplete, implementation of the remedy may
increase the migration from unidentified sources and may not
capture the migration from other sources.
77
-------
The proposed remedy will not result in any
meaningful reduction of volume. As calculated above, the
proposed remedy will remove 5 percent of the contaminant
mass, or about one 55-gallon drum of material.
Although the proposed remedy involves the use of.
treatment technology, so does source control. EPA may
satisfy the statutory preference for treatment technologies
through source control without undertaking this unnecessary
remedy.
5. Short Term Effectiveness.
The proposed remedy would be ineffective on a
short term basis. At EPA's most optimistic assessment, the:
proposed remedy would take 30 years to cleanup a portion of'
the aquifer. EPA has acknowledged, however, that this
remedy cannot be effective until source controls are . ..
implemented. Moreover, EPA has indicated that, even if . .
effective source controls are implemented, the technical.
difficulties in remediating the ground water may make:..this
goal unachievable. PRAP, at p. 6. Thus, the proposed
remedy may not achieve any faster cleanup than through
natural attenuation.
6. Implementabilitv.
The proposed remedy is not truly implementable.
The remedy cannot be effective before source controls are
78
-------
operating effectively. The impact of source control
measures on the aquifer have not been considered. Source
controls may make the proposed alternative unnecessary or
even counterproductive. Yet this remedy is proposed prior
to the implementation of source controls. Even EPA has
expressed uncertainty that this remedy will be effective,
even with source controls. PRAP at p. 6. Only after all
sources have been adequately characterized and source
controls have been assessed and implemented, could a
mitigation of migration remedy, if necessary, be
implemented.
7. Cost: The Proposed Remedy Is Not Cost-
Effective.
In various provisions of SARA, Congress repeatedly
expressed its intention that cleanup remedies be "cost-
effective." For example, § 112(a) states that "the
President shall select remedial actions . . . which provide
for cost-effective response." 42 U.S.C. § 9621(a). Section
121(b)(l) repeats the requirement that the President only
select cost-effective remedies. 42 U.S.C. § 9261(b)(l).
Finally, the provisions concerning the NCP, as originally
promulgated in 1980, require consideration of cost-
effectiveness. 42 U.S.C. § 9605(1).
Both the legislative history of SARA and the
preamble to the recently promulgated revised NCP demonstrate
79
-------
that cost-effectiveness becomes an issue once EPA has
identified various remedies which all adequately protect
human health and the environment. See 55 Fed. Reg. at
8,727; H.R. Rep. 962, 99th Cong., 2d Sess.-245 (1986). EPA
noted in the preamble to the revised NCP provisions that "it
is clear that if all the remedies examined are equally
feasible, reliable, and provide the same level of
protection, the lead agency will select the least expensive
remedy."8 55 Fed. Reg. at 8,727 (quoting 50 Fed. Reg. at
47,921 (Nov. 20, 1985)). Moreover, EPA clarified in the
preamble to the recent NCP that the statutory requirement
that remedies be cost-effective applies to both Fund-
financed as well as PRP-financed remedies. Id. at 8,729.
Once the Agency has identified various
alternatives, "cost is a legitimate factor for choosing
among such alternatives." Id. at 8,727. In a sense, the -.
8. This is more or less how EPA defined "cost-
effectiveness" in the past -- "the lowest cost alternative
that is technologically feasible and reliable and which
effectively mitigates and minimized damage to and provides
adequate protection of public health, welfare, or the
environment." See U.S. v. Northeastern Pharmaceutical,
810 F.2d 726, 748 (8th Cir. 1986); U.S. v. Northernaire
Plating Co., 685 F. Supp. 1410, 1415 (W.D. Mich. 1988),
affjjd, 889 F.2d 1497 (6th Cir. 1989); United States v. Ward.
618 F. Supp. 884, 900 (D.N.C. 1985).
In the preamble to the new NCP, EPA notes that Congress,
in the legislative history of SARA, "specifically approved
of the approach to cost-effectiveness taken by EPA in the
1985 NCP." 55 Fed. Reg. at 8,726
80
-------
process is simply one of deciding "which options offer a
reasonable value of the money in light of the results they
achieve." Id. at 8,729. As stated in the new NCP, cost-
effectiveness is determined by comparing overall
effectiveness to costs to ensure that the remedy is cost-
effective. "A remedy is cost-effective if its costs are
proportional to its overall effectiveness." 55 Fed. Reg. at
8,850 (to be codified at 40 C.F.R. § 300.430(f) (1) (ii) (D) ) .
Here, the proposed remedy is an unreasonable value
for its $14 million cost for several reasons. First, EPA
has "a high degree of uncertainty" that it will be
successful at all. EPA has admitted that the proposed
remedy cannot be successful until source controls are
effectively implemented. EPA has further acknowledged that
ground water ARARs may not be unattainable at all at this
Site.
Second, under Westinghouse's calculations, this
remedy may be unnecessary because source control and natural
attenuation will achieve clean up levels throughout the
aquifer in 15 to 20 years. This remedy would not enhance
natural attenuation.
Third, even under EPA's calculations, the maximum
benefit achieved by this remedy is that drinking water
standards would be achieved in a portion of the aquifer in
81
-------
30 years, rather than 53 years. Thus the proposed remedy
would not speed up the time to achieve ground water ARARs in
of the aquifer as a whole. Moreover, the proposed remedy
would only remove 5 percent of contaminant mass.
Fourth, implementation of this remedy will have no
significant public health benefit. EPA has already
connected the citizens to public water supplies, so they are
not at risk. Water supplies are ample. Moreover, under
EPA's calculations, the remedy could only achieve drinking
water standards in a portion of the aquifer in 30 years, so
there would be no public benefit to private well users until
the year 2022. Finally, if any one were exposed to this
ground water, between 87 and 95 percent of EPA's calculated.
health risks would come from naturally occurring background
levels of arsenic.
As discussed above, EPA will determine whether a
remedy is cost-effective if it represents a reasonable value
for the money. Here, a $14 million expenditure would not
offer any reasonable value because it would not achieve any
significant public health or environmental result.
Therefore, at $14 million, this remedy represents an
unreasonable value and should be rejected in favor of the
82
-------
remedy selected in the 1986 ROD -- identification of all
sources, and implementation of source control.9
8. State Acceptance.
Although New York State may have initially agreed
to this remedy, the State, like EPA, did not have sufficient
data to make an informed decision because potential sources
were not adequately characterized and source control had not
been implemented.
9. Community Awareness.
The community is aware that an adequate drinking
water supply is being provided by using filtered river water
and by reinstating the Sullivan Street Wellfield. There has
been no popular demand for a remedy such as this one. As a
long time member of the community, Westinghouse has proposed
addressing this problem through source control and natural
attenuation.
C. The Proposed Remedy Is Not Required Under EPA's
Ground Water Policy.
EPA has acknowledged that a reasonable restoration
period for an aquifer may take several decades. By its own
estimate, EPA's remedy will take approximately 30 years to
achieve drinking water standards in 5 percent of the
aquifer. Under Westinghouse's calculations, source control
9. Moreover, EPA overestimated the cost of implementing
MOM-2B and MOM-5A.
83
-------
and natural attenuation will achieve clean up levels
throughout the aquifer in 15 to 20 years. Thus, active
restoration is not practicable, cost-effective or warranted
here.
EPA has said that active restoration is most
appropriate in Class I aquifers where there is need for a
drinking water supply or where institutional controls are
ineffective. The Newtown Creek aquifer is a Class IIA
aquifer, not a Class I aquifer. It is not classified as
Class I because a reasonable alternative source of drinking
water is available to the population and no unique habitats
are at risk of destruction.
Given current population trends in the area, there
is no immediate need for an additional drinking water
supply, nor is such a need likely in the foreseeable future.
Further, institutional controls will successfully protect.. -
the public. The Elmira Water Board, not private wells,
supplies drinking water.
In the preamble to the new NCP, EPA acknowledged
that natural attenuation is sometimes preferable over active
restoration. According to EPA, natural attenuation is
generally recommended when "active restoration is not
practicable, cost-effective or warranted because of site-
specific conditions (e.g., . . . ground water which is
84
-------
unlikely to be used in the foreseeable future and therefore
can be remediated over an extended period of time)."
55 Fed. Reg. at 3,734. The selection of natural attenuation
as a remedy does not mean that EPA has "written off" the
ground water and that it will "not be cleaned up." Id.
Rather, choosing natural attenuation only means that this
remedy will "effectively reduce contaminants in the ground
water to concentrations protective of human health in the
time frame comparable to that which could be achieved
through active restoration." Id. Finally, EPA acknowledges
in the preamble that pump and treat systems may be
ineffective, and natural attenuation may be necessary to
complete remediation. Id.
The proposed remedy is not practicable, cost-
effective, or consistent with the NCP when compared to
source control and natural attenuation. EPA has already
admitted that there is "a high degree of uncertainty"
whether this proposed pump and treat remedy will be
effective. Even if it does work, the proposed remedy will
take several decades, by EPA's calculation, to cleanup only
a portion of the aquifer at a cost of $14 million. Source
control and natural attenuation will clean up the entire
aquifer in 15 to 20 years. Active restoration is
unwarranted when ground water will not be used in the
85
-------
foreseeable future and when natural attenuation, in
combination with source control, will achieve clean up more
quickly at a lower cost.
In conclusion, by implementing source control,
coupled with natural attenuation, EPA would have a remedy
that is far superior to active restoration in terms of time,
safety, and cost. This approach would be consistent with
the Ground Water Policy and the NCP.
D. Proposed Remedy Exceeds EPA's Legal Authority
Under CERCLA And The NCP.
Section 104(a)(l) of CERCLA, 42 U.S.C.
§ 9604(a)(1), limits removal and other remedial activities
under CERCLA to the release or substantial threat of release
of a hazardous substance or any pollutant or contaminant..
EPA has proposed as part of the remedy to treat iron and
manganese. Iron and manganese are not hazardous substances.
under CERCLA, see 40 C.F.R. § 302.4, nor do they fall within
the definition of ''pollutant or contaminant," 42 U.S.C.
§ 9601(33). Finally, iron and manganese are naturally
occurring in the environment. See discussion below. Given
these factors, EPA does not have the authority under CERCLA
to reduce the level of these metals.
Further, EPA does not have the authority under
CERCLA to cleanup naturally occurring compounds, such as
arsenic and the metals found here. According to the draft
86
-------
FS (July, 1990), both MOM-2B and MOM-5A would comply with
the potential ground water, and surface water ARARs for
contaminants of concern. The "potential" ARARs for arsenic
iron, and manganese, however, are inappropriate, because
these contaminants are naturally occurring and therefore do
not fall within the scope of remedial actions under CERCLA.
Section 104(a)(3) of CERCLA contains various
limitations, one of which expressly excludes a removal or
remedial action in response to a release or threat of
release "of a naturally occurring substance in its unaltered
form, or altered solely through naturally occurring
processes or phenomena, from a location where it is
naturally found." 42 U.S.C. § 104 (a) (3) (A); see Amoco Oil
Co. v. Borden. Inc.. 889 F.2d 664, 670 (5th Cir. 1989).
Because § I04(a)(3) originated as § 112(b) of
Senate Bill S.51, which was the Senate's version of SARA and
which later became part of the final legislation, courts
have specifically relied upon Senate Report No. 11 in order
to interpret the scope of the various limitations contained
in § 104(a)(3). First United Methodist Church v. U.S.
Gypsum Co.. 882 F.2d 862, 868 (4th Cir. 1989), cert, denied.
110 S.Ct 1113 (1990); Retirement Community Developers, Inc.
v. Merine. 713 F. Supp. 153, 157 (D.Md. 1989). According to
the courts, the Senate Report makes clear that the
87
-------
§ 104(a)(3) "was intended to be a limit on the substantive
scope of CERCLA and not solely a limit on the President's
authority under the statute." Retirement Community
Developers. 713 F. Supp. at 157.
According to Senate Report No. 11, the Senate
amended section 104 in order to make "more explicit the fact
that certain circumstances which may present genuine threats
to human health, welfare or the environment are not within
the scope of CERCLA." S.Rep. No. 11, 99th Cong., 1st Sess.
15-16 (1985). The report goes on to note that EPA "has
encountered some difficulties, primarily political, in
restraining CERCLA responses to the scope of the law." Id.
at 16.
With respect to naturally occurring substances, .
the report states:
The provision on naturally occurring
releases excludes from remedial and
removal action situations such as
arsenic trioxide contamination of ground
water that is a result of natural
processes such as rainfall ... or high
concentrations of metal (e.g.. selenium)
in the surface or groundwater which
results from the natural leaching of
these metals from the undisturbed soil. .'
Id. at 16-17. Thus, naturally occurring substances such as
arsenic and various other metals, although they cause
contamination of ground water.and may be life-threatening,
are not covered under CERCLA.
88
-------
With respect to the Kentucky Avenue Wellfield
Site, arsenic and various other metals, such as iron and
manganese, have been detected at the Site. As described at
page 65-68, the concentrations of arsenic detected in the
soils are all within the range of natural background levels,
except for one sample. Iron and manganese are also
naturally occurring in the soil and ground water. Thus,
removal or remedial actions involving these contaminants, do
not fall within the scope of CERCLA under § 104(a) (3) (A) .
Indeed, iron and manganese are routinely removed, from
ground water by water supply systems who wish to "soften"
their water.
While there is an exception to the limitations
contained in § 104(a)(3), this exception is not applicable
here. The exception states that EPA may respond to an
emergency if no other person or entity has the capability to
do so in a timely manner. 42 U.S.C. § 9604(a)(4). First,
no true "public health or environmental emergency" exists,
because these elements do not present a significant health
risk and virtually all citizens are connected to public
water supplies. Second, the entity most capable to respond
to this contamination in a "timely manner" is the Elmira
Water Board which could install metals treatment if
additional water supply capacity were needed.
89
-------
CONCLUSION
For the foregoing reasons, Westinghouse requests
that EPA reopen the public comment period and that EPA make
publicly available all information about the RI/FS, so that
Westinghouse and others may have an opportunity to comment
more completely on the proposed remedies and EPA and
Ebasco's conclusions. In addition, Westinghouse requests
EPA to complete the implementation of the 1986 ROD and fully
identify and characterize all sources, and assess source
control measures at all sources before considering a
mitigation of migration remedy. EPA should defer all
consideration of whether a mitigation of migration remedy is
needed at the Site until source control measures are in
place at all sources and have been determined to operate.
effectively. The only appropriate remedy to select at thi's
time is MOM-1 "no action," coupled with the institutional
controls provided in the 1986 ROD.
Submitted by:
Westinghouse Electric Corporation
September 18, 1990
90
ATwpc:\80758-2\0112\2170\Comrnents
-------
Table 1
COMPARISON OF CENSUS DATA 1980 TO 1990
FOR AREA SCREENED BY THE ELMIRA WATER BOARD SYSTEM
POPULATION
Location 1980 1990
TOWNS
Elmira 7,735 7,393
Horseheads 20,238 19,880
Southport 11,586 11,538
VILLAGES
Elmira Heights 4,279 4,343
CITY
Elmira 35,327 33.634
TOTAi 79,165 76,788 3.0%
Decrease
TOTA.L WATER USAGE DATA - ELMIRA WATER BOARD
15.80 1984 1988
10.02 mgd 9.42 mgd 9.76 mgd 2.6% Decrease
91
-------
Response to Comments submitted by Weil, Gotshal C Manges on
behalf of Westinghouse Electric Corporation.
Pages 1-10. The comments are summarized as follows:
a) Westinghouse Electric Corporation believes that EPA did not
comply with its public participation responsibilities under
Section 117 of the Comprehensive Environmental Response,
Compensation, and Liability Act (CERCLA). b) Westinghouse
Electric Corporation believes it has not been provided adequate
time to comment on the Proposed Plan, c) Westinghouse Electric
Corporation requests a meeting with EPA before the Record of
Decision is executed to discuss the conditions and solutions for
the contamination problems at their facility, d) Westinghouse
commented that the model used by Ebasco Service is proprietary.
EPA Response; EPA has met the requirements of Section 117 of
CERCLA. Section 117 (a) of CERCLA states that the following
requirements be met before EPA adopts any plan for remedial
action.
1) "Publish a notice and brief analysis of the proposed plan and
make such a plan available to the public".
2) "Provide a reasonable opportunity for submission of written .
and oral comments and an opportunity for a public meeting at or
near the facility of issue regarding the proposed plan and
regarding any proposed findings under Section 121 (d)(4). The
President or the State shall keep a transcript available to the
Public".
EPA satisfied the requirements of Section 117 (a)(1) of CERCLA-
when it published a Public Notice in the ELmira Star-Gazette on .
July 21, 1990. This Public Notice is attached to this
Responsiveness Summary as Appendix B. This notice provides a
reasonable explanation of the proposed plan and the alternative
proposals. In addition, EPA distributed the Proposed Plan,
entitled "Superfund Proposed Plan, Kentucky Avenue Wellfield
Site, Chemung County, New York" July 1990 (Proposed Plan) to the
public repositories identified in the Public Notice, and mailed a
copy of the Proposed Plan on July 21, 1990 to interested parties
including Westinghouse Electric Corporation. A copy of the
mailing list is included in the Administrative Record File.
EPA satisfied the requirements of Section 117(a)(2) and 40 C.F.R.
Part §300.430 (f)(3)(C) (The National Oil and Hazardous
Substances Pollution Contingency Plan; Final Rule or simply NCP)
by establishing a thirty day public comment period. Upon
request by Westinghouse Electric Corporation, the public comment
period was extended by EPA for an additional 30 days as required
in the NCP. This is consistent with requests for extensions in
'Region II. The public comment period ended on September 13,
-------
On August 1, 1990 EPA held a Public Meeting at the Town of
Horseheads Town Hall located in the Town of Horseheads, New York.
At the public meeting, EPA explained the public participation
process in the Superfund Program, presented a general overview of
the Superfund Program and how it relates to the Kentucky Avenue
Wellfield site, discussed the results of the Supplemental
Remedial Investigation/Feasibility Study, and presented the
Proposed Plan. EPA answered all questions presented to us at the
public meeting and recorded all comments. A copy of the
transcript from the public meeting is a part of the
Administrative Record File for the Site.
Westinghouse Electric Corporation submitted a written request to
EPA on September 10, 1990 for a meeting with EPA to discuss
technical questions. (The technical questions and the EPA
response to these questions are provided in the Responsiveness
Summary section entitled "Response to comments submitted by
Phillips, Lytle, Hitchcock, Elaine & Huber on behalf of
Westinghouse Electric Corporation). EPA promptly scheduled a
meeting with Westinghouse on September 12, 1990, and EPA and its
contractor Ebasco Services, Inc. answered all the questions
which were raised by Westinghouse Electric Corporation, their
consultants and attorneys.
Problems encountered at many Superfund Sites are complex. It is
for this reason that EPA provides for at a minimum thirty day
public comment period, and EPA will extend the comment period ,.
when it receives a timely request. For the Kentucky Avenue
Wellfield Site EPA extended the public comment period by 30 days.
We believe that this is a sufficient amount of time to review the
Proposed Plan and the supporting documentation.
The "flush-pro" model used in the Feasibility Study conducted by
Ebasco Services Incorporated is not proprietary information.
Ebasco Services adapted the equations presented in the text of
the Feasibility Study, Appendix C, for use on a personnel
computer.
EPA cannot at this time commit to meet with Westinghouse Electric
Corporation to discuss the sources of contamination at the
Horseheads facility before the Second Operable Unit Record of
Decision is issued, but will meet with Westinghouse Electric
Corporation to discuss the Horseheads facility.
Page 11-18 Provide discussion on Facility history, operations and
operations, with comment.
?v.;;: .3 - -iC ' '^sc Inohc'jse Electric Corporation indicates that
they believe that EPA has failed to Implement the 1986 Record of
Decision.
EPA Response; EPA has implemented the 1986 Record of Decision as
-------
The 1986 Record of Decision Remedial Alternative Selection
"Description of Selected Remedy" reads as follows:
An investigation to identify all residences in the study area
currently using private wells. Upon completion of the
investigation, all private well users will be connected to
the public water supply.
Installation of monitoring wells upgradient of the Sullivan
Street wells, with sampling at and upgradient of the wells to
be performed on a quarterly basis.
Conduct a supplemental source control Remedial
Investigation/Feasibility Study (RI/FS) to identify the source
of contamination and to determine which, if any source control
measures would be feasible and cost effective. The source
control RI/FS will be a composite of both ongoing and
proposed studies at various potential source sites within the
study area.
1) The Supplemental Remedial Investigation/Feasibility Study was
conducted in order to determine the extent to which potential
source areas in the vicinity of the Kentucky Avenue Well
contribute to the aquifer contamination, (see Supplemental RI
Report). The work conducted for the Supplemental RI included
collection of 148 soil gas readings, completion of 32 soil
borings, and analysis of 147 soil samples for a large number of.
potential contaminants at the sites which were determined during
the design stage of the Remedial Action to require investigation.
In addition, EPA collected ground water samples for analysis for
either hazardous substance list or target compound list
parameters on at least three occasions from 30 monitoring wells,
and 3 residential wells. EPA conducted aquifer testing at 27
monitoring wells to characterize the aquifer properties.
EPA collected 8 surface water samples and 6 sediment samples in
order to have them analyzed for contaminants.
Incorporated in the Supplemental RI are data tabulated from
investigations within the study area including Westinghouse
Electric Corporation, Facet Enterprises, Inc., and LRC
Electronic, Inc.
The data collected by Westinghouse Electric Corporation is
included in the Supplemental RI/FS and supports EPA's contention
that the Westinghouse Electric Corporation Horsehead facility is
a source area. The investigation conducted by Westiijghov.se at
their fac:.'I L f :\2fl net evaluate source control measures.
-------
The Supplemental RI/FS enabled EPA to determine that the
potential source areas investigated by EPA were not contributing
to the aquifer contamination and therefore source controls are
not. necessary at the Chemung County Department of Highways
Garage, the Old Horseheads Landfill, the former Koppers Company
Properties, a sand and gravel pit, and a fill area. In addition,
EPA determined that therefore no source control measures would be
required.
2) As of August 1990, EPA had connected an additional forty five
residences to the public water supply due to TCE contamination in
their private wells.
3) Under a cooperative agreement with EPA, the New York State
Department of Environmental Conservation (NYSDEC) installed
monitoring wells strategically located in order to monitor ground
water quality upgradient of the Sullivan Street Wellfield.
Installation of these monitoring wells was completed in the
Summer of 1989, and were sampled by EPA in January 1990. The
results of the sampling are presented in the Supplemental RI
Report.
Page 23; The comment indicates that Westinghouse Electric
believes that the RI/FS has not adequately evaluated all
potential sources of TCE.
EPA Response: EPA conducted soil boring investigations and ground
water sampling investigations in order to evaluate if seven
potential source areas contribute to the aquifer contamination,
and to conduct a baseline risk assessment in order to evaluate
no-action alternatives at these seven areas. EPA detected
contaminants in soils at some of the areas investigated, but none
of these areas appear to be contributing to the TCE contamination
at the Kentucky Avenue Well.
In addition, EPA compiled data gathered during investigations at
industrial facilities in the Elmira-Horseheads area in order to
determine if and if so, the extent to which the facilities
contribute to contamination at the Kentucky Avenue Wellfield.
In January 1990, the New York State Department of Health provided
data to EPA which was collected during an investigation of 1,1,1-
trichloroethane contamination in the aquifer in the
Fisherville/Big Flats area. The data indicates that TCE is
present in the ground water at the Horseheads Automotive Garage
at a concentration of 95 ppb. The data provided to EPA is
presented in the Supplemental RI and EPA has considered this
data. Based -ipon :v;. fSi'aluatior. or this data en*" considerations
of the geologic and hydrologic conditions in this area EPA has
decided to conduct an evaluation of the ground-water flow
direction from the Horseheads Automotive Garage in order to
determine if this facility contributes to the contamination at
-------
the Kentucky Avenue Wellfield.
Westinghouse Electric Corporation has indicated that EPA did not
consider TCE contamination detected at monitoring well CW-2D and
two private wells in the Fisherville area.
EPA Response; EPA did consider the TCE at the Horseheads
Automotive Garage as discussed above. TCE was also detected at a
residence at 0.8 ppb. This data is presented in the Supplemental
RI Report. The level of 0.8 ppb TCE at this residence indicates
that the residence is not a likely source of TCE contamination at
the Kentucky Avenue Well, located approximately 1.7 miles away.
Page 24-25. Westinghouse does not believe that other facilities
identified including Facet Enterprises, Inc. and LRC Electronics
Inc. have been adequately characterized.
EPA Response: As discussed on page 6 of the Proposed Plan, Facet
Enterprises, Inc., a separate National Priorities List site, is
conducting a Remedial Investigation and Feasibility Study under
Administrative Order with EPA. EPA anticipates that a remedy .for
this facility will be selected during 1991. LRC Electronics,
Inc. is conducting an investigation under a consent agreement
with the New York State Department of Environmental Conservation
(NYSDEC), and the NYSDEC has indicated that they expect to select
a remedy within two years for this facility. The results from
both of the investigations at these facilities to date, have been
considered and incorporated into the RI/FS.
Page 28. The comments indicate that Westinghouse Electric
Corporation does not believe that EPA has justified selecting a
Mitigation (sic) of Migration Remedy before source control is.in:;
place.
EPA Response; Page 6 of the Proposed Plan "Scope and Role of the
Response Action" indicates that the goal of this preferred
remedial action is to halt the spread of a contaminant plume, and
to capture contaminant mass. In addition, page 6 of the Proposed
Plan indicates that the ultimate goal of EPA's Superfund Program
approach to ground water remediation as stated in the NCP, is to
return useable ground water to its beneficial uses within a time
frame that is reasonable. Therefore, for the Newtown Creek
Aquifer which is classified as a Class Ila aquifer, the final
remediation goals are State and Federal drinking water standards..
EPA is justified in its decision to halt the spread and capture
of contaminants, and furthermore it is acting in a manner
ccn-=-\stent wiua cur p.2':ix>nal policy and the NCP in the selection
of this remedy.
-------
Page 29 -31. The comment indicates that Westinghouse Electric
Corporation does not believe that there is an immediate need to
put the Kentucky Avenue Wellfield back in operation. The
comments indicate that the Sullivan Street Wellfield could be
used as a "reserve capacity". Westinghouse comments that EPA has
already connected all the families in the community to water
supplied by the Elmira Water Board, except two families which
have refused connection and drink from private wells.
EPA Response: The Kentucky Avenue Well is a public water supply
well closed in 1980 as a result of TCE contamination. In
September 1983, EPA placed the Kentucky Avenue Wellfield site on
the National Priorities List making it eligible to receive funds
from Superfund.
The proposal to distribute the ground water collected and treated
from the Kentucky Avenue Wellfield as a public water supply will
result in reinstating a natural resource which was developed for
public use by the Elmira Water Board during the 1960's and then
subsequently rendered useless in the early 1980's by the TCE
contamination. The data included in the "Annual Report 1988
Elmira Water Board City of Elmira, New York" indicates that
ground water used for public distribution increased from 9.3% in
1962 to 42.1% in 1981. This growth in ground water use resulted
from the large amount of exploratory work conducted by the Elmira
Water Board which indicated that the Newtown Creek Aquifer is a
long-term reliable source of drinking water. Since 1981, use of
the Newtown Creek Aquifer as a drinking water source has leveled
off as a consequence of contamination of the Newtown Creek
Aquifer. The use of this aquifer has leveled off, and not
discontinued altogether, because the Elmira Water Board relies on
the ground water to supply approximately 44% of its supply.
By reinstating the Kentucky Avenue Well and installing the
pumping wells between the Westinghouse facility and the Kentucky
Avenue Well now, EPA will begin a phased approach to restore the
aquifer quality while source control measures at Westinghouse are
evaluated.
Since the Proposed Plan was released in July 1990, the public has
provided information to EPA indicating that there are still
private well users in the Elmira-Horseheads area in areas
potentially impacted by contamination from the Westinghouse
facility. EPA has requested that the New York State Department
of Health sample residential homes that are using private wells
in this area. In addition, EPA has identified three additional
commercial facilities which use private wells as a potable water
source and therefore they sJ. ;uld be connected to the public water
supply.
The Elmira Water Board uses the Sullivan Street Wellfield to
supply approximately 30% of its total water supply.
-------
Pages 34-38. Westinghouse Electric Corporation indicate that
they believe EPA and Ebasco have overestimated the time for
natural attenuation to clean up the aquifer. Westinghouse
Electric Corporation also commented that they believe EPA lacks
confidence in the Proposed Remedy.
A detailed description of the modeling approach used by EPA is
provided as Response to comments submitted by Phillips, Lytle,
Hitchcock, Elaine & Huber on behalf of Westinghouse Electric
Corporation. The data EPA used to estimate cleanup was from
published reports, or data obtained in the field. As stated in
the Proposed Plan on page 6, this interim remedial action will
allow for the collection of data to assess aquifer and
contaminant response to remediation efforts. If the data
collected during this interim remedial action indicates that the
pumping is effective at reducing contaminant mass and preventing
the concentration of TCE in the aquifer from increasing, then EPA
may expand the aquifer remediation program in a phased approach
to achieve cleanup levels.
If the period required for aquifer remediation is less than 30
years this will be beneficial to both human health and the
environment. Models used to estimate remediation time are useful
tools. However, EPA has identified several trends and limiting
factors associated with ground water remediation actions at
Superfund Sites. (EPA Directive No. 9355.4-03 located in the
Administrative Record File) They are:
1. The extraction systems are generally effective in containing
contaminant plumes.
2. Significant mass removal of contaminants is being achieved.
3. Concentrations of contaminants have generally decreased
significantly after initiation of extraction systems but tend
to level off after a period of time. The leveling off may
begin to occur at levels above the cleanup criteria.
4. Data collection may not be sufficient to fully assess
contaminant movement and system response to extraction.
Factors which limit effectiveness may include:
1. Hydrological factors such as heterogeneity of the subsurface,
:.r the presence of low permeability layers.
2. Contaminant related factors such as sorption to soil.
3. System design parameters.
-------
8
4. Continued leaching from source areas.
Actual field data collected during the interim remedial action
will best determine the effectiveness of the selected remedy.
The data collected will permit an evaluation to assess the
feasibility of final aquifer remediation Record of Decision.
EPA does not lack confidence in the proposed interim remedy. The
purpose of the proposed interim remedy is to prevent the ground
water contamination from continuing to spread throughout the
Newtown Creek Aquifer, to collect data in order to optimize
design parameters for a final remedy, and to restore a potable
drinking water source. The data collected will be used to
optimize system design or to reconsider the technical feasibility
of reaching final remediation goals if remediation goals are not
approached during the interim remedial action.
Pages 39-46. Westinghouse Electric Corporation comments that 1)
The Proposed Remedy cannot be justified as an interim measure.
and 2) They do not believe that the Proposed Plan meets the
criteria set forth in EPA Guidance on Remedial Actions for
Contaminated Ground Water at Superfund Sites, as it relates to
interim remedial actions.
EPA Response; 1) EPA intends to evaluate the data collected
during this interim remedial action and issue a Record of
Decision which will either call for a complete aquifer program,
or, if necessary, will consider ARAR waivers because of a
technical impracticability of a pump and treat remedy to meet "
ARARs for the Newtown Creek Aquifer. The NCP states that interim
measures are acceptable for controlling or preventing the further
spread of contamination while EPA is deciding upon a final
remedy. That is the express goal of the pump & treat program at
the Site.
2) EPA has determined that the Proposed Plan would meet the
criteria for an interim remedial action. As specified in
Guidance on Remedial Actions for Contaminated Ground Water at
Superfund Sites.
The following criteria are from the Guidance, and an explanation
of how each criteria is met by the proposed action follows.
a) w The interim action is necessary or appropriate to stabilize
the site, control the source, prevent further degradation,
prevent exposure, or otherwise significantly reduce threats
to human health and the environment."
c] "The interim action will not exacerbate the site problem."
c) "The interim action is consistent with the final remedy."
-------
d) "There is a commitment to evaluate additional information and
select a final remedy within a specified time frame."
Pumping ground water at 700 gpm at the Kentucky Avenue Well, and
140 gpm from recovery wells down gradient of the Westinghouse
facility is intended to capture the contaminant mass and prevent
further deterioration of ground water quality within the Newtown
Creek Aquifer. This action is intended to stabilize the site by
capturing the flow of contaminants from Westinghouse Electric
Corporation. This interim action will permit the collection of
data to evaluate the aquifer and contaminant response to a ground
water pump and treat remedial action. In addition, the proposed
action will provide a reliable, long-term potable water supply.
EPA has characterized the quality of the ground water
sufficiently to determine that the Westinghouse facility is a
source of aquifer contamination. EPA has also conducted soil
boring and analysis investigation at other areas including the
Old Horseheads Landfill, the property formally owned and operated
by the Koppers Company, a sand and gravel pit, and the Chemung
County Department of Highways Garage. These areas which are
located in the vicinity of the Kentucky Avenue Well do not have
concentrations of contaminants indicating that they are a source
of aquifer contamination. Detailed design work will be conducted
in order to ensure that pumping wells are properly placed to
ensure effectiveness, and careful monitoring of the remedial
action will ensure that the ground water contamination problem'is
not exacerbated.
As stated in the Proposed plan the ultimate goal of EPA's
Superfund Progran approach to ground water remediation, as stated
in the NCP, is to return useable ground water to it's beneficial
uses within a time frame that is reasonable. EPA has reported
that the most common method for restoring contaminated ground
water is extraction and treatment of the contaminated ground
water, rather than taking no action to remediate the Newtown
Creek Aquifer, and restore it as a resource, as Westinghouse
repeatedly suggests; the goal of the proposed/remedy would make
this interim remedial action consistent with an anticipated/
potential final remedial action (" See Considerations in Ground
Water Remediation at Superfund Site. EPA Directive No. 9355.4-
03, included in the Administrative Record File").
There is a commitment to evaluate information from the known
sources of aquifer contamination and evaluate source control
measures. As discussed in the Proposed Plan (page 6), a RI/FS
for the Facet Enterprises, Inc. facility is scheduled for
completion in 1991. EPA anticipates selecting .a remedy for this
facility during 1991. Selection of source control measures at
the Westinghouse and LRC facilities are scheduled within two
-------
10
years.
Page 46. Westinghouse Electric Corporation commented that
selecting the remedy at this time is neither cost effective nor
consistent with the NCP and that they do not believe that EPA has
sufficient data to select a remedy at this time.
EPA Response; The Supplemental RI/FS has identified the potential
sources of aquifer contamination, and the delays associated with
further studies, are not in the publics best interest.
Furthermore, since EPA policy is to restore aquifers, 14 million
is not being wasted since, eventually it is likely we will select
aguifer remediation.
Westinghouse has assumed in their estimates of total time to
remediate the entire aguifer that the proposed interim remedial
action is the only action that EPA will take to remediate the
aquifer. EPA will collect data during this interim remedial
action and determine the feasibility of a complete aguifer
cleanup project. EPA may, for example, propose installing more
recovery wells to expedite the final cleanup if the results of
the interim action indicate that the pumping effectively reduces
contaminant migration, and/or reaching ARARs for the entire
aquifer is feasible.
EPA believes that the selected interim remedial action is cost
effective. The proposed interim action will begin the
remediation process for the Newtown Creek Aguifer, and it will..
provide a potable source of drinking water to the public. EPA
believes that the treatment technologies that are available and
are proposed for this remedial action can remove the contaminants
from the contaminated ground water to meet Federal and New York
State Drinking Water Standards, and that the proposed treatment
systems are cost effective in providing this treatment. Compared
to the other ground water remediation alternative evaluated, the
proposed interim action provides a cost proportionate to its
effectiveness. By implementing the Proposed Plan, EPA will
provide for initiation of an aguifer remediation program. A
phased approach which relies on data collected during each phase
of the remediation program is required for the Site because of
the extent of the contamination, the fact that more than one
source is contributing to the aguifer contamination, and because
of the complexity of evaluating aquifer response to pump and
treat remedial action over large areas of aquifer.
EPA believes that the data collected for the Remedial
Investigation is more than adequate to support the proposed
interim remedial a'-hi on.
Page 49. Westinghouse Electric Corporation indicates that EPA
identified a drainage ditch as a major source of contamination.
-------
11
EPA Response; Page 5 of the Proposed Plan #7, indicates that "The
results of sampling and analysis from a drainage way south of the
Westinghouse Electric Corporation Property indicate that
accumulation by heavy metals has occurred which may be a result
of the permitted industrial discharge from this facility. This
unnamed drainageway empties into a pond south of the Old
Horseheads Landfill, and then continues to flow south to the
Newtown Creek. The permitted discharges may also be contributing
to the metals and TCE contamination, although the primary
(emphasis added) source of TCE in the ground water is believed to
be from the disposal areas or spills at the facilities
identified in the Supplemental RI as contributors to the aquifer
contamination."
Page 50. Westinghouse Electric Corporation believes that EPA
should have performed soil borings at the Landfill before we
concluded that this is not a source of aquifer
contamination.
EPA Response; EPA collected soil gas data and performed soil
borings at the Old Horseheads Landfill. Section 4.2.3 of the
Supplemental Remedial Investigation Report discusses the results
of the investigations at this landfill.
Page 50. Westinghouse Electric Corporation believes that the
soil-gas results were faulty for boring SO-26 because no soil
gases were detected, but a boring at this location detected
volatiles.
EPA Response; Contrary to Westinghouse's assertion, the soil
boring data indicate that bis(2-ethylhexyl)phthalate (BEHP) was
detected in soil samples at a level of 120 ppb. The level of
BEHP and the nature of the contamination detected in this sample
does not indicate that this area is a source of contamination.
Page 53. Westinghouse Electric Corporation commented that the
QA/QC was not adequate for the samples collected by EPA.
EPA Response; All the samples collected were collected according
to EPA-approved field methods as described in the Field
Operations Plan. Also, all data is validated according to EPA
Region II Standard Operating Procedures as described in the
Region II CERCLA Quality Assurance Manual Final Copy October
1989.
Page 54. Westinghouse Electric Corporation questioned the model
used to calculate remediation time, and, presented an alternative
analysis. Westinghouse Electric Corporation feels that the
analysis of alternatives f-vils to properly assess the impact of
the proposed remedy on the plume. Westinghouse Electric
Corporation commented that with the pumping rate proposed, the
Keely and Tsang analysis does not indicate an effective
-------
12
withdrawal rate to prevent contaminant spread.
EPA Response; This response is provided in conjunction with our
Written Response to questions submitted to EPA by Philips, Lytle,
Hitchcock, Elaine, & Huber on behalf of Westinghouse Electric
Corporation.
Westinghouse uses the same generalized aquifer properties as EPA
for the Newtown Creek Aquifer, but then uses Darcy's Law to
calculate flow for ground water in the vicinity of the proposed
pumping wells. They arrive at a higher design pumping rate than
Ebasco. One difference between the results Westinghouse reached
and the results that Ebasco reached may be that the Westinghouse
calculations do not take into account the millions of gallons
withdrawn from the aquifer every day as a result of industrial
pumping at their facility.
The information presented in the Feasibility Study is not
intended to be a design. Careful aquifer testing and strategic
placement of recovery wells will be required. A major purpose of
the model used in the feasibility study includes evaluation of
cost effectiveness of the all the pump and treat alternatives
evaluated.
The proposed remedial alternatives are designed to prevent the
plume from the Westinghouse facility from spreading further into
the aquifer.
At this time EPA believes that the rate of ground water pumping
at the Westinghouse facility should be accounted for in the
preliminary design. The results of the modelling will be
verified during design stage to ensure that the pumping rate
during the remedial action is optimized.
Page 60. Westinghouse Electric Corporation comments that,
according to its calculations, EPA's proposal would result in
remediation of only 5% of the aquifer (or capture of 265
kilograms of TCE at a cost of 5.8 million dollars). Westinghouse
Electric Corporation argues that the proposed aquifer remediation
would only remove a small mass of contaminant at a cost of
$105,455 per gallon of TCE removed.
EPA Response; The calculations provided in the Supplemental RI
assume that the distribution of TCE is uniform throughout the
aquifer. This assumption is necessary in order to use the model
to evaluate the remedial alternatives cost effectiveness.
As indicated in the Supplemental RI, the contaminant
concentration is higher in source areas. Downgradient of the
source areas at the Westinghouse facility, EPA data indicate that
the concentration of TCE tends to be between 50 and 100 ppb for a
distance of 4000 feet southeast of the facility and then drops to
-------
13
20 ppb level or lower until other source areas contaminate the
aquifer. EPA studies indicate that by removing the higher levels
of ground water contamination early in the remedial process it
will prevent further degradation of aquifer water quality and
accelerate the overall remedial process.
EPA does not believe that by calculating the mass of TCE
dissolved in the water which will be removed is an appropriate
method of considering cost effectiveness of the proposed remedy,
because once a volume of water becomes contaminated with the TCE,
that entire volume of water must be treated. The TCE within the
water cannot be treated independently of the water itself. If
this remedial action continues for 30 years at a pumping rate of
700 gpm at the Kentucky Avenue Well, and 140 gpm at the recovery
wells, a total of 1.32 x 1010 gallons of water will be treated to
Federal and New York State drinking water standards. EPA
believes that the proposed treatment of this ground water is cost
effective.
Page 62. Westinghouse Electric Corporation comments that by
selecting the remedies in the proposed plan EPA would be acting
arbitrarily and capriciously.
EPA Response; The Proposed plan reflects that the ultimate goal.
of EPA's Superfund Program approach to aquifer remediation is to
return ground water to its most beneficial use. For the Kentucky'
Avenue Wellfield site, the contamination is widespread throughout
the Newtown Creek Aquifer, and there are a number of sources as
indicated in the Supplemental RI Report and the Proposed Plan.
For these reasons EPA has proposed a phased approach to aquifer
restoration. The proposed remedial action will provide a long-
term source of drinking water which meets Federal and New York
State Drinking water standards. The proposed treatment
alternatives for treating the ground water are easily
implementable, reliable, and demonstrated to be effective. The
proposed remedial action will reduce the mobility and volume of
contaminated ground water within the aquifer, and the proposed
treatment system is a cost effective method for treating ground
water. EPA received positive comments on our proposed plan
during the Public meeting held at the Town Hall in Horseheads,
New York. In addition, EPA received three positive written
public comments during the public comment period. Only one set of
written comments (from Westinghouse Electric Corporation) favored
a different remedy than EPA's Proposed Plan. Westinghouse
Electric favored a no-action alternative.
Page 68. Westinghouse comments that it is EPA's conclusion that
th« drainaceway is the sole source of TCE in the ground water.
EPA Response; The Supplemental RI and the Proposed Plan state
that the TCE sources in the vicinity of the Westinghouse facility
include former disposal areas, waste handling and storage areas,
-------
14
and spill areas and possibly the industrial drainageway.
Page 70. Westinghouse comments that incorrect Rfd values were
used by Ebasco in the Risk Assessment. Westinghouse provides
values for toluene, arsenic, manganese, acenaphthene, anthracene,
fluoranthene, fluorene, and pyrene. A oral cancer slope factor
for beryllium is provided.
EPA Response; The values provided by Westinghouse Electric
Corporation are the most recent data from the IRIS computer
system for risk assessment information. This data base is
updated monthly. Since completion of the risk assessment, values
have been updated in IRIS for toluene, manganese, and arsenic.
Also, the method for calculating risk associated with exposure to
the polyaromatic hydrocarbons has been recently changed from past
guidance.
EPA has considered the data provided by Westinghouse Electric
Corporation. All of the numbers provided by Westinghouse
Electric indicate that a lower risk due to exposure to soils
exists than that calculated in the risk assessment. The risks
posed by the soils at the seven areas investigated by EPA were
below a level at which Superfund would typically conduct an
action and therefore our conclusions about these areas are the
same as stated in the Proposed Plan.
Page 72. Compliance with ARARs.
EPA Response: The proposed interim remedial action for the
aquifer remediation will not by itself, result in the entire
Newtown Creek aquifer reaching ARARs. The proposed interim
remedial action will provide drinking water which meets all
Federal and New York State regulations for a public drinking
water supply and provide data to assess the potential for final
remediation of the aquifer. The goal of any aquifer remedy will
be to satisfy ARAR's, but compliance for an interim action is not
required; Westinghouse is inaccurate in concluding that an
interim remedy which has the intended goal of complying with
ARAiRs has no lawful purpose.
Page 74. Westinghouse commented that the Proposed remedy will not
be a permanent remedy and will not achieve long-term
effectiveness.
EPA Response: The proposed remedy will provide a reliable, long-
term source of potable water for the community.
Pa-je 75. 7eBr..;,.(-;;...,.us/; riectcic Company conrr.entfed that. "EFA h^3
based the effectiveness of this remedy, in part, on the statement
that Facet Enterprises and LRC Electronics, Inc. "could not
contribute to the ground water contamination at the Kentucky
Avenue Well."
-------
15
EPA Response; EPA does not generally base the effectiveness of
any remedy on a statement. Pump and treat remedial alternatives
have been proven at many Superfund sites to be effective at
containing contaminant migration. In addition, the ground water
treatment alternatives evaluated are proven technologies for
treating ground water to drinking water standards.
The Facet Enterprises facility is located between 4,000 and 5,000
feet south or slightly southwest of the Kentucky Avenue Well.
Ground water elevation data collected during the Supplemental RI
indicate that the water level elevation in the Newtown Creek
Aquifer at the Facet Enterprises facility is approximately 20
feet lower than at the Kentucky Avenue Well (without the well
pumping). TCE was detected during the Supplemental RI at the
Kentucky Avenue well and based on the data collected during the
Supplemental RI the Westinghouse facility has been identified as
a source of TCE. In addition, EPA has proposed to investigate a
possible source of aquifer contamination to the west of the
Westinghouse facility.
Page 77. Westinghouse commented that they do not believe that
the proposed remedy will achieve any significant reduction in the
toxicity, mobility, or volume of the materials in the plume.
Westinghouse Electric Corporation comments that although the
proposed remedy involves the use of treatment technology, so does
source control.
*
EPA Response; If the pumping wells and the Kentucky Avenue Well
pump at the estimated rate of 840 gpm for thirty years, the
ground water remediation program will treat a total of 1.32 x 1010
gallons of contaminated ground water which would have otherwise
continued lowering ground water quality within the Newtown Creek
Aquifer for the next 30 years. The proposed interim remedial
action will prevent the spread of contaminants to areas
downgradient of the pumping wells. The proposed interim remedial
action will reduce the mobility of the contaminants by preventing
contaminant flow downgradient of the pumping wells. EPA agrees
that source control measures would likely involve treatment
technologies, and establishing source control measures is
discussed as a priority in the proposed plan.
Page 78. Westinghouse Electric Corporation does not believe that
the proposed plan is implementable.
EPA Response; The interim remedial action is implementable.
Installation of recovery wells is relatively simple, and
restoration of the Kentucky Avenue Well, or the replacement of
the Kentu'-!<._.' Avenue Well, can be easily accomplished.
All the proposed treatment systems are proven technologies for
removing the contaminants to drinking water standards. All of the
material needed to implement this remedy are easily obtained, and
-------
16
the services needed to operate and maintain the pumping and
treatment systems are commercially available.
Page 79 Westinghouse Electric Corporation commented that they do .
not believe that the proposed remedy is cost effective. (This
comment is also made on the following pages: 22,45,46,73,74,79,
and page 87)
EPA Response; The capital costs of restoring the Kentucky Avenue
Well and providing a filtration system, air stripper, carbon
adsorption unit for the air emissions, and discharge to the
public water supply is estimated to be $1,089,000, and the annual
operation and maintenance costs are estimated to be $549,000.
The capital cost for the pumping wells installed down gradient of
the Westinghouse facility for treatment of the ground water with
filtration, air stripping, and carbon absorption for air
emissions, and eventual discharge to the public water supply is
estimated to be $839,600. Annual operation and maintenance costs
are estimated to be $355,600. EPA believes that considering the
benefits cf controlling contaminant migration and providing
additional potable water this is a cost effective proposed
remedy.
Page 83. Westinghouse Electric Corporation commented that
although the state initially concurred on the Proposed Plan, the
state and EPA did not have sufficient data to make an informed
decision because potential sources were not adequately
characterized and source control had not been implemented.
EPA Response: The New York State Department of Environmental
Conservation would have informed EPA if they felt that
insufficient data exists for them to concur on the Proposed Plan.
The NYSDEC has concurred on this Record of Decision. The letter
of concurrence is attached to the Record of Decision.
Page 83. Westinghouse Electric Corporation has evaluated
"Community Awareness" and has commented that 1) The community is
aware that an adequate water supply is being provided by another
source (by using filtered river water and by reinstating the
Sullivan Street Wellfield), 2) that there has been no popular
demand for the proposed remedy, and 3) that as a long time member
of the community, Westinghouse has proposed addressing the
problem through source control and natural attenuation.
EPA Response: EPA evaluates Community Acceptance of all Proposed
Remedial Actions at Superfund sites to ensure public input into
G-jr decision making process. The Community Acceptance is
generally ev ^-.iuated by the question and comment period during the
Public Meeting, and by evaluating comments sent by the Public to
EPA during the Public Comment Period.
-------
17
EPA received favorable comments on the Proposed Plan during the
Public Meeting with respect to our proposal to begin initiation
of an aquifer remediation program. (See Responsiveness summary
pp.12).
During the public comment period, EPA received six comments.
Three letters favored the planned interim remedial action. One
letter requested clarification of the Supplemental RI text, one
letter requested general information about the site, and
Westinghouse Electric Corporations letter which favors a no -
action alternative. Based on the comments received during the
public comment period EPA concludes that there is community
acceptance of the proposed interim remedial action.
Page 84. Westinghouse comments that "EPA has said that active
restoration is most appropriate in Class I aquifers where there
is need for a drinking water supply or where institutional
controls are ineffective."
EPA Response; The preamble to the NCP indicates that "EPA's
preference is for rapid restoration, when practicable, of Class I
ground water and (underline added for emphasis) contaminated
ground waters that are currently, or likely in the near-term to
be the source of a drinking water supply". The preamble to the
NCP further states that "For Class I and Class II ground waters,
preliminary remediation goals are generally set at maximum
contaminant levels,, and non-zero maximum contaminant level goals
where relevant an appropriate, promulgated under the Safe
Drinking Water Act or more stringent state standards..."
The Elmira Water Board began to develop the Newtown Creek Aquifer
resources in 1962 as a public water supply. In 1980, the
Kentucky Avenue Well provided approximately 10% of the water for
this public water supply. The Kentucky Avenue Well was closed
due to TCE contamination in the Newtown Creek Aquifer. In 1988,
the Elmira Water Board Sullivan Street Wells which obtain ground
water from the Newtown Creek Aquifer provided approximately 30%
of the total water required for this supply which serves
approximately 60,000 people.
Page 87. Westinghouse Electric Corporation comments that the
Proposed Remedy Exceeds EPA's Legal Authority Under CERCLA and
the NCP.
EPA Response; The Proposed Remedy does not exceed EPA's legal
authority under CERCLA and the NCP.
Section 104 {a} (1) r.f CEP.CIA f-.~ U.S.C, §9SC ; (a) (.1) indicate;;
'Whenever (a) any hazardous substance is released or there is a
substantial threat of such a release into the environment, or (b)
there is a release or substantial threat of release into the
-------
18
environment of any pollutant or contaminant which may present an
imminent and substantial danger to the public health or welfare,
the President is authorized to act, consistent with the national
contingency plan, to remove or arrange for the removal of, and
provide for remedial action relating to such hazardous substance,
pollutant, or contaminant at any time (including its removal from
any contaminated natural resource), or take any other response
measure consistent with the national contingency plan which the
President deems necessary to protect the public health or welfare
or the environment..."
The ground water quality investigation conducted by EPA during
the Supplemental Remedial Investigation has detected the presence
of hazardous substances listed in Section 302.4 of the NCP.
These hazardous substance detected in the Newtown Creek Aquifer,
include trichloroethylene, arsenic, and chromium. The Newtown
Creek Aquifer is a drinking water aquifer which currently
provides approximately 30% of the water supply for the Elmira
Water Board and serves approximately 60,000 people. The interim
remedial action described in the Proposed Plan provides for the
removal of hazardous substances from the drinking water aquifer.
In addition, the treatment of ground water removed from the
Newtown Creek Aquifer will result in a potable water supply which
meets both Federal and New York State drinking water standards.
Federal and New York State drinking water standards are
applicable requirement for this interim remedial action because
the water will be distributed to the public water supply system.
During the Supplemental Remedial Investigation the following
metals were detected at the following maximum concentrations:
chromium (49,100 ppb), lead (321 ppb), and zinc (2640 ppb). EPA
believes that these substances at these concentrations do not
represent naturally occurring substance in their unaltered forms
as intended by Section 104(a)(3) of CERCLA. Furthermore the
inorganic contamination exceeds Federal and State drinking water
standards. Filtration will be required to reduce the level of
these substances in the ground water, and the cost associated
with this process is the same for filtering one or more
substances. Arsenic was detected in 24 out of 38 ground water
samples analyzed. Only 3 samples of the 24 detections exceed
New York State and Federal drinking water standards. The proposal
to treat the inorganic contamination was not based solely on the
arsenic detected in ground water samples.
Page 90. Westinghouse Electric Corporation concludes that EPA
should reopen the public comment period and that EPA make public
all available information about the RI/FS, so that Westinghouse
and. others may have an opportunity to comment more completely.
EPA Response; As EPA stated in its response to Westinghouse's
request for additional time EPA believes that sixty days was an
adecfuate period for review of the proposed plan. The NYSDEC, and
-------
19
other members of the public reviewed the Supplemental RI/FS
during this two month period and were able to reach a conclusion
as to the acceptability of the proposed plan. Furthermore, it is
unclear to EPA what additional information Westinghouse desires
in light of the fact that EPA has provided the information
requested by Westinghouse pursuant to Freedom of Information Act
(5 U.S.C.§ 552) requests as mentioned on page 5 of the comments
submitted to EPA. Information related to the site including the
Supplemental RI/FS is located in the information repositories.
-------
767 TITTH AVENUE
NEW YORK. N.v. IO'S3
<2i2> 3K5-BOOC
TELECOPIER: '212' 3-O-80C7
CABLE: MEGOMA
TELEX: ITT «2«28i
ITT 42>>A4
9OI MAIN STREET
SUITE «IOO
DALLAS. TEXAS 7S2O2
I2l«: 746-77OO
TELECOPIER: i2i«i 7*6-7777
WEIL, GOTSHAL & MANGES
A BADTNCKSxie INCLUDING POO'C SSION AL C O "> =O »» T IO N S
1615 L. STREET. N.W.
WASHINGTON. D.C. 2OO36
(2OS) 682-7OOO
TELECOPIER: 12021 357-0939
I2O2> B57-O9«O
TELEX: ITT ««oo«s
WRITER'S DIRECT LINC
(202) 682-7175
September 18, 1990
i6oo FIRST REPUBLICBANK CENTER
7OO LOUISIANA
HOUSTON. TEXAS 77OC2
(7131 546-5OOO
TELECOPIER: 17131 22«-95n
TELEX: ITT «6JO>««
7OI BHICKELL AVENUE
MIAMI. FLORIDA. 33131
OO5I S77-3IOO
TELECOPIER: oosi 374-7159
Mr. J. Jeff Josephson
Remedial Project Manager
U.S. Environmental Protection Agency
Region II
26 Federal Plaza, Room 747
New York, New York 10278
Re: Kentucky Avenue Wellfield Site
Chemung County, New York
Dear Mr. Josephson:
Enclosed please find the written Comments of
Westinghouse Electric Corporation pertaining to EPA Region II's
"Superfund Proposed Plan Kentucky Avenue Wellfield Site, Chemung
County, New York, July 1990." These Comments are hereby
submitted by Westinghouse Electric Corporation to EPA during the
period for public comment in response to the Plan, and for
inclusion and filing in the administrative record file for this
Site..
In a telephone conversation between Morgan G. Graham,
counsel for Westinghouse, and James F. Doyle, Assistant Regional
Counsel for EPA, Mr. Doyle stated that these Comments would be
considered timely filed if they were post-marked by September 18,
1990, and copies were sent to EPA by Federal Express. You
further agreed to this procedure in your telephone conference
with Morgan G. Graham today. Accordingly, these Comments are
being submitted by U.S. mail, with today's post-mark, and we are
sending copies by Federal Express. At your request, we are also
faxing you the first 10 pages of the Comments today; however,
-------
WEIL. GOTSHAL & MANGES
Mr. J. Jeff Josephson
September 18, 1990
Page 2
certain blanks appear in the faxed pages where there are cross-
references to other pages in the document. Those blanks will be
filled in on the copies you will receive by mail and Federal
Express.
Sincerely,
David B. Hird
cc: Richard L. Caspe (w/encs.)
James F. Doyle, Esq. (w/encs.)
-------
Public Meeting
Kentucky Avenue Wellfield Superfund Site
Town of Horseheads Town Hall
Town of Horseheads, New York
August 1, 1990
Reported by: PAMELA A. MORLEY
Shorthand Reporter
Notary Public
APPEARANCES:
ANN RYCHLENSKI; Public Affairs Specialist, U.S. Environmental
Protection Agency, Region II.
KEVIN LYNCH; Chief, Western New York Compliance Section",
U.S. Environmental Protection Agency, Region II.
JEFF JOSEPHSON; Remedial Project Manager, U.S. Environmental
Protection Agency, Region II.
K. SUBBURAMU; Site Manager, Ebasco Services, Inc.
(Environmental Protection Agency's Contractor).
JAMES DOYLE, ESQ.; Office of Regional Counsel, U.S.
Environmental Protection Agency, Region II.
VERBATIM
COURT REPORTING SERVICE
Elmira (607) 733-1262 VP/L. F-/D Z\ | ||\ A Corning (607) 962-1513
Ithaca (607) 272-1345 W flXlJ/X IV Binghamton (607) 722-6426
-------
Superfund Proposed Plan
w
0
)
«
I
i
3
z
a
X
>'
a
z
3
<
0
z
w
&
n
N
i
i/i
IL
D
I
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
MS. RYCHLENSKI: Good evening, ladies and
gentlemen, and thank you for coming out this
evening to this meeting hosted by Region II of .
«*
the Environmental Protection Agency. The purpose
of this meeting is to outline the agency's
proposed plan to clean up groundwater contamina-
tion at the Kentucky Avenue Wellfield Superfund
Site in the town of Horseheads. I want to
introduce the people up here at the table from
EPA and the contractor of Ebasco that will be
giving the presentation tonight, and I just want
to let you know that there is indeed a
stenographer present here this evening to provi
an accurate record of this meeting because your
comments are very important to us in the decision
that will be made on how to deal with this site,
and I'm going to ask you to please hold your
questions to the very end of the meeting. When
you do decide to ask a question, will you please
stand and speak your name clearly and .just exactly
where it is that you live. We don't need your
address, but just the town or village that you
do live in.
The people up here with me, starting right
hero to ~;y extreme right, "r. Kevin Lynch from
-------
Superfund Proposed Plan
1
2
3
4
5
6
7
8
9
10
11
12
13
14
13
16
17
18
19
20
21
22
23
24
EPA, Kevin is the chief of our Western New York
Compliance Branch, Region II, and what he's going
to be giving you tonight is a brief history of .
the Kentucky Avenue Wellfield Site, and he's
going to give you an idea of exactly how it is
that the Superfund process works. Next to him
is Mr. Jeff Josephson. He is the Remedial Project
Manager for the site, and he's going .to be talking
to you about two things tonight. He's going to
be giving you the results of the studies that
were completed at the site, and he's also going to
be talking to you about the proposed plan for
cleanup, which is the main purpose of this
meeting this evening. Next to Mr. Josephson is
Mr. K. Subbaramu. He is with our contractor,
Ebasco. He's the Site Manager over at the Kentucky
Avenue Wellfield Site, and he's going to be talking
about the Feasibility Study, which is the process
by which we come to the decision about how we're
going to handle the site ultimately. And also
here to answer questions later on this
evening is Mr. James Doyle, and Mr. Doyle is
with our Office of Regional Counsel.
I just want to talk to you a little bit
about corruTiunitv relations. I am a Public Affairs
-------
Superfund Proposed Plan
Z
n
1
2
3
4
3
8
9
10
1.1
12
13
1-4
15
16
17
IS
19
20
21
22
23
24
Specialist with EPA, Region II, and I'm the
community relations liaison to this particular
site. What my job is is to be your in into EPA.
*
If you have questions about this site, if there
are needs that you have regarding how this site
is handled, if you need information, I'm the
person you contact and I can get to the proper
sources to answer your questions for you.
I just want to let you know that something
that is very important to us and so that you know
that what we talk about here and when we talk
about public communication and citizen
participation, EPA does indeed take: that very,
\
very seriously, and your commentary is extremely
important to us. This 13 not a one-way monologue
from EPA to you. This is a dialogue from you to
us as well. One thing that we do want you to know
is that you can comment on this plan, and your
comments on our plan to handle groundwater
contamination are very important in.how we render
our ultimate decision. And those comments can
be addressed to Mr. Josephson in writing and
they will also go on the record tonight through
our stenographer.
Hers we have information reoositories. You
-------
Suoerfund Proposed Plan
1
2
3
4
3
6
7
8
9
10
II
12
13
14
13
16
17
18
19
20
21
22
23
24
see these documents that are sitting on the table?
Those are all the documents of the documents
those are not all, they're just some that
pertain to this site, and those documents are
available for your review in information
repositories that have been specifically established
for public review of those documents, and the
repositories are at the New York State
Department of Environmental Conservation, Region
VIII and also here at the town of Horseheads Town
Hall so that you can review the documents and
comment on them.
We have a public comment period which goes
until August 19th, so all of your comments must be
postmarked by that date, and again, if you will
please send them on to Mr. Josephson.
Before I open this program up this evening, I
just want to acknowledge some people that are here
this evening. Mr. George Harris and Mr. Gardner
Cross, New York State DEC, Division of Hazardous
Waste and Remediation; Andy Norton, New York State
DEC; James Barr, Chemung County Health Department;
and Ed Considine, Elmira Water Board. Is there
anyone else that's here this evening from a state
or ioc-?.r. agency or elected official or th.?ir
representative that we may have missed? Okay.
-------
Superfund Proposed Plan
Ik
a
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
In that case I'm going to throw the meetina open.
Mr. Lynch?
MR. LYNCH: Tonight I'd like to explain the
Superfund process we use for addressing a site and
give a short history of the site. The site was
nominated to the National Priorities List
by the state that closed the Kentucky Avenue
Well due to contamination with trichloroethylene,
a common solvent used for degreasing. When a
site is nominated, we gather information on the
site and plug this information into a math-
ematical model in an attempt to rank the site
to see if it poses a risk to human health or the
environment. If it ranks above a certain score,
it gets on the list and then we can spend Superfund
money to clean up the site. The analysis of the
well in this case caused it to be included on
the National Priorities List.
This site is different from those we
normally address with Superfund. We -usually have
a hazardous waste facility, and we have to determine
what is in the site, is anything leave the site, and
if so, what is happening to it. What we're basically
looking for is, what are the problems associated with
i.he site. In this irstance, we had a problem esscxriatec and
-------
0
n
*
Z
U
Z
3
I
O
7
?
U
Z
w
*
N
i
a
k.
(D
1
2
3
4
5
6 i
7
8
9
10
11
12 '
13
14
15
US
I"
18
19
20
21
22
23
24
25 ,
Superfund Proposed Plan
what we had to do was go out and find out how
widespread the problem was and also try to
attempt to find out what the sources of the
problem were. We take the information that we
gather and then form a Feasibility Study, which is tc
identify various alternative solutions to the
problem and to determine what the best solution
is. We then publish a Proposed Plan, hold a
public meeting as we're doing tonight to get
input from you, the community, as to what you
think of our plan. We'll then make our decision,
and we then publish this decision in what we call a
Record of Decision. It's a legal document that
allows us to go forward with the remedial design
and the remedial implementation.
We also have a process for dealing with
emergencies. If we discover a dangerous
situation, we can take an emergency action,
called a removal, at a site without doing a
lengthy remedial investigation. At this site,
in January of '86 we took a removal action to
hook 49 homes whose wells were contaminated, to
the public water supply.
As some of you may know, this is the second
-------
Superfund Proposed Plan
8
z
ID
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
IS
19
20
21
22
23
24
15
Remedial Investigation /feasibility Study that we
have done at the site. This is not rare,
unfortunately. At the end of the study we may
need additional information to choose a final
remedy or a solution for the entire site, but we
do have enough information to take an action.
We call these partial remedies operable units.
In November of 1985 the State Department of
Environmental Conservation performed a Remedial
Investigation/Feasibility Study to discover the
extent of the groundwater contamination. As a
result of that study we have hooked up additional
residences to the public water suppl.y, installed
monitoring wells north of the Sullivan Street
public water supply well, and have also performed
this additional Remedial Investigation /
Feasibility Study to attempt to identify sources
of the contamination. We have completed that
study, and tonight we are presenting our proposed
plan, one ching I'd also like to mention on the ,
actions we took tu hook up people who are in the
affected area of the plume to the public water
supply. If there is anyone out there that you
know of or if any of you are still on private
wells, if anyone is in the affected area, if you
-------
M
0
B
K
V
Z
0
Z
3
Z
I*
o
Z
i
<
o
Z
kl
&
r>
N
a
li.
a
1
2
3
4
5
6
7
8
9
10
11
12
13
1-4
15
16
17
IS
19
20
21
22
23
24
23
Superfund Proposed Plan
would contact either us, the health department,
or the DEC, the offer to hook up in the
contaminated area to the public water supply
still stands so just identify yourself at any .,
time. Now I'd like to introduce Jeff Josephson
who will give us the result of the Remedial
Investigation.
MR. JOSEPHSON: I will now present the
results of the Remedial Investigation conducted
for the Kentucky Avenue Wellfield Site. EPA
conducted this investigation in order to
determine the sources of the TCE contamination
at the Kentucky Avenue well. The study area
which we were involved is bordered on the east by
the Newtown Creek, the south by Elmira, on the west
<*i
by Route 14, and to the north by Horseheads. In '
addition to determining the sources of contamina-
tion to the Kentucky Avenue well, we also wanted
to determine the extent to which this contamina-
tion extends throughout the aquifer, in other
words the groundwater.
Our investigation consisted of a soil boring
investigation, a surface water and sediment
investigation, and a groundwater investigation.
The purpose of the soil boring investigation is
-------
Superfund Proposed Plan
10
*!
li.
I
2
3
4
9
10
11
12
13
14
15
16
17
IS
19
20
21
22
23
24
to go to areas that have been identified as
potential sources of contamination to the
Kentucky Avenue Well, collect samples from the sub-
surface/ and to have these samples sent to our
laboratory for analysis. The areas that we had
investigated had been determined to be potential
sources from previous investigations or other
information obtained by EPA. These include the
Chemung County Department of Highways Garage, the
Old Horseheads Landfill, three properties
formerly owned by the Koppers Company, the sand and
gravel pit, and a small fill area north of Route
17. In addition to these areas, . some priva
\
:narties, including Westinghouse Facility, the
Facet Enterprises Facility, and the LRC
Electronics Facility are conducting their own
investigations with EPA or New York Department
of Environmental Conservation for this site.
EPA went to each of these areas, and with
the drill rig we actually drilled into the ground
to collect our samples. The distribution of the
samples that we collected was based on the Soil Gas
Survey. We collected a total of one hundred
forty-seven samples from these areas and had them
s£nt to our laboratory for analysis. The
-------
Superfund Proposed Plan
11
B
N
S
n
1
2
3
4
3
6
7
8
9
10
11
12
13
14
13
16
17
IS
19
20
21
22
23
24
samples were analyzed for a long list of
potential contaminants. The results of the
analysis indicated that none of these areas that
*
were investigated by EPA contributed to the
groundwater contamination at the Kentucky Avenue
Wellfield Site. In addition, EPA conducted a
limited surface water and sediment investigation
along a drainage way that includes south of the
Westinghouse Facility along the east margin of
the Chemung County Department of Highways Garage
into a pond south of the Old Horseheads Landfill
and then continues south and eventually
discharges into the Newtown Creek. The results
of this investigation, which included collecting
sediment samples from the bottoms of these-streams
and sending these sediment samples for analysis,
indicated there is accumulation of heavy metals
to above background levels in this drainage -way.
Our groundwater investigation involved the
installation of monitoring wells at areas that
we thought would indicate to us the extent to
which contamination exists throughout the Newtown
Creek aquifer, that is, groundwater aquifer
within this valley. The results of our investiga-
tion inrMca^f TCE co/ Lamina " ;.on is the h\^'~ii.~i
-------
Superfund Proposed Plan
12
e
N
I
(I
L
I
2
3
4
3
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
2A
25
at the facilities that have been identified in
the past as contributors to aquifer contamination.
Throughout the rest of the aquifer the contamina-
tion is at lower levels, but exceeds drinking
water standards.
Information obtained by EPA from the New
York State Department of Environmental
Conservation indicates also that there is some
TCE contamination at the LRC Electronics Facility.
Information that the DEC has provided to us,
however, indicates that they may not be
contributing to the contamination of the Kentucky
Avenue Wellfield. Information provided to. us
from Facet Enterprises and information gathered
by our investigation indicates that the Facet
Enterprises Site also does not contribute to the
contamination at the Kentucky Avenue Well itself,
but does contribute to contamination within the
Newtown Creek aquifer.
To summarize the results of our investiga-
tion, contributing sources of groundwater
contamination, both organic and inorganic within th
site, included Westinghouse Electric Corporation,
Facet Enterprises and LRC Electronics. The Chemunq
County Department of Highways Garage, the Clc
Horseheads Landfill, the sand and gravel
-------
Superfund Proposed Plan
13
1
2
3
A
5
6
7
8
9
10
11
12
13
14
13
16
17
18
19
20
21
22
23
24
pit, and the Koppers Company do have inorganics at
elevated levels but they do not appear to be
contributing to the groundwater contamination. Our
surface water and sediment investigation indicates
that there is an accumulation of heavy metals in the
sediments in the drainageway and pond that we
investigated. Finally, our groundwater investigatior
has indicated that there is widepread contamination
of groundwater by TCE, and there is also
contamination of groundwater by some heavy metals.
Contamination of groundwater by the heavy metals
has been identified as primarily a particular
phase. That's to say that the metals are absorbed
to small particulars within the aquifer material.
There was one detection of metals that was
actually dissolved metals with the aquifer.
Now I turn the meeting over to Mr. Subburamu
to discuss the Feasibility Study.
MR. SUBBURAMU: From the Remedial Investigation
it was found that the groundwater is more
contaminated compared to other media, so this
Feasibility Study is mainly focused to remediate
the groundwater contamination. The cleanup
alternatives that were considered to restore the
crcundv^ter are: Restoration cf Kentucky Avenue
Well, minimization of site migration, and the third one
-------
Superfund Proposed Plan
14
01
li
1
2
3
- 4
5
6
7
8
9
10
li
12
13
14
15
16
17
IS
19
20
21
22
23
24
is restoration of Newtown Creek aquifer as a
future groundwater source. To achieve that
alternative for groundwater, these alternatives
fall into three categories . The first one is
no action, the second one is water restriction and
permit requirements, and the third one is
recover the groundwater and treat it and
discharge.
This involves three components as you see
here. The recovery of groundwater can be
achieved by one of these options here. We can
extract the groundwater from Kentucky Avenue
or extract groundwater from portions of the
aquifer,' and the third one is remediation of the
entire aquifer. The groundwater is contaminated
with two types of contaminants. The first type
is metal contamination that are attached to
suspended particles which can be easily treated
by filtration, and the second type is volatile
organics, mainly TCE, which can be treated by
one of these processes: That's air stripping,
carbon adsorption, or UV ozone oxidation. This
treatment system would be designed to meet all
the federal and state standards and reocirements.
-------
Superfund Proposed Plan
15
6
N
IB
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
IS
19
20
21
22
23
24
The discharge options that were evaluated
for the site are these three: After
treatment, it will be discharged to a drinking .
w
water supply, or it can be discharged to surface
water, or it can be put back to the ground by
re-injection. The treatment alternatives can be
formulated by a combination of these three
categories of groundwater extraction, treatment,
and discharge so there are a number of possible
alternatives.
Now I invite Jeff to present the Remedial
Alternative Evaluation.
MR. JOSEPHSON: As a part of the Remedial
Investigation process, EPA conducted a risk
assessment. A risk assessment uses all the "data
collected during the Remedial Investigation and
looks at the exposure pathways to this contamina-
tion and then estimates in a very conservative
sense the risk that these contaminants may pose
to the public. A risk assessment looks
at, for example, ingestion of groundwater that's
contaminated or ingestion of sediments.
Based on the results of our assessment, the
largest risk posed by the site is ingestion of
unf .i Itered groundwater, or untreated groundwater.
-------
Superfund Proposed Plan
16
n
S
9
10
11
12
13
1-4
15
16
17
IS
19
20
21
22
23
24
EPA looked at a large number of alternatives
which dealt with the remediation of the entire
aquifer, remediation of a portion of the aquifer,
restoration of the Kentucky Avenue Well as a
public water supply well, no action alternative,
and a water use restriction alternative which
would be an administrative alternative that would
put requirements on putting in a well and
requires no active remediation.
The conditions imposed by the -Kentucky
Avenue Wellfield Site are complex. This is due
to the fact that the contamination ds widespread
throughout the aquifer. It extends well beyond
\
the Kentucky Avenue Well. In addition, another
NPL site downgradient of the Kentucky Avenue Well
Site contributes to this groundwater contamina-
tion .
When EPA looks at remediation efforts for
groundwater, we look, to our classification of the
groundwater or .aquifer. EPA has classified this
aquifer as a drinking water source.. Therefore
it is our policy to restore this aquifer to the
drinking water standards. However, EPA has gathered
data on restoration of aquifers and it's found
that pump and treat systems are very effective
-------
Superfund Proposed Plan
17
z
tn
I
2
3
4
5
6
9
10
12
13
1-4
15
16
17
IS
19
20
21
22
23
24
at preventing contaminant migration, but
predicting the ultimate concentration as to
which we can achieve remediation was very
*
difficult. But, this is due to the complex
hydogeologic conditions that may exist, or
this may be due to sources that have not been
identified which continue to contribute to the
aquifer contamination. For these reasons, for
the aquifer remediation, EPA is proposing an
interim action. We are proposing to install a
minimum number of pumping wells downgradient of
the Westinghouse Facility. The groundwater
will be recovered and treated and we
believe could be redistributed to the public
water supply. This would involve installation
in this area right here. This action would be
an interim action for the aquifer. That's to
say that we may come back and we' will re-evaluate
the effectiveness of this remediation measure.
If this remediation measure does appear to
be successful in reducing contaminant levels to
the amount that we expect, we may propose a final
remedy for aquifer remediation.
As a second part of the remedial alternatives
selected, EPA is proposing to re. 'rhe Ke;:..ucj<. y
-------
Superfund Proposed Plan
18
to
n
8
9
10
11
E
13
14
15
16
1."
IS
19
20
21
22
23
24
Avenue Well to a public water supply, building a
treatment plant for this well, and distributing
this water to the public water supply.
^
I'll now open up the session to questions
or comments.
MR. MANGES: I'm Richard Manges. I live in
the village of Elmira Heights and I work for
the County Health Department. Mr. Lynch, you
said that if we knew of anyone within this area
who was not hooked up, is that map the one that
we're talking about?
MR. LYNCH: Yes.
MR. MANGES: That map extends considerably
farther than we originally looked at.
MR. LYNCH: Yes.
MR. KEEFE: John Keefe, South Hampton Road,
Elmira, New York. How deep do you consider so-
called ground water?
MR. JOSEPHSON: When you say deep, you mean
how far below the surface?
MR. KEEFE: How far below the surface do vou
consider groundwater?
MR. JOSEPHSON: The data that we collected
indicates it was approximately fifteen to twenty-
five feet below the ground surt^c-;-.
MR. KEEFE: The deepest you went was ten,
-------
Superfund Proposed Plan
19
8
9
10
11
i:
13
14
15
16
17
IS
19
20
21
22
23
24
you say?
MR. JOSEPHSON: No. The deepest we went
was well, the monitoring wells that were
installed go down fifty or sixty feet in some
locations. In other locations we're at twenty
feet, thirty feet. I can show you
MR. KEEFE: That's all right. If you find
it, I'll see it later on.
MR. JOSEPHSON: Here it is. I can just
show you an example of the types of investigation
we did. This is the monitoring wells that we
installed that were closest to the Westinghouse
Facility. We had put in a shallow well, a deeper
well, and a very deep well. This is the water
table right here. This is the ground surface
right here, so this well would be at approximately
fifteen to twenty feet. This well would be at
thirty or forty feet. This well would be at
sixty or seventy feet.
MR. KEEFE: The only other question I have
for you is, how old would you say the material
that you found in the intakes, how recent would
those materials be? Do you have any idea of th
age of the materials that you found in the
intake ~. at all?
-------
Superfund Proposed Plan
20
n
N
i
in
ii
1
2
3
4
5
6
7
8
9
10
11
12
13
1-1
15
16
17
IS
19
20
21
22
23
24
MR. JOSEPHSON: I'm not sure which intakes.
MR. KEEFE: Well, you were talking about
you found materials.
MR. JOSEPHSON: At the outfalls.
MR. KEEFE: Okay. How old would you say
they were, how recent or whatever?
MR. JOSEPHSON: We recently collected data
within the last few years with the Remedial
Investigation report that we provided the public,
We've incorporated other data that's been
collected. Some of that data was collected by
the Westinghouse Corporation durinq their
investigation, and other data was collected .by.
EPA approximately five years ago.
MR. KEEFE: I know it was collected from :
you, but did you investigate the fact that the-
actual material -- did you put an age analysis
on the material?
MR. JOSEPHSON: No.
MR. KEEFE: Okay. Thank you.
MR. FAGAN: Dennis Fagan, Fagan Engineers,
Elmira, New York. Just a question on sort of an
overview. It's my understanding that the
Sullivan Street Well, has trace contamination
a]so. How dees this plan tie into your vjews on
-------
Superfund Proposed Plan
21
o
I
I
n
1
2
3
4
5
6
7
8
9
10
11
\2
13
14
13
16
17
IS
19
20
21
22
23
24
the Sullivan Street Well contamination and on
the situation with the Facet potential contribution
which is downstream of this project but possibly
impacting Sullivan Street?
MR. JOSEPHSON: One thing that wasn't
mentioned earlier, this spring EPA issued in the
local paper a public notice which explained a
difference to the original remedy that we
selected in 1986. This public notice indicated
that EPA has committed to building an air stripper
or treatment system at the Sullivan Street
Wellfield. That will reduce the level of
contamination at the wellfield to below federally
and state mandated drinking water levels.
At this point we haven't exactly begun-
design, but we're in the process of obtaining
the money and the funds and the resources to
i
build or to design that air stripper.
MR. FAGAN: What sort of time-frame are we looking at
in the implementation of this Proposed Plan?
MR. JOSEPHSON: Approximately three years
to design and construct, and then the actual
remediation effort will take a long time; thirty
years.
IIP.. DOYLE: The second half cf your question
-------
Superfund Proposed Plan
22
z
BO
IL.
-------
Superfund Proposed Plan
-------
Superfund Proposed Plan
24
h.
1
2
3
4
5
6
7
8
9
10
II
12
13
14
15
16
17
18
19
20
21
22
23
24
MR. JOSEPHSON: The Elmira Water Board
system.
MR. CAPARULO: Joseph Caparulo from Elmira
Heights. You've mentioned that the most likely
way for a resident to be contaminated is through
actual drinking of the water, or you cited
something about a child eating the soil. Those
are the only two ways? In other words, if you
don't have a well and your child does not eat
dirt, you're considered to be in a safe area?
I'm thinking about back yard gardens for
vegetables. Is there any possibility of toxicity
through eating of vegetables grown in the soil?
MR. LYNCH: Not that we've identified
through this site, so it would be nothing from'
the groundwater that would be contributing, to
that up by --
MR. CAPARULO: Contaminants of. such, are: not:
the type that would be --
MR. LYNCH: It's where they are. It's in .
the groundwater. The groundwater>is deep enough
underneath the soil that that is not the water.
that feeds the vegetables or feeds whatever: is'
growing.
MR. CAPARULO: So the ccrrunent about the
-------
Superfund Proposed Plan
25
d
s
<
I
u
z
3
a
V
0
z
15
<
a
z
IM
&
n
N
I
o
li.
B
1
2
3
4
5
6
7
8
9
10
11
12
13
14
13
16
17
IS
19
20
21
22
23
24
soil, the child eating
MR. LYNCH: That was just -- we're trying
to give you an example of when we take the data
*
what we do with it to try to determine what the
risks are, and what we've determined on this is
that the risk is due to the drinking of any
untreated groundwater. That's why we encourage
anyone who doesn't have a private well in the
area that the water is indeed treated from, that
they do get hooked up to public water supply.
MR. DOYLE: We have pointed out that in some
of the areas we looked at, the green areas as
you see on that chart, like the landfill itself,
unless you have a garden in the landfill, you're
all right. If the child were to go or anycJhe,
it's just children are more likely to play
around dirt, that would be a potential risk.
It's not nearly as likely since people don't
ingest soil that much, so it's a low risk.
MS. MCKINLEY: Teresa McKinley, State
Engineer, Elmira, New York. In conjunction with
that gentleman's question, the focus of this
study was TCE contamination, but you've also
found that there are organics in the soil
end grouncwater, D.V' you consider rr e possible
-------
Superfund Proposed Plan
26
B
N
1
-------
Superfund Proposed Plan
27
o
z
I
o
z
k.
B
1
2
3
4
5
6
7
8
9
10
11
12
13
1-1
15
16
17
18
19
20
21
22
23
24
industrial activity may have occurred in the past.
We wouldn't just go into a neighborhood and
take a sample for no reason.
«r
MR. DOYLE: We looked at instead historical
photographs to determine in the past where industria]
activity took place. So if housing were not placed
on what was once an industrial facility, then we
would have. Judging from the information we had
and in terms of the practices in the valley, we
looked at those sources. We didn't canvass the
entire valley.
MR. LYNCH: We did identify the problem being
TCE contamination, but when we do go out to do a
study, we look at a full range of both organic and
inorganic and we identify the problem. But #e also
want to find out why all the problems are associated
We did look at a wider range of chemicals than just
the solvent.
UNIDENTIFIED SPEAKER: I live close to the
dump area, and when the dump was being operated and
I've been over there, on numerous occasions dump
stuff, and the barrels of stuff would be brought in
from Eclipse Natural Glass and even down from Corning
and dump there. Now there were barrels sealed with
liquids. What's going to be done abcut it? Is that
-------
Superfund Proposed Plan
28
0
N
1
n
li.
a
I
2
3
4
5
6
7
8
9
10
li
12
13
14
i:
16
17
IS
19
20
21
22
23
24
stuff goinq to be excavated and removed or what?
MR. JOSEPHSON: The information that we
collected did not indicate that there was
contamination in the soils at that area.
UNIDENTIFIED SPEAKER: Well, I disagree
with you.
MR. LYNCH: The focus of this investigation
was to determine the groundwater problem and
what was there, if these were sources to the
groundwater, so there was not a full characterization
done at every single site to determine all the
problems. The information that we have gathered,
however, I know on this landfill, we have given
"\
the state DEC and I don't know what their plans
are in their landfill closure program, but they
may be addressing that. But we did not address
it as part of this.
MR. HARRIS: I'd like to speak to that just
briefly. We would like to take your name and
get that information from you. Basically, what
is planned at this point for the landfill,,there
will be a Phase II study conducted for that
plant.
MR. CROSS: We're right at the point in the
investigation now. There are people
-------
Superfund Proposed Plan
29
z
ID
1
2
3
4
5
6
7
/
8
9
10
11
12
13
1-4
15
16
17
18
19
20
21
22
23
24
UNIDENTIFIED SPEAKER: I do know there are
things, barrels, from different factories. They
were dumped in that area.
MR. HARRIS: We'll get your name, and we'd
like to speak to you briefly.
MR. FAGAH: Dennis Pagan again. Since you're going
to conduct a Phase II investigation, do you have a
time schedule in actually completing that work
and starting that work? One of the concerns
we have locally is being onto a list and not
seeing projects implemented in a timely manner.
Is there a specific time frame that DEC has to
conduct these Phase II investigations?
MR. HARRIS: We don't actually conduct the
Phase II study. We work with a bureau that does
that. I would say, generally speaking, a Phase II
study on this site would probably start in a
year. It's possible that the town could conduct
the study themselves if they wanted to. They'd
have to contact our bureau to make those
arrangements, but it is possible.
MS. MCKINLEY: Teresa McKinley again. I
have a question regarding LRC, and you spoke,
and in the report you talked about TCE contarr.ina-
Liuj; :.; the gicundwater. Did you ever itiap, you
-------
Superfund Proposed Plan
30
1
2
3
4
5
6
7
8
9
10
11
12
13
14
13
16
17
18
19
20
21
22
23
24
know, sink wells and take groundwater samples heading
out past Agway to the aquifer, because the last
I got from that was you found contamination in the
«-
well by Agway, and you assumed that they were
contaminated also. Did you do follow-up samples?
MR. JOSEPHSON: The investigation at LRC is
beina overseen by the New York State DEC. They
can probably address that question.
MR. CROSS: Gardner Cross with DEC, Albany.
We have done some limited sampling of existing wells,
and there have been some monitoring wells installed
in the area that you're speaking of, but the
progress in getting those wells installed has not
been very rapid. It appears that we shall be
4'
making some progress, probably in the next few
months in getting more wells installed to see
how far the plume at LRC has progressed.
Right now the contamination that's left on
the LRC site appears to be relatively low-level.
That's not to say if we look a little farther
away from the site, some of the stuff that was
disposed of a few years ago may not be a little
stronger, but that investigation is ongoing and
in a relatively short time I should have some
iriore information for you.
-------
w
O
*
Z
m
u
z
3
I
0
z
1
e
z
*
N
i
B
IB
r i
2
3
5
6
8
9
10
11
12
13
14
13
16
17
18
19
20
21
22
23
24
'I ':'
Superfund Proposed Plan
31
MS. MCKINLEY: Have you done any water
sampling at the high school to see if that area
is contaminated?
w
MR. CROSS: The high school is way
upgradient. The upgradient wells at the LRC
Facility itself are quite clean. The problem
appears to be in the immediate area south and
east of the LRC Facility.
MS. RYCHLENSKI: Any otner questions or
comments?
MR. SCARINGE: One more clarification on the
progress of putting an air stripper in Sullivan
Street. Where are we in that phase? Like
Dennis Fagan has said, these things seem to be
ongoing, but nothing ever seems to be a concrete .
benefit that would actually start benefiting the
public drinking supply.
MR. JOSEPHSON: As I indicated, we're in
the process of obtaining the money to do it.
That's going to involve what we basically
have to do is write out a budget and have it
approved through the region, and we're working
on it. It's going to take a little bit of time.
We believe that once it's approved, we can
design the air stripper, with your help, in
-------
Superfund Proposed Plan
32
c
N
i
to
k
a
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
approximately six weeks. We think that's how
long it will take at this time. Then we believe
it may take approximately three months to
actually construct this.
MR. SCARINGE: Is there any possibility of
1991 being a target?
MR. JOSEPHSON: Yes, sir, there is a
possibility.
MR. KEEFE: John Keefe again. Can you see
a budget being worked up with any different
figures than what you've already presented in
this report?
MR. LYNCH: This is outside of the report.
This is based on the earlier work. This is just
the unfortunate bureaucratic way we have to" go
about doing things.
MS. RYCHLENSKI: Anyone else?
MR. KEEFE: I think, for the record, we
should expediate this with the highest speed
that we possibly can and get going on this thing.
The dearest thing we have in the area, any area,
is the water. Can't waste it, can't lose it.
MS. RYCHLENSKI: Okay. If there are no more
questions "or comments, we will end this meeting
and we tl^nk you very much. If you want to make-
-------
H
O
;i
13
2
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
Superfund Proposed Plan
33
any written comments,they go to Mr. Josephson
by the 19th, and if you haven't signed in,
please do so so that we can add you to our
mailing list and keep you abreast of what we're
doing with this site. Thanks again. Good night,
-------
I
V
I)
N
k.
e
1
2
3
A
5
6
7
8
9
10
11
12
13
14
13
16
17
18
19
20
21
22
23
24
IN THE MATTER OF:
HELD AT:
HELD ON:
BEFORE:
CERTIFICATE
Public Meeting
Kentucky Avenue Wellfield Superfund Site
Town of Horseheads Town Hall
Town of Horseheads, New York
August 1, 1990
Pamela A. Morley
'Shorthand Reporter
Notary Public
This is to certify that the foregoing is a true and correct1.
transcript, to the best of my ability, of the verbatim
stenographic minutes of the public meeting held in the above-
entitled matter, at the above-mentioned place, on the above--
\
mentioned date, and of the whole thereof, taken by Pamela A.,
Morley.
PAMELA A. MORLEY
Shorthand Reporter
Notary Public
VERBATIM COURT REPORTING SERVICE
402 West Church Street
Elmira, New York 14901
Telephone 607-733-1262
------- |