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

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 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

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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).

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                 DECLARATION
        KENTUCKY AVENUE WELLFXELD SITE
             TOWN OF HORSEHEADS
          CEEMUNG COUNTY, NEW YORK
United States Environmental Protection Agency
                  Region II

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              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-

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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-

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 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-

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                          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

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                         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

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      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-

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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-

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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-

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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-

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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-

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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-

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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-

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facilities including sources of aquifer contamination are expected
to be selected within two years.
                               -9-

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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-

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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-

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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-

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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-

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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-

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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-

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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-

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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-

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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-

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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

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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-

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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

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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:
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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

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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-

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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.

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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.


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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


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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

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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
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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

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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
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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
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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

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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

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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

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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

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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

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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.
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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,


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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.


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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.
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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


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     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 wi€hin
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^'s—s 	
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.
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                                                             US. ENVIRONMENTAL  PRO:
                                                             	    AGENCY
                              KENTUCKY AVENUE WELLFI2LD
                                                           DEPARTMENT OF HEALTH (Fi$'.WiLt.'?!
                                                           GROUND/rATER SAMPLING LOCATIONS
                                                                WITH TCE CONCENTRATIONS

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                                               MAGNESIUM CHIP
                                               BURIAL AHEA
                                    INDIcP
                                  MW-tS
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                     CONRAIL HAILROAO
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                                            SURFACE WATER SAMPLE

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                                            ON-SITE MONITOHIMO WELL
                                            tS-SHALLOW. 0-OtEPI
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    100   tOO 300  400
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    «r*ir IN FFFT

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Figure Q
                                                            tE ELEVATIONS.
                                                               IT 0 T
                                                       ASSCC. (HID
                Areas investigated by EPA  during the Supplemental RI

                ?.  •  Cb~;.:-jng County Department of Highways Garage
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                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

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Figure  10
                                                                        (TKttT
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KENTUCKY  AVENJE WELL^IELD SITE
     zi W*TE*/SE»MEKT RESJLTS-
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                                                                                        U9. ENVIRONMEMTAL PnOTECTIOM
                                                                                                  AGENCY
                                                                                       KENTUCKY AVENUE YfELLHELD SITE
                                                                                        SUflfACE
                                                                                                          ;Tmc conr.

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APPENDIX 3

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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

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APPENDIX 4

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 FINAL RESPONSIVENESS SUMMARY
KENTUCKY AVENUE WELLFIELD SITE
   CHEMUNG COUNTY, NEW YORK

        SEPTEMBER 1990

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                   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

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                  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.

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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.

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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

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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.

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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-

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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

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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

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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 
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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.

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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 to—the 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

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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

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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

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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

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                      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.

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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

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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

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                               -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.

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                               -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.

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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,

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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.)

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        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.

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          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

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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.

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          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,

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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

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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

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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

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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

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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

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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

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     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

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     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

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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

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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

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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

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          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

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 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

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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

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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

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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

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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

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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

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          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

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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

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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

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    *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

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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

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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

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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

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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

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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

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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

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           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

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          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

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          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

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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

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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

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 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

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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

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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

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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

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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

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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

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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

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          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

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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

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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

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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

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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

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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

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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

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          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

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          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

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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

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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

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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

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 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

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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

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$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

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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

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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

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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 .

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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

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"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

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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

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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

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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.
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          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

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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

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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

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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

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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

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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

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          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

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          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

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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

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 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
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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

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 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

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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

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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

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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

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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

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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

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§ 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

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          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

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                          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

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                                  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

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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,

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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

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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.

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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

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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.

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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.

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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.

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                                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."

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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

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                               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.

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                                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

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                               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

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                                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,

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                                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."

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                                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

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                               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.

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                                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

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                               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

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                                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.

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   767 TITTH AVENUE

  NEW YORK. N.v. IO'S3

    <2i2> 3K5-BOOC

TELECOPIER: '212' 3-O-80C7

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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
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          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
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    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,

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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.)

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                      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

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Superfund Proposed Plan














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                    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

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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

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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

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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.

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             Superfund  Proposed  Plan
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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

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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

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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

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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

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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

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               Superfund Proposed Plan
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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

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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

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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

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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.

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     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.

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      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

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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

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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,

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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?

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     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

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 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

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     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

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              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

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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

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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

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     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

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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.

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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

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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-

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               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,

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               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

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