United States
          Environmental Protection
          Agency
Office of
Emergency and
Remedial Response
 EPA/ROD/R02-93/197
 March 1993
PB94-963822
&EPA   Superfund
          Record of Decision
          Johnstown City Landfill, NY

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50272-101
  REPORT DOCUMENTATION
          PAGE
1. REPORT NO.
EPA/ROD/RO2-93/197
3. Recipient's Accession No.
   Title and Subtitle
   SUPERFUND RECORD OF DECISION
   Johnstown City Landfill, NY
   First  Remedial Action - Final
                                          5.  Report Date
                                                   03/31/93
7.  Author(t)
                                          8.  Performing Organization Rept. No.
9.  Performing Organization Name and Addreaa
                                          10  Project Taak/Work Unit No.
                                                                    11.  Contract(C) 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

                                             800/800
                                          14.
IS. Supplementary Notes
                    PB94-963822
16 Abstract (Limit: 200 words)

  The 68-acre Johnstown  City Landfill  site is a municipally-operated,  unlined landfill
  situated  in the LaGrange Gravel pit  located in Johnstown,  Fulton  County, New York.
  Land use  in the area is  predominately mixed residential,  agricultural,  and
  recreational.   The site  overlies both an overburdened and bedrock aquifer, which  appear
  to be hydraulically connected downgradient from the  site.   The primary surface  water in
  the immediate  vicinity of the landfill is Mathews  Creek,  which along with the
  associated wetlands, appears to be affected by contamination from the site.  The
  estimated 1,000 people who reside within one mile  of the site use private wells to
  obtain their drinking  water supply.   The site consists of two flat terraces filled  into
  former borrow  pits, and  a remnant of a pit along the western side of the landfill,
  which was used previously to dispose of demolition debris and metals.  From 1947  until
  1960, 34  acres of the  site were used as an open refuse disposal facility, which
  subsequently was converted into a sanitary landfill.  Until 1979,  the landfill  accepted
  industrial wastes, which included chromium-treated hides,  trimmings, and other
  materials from local tanneries and textile plants.   From 1973 to  1979,  sewage sludge

  (See Attached  Page)
17. Document Analysis     a. Descriptors
   Record of Decision - Johnstown City Landfill,  NY
   First Remedial  Action - Final
   Contaminated Media: soil,  sediment, debris,  gw
   Key Contaminants:  VOCs  (benzene, PCE, TCE,  toluene, xylenes), other  organics  (PAHs,
                       PCBs, pesticides, phenols),  metals  (arsenic, chromium, lead),
                       inorganics (cyanide)
   b.   Identifiers/Open-Ended Terms
   c.   COSATI Field/Group
18. Availability Statement
                          19. Security Class (This Report)
                                    None
                                                     20.  Security Class (This Page)
                                                               None
          21. No. of Pages
                  66
                                                    22. Price
(SMANSI-Z39.18)
                                   SM Instructions on Rtvtrte
                                                   OPTIONAL FORM 272 (4-77)
                                                   (Formerly NTIS-35)
                                                   Department of Commerce

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EPA/ROD/R02-93/197
Johnstown City Landfill, NY
First Remedial Action - Final

Abstract (Continued)

containing concentrations of chromium, iron, and lead was accepted from the nearby
treatment plant and disposed of onsite in open piles.  All onsite landfilling operations
ceased in 1989.  Routine storm water runoff and drainage have created ponded areas on the
landfill surface, which have eventually infiltrated into landfill wastes.  The associated
leachate seeps and occasional ephemeral runoff from the landfill then flowed into, and
contaminated, the adjacent LaGrange Gravel pit.  This ROD addresses both onsite source and
ground water contamination, as the first and final remedial action for this site.  The
primary contaminants of concern affecting the soil, sediment, debris, and ground water are
VOCs, including benzene, PCE, TCE, toluene, and xylenes; other organics, including PAHs,
PCBs, pesticides, and phenols; metals, including arsenic, chromium, and lead; and
inorganics, including cyanide.

The selected remedial action for this site includes excavating contaminated LaGrange Pit
sediment, and placing the excavated material on the existing landfill; regrading and
constructing a multi-layer cap over the landfill and excavated sediment; filling any
excavated areas with clean fill; allowing ground water to naturally attenuate; expanding
the city's municipal water supply to provide potable water to all residences potentially
affected by the site; performing a cultural resource survey for onsite and offsite areas
to determine sensitivity of the site for cultural resources; monitoring ground water,
surface water, and air; .maintaining the cap and monitoring and controlling landfill gas
emissions, as needed; implementing institutional controls, including deed restrictions,
and site access restrictions, including fencing; and providing for a contingency in the
event that monitoring indicates that the ground water is not being restored to acceptable
levels through natural  attenuation.  The contingency remedy involves extraction and onsite
treatment of ground water using physical/chemical processes such as pH adjustment/
chemical precipitation, and carbon adsorption, with discharge of the treated water to the
aquifer through percolation ponds, injection wells, or direct discharge to surface water.
The estimated present worth cost for this remedial action is $16,454,000, which includes
an estimated annual O&M cost of $174,000 for 30 years.  The estimated present worth cost
for the contingency remedy is $32,580,000, which includes an estimated annual O&M cost  of
$936,000 for 30 years.

PERFORMANCE STANDARDS OR GOALS:

Not provided.

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                         ROD FACT  SHEET
Name:

Location:

HRS Score:


ROD

Date Signed:

Remedy:



Capital Cost:

0 & M Cost:

Present Worth Cost:


LEAD

Agency:

Primary Contact:

Secondary Contact:

Main PRPs:


WASTE

Type:


Medium:

Origin:

Est. Quantity:
Johnstown City Landfill

Town of Johnstown, New York

48.36




March 31, 1993

Landfill Cap/Extension of City
Water Supply Line/ and if needed,
GW Collection/Treatment/Disposal

$13,763,000 - $16,454,000

   $174,000 -    $936,000

$18,174,000 - $32,580,000




NYSDEC

Robert Nunes (212) 264-2723

Joel Singerman (212) 264-1132

City of Johnstown
Volatiles, Semi-Volatiles,
Inorganics

Soil, groundwater, surface water

Municipal and hazardous wastes

Municipal Landfill Size: 68 acres

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              DECLARATION FOR THE RECORD OF DECISION
                                        I

Site Name and Location

Town of Johnstown, Johnstown City Landfill, Fulton County, New York


Statement of Basis and Purpose

This decision document presents  the selected remedial action for
the Johnstown City Landfill site  (the "Site"), located in the City
of  Johnstown,  Fulton County,  New  York, which was  chosen  in
accordance with the requirements of the Comprehensive Environmental
Response, Compensation,  and Liability Act, 42  U.S.C.  §§ 9601-9675,
as amended  (CERCLA),  and to  the  extent  practicable,  the National
Oil and Hazardous Substances Pollution Contingency Plan (NCP),  40
CFR Part  300.  This  decision document  explains the  factual and
legal basis for selecting the remedy for the Site. The information
supporting  this remedial action  decision  is  contained in  the
administrative  record for the Site.  The administrative record
index is attached (Appendix III).

The  New  York  State Department  of Environmental  Conservation
(NYSDEC) concurs with the selected remedy. NYSDEC will also concur
with  the contingent  remedy,  should future  water quality  data
indicate  that  the  ground-water  remediation  component  of  the
contingent remedy is  appropriate.  (See Appendix  IV.)


Assessment of the Site

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  a significant and
substantial   endangerment to  public  health,   welfare,  or  the
environment.


Description  of  the Selected Remedy

This  operable unit  represents the entire remedial action for the
Site.   It addresses the  principal threats to human health and the
environment  at  the Site by controlling the source of contamination
and the generation of leachate.

The major components  of  the  selected remedy  include:

          Excavation  of  the LaGrange  Gravel  Pit  sediments and
          placing the excavated materials  on the existing landfill.
          The pit will be filled  with clean fill, so that it may be
          used  as an  infiltration basin and/or  stormwater collec-
          tion  basin;

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     •     Regrading and compacting the landfill mound to provide a
          stable foundation for placement of the various layers  of
          the cap  and to  promote  rapid  runoff;

          Construction of  a  multi-layer closure  cap  over the
          landfill mound  and excavated sediments as per New  York
          State 6 NYCRR Part 360 regulations.  The cap, by reducing
          leachate generation, will act to improve the ground-water
          quality  in the upper (overburden)  and lower  (bedrock)
          aquifers and   surface-water  quality  in  Mathew  Creek
          through  natural attenuation of contaminants;

     •     Expansion of the Johnstown City water-supply  system  to
          provide   potable  water to  all private  water supplies
          potentially impacted by  the  landfill.  Providing  city
          water will  require the extension  of the City's  water
          lines and construction of a booster pump station;  and

     •     Erection of  approximately 6,800  feet of  conventional
          chain-link fencing  surrounding the entire landfill mound,
          with placement  of appropriate warning signs.

The effectiveness  of the landfill  cap will  be evaluated  through
post-construction  monitoring of ground-water  and  surface-water
quality.  The evaluation will be conducted within 5 years following
initiation of construction of the landfill cap,  and at any time as
needed thereafter, during  the long-term monitoring of  the Site.
Should the  monitoring results indicate  that either ground-water
quality in  the upper (overburden)  aquifer  or the  lower (bedrock)
aquifer,  or surface-water  quality  in Mathew Creek,  is  not being
restored  to acceptable levels through natural attenuation  as a
result  of  reduced leachate  generation,  the  following will  be
implemented:

          Extraction of  contaminated ground  water from either of
          the aquifers,  as necessary.  The extraction system would
          utilize  extraction wells which would  induce flow to the
          wells  through  drawdown  of  the  ground-water  table.
          Operation  of the ground-water extraction system would
          reduce the migration of contaminants away  from the Site;

     •    Treatment  of ground water by a treatment system located
          permanently  on-Site that  would use physical/chemical
          processes such as pH adjustment, chemical precipitation,
          and carbon adsorption, to  remove inorganic and volatile
          organic  contaminants; and

          Discharge  of treated ground water by returning it to the
          aquifer  via percolation ponds  or injection wells, or by
          discharging  it to  a stream, the  nearest being Mathew
          Creek.   The discharge standards would be  established by
          NYSDEC.

                                ii

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Declaration

The selected remedy is protective of human health and the environ-
ment, 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 practica-
ble.  In keeping with the statutory preference for treatment as a
principal element of the remedy, the contaminated ground water will
be collected  and treated,  if necessary.  The  landfill  material,
however, cannot  be  excavated and treated  effectively,  because of
the  size  of the landfill and  because  there are no  on-Site "hot
spots" that represent the major sources of contamination.

A review  of the Site will be conducted no  later than  five years
after commencement of the remedial action to  ensure  that the remedy
continues to  provide  adequate  protection  of human  health and the
environment, because this remedy will result  in hazardous substanc-
es remaining on-Site above health-based levels.
William J.^uszyns]£K P.E.                          Date
Acting Regional Administrator
                                iii

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              DECISION SUMMARY
        Johnstown City Landfill SITE

              City of Johnstown
           Fulton County, New York
United States Environmental Protection Agency
                  Region II
              New York, New York
                  March 1993

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                        TABLE OF CONTENTS
SITE NAME, LOCATION AND DESCRIPTION 	   1

SITE HISTORY AND ENFORCEMENT ACTIVITIES 	   1

HIGHLIGHTS OF COMMUNITY PARTICIPATION 	 ....   2

SCOPE AND ROLE OF OPERABLE UNIT	   3

SUMMARY OF SITE CHARACTERISTICS	   3

SUMMARY OF SITE RISKS	   8

DESCRIPTION OF REMEDIAL ALTERNATIVES	12

SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES	17

SELECTED REMEDY	24

STATUTORY DETERMINATIONS	27

DOCUMENTATION OF SIGNIFICANT CHANGES  	  31




ATTACHMENTS

APPENDIX I.    FIGURES
APPENDIX II.   TABLES
APPENDIX III.  ADMINISTRATIVE RECORD INDEX
APPENDIX IV.   NYSDEC LETTER OF CONCURRENCE
APPENDIX V.    RESPONSIVENESS SUMMARY

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SITE NAME, LOCATION AND DESCRIPTION

The Johnstown  City Landfill  is  a municipally  operated,  unlined
landfill, situated in a 68-acre gravel  pit  in the Town of Johns-
town, Fulton County, New York.  The Site is located approximately
1.5 miles northwest of the City of Johnstown and 1.75 miles west of
the City of Gloversville.   (See Figure 1.)

The landfill consists of two, generally flat terraces filled into
former borrow pits.  A remnant of a pit once used as a demolition
debris and metals disposal area, approximately 30 feet deep, exists
on the westward side of the landfill  at  the  base  of a steep ridge.
(See.Figure 2.)

The surrounding  area has  a  mixed  residential,  agricultural, and
recreational land use.  Approximately 10 homes are located within
1,000  feet of the  Site,  and an  estimated 80  homes  are located
within one mile downgradient of the Site.   (See Figure  3.)  All of
these homes have private wells with depths  ranging from 10 to 208
feet.   The population  within a one-mile  radius of the  Site is
approximately  1,000 persons.

The surface-water  drainage in the vicinity of the landfill  flows
generally  to the southeast.   Surface waters flow from the upland
areas, north of  the Site,  via intermittent drainage ways towards
the  south-southeast.    The primary surface-water  feature in the
immediate vicinity of the landfill  is Mathew Creek. The headwaters
of  the creek  (LaGrange Springs)  are located approximately  1,000
feet southeast of the Site.   The creek flows southeasterly until it
converges  with  Hall  Creek  prior  to discharging  into Cayadutta
Creek.   The flow of Mathew Creek is  interrupted by a manmade pond
 (Hulbert's Pond) before it converges with  Hall  Creek.  Cayadutta
Creek  ultimately discharges  to the Mohawk River.

Due  to differences in  surface  elevation,   storm-water runoff and
drainage from West Fulton Street Extension flow onto the surface of
the landfill creating ponded water near its northeast corner. The
water  in  this  approximately one-acre  pond either evaporates or
 infiltrates  into  the  landfilled  wastes.    LaGrange  Gravel  Pit,
 located  approximately 100  feet east of the eastern margin of the
 landfill,  receives surface runoff from hill  slopes in its immediate
vicinity,  minor  flows from leachate seeps and occasional ephemeral
 runoff from the landfill  surface.   (See Figure 2.)   Except for
 short-lived discharges  to  LaGrange Gravel Pit, there is no surface
 water  runoff  from  the  landfill.   There  is no surface water runoff
 from LaGrange  Gravel Pit.


 SITE HISTORY AND ENFORCEMENT ACTIVITIES

 Site History

 Thirty-four acres  of the 68-acre Johnstown  City Landfill were used
 as an  open refuse  disposal facility  from 1947 to 1960 before being

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converted to a sanitary landfill.  The landfill accepted industrial
wastes from local tanneries and textile  plants  until April 1979,
and sludge from the Gloversville-Johnstown Joint Sewage Treatment
Plant from 1973  to April  1979.  Landfill  operations ceased in June
1989.  Much  of  the  tannery wastes were  disposed  of  as chromium-
treated hide  trimmings  and other  materials.   Sewage  sludge was
disposed of in open piles at a rate of approximately 20,000 cubic
yards per year.   The sludge contained concentrations of chromium,
iron, and lead.   There are no  records available which detail the
amounts of industrial wastes accepted by the landfill.

On June 10,  1986, the Johnstown City Landfill  site was placed on
the Superfund National Priorities List.


Enforcement Activities

On June 5, 1987, the state of New  York filed suit under CERCLA and
state   common   law  against   the   City  of   Johnstown,   the
Gloversville/Johnstown Joint  Sewer Board, Bruce  Miller Trucking
Company,  and about  a  dozen waste generators.   Several  of the
defendants  subsequently   impleaded  approximately  52 third-party
defendants,  including  additional  generators, transporters  and a
number of area  municipalities.  When  the defendants declined to
fund an RI/FS, the State  and the City of  Johnstown entered into an
interim consent order,  which was approved by Federal  Judge Con. G.
Cholakis on October 4, 1988.

Under the interim order,  the City agreed to conduct an RI/FS  of the
Site  consistent with the NCP  and state  guidance,  and agreed to
close the Site  by June 1, 1990, or within thirty days of the date
a new solid waste management  facility in Fulton County (the Mud
Road Facility)  was to accept refuse, whichever was sooner.

On  February  12,  1988,  EPA issued  Special Notice Letters  to 15
parties potentially responsible for  contamination at the Site.

During the implementation of the RI/FS, the parties involved in the
litigation  have  conducted extensive document  discovery  and the
defendants have made initial attempts  to allocate responsibility.
It  is  NYSDEC's  intention to  have the responsible parties for the
site undertake  any  remedial activities.


HIGHLIGHTS OF COMMUNITY  PARTICIPATION

On  May 17,  1989, the City of Johnstown  and  NYSDEC conducted  a
public meeting  in Johnstown,  New York,  to inform  local officials
and interested  citizens  of the upcoming RI and to respond  to  any
questions from area residents  and  other attendees.   A follow-up
public meeting  was held on June 13,  1990  to describe the results of
the first phase of the RI and to present  plans for the second phase
of  field  work.

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T?he~RI report, FS report, and the Proposed Plan for the Site were
released to  the  public for comment  on  January 21,  1993.   These
documents were made available to the public in the administrative
record repositories at the EPA Docket Room in Region II, New York
and at  the Johnstown Public  Library, Johnstown,  New  York.   The
documents were also made available at the information repositories
at NYSDEC's  Albany,  New York office, at NYSDEC's  Ray Brook, New
York office, and at the City of Johnstown Attorney's Office.  The
public  comment period on these  documents  ended on  February 19,
1993.

During the public comment period, a public meeting was  held at the
Johnstown High School, Johnstown, New York on February  10, 1993 to
present  the  RI/FS  reports  and  the Proposed Plan,   to  answer
questions, and to accept oral comments.  At this meeting, represen-
tatives  from the  NYSDEC,  the  New York State Department of Health
(NYSDOH), and EPA answered questions about problems at the Site and
the remedial alternatives under  consideration.  A summary of the
comments presented at the public meeting and their responses, as
well as written comments received during the public comment period
and  their  responses, are included in the  Responsiveness Summary
(see Appendix V.)


SCOPE AND  ROLE OF  OPERABLE UNIT

This  response action applies a comprehensive  approach,  therefore
only  one operable unit  is required to remediate the  Site.

Remedial action objectives are  specific goals to protect  human
health   and  the  environment.   These  objectives  are  based on
available  information and standards such as applicable or relevant
and   appropriate  requirements  (ARARs)  and  risk-based   levels
established in the risk assessment.

The  following  remedial  action  objectives  were  established: 1)
prevent human and animal contact with contaminated  soil from  the
landfill surface;  2)  prevent  erosion of contaminated surface soil
through surface-water  runoff;  3)  minimize the  infiltration of
rainfall or snow melt into the landfill, thus reducing the quantity
of water percolating through the landfill  materials and leaching
out contaminants;  4) mitigate the off-Site migration of contaminat-
ed ground  water; 5)  prevent unacceptable  exposure  to off-Site
contaminated  ground  water;   6)  restore ground-water  quality to
levels   which . do not  exceed  state or  federal  drinking-water
standards; 7)  prevent ingestion of on-Site ground water; 8)  control
generation and prevent migration of subsurface  landfill gas; and 9)
prevent unacceptable exposure to vapors from the  landfill.

NYSDEC  is  the lead agency for  this  project;  EPA is  the  support
agency.

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SUMMARY OF SITE CHARACTERISTICS

The RI field work was carried out in two phases: Phase I, between
June 1989 and June 1990;  and Phase II, between July 1990 and March
1992.  Media sampled during the RI included subsurface soil, ground
water,  surface water,  sediments,  and  air.    The  frequency  of
detection, lowest and highest concentrations detected, and location
of highest concentrations detected,  are shown for all sampled on-
Site and off-Site ground water,  surface water,  subsurface soils,
and sediments in  Tables  la,  Ib,  2a,  2b,  3a,  and 3b.   The RI also
included ground-water flow  studies  to evaluate  the  hydrogeologic
conditions  at and  in the vicinity  of  the landfill,  a  wetlands
delineation in the vicinity of the Mathew  Creek area, and ecologi-
cal studies in Mathew Creek and Halls Brook.

Subsurface  soil  samples  were  collected  for  all  ground-water
monitoring wells  shown on Figure 4,  except for MW-15 and MW-19.
Soils located directly beneath the landfill exhibited the majority
of  the soil  contamination.   Eight  volatile  organic compounds
(VOCs) , acetone, methylene chloride,  xylene,  benzene, ethylbenzene,
2-butanone,  4-methyl-2-pentanone,  and  toluene  were  detected  in
landfill subsurface soil samples  (MW-16 through MW-18) at concen-
trations  ranging  from 3  micrograms per kilogram (M9/kg)  to 440
jig/kg.  Benzoic acid,  phthalate,  and polycyclic aromatic hydrocar-
bon  (PAH)  compounds comprised most  of  the  semi-volatile organic
compound (SVOC) contamination detected in landfill soil zones, with
phthalate esters  observed to have the highest range of concentra-
tions  (42 /ig/kg to 1,100 ^tg/kg) .   Eighteen metals were detected in
subsurface  soil samples  collected within the landfill ranging in
concentrations from 0.43 milligrams  per  kilogram (mg/kg) to 72,000
mg/kg.    Eight  of  these  (antimony,   calcium,  chromium,  lead,
magnesium, sodium, aluminum, and zinc) exceeded background values.
Eleven pesticides were  also detected in landfill subsurface soil
samples  at   concentrations  between  4.1  M9/kg  and  37  /xg/kg.
Downgradient  inorganic substances found in all of the  4 subsurface
soil  samples  (MW-9 through  MW-12)  included aluminum,  arsenic,
barium, beryllium,  calcium, chromium, cobalt, copper,  iron, lead,
magnesium,  manganese,  nickel,  potassium, sodium,  vanadium,  and
zinc,  at  concentrations  ranging from 0.31 mg/kg to 39,000 mg/kg.
Organic contaminants  that were found in  more than  half  of the  9
downgradient  subsurface  soil samples  (MW-1  through  MW-4,  MW-8
through MW-12) included  acetone, methylene  chloride, toluene, and
tetrachloroethylene at  concentrations  between  0.6 Mg/kg  and 75
The  volatile contamination detected  in  the shallow downgradient
aquifer  (MW-1 through MW-4,  MW-8 through MW-12, and MW-15)  included
13  VOCs.   Concentrations  of these contaminants  ranged from  0.2
micrograms  per liter (/xg/L) to 62.0 pg/L, with the highest being
toluene  detected at  MW-3S, which  is located near  the  LaGrange
Gravel Pit.  Semi-volatile contamination in downgradient monitoring
wells  included phthalate ester  compounds, polycyclic  aromatics,
methylphenol ,  and benzoic acid at concentrations  between  0.3 ng/"L
and  150  M9/L-   Twenty metals  .were  detected in  shallow wells
downgradient of the landfill  at  levels often  exceeding background

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revels.   Eight metals  (iron,  manganese, sodium,  arsenic,  lead,
chromium, copper,  and zinc) exceeded EPA and/or NYSDEC standards in
downgradient monitoring  wells.   Two pesticides  were  detected in
downgradient. monitoring  wells,  MW-9S  and  MW-11D,  at  0.04  /*g/L
(delta-BHC) and 0.05 /ig/L (Endosulfan 1), respectively.

Acetone and bis(2-ethylhexyl)phthalate  were the primary contami-
nants detected within the bedrock ground-water aquifer at concen-
trations  generally  much greater than  those found  at  the source
(landfill) wells.    The  highest concentration of  acetone (2,900
/ig/L) was detected at MW-7D located northwest of the landfill.  The
highest concentration of bis(2-ethylhexyl)phthalate (150 M9/L) was
detected  at MW-3D located near the LaGrange Gravel  Pit.

Five  VOCs,  acetone, methylene  chloride,  xylene, benzene,  and
ethylbenzene were detected in the  ground-water sample collected
from  landfill  well  MW-16, at  concentrations  ranging  from 9 Mg/L
(benzene) to 230 ng/I* (xylene).  Generally,  the highest concentra-
tions of  inorganic contaminants in ground water were also detected
at MW-16.  Six pesticide compounds, none of which were found in
downgradient  ground-water  samples,  were detected at MW-16  at
concentrations  ranging  from  0.01 ng/L  (4,4'-DDE) to  0.35 /xg/L
(4,4*-ODD).    Based on  water-level  data,  these  results  may be
characteristic of leachate.  Benzene and ethylbenzene were detected
in  landfill  well MW-19, at 0.9  /ig/L and  7 pg/l>, respectively.
Eleven SVOCs were detected in landfill wells MW-16, MW-18,  and MW-
19 at concentrations ranging from 0.6 ng/L (di-n-octylphthalate) to
24 pg/L  (bis(2-Ethylhexyl)phthalate).   No VOCs or  pesticides were
detected  in  landfill monitoring well  MW-18.   No  polychlorinated
biphenyls (PCBs) were detected in any of the three sampled landfill
monitoring wells.

No  inorganic  contaminants  found  in  residential well   samples
exceeded New York State or EPA primary  drinking water  standards.
Some  compounds, such as  iron, manganese, zinc, and total dissolved
solids  (TDS),  were detected at concentrations  which may  affect
aesthetic qualities  of  drinking  water  (e.g.,  taste,  odor, and
staining of fixtures).   VOC compounds detected in residential well
samples  included acetone,  carbon  disulfide,  methylene chloride,
trichloroethylene,  1,1,1-trichloroethane,  and toluene, but were
found at  concentrations below state  and federal  drinking  water
standards. Acetone was  detected in 6 of the 52 samples collected,
at  concentrations ranging from 3 to 6  fig/I>.  Carbon disulfide was
detected in 4 of the 52 samples,  at concentrations ranging from 0.3
to  3  M9/L.  Methylene chloride was detected in 3 of the 52 samples
at concentrations up to 2 M9/L.  Trichloroethylene, 1,1,1-trichlor-
oethane,  and toluene were each detected  in  one  of the  52  samples
collected, at 2, 3, and 2 /ig/L,  respectively.    Three phthalate
esters were detected in  residential well  samples.  Bis(2-ethylhex-
yl) phthalate was detected  in  34  of  the  39  residential  wells
sampled,  at concentrations ranging from 2 to 66  Mg/L.   In  4  of
these  samples,   concentrations  of   bis(2-ethylhexyl)phthalate
exceeded the NYSDEC ground-water standard  of 50  ng/l>.   (In  all
three sampling rounds, bis(2-ethylhexyl)phthalate was also detected
 in laboratory samples,  indicating that its presence  in collected

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residential well samples may be attributed to contamination in the
laboratory, and may not be representative of  actual water quality.)
Di-n-butylphthalate was detected in 6 of the 52 samples collected
at concentrations ranging from 0.8 to 2 M9/L.  N-nitrosodiphenyl-
amine was detected in one of the 52 samples at a concentration of
2 ng/L.   No pesticide or PCB compounds were detected in residential
well samples.

Surface-water quality and sediment sampling  locations are shown on
Figures  5a and 5b.   Inorganic compounds found  in surface-water
samples collected  from Mathew  Creek included aluminum, antimony,
barium,  'chromium, cobalt, copper, iron, lead, magnesium, mercury,
nickel,   potassium,  selenium,   sodium,   zinc,  cyanide,  sulfate,
chloride,  bicarbonate,   and ammonia-nitrogen  at  concentrations
ranging  from  1.2  Aig/L  (selenium)  to  111,000  pig/L  (calcium).
Concentrations were generally higher at the  headwater springs than
at other locations.  However, several metals, including chromium,
lead, iron, and zinc, were detected at the highest concentration at
the furthest downstream sampling location (Station  #4).  Six VOCs,
acetone, methylene  chloride, toluene, trichloroethylene, tetrachlo-
roethylene, and  chlorobenzene  were also detected in Mathew Creek
samples at concentrations ranging from 0.7 pq/L (chlorobenzene) to
24 M9/L  (acetone).   Acetone, methylene chloride,  and toluene were
detected in  more than one  sample.    Three phthalate  ester com-
pounds,  diethylphthalate, di-n-butylphthalate, and bis(2-ethylhex-
yl)phthalate, were detected  in Mathew Creek samples at concentra-
tions ranging from 0.4 M9/L  (diethylphthalate) to 16 M9/L (bis(2-
ethylhexyl)phthalate).   Seven of  the  8  surface water  samples
collected  in Mathew Creek had detectable concentrations of bis(2-
ethylhexyl)phthalate  that   exceeded  the   NYSDEC  surface  water
standard of 0.6 M9/L.  No pesticides or PCBs were detected in any
surface-water samples from Mathew Creek.

Surface-water samples were collected  from the LaGrange Gravel Pit
 (Sta #5 on Figure 5a) during  the second and third  rounds of on-Site
water-quality sampling.  The concentrations  of inorganic compounds
in the LaGrange Pit were typically  consistent with those detected
in  the  ground water around the landfill.   The  sample collected
during Round 2 had detectable  concentrations  of 6 VOCs, namely,
acetone,  methylene  chloride,  benzene, 2-butanone,   4-methyl-2-
pentanone,  and toluene,  at concentrations ranging from  2 /ig/L
 (benzene)  to 250  nq/L  (2-butanone).    The  Round 2 water-quality
sample also  indicated the presence of  9 SVOCs from the LaGrange
Gravel Pit at concentrations  between 0.2 Mg/L (di-n-octylphthalate)
and 190 ng/L (benzoic acid).  Five of these compounds are phthalate
esters and were prevalent in both soil and ground-water samples.
No  pesticides or PCBs were detected in any surface-water samples
 from LaGrange Pit.

Sediment contamination in Mathew Creek included metals,  ammonia-ni-
trogen,  VOCs,  SVOCs, and pesticides.   Concentrations  for arsenic,
cadmium,  chromium, copper,  iron,  lead, manganese,  mercury, and
nickel exceeded NYSDEC Sediment Criteria Guidance Values in one  or
more  sediment samples  from Mathew Creek.   Eight VOCs, acetone,
methylene  chloride,  trichloroethylene, chloroform,  benzene,  2-

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b'utanone,  carbon disulfide,  and toluene, were  detected at concen-
trations ranging from 2  M9/kg to  380 /xg/kg  (acetone) .   Twenty-two
SVOCs  were detected in sediment samples at  concentrations ranging
from 4 Mg/kg .(benzo(g,h,i)perylene) to 4,500 /xg/kg (benzoic acid).
Two pesticides, delta-BHC and 4,4'-DDE, were detected at concentra-
tions  ranging  from 2.1 M9/kg (4,4'-DDE) to  13  M9/kg (delta-BHC).

Sediment  contamination in the LaGrange  Gravel Pit also  included
inorganic  compounds,  VOCs,  SVOCs,  and pesticides.    Twenty-one
metals were detected at concentrations ranging  from  0.14  mg/kg
 (mercury)  to 106,000 mg/kg (calcium).  Six VOCs, acetone, methylene
chloride,  benzene, 2-butanone, 4-methyl-2-pentanone, and toluene at
concentrations ranging from 2 M9/kg (benzene) to 99 ^g/kg (acetone)
were detected.   Nineteen SVOCs  were  detected at  concentrations
ranging from  11 /itg/kg  (fluorene)  to  1,400 M9/kg  (naphthalene).
Four pesticides, 4,4'-DDE, 4,4'-ODD, heptachlor, and  aldrin were
detected  at concentrations ranging from 1.8 /xg/kg (aldrin) to 170
Atg/kg (4,4'-DDE) .

Ambient air in the vicinity of the landfill was measured for VOCs
and particulate chromium.  Acetone, benzene, toluene,  2-butanone,
 1,1,1-trichloroethane, and carbon  tetrachloride  were  detected at
concentrations ranging from  0.47 micrograms per cubic meter (/ig/m3)
 (carbon tetrachloride) to 20.6 /xg/m3 (acetone).  The highest total
 concentration of VOCs for any one sample was 23.2 /^g/m3.  Airborne
 chromium was detected at concentrations ranging from 0.002  to 0.005
 Mg/m3.  All  of the airborne  VOCs  and chromium detected during the
 RI are within  the guideline values for both  occupational values and
 New York State guidance criteria.  (See Tables 4 and 5.)

 The hydrogeological investigation  determined that two aquifers
 exist beneath the Johnstown  City  Landfill.  The upper  (overburden)
 aquifer flows  through till, sand and gravel,  and flows generally
 towards the southeast and south from the landfill  following surface
 drainage patterns.  A geologic cross section from the northeastern
 boundary of the landfill to the LaGrange Springs area  is  shown in
 Figure 6.   Ground water in the overburden  and shallow bedrock
 aquifers  appears  to be  hydraulically connected downgradient from
 the  Site  and  to discharge into the  wetlands  area  of  LaGrange
 Springs  and  Mathew Creek  located southeast  of  the Site.   In
 contrast  to  the ground-water flow pattern in the shallow water
- table, deep  (bedrock) ground  water generally flows  from west to
 east across the  Site.

 The immediate area of the landfill is underlain by  the Canojoharie
 Shale,  a mid-Ordovician age,  calcarious  shale with occasional
 pyrite lobes.  The bedrock was found to be  mildly fractured in the
 upper 20 feet of the unit.  Depth to bedrock ranges  across the site
 from about 30  feet to 120 feet.

 Wetland areas associated with Mathew Creek were identified using
 aerial photography,  the  NYSDEC wetland map on the  Johnstown area,
 and the U.S. Soil Conservation Service draft soils map of the area.
 Wetland  boundaries  were verified  in  the  field in  May 1990 by
 viewing vegetation and  hydrology.   (See Figure 7.)  Wetland types

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fhcrude palustrine forest, scrub-shrub, emergent, and open water.
A wetland  assessment using the Hollands and Magee  (1985)  method
indicated above-average scores  for  the biological,  hydrological,
and socio-economic functions of the wetlands.
SUMMARY OF SITE RISKS

Human Health Risk Assessment

A baseline risk assessment was conducted to evaluate the potential
risks to human health and the  environment associated with the Site
in  its  current state.   The baseline risk assessment  focused on
contaminants in the soil,  ground water, and air which are likely to
pose significant risks to human health and the environment.  A list
of the contaminants of potential concern in ground water, soil, and
air is found in Table  6.

The baseline  risk assessment evaluated the  health  effects which
could result  from exposure to contamination as a result  of ten
basic exposure pathways.  These pathways included: 1) ingestion of
soil; 2) dermal contact with soil; 3) inhalation of fugitive dust
from the landfill; 4)  ingestion of Mathew Creek surface water; 5)
dermal contact with Mathew Creek surface water;  6)  ingestion of
Mathew  Creek  sediments;  7)  dermal  contact with  Mathew Creek
sediments; 8)  ingestion of ground water; 9) inhalation of outdoor
air;  and  10)  inhalation  of  ground-water  contaminants  while
showering.  The exposure pathways were evaluated  under both current
and potential  future  land-use conditions, except for exposures to
landfill soil, for which  only current conditions were considered.
Three  potential  receptors were  identified: young  (ages 6-18)
trespassers;  adult,  young  (ages  6-18)   and  child   (ages  0-6)
residents living downgradient and off-Site; and young  (ages 6-18)
and adult  users of Mathew Creek.   These  exposure  pathways were
evaluated  separately for  adults  and children and are listed in
Table  7.   Exposure  intakes  (doses)  were  calculated  for  each
receptor for all exposure pathways considered.

Under  current  EPA guidelines,  the  likelihood  of  carcinogenic
(cancer  causing)  and noncarcinogenic effects due to  exposure to
site chemicals are considered separately.   It was  assumed that the
toxic  effects of  the Site-related chemicals would  be additive.
Thus,  carcinogenic  and  noncarcinogenic  risks  associated  with
exposures  to  individual  compounds  of  concern  were summed to
indicate the potential risks associated with  mixtures of potential
carcinogens and noncarcinogens, respectively.

Noncarcinogenic  risks  were  assessed using  a hazard  index  (HI)
approach, based on a comparison of expected contaminant intakes and
safe  levels  of intake (Reference Doses).   Reference doses  (RfDs)
have been developed by EPA for indicating the potential for  adverse
health effects.   RfDs, which  are expressed in units of mg/kg-day,
are estimates of daily exposure levels for humans which are  thought
to  be safe  over  a lifetime  (including  sensitive individuals).
Estimated  intakes of  chemicals from environmental media (e.g., the

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amount of a chemical ingested from contaminated drinking water) are
compared  with the  RfD to  derive  the  hazard  quotient for  the
contaminant in the particular medium.  The reference doses for the
compounds of concern at the Site are presented in Table 8.

The hazard index is obtained by adding the hazard quotients for all
compounds  across  all  media.    A hazard  index  greater than  1
indicates that the potential  exists for noncarcinogenic  health
effects to occur as a result of  Site-related exposures.   The HI
provides  a  useful reference  point  for gauging the  potential
significance  of multiple contaminant exposures within  a  single
medium or across media.

The HI was significant (i.e., greater than 1.0)  for all age groups
ingesting  ground  water under  current  land use.    The HI  for
ingesting ground water was  estimated to be  6.5, 3.3, and 2.5 for
children,  youths,  and adults,  respectively.   In  the case of
residents  ingesting  ground  water,  the major contribution  to
noncancer health risk is attributable to ingestion of antimony and
thallium  in drinking water by nearby  residents.  A summary of the
noncarcinogenic  risks  associated with  the  chemicals  evaluated
across various exposure pathways is found in Table 9.   It should be
noted that antimony was not  detected in any of the 51 water quality
samples  collected in downgradient ground-water monitoring wells,
and  thallium was  detected  in only  2 of the 51  monitoring well
samples.   Among the  52 residential  wells  sampled,  antimony and
thallium  were detected in 8  and 6 of the water-quality samples,
respectively.   Therefore,  these compounds may originate from the
native  soils  and not from  the landfill  waste  mass.   Without
antimony  and thallium, the HI for residents  ingesting ground water
for current land use is below 1.0 for all age groups.  Under future
land  use conditions,  which  assumes that the contaminated ground
water beneath  the landfill migrates to a residential  receptor, the
HI for adults  and children ingesting ground water was estimated to
be 1.5 and 1.0, respectively. The major contributor to these  risks
is arsenic.

The  HI  was  also  significant for  youths  and  adults  wading and
fishing  in Mathew Creek.  The  HI was 1.2  and 1.1 for youths and
adults,  respectively.   The major contributors to these  risks are
lead and mercury.

Potential carcinogenic risks were evaluated using the cancer  slope
factors  developed by EPA for the contaminants of  concern.  Cancer
slope factors (SFs) have been developed by EPA's Carcinogenic Risk
Assessment  Verification Endeavor for estimating excess  lifetime
cancer risks associated with exposure to potentially carcinogenic
chemicals.   SFs, 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 generate  an upper-bound  estimate of  the excess
lifetime cancer risk  associated with exposure  to the  compound  at
that intake level.  The term "upper bound"  reflects  the conserva-
tive estimate of the  risks  calculated from the SF.  Use of this
approach makes  the  underestimation of the risk  highly unlikely.
The SF for the compounds of concern are presented in Table 10.

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                                10

Foreknown  or suspected  carcinogens,  EPA considers  excess upper
bound individual lifetime cancer risks of between 10~* to  10* to be
acceptable.   This  level indicates  that an  individual has  not
greater than a one  in ten thousand to one in a million chance of
developing  cancer  as  a  result of  site-related  exposure to  a
carcinogen over a 70-year period under specific exposure conditions
at the Site.  Under the current land-use conditions, the cumulative
cancer risk  for all receptors evaluated  (i.e.,  adults, youths,
children) was 6 X 10"5.  The overwhelming contribution to this risk
is attributable to residents ingesting contaminated ground water.
This risk is within EPA's acceptable cancer risk range of  10"4 to
10"6.  However, under future land-use conditions, which assumes that
the contaminated ground water  beneath the landfill migrates to a
residential receptor, a cancer risk of 2  X 10"1 was found for the
adult receptor.  This risk, which slightly exceeds the acceptable
cancer range,  is  attributable to the  ingestion  of ground water,
with beryllium accounting for most of the risk.  A summary of the
carcinogenic  risks  for  the chemicals  evaluated  across various
current exposure pathways is found on Table 11.

The calculations were based on the  contaminants detected  in soils,
on-Site monitoring  wells,  and  air.   It was  assumed that  in the
future case,  on-Site monitoring wells would be used for residential
purposes.  Risk estimates were developed by  taking into account
various conservative assumptions about  the likelihood of a person
being  exposed to the various  contaminated media.   It  should be
noted  too,  that  the  carcinogenic  and  noncarcinogenic  risks
attributable  to lead,   which was  detected in  44 of  54 on-Site
samples  at  an average  concentration  of 38.6  /ig/L,  cannot be
quantified because cancer and noncancer toxicity factors have not
been developed for this compound.  However, EPA considers lead to
be  a probable  carcinogen,  and is known  to interfere  with the
central nervous system as a noncarcinogen.  An action level of 15
Mg/L was established by EPA for this compound, meaning that  some
remedial measures should be implemented,  if the concentration of
lead in drinking water exceeds  this level.

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.   Environmental chemistry analysis  error can  stem
from several  sources including the errors inherent in" the analyti-

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                                11

cal "methods and characteristics of the matrix being sampled.

Uncertainties in the exposure assessment are related to estimates
of how often an individual would actually come in contact with the
chemicals of concern, the period of time over which such exposure
would occur, and in the models  used to estimate the concentrations
of the chemicals of concern at the point of exposure.

Uncertainties  in  toxicological data occur  in  extrapolating both
from animals to humans and from high to low doses of exposure, as
well  as  from  the difficulties  in  assessing  the  toxicity  of a
mixture of chemicals.  These uncertainties are addressed by making
conservative assumptions  concerning  risk  and exposure parameters
throughout  the  assessment.    As  a  result,  the  baseline  risk
assessment provides upper bound estimates of the risks to popula-
tions near  the Landfill,  and is highly unlikely to underestimate
actual risks related to the Site.

More specific information concerning public health risks, including
a  quantitative evaluation of the degree of risk associated with
various exposure pathways, is presented in the RI report.

Ecological Risk Assessment

A   four-step   process   is  utilized  for  assessing  site-related
ecological  risks  for  a reasonable  maximum  exposure scenario:
Problem  Formulation —  a qualitative evaluation  of  contaminant
release,  migration,  and  fate;  identification  of contaminants of
concern, receptors, exposure pathways, and known ecological effects
of the contaminants; and selection of endpoints for further  study.
Exposure  Assessment —  a  quantitative  evaluation of  contaminant
release, migration, and fate; characterization of exposure pathways
and receptors; and  measurement or estimation  of  exposure  point
concentrations.    Ecological  Effects  Assessment —  literature
reviews,  field studies,  and  toxicity  tests, linking  contaminant
concentrations to effects on ecological receptors.  Risk Character-
ization  — measurement or estimation of  both current and  future
adverse effects.

Sediment,  surface water,  vegetation, wildlife,  fish, and  macroin-
vertebrates were assessed along Mathew Creek and a nearby  reference
stream, Halls Brook.  Fish tissue was collected and analyzed for
the presence of heavy metals and pesticides.  In-situ and  laborato-
ry bioassays  were  performed to evaluate  the  toxicity of  Mathew
Creek surface water to aquatic life.

The contaminants in Mathew Creek sediments appear  to be  adversely
affecting the aquatic  communities,  and  may  potentially  affect
wildlife  species such  as beaver, muskrat,  and waterfowl,  which are
dependent on  food resources  from the stream.  Arsenic,  cadmium,
chromium,  copper, iron, lead,  manganese, mercury,  and  nickel were
all present in  stream sediments at concentrations  that  exceeded
criteria  established by NYSDEC.  Exceeding these criteria suggests
that a given metal has  reached a concentration  that can possibly
result in chronic, sublethal effects that can include inhibition of

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                                12

reproduction, inefficient metabolism of food items,  alteration of
an organism's ability to compete, etc.  The Mathew Creek biota most
likely at risk of exposure to metal contaminated sediments (other
than  mercury)  are  benthic  macroinvertebrates  such  as  worms,
beetles, and midges.

Free-swimming  aquatic organisms  in  Mathew  Creek  may  also  be
adversely  affected  by creek   contamination,  particularly  high
ammonia concentrations in surface water.  Water  quality samples
collected in Mathew  Creek, over three sampling rounds,  indicated
the presence  of 8 inorganic substances, namely,  aluminum,  iron,
lead, manganese, selenium, cyanide, zinc, and ammonia-nitrogen, at
concentrations  above NYSDEC surface-water  standards and/or  EPA
Ambient Water Quality freshwater toxicity criteria.  Concentrations
of aluminum, iron, and cyanide were also above EPA acute freshwater
toxicity criteria.   Aluminum and cyanide exceeded the  EPA acute
fresh water toxicity criteria  at  downstream stations  in Mathew
Creek.   Ammonia-nitrogen exceeded  the EPA  acute  fresh  water
toxicity criterion at the  headwater springs and just downstream of
Hulbert pond.  Vegetation  does  not  appear to be adversely affected
by contaminants in Mathew Creek.

In summary, actual or threatened releases of hazardous substances
from the Site, if not addressed by the preferred alternative or one
of the other active measures considered, may present a current or
potential threat to public health, welfare or the environment.


DESCRIPTION OF REMEDIAL ALTERNATIVES

CERCLA  requires that each selected site remedy be  protective of
human health  and the environment,  be cost-effective,  comply with
other statutory laws, and  utilize permanent solutions, alternative
treatment technologies and resource  recovery alternatives to the
maximum extent  practicable.   In addition,  the statute includes a
preference  for the use of treatment as a principal element for the
reduction   of  toxicity,   mobility,  or  volume  of the  hazardous
substances.

This Record of  Decision evaluates in detail,  7 remedial alterna-
tives for addressing the  contamination associated with the Site.
The time to implement reflects only the time required to construct
or implement  the  remedy and  does not  include the time required to
design  the remedy,  negotiate  with  the responsible  parties, or
procure contracts  for design and construction.  These alternatives
are described below.
Alternative  SC-l:  No  Action

Capital  Cost:                       $14,000
Operation and  Maintenance Cost:    $119,000
Present-Worth  Cost:              $1,860,000
Time  to"  Implement:                3 months

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                                13

The "Superfund program requires that the "no-action" alternative be
considered as  a  baseline for comparison with the  other alterna-
tives.   The  no-action remedial alternative does not  include any
physical remedial measures that address the problem of contamina-
tion at the Site.  However, this response action does include the
implementation  of a  long-term  ground-water,  surface-water  and
sediment-monitoring  program.    Water  quality samples  would  be
collected  on  a   quarterly  basis  from upgradient,  on-Site  and
downgradient ground-water monitoring wells  and  from locations on
Mathew Creek.  Sediment samples would be collected from the creek
bed.  Parameters to be sampled and analyzed would be in accordance
with 6 NYCRR Part 360 baseline and routine parameters.

The no-action response also includes the development and implemen-
tation  of  a  public  awareness  and  education  program for  the
residents  in  the area surrounding the Site.  This program would
include  the  preparation and  distribution  of  informational press
releases  and  circulars and  convening public  meetings.   These
activities would serve to enhance the public's  knowledge  of the
conditions existing at  the Site.  The capital cost for the public
awareness program is approximately $14,000.  This alternative would
also  require  the involvement  of local government,  various health
departments and  environmental agencies.

Because this alternative would result in contaminants remaining on-
Site  above health-based levels,  CERCLA requires that the Site be
reviewed every five  years.   If justified by the review, remedial
actions  may be implemented to remove or treat the wastes.


Alternative sc-2: Limited Action, Residential Water Replacement

Capital  Cost:                    $8,343,000
Operation  and Maintenance  Cost:    $174,000
Present-Worth Cost:              $11,034,000
Time  to  Implement:                  3 years

This  alternative includes a  Site  access restriction which would
consist  of surrounding the entire landfill mound with approximately
6,800 feet of conventional chain-link fencing and placing appropri-
ate  warning   signs.    In addition  to  the  access  restriction,
institutional controls  would  be implemented to restrict the use of
the land because of the threat of contamination.  This may occur in
the form of local ordinances  or deed restrictions.   As part of the
limited  action  alternative,  the  landfill would  be  regraded to
prevent  stormwater from ponding on the landfill mound, and to  allow
rapid runoff  from the  Site,  while minimizing soil erosion.    The
regrading  would include excavation  of  the  LaGrange • Gravel  Pit
sediments, placing the excavated material on the existing landfill,
and covering  them.  The pit would then be filled with clean fill so
that  it may be  used  as an infiltration basin,  and/or  an  area to
collect  stormwater.

The limited-action  alternative also calls for the expansion of the
Johnstown  City water  supply system to provide potable water to all

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                                14

dbwngradient private  water supplies potentially impacted  by the
landfill.  Providing city water would require the extension of the
City's water  lines and  a booster  pump station requiring major
construction.    Under this alternative,  at least 24,600  feet of
water line would be constructed.

Similar to Alternative SC-1,  this  alternative  would also include
long-term monitoring of ground water, surface water and sediments,
and the implementation of. a public awareness program to ensure that
the nearby residents are  familiar with all aspects of this response
action.

Because this alternative  would result in contaminants remaining on-
Site above health-based  levels, CERCLA requires that the Site be
reviewed every  five years.   If justified by  the review,  remedial
actions may be  implemented to remove or treat the wastes.


Alternative SC-3: Installation of  6 NYCRR  Part 360  Landfill Cap,
Residential Water Replacement

capital Cost:                    $13,763,000
Operation and Maintenance Cost:    $174,000
Present-Worth Cost:             $16,454,000
Time to Implement:                  3 years

The  major features  of  this  alternative include constructing a
multi-layer closure  cap  over the  landfill mound,  supplying city
water to  replace  existing private  wells, and erecting a security
fence.   The replacement  of private water  sources  with Johnstown
City  water,  land  use restrictions,  and fencing components are
identical to  those described in Alternative SC-2.   Prior to the
construction  of the  cap, the  landfill mound  would have  to be
regraded and compacted to provide a stable foundation for placement
of the various  layers of the  cap  and  to provide  rapid runoff as
described in Alternative SC-2.  The landfill cap would be designed
and constructed as per New York State 6 NYCRR Part 360 regulations.
A landfill cap meeting these requirements would consist of a filter
fabric, 12 inches for a gas venting layer, a 40  mil geomembrane  (or
18 inches of clay), 24 inches  of drainage material and six inches
of topsoil. Capping the  landfill would minimize the  release of the
additional  leachate into  ground water and would be expected to
allow  reduction  of  ground-water  contaminants  by  processes of
natural attenuation which may include  dilution, biodegradation and
sorption.   Landfill  gases would be monitored and vented into the
atmosphere or controlled as needed.

Similar  to  Alternative SC-1,  this alternative would also  include
long-term monitoring of ground water, surface water,  and sediments,
and the implementation of a public awareness program to ensure that
the nearby residents are  familiar with  all aspects of this response
action.

Because this alternative would result in contaminants remaining on-
Site  above  health-based  levels, CERCLA requires that the  Site be

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                                15

Reviewed every five years.   If  justified by the review,  remedial
actions may be implemented to remove or treat the wastes.


Alternative SC-4: Installation  of  RCRA Landfill Cap, Residential
Water Replacement

Capital Cost:                   $19,729,000
Operation and Maintenance Cost:    $174,000
Present-Worth Cost:             $22,420,000
Time to Implement:                  3 years

The  major features  of this  alternative include  constructing a
multi-layer  closure  cap over the  landfill  mound,  supplying city
water to residences,  and erecting a security fence.  This alterna-
tive is identical to  Alternative SC-3 except that a RCRA capping
system would be used  instead of  the 6 NYCRR Part 360 cap that would
be implemented under  Alternative SC-3.  The RCRA cap system differs
from the NYCRR cap by requiring a 24-inch thick soil barrier layer
(NYCRR requires  18 inches,  if soil is used) and a  40 mil geomem-
brane  (NYCRR requires  either the  membrane or the soil barrier
layer), a 12-inch thick drainage layer  (NYCRR  requires 24 inches)
and  a  24-inch thick  topsoil layer  (NYCRR  requires 6-inch thick
topsoil).  Capping the landfill would minimize the  release of  the
additional  leachate  into ground  water and would  be expected to
allow  reduction  of   ground-water contaminants  by  processes  of
natural attenuation which may include dilution, biodegradation  and
sorption.   Landfill  gases would be vented into the atmosphere or
controlled,  as needed.

Similar to  Alternative SC-1, this alternative would also include
long-term monitoring of ground water,  surface water, and sediments,
and the implementation of a public  awareness program to ensure that
the nearby residents are familiar with all aspects of this response
action.

Because this alternative would result in contaminants remaining on-
Site above  health-based levels, CERCLA requires that the Site be
reviewed  every five  years.  If justified by the review, remedial
actions may be implemented to remove or treat  the  wastes.


Alternative SC-5:  Ground  Water  Collection/Treatment/Discharge,
Residential Water Replacement

Capital Cost:                    $12,754,000
Operation and Maintenance Cost:    $936,000
Present-Worth Cost:              $27,160,000
Time to Implement:                   3 years

This remedial alternative includes the collection of contaminated
ground water in  the  upper  (overburden) aquifer and/or  the  lower
 (bedrock) aquifer,  followed by its  treatment and  discharge  via
percolation ponds  or  injection wells.   Ground  water  would be
extracted utilizing  extraction wells which would  induce  ground-

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                                16

Water flow to the wells by drawdown  development.  Ground-water flow
leaving the Site would be collected by the creation of overlapping
zones  of  influence of  the extraction  wells.   The  ground-water
treatment system would be located permanently at the Johnstown City
Landfill site and would utilize physical-chemical processes, such
as pH adjustment, chemical precipitation, and carbon adsorption, to
remove inorganic and volatile organic contaminants.  Treated ground
water would  be  discharged by returning it to  the aquifer,  or by
discharging  to  a  stream,  the nearest  being Mathew Creek.   The
discharge standards would be established by NYSOEC.

The other major  features of this alternative include regrading with
a two-foot soil  cover, residential water replacement with Johnstown
City  public water, security fencing,   and deed restrictions  as
described in Alternative SC-2.

Similar to Alternative SC-1,  this  alternative would also include
long-term monitoring of ground water, surface water, and sediments,
and the implementation of a public awareness program to ensure that
the nearby residents are  familiar with all aspects of this response
action.

Because this alternative would result in contaminants remaining on-
Site above health-based  levels,  CERCLA requires that the Site be
reviewed every  five years.   If justified by the review, remedial
actions may be  implemented to remove or treat the wastes.


Alternative SC-6:  6 NYCRR part 360  Cap,  Residential Water Replace-
ment, Ground Water Collection/Treatment/Discharge

Capital Cost:                   $18,174,000
Operation and Maintenance Cost:    $936,000
Present-Worth Cost:             $32,580,000
Time to Implement:                  3 years

This alternative consists of the following:  constructing a multi-
layer NYCRR  closure cap over the landfill mound as in Alternative
SC-3; treating extracted ground water with discharge to the aquifer
or surface  water as  in Alternative SC-5; supplying city water to
local residents; erecting a security fence around the landfill; and
implementing institutional controls as  in Alternative SC-2.

Similar to  Alternative SC-1, this  alternative would also include
long-term  monitoring  of the  ground  water, surface water,  and
sediments, and  the implementation of a public awareness  program to
ensure that  the nearby residents are familiar  with all  aspects of
this  response action.

Because this alternative would result in contaminants remaining on-
Site  above  health-based levels, CERCLA requires that the Site be
reviewed  every  five  years.   If justified by the review, remedial
actions may be  implemented to remove or treat  the wastes.

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                                17

Alternative SC-7:  RCRA Cap, Residential Water Replacement, Ground
Water Collection/Treatment/Discharge

Capital Cost:                   $24,139,000
Operation and Maintenance Cost:    $936,000
Present-Worth Cost:             $38,545,000
Time to Implement:                  3 years

This alternative consists of the construction of a multi-layer RCRA
closure  cap  over the  landfill mound  as  in  Alternative  SC-4;
treatment  of  extracted ground  water followed by discharge  to
surface  water,  as in  Alternative  SC-5;  supplying city  water to
local  residents;  implementing  ground  water  and  landfill  gas
monitoring programs; erecting a security fence around the landfill;
and implementing institutional controls, as in  Alternative SC-2.

Similar  to  Alternative SC-1,  this  alternative would also include
long-term monitoring of ground water,  surface water and sediments,
and the implementation of a public awareness program to ensure that
the nearby residents are familiar with all aspects of this response
action.

Because this alternative would result  in contaminants remaining on-
Site  above  health-based levels,  CERCLA requires that the Site be
reviewed every five years.  If justified by the review, remedial
actions  may be implemented to remove  or treat the wastes.
 SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES

 During  the  detailed  evaluation of  remedial  alternatives,  each
 alternative was assessed utilizing nine evaluation criteria as set
 forth in the  NCP  and OSWER Directive 9355.3-01.  These  criteria
 were developed to address the requirements of Section 121 of CERCLA
 to ensure all important considerations are factored  into  remedy
 selection decisions.

 The following "threshold" criteria are the most important, and must
 be  satisfied by  any  alternative  in  order  to  be  eligible  for
 selection:

 1.  Overall protection of human health and the environment address-
     es  whether  or  not a remedy provides  adequate protection and
     describes how risks posed through each exposure pathway (based
     on  a  reasonable  maximum  exposure scenario) are  eliminated,
     reduced, or controlled through treatment, engineering controls,
     or  institutional  controls.

 2.  Compliance with ARARs addresses whether or not a remedy would
     meet all of the applicable or relevant and appropriate require-
     ments of federal and state  environmental statutes and require-
     ments or  provide  grounds for invoking a waiver.

 The  following  "primary balancing"  criteria  are used  to  make
 comparisons and to identify the major trade-offs between alterna-

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                                18

t"ive~s:

3.  Long-term effectiveness and permanence refers to the ability of
    a remedy to maintain  reliable protection  of human health and
    the environment over  time, once cleanup goals  have been met.
    It  also addresses  the magnitude  and effectiveness of  the
    measures that may be required  to manage  the  risk  posed by
    treatment residuals and/or untreated wastes.

4.  Reduction of toxicity. mobility, or volume through treatment is
    the anticipated  performance of a  remedial  technology,  with
    respect to these parameters, that a remedy may employ.

5.  Short-term effectiveness addresses the period of time needed to
    achieve protection and any adverse  impacts on human health and
    the environment that  may be posed during the construction and
    implementation periods until cleanup goals are achieved.

6.  Implementabilitv is the technical and administrative feasibili-
    ty  of  a remedy,  including the availability  of materials and
    services needed.

7.  Cost includes estimated capital and operation and maintenance
    costs, and the present worth costs.

The following "modifying" criteria are considered fully after the
formal public comment period on the Proposed Plan is complete:

8.  State acceptance indicates whether, based  on its review of the
    RI/FS  and the  Proposed Plan, the State  supports,  opposes,
    and/or  has identified  any reservations . with the preferred
    alternative.

9.  Community acceptance refers  to the public's general response to
    the alternatives described in the Proposed Plan and the RI/FS
    reports.   Factors  of  community  acceptance to  be discussed
    include support, reservation,  and opposition by the community.

A comparative analysis of the remedial  alternatives based upon the
evaluation  criteria noted above follows.
Overall Protection  of Human Health and the Environment

The  no-action alternative, Alternative SC-1,  would be the least
protective  of human health and the environment since it does not
address any of the  remedial action objectives  established  for the
Site.  Alternative  SC-2 would be more effective than Alternative
SC-1  in  protecting human  health  and  the  environment by reducing
risks attributed to direct exposure and from ingestion  of contami-
nated drinking water.  Direct  exposure would be reduced somewhat by
constructing fences,  posting signs, and implementing institutional
controls  which would limit access to the Site by trespassers and
children.   Risks from ingestion of contaminated ground  water would
be  reduced since  the  landfill  would  be  regraded  to   prevent

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                                19

stormwater from ponding  on the  landfill  mound and to  allow  for
rapid runoff from the Site while minimizing  soil  erosion.   It is
estimated that this  would limit  infiltration of precipitation into
the landfill and reduce the generation of landfill leachate by 36
percent.   Also,  extension of  city water  services proposed  in
Alternative SC-2 would reduce the  risk associated with ingestion
and exposure to contaminated ground water.

The  closure  cap  systems of  Alternatives SC-3  and SC-4,  which
include  an impermeable  layer,  would  further  reduce  run-on  and
infiltration of  rainfall and snow melt into  the  landfill,  thus
reducing the  quantity  of water  percolating  through the landfill
materials  and  leaching out contaminants.   It is  estimated that
Alternative SC-3 (NYCRR impermeable cap) would provide a 94 to 99
percent reduction in leachate production and Alternative SC-4 (RCRA
impermeable cap)  would provide greater than 99 percent reduction in
leachate production.   Alternative SC-4 would therefore  be more
protective than Alternative SC-3.  But both Alternatives SC-3 and
SC-4 would be significantly more protective than Alternative SC-2.
None of these alternatives include  any direct ground-water control
or remediation measures;  therefore, the contaminated ground water
would  remain unaffected  except for  reduced leachate production
allowing ground-water contaminant levels to decline.  Although the
rate of contaminant decrease  cannot be predicted with certainty,
mathematical  modelling results  indicate that  Site ground-water
contamination levels may  continue  to  exceed ARARs for a period of
about 3 to 12 years following installation of the  cap,  if there is
no control or direct remediation of ground water.

The  extraction and treatment  system of Alternative  SC-5 would
reduce  the movement  and toxicity of  the  contaminated landfill
leachate and  ground water by pumping and treating this water and
preventing its downgradient migration.  Under Alternative SC-5 the
landfill  would be  regraded and a  soil cover  would be placed as
described  under Alternative SC-2.  Alternative SC-5 would be more
protective in remediating contaminated ground  water than Alterna-
tive SC-2.   However, Alternative SC-5 would be less effective in
limiting leachate production than  Alternatives SC-3 and SC-4.

Alternatives  SC-6  and  SC-7 include  the closure  cap systems of
Alternatives  SC-3  and  SC-4 respectively, ground water  extraction
and treatment as in Alternative  SC-5, and city water service as in
Alternative SC-2.  Alternatives SC-6 and SC-7 would thereby further
reduce  the volume  of  ground water coming  into  contact with the
contaminant  source, reducing the  remediation  time in  comparison
with Alternative SC-5.   Alternatives SC-7  and SC-6 would be the
most protective and second most protective  alternatives,  respec-
tively, of human health  and the environment.


Compliance with ARARs

The New York State Part 360 landfill cap is an action-specific ARAR
for  landfill  closure.  Alternatives SC-1, SC-2, and SC-5 would not
meet this ARAR,  since  they do  not  include  any provisions for  a

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                               20

landfill cap.   Alternatives SC-3,  SC-4,  SC-6, and  SC-7  include
provisions for a landfill cap which would meet or exceed the Part
360 requirement for an impermeable cap.

Alternatives SC-6 and SC-7 would be the most effective in reducing
ground water contaminant concentrations below maximum contaminant
levels (MCLs),  because of the lower infiltration rate of precipita-
tion associated with placing an impermeable cap over the landfill,
and  because they  include   collection  and  on-Site treatment  of
contaminated ground  water.    Alternative SC-5 may be  nearly  as
effective as Alternatives SC-6 and  SC-7  in  reducing  ground water
contamination,  provided that the collection system was designed and
operated to capture all the contaminated ground  water.   However,
without an impermeable cap there would be more leachate generated
and additional contaminated ground water requiring collection and
treatment under Alternative SC-5 than under Alternatives SC-6 and
SC-7.  Alternatives SC-1,  SC-2,  SC-3, and SC-4 do not provide for
any direct remediation of ground water.   However,  under Alterna-
tives SC-2, SC-3,  and SC-4  less leachate would  be generated and
introduced  into the  ground water.   This  would  facilitate the
reduction of contaminant levels in ground water to ARARs by natural
attenuation.
Lonq-Term Effectiveness and Permanence

Alternative SC-1 provides no  long-term  controls for handling the
on-Site contamination or the ground-water contamination.  Alterna-
tive SC-2 would minimally reduce the rate of leachate production,
thereby  limiting  direct contact with  the contamination.   Under
Alternative SC-2,  the replacement of residential water supplies and
the erection of a security fence would be permanent actions which
would reduce potential exposure to contaminated ground water and to
contaminated waste.   However,  it  is doubtful  that ground-water
quality would be restored to acceptable levels, since significant
quantities of leachate would be  generated as  a result of continued
infiltration of precipitation  through the soil cover.  Alternatives
SC-3 and SC-4  would provide  much greater reduction of leachate
production  than  Alternative  SC-2,  resulting  in  ground-water
remediation by natural attenuation.  Alternative SC-5 would provide
an equivalent reduction in leachate generation as would Alternative
SC-2 due to the soil cover.  In addition, ground-water contaminants
would be contained by  the  ground-water collection and treatment
system  proposed  under  Alternative  SC-5.    The  collection and
treatment system would be operated until contaminant concentration
levels in ground water are reduced to acceptable levels.  Alterna-
tive SC-6  would combine the capping and ground-water remediation
components  of  Alternatives SC-3  and SC-5,  and Alternative SC-7
would combine the capping and ground-water remediation components
of  Alternatives  SC-4  and  SC-5,  thus  reducing  the period  of
treatment  necessary.   The closure cap  is  a permanent technology
that  must  be  maintained  at regular  intervals  to  ensure its
structural  integrity and impermeability.

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                               21

Reduction in Toxicity. Mobility,  or Volume Through Treatment

The no-action alternative (Alternative SOI)  does not contain any
remedial measures  which would reduce the toxicity,  mobility,  or
volume  of  the  ground-water  contamination.    The  limited  action
alternative (Alternative SC-2) provides some limited reduction of
leachate and leachate seeps through regrading.

Alternatives SC-3 and SC-4 provide  further reduction of the volume
of  contaminated ground water by  further reducing the  amount of
water infiltrating the landfill.  These alternatives also eliminate
the formation of contaminated leachate seeps.

Implementation of Alternative SC-5, SC-6, or  SC-7 would reduce the
toxicity, mobility, and volume of the contaminated  ground water by
extracting and treating the ground water. These alternatives would
remove  the  contaminated ground water from  the aquifer and reduce
contaminant concentrations in ground water  to acceptable levels,
which  would reduce  downgradient  migration  of  the  contaminated
ground  water.

Alternative SC-5 would reduce the leachate production using a soil
cover.   Alternatives SC-6 and SC-7 would further reduce leachate
generation with an impermeable cap.  Alternative SC-5 would leach
some contaminants from the landfill mound but at a rate slower than
is  occurring  now.    Therefore,  dilution would  be  achieved and
treatment  could probably end after a relatively short period.
Alternatives SC-6  and SC-7 would result in the elimination of the
production  of  almost  all  leachate and,  thereby,  provide  the
shortest treatment  period.   However,  leachate  production would
restart,  if  the  impermeable cap  were to  fail.    Data  is not
presently  available  concerning the  effective  life of a landfill
cap.

None of the alternatives proposed reduces the toxicity or volume of
waste present  in the landfill.


Short-Term  Effectiveness

Alternative SC-1  does not  include  any  physical  construction
measures and,  therefore, does not  present a  risk to  the community
as  a  result of its implementation.

The remaining alternatives involve major construction activities at
the Site and the use of heavy earth-moving  equipment.   All  of the
potential  impacts associated with implementation  of Alternatives
SC-2,  SC-3,  SC-4,  SC-5, SC-6, and SC-7 could be  mitigated  in part
by  using proper construction techniques and operational procedures.
The potential  for   on-Site accidents  and  worker  exposure to
contaminated media  would  increase as the number  of construction
activities increases.  These risks would be minimized with proper
health  and  safety  training and  personal  protective  equipment.
 Potential hazards to the surrounding community  and  environment
would  include  adverse  traffic   conditions,  airborne  dust  and

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                                22

particulate emissions,  an increase in noise  levels,  and adverse
impacts  to the  wetlands  area.   Mitigative  measures would  be
implemented to minimize the impacts from these hazards.

The ground-water treatment systems of Alternatives SC-5, SC-6 and
SC-7 would require  storage  and handling  of  possibly dangerous
materials, such as process reagents and residuals.  These activi-
ties may  be accomplished with  minimal  risks to workers,  by the
development and implementation  of  safe  operating and maintenance
practices.  Compliance with applicable regulations  would ensure
proper  hazardous  waste  transportation  and  disposal  of  drummed
process sludge at an appropriate off-Site  treatment and disposal
facility.


Implementability

Alternative SC-1,  the no-action alternative, would be the easiest
of the alternatives to implement because it requires only minimal
on-Site activity.   Public information programs  and ground-water
monitoring are easily implemented.

The construction procedures, materials and earth-moving equipment
required for the implementation of Alternatives SC-2, SC-3, SC-4,
SC-5, SC-6, and SC-7 are conventional and are used extensively in
standard commercial  and  industrial applications.   Supplying city
water to nearby residents is readily achievable.

Alternatives SC-3, SC-4, SC-6,  and  SC-7, which involve  capping the
landfill, may be somewhat more difficult to implement.  Construc-
tion  methods  for  capping  are well  established,  although some
technical  problems,  such as  those  attributed  to meeting the
required specifications for the impermeable layer, may be encoun-
tered.  The treatment systems of Alternatives SC-5, SC-6 and SC-7
utilize standard unit operations and water treatment equipment that
are well suited for this application and are technically reliable.
Transportation  and  disposal  of  the dewatered  process   sludge
involves easily implementable practices and the use of commercially
available  facilities.

All  of the alternatives  involve   some  degree  of institutional
management.  Alternative SC-1 requires administrative coordination
of  the ground-water monitoring program and the  five-year site
status reviews, along with the development  of the public education
program.  Alternative SC-2 requires a similar level of  control for
those activities and also for maintenance of the security fence and
administrative issues related to extension of the city water system
to residents.

The  administrative  requirements of Alternatives SC-3,  SC-4,  SC-5,
SC-6, and SC-7 include the ground-water, surface-water and sediment
monitoring programs,  the extension of the city water  system, and
the  security  fence  inspection.   In addition to these  activities,
the  structural integrity and impermeability of the closure cap and
cover must be maintained through a program of periodic surveillance

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                                23

efnd~necessary  repairs.    Because  of the  large  land area  of  the
landfill, this item could be fairly substantial.

Alternatives  SC-5,   SC-6,  and  SC-7  also  require  an  extensive
monitoring program for the operation and maintenance  of the ground-
water treatment  facility.   The administrative elements  of this
program are extensive because  they include equipment maintenance
schedules  and  transportation and  disposal of  hazardous  process
residuals  in compliance with regulations.  Also,  should treated
leachate and ground  water be discharged to surface water, system
effluent monitoring to meet surface-water discharge standards would
be necessary.

Most services and materials required for implementation of any of
these  potential  remedial  alternatives  are  readily  available.
Standard construction equipment and practices can be employed for
the fence  installation  and  the extensive Site work activities of
Alternatives SC-2, SC-3, SC-4, SC-5, SC-6,  and  SC-7.  Most of the
materials  and  equipment  required  for these  alternatives may be
obtained locally.

Contractors to provide the construction services are also available
in the Fulton County area.   Because the work will be taking place
at  a  Superfund  site, all  on-Site personnel must  have  approved
health  and safety  training.   Many  companies are  available to
provide this training to  contractors.  The engineering and design
services required for implementation of Alternatives SC-2, SC-3,
SC-4,  SC-5,  SC-6 and SC-7  may be  obtained from many companies.
Hazardous waste transportation and disposal for treatment residuals
required for Alternatives SC-5,  SC-6, and SC-7 are also commercial-
ly available.
 Cost estimates were developed for each of the  potential  remedial
 alternatives.    The present-worth  costs  are  calculated  using  a
 discount rate  of  5 percent  and a  30-year time  interval.    The
 estimated capital,  annual operation and maintenance,  and present
 worth costs for each of the alternatives  are as follows:

 Alternative   Capital  Cost   Annual Cost     Present Worth Cost

 SC-1              $14,000     $119,000        $1,859,000
 SC-2           $8,343,000     $174,000       $11,034,000
 SC-3          $13,763,000     $174,000       $16,454,000
 SC-4          $19,729,000     $174,000       $22,420,000
 SC-5          $12,754,000     $936,000       $27,160,000
 SC-6          $18,174,000     $936,000       $32,580,000
 SC-7          $24,139,000     $936,000       $38,545,000

 The capital cost  and  annual  cost  for Alternative  SC-1,  the no-
 action  alternative, includes the  cost  for the  public awareness
 program and for long-term  monitoring, respectively.  The capital
 cost for Alternative SC-2 includes costs for  clearing and regrading

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                               24

the "landfill and for construction of the water-line extension.  The
capital cost for Alternatives SC-3 and SC-4 are for. construction of
the 6 NYCRR Part 360 cap and RCRA cap,  respectively, in addition to
necessary clearing and regrading of the landfill and construction
of the water-line extension.  The annual cost for Alternatives
SC-2, SC-3,  and  SC-4 includes operation and maintenance  of the
landfill cover and surface-water drainage systems,  in addition to
long-term monitoring.  The capital costs for Alternatives SC-5,
SC-6,  and SC-7  includes the  construction  of  the  ground-water
collection, treatment, and discharge system, in addition to those
capital costs  specified for Alternatives  SC-2, SC-3,  and SC-4,
respectively.  The annual cost for Alternatives SC-5, SC-6, and
SC-7  include  operation  and  maintenance  of  the  ground-water
extraction,  treatment,   and discharge  system,  in  addition  to
operation and maintenance of the landfill cover and surface-water
drainage systems,  and for long-term monitoring.


State Acceptance

NYSDEC concurs with the  selected  alternative.  NYSDEC also concurs
with  the  contingent remedy,  should  future water-quality  data
indicate  that  the  ground-water  remediation   component  of  the
contingent remedy is appropriate.


Community Acceptance

The community's comments and concerns  identified during the public
comment period are summarized and addressed in the Responsiveness
Summary, which is attached as Appendix V to this document.  While
several  residents expressed concerns at the  February  10,  1993
public meeting related to the costs of water use  and water district
taxes  associated  with extending the  Johnstown  City water-supply
system, it appears that  the majority of the community  is supportive
of the water line.   This  is  evidenced from Resolution  No. 110
adopted by  the Town  Board  of Johnstown at its meeting on October
19, 1992 and from statements made at a Town  Board meeting on March
4, 1993.
SELECTED REMEDY

Based  upon  consideration  of the  requirements  of  CERCLA,  the
detailed analysis  of the alternatives,  and public comments, both
NYSDEC  and  EPA have  determined  that  Alternative  SC-3  is the
appropriate  remedy,  with Alternative SC-6 as a contingent remedy
for the Site.

Alternative  SC-3, as the selected remedy,  and Alternative SC-6,  as
the contingent remedy, are effective  in protecting human health and
the  environment and  in meeting  ARARs  for  landfill  closure and
ground-water quality,  since they include an  impermeable landfill
cap  and ground-water remediation,  if  it  is needed.    Although
Alternative  SC-6 would  be more  protective  in that  it  includes

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                               25

cfolTection and treatment of contaminated ground water, NYSDEC and
EPA  believe  that  Alternative  SOS is  more cost-effective  than
Alternative SC-6.  Under Alternative SC-6, ground-water collection
and treatment would  raise the  capital cost  of  the remedy by more
than  $4  million and would  raise  the present-worth cost  of the
remedy by about $16 million.  Given that  the  levels of ground-water
contamination  are  generally only slightly  above  ARARs,  that the
cancerous risk  is  only  slightly  above the acceptable risk range,
and that the noncancerous risk posed by ground-water ingestion is
only slightly above the significant level,  ground water remediation
does not appear to be warranted unless ground-water contamination
levels  and surface-water contamination in Mathew Creek  do not
improve through natural attenuation.   It is estimated  that as a
result of  reduced  leachate  generation,  ground-water and surface-
water  contamination  would begin to naturally  attenuate within 5
years  following  initiation  of construction  of the cap.

NYSDEC and EPA consider Alternative SC-3 (with  Alternative  SC-6 as
the  contingent alternative) to be preferable to Alternative SC-4
(with  Alternative  SC-7  as the  contingent alternative),   since
Alternative  SC-3 provides  a comparable degree of protection as
Alternative  SC-4,   but  is  more  cost-effective.    The  RCRA cap
required under Alternative  SC-4  (and Alternative  SC-7) would cost
approximately  $6 million more to  construct than the NYSDEC Part 360
cap under Alternative SC-3  (and Alternative SC-6), but would  only,
at most,  marginally reduce  infiltration of precipitation  through
the  cap.  Unlike Alternatives  SC-2 and  SC-5, which  do not  include
an impermeable cap,  Alternatives SC-3 and SC-6  will be designed to
meet New York  State  landfill closure ARARs  and thereby  reduce the
volume of contaminated ground water. Although  Alternative  SC-1 is
significantly  lower  in cost than the other alternatives,  including
the  preferred  alternative,  it would not  attain  remedial  action
objectives  for  this site,  since it would not  reduce leachate
generation, prevent  human and animal contact with contaminated soil
from the landfill  surface, prevent erosion of contaminated  surface
soil,  nor  provide  a  means of treating landfill gas emissions.

The  major  components of the selected remedy are as follows:

     •   Excavation  of the LaGrange Gravel Pit sediments and placing
        the excavated materials on the existing landfill.  The  pit
        will then be  filled  with  clean fill, so that it may be used
        as an infiltration basin and/or stormwater collection basin;

        Regrading and compacting the landfill  mound to  provide  a
        stable foundation  for placement of the various layers of the
        cap and to  promote rapid runoff;

     •  Construction of  a multi-layer closure cap over the landfill
        mound and excavated  sediments as per New York State 6 NYCRR
        Part  360  regulations.    The cap,  by reducing  leachate
        generation, will act to improve the ground-water quality in
        the upper  (overburden)   and lower  (bedrock)  aquifers  and
        surface-water quality   in Mathew   Creek  through  natural
        attenuation of contaminants;

-------
                               26

   "•  Expansion  of  the Johnstown  City water-supply  system to
      provide potable water to all  private water supplies poten-
      tially impacted by the landfill.  Providing city water will
      require the extension of  the City's  water lines and con-
      struction of a booster pump station;

      Erection of approximately 6,800 feet of conventional chain-
      link  fencing surrounding  the entire  landfill mound,  with
      placement of appropriate warning  signs;

    •  Performance of air monitoring prior to, during,  and follow-
      ing construction  at the Site to ensure that air emissions
      resulting  from the  cap  construction meet  applicable or
      relevant and appropriate requirements.  Perimeter subsurface
      gas  monitoring  between  the  landfill  and   the adjacent
      properties will be performed.  The gas-monitoring wells will
      be monitored quarterly for explosive gas concentrations;

    •  Performance of air dispersion modeling to estimate ambient
      air concentrations of contaminants.  Landfill gas emissions
      will  be  vented  into the atmosphere,  or  if  necessary,
      controlled;

    •  Imposition of  property deed restrictions by the appropriate
      state or local authorities.    The  deed restrictions will
      include measures  to  prevent  the  installation of drinking
      water wells at the Site, and restrict activities which could
      affect the  integrity of the cap;

    •  Performance  of a maintenance  and sampling program upon
      completion  of  closure activities.  The monitoring program
      will  fulfill the  requirements of 6 NYCRR Part 360 for post-
      closure  landfill monitoring  in  addition  to  monitoring
      parameters  of  concern found at the Site;

    •  Development and implementation of a dust control plan.   The
      plan  will contain all possible  sources  of fugitive  dust
      emissions  which  exceed  action levels  including intrusive
      field activities  such as  excavation or regrading of waste.
      Normal dust suppression techniques for handling of soils and
      road  materials will be addressed in the plan.  The plan will
      also  include how  each of these potential dust sources  will
      be controlled  by addressing the control methods that will be
      conducted.  The plan will prohibit the  use of environmental-
      ly unacceptable  products  such  as halides or  petroleum
      products;

      Performance of a Stage IA cultural resources  survey (CRS) as
      early as possible in the Remedial Design phase for both on-
      Site  and  off-Site areas to evaluate the sensitivity of the
      site  for cultural resources.   The  results of the  Stage IA
      survey  will be used to assist in determining if additional
      CRS work will  be  required.

The effectiveness of the landfill   cap will  be  evaluated  through

-------
                               27

post-construction monitoring  of  ground-water and  surface-water
quality.  The evaluation will be conducted within 5 years following
initiation of construction of  the  landfill cap, and at any time as
needed thereafter, during the long-term monitoring  of  the Site.
Should the  monitoring results indicate  that  either ground-water
quality in  the upper  (overburden)  aquifer or  the  lower (bedrock)
aquifer, or surface-water quality in Mathew Creek,  is  not being
restored  to acceptable levels through  natural attenuation  as a
result of reduced leachate generation, the ground-water remediation
component  of  the contingent  remedy, Alternative  SC-6, will  be
implemented.  This would include:

    •  Extraction of contaminated ground water from either of the
       aquifers as necessary.   The extraction system would utilize
       extraction wells  which  would induce  flow  to  the wells
       through drawdown of  the ground-water table.   Operation of
       the  ground-water extraction system would reduce the migra-
       tion of contaminants away from the Site;

       Treatment  of  ground water  by a  treatment  system  located
       permanently  on-Site  that  would  use  physical/chemical
       processes such as pH adjustment, chemical precipitation, and
       carbon adsorption, to remove inorganic  and volatile  organic
       contaminants;  and

       Discharge  of  treated ground water by  returning it to the
       aquifer  via  percolation ponds or injection  wells, or by
       discharging it to a stream, the nearest being Mathew Creek.
       The  discharge  standards would be  established  by  NYSDEC.

The purpose of this response  action  is to reduce the present risk
to human health and  the environment due to contaminants leaching
from the landfill mound.  The  capping of the landfill will minimize
the  infiltration of  rainfall and  snow melt  into  the landfill,
thereby  reducing the  potential for contaminants leaching from  the
landfill  and negatively impacting the wetlands habitat and  ground-
water  quality.   Capping  will  prevent direct  contact exposure to
contaminated  soils,  and as such,  will  result in risks which-  are
less than EPA's  target levels of  10"8 and 1  for carcinogenic  risks
and  the noncarcinogenic HI,  respectively.  The extension of  the
City  of  Johnstown's  municipal water lines  supply to residents
living near the  landfill will ensure that the  residents have  a
potable supply of drinking water.   The goal of pumping and treating
the  ground water,  if  implemented,  would  be to  facilitate  the
natural  attenuation processes in restoring ground water and Mathew
Creek  surface water to applicable  or relevant and appropriate state
and  federal standards.
 STATUTORY DETERMINATIONS

 Under its  legal authorities,  EPA's  primary responsibilities  at
 Superfund sites  are  to undertake  remedial actions  that  achieve
 protection of  human  health  and the environment.    In  addition,
 Section 121 of  CERCLA establishes several other statutory require-

-------
                                28

nfents  and preferences.   These specify  that when  complete,  the
selected remedial action for the Site must comply with applicable
or relevant  and appropriate environmental  standards established
under  federal  and  state environmental  laws unless  a  statutory
waiver  is justified.   The  selected  remedy  also  must be  cost-
effective and utilize permanent solutions and alternative treatment
technologies or resource  recovery technologies  to  the  maximum
extent practicable.   Finally, the statute includes a preference for
remedies that employ treatment that permanently and significantly
reduce the volume,  toxicity, or mobility of hazardous wastes,  as
available. The following sections discuss how the selected remedy
meets  these  statutory requirements.   The contingent remedy will
also meet these requirements.


Protection of Human Health and the Environment

Alternative SC-3 and Alternative SC-6  are fully responsive to this
criterion and  to  the remedial response  objectives.   Capping the
landfill will protect human health  and the environment by reducing
the mobility of contaminated materials, in  that the leaching of
contaminants into the aquifers will be significantly reduced.  In
addition, capping  the landfill will  eliminate threats  posed to
adults,  children, trespassers,  and wildlife  who come in contact
with the  Site.  The extension  of the Johnstown City water supply
system to all  private water supplies  potentially impacted by the
Site,  will ensure that the community  continues to have a potable
supply of drinking water.


Compliance with ARARs

The  multi-layer closure cap  over the landfill  mound will  be
designed  and constructed as per New  York State  6  NYCRR Part 360
regulations.

Attainment of chemical-specific ARARs for ground water and surface
water will be hastened due to reduced  leaching following construc-
tion of the cap.  Should monitoring results  show that ground-water
quality  or  surface-water  quality  in Mathew Creek  is  not being
restored  to  acceptable  levels  through natural attenuation as a
result of reduced  leaching, ground  water will be extracted and
treated  as described in  the contingent alternative.  Action- and
location-specific ARARs  will be complied with during implementa-
tion.

Action-specific ARARs:

     •  New York State Solid Waste Management Facilities 6 NYCRR
       Part  360

       National Emissions standards  for Hazardous Air Pollutants
        (NESHAPs)

     •   6 NYCRR Part 257  Air Quality Standards

-------
                               29

-"  -'•   6 NYCRR Part 212 Air Emission Standards

    •   6 NYCRR Part 373 Fugitive Dusts

       40 CFR 50 Air Quality Standards

       SPDES - Discharge

    •   Resource Conservation and Recovery Act (RCRA)

Chemical-specific ARARs:

    •   SDWA MCLs

       6 NYCRR Parts 700-705 Ground Water and Surface Water Quality
       Regulations

       10 NYCRR Part 5 State Sanitary Code

Location-spec!fie ARARs:

    •   Clean Water Act Section 404, 33 USC 1344

    •   Fish and Wildlife Coordination Act, 16 USC 661

       National Historic Preservation Act, 16 USC 470

    •   New York State  Freshwater Wetlands Law ECL, Article 24, 71
       in Title 23

       New York State  Freshwater Wetlands Permit Requirements and
       Classification,  6 NYCRR 663  and 664

       New York State Endangered and Threatened Species of Fish and
       Wildlife Requirements, 6 NYCRR 182

 other  Criteria, Advisories, or Guidance  To Be considered:

       Executive  Order 11990  (Protection of  Wetlands)

       Executive  Order 11988  (Floodplain Management)

    •  EPA Statement of Policy on Floodplains and Wetlands Assess-
       ments  for  CERCLA Actions

    •   New  York Guidelines for  Soil Erosion and Sediment Control

        New  York State Sediment  Criteria, December 1989

        New  York State Air Cleanup Criteria,  January  1990

    •   SDWA Proposed Maximum Contaminant Levels (PMCLs)  and
        Maximum Contaminant Level Goals  (MCLGs)

     •   NYSDEC Technical  and Operational  Guidance Series  1.1.1,

-------
                                30

       November 1991
Cost-Effectiveness

The  selected  remedy  and  the  contingent  remedy provide  overall
effectiveness proportional to their costs.  The total capital and
present-worth costs  for the selected remedy are estimated  to be
$13,763,000, and  $16,454,000,  respectively.   For  the contingent
remedy, which includes active ground-water remediation, the total
capital and present-worth  costs  are $18,174,000 and $32,580,000,
respectively.


Utilization  of  Permanent  Solutions and  Alternative  Treatment
Technologies to the Maximum Extent Practicable

Given the  size of the landfill  and the absence of isolated hot
spots, containment of the waste mass is the only  practical means to
remediate the  Site.   By constructing a multi-media cap over the
landfill in accordance with New York State's 6 NYCKR Part 360 for
landfill closure,  hazardous wastes in the landfill will be isolated
from the environment and  their mobility will be minimized.   The
closure cap is a  permanent technology that must be maintained at
regular intervals to ensure its structural integrity and imperme-
ability.  The installation of a water line  to supply potable water
to affected residents is  a permanent solution  to meeting their
drinking water needs.  If needed,  ground water will be collected
via ground-water extraction wells, and treated using a ground-water
treatment  system located  permanently at  the  Site.    Thus,  the
selected remedy and contingent remedy which require the construc-
tion  of the  Part 360  cap,  installation  of a water  to supply
residents  with  municipal  water,   and  if needed,  ground-water
collection and treatment,  utilize permanent solutions  and alterna-
tive treatment technologies to the maximum extent practicable.  The
selected  remedy  and the  contingent remedy  represent  the best
balance of  trade-offs among the  alternatives with respect to the
evaluation criteria.

Ground-water  and surface-water  monitoring will be performed to
demonstrate that the  selected remedy meets all remedial action
objectives.  If the monitoring results indicate that  the  selected
remedy is not effective in meeting remedial action objectives, then
the  contingent remedy will be implemented.  The  extraction and
subsequent  treatment of   ground   water,  if   implemented,  will
permanently and  significantly reduce the toxicity, mobility, and
volume of contaminants in  the ground water.

The  selected  remedy  will  require construction  of  a landfill  cap.
No technological  problems  should arise since the technologies and
materials  needed for capping the landfill are  readily  available.
With the construction of the landfill cap, the direct contact risk
to the  landfill  surface will  be  eliminated.

-------
                               31

Preference for Treatment as a Principal Element

The statutory preference for remedies  that  employ  treatment as a
principal element  cannot be satisfied for the  landfill  itself,
since treatment of the landfill material is not practicable.  The
size of the landfill and the fact that  there are no identified on-
Site hot spots that  represent  the  major sources of contamination
preclude a  remedy in which contaminants could be  excavated and
treated effectively.  However,  the  contingent remedy calls for the
treatment of  contaminated  ground  water at the Site  and,  hence,
would satisfy the preference for treatment  for this portion of the
remedy, if needed.


DOCUMENTATION OF SIGNIFICANT CHANGES

There  are  no  significant changes  from the preferred alternative
presented in the Proposed Plan.

-------
APPENDIX I




  FIGURES

-------
                 JOHNSTOWN LANDFILL
      JOHNSTOWN LANDF1LL
     JOHNSTOWN, NEW YORK
Thermo  Consulting Engineers
   (formerly Nbrmandeou Engineers)
                   FIGURE 1 -•-••
GENERAL LOCATION  MAP SHOWING SURFACE WATER  FEATURES
  LaGRANGE SPRINGS, HULBERTS POND. MATHEW CREEK,
          HALL CREEK AND CAYADUTTA CREEK.
                  NOVEMBER  1991

-------
0	  250	MO


   APPROXIUATE SCAl£ H FEET
LEGEND


 PROPERTY BOUNDARY

 UONfTORWC WELL LOCATION


 CRAVD. ACCESS ROAD


 FENCE


 TREELJNE

 APPROXIMATE BOUNDARY OF
 CONSTRUCTION DEBRIS DISPOSAL


 APPROXIMATE BOUNDARY OF
 WASTE DISPOSAL
                                                                                                                  LaGRANGE
                                                                                                                  GRAVEL PIT
                                                                                                                                      JOHNSTOWN LANDFILL  '•
                                                                                                                                     JOHNSTOWN. NEW YORK
                                                                                                                                         RGURE 2
                                                                                                                                      Site  Plan
                                                                                                                                        NOVEMBER 1991
                                                                                                                               I Thermo Consulting Engineers
                                                                                                                                   (formerly  Normandaou Englnoero)
                                                                                                                                               (-
                                                                                                                                   LoGRANGE
                                                                                                                                    SPRINGS

-------
APPROXIMATE SCALE T -  1000'
                                                                                                                                             JOHNSTOWN LANDFILL
                                                                                                                                             JOHNSTOWN. NEW YORK
                                                                                                                                                FIGURE 3
                                                                                                                                     APPROXIMATE LOCATIONS OF RESIDENCES
                                                                                                                                  CANVASSED DURING DOMESTIC WEU INVENTORY.

                                                                                                                                               NOVEMBER 1991
I Thermo  Consulting Engineers
    (formerly Normandoau Engine era)

-------
                                                                                                                                   JOHNSTOWN LANDFILL  .
                                                                                                                                  JOHNSTOWN. NEW YORK
                                                                                                                                      FIGURE 4         I

                                                                                                                        GROONOWATER  MONITORING WELL LOCATIONS

                                                                                                                                    NOVEMBER  1991
                                                                                                                             Thermo  Consulting  Engineers
                                                                                                                               (formerly Normandoau  Engineers)
APPROXIUTE SCALE M FEET
                                                   0 MW-JS
                                                      SA
                                                      A
PROPtRlY BOUNDARY


MONITORINC  WELL LOCATION '


CR*Va ACCESS ROAO


FENCE


TREEUNE


SEDIMENT SAUPUNC
LOCATIONS ON LoGKANCC PIT
                                                                                                                                LaGRANGE
                                                                                                                                 SPRINGS
                                                                                                                 mw-ns
                                                                                                                 > IW-IID

-------
                                                   LoGRANGE
                                                  GRAVEL P/T
JOHNSTOWN LANDFILL
                                       LAGRANGE SPRINGS
                                                  INSET - SEE
                                                 FIGURE 2-208
                                                   •HULBERT
                                             STA J3 \ POND
                                             UPSTREAM
      REPRESENTS APPROXIMATE LOCAT70N
      OF SAMPUNG STATION
                                                                                 CAXADUTTA
                                                                                  CREEK
OC34.220A
PLOT DATE 9/10/92
                                      NOT TO SCALE
            JOHNSTOWN LANDFILL
            JOHNSTOWN. NEW YORK
      Thermo  Consulting Engineers
         (formerly Normandeou Engineers)
                                       FIGURE  5a

                          APPROXIMATE LOCATIONS OF SAMPLING STATIONS
                           ON  LoGRANGE SPRINGS AND  MATHEW CREEK

                                       NOVEMBER  1991

-------
      SCALE: 1  Inch - 200 
-------
z

o
920
900 •
       OUTWASH-ICE CONTACT DEPOSITS

          STRATIFIED SAND. FINE SAND
          AND SILT

*.' .'.°|    SAND AND GRAVEL

       LODGEMENT TILL

          SILT. SAND AND GRAVEL

       BEDROCK

          CANAJOHARIE SHALE
                                                                                                                                                         UW-8
860 •   :
840 •
820 •
800 -
780 -
                                                                                          	:- —_       MW-2     X"  •  •
                                                                                •  •   '   '      .  .~~-~-. S.M.D .,-».  •
                                                                                        .  CAkin       .   ^^ ~~~	i —• ~^
          . .  	              TILL-
       •\i^*"^   '    »'    SILT. SAND
       	4   "'       .   AND GRAVEL.
                                                                                                                    BEDROCK-CANAJOHARIE SHALE—.
                                                                                                                                                                         NO TOPOGRAPHIC
                                                                                                                                                                         DATA AVAILABLE
                                                                                                                                                                   SOIL/BEDROCK BORING
                                                                                                                                                                   AND MONITORING WELL
                                                                                                                                                                   IDENTIFICATION WITH SLOTTED
                                                                                                                                                                   SCREEN SECTION SHOWN
                                                                                                                                                                   GROUNDWATER TABLE
                                                                                                                                                                   aEVATION RECORDED
                                                                                                                                                                   APRIL 1. 1991
                                                                                                                                                               A"
                                                                                                                                                               MW-15
                                                                                                                                                                S.D
                                                                                                                                                                       WEATHERED BEDROCK
                 200
                                          600
                                                      800
                                                                  1000
                                                                               1200
                                                                                           14OO
                                                                                                       1600
                                                                                                                    1800
                                                                                                                                2000
                                                                                                                                            2200
                                                                                                                                                         2400
                                                                                                                                                                     2600
                                                         HORIZONTAL  DISTANCE IN  FEET
                                                                                                                                                          JOHNSTOWN LANDFILL
                                                                                                                                                         JOHNSTOWN. NEW YORK
                                                                                                                                                             FIGURE   6 '
                                                                                                                                            GEOLOGIC  CROSS SECTION OF  SURFICIAL DEPOSITS
                                                                                                                                                AND BEDROCK ALONG TRANSECT A' - A"
                                                                                                                                               LOCATED EAST OF THE JOHNSTOWN LANDFILL

                                                                                                                                                           FEBRUARY  1992
                                                                                                                                                  I Thermo Consulting Engineers
                                                                                                                                                      (form*rly  Normandeau Engineers)

-------
  STTE LOCATION
          KEY
or.oiuvn.HT
0 • DISTURBED
II
H'B HARDWOOD FOREST
    	 FOREST
• • SOP IWUOO FOREST
                               MOTE «EiumE»rannuiioFTWKMr«an
A*. ABANDONED HELD
SI.SHRU8UNO
WSL . •Cm»««U« SWAMP
WFH • FORESTED HARDWOOD SWAMP
                                  NMK RttoooHmnc* tarel never bouatata m
                                     ooi {omul wetbod bonadify defiaeul
                               JOHNSTOWN LANOFIU.
                              JOHNSTOim. NEW YORK
                                  RCURE- 7. -
               WEUANDS IN THE VICtNITY OF  MATHEW CREEK. JOHNSTOWN.
                NY. BASED ON AERIAL PHOTOGRAPHS (5-12-88). DRAFT
                SOILS MAP (FULTON COUNTY SCS. 1992). THE NYS DEC
                      WETLANDS MAP. AND  HELD VERIFICATION.
                         Thermo Consulting Engineers
                            (fomwfy NormondMu Cngbww*)

-------
APPENDIX II




   TABLES

-------
                             Tables
Table la -
Table Ib -
Table 2a -
Table 2b -
Table 3a -
Table 3b -
Table 4  -
Table 5  -
Table 6  -
Table 7  -
Table 8  -
Table 9  -
Table 10 -
Table 11 -
Summary of Inorganic Ground Water and Surface Water Data
Summary of Inorganic Soil Boring and Sediment Data
Summary of TCL VOC  Ground Water and Surface Water Data
Summary of TCL VOC  Soil  Boring and Sediment Data
Summary of TCL SVOC Ground Water and Surface Water Data
Summary of TCL SVOC Soil Boring and Sediment Data
Summary of 3-Hour Air  Quality Data for VOCs
Summary of Airborne Chromium Data
Chemicals of  Potential Concern
Potential Exposure  Pathways
Noncarcinogenic  Toxicity Values
Summary of Noncancer Risks
Carcinogenic  Toxicity  Values
Summary of Cancer Risks

-------
   Table   1A:  Nature and Source of Contaminants Profile
                Metals and Miscellaneous Inorganics
                Groundwater and Surface Water
                Johnstown Landfill, Johnstown, New York

Parameter
METALS (w/L)
Aluminum
Antimony
ArMnlc
Barium
Beryllium
Cadmium
Calcium
ChromlumfT)
Cohan
Copper
Iron
Lead
MagneeJum
Mangan***
Mercury
Nick*)
PoUadum
Solonlum
Sflvw
Sodium
Thallium
Vanadium
ZIno
Cyanlda
Htxchrom*
Sulfat*
Cfuorld*
COO
IDS
Bicarbonate
Carbonate
TOO
Hardnaa*
Ammonla-N
GROUND WATER
UPQRADIENT WELLS
FREQ

27/27
2/27
an?
26/87
7/27
18/27
27/27
26/27
13/27
IS/27
87/27
2607
27/27
27/27
2/27
18/27
27/27
0/27
0/27
27/27
0/27
21/27
27/27
0/27
2/27
ill
20/27
28/27
14/27
27/27
27/27
0/11
11/11
11/11
10/11
LOW
^s8§i!ip
87
16.*
1.1
1M
0.23
1.3
42.700
3.8
2.4
3.8
851
1.0
6.210
24
0.20
e.e
701


1.880

3.7
10.8

30
siaEaSisgaB
7.41
8.30
11.2
101
84.4

1.4
(1.0
0.08
HIGH
SSBiUP
43.200
28.3
18.0
426
3.3
63.0
788.000
187
68
268
124.000
6S.3
88,600
4.830
0.40
247
13.100


88.800

163
788

30
103
112
668
834
622

105
650
158
MW

63
140
68
130
130
70
13O
19O
63
130
68
65
63
68
6S
130
68


60

ISO
130

6S.M
6M
8O
130
68
6S

TO
68
6M
QROUND WATER
LANDFILL WELLS
FHEO
Karate
PSS
3/3
0/3
3/3
3/3
3/1
3/3
30
3/3
3/3
3/3
3/3
3/3
3/3
3/3
3/3
3/3
3/3
0/3
0/3
3/3
1/3
2O
3/3
1/3
on
nn
3/3
3/3
3/3
3/3
3/3
on
3/1
3/3
3/3
LOW
13,300

11.9
17.7
2.4
2.6
327.000
14S
20.6
104
46.800
S4.0
36.800
1.360
0.21
61.7
7.100


13.300

,48.8
216


11.6
26.3
10.3
286
411

16.1
261
33.6
HIGH
66.600

36.7
1.0*0
6.0
77.6
1.430.000
2.330
81.2
250
130.000
487
82.800
2.670
10.6
446
206.000


423.000
1.8
131
2.730
73

13J!
688
852
2.100
2,880

176
700
472
MW
16

16
16
16
16
16
16
16
16
16
16
16
16
16
16
16


16
16
18
16
16

18
16
1*
16
16

16
16
16
GROUND WATER
DOWNGRADIENT WELLS
FHEO

61/61
0/61
44/61
61/61
61/61
22/61
61/61
46/51
20/61
38/61
61/61
48/51
61/61
61/81
Ml
48/51
60/61
0/61
0/61
61/51
2/51
SVS1
50/51
1(91
Ml
36/61
46/51
28/61
61/61
61/61
0/23
22/23
23/23
23/23
LOW
imP^S
83.8

0.6
41.6
0.37
1.1
36.300
2.6
2.2
6.8
68.0
1.0
4.860
7.8
0.26
7.8
1.070


1.780
1.0
4
3.6

20
Bslgj8gejjj88i
11.8
3.17
10.3
134
74.4

0.64
108
0.08
HIGH

104.000

48.6
684
8.2
11.4
1.610.000
228
121
286
202.000
464
80.400
67.300
0.48
332
18.600


166.0OO
27
270
470
10.2
40
61.3
216
672
1.330
780

68.7
448
64.5
MW

118

38
. 168
118
30
38
168
18
38
38
28
28
18
18
38
38


18
18
168
18.38
10
18
30
38
10B
38
38

160
48
15S.9D
GROUND WATER
RESIDENTIAL WELLS
FREQ

34/62
6/52
11/52
41/62
4/52
0/52
61/52
1/62
0/62
22/52
43/62
18/62
61/62
40/52
0/52
6/62
43/62
10/62
1/62
62/52
C/62
2/62
38/62
2/64
0/82
46/62
34/52
6/62
62/52
62/62
12/35

17/17
8/8
LOW
&£&K%H£&&1
BSBwfssSyiBS
16.0
13.6
0.30
2.1
0.21

67.6


3.1
63.0
0.4
33.8
0.72

5.8
618
0.6

2,200
0.7
6.6
4.2
16.0

10.3
3.1
12.7
82.0
67.6
0.02

74
0.010
HIGH
sMiHiHI
1.410
21.4
1.6
666
0.46

121,000
3.4

30.6
6,840
6.6
26.100
7.880

13.6
13.600
1.4
2.6
258,000
1.6
73
780
28.2

67.0
164
36.7
1.160
680
2.4

328
6.5
RESIDENT
iMK^H
Gunnlnn
PalmatMr
LaQrange
QunnlMn
Hulbert

Pln*Tr**
Blank*

Gunnlaon
Gunnlaon
Pint Tree
LaGrattg*
Gunnlaon

Pin* Tr**
Blanket
Fomater
WlnMrmuu
Hannon
Sehwppel
Wheeler
Pin* Tr**
Wagar

Wagar
Pln*Tr**
Hulbert
Whetltr
Pin* Tr«*
LaQrange

Pin* Tr»*
Pin* Trw
SURFACE WATER
MATHEW CREEK
FREQ
s§»!S
11/12
1/12
0/12
12/12
0/12
0/12
12/12
4/12
1/12
0/12
12/12
1/12
12/12
12/12
0/12
3/12
12/12
2/12
0/12
12/12
0/12
0/12
3/12
2/12
0/12
ijPPl
10/12
12/12
6/12
12/12
12/12
0/4
4/4
4/4
4/4
LOW
ilililllP
34.8


27


48.800
3.7


63.7

6.480
28.3

0.2
2.860
1.2

14,700


3.8
34.8

11.1
22.2
10.4
202
140

4.70
188
2.72
NIGH
impum
383
13.0

72.6


111.000
13
3.7

4,840
6.6
16.000
667

12
6.420
1.4

70,000


20.4
41.0

^S^te
68.0
88.8
41
483
400

11.2
278
33.5
8TAT»

MR
«1

l\


l\
M
ft

14
14
K
ft

14
m
«R

K


14
n

fsplPis
•i
n
n
i\
*t

»3
l\
i\
SURFACE WATER
UGRANGEPIT
FREQ
^PiiifiS*
2/2
1/2
1/2
2/2
M
0/2
2/2
2/2
0/2
0/2
2/2
1/2
2/2
2/2
0/2
1/2
2/2
0/2
0/2
2/2
0/2
2/2
2/2
0/2
0/2
R£p
2/2
2/2
2/2
2/2
2/2
0/1
1/1
1/1
1/t
LOW
Annuls
182


22.8


64.000
34


1.410

6,070
03.0


0.700


33.000

5.0
16.8


^SS^:
18.0
40.3
26.2
322
245




HIGH

357
17
1.6
32.4


88,200
40.6


6.330
2.2
11.100
044

12.6
23,000


07.300

8
283


^KMSis
20.2
136
210
738
315

8.15
187
11.2
Nola*:
FREQ - Fr»qu«noy of analyt* d*t*ct*d abov* aampl* d«t*ctlon limit*
LOW • Lowatt concentration detected In each aampllng calagory
HIGH - Hlghert concentration delected In each aampllng oatagory
MW.RESIDENCE.STATf • Sample location where highest concentration of analyt* wat detected
UPGRADIENT WELLS:
OOWNGRADIENT WELLS:
LANDFILL WELLS:
CLUSTER MW* 6.6.7.13,14
CLUSTER MWt 1,2,3.4.8.9.10.11.12.16
MW* 16,18,10

-------
    Table   1B:  Nature and Source of Contaminants Profile
                  Metals and Miscellaneous Inorganics
                  Soil Boring and Sediment Samples
                  Johnstown Landfill, Johnstown, New York

Parameter
METALS(mg/Kg)
Aluminum
Antimony
Arsenic
Barium
Beryllium
Cadmium
Calcium
ChrofnlumfT)
Cobalt
Copper
Iron
LMd
Magnesium
Manganese
M«roury
Nickel
Potassium
Selenium
Silver
Sodium
Ttiallium
Vanadium
Zinc
Cyanide
Hexchroma
INORQ. (ma/Kg)
Sullate
COO
TOC
Ammonla-N
SOIL SAMPLES
UPQRADIENT BORINGS
FflEQ
»VH1
2/2
0/2
in
2/2
2/2
0/2
2/2
2/2
2/2
2/2
2/2
2/2
2/2
2/2
0/2
2/2
2/2
0/2
0/2
2/2
1/2
2/2
a/2
NT
0/2
;SQ
NT
NT
NT
NT
LOW
^S'O^
3.860

07
14.4
0.3»

12.100
6.9
10
4.5
4.UO
1.7
3,100
10«

4.4
1,080


340

7.1
12.5


;^titn-|




HIGH
"*-\?m
6.710

1.4
21.3
0.53

63,400
11.«
3.0
10.1
B.710
3.S
6.780
188

10.9
1.<10


365
0.21
17.3
18.9


*$.< f ,,%




MW

140

140
140
140

130
140
14O
140
140
14O
140
140

14O
140


14O
14O
140
14O







SOIL SAMPLES
LANDFILL BORINGS
FREQ

3/3
1/3
3/3
an
313
on
3/3
3/3
3/3
3/3
3/3
3/3
3/3
3/3
0/3
3/3
3/3
0/3
0/3
3/3
0/3
a/3
3/3
0/3
0/3
«i
1/3
3/3
NT
NT
LOW

4.000

0.43
19.0
0.23

11,000
0.3
2.2
6.0
6.200
2.e
1,600
120

4.6
804


343

10.3
13.6


jumps?

5.420


HIGH
nnnis
«.480
4.2
1.1
23.9
0.30

72.000
30.0
3.0
7.1
9,2M
7.8
e.oeo
168

7.1
1.030


607

15.1
32.0



250
80.800


MW
Wl
16
17
16
10
17

IS
10
10
17
IB
16
17
17

16
18


17

10
10


f*t
17
17


SOIL SAMPLES
DOWNGRADIENT BORINGS
FREO
fe$
4/4
0/4
4/4
4/4
4/4
0/4
4/4
4/4
4/4
4/4
4/4
4/4
4/4
4/4
0/4
4/4
4/4
0/4
0/4
4/4
2/4
4/4
4/4
NT
0/4
lsf&
0/4
4/4


LOW
$$t%&
3.050

0.6
11.3
0.31

1.230
6.2
1.6
4.3
4.690
1.7
704
78.6

4.0
303


239
0.23
6.6
11.3


vKj$&?

2,810


HIGH

11.200

1.0
21.0
0.43

39.200
11.6
4.0
9.1
11.100
3.6
2.060
224

6.6
786


365
0.26
16.2
22.3




11,000


MW

110

120
90
90

too
110
110
100
00
120
100
120

90
110


100
too
110
90


tfftf*

120



FREO

16/10
0/16
16/16
16/16
13/16
3/16
16/16
16/16
14/16
15/16
16/16
16/16
16/16
16/10
0/16
14/16
16/16
6/16
0/16
16/16
1/16
16/16
16/16
3/16
2/16
P*
12/16
16/16
NT
NT
SEDIMENT-ROUNDS 1 & 2
MATHEW CREEK
LOW
»»
1,940

0.58
12
0.06
0.93
1.740
1.9
2.6
1.4
6.100
2.7
602
41.6

1.6
279
0.43

105

7.1
13.1
1.1
0.06

81.8
8.360


HIGH

16.100

12.2
316
0.83
3.7
66.300
33.8
39.3
43.2
121.000
17.8
3.910 •
4.220

60.6
1.790
1.8

666
0.3
45.7
95.7
1.4
0.66
x^jtie
677
347.000


STATION
ssiis
»1,0-6'

11,6-12'
*1,0-6'
I3INLET
»1.0-6'
»1.0-6'
11.0-9-
»1.0-6'
MINUET
f 1.0-6'
1 1.0-6'
f1.0-«'
11.6-12'

f 1.0-6'
ti.o-e'
11.9-12'

fl.0-6'
• 1.6-12'
»1.0-6'
fl.0-6'
f2,0-«'
fl.0-6'

12.6-12'
#1.0-9'


SEDIMENT-ROUNDS
MATHEW CREEK
FREO

16/16
0/16
16/16
16/16
6/16
16/16
16/16
16/16
16/16
16/16
16/16
16/16
16/16
16/16
6/16
16/16
16/16
1/16
2/16
16/16
0/16
16/16
16/16
1/16
1/16
$**%?
0/16
19/16
11/19
16/16
LOW
/S!§»
1,680

0.76
19.3
0.17
0.60
3,020
2.6
1.7
0.61
6.290
2.6
638
79.4
0.10
3.0
160

0.86
63.4

4.9
12


5pyj?pH
.!!..%eo.ooo
987
STATION
••r
-------
          Table   2A:  Nature and Source ol Contaminants Profile
                        TCL Volatile Organic Compounds
                        Groundwater and Surface Water
                        Johnstown Landfill, Johnstown, New York

Parameter
VOC'e (,/g/L)
Acetone
Methylene Chloride
Tilchloroethytene
1.1.1 Trichloroethane
Chloroform
Vinyl Chloride
Xylene
Benzene
Elhylbenzene
Chlorobenzene
2-fiuttnone
4-Mathyt-2-Pentanonc
Vinyl Acetite
1,1-Olchloroethui»
Styrene
C«rtx>n DltulNde
Toluene
'etrachloroethytene
1.1-DichloroMhylen*
1.2-Olchloroethytene
GROUND WATER
UPQRADIENT WELLS
FREO

12/27(8)
8/27g?3
120
8





2


250
40




18



Nolet:
FREO - Frequency of analyte detected above (ample detection llmltt
LOW -  Lowert concentration detected In each umpllng calegoiy
HIGH • Highest concentration detected In each tampllng category
MW.RESIDENCE.STAT* - Sample location where highest concentration ol analyte wa> detected
(B) - Flag Indicate! analyte wai detected In method blanka (or one or more ol the eamplei
UPQRADIENT WELLS:
DOWNQRADIENT WELLS:
LANDFILL WELLS:
CLUSTER MWa 5.6.7.13.14
CLUSTER MWa 1.2.3.4.8.9.10.11.12.15
MWa 18.18.19

-------
        Table '  2B: Nature and Source ol Contaminants Profile
                     TCL Volatile Organic Compounds
                     Soil and Sediment Samples
                     Johnstown Landfill. Johnstown, New York

Parameter
VOC'e (j/g/Kg)
Acetone
Melhylene Chloride
Trichloroethylene
I.I.ITrichloroettane
Chloroform
Vinyl Chloride
Xylene
Benzene
Elhylbenzene
Chlorobenzene
2-Butanone
4-Methyl-2-Pentanone
Vinyl Acetate
1.1-OIchl»oelhane
Styrene
Cuban DJeulfide
Toluene
Tetrachloroethylena
1 , 1 -Olchloroethyfene
1 ,2-Olchloroelhylene
SOIL BORINGS
UPaRAOIENT WELLS
FREQ

6/5(8)
3/5(B)
0/5
0/5
3/5
0/5
0/5
0/6
0/5
0/5
3IS(B)
0/5
0/5
0/5
0/5
0/5
3/S(B)
1/5
•0/5
0/5
LOW

6
2


1





2





0.6



HIQH
HUmi
180
e


i





4





2
3


MW
mHI
78
130


«.6.7





5O





140
78


GOILBORINQS
LANDFILL WELLS
FREQ
l#tt
a«(B)
3/3(B)
0/3
0/3
0/3
0/3
2/3
1/3
2/3
0/3
2/3(8)
1«(B)
0/3
0/3
0/3
0/3
2/3
on
0/3
0/3
LOW

13
4




to

3

7





10



HIQH

440
7




16
13
6

360
14




61



MW
*ff
16
ie




16
10
17

te
it




16



SOILBORINQS
OOWNQRADIENT WELLS
FREQ

0/9(B)
7/9(8)
2/»
2/8
1/0
019
2/9
lit
2/9
0/9
3fl(B)
W9
0/0
M
0/»
0/»
6«
6/B
2«
0/9
LOW

7
2
7
4


3

1

2





0.6
0.7


HIGH
mum
75
6
0
6
1

0
o.e
2

3





2
2
0.0

MW
M
10
20
12O
100
ID

120
12O
120

120





3D
10.30
30.1 1O

SEDIMENT
MATHEW CREEK
ROUNDS 1&2
FREQ

16/16(8)
18/16(8)
0/16
0/16
4/16(8)
0/16
0/16
1/16
0/16
0/16
*/16
0/16
0/16
0/18
0/16
i/te
3/16
0/16
0/16
0/16
LOW

14
2


o.s





6





2



HIGH

3*0
28


2


3


100




3t
3



STATION

ll.O-«'
f 1.0-6'


»1.6-12'


f2.0-6'


*3 INLET




13 INLET
f1S3IN.



SEDIMENT
MATHEW CREEK
ROUNDS
FREQ

16/16(8)
15/16(8)
1/16
0/16
0/16
0/16
0/16
0/16
o/ie
0/16
11/16(8)
0/16
0/16
0/16
0/16
1/16
2/16
0/16
0/16
0/16
.LOW

16
6








2





4



HIGH .

130
23
18







32





6



STATION

MINLET
I3INLET
SO(B).0-12-







I3INLET





14.0-6'



SEDIMENT
UQRANGE PIT
ROUNDS 2 ft 3
FREO

6/8(8)
6/6(8)
0/6
0/6
0/B
o/e
0/6
0/6
0/6
on
3/6(8)
i/a
0/6
0/6
0/0
on
2/6
0/6
0/6
0/6
LOW

16
4








3





3



HIGH
mill
90
*





2


96
16




23



Not«:
FHEQ • Frequency of «n«lyt» d«l«cttd ibov* umpl« dglKtlon llmlll
LOW - Lowatt oonctnlntlon detected In each eampllng category
HIGH - HlgheM concentr
-------
            Table   3A:  Nature and Source pi Contaminants Profile
                         TCL Semi-Volatile Organlcs and Pesticides
                         Groundwater and Surface Water
                         Johnstown Landfill, Johnstown, New York

Parameter
SVOC'a ((/9/L)
Phenol
Benzyl alcohol
1.2-Oichlorobenzene
4-Melhylphenol
Benzole acid
Naphthalene
2-Methylnaphthalene
DimethylphlhalaU
Olethylphthalate
N-Nitro*od!phenylanilne(1)
Phenanlhren*
Anthracene
Di-n-butylphthalite
Fluor anthene
Pyrene
Butylbenzylphtiialate
3.3'-Olchlorobenzbfine
Benzo(a)anlhracene
Chryeena
btt(2-EUiylhe
0/1 9
0/19
0/18
0/19
0/19
1/19
0/19
1/1*
6/19(B)
0/19
0/1*
0/19
8/19(8)
0/19
0/19
2/19
0/19
0/19
0/19
18/19(B)
4/19
0/19
O/19
0/19
0/19
T('!-?!-X!?S;<
0/19
0/19
0/19
0/19
0/19
0/19
0/19
0/19
0/19
0/19
0/19
0/19
0/19
LOW
•*-








0.4



0.4






0.7





£&£&&













HIGH
»= /^








1



0.7






18





'-:,s>",.













STATt
^-«-a








'1.3



f4






fl





' •"->'>«•••













SURFACE WATER
UGRANGE PIT
FREO
S,%>«:













HIGH
<&:$tpr
41
4

10
190



21



2


0.2



9
0.2




\>; ,













Notei:
FREQ - Frequtncy of analyte delected above iample detection llmltl
LOW -  Lowell concentration detected In each sampling categonr
HIGH • Highest concentration detected In each aampllng category
MW.HESIOENCE.STAT* - Sample location where highest concentration of analyte was detected
(B) • Flag indicate* analyte wae detected in method blankt (or one or more of the aamplea
UPGRADIENT WELLS:
DOWNGRAOIENT WELLS:
LANDFILL WELLS:
CLUSTER MWe 5.8.7.13.14
CLUSTER MWa 1.2,3.4.8.9.10.11.12.15
MWe 18.18.19

-------
               Table   3B: Nature and Source ol Contaminants Prolila
                            TCL Seml-Volallle Organlcs and Pesticides
                            Soil and Sediment Samples
                            Johnstown Landllll, Johnstown, New York

Parameter
SVOC'a (/ig/Kg)
Acenaphtnene
Olbenzofuran
Fluorene
Acenaphthylene
Benzole acid
Naphthalene
2-*tethylnaprithalene
Dlmelhytphlhalale
Dlethyfphlhalate
N-Nitroaodiphenylamlne(1)
Phenanthrene
Anthracene
Dl-n-butylphthalate
Fluorantfiene
Pyrerw
Butyl benzyiphthalate
S.S'-Oichlorobenzldlne
Benzo(a)anthracene
Chrywne
bls(2-Ettiylhexyl)phlhalaIe
Dl-n-octytphthaJale
Benzoflijfluorantnene
Benzo0c)fluoranthene
Benzo(«)pyrene
lndeno(1 ,2.3-cd)pyrene
Benzo(g,h.l)perylene
IMO nor one
PESTICIDES <«/Kfl)
gamma-BHC
della-BHC
Endoeulfan 1
Dieldrin
4.4'-ODE
4.4--ODD
4.4--ODT
alpha-Chlordane
gamma-Chlordane
toptachlor
Aldrin
Heptachlor Epoxkle
Endrln
SOIL BORINGS
LANDFIU WELLS
FREQ
§i>w*SS$t^ll*
0/3
0/3
0/3
0/3
2/3
1/3
0/3
0/3
1/3
0/3
0/3
0/3
1/3
0/3
0/3
1/3
0/3
0/3
0/3
3/3(8)
1/3
00
0/3
0/3
0/3
0/3
0/3
t*&W&'*'«
1/3
1/3
1/3
1/3
2/3
1/3
2/3
0/3
0/3
1/3
1/3
1/3
1/3
LOW





120














400







-?¥

13


•.8








STAT





•1.0-8



•4.8-12

•1.0-8

•4.8-12
• 1.0-8
•1,0-«


•1.0-8
•1.0-8
•4,6-12
•4.8-12
•1,0-6

•4.6-12
•4.6-12
•

sSsf^>^*

•3.IN


•1.0-4








SEDIMENT SAMPLES
MATHEW CREEK
ROUND 2
FREO

0/3
0/3
on
1/8
7/8
1/8
1/8
1/8
C/8(B)
0/3
4/8
3/B
1/8(8)
1/8
6/8(8)
3/8(8)
0/8
4/8
4/8
1/8(8)
8/8
3/8
2/8
3/8
0/8
1/8
2/8
«»!"»»
0/8
0/8
on
0/1
4/8
0/8
on
on
on
on
on
on
0/8
LOW
s?8l^i^il^s




28



19

37
20
23
IS
10
•

22
• 22
M
12
41
66
48


7
f,4tfe&-«js.l£




2.5








HIQH
^mts&s&'&'fs ,



12
480
16
a
18
68

220
61
M
260
210
36

B3
110
140
180
76
60
70

4
•





12








STAT
VM!^ti-;/'!



•4.6-12
•1.8-12
•4,6-12
•4.6-12
•3.OUT
•1.0-6

•4.6-12
•4,6-12
•1,0-6
•4.0-12
•4.0-12
•3.IN

•4.6-12
•4,0-12
•3,IN
•3,IN
•4.0-0
•3.OUT
•4.0-12

•4,6-12
•3.OUT
«BJ.«i<-"




• 1.0-0








SEDIMENT SAMPLES
UGRANGE PIT
ROUNDS 1&2
FREO
* >* '", -\ ^'i ^
1/2
1/2
2/2
2/2
on
2/2
2/2
0/2
2/2(8)
on
2/2
2/2
1/2(8)
2/2
2/2
OK
0/2
2/2
2/2
2H(B)
2/2(8)
2/2
1/2
1/2
0/2
0/2
0/2
*J<' ?'-,V>-vV
0/2
0/2
0/2
0/2
2/2
2/2
0/2
0/2
0/2
1/2
1/2
0/2
0/2
LOW
•iJ-'^^IPPPi


IS
It

170
40

62

66
16

09
71


46
45
430
45
43





'•if ;'"» "




38
13







HIGH
slWPS£WS
44
48
•1
42

1.400
320

71

170
61
41
160
ISO


84
M
850
270
240
160
43



! ,»<»~>»4y




170
69



3.7
1.8


Notei:
FREQ - Frequency of analyte detected above «ample detection limit*
LOW • Lowett concentration detected In each sampling category
HIGH - Highest concentration detected In each tempting category
MW.STAT* • Sample location where highect concentration ol anaJyte wat detected
UPQRAOIENT BORING :                  MWl 6.6.7.13,14
DOWNQRADIENT BORING :               MW. 1,2.3.4.8.9.10.11.12
LANDFILL BORINQ:                     MWt 18.17.18
(B) - Flag Indicates analyte wai detected In method blanks tor one or more of the samples

-------
          Table  ,4 :  Summary Results of 3-Hour Air Quality Sampling For VOCs
                     Johnstown Landfill, Johnstown, New York, September, 1989.

Date Sampled
Sample Number
Pump Flow Rate (L/mln)
Parameter
Acetone
Benzene
Toluene
2-Butanone
1,1,1 -Trlchloroethane
Carbon Tetrachlorlde
Totals
Station
No. ST-1
9/13
T-2
0.104

3.05
1.84
1.26
NO
1.05
ND
7.20
9/13
T-3
0.251

2.44
1.02
1.00
NO
0.64
ND
6.30
9/21
T-8
0.100

6.11
1.11
NO
ND
ND
ND
7.22
9/21
T-9
0.251
•illT
ND
0.64
0.49
ND
0.69
0.47
2.29
Station
No. ST-2 ,
9/13
T-4
0.100
&P$HH
ND
1.89
1.17
1.61
1.39
ND
6.08
9/13
T-5
0.253
P*J$7
1.00
0.74
0.61
0.63
0.83
ND
3.81
9/21
T-10
0.102

1.22
ND
1.22
ND
1.60
ND
3.94
9/21
T-11
0.253
«^
ND
ND
0.57
ND
0.98
ND
1.67
Station
No. ST-3
9/13
T-6
0.102
I^W
4.44
0.69
0.62
ND
0.69
ND
6.44
9/13
T-7
0.252
*3*5&
20.66
1.44
ND
ND
1.22
ND
23.22
9/21
T-12
0.104
:%&$t
ND
1.63
ND
ND
ND
ND
1.63
9/21
T-13
0.252
^*t J
ND
0.62
0.62
ND
0.62
ND
1.86

Occupat.
Value*
(24-HR)
t
AGO"
(annual)
>y v-^^\£****&:
1.78E6
30.000
375.000
690,000
1.00E6
30,000
35.600(0)
100(a)
7,600(0)
1.967(b)
38.000(c)
100(a)
y >. v"* % s»' * =-^
-{'4\.+' vnV";y\<
s ' ''- ';«w** ., ?
Notes :
All concentration values expressed In micrograms per cubic meter (ug/cu. m)
(a) = High Toxicity Air Contaminants
(b) = Moderate Toxicity Air Contaminants
(c) = Low Toxicity Air Contaminants
* = Short Term 1989 ACGIH TWA-TLV
* * = Long Term Ambient Guideline Concentration - (derived from ACGIH TWA-TLV)
ND = Not Detectable

-------
            Table  5 :  Summary Results of Airborne Chromium Sampling
                       Johnstown Landfill, Johnstown, New York
                       September and October, 1989.
Station
Number
HV-1-P
HV-1-C
HV-2

HV-3

Date
9/14/89
10/1/89
10/6/89
9/14/89
10/1/89
10/6/89
9/14/89
10/1/89
10/6/89
9/14/89
10/1/89
10/6/89
Filter
Number
2872
2881
2885
2873
2882
2886
2875
2883
2887
2874
2884
2889
Total
Chromium
(MJ)
6.0
9.9
6.9
5.9
9.2
6.4
4.6
4.6
5.5
5.3
3.5
6.8
Total
Flow
(cu. m)
1,898.9
1,929.3
1,937.6
1,815.1
1,875.4
1,821.3
1,592.3
1,672.2
1,670.7
1,569.9
1,705.3
1,692.7
Chromium
Concentration
(jjglcu. m)
0.003
0.005
0.004
0.003
0.005
0:004
0.003
0.003
0.003
0.003
0.002
0.004
Average
Chromium
Concentration
Ct/g/cu. m)

0.004

0.004
0.003
0.003
AGC*
fo/g/cu. m)
0.167
0.167
0.167
0.167
Ocbupational
Value**
(/yg/cu. m)
50
50
50
50
Notes:
* = Ambient Guideline Concentration - Annual Average - derived from 1989 ACGIH TWA-TLV
**  a 1989 ACGIH Short Term TWA-TLV

-------
                                                       Table 6 •:
                           Study chemicals, with Abbreviations and common Synonyms
                                      Johnstown Landfill, Johnstown,  NY
Chemical
Metals aad Cyaaido
  aluminum
  antimony
  arsenic
  barium   .
  beryllium
  cadmium
  chromium
  chromium VI
  cobalt
  copper
  lead
  mercury
  nickel
  selenium
  silver
  strontium
  thallium
  titanium
  vanadium
  zinc
  cyanide

 Volatil* Organic Compound*
  methylene  chloride
  chloroform
  carbon tetrachloride
  carbon disulfide
   1,1,1-trichloroethane
  vinyl chloride
   trichloroethylene
   tetrachloroethylene
   acetone
   2'butanone
   4-methyl-2-pentanone
   benzene
   ethylbenzene
   toluene
   xylenes (total)
   styrene
Saai-Volatil* Organic Compound*
  benzole acid
  phenol
  4 -methy Iphenol
  di-n-butylphthalate
  di-n-octylphthalate
  bis(2-ethylhexyl)phthalate   DEHP
  butylbenzylphthalate
  naphthalene

Pesticides and PCBs
  IDDTR
                              Abbreviation   Synonym 1
                                                                     Synonym 2
                              Al
                              sb
                              As
                              Ba
                              Be
                              Cd
                              Cr (III)
                              cr (VI)
                              Co
                              Cu
                              Pb
                              Hg
                              Ni
                              Se
                              Ag
                              Sr
                              Tl
                              Ti
                              V
                              Zn
                               DCM
                               1,1,1-TCA

                               TCE
                               PCE

                               MEK
                               MIBK
chloroethylene

perchloroethylene
                                                                                                CAS
                                                                                             Number
                    7429-90-S
                    7440-36-0
                    7440-38-2
                    7440-39-3
                    7440-41-7
                    7440-43-9
                   18S40-
                    7440-
                    7440-
                    7439-
                    7439-
                    7440-
                    7782-
                    .7440-
                    7440-
                    7440'
                  •  7440
                    7440
                    7440
                       57
dichloromethane
trichloromethane
perchloromethane

methyl chloroform
chloroetbene
trichloroethene
tetrachloroethene
dimethyl ketone        2-propanone
methyl  ethyl  ketone
methyl isobutyl ketone
benzol
phenylethane
methylbenzene
xylene, mixed          xylenes  [total]
vinylbenzene
                                                benzene carboxylic acid
                                                carbolic acid
                                                p-cresol               4-cresol
                                                 di (2-ethylhexyl)phthalate
                                               Total DDT Residue (sum of DDT,-ODD,  DDE)
                                                29-9
                                                48-4
                                                50-8
                                                92-1
                                                •97-6
                                                •02-0
                                                •49-2
                                                •22-4
                                                •24-6
                                                •28-0
                                                -32-6
                                                -62-2
                                                -66-6
                                                 12-5
 75-09-2
 67-66-3
 56-23-5
 75-15-0
 71-55-6
 75-01-4
 79-01-6
127-18-4
                                                                                           108-10-1
                                                                                            71-43-2
                                                                                           100-41-4
                                                                                           108-88-3
                                                                                          1330-20-7
                                                                                           100-42-5
                        65-85-0
                       108-95-2
                       106-44-5
                        84-74-2
                       117-84-0
                       117-81-7
                        85-68-7
                        91-20-3

-------
                                                                                   Table   7
                                                                         Summary of Exposure Scenarios
                                                                       Johnstown Landfill.  Johnstown, NY
                                                Scenario 1:   Nearby Residents
                                                     current Conditions
                                              (Landfill Closed and Unremediated)
 Exposures to Soil froa the Landfill

 Incidental  Ingestion  of  Soil  on Landfill

     Dermal  Contact with  Soil  on Landfill

  Inhalation of Fugitive  Dust  on Landfill

 Bxpocur** to tUtthcw Cr**k

       Incidental Ingestion of  Sediments

            Dermal Contact with  Sediments

    Incidental Ingestion  of surface Water

       Dermal Contact with Surface Water

                       Ingestion of Fish

Bxpo«ur»»/ to Oround  Water

  Use of Ground Water as Household Water

Bxpo«ur*« to Outdoor Air

               Inhalation of Outdoor Air
Scenario 2i  Nearby Residents
     Future Conditions
 (Landfill  Capped and  Fenced,
    with no Ground Water
 Interception and Treatment)
Scenario 3i  Nearby Residents
      Future Conditions
(Landfill Capped and Fenced,
      with Ground Water
 Interception and Treatment)
la Ib
Trespassing Wading/
on the Fishing in
Landfill Matthew Creek

Yes
Yes
Yes
No
No
No
No
No
No
Yes
No
No
No
Yes
Yes
Yes
Yes
Yes

No

Yes I
Ic 2a 2b , 2c 3a 3b 3c
Trespassing Wading/ Trespassing Wading/
Living on the Fishing 'in Living on the Fishing in Living
at Home Landfill Matthew Creek at Home Landllll Matthew Creek at Home
No No
No No
No No
No No
No No
1
No No
No No
No No
Yes | No

Yes | | Yes
No No No
No No No
No No No
Yes
Yes
Yes
Yes
Yes
No
Yes
No No
No No
No No
No No
No No
Yes | . No

Yes | | Yes
No No
No No
No No
Yes
Yes
Yes
Yes
Yea
No
Yes
No
No
No
No
No
Yes |

Yes |

-------
                                                                 Table
                                            Summary of Key Toxicotogical Properties of Study Chemicals
                                                       Johnstown Landffl, Johnstown, UY.
Chemical
                         Species Tested
Reference Dose  Confidence    in Critical
    {RfD)        inRfD       Study
 (mcy(ko«day))	
Metals and Cyanide
  aluminum  .
  antimony
  arsenic
  barium •'•'•-.'   . ••
  berytDum ••-• •             -
  cadmium
  chromium III         .
  chromium VI
  cobalt   :    •  '•
  copper
  lead
  mercury
  nickel
  selenium
  silver
  strontium
  thaffium
  titanium
  vanadum
  zinc
  cyanide

Volatll* Organic Compounds
  methylena chloride
  chloroform
  carbon telrachtorida
  carbon dtsdfide
  1.1,1-trichloroetriane
  vinyl chloride
  trichloroathytene
  tetrachtoroethylene
  acetone
  2-butanqne
  4-methyt-2-pentanone
  benzene
  ethylbenzene
  toluene
  xytenes (total)
  styrene

 Seml-Volatfle Organic Compounds
  benzole acid
  phenol
  4-methyIphenol
  dHVbutylphthalate
  di-n-octylphlhalate
  bis(2-etnylhexyl)phthalate
  butylbenzylphthaJate
  naphthalene

 Pesticides and PCBs
  ZDDTR

  4,4'-DDD
  4.4--DDE
  4,4'-DDT
                                                   Reference     Reference
                                                 Concentration     Dose      Confidence    in Critical
                                                     (RfC)         (RfD)
                                                   .(mcyrrQ)
4E-04
3E-04
7E-02
5E-03
5E-04
1E+00
5E-03
    5E-04
    3E-04
    2E-02
    5E-03
    5E-C3

    7E-05

    7E-03
    2E-01
    2E-02
                                  6E-02
                                  1E-02
                                  7E-04
                                  1E-01
                                  9E-02
                                  1E-02
                                  1E-01
                                   1E-01
                                   2E-01
                                   2E+00
                                   2E-01
tow
med
mad
tow
high
tow
tow
                                               med
                                               high
                                                tow
     6E-01

     1E-01

     2E-02
     2E-01
     4E-03


     5E-04



     5E-04
                                                med
                  med
                  med
                  med
                  med
                  med
                  tow
                   tow
                  med
                  med
                  med
                                                med
                                                tow

                                                tow

                                                med
  rat
human
human
  rat
human
  rat
  rat

human

  rat
  rat
human
human

  rat

  rat
human
  rat
                           rat
                           dog
                           rat
                          rabbit
                        guinea pig
                        mouse; rat
                           rat
                           rat
                           rat
                           rat
                          human
                           rat

                           rat

                        guinea pig
                           rat
                           rat
                                                                                      :5E-04
                                                                                      2E-06
                                                                                      2E-06
                                                                                      3E-04
                                                                                                 • • 1E-04
                                                                                              human
                                                                                              human
                                                                                                    9E-OS
                                       3E+00
                                                         1E-02
                                                         1E400
                                       1E+00
                                       2E400
                                       3E-01
                                                     9E-01
                                                     1E-02
                                                     7E-04
                                                     3E-03
                                                     3E-°1
                                                     1E-02
                                                     1E-01
                                         3E-01
                                                                   rat
                                                                   rat
                                                                guinea pig
                                                       bw
                                                med
                                                             rat
                                                                  9E-°2
                                                                  2E-01
                                                     4E+00
                                                     6E-01

                                                     1E-01

                                                     2E-02
                                                     2E-01
                                                     4E-03
                                                                                                    5E-04
                                                                                                    5E-04
                                                                 rat, rabbit
                                                                 human
                                                                 human

-------
                                                      Table  9
                                         Summary  of  Noncancer Risks
                                          Current Land Use  Scenario
  Chemical
Metal* and Cyanld*
•  aluminum
  antimony
  arsenic
  barium
  beryllium
  cadnuum
  chromium
  chromium VI
  cobalt
  copper
   lead
   mercury
   nickel
   selenium
   silver
   strontium
   thallium
   titanium
   vanadium
   zinc
   cyanide

  Volatile Organic Compound*
   mettiytene chloride
   'chloroform
   carbon tetrachloride
   carbon dtsutfide
  '  1,1,1-tichloroetnane
   vinyl chloride
    tnchloroelriytene ._.•
    tetrachloroethytene
    acetone
    2-butanone
    4-methyl-2-pentanone
    benzene
    ettrylbenzene
    toluene
    xytenes (total)
    styrene

  S«mi-Volattl« Organic Compound*
    benzoicacid
    phenol
    4-methylphenol
    dkvbutyiphlhalate
     di-n-octylphthalate
     bfe(2-ethylhexyl)phthalate
     butylbenzylphthalate
     naphthalene

   PasUcides and PCBs
     2DDTR
Total HI •
as a Child i
Living at Home!
(ratio) |
Total HI as a Youth !
Trespassing Wading / Fishing
(ratio) (ratio)
Total HI a* an Adult
Living at Home [Wading /Fishing Living at Home
(ratio) j (ratio) (ratio)
.1 ' 1
2.4E+00
2.1E-01
1.6E-01
4.3E-03

1.1E-04

1.5E-02
2.2E-01

1.5E-02
1.2E-02
2.3E-02
•
|
|
1
|
|
•
|
}
:
•
:
:
I

32E-M
6.0E-05
1.8E-06
6.2E-05
7.3E-01

1.6E-05
2.8E-03
^OE-05
1.6E-05
25E-06

4.5E-04
2.1E-03
5.1E-02
7.1E-06
23E-04
6.7E-04
1.1E-02
8.6E-01
1.3E-01
6.4E-OS
1JE-05
1.2E+00
. 1.1E-01 *
75E-02
5.3E-05
7.6E-03
1.1E-01
7.3E-03
6.0E-03
|
|
|
{
I
2.7E-04
1JE-03
45E-02
4.3E-C6
15E-04
6.0E-04
2.4E-05
1.0E-02
7.7E-01
12E-01
3.9E-05
8.1E-06
95E-01
8.6E-02
6JE-02
1.7E-03
43E-05
6.1E-03
8.7E-02
55E-03
4.8E-03
9.4&03
2JE+00
                                         1.3E+00
2.8E-02   i   5.1E-05
4.0E-02   1   1SE-05
                           4.4E-02
                          1.4E-02    i
                          2.0E-02    i
                          1.1E-02    !
             1.7E-04
             3.9E-02
             1.6E-05
             1.0E400

             1.1E-02
             1.6E-02
             85E-03

6.8E-01
5.3E-02
33E-03


3.0E-02
6.0E-02
|
:
!
j
i
I

:
15E-07
2.9E-03

15E-05

--

2.6E-04
3.7E-07
1.3E-04
1.7E-07
6.9E-07


9.3E-06
1.3E-05

3.8E-01
2.6E-02
1.9E-03


15E-02
3.3E-02
|
:
I
:
i
j

!
2.6E-07
6.7E-05
1^E-07
3.5E-07


6.1E-06
7.0E-06

15E-01
2.1E-02
9.7E-04


1J2E-02
1.7E-02
1.6E-03
               63E-06
5.0E-05


6.6E-05
             3.8E-07
                            15E-07
                            3.9E-04
                             1.4E-01
8.7E-04
                                                                                             !
2.1E-07
                                                          1.0E-07
                                                          2.7E-04
                                                          12E-01
4JE-04
                                          6.5E+00
               7JE-01
                              1.2E+00
                            3.3E+00   i    1.1E+00
                                                                                                                25E+00

-------
          Table 10
Carcinogenic Toxicity. Values
Weight-of-
Evidence
Classification
Chemical
Metals and Cyanide
aluminum
antimony
arsenic
barium
' -beryllium
• cadmium
chromium 111
chromium VI
cobalt
copper
lead
mercury
rirkal
IKMn
selenium
silver
strontium
thallium
titanium
vanadium
Zinc
cyanide . ..
Volatile Organic Compounds
methylene chloride
chloroform
carbon tetrachtoride
carbon dteuffide
1.1.1-trichloroelhane
vinyl chloride
tnohloroethylene
tetrachJoroethytena
acetone
2-butamne
4-metrryI-2-parrtarcre
benzene
etnylbenzenB
toluene
xylenes (total)
styrene
Samt-Yolatltai Organic Compounds
benzoicacjd
phenol
4-methytphenol
dK)-butylphthalate
dHvoctylphtnalala
bis(2-«tnylhexyl)phthalate
butylbenzylphthalate
naphthalene
PestlcldM and PCBs
ZDDTR
4.4-DDD
4.4--DDE
4,4'-DDT



A
82

D
B2
D

D
D




D
D

82
82
82
D
A
82
82
D


A
D
D
D
82

D
D
C
D

82
C
D

82
82
82
82
Drinking Water Cancer Potency
Unit Risk Factor
(CPF)
((ug/0-1) (mo/w\49* MV«IV Wf HI
Weightxrf- InhalaBon
Evidence Unit Risk
Classification
• fuo/m3V1



A
82
81
A
D
B2
D

A
0
D




D
0

82
82
82
D
A
82
82
D


A
D
D
D
82

, D
D
C
D

82
0

82
82
82



4.3E-03
2.4E^»
1.8E-03
12E-02




2.4E-04








4.7E-07
2.3E-05
1.SEXJ5

8.4E-05
1.7E-06
S^E-07


8.3E-06


S.7E-07









9.7E-05
9.7E-05
Cancer Potency
Factor
(CPF)
/rryi/flf r^fiu u\\_ 1



5.0E+01
8.4E400
6.3E+00
4.1E+01

• ' '•


8.4E-01








1.6E-03
8.1E-02
1.3E-01

2.9E-01 ;
1.7E-02
1.8E-03


2.9E-02


2.0E-03






1.4E-02


3.4E-01
2.4E-01
3.4E-01
3.4E-01

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                                                      Table  11
                                           Summary of  Cancer  Risks
                                         Current Land  Use  Scenario
                                                                      Total ILCR
  Chemical
Trespassing    Wading / Fishing   Living at Home    AH Activities     Percent of
                                                              Summary
                                                                ILCR
   (prob)	(prob)	(prob)	(prob)	(%)
• Itotals and Cyanide
   aluminum  '
   antimony           • • -..  -   •
   arsenic
   barium
   beryffium
  • caflOTum
  • chromium
   chromium VI
   cobalt
   copper
   lead
   mercury
   nickel
   selenium
   silver
   strontium
   thaffium
   titanium
   vanadium
   zinc  :
   cyankte.......

  Volatile Organic Compounds
   me thytene chloride
   chloroform
 -' carbon tetracHoride
   carbon disuJfide
    1,1,1-trichloroethane
    vinyl crdonde
    trichforoethytene
    tetrachtoroethytene
    acetone
    2-butanone
    4-methyl-2-pentanone
    benzene
    ethylbenzene
    toluene
    xytenes (total)
    styrene

   S«nl-Volatil« Organic Compounds
    benzole acid
    phenol
    4-methylphenol
     o5-n-butylphthaJate
     di-n-octylphtnalate
     b's(2-ethythexyOphlnalate
     butylbenzylphthalate
     naphthalene

   Pesticides and PCBs
     ZDDTR
  23E-09

 : 4£E-09
  1.1E-10
4.2E-Q8
22E-05
2JE-09

22E-05
1.1E-10
0.0%

40.7%
0.0%
   15E-10
                                15E-10
                                                                 0.0%
   7.6E-12         45E-11

   3.0E-08         3.1E-09
                                5.6E-11        0.0%

                 1.4E-05        1.4E-OS        25.9%
                   4.9E-11                         4J9E-11         0.0%
                   1.3E-09          Z1E-06         2.1E-06         3.9%
    1.8E-O8
  1.9E-09
  8.4E-06
                                                   8.4E-06        15.4%
     1JE-09
                    32E-08
                     7.7E-06
                                                    32E-08
                                  7.7E-06
                                                                   0.1%
                                                                   14.1%
                                          5.7E-08
                                           0.1%
                     7.7E-06
                      14^54
                   4.7E-05
                    85.7%
                  5.5E-05
                  100.0%
                                                                                                        100.0%

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        APPENDIX IV




NYSDEC LETTER OF CONCURRENCE

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New'York State Department of Environmental Conservation
50 Wolf Road, Albany, New York 12233
                                            MAR 2 3  1993
                                                             Thomas C. Joriing
                                                             Commissioner
                                                                 8:
                                                                f
                                                                    CO
                                                            co  -o
Mr. William J. Muszynski
Acting Regional Administrator
United States Environmental
  Protection Agency, Region II
26 Federal Plaza                                            -fT  •*"
New York, New York   10278                                  f\>

Dear Mr. Muszynski:

          RE:   Johnstown City Landfill - Site No. 518002
                        Record of Decision

     Concerning the draft Record of Decision  at  the Johnstown
City Landfill Site, the New York State  Department  of
Environmental Conservation  (NYSDEC) concurs with the United
States Environmental Protection Agency's  (USEPA) selection of
Alternative SC-3, which will include  the  following major
components:

     1.   Excavation of the LaGrange  Gravel Pit  sediments,
          placing the excavated materials on  the existing
          landfill.  The pit would then be filled  with clean fill
          to eliminate any standing water.

     2.   Construction of a multi-layer closure  cap over the
          landfill mound and excavated  sediments per New York
          State 6NYCRR Part 360 regulations.

     3.   Expansion of the Johnstown  City water  supply system to
          provide potable water to all  private water supplies
          potentially impacted by the landfill.

     4.   Erection of approximately 6800  feet of conventional
          chain link fencing surrounding  the  entire landfill
          mound, with placement of appropriate warning signs.

     5.   Performance of air monitoring prior to,  during, and
          following construction at the site. Perimeter
          subsurface gas monitoring between  the  landfilled area
          and  adjacent properties will  be conducted and landfill
          gas  emissions controlled as needed.

-------
Mr. William J. Muszynski                                 Page 2


     6.   Performance of a maintenance and monitoring program
          which at a minimum will fulfill the requirements of
          6NYCRR Part 360 for post closure monitoring.

     7.   Performance of a Stage 1A cultural resources survey in
          on-site and in off-site areas where there is a
          potential impact to cultural resources.

     8.   Imposition of property deed restrictions which will
          include measures to prevent the installation of
          drinking water wells at the site and restrict
          activities which could affect the integrity of the cap.

     The NYSDEC also concurs with the contingent remedy,
Alternative SC-6, which may be implemented should monitoring
results show that groundwater and/or surface water quality is not
being restored to acceptable levels through natural attenuation
after construction of the landfill cap required in Alternative
SC-3.  Alternative SC-6 would include all of the major components
of Alternative SC-3 described above, and in addition groundwater
extraction, treatment and discharge.

     If you have any questions, please contact Mr. Robert Cozzy
at 518-457-1641.
                             Sincerely,
                             Ann Hill DeBarbieri
                             Deputy Commissioner
                             Office of Environmental
                               Remediation

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      APPENDIX V




RESPONSIVENESS SUMMARY

-------