PB94-963840
EPA/ROD/R02-94/235
January 1995
EPA Superfund
Record of Decision:
Hooker Chemical/Ruco Polymer
Site (O.U. 1), Hicksville, NY
1/28/1994
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RECORD OF DECISION
Hooker Chemical/Ruco Polymer Site
Town of Oyster Bay, Nassau County, New York
United States Environmental Protection Agency
Region II
New York, New York
January, 1994
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ROD FACT SHEET
Site name: Hooker Chemical/Ruco Polymer Site
Site location: Hicksville, Town of Oyster Bay, Nassau County, New York
MRS score: 41.60
ROD
Selected remedy: Groundwater pump and treat combined with soil flushing and soil
excavation.
Capital cost: Between $ 5,246,000 and $ 5,531,000
O & M cost: Between $ 550,000 and $ 552,000
Present-worth cost:
- 10-year present-worth cost: between $ 9,012,000 and $ 9,031,000
- 30-year present-worth cost: between $ 13,222,000 and $ 13,250,000
LEAD
United States Environmental Protection Agency
Primary Contact: Dale J. Carpenter, (212) 264-9342
Secondary Contact: Kevin M. Lynch (212) 264-6194
Main PRPs: Occidental Chemical-Corporation, Ruco Polymer Corporation
WASTE
Waste type: Various volatile, semi-volatile, inorganics and tentatively identified compounds
(TICs)
Waste origin: Chemical manufacturing and processing.
Estimated waste quantity: Groundwater: Estimated volume to be pumped and treated
annually is 53,000,000 gal. Deep Soils: between 20,000 and 30,340 cubic yds. Shallow
Soils: between 445 cubic yds. and 710 cubic yds.
Contaminated medium: Groundwater, deep soils (below 10 feet) and surficial soils.
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DECLARATION FOR THE RECORD OF DECISION
SITE NAME AND L OCA TION
Hooker Chemical/Ruco Polymer Site
Town of Oyster Bay, Hicksville
Nassau County, New York
STA TEMENT OF BASIS AND PURPOSE
This decision document presents the selected remedial action for the Hooker
Chemical/Ruco Polymer Site, which was chosen in accordance with the requirements of
the Comprehensive Environmental Response, Compensation, and Liability Act of 1980, as
amended (CERCLA), and to the extent practicable, the National Oil and Hazardous
Substances Pollution Contingency Plan (NCP). This decision document explains the factual
and legal basis for selecting the remedy for this Site.
The New York State Department of Environmental Conservation (NYSDEC) concurs with
the selected remedy. A letter of concurrence from the NYSDEC is attached to this
document (Appendix IV). .-
The information supporting this remedial action decision is contained in the administrative
record for this Site. The index for the administrative record is attached to this document
(Appendix III).
DESCRIPTION OF THE SELECTED REMED Y
This operable unit (operable unit one) is the first of two (and possibly three) operable units
for the Site. Operable unit two addressed specific areas of the Site with PCB contaminated
soils. Operable unit two was completed and approved as an early action in March 1993
to remediate the greatest risk to workers at the Site. (A potential third operable unit will
address the downgradient groundwater contamination.) Operable unit one (the subject of
this Record of Decision) at the Hooker Chemical/Ruco Polymer Site will address the
contaminants in the soils that were not remediated as part of operable unit two and present
the largest threat to the groundwater as continued sources of contamination. The
remaining soil contamination is being addressed to eliminate its potential contribution to
groundwater contamination and further reduce potential risks to Site workers from
exposure to surficial soils contaminants. This operable unit will also address groundwater
contamination beneath the Ruco facility through a pump and treat system to prevent further
downgradient migration of contaminants. Operable unit one will require long-term
management to maintain the groundwater pump and treat systems and periodically
measure the success of the deep soil flushing.
The major components of the selected remedy include the following:
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- Installation of groundwater extraction wells to control the flow of contaminated
groundwater from leaving the Ruco property and migrating downgradient. The conceptual
groundwater modeling performed in the Feasibility Study Report estimated that approxi-
mately 100 gallons per minute (gpm) will be required to control the groundwater flow. The
exact number, depth, size and pumping rates of the extraction wells will be determined
through tests conducted in the Remedial Design.
- Installation of a groundwater treatment system to treat the extracted groundwater.
Treatment of the extracted groundwater with an on-site treatment system will be expected
to achieve the appropriate discharge standards. The exact combination and type of
treatment technologies (i.e., granulated activated carbon, ultraviolet oxidation, flocculation,
etc.), and their effectiveness on tentatively identified compounds (TICs) will be determined
in the design phase through the performance of treatability studies. Additional analyses
of the TICs in the groundwater will be required to identify the classes of chemical
compounds that comprise the TICs. If the results of the treatability studies indicate the
discharge standards can not be achieved, the selected remedy will have to be revisited.
- Installation of a discharge system to dispose of the majority of the treated groundwater.
The discharge will be to a sump to be constructed on the Ruco property, unless a more
appropriate off-site location can be found by the potentially responsible parties for the
discharge of the treated groundwater. The majority of the discharge volume will be
required to be diverted to this proposed sump to avoid overloading sumps one and two
(see soil flushing below) and the groundwater extraction system. The discharged
groundwater is expected to meet the appropriate discharge criteria through treatment (see
treatment above).
- Additional soil testing in the bottom of sump two to determine if contaminants are present
in the deep soils and to compare the levels present to the soil cleanup criteria that are
considered protective of groundwater quality. If contaminants are present at levels above
the protection of groundwater criteria, the soils in sump two will be addressed in the same
manner as the soils in sump one.
- Soil flushing for the deep soils in sump one, and possibly sump two (based on the results
of additional soil testing). The soils will be flushed by the discharge of treated groundwater.
The contaminants flushed out by this process will be recaptured by groundwater extraction
wells. The exact location, depth, size and pumping rates of the wells will be determined
during the design phase of the selected remedy. Additional analyses of the tentatively
identified compounds (TICs) in the soil will be required to identify the classes of chemical
compounds that comprise the TICs. Treatability studies (e.g., soil column tests) will also
be performed on the soils to evaluate the effectiveness of soil flushing on TICs. The
contaminant levels in the sumps will be re-evaluated during periodic monitoring and at the
five-year review to measure the progress of the flushing. A portion of the groundwater
discharge (approximately 10 gallons per minute) will be circulated to sump one (and
possibly sump two, depending on subsequent soil boring results) to flush the soil
contaminants. The exact delineation of the areas to be flushed will be performed during
the design phase of the remedial action. In order to install a flushing system in sump one,
the existing concrete storage tanks in that sump will be removed.
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- Additional soil testing in the area around monitoring well E to determine if contaminants
are present. If contaminants are present, the concentrations will be compared to the soil
criteria considered to be protective of groundwater quality to determine whether a
significant potential contaminant source to the groundwater exists. If the contaminants are
present above the protection of groundwater quality criteria, and exist in the shallow soils,
the area around well E will be addressed in the same manner as the former drum storage
area (see excavation below). If the contaminants are present in the deeper soils, further
evaluation of potential remedial alternatives will be required.
- Excavation of the soils in the former drum storage area and possibly the area around
monitoring well E (to be determined by subsequent soil borings). The excavated soils will
then be disposed of off-site. The approximate volume of the soils to be excavated in
former drum storage area is 445 cubic yards (and 265 cubic yards for the area around
monitoring well E). The extent of the excavation in the former drum storage area, and
possibly the area around monitoring well E, will be based on the results of soil samples
collected during the design phase.
- Periodic monitoring of the groundwater extraction system to assure adequate control is
maintained; periodic sampling of the groundwater treatment system discharge, to assure
treatment standards are achieved; and periodic sampling of the soils in sump one and
possibly sump two to measure the progress of the selected remedy in achieving the
cleanup standards. Existing monitoring wells on the Ruco property will be used to monitor
the performance of the groundwater extraction system and establish that sufficient control
occurs. Additional monitoring wells may be required. The need for additional monitoring
wells will be determined during the design and implementation of the groundwater
extraction system.
- The use of institutional controls in the form of deed restrictions and groundwater use
restrictions at the Ruco property. The purpose of the deed restrictions are to restrict the
use of the Ruco property to industrial development only, as long as contaminants remain
on the property and the treatment systems are in place. Groundwater use restrictions, in
addition to the existing Nassau County Ordinance, will be implemented through deed
restrictions as well. The use of groundwater will be restricted until such time as the
groundwater beneath the Site has been determined to be fully remediated.
DECLARA TION OF STA TUTORY DETERMINA TIONS
The selected remedy is protective of human health and the environment, complies with
federal and state requirements that are legally applicable or relevant and appropriate to the
remedial action, and is cost-effective. The selected remedy utilizes permanent solutions
and alternative treatment (or resource recovery) technologies to the maximum extent
practicable, and it satisfies the statutory preference for remedies that employ treatment that
reduces toxicity, mobility, or volume as their principal element.
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Because this remedy will result in hazardous substances remaining on-site above health-
based levels, a review will be conducted within five years after commencement of remedial
action, and every five years thereafter, to ensure that the remedy continues to provide
adequate protection of human health and the environment.
William J. M
Acting R
Date
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RECORD OF DECISION
DECISION SUMMARY
Hooker Chemical/Ruco Polymer Site
Town of Oyster Bay, Nassau County, New York
United States Environmental Protection Agency
Region II
New York, New York
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TABLE OF CONTENTS
SITE NAME, LOCATION AND DESCRIPTION Page 1
SITE HISTORY AND ENFORCEMENT ACTIVITIES Page 4
HIGHLIGHTS OF COMMUNITY PARTICIPATION Page 8
SCOPE AND ROLE OF OPERABLE UNIT Page 8
REMEDIAL ACTION OBJECTIVES Page 10
SUMMARY OF SITE CHARACTERISTICS Page 11
SUMMARY OF SITE RISKS Page 14
DESCRIPTION OF REMEDIAL ALTERNATIVES Page 20
SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES Page 31
SELECTED REMEDY Page 42
STATUTORY DETERMINATIONS Page 46
DOCUMENTATION OF SIGNIFICANT CHANGES Page 49
ATTACHMENTS
APPENDIX I. FIGURES
APPENDIX II. TABLES
APPENDIX Ml. ADMINISTRATIVE RECORD INDEX
APPENDIX IV. STATE LETTER OF CONCURRENCE
APPENDIX V. RESPONSIVENESS SUMMARY
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SITE NAME, LOCATION AND DESCRIPTION
The Hooker Chemical/Ruco Polymer Site (Hooker/Ruco) is located in Hicksville, Township
of Oyster Bay, Nassau County, New York, approximately 25 miles east of New York City
(see Figure 1). The Site is an active chemical manufacturing facility in a heavily industrial-
ized section of Hicksville. The plant, currently owned and operated by the Ruco Polymer
Corporation (Ruco), contains six buildings for the manufacture and storage of chemical
products (Plants 1,2,3, the Pilot Plant, a warehouse, and an administration building)(see
Figure 2). The remainder of the 14 acre Site contains parking areas, chemical storage
tanks, four recharge basins (sumps) and small ancillary buildings. The facility currently
employs 96 personnel and manufactures polyester, polyols and powder coating resins.
The major facilities in the industrial zone near the Ruco facility are the Grumman Aerospace
Corporation (Grumman), Bethpage manufacturing facility and airport, and the Naval
Weapons Industrial Reserve Plant (NWIRP). There are other smalMndustries, commercial
operations, utilities, and transportation corridors and stormwater management basins in the
area. Residential neighborhoods are in close proximity to, and surround the industrial area.
The Hooker/Ruco Site is physically bounded by the Long Island Railroad (LIRR) tracks to
the southwest, New South Road to the West, Commerce Street to the north and the
Grumman facility to the east and south.
The 14 acre triangular shaped Hooker/Ruco facility is composed of parking areas,
undeveloped land, industrial buildings and chemical storage structures. As shown on
Figure 2, Commerce Street and adjacent industrial development comprise the 880 foot
northern Site boundary. Along the facility's 1,000 foot eastern side is a large warehouse
building owned by Grumman. A small portion of undeveloped Grumman land abuts the
facility's 250 foot southern property boundary. Two active tracks of the LIRR parallel the
facility's 940 foot southwestern property boundary. The facility is bounded on the 270 foot
western boundary by New South Road. The property line is demarcated by a chain-link
fence which completely encompasses the Hooker/Ruco facility.
Vehicular access to the Site is via New South Road. South and southeast of the parking
lot area is approximately 3 acres of undeveloped land. Access to the active plant site is
along a paved roadway passing a security building and freight scales. The paved roadway
extends to the central, eastern and southern portions of the Site.
In addition to vehicular traffic, a spur of the LIRR enters the property's southwestern
boundary. The rail spur, once on the facility, splits into two diverging sidings, one that
progresses east toward the corners of Plants 2 and 3, and the other siding angling south
between Plant 1 and the warehouse.
Plant 1, located in the south/central portion on the facility, is the largest structure,
comprising approximately 44,800 square feet. The single story brick building, built in 1945,
consists of manufacturing and latex storage. A small office complex was added to the
building's front side in 1964 and houses the plant's engineering division. The northern
portion of Plant 1 contains a small laboratory.
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Adjacent to, but south of Plant 1, is a warehouse, constructed of sheet metal, installed in
1952 covering approximately 12,000 square feet. The warehouse is used for storage of
raw and finished stock. A loading dock for shipping and receiving is located in the
northern portion of the building.
Northeast of Plant 1 is a small, approximately 2,300 square foot, brick and sheet metal
structure, termed the Pilot Plant. The Pilot Plant, installed in 1945, is an independent facility
used to pilot test new/emerging products prior to full production.
South of Plant 1 is the ester tank farm which has been inactive since 1982. The tank farm
consists of five 10,000 gallon and eight 5,000 gallon horizontal storage tanks housed in
concrete saddles. The entire tank farm is surrounded by a concrete dike. The storage of
product, however, has been discontinued in the tank farm and storage of esters and higher
alcohols is currently in four silos adjacent to Plant 1.
The Plant 2 complex is located in the north/central portion of the Site and is composed of
Plant 2, the adjacent tank farm and cold room building. Plant 2, built in 1956, is composed
of the filter storage and reactor buildings covering approximately 11,000 square feet. The
filter storage building in the southern portion of Plant 2 contains offices, a small laboratory
and maintenance, with the rotary drier associated with production in the rear of the
building. Adjacent, in the northern half of Plant 2, are a series of chemical reactors used
in the production stages of manufacturing. Because of the reactor's dimensions, the
northern half of Plant 2 is a two story building.
North of Plant 2 is an above-ground tank farm, previously used to store raw plastic stocks,
and currently storing solvents and alcohols. The tank farm consists of a 30,000 gallon, two
25,000 gallon and three 15,000 gallon above-ground horizontal storage tanks. These
storage tanks are surrounded and separated by a 5 foot earthen dike. Just to the east of
the tank farm is a small, 300 square foot refrigerated building, termed the cold room. The
cold room was an integral part of the discontinued plastic manufacturing process.
Plant 3 is an approximately 10,800 square foot, two story, sheet metal building, located in
the central portion of the facility. Plant 3 is primarily used for raw and finished stock
storage. Adjacent to Plant 3, along the building's south side, are five 100,000 gallon silos
used for product storage.
The administration building is approximately 7,700 square feet and is located along the
Site's northern boundary. The administration building, formerly the plastic research and
development complex, has been converted from a laboratory to offices for corporate
accounting and production personnel. The rear of the building was discontinued in 1975.
With the exception of the ester tank farm, all of the structures on the facility are currently
in use.
Four surfacewater sump basins are located along the facility's eastern property boundary.
Sumps one and two are located in the southern portion of the facility, southeast of Plant
1. Sump one is approximately 5 feet deep, has been partially backfilled and contains a
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series of six concrete settling basins. Sump 2 is adjacent to sump 1. Sump three, installed
in 1968, is located east of the pilot plant and contains surface water derived from plant
runoff. Sump four, located east of Plant 2, also contains standing surface water. The
interior of sump four has been subdivided into three substructures by an earthen dike.
Sumps five and six have been backfilled to grade surface and are not topographically
represented. Sump five was approximately 5,000 square feet and square in shape. The
sump was located adjacent to sump four in the area between Plant 2 and the cold room.
Sump six was a rectangular shaped sump along the Site's northeastern-most boundary
and covered approximately 8,000 square feet.
Water supply at the Site is now derived from city water mains running beneath the Site from
New South Road. A 150,000 gallon tank and two 400 square feet cooling water towers are
located along the facility's eastern boundary. Miscellaneous structures, including a pump
house and two maintenance garages, are located in the vicinity adjacent to sump three.
Off-site electrical power is brought on-site via above-ground utility poles and below grade
electrical lines. Three transformer vaults distribute the electricity to individual buildings.
The transformer vault, adjacent to Plant 1, consists of a bank of three 333KVA transformer
banks. The facility is currently served by a public sanitary sewer system. In the past, septic
waste was discharged to on-site septic systems.
The relatively level surface of the Site slopes gently to the south. The Site surface is
primarily permeable except for the presence of the buildings and limited paved areas.
Surface water from precipitation drains from the buildings, paved areas and other areas of
the Site into a recharge basin (sump three) located along the eastern edge of the Site.
There are three major aquifers underlying the Site. These are: the unconfined Upper
Glacial aquifer; the semi-confined Magothy aquifer; and, the confined LJoyd Sand aquifer.
The total thickness of these three aquifers beneath the Site is approximately 1,200 feet.
The two aquifers of environmental concern for this Site are the Upper Glacial and the
Magothy, since the LJoyd Sand is a deep aquifer (1000 feet) and not hydrogeologically
connected to the above aquifers. Studies have indicated that the Upper Glacial and
Magothy aquifers are hydrogeologically connected under the Site. The Magothy aquifer
is totally dependent upon downward percolating rainfall and recharge from the overlying
Upper Glacial deposits for its surface replenishment.
The Raritan Formation is an Upper Cretaceous age coastal plain deposit which lies
unconformably on the bedrock below and consists of two members. The lower member
is the LJoyd Sand, the top of which is about 750 below sea level. This is a stratified deposit
of sand, gravel, sandy clay, silt and clay generally occurring in discontinuous and lenticular
beds. The upper member is the Raritan Clay, which is composed of primarily silt and clay,
but which has some lenses of sand and clayey sand. The Raritan Clay functions as an
aquiclude, separating the ground water within the LJoyd Sand from the ground water within
the overlying Magothy Formation. Beneath the Site, the LJoyd Sand is approximately 200
to 300 feet thick and the relatively impermeable Raritan Clay is approximately 160 feet thick.
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The total formation thickness ranges from 300 to 600 feet and is the deepest unconsolidat-
ed deposit beneath the Site.
The Magothy Formation is a thick sequence of Upper Cretaceous age sediments which
were deposited upon the underlying Rarrtan Formation. At the Site the Magothy Formation
is approximately 680 feet thick and is composed of marine and terrestrially deposited,
stratified, coastal plain sediments. The sediments are primarily fine sand, clayey sand, silt
and clay, but may also contain discontinuous lenses of coarse sand and gravel.
Lying unconforrnably on the Magothy Formation are glacio-fluvial outwash deposits of
Quaternary Age. These Pleistocene deposits which comprise the Upper Glacial aquifer
deposits are approximately 30 to 50 feet thick directly under the Site. The Upper Glacial
sediments consist of horizontally stratified beds of fine to coarse sands and gravel. The
Magothy and the Upper Glacial aquifers have historically been distinguished by differences
in sediment color, texture and composition.
The direction and relatively rapid rate of shallow (near the water table) groundwater flow
beneath the Site is southerly. The water table at the Site was found to be between 50 to
60 feet below the surface. Deeper in to the Magothy aquifer, the groundwater flow is to
the south with an easterly component of flow that results from the influence of high
pumping rates at the Grumman facility adjacent to the Site.
Ground water supplies the public and private needs of the entire population of Nassau
County. The two most commonly tapped aquifers for water supply purposes are the Upper
Glacial and the Magothy. The Magothy aquifer is the primary source of potable drinking
water in the area of the Site. Water is pumped from municipal supply wells to the homes
and businesses in the vicinity of the Site. The Hicksville, Bethpage and Levittown Water
Districts supply the businesses and residents in the vicinity of the Site as well as areas to
the south. All of the local public supply wells are advanced to and completed within the
Magothy aquifer. The nearest municipal well field is located upgradient at 2,000 feet to the
north of the Site (Hicksville supply wells)i The ground-water flow is to the south. Other
municipal supply wells are located 3,500 feet to the west (Hicksville supply well) and 6,000
feet to the east (Bethpage supply well) of the Site. Municipal well fields located down-
gradient are 5,500 feet southwest (Hicksville and Levittown) and approximately 10,000 feet
south-southeast (Bethpage supply wells) of the Site. '
The industrial area, including the Site, as well as the surrounding residential areas are
above the groundwater aquifer that supplies the surrounding communities with water. The
aquifer on Long Island is designated a sole source aquifer.
SITE HISTORY AND ENFORCEMENT ACTIVITIES
The Hooker/Ruco Site, located off of New South Road in Hicksville, was developed by the
Rubber Corporation of America, a small privately held company. Operations at the Site
began in 1945 and included natural latex storage, concentration and compounding. Five
years later the company began producing small volumes of plasticizers. These activities
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were expanded "and modified through the years. In 1956, a polyvinyl chloride plant was
built and was initially operated under the name of Insular Chemical Corporation. At that
time the two companies, Insular Chemical Corporation and the Rubber Company of
America occupied the Site. Although they were two separate corporations, they shared the
same pilot plant. The two companies eventually merged into the Rubber Corporation of
America. In 1965, the company was purchased by the Hooker Chemical Company and
was known and operated as the Ruco Division. The Hooker Chemical Company has since
undergone several name changes, with the current name being Occidental Chemical
Corporation (Occidental or OCC). In 1982, the employees of the Ruco Division bought the
company from Occidental and it became known as the Ruco Polymer Corporation (not
affiliated with Occidental Chemical Company).
Since 1946, the facility was used for the production of various polymers, including polyvinyl
chloride (PVC), styrene/butadiene latex, vinyl chloride/vinyl acetate copolymer, and
polyurethane, as well as ester plasticizers. This facility is currently active, and manufac-
tures such products as polyester, polyols and powder coating resins.
During Site operations between 1956 and 1975, industrial process wastewater and
stormwater runoff from the facility was discharged to six (6) on-s'rte recharge basins or
sumps. This wastewater contained, among other things, vinyl chloride, trichloroethylene,
barium and cadmium soap, vinyl acetate, organic acids, and styrene condensate. Drums
containing various chemicals were also stored on-site where occasional spills would occur.
As a result of these releases, groundwater beneath and downgradient from the Site has
been contaminated. Limited areas of residual soils contamination exist above levels that
would be considered protective of groundwater quality. Currently, only non-contact cooling
water is discharged into sump four and sump three collects surfacewater runoff. From
1975 to 1991 a concrete settling basin was used to store ester waste prior to being
incinerated on-site. Ester wastes are presently stored in an on-site, above ground tank
prior to off-site disposal or incineration on-site. Hazardous wastes are stored in drums on-
site until they are disposed of at a permitted off-site facility.
From 1946 to 1978, the pilot plant used a heat transfer fluid called Therminol, which
contained PCBs. During the operation of the facility, there was a release of PCBs to the
soil adjacent to the pilot plant. Some of this contaminated soil was spread to surrounding
areas by surfacewater run-off, sediment transport, and truck traffic. Occidental has
conducted several investigations, since 1984, to determine the extent of PCB and other
soils and groundwater contamination at the Ruco Polymer plant. In 1989, an underground
fuel oil storage tank adjacent to Plant 1 was removed, and the soils surrounding the tank
were excavated, sampled, and found to be contaminated with PCBs. These excavated
soils were covered with plastic sheeting, pending the remediation of the other PCB-
contaminated soils on the Site.
Initial investigations were started at the Hooker/Ruco Site in 1978. Originally efforts were
directed towards understanding past manufacturing processes, waste generation and
disposal. A Site background report was prepared in 1981. This report presented the Site
in the context of its surroundings and examined waste disposal, regional geology and
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hydrogeology, and regional water withdrawals and water quality. At that time the New York
State Department of Environmental Conservation (NYSDEC) was the lead government
agency. A work plan for conducting a soils and groundwater investigation was submitted
to the NYSDEC in 1983. This work plan was approved in 1983 and the investigation
commenced. The investigation consisted of installing and sampling six groundwater
monitoring well clusters at locations downgradient of suspected areas of waste disposal,
the drilling and sampling of two deep test borings in formerly active sumps, and drilling and
sampling four shallow borings in the vicinity of the reported Therminol spill. The results of
this study were presented in a report entitled "Report of Groundwater & Soils Investigation
at the Former Ruco Division Piant Site, Hicksville, New York", dated August 1984.
These initial investigations led to the Site being placed on the National Priorities List (NPL)
in 1984.
In March 1985, four additional borings were drilled and sampled in the Therminol spill area,
and in May 1985, a second round of groundwater samples were obtained. The results of
these investigations were presented in a report entitled "Report of Groundwater & Soils
Investigation at the Former Ruco Division Plantsrte, Hicksville, New York: Second Round
of Sampling", dated February 1986.
From 1986 through September 1988, several sampling programs were undertaken to
further define the extent of PCBs in the shallow soils around the pilot plant, and in soils
excavated during the underground storage tank removal. The results of these programs
were presented in progress reports dated January 1987, July 1987, December 1987,
February 1988 and June 1988. These data are summarized in the "Focused Feasibility
Study for Remediation of Soils Containing Aroclor 1248" dated August 1989.
In July 1988, EPA sent OCC a request for information on the Hooker/Ruco Site. A
response to the EPA request for information was submitted in September 1988.
Initially, negotiations by NYSDEC and EPA failed to reach a settlement with the potentially
responsible parties (Occidental Chemical and Ruco Polymer) to conduct the Remedial
Investigation/Feasibility Study (RI/FS) for the Site. Therefore, EPA issued a work
assignment to its contractor, Ebasco Services Inc., to prepare a work plan and conduct
the RI/FS. However, in September 1988, after the work plan was finalized, Occidental
agreed to perform the work. OCC entered into an Administrative Order on Consent with
EPA in September 1988. Subsequently, a Field Operations Plan, based on the Ebasco
Work Plan, was submitted for EPA review in October 1988. In September 1989, RI/FS fiefd
work commenced. Field work was completed in February 1990 and a draft Rl Report was
submitted in April 1990. Portions of the Rl Report pertaining to the PCB contaminated
areas were approved to expedite the remediation of those areas. The final, complete Rl
report was approved in December of 1992.
An FS outline for operable unit 1 (OU 1) was submitted December 18,1992 containing the
preliminary groundwater and soils treatment alternatives. The Draft FS was received April
17, 1993 and reviewed by the EPA and NYSDEC. The Revised FS Report was received
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on July 18, 1993 and the Final FS report was approved in August 1993. The Rl Report,
the FS Report, Proposed Plan and Responsiveness Summary, along with other Site related
documents, provide the basis for this Record Of Decision.
In order to expedite action to deal with the most immediate human health threats at the Site
first, separate distinct phases or "operable units (Oils)" were established. The Ous for this
Site are divided as follows:
o OU 1: Covers the majority of the Ruco property; soil and groundwater
contamination from previous disposal activities.
o OU 2: Addressed the PCB-contaminated soils.
o A third area of concern is the contaminated groundwater, downgradient of the Ruco
property boundary.
Occidental proposed to perform an early action to remediate the PCB contaminated areas
separately in 1989 (while the Rl was underway). To support such an action, Occidental
prepared a Focused Feasibility Study (FFS) which analyzed alternatives to address the
PCB-contaminated areas on the Site. Given that the PCB-contaminated areas had been
defined by previous investigations, and the technologies for treatment were different from
the rest of the Site, the PCB excavation was designated as OU 2.
OU 2 for this Site covered an area surrounding the pilot plant building and a portion of
sump three which was contaminated by PCBs. A ROD addressing OU 2 was issued on
September 28, 1990. The Special Notice letter for the implementation of the remedial
design/remedial action (RD/RA) and the draft Consent Decree were sent to OCC and
Ruco Polymer on December 20, 1990. A Good Faith Offer to perform the RD/RA and to
enter into a Consent Decree was received from Occidental on February 27, 1991. A
response was also received from Ruco Polymer, expressing their willingness to cooperate
with EPA and Occidental (Occidental has assumed responsibility for environmental matters
at the Site).
Occidental formally rejected EPA's offer to enter into a Consent Decree in a letter dated
June 5,1991. A Unilateral Administrative Order was signed by the Regional Administrator
on June 27, 1991. Notices of Intent to Comply with the order were submitted by both
Occidental and Ruco Polymer (both letters are dated July 16,1991) and were received by
EPA on July 17,1991. Due to deficiencies in its original submittal, Ruco Polymer submitted
a revised Notice of Intent to Comply (dated July 26, 1991).
The RD/RA Work Plan Outline was received on May 13, 1991, followed by the RD/RA
Work Plan (Remedial Design) in July, 1991. Final RD/RA Work Plan approval was given
on April 24,1992. Mobilization for the execution of the Remedial Action of OU 2 took place
on May 4,1992. All operations of the work were monitored by an EPA oversight contrac-
tor. Notice from Occidental for Final Inspection was received on July 22, 1992. An
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Inspection visit was made on September 3, 1992 at which time all restoration was
completed.
Occidental's Remedial Action Report was received on October 19,1992 and final approval
was issued on March 12, 1993. This concluded the activities associated with
OU 2.
Upon completion of the Remedial Action of OU 2, four areas of PCB contaminated soils
surrounding the pilot plant were addressed. They were: 1) the direct spill area;
2) transport related areas; 3) the previously excavated soils; and, 4) the impacted recharge
basin (sump three) (See Figure 3).
The volumes of PCB-contaminated soils that were removed during the Remedial Action of
OU 2 were as follows:
10 ppm - 500 ppm = 3,230 tons (1,957 cu.yds.)
500+ ppm = 85.2 tons (52 cu.yds)
HIGHLIGHTS OF COMMUNITY PARTICIPATION
The Rl report, FS report, and the Proposed Plan for the Site were released to the public
for comment on August 23,1993. These documents were made available to the public in
the administrative record file at the EPA Docket Room in Region II, New York and the
information repository at the Hicksville Public Library, 169 Jerusalem Avenue, Hicksville,
New York. The notice of availability for the above-referenced documents was published in
the Nassau County edition of "Newsday" on August 23,1993. The public comment period
on these documents was held from August 23, 1993 to September 22, 1993. As per a
request, the comment period was extended 30 days to October 22, 1993.
On September 8, 1993, EPA and NYSDEC conducted a public meeting at the Hicksville
Elks Lodge, No. 1931, 80 East Barclay Street, Hicksville, New York to inform local officials
and interested citizens about the Superfund process, to review current and planned
remedial activities at the Site, and to respond to any questions from area residents and
other attendees.
Responses to the comments received at the public meeting and in writing during the public
comment period are included in the Responsiveness Summary (see Appendix V).
SCOPE AND ROLE OF OPERABLE UNIT
As discussed previously, this Site has been separated into two (and possibly three)
operable units or OUs.
o OU 1: Covers the majority of the Site; soils and groundwater contamination from
previous disposal activities.
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o OU 2: PCB-contaminated soils surrounding the pilot plant and in sump three.
o A third area of concern that has not been officially designated as an OU:
Contaminated groundwater, downgradient of the Ruco property boundary.
This decision document addresses the first OU. The Rl Report for OU 1 was approved in
December 1992 by EPA. The Rl identified groundwater beneath the Ruco property above
New York State groundwater quality standards, NYS drinking water standards and Federal
MCLs. The Rl has also identified limited areas of soils on the property that need to be
remediated to protect the groundwater quality. Additional limited areas of soils have been
identified that may potentially need to be remediated to protect groundwater quality.
Therefore, OU 1 will address the control (and remediation) of the groundwater beneath the
Ruco property and the soils in the following areas: 1) the soils beneath sump one, 2) the
surficial soils in the former drum storage area; and, based on additional sampling, possibly
3) the soils beneath sump 2, and 4) the surficial soils around monitoring well E. The FS
Report, which identifies and describes various alternatives for addressing the contamination
in the areas identified above, was approved in August of 1993.
As mentioned above, the second OU has been completed.
The larger problem associated with this Site and the adjacent sites (Grumman and the
Navy), is the existence of downgradient groundwater contamination. This is the third area
of concern stated above. The EPA and NYSDEC are currently coordinating activities
concerning the RI/FS of the groundwater contamination that has migrated downgradient
from the Ruco property boundary and the Grumman and Navy facilities. The EPA and
NYSDEC have identified three sites that have and are currently contributing to the
groundwater contamination including: the Hooker/Ruco (EPA lead), Grumman (NYS lead)
and the Navy (NYS lead with involvement of EPA's Federal Facilities and RCRA Divisions)
sites. The agencies are managing their sites by using source control measures at each
site (e.g., OU 1 and OU 2 for the Hooker/Ruco Site), then addressing the downgradient
groundwater contamination problem separately, and in addition to, the source control. A
regional approach to the groundwater contamination problem is being applied. NYSDEC
and the EPA are coordinating the downgradient contamination investigation and remedial
actions for the three sites to avoid duplication of efforts. Much of the investigation field
work has been completed already. It is expected that it will be approximately one year
before EPA and NYSDEC select a remedy for the groundwater problem. In the interim,
actions have been taken to provide protection of the public water supply. A treatment
system has been installed at one of the Bethpage Water District's (BWD) supply plants,
additional treatment systems are being designed for two other BWD supply plants and
monitoring wells are being installed to detect contaminants as they approach other supply
wells. Sampling of the water supply is being conducted on a quarterly basis at most of the
wells. The BWD is testing their water on a more frequent .basis (approximately on a
monthly basis).
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Other actions on the Ruco property are being initiated to address potential buried materials
in the soil. The electromagnetic survey conducted during the Rl indicated the presence of
magnetic anomalies in the subsurface soils. The presence of such anomalies may indicate
buried metallic objects such as a tank or drum. A Work Plan was submitted by Occidental
and approved by the EPA in August 1993, to further investigate these anomalies and
remove any buried objects that may present a potential source of contamination. The field
work to investigate the magnetic anomalies began in September of 1993. At one of the
three anomaly locations, three buried tanks were uncovered. The EPA is currently waiting
for the analytical results from samples collected in the tanks to execute proper disposal of
the tanks. Additionally, investigations of buried materials in the soils between the Pilot Plant
and Plant 2, not associated with the magnetic anomalies, will be conducted which may
involve the excavation of test pits or trenches. A Work Plan to address these areas is
expected to be approved in February of 1994. These actions are not being conducted as
part of a specific OU. Instead, they are being treated as removal-type response actions
to facilitate quick action.
The EPA has been the lead agency for this Site with support from the NYSDEC since 1988.
REMEDIAL ACTION OBJECTIVES
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:
Groundwater
The Risk Assessment has identified a number of contaminants of concern (COCs) in the
groundwater. These contaminants are listed in the Risk Assessment Summary Section.
The contaminants in the groundwater pose a future carcinogenic and noncarcinogenic
health risk to residents who may reside at the downgradient (southern) Ruco property
fenceline. These contaminants in groundwater are subject to a number of regulations for
cleanup and discharge. These regulations include the New York State Water Quality
Regulations, specifically, 6 NYCRR and 10 NYCRR as well as Federal Maximum
Contaminant Levels (MCLs). A complete list of the ARARs is included in Table 1. The
specific ARARs identifying the groundwater cleanup and discharge criteria are presented
in Tables 2 and 3 respectively. The treatment of groundwater will also address compounds
which are not COCs, but exceed the ARARs.
Therefore, the specific Remedial Action Objectives for groundwater are the reduction of
risks to human health associated with potential exposure to Site related compounds by
controlling the migration of groundwater downgradient from the Ruco property and
attaining the groundwater cleanup criteria established by ARARs beneath the Ruco facility.
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Deep and Shallow Soils
Risks associated with direct exposure to the contaminants remaining in Site soils were
within the acceptable risk range for the exposure scenarios considered. However,
contaminant concentrations in the soils of the former drum storage area, sump one and
possibly the area around monitoring well E and sump two are, or are suspected to be,
above levels that would be protective of the groundwater quality. This means that, unless
remediated, the soil could continue to act as a source of contamination to the groundwater.
The NYSDEC has developed soil cleanup criteria that they consider to be protective of
groundwater quality. This criteria, established in NYSDEC's Technical and Administrative
Guidance Memorandum (TAGM), will be used as a to-be-considered (TBC) goal in cleaning
up soils at the Site (Table 4). The TBC values are not promulgated regulations and
therefore, are not considered ARARs. As TBCs, they are not enforceable standards but
may be used as one of the criteria in determining whether the remedial action objectives
have been met. The EPA has also identified the shallow (0'- 5') soils in the former drum
storage area as a potential hazard that would require remediation. These soils, particularly
the area around soil boring TB-10, displayed high concentrations of TICs. The risk to Site
workers and others from these TICs is unknown (can not be quantified), however, the
combined risk of the TICs with the quantified soils risk identified in the Risks Assessment
provides additional justification for remedial action.
Therefore, the Remedial Action Objectives for soils at the Site are the protection of the sole
source aquifer groundwater quality, and ultimately human health, as well as limiting
exposure to surficial soil contaminants.
SUMMARY OF SITE CHARACTERISTICS
The Rl, combined with previous studies, resulted in the characterization of the environmen-
tal conditions on the Ruco property. Sampling of all media including air, soil vapor, soils,
surface water, sediment and groundwater has identified areas of potential environmental
concern. The following briefly summarizes the results of the sampling conducted during
the Rl:
Soil Vapor: Soil-vapor sampling and analysis for volatile organics was performed at 80
locations throughout the Site (See Figure 4) using a photoionization detector (PID) with gas
chromatograph (GC) confirmation. The results of the soil-vapor analysis did not reveal any
area of soils with levels of volatile organic vapors above background, or additional areas
of the plant soils requiring further environmental sampling.
Electromagnetic Survey: A geophysical investigation consisting of an electromagnetic(EM)-
terrain conductivity survey was conducted in the northwestern and northeastern areas of
the Site based on historical information indicating the possible presence of buried objects
(tanks or tanker cars or drums) in these areas. Both in-phase and quadraphase
conductivity results were collected during the investigation. The results of the survey
indicated that two anomalies were detected in the northwestern section of the Site. One
anomaly was located approximately 100 to 180 feet south of the parking lot area oriented
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in an east to west direction. This location corresponds with the historical description of the
location of three buried latex tanks. A second anomaly was located 60 to 80 feet south of
plant 3. This anomaly however, was less pronounced with readings that did not conclude
an axial trend or distinctive shape. This may be more indicative of subtle geological
changes (e.g., fill) at this location rather than a subsurface conductor (see Figure 5).
Two negative anomalies were also detected in the northeastern area of the Site during the
investigation. The location of the first anomaly in the northeast corner corresponds with
the general description of the location of the latex trailer buried in 1962. Quadraphase
readings, however, failed to show a significant axial trend of the buried conductor. The
second anomaly was indicative of below-ground piping. The axial trend of this anomaly
was northeast-southwest. Further review of the plan's engineering drawings showed that
the readings correspond with the presence of two 6 inch water mains (See Figure 6).
Sump Sediments: The sediments from sumps three and four contained low levels of
chemicals associated with the Site's past and current activities. Sump three contained
phthalates, toluene, xylene, ethylbenzene, trichloroethylene (TCE) and polyaromatic
hydrocarbons (PAH)s all below levels considered protective of groundwater quality. PCBs
were also detected in the sediments of sump three. These PCB contaminated soils were
subsequently removed as part of the remedial action for OU 2. Sump four sediments
contained PAH's, phthalates, xylene, toluene, ethylbenzene, benzoic acid and 1,2-
dichloroethylene (1,2-DCE) at levels below concentrations considered protective of
groundwater. (i.e., The concentrations of the compounds detected in the soil were below
the TBC criteria, and therefore, do not pose a threat to the groundwater. Concentrations
of contaminants in soils which exceed the TBC criteria would not be considered to be
protective of groundwater.) These sediments also contained tentatively identified
compounds or TICs. These sumps received surface water runoff from active areas Of the
plant and process wastewaters from production processes which contained low levels of
chemicals. Currently sump three receives surface water run-off from active areas of the
plant which can contain low levels of chemical compounds, as evidenced in the surface
water analyses. Low-level accumulation of these chemicals in the sediments is a
continuing process related to current plant activity. Sump four currently receives the
"blowdown" from the non-contact cooling water tower. Both of these outfalls are State
Pollutant Discharge Elimination System (SPDES) permitted.
Shallow Soils: Soil borings were performed at approximately 50 locations across the Ruco
property with over 150 samples collected and analyzed (see Figures 7 & 8). The investi-
gation identified sporadic, low-level occurrences of chemicals in the surficial soil throughout
the active plant areas including the fill in former sumps five and six. Shallow soils in the
former drum storage area, particularly in the area of boring number 10 (TB-10) (Figure 7),
contained TICs at levels that were of some concern. Because very little or no risk
information exists for these compounds, and TICs have been detected in the groundwater,
the soils in this area have been identified as requiring remediation. In 1984, a soil boring
performed in the area of monitoring well E indicated the presence of tetrachloroethylene
(PCE) at 244 ppm at the surface (Figure 9). This level is not considered to be protective
of groundwater. However, since the boring was performed some time ago, additional
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boring(s) will be'required to confirm the presence of PCE in this area. The occurrence of
PCBs in shallow soils was completely defined and was the subject of a FFS, Proposed Plan
and ROD. These soils were remediated as part of the remedial action executed for OU 2.
Deep Soils: The deep soils (below 12 feet) beneath former sump five did not reveal the
presence of contaminants above concentrations considered protective of groundwater.
The deep soils beneath sump six also contained volatile organics, toluene and ethyl-
benzene below concentrations considered protective of groundwater. The deep soils
beneath sumps three and four did not detect elevated levels of contaminants (see Figure
10).
The deep soils beneath sump one contained compounds such as TCE, PCE, 1,2-DCE,
phthalates, ethylbenzene, toulene, xylene and phenols at levels that could potentially
continue to go into solution and enter the groundwater system. TICs were also detected
at elevated levels in the soils. The soils beneath sump one represent a "hot spot" or a
concentrated area of elevated contaminant levels.
The analytical information obtained during the Rl did not indicate the presence of chemicals
in the surficial (0' - 10') soils of sump two above levels that are considered protective of
groundwater. However, additional sampling will be required for the deeper soils of sump
two to confirm the presence or absence of potential contaminants.
Groundwater: A total of 32 monitoring wells have been installed at the Site (see Figure 9).
Some of these wells were installed prior to the Rl and some were installed as part of the
Rl. The wells are located on, or in the immediate vicinity of the Ruco property and monitor
the upper portions of the Magothy aquifer (135' below the water table) and the unconfined
Upper Glacial aquifer (water table). Based on the sampling conducted prior to, and during
the Rl, the evidence indicates that groundwater beneath the Ruco property contains
chemical constituents above the New York State (NYS) drinking water standards, NYS
groundwater quality standards and EPA maximum contaminant levels (MCLs). Ground-
water containing vinyl chloride monomer (VCM), PCE, DCE, TCE, TICs and arsenic, is
moving downgradient from the Ruco property. Available information from the Rl and other
investigations indicates there are regional occurrences of chloroethylenes and that
additional sources of these contaminants are present. Low levels of some of the
chloroethylenes have been detected upgradient from the Ruco property. (See Figures
11,12,13.)
Surface Water: The surface water existing in sump three contained no chemicals except
for low levels of bis-2-ethylhexyl phthalate which is related to the surface water runoff from
the active plant areas. Sump four contained TICs and PCBs which are most likely related
to surface water run-off at the Site as PCBs were not detected in the sediments of sump
four.
Air: Air sampling was conducted at the Site on two separate occasions during the
Remedial Investigation at both upwind and downwind locations (see Figure 14). Samples
were analyzed for specific volatile organics which were PCE, TCE, 1,2-DCE and VCM.
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These compounds were not detected. Analysis was also performed for respirable
particulates which were below the ACGIH threshold limit values of 0.15 mg/m3. Samples
were collected and analyzed for aroclor on particulates. Aroclor 1248 was detected at
0.00005 mg/m3 at one upwind location. The other samples collected showed no
detections during either sampling event.
In summation, the results of the Remedial Investigation conducted at the Hooker/Ruco Site
indicate the past disposal practices of discharging process wastewater to the sumps has
contaminated the soils and groundwater on the Ruco property. Sampling at the Site
indicates the presence of volatile and semi-volatile organic contaminants in the deep soils
beneath sump one and the surface soils in the former drum storage area above levels
considered protective of groundwater quality. Two additional areas of the property have
been identified as potential sources of contamination. These areas are the soils beneath
sump two and the surface soils near monitoring well E. Additional sampling will be required
to verify the presence of contaminants in these areas and determine if concentrations are
above levels protective of groundwater. If this is the case, the soils beneath sump two and
surface soils around well E will also be addressed by this remedy.
SUMMARY OF SITE RISKS
The following Tables are included in Appendix II for the risk assessment discussion below:
Table a:
Contaminants of concern which indicate the frequency of detection are included in Table
a. The range of concentrations detected, 95% upper confidence levels (95% UCL),
concentration value used in the risk assessment (if other than 95% UCL) are included in
Table g.
Table b:
Exposure pathways considered, pathways quantitatively evaluated clearly distinguishing
between current and future land-uses, populations evaluated (i.e., children, adults) and the
rationale for selection or exclusion of a pathway.
Table c:
*
Noncarcinogenic toxicity values-oral and inhalation and subchronic, if applicable.
Table d:
Noncarcinogenic risk estimates for each exposure pathway and receptor assessed. Total
Site risk.
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Table e:
Carcinogenic toxicity values - oral and inhalation, if applicable.
Table f:
Carcinogenic risk estimates for each exposure pathway and receptor assessed. Total Site
risk.
Table g:
Contaminant concentration data, by medium, used in the environmental evaluation
(assessment of risk to non-human receptors).
Table h:
List of exposure assumptions.
Table i:
List of cumulative Site risks.
EPA conducted a baseline risk assessment to evaluate the potential risks to human health
and the environment associated with the Hooker Chemical/Ruco Polymer Site in its current
and future states. The Risk Assessment focused on contaminants in the air, sediment,
surface water, soils and groundwater which are likely to pose significant risks to human
health and the environment. The summary of the contaminants of concern (COC) in
sampled matrices are listed in Tables a and g for human health and the environmental
receptors, respectively.
EPA's baseline risk assessment addressed the potential risks to human health by
identifying several potential exposure pathways by which the public may be exposed to
contaminant releases at the Site under current and future land-use conditions. Air, soil,
sediment, surface water, and groundwater exposures were assessed for both potential
present and future land use scenarios. The current land use scenario evaluated the
surface water pathway for Site workers and child trespassers (ages 10-18) through dermal
contact. Sediment ingestion, inhalation and dermal contact by Site workers and child
trespassers was also evaluated under the current land use scenario. The surface soil
medium evaluation included the ingestion, inhalation and dermal contact pathways for Site
workers and child trespassers. Off-site residents were also included for the inhalation
pathway under the current land-use scenario. Finally, the current land-use scenario
considered the air inhalation exposure pathway for Site workers, child trespassers and off-
site residents. The future land-use scenarios evaluated the groundwater ingestion,
inhalation and dermal contact pathways for adult and child residents. Dermal contact of
surface water by Site workers and child trespassers was also considered in the future
scenario. The ingestion, inhalation and dermal contact of Site sediments (sumps three and
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four) by Site workers and child trespassers was evaluated. For the surface soils, ingestion,
inhalation and dermal contact were considered for construction workers (future construc-
tion at the Site), Site workers, and child trespassers. The future land-use also evaluated
the inhalation of surface soils pathway for off-site residents. The subsurface soils were
evaluated under the future land-use scenario for ingestion, inhalation and dermal contact
by construction workers. The final pathway considered for the future-use scenario was the
air inhalation exposure pathway for Site workers, child trespassers, off-site residents, and
construction workers. The exposure pathways considered under current and future uses
are listed in Table b. The reasonable maximum exposure was evaluated.
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
amount of a chemical ingested from contaminated drinking water) are compared to the RfD
to derive the hazard quotient for the contaminant in the particular medium. The HI is
obtained by adding the hazard quotients for all compounds across all media that impact
a particular receptor population.
An HI greater than 1.0 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 reference doses for the compounds of concern at the Site are
presented in Table c. A summary of the noncarcinogenic risks associated with these
chemicals across various exposure pathways is found in Table d.
It can be seen from table d that the HI for noncarcinogenic effects from groundwater
ingestion under the reasonable maximum exposure for children and adults is 1.02 x 101
and 4.89 respectively. Therefore, noncarcinogenic effects may occur from the exposure
routes evaluated in the Risk Assessment. The noncarcinogenic risk was attributable to
several compounds including antimony and arsenic.
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
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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 conservative estimate of the risks calculated from the SR
Use of this approach makes the underestimation of the risk highly unlikely. The SF for the
compounds of concern are presented in Table e.
For known or suspected carcinogens, EPA considers excess upper-bound individual
lifetime cancer risks of between 10"4 to 10"6 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 future land-use scenario,
the excess lifetime cancer risk for a child exposed to the highest levels of contaminants by
ingesting the contaminated groundwater is 8.84 x 10"4, which is above EPA's acceptable
risk range. Under the same scenario, adult residents had an excess lifetime cancer risk
of 2.21 x 10~3 attributable to ingestion of contaminated groundwater, and a risk of 5.06 x
10"4, attributable to inhalation of the same contaminated groundwater.
Table i presents the reasonable maximum exposure pathway cumulative risk for present
and future use scenarios at the Hooker/Ruco Site. Adult and child residents off-site (at the
downgradient Ruco fenceline), Site workers, potential future construction workers and child
trespassers are considered the populations with potential multiple pathways of exposure.
The present and future off-site resident exposures were assessed for the soil ingestion and
inhalation scenarios. The future existence of residents at the fenceline exposure scenario
was evaluated for all pathways including groundwater via the ingestion, inhalation and
dermal contact routes, and inhalation and ingestion of airborne soil dust.
The combining of risk levels across pathways resulted in the greatest cumulative upper-
bound cancer risk at the Site. For carcinogens, the combined reasonable maximum
exposure to all adult (off-site and fenceline) residents yielded a potential carcinogenic risk
of 2.83 x 10"3. Potential noncarcinogenic health effects were exhibited, with an HI of 5.15.
Similar results were obtained for child off-site resident exposures. Cumulative carcinogenic
risk was estimated at 1.01 x 10"3, and the noncarcinogenic HI was 1.04 x 101. These risks
for carcinogens at the Site are above the EPA's acceptable risk range of 10"4 to 10"6 (see
Table f). It should be noted that future fenceline resident adult potential carcinogenic risks
were calculated at 2.21 x 10'3, 5.06 x 10"4 and 1.12 x. 10"4 for the groundwater ingestion,
inhalation and dermal contact pathways, respectively. The risks for children are similar.
These future, not current, scenarios constitute the majority of risks to residents. The
estimated total risks are primarily due to vinyl chloride, tetrachloroethene, arsenic, berylium
and bis(2-ethylhexyl)phthalate.
The risk calculations were based on the contaminants detected in on-site soils and
groundwater monitoring wells. It was assumed that in the future groundwater supply wells
would be installed at the downgradient Ruco fenceline and used for residential purposes.
Exposure of residents to groundwater contaminants while showering (inhalation and dermal
contact) and ingestion, utilizing reasonable maximum exposure conditions, contributed to
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the majority of the total cancer risk. Reasonable maximum exposure conditions due to
inhalation of contaminated soil dust from the Site soils contributed very little to the total
cancer risk. These estimates were developed by taking into account various conservative
assumptions about the likelihood of a person being exposed to these media. For example,
it was assumed that the Site's contaminant plume will migrate downgradient to a well
installed by a resident who utilizes the well for potable water supply. This assumption
would require the future development of the downgradient property, currently zoned
industrial, to be residentially developed, and the installation of a private groundwater supply
well which is currently prohibited by County regulations.
The results of the baseline risk assessment indicated that the current use of groundwater
at/beneath the Ruco property was not a risk since no one uses the groundwater for
domestic purposes. On the Ruco property, the soil pathway alone was also determined
not to be a human health risk in both the current and future-use scenarios. However, the
combined soil, sediment and surface water pathway for an on-site worker was estimated
to be 2.05 x 10'4 which is near the upper limit of the risk range. The risks associated with
the TICs in the on-site shallow soils could not be quantified due to the lack of existing
toxicity information for these compounds. The risks to on-site workers from the TICs is
therefore unknown. This unknown risk, combined with the cumulative cross-media
quantified risks to Site workers is cause for potential concern.
Potential risks to the environmental receptors associated with the Hooker Ruco Polymer
Site were identified in the ecological risk assessment. The ecological risk assessment
identified no species, sensitive environments/resources as potential receptors threatened
by the Site contaminants under current Site conditions. The reasonable maximum
environmental exposure is evaluated. 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 ^ssessmenMiterature reviews, field
studies, and toxicity tests, linking contaminant concentrations to effects on ecological
receptors. Risk C/iafacter/zatfo/v-measurement or estimation of both current and future
adverse effects.
The ecological risk assessment began with evaluating the contaminants associated with
the Site in conjunction with the Site-specific biological species/habitat information. The
contaminants of concern at this Site are not expected to significantly impact any ecological
receptors (plant or animal species or habitat).
The Site is fully developed as an industrial facility, and is surrounded by similar types of
land use. There are no natural surface water bodies or wetlands within the Site vicinity.
The contaminants of concern are found in the soils and groundwater which do not appear
to be a habitat for any wildlife that may impact the food chain. The only observed animal
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life at the Site were transient Canadian geese, which are not expected to be part of the
higher food chain, and therefore, any impacts to the geese from the Site are not expected
to affect the area wildlife population. The risk assessment also considered whether there
were present visible signs of impairment to the geese that were attributable to the
contamination found at the Site. No visible signs were observed.
The results of the ecological risk assessment indicate that the contaminated soils and
groundwater at the Site do not pose an unacceptable ecological risk.
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 analytical 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 Risk Assessment provides upper-bound estimates of the risks to populations
near the Site, 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 Risk
Assessment Report.
Actual or threatened releases of hazardous substances from this Site, if not addressed by
the selected alternative or one of the other remedial measures considered, may present
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an imminent and substantial endangerment to the public health, welfare, and 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, four groundwater alternatives, four deep soil
alternatives and three shallow soil remedial alternatives for addressing the contamination
associated with the Hooker Chemical/Ruco Polymer Site.
Construction time refers to the time required to physically construct the remedial alternative.
This does not include the time required to negotiate with the responsible parties for the
remedial design and remedial action, or design the remedy.
GROUNDWATER
The remedial alternatives to address the groundwater medium are as follows:
Alternative 1: No Action
Capital Cost: $ 0
O & M Cost: $ 0
Present Worth Cost: $ 0
Construction Time: No construction is required for the no action alternative.
The Superfund program requires that the "no-action" alternative be considered as a
baseline for comparison of other alternatives. This alternative has been included in order
to provide a datum from which to evaluate the other alternatives. The no action alternative
assumes no additional actions will be taken at the Hooker/Ruco Site to address
groundwater contamination. Contaminated groundwater beneath the Ruco property would
continue to move uncontrolled, downgradient and threaten public water supply wells.
Contaminated soils at the Site would not be addressed by this alternative either. This
would allow contaminants to contribute to the degradation of the groundwater quality by
leaching from the soils. No institutional controls would be implemented which would
provide no controls for groundwater use in the area or well restrictions. This alternative
would not treat any quantity of the contaminated groundwater, requires no engineering
components, treatment components, and has no costs associated with its implementation.
The no action alternative is easily implemented as no effort would be required. The
groundwater ARARs would not be met for this alternative.
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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, further remedial actions may be implemented to remove, treat or otherwise address
the wastes.
Alternative 2: Deed Restrictions with Monitoring
Capital Cost: $ 39,000
O & M Cost: $ 37,000/year
Present Worth Cost:
- 10-year - $ 325,000
- 30-year - $ 608,000.
Construction Time: The time to implement this alternative reflects only the time required to
obtain the necessary deed restrictions and well restrictions. This would require less than
one year to implement.
Alternative 2 involves the use of institutional controls by obtaining deed restrictions or
notations to limit the land use activities at the Ruco property, well permitting to restrict
groundwater use and groundwater monitoring. Deed restrictions would be applied to
restrict the development of the Ruco property to commercial/industrial uses only. This
would be intended to prevent the future development of the Site for residential purposes
and thereby reduce the potential for groundwater exposure beneath the Ruco facility.
Deed restrictions would also be focused on preventing the drilling of groundwater supply
wells or requiring treatment if wells were drilled. This would provide some degree of control
on the groundwater use, well construction activities and control development of the Ruco
property. Annual sampling of the existing monitoring wells on the Ruco property would
provide an assessment of the groundwater contaminant concentrations and mobility.
Annual status reports would be filed with the appropriate regulatory agencies. Implementa-
tion of the institutional controls might require the cooperation of the current property owner,
Ruco Polymer Corporation, and mechanisms to ensure the future enforcement of such
institutional controls. Controls for water use and well construction restrictions are currently
in place in the form of a permit and approval process, Article IV of the Nassau County
Public Health Ordinance, at the county level. Monitoring the status of the impacted
groundwater by collection and analysis of samples is a standard technology that is easily
implementable. This alternative does not involve the treatment of any portion of the
contaminated groundwater or soils. Therefore, no engineering or treatment components
are part of this alternative. ARARs would not be achieved for the groundwater with this
alternative. Capital costs consist of legal fees for obtaining the deed notations and well
permitting, while the O&M costs consist of annual monitoring costs.
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, further remedial actions may be implemented to remove, treat or otherwise address
the wastes.
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Alternative 3: Groundwater Extraction and Treatment with Discharge to an On-Site
Recharge Basin
Capital Cost: $ 4,748,000
O & M Cost: $ 549,000/year
Present Worth Cost:
- 10-year - $ 8,986,000
- 30-year - $ 13,185,000.
Construction Time: It is estimated that the time required to install the groundwater
extraction wells, water treatment and discharge systems would be less than one year.
Under this alternative, groundwater would be pumped from extraction (recovery) wells and
piped to a treatment system utilizing applicable technologies. The exact number of
extraction wells and quantity of water to be pumped would be determined in the design
phase of OU 1. Sufficient extraction rates to achieve a capture area capable of preventing
contamination in the groundwater from moving beyond the Ruco property boundary would
have to be established. This will require the performance of pump tests to measure the
drawdown response in various monitoring wells. For the purposes of the FS, three 8 inch
diameter extraction wells, at depths of 125 feet below grade (bg), screened from 40 bg to
the bottom, and pumping at a combined rate of 100 gpm were used in the development
of the groundwater extraction alternatives. The optimum technology or technologies to
treat the pumped groundwater would also be determined during the design phase.
Treatability studies will be required to evaluate which technologies will be most effective in
treating the contaminants in the groundwater. However, for the purpose of evaluating this
potential remedy, the FS Report was required to make some reasonable assumptions.
These assumptions were based on groundwater modeling, current knowledge of existing
waste treatment practices, availability, and standard engineering principles. At 100 gpm,
this alternative would treat approximately 53,000,000 gallons of groundwater per year. The
effluent from the groundwater treatment process would be discharged to sump three on
the Ruco property. Deed restrictions and monitoring would also be applied as described
in Alternative 2 above. The O&M would include electric power, servicing of pumps and
motors, periodic well development, treatment system operation and annual monitoring.
The effectiveness of the proposed extraction wells was evaluated using the computer
model described in Appendix B of the FS Report. According to the conceptual model, the
recovery wells will prevent the downgradient migration of impacted groundwater. The
treatment of the groundwater at the Ruco property would be expected to reduce the
toxicrty, mobility and volume of the waste permanently through treatment. Installing the
extraction wells and treatment system is technically feasible as the necessary equipment,
services and materials are readily available for constructing the systems. The groundwater
treatment would comply with the substantive requirements of the ARARs for groundwater
discharge criteria (SPDES permit process). The extraction and treatment systems would
potentially be able to obtain the groundwater quality criteria in the aquifer or at least
achieve upgradient contaminant levels.
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This alternative is considered a long-term response action which may require up to 30
years or more to implement. Because this alternative may result in contaminants remaining
on-site above health-based levels during it's implementation, CERCLA requires that the Site
be reviewed every five years. If justified by the review, further remedial actions may be
implemented to remove, treat or otherwise address the wastes.
Alternative 4: Groundwater Extraction and Treatment with Discharge to Leaching
Galleries
Capital Cost: $ 4,867,000
O & Ivl Cost: $ 549,000/year
Present Worth Cost:
- 10-year - $ 9,105,000
- 30-year - $ 13,304,000
Construction Time: The estimated time to construct this alternative would be less than one
year.
The extraction and treatment of groundwater in this alternative is the same as described
in Alternative 3 above. The only difference between Alternative 3 and this alternative would
be the point of discharge for the treated groundwater. Under this alternative the treated
groundwater would be discharged to leaching galleries on the Ruco property. The
proposed leaching gallery area would be approximately 75 by 75 feet, would be completed
to a depth of 5 feet, and be located behind the administration building on the Site. The
effectiveness for this alternative is similar to Alternative 3. Leaching galleries are a proven
means of water recharge and the geology in this area would be compatible to the use of
this technology.
This alternative is technically feasible, with the implementation of the extraction and
treatment processes being the same as Alternative 3. Additional piping and trenching
would be required as well as the construction of the leaching galleries.
Because this alternative may result in contaminants remaining on-site above health-based
levels during its implementation, EPA policy calls for the Site to be reviewed every five
years until health-based levels are met. If justified by the review, further remedial actions
may be implemented to remove, treat, or otherwise address the wastes.
Deep Soils
The FS also examined alternatives to address the deep and shallow soil contaminants
remaining at the Site that would be potentially contributing to the degradation of the
groundwater quality. All of the alternatives to address the soils in sump one, with the
exception of the no action alternative, would require the existing concrete settling tanks to
be removed. Prior to removal, the tanks would be cleaned and then subjected to waste
characterization tests followed by disposal in a RCRA regulated Subtitle C landfill if
necessary, or a Subtitle D landfill. The alternatives to address the deeper soils also include
two scenarios based on the results of additional soil sampling to be conducted in the pre-
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design/design phase of OU 1. The alternatives present the costs for sump one alone and
the costs for sump one and sump two based on the results of the soil sampling performed
in sump two.
The alternatives for the deep soils are as follows:
Alternative 1: No Action
Capital Cost: $ 0
O & M Cost: $ 0/yr
Present Worth Cost: $ 0
Construction Time: This alternative does not require construction.
The Superfund program requires that the "no-action" alternative be considered as a
baseline for comparison of other alternatives. The no action alternative requires no
changes to be made to the existing Site conditions. Therefore, there would be no
technical, engineering or treatment components of this alternative. The TBC criteria (soil
cleanup values that would protect groundwater), would not be achieved by implementing
this alternative. Precipitation would continue to infiltrate the soils and most likely flush the
soluble contaminants into the groundwater. Eventually, over a long period of time, the
soluble compounds would be flushed from the soil and not leach into the groundwater at
levels above the groundwater criteria. The insoluble contaminants in the soil would not be
expected to readily leach from the soil into the groundwater and would remain sorbed to
soil particles.
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,
further remedial actions may be implemented to remove, treat or otherwise address the
wastes.
Alternative 2: Capping of Sump One (and Possibly Sump Two)
Capital Cost:
Sump One alone - $ 213,000
Sump One and Sump Two - $ 345,000
O & M Cost:
Sump One - $ 5,000/yr
Sump One and Sump Two - $ 7,000/yr
Present Worth Cost:
For Sump One alone;
-10-year-$251,000
- 30-year - $289,000
For Sump One and Sump Two;
- 10-year - $ 396,000
- 30-year present - $ 446,000.
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Construction Time: This alternative would require approximately two to three months to
construct.
This alternative involves installing a cap over the potential soil remediation area, sump one,
in accordance with modified RCRA Subtitle C performance specifications. The proposed
cap would occupy an area of approximately 13,500 square feet. Based on the results of
additional post-ROD soil borings in sump two, the area of the proposed cap would be
extended. If contaminants are found to be present in sump two above the protection of
groundwater criteria, sump two would also require capping. This would require the size
of the proposed cap to be approximately 20,500 square feet. The associated costs of the
extended cap would also increase as have been indicated above. The proposed cap
would consist of the following layers above the existing soil: a geosynthetic clay liner
(comprised of geotextile outer layers with an inner layer of low permeability sodium
bentonrte), a 60-mil high-density polyethylene (HOPE) geomembrane liner, 6 inches of
gravel acting as a drainage layer, a 20-mil filter fabric, 12 inches of gravel subbase and 6
inches of asphalt.
The cap would provide for the protection of groundwater quality by removing the exposure
of the contaminants in the soils to the infiltration of precipitation. The downward movement
of water through the soils (percolation) would not occur with the cap in place. Leaching
of contaminants from the soil into the groundwater would be greatly reduced. Capping
would not reduce the concentration of the compounds in the soils, but would reduce their
mobility. The TBC criteria for soils would not be met, however, groundwater quality would
be somewhat protected by removing the migration pathway to the groundwater.
The installation of a cap would require a moderate design effort followed by approximately
two to three months of construction and moderate effort in reporting and documentation.
Periodic inspections to ensure the integrity of the cap would be required as part of the
O&M.
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, further remedial actions may be implemented to remove, treat or otherwise address
the wastes.
Alternative 3: Soil Vapor Extraction and Capping
Capital Cost:
Sump One alone - $ 332,000
Sump One and Sump Two - $ 515,000
O&M Cost:
Sump One - $ 48,000/yr
Sump One and Sump Two - $ 56,000/yr
Present Worth Cost:
Sump One alone;
- 10-year - $ 703,000
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-30-year-$1,070,000
For Sump One and Sump Two;
- 10-year - $ 948,000
-30-year-$1,378,000
Construction Time: It is estimated that the time to construct the soil vapor extraction system
and cap would be less than one year.
Alternative 3 for the deep soils is the same as Alternative 2 above, with the addition of the
soil vapor extraction (SVE) system. This alternative involves the installation of soil vapor
extraction welis in sump one (and possibly sump two, based on subsequent soil sampling)
and treating the collected vapor prior to discharge to the atmosphere. Air inlet wells would
be installed at the cap perimeter to enhance the availability of air to the soils and the vapor
removal. The SVE and air inlet wells would be drilled to an approximate depth of 50 feet
below ground (bg), be approximately 4 inches in diameter, and be screened from 20 feet
bg to the bottom. The SVE piping would be installed beneath the cap (described in
Alternative 2). The SVE wells would be joined by a common header pipe located in the
treatment shed. This pipe would be connected to a vapor phase separator (demister)
where moisture would be removed from the air stream. The demister would be connected
to a positive displacement blower, which provides a negative vapor pressure gradient to
the subsurface soil. For the purposes of the FS, it was conservatively assumed that the
discharge from the blower would undergo treatment using vapor-phase carbon prior to
being vented to the atmosphere. The cap would act as a seal to prevent air from entering
near the extraction wells (where the pressure gradient is greatest) and would promote a
radial horizontal subsurface air flow. A radial flow forces air to be drawn over a greater
distance, thereby contacting a greater volume of soil. The actual system parameters would
be determined in the remedial design phase.
SVE has been a proven technology for soils impacted by volatile organic carbon (VOCs)
contaminants. This process has been employed at many sites at both small and large-
scale field applications. The effectiveness of SVE is highly dependent upon the volatility
of a particular contaminant as measured by Henry's constant (generally a Henry's constant
of greater than 0.001 atmosphere cubic meter/mole or atm-m3/mol is required for SVE to
be effective). Based on the Henry's constants for the Site specific compounds, SVE would
be effective for treating PCE, TCE and 1,2-DCE but not for phenol, di-n-butyl phthalate and
TICs. It is expected then, SVE may be effective for some of the contaminants, but not for
others as indicated above. The effectiveness of SVE on removing low-levels of VOC
contaminants from the soils has not been fully demonstrated. SVE would probably not be
able to remove VOCs below the low ppm range. Therefore, the protection of groundwater
criteria may not be achieved. The SVE system would be required to meet the substantive
requirements for air emission discharge criteria which is considered an ARAR. Because
the soil in the potential remediation area consists of medium to coarse sand and fine to
coarse gravel, SVE is well suited for the geologic conditions at the Site. The necessary
equipment is readily available and the process is easily implemented.
Because this alternative may result in contaminants remaining on-site above health-based
levels, CERCLA requires that the Site be reviewed every five years. If justified by the
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review, further remedial actions may be implemented to remove, treat or otherwise address
the wastes.
Alternative 4: Soil Flushing
Capital Cost:
Sump One - $ 16,000
Sump One and Sump Two - $ 25,000
0 & M Cost:
Sump One - $ 1,000/yr
Sump One and Sump Two - $ 3,000
Present Worth Cost:
Sump One;
- 10-year - $ 26,000
- 30-year - $ 37,000
Sump One and Sump Two;
- 10-year - $ 45,000
- 30-year - $ 65,000.
Construction Time: It is estimated that the time to construct the soil flushing system would
be less than one year.
This alternative would consist of flushing the contaminants from the soils in sump one, and
possibly sump two, by the deliberate discharge of water to the sumps. The discharged
water would then percolate down through the contaminated soil and flush out the soluble
contaminants. The contaminant compounds, now dissolved in the water, would be
recovered through the use of extraction wells. This alternative requires the use of a
groundwater or vadose zone recovery system which could be either a separate extraction
system designed for the soils only, or, in this case, as part of the extraction and treatment
system described in the alternatives to treat the groundwater. This type of system would
essentially be an injection and recirculation process. In this case, treated groundwater
from the groundwater extraction and treatment system would be discharged to sump one.
Sump two would also be included if the results of subsequent soil borings indicate the
presence of soil contamination in excess of the soil cleanup criteria that is considered
protective of groundwater. The conceptual model developed in the FS, for the purposes
of evaluating this alternative, estimated that a total of approximately 10 gpm could be
discharged to sump one and sump two without overloading the groundwater recovery
system. In comparison with the estimated rate of extraction (100 gpm), the rate of
recharge to sumps one and two is about 10% of the extraction rate. The discharged water,
after percolation through the sump soils, would be recovered by the groundwater extraction
wells and treated by the same method as the extracted groundwater. The type of
discharge system and placement of the extraction wells would be determined during the
design process.
This alternative would be effective for those contaminants that are relatively soluble, or likely
to dissolve in water. The contaminants that are most soluble, such as the VOCs (e.g.,
TCE, PCE, VCM, phenol, 1,2-DCE and, based on preliminary information, the TICs) would
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be readily dissolved and flushed from the soil. These compounds have all been observed
in the groundwater beneath the Site. The more insoluble compounds, such as the phthal-
ates, would not dissolve as easily, or in some cases, not at all. These insoluble
compounds tend to adsorb onto small soil particles and be persistent in the soil. The soil
flushing alternative for these compounds would be less effective. However, the flushing of
the soil would recover some of these adsorbed contaminants through the movement and
capture of these small soil particles. Any contaminants that could not be dissolved, or
particles that could not be mobilized through the soil flushing would not be expected to
enter the groundwater system in sufficient quantity to degrade the future groundwater
quality.
The technology and materials to implement this technology are readily available and not
difficult to install. Achievement of the TBC soil criteria would be evaluated as part of the
five year review process.
Because this alternative may require more than five years to complete and result in
contaminants remaining on-srte above health-based levels during it's implementation, EPA
policy calls for the Site to be reviewed every five years until health-based levels are met.
If justified by the review, further remedial actions may be implemented to remove, treat or
otherwise address the wastes.
Shallow Soils
The alternatives identified in the FS to address the shallow soils examined two potential
scenarios. The first scenario would involve addressing the soils in the former drum storage
area only. The second scenario would include the soils around monitoring well E as well
as the former drum storage area based on the results of pre-design soil sampling.
The alternatives to address the shallow soils are:
Alternative 1: No Action
Capital Cost: $ 0
O & M Cost: $ 0/yr
Present Worth Cost:
- 10-year - $ 0
- 30-year - $ 0 respectively.
Construction Time: No construction is required for this alternative.
The Superfund program requires that the "no-action" alternative be considered as a
baseline for comparison of other alternatives. The no action alternative requires no
changes to be made to the existing Site conditions. Therefore, there would be no
technical, engineering or treatment components of this alternative. The TBC criteria (soil
cleanup values that are considered protective of groundwater), would not be achieved by
implementing this alternative. Precipitation would continue to infiltrate the soils and most
likely flush the soluble contaminants into the deeper soils and eventually, the groundwater.
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Workers at the fluco Polymer Site would potentially be exposed to contaminants in the
surficial soils.
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, further remedial actions may be implemented to remove, treat or otherwise address
the wastes.
Alternative 2: Capping
Capital Cost:
Former Drum Storage Area Only - $ 86,000
Drum Storage Area plus Well E Area - $ 95,000
O & M Cost:
Drum Storage Area - $ 3,000/yr
Drum Storage Area plus Well E Area - $ 3,000/yr
Present Worth Cost:
Former Drum Storage Area;
- 10-year - $ 107,000
- 30-year - $ 128,000
Drum Storage Area plus the Well E Area;
-10-year-$121,000
- 30-year - $ 146,000
Construction Time: It is estimated that the time to construct the cap(s) would be two to
three months.
This alternative involves installing a cap over the potential soil remediation area, the former
drum storage area, in accordance with modified RCRA Subtitle C performance specifica-
tions. The proposed cap would occupy an area of approximately 3,850 square feet.
Based on the results of additional post-ROD soil borings to be performed in the area near
monitoring well E, a cap may be required. If contaminants are found to be present in the
surficial soils around monitoring well E above levels considered protective of groundwater,
this area would also require capping. Additional soil sampling may be required to delineate
the extent of the cap. This would require an additional area to be capped of approximately
1,160 square feet. The proposed cap would consist of the following layers above the
existing soil: a geosynthetic clay liner (comprised of geotextile outer layers with an inner
layer of low permeability sodium bentonrte), a 60-mil high-density polyethylene (HDPE)
geomembrane liner, 6 inches of gravel acting as a drainage layer, a 20-mil filter fabric, 12
inches of gravel subbase and 6 inches of asphalt.
The cap would provide for the protection of groundwater quality by removing the exposure
of the contaminants in the soils to precipitation. The downward movement of water
through the soils (percolation) would not occur with the cap in place. Leaching of
contaminants from the soil into the groundwater would be greatly reduced. The cap would
also eliminate any potential exposure of Site workers to surficial soil contaminants.
Capping would not reduce the concentration of the compounds in the soils, but would
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reduce their mobility. The TBC criteria for soils would not be met, however, groundwater
quality would be somewhat protected by removing the migration pathway to the
groundwater.
The installation of a cap would require a moderate design effort followed by approximately
two to three months of construction and moderate effort in reporting and documentation.
Periodic inspections to ensure the integrity of the cap would be required as part of the
O&M.
Because this alternative would result in contaminants remaining on-sfte above health-based
levels, CERCLA requires that the Site be reviewed every five years. If justified by the
review, further remedial actions may be implemented to remove, treat or otherwise address
the wastes.
Alternative 3: Excavation and Off-Site Disposal in a Landfill
Capital Cost:
Former Drum Storage Area only - $ 482,000
Drum Storage Area plus Monitoring Well E Area - $ 758,000
O&M Cost: There are no O&M costs associated with excavation and off-site disposal
Present Worth Cost:
Former Drum Storage Area;
- 10-year - $ 482,000
- 30-year - $ 482,000 This represents the one-time investment of the capital costs.
Drum Storage Area plus Monitoring Well E Area;
- 10-year - $ 758,000
- 30-year - $ 758,000 This represents the one-time investment of the capital costs.
Construction Time: It is estimated that the time to construct the soil flushing system would
be less than one year.
This alternative would require the excavation of the surficial soils in the former drum storage
area, specifically the area around TB-10. The proposed excavation would remove an
estimated total soil volume of 445 cubic yards from the former drum storage area. Based
on the results of additional post-ROD soil borings in the area near monitoring well E, an .
additional area of excavation may be required. If contaminants are found to be present in
the area around monitoring well E above the protection of groundwater criteria, this area
would also require excavation. This would increase the total volume of the soil to be
excavated by approximately 265 cubic yards. Additional soil sampling in the area of
monitoring well E may be required to delineate the extent of the soils to be removed.
The excavated soils would then be tested to determine if they could be classified as a
characteristic hazardous waste. If the soils were determined to be a characteristic hazard-
ous waste the RCRA Land Ban restrictions would be an ARAR. This would mean the soils
would require treatment before disposal. For the purposes of evaluating this alternative in
the FS, the assumption was made that the soils would not require treatment prior to
disposal. Therefore, the costs cited above do not reflect any potential treatment costs.
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This alternative would be effective in permanently removing the contaminants from the Site,
thereby eliminating the potential for the contaminants to migrate to the groundwater and
removing any risks associated with direct contact with the soils. Excavation is easily imple-
mented through the use of standard construction equipment and would require one or two
months of field work to complete. No O&M requirements are involved with the excavation
of the shallow soils alternative.
This alternative would result in the complete removal of contaminants in the shallow soils
identified as the former drum storage area and the area around monitoring well E.
Therefore, the Site would not require a five year review.
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 addresses 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 institu-
tional controls.
2. Compliance with ARARs addresses whether or not a remedy would meet all of the
applicable, or relevant and appropriate requirements of federal and state environ-
mental statutes and requirements 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 alternatives:
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
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during the construction and implementation periods until cleanup goals are
achieved.
6. Implementability is the technical and administrative feasibility 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.
o Overall Protection of Human Health and the Environment
Groundwater:
Alternative 1, no action, would not provide for the protection of human health for the future
potential residential use of the area at the Ruco Polymer downgradient fenceline.
Contaminated groundwater would continue to migrate downgradient degrading the aquifer.
Exposure to the contaminants in the groundwater would present an unacceptable health
risk to the users. Alternative 2, Deed Restrictions with Monitoring, would provide some
level of protection to the potential users of groundwater at the Ruco property by restricting
groundwater uses beneath the Ruco facility. However, future risks to the public would still
remain as described for Alternative 1, above. Alternatives 3 and 4 would provide the
greatest level of protection to potential downgradient residents by controlling the migration
of groundwater contaminants. Groundwater beneath the Ruco property would be captured
and treated before downgradient receptors could be exposed. Groundwater pump and
treat also has the potential to prevent further degradation to a sole source aquifer and
restore the aquifer beneath the Ruco property to its beneficial use.
Deep Soils:
The no action alternative (Alternative 1) would not provide protection of human health
because the contaminants in the soil would continue to leach into the groundwater and
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Deep Soils:
There are currently no promulgated standards for contaminant levels in soils at the Federal
or State level. For this Site, EPA is using the soil cleanup values developed by NYSDEC
that are considered protective of groundwater quality, as TBC criteria for organic chemicals
in soil. The TBC values, as discussed above, are taken from NYSDEC's TAGM (Table 4).
Alternative 1, no action, would not meet the TBC soil criteria. Contaminants in the soil
would not be treated or contained in any manner, resulting in continued leaching into the
groundwater system. Alternative 2, capping, would not meet the TBC criteria either.
However, the mobility of the contaminants would be reduced by eliminating the exposure
to infiltrating precipitation. Alternatives 3 and 4 would not be expected to achieve the TBC
criteria for all the contaminants in the soil. Some of the compounds would be remediated
to the TBC levels. Contaminants with low solubility would not be removed by flushing while
contaminants with low volatility would not be removed by SVE. Based on the chemical
characteristics of the compounds at the Site (more soluble compounds than volatile
compounds), the soil flushing alternative would have a greater potential to achieve the TBC
criteria than SVE.
Shallow Soils:
Alternatives 1 and 2 would not meet the TBC soil criteria as the contaminants would remain
in the soil. Alternative 1 would pose a potential threat to groundwater quality. Alternative
2, however, would reduce the mobility of the contaminants by eliminating the exposure to
precipitation. Alternative 3, excavation, would meet the TBC criteria by removing the
contaminated soil from the Site.
o Long-Term Effectiveness and Permanence
Groundwater:
Alternative 1 would not be effective or permanent in providing protection to public health
over the long-term. Contaminated groundwater would continue to migrate from the Site
posing a risk to potential receptors. Alternative 2 would provide some degree of
effectiveness by limiting the potential groundwater exposure pathway through institutional
restrictions. However, the ability to enforce such restrictions over the long-term is
considered unreliable. Therefore, the permanence of this alternative is questionable.
EPA's policy is not to rely on the use of institutional controls alone to address contamina-
tion at a site. Monitoring would be required to track the presence and concentration of
contaminants in groundwater entering and leaving the Ruco property. Contaminants would
remain in the groundwater posing a potential risk to a receptor. Alternatives 3 and 4 would
be expected to be effective in providing protection to human health by controlling the
migration of contaminants in the groundwater. Permanence of protection would be
achieved by removal of the contaminants from the groundwater through treatment. These
alternatives also have the potential to restore the groundwater to usable quality or, at a
minimum, clean up the aquifer under the Ruco property to upgradient contaminant levels.
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therefore, degrade the groundwater quality. The potential for exposure through the
groundwater migration pathway would then present a human health risk. Alternatives 2,
3 and 4 all offer.protection by either, limiting the mobility of the contaminants, as is the
case with capping, or by removing and capturing the contaminants through SVE or soil
flushing. This would eliminate the potential contribution of the contaminants in these areas
to the degradation of the groundwater (sole source aquifer) quality.
Shallow Soils:
The no action alternative for the shallow soils would most likely not be protective of human
health due to the existence of a potential exposure pathway. While this exposure pathway
is somewhat limited (to workers at the Ruco plant) and unquantifiable (risk information for
the TICs does not exist), the potential for exposure still exists. More importantly, the
contaminants in these areas present a potential source of future groundwater contamina-
tion. The resultant groundwater contamination would then present potential human health
risks. Alternative 2, capping, would provide the necessary level of protection to the
groundwater and human health by eliminating the potential migration and exposure
pathways. Alternative 3, excavation, would provide the greatest level of protection by
removing the contaminants from the Site permanently.
o Compliance with ARARs
Groundwater:
Alternatives 1 and 2 would not meet the chemical-specific ARARs that have been identified
for this Site, namely the NYS Groundwater Quality Criteria and Federal MCLs. Contami-
nants in the groundwater would remain in the aquifer at levels above established ARARs.
Alternatives 3 and 4 would be expected to achieve the groundwater chemical-specific
ARARs through the application of extraction and treatment. Regional occurrences of
volatile organics in the groundwater upgradient of this Site however, may make this goal
unachieveable. The extraction and treatment of the groundwater beneath the Ruco
property would be expected to, at a minimum, achieve upgradient groundwater quality
levels. The extraction and treatment of the groundwater would, of course, require the
discharge of the treated water on the Ruco property. The appropriate discharge
standards, identified in Table 3, would be expected to be achieved through the treatment
process. The substantive requirements of any State Pollutant Discharge Elimination System
(SPDES) permit would be met for these alternatives. If the treatment of groundwater
should require the application of air stripping technology, the appropriate air emissions
ARARs, National Ambient Air Quality Standards (NAAQS) and New York State regulations
6 NYCRR (identified in Table 5), would be met. TBC criteria for air emissions, NYS Draft
Guidelines for Air Emissions and EPA's Air Stripper Directive, would also be used to
regulate air emissions at the Site from groundwater treatment.
There are no action-specific or location-specific ARARs identified for the groundwater
alternatives.
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The ability of the treatment system to meet the remedial action objectives has not yet been
proven. However, based on current knowledge of remedial technologies, it is expected
that a treatment system can be designed to achieve the necessary performance
specifications. Operation and maintenance of the extraction and treatment system would
be required including the servicing of pumps and motors, periodic well development and
treatment operation. The extraction and treatment system would be monitored to measure
its performance. A five-year review would also be required to evaluate the effectiveness
of these alternatives.
Deep Soils:
While the deep soils at the Site have not been identified as a direct risk to human health
or the environment, they are evaluated here for their potential to be a continuing source
of contamination to the groundwater.
Alternative 1 would not provide any long-term effectiveness or permanence. Contaminants
in the soil would continue to enter the groundwater system and pose a risk to potential
receptors. Alternative 2 would reduce contaminant mobility and, therefore, be effective in
greatly reducing the migration of contaminants into the groundwater. The effectiveness of
capping for contaminants in the deeper soils near the groundwater table and capillary
fringe, contains a degree of uncertainty. It is possible that the seasonal fluctuations (rise
and fall) in the groundwater table, or the lateral migration of infiltrating precipitation, could
potentially flush contaminants from the soil and into the groundwater system. The
installation of a cap would require operation and maintenance to insure the integrity of the
cap. A five-year review would also be required since contaminants would remain on the
Ruco property. Alternative 3, SVE, would provide long-term effectiveness for some of the
compounds by permanently removing them from the soil. However, other contaminants
at the Site are not effectively removed by SVE due to their low volatility. These remaining
contaminants may possess solubilities that would allow them to be transported into the
groundwater. Following the application of the SVE, capping of the sumps would be applied
to reduce or eliminate the mobility of the remaining contaminants. A degree of uncertainty
exists for the effectiveness of capping as discussed for Alternative 2, above. O&M would
be required to operate the SVE system and maintain the cap. Periodic monitoring would
be required to evaluate the performance of the SVE. A five-year review would be required
to determine the alternative's effectiveness in protecting the groundwater quality.
Alternative 4 would be expected to be effective in the long-term by removing the
contaminant compounds that are most soluble and, therefore, most likely to be transported
into the groundwater. By capturing the contaminants once they have been flushed out of
the soil, they are permanently removed from the Site through treatment (See discussion
of the effectiveness of groundwater pump and treat, above and implementability, below).
Any remaining contaminants would not be expected to leach from the soils due to their low
solubility. This alternative would require the O&M of the extraction, treatment and recharge
systems. Periodic monitoring would be involved to check the functioning of the systems.
A five-year review would be required to evaluate the effectiveness of the soil flushing and
determine if further steps would be required to protect the groundwater quality.
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Shallow Soils:
No action, Alternative 1, would not provide long-term effectiveness or permanent protection
of the groundwater quality. Soluble contaminants would be able to leach into the
groundwater system by exposure to precipitation. Alternative 2 would be effective in
addressing the surficial soils by greatly reducing the mobility of the contaminants and thus,
their ability to enter the groundwater system. Tliis is expected to be effective in the long-
term provided the cap is maintained permanently. The maintenance of any structure
permanently has inherent uncertainties such as the ability to enforce and regulate. O&M
would ensure the cap's structural integrity. Alternative 3 would provide long-term
effectiveness and permanence through the removal of the contaminants from the Site.
Disposal of the soil in an off-site landfill would be required. No O&M or five-year review
would be involved with the excavation alternative.
o Reduction in Toxicity. Mobility, or Volume
Groundwater:
Alternatives 1 and 2 do not reduce the toxicity, mobility or volume of contaminants present
in the groundwater. The movement of contaminated groundwater would be unrestricted
allowing downgradient migration and the existence of a potential exposure pathway. Such
an exposure pathway would create an unacceptable risk to human health. Also, these
alternatives do not satisfy the statutory preference for treatment that reduces toxicity,
mobility or volume as a principal element. Alternatives 3 and 4 would both reduce the
mobility of the contaminants by controlling the movement of the groundwater beneath the
Ruco property through a pumping system. (The conceptual design developed in the FS
estimated that a minimum of 100 gal/min would be required to prevent the migration of
contaminated groundwater beneath the Ruco Property. At 100 gal/min, the pump and
treat alternatives would treat approximately 53,000,000 gal/year.) Migration of the
contaminants in the groundwater to downgradient potential receptors would be eliminated.
The extraction and treatment of the groundwater would also reduce the volume of the
contaminants present in the groundwater system. The volume and toxicity of the actual
contaminant compounds may or may not be reduced depending of the type of technology
employed by the treatment system. A technology such as Ultra Violet (UV) oxidation would
physically destroy some of the contaminant compounds resulting in a reduction of volume
and toxicity, while a technology such as Granulated Activated Carbon (GAC) would merely
filter and collect the contaminants. The exact type of technology to be used in the
treatment system would be determined in the design phase through the use of treatability
studies. The primary objective of Alternatives 3 and 4 would be to reduce the mobility of
the contaminants. This would address the primary objective of preventing further
contribution to downgradient groundwater contamination and eliminate the exposure
pathway to potential receptors. These alternatives also have the potential to restore the
groundwater beneath the Ruco facility (a sole source aquifer) to a usable quality through
extraction and treatment.
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Deep Soils:
Alternative 1 would not result in the reduction of the toxicity, mobility or volume of the
contaminants present at the Site. If no action were taken at the Site, contaminants in the
sump(s) would continue to leach into the groundwater resulting in greater mobility. While
the contaminant concentrations would decrease in the soil the resultant volume of
contaminated material would also increase as contaminants spread through the
groundwater. Alternative 2 would not decrease the toxicity or volume of the contaminant
compounds in the soil, but would reduce the mobility of most contaminants in the soil.
Capping would prevent the infiltration of precipitation and the resultant leaching of
compounds into the groundwater. This would meet the primary objective of protecting
groundwater quality. Alternatives 3 and 4 would initially increase the mobility of some of
the contaminant compounds in the process of extracting them. In the process of
recovering and treating the contaminants, these alternatives would reduce contaminant
mobility and volume of contaminated media. Alternative 3 would increase the mobility of
compounds with a higher volatility through vaporization, then capture the contaminants
through vacuum extraction. If necessary, the vapor would be treated through GAC which
would not reduce the actual contaminant compound volume. As part of Alternative 3, a
cap would be installed to enhance the operation of the SVE system. This would also
reduce the mobility of any contaminants remaining in the soil after completion of the SVE
operation. Alternative 4 would also increase the mobility of the more soluble compounds
initially so that they may be recovered through extraction of groundwater. The extraction
and treatment of the water flushed through the soil would reduce the volume of
contaminated soil. The volume and toxicity of contaminant compounds may also be
reduced depending on the type of treatment technologies selected in the remedial design
(see Groundwater Alternatives above). Alternatives involving the generation of treatment
residuals would require that the generated material be disposed of in an appropriate off-site
disposal facility. This would be determined by conducting a TCLP test on the residuals.
Both Alternatives 3 and 4 would meet the primary criteria of protecting groundwater quality.
Shallow Soils:
Alternative 1 would not reduce contaminant toxicity, mobility or volume. Contaminant
compounds would remain in the soils and act as potential sources to groundwater
contamination and contribute an unknown, unquantifiable risk to Site workers. Alternative
2, which does not include treatment, would reduce only the mobility of the contaminants
by eliminating their exposure to the elements. This would require the construction of a cap
to cover an area of approximately 3,850 square feet for the Former Drum Storage Area and
1,160 square feet for the Well E Area. The volume of contaminated media and volume of
the contaminant compounds would remain the same. The toxicity of the compounds in the
soil would also remain unchanged. Although Alternative 2 would not reduce the volume
or toxicity of contaminant compounds, the emplacement of a cap would achieve the
primary objective of protecting groundwater quality and eliminate a potential exposure
pathway as well. Alternative 3 would reduce the mobility of the contaminant compounds
in the shallow soils at the Site by excavating the soils and disposing of them off-site. The
toxicity and volume of the contaminant compounds at the Site would be reduced by off-
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site disposal. The relative toxicity and volume of the contaminants in the soil to be
disposed of would not change. Excavation would remove the contaminated soil from the
Site, but, would not reduce the actual levels of contaminant compounds in the soil being
disposed of. Before disposal the soil would have to be tested to determine if it qualifies as
a characteristic hazardous waste as defined by RCRA. If it is not a hazardous waste, it
would not be subject to the Land Disposal Restrictions (LDRs). If it was determined to be
a hazardous waste, treatment would be required prior to off-site disposal. Such treatment
might reduce the toxicity or volume of the contaminants in the soil. Alternative 3 would also
result in achieving the primary objective of protecting the groundwater quality.
o Short-Term Effectiveness
Groundwater:
No immediate risks to human health have been identified through exposure of contaminat-
ed groundwater beneath the Ruco property because there is currently no use of the
groundwater beneath the Ruco property. Therefore, all of the groundwater alternatives
should be effective in protecting human health and the environment in the short-term (until
construction is complete). For Alternatives 3 and 4, no short term risks to the public are
expected to be created by constructing the groundwater extraction and treatment systems.
The time required to construct these alternatives and render them operational and
functional, should be less than one year. Once operational, Alternatives 3 and 4 should
be effective in controlling the migration of contaminated groundwater downgradient of the
Ruco property. Longer-term effectiveness and protection is provided by these alternatives
as the systems operate over time to remove contaminants from the aquifer. The operation
of the extraction and treatment systems are expected to be long-term activities which are
not anticipated to present a risk to the public. Depending on exactly which technologies
are selected for the treatment system, wastes may be generated that have to be treated
(e.g., vapors from air stripping) or disposed of off-site (e.g., sludge from filtering
processes): The generation of vapors would be regulated and controlled through the
application of vapor control technology such as a carbon absorption unit. The off-site
disposal of generated wastes would not create a significant increase in the vehicular traffic
in the area as only small quantities would be generated. These activities would be
conducted in a manner that would not present a risk to the public.
Deep Soils:
Alternative 1, no action, would not present any short-term risk due to the fact that the
contaminants are present at depth which leaves no opportunity for immediate exposure.
However, beyond the immediate future, the no action alternative presents the potential for
groundwater degradation as well as the potential for future human exposure. Alternatives
2 and 4 are not expected to present any short-term risks through the construction and
implementation of the remedies. Alternative 2 may involve a slight increase in truck traffic
in the area to transport in materials to construct the cap. This impact is expected to be
minimal as the area is industrial and truck traffic is a routine occurrence. Alternative 2
would require only a few months to construct and would therefore provide the most rapid
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short-term level -of protection. However, the immediate benefit of protection is off-set by
uncertainties in capping's long-term effectiveness and the ability of Alternatives 3 and 4 to
be more permanent. Alternative 3 would not present any risks during construction (which
would require less than one year), however, the operation of the SVE system would
generate volatile organic vapors by extracting them from the soil. These vapors,
depending on their concentration, may require treatment in the form of carbon adsorption
or a burn unit to destroy the vapors. The SVE system is not expected to present a risk
when properly monitored and operated. Alternatives 3 and 4 would require slightly longer
construction times than Alternative 2, and would therefore, take a greater amount of time
than Alternative 2 to provide protection. However, Alternatives 3 and 4 would be more
effective in actually removing contaminants through treatment in the short-term which would
provide a greater level of protection in the long-term.
Shallow Soils:
Alternatives 1 and 2 are not expected to create any short-term hazards or risks through
their implementation. As discussed above, capping may slightly increase the truck traffic
at the Site though this would not be a significant problem. Alternative 3 may present some
low level, short-term risks through the excavation activities. Excavation would create the
potential for the generation of fugitive dust emissions. However, such emissions could be
controlled through simple dust suppression techniques. Off-site transport of excavated
materials may also present a potential risk to residents along the transport route, although
such a risk would be considered minimal. Alternatives 2 and 3 would both provide
immediate short-term effectiveness in achieving protection as both require very little time
to implement. Alternative 3 would achieve the greatest short-term protection as well as
long-term protection by permanently removing the contaminants from the Site.
o Implementability
Groundwater:
The no action alternative, Alternative 1, would not involve construction or the use of
technologies of any kind. No modifications to the Site would be required to be made.
Therefore, this alternative would be easily implemented. However, the downgradient
migration of contaminants in the groundwater would continue to occur, creating a potential
risk to receptors.
Alternative 2 would require the development and implementation of deed restrictions and
well permitting restrictions (i.e., institutional controls), in conjunction with a groundwater
monitoring program. Monitoring the status of the aerial extent of impacted groundwater
by collection and analysis of groundwater samples is a standard technology that is easily
implementable. Monitoring could be conducted through a series of existing wells. The
implementation of institutional controls would not be as easy or reliable as the monitoring
aspect of this alternative. Currently, well construction for the purposes of drinking water
supply is regulated through Article IV, Nassau County Public Health Ordinance, regulating
the installation of private drinking systems. Further institutional controls to restrict the
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construction of water wells on the Ruco property would be required to further reduce the
risk of exposure to contaminated groundwater. This would require the development and
implementation of some sort of well permitting and approval process controlled by the
NYSDEC or Nassau County, and/or the specification of some type of deed restriction (to
prevent well construction). Additional institutional controls would require obtaining deed
notations to limit the land use activities at the Ruco property. Obtaining the deed
restrictions might require the cooperation of the current property owner, Ruco Polymer
Corporation. Historically, the enforcement of institutional controls has been considered
unreliable. The EPA would attempt to enhance the reliability of the institutional controls and
improve their effectiveness by seeking to ensure that mechanisms would be put in place
to guarantee the future enforcement of the institutional controls. While Alternative 2 would
be easy to implement technically, the administrative requirements would not be as easily
achieved.
Alternatives 3 and 4 involve the extraction and treatment of groundwater. This type of
technology has been applied at a variety of sites with mixed results. From a geologic and
hydrologic viewpoint, the groundwater aquifer under Long Island would be the optimum
type of aquifer in which to operate a pump and treat system with a high degree of
confidence in success. The aquifer possesses good characteristics (e.g., homogeneous,
and isotropic) that would allow for a relatively simple and straight-forward design.
Adequate control of groundwater beneath the Ruco property could be established and
monitored through the use of a system of extraction and monitoring wells. The treatment
systems required in these two alternatives would be the same. Many standard water
treatment technologies exist that have been employed at other sites. It would be expected
that these same technologies would be able to treat the groundwater at this Site. However,
because of the presence of the TICs in the groundwater, there exists a degree of
uncertainty in the application of standard technologies. Therefore, treatability studies would
be required to determine the optimum technology or combination of technologies to treat
all the contaminants in the groundwater. This factor makes the groundwater pump and
treat alternatives slightly more difficult technically than non-treatment alternatives to
implement.
Deep Soils:
Alternative 1 has no technical or construction requirements making it the easiest alternative
to physically implement. Alternative 2, capping is also a very easy technology to implement
and has been used at many sites across the country. The cap would require long term
maintenance and periodic inspections by the agencies to ensure its integrity. This would
certainly restrict any future potential uses of the property. Alternatives 3 and 4 would be
only slightly more difficult to implement from a technical stand-point. With Alternative 3, the
same long-term requirements for the maintenance of the cap would exist that have been
identified for Alternative 2, above. Alternative 4 would require some additional testing (e.g.,
pump tests) to ensure sufficient recapture of the water being flushed through the sump(s).
If properly designed and constructed, this alternative would be expected to reliably
recapture this water. Alternative 4 would also have to be integrated with the groundwater
extraction and treatment (Alternative 3 or 4 for groundwater) system, therefore, any
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costs. To address sump one, Alternative 4 was estimated to require a capital cost
investment of $ 16,000 and an annual O&M cost of $ 1,000, and incur 10 and 30-year
present worth costs of $ 26,000 and $ 37,000. To address sump one and sump two the
capital cost of Alternative 4 would be $ 25,000. The annual O&M cost would be $ 3,000
and the 10-year, 30-year costs would be $ 45,000 and $ 65,000 respectively.
Shallow Soils:
The costs developed for the shallow soils alternatives show that the no action alternative,
Alternative 1, has $ 0 capital costs, $ 0 O&M costs, and $ 0 present worth costs.
Alternatives 2 and 3 generated two sets of costs for each alternative based on addressing
the former drum storage area alone, or the former drum storage area and the area around
monitoring well E as well. The costs required for the construction and operation of
Alternative 2 in the former drum storage are only are $ 86,000 capital costs, $ 3,000 per
year O&M costs, and $ 107,000 and $ 128,000 10-year and 30-year present worth costs.
If the area around monitoring well E is also included Alternative 2 would then cost
$ 95,000 for capital cost, $ 3,000 annual O&M cost, $ 121,000 10-year present worth cost
and $ 146,000 30-year present worth cost. Alternative 3, excavation and off-site disposal,
was the most expensive alternative. To address the former drum storage area alone, a
capital cost of $ 482,000 would be incurred. This alternative would not require annual O&M
cost, which would therefore be $ 0. The present 10-year and 30-year present worth costs
would represent a one-time investment cost of $ 482,000. To include the area around
monitoring well E in the excavation and disposal, the capital cost would be $ 758,000, with
annual O&M costs again equalling $ 0. The 10 and 30-year present worth costs would be
$ 758,000 representing the one-time investment cost.
o State Acceptance
After review of all available information the NYSDEC has indicated that they concur with the
selected remedy. NYSDEC's letter of concurrence presented in Appendix IV of this
document.
o Community Acceptance
Community acceptance of the preferred alternative has been assessed in the Responsive-
ness Summary portion of this ROD following review of the public comments received on
the RI/FS report and the Proposed Plan. All comments submitted during the public
comment period were evaluated and are addressed in the attached Responsiveness
Summary (Appendix V). Many of the public's concerns were unrelated to OU 1 and
instead pertained to air quality issues that are the result of current operations at the Ruco
facility. In general, the public was supportive of EPA's proposed remedy.
SELECTED REMEDY
The US EPA has determined, upon consideration of the requirements of CERCLA, the
detailed analysis of the various alternatives, and public comments, that Alternative 3 (with
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difficulties in implementing those alternatives would be applicable here. These alternatives
would require more design and construction work but both use well established technolo-
gies. Construction of either alternative is not expected to be a problem.
Shallow Soils:
Alternative 1, no action, would be the technically simplest alternative. No design,
construction, or monitoring requirements are involved. Alternative 2 would be easy to
design and construct, however, long-term maintenance, inspection and therefore, agency
involvement would be required. Alternative 3 could be completed using simple, widely
utilized excavation techniques, with some minor modifications to ensure the proper dust
suppression was executed. Once excavation was complete, no agency involvement would
be required in the shallow soil areas.
o Cost
Groundwater:
Looking at the various groundwater alternatives, Alternative 1, no action, presents the
lowest costs at $ 0 for capital, present-worth and O&M. This alternative provides a
baseline to compare the costs of other alternatives. Alternative 2 is the next least
expensive alternative to implement with a capital cost of $ 39,000, 10-year and 30-year
present worth costs of $ 325,000 and $ 608,000 respectively, and an O&M cost of $37,000
annually. The costs associated with Alternatives 3 and 4 are very similar. The capital costs
are $ 4,748,000 for Alternative 3 and $4,867,000 for Alternative 4. The O&M costs are
$ 549,000 for both alternatives. Alternative 4 has slightly higher costs for the present worth
analysis at $ 9,105,000 for the 10-year estimate and $13,304,000 for the 30-year estimate.
Alternative 3 has estimated 10 and 30-year present worth costs at $ 8,986,000 and
$ 13,185,000 respectively. A list of the alternatives assembled in increasing order of cost
indicates that Alternative 1 is the least expensive, followed by Alternatives 2, 3, and 4.
Deep Soils:
Alternative 1 is the least expensive alternative evaluated with $ 0 capital costs, $ 0 O&M
costs and $ 0 present worth costs. Alternatives 2,3 and 4 have two sets of costs associat-
ed with each alternative based on the need for addressing sump one alone, or sump one
and sump two together. Alternative 2, capping, has an associated capital cost of
$ 213,000, an O&M cost of $ 5,000 per year and 10 and 30-year present worth costs of
$ 251,000 and $ 289,000 for sump one. If sump two is added to this alternative, the costs
are: $ 345,000 capital cost, $ 7,000 annual O&M cost and 10-year and 30-year present
worth costs of $ 396,000 and $ 446,000. Alternative 3 would be the highest cost alternative
with a capital cost of $ 332,000, O&M cost of $ 48,000 and 10-year and 30-year present
worth costs of $ 703,000 and $ 1,070,000 for sump one alone. For sump one and sump
two, Alternative 3 would have the following costs: capital cost of $ 515,000, annual O&M
cost of $ 56,000, a 10-year present worth cost of $ 948,000 and a 30-year present worth
cost of $ 1,378,000. Alternative 4 was the least expensive alternative that incurred any
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minor modifications) for the groundwater in combination with Alternative 4 for the deep
soils, and Alternative 3 for the shallow soils is the appropriate remedy for the Site.
The major components of the selected remedy are as follows:
- Installation of groundwater extraction wells to control the flow of contaminated
groundwater from leaving the Ruco property and migrating downgradient (see Figure 15).
The exact location, number, size, depth and pumping rates of the extraction wells will be
determined through tests conducted in the remedial design phase of the selected
alternative. Existing monitoring wells on the Ruco property will be used to monitor the
performance of the groundwater extraction system and establish that sufficient control
occurs. Additional monitoring wells may be required. The need for additional monitoring
wells will be evaluated and determined during the design and implementation of the
groundwater extraction system.
- Installation of a groundwater treatment system. Treatment of the extracted groundwater
with an on-site treatment system will occur to achieve the appropriate discharge standards.
The exact combination and type of treatment technologies (i.e., granulated activated
carbon, ultraviolet oxidation, flocculation, etc.), and their effectiveness on TICs will be
determined in the design phase through treatability studies. Additional analyses of the
tentatively identified compounds (TICs) in the groundwater will be required to identify the
classes of chemical compounds that comprise the TICs. If the results of the treatability
studies indicate the discharge standards can not be achieved, the selected treatment
alternative will have to be revisited.
- Installation of a discharge system to dispose of the majority of the treated groundwater.
The discharge will be to a sump to be constructed on the Ruco property, unless a more
appropriate off-site location can be found by the potentially responsible parties for the
discharge of the treated groundwater. The majority of the discharge volume will be
required to be diverted to this proposed sump to avoid overloading sumps one and two
(see soil flushing below) and the groundwater extraction system. The discharged
groundwater is expected to meet the appropriate discharge criteria through treatment (see
treatment above).
- Additional soil testing (the bottom of sump two to the water table) to determine if
contaminants are present in the soils, and compare the levels present to the soil cleanup
criteria that are considered protective of groundwater quality. If contaminants are present
above levels considered protective of the groundwater, the soils in sump two will be
addressed in the same manner as the soils in sump one.
- Soil flushing for the deep soils in sump one, and possibly sump two (based on the results
of the soil testing). The exact delineation of the areas to be flushed will be performed
during the design phase of the remedial action. The soils will be flushed by a portion of
the discharge of treated groundwater. The method of discharging the treated water will be
determined in the design phase. The contaminants flushed out by this process will be
recaptured by groundwater extraction wells. The exact location, depth, size and pumping
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rates of the groundwater extraction wells will be determined during the design phase of the
preferred alternative. Additional analyses of the tentatively identified compounds (TICs) in
the soil will be required to identify the classes of chemical compounds that comprise the
TICs. Treatability studies (e.g., soil column tests) will also be performed on the soils to
evaluate the effectiveness of soil flushing on TICs. The contaminant levels in the sumps
will be re-evaluated during periodic monitoring and at the five-year review to measure the
progress of the flushing. In order to install the flushing system in sump one, the existing
concrete storage tanks in that sump will be removed and disposed of. (See Figure 16 for
the areas of soils to be addressed.)
- Additional soil testing in the area around monitoring well E to determine if contaminants
are present. If contaminants are present above concentrations considered to be protective
of groundwater quality, and exist in the shallow soils, the area around well E will be
addressed in the same manner as the former drum storage area. If the contaminants are
present in the deeper soils, further evaluation of potential remedial alternatives will occur.
- Excavation of the soils in the former drum storage area and possibly the area around
monitoring well E, to be determined by subsequent soil borings. Excavated soils will be
disposed of off-site. The extent of the excavation in the former drum storage area, and
possibly the area around monitoring well E, will be based on the results of the soil samples
collected during the Remedial Investigation and further sampling to be conducted during
the pre-design or design phase. (See Figure 16 for the areas of soils to be addressed.)
- Periodic monitoring of the groundwater extraction system to assure adequate control is
maintained; periodic sampling of the groundwater treatment system discharge, to assure
treatment standards are achieved; and periodic sampling of the groundwater and soils in
sump one and possibly sump two to measure the progress of the selected remedy in
achieving the cleanup standards.
- Institutional controls in the form of deed restrictions and groundwater use restrictions at
the Ruco property. The deed restrictions will be required to restrict the Ruco property to
industrial/commercial development only, as long as contaminants remain on the property
above levels considered appropriate for residential development and the treatment systems
are in place. Groundwater use restrictions in addition to the existing Nassau County
Ordinance, will be implemented through deed restrictions as well. The use of groundwater
will be restricted until such time as the groundwater beneath the Site has been determined
to be fully remediated.
The goal of the remedial action is to restore the groundwater to its beneficial use, which
is, at this Site, a sole source drinking water aquifer. Based on information obtained during
the remedial investigation, and the analysis of all remedial alternatives, EPA and NYSDEC
believe that the selected remedy may be able to achieve this goal. However, sporadic low-
level regional groundwater contamination may be especially persistent upgradient of the
Ruco facility. Therefore, the ability to achieve cleanup goals in the groundwater beneath
the Ruco facility, cannot be determined until the extraction and treatment systems have
been implemented, modified as necessary, and plume response monitored over time.
44
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Recent studies 'have indicated that pumping and treatment technologies may contain
uncertainties in achieving the ppb concentrations required under ARARs over a reasonable
period of time. However, these studies also indicate significant decreases in contaminant
concentrations are attained early in the system implementation, followed by a leveling out.
For these reasons, this remedy stipulates contingency measures, whereby the groundwater
extraction and treatment system's performance will be monitored on a regular basis and
adjusted as warranted by the performance data collected during operation. Modifications
may include any or all of the following:
a) at individual wells where cleanup goals have been attained, pumping may be
discontinued;
b) alternating pumping at wells to eliminate stagnation points;
c) pulse pumping to allow aquifer equilibration and encourage adsorbed contaminants to
partition into groundwater; and
d) installation of additional extraction wells to facilitate or accelerate cleanup of the
contaminant plume.
If it is determined, on the basis of the preceding criteria and the system performance data,
that certain portions of the aquifer cannot be restored to their beneficial use in a reasonable
time frame, all or some of the following measures involving long-term management may
occur, for an indefinite period of time, as modification of the existing system:
a) engineering controls such as physical barriers, source control measures, or long term
gradient control provided by low level pumping, as containment measures;
b) chemical-specific ARARs may be waived for the cleanup of those portions of the aquifer
based on the technical impracticability of achieving further contaminant reduction;
c) institutional controls, in the form of local zoning ordinances, for example, may be
recommended to be implemented and maintained to restrict access to those portions of
the aquifer which remain above remediation goals;
d) continued monitoring of specified wells; and
e) periodic reevaluation of remedial technologies for groundwater restoration.
The decision to invoke any or all of these measures may be made during a periodic review
of the remedial action, which will occur at intervals of no less than every five years. At that
time the State of New York will be given the opportunity to review, comment and concur
on all contingency decisions.
45
-------
The estimated costs for the selected remedy are as follows:
- Groundwater extraction and treatment; capital cost $ 4,748,000, annual O&M costs of
$549,000, with 10-year and 30-year present worth costs of $ 8,986,000 and $ 13,185,000.
Note: These costs are calculated for discharge to an on-site sump. Discharge to an off-
site location is not expected to significantly affect the costs of this portion of the selected
remedy.
- Soil flushing of Sump one only: capital cost $ 16,000, annual O&M costs of $ 1,000, and
10-year and 30-year present worth costs of $ 26,000 and $ 37,000.
- Soil flushing of Sump one and Sump two: capital cost of $ 25,000, annual O&M costs of
$ 3,000, and 10-year and 30-year present worth costs of $ 45,00 and $ 65,000.
- Excavation of the shallow soils in the former drum storage area only: capital cost $
482,000, annual O&M costs $ 0, and 10-year and 30-year present worth costs of $ 482,000
which represents a one-time investment cost.
- Excavation of the shallow soils in the former drum storage area and the area around
monitoring well E: capital cost $ 758,000, annual O&M costs of $ 0, and 10-year and 30-
year present worth costs of $ 758,000 which represents a one-time investment cost.
If all the targeted areas mentioned in the selected remedy above require remediation (i.e.,
Sump two and the area around monitoring well E are included), the total estimated cost
of the selected remedy would be approximately:
Capital Cost: $ 5,531,000
Annual O&M Costs: $ 552,000
10-year Present Worth Cost: $ 9,031,000
30-year Present Worth Cost: $ 13,250,000
STATUTORY DETERMINATIONS
Under its legal authorities, EPA's primary responsibility at Superfund sites is to undertake
remedial actions that are protective of human health and the environment. In addition,
Section 121 of CERCLA establishes several other statutory requirements and preferences.
These specify that when complete the selected remedial action for this 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, toxicrty, or mobility of hazardous
46
-------
substances, as available. The following sections discuss how the selected remedy meets
these statutory requirements.
Protection of Human Health and the Environment
The selected remedy is protective of human health and the environment. Contaminated
groundwater will be prevented from migrating downgradient of the Ruco property and
further degrading the aquifer quality. Potential exposure to contaminated groundwater will
be controlled through the extraction and treatment of the groundwater. Contaminants in
the groundwater will be removed through treatment with the potential to restore the sole
source aquifer beneath the Site to its beneficial use. The deep soils representing potential
sources of contamination to the groundwater will be treated through soil flushing. These
contaminants will then be recaptured through groundwater extraction removing them from
the environment. The deep soil contaminant sources will then be eliminated. The shallow
soils representing potential sources of groundwater contamination and potential human
health risks will be removed from the Site through excavation. This will permanently
remove the threat created by the contaminants in the shallow soils.
The selected remedy addresses the threats posed by contaminated groundwater beneath
the Ruco property and at the downgradient property boundary, which are; the potential
human health risk and prevention of further groundwater contamination downgradient
(source control). The implementation of the groundwater remedy also has the potential to
return the aquifer to a usable quality. Although EPA acknowledges that groundwater
ARARs may be unattainable, by actively removing and treating contaminants in the
groundwater aquifer, human health and the environment are protected under the chosen
remedy. The selected remedy also combines the groundwater remediation with the soils
remediation to address the principal threat posed by the soils, which is; the further
contribution to groundwater degradation from contaminants in the soil. By addressing the
shallow soils the preferred alternative also provides an unquantifiable, but added level of
protection to Site workers from potential exposure to contaminants and reduces the
potential contribution to groundwater contamination.
Groundwater extraction and treatment, soil flushing and excavation would provide long-term
effectiveness in the protection of human health and the environment.
It is not anticipated that any significant short-term impacts on human health or the
environment would occur during the construction and implementation of the preferred
alternative.
Compliance with ARARs
The groundwater extraction and treatment portion of the selected remedy is expected to
meet the discharge to groundwater ARARs (6NYCRR), however, some uncertainty does
exist due to the presence of TICs. The ARARs for groundwater quality (State groundwater
quality standards and Federal MCLs ) would also be expected to be achieved with the
preferred alternative, although the presence of groundwater contaminants upgradient of the
47
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Site may make this goal impossible to reach. As indicated in the selected remedy section
above, the EPA may invoke contingency measures if implementation of the selected
remedy indicates that reaching the groundwater ARARs beneath the Ruco facility is
technically impracticable due to the presence of persistent upgradient sources.
The flushing of the soils in the sump(s) is also is expected to achieve soil contaminant
concentration levels that are considered to be protective of groundwater (TBC criteria) for
the soluble contaminants in the soils. The effectiveness of flushing on the more insoluble
contaminants is unknown at this time, however, a small portion of these insoluble
contaminants will (or may) be removed through flushing. Remaining insoluble contami-
nants are not expected to readily leach from the soils and mobilize into the groundwater.
Excavation of the shallow soils will achieve soil cleanup levels considered protective of
groundwater (TBC criteria) by removing the contaminants from the Site. A reduction in the
toxicity, mobility and volume of the contaminants will be achieved and the leaching of
contaminants into the groundwater will be prevented. The applicability of the LDR's will be
evaluated and complied with during the implementation of the selected remedy.
Cost-Effectiveness
The selected remedy is cost-effective because it has been demonstrated to provide the
best overall effectiveness proportional to its cost.
The selected remedy achieves the ARARs more quickly, or as quickly, and at less cost than
the other options except for the shallow soils where excavation will cost more than the
other alternatives. However, the excavation will be more permanent, require no O&M and
will not require a five-year review. No contaminants in the shallow soil areas targeted will
be left on-site. Therefore, the selected remedy will provide the best balance of trade-offs
among alternatives with respect to the evaluating criteria.
Utilization of Permanent Solutions and Alternative Treatment Technologies to the Maximum
Extent Practicable
By employing treatment for the groundwater and the deep soils, the selected remedy
utilizes permanent solutions and treatment technologies to the maximum extent practicable.
It is anticipated that the groundwater extraction and treatment portion of the preferred
alternative will effectively reduce the mobility and volume of the contaminated groundwater.
Uncertainty does exist concerning the ability of the treatment system to achieve the
appropriate treatment standards. The ability to achieve the standards through treatment
will be determined in the pre-design phase by treatability tests. Depending on the
treatment technology chosen, the toxicity of the contaminants may also be reduced
through destruction. The contaminants in the deep soils will initially become more mobile
as they are flushed out of the soils reducing the volume of the compounds in the soil. The
contaminants will then be recaptured and treated in the groundwater treatment system,
permanently reducing their volume, mobility and potentially their toxicity. Excavation of the
shallow soils will permanently remove the contaminants from the Site.
48
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Preference for Treatment as a Principal Element
This remedy also satisfies the statutory preference for treatment as a principal element to
reduce the toxicity, mobility and volume of contaminants at the Site.
Groundwater extraction and treatment, soil flushing and excavation will provide long-term
effectiveness in the protection of human health and the environment. The extraction and
treatment of groundwater and the flushing of the soils in the sump(s) and excavation of
shallow soils will also be permanent solutions through the removal of contaminants in the
affected media. The application of groundwater pump and treat combined with the soil
flushing will utilize treatment technologies to address the contaminants present at the Site.
Soil excavation will not involve the use of treatment unless the soils to be excavated fail the
hazardous waste characterization tests. If the soils were to fail the tests, treatment would
be required prior to off-site disposal.
DOCUMENTATION OF SIGNIFICANT CHANGES
There are no significant changes from the preferred alternative presented in the Proposed
Plan except that this ROD provides more flexibility with respect to the location of a
discharge point for the treated groundwater.
49
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APPENDIX I
FIGURES
Figure 1 - Site Location
Figure 2 - Site Plan
Figure 3 - Area Remediated by OU 2
Figure 4 - Soil Vapor Sampling Locations
Figure 5 - Electromagnetic Survey (western)
Figure 6 • Electromagnetic Survey (eastern)
Figure 7 - Soil Boring Locations
Rgure 8 - Soil Boring Locations
Figure 9 - Monitoring Well Locations
Rgure 10 - Location of Existing and Former Sumps
Figure 11 - Chloroethylenes in Groundwater
Rgure 12 - VOCs and Phthalates in Groundwater
Rgure 13 - TICs in Groundwater
Figure 14 - Air Sampling Locations
Figure 15 - Conceptual Groundwater Control Using Extraction Wells
Figure 16 - Areas of Soils to be Addressed
-------
CKSVILLE FACILITY
r-«99!pir f I I I f ''
! Tn^r*.1?^-
&3Wj*wm
-. :*«£" .JJUwflina
f\,:»•..:•'. « ^ .^ Vriii?^^B^*
. ; .V'*1.,
•. ««o*<«
• T"^' —
,. -• f » ^ ; J
^j-? * f7? ''•
as«'£JJ"'
."-H'-ST"
HOOKER CHEMIC
RUCO POLYMER
CORP.
NEW YORK
EPA ID# NYD002920312
EPA REGION 2
Nassau County
Hicksvllle
Othtr Namts:
Ruco Polymtr Corp.
FIGURE 1
-------
LONG /SLAND
RA/LROAD
'OCCIDENTAL CHEMICAL CORPORATION
HOOKER/RUCO SITE
HICKSVILLE. NEW YORK
AERIAL SITE MAP
3-13-69
DATE
REVISED
BY:
LEGGE7TE. BRASHEAP.S & GSAHJM, NC.
aontl Groeai-ftler CtLsultats
72 Danbury Road
Wilton. CT 06B97
. (203) 762-1207
DATE: 5/4/92 | FIGURE: 2'
-------
COMMERCE STREET
LONG ISLAND
RAILROAD
CHEMICAL CORPORATION
-------
OCCIDENTAL CHEMICAL CORPORATION
HOOKER/RUCO SITE
HICKSVILLE. NEW YORK
SOIL-VAPOR SAMPLING LOCATION MAP
DATE
KYJSED
PREPARED BY:
LEGGETTE, BRASHEAXS A CRAHAX, INC.
ftrunrf-r«Ur ut torinamaUl
7? Canbury Feed
FUton. CI 0689?
(203) tG?-12D7
DATE: B/4/Se
4
-------
WESTERN
POSSIBLE BURIED
TMK
POSSIBLE
SOIL HORIZON
ANOMALY
LEGEND
:> COWOUR VALUE ABOVE AND BELOW
' BACKGROUND READING IN mmho/m
£-M TRAVERSE END POINTS
SCALE IN FEET
OCCIDENTAL CHEMICAL CORPORATION
HOOKER/RUCO SITE
HICKSVILLE. NEW YORK
DATE
E-M CONDUCTIVITY CONTOUR MAP OF
THE WESTERN STUDY AREA
REVISED
'PREPARED BY:
LEGGETTE. BRASKEASS & GRAHAU, JVC.
fioiesaestl Croiurf-FaJw Coosulitsts
72 Danbury Road
Wilton. CT 06B97
(203) 762-1207
.IDATE: 7/31/92 \ FIGURE: 5
-------
POSSIBLE BURIED'
TANK
EASTERN,
CONFIRMED FACILITY
UTILITIES. PLANT
COOLING WATER LOOP
O
LEGEND
COWJR VALUE ASCW AND BELOW
BACKGROUHD READIES /N rr.rr.ho/m
-U TRAVERSE END POINT
SCALE IN FEET
OCCIDENTAL CHEMICAL CORPORATION
HOOKER/RUCO SITE
HICKSVILLE, NEW YORK
DATE
E-M CONDUCTIVITY CONTOUR MAP OF
THE EASTERN STUDY AREA
REVISED
PREPARED BY:
LEGGETTE. BRASHEARS & GRAHAX. 1VC.
ProfessioDtl Ground-filer
72 Danbury Road
Wilton. CT 06B97
(203) 762-1207
DATE: 7/31/92 \ FlGlrRE: o
-------
CURRENT DRUM-
STORAGE AREA
ABOVEGROUND TANKS
FORMER DRUM
STORAGE AREA
H547ER TANK
SUMP 3
SUMP 7
SUMP 2
LEGEND
TEST BORING LOCATIONS
0 700
SCALE IN FEET
, i^u_. wi.iuivj.iu/Uj UUK.f
HOOKER/RUCO SITE
HICKSVILLE. NEW YORK
TEST BORING LOCATIONS SOUTH
.REVISED
PREPARED BY:
LEGGETTE, BRASHEARS & GRAHAM. JVC.
JTo/exscaaj Gfouoi-Wtter Ceasvliuit
72 Daabury Road
Wilton. CT 06697
(203) 762-1207
DATE:
-------
ABOVEGROUND TANKS
FORMER
SUMP 5
FORMER
SUMP 6
TRANSFORMERS
SUMP 4
LEGEND
• TEST BORING LOCATION
TOO
SCALE IN FEET
OCCIDENTAL CHEMICAL CORPORATION
HOOKER/RUCO SITE
HICKS VILLE, NEW YORK
TEST BORING LOCATION NORTH
LATE
REVISED
PREPARED BY:
LEGGETTE. BRASHEARS & GRAHAM. INC.
Prolessimtl Ground-Filer
72 Panbury Road
Wilton, CT 06807
(203) 762-12
4.VATE: 7/29/92 ] FKH
-------
I
I
LEGEND
WELL LOCATION
360,
SCALE IN FEET
OCCIDENTAL CHEMICAL CORPORATION
HOOKER/RUCO SITE
fflCKSVEIE. NEW YORK
GROUND-WATER SAMPLING LOCATION
DATE
REVISED.
r
PREPARED BY:
LEGGETTE, BRASHEARS ie GRAHAM, INC,
Pnttaantl Gnmi-Wtttr
72 Daabtuy Road
Tilton. CT 05597
(203) 762-1207
JUTE: 7/30/82
FIGURE:
-------
EXISTING PIPING,
TRENCHES OR DITCHES
PREVIOUS LOCATIONS
OF TRENCHING,
DITCHES OR SUMPS
THAT ARE NO LONGER
ACTIVE
50
SCALE IN FEET
OCCIDENTAL CHEMICAL CORPORATION
HOOKER/RUCO SITE
HICKSVILLE, NEW YORK
WASTE-WATER DISPOSAL NETWORKS AT THE
HOOKER/RUCO SITE
DATE
REVISIONS
PREPARED BY:
LEGCETTE. BRASHEARS & GRAKA1!. INC.
Professional. Ground-Water Consultants
. 72 Daubury Road
Wilton. CT 06607
(e « 76?-1207
'DATE:
IF'IGURE
-------
«U IOCUMN
OCCIDENTAL CHEMICAL CORPORATION
HOOKER/RUCO SITE
fflCKSVILLE. NEV YORK
DATE
CONCENTRATIONS OF CHLOROETHYLENES
IN GROUND WATER. RESULTS IN U£/l
REVISED
PREPARED BY:
UGCETTE. BM5HEARS It GRAHAM. INC.
Pnttmttatl torund-nt«r mi bifraaafBti/ Strriem
72 Dtnbury Road
Wilton. CT 06B97
(203) 762-1207
DATS: 8/4/92 rtJGUSS:~ll
-------
N
LFCFWO
•*• «CU LOCATION
OCCIDENTAL CHEMICAL CORPORATION
HOOKER/RUCO SITE
. HICKSVILLE. NEW YORK
CONCENTRATIONS OF VOLATILE ORGANICS AND PHTHLATES
IN GROUND WATER. RESULTS IN ue/1
DJOE
REVISED
PREPARED BY:
LFGGOTT. BRASHEARS le GRAHAH. INC.
PrefetsleaMj envoi- ter tat torirumuttl Senicn
72 . 3&IU7 Rend
WUt . CI 06897
Z; 762-1207
DATE: e/4/92 \flGVRE: \-)
-------
\DATT
SITE
S
SULTS IN
PREPARED BY:
, BRASHEAKS It GRAHAM. INC.
6mad-r«Ur ui AnraamateJ Ante*
72 Duibtuy Hand
Wilton. CT 00097
(203; 762-1807
-------
LEGEND
AIR SAMPLING LOCATION
DW-1
10/23/89 DATE SAMPLED
WIND r./.PFCT.'S.V
310 —v /—C5C6
10/22/89 V~X 9/25/55
n
750
SCALE IN FEET
OCCIDENTAL CHEMICAL CORPORATION
HOOKER/RUCO SITE
HICKSVILLE. NEW YORK
AIR SAMPLING LOCATIONS
DATE
REVISED
PREPARED BY:
LEGGETTE, BRASHEARS & GRAHAM, INC.
Professional Grousd-Fater CossuKtats
72 Panbury Road
miton, CT 06897
" (203) 762-1207
7/29/92 J FJC-USE:
-------
LONG ISLAND RAILROAD
LEGEND
RECOVERY WELL
CAPTURE ZONE
150
SCALE IN FEET
OCCIDENTAL CHEMICAL CORPORATION
HOOKER/RUCQ SITE
HICKSVILLE. NEW YORK
RECOVERY 1TELL LOCATIONS AND CAPTURE ZONES
DATE
REVISED
PREPARED BY:
I£G ENGINEERING SERVICES. INC.
PrafmieeiJ tnrirouaeitttl utf Civil Xngioten
fZ Dan burr jfoad
WUioo. CT 08897
(203) 702-5502
.DATE: 3/9/93 \ FIGURE: IS
-------
LONG ISLAND RAILROAD
LEGEND
AREAL EXTENT OF
SOILS TO BE ADDRESSED
OCCIDENTAL CHEMICAL CORPORATION
HOOKER/RUCO SITE
fflCKSVnlfe. NEW YORK
AREAL EXTENT OF SOILS TO BE ADDRESSED
DATE
REVISED
PREPARED BY:
IBG ENGINEERING SERVICES. INC.
' AtTfraoBtaUl «nd CM
7? D&nbury Road
WUtoa. CT 06B97
(203; 762-8502
DATE: 8/2/93
FIGURE: 16
-------
APPENDIX II
TABLES
Table 1 - List of Potential ARARs
Table 2 - Chemical-Specific Groundwater Quality Criteria
Table 3 - Chemical-Specific Groundwaer Discharge Criteria
Table 4 - New York State TAGM Values
Table a - Risk Assessment: Contaminants of Concern
Table b - Risk Assessment: Summary of Expsoure Pathways
Table c - Risk Assessment: Noncarcinogenic Toxicity Values
Table d - Risk Assessment: Noncarcinogenic Risk Estimates
Table e - Risk Assessment: Carcinogenic Toxicity Values
Table f - Risk Assessment: Carcinogenic Risk Estimates
Table g - Risk Assessment: Contaminant Concentration Data
Table h - Risk Assessment: List of Exposure Assumptions
Table i - Risk Assessment: Cumulative Site Risks
Table 5 - Air Regulations
-------
TABLE 1
List of ARARs
-------
3.2 Applicable or Relevant and Appropriate Requirements
3.2.1 ARARs for Ground water Cleanup Criteria
3.2.1.1 Federal Regulations
The following sources of ARARs have been identified for site groundwater:
40CFR
40CFR
Part 141
Subpart B
Section 141.11
Section 141.12
Subpart F
Section 141.50
Section 141.51
Subpart G
Section 141.61
Part 143
Section 143.3
National Primary Drinking Water Regulations
Maximum Contaminant Levels
Maximum Contaminant Levels for Inorganic
Chemicals
Maximum Contaminant Levels for .Organic
Chemicals
Maximum Contaminant Level Goals
Maximum Contaminant Level Goals for Organic
Contaminants
Maximum Contaminant Level Goals for Inorganic
Contaminants
National Revised Drinking Water Regulations:
Maximum Contaminant Levels
Maximum Contaminant Levels for Organic
Contaminants
National Secondary Drinking Water Regulations
Secondary Maximum Contaminant Levels
3.2.1.2 New York Regulations
The following sources of ARARs have been identified for site groundwater:
6NYCRR
10NYCRR
Part 701
Section 701.15
Part 702
Section 702.1 .
Section 702.2
Pan 703
Section 703.5
PartS
Subpart 5-1
Section 5-1.51
Classifications-Surface Waters and Ground Waters
Class GA Fresh Ground Waters
Derivation and Use of Standards and Guidance
Values
Basis for Derivation of Water Quality Standards and
Guidance Values
Standards and Guidance Values for Protection of
Human Health and Sources of Potable Water
Supplies
Surface Water and Ground Water Quality Standards
and Ground Water Effluent Standards
Water Quality Standards for Taste, Color and Odor-
Producing, Toxic and Other Deleterious Substances
Drinking Water Supplies
Public Water Systems
Maximum Contaminant levels
21
LBC ENGINEERING SERVICES, INC.
-------
Section 5-1.52
Tables; Table 1 - Inorganic Chemicals and Physical
Characteristics Maximum Contaminant Level
Determination, Table 3 - Organic Chemicals
Maximum Contaminant Level Determination
3.2.1.3 Specific ARARs for Ground water Cleanup Criteria
The specific ARARs for groundwater cleanup criteria are listed in table 2.
3.2.2 ARARs for Groundwater Discharge Criteria
3.2.2.1 Federal Regulations
The following sources of ARARs have been identified for site groundwater
discharge:
40CFR
40CFR
Pan 141
Subpart B
Section 141.11
Section 141.12
Subpart F
Section 141.50
Section 141.51
Subpart G
Section 141.61
Part 143
Section 143.3
National Primary Drinking Water Regulations
Maximum Contaminant Levels
Maximum Contaminant Levels for Inorganic
Chemicals
Maximum Contaminant Levels for Organic
Chemicals
Maximum Contaminant Level Goals
Maximum Contaminant Level Goals for Organic
Contaminants
Maximum Contaminant Level Goals for Inorganic
Contaminants
National Revised Drinking Water Regulations:
Maximum Contaminant Levels
Maximum Contaminant Levels for Organic
Contaminants
National Secondary Drinking Water Regulations
Secondary Maximum Contaminant Levels
3.2.2.2 New York Regulations
The following sources of ARARs have been identified for site groundwater
discharge:
6 NYCRR Part 701 Classifications-Surface Waters and Ground Waters
Section 701.15
Part 702
Class GA Fresh Ground Waters
Derivation and Use of Standards and Guidance
Values
22
LBG ENGINEER* c SERVICES, INC.
-------
Section 702.1
Section 702.2
Section 702.16
Section 702.18
Part 703
Section 703.5
Section 703.6
10 NYCRR Part 5
Subpart 5-1
Section 5-1.51
Section 5-1.52
Basis for Derivation of Water Quality Standards and
Guidance Values
Standards and Guidance Values for Protection of
Human Health and Sources of Potable Water
Supplies
Derivation and Implementation of Effluent
Limitations
More Stringent Groundwater Effluent Standards or
Limitations
Surface Water and Ground Water Quality Standards
and Ground Water Effluent Standards
Water Quality Standards for Taste, Color and Odor-
Producing, Toxic and Other Deleterious Substances
Ground Water Effluent Standards and Limitations
for Discharges to Class GA Waters
Drinking Water Supplies
Public Water Systems
Maximum Contaminant Levels
Tables; Table 1 - Inorganic Chemicals and Physical
Characteristics Maximum Contaminant Level
Determination, Table 3 - Organic Chemicals
Maximum Contaminant Level Determination
3.2.2.3 Specific ARARs for Groundwater Discharge Criteria
The specific ARARs for groundwater discharge criteria are listed in table 3.
The substantive requirements of the State Pollutant Discharge Elimination System
(SPDES) permit program shall be met for the discharge of treated groundwater at the
site. The final effluent standards for discharge are set through the SPDES process.
3.2.3 ARARs for Air Emission Discharge Criteria
3.2.3.1 Federal Regulations
The EPA has established guidance values on the control of air emissions through
the Clean Air Act at CERCLA sites for groundwater treatment (EPA, 1989). This
guidance indicates that the sources most in need of controls are those with an actual
emissions rate in excess of 3 Ibs/hr or 15 Ibs/day, or a calculated annual .rate of
10 tons/year of total VOCs. The calculated annual rate assumes 24-hour operation,
365 days per year.
LEG ENGINEERING SERVICES, INC.
-------
RCRA regulations outlined in 40 CFR Parts 264 and 265, Subpart AA-Air
Emission Standards for Process Vents and Subpan BB - Air Emission Standards for
Equipment Leaks are potential ARARs. These standards, applicable to wastestreams with
organic concentrations of at least 10 ppmw (parts per million by weight), require that the
total organic emissions from all effected processes be reduced below 3 Ibs/hr and
3.1 tons/yr or reduction of total organic emissions by 95 percent weight.
3.2,32 New York Guidelines
The New York State DEC Division of Air Resources has issued draft guidelines
for the control of toxic ambient air contaminants in New York State. These guidelines
are presented in the New York State Air Guide-1. State guidance values pertaining to
potential air emissions from groundwater treatment equipment to be used at the
Hooker/Ruco site are listed in table 5.
3.2.4 ARARs for Transport and Disposal of Hazardous Byproduct Wastes
3.2.4.1 Federal Regulations
The following sources of ARARs have been identified for treatment,
transportation and disposal of hazardous byproducts:
40 CFR Pan 261 Identification and Listing of Hazardous Waste
Pan 262 Standards Applicable to Generators of Hazardous
Waste
Part 263 Standards Applicable to Transporters of Hazardous
Waste
Part 264 Standards for Owners and Operators of Hazardous
Waste Treatment, Storage and Disposal Facilities
Subpart B General Facility Standards
Subpart E Manifest System, Recordkeeping and Reporting
Subpart N Landfills
Subpart O Incinerators
Part 265 Interim Status Standards for Owners and Operators
of Hazardous Waste Treatment, Storage and
Disposal Facilities
Subpart B General Facility Standards
Subpart E Manifest System, Recordkeeping and Reporting
Subpart N Landfills
Subpart 0 Incinerators
24
LBC EN INEERING SERVICES, INC.
-------
49CFR
Subpart P
Subpan Q
Part 268
Part 172
Part 173
Part 178
Part 179
Thermal Treatment
Chemical, Physical and Biological Treatment
Land Disposal Restrictions
Hazardous Material Regulations of the Department
of Transportation, Hazardous Materials Tables and
hazardous Communication Requirements and
Emergency Response Information Requirements
Hazardous Material Regulations of the Department
of Transportation, Shippers, General Requirements
for Shipping and Packaging .
Hazardous Material Regulations of the Department
of Transportation, Shipping Container Specifications
Hazardous Material Regulations of the Department
of Transportation, Specifications for Tank Cars
3.2.4.2 New York Regulations
The following sources of ARARs have been identified for treatment,
transportation and disposal of hazardous byproducts:
6NYCRR
Part 360
Part 370
Part 371
Part 372
Part 373
Subpart 373.1
Subpart 373.2
Subpart 373.3
Part 376
Solid Waste Management Facilities
Hazardous Waste Management System - General
Identification and Listing of Hazardous Waste
Hazardous Waste Manifest System and Related
Standards for Generators, Transporters and
Facilities
Hazardous Waste Management Facilities
Hazardous Waste Treatment, Storage and Disposal
Facility Permitting Requirements
Final Status Standards for Owners and Operators of
Hazardous Waste Treatment, Storage and Disposal
Facilities
Interim Status Standards Regulations for Owners
and Operators of Hazardous Waste Facilities
Land Disposal Restrictions
LBC ENGINEERING SERVICES, INC.
-------
Section 3.2.5 New York State ARARs for Air Emissions
The following sources of New York State ARARs have been
identified for air emissions:
6NYCRR Part 200 General Provisions
6NYCRR Part 201 Permits and Certificates
6NYCRR Part 202 Emissions Testing, Sampling and
Analytical Determinations
6NYCRR Part 212 General Process Emissions Sources
6NYCRR Part 257 Air Quality Standards
-------
TABLE 2
Chemical-Specific Groundwater Quality ARARc
-------
TABLE 2
OCCIDENTAL CHEMICAL CORPORATION
HOOKER/RUCO SITE
HICKSVUJLE, NEW YORK
Chemical-Specific ARARs for Groundwater Cleanup Criteria1'
'• Compound
Acetone
Benzene
Bis (2
10,000
NR
MCLGs?
NR
0*
NR
NR
NR
NR
NR
NR
NR
70
NR
NR
700
0*
NR
NR
0»
0«
0«
10.000
NR
SMCU*
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
Sutt Standards "
Groundwater
sQuality ™
Standards*
NR
0.7
50
NR
NR
5
7
NR
ND13
5
NR
NR
5
ND12
NR
NR
5
5
2
5
NR
" XMaluag.
" - Water " <
Standards?
50"
5'
50"
50U
50"
5'
100
5'
50"
5P
50"
50U
5"
50U
50U
50"
5P
5"
2
5'
50"
- Minimum
ARAR-Based
Ground water
Oramip
.. Criteria
50
0.7
50
50
50
5
7
5
ND13
5
SO
50
5
ND«
50
50
5
5
2
5
50
27
LBC ENGINEERING SERVICES, INC.
-------
TABLE 2
(continued)
OCCIDENTAL CHEMICAL CORPORATION
HOOKER/RUCO SITE
HICKSVILLE, NEW YORK
Chemical Specific ARARs for Groundwater Cleanup Criteria1'
Compound
f
^
Aluminum
Antimony
Arsenic
Barium
Beryllium
Cadmium
Calcium
Chromium III
Chromium VI
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Nickel
Potassium
Selenium
, Federal Standard? ' ....
MCL*
NR
6
50
1,000
1
10
NR
NR
SO
NR
NR
NR
IS
NR
NR
NR
NR
10
MCLGc*
% ••;. "*>
NR
3
NR
2.000
0*
5
NR
NR
100
NR
1.300
NR
0*
NR
NR
NR
NR
NR
SMCLs?
SO
NR
NR
NR
NR
NR
NR
NR
NR
NR
1.000
300
NR
NR
SO
NR
NR
NR
: State Standards
Groaodwater
QuaBty ;
Standards*
NR
NR
25
1.000
NR
10
NR
50
SO
NR
200
300t
25
NR
300t
NR
NR
10
, Drinking
^ Water ° '
Standards*'
NR
NR
SO
1,000
NR
10
NR
SO
SO
NR
1,000
300t
SO
NR .
300t
NR
NR
10
Minimum
ARAR-Based
Groundwater
.Cleanup
-Criteria
NR
6
25
1.000
1
5
NR
50
50
NR
200
300
15
NR
300
-NR
NR
10
28 ~
LBC ENGINEERING SERVICES, IN
-------
TABLE 2
(continued)
OCCIDENTAL CHEMICAL CORPORATION
HOOKER/RUCO SITE
HICKSVILLE, NEW YORK
Chemical Specific ARARs for Groundwater Cleanup Criteria17
'V .. Compound - , ,
Silver
Sodium
Vanadium
Zinc
.. Federal Standards , .. """;•
MCL*:
50
NR
NR
NR
incuse.
NR
NR
NR
NR
SMCL**
X % ^ %! s
NR
NR
NR
5.000
V~, ' State Standards - \- •-
Groandwater
QnaBtj
Standard' ' '
50
20,000
NR
300
Drinking "
^Mtotar •>
* Standards*
50
NR
NR
5,000
: Minimum
ARAR-Based
^Groundwater
: Cleanup "
, Criteria
SO
20,000
NR
300
I/ Micrograms per liter.
2/ 40 CFR 141.11. 141.12. 141.61.
II 40 CFR 141.50. 141.51.
4/ 40 CFR 143.3.
5/ 6 NYCRR 703.5
61 10 NYCRR 5-1.52.
NR Not regulated.
P Principle Organic Compound: each cannot exceed 5 ug/1.
U Unspecified Organic Compound: each cannot exceed 50 ug/1.
ND, Not detected at or above X.
* The EPA believes that an MCLG of zero is not an appropriate setting for cleanup levels, and the corresponding MCL will be the
potentially relevant and appropriate requirement (EPA. 1990).
t The total of iron and manganese cannot exceed 500 ug/1.
29
LEG ENGINEERING SERVICES, INC.
-------
TABLE 3
Chemical-Specific Groundwater Discharge ARARc
-------
TABLE 3
OCCIDENTAL CHEMICAL CORPORATION
IIOOKER/RUCO SITE
HICKSVILLE, NEW YORK
Chemical-Specific ARARs fur Groundwuter Discharge Crileriu1'
. Compuuncl , ;
' * % ' ; ' '" ','\
Acetone
Benzene
Bis (2-elhylhcxyl) phlhalalc
2-Bulanone
Carbon disulfide
Chlorobenzene
Chloroform
Chloromclhanc
Dicldrin
1 ,2-Dichloroelhylcne total!7
Di-n-butyl phlh:ilalc
Di-n-oclyl-|)lilhalale
Elliylhcnzcne
- Federal Standard*
MCL?
NR
5
NR
NR
NR
NR
100
NR
NR
70
NR
NR
700
MCLUs?
NR
0*
NR
NR
NR
NR
NR
NR
NR
70
NR
NR
700
SMCU*
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
.. $•»!* Standard*
Groundwater
Quality ,
Standards*'
NR
0.7
50
NR
NR
5
7
NR
ND
5
NR
NR
5
Prinking Water
Standard** *
50"
5'
50"
50°
50°
5'
100
f
50"
5"
50U
50U
5'
Graundwater ,
effluent
- Standard*
ClMiCA?
NR
0.7
4200
NR
NR
NR
7
NR
ND
NR
770
NR
NR
ARAR-Based ..
-------
TABLE 3
(continued)
OCCIDENTAL CHEMICAL CORPORATION
IIOOKER/RUCO SITE
IIICKSVILLE, NEW YORK
Chemical Specific ARARs for Groundwater Discharge Criteria1'
'*/ * ' , '<„
';'-,,,>*' Compound -,'
S ' '' f
Hc|rtachlor cpoxide
4-Me(hyl-2-pcnlanone .
Naphthalene
Tctrachlorodhylcne
Trichforodhylcnc
Vinyl chloride
Xylene*
TICs
Aluminum
Antimony
Arsenic
Barium
(| Jcrylliuin
<-" •!'••* Federal Standards
MCI^
NR
NR
NR
5
5
2
IO.OOO
NR
NR
6
SO
I.OOO
1
MCMJsi'
0«
NR
NR
0»
0*
0«
10.000
NR
NR
3
NR
2.000
0*
SMCI4?
NR
NR
NR
NR
NR
NR
NR
NR
SO
NR
NR
NR
NR
-, - * ',..„:..' ", Stale Standardf J-'^ ,<,.. „*; ,
" Uroundwater
Quality
Stnndardi^ .. "
ND
NR
NR
5
5
2
5
NR
NR
NR
25
1,000
NR
Drinking Watrr
Siandnrdv*' ,
50U
50U
50U
5r
5'
'. 2
5'
50U
NR
NR
SO
1.000
NR
•• Croundvratcr
, Effluent s ,
Staadards
Cl«$ CAP
ND
NR
NR
NR
10
S
NR
NR .
2.000
NR
SO
2.000
NR
ARAR-Based
" ~ iGround\va(ct
Uischargr
Criteria''
ND,.,
SO
SO
5
S
2
S
soft
2.000
6
25
1.000
1
m
z
o
z
m
m
»
Z
Z
n
-------
TABLE 3
(continued)
OCCIDENTAL CHEMICAL CORPORATION
IIOOKER/RUCO SITE
IIICKSVILLE, NEW YORK
Chemical Specific ARARs for Groundwuler Discharge Criteria1'
, ' Compound . -,
Cadmium
Calcium
Chromium III
Chromium VI
Coball
Copper
Iron
Lcud
Magnesium
Manganese
Nickel
Potassium
Selenium
Silver
Federal Standards
MCI*
10
NR
NR
SO
NR
NR
NR
SO
NR
NR
NR
NR
10
SO
MCI.GS?
5
NR
NR
100
NR
1.300
NR
0*
NR
NR
NR
NR
NR
NR
SMCI.S-"
NR
NR
NR
NR
NR
1.000
300
NR
NR
SO
NR
NR
NR
NR
State Standard!
Groundwater
Quality
Standards*'
10
NR
SO
SO
NR
200
300f
25
NR
300t
NR
NR
10
50
Drinking Water
Standardv?
10
NR
SO
50
NR
1.000
300t
SO
NR
300f
NR
NR
10
SO
Groundwaler
Effluent
Standards
Claw CA»
20
NR
NR
100
NR
1.000
600$
SO
NR
600*
2.000
NR
40
100
ARAK-Based
ftrountfwHer
Discharge
Criteria!'
10
NR
SO
SO
NR
1,000
600 J:
25
NR
600t
2,000
NR
10
too
CO
m
z
Jt
t—
z
n
m
Z
n
-------
m
z
z
m
m
Z
o
30
fS
m
VI
TABLE 3
(continued)
OCCIDENTAL CHEMICAL CORPORATION
HOOKER/RUCO SITE
IIICKSVILLE, NEW YORK
Chemical Specific ARARs for Groundwaler Discharge Criteria1'
'<"! f'^ ' '-» "', %> '/'"• '•' "
, --•• Compound! » *< ? •*< '• '
''/V H V ^
' f
Sodium
Vanadium
Zinc
"'-A * A -7<>ed«rii1 Standard* ^ v ' •
MCt* -
NR
NR
NR
MCl.Osi'
NR
NR
NR
SMCLs?
NR
NR
5.000
; 'W ;'>; Stute Standards .;'; ^\' "f I
Groundwater
Quality
Stundardsf
20.000
NR
300
Drinking Wntvr
Standwrd^
NR
NR
5.000
GroundwHter '
EfnuenC
.• Suadardi "
Cla« GA^ ,
NR
NR
5.000
ARAR-Baml
Groi.nd\v«ler
DUchnrge
Criteria*'
<
20.000 '
NR
5.000
J./
CO
Micrugnmi p«r liter.
40CFRI4l.il. Ml. 12. 141.61.
40CFRI4l.50.HI.il.
40CFRI4J.1.
6 NYCRR 70I.S.
10 NYCRR 5 1. 52
6 NYCRR 70J.6.
i/ 6 NYCRR 702. 16.
NR Not reguUled.
J/
4/
I/
6/
7/
P Principle Orginic Compound; eich cinnot exceed 5 ug/l.
U Unspecified Organic Compound; etch cinnol exceed SO ug/l.
NO, No« Uclcclcd at or ibove X.
• The EPA believes thai «n MCLQ of zero U not «n •ppropriate telling Tor
cleanup leveli. and the corresponding MCL will be the potentially relevant
and appropriate requirement (EPA, 1990).
tt Applies lo each individual compound.
t The tola! of iron and manganese cannot exceed 500 ug/l.
$ Combined concentration of iion and nungtiKK shall not exceed 1,000 ug/l.
Z
n
-------
TABLE 4
New York State TAOM Values (XBC Criteria)
-------
TABLE A
OCCIDENTAL CHEMICAL CORPORATION
IIOOKER/RUCO SITE
IIICKSVILLE, NEW YORK
Specific TBC Soil Cleanup Criteria lo Protect Groundwnler Quality1'
Compound
Solubility
S
(nig/I)
trillion
Coefficient
KOC
(ml/ft)
Craundwater
Standard*
Criteria
,cw
(ug/l)
Allowable
Soil
Co.*.*
c» .
(ppm)
Soil Cleanup
Objective* (0
Protect Ground*
Water Quality*'
(ppm)
R (Commended
Soil Cleanup
Objective?
(ppm) '
Background***
(ppm) ,
TBC Soil
Cleanup Criteria
to Protect
Croundtvater
Quality
(ppm)
Volatile Organic*
Benzene
Xylenes
Elhylbenzene
Toluene
Tclrncliloroclhcne
Trichlorodhene
Mclhylcnc chloride
Acetone
2-Bulanone
4-Mclhyl-2-PenUnone
1,1-Dichlorocthane
1 ,2-Dichlorocthnne
1,1.1 -Trichloroethone
1.750
198
152
535
150
1.100
16,700
1,000,000
268.000
19,100
5,500
8.520
1.500
83
240
1.100
300
277
126
21
2.2
4.5*
19*
30
14
152
0.7
5
5
5
5
5
5
SO
50
50
5
5
5
0.0006
0.012
0.055
0.015
0.014
0.007
0.001
0.001 1
0.003
0.01
0.002
0.001
0.0076
0.06
1.2
5.5
I.S
1.4
0.70
O.I
0.11
0.3
1.0
0.2
O.I
0.76
0.06
1.2
5.5
1.5
1.4
0.7
O.I
0.2
0.3
1.0
0.2
O.I
0.8
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
0.06
1.2
5.5
1.5
1.4
0.7
O.I
0.2
0.3
1.0
0.2
O.I
0.8
09
£.
m
z
•
10
Z
o
jo
<
O
Z
n
-------
TABLE 4
(continued)
OCCIDENTAL CHEMICAL CORPORATION
IIOOKER/RUCO SITE
IMCKSVILLE, NEW YORK
Specific TDC Soil Cleanup Criteria to Protect Groundwater Quality*'
Compound
4- "•
1 . 1 ,2,2-Tctrachloroclhane
1 , 1 -Dichlproethane
1 .2-Dichloroethene (trans)
Chlorobcnzenc
Chloroethane
1 ,2-Dichlorobenzcne
1 ,3-Dichlorobenzene
1 ,4-Dichlorobenzene
1 .2,4-Trichlorob«n7.ene
Vinyl chloride
1 ,2.3-Trichloropropane
1 ,3-Dichloroprnpane
Dibromochlommeihiinc
Chloroform
Soluhilily
S
("•8/D ,
2,900
2.250
6.300
466
5.740
100
123
79
30
2.670
1.900
2.700
N/A
8.200
Partition
CWHTdenl
**
-------
TABLE 4
(continued)
OCCIDENTAL CHEMICAL CORPORATION
IIOOKER/RUCO SITE
IIICKSVILLE, NEW YORK
Specific TBC Soil Cleanup Criteria lo Protect Groundwater Quality1'
Compound
t+ * -.-. f
f j*f
f ff i
'-/"'"
f f
Carbon Tclrnchloride
Benzoic Acid
Carbon Disulfide
Benza(b)nuoranlhene
Benzo(k)fluoranlhcne
Ptienanlhrcne
Fluoranthene
Pyrcnc
Bcnzo(a)|>yrcne
lntlcno( 1 ,2 ,3-cd)pyrene
2-Mcthylphenol
4-Mclhylphenol
Fluorcne
Solubility
;' */'
(mg/i)
757
2.900
2,940
Partition
Coefficient
t '
K0c
(ml/g)
110*
54*
54*
0.014
0.0043
1
0.206
0.132
0.0012
0.0005
31.000
24,000
1.7
550.000
550,000
4.365*
38.000
13.295*
5,500.000
1.600.000 -
15
17
7.300
GrOiiridMwter
SUndnnh
CrJlerl*
C* .
(ug/t)
5
50
50
AOovfrxble
Soil
Cow.*
f }
* ^' <
0.6
2.7
2.7
Srmi-Volifile Organic]
0.002
0.002
50
SO
50
0.002 (ND)
0.002
5
50
50
0.01 1
0.01 1
2.20
19
6.65
O.I 10
0.032
0.001
0.009
3.5
I.I
I.I
220
1.900
665
no
3.2
O.I
0.9
350.0
I.I
I.I
50.0
50.0
50.0
0.061 or MDL
3.2
O.I 00 or MDL
0.9
50.0
ftwkgroand^
'- , ; '. ,- -;<
itppm) ;
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
„ TBC Soil
Ckaaup Crkerb
IttlVotcd
Croundwatcr
< , it Qtiallty
(ppoi)
0.6
2.7
2.7
I.I
I.I
50.0
50.0
50.0
no
3.2
0.100 or MDL
0.9
50.0
m
z
o
Z
o
I/)
m
jo
-------
TABLE 4
(continued)
OCCIDENTAL CHEMICAL CORPORATION
IIOOKER/RUCO SITE
IIICKSVILLE, NEW YORK
Specific TRC Soil Cleanup Criteria to Protect Groundwater Quality1'
Compound
Dibenzofuran
Acenaphlhene
Acenaphthylene
Napthalcne
2-Mcthynaphlhilene
Anthracene
bis(2-elhylhexyl)phllmlate
Dimclhylphthlale
Dicthylplilhlale
Bulyhcnzylplilhlale
Di-n butyl phthalale
Di-n-oclyl. plilhlale
ChryscnC
Bcnzo(a)anlhraccne
Solubility
's
,, NtfO
10
3.42
3.93
31.70
26
0045
0.285
5,000
896
2.9
400
3
0.0018
0.0057
Partition
Cftrffirtttil
K
-------
TABLE A
(continued)
OCCIDENTAL CHEMICAL CORPORATION
IIOOKER/RUCO SITE
IIICKSVILLE, NEW YORK
Specific TBC Soil Cleanup Criteria to Protect Groundwuter Quality1-'
Compound -
Bcnz»(g,h,i)perylcne
2,4-Dichlorophenol
2,4,5-Trichlorophenol
Dibenzo(a ,h)an1hnccnc
3 ,3 '-Dichlorobcnzidinc
llcxachlorobenzene
Phenol
Penlnchlorophenol
Nilrolien/cnc
4-Clitoro-3-inclhylphcnol
2.4-Dinilrophenol
4-Nilrophcnol
2-Nilrophenol
2-Clilorophenol
Soluollity
$
tmg/l)
0.0007
4.600
1.190
0.0005
N/A
0.006
82,000
14.00
1.900
3.8SO
5.600
16.000
2.100
28.500
Partition
Coefficient
KOC
f (ml/g)
1.600.000
380
89*
33.000.000
N/A
3,900
27
1.022
36
47
38
21
65
15*
CrotindwMter
Standard*
Criteria
Cw
(ug/l)
5
1
1
SO
N/A
0.35
1
1
5
5
5
5
5
50
Allowable
Soil
Cone.*
cs
(ppm)
8.0
0.004
0.001
1.650
N/A
0.014
0.0003
0.01
0.002
0.0024
OXW2
0.001
0.0033
0008
Soil Cleanup
Objectives (o
Protect Ooilnd-
Water Quality*
(ppm)
800
0.4
O.I
165.000
N/A
1.4
0.03
1
0.2
0.24
0.2
O.I
0.33
0.8
s ..
Recommended
Soil Cleanup
Objective*
(ppm)
50.0
0.4
O.I
0.014 or MDL
N/A
0.41
0.03 or MDL
1 or MDL .
0.200 or MDL
0.240 or MDL
0.200 or MDL
0.100 or MDL
0.330 or MDL
08
Background**^
(ppm)
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
TBC Soil
Cleanup Criteria
to Protect
Gronndwater
Quality
(ppm)
50.0
0.4
O.I
165.000
N/A
1.4
0.03 or MDL
1 or MDL
0.200 or MDL
0.240 or MDL
0.200 or MDL
0.100 or MDL
0.330 or MDL
0.8
NO
OO
00
m
z
o
z
rn
m
JO
Z
n
m
in
z
n
-------
TABLE 4
(continued)
OCCIDENTAL CHEMICAL CORPORATION
IIOOKER/RUCO SITE
IIICKSVILLE, NEW YORK
Specific TBC Soil Cleanup Criteria lo Protect Groundwnter Quality1-'
Compound
N i »'' i-r
/
?* •> ,
L.
Aniline
2-Nilroaniline
3-Nilroaniline
4-Chlroraniline
2,6-Dinilrololuene
4.4'-DDD
4,4'-DDE
4.4--DDT
Dicldrin
Endrin
Aldrin
Endosulfan 1
Endosiilfan II
Solubility
''I]
(mg/i)
35.000
1.260
1,100
-
277.0
Partition
Coefficient
. K«r
% 5-V f ^
(ppm)
NA
NA
NA
NA
NA
TBC Soil
Cleanup Criteria
to Protect
.. Groundtvfltrr -
Quality
(ppm)
O.I
0.430 or MDL
0.500 or MDL
0.220 or MDL
1°
Organic Pesilridn/ltrrbicidn and PCBs
0.16
0.04
0.005
0.195
0.26
0.017
0.32
0.33
770.000*
440.000*
243.000*
10.700*
9.157*
96,000
8,168*
8.031*
ND(
-------
TABLE 4
(continued)
OCCIDENTAL CHEMICAL CORPORATION
IIOOKKR/RIICO SITE
IIICKSVILLE, NEW YORK
Specific TBC Soil Cleanup Criteria to Protect Groundwater Quality1-'
Compound
Endosulfan Stilfnlc
Heplachlor
Hcptachlor epoxide
Chtordane
2.4-D
2.4.5T
Silvex
PCBs
Polyclilorinaled
dihcnzofuranes (PCDF)
Dibcnzo-P-dioxins
(PCDD)
2.3.7.8 TCDD
alpha - BHC
beta - BHC
SoluMIXjr
s
>lg/1)
0.22
0.18
0.35
0.056
890
238
140
0.08
N/A
0.0000193
1.63
0.24
Partition
Coefficient
KOC
(ml/g)
,1
10.038*
12.000
220
21.305*
104*
53
2.600
17.510*
N/A
1,709,800
3.800
3.800
Groitndwater
Standards
Criteria
-------
TABLE 4
(continued)
OCCIDENTAL CHEMICAL CORPORATION
HOOKER/RUCO SITE
IIICKSVILLE, NEW YORK
Specific TBC Soil Cleanup Criteria to Protect Groundwnter Quality1'
Compound
f s
dclla - BHC
gamma - BHC (Lindane)
Parelhion
Milolane
Methoxychlnr
Endrin kcytone
gamma - chlonfane
SoluhllHy
'8
(ing/1)
3.14
7.0
24.0
N/A
0.040
N/A
0.56
Partition
CtM-fficlenj
- K<«?
(ml/8)
6,600
1.080
760
N/A
25.637
N/A
140,000
Gronridwaieir
Standard*
Criteria
Cw
(og/l)
ND«0.05)
ND«0.05)
1.5
N/A
35.0
N/A
O.I
Aluminum
Antimony
Arsenic
Barium
Beryllium
Cadmium
-- -
Allotfabie
Soil
CM*.*
c,
(ppm)
0.003
0.0006
0.012
N/A
9.0
N/A
0.14
* SoUOeartiip
Objective) lo
Protect GrwintN
Water Quality*'
(ppm)
0.3
0.06
1.2
N/A
900
N/A
14.0
RtrOmmWdw
SoU Cleanup
Objective^
(ppmj
0.3
0.06
1.2
N/A
10.0
N/A
0.54
Inorganics
N/A
N/A
N/A
N/A
N/A
N/A
SB
SB
7.5 or SB
300 or SB
1.0 or SB
1 or SB
ft**irbuiid**#
<
(ppm)
s
NA
NA
NA
NA
NA
NA
NA
246-25.000
<3-l8
0.44-21
2.3-1.600
0-7
0.01-2
, TBCSott .'
Ck*nup Criteria
id Protect
Gronndwatcr
QlllUitj
(ppm)
0.3
0.06
1.2
N/A
900
N/A
14.0
25.000
18
21
1.600
7
2
00
O
m
z
o
m
90
Z
O
O
m
VI
Z
h
-------
TABLE 4
(continued)
OCCIDENTAL CHEMICAL CORPORATION
IIOOKER/RUCO SITE
IIICKSVILLE, NEW YORK
Specific TBC Soil Cleanup Criteria In Protect Groundwater Quality1'
• Compound
f
Calcium
Copper
Chromium
Cobalt
Cyanide
Iron
Lead
Magnesium
Manganese
Mercury
Nickel
Potassium
Silver
Selenium
Solubility
S
(mg/l)
Partition
Coefficient
•vx*
(ml/g)
Croiindwitrr
Standard*
Criteria.
Cw
(UR/I)
.
Attomlnte
Soil
Cone.*
c,
(ppm)
Soil Cteamip
Olijeclive$ (o
IVotwl Crouiid-
W»«-r Quilily'-'
(ppm)
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
Rfcoihnitiidfd
Soil Ckanup
Objective^
(ppm)
f:
SB
25 or SB
10 or SB
30 or SB
N/A
2,000 or SB
30 or SB
SB
SB
O.I
13 or SB
SB
SB
2 or SB
Bickground^
(ppm)
< 15-35.000
1.7-31
1.1-4.
< 0.48-60
<2.9
901-16,000
0.68-240
< 12. 1-9.700
O.4-5.000
•CO.070.33
0.5-34
56-43.000
-------
TABLE 4
(continued)
OCCIDENTAL CHEMICAL CORPORATION
HOOKER/RUCO SITE
IIICKSVILLE, NEW YORK
Specific TRC Soil Cleanup Criteria to Protect Groundwater Quality1'
Compound
' s '?' '' '
.. ., , r*, f *
' '• '' ,
]'' ':" •
Sodium
Thalliur*
Vanadium
Zinc
SoUiMllly
» , ,
(mg/ft
Partition
Coefficient
, */
•Wir
(ml/g)
Groundwkter
Stanilardi
Criteria
C*
N
(US/0
Allowable
Soil
Cow.*'
/* ""' •
* Cs
' (Ppm)
, ' Soil Clwioup
Objective* to
Protect Ground*
•. Wafer Quality*'
(ppiii) ,
N/A
N/A
N/A
N/A
RfWiltlWrttowt .
SoO Cleanup
Object!**'' ,
'• " ''',,! s
rpp:m);
SB
SB
ISO or SB
20 or SB
Bkkgraund***
•• •••. \ $
'" , '-<< ','£ !
~ (pj»n>)
10.7-50,000
<0. 17-0.55
1-300
< 1.7-1 10
fBCSoJI
Cleanup Criteria
to Protect
Groundwater
Quality
(ppm)
50,000
0.55
300
110
s
oo
n
m
z
o
.z
o
n
m
t/i
^
F
o
I/ NYSDEC TAGM 4046, *Ddenninalion of Soil Cleanup Objectives and Cleanup
Levels," 1992.
2/ Allowable soil concentration Cf = f » €» * KOC (f=0 01).
31 Soil Cleanup Objective = Cf * 100 (correction factor).
4/. As per proposed TAGM, total VOCs £10 ppm, total semi VOCs £500 ppm,
individual semi VOCs £50 ppm and total pesticides £ 10 ppm.
J/ McGovern, E., "Background Concentrations of 20 Elements in Soil with Special
Regard for New York Stale".
6/ Geraghty & Miller, Inc. TDala Report, Phase I Remedial Investigation, Grumman
Aerospace Corporation. Bethpage, New York (1992)"; Inorganic Soil
Concentrations from CMS-IS, CMS-11, GMS-21 and GMS-31.
7/ Inorganic soil concentrations from baseline borings Pilot Hole G, Pilot Hole S and
Well Q-l installed during the 1989 Rl.
NA Not applicable.
* Log KM = -0.55 log S -f 3.64. Other values are experimental values.
N/A Not available.
MDL Method Detection Limit.
t K« is derived from the correlation
SB Site background.
0.63 K...
-------
TABLE a
Risk Assessment - Contaminants of Concern
(See Table g for Contaminant Concentration Information)
-------
TABLE a
HOOKER/RUCO SITE
INDICATOR CONTAMINANTS Of POTENTIAL CONCERN
BY MATRIX
:h*mtoats
rotaWas:
I.I.I Trtchkxoethane
1 . 1 .2.2-Te*acMoroe»tane
1.1 Dfchloroetene
2-Butanom
4 Metiyl 2-pentanona
Acetone
Benzene
BromodtehloronioViane
Carton DtsutlWe
Carbon Tetracittorlde
CNorobenzene
Chloroform
ChlorOmethane
Elhyberuene x
Styrene
TetracNoroetona
Toluene
Total Xytenes
Trans- 1 .2 Dfchtoroettene
TrfchfonM tamo
Vinyl Chtorkfe
Surface Sol
X
.
X
•
.
.
X
.
•
X
X
X
'
X
X
X
X
X
X
X
-
Subsurface Sol Surface Water
X
X
X
.
» •
.
X
X
X
X
X
X
.
X
X
X
X
X
X
X
•
Ground Water
.
•
-
X
X
X
X
-
X
-
X
-
X
X
-
X
.
X
X
X
X
Sediments
.
-
.
•
-
.
-
.
-
.
.
-
.
X
X
X
X
-
X
X
-
Indicator
YES
YES
YES
YES
YES
YES
YES
YES
YES
YES
YES
YES
YES
YES
YES
YES
YES
YES
YES
YES
YES
•NO' -YES'
e
6.8
6
7.8
8
8
5.7.8
6.8
8
6.8
7.8
6.8
6.8
7.8
6.7.8
6
8
8
8
6.8
5.6.7.8
Indicates ttw contaminant was detected In tw maWx.
Indicate* the contaminant was not detected In tie matte
Both ktvatont and fmavalent chromium are conekfarad art*
ugh |ustrflcaton S, 6 and 7 rafar to hexavatent chromium onry.
(I) Contamtrant*>esrx*wntit)u»OJ%to»ieto«alrhkkx»^
|2): EPA approved toxfcty Mtoea do notaxtel to quantttatvely evaluate the contaminant.
(3): Contaminant does not exceed • 5% frequency of detection.
(4): Contaminant b not a Group A carcinogen.
(5): Contaminant b a Group A carcinogen.
(6): Contaminant to • carcinogen (or potanOal) wtti • dalectom above 1 ug/1 (groundwater and surface water) or 1 mg/fcg (subsurface sol .surface sols and sediments-Inorganic)
or 1 ug/kg (surface sol. subsurface soils and sediments -organlcs).
(7): Contaminant contributes 0. IX or more to (he total risk for tie maWx using tie toxldty screening analysis.
(8): Contaminant exceeds a SK frequency of detectton In one or more matrices.
(9): AlAroctor concentraOons are summed and evaluated as total PCBs.
(10): Essential and ranessenlal elements (aluminum, calcium, magnesium, potassium, and sodium) are not evaluated.
Pag* 1 o(4
-------
TABLE- a
HOOKER/RUCO SITE
INDICATOR CONTAMINANTS OF POTENTIAL CONCERN
BY MATRIX
Chemicals
Semi
•
Votatttoa;
2 Metiytnaphthatene
4 Metrytphenol
Benzole Add
Bb(2«tiythexyl)phthalato
Butyl benzyl phtialate
Dl-n-butyl phtialate
CM- n-octyl phtialate
Hexachtoroberuerw
n-niBOSuuynenyiamfffW
Phanantvena
Phenol
Carcinogenic PAHs
Benzo(a)antiracerw
Benzo(a)pyrene
Benzo(b)FluorantNna
Benzo(k)F1uorantMna
Chrysena v
NoncardnogentePArte
Acenaphtwrw
Anthracene
Benzo (g.h.l) parywrw
Dftwnzofuran
Fluoranthene
Fluor ene
Naphthatene
Pyrene
lnilliiBtea • Ill iBilnl.ilt Ml«* liiv
Surface Sol Subsurface Sol Surface Water Ground Water Sediments
X
X
-
X
X
X
X
X
.
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
- • •_ -*- - __^JU
Indicates tw contaninajii was oowmfo n BW mm*.
Indicates tw contaminant was not detected In tw matrix.
Bott tnVatent and hexavatenl chromium are considered aft
X -•-
.
X
XXX-
.
X - X -
X - X
.
X
X
.
X
X
X
X ...
X - - -
X
X
.
.
X
.
X - X
X
hough Justification 5. 6 and 7 refer to hexavatent chromium only.
Indicator
NO
NO
YES
YES
NO
YES
YES
YES
YES
NO
NO
YES
YES
YES
NO
NO
YES
YES
NO
YES
•NO* "YES*
2
2
8
6.7.8
1.3.4
8
7.8
6.7.8
6
2
1.3.4
6.8
8
8
2
2
8
8
1.3.4
8
(t): Contaminant does not contribute 0.1% to tw total risk tor the matrix using tw toxldly screening analysis.
(2): EPA approved toxldty Indices do not exist to «-«anlltatfveiy evaluate tw contamlnanl.
(3): Contaminant doos not exceed a 5% frequency of detection.
(4): Contamlnanl Is not a Group A carcinogen.
(5): Contamlnanl Is a Group A carcinogen.
(6): Contamlnanl Is a carcinogen (or potential) with a detectons above 1 ugl (groundwater and surface water) or 1 mg/kg (subsurface soil .surface sods and sediments Inorganic)
or 1 ug/kg (surface sol. subsurface soils and sediments -organlcs).
(7): Contaminant oonMbutea 0.1% or more to rha total risk for the matrix using tie toxldty screening analysis.
(8): Contamlnanl exceeds a 5% frequency of detectton In one or more matrices.
(9): Al Arodor concentrations are summed and evaluated as total PCBs.
(10): Essenttal and norwssenfW elements (aluminum, calcium, magnesium, potassium, and sodium) arc not evaluated.
Page 2 of 4
-------
TABLE a
HOOKER/RUCO SITE
INDICATOR CONTAMINANTS OF POTENTIAL CONCERN
BY MATRIX
Chemlcab
Inorganics:
Antimony
Arsenic
Barium
iMfyvufli
CftOmHWI
Chromium*
Cobalt
Copper
Iron
Lead
Mnnfjanosa
Mercury
Nickel
Sfltonhm
Slver "
ThaMum
Varwdkm
Zinc
Surface Sol
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Subsurface Soi
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Surface Water
-
X
X
X
X
X
X
X
X
X
X
X
X
.
X
.
X
X
Ground Water
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
.
X
X
Sediments
X
X
X
-
X
X
X
X
X
X
X
.
X
.
.
X
X
X
Indicator
YES
YES
YES
YES
YES
YES
NO
NO
NO
NO
YES
YES
YES
YES
YES
NO
YES
YES
•NO' 'YES'
7.8
5.6.7.8
7.8
6.7.8
6.7.8
9,6.7.8
2
2
2
2
7.8
7.8
5.6.7.8
7.8
7.8
1.3.4
7.8
7.8
X:
01:
(2):
0):
(4):
(6):
(8):
(B):
(10):
fa> Mttm^mm Mk^ *MM«ftM«B&«^M*f ^^aA
moiCMBB ajw Ournamwwni waa
Bc^h»1yalertandrwKava>er*c*yomlumareajrwKferedalt»ouo^ 7 refer to tmavalenl chromium only.
Contaminant doee not contribute 0.1% to tw total rbk tor tw matrix using twtoxfcty screening an arysb.
EPA approved toxldry Indtoes do not exist to quanttatfvety evaluate tw contaminant.
Contaminant does, not exceed a 5% frequency of defccJon.
Contaminant b not a Group A can
Contaminant b a Group A carcinogen.
Contaminant b a carcinogen (or potontaQ wrtti • detections above t ug/1 (grourxtwater and surface water) or t mg/fcg (subsurface sol .surface sots and sediments Inorganic)
or 1 ugfeg (surface ac*. subsurface sorb and sedknenb -organlcs).
Contaminant conMbutes 0.1% or mom to tw total rbk for tw mafrlx using tw toxldty screening anatysb.
Contaminant exceeds • 8% frequency of detection In one or more matrices.
Al Aroclor concenfrations are summed and evaluated as total PCBs.
Essential and nonessential etemenb (aluminum, calcium, magnesium, potassium, and sodium) are not evaluated
-------
TABLE a
HOOKER/RUCO SITE
INDICATOR CONTAMINANTS OF POTENTIAL CONCERN
BY MATRIX
ihemfcats
'CBsAndPesecMe:
4.4' ODD
4.4' DOE
4.4--DOT
Alpha Chtordane
Beta-BHC
Dteklrln
Haptachtor Epoxlde
Total PCBs
Arodort248
Aroctor12S4
Surface Sol
X
.
X
•
•
•
X
X
X
Subsurface Sol Surface Water Ground Water Sediments
X
X
X
X
X
X
X - X
. XX • X
X -
Indicator
YES
YES
YES
YES
YES
NO
YES
YES
•NO* 'YES'
6
6
6.8
6.7
6.7.8
1.3.4
7.8
6.7.8
(I):
(2):
(3):
(4):
(5):
(6):
(7):
(8):
(9):
(10):
Indicates tM contaminant MM detected In t» mrtta.
Indlcam tM contaminant WM not (MKM In t» mMrtx.
BoVi Mvatsnl tnd hcxavBtanl chromium v* ooraMtrad •!•»
u|^i|U9Mca>on 5. 6 and 7 rater to rwxavatonl chromium only.
Cor*mln«nt*Mnotoi>nM>uto0.1%to«»to«riifaklbr«Mr^
Contamhant does not moMdaS%fcvquanqroldalKton.
ContamhanlbnotaOroupA Mfdnogan.
CoKarnlnarH h a Group A cardnogan.
Contaminant te • carcinogen (or potonM) wMi • datoctons abovo t ugl (groundwatar and surface water) or 1 mg/kg (subsurfaoa sol .surface softs and sedknanls-lnorganlc)
or t ugftg (aurtaoa sol . subsurfac* toNs and Mdbnants -organlcs).
Contaminant oonMwkn O.t% or mom to tie total risk tor t» mafrli using tw toxtetty saaening analysb.
Contamlnar«axc««d«a5%h«qu«ncyold«toc«anlnon» w mora matrlcas.
Al Afodotconoenka«omafa summed and avaluated as total PCBs.
Easental and nonaasanM alamanfa (aluminum, calcium, magnesium, potassium, and sodium) ara not evaluated.
-------
TABLE b
Risk Assessment - Summary of Exposure Pathway!
-------
TABLE b
HOOKER/RUCO SITE EXPOSURE PATHWAY ANALYSIS
Pathway
GROUND WATER
Ingest ton
Inhalation
Dermal Contact
Dermal Contact
Ingestfon
Inhalation
Dermal Contact
Receptor
Timeframe
Evaluated
, ,,. .,, f.ppMp*W'Wff->
Adult/Child Resident
Adutt/Chitd Resident
Adutt/ChikJ Resident
Present
No
No
No
llMiSllilM^
Site Worker
Child Trespasser
''•i'-''\Wl\i
-------
TABLE b
HOOKER/RUCO SITE EXPOSURE PATHWAY ANALYSIS
Pathway
SURFACE SOIL
Ingest ion
Inhalation
' Dermal Contact
Receptor
Timeframe
Evaluated
Present Future
No
Yes
Construction Worker
Site Worker
Child Trespasser
Construction Worker
Site Worker
Child Trespasser
Off-Site Resident
(Child/Adult)
Construction Worker No Yes
Site Worker Yes Yes
Child Trespasser Yes Yes
Degree of
Assessment
Quant. Qual.
Yes
Yes
No
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
X
X
X
X
X
X
X
X
Rationale for Selection or Exclusion
Incidental soil ingestion assumed to occur
during proposed wastewater treatment plant construction.
Incidental soil ingestion assumed to occur during work.
Incidental soil ingestion assumed to occur during play.
VOAs detected in surface soil. Inhalation ofVOAs/dust
assumed to occur during proposed wastewater
treatment plant construction.
Inhalation of VOAs/dust assumed to occur during work.
Inhalation of VOAs/dust assumed to occur during play.
Inhalation of VOAs/dust assumed to occur at residences.
PCBs and cadmium detected in surface soil. Dermal
contact assumed to occur during proposed
wastewater treatment plant construction.
Dermal contact assumed to occur during work.
Dermal contact assumed to occur during play.
Page 2 of 3
-------
TABLE b
HOOKER/RUCO SITE EXPOSURE PATHWAY ANALYSIS
Pathway
Receptor
SUBSURFACE SOIL • ',', f* I ^,T, Y-F;
Ingestion Construction Worker
Inhalation
Dermal contact
Construction Worker
Construction Worker
Timeframe
Evaluated
Present Future
No
No
No
Yes
Yes
Yes
Degree of
Assessment
Quant. Qual.
Rationale for Selection or Exclusion
Incidental soHingestbn assumed to occur during
proposed wastewater treatment plant construction.
Inhalation of VOAs/dust assumed to occur during
proposed wastewater treatment plant construction.
Dermal contact assumed to occur during
proposed wastewater treatment plant construction.
Site Worker
Yes Yes
Inhalation of VOAs assumed to occur during work.
Child Trespasser
Yes Yes
Inhalation of VOAs assumed to occur during play.
Off-Site Resident
(Adult/Child)
Construction Worker
Yes Yes
No
Yes
Inhalation of VOAs assumed to occur at residences.
Inhalation of VOAs assumed to occur
during proposed wastewater treatment plant construction.
Page 3 of 3
-------
TABLE c
Risk Assessment - Noncarcinogenic Toxicity Values
-------
TABLE C
HOOKER/RUCO SITE
TOXICITY DATA FOR NONCARCINOOENIC
AND POTENTIAL CARCINOGENIC EFFECTS
DOSE RESPONSE EVALUATION
Votoflles:
1.1.1-TrtcNoroethane
1 .1 ,2.2-T«tracNoroettun«
1,1-Dlchloroelhene
2-Butanono
4-Methy1-2-pentanone
Acetone
Benzene
BromodkhkmmettMne
Caitxm DlsullWe
. Carbon Tetrachloflde
CNofobenzene
Chloroform
CMofomolfuine
Elhylberuene
Styrene
Tetrachtoroettene
Toluene
Total Xytenes
fe
• NoncaranoD
RtD(orH) v l«
(ma/Ka^l
9.00E-02
NA
B.OOE-03
S.OOE-02
5.00E-O2
1.00E-01
NA
200E42
100E01
7.00E04
200E-O2
1.00E-02
NA
1.00E41
2.00E-01
1.00E-O2
200E-O1
200E+00
2.00E-02
NA
NA
pn iweronoe DOS* : .
:j\\i<\ RfDJWiateBon) .
ilifilS.(mB«B-d«yJ . ti-i
300E01
NA
ND
000E02
200E42
NA
NA
ND
2.90E43
ND
S.OOE03
NA
NA
290E01
ND
NA
5.70E-Ot
8.60E02
ND
NA
NA
isWcaflons are as follows:
Human Carcinogen. Sufficient evidence from
Probable Human Carcinogen. UmHedevMen
Probable Human Carcinogen. Sufficient evldi
BMA»V«|A UiMMMt I^Mn^inrann 1 L»«llMMi t^Attftf**
puocnronic Nonoa
RID (oral sub)
B.OOEOt
NA
O.OOE-03
S.OOEO1
NA
100E+00
NA
200E02
100E01
7.00E03
200E^)1
lOOEiOO
NA
t.OOE+OO
2.00E400
I.OOEOt
2.00E400
400E«00
200E01
NA
NA
epUemMoglc studh
00 of cafunoQonvcny
mot of cw dnoQoolcl
•*• *4 t*t*» nl«««>«aii«ilxiifci
•cmoam nererence uose
RfCKWwtatton. tub)
3.00E+00
NA
ND
0 ODE 01
NA
NA
NA
ND
290E03
ND
8.00E02
NA
NA
290E01
ND
NA
270E01
8.60E^)2
ND
NA
NA
1
OralSF
NA
200E01
600E01
NA
NA
NA
2.90E-02
1.30E01
NA
1.30E01
NA
6 IDE 03
1.30E-02
NA
300E-02
6. IDE -02
NA
NA
NA
1. IDE -02
1.90E«OO
In human from epMemWoojcal studies.
tytnanlmeJi. Inadequate evidence of carcinogen
•M MMbMMlA
uBrcmoQon swpo rMtov
Weight Inhalation SF
D
C
C
D
NA
D
A
82
NA
82
D
82
C
D
82
B2
D
D
NA
B2
A
jre and cancer.
Wty In humans.
NA
200E01
120E+00
NA
NA
NA
2.90E-02
ND
NA
130E01
NA
8.10E02
630E03
NA
2.00E-03
180E03
NA
NA
NA
1.70E02
290E01
Weight
D
C
C
D
NA
D
A
B2
NA
B2
D
•»B2
C
D
B2
82
D
D
NA
B2
A
Conipounds
Tftcfitofoetfiene
' -yl Chloride
Group A:-
Group Bt>
Oroup B2:-
QroupC:-
QroupD:- Not Classified. Inadequate evidence of cardnogenlclty In animate.
Note:
Al toxJdty Values unless o»»rwbe noted are from Integrated Risk Infcrmaton Syslom (IRIS) June 1992 sessions.
and from Health Effects Assessment Summary TsMes (HEAST>1990 <"» Quarter (USEPA. 1990).
NA.NotAvataMB
ND: Not Determined
Pagel
-------
TABLE c
HOOKER/RUCO SITE
TOXICITY DATA FOR NONCARCINOGENIC
AND POTENTIAL CARCINOGENIC EFFECTS
DOSE RESPONSE EVALUATION
CrwrnfotlNwrw .;V :,'•.. •' .; (rnB/KoHfay) !
400E400
2.00E-02
2.00E400
100E400
200E02
8.00E04
NA
6.00E01
NA
fiOOEOI
300E4OO
400E01
4.00E01
4.00E02
300E01
Classifications are as folfcnn.
Human Carcinogen. Sutltatent •vMence from epMemtotoglc stodtes
Probabto Human Cardnogen. Limited evtdenca of cardnogerterty Ir
nogon norerencB uose
RfD(tnhatetion. cub)
(m0«0^y)
NA
NA
NA
NA
NA
ND
NA
NA
NA
NA
NA
NA
NA
NA
NA
u
OralSF
(mg/Kg-dayH
NA
1.40E-02
NA
NA
NA
1.GOE400
490E-03
NA
S80E400
NA
NA
NA
NA
NA
NA
i human from epWemtotoglcal studies.
t b* •wt^wniA lfm*t*±fu*if*t** *t*Ajls*f**m f*A ^wk»«tU*^v»««t«*L
£fCNiogen
Weight
D
B2
C
D
NA
B2
B2
D
B2
D
D
NA
D
D
D
siope h actor
Inhalation SF
(mg/Kg-dayM
NA
ND
NA
NA
NA
160E+00
NA
NA
6. IDE 400
NA
NA
NA
NA
NA
NA
Weight
D
B2
C
D
NA
B2
B2
D
B2
D
D
NA
D
D
D
re and cancer.
•Ik. l_ k*l«»U
Carcinogenic PAH* (1)
Noncardnogenle PAHs
Acenaphthene
Anthracene
FhJoranthrene
Ftorene
Naphthalene
Pyrene
Group A:-
GroupBI:-
Oroup B2>
OroupC:- Possible Human Cardnogon. limited evtderro of cardnogenldtly In animals
,vD:- NotClassHtod. Inadequate evidence of cardnogenldty In anknab.
Note:
Al toxtdty Values unless oterwise noted are from Integrated Risk Informaton System (IRIS) June 1992 sessions.
and from Heal* Effects Assessment Summary Tabtes (HEAST) 1990 4lh Quarter (USEPA. 1990).
(1). Al cardnogenlc PAHt arc evaluated as Benzo(a)pyrana
NA :Not Avalabte
ND: Not Determined
Compounds
w/o Criteria
2 Metfiylnnphlhateoe
Benzo (g.h.l) perytane
4-Methylphenol
Phenan throne
Dfberuoruran
Page 2
-------
TABLE c
HOOKER/RUCO SITE
TOXICITY DATA FOR NONCARCINOGENIC
AND POTENTIAL CARCINOGENIC EFFECTS
DOSE RESPONSE EVALUATION
»Doa»
PCBs And Pesttdde:
4.4--DDD
4.4--DDE
4.4'DDT
BetaBHC
Chtordaiw (2)
DtoMrin
Heptachtor Epoxtde
Total PCBS (3)
RID(lnhateflon)
Subohfonlc Noooafdnooan Reference Dose
RID (oral «ub) R(D(hhala*>n. tub)
.! (mg/Kg-day) f .-. (rog/Ko-dey)
Caidnogao Slope Factor
OralSF Weight
(mg/Kg-dayH .. ..
NA
NA
5.00E44
NA
6.00E09
500E-OS
1.30E-OS
ND
NA
NA
NA
NA
ND
NA
NA
ND
NA
NA
5.00E04
NA
600E09
5.00E05
5.00E04
NA
NA
NA
NA
NA
ND
NA
NA
NA
240EOI
340E01
3.40E01
1.80E400
130E*00
160E+01
910E+00
7.70E+00
B2
B2
82
C
B2
B2
B2
B2
Inhalation SF Weight
B2
82
B2
C
B2
B2
B2
82
Coinpoufids
NA
NA
340E01
1.80E«00
1306*00
160EtOl
9. IDE tOO
ND
• from apfctemtotoglc aludtoa to support • causal association between exposure and cancer.
EPA Weight of Evidence Classifications are as Mom:
Group A:- Human Carcinogen. Sufficient evMe
Group B1> Probable Human Carcinogen. United evidence of caidnogonklty In human Irom epMeinlotoglcal studies.
Group B2:- Probable Human Carcinogen. Sufficient evidence of cardnogenlclly In animals. Inadequate evidence of cardnogenldty In humans.
Group C:- PossMe Human Cardnogan. UmltedevMertoe of carcinogenic^ In animate.
Group D:- Not Ctasslftod. Inadequate evUence of cardnogentdty In animals.
, Altoxldty Values unless otherwise noted are from Integrated Risk Intormatton System (IRIS) June 1992 sessions,
and from Health Effects Assessment Summary Tabtoa (HEAS1>1990 4th Quarter (USEPA. 1990).
NA:NotAva«abto
ND: Not Determined
(2) Alpha ohfordana to evaluated as chlordana.
(3) All PCBs are •valuated as Arodor 1260
Pann
-------
CherntealNam*
!..' - .".•• •'
Inorganics:
Antimony
Arsenic
Barium
Beryllium
Cadmium
Chromium (III)
Chromium (VI)
Manganese
Mercury
Nickel
Selenium •
SfJver
Thorium
Vanadhm
dnooen Reteronoe Boa*
TABLE C
HOOKER/RUCO SITE
TOXICITY DATA FOR NONCARCINOGENIC
AND POTENTIAL CARCINOGENIC EFFECTS
DOSE RESPONSE EVALUATION
Subchronlc Nonpar dnogeo Roteronm Dose
RfD(ortf) ; ••?
(movKCr^M i
400E-04
300E04
7.00E-02
500E03
1.00E-03food
500E04water
1.00E+OO
B.OOE-03
100E01
300E04
200E02
SOOE-03
3.00E03
BOOE-05
7.00E-03
2.00E01
SSHlCBtfonS 9f9 AS fa
Hunwn CAfdnoQtt
gi.nii .>.!• • • r
;?,,•;: RfCHWiatetlon)
tM-i:. *«•«*<*«
NA
NA
1.00E04
NA
NA
NA
NA
1 10E04
860E05
NA
NA
NA
NA
NA
NA
flows:
FI. Sufficient ovfdenoe fiun
RID (oral sub)
(mg/Kg-day)
4.00E04
1.00E03
500E02
5.00E03
NA
100E400
2.00E02
100E01
300E04
200E02
NA
300E03
7.00E04
700E03
2.00E01
i rMtirlfimlrJru^i •htrttfM
1 0pIOOfnKllOQK BnlOIBS
«MA fA f*f^+lft+u^if*Lr>t*n IP
RfDOnhalatkm. tub)
(mg/Ko-d«y)
NA
NA
1.00E03
NA
NA
NA
NA
1.10E04
860E05
NA
NA
NA
NA
NA
NA
lo support • CBUSa BSSOCH
k lMiMn«ilU^rwiif
Cof cinogon Slops Factor
OralSF
NA
1.75E+00
NA
430E+00
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
Weight
1
NA
A
NA
B2
B1
NA
NA
D
D
A
D
D
D
NA
D
Inhalation SF
(mg/Kg4ay)-1
NA
150E+01
NA
840E«00
630E400
NA
420E+01
NA
NA
8.40E01
NA
NA
NA
NA
NA
Weight
NA
A
NA
B2
B1
NA
A
D
D
A
D
D
\D
NA
D
Compounds
w/o Criteria
Cobalt
Copper
Iron
Lead
Group A>
GroupBI:
Group B2> Probable Human Carcinogen. Sufficient evMenoe ol cardnogenldty In animals. Inadequate evWence of cardnogenlcrty In humans.
Group C:- Possible Human Carcinogen. Limited evidence of cardnogenlcftty In animate.
Group D:- Not Classified. Inadequate evidence ol cardnogenlcrty In animals.
Note:
Al toxtetty Values untesa
-------
TABLE d
Risk Assessment - Noncarcinogenic Risk Estimates
-------
Table d
SUMMARY OF NONCARCINOGENIC HAZARD INDEX RESULTS BY EXPOSURE PATHWAY
Matrix
Receptor
Exposure Pathway Nonarcinogentc Hazard Index Major Contributor(s) to Risk
^i.ox :,..;„ .•..',;
Surface Water
Surface Water
m?mmmn
Ground Water
Ground Water
Ground Water
Ground Water
Ground Water
Ground Water
mmimm
Sediment
Sediment
Sediment
Sediment
...i •::-.::.,,,- .^1.4
Child Trespasser
SHe Worker
Child Resident
AduH Resident
Child Resident
AduH Resident
Child Resident
AduH Resident
^^Mf^«1i'W»^i
Site Worker
SHe Worker
SHe Worker
Child Trespasser
Child Trespasser
fcMSfotocf .- :.- ,-
Dermal Contact
Dermal Contact
mmmm^m^
Inhalation
Inhalation
Ingestion
Ingestion
Dermal Contact
Dermal Contact
mm$:i?Mwx$ft&v\
Inhalation
Ingestion
Dermal Contact
Inhalation
Ingestion
'• • '
2.08E-02
1.79E-02
^m^M^'/wm.*
1.25E-01
5.82E-02
1.02E401
4.89E+00
1.22E-01
2.00E-01
^-i'C'l^ t ''::]}'••*,$" 'i'l»:^Jif,lf l.'J.j;!
1.39E-11
6.43E-03
2.64E-04
4.16E-12
3.34E-02
Antimony, Arsenic, Barium, Maganese, Vanadium,
Bis (2-ethylhexyO phthalate
:-•!•;;' v., ••'«,;. .>\-^T:'v'> ••::•••• '•• : ,\^-:.^\"-1 ;, >.- *••;•'-'• '•. •
Carbon Disuffide. 4-methyl-2-Pentanone
N
Antimony, Arsenic
Antimony, Arsenic, Tetrachtoroethene,
Bis (2-ethyl hexyl) phthalate
>:',:•,',:.,•.-' •,-:-^'. ;••", ^,v . -••: ,,'•-!
Ethybenzene
Antimony, Cadmium
Cadmium
Ethytoenzene
Antimony, Vanadium
Page 1 of 2
-------
Table d
SUMMARY OF NONCARCINOGENIC HAZARD INDEX RESULTS BY EXPOSURE PATHWAY
Matrix
Receptor
Exposure Pathway Nonarcinogenic Hazard Index Major Contributor(s) to Risk
Subsurface Soil
Subsurface Soil
Surface Soil
Surface Soil
Surface Soil
Surface Soil
Surface Soil
Surface Soil
Surface Soil
Surface Soil
Surface Soil
Construction Worker
Construction Worker
. = ::«.,< • „ , '
Adult Resident
Child Resident
Construction Worker
Construction Worker
Site Worker
Site Worker
Site Worker
Child Trespasser
Child Trespasser
Inhalation
Ingest ion
I1 ,
Inhalation
Inhalation
Inhalation
Ingest ion
Inhalation
Ingest ion
Dermal Contact
Inhalation
Ingest ion
• • i „
7.53E-10
1.35E-02
f( j ^
1.64E-09
3.28E-09
1.91E-09
2.71E-03
1.30E-09
5.83E-03
5.46E-07
5.25E-10
2.38E-03
Toluene
Arsenic, Bis (2-ethylhexyl) phthalate. Vanadium
!--'. ' - . .'•.,. ~ ' ''
Mercury, Toluene
Mercury, Toluene
Toluene
Bis (2-ethylhxyl) phthalate, 4,4-DDT, Hexachlorobenzene
Mercury, Toluene
Bis (2-ethylhxyl) phthalate, Heptachlor Epoxide
Cadmium
Mercury, Toluene
Bis (2-ethylhxyl) phthalate, 4,4-DDT, Hexachlorobenzene
' » ' » I ( I I I
Page 2 of 2
i • i » I i
1 i I l I » I < I » 1
' '
-------
TABLE e
Risk Assessment - Carcinogenic Toxicity Values
-------
TABLE e
HOOKER/RUCO SITE
TOXICITY DATA FOR NONCARCINOGENIC
AND POTENTIAL CARCINOGENIC EFFECTS
DOSE RESPONSE EVALUATION
Noncararwwn n
,| , •; RfD(oral) Vi|&jjj
iitt"vfa0K&bitlMmv
9.00E-02
NA
OOOE-03
8.00602
500E-02
t.OOE-01
NA
2.00642
1.006-01
7.00604
200E02
1.00642
NA
1.006-01
2.006-01
1.00642
2.0064)1
2006400
2.006-02
NA
NA
ssntcavons are as fellows:
Human Carcinogen. Sufi
DinhoklA Lh_«»» f-~I~n
wwenoauos*
, RfD(lnhala»on) ,
ife (mg/KjHtay) v.^:
3.00601
NA
ND
0.00E02
200E02
NA
NA
ND
2.90E03
ND
5.00E4>3
NA
NA
2.90E41
ND
NA
S.TOE^tt
8.60E42
ND
NA
NA
Detent evidence from i
itfWM* 1 tmltotl «*Lfk4«k««^
ouoonrorac Nonoarcm
RID (oral sub)
Hi'!1.! (mg'KBHlay):-,,1^!!-!
9.00E-01
NA
9.00E-03
500E01
NA
I.OOE+OO
NA
200E02
100E01
7.00E03
2.00E-01
lOOEtOO
NA
100E+00
2.00E400
t.OOE-01
200E+00
400E+OO
2.00E-01
NA
NA
Bpidemlologlc studies t
A Mi *m*S**l*MI%^l***M bk 1
ogen rwmrance uosa
RfDCnhatolion.«ub)
Vi-i.!'. (mo/Kg-day) , ••• ,..,
aooEtoo
NA
ND
O.OOEOt
NA
NA
NA
ND
2.90E03
ND
B.OOE-02
NA
NA
2.90E-01
ND
NA
2.70E01
860E02
ND
NA
NA
n fumnort • mmfll Avioclntki
V WJf^^M I •• VaifrtCM CiJJ^^jKllHJ
Cardnogen slope Factor
CNmfcalNwtt ,'',";''/,//
^ JiV ** •'!' ^ WM.'V^Jif! %,;i
Votatttea:
1.1.1 TrieHoroelhw»
1.1.2.2-TefracNonMthana
1.1 DIchkKoe then*
2-Butanona
4-Mettiy1-2-pentanona
Acetone
Benzene
Bronxxflchtorametttane
Cartoon DtsulMe
Cwfoon TekacMoride
Chlorobenzena
CMofofonn
Chloromethane
Ettiylbenzene
Slymnf
Tetrachkmettwna
Toluene
Total Xytenes
Trans-1,2-Dtcbtor oetfien*
Trtcnkxoelhene
Vinyl Chloride
Group A:-
Group B1:-
Group 82:- Probable Human Carcinogen. Sufficient evidence of cardnogenlcrty In animate. Inadequate evidence of carclnogenldty In humans.
Group C:- Possible Human Carcinogen. United evidence of cardnogenlcNry In animals.
Group D> Not Classified. Inadequate evidence ol cwdnogentefty In animate.
OraJSF
NA
200E01
6.00E01
NA
NA
NA
290E02
1.30E01
NA
1.30E01
NA
6 IDE 03
1.30E-02
NA
3.0064)2
5. 106-02
NA
NA
NA
1.10602
1.90E+00
Weight
1 , '.;-,i •..!;;.-,
D
C
C
D
NA
D
A
82
NA
B2
D
82
C
D
B2
B2
D
D
NA
82
A
Inhalation SF
NA
200601
1.20E+00
NA
NA
NA
290E02
ND
NA
1.30E01
NA
8.10E-02
6.30E03
NA
2.006-03
1.80603
NA
NA
NA
1.70E02
290E-01
Weight
D
C
C
D
NA
D
A
82
NA
82
D
>B2
C
D
82
B2
D
D
NA
B2
A
Compounds
, w/o Criteria
Note:
Al toxfctty Values unless otherwise noted are from Integrated Rbk Informatfon System (IRIS) June 1992 sessions.
and from Health Effects Assessment Summary Tabbs (HEAST)-1990 4tti Quarter (USEPA. 1990).
NA:NotAvalaMe
ND: Not Determined
Pano 1
-------
TABLE e
HOOKER/RUCO SITE
TOXICITY DATA FOR NONCARCINOGENIC
AND POTENTIAL CARCINOGENIC EFFECTS
DOSE RESPONSE EVALUATION
,v.-!;V% -,-i .•>'• .\\\:i' tlt'ft •!-... ',,•.-<•••'<:([ "i;
' NMmvelnQiimRqfiri
no. DM
• SubdironloNofloarclnpaanRotoronoBDosa
Cardnoden Slope Factor
Cnsmlc*! Nanw ••.{•':. 41'. ':! '' •'' 'tW. • • ' RfD(orsi) . «yu,HikRfDfJrih8latlcn) { . RID (oral sub) , RID(lnhalation. sub) OraJSF
Seml-Votatfles;
Doozolc Add
Bh(2-ethy1hexyl)phthaiate
Butyl benzyl phthalate
Dt-n-butylpMhalata
Dl-n-octyl prrihatale
Hexachtoroberuene
n-Nltrosodlphenylamlne
Phenol
Cardnoflonte PAHs (t)
NoncarclnogeotcPAHs
Acenaphlhene
' Anthracene i
Fluor anlhrene
FhJorene
Naphthalene
Pyreoe
EPA Weight of Evidence Ctas
f^^jtt,,, A •
Group 61 :•
Group B2:-
QroupC:-
OroupD:-
4.00E+00
2.00E-02
200E01
1.00E-01
200E-02
8.00E-04
NA
600E01
NA
6.00E-02
300E01
4.00E02
4.00E-02
4.00E03
3.00E-02
stflcfttlons w AS follows*
Probable Human Carcinogen.
Probable Human Carcinogen.
Possible Human Carcinogen.
NA
ND
NA
NA
NA
ND
NA
NA
NA
NA
NA
NA
NA
NA
NA
taubfcvv
4.00EtOO NA
200E02 NA
200E+00 NA
lOOEtOO NA
200E02 NA
BOOE04 ND
NA NA
600E01 NA
NA NA
800E01 NA
300E400 NA
400E01 NA
400E01 NA
400E02 NA
3.00E41 NA
NA
1.40E02
NA
NA
NA
1.60E«00
490E03
NA
560E+00
NA
NA
NA
NA
NA
NA
j^laMnn j-intaiinna"* Avnf^il
Weight Inhalation SF
(mo/Kg-day)-1
D
B2
C
D
NA
B2 1
B2
D
B2 6
D
D
NA
D
D
D
fA mr*i f*mns**
NA
ND
NA
NA
NA
60E+00
NA
NA
IDE +00
NA
NA
NA
NA
NA
NA
Weight
D
B2
C
D
NA
B2
B2
D
B2
D
D
NA
D
D
D
Untied evidence of cardnogenWty In human from epMemtotogtcal studies.
Sufficient evtdenoe of cardnogenlcHy In animals. Inadequate evidence of cardnonenldty In humans.
Limited evidence of cardnogertcWy In animals.
Not Classified. Inadequate evidence of cardneganfclty In animals.
AM ft^ul-lfe. ••-» .t^lAAA Illil 11 Illia n •**»•** A«A JMMMl iMtMMMiatft DU^ iMAMMMMllMM CM^fcMM flDICl hlMA
-------
TABLE e
HOOKER/RUCO SITE
TOXICITY DATA FOR NONCARCINOQENIC
AND POTENTIAL CARCINOGENIC EFFECTS
DOSE RESPONSE EVALUATION
Ch«n>cal Name
PCBs And Pesticide:
4.4'DDO
4.4' DDE
4.4'-ODT
Bet»BHC
CMordana(2)
DtekMn
HeptecMor EpoxMe
Total PCBS (3)
Subchronlc Nonoardnooen Reference Do«a
RID (oral tub)
Cardnoqen Stepa Factor
OralSF Weight Inhalation SF Weight
Compounds
wto Criteria
NA
NA
S.OOE-04
NA
6.00E-05
5.00E4S
1.30E-O5
ND
NA
NA
NA
NA
ND
NA
NA
ND
NA
NA
6.00E04
NA
600E-05
500E05
500E-04
NA
NA
NA
NA
NA
ND
NA
NA
NA
240E01
3.40E-OI
340EOI
I.80E+00
130E400
I.60E«01
910E»00
7.70E+OO
B2
B2
B2
C
82
B2
62
B2
NA
NA
340E01
180E+00
130E+00
160E«01
9. IDE 400
ND
B2
B2
B2
C
82
82
B2
82
(In
•pkta
°9»c
EPA Weight ol Evidence Ctassfflcatom are as follows
Group A> Human Carcinogen. SuflV
Group 81:-
QroupB2:-
QroupC:- PossMa Human Carcinogen. LMted evtdonce of cardnogenlcMy In anbnab.
Group D> Not Ctesslfled. Inadequata evidence of cardnogentelty In arrimab.
studtos to support • causal association between exposure and cancer.
Probable Human Carcinogen. Limited evidence of eardnogentdty In human tforn epktemMoglcal studies.
Probable Human Carcinogen. Sufficient evidence ol cardnogenldty In animals. Inadequate evidence ol cardnogenldty In humans.
Note:
Al toxtdty Values unless otherwise noted are from Integrated Risk Information System (IRIS) June 1992 sessions.
and from Health Effects Assessment Summary Tables (HEAST>1990 4tti Quarter (USEPA. 1990).
NA:NotAvalabte
ND: Not Determined
(2) Alpha cMordane b evaluated as chJordane.
(3) AM PCBs are evaluated as Arodor 1260
-------
Cn0fflNMl NttfTM • ;
V.,:."'". ••'•••< ':'•:.
Inorganics:
Antfmony
Arsenic
Barium
Beryllium
Cadmium
Chromium (III)
Chromium (VI)
Manganese
Mercury
Nlckal
Selenium
Slvw
ThaHum
Vanadkm
Zinc
TABLE e
HOOKEfVflUCO SITE
TOXICITY DATA FOR NONCARCINOGENIC
AND POTENTIAL CARCINOGENIC EFFECTS
DOSE RESPONSE EVALUATION
Nonc«folooq»n ftoterono Dose
.RtD(lnhalatlon)
4.00E-04
300E-04
700E02
600E03
100E03tood
5.00E-04watar
100E+00
800E03
1.00E01
300E04
200E02
SOOE-03
300E03
8.00E-05
700E-03
200E01
NA
NA
1.00E04
NA
NA
NA
NA
1.10E04
8.60EOS
NA
NA
NA
NA
NA
NA
n Subdvonlc Nonoardnonen Reference Pose
RID (oral cub) R(D(tnhalatton. wb)
(mg/Kg-4ay) {mg/Kg-day}
400E04
100E03
S.OOE-02
B.OOE03
NA
1.00E400
200E-02
100E01
300E04
2.00E02
NA
300E03
7.00E04
700E03
2.00E-01
NA
NA
1.00E03
NA
NA
NA
NA
1. IDE 04
060E05
NA
NA
NA
NA
NA
NA
Cardnonen Stops Factor
OralSF
(m#Kg dayy-1
NA
175E»00
NA
4.30E+00
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
Weight
NA
A
NA
B2
B1
NA
NA
D
D
A
D
D
D
NA
D
Inhalation SF
(mg/Kg-dayfl
NA
1.50E401
NA
8.40E+00
6.30E+00
NA
420E+OI
NA
NA
840E01
NA
NA
NA
NA
NA
Weight
NA
A
NA
B2
61
NA
A
D
D
A
0
D
>D
NA
D
Compounds
w/o Criteria
Cobalt
Copper
Iron
Lead
EPA Weight ol Evidence Ctessfflcattons are as Mtows:
Group A:- Human Carcinogen. Sufficient evidence from epMemlologlc studtes to support a causal aasodatton between exposure and cancer.
Group B1:- Probable Human Carcinogen. Dented evMenoa of cardnotfunlcHy In human from eptdemtotogtcal studtes.
Group 82:- Probable Human Cardnogen. Sufficient evtdanoa ol cardnogenlcHy In anhnab. Inadequate evidence of cardnogenldty In humans.
Group C:- Possible Human Cardnogen. Limited evidence ol cardnogenlcWy In anlmab.
Group D:- Not Classified. Inadequate evidence ol cardnogenklty In animals.
Note:
Al toxWty Values unless ottwrvube noted are from Integrated Risk Information System (IRIS) June 1992 sessions,
and from Health Effects Assessment Summary Tables (HEASTJ-1990 4th Quarter (USEPA. 1990).
NA :Not Available
ND: Not Determined
Page 4
-------
TABLE f
Risk Assessment - Carcinogenic Risk Estimates
-------
Table £
SUMMARY OF CARCINOGENIC TOTAL RISK RESULTS BY EXPOSURE PATHWAY
Matrix
Receptor
Exposure Pathway Carcinogenic Risk Major Contributor(s) to Risk
Surface Water
Surface Water
Ground Water
Ground Water
Ground Water
Ground Water
Ground Water
Ground Water
Sediment
Sediment
Sediment
Sediment
Sediment
Sediment
• . • .':. •<•>'• '"
Child Trespasser
Site Worker
Child Resident
Adult Resident
Child Resident
Adult Resident
Dermal Contact
Dermal Contact
Inhalation
Inhalation
Ingestion
Ingestion
Child Resident Dermal Contact
Adult Resident Dermal Contact
IKWTOWWl-t W^l!f^'ffl^^ll»->^^lr'i":'-T':'^Hr '"» 5I"! ':'?'• -' '?' W*
SHe Worker Ingestion
SHe Worker Inhalation
SHe Worker Dermal Contact
Child Trespasser
Child Trespasser
Child Trespasser
Ingestion
Inhalation
Dermal Contact
9.05E-05
1.05E-04
109E-04
5.06E-04
8.84E-04
2 21 E 03
1.34E-05
1.12E-04
V !¥'r't!'?!1!""':iVii*4'V%':
2.78E-06
1.23E-09
2.42E-06
611E06
8.48E-11
2.56E-06
Beryllium. PCBs
Beryllium. PCBs
'•'• ', • f", ' . ' ' . ! ' ' i ' '
Vinyl Chloride
Vinyl Chloride
Vinyl Chloride. Arsenic,
Vinyl Chloride. Arsenic,
; r-r,. .,.-..
BerylHum, Tetrachloroethene
Beryllium, Tetrachloroethene
Vinyl Chloride, Arsenic, Tetrachloroethene
Vinyl Chloride, Arsenic, Tetrachlordethene
PCBs
Cadmium
PCBs
PCBs
Cadmium
PCBs
Page 1 of 2
-------
Matrix
Table f
SUMMARY OF CARCINOGENIC TOTAL RISK RESULTS BY EXPOSURE PATHWAY
Exposure Pathway Carcinogenic Risk Major Contributor(s) to Risk
Surface Soil
Surface Soil
Surface Soil
Surface Soil
Surface Soil
Surface Soil
Surface Soil
Surface Soil
Surface Soil
Surface Soil
Surface Soil
i
Subsurface Soil
Subsurface Soil
Subsurface Soil
Adutt Resident
Child Resident
Construction Worker
Construction Worker
Construction Worker
Site Worker
Site Worker
SHe Worker
Child Trespasser
Child Trespasser
Child Trespasser
.v^-ru.. •.*".•«< .•:'".'!.'•.. 'it-. 'W-. •:•"••
Construction Worker
Construction Worker
Construction Worker
Inhalation
Inhalation
Ingest ion
Inhalation
Dermal Contact
Ingestion
Inhalation
Dermal Contact
Ingestion
Inhalation
Dermal Contact
Ingestion
Inhalation
Dermal Contact
6.40E-09
2.56E-09
2.11E-06
1.69E-10
181E-06
493E05
4.23E-09
4.52E-05
1.12E-05
2.79E-10
1.40E-06
3.19E-06
5.57E-10
498E-06
PAHs. Arsenic. Hexachlorobenzene, Heptachtor Epoxide
PAHs. Arsenic, Hexachlorobenzene, Heptachlor Epoxide
PAHs, Hexachlorobenzene,
PAHs, Hexachlorobenzene
PCBs
PCBs. PAHs
Hexachlorobenzene, PAHs
PCBs
PCBs. PAHs
PAHs
PCBs
PCBs
PCBs, PAHs, Arsenic, Bis(2-ethylhxyl)phthalate
PAHs
PCBs, Arsenic
Page 2 of 2
-------
TABLE g
Rick Assessment - Contaminant Concentration Data
-------
EBASCO Fill
06/02/92
WOK'S CKENICM./KXC FCtTSS >iir
SUMMARY OF CHEMICAL COMPOUNDS ( DETECTS • UNDEIECIS/2 )
SEDIMENI mSIDE t OUTSIDE SPILL MM
PACE 1
NININUN
UN- FIEO OETECfEO
COMPOUND VALID OCCUR OflECI EtT IEJECI OE1EC! CORCENIRAIION SAMPLE ID
II Volllll* ( VQA ) ug/Kg
< H«loo«n*t«d VoUlllo >
lETRACNLOMflHENf 10 2 822 0.20 0.100 II 29 6 10
IRANS-I.2-OICIUOtOETHENE 12 2 10 2 0 0.17 M.OOO II 28 8 10
IRICNLOROEINCNI 12 2 10 2 0 0.17 1.000 11 28 8 10
TOTAL ••••> IS. 100
( Non-Nilogerwttd Volotlln >
EINUBCNIENE 12 r J 6 0 O.S8 0.900 IB 29 6 80
SITRENE 8 1 71 4 0.11 0.600 II 29 8 10
TOIAL ••••> 2.500
II P«itfcf ug/K«
( PCil >
««OCIOR I24B 12 f $ 0 0 O.S8 HOO.OOO II 29 8 10
10IAL •*••> UOO.OOO
II Inorganic ( IHOOC ) ng/Kg
AlUNINUN 12 6 660 0.40 1000.000 II 28 6 8
ANIINONT 12 * 810 0.31 8.000 II 28 6 8
NAXIHUM
DETECTED
CONCENTRATION SAMPLE 10
0.600 IB 29 6 80
76.000 II 21 6 8
2.000 II 28 6 8
78.600
120.000 II 28 8 TO
0.600 II 29 8 10
9.000 18 29 0 2
129.600
10000.000 II 30 0 2
10000.000
3000.000 IB 29 8 10
11.000 IB 28 8 1O
MEDIAN
CONCOIRATIGN
GEOMEIRIC
MEAN
MEAN
CONCENIRAIION
LOUER
OUARIILE
UPPER
OUARIILE
SINDRD.
DEV.
9SX Cl
UPPER LINII
1.000
1.000
1.000
3.500
1.000
6.000
2100.000
1500.000
8.000
0.842
1.925
0.9U
4.127
0.938
2.280
781.224
12)4.067
5.J39
0.890
10.000
1.000
21.367
0.950
3.500
2704.583
1400.000
6.9S8
1.000
1.000
1.000
1.000
1.000
1.000
95.000
950.000
3.000
1.000
1.000
1.000
19.000
1.000
9.000
1700.000
11.000
1.487
4.659
1.429
5.876
1.198
2.863
5400.000 7.229
1.700
2.250
1.201 X
48.92S
1.251
280.031 »
1.092 X
80341.332 X
106606.002 X
2042.967
14.490 X
NOIE: ( X >, IN 95X Cl COtUM, INDICATES VALUE IS CREAIER THAU MAXIMUM COKCENIRAIIOM; ( • ), ASTERISKS, INOICAIE THAT IKE NUMBER OF OCCURRENCES IS 100 SNAIL 10 AltOU CALOJLAIION
-------
IBASCO fill
116/02/92
HOOKER CHENICAl/RUCO POLTNEft SITE
SUMMARY OF CHEMICAL COMPOUNDS ( DETECTS « UNOEIECIS/2 )
SEDIMENT INSIDE t OU1SIDE SPILL AREA
PACE 2
• COMPOUND
ARSENIC
IIARIUM
CADMIUM
C.ALCIUN
I:HRONIIM
' I 08 All
, ami
•' IRON
IEAD
HACNESIUH
MANGANESE
NICKEL
I-OIASSIUM
bOOIUM
IHAlllUN
VANADIUM
IIKC
UN-
VALID OCCUR OEIECT
12 6
12
12
12
12
12
12
12
12
12
12
12
12
12
12
12
12
6
6
6
6
7
6
6
6
«
6
6
7
6
to
6
6
ESI
0
0
6
0
0
0
0
6
6
6
1
0
0
6
I
0
0
MINIMUM MAXIMUM
FIEO DETECTED OEIECTED
•EJECT DETECT CONCENTRATION SAMPLE ID CONCENTRATION SAMPLE ID
0 .$0 1.100 II 28 8 10 7.100 IB 29 0
0 .SO 7.800 11 29 6 80 16.000 II 29 0
0 .SO 1.900 tl 29 0 2 9.000 IB 29 6
0 .SO 170.000 II 29 6 80 700.000 TB 29 0
0 .SO 18.000 » 28 6 8 61.000 IB 29 0
0 .42 0.260 II 28 6 8 2.SOO IB 29 8 10
0 .SO S.400 II 29 6 8D 80.000 II 29 0 2
0 .SO 1400.000 11 28 6 8 6900.000 II 29 8 10
0 O.SO 2.600 11 29 6 8 59.000 II 29 0 2
0 O.SO 190.000 IB 28 6 8 790.000 IB 29 0 2
0 O.SO 8.SOO II 28 6 8 42.000 II 29 10
0 O.SO 1.500 II 28 6 8 6.500 II 29 10
0 0.42 71.000 112968 270.000 1129 10
0 O.SO 110.000 II 29 8 10 210.000 18 29 8
0 0.17 0.400 II 28 6 8 0.600 II 28 10
0 O.SO 2.000 II 28 6 8 42.000 II 28 10
0 O.SO 21.000 II 29 6 8D 150.000 II 29 2
MEDIAN
CONCENIRAIION
1.2SO
10.400
2.7SO
295.000
11.750
0.900
14.500
2*25.000
10.250
275.000
9.600
1.700
110.000
170.000
0.27S
1.775
39.500
GEOMETRIC
KAN
1.298
8.206
0.858
200.450
26.604
O.S76
11.225
1791.697
7.819
214.199
9.890
1.218
69.766
164.610
0.214
1.916
27.148
MEAN
CONCENIRAIION
1.800
9.511
2.919
265.811
11.111
0.902
19.646
2645.811
14. 717
297.500
14.258
2.061
109.417
168.750
0.262
6.804
41.458
LOWER
QUART HE
0.900
4.900
0.085
85.000
16.500
0.285
S.400
800.000
1.100
190.000
6.000
0.455
71.000
115.000
0.160
2.100
10.500
UPPER
OUARIIIE
2.100
15.000
6.600
180.000
54.000
1.200
18.000
5100.000
25.500
185.000
21.000
1.200
150.000
210.000
0.150
6.500
55.000
SINORO.
OEV.
2.221
1.810
7.289
2.108
1.828
2.989
1.018
2.609
1.150
2.084
2.188
1.195
2.019
1.260
1.618
2.451
2.912
95X Cl
UPPER LIMII
1.112
15.289
120.511 X
567.160
49.499
1.212 X
64.797
6597.182
48.772
541.995
29.611
7.969 X
200.882
191.404
0.158
12.148
141.211
10IAI ••••>
1041.260
12580.700
-------
IBASCO mi
fJ5/2?/9»
HOOKER CKENICAl/lluCO KniKi Site
SUMMARY OF CHEMICAL COMPOUNDS ( DEIECIS « UNOEIECIS/2 )
SU1SURFACE SOU INSIDE t OJISIOE SPIll AREA
COMPOUND
II Volalilt ( VOA ) U9/»S
( Hllogenitcd VoUlilcl )
1,1,1-iRicmoROEiiuuiE
1.1,2,2-IEIRACNLOtOEIHAIIE
1.1-DICHIOROE1NENE
BROMOICHLOMMEIMUIE
CMMM IEIRACHLORIOE
CHLOROBEMEIK
CHLOROFOW
lEtRACMlOROEIHENE
!•»«$• 1,2 DICHLOROEIHEIIE
1RICHLOROHNENE
( Non-Hilofttnated Volitilet >
BENIEIIE
CARION DISULflDE
EINIIIENIENE
SHRENE
lOtUENE
IOIAI XTLEHES
M.IO
61
63
63
61
63
63
52
58
61
63
63
60
63
62
44
60
OCCUR
3
1
2
1
U
2
7
36
7
It
3
1
2
2
19
5
UN
DEIECI
60
62
61
60
49
61
U
22
54
45
60
59
61
60
25
55
ESI
3
1
2
1
U
2
7
36
7
17
3
0
2
2
ia
s
FREQ
REJECT DEIECI
0 0.05
0 0.02
0 0.03
2 0.02
0 0.22
0 0.03
11 0.13
S 0.62
I 0.11
0 0.29
torn ••«>
0 0.05
3 0.02
0 0.03
1 0.03
19 0.43
3 0.06
MINIMUM
DEIECIED
CONCENIIAIION SAMPLE ID
0.000 U 10 3 5
13.000 II 10 3 »
S.OOO II 11 3 S
1.000 11 M 3 5
0.600 11 10 12
0.300 II 25 3 S
1.000 01 10 12
0.300 11 39 3 »
2.000 11 39 3 S
0.400 II 33 6 10
24.400
0.500 11 10 3 5
7.000 II 20 10 12
2.000 II OS 3 5
0.500 II 19 6 8
0.500 01 10 12
0.000 II 22 10 12
MAXIMUM
DEIEC1EO
CONCEN1IAIION
2.000
13.000
15.000
3.000
40.000
11.000
24.000
030.000
720.000
7600.000
9258.000
1.000
7.000
2.000
9.000
1400.000
28.000
MEDIAN CEOMEIBIC MEAN tOUER UPPER SINDBD.
SAMP1E
li M
11 10
IB 05
U OS
II 21
II 05
II 01
II 05
U 18
II 18
II 08
II 70
II 08
11 IB
II OB
11 os
ID CONCEHIRAIION MEAN CONCENIRAIION OUARIILE OUAR1UE DEV.
50 .000
5 .000
11 .000
5 .000
4 16 .000
11 .000
s .000
11 .500
10 12 .000
10 12 .000
3 50 .000
10 12 .000
3 50 .000
10 12 .000
3 50 .000
9 11 .000
.202 1.862 .000
.210 2.024 .000
.200 1.929 .000
.208 1.893 .000
.370 3.140 .000
.159 1.830 .000
.428 3.027 .000
.169 42.990 .000
.521 15.311 .000
.856 129.171 .000
.163 1.822 .000
.230 1.975 .000
.252 2.008 .000
.199 1.806 .000
.253 122.487 .000
.361 2.713 .000
.000 1.897
.000 2.013
.000 1.942
.000 1.921
.000 2.590
.000 1.931
.000 2.597
1 .000 7.003
.000 3.245
.250 4.835
1.000 1.902
1.000 1.986
1.000 1.996
1.000 1.924
26.000 11.6)0
1.000 2.384
95X Cl
UPPER I IHII
1.740
1.897
1.774
1.774
2.848
1.705
3.064
68.897
4.499
12.193
1.68B «
1.864
1.899
1.761
593.360
2.547
IOIAI •••«>
11.300
1447.000
NOIE: < X 1, IN 95X Cl COIUHN. INOICA1ES VALUE IS CREAIER IHAN MAXIMUM CONCENIRAIION; ( • >. ASIERISKS, INOICAIE IHM I HE NUHBCR OF OCCURRENCES IS IOO SMALL 10 ALLOW CM.CUIAIION
-------
(••SCO (-III
M/2A/V2
MXBII tMHi»i/iuto nami nit ma
fuMif Of curnicu covouet < Minn mil >
UDII«»I IIMOf I OllSIOf Will UK
mmiui NumM
un rna Miicm ociiciro MOIU CICKIIIC MM UMI umi nwto. «t ci
VHID oton MIECI 111 tijtci Miici ttKiiiiMio wwti IB cwcinit«iIM umi n toMniuuai «u amiiiMiai aiuiui OUMIIII 01*. UPHI imn
Mtt/Kt
>00 O.M HOO.OOO II 19 a 10 10000.000 l« JO 0 ? MOO.000 1615.570 U7I.4I9 1100.000 . MIUIUI. IBIUII lui !«• IMII w occutimat 11 too m»i 10 uiw
-------
moiti CMiiini/nicoraim* sin
MMMT or e«mc*i commit < H licit mil )
SUKWIUE ton mm I amiof win utt
cavomo
• mmiui
m/«t
< raiment «rc»»tlc »
I-MIMIUMIMIIM
MtwniMIt
UIMCIM
MITOUIMIHUtlM
•fllOI.IHItW
IfltOlblllUDIUIMM
MIMIkiriUOtUUMIIf
CMIHH
iiura/umm*
MMIMICK
mUUIMIM
rtn«e
I rtil»«l«lt filtri 1
MIIOIC UIO
11112 iiniKniiMiui
II -11-lumMtlUMI
UK xin muuli
iixini Mtuutf
Hirer Kim >
41
41
41
41
41
41
41
41
4t
41
41
41
4!
Ml 14
11
41
41
UOIF : f I
1
t
1
t
t
I
1
4
It
t
11
It
1
11
1
1
1
» !•
4t
4t
It
41
41
M
42
17
10
41
II 10
tl It
0.02
1.02
I.OI
1.01
0.01
0.01
1.01
0.10
•.If
I.Ot
0.11
0.21
IOIM ••••>
60 0 0.0!
i tr o.n
M It 0.4*
41 1 O.M
41 • 4.01
tot* ••••»
tl.OOO
111.10*
4I.M
16*. MO
IW.M
1 21.100
II*.***
7*.M*
tl.«0»
K.MO
41.«N
M.OOO
1201.000
•44.000
tM.M*
IT**.**)
ItM.MO
n.m
MM.M*
I* It 10 12
II tO 1 i
t* 01 » II
ii n « ii
II 40 1 1
II 14 1 1
tl to 1 1
n ii i i
ti ii i i
II It 10 It
ii it i i
t* it i i
ti » 1 1
II 10 10 II
II tl It It
tl M * 11
n n 10 it
•0.000
110.000
110.000
110.000
tto.ooo
tto.ooo
IM.OOO
110.000
470.000
11.000
ivo.ooo
600.000
1794.000
7100.000
40000.00*
MOO. 000
ItW.M
7t.«*
tnrt.ooi
ii n 10 it
II tO 1 i
II to J »
II tO 1 5
II 20 10 12
1* IO 1 I
II tO I 1
II tO 10 It
II IO 10 It
II » 10 It
II 2O 10 II
II to S »
II IV 6 I
•t to it
tl M • tl
ii n » ti
H n t* 11
0.000
o.om
110.000
IM.OOO
tto.ooo
•70.000
0.000
200.000
m.ooo
0.000
120.000
tto.ooo
7100.000
uoo.oao
MOO. 000
l.ooo
•.IM
•0.000
110000
M.tl7
119.7*1
111. MI
117.0tl
IM.OOO
174.71*
161.1*1
11.000
I».OM
It!.tl7
l*7*.tl*
1701.M1
114*. 701
ItOO.OO*
Tt.OO*
10.000-
110.000
•9.000
ttl.OM
1*0.000
171.000
] 10. 000
101.647
229.917
I*. 000
1*0. Ill
191.lt!
MRO.OOO
I19II.07T
tai.ni
i too. ooo
7t.*0*
0.000
1.000
0.000
•.000
•.000
m.ooo
0.000
120.000
tto.ooo
0.000
91.000
19.000
(.000
771.000
(.000
0.000
root
0.000
0.000
0.000
•.000
• .000
tll.OOO
0.000
MO.ooo
MO.COO
0.000
120.000
tto.ooo
•.000
uot.ooo
*.oo*
*.M
•.M
1.000
1.000
.tot
.Ml
.t4t
.111
.000
.114
.ttt
.000
.111
.011
l.oa
1.U7
l.ltl
I.W*
t.M*
tm
••••••••••••• 1
144.210 I
661. til I
141.11*1
712. ttt 1
M7.t7* I
tll.lM
147. *7t
H1.M2
I647721017.il I
ll*7tl.007 I
1295 .til 1
-------
EBASCO fill
05/27/92
HOOKER CNENICAl/RUCO POtYHEl SUE
SUNURr 0( CHEMICAL COMPOUNDS ( OEIECIS » UNDEIECIS/2 )
SmSlMFACE SOU INSIDE I OUTSIDE SPIll AREA
PAGE I
UN-
COMPOUND VALID OCCUR OEIECI 1
( Others )
N-NIIIOSODIPHENUAMINE 61 1 62
II Ptttlcldt/Polychlarlrwtxl llphmyt ( PESI/PCI
( PMticldet )
4-4-000 62 1 61
4-4-OOC 62 1 61
4 4 001 62 1 19
ALPHA CHLORDANE 62 1 61
•ETA-IHC 62 1 59
MPIACHIM EPOXIDE 62 1 61
( PCfls )
AIOCLOR 1248 62 14 48
AROCIOR 1254 62 4 58
1) Inorgmic 1 INORC ) *g/tg
ALUMINUM 61 51 6
ANIINONT 57 12 45
Ml
FREQ OE
•SI REJEC1 OEIECI CO
1 0 0.02
101 Al ••••>
> ug/(g
0 0 0.02
0 0 0.02
2 0 0.05
1 0 0.02
0 0 0.05
1 0 0.02
I01AI ••••>
0 0 0.21
0 0 0.06
10IAL ••*=>
18 0 0.87
6 4 0.21
NINUM
IECIED
NCENIRAIION SAMPLE ID
71.000 IB 12 I 5
71.000
150.000 II 20 10 12
41.000 11 07 9 11
24.000 II 04 11 15
19.000 II 20 10 12
170.000 II 06 9 11
12.000 II 20 10 12
618.000
440.000 PH J 10 12
490.000 11 16 1 5
910.000
600.000 R1 10 12
1.000 1* 16 1 5
MAXIMUM
DEIECIEO MEDIAN GEOUIRIC MEAN 1 Out 8 UPPIR SIHORO. 95X Cl
CONCEN1RAIION SAMPLE ID CONCEN1RAIION MEAN CONCENIRAIION QUAR1IIE OUARMLE OfV. UPPER LINII
71.000 IB 12 1 5 in. 000 225.771 646.165 170.000 185.000 2.778 5J1.792 >
71.000
150.000 II 20 10 12 17.000 20.812 92.790 16.000 18.000 2.191 18.959
41.000 II 07 9 11 17.000 20.119 87.819 16.000 18.000 2.221 14.155
160.000 II 20 10 12 17.000 20.810 89.992 16.000 18.000 2.105 17.179
19.000 IB 20 10 12 85.000 97.579 412.056 80.000 90.000 2.227 168.601 >
210.000 II 06 11 15 8.500 11.517 52.877 8.000 9.000 2.791 27.448
12.000 II 20 10 12 8.500 9.916 41.116 8.000 9.000 2.209 16.852 1
814.000
24000.000 II 22 10 12 85.000 190.116 1270.415 80.000 180.000 4.78] 1228. 5J6
1900.000 IB 12 1 50 170.000 222.020 979.819 160.000 180.000 2.576 459.251
27900.000
15000.000 IB 17 1 5 2700.000 2544.117 1621.80) U50.000 5050.000 2.164 4707.160
9.000 IB 26 1 5 4.000 2.951 1.570 1.500 5.000 1.884 4.261
-------
IBASCO f-lii
05/27/92
COVOUHD
MSEHIC
BMMI*
KIUUUN
CMttlUN
CWXIO"
CMONIUH
COttll
COPPW
IMM
UAO
MAGNESIUM
HEICUM
POUSSIIW
SEIEHIUM
SIIVCR
SOOIUH
MM. HUH
1INC
HOCKE1 CHlHiC«W;iXS KM'!** *IK
SUMMIT Of CHEMICAL COMPOUNDS ( Of It CIS • UNOE1EC1S/2 >
sou IHSIOE i OUISIDE win AMA
I1PPE6 SIHOHO. 9M Cl
KAKIW
UN- '«"
»»UO OCCU. OEHCt ESI KJECI BIIKI
OE1IC1ED
I0
5,
61
61
59
61
56
61
61
61
61
61
58
61
55
61
61
61
61
61
58
58
45 8 11 8
51 810
21 40 0
20 19 16
51 8 24
48 8 24
51 10 6
51 8 24
51 87
5, 8 11
51 8 17
50 8 22
1 58 1
44 11 9
51 8 21
1 58 1
14 47 IS
52 9 26
1 60 1
49 9 21
50 8 29
0,85
0.87
0.14
0.14
0.87
0.86
0.84
0.87
0.87
0.87
0.87
0.86
0.05
0.80
0.87
0.05
0.21
0.85
0.02
0.84
0.86
0.700 HP 10 12
2.800 PH K 10 12
0.170 HP 10 12
0.190 01 10 12
61.000 IP 10 12
1.900 11 06 11 15
0.470 11 07 11 15
1.800 18 06 11 15
2100.000 18 06 U 15
1.200 IP 10 12
84.000 18 18 10 12
5.600 II 18 10 12
0.110 11 04 7 90
0.420 18 12 4 6
16.000 PH t 10 12
0.400 11 18 10 12
0.510 HP 10 12
120.000 11 16 1 5
0.500 PH 1 10 12
0.170 01 10 120
1.400 HP 10 12
tOIAl "">
,024.160
— -"
250.000
42.7,2
-------
IBASCO Fill
05/27/92
HOOKER CHENICAl/RUCO POITMER SUE
or CHENICU COMPOUNDS < OEIECIS • UDEIECIS/J >
SUBSURFACE SOU INSIDE I Oil SIDE SPIU ME*
PAGE 2
COMPOUND
UN-
VALID OCCUR DEIECI ESI REJECI
(I 8»« Neutr.l Acid ( 8NA ) u«/K«
{ Polycyclic AroMtic Hydrocirbora )
2-NEINn*APNIIttlfM 6}
ACENAMINfM
ANIWACENf
UltOMMINMCUf
lEMOUlPmiE
HltOlbiriUOUHIMENE
lENtOUIHUORANIMENf
CHRfSftt
rtUO«ANIH«ENE
NAPHINALENC
PHENANTKSENE
PtRtNt
( PMh.t.tt Citcn >
8ENIOIC ACID
IISK-EINUNEXUIPHIHAIAIE
DI-n-WmPNINAlAlE
01 n OCIIl PRIHAIAIE
DINEINU PHIBAIATE
61
6]
61
6}
6}
6)
61
62
61
62
62
61
16
15
62
61
1
1
2
2
2
S
1
6
12
1
11
14
1
11
1
1
1
62
62
61
61
61
sa
62
57
SO
62
SI
48
60
)
12
61
62
1
I
2
2
1
1
1
6
9
1
10
12
2
6
2
0
1
0
0
1
0
1
1
TOTAL
0
47
28
1
0
MINIMUM
FREO OCIECIEO
DEIECI CONCENIRAIION
0.02
0.02
0.01
0.01
0.01
0.08
0.02
0.10
0.19
0.02
0.18
0.21
••••>
0.05
0.81
0.09
0.02
0.02
40.000
110.000
68.000
160.000
140.000
120.000
110.000
70.000
41.000
18.000
45.000
59.000
1201.000
840.000
480.000
1700.000
1400.000
74.000
MAXIMUM
DETECTED
SAMPIE IP COXCENIRAIION
II 22 10 12 40.000
II 40
18 OS
18 05
18 40
18 16
18 40
18 16
18 12
18 22
18 12
18 12
S UO.OOO
11 UO.OOO
11 110.000
240.000
450.000
110.000
110.000
670.000
0 12 18.000
590.000
600.000
1798.000
18 15 1 S 7100.000
18 20 10 12 88000.000
18 21 12 14 1000.000
18 OS 9 11 1400.000
18 22 to 12 74.000
MEDIAN GEOKEIRIC MIAN tOUER UPPER SINORD. 9SX Cl
SAMPIE ID CONCENIRAMON MEAN CONCENIRAIION OUARIIIE OUARIIIE OEV. UPPER UHII
II 22 to 12
11 40 I S
II 40 1 S
II 40 1 S
II 20 10 12
II 40 1 5
11 40 1 S
II 20 10 12
II 20 10 12
11 22 10 12
II 20 10 12
II 40 } 5
II 19 6 a
Ml 10 12
II 05 9 11
II OS 9 11
II 22 10 12
175.000
ITS. 000
ITS. 000
175.000
175.000
175.000
175.000
175.000
172.500
ITS. 000
170.000
170.000
850.000
4500.000
170.000
175.000
175.000
220.844
227.147
224.06S
211.124
229.164
214.106
211.147
228.74}
227.902
217.114
220.255
219.171
1152.146
1111.421
274.161
250.111
225.921
841.968
846.984
845.165
850.117
848.151
855.476
850.476
850.159
869.177
845.52$
861.081
861.758
4258.750
11705.625
969.714
955.081
846.411
170.000
170.000
170.000
170.000
170.000
170.000
170.000
170.000
170.000
170.000
170.000
170.000
.
800.000
750.000
170.000
HO. 000
170.000
185.000
185.000
185.000
185.000
185.000
185.000
185.000
185.000
185.000
185.000
185.000
185.000
900.000
9200.000
185.000
185.000
185.000
2.810
2.760
2.790
2.752
2.751
2.77}
2.751
2.789
2.918
2.9tl
2.950
2.970
2.8?8
5.98}
1.219
1.042
2.776
511.469 »
510.816 X
510.761 1
517.528 X
555.146 X
550.592 X
517.811 X
541.812 I
581.459
546.258 X
565.117
567.998
2780.921
126880.874 X
940.611
671.266
551.609 >
TOTAL <"•>
4494.000
99574.000
-------
EBASCO (III
HOOKER CHEMICAL/RUCO POUT*8 SUE
SUMUR* Of CHEMICAL COMPOUNDS t DEIECIS • UNOEIECIS/2 )
GROUNDUAIER
PAC.I 1
MINIMUM
UN- fREO OtltCUO
VALID OCCUR OEICCI ESI REJECT OEIECI CONCCNtlAMON SAMPLE ID
MAXIMUM
DETECTED
CONCENIRAIION
( Htlognwted Volatile* >
Chlorobtmen*
ChloroMthMit
IctrKhlorMthcn*
trm-1,2-Olchloroeth«M
frichloroehlrn*
Vinyl Chloride
< Non-Hilogenited VolitllM )
2-lut«nom
4-Nethyl -2-Pcntwione
Acetone
leniene
C«rbon Oi tut I Id*
Ethylbemen*
Kylene
2
9
0
1
2
r
21
1
11
10
to
1
1
1
19
.000
.000
.800
.000
.000
.000
.800
.000
.000
.000
.000
.000
.000
.000
.000
El
* 1059 1
12
12
C2
02
J2
J1
A1
N 1059 1
02
El
H
MEDIAN CEOHEIRIC
SAMPLE 10 CONCENIRAIION MEAN
WAN
CONCENIRAIION
6.000
10.000
98.000
54.000
18.000
560.000
746.000
i.ooo
120.000
10.000
10.000
4.000
8.000
15.000
170.000
Nl D
01
01
01
• 1059
J2
Pt
• 1059 1
M
PI
Pt
0.020
0.06*
0.070
0.050
0.095
0.085
i.OOO
i.OOO
10.000
0.020
2.500
0.0 JO
o.oso
LOWER
OUAtllLE
0.027
0.086
O.S07
0.158
0.297
0.278
4.910
5.951
10.000
0.024
2.167
0.046
0.100
UPPER
aiARMlE
SIHDRD.
DEV.
95X Cl
UPPII I INI I
0.241
0.589
11.979
4.86!
2.096
22.180
4.944
14.106
10.000
0.297
2 455
0.528
0.901
0.020
0.06S
0.070
0.050
0.095
0.085
5.000
5.000
10.000
0.020
2.500
0.010
0.050
0.020
0.065
5.000
1.000
2.000
0.085
5.000
5.000
10.000
0.020
2.500
0.030
0.050
1.1)5
1.181
15.182
12.117
6.694
12.565
1.089
2. on
1.000
2.817
1.149
4.117
5.088
0.100
0.290
275.570 I
55.590 I
6.150
68.510
5.070 I
10.190
10.000
0.070
2.720
0.290
0.970
NOIE: C X I, IN 95X Cl COLUMN, INOICAIES VALUE IS CREAUR I HAN MAXIMUM CONCENIRAIIOH; ( • >, ASIERISKS, INDICATE I HA I IDE NUMBER OF OCCURRENCES IS 100 SMALL 10 ALLOW CALCULATION
-------
luico rui
M/27/92
nootti cutmtn/mco POUMI mi
BfMII 0) CMMICM COHKMBt ( MIICIS Wit >
Msuirur sou IHIIM i IUISIM sun «•(•
MM t
I Ottwrl I
II P*«tlrl
totu ••••>
910.000
27900.000
-------
fWtCO I III
u/nin
wntit CWKICII/IUCO poiim silt
suwtT M cnnicai coraMD! ( Mireu ant >
CKUDtUlfl
HIIIIWI MIIWH
>•• 'HO NTICIIO OtlltlfO KOIW CfOWtllC NIW lOWt umi
v«l«l«l«
f>
M
14
It
1
I
1)
H
))
0.»
0.01
0.01
1.000 111
«5.000 fl
I.000 01
a.ooo
» ooo it
tt.ooo ri
;.ooo 01
51.000
1.000
0.000
0.000
t.wt
H 000
1.000
1.000
il 000
1.000
? 000
0.000
0.000
«.ooo
0.000
0.000
1.WI
i.ooo
i.ooo
II Mlllcldt/Polyclilorliwtcdllplunyl ( PC1I/KI > ug/t
OIIIOIIII
«>IMm« CMIIM
M
II
0.0!
O.Ot
0.004
•.on
o.oo« u
0.011 It
0.000
0.011
0.004
o.oor
0.004
0.009
0.000
0.000
0.000
0.000
1.000
1.121
o.na i
•out («).!• n* ci coitM, iiniotit vui* if cn«ii« mu MIIIUI cowi«i*nni; 1*1. HIIIIHI. IIBIC*II iwi IN mmtt t» occumwti n 100 iwii 10 «uou CMCUMIOI
-------
EIASCO f III
06/03/9?
HOOKEI CHENICAl/RUCO POirNER SHE
SUMMAII OF CHEMICAL COMPOUNDS ( DEICCIS • UNOEIECI5/2 )
CROUNOVAIE*
MINIMUM
COMPOUND
IERUIIUM
CADMIUM
CALCIUM
CHROMIUM
COMLI
COPPfR
IRON
LEAD
MAGNESIUM
MANGANESE
MERCUtr
NICKEL
POt ASS 1 UN
SELCNIUM
SILVER
SODIUM
VANADIUM
2INC
VALID
IS
IS
IS
10
IS
11
14
It
IS
11
IS
22
14
IS
11
IS
28
22
UN-
OCCUR DEIECI
15
a
14
15
17
19
17
14
11
IS
11
1
7
14
1
7
IS
6
11
0
27
21
0
11
16
16
0
18
0
0
M
IS
0
M
26
0
22
It
IKO DETECTED
ESI REJECT DEIECr CONCENTRATION SAMPLE ID
2
0
1
29
2
1
2
26
11
4
25
0
1
5
1
6
10
2
6
0 1.00
0 0.21
0 0.40
0 1.00
S O.S7
0 O.S4
2 O.S2
1 1.00
4 0.42
0 1.00
2 1.00
0 0.01
IS 0.12
1 1.00
0 0.0]
2 0.21
0 1.00
7 0.21
11 0.50
8.000 S2
0.210 G2
1.000 D2
2400.000 A2
1.000 F1
2.000 Et
0.140 F2
49.000 N1 0
2.000 02
160.000 SI 0
4.000 II
0.200 It
1. 000 01
660.000 A2
4.000 It
1.000 01
1200.000 (1
4.000 N1 0
1.000 II
MAXIMUM
DETECTED
CONCENTRATION
140.000
2.000
110.000
150000.000
160.000
49.000
16.000
84000.000
44.000
6400.000
1700.000
0.200
150.000
22000.000
4.000
6.000
54000.000
16.000
100.000
SAMPLE ID
It 0
At
Cl
SI D
01
11
At
M
N 1059 1
Gl
N 1059 1
II
N2
S2
11
Al
At
S2
It
HEDIAN GEOHEIRIC MEAN l«R WPH
WNCENIRAIION MEAN CONCENTRATION OUARIIIE OUARTUE
19.000
1.000
1.000
15000.000
2.000
1.000
2.000
1900.000
1.000
2600.000
120.000
0.100
1.000
1600.000
1. 000
1.000
17000.000
2.000
16.211
0.611
1.129
14UI.601
1.788
1.02S
1.121
2206.8IS
1.790
1977.011
88.625
0.102
4.079
2074.450
1.154
0.954
11648.65$
1.720
51.114
0.799
5.129
21140.000
8.18]
7.141
1.210
15496.971
1.290
2457.429
276.121
0.101
11.118
1169.706
2.114
1.182
15SS1.429
2.679
11.271
19.000
0.585
1.000
8650.000
0.500
1.500
0.150
170.000
1. 000
1250.000
21.000
0.100
1.000
1100.000
1.000
0.500
6200.000
0.500
1.000
74.000
1.000
1.500
21000.000
4.000
6.000
4.100
21000.000
1.000
1150.000
460.000
0.100
7.000
1600.000
1.000
1.000
20500.000
2.000
10.000
SINORO.
DEV.
2.402
2.480
2.789
2.465
4.066
1.611
S.2S1
11.469
2.100
2.076
5.990
1.124
2.999
2.294
2.150
1.812
2.118
2. 567
1.661
95X Cl
UPPER I INII
75.258
1.146
1.640
11421.701
11.126
11.720
12.181
101657.156 «
1.596
1401.812
1469.572
0.106
15.020
4089.514
2.422
1.406
21181.772
4.270
10.911
TOTAL "">
4718.750
120251.200
-------
EiASCO fill
06/03/93
HOOKER CHCHICAL/RUCO POUNER SHE
Sf CHtHildl COMPOUNDS ( OEIECIS • UNOETECIS/2 )
GROUXDUAIER
COMPOUND
MINIMUM
UN- MEQ MIECKO
VAIIO OCCUR OtltCT ESI (EJECT OEIfCI CONCENTtAIIOM SAMPLE 10
MAXIMUM
DEIECIEO
CONCENIRAIION SAMPLE ID
MEDIAN GfOHHRIC MEAN LOWER
CONCENIRAIION MEAN CONCENIRAIION SUARHIE
UPPER
OUAIIIIE
SINORD. 95X Cl
OIV. UPPER UNI I
II lite Neutral Acid < BNA )
U9/L
< Polycyclfc Aromtic Hydrocarbons )
NAPNIMAIENE M 1 11 1 0 0.0}
IOIAI •••«>
< Phlh>l*te Eittri )
IISI2-EIHUHEXUIPHIHALAIE
01 n BUiriPHIKALAlE
Ol-n OCIU PMIHALAIE
(1 P«licide/Polychlorin»led
< Peiticidei 1
OIEIOIIN
HEPIACNLO* EPOJIIOE
II Inorganic ( INORC ) 09/1
ALUMINUM
ANIIMONr
ARSENIC
i<> 16 11 16 S O.M
v. \ n o o o.oi
M 1 3J 1 0 0.0}
IOIAI ••••>
tipftcnyl ( PESI/PCI > ug/L
J5 1 M 1 0 0.0}
» 2 }} 2 0 0.06
I «•*»
}| 31 0 20 4 1.00
15 3 32 1 0 0.09
35 11 22 r 0 O.H
2.000 El
2.000
1.000 HI
45.000 PI
2.000 01
41.000
0.004 C2
0.001 C2
0.007
12.000 A2
22.000 M
2.000 12
1200.000
66.000
M.OOO
2.000 El
2.000
6.000
45.000
2.000
51.000
0.004 G2
0.015 11
0.019
5.000
5.000
5.000
5.000
0.050
0.025
210.000
17.000
1.000
4.067
3.547
5.334
4.867
0.050
0.02S
198.558
IS. 16)
2.999
4.912
3.897
6.176
4.912
0.062
0.011
145.194
17.206
11.114
5.000
2.000
5.000
5.000
0.050
0.025
160.000
10.000
1.000
5.000 1.170
5.000
5.000
5.000
0.050
0.025
300.000
17.000
0.000
1.60]
1.458
1.170
1.799
1.724
1.446
1.541
4.002
5.160 X
4.747
6.460
5.160 I
0.071 X
0.015 X
791.917
19.470
26.8*4
NOIE: ( X >. IN 9SX Cl COLUMN, IMOICAIES VALUE IS CRE4IER I HAN MAXIMUM CONCENIRAIION; < • ), ASICRISKS. INDICATE IHAI IKE NUMBER OF OCCURRENCES IS TOO SNAll 10 AllOU CALCULATION
-------
EBASCO I-III
06/01/9?
HOOKER CKCNICAl/RUCO POLTMER Sill
SUMMAR1 01 CHEMICAL COMPOUNDS ( OEItCIS • UNOEIECIS/2 )
SURFACE UAIER
COMPOUND
MINIMUM
DM FREO DEIECIEO
VALID OCCUR OEUCI ESI IEJECI DEIECI CONCIIIUAIION SAMPLE ID
HA«INUM
OEIECIEO
CONCENIRAIION SAMPLE 10
MEDIAN GEOHEIRIC MEAN LOUER
CONCENIRAIION MEAN CONCENIRAIION OUAR1ILE
UPPER
OUAIIILE
() IMC Neutral Acid ( «MA ) uo/l
( Phlhalale Etterc >
• ISI2 CIHHKEmlPMIHALMI 220
II P«iticld«/Polychlorinat«l iljfienyl ( PESI/PCI
( PCBt >
AIOCIOR 1248 1 1 2
1) Inorganic ( INORG ) ug/l
ALUMINUM
AISENIC
IARIUH
IERTIIIUM
CADMIIM
CALCIUM
CHROMIUM
COSAll
COPPER
IRON
LEAD
MAGNESIUM
1 0
0
0
0
0
0
0
2
0
0
0
0
1
t
IOIAI
t
mm
00
• •>
1
1
000
000
SU
1
> ug/i
0
1
I
0
0
2
S
2
0
1
1
1
1
0
IOIAI
0
0
0
0
0
0
0
0
0
0
0
0
0
.11
*•••>
1
1
1
1
1
1
1
0
t
1
1
1
.00
.00
.00
.00
.00
.00
.00
.1)
.00
.00
.00
.00
1
1
1000
4
1«
0
1
6700
a
4
19
1000
21
2100
500
500
000
000
000
120
000
000
000
ooo
000
.000
.000
.000
su
SU
SU
tu
SU
SU
SU
SU
SU
SU
SU
SU
SU
1
2
2
2
2
2
2
t
1
1
2
2
2
31.000 SU 1
11.000
1
1
9900
15
140
0
7
22000
14
.500
.500
.000
.000
.000
.960
.000
.000
.000
4.000
95
14000
270
9100
.000
.000
.000
.000
SU 1
SU 1
SU
SU
SU
SU
SU
SU
SU
SU
SU
SU
SU
11.000
1.500
WOO. 000
15.000
HO. 000
0.960
7.000
22000.000
It .000
4.000
95.000
14000.000
2ro.ooo
9100.000
9.644
0.091
5595.994
9.205
41.126
0.410
4.716
10520.62}
18.155
2.060
61.24)
6)85.776
55 407
106).174
17.000
0.517
6266.667
10.667
61.111
0.671
5.000
.12200.000
21.111
2.1)1
6).11)
77)).))!
107.000
4766.667
SIUORD. 95X Cl
OEV. UPPER IINII
0.000
0.000
0.000
0.000
0.000
o.ooo
0.000
0.000
0.000
0.000
0.000
o.ooo
o.ooo
0.000
0.000 5.214
1127.151 K
0.000 10.612
0.000 .820
o.ooo
o.ooo
o.ooo
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
.065
.812
.776
.5)2
.904
.101
.762
.561
.161
.987
.148
182419.062 It
2520.79) »
12421401. (SO II
17.119 1
16.660 I
82458). 455 II
5706.1)7 >
55.6)6 II
522.715 X
2526617.147 «
30458702185.7 1
1455282.047 II
NOIE: < I >, IN 95X Cl COLUMN, INDICAIES VALUE IS GREAIER 1KAN MAXIMUM CONCENIRAIION; ( • >, ASIERISKS, INDICAIE IHAI IKE NUMBER OF OCCURRENCES IS TOO SMALL 10 AIIOU CALCULAIION
-------
IIUCO (III
otinm
MOKfl CNfHICAl/IUCO MITM* Sill
i IK cmmcM cnnu*» « Oflms wit >
smucr will
•KIPMI
«• itio Miictro
«MI» OCCUI OfUCI 111 IIJICI NlfCI COKflllMiai Vlflt ID
MIIMLH
Hiiciro
COHtlllltllOl UMTll ID
MOKI ciowinc «» loci umi
CCMdIMIlW KM COKOIMIIOH OUKIIlf OUIIIKI
O. «» Cl
M*. umi imn
I) •»» ltulr«l tcld ) M* >
4 Ptithilit* Itltri )
• I SI?-I INIlMtlrllMIMt«tC
I I 1.00
IOIM ••••>
11.000 SU I
11.000
0.000 J.Ill
II fnlicldr/rolrclllarlniltd ll(*m»l I Ktl/KI ) ug/l
< Ktl )
itoaot i
200 0.11
101A1 ••••»
0.000 1.000
IF«
-------
E>ASCO (III
06/01/92
HOOCH CHENICAl/RUCO POltHER SHE
SUNNARI OF CHEMICAL CONFOUNDS I OEIECIS « UNOEIECIS/2 )
SURfACE UAHR
PAGl i
UK
COMPOUNO VALID OCCUR DflCCI
MANGANESE
MEROJRT
NICKEL
POTASSIUM
SHVM
SODIUM
VANADIUM
I IMC
0
2
0
0
1
0
0
0
ESI
1
0
0
0
z
I
0
0
MINIMUM MAXIMUM
IIIO OIICCIEO OEUCIED MEDIAN CEOHEIDIC MEAN LOUCR UPPER SINORP. 9M Cl
REJECf DEIfCT CONCENTRATION SAMPl£ ID CONCEHIRAIION SAMP1E ID CONCENIRAIION MEAN CONCENIRAIION OUARIUE OUARTILE DIV. UPPER 1IMII
0 1.00 41.000 SU 2 200.000 SU 200.000 87.2SO 107.1)} 0.000 0.000 2.2U *2tOJ. U7 K
0 0.3J 0.240 SW I 0.240 SU 0.240 0.114 0.147 0.000 0.000 I.6S8 2.476 »
0 1.00 14.000 SU 2 2S.OOO SU 2S.OOO 18.80$ I9.3JJ 0.000 , 0.000 1.554 4!.»3 1
0 1.00 740.000 SU 1 2100.000 SU 2100.000 IIM.4I6 1121.111 0.000 0.000 1.822 18211. W2 I
0 0.«7 2.000 SW 1 2.000 SU 2.000 1.587 1.467 0.000 0.000 1.492 10.806 I
0 1.00 5600.000 SU I 11000.000 SU 11000.000 7670.806 8266.667 0.000 0.000 I.S84 70401.764 X
0 1.00 9.000 SU 2 11.000 SU 11.000 14.174 17.111 0.000 0.000 2.058 1820.164 >
0 1.00 200.000 SU 1 480.000 SU 460.000 267.771 291.111 0.000 0.000 1.658 49H.088 >
IOIAI ••«•>
21704.S60
71806.200
-------
FIASCO Fill
05/24/92
HOOKER CHENICAl/RUCO POLTNCR SHE
SUMMARY or CHEMICAL COMPOUNDS i OEIECIS •
SURFACE SOU INSIDE I OUTSIDE SPIll AREA
PACE 1
CONPOUND
II Vol.liU ( VOA ) ug/Kg
( N«togeiwt«d VoUtilei )
l.t.l-fllCKLOROEIIUNE
1.1-OICMlOtOEINKE
CHARON lEtRACNLOtlOE
CNLOMKNIfNf
CNLOtOrOM
lEIIACIILOKKIMEIt
IRANI-1,2-DICNlOROEIHENE
IRICHLOROEIHCNE
( Non-Hilogcntted Volatile* »
BENZENE
EIHHIENIENE
SIIRENE
IOIUENE
IOIAL XHENES
a 10
42
42
41
42
IS
17
40
42
42
42
41
2)
18
OCCUR I
2
1
4
1
a
21
7
16
2
2
1
It
6
JN-
IEIECI
40
41
17
19
2$
It
11
24
40
40
40
12
12
ESI IEJECF
2 0
1
4
1
a
21
7
16 0
low
2 0
2 0
1 1
11 19
6 4
F«
OE
0
0
0
0
0
0
0
0
• •
0
0
0
0
0
EO
1ECI
.05
.02
.10
.07
.24
.$7
.17
.U
• 3»
.01
.OS
.02
.48
.16
MINIMUM
OEIECIEO
CONCENIRA
0
a
i
0
0
0
1
0
12
1
2
0
0
0
DON
.100
.000
.000
.400
.900
.100
.000
.400
.100
.000
.000
.400
.500
.100
SAI
en
»
II
PM
Ml
At
II
M
te
11
ii
PN
at
*P1E 10
.102
1102
17 1 1
J 0 2
0 2
0 2
1» 0 20
J 0 2
01 0 2
10 0 2
27 0 2
J 0 2
0 2
NAKIMLM
OEIECIEO
CONCENIRAIION
2.000
e
600
0
9
710
It
720
2140
1
19
0
1600
110
.000
.000
.500
.000
.000
.000
.000
.500
.000
.000
.400
.000
.000
SANPIE 10
II
II
IIP
II
II
11
N1
N1
II
II
II
II
II
to
11
0
27
10
to
0
0
10
01
27
to
ot
0
0
2
0
0
0
2
2
0
0
0
0
0
2
2
2
2
2
2
2
2
2
2
MEDIAN
CONCENIRAIION
GEOHHRIC
MEAN
MEAN
CONCENIRAIION
.000
.000
.000
.000
.000
.000
.000
.000
.000
.000
.000
.000
.000
LOUtR
OUMIIIE
1.021
1.074
1.276
0.997
1.162
1.219
1.448
1.S01
1.051
1.168
1.014
1.469
1.291
umi
OUARtllE
SINORP.
OEV.
1.090
1.202
17.951
1.057
1.505
17.149
2.250
19.015
1.095
2.024
1.071
118.161
9.512
.000
.000
.000
.000
.000
.000
.000
.000
1.000
1.000
1.000
1.000
1.000
5.250
1.000
2.000
.000
.000
.000
.000
.000
95X Cl
UPPER IIHII
1.40S
1.05
i.ooo
1.178
1.826
6.261
2.202
1.471
1.000 1.?67
1.000 1.8(2
1.000 t.157
1.500 11.617
1.000 2.862
1.198
1.262
1.752
1.151 II
1.742
56.741
2.611
S.548
1.157 II
1.720
1.161 >
971.028
1.609
IOIAL
4.200
2150.400
II 8o«« Neutral Acid ( INA ) U9/Kg
( Phenolt >
4-HflNUPHENOt
41
40
0.02
220.000 II 01 0 2
220.000 II 01 0 2
185.000
251.454
1002.071
180.000
195.000 2.958
724.004 II
N01E: IK). IN 95X Cl COLUMN. INOICAIES VALUE IS G«EAIE* IHAN MAXIMUM CONCENIRAIION; < • >. ASIERISKS. INOICAIE IHAI IHI NUMBEI Of OCCURRENCES IS 100 SMALL 10 AllOU CALCUIAIIW
-------
EBASCO f-lll
05/26/92
COMPOUND
PHEMOt
( Polycycllc Arowtlc
2-NEIHn.NAPHIHALENE
ACENAPHIKENE
AN1HMCENE
BENZOUIANIHRACttt
BENIOIllPVIENE
8EMO(tamUO*ANTHENE
bENZOia,H,IJPMH€NE
BENZOIkmUOMNIHENE
CHRTSEHE
OIBEHIOFUftAN
riUOtMHMENE
HWMENE
UK-
VALID OCCUR DEIECI
(1
Hydrocarbon* )
*1
41
41
41
41
41
41
41
41
41
41
41
IHDENOM.2.1-C01PHEHE «1
HAPHIKAIEME
PHENANIKIENE
PtRENC
< Bemenes >
HtXACHLCROBEHHNE
41
41
41
41
I
1
1
It
1
17
2
4
1
11
17
2
40
40
(0
ia
12
58
12
U
U
10
40
24
19
17
40
21
24
39
EST
1
t
1
I
7
1
S
1
2
7
1
11
2
2
1
11
U
1
(EJECT
0
TOTAL
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
I01AI
0
IOIAI
HOOKER CHEMICAl/RUCO POl!K£8 SITE p«GE 2
SUNMARI Of CHEMICAL COMPOUNDS ( DETECTS • UNOEIECIS/2 )
SURFACE SOU INSIDE I OUTSIDE SPILL AREA
MINIMUM MAXIMUM
m8 DETECTED DEtECIED MEDIAN GEOMETRIC MEAN LOWER UPPER SINORO. 95 X Cl
DETECT CONCENIRA1 ION
0.02
• •••>
0.02
0.02
0.07
0.22
0.07
0.22
0.07
0.07
0.27
0.02
0.41
0.04
0.10
0.02
0.12
0.41
*ȣ>
0.05
*»cc>
290.000
510.000
190.000
210.000
40.000
85.000
270.000
100.000
240.000
140.000
99.000
2SO.OOO
70.000
100.000
110.000
270.000
12.000
71.000
2515.000
270.000
270.000
SAMPLE ID
IB 14 1 1
Tl 01 0 2
II 40 0 2
• 102
Tl 20 0 2
Tl 40 0
Tl 20 0
Tl 25 0
Tl 40 0
II 20 0
II 01 0
II 27 0
II 40 0
II 40 0
II 01 0
II 0 20
Tl 12 0 2
18 20 0 2
CONCENTRATION
290.000
510.000
190.000
210.000
210.000
810.000
410.000
1900.000
500.000
610.000
1400.000
250.000
2400.000
120.000
790.000
270.000
1200.000
1600.000
11)10.000
580.000
580.000
SAMPLE ID CONCENIRAIION MEAN CONCENIRAIION QUARIIIE OUARTIIE DEV. UPPER LIHII
IB 14 1 1
IB 01 0 2
IB 40 0 2
IB 40 0 2
IB 40 0 2
PM K 0 2
II 40 0
II 01 0
II 01 0
IB 01 0
IB 01 0
II 01 0
IB 01 0
IB 25 0
II 01 0
II 01 0 2
11 40 0 2
IB 21 0 2
185.000
185.000
185.000
185.000
190.000
190.000
190.000
190.000
185.000
185.000
Hi. 000
190.000
185.000
190.000
185.000
185.000
190.000
190.000
229.160
254.990
227.672
241.909
268.541
261.219
292.168
261.061
259.250
278.612
252.219
291.176
250.121
265.972
252.711
211.811
270.119
261.0)5
728.049
1006.220
726.141
998.517
1011.902
1014.190
1085.854
1015.610
1011.659
1061.141
1002.805
1121.488
1002.681
1024.024
1001.291
1011. 488
1074.024
1011.780
180.000
180.000
180.000
180.000
180.000
180.000
180.000
180.000
180.000
180.000
180.000
175.000
180.000
180.006
180.000
172.500
172.500
182.500
195.000
195.000
195.000
195.000
200.000
200.000
200.000
200.000
197.500
200.000
195.000
285.000
195.000
200.000
195.000
197.500
215.000
200.000
2.452
2.964
2.449
1.027
1.092
2.961
1.209
2.971
2.990
1.189
2.958
1.459
2.984
1.016
2. 958
1.540
1.159
2.97)
475. )51 II
716. )29 X
4M.628 X
727.527 X
827.541 X
758.871 X
954.9)8
761.269 X
758.816 X
901.540
726.014 X
1081.590
710.156 X
788.817
727.454 X
951.111
951.519
757.218 X
-------
ISASCO fill
OS/26/9?
HOOKER CMEHICAl/RUCO POITNER SITE
of CHH!!Mi c&yauxi: ; s£; ug/i«
0 0
0 1
0 0
IOIAL
0 0
0 0
IOIAL
(DEO
OEIECI
0.75
0.02
0.04
0.02
••••>
0.02
0.02
0.02
«««*>
o.»
0.0$
£»33>
MINIMUM
OEIECIEO
CONCENUAIION
500.000
800.000
7200.000
4200.000
12700.000
1400.000
1900.000
58.000
1158.000
620.000
560.000
1200.000
SAMPLE 10
II 20 0 2
II 01 0 2
II 01 0 2
II 01 0 2
11 20 0 2
II 20 0 2
II 20 0 2
II 27 0 2
II 12 0 2
II Inorginic ( INORG ) ag/Kg
ALUMINUM
MIIMNI
41
58
54
12
5
26
14 0
0 1
0.88
0.12
1800.000
1.000
II 11 0 2
PH 1 0 2
MAXIMUM
PE1EC1EO
CONCENIRAIION
14000.000
800.000
7200.000
4200.000
46200.000
MEDIAN
SAMPLE ID
IB 01 0 2
18 01 0 2
II 01 0 2
II 01 0 2
1400.000 II 20 0 2
1900.000 II 20 0 2
58.000 II 20 0 2
1158.000
10000.000 II 16 1 I
1200.000 II 11 0 2
11200.DUO
18000.000
11.000
II 26 0 2
II 25 0 2
IN GtOIEIRIC MEAN IOUFR UPPER SINORO.
1NIRAIION MEAN CONCENIRAIION OUABIILE OUARIILE OEV.
4100.000 2848.984 8164.581 780.000 16000.000 5.459
185.000 259.498 1016.220 180.000 195.000 1.002
190.000 148.666 1802.400 177.500 197.500 4.495
185.000 261.177 924.756 180.000 195.000 2.992
18.250 27.596 279.452 17.000 19.500 1.575
18.500 28.111 298.017 17.250 19.500 1.712
9.000 11.012 126.726 8.500 9.500 1.118
95.000 278.179 1446.429 90.000 770.000 5.180
185.000 271.809 2501.214 170.000 200.000 J 154
8600.000 6812.857 8465.854 4700.000 12000.000 2.099
5.000 4.277 6.474 2.000 8.000 2.461
V5X Cl
UPPCI LIHII
115617.120 *
764.057
1176. 859
771.564
114.570
125.751
40.451
2827.696
850.518
11610.917
9.196
-------
E8ASCO fill
05/26/92
HOOKER CHENICAl/RUCO POlfMER SITE
SUHNARf OF. CHEMICAL COMPOUNDS ( DETECTS » UNOEIECIS/2 )
SURFACE SOU INSIDE t OU1SIOE SPILl ADEA
PAGE 4
COMPOUND
ARSENIC
BARIUM
BERTH IUN
CADMIUM
CALCIUM
CHROMIUM
COBALT
COPPER
IRON
IEAD
MAGNESIUM
MANGANESE
MERCURf
NICUl
POTASSIUM
SELENIUM
SILVER
SODIUM
THALLIUM
VANADIUM
1INC
UN-
VALID OCCUR DEIECI
58
41
41
41
41
37
41
41
4t
4t
4t
39
41
M
41
41
41
41
41
39
3»
33
36
23
18
35
32
36
36
36
36
36
34
8
31
16
8
7
36
1
34
34
5
f
18
23
6
S
S
s
s
s
t
s
33
S
s
33
34
S
40
S
5
ESI REJECT
7
1
0
14
12
14
6
16
3
26
a
is
t
8
10
6
r
is
i
16
If
3
0
0
0
0
4
0
0
0
0
0
2
0
s
0
0
0
0
0
2
2
MINIMUM
FREO DETECTED
DEIECI CONCENTRATION
0.87
0.88
0.56
0.44
0.8S
0.86
0.68
0.88
0.88
0.88
0.88
0.87
0.20
0.86
0.88
0.20
0.17
0.88
0.02
0.87
0.87
1.500
6.300
0.290
0.170
200.000
6.200
0.390
4.700
1700.000
3.500
220.000
9.000
0.130
2.800
SI. 000
0.340
0.820
56.000
0.500
1.000
10.000
SAMPLE ID
11 32 0 2
II 32 0 2
II 11 0 2
01 0 2
T8 32 0 2
FN 1 0 2
Tl 32 0 2
PN 1 0 2
Tl 32 0 2
PN 1 0 2
Tl 32 0 2
Tl 32 0 2
R1 0 2
Tl 27 0 2
II 33 0 2
18 16 1 3
II It 0 2
II 26 0 2
PN 1 0 2
IP 0 2
PN 1 0 2
MAXIMUM
DETECTED
CONCENTRATION
26.000
150.000
11.000
2.300
33000.000
89.000
30.000
740.000
30000.000
900.000
19000.000
320.000
1.800
430.000
970.000
0.800
2.500
820.000
0.500
31.000
1900.000
SAMPLE 10
R1 0 2
IB 25 0 2
II 25 0 2
R1 0 20
Tl 01 0 2
II 25 0 2
II 2S 0 2
II 25 0 2
II 2S 0 2
II 25 0 2
II 01 0 2
II 25 0 2
II 11 0 2
11 25 0 2
II 26 0 2
II 17 1 3
IB 01 0 2
II 2S 0 2
PH 1 0 2
II 09 0 2
II 25 0 2
MEDIAN GEOMEIRIC MEAN LOUER UPPER SINORO. 95X Cl
CONCENTRATION MEAN CONCENTRATION OUARTIIE OUARIILE OEV. UPPER LIMII
11.000
26.000
0.370
0.390
950.000
IS. 000
5.200
11.000
11000.000
15.000
1600.000
120.000
0.05S
8.900
340.000
0.1BO
0.085
250.000
0.17S
IS. 000
27.000
8.800
22.150
0.350
0.313
1047.820
14.SS3
4. $27
13.026
9159. 14$
21.206
U46.S10
102.S04
0.088
B.S26
296.921
0.36$
0.138
224.596
0.173
11. $85
33.824
11.107
27.400
0.648
0.619
3246.488
19.968
5.75$
31.961
10800.000
58.29$
24$0.4BB
123.38$
0.154
21.156
349.171
O.S94
0.372
256.854
0.177
13.646
88.179
6.100
16.500
0.170
0.085
47$. 000
9.800
3.200
8.750
7050.000
9.500
965.000
83.000
0.05S
$.100
20$. 000
0.172
0.080
UO.OpO
0.160
8.450
20.500
16.000
31.500
0.$7$
0.96$
2500.000
19.000
7.250
20.000
15000.000
42.000
2075.000
14$. 000
0.13$
11.000
485.000
1.150
0.09$
115.000
0.180
18.500
53.500
2.163
1.921
2.298
3.384
5.459
2.151
2.090
2.403
1.878
3.39$
2.644
2.00$
2.332
2.591
1.866
2.6)0
3.19$
1.711
1.214
1.956
2.717
15.665
34.054
0.671
1.116
11127.56$
25.852
7.680
26.353
1)775.306
7$. 952
))68.662
16$. $02
0.171
19.810
443.870
0.844 «
0.448
307.664
0.186
18.240
82.573
TOTAL «"«>
4077.640
10M$7.900
-------
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41
41
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120.000 II 01 0 2
no. ooo ii u i i
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170.000 I* 40 0 2
IM.OM It 20 t 2
140.00* II 21 t 2
14t.OM II 40 0 2
tl.OO* II 20 0 2
n*.*oo ii oi o 2
70.000 II 17 0 2
IM.OM 10 40 0 2
IM.OM II 40 0 2
170. »00 II 01 0 2
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n.M* t* 12 o 2
MIINM
MIICIIO
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IIO.OM II 01 0 2
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110.000
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110.000 II 40 0 2
IIO.OM II 40 * 2
110.000 II 40 0 I
4IO.OM M 1 0 t
IOM.OM I* 40 0 2
MO.OOO II II 0 I
4JO.OOO 10 11 0 2
1400 000 II 01 0 2
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740.000 It n 0 2
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1.000
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4IO.OM
IIO.OM
500.000
410.000
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IIO.OM
640.000
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2IO.OM
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170.000
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190.000
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174.402
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171. *M
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790.000
190.000
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IM.OM 2.172
t.OM 1.2M
170. OM 1.4JO
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790.000 2.11*
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270.000 II 20 0 2
170.000
tOO. 000 II 20 0 2
12700.000
1400.000 II 20 0 2
1900.000 II 20 0 2
M.OOO II 20 0 2
11M.OOO
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1400.000 II 20 0 2
1900.000 II 20 0 I
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4000.000 MJ4.MI 7141.)]) MO. 000 10100.000 4.417 192291. 819 I
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0.000 1900.000 1900.000 0.000 0.000 1.000 •••«•••••••• 1
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-------
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IOMI .".» 1200.000 1I?00.000
-------
TABLE h
Risk Assessment - List of Exposure Assumptions
-------
TABLE 7-2
HOOKER/RUCO SITE
EXPOSURE PATHWAY - PRESENT AND FUTURE USE SCENARIOS
TIME FRAME AND MATRIX
RECEPTORS
EXPOSURE ROUTE
Ground HMw
Future Us*
Surf** Wfttr
Present And
Future Use
Present And
Future Use
Surf*t» Soil
Present And
Future Use
Future Use
Subaurftc* Soil
Future Use
Air
Present And
Future Use
Future Use
Residents
(attenceNne)
Site Workers
Trespassers
Site Workers
Trespassers
Site Workers
Trespassers
Off-site Residents
Construction Workers
Construction Workers
Site Workers
Trespasser
Off-site Residents
Construction Workers
Children
Adults
Adults
Children
Adults
Children
Adults
Children
Children
Adults
Adults
Adults
Adults
Children
Children
Adults
Adults
Ingesbon/lnhalatton/Oermal Contact
Ingesdon/lnhalatkxi/Oermal Contact
Dermal Contact
Dermal Contact
Irtgesfon/lnhalation/Dermal Contact
IngesUon/lnhalatJon/Dermal Contact
Ingestion/lnhalation/Dermal Contact
Ingesdon/lnhaladon/Dermal Contact
Inhalation
Inhalation
Ingestion/lnhalation/Dermal Contact
Ingestion/tnhalatton/Dermal Contact
Inhalation
Inhalation
Inhalation
Inhalation
Inhalation
-------
TABLE 7-3
PARAMETERS AND ASSUMPTIONS TO CALCULATE
GROUND WATER EXPOSURE PATHWAYS
FUTURE USE SCENARIO
HOOKER/RUCOSITE
Receptor: Residents-Adults
Exposure Route
Exposure Frequency
days/year
350
Dermal Ccrtact
350
trthaiabon
350
Exposure Duration
years/life time
30
30
30
Body Weight
kg
70
70
70
Bioavailability Factor
Ingestion Rate
L/day
Skin Surface Area
cm2
20000
Exposure Time
hours/day
025
0.33
Inhalation Rate
M3/Hr
1.4
Parameters for Shower
Shower Frequency-1/day
Shower Room Vol.(mA3)-12.0
Droplet Diam.(mm)-1.0
Shower Water Row Rate (Vmin.)«10.0
Bathroom Air Exchange Rate (exch/hr)»1.0
Shower Water Temperature (C)«45.0
Droplet Drop Time (sec.)«2.000
Shower Duration (min.) -15.0
Time in Room After Shower (min.) «5.0
Viscosity of Shower Water (cp) • 0.601
-------
TABLE 7-4
PARAMETERS AND ASSUMPTIONS TO CALCULATE
GROUND WATER EXPOSURE PATHWAYS
FUTURE USE SCENARIO
HOOKER7RUCOSITE
Receptor: Residents-Children
Exposure Route
Exposure Frequency
days/year
tngestion
350
Dermal Contact
350
inhalation
350
Exposure Duration
years/Me time
Body Weight
35
35
35
Bioavailabilrty Factor
Ingestion Rate
Utiay
1
2
Skin Surface Area
cm2
12000
Exposure Time
hours/day
Inhalation Rate
IWHr
0.25
033
1.5
Parameters for Shower
Shower Frequency-1/day
Shower Room Vol.(mA3)«12.0
Droplet Diam.(mm)«1.0
Shower Water Row Rate (Vmin.)«10.0
Bathroom Air Exchange Rate (exeh/hr)«1.0
Shower Water Temperature (C)-45.0
Droplet Drop Time (sec.)«2.000
Shower Duration (min.) -15.0
Time in Room After Shower (min.) «5.0
Viscosity of Shower Water (cp) • 0.601
-------
TABLE 7-5
PARAMETERS AND ASSUMPTIONS TO CALCULATE
SURFACE WATER EXPOSURE PATHWAYS
PRESENT AND FUTURE USE SCENARIO
HOOKER/RUCO SITE
Receptor: Site Workers
Exposure Route Dermal Contact
Exposure Frequency 24
days/year
Exposure Duration 25
years/lifetime
Exposure Time 8
hours/event
Body Weight 70
Bioavailability Factor 1
Sikin Surface Area 3120
cm2
-------
TABLE 7-6
PARAMETERS AND ASSUMPTIONS TO CALCULATE
SURFACE WATER EXPOSURE PATHWAYS
FUTURE USE SCENARIO
HOOKER/RUCO SITE
Trespassers- Children
Exposure Route Dermal Contact
Exposure Frequency 55
days/year
Exposure Duration 6
years/lifetime
Exposure Time 5
hours/event
Body Weight 35
Bioavaflabifity Factor 1
Skin Surface Area 3000
cm2
-------
TABLE 7-7
PARAMETERS AND ASSUMPTIONS TO CALCULATE
SEDIMENT EXPOSURE PATHWAYS
PRESENT AND FUTURE USE SCENARIO
HOOKER/RUCO SITE
Receptor: Site Workers
Exposure Route
Exposure Frequency
days/year
tngestion
24
Dermal Contact
24
Inhalation
24
Exposure Duration
years/life time
25
25
25
Body Weight
IV
70
70
70
Bioavailabilrty Factor
1
Skin Surface Area
cm2
3120
Sediment Deposition Rate
mg/cm2
Exposure Time
hours/day
8
8
Inhalation Rate
m3/hour
Absorption Factors
Ingestion Rate
ing/day
100
0.5-PCBs
3-Cadmium
-------
TABLE 7-8
PARAMETERS AND ASSUMPTIONS TO CALCULATE
SEDIMENT EXPOSURE PATHWAYS
PRESENT AND FUTURE USE SCENARIO
HOOKER/RUCO SITE
Receptor: Trespassers-Children
Exposure Route
Exposure Frequency
days/year
-tngesbon
55
Dermal Contact
55
Inhalation
55
Exposure Duration
years/life time
Body Weight
kg
35
35
35
Bioavailabilrty Factor
Skin Surface Area
cm2
3000
Sediment Deposition Rate
mg/cm2
Exposure Time
hours/day
Inhalation Rate
m3/hour
Absorption Factors
0.5-PCBs
3-Cadmium
Ingestton Rate
mg/day
100
-------
TABLE 7-9
PARAMETERS AND ASSUMPTIONS TO CALCULATE
SURFACE SOIL EXPOSURE PATHWAYS
PRESENT AND FUTURE USE SCENARIO
HOOKER/RUCO SITE
Receptor: Site Workers
Exposure Route
Exposure Frequency
days/year
digestion
250
Dermal Contact
250
inhalation
250
Exposure Duration
years/life time
25
25
25
Body Weight
kg
70
70
70
Bioavailabilrty Factor
Ingestion Rate
mg/day
1
100
0.5
Skin Surface Area
cm2
5000
Soil Deposition Rate
Exposure Time
hours/day
8
.8
8
Inhalation Rate
rrWhour
Absorption Factors
0.5-PCBs
3-Cadmium
-------
TABLE 7-10
PARAMETERS AND ASSUMPTIONS TO CALCULATE
SURFACE SOIL EXPOSURE PATHWAYS
PRESENT AND FUTURE USE SCENARIO
HOOKER/RUCOSITE
Receptor: Trespassers - Children
Exposure Route
Exposure Frequency
days/year
Jngestion
55
Dermal Contact
55
Inhalation
55
Exposure Duration
years/life time
Body Weight
35
35
35
Boavailabilrty Factor
hgestion Rate
tng/day
1
200
Skin Surface Area
cm2
. 3000
Soil Deposition Rate
Exposure Time
hours/day
Inhalation Rate
n&hour
Absorption Factors
0.5-PCBs
3-Cadmium
-------
TABLE 7-11
PARAMETERS AND ASSUMPTIONS TO CALCULATE
SURFACE SOIL EXPOSURE PATHWAYS
FUTURE USE SCENARIO
HOOKER/RUCOSITE
Receptor: Construction Workers
Exposure Route ;
Exposure Frequency
days/year
digestion
250
Derma] Contact
250
Inhalation
250
Exposure Duration
years/life time
Body Weight
70
70
70
Btoavailabil'rty Factor
Ingestion Rate
mg/day
1
100
0.5
Skin Surface Area
cm2
5000
Soil Deposition Rate
mg/cm2
Exposure Time
hours/day
8
8
8
Inhalation Rate
m3/hr
Absorption Factors
0.5-PCBs
3-Cadmium
-------
TABLE 7-12
PARAMETERS AND ASSUMPTIONS TO CALCULATE
SURFACE SOIL EXPOSURE PATHWAYS
PRESENT AND FUTURE USE SCENARIO
HOOKER/RUCO SITE
Receptor: Off-She Residents • Adults
Exposure Route ." /'\;V:''':":'^.;P. \C:::o3;v'X'X^^:;;>- ••.'• ^inhalation
Exposure Frequency 350
days/year
Exposure Duration 30
years/life time
Body Weight 70
Bbavailability Factor 1
Inhalation Rate 0.90
m3/hour
Exposure Time
hours/day 24
-------
TABLE 7-13
PARAMETERS AND ASSUMPTIONS TO CALCULATE
SURFACE SOIL EXPOSURE PATHWAYS
PRESENT AND FUTURE USE SCENARIO
HOOKER/RUCOSITE
Receptor: Off-Site Residents • Children
Exposure Route ."'. • .';''"':' v".-.-',, ;.', :.;;...X;-::/;3f^J"" Inhalation.
Exposure Frequency 350
days/year
Exposure Duration 6
years/life time
Body Weight 35
Bioavailabilrty Factor . 1
Inhalation Rate 0.90
m3/hour
Exposure Time
hours/day 24
-------
TABLE 7-14
PARAMETERS AND ASSUMPTIONS TO CALCULATE
SUBSURFACE SOIL EXPOSURE PATHWAYS
FUTURE USE SCENARIO
HOOKER/RUCOSITE
Receptor: Construction Workers
Exposure Route 1V; Ingestion ,.,'.' •;/. ;; permal Contact ; • ; ^inhalation
Exposure Frequency 250 250 250
days/year
Exposure Duration 1 1 1
years/life time
Body Weight 70 70 70
Bioavailabiirty Factor 1 0.5 1
Ingestion Rate 100
rnp/day
Skin Surface Area - 5000
cm2
Soil Deposition Rate • 1 • -
tng/cm2
Exposure Time 8 88
hours/day
Inhalation Rale • - 3
m3/hr
Absorption Factors - 0.5-PCBs
% 3-Cadmium
-------
TABLE i
Risk Assessment - Cumulative Site Risks
-------
TABLE 7-15
HOOKER/RUCO SITE
SUMMARY ACROSS EXPOSURE PATHWAYS
PRESENT/FUTURE USE SCENARIOS-RESIDENTS ADULTS
Present/Future Use Scenarios:
Off-Site Adult Residents
Carcinogenic Risk Levels
Reasonable Maximum Exposure
Noncardnogente Hazard Index Values
Reasonable Maximum Exposure
1) Exposure to Surface SoH
Inhalation
6.40E-09
1.64E-09
Total Health Risk - Surface soil inhalation
SUMMATION RESULTS
Carcinogens
Reasonable Maximum Exposure-
Noncarcinogens
Reasonable Maximum Exposure*
6.40E-09
1.64E-09
-------
TABLE 7-15
HOOKER/RUCO SITE
SUMMARY ACROSS EXPOSURE PATHWAYS
PRESENT/FUTURE USE SCENARIOS-RESIDENTS ADULTS
Future Use Scenarios: Carcinogenic Risk Levels Noncarcinogenic Hazard Index Values
Fence-Line Adult Residents Reasonable Maximum Exposure Reasonable Maximum Exposure
1) Exposure to Ground Water
Ingestion 221E-03 4.89E+00
Inhalation 5.06E-04 5.82E-02
Dermal Contact 1.12E-04 2.01 E-01
2) Exposure to Surface Soil
Inhalation 6.40E-09 1.64E-09
Total Health Risk - Ground water ingestion + Ground water inhalation + Ground water dermal contact + Surface soil inhalation
SUMMATION RESULTS
Carcinogens
Reasonable Maximum Exposure- 2.83E 03
Noncarcinogens
Reasonable Maximum Exposure" 5.15E+00
-------
TABLE 7-16
HOOKER/HUGO SITE
SUMMARY ACROSS EXPOSURE PATHWAYS
PRESENT/FUTURE USE SCENARIOS-RESIDENT CHILDREN
Present/Future Use Scenarios: Carcinogenic Risk Levels Noncarcinogente Hazard Index Values
Off-She Child Residents Reasonable Maximum Exposure Reasonable Maximum Exposure
1) Exposure to Surface SoH
Inhalation 2.56E-09 3.28E-09
Total Health Risk - Surface soil Inhalation
SUMMATION RESULTS
Carcinogens
Reasonable Maximum Exposure- 2.56E-09
Noncarcinogens
Reasonable Maximum Exposure* 3.28E-09
-------
TABLE 7-16
HOOKER/RUCO SITE
SUMMARY ACROSS EXPOSURE PATHWAYS
PRESENT/FUTURE USE SCENARIOS-RESIDENT CHILDREN
Future Use Scenarios: Carcinogenic Risk Levels Noncartinogenic Hazard Index Values
OH-Site Child Residents Reasonable Maximum Exposure Reasonable Maximum Exposure
1) Exposure to Ground Water
Ingestion 8.B4E-04 1.02E+01
Inhalation 1.09E-04 125E-01
Dermal Contact 1.34E-05 1.22E-01
2) Exposure to Surface Soy
Inhalation 2.56E-09 3.28E-09
Total Health Risk - Ground water ingestion + Ground water inhalation + Ground water dermal contact + Surface soil inhalation
SUMMATION RESULTS
Carcinogens
Reasonable Maximum Exposure- 1.01E-03
Noncarcinogens
Reasonable Maximum Exposure- 1.04E+01
-------
TABLE 7-17
HOOKER/RUCO SITE
SUMMARY ACROSS EXPOSURE PATHWAYS
PRESENT/FUTURE USE SCENARIOS-CHILD TRESPASSERS
Present/Future Use Scenarios: Carcinogenic Risk Levels Noncardnogente Hazard Index Values
Child Trespassers Reasonable Maximum Exposure Reasonable Maximum Exposure
1) Exposure to Surface Water
Dermal Contact 9.05E-05 2.08E-02
2) Exposure to Sediment
digestion 6.11E-06 3.34E-02
Inhalation 8.48E-11 4.16E-12
Dermal Contact 2.56E-06
3) Exposure to Surface Soil
Ingestion 1.12E-05 2.38E-03
Inhalation 2.79E-10 5.25E-10
Dermal Contact 1.40E-06
Total Health Risk - Surface water dermal contact + Sediment Ingestion + Sediment dermal contact + Sediment inhalation +
Surface soil tagestton + Surface soil inhalation + Surface soil dermal contact
SUMMATION RESULTS
Carcinogens
Reasonable Maximum Exposure* 1.12E-04
Noncarcinogens
Reasonable Maximum Exposure- 5.66E-02
-------
TABLE 7-18
HOOKER/RUCO SITE
SUMMARY ACROSS EXPOSURE PATHWAYS
PRESENT/FUTURE USE SCENARIOS- SITE WORKERS
Present/Future Use Scenarios: Carcinogenic Risk Levels Noncarcinogenic Hazard Index Values
Site Workers Reasonable Maximum Exposure Reasonable Maximum Exposure
1) Exposure to Surface Water
Dermal Contact 1.05E-04 7.30E-03
2) Exposure to Sediment
Ingestion 2.78E-06 6.43E-03
Inhalation 1.23E-09 1.39E-11
Dermal Contact 2.42E-06 2.64E-04
3) Exposure to Surface Soil
Ingestion 4.93E-05 583E-03
Inhalation 4.23E-09 1.30E-09
Dermal Contact 4.52E-05 5.46E-07
Total Health Risk • Surface water dermal contact + Sediment ingestion + Sediment dermal contact + Sediment inhalation +
Surface soil ingestion + Surface soil inhalation + Surface soil dermal contact
SUMMATION RESULTS
Carcinogens
Reasonable Maximum Exposure^ 2.05E 04
Noncarcinogens
Reasonable Maximum Exposure^ 1.98E-02
-------
TABLE 7-19
HOOKER/RUCO SITE
SUMMARY ACROSS EXPOSURE PATHWAYS
FUTURE USE SCENARIOS-CONSTRUCTION WORKERS
Present/Future Use Scenarios: Carcinogenic Risk Levels Noncarcinogenfe Hazard Index Values
Construction Workers Reasonable Maximum Exposure Reasonable Maximum Exposure
1) Exposure to Surface Soil
Ingestion 2.11E-06 2.71E-03
Inhalation 1.69E-10 1.91E-09
Dermal Contact 1.81E-06
2) Exposure to Subsurface Soil
Ingestion 3.19E-06 1.35E-02
Inhalation 5.57 E-10 7.S3E-10
Dermal Contact 4.98E-06
Total Health Risk • Surface soil ingestton + Surface soil inhalation + Surface soil dermal contact +
Subsurface soil Ingestion + Subsurface soil inhalation + Subsurface soil dermal contact
SUMMATION RESULTS
Carcinogens
Reasonable Maximum Exposure* 1.21E-05
Noncarcinogens
Reasonable Maximum Exposure* 1.62E-02
-------
TABLE 5
Air Regulations and TBC Criteria
-------
UNITED STATES ENVIRONMENTAL PROTECTiON AGESCY
tCN OC
JUM I 5 1939
OSWZR Directive 9355.0-28
MEMORANDUM
SUBJECTS Control of Air Emissions-From Superfund Air
Strippers at Superfund Groundvater fftes
FROM: Henry L. Longest II, Director
Office of Emergency and
Gerald Eaison, Dir« mm
Office of Air Quality Plinhtngand Standards
-•TO: Addressees
PURPOSE
This memorandum establishes guidance on the control of air
emissions froa air.strippers used at Sup.erfund sites for
groundwater treatment and establishes procedures for
implementation. Under this guidance, Regions should continue to
nafce air eaission control decisions on a case-by-case basis
using the nine reaedy selection criteria and the reaedy
selection process set forth in the proposed National Contingency
Plan (HOP). As described below, however, the evaluation and
weighing of the criteria in a "to be considered* (TBC) context
will differ according to the air quality status of the site's
location.
• ' •••.,• .'....'',.•«.* •.".'. "
BACKGROUND • • ' ''''!• '. '' ''•' '
Apprexiaately 35% of the Records of Decision (RODs) signed
to date have involved sites which use a pu»p and treat technique
to either partially or fully remediate groundwater
contamination. Close to 45% of these puap and treat sites have
selected air stripping. For the foreseeable future, OZRR
expect* to use air stripping at about the same rat*. This
treatment technique relies on volatilization to remove volatile
organic compounds (VOCs) from the groundwater, i.e. it transfers
the contaminants froa the'liquid to vapor phase. One known side
effect of air stripping is the emission of VOCs, aany of which
-------
-2- OSWZR Directive 9355.0-28
are toxic, to the ambient air. The Superfund Program uses
control devices such as vapor phase carbon adsorption and
incineration to control these emissions.
In'response to a request froa Regional Air Division
Directors for a policy to guide the selection of controls for
air strippers, OERR and OAQPS conducted a joint study. The
results shoved that historically close to half of the Superfund
air stripper sites had adopted controls during remedy
selection. Another 25 percent deferred the decision to the
remedial design phase. At sites with RODs signed after the ,
enactment of the Superfund Amendments and ^authorization Act,
approximately two-thirds of the air strippers are controlled.
At these sites, control decisions were based on an analysis of
the cleanup standards established in Section 121 of CERCIA and
the other statutory considerations which together comprise the
nine remedy selection criteria! overall protection of human.
health and the environment; compliance with Applicable or
Relevant and Appropriate Requirements (ARARs); long-term
effectiveness/permanence; reduction of mobility, toxieity or
volume (MTV); short-term effectiveness; implementability; cost;
State acceptance; and community acceptance. Control decisions
to date have been driven largely by pretectivaness and State
ARARs for both air toxics control and VOC control for ozone
reduction, other criteria such as MTV, sfiort-term
effectiveness, cost, and community acceptance, have also
influenced the inclusion of controls.
Despite the trend towards increased control of air emissions
froa Superfund air strippers, the Agency remains concerned with
the control of thesa air emissions. This concern underlies the
vigorous efforts by EPA, States, localities, and industry across
the country to control air toxics and reduce Vocs in oxone
nonattainment areas. The adoption of this policy responds to
these concerns, reflects an overall Agency concern with
preventing the- cross-media transfer of pollutants, and
recognizes that the number of federal, State, and local ARARs
for both VOCs and air toxics appears to be rapidly increasing.
The following policy has been adopted to guide Regional
decisionmaJcers on the use of controls for air emissions from
Superfund air strippers, and other vented Superfund sources of
VOCs. This policy is grounded in the remedy selection process
and distinguishes between sites located in attainment and
nonattainmeat areas. *
-------
-J- OSHER Directive 9355.0-28
STATEMENT OF POLICY
For sites located in areas that are attaining the National
Ambient Air Quality Standards for 02one. Regions should continue
applying controls based on existing Agency policy. In most
cases, this will Bean the adoption of controls largely in
response to State ARARs, risk management (i.e., protective-
ness) guidelines, and other requireaents of CSRCLA Section 121.
In ozone nonattainment areas, however, the adoption of
controls is more likely to be indicated even if they are' not
mandated by current Federal or State laws and regulations or
indicated by a cancer risk analysis. Aside froa cancer risk
from air. toxics, voc emissions contribute to non-cancer health
risks in nonattainment areas because most are precursors to the
formation of ozone. Consideration of these non-cancer risks
when applying the remedy selection criteria generally will show
that in nonattainment areas superfund air strippers, except -
those with the lowest emissions rates as indicated below,
generally merit controls. In determining the need for air
stripper controls at a particular Superfund site in a
nonattainment area, the Regions should be guided by the
emissions limit goals in the document entitled, "Issues Relating
to VOC Regulation Outpoints, Deficiencies, and Deviations,"
issued in May 1988 by the Office of Air .Quality Planning and
Standards (OAQPS) to aid states in revising their State
Implementation Plans (SIPS) to incorporate post-1987 ozone
attainment strategies. The OAQPS guidance indicates that the
sources most in need of controls are those with an actual
emissions rate in excess of 3 pounds per hour (Ib/hr) or 15
Ib/tfay or a potential (i.e., calculated) rate of 10 tons per
year (TPY) of total VOCs. The calculated rate assumes 24-hour
operation, 3€5 days per year. Regions should note that control
levels are applied on a facility basis, for the purposes of
this guidance, facility is defined as a contiguous piece of ,
property under common ownership. •','-•.
This guidance applies to air strippers at Superfund sites.
In establishing the policy, however, the potential for
applicability to other VOC sources is recognized. Generally,
the guidelines described for sir strippers are suitable for Voc
sir emissions from other vented extraction techniques (e.g.,
soil vapor extraction) but not from area sources
-------
-4- OSWER Directive 9355.0-28
actions taken by the removal program in the ease of emergency or
time critical removal actions. However, where tine and other
response circumstances permit, such as for non-time critical
actions, adherence to this policy is expected.
The control levels referred to above serve as guidelines
only if ARARs do not exist or are less stringent than presented
here. They are not intended to preclude or replace State
proposals for more stringent levels of control.in pursuit of
Clean Air Act goals as part of SZP revisions in nonattainaent
areas.
«
IMPLEMENTATION
This guidance seeks to incorporate air quality concerns into
the superfund remedy selection process. Zn particular, the use
of controls for Superfund air strippers in nonattainment areas
demonstrates the Agency's commitment to reducing VOCs and thus •
progressing toward attainment of the ozone standard.
Additionally, the guidance is consistent with both the current
NCP and proposed revisions. Where ARARs do not exist, EPA nay
consider TBCS in setting target cleanup levels. This guidance
constitutes a TBC.
The Remedial Investigation/Feasibility -Study (RI/FS) should
generate the data needed to support control decisions for both
attainment and nonattainaent areas. At a minimum, the five
aajor types of information needed ares
Estimated cumulative uncontrolled air emissions rate
froa all air strippers at the site
Consideration of health risks froa the execution of the
remedy as wall as froa the uncontrolled site
• Control alternatives and their costs
Oxone attainment status
•' . • Air ARARs .-'"• • '-.-•••.
For purposes of this guidance •nonattaituent area" means any
county included in a formal post-1987 ozone fix* deficiency
notification (SZP call) or any other county when the ozone
National Ambient Air Quality standard was exceeded during the
previous three-year period. EPA's initial SIP calls were issued
pursuant to section lio(a) (2) (H) of the Clean Air Act and were
described in the September 7, 1911 federal
-------
-5-
OSW£R Directive 9355.0-23
The RI/FS cooping phase and work plan development should
describe the specific data to be generated and the methods for
doing so. Remedial Project Managers should consult with the
designated Air Superfund Coordinator for technical assistance.
Additional assistance is available from National Technical
Guidance Manuals developed jointly by the Air and Superfund
program offices for estimating air emissions and conducting air
pathway analyses. The ROD should summarize this information.as
appropriate and clearly document the basis for the air emissions
control decision.
Addressees:
Regional Waste Management Division Directors
Regional Superfund Branch Chiefs
Regional Air Division Directors
Regional Air Branch Chiefs
OERR Division Directors
OAQPS Division Directors
-------
Attachment II
Booker Chemical/Ruco Polymer Superfund Site
Bicksville, Nassau County, New York
General ARASs
40 CFR 50 National Aatoat Air Quality Standards
§50.6 Jarticulett Matter
(•) 150 m/ttf for a 24 hour map
(b) 50 M/m* fcr aa omul
eNYOUl Part 211 Oc
1211.2 Air palhaioB prohibited. No pcnc« ehtll cauec or alfcv emeem rfair oatamiaenU MBKartdoaratmaepheRof
avcb quantity, dtamrtrriatif or duntioa which arc iajuriout to human, plant or animal file or to property or which Banaaonably
faerfm wi& the ccofcitabkenjcTDM of life cr property. F^-^fcr—^im 1*- -Tinur* fff ir***f* ri* gn^r **Tr*tn>- ~
•niacioB bmiu, thii pnhibaiaa ippliu, hut i» oat fimitcd to, «ny puticubte, tnoe, HIM, fu, odor, note, viper,, polka,
or aeleuriou* oniMion, «afaq ilont or fa combiauioB witti olhcn.
|21IJVu3>kcaMiioaiiiiiBUd. Exc«pt M pcnmtxd by « y»clfic pm of tut StdtchtpmriDd far opmfimfer which*
muieted bumim pcrmii hu hwa inucd, so penoo riuU allow or permit «ny nr cooUfluattiaa tourc* to Mail any BMtcrial
hi viaj n opacity equal to or gtttitt than 20 percent (6 miautc eveaft) except fix oae «~*:— "*•* 6-oriiwie period per hour of
aot more lhaa 57 perceat opacity.
•NVCRR Pan 256 Air Quality Oaui&catictt Syetem
1256.1 Cka«ficaiiookveli. Four feaen! leveli of ec«ial ead ecooooac oevelopaieat tad polhitics poiMliab oiit ia lac
Slate. TIM Uivt n»j .^«.;.t«^ -^, «h» ^if,^*^...;^ i~»j. tHftr^ v f^gnr^^? «~* Tf 1h* f!ft tr* ffnliaH frr1)? *'
irilow*:
Level J - predominantly uatd fcr tiaber, «frieulaii»l crept, cany toning, or recfeatioo. Hehhatioc tad jaduetry
predomiaenay aiagk aad two fccaly reaiJcncti, emtD fcaae, and Baited uccBnim.ial eervicet and iaduauial
- deaicly popnliifd, primarily eoamercia) office buildias*, department mont and ujfat mduetriee in enaD
and medium metropolilaD compkxei, or wburitaa arm of fimited commercial and induetrial development near Urge
metropoliua compkxe*.
LtvtlJV ' deaaely popubu>d, primarily commercial office buildias*, department •one aad tDduatriee ia large
an unHjCtaa ccoplexea, or ana* of heavy induatry.
OnrCKR Part 257 Air Quality Sttodard*
1 257-3 Paniculate*
3 J Suadird for Mapcaded puticlet.
(t) 24-hour auodard. fnr inj71 tmnrptrimt. Ifa irrrijr fi»» iKiiiim atuTT nrt nntAIWnitnt mnrr
ftaa once a year.
(b) Annual ataodard. I*afyuytti^mieru^mea^teg»oot&mmLt{tot1itau**ngt
Leveli 45«/m> Levalffi «5a»/m1
Level D 55«/m> Level IV 75 ^/m*
(c) 30 day ataadard. Ihirmf aay 30 e«aeecutrye at y», Ate aridimelic BMaa of Bx 24-hour averaft
Leveli SOw/m* Level m
Level n lOOpf/af Level IV
fd) 60 day ataadard. Durinjany cceeecutive 60 dtyt, •« arithmetic aaeaa of AM 24-hour everaft
Lawll TOw/o* Level m 95«/tn»
Level n «5«/m> Level IV US &a?
(c) 90 day ataadard. Durim any uuuatmtivi 90 deya.
-------
ecoeeatrationj,at any location, ebaH not exceed:
Level I 65«/m* Level ID 90«/nj'
Level D Kng/af Level IV I05«/m*
3.4 Standard for aeOletble particle*.
(•) During any 12 eoMecutivt moom*, 50 percent of Ac value* of be 30 day avenge cooeeamioai dull
•ocexceed:
Level I OJOav/cnrVno Level m 0.40 m*/cmVmo
Level H 030 of/of to Level IV 0.60 mj/enrVmo
(b) During eny 13 eonaecutive moattu. X percent of fee value* of fee 30 day avenge i
•M exceed:
Level I 0.45«f/enrYao Level m 0.60 ««/CBrVmo
Level D 0.45 agleaf/ao Level IV
Pin 201 Pmnhi tad Cettifieate*
(e) No penon etuJ commence conanictioe of aa eir ooBUannetioo eoutoe or proceed wilfa i modification without
foiog throuffa i permit equtaleacy praceu.
(d) A penoo wbo owoi or operuet ea air r-nrtitninilioa taunt atull eoaetnict, modify, tec, iaeull, tad opentc web
aouree in >c«mUatt with all Ibe roodhiom of tfae permit equivalency.
Capping, Excavation tod Fugitive Dust ARARs
40 CF& 264 &CRA Sttadardi
|264 .251 Deafen and opentiqg iwprimneou.
(0 tf any har«nloui wuu pile coaaini ptftimUlr tuner which aay be eutject lo %iad dupeml, fee owner or
•penior nuat cover or otberwut atatgt the pik to eootrol wind duperaal.
1264 .254 Mooitoriof aod Inap«irtirni
(a) During caoBnictioa or ioeullatioo cover fyatemi inuc be jnaptrted tot uaiformhy, damage, cad inperfiKtiooi
(c.f ., boka, cracki, *in apou, or fotttgo material*). Immediately after conetruttioo or mBalUtion:
(1) Syntbok coven owl be inapfciad lo eaaure tight aeami aad joiata aad the abaeacc of lean, puDcturet,
orblicten.
H««Uiiiep«n«edw»eMya^afiMtoda»eae^id
-------
Bide 404: Fugitive Out
A) No penon abaD came or permit toy mteriali to be handled, truaported, or attnd without ttkiag tMiooibk
pr«fimic»M to preveapifticuUUaaaerfioabecooi^ airborne, facb raaaonabk precaution! ahall
include, but not be fruited to. fee following:
1. Tbe OK of water or euftabk chemical* fer fee control of dual in fee dcaofition of anting bunding*.
conjunction operation*, fee grading of road* or the clearing of land;
2. The application of aaphab, water, or aukabk «*«f«u«i. on din road* or road* under im^v^fm.
SMtcrub, atockpika, ud other aurfrca* which eu five rite to airborne dutt;
4. The covering, it «H time* when ife notion, of opett bodied truck* transporting material* Ekely to give
BM lo aiitiotHe duet;
B)Noper*onahiJlcautcarpenniifeediachaiicofviaJbkami**^
property cc which fee amitrinni originate.
VM212 GcwnlProccM
1212.1 Determination of an
When an application if atde fcr • permit eejuivakney to eoMBuet or accrue • procwt naiMion nource, fte NYSDEC
or tbe EPA will IMUC in wviiaaaenul nting for Meb vt ~-**~i"«' from Mcb •niininri poiat in •ccordioc* with
Table I(i*efecfiaifcsof!hiipaitfcr6c tkblu) of thu put.
I212J EoiMioof from new cmiuioMeouiow and/or •odificitioai.
EminioDf from any procei* emucioo eouree for which an •pplieuioo for a pttnrii oquvakncjr it ne«iv*d we ntticted
M followi:
(•) No penon will came or aBow •-^•^~r that exceed the appfieabk pafniaribk notiaaion rate a*
tfetetniwd from Tabk 2, Tabk 3 or Tabk 4 of Oil Pan far fee eavironBMnul ruing •»«•<»; <»
fh) TBor JMM «~4 i^jiAi j».«^ii.«>. »M. «« ««i;..i»«^««.i «-ti'ij »«f A » or C, and far aoBd pattifiilatfi
with an •avifonBeaul nting of A, where fee aaiiaioo rate potontial b not ahown in Tabk 2, fee
pfnninihk WBiaion rate abiB be ipcifitd by fee NY5DEC or fee EPA; or
(c) In mmtrrrt where the detenunuion of pemuaBbk fmirriim rate tuiiig proceai weight it not applicable
(tee Tabk 5) and for an eavirocacaul rating of B or C ao peraon wiD cauae or allow ainiMimii of aolid
naniclM feat exceed 0.05 grain of paniailaiat par cabic Coot of cxfaauat gu, axprc*Md at •undird
condition* on a dry fat baaii.
1 212.4 Determining applicabk aoiaaioni aundardi.
(a) Where air ~«r*»"^"-«'* Croca two or aorc device* or ooatrivaaoe* are aoia«d to fee outdoor aimiiepheic
ferougb a aingk aimiaioo point, fee peraittibk aauiaioo rate or dcfne of air cleaniag nquindii
oetcrmined by utiag fee aum of fee procMi waighu or •oaajon ate potential* for all auch device* or
-------
TABLE 5
OCCIDENTAL CHEMICAL CORPORATION
HOOKER/RUCO SITE
HICKSVILLE, NEW YORK
New York State Draft Guidelines
for Air Emissions*'
. -, - Compound
'> / ; ''
f '• <-v. f
Acetone
Benzene
Bis (2-ethyIhexyl) phthalate
2-Butaoone
ChJorobenzene
ChJoroform
Chloromethane
Dieldrin
1,2-Dichloroethylene total
Di-n-butyl-phthalate
Di-n-octyl-phthalate
Ethylbenzene
Heptachlor epoxide
4-Methyl-2-pentanone
Naphthalene
Tetnchloroethylene
Trichloroethylene
Vinyl chloride
Xyleoes
TICs
Aluminum
Antimony
Short-Term Guideline
Concentration -
140,000.0
30.0
NR
NR
11,000.0
980.0
22,000.0
NR
190,000.0
NR
NR
100,000.0
NR
NR
12,000.0
81,000.0
33,000.0
1,300.0
100,000.0
NR
NR
120.0
Annual Guideline
Concentration
14,000.0
1.2E-01
NR
NR
20.0
23.0
770.0
NR
1,900.0
NR
NR
1,000.0
NR
NR
120.0
7.5E-02
4.5E-01
2.0E-02
300.0
NR
NR
1.2
34
LBC ENGINEERING SERVICES, INC.
-------
TABLE 5
(continued)
OCCIDENTAL CHEMICAL CORPORATION
HOOKER/RUCO SITE
HICKSVTLLE, NEW YORK
New York State Draft Guidelines
for Air Emissions1'
Compound
, ^vT * -<;
•• \ ' "'' %
Arsenic
Barium
Beryllium
Cadmium
Calcium
Chromium III
Chromium TV
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Nickel
Potassium
Selenium
Silver
Sodium
Vanadium
Zinc
", Short-Teem Guideline , /
f , «; v ' -'
;• cofloentnutOB
• : s
- ' •.••'•••• ^
2.0E-01
120.0
5.0E-02
2.0E-01
NR
MR
l.OE-01
12.0
240.0
NR
NR
NR
240.0
1.5
NR
48.0
NR
NR
100.0
NR
::;: Annual Guideline
\r- LU)ncentrauon
''*''•'{' *• ^ ^
2.34E-04
5.0E-01
4.0E-04
5.0E-04
NR
NR
2.0E-5
1.2E-01
2.4
NR
NR
NR
3.0E-01
2.0E-02
NR
4.8E-01
NR
NR
2.0E-01
NR
±1 Micrograms per cubic meter.
NR Nor regulated.
35
LBC ENGINEERING SERVICES, INC.
-------
APPENDIX
ADMINISTRATIVE RECORD INDEX
-------
09/01/93 Index Oocunent Mutter Order Pipe: 1
MOOKER/RUCO, OPERABLE UNIT 1 Docunents
Docueant fcHber: ttt-001-0001 To 0001 Date: / /
Tftlt: (Mot* to Hie: The leport of Crouiduater ( Soila Investigation at tht Fora»r luce Oiviaiora
Plant Site. Bicksville. Hew York, faction II. Mydrogeology, ia available in the AR for the
Boeker/Ruco aite. Operable Unit 2, and
-------
09/01/93 Index Oocuaent Nuflber Order »age: 2
ER/RUCO, OPERABLE UNIT 1 Oocuwnts
nt Buofeer: BO-001-0715 To 0963 Date: 08/01/92
Title: Remedial Investigation Report. Voluoe IV, Mooker/Ruco Site. IlicksvUle, Hew Tork
Type: IEPORT
Category: 3.4.0.0.0 RI Reports
Author: none: Leggette, Brasheara I Crihaa
Iteipient: none: Occidental Chemical
Bocuoent Kuaber: BKR-001-0964 To 1276 Date: 08/01/92
Title: Remedial Investigation Report, Volune V. Hooker/Ruco Site. Hickcville, New Tork
Type: KPORT
Category: 3.4.0.0.0 R! Reports
Author: none: Leggette, Brashearc t Crahaa
Iteipient: none: Occidental Chemical
Bocuoent Umber: hXR-001-1277 To 1406 Date: 08/01/92
Title: Remedial Investigation Report. Volune VI, Nooker/Ruco Site. Bicksville, Mew Tork
Type: REPORT
Category: 3.4.0.0.0 RI Reports
Author: none: Leggette. Brashears I Crahaa
Recipient: none: Occidental Chemical
•«•••••»*•»•••••*••••»*•••••»••••••••••••*»••»••••*••»•••»••••**»•»••••»•••••••»•»»••••••»•••••••••••
Docuaent Umber: Htt-001*1407 To 1408 Bate: 10/09/92
Title: (Letter sutoitting the attached revised Final Risk Assessment and Fate and Transport Report
for the Booker Cheaical/Ruco Polymer site)
Type: CORRESPONDENCE
Category: 3.4.0.0.0 RI Reports
Author: Sachdev. Dcv R.: Ebasco Services
Recipient: Carpenter, Bale J.: US EPA
Backer, JUl: US EPA
Attached: BXR-001-1409
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09/01/93 Index Document Muober Order Page: 3
HOOKER/RUM, OPERABLE UNIT 1 Docuoents
Doaoent Kuiber: ttS-001-1409 To 1746 Parent: BO-001-U07 Date: 10/01/92
Title: tevised Final lie* Assessnent and Fat* and Transport Report, Operable Unit 1, Hooker Chanical/Buco
Polyaer Site. Hicksvilie, Hew Tork
Type: IEPCRT
Category: 3.4.0.0.0 II leports
Author: Subburasu, £.: Ehasco Services
lecipient: none: US EPA
Oocunent Umber: Htt-001-1747 To 1748 Date: 05/13/92
Title: (Letter submitting the enclosed analytical reports describing results of grounduater taapling
taken fro* the Mooker/Ruco site)
Type: CORBESPOUDEtlCE
Category: 7.8.0.0.0 Enforcement Correspondence
Author: Ueston, Alan F.: Occidental Cheaical
lecipient: Carpenter, Dale J.: US EPA
Attiched: KO -001 -1749
Oocuwnt HuBtwr: UKR-001-1749 To 1808 Parent: KKR-001-1747 Date: 05/11/92
Titln: QA/QC Beview of Selected Ketone, Glycol and Diol Analysis of Croinduater froa the Hooker/Ruco
Site. Bieksvi lie. Hew Tork
Type: PLAH
CetiiBory: 7.8.0.0.0 Enforceaent Correspondence
Author: none: none
lecipient: none: none
Docwent Kiober: KKR-001-1809 To 1840 Date: / /
Titln: fieohydrolegy of the Bethpese-Hidctvflle-Levittoun Area, Long Island, Mew York
Type: PLAN
Catiigory: 11.0.0.0.0 Technical Sources and Guidance Documents
Author: Feldoan. Steven N.: US Geological Survey (USCS)
none: MY Oept ef Law
Sooleraky, Douglas A.: US Geological Survey (USCS)
•ecipient: none: none ..
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09/01/93 Index Docunent MuBber Order Page:
KJOKER/RUCO. OPERABLE UNIT 1 Documents
Oociaent Muafeer: KOi-001-1841 To 1898 Date: / /
Title: Grand-Water Quality in the lethpage-HicksvilU-Levittew Area, Long Island. New York, Mith
Eophasis en Volatilt Organic Coopounds
Type: FLAN
Category: 11.0.0.0.0 Technical Sources and Guidance Documents
Author: Ftldnsn, Steven M.; US Geological Survey CUSGS)
Masterson, John P.: US Geological Survey (USGS)
none: Nassau County Departnent of Health
Snolensky, Douglas A.: US Geological Survey (USGS)
Recipient: none: none
Docuaent Muster: HKR-001-1899 To 1899 Date: 07/28/92
Title: Federal and State NCL Tables Update
Type: CORRESPONDENCE
Category: 3.5.0.0.0 leocdial Investigation Correspondence
Author: LaPosta, Dora: US EPA
Recipient: Evangelista. Pat: US EPA
Feldstein, Janet: US EPA
£arb*rini, Douglas: US EPA
Hauptaan, Nelvin: US EPA
Lynch, Donald: US EPA
Lynch, Kevin: US EPA
NcKnight, Robert: US EPA
O'Connell, Kim: US EPA
Santclla, Dennis: US EPA
Singeraan, Joel: US EPA
Tenerella, Charles: US EPA
Wing, Robert: US EPA
Attached: HOt-001-1900
Oocunent Uufeer: HKR-001-1900 To 1909 Parent: HKS-001-1899 Date: 06/01/92
Title: Federal Drinking Water Standards. Organic - 40 CFR Part 141
Type: DATA
Category: 3.2.0.0.0 Sampling and Analysis Data/Chain of Custody Form
Author: none: none
Recipient: none: none „
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09/01/93 Index Docunent Muter Order Page: S
•OOKER/RUCO. OPERABLE UNIT 1 OocUBents
Deooent Hiaber: Ba-001-1910 To 2121 Date: 04/01/89
Titlt: Occident*t Cheated Corporation, Heeker/Buce Site, Hicksville, Mew Tork - Field Operation*
Plan
Type: PUH
Citegory: 4.2.0.0.0 FS Reports
Author: none: Leggette, Irashears I Craaaa
••cipiant: none: Occidental Oieaical
Oaanent Mvrter: HKR-001-2122 Te 2125 Pate: OS/29/88
Title: (Letter regarding Occidental Chemical as potentially responsible for the conditions at the
•ooker/Rueo Site)
Type: CORRESPONDENCE
Ciitegory: 7.S.O.O.O Enforcement Correspondence
Author: Luftig, Stephen 0.: US EPA
Recipient: Banna, John Jr.: Occidental Chaaical
Irani, Kay: Occidental Clinical
Jennings, Thonas L.: Occidental Chemical
ftudick, Michael J.: Occidental Chaaical
ftocusent Umber: HKH-001-2126 Te 2130 Date: 06/01/93
Title: Hooker Cheaical/Ruco Polymer Site • Hicksville, lieu Tork - Superfmd Update
Type: OTHER
Category: 10.6.0.0.0 Fact Sheets and Press Releases
Author: none
Recipient: none
Docunent muter: nn-001-2131 To 2136 Date: 09/01/91
Title: Guide for Conducting Treliability Studies under CERCLA: Soil Vapor Extraction - Quick Reference
Fact Sheet
Type: OTHER
Category: 10.6.0.0.0 Fact Sheets and Press Releases
Author: none: US EPA -
Ktclpitnt: none: US EPA
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09/01/93 Index Document Number Order Page: 6
HOOGR/RUCO. OPERABLE UK IT 1 Documents
Document Hu*er: 1031-001-2137 To 2306 Date: 01/01/90
Title: Handbook on in Situ Treatment of Hazardous waste-Contaminated Soils
Type: PLAN
Category: 11.0.0.0.0 Technical Sources and Guidance Docunentc
Author: none: US EPA
Recipient: none: US EPA
Document Nusber: Htt-001-2307 To 2312 Bate: 04/13/88
Title: Article IV - Nassau County Public Health Ordinance Private Drinking System, Effective August
1, 1987, Amended April 13, 1988
Type: PLAN
Category: 11.0.0.0.0 Technical Sources and Guidance Documents
Author: none: none
Recipient: none: none
nt Huoter: HKR-002-0001 To 0078 Date: 09/01/91
Title: Guide for Conducting Treliability Studies Under CERCLA: Soil Vapor Extraction • Interim Guidance
Type: PLAN
Category: 11.1.0.0.0 EPA Headquarters Guidance
Author: none: US EPA
Recipient: none: US EPA
Oocuaent Hwber: HKR-002-0079 To 0268 Date: 10/01/88
Title: Guidance for Conducting Remedial Investigations and Feasibility Studies Under CERCLA - Interim
Final
Type: PLAN
Category: 11.1.0.0.0 EPA Headquarters Guidance
Author: none: US EPA
Recipient: none: US EPA
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09/1)1/93 Index Ooontnt Muster Order Page: 7
•OOKEK/KUCO. OPERABLE UNIT 1 DocuBent*
Boaavnt Nuaber: HCK-002-0269 To 0272 Date: 08/29/91
TitlLe: Update en OSUER Soil Leed Cleanup Guidance
Type: CORRESPONDENCE
Category: 11.5.0.0.0 Technical Sources and Guidance Document Correspondence
Author: Clay, Don R.: US EPA
teclpient: none: US EPA
Deciaent MiBter: BCR-002-0273 To 0337 Date: 05/01/93
TitlLe: Occidental Chemical Corporation. Hoeker/Ruco Site. Hicksville, Hew York - Supplemental Test
Boring Program, Plant 2-Above Ground Tanks
Type: IEPOST
Caicegory: 3.2.0.0.0 Saspling and Analysis Data/Chain of Custody Forme
Author: Leggette, Brashears t Graham
•eeiipient: Occidental Cheaicat
Doaaent Huiter: HKS-002-033S To 0&33 Date: 08/01/93
Titlle: Occidental Chemical Corporation, Kooker/Ruco Site. Hicksville. New York, Final Feasibility
Study Report for Operable Unit 1
Type: KEPORT
Category: (.2.0.0.0 FS Reports
Jluthor: Leggette, Brashears I Graham
teeipient: none: none
Deejoent Uujter: KCR-002-Oo34 To 0662 ' Date: 08/01/93
Title: Superfund Proposed Plan • Hooker Chemical/Ruco Polymer. Hickaville, Nassau County, Hew York
Type: PLAH
Category: 4.3.0.0.0 Proposed Plan
Author: none: US EPA
•eclpient: none: none
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09/01/93 Index Docuaent Muter Order Page: S
•OOES/BUCO, OPERABLE WIT t DoeanentS
Deoatnc Hunter: ma-002-0663 To 0667 Bate: 06/15/89
Title: (MeooranduB discuss ins Control of Air Emissions from Superfund Air Strippers at Superfund
Groundwater Sites)
Type: CORRESPOMDEHCE
Category: 11.5.0.0.0 Technical Sources and Cuidanca Oocuoent Correspondence
Author: Eaison, Gerald: US EPA
Longest II, aenry U: US EPA
lecipient: various
Attached: HXR-002-0668
Oocugent Mincer: HIS-002-0668 To 0670 Parent: HKR-002-0663 Date: / /
Title: Attachment II - looker Chamical/Kuco Polyner Superhnd Site, Hidcsville, Nassau County, Meu
Tork
Type: OTHE8 • .
Category: 4.1.0.0.0 ARAK Determinations
Author: none: none
•ecipient: none: none
Acsinis'trE.tive Record Index for OU-1. The docisnents comprising
the Adminis-tra-tive Record file for Operable Unit Two (OU-2) of
Hooker/Ruco (the Site) are hereby incorporated into.the
Administrative Record for Operable Unit One (OU-1) of the Site by
Reference. As such, attached to this OU-l Administrative Record
is the Administrative Record file index for OU-2 of the Site.
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APPENDIX IV
STATE LETTER OF CONCURRENCE
-------
jHiJ-i=.-i?r- 10^5 FPCP'' i;^..£'H;F.<:u!iSEP<.<*T!J:i
New York State Department of Environmental Conservation
50 Wolf fto»<3. Albany, Now York 12233
Tfiomts C.
jIN )2 1994 CommlMlonw
Mr. George Pavlou
Acting Director
Emergency and Remedial Response Division
U.S. Environmental Protection Agency
Region II
26 Federal Plaza
New York, NY 10278
Re: Hooker Chemicfci/Ruco Polymer Site ID No. 130004 OU 1
Dear Mr. Pavlou:
The New York State Department of Environmental Conservation has reviewed the
draft fir.a: Record of Decision (HOD) which was sent on December 14, 1993 from your
office. We concur with the remedy outlined in the Declaration For The ROD.
!f you have any questions, please contact Kama! Gupta, of my staff, at (518}
457-3976.
Sincerely,
nHilPDeBarbieri
Anr
Deputy Commissioner
Office of Environmental Remediation
cc: A. Carlson. NYSDOH
**——'
r ••«*•<* c"'*c**0Mw
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APPENDIX V
RESPONSIVENESS SUMMARY
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RESPONSIVENESS SUMMARY
HOOKER CHEMICAL/RUCO POLYMER SITE
fflCKSVILLE, NASSAU COUNTY, NEW YORK
The U.S. Environmental Protection Agency (EPA) held a public comment period from
August 23,1993 through September 22,1993 which was extended through October 22,1993
for interested parties to comment on EPA's Proposed Plan for Operable Unit 1 at the
Hooker Chemical/Ruco Polymer (Hooker/Ruco) Superfund Site in Hicksville, New York.
The Proposed Plan was developed by the EPA with support from the New York State
Department of Environmental Conservation (NYSDEC).
EPA held a public meeting on September 8, 1993 at the Elks Lodge, Hicksville, New York
to describe the remedial alternatives and to present EPA's and NYSDEC's preferred
remedial alternative to remediate the Hooker/Ruco Site.
The responsiveness summary is prepared for the purpose of providing EPA and the public
with a summary of citizens' comments and concerns about the Site raised during the public
comment period and EPA's responses to those comments and concerns. All comments
summarized in this document will be considered in EPA's final decision for selection of the
remedial alternative for remediation of the Site. The responsiveness summary is organized
into the following sections:
I. Responsiveness Summary Overview. This section briefly
describes the public meeting held on September 8, 1993 and
includes historical information about the Hooker/Ruco Site
along with the proposed remedial alternatives to clean up the
Site.
II. Background on Community Involvement and Concerns. This
section provides a brief history of community interest and
concerns regarding the Hooker/Ruco Site.
III. Summary of Major Questions and Comments Received During
the Public Comment Period and EPA's Responses to
Comments. This section summarizes comments submitted to
EPA at the public meeting and during the public comment
period and provides EPA's responses to these comments.
Section A summarizes those comments received at the public
meeting held on September 8,1993. Section B summarizes the
written comments received during the public comment period.
W1574.LYN
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Attached to this responsiveness summary are four appendices: Appendix A is EPA's agenda
for the public meeting; Appendix B is EPA's Proposed Plan for the Hooker/Ruco Site;
Appendix C is the public meeting sign-in sheet; and Appendix D is correspondence received
by EPA during the public comment period.
I. RESPONSIVENESS SUMMARY OVERVIEW
A. PUBLIC MEETING AND SITE HISTORY
The public meeting for the Hooker/Ruco Site began at 7:00 p.m., on September 8, 1993
with presentations by EPA and was followed by a question and answer session.
Approximately 55 residents and local officials attended the meeting.
Kevin Lynch, Section Chief, Superfund, Western New York Section II; Dale J. Carpenter,
Hooker/Ruco Site Remedial Project Manager; and Ann Rychlenski, Region II Community
Relations Coordinator represented EPA. EPA contractor personnel were represented by
Stuart Fiedel, ARCS II Community Relations Specialist.
Ms. Rychlenski opened the meeting and explained that the purpose of the informational
meeting was to discuss the remedial alternatives considered for the Site and to present the
EPA's preferred remedial alternative for cleanup of the Hooker/Ruco Site. She stressed
that public input into the process of choosing remediation for a site is very important and
encouraged all to comment either verbally or in writing during the comment period. Ms.
Rychlenski also informed the group about the Technical Assistance Grant Program. Ms.
Rychlenski introduced: Councilman Clark and thanked him for his assistance in getting the
Elks Lodge for the meeting; John Barnes (New York State Department of Environmental
Conservation); Anthony Sabino (Bethpage Water Commission); Lloyd Wilson (New York
State Department of Health); and Bruce McKay and Lori Lutzger (Nassau County
Department of Health); and Town of Oyster Bay Supervisor Lewis Yevoli. Ms. Rychlenski
then turned the floor to Mr. Kevin Lynch.
Mr. Lynch discussed the Superfund law (Comprehensive Environmental Response,
Compensation, and Liability Act [CERCLA]), why it was enacted and how it sets out the
rules to address Superfund sites. Mr. Lynch discussed the National Priorities List (NPL) and
how a site qualifies to be placed on the list through the Hazard Ranking System (HRS)
process. The initial examination of a site is called the Remedial Investigation (RI) wherein
the nature and extent of site contamination is determined. Samples of soil, air, sediment,
surface water, and groundwater are collected and analyzed by EPA-approved laboratories.
EPA then evaluates the potential risk to human health and the environment of the
contaminants detected at a site through the performance of a Risk Assessment. EPA also
evaluates the potential routes through which flora or fauna may come into contact with
these contaminants. At the next stage of investigation, the Feasibility Study (FS), EPA
W1S74.LYN
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develops a number of alternatives to remediate site contamination based on the established
criteria. EPA uses nine criteria to evaluate the remedial alternatives. These criteria are:
Overall protection of human health and the environment
Compliance with applicable or relevant and appropriate requirements
(ARARs^
Long-term effectiveness and permanence
Reduction of toxicity. mobility, or volume through treatment
Short-term effectiveness
Implementability
Cost
State acceptance
Community acceptance
EPA presents its preferred remedial alternative(s) for cleanup of the site in a Proposed
Plan. The Proposed Plan is presented to state agencies and the public for review and
comment. EPA evaluates the responses and factors them into its final selection for a site
remedy. A responsiveness summary which addresses public comments is then prepared.
This becomes part of the Record of Decision (ROD) which documents EPA's decision
process. The Remedial Design (RD) is the next stage of site cleanup in which the selected
remedy is detailed. The final phase is called the Remedial Action (RA) phase. This phase
is when the selected remedy is implemented and the site cleanup actually occurs. Time
frames for these activities vary according to the characteristics of the particular site. The
RI/FS can take from 18-24 months; the RD takes between 12-18 months; the RA can take
as long as 30 years if the remedy includes the pumping and treatment of contaminated
groundwater. If the remedy is as simple as removing items such as drums, remediation can
take as little time as six months to complete. Mr. Lynch also discussed EPA enforcement
activities under Superfund, including the role of the potentially responsible party (PRP) in
assuming responsibility for site remediation. The Occidental Chemical Corporation and the
Ruco Polymer Corporation are the PRPs for the Hooker/Ruco Site. Mr. Lynch then
introduced Mr. Dale Carpenter.
The program continued with Mr. Carpenter who presented a brief historical overview and
physical description of the Site.
W1574.LYN
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Mr. Carpenter reported the results of the various testing conducted during the RI on
samples from the Site. The results of the soil testing revealed a wide presence of low levels
of contaminants. The highest concentration of contaminants were found in Sump 1. One
surface location was found to contain possible elevated levels of tentatively identified
compounds (TICs) and a second surface soil location was suspected to contain contaminants
based on previous investigations. A PCB concentration was noted around the Pilot Plant.
The soil vapor sampling resulted in no detection of any volatile organic vapors. The
electromagnetic survey revealed the possible presence of buried objects in three locations.
The groundwater sampling program revealed the presence of contaminants in the
groundwater predominantly in the southern portion of the Site. Chloroethylenes, including
trichloroethylene and dichloroethylene, commonly associated with solvent use, were found
sitewide but with higher levels downgradient. Groundwater at the site was found to move
from the north to the south. The air sampling at the Site revealed the presence of no
hazardous chemicals above detectable limits at the site.
Based on the results of the testing, Mr. Carpenter explained that EPA designated two
Operable Units (OUs). The rationale for designating separate OUs was to address a
portion of the Site's contamination which could be dealt with quickly. These OUs include:
Operable Unit 2, the PCB-contaminated soils; and Operable Unit 1, the remaining
contaminated soils on the site and the groundwater beneath the Site. Operable Unit 2 was
completed in 1992. Operable Unit 1, which would take more time to remediate, is the topic
of the public meeting. Mr. Carpenter said that the three areas which the electromagnetic
survey indicated may potentially contain buried objects were to be the subject of exploratory
excavations and removal (if necessary) early in September 1993. The exploratory
excavations revealed the presence of three buried tanks in one of the areas previously
identified. These tanks are scheduled to be removed in 1994. In addition, Mr. Carpenter
indicated that EPA proposed to conduct additional exploratory soil excavations between
Plant 2 and the Pilot Plant for further soil analysis. These excavations are not associated
with the detection of the magnetic anomalies but are the result of the discovery of a tar-like
substance uncovered during a routine utility trench excavation. A Work Plan to address
these additional areas is expected to be approved by February 1994.
Mr. Carpenter then went on to describe the various proposed remedial alternatives
presented in the FS and considered by the EPA. He explained that the various media (i.e.
groundwater, the deeper soils, and the shallow soils) would all be addressed differently and
required different technologies and techniques for cleanup.
B. SUMMARY OF REMEDIAL ALTERNATIVES
The alternatives which EPA considered focus on the groundwater, deep soils and shallow
soils (Operable Unit 1). These were:
W1574.LYN
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Remedial alternatives to address the groundwater medium:
Alternative 1: No Action
Alternative 2: Deed Notations with Monitoring
Alternative 3: Groundwater Extraction and Treatment with Discharge to an On-Site
Recharge Basin (Sump 3)
Alternative 4: Groundwater Extraction and Treatment with Discharge to Leaching
Galleries
Remedial alternatives to address the deep soils:
Alternative 1: No Action
Alternative 2: Capping of Sump 1 (and Possibly Sump 2)
Alternative 3: Soil Vapor Extraction and Capping
Alternative 4: Soil Flushing
Remedial alternatives to address shallow soils:
Alternative 1: No Action
Alternative 2: Capping
Alternative 3: Excavation and Off-Site Disposal in a Landfill
Mr. Carpenter went on to explain that the various alternatives were evaluated using the nine
criteria discussed by Mr. Lynch. Based on the information gathered for the Site, and the
evaluation of the various alternatives, the EPA formulated a preferred alternative.
THE PREFERRED ALTERNATIVE
Mr. Carpenter then presented EPA's preferred alternative for the Hooker/Ruco Site
Operable Unit 1.
Based upon an evaluation of the various alternatives, EPA and the NYSDEC recommend
Alternative 3 (groundwater extraction and treatment with discharge to an on-site sump) for
the groundwater, in conjunction with Alternative 4 (soil flushing) for the deep soils.
W1574.LYN
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Alternative 3, Excavation, is the preferred alternative to address the shallow soils. If all of
the targeted areas are included (i.e., if Sump 2, and the area around monitoring well E
contain contaminants above the cleanup goals), the total cost of the remedies for Operable
Unit 1 would be:
Capital Cost : $5,531,000
O&M Cost: $552,000/year
Present Worth Cost: 10-year present worth cost - $ 9,031,000
30-year present worth cost - $13,250,000
Specifically, the preferred alternative would achieve substantial risk reduction through the
following actions:
Control of the groundwater through the installation of groundwater extraction
wells;
Treatment of the extracted groundwater with an on-site treatment system to
achieve the appropriate discharge standards;
Additional soil testing in the bottom of Sump 2 to determine if contaminants
are or are not present in the soils, and determine the need for treatment (as
per Sump 1);
Discharge a portion of the treated groundwater to Sump 1 and possibly Sump
2;
Soil flushing for the deep soils in Sump 1 and possibly Sump 2 through the
discharge of a portion of the treated groundwater. Reevaluate contaminant
levels in the sumps in five-year review to determine effectiveness of treatment;
Additional soil testing in the area around monitoring well E to determine if
contaminants are present;
Excavation of shallow soils in the former drum storage area adjacent to plant
2 and possibly in the area around monitoring well E;
Periodic monitoring of groundwater extraction system to assure adequate
control is maintained; and
Placement of institutional controls in the form of deed restrictions and
groundwater use restrictions at the Ruco property.
W1574.LYN
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II. BACKGROUND AND COMMUNITY INVOLVEMENT AND CONCERNS
In 1976, public concern regarding pollution at the Hooker/Ruco Site began to be expressed
when vinyl chloride contamination was detected in wells at the Grumman Aerospace
Corporation facility, adjacent to the Site. In response to this and other potentially harmful
site conditions, environmental action groups staged demonstrations at the Hooker/Ruco Site
in an attempt to close plant operations. During this time period the Site was frequently
linked in media accounts to the Love Canal Superfund Site in Niagara Falls, New York,
since the Hooker Chemical Company owned both Sites. Long Island Newsday published
a cover story on contamination at the Hooker/Ruco Site which represented the media's
peak interest in the Site.
In the 1980s, as the public perceived that the NYSDEC was implementing a cleanup plan
and monitoring program for the Site, community interest declined. Due to difficulties in
negotiations between NYSDEC and OCC, the enforcement lead for the Site was transferred
to the EPA. Upon receiving subsequent information that an RI/FS was planned for the Site
(under EPA authority), citizens expressed surprise that Site cleanup activities were not yet
underway. Similar public concerns regarding the perceived slow pace of Site remediation
were expressed upon release of the Focused Feasibility Study (FFS) and the Proposed Plan
addressing the PCB-contaminated soils in 1988. At the time of the release of the FFS and
the Proposed Plan, the overall level of public involvement among area residents was
markedly decreased compared to the initial levels in the 1970's and early 1980's:
A Final Community Relations Plan for the Hooker/Ruco Site was completed by EPA in
July 1988. Input received at that time indicated that issues of concern to the community
included: the potential for and extent of groundwater contamination; liability of Site
owners; cleanup schedule and funding; and potential negative impacts on local property
values.
The public meeting held on September 8,1993 to present the Proposed Plan for OU 1 drew
only a moderate to low public response with approximately 40 residents attending the
meeting. The majority of individuals attending the meeting were residents and business
owners who resided in the immediate vicinity of the Ruco facility. The predominant
concern of the local residents regarding this Site pertained to air quality issues. The air
quality issues are related to current operations at the Ruco facility and not related to the
Superfund actions being implemented at this Site.
III. SUMMARY OF MAJOR QUESTIONS AND COMMENTS RECEIVED
DURING THE PUBLIC COMMENT PERIOD AND EPA RESPONSES TO
THESE COMMENTS
W1574.LYN
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Issues and questions raised during the public comment period for the Hooker/Ruco Site are
summarized below and are organized into the following categories:
Section A: Comments Received During the Public Meeting
A. Groundwater Contamination
B. Air Quality
C. Other Concerns
Section B: Written Comments Received During the Comment Period
SECTION A
A. GROUNDWATER CONTAMINATION
1. COMMENT: A resident asked about the potential for PCB contamination in
the soils at the Site to enter the groundwater.
EPA RESPONSE: The results of all groundwater sampling at the Site did not
indicate the presence of PCBs in groundwater. This was expected as the
physical and chemical properties of PCBs indicate that they are non-soluble
and, as such, would not readily enter the groundwater. The PCBs at the
Hooker/Ruco Site were removed as a result of the remedial action of OU 2.
2. COMMENT: A resident asked if anyone has tested the water in area homes.
NEW YORK STATE HEALTH DEPARTMENT RESPONSE: The residents
in this area are served by three public water supplies: Hicksville, Levittown,
and Bethpage. These water supply agencies are required by the New York
State Department of Health to periodically sample the water. This regular
testing of the water is done before it is distributed to local residents and
prevents public exposure to contaminants in the water supply. The drinking
water wells are regulated by New York State and Nassau County Department
of Health. Lloyd Wilson of the New York State Department of Health
confirmed that the public water supplies were required to be tested and were
routinely tested, approximately monthly, by the Bethpage Water District.
3. COMMENT: A representative of an environmental group called for soil
monitoring to determine if reverse migration up through soils from
contaminated groundwater and into facilities that people inhabit and work at
has occurred.
W1574.LYN
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EPA RESPONSE: The EPA does not believe that volatilization of
contaminants upward to the surficial soils from the groundwater is occuring
at the Site due to the physical characteristics of the Site and the low VOC
concentrations that exist in the groundwater. Mr. Lloyd Wilson of the New
York State Department of Health indicated that, based on information he has
seen, the upward volatilization would not have a measurable impact on indoor
air quality when the aquifer is 50 feet deep such as is the case at this Site.
Upward volatilization could, however, be a problem at locations where the
groundwater is only 10 feet or less below the surface and soil conditions were
permeable to volatile organic vapors. The soil vapor data collected for this
and adjacent Sites indicates that upward volatilization of VOC vapors to
surficial soils is not a concern. Groundwater quality data also suggests that
contaminants are moving deeper into the aquifer, not upward.
4. COMMENT: A resident asked EPA to clarify the section of the RI/FS report
which addresses a "future groundwater risk scenario."
EPA RESPONSE: EPA's Mr. Mark Maddaloni spoke at some length
concerning the details of the Risk Assessment performed for this Site and,
specifically the future groundwater use scenario. Since everyone is on
municipal water there are no current risks, especially since that water is
regularly monitored. EPA is required to also look at possible future risks. We
look at the chemicals of concern, the exposure pathway, and the potential to
drink this water for a long period of time (e.g. 30-year exposure). We look
at the chemical, the type and extent of exposure, and the potency of this
carcinogen. Based on this information, we make statements about the
carcinogenic risk. EPA has determined that if the potential cancer rate is
greater than one case in ten thousand over a lifetime, remedial action is
generally appropriate. That is why EPA is taking action on the groundwater,
because the excess risk was greater than one in ten thousand due to the
potential future use by a resident of the most contaminated portion of the
groundwater. In developing the risk numbers EPA makes very conservative
estimates which means that in all probability the actual risk from the Site is
no higher than the risk estimates presented in the Risk Assessment Report.
5. COMMENT: A resident asked about the cleanup goals for groundwater.
EPA RESPONSE: New York State has promulgated standards for
groundwater quality, which are equal to or more stringent than EPA's
standards, and these are the goals which EPA has set to clean up the
groundwater. New York State also has standards for discharge criteria, which
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are also going to be applied in the process of treating the groundwater and
then discharging it to a sump.
6. COMMENT: A resident asked if all of the testing of the community's
drinking water was for bacteria and not for chemical and solvents.
EPA RESPONSE: EPA indicated that standard procedure is to test for
bacteria and that in addition, a long list of chemicals are routinely examined
in municipal groundwater supply wells, including solvents.
7. COMMENT: A resident asked if the limits of the off-site plume had been
identified. The resident then asked who is responsible for cleanup of the
plume.
EPA RESPONSE: The NYSDEC is the main agency responsible for the study
of the off-site plume. A great deal of work is currently being carried out to
accurately define the limits of the plume. Some preliminary work has been
done by the United States Geological Survey. With information from the
Hooker/Ruco Site, Grumman Site and the Navy Site being collected, a
regional picture is emerging. Mr. Carpenter indicated that the general
movement of the plume appears to be from north to south. EPA and
NYSDEC personnel believe they have a good handle on the size of the
groundwater plume. John Barnes of the NYSDEC said they were studying
both the Grumman Site and the Navy Site and they anticipate having a
meeting similar to this EPA meeting for the Navy and Grumman Sites. A
meeting for the Grumman Site may be held around the spring of 1994.
When a responsible party is identified, that party is responsible for cleanup from the
beginning of the plume to the end of the plume. However, a problem with a large
plume is that once it leaves a facility, it may mix with other plumes from other
facilities. At this Site, when the plume of contaminants in the groundwater leaves
the Ruco facility, it mixes with other contaminants in the groundwater from the
Grumman and Navy Sites. All contributors to the plume are legally responsible for
cleanup.
B. AIR QUALITY
The bulk of the questions and comments raised at the public meeting were focused on air
quality concerns, the following summarizes the general questions received:
1. COMMENT: Many of the residents commented that there is a very bad,
noxious odor in the area of the Site.
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EPA RESPONSE: EPA personnel acknowledged the odor. Mr. Carpenter
indicated that he had been in touch with the Nassau County Department of
Health about the smell. He assured the residents that the odor was non-
hazardous and not a health risk. Mr. Carpenter indicated that jurisdiction
over air emissions came from legislation to Nassau County through New York
State and other divisions of the EPA. EPA indicated that noxious odors
would be a violation of the nuisance portion of the NYS air regulations. EPA
indicated that Ruco Polymer has been notified for this previously. After
several inspections by the Nassau County Department of Health, they have
referred the issue to the NYSDEC for action. A notice of violation of New
York State's air regulations was issued by the Nassau County Department of
Health. He also indicated that he was aware that Hooker/Ruco had taken
many steps to employ new technology to try to reduce the odor emissions
from the Site (e.g. rerouting their process vents and burning off the odors).
The smells may be coming from the Hooker/Ruco Site and may be due to
ethylene glycol or some kind of a glycol, a substance which has a low odor
threshold.
Kevin Lynch of the EPA indicated that regulation of air emissions from operating
facilities is outside the jurisdiction of the EPA personnel present who are here to
deal with the problems associated with past disposal areas at the Hooker/Ruco Site:
The air monitoring conducted during the RI at the Hooker/Ruco Site indicated that
there was not an air problem associated with these past disposal areas. The focus
of the present study and meeting is intended to be on the Superfund Site, defined as
a soil and groundwater contamination issue. Therefore, the Superfund tasks at the
Hooker/Ruco Site focus on the disposal areas and their potential impacts.
Personnel from the New York State Health Department agreed to transmit
resident's concerns on the air quality to their experts.
Mr. Carpenter indicated that the people to contact are those at the Nassau County
Department of Health and the NYSDEC and then supplied the number of the Air
Programs Office of the Nassau County Department of Health. EPA personnel also
encouraged the residents to write to EPA's air compliance division. They assured the
residents that letters and comments do elicit a response from the agencies contacted.
Representatives of the Nassau County Department of Health indicated that they send
out investigators to try and trace the odors to a source. EPA personnel encouraged
the residents and concerned citizens, to write their local officials and congressmen
with their concerns on air issues.
EPA indicated that the air testing had been conducted during the remedial
investigation in August and September, 1989. More recently, within the past
W1574.LYN 11
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six months, the Nassau County Department of Health conducted a stack test
at the Ruco facility.
Councilman Clark and Supervisor Yevoli, in the audience, volunteered to try
to set up a meeting for residents with the state and county regarding the air
quality of the area and what steps can be taken to deal with the problem.
C. OTHER CONCERNS
1. COMMENT: Several residents stated that a study should be made of the
incidence of cancer among local residents or that a health study be performed.
EPA RESPONSE: EPA personnel indicated that the Agency for Toxic
Substances and Disease Registries (ATSDR) is charged specifically with the
conduct of community health surveys to see what impact may have occurred
in a community. Some cancer studies for Long Island are currently being
conducted and evaluated by other agencies. In response to this meeting, EPA
did refer public concerns and requests to the ATSDR regarding a community-
wide study.
2. COMMENT: A resident asked if Hooker/Ruco is presently operating without
contributing contamination other than air odors.
EPA RESPONSE: EPA responded that discharge is no longer occurring to
any of the sumps at the Site. Currently the waste is drummed and shipped off
site.
3. COMMENT: A resident asked about the possibility of spills at the Site
during the process of excavating and shipping waste off-site.
EPA RESPONSE: The EPA indicated that the excavated soil would most
likely have to be removed by truck or rail car. If that were the case there are
specific laws that govern the transportation of this kind of material. Also we
would be dealing with a fairly small volume of material, so only one or two
trucks would be required and they would be covered. There always exists a
possibility that a spill could occur; however, disposal operations will be
carefully monitored by the EPA and any spills will be properly cleaned up.
4. COMMENT: A resident asked how far the soil contamination extends on and
off the property and asked if soils on area residential properties can be tested.
He was concerned that he and his family may be eating heavy metals by
eating vegetables grown in his backyard garden.
W1574.LYN • 12
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EPA RESPONSE: The testing results from soils sampled on the Site
indicated that the soil contamination is limited to specific areas on the Site.
Metals, which were not really a problem on the Site, should not be a problem
outside of the Site. The soil contamination at the Site is mostly related to the
presence of organic chemicals in very specific areas. These organic chemicals
then migrate into the groundwater, which represents the largest problem
attributable to the Hooker/Ruco Site.
5. COMMENT: A resident asked if consideration was given to any type of
bioremediation as a treatment alternative.
EPA RESPONSE: The feasibility study examined the bioremediation technology and
screened it out during the screening process. This was because the relative
concentrations of the contaminants in the soil were too low to provide sufficient
"food" for the bacteria or enzymes to utilize.
SECTION B
Written comments were received from Occidental Chemical Corporation (OCC) and the
Ruco Polymer Corporation (Ruco) only. The following section summarizes the written
comments received and EPA's response to those comments:
1. COMMENT: Both OCC and Ruco objected to EPA's proposal to locate a
sump in the northwest corner of the Ruco property to receive the discharge
of a portion of the treated groundwater for a variety of reasons. Both OCC
and Ruco requested that the existing Sump 3 (located on the eastern property
boundary) be used for the discharge of treated groundwater as was presented
in the FS. OCC and Ruco argued that locating the sump in the northwest
corner of the Ruco facility would possibly interfere with future development
of that portion of Ruco's property. Ruco also felt that locating a sump in the
northwest corner of the property would create a security problem by attracting
potential trespassers^ OCC also felt that it would be imprudent to discharge
treated groundwater in the northwest portion of the Ruco Polymer facility
because: 1) this area has not been impacted by past waste storage or handling;
and 2) if the treatment technology does not achieve ambient levels of all
plume constituents, Site indicator compounds may be released to the
groundwater at levels which may meet current standards, but which may not
meet future requirements. OCC has suggested the ROD not specify a
discharge location for the treated groundwater.
EPA RESPONSE: After review of the FS and the various discharge options for the
treated groundwater, the EPA and NYSDEC believe that discharge to Sump 3 on the
W1574.LYN 13
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Ruco facility is not an acceptable discharge option. Due to the dynamics of the
hydrogeology EPA and NYSDEC believe the discharge of the treated groundwater
should be located as far as possible from the area of influence of the proposed
pumping wells. By discharging to sump three, the pumping system, which is designed
to prevent further downgradient migration of contaminants in the groundwater, will
be overwhelmed. A proper capture zone created by the pumping wells would not be
able to be maintained with the continual recharge in an area immediately adjacent
to or above the capture zone. This is one of the reasons the EPA proposed the area
in the northwest corner. The optimum location for the discharge of the treated water
would be somewhere beyond the area of influence of the pumping wells. Because
all of the potential discharge location options may not have been fully developed, and
Ruco may want to develop portions of their property at a later date, the EPA will
provide flexibility in the ROD language that will allow for an alternate discharge
location to be determined during the remedial design phase.
2. COMMENT: OCC contends that since treatability studies to determine the
effectiveness of various groundwater treatment technologies were not
performed, it is unknown if available technologies will be able to achieve
ARARs in the groundwater or meet the SPDES requirements. Therefore,
OCC believes cleanup goals and discharge criteria should not be specified in
the ROD but should be assessed in the remedial design phase.
EPA RESPONSE: The NCP requires that the cleanup goals be established for
CERCLA sites using all ARARs when they exist. The ARARs are legally
established standards or criteria that are used as cleanup goals that are to be
achieved through remedial actions at a site. The RI/FS is required to identify these
ARARs which are then used as cleanup goals at a site. At the Hooker/Ruco Site,
the ARARs for groundwater are clearly established and specified in NYSDEC's
groundwater quality and groundwater discharge standards, 6NYCRR. These
standards will be used as cleanup goals and discharge standards unless it is
demonstrated that, under very specific criteria, the standards cannot be achieved.
Based on review of all the available information, the EPA believes that the cleanup
standards and discharge criteria, established through ARARs for this Site, are
achievable. However, the EPA does acknowledge that some uncertainties do exist
in the ability of the selected remedy to achieve the groundwater cleanup standards
and the discharge to groundwater standards. These uncertainties are identified in the
Selected Remedy portion of the ROD and elsewhere. Due to this uncertainty the
EPA concurs with OCC on the need for treatability studies during the design phase
to more accurately determine the effectiveness of various treatment technologies for
groundwater and the potential to achieve the discharge standards. Treatability
studies have been specified in the Selected Remedy section of the ROD. The EPA
believes the results of the treatability studies will indicate that an adequate treatment
V -4.LYN 14
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system can be designed to meet the discharge standards. If the treatability studies
indicate that the discharge standards are impossible to achieve through currently
available technologies, then the selected remedy would have to be revisited by the
agencies. The Selected Remedy Section of the ROD acknowledges this. If, during
the operation of the groundwater pump and treat system, it becomes evident that the
groundwater cleanup standards in the aquifer cannot be attained, a number of
contingent responses are possible. These contingencies are also indicated in the
Selected Remedy section of the ROD.
3. COMMENT: In several comments OCC asserts that the shallow soils should
not be included in the Site remedy because: a) no risk has been assigned to
the soils, b) any chemicals exceeding the "to-be-considered" (TBC) protection
of groundwater standards would leach to the groundwater, under the no action
alternative, and would be captured by the groundwater extraction system
which would lead to the attainment of the TBC criteria.
EPA RESPONSE: OCC's assertion that "no risk" has been assigned to the Site soils
is incorrect. Part of the risk assessment performed for this Site examined the
potential risks to workers at the Ruco facility, trespassers and potential future
construction workers at the Ruco facility from exposure to compounds in the soil,
surface water and sediments at the facility. Risk calculations were made for each of
the potentially exposed individuals. These risk calculations were performed for each
individual's exposure to the various media at the Site (i.e., soil, sediment and surface
water). A quantifiable risk was determined for each of these scenarios. The highest
carcinogenic risks attributable to exposure of Site soils were to the workers at the
Ruco facility. The carcinogenic risks were 4.93 x 10'5 for ingestion, 4.23 x 10"9 for
inhalation and 4.52 x 10"5 for dermal contact. While this risk value may be within
EPA's "acceptable" risk range, it does not mean that there is "no" risk assigned to the
soils. EPA's concern regarding the risks from soil at the facility are due in part to
the role of the soil risk in the cumulative, cross-media risks that a worker may incur
at the Site. The cumulative risk is calculated by the addition of the risks from each
particular medium to a particular individual or group (i.e., Site workers). The
cumulative risk to Site workers was calculated to be 2.05 x ID*4, which is at the high
end of the EPA's acceptable risk range. This risk, which includes the soil risks, is a
cause for the EPA's potential concern. The human health risk posed to Site workers
by the shallow soils, alone, was not the major factor in determining the need to
address the shallow soils. Based on initial soil tests, the shallow soils in the two
areas specified in the ROD (the former drum storage area, particularly at TB-10; and
the area at monitoring well E), indicated the presence of compounds at levels above
that which is considered protective of groundwater (TBC criteria). These soils could
potentially spread to contaminate the deeper soils and eventually the groundwater.
This necessitates that the shallow soils be addressed.
W1574.LYN . 15
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OCC then contends that the shallow soils be remediated through the application of
the no action alternative which would eventually lead to the attainment of the TBC
soil criteria. The EPA and the NYSDEC do not agree with this contention. By
allowing the compounds in the shallow soils to leach downward into the deeper soils
and potentially the groundwater, the area of contamination would increase and would
be equivalent to an unabated release. This further contamination of the soils and
groundwater is unnecessary and unwarranted. By actively remediating the shallow
soils a permanent, effective solution with far fewer uncertainties than no action, can
be achieved. EPA's evaluation of the nine criteria with respect to the various
shallow soil remedial options indicated that the long-term permanence and
effectiveness of the soil excavation alternative was superior to the other alternatives
considered. The NYSDEC and the EPA continue to believe that soil excavation for
shallow soils is the preferred alternative based on the evaluation criteria. However,
the EPA does believe that some uncertainty exists regarding the reliability and
accuracy of the soil data collected in the two shallow soil areas of concern.
Therefore, further soil sampling shall be required during the pre-design or design
phase to more accurately characterize these areas.
4. COMMENT: OCC suggests that the ROD state: "...all of the groundwater
which emanates from the Hooker/Ruco Site is, and has been captured by the
Grumman wells." OCC believes that this concept has been definitively
demonstrated by the United States Geological Survey (USGS) model as
presented in several public forums.
EPA RESPONSE: The EPA and NYSDEC do not believe that OCC has presented
sufficient evidence to support their suggested language. The movement of the
groundwater once it leaves the Ruco facility has not been investigated by OCC, and
the information obtained to date on the movement of downgradient groundwater is
incomplete. EPA and NYSDEC also believe the USGS model does not "definitively"
demonstrate the concept put forth by OCC. The model is based on a number of
assumptions and averages pumping rates from a specific year. The pumping rates at
the Grumman and Navy facilities have been documented to significantly vary from
year to year and seasonally. Because of the many imperfections in predictive
modeling, the EPA and NYSDEC believe that models are not capable of
"definitively" demonstrating the complex hydrogeology that exists in the area, but can
be useful tools in attempting to study the hydrogeology. Until further information
is obtained regarding the flow of groundwater beyond the Ruco facility, the EPA
does not believe OCC's statement is substantiated.
5. COMMENT: In commenting on the Proposed Plan, OCC states that there is
currently no data to support the statement that there are downgradient
contaminants (in the groundwater).
W1574.LYN 16
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EPA RESPONSE: Both the EPA and NYSDEC believe that there is more than
sufficient evidence to document the presence of contaminants in groundwater
downgradient of the Ruco facility. Investigative work conducted at the Grumman
facility and work conducted by the USGS on the regional groundwater quality, reveal
the widespread existence of contaminants in the groundwater downgradient of the
Ruco facility. The contaminants detected downgradient were in many cases the same
as contaminants found in the groundwater beneath the Ruco facility. Studies of
regional groundwater movement clearly show a north to south direction of flow. The
EPA and NYSDEC believe that contaminants introduced into the environment as
a result of operations at the Ruco facility, particularly the groundwater, have clearly
moved downgradient.
5. COMMENT: OCC comments that a statement be included in the ROD to
indicate that there are many and substantial contributors to the groundwater
contamination downgradient from the Ruco facility.
EPA RESPONSE: The EPA and NYSDEC acknowledge that there are contributors
to the contamination present in the groundwater downgradient of the Ruco facility.
This is indicated in the Scope and Role of Operable Unit section of the ROD.
W1574.LYN
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APPENDIX A - MEETING AGENDA
W1574.LYN
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Public Meeting (•&
ILS. EPA, REGION 2
Wednesday, September 8,1993 at 7:00 PJVL
Hicksville Elks Lodge - No. 1931
Hicksville, New York
TOPIC: PROPOSED CUBAN UP AT THE HOOKER CHEMICAL/RUCO POLYMER
SUPERTOND Snt IN HICKSVILLE, NEW YORK
AGENDA
Welcome & Introduction Ann Rychlenski, Community Relations
Coordinator, U.S. EPA, Region 2
Overview of the Superfund Kevin M. Lynch, Section Chief,
Process Superfund, Western NY Section H,
U.S. EPA, Region 2
Site History & Update Dale J. Carpenter, Remedial Project
Manager, U.S. EPA, Region 2
Reivew of the Proposed Plan Dale J. Carpenter
Question and Answer Period
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APPENDIX B - PROPOSED PLAN
WJ574.LW
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Superfund Proposed Plan
Hooker Chemical/Ruco Polymer
,,
v _
*
Hicksville
Nassau County, New York
EPA
Region 2
August, 1993
PURPOSE OF PROPOSED PLAN
This Proposed Plan describes the remedial alternatives
considered for the Hooker Chemical/Ruco Polymer
Superfund site and identifies the preferred remedial
alternative with the rationale for this preference. The
Proposed Plan was developed by the U.S. Environmental
Protection Agency (EPA), as lead agency, with support
from the New York State Department of Environmental
Conservation (NYSDEC). The U.S. EPA, is issuing the
Proposed Plan as part of its public participation responsi-
bilities under Section 117(a) of the Comprehensive Envi-
ronmental Response, Compensation, and Liability Act
(CERCLA) of 1980, as amended, and Section 300.430(0 of
the National Contingency Plan (NCP). The alternatives
summarized here are described in the Remedial Investiga-
tion and Feasibility Study (RI/FS) reports which should be
consulted for a more detailed description of all the alterna-
tives.
This Proposed Plan is being provided as a supplement to
the RI/FS report to inform the public of EPA's and
NYSDEC's preferred remedy and to solicit public com-
ments pertaining to all the remedial alternatives evaluated,
as well as the preferred alternative.
The remedy described in this Proposed Plan is the pre-
ferred remedy for the site. Changes to the preferred
remedy or a change from the preferred remedy to another
remedy may be made, if public comments or additional
data indicate that such a change will result in a more
appropriate remedial action. The final decision regarding
the selected remedy will be made after EPA has taken into
consideration all public comments. We are soliciting public
comment on all of the alternatives considered in the
detailed analysis of the RI/FS because EPA and NYSDEC
may select a remedy other than the preferred remedy.
COMMUNITY ROLE IN SELECTION PROCESS
EPA and NYSDEC rely on public input to ensure that the
concerns of the community are considered in selecting an
effective remedy for each Superfund site. To this end, the
RI/FS reports, Proposed Plan, and supporting documenta-
tion has been made available to the public for a public
comment period which begins on August 23,1993 and con-
cludes on September 22,1993.
A public meeting will be held during the public comment
period at the Hicksville Elks Lodge - No. 1931, 80 East
Barclay Street, Hicksville, New York, on September 8,
1993 at 7:00 pm to present the conclusions of the RI/FS,
to elaborate further on the reasons for recommending the
preferred remedial alternative, and to receive public com-
ments.
Comments received at the public meeting, as well as
written comments, will be documented in the Responsive-
ness Summary Section of the Record of Decision (ROD),
the document which formalizes the selection of the
remedy.
All written comments should be addressed to:
Dale J. Carpenter
26 Federal Plaza, Room 747
New York, New York 10278
Phone Number (212) 264-9342
Dates to remember:
MARK YOUR CALENDAR
August 23,1993 to September 22,1993
Public comment period on RI/FS report, Proposed
Plan, and remedies considered
September 8,1993
Public meeting at the:
Hicksville Elks Lodge - No. 1931
80 East Barclay Street
Hicksville, New York 11801
7:00pm
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Copies of the RI/FS report, Proposed Plan, and
supporting documentation are available at the follow-
ing repositories:
Hicksville Public Library
169 Jerusalem Avenue
Hicksville, New York 11801
(516) 931-1417
Hours: M-F 10-9, Sat 10-5
and
U.S. EPA - Region II
26 Federal Plaza
New York, New York 10278
(212) 264-8770
SITE BACKGROUND
The Hooker Chemical/Ruco Polymer site, also called the
Hooker/Ruco site, is an active chemical manufacturing
facility located in a heavily industrialized section of
Hicksville, Nassau County, New York (See Figure 1). The
site, located off of New South Road in Hicksville, was
developed by the Rubber Corporation of America, a small
privately held company. Operations at the site began in
1945 and included natural latex storage, concentration and
compounding. Five years later the company began
producing small volumes of plasticizers. These activities
were expanded and modified through the years. In 1956,
a polyvinyl chloride plant was built and was initially
operated under the name of Insular Chemical Corporation.
At that time the two companies, Insular Chemical Corpo-
ration and the Rubber Company of America, occupied the
site. Although they were two separate corporations, they
shared the same pilot plant. The two companies eventual-
ly merged into the Rubber Corporation of America. In
1965, the company was purchased by the Hooker Chemical
Company and was known and operated as the Ruco
Division. Hooker Chemical has undergone several name
changes, with the current name being Occidental Chemical
Company (Occidental). In 1982, the employees bought the
company from Occidental and it became known as the
Ruco Polymer Corporation (not affiliated with Occidental
Chemical Company).
The Ruco Polymer plant, currently owned and operated by
the Ruco Polymer Corporation (Ruco), contains four
buildings for the manufacture and storage of chemical
products (Plants 1,2,3 and the Pilot Plant, See Figure 1.2)
and an administration building. The remainder of the 14
acre site contains parking areas, chemical storage tanks,
4 recharge basins (sumps) and small ancillary buildings.
The facility currently r nufactures polyester, polyols and
powder coating resins.
The major industrial facilities in the area are the Grum-
man Aerospace Corporation (Grumman) Bethpage -manu-
facturing facility and airport and the U.S. Naval Weapons
Industrial Reserve Plant (NWIRP). There are other small
industries, commercial operations, utilities, and transporta-
tion corridors in the area. Residential neighborhoods are
in close proximity to and surround the industrial area.
The Hooker/Ruco Site is physically bounded by the LIRR
tracks to the southwest, New South Road to the West,
Commerce Drive to the north and the Grumman facility to
the east and south.
The industrial area, including the Site, as well as the
surrounding residential areas are above the groundwater
aquifer that supplies the surrounding communities with
water. The aquifer on Long Island is designated a sole
source aquifer.
Since 1946, the facility was used for the production of
various polymers, including: polyvinyl chloride (PVC),
polyesters, polyurethanes, vinyl film sheeting, pelletized
plastic compounds, styrene/butadiene latex, vinyl chlo-
ride/vinyl acetate copolymer, and polyurethane, as well as
ester plasticizers. This facility is currently active and
manufactures such products as polyester, polyols and
powder coating resins.
During site operations between 1956 to 1975, industrial
wastewater and stormwater from the facility was dis-
charged to six (6) on-site recharge basins or sumps. This
wastewater contained, among other things, vinyl chloride,
trichloroethylene, barium and cadmium soap, vinyl acetate,
organic acids, and styrene condensate. From 1951 to 1974,
process wastewater from ester production was fed to Sump
1. Sump 2 received any overflow from Sump 1 as well as
stormwater runoff from the site. Sump 1 was then partial-
ly backfilled and a series of six concrete settling basins
were installed. From 1975 to 1991 the concrete settling
basins were used to store process wastewater from ester
production prior to being incinerated on-site. These
wastewaters are presently stored in an on-site, above
ground tank prior to off-site disposal or incineration on-
site. Sump 3 currently receives the surface-water runoff
from a large part of the plant, including most of the
manufacturing areas. Sumps 4, 5 and 6 received waste-
streams from Plant 2 processes. Sumps 4 and 5 were the
primary recipients of the discharges, with Sump 6 added
in 1962 to handle any intermittent overflow. Sump 4 is
currently used for the discharge of blowdown from the
non-contact cooling water system. Sumps 5 and 6 have
been completely backfilled.
As a result of these releases, groundwater beneath and
downgradient from the site has been contaminated.
Limited areas of residual soils contamination exist above
levels that would be considered protective of groundwater
quality.
From 1946 to 1978, the Pilot Plant used a heat transfer
fluid called Therminol, which contained PCBs. During the
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operation of the facility, there was a release of PCBs to the
sofl adjacent to the pilot plant Some of this contaminated
soil was spread to surrounding areas by surface-water run-
off; sediment transport, and truck traffic. Since 1984,
Occidental has conducted several investigations to deter-
mine the extent of PCB and other soils and groundwater
contamination at the Ruco Polymer plant In 1989, an
underground fuel oil storage tank adjacent to Plant 1 was
removed, and the soils surrounding the tank were excavat-
ed, sampled, and found to be contaminated with PCBs.
These excavated soils were covered with plastic sheeting,
pending the remediation of the other PCB-contaminated
sofls on the site.
The site was placed on the National Priorities List (NPL)
in 1984. Initially, negotiations by NYSDEC and EPA failed
to reach a settlement with the potentially responsible
parties (Occidental Chemical and Ruco Polymer) to
conduct the PJ/FS for the site. Therefore, EPA issued a
work assignment to its contractor, Ebasco Services Inc., to
prepare a work plan and conduct the RI/FS. However, in
September 1988, after the work plan was finalized,
Occidental agreed to perform the work. In September
1989, RI/FS field work commenced. Field work was
completed in February 1990 and a draft RI Report was
submitted in April 1990. Portions of the RI Report
pertaining to the PCB contaminated areas were approved
to expedite the remediation of those areas. The final,
complete RI report was approved in December, 1992.
In order to expedite action to deal with the most immedi-
ate human health threats at the site first, separate distinct
remedial actions or "operable units (OUs)" were estab-
lished. The OUs are for this site are divided as follows:
o OU 1: Covers the majority of the Ruco property;
soil and groundwater contamination from previous
disposal activities.
o OU 2: Addressed the PCB-contaminated soils.
o A third area of concern: Contaminated groundwater
dciwngradient of the Ruco property boundary.
As stilted above, the RI Report for OU 1 was approved in
December 1992 by the EPA. The FS Report containing
the various alternatives to address the OU 1 contamination
was, approved in August, 1993. This Proposed Plan
addresses OU 1.
To perform an early action to remediate the PCB contami-
nated areas separately, Occidental prepared a Focused
Feasibility Study (FFS) which analyzed alternatives to
address the PCB-contaminated areas on the site. Since the
PCB-contaminated areas had been defined by previous
investigations, and the technologies for treatment were
different from the rest of the site, -it was decided to
perform an early action. The PCB excavation was then
designated as OU 2.
OU 2 of the site covered an area surrounding the pilot
plant building and a portion of Sump 3 which was contam-
inated by PCBs. A ROD addressing OU 2 was issued on
September 28, 1990. The ROD selected excavation
followed by offsite disposal and incineration of the PCB
contaminated soils.
A Unilateral Administrative Order was issued by the EPA
to perform the OU 2 Remedial Design and Remedial
Action (RD/RA) on June 27, 1991. Notices of Intent to
Comply with the order were submitted by both Occidental
and Ruco Polymer and were, received by EPA on July 17,
1991.
Final approval of the RD/RA Work Plan was given by EPA
in April, 1992. Mobilization for the execution of the
Remedial Action of OU 2 took place on May 4, 1992. All
operations of the work were monitored by an EPA over-
sight contractor. An EPA inspection visit was made on
September 3, 1992 at which time all restoration was
completed.
Occidental's Remedial Action Report was received on
October 19, 1992 and EPA's final approval was issued on
March 12, 1993. This concluded the activities associated
with OU 2.
Upon completion of the OU 2 remedy, four areas of PCB
contaminated soils surrounding the pilot plant were
addressed. They were: 1) the direct spill area;
2) transport related areas; 3) the previously excavated
soils; and, 4) the impacted recharge basin (Sump 3)
(Figure 2). The volumes of PCB-contaminated soils that
were removed, were as follows:
10 ppm - 500 ppm = 3,230 tons (1,957 cu.yds.)
500+ ppm
85.2 tons (52 cu.yds)
A larger problem associated with this site and the adjacent
sites (Grumman and the Navy), is the existence of down-
gradient groundwater contamination. This is the third
area of concern stated above. The EPA and NYSDEC are
currently coordinating activities concerning the RI/FS of
the groundwater contamination that has migrated down-
gradient from the Ruco property boundary and the Grum-
man and Navy facilities. The EPA and NYSDEC have
identified three sites that are currently contributing to the
groundwater contamination including; the Hooker/Ruco
(EPA lead), Grumman (State lead) and the Navy (State
and EPA lead) sites. NYSDEC and EPA are coordinating
the downgradient contamination investigation and remedi-
al actions for the three sites to avoid duplication of efforts.
The agencies are managing their sites by implementing
source control measures (e.g., OU 1 and OU 2 for the
Hooker/Ruco site), then addressing the 'owngradient
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groundwater contamination problem separately. A
regional approach to the groundwater contamination
problem is being applied. Much of the investigation field
work has been completed already. It is expected that it
wfll be approximately one year before EPA and NYSDEC
select a remedy for the groundwater problem. In the
interim, actions have been taken by NYSDEC and Grum-
man to provide protection of the public water supply. A
treatment system has been installed on one of the Beth-
page Water District's supply wells, and additional monitor-
iagwells are being installed to detect contaminants as they
approach other supply wells.
Other actions on the Ruco property are being initiated to
address potential buried materials in the soil. The electro-
magnetic survey conducted during the RI indicated the
presence of magnetic anomalies in the subsurface soils.
The presence of such anomalies may indicate buried
metallic objects such as a tank or drum. A Work Plan has
been submitted by Occidental and approved by the EPA to
further investigate these anomalies and remove any buried
objects that may present a potential source of contamina-
tion.
Additionally, an investigation of buried materials in the
soils not associated with the magnetic anomalies is expect-
ed to be conducted. This investigation between Plant 2
and the Pilot Plant, may involve the excavation of test pits
or trenches. This work is expected to begin in August or
September of 1993.
The two actions cited above are not being conducted as
part of a specific OU. Instead, they are being treated as
removal-type remedies to facilitate quick action.
REMEDIAL INVESTIGATION SUMMARY
The RI, combined with previous studies, resulted in a
characterization of the environmental conditions of the
Rnco property. Sampling of all media, including air, soil
vapor, soils, surface water, sediment and groundwater has
identified areas of potential environmental concern. The
following briefly summarizes the results of the sampling
conducted during the RI:
SoD Vapor Soil-vapor sampling and analysis was per-
formed at 80 locations throughout the site. The results of
the soil-vapor analysis did not reveal any soils with volatile
organic vapors, or additional areas of the plant soils
requiring further environmental sampling.
Surface Water: The surface water existing in Sumps 3 and
4 contained low levels of chemicals associated with the site
due to surface water runoff from the active plant areas.
The presence of these chemicals is related to present
activities at the site.
Sump Sediments: The sediments from Sumps 3 and 4
contained low levels of chemicals associated with past and
current site activities. Sump 3 contained phthalates and
PCBs, which were removed as part of the OU 2 remedy.
Sump 4 sediments contained polycyclic aromatic hydrocar-
bons (PAH's), phthalates, and 1,2-dichloroethylene (1,2-
DCE) at levels below concentrations considered protective
of groundwater. These sediments also contained tentative-
ly identified compounds or TICs. TICs are compounds that
are not on EPA's Target Compound List (TCL) and are
not routinely analyzed for in samples collected. Routine
analysis merely identifies the presence of a compound that
is not on the TCL list and attempts to name the compound
through a computer library search. They are therefore
designated as TICs. These sumps receive surface water
runoff from active areas of the plant which can contain low
levels of chemicals, as seen in the surface water. Low-level
accumulation of these chemicals in the sediments is a
continuing process related to current plant activity.
Shallow Soils: SoD borings were performed at approxi-
mately 50 locations across the Ruco property. The investi-
gation identified sporadic, low-level occurrences of chemi-
cals in the surficial soil throughout the active plant areas.
Shallow soils in the former drum storage area, particularly
in the area of boring number 10 (TB-10) (Figure 3),
contained TICs at levels that were of some concern.
Because very little or no risk information exists for these
compounds, and TICs have been detected in the groundwa-
ter, the soils in this area have been' included .in this
Proposed Plan as requiring remediation. In 1984, a soil
boring performed in the area of monitoring well E
(MW-E), indicated the presence of tetrachloroethylene
(PCE, sometimes referred to as perchlorothlyene or "perc")
at 244 ppm at the surface (Figure 4). This level is not
considered to be protective of groundwater. However,
since the boring was performed some time ago, additional
borings will be required to confirm the presence of PCE in
this area. The occurrence of PCBs in shallow.soils was
completely defined and was the subject of the OU 2
remedial action.
Deep Soils: The deep soils beneath Sumps 5 and 6 do not
contain chemicals at concentrations significantly above the
protection of groundwater criteria. However, the deep
soils beneath Sump 1 contain compounds such as trichloro-
ethylene (TCE), PCE, 1,2-DCE, phthalates and phenols at
levels that could potentially continue to go into solution
and enter the groundwater system. Only the soils beneath
Sump 1 represent a "hot spot" or a concentrated area of
elevated contaminants. The analytical information ob-
tained during the RI did not indicate the presence of
chemicals in the surficial soils of Sump 2 above levels that
are considered protective of groundwater. However, to
confirm the presence or absence of potential contaminants
in the deep soils of Sump 2 (below 12 feet), additional
sampling will be required.
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Groundwater: A total of 32 monitoring wells have been
installed at the site. Some of these wells were installed
prior to the RI and some were installed as part of the HI.
The wells are located on, or in the immediate vicinity of
Ruco property and monitor the upper to middle portions
of the Magothy aquifer (for more detailed information on
the geology and hydrology at the Site, the Remedial
Investigation Report should be referenced). Based on the
sampling conducted prior to and during the RI, the
evidence indicates that groundwater beneath the Ruco
property, specifically in the southeast portion, contains
chemical constituents above the New York State drinking
water standards, NYS groundwater quality standards and
EPA maximum contaminant levels (MCLs). Groundwater
containing vinyl chloride monomer (VCM), PCE, DCE,
TCE, TICs and arsenic, is moving with the groundwater,
downgradient from the Ruco property. Available informa-
tion from the RI and other investigations indicates there
are regional occurrences of chloroethylenes, and that
additional sources of these contaminants are present. Low
levels of some of the chloroethylenes have been detected
npgradient from the Ruco property.
Currently, there are no private drinking water supply wells
on the Ruco property or in the residential areas surround-
ing the property. A Nassau County Ordinance only
permits obtaining drinking water from a public supply
source Public water supply is obtained from the ground-
water aquifer in the surrounding communities of Hicks-
vflle, Bethpage and Levittown. The nearest public supply
wells to the Ruco property are located 2,000 feet to the
north (Hicksville supply wells), 3,500 feet to the west
(Hicksville supply well) and 6,000 feet to the east (Beth-
page supply wells). Other public supply wells located
downgradient to the site are 5,500 feet to the southwest
(Hicksville and Levittown supply wells) and approximately
10,000 feet to the south (Bethpage and Levittown supply
wells).
In summation, the results of the Remedial Investigation
conducted at the Hooker/Ruco site indicate the past
disposal practices bf discharging process wastewater to the
sump.1; has contaminated the soils and groundwater on the
Ruco property. Sampling at the site indicates the presence
of volatile and semi-volatile organic contaminants in the
deep soils beneath Sump 1 and the surface soils in the
former drum storage area above levels considered protec-
tive of groundwater quality. Two additional areas of the
property have been identified as potential sources of
contamination. These areas are the soils beneath Sump 2
and the surface soils near monitoring well E. Additional
sampling will be required to verify the presence of contam-
inants in these areas and determine if concentrations are
above levels protective of groundwater. If this is the case,
the soils beneath Sump 2 and surface soils around well E
wfll also be addressed by the preferred alternative.
The RI, through the sampling of groundwater monitoring
wells, indicates the presence of contaminants in the
groundwater. The level of these contaminants are above
NYSDEC's groundwater standards and EPA's MCL's.
SUMMARY OF SITE RISK
Based upon the results of the RI, a baseline risk assess-
ment was conducted to estimate the risks associated with
current and future site conditions. The baseline risk
assessment estimates the human health and ecological risk
which could result from the contamination at the site if no
remedial action were taken.
Human Health Risk Assessment
The reasonable maximum human exposure is evaluated.
A four-step process is utilized for assessing site-related
human health risks for a reasonable maximum exposure
scenario: Hazard Identification-identifies the contami-
nants of concern at the site based on several factors such
as toxicity, frequency of occurrence, and concentration.
Exposure Assessment-estimates the magnitude of actual
and/or potential human exposures, the frequency and
duration of these exposures, and the pathways (e.g.,
ingesting contaminated well-water) by which humans are
potentially exposed. Toxicity Assessment-determines the
types of adverse health effects associated with chemical
exposures, and the relationship between magnitude of
exposure (dose) and severity of adverse effects (response).
Risk Characterization-summarizes and combines outputs
of the exposure and toxicity assessments to provide a
quantitative (e.g., one-in-a-million excess cancer risk)
assessment of site-related risks.
The baseline risk assessment began with selecting contam-
inants of concern which would be representative of
contaminants detected at the site. These contaminants of
concern were used to calculate the human health risks
from exposure to the various media (i.e., groundwater, soil,
sediments, etc.). The development of the risk estimates
indicated that a few specific chemicals were the major
contributors to the site risks. These included: PCE, vinyl
chloride, antimony, arsenic, beryllium, and manganese.
Of the contaminants listed above, PCE is known to cause
cancer in laboratory animals and is suspected to be a
human carcinogen. The other contaminants, arsenic,
beryllium, and vinyl chloride are class A carcinogens, or,
are known to cause cancer in humans. The contaminants
antimony and manganese were identified as the major
contributors to the noncarcinogenic risks at the site.
The baseline risk assessment evaluated the health effects
which could result from exposure to contamination as a
result of dermal contact, ingestion, and inhalation of site
soils, sediments, surface water and groundwater. The
current land-use at the Ruco Property was considered to
be industrial, as it is presently zoned. The futur ise
-------
scenario also assumed the Ruco Polymer property would
remain zoned for industrial use. However, a resident was
assumed to live at the downgradient property line and use
the sole source aquifer as a water supply. The exposure
scenarios included on-site workers, trespassers, and
residents.
EPA's current guideline for acceptable exposure is an
individual lifetime excess carcinogenic risk in the range of
10"* to 10"*. This should he interpreted to mean that an
individual may have one in ten thousand (10"*) to one in
one million (10*) increased chance of developing cancer as
a result of Site related exposure to a carcinogenic com-
pound over a 70 year lifetime.
The results of the baseline risk assessment indicated that
the current use of groundwater at the Ruco property was
not a risk since no one uses the groundwater for domestic
purposes. On the Ruco property, the soil pathway alone
was also determined not to be a human health risk in both
the current and future-use scenarios. However, the
combined .soil, sediment and surface water pathway for an
on-site worker was estimated to be at the 10"* or upper
limit of the risk range. The risks associated with TICs in
the shallow soils could not be quantified due to the lack of
toxicity information for these compounds. The risk from
TIC exposure is therefore unknown. This unknown risk,
combined with the quantified risk from shallow soils was
cause for potential concern at the site.
The future groundwater-use scenario was the only scenario
to pose an unacceptable risk to human health. The
carcinogenic risks that have been identified for the future
groundwater exposure scenarios are as follows: ingestion
exposures yielded a potential carcinogenic risk to adults of
2.2 x 10"3 (i.e., 2.2 additional persons out 1000 are at risk
of developing cancer if the site is not remediated.), and for
children a risk of 8.8 x 10"4 (i.e., 8.8 additional persons out
of 10,000 are at risk of developing cancer). The inhalation
exposures to adult residents in the future use scenario
result in a potential carcinogenic risk of 5.0 x 10"* (i.e., 5.0
additional persons out of 10,000 are at risk of developing
cancer). Carcinogenic inhalation risks to children residing
at the property line were calculated to be 1.0 x 10"* (i.e.,
1.0 additional child in 10,000 is at risk). Analysis of
groundwater dermal contact exposure to residents (both
adults and children) resulted in a potential carcinogenic
risk to adults of 1.1 x 10** (i.e., 1.1 additional persons out
of 10,000 are at risk of developing cancer), and to children
of 1.3 x 10"6 (i.e., 1.3 additional persons out of 100,000 are
at risk).
The Hazard Index, which reflects noncarcinogenic effects
for a human receptor, was estimated to be 10.2 for
children and 4.89 for adults in the groundwater ingestion
future use scenario. A hazard index greater than 1.0
ind: tes that the exposure level may exceed the protective
level for that particular chemical.
Actual or threatened releases of hazardous substances
from this site, if not addressed by the preferred alternative
or one of the other active measures considered, may
present a potential threat to public health.
Ecological Risk Assessment
The reasonable maximum environmental exposure is
evaluated. A four-step process is utilized for assessing
site-related ecological risks for a reasonable maximum
exposure scenario: Problem Formulation-& 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 con-
taminant 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 Characterize ion -measure-
ment or estimation of both current and future adverse
effects.
The ecological risk assessment began with evaluating the
contaminants associated with the site in conjunction with
the site-specific biological species/habitat information. The
contaminants of concern at this site are not expected to
significantly impact any ecological receptors (plant or
animal species or habitat).
The site is fully developed as an industrial facility and is
surrounded by similar types of land use. There are no
natural surface water bodies or wetlands within the site
vicinity. The contaminants of concern are found in the
soils and groundwater which do not appear to be a habitat
for any wildlife that may impact the food chain. The only
observed animal life at the site were transient Canada
geese, which are not expected to be part of the higher food
chain, and therefore, any impacts to the geese from the
site are not expected to affect the area wildlife population.
The risk assessment also considered whether there were
present visible signs of impairment to the geese that were
attributable to the contamination found at the site. No
visible signs were observed.
The results of the ecological risk assessment indicate that
the contaminated soils and groundwater at the site do not
pose an unacceptable ecological risk.
SCOPE AND ROLE OF ACTION
As stated above, the site has been separated into distinct
remedial actions or "operable units (OUs)." The OUs for
this site are divided as follows:
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o ()U 1: Covers the majority of the site; soils and
groundwater contamination from previous disposal
activities.
o OU 2: PCB-contaminated soils surrounding the
pilot plant and in sump three.
o A third area of concern: Contaminated groundwater,
downgradient of the Ruco property boundary.
This proposed plan addresses the first OU. The EPA is
proposing this action to eliminate the potential threat from
the contaminated groundwater at the Ruco property and
also eliminate the contribution of contaminated soils to the
degradation of the sole source aquifer. The RI identified
groundwater beneath the Ruco property above New York
State groundwater quality standards, NYS drinking water
standards and Federal MCLs. The RI has also identified
limited areas of soils on the property that need to be
remediated to protect the groundwater quality. Additional
limited areas of soils have been identified that may
potentially need to be remediated to protect groundwater
quality. Therefore, OU 1 will address:
- groundwater beneath the Ruco property,
- the remediation of soils in the following areas:
1) the soils beneath Sump 1,
2) the surficial soils in the former drum storage area;
and based on additional sampling,
3) the soils beneath Sump 2, and
4) the surficial soils around monitoring well E.
REMEDIAL ACTION OBJECTIVES
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
(ARAKs) and risk-based levels established in the risk
assessment.
The following remedial action objectives were established:
Groiuadwater
The Risk Assessment has identified a future carcinogenic
and noncarcinogenic health risk to residents who may
reside at the Ruco property fenceline and use the ground-
water (a sole source aquifer). The contaminants in
groundwater are subject to a number of regulations for
cleanup and discharge. These regulations are the NYS
Water Quality Regulations specifically, 6 NYCRR and 10
NYCBR as well as the Federal MCLs. The EPA selects
the most stringent criteria for cleanup at superfund sites.
The specific ARARs identifying the groundwater cleanup
and discharge criteria are listed in the regulations cited
above. These are also listed in the FS Report for this site.
Therefore, the specific Remedial Action Objectives for
groundwater are the reduction of risks to human health
associated with potential exposure to site related com-
pounds by controling the migration of groundwater
downgradient from the Ruco property and attaining the
sole source aquifer (groundwater) cleanup criteria estab-
lished by ARARs.
Deep and Shallow Soils
For the soils, no risks were associated with direct exposure
to the contaminants remaining at the site. However,
contaminant concentrations in the soils of the former drum
storage area, Sump 1 and possibly the area around moni-
toring wells E and Sump 2 at the site are, or are suspected
to be, above levels that would be protective of the ground-
water quality. This means that contaminants in the soil
could leach into the groundwater at levels above the
groundwater ARARs. The NYSDEC has developed soil
cleanup criteria that is considered protective of ground-
water quality. This criteria, established in NYSDEC's
Technical and Administrative Guidance Memorandum
(TAGM), will be used as a to-be-considered (TBC) goal in
cleaning up soils at the site. The TBC values are not
promulgated regulations and therefore, are not considered
ARARs. As TBCs, they are not enforceable standards but
may be used as one of the criteria in determining whether
the remedial action objectives have been met The EPA
has also identified the shallow (0* to 5') soils in the former
drum storage area as a potential hazard that would require
remediation. These soils, particularly the area around soil
boring TB-10, displayed high concentrations of TICs. The
risk to site workers and others from these TICs is un-
known, however, the combined risk of the TICs with the
quantified soils risk identified in the Risk Assessment
necessitates remedial action.
Therefore, the Remedial Action Objectives for soils at the
site are the protection of the sole source aquifer (ground-
water quality, and ultimately human health as well as
limiting exposure to surficial soil contaminants.
Actual or threatened releases of hazardous substances
from this site, if not addressed by the preferred alternative
or one of the other measures considered, may present a
potential threat to the public's health.
SUMMARY 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 and alternative treatment technolo-
-------
gies 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.
The FS report evaluates in detail four groundwater
alternatives, four deep soil alternatives and three shallow
soil remedial alternatives for addressing the contamination
associated with the Hooker Chemical/Ruco Polymer site.
These alternatives are media specific, meaning a set of
alternatives to address the groundwater contamination and
a set of alternatives to address the soils contamination has
been developed separately. These alternatives are summa-
rized in this section.
GROUNDWATER
The remedial alternatives to address the groundwater
medium are as follows:
Groundwater Alternative 1: No Action
Capital Cost: $ 0
O & M Cost: $ 0
Present Worth Cost: $ 0
Construction Time: None
(Construction time refers to the time required to physically
construct the remedial alternative. This does not include
the time required to negotiate with the responsible parties
for the remedial design and remedial action, or design the
remedy.)
The Superfund program requires that the "no-action"
alternative be considered as a baseline for comparison of
other alternatives. This alternative has been included in
order to provide a datum from which to evaluate the other
alternatives. The no action alternative assumes no
additional actions will be taken at the Hooker/Ruco site to
address groundwater contamination. Contaminated
groundwater beneath the Ruco property would continue to
move uncontrolled downgradient Contaminated soils at
the site would not be addressed by this alternative either.
This would allow contaminants to contribute to the
degradation of the groundwater quality by leaching from
the soils. No institutional controls would be implemented
which would provide no control of groundwater use in the
area or well restrictions. This alternative would not treat
any quantity of the contaminated groundwater, requires no
engineering components, treatment components, and has
no costs associated with its implementation.
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 imple-
mented to remove or treat the wastes.
Groundwater Alternative 2: Deed Notations with
Monitoring
Capital Cost: $ 39,000
O & M Cost $ 37,000/year
Present Worth Cost
- 10-year •$ 325,000
. 30-year - $ 608,000.
Construction Time: Less than one year.
Alternative 2 invloves the use of institutional controls by
obtaining deed notations to limit the land use activities at
the Ruco property, well permitting to restrict groundwater
use and groundwater monitoring. Deed notations would
be required to limit the development of the property to
industrial uses only. Deed notations would also be focused
on preventing the drilling of wells at the site or requiring
treatment if wells were drilled. This would provide some
degree of control on the groundwater use and well con-
struction activities and control development of the Ruco
property. Annual sampling of the existing monitoring
wells on the Ruco property would provide an assessment
of the groundwater contaminant concentrations and
mobility. Annual status reports would be filed with the
appropriate regulatory agencies. Implementation of these
institutional controls would require the cooperation of
Ruco Polymer Corporation to file the deed restrictions and
the enforcement of these restrictions by the appropriate
regulatory agencies. Controls for water use and well
construction restrictions are currently in place in the form
of a permit and approval process, Article IV of the Nassau
County Public Health Ordinance, at the county level.
Monitoring the status of the impacted groundwater by
collection and analysis of samples is a standard technology
that is easily implementable. This alternative does not
involve the treatment of any portion of the contaminated
groundwater or soils. Therefore, no engineering or treat-
ment components are part of this alternative. Capital costs
consist of legal fees for obtaining the deed notations and
well permitting, while the O&M costs consist of annual
monitoring costs.
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 imple-
mented to remove or treat the wastes.
Groundwater Alternative 3: Groundwater Extrac-
tion and Treatment with Discharge to an On-Site
Recharge Basin
Capital Cost $ 4,748,000
O&M Cost: $ 549,000/year
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Present Worth Cost:
- 10-ytsar - $ 8,986,000
- 30-ytsar - $ 13,185,000.
Construction Time: Less than one year.
Under this alternative, groundwater would be pumped
from extraction (recovery) wells, and piped to a treatment
system utilizing applicable technologies. The exact number
of extraction wells and quantity of water to be pumped
would be determined in the design phase. For the purpos-
es of lie FS, three 8 inch diameter extraction wells, at
depths: of 125 feet below grade (bg), screened from 40 feet
bg to 1iie bottom and were estimated to pump at a com-
bined flow rate of 100 gpm. This conceptual design was
used in the development of the groundwater extraction
alternatives. The optimum technology or technologies to
treat the pumped groundwater would also be determined
during the design phase. However, for the purpose of
evaluating this potential remedy, the FS Report was
required to make some reasonable assumptions. These
assumptions were based on groundwater modeling, current
knowledge of existing waste treatment practices, availabili-
ty, and: standard engineering principles. At 100 gpm, this
alternative would treat approximately 53,000,000 gallons
of groundwater per year. The effluent from the groundwa-
ter treatment process would be discharged to Sump 3 on
the Ruco property. Deed restrictions and monitoring
would be applied as described in Alternative 2 above. The
O&M would include electric power, servicing of pumps and
motors;, periodic well development, treatment system
operation and annual monitoring.
The effectiveness of the proposed extraction wells was
evaluated using the computer model described in Appendix
B of the FS Report. According to the conceptual model,
the recovery wells will prevent the downgradient migration
of impacted groundwater.
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 imple-
mented to remove or treat the wastes.
Groundwater Alternative 4: Groundwater Extrac-
tion eind Treatment with Discharge to Leaching
Galleries
Capital! Cost: $ 4,867,000
O&M: Cost $ 549,000/year
Present Worth Cost:
- 10-year - $ 9,105,000
- 30-year - $ 13,304,000
Construction Time: Less than one year.
The attraction and treatment of groundwater in this
alternative is the same as described in Alternative 3 above.
The only difference between Alternative 3 and this alterna-
tive would be the point of discharge for the treated
groundwater. Under this alternative the treated ground-
water would be discharged to leaching galleries on the
Ruco property. The proposed leaching gallery area would
be approximately 75 by 75 feet, and would be completed to
a depth of 5 feet bg.
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 imple-
mented to remove or treat the wastes.
DEEP SOILS
The FS also examined alternatives to address the deep and
shallow soil contaminants remaining at the site that would
be potentially contributing to the degradation of the
groundwater quality. All of the alternatives to address the
soils in Sump 1, with the exception of the no action
alternative, would require the existing concrete storage
tanks to be removed. Prior to removal, the tanks would be
cleaned and then subjected to Waste Characterization tests
prior to disposal in a RCRA regulated subtitle C landfill if
necessary, or a subtitle D landfill. The alternatives to
address the deeper soils also include two scenarios based
on the results of additional soil sampling to be conducted
in the pre-design phase of OU 1. The alternatives present
the costs for Sump 1 alone and the costs for Sump 1 and
Sump 2 based on the soil sampling results.
The alternatives for the deep soils are as follows:
Deep Soil Alternative 1: No Action
Capital Cost: $ 0
O&M Cost: $ 0/yr
Present Worth Cost $ 0
Construction Time: This
construction.
alternative does not require
The Superfund program requires that the "no-action"
alternative be considered as a baseline for comparison of
other alternatives. The no action alternative requires no
changes to be made to the existing site conditions.
Therefore, there would be no technical, engineering or
treatment components of this alternative. The TBC
criteria (soil cleanup values that would protect groundwa-
ter), would not be achieved by implementing this alterna-
tive. Precipitation would continue to infiltrate the soils
and most likely flush the soluble contaminants into the
groundwater.
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
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10
justified by the review, remedial actions may be imple-
mented to remove or treat the wastes.
Deep Soil Alternative 2: Capping of Sump 1 (and
Possibly Sump 2)
Capital Cost:
Sump 1 alone - $ 213,000,
Sump 1 and Sump 2 - $ 345,000
0 & M Cost-
Sump 1 - $ 5,000/yr,
Sump 1 and Sump 2 - $ 7,000/yr
Present Worth Cost:
Sump 1:10-year - $ 251,000
30-year - $ 289,000
For Sump I and Sump 2: 10-year - $ 396,000
30-year - $ 446,000.
Construction Time: Two to three months.
This alternative involves installing a cap over the potential
soil remediation area, Sump 1, in accordance the RCRA
performance specifications. The proposed cap would
occupy an area of approximately 13,500 square feet
Based on the results of additional post-ROD soil borings in
Sump 2, the area of the proposed cap would be extended.
If contaminants are found to be present in Sump 2 above
the protection of groundwater criteria, Sump 2 would also
require capping. This would require the size of the
proposed cap to be approximately 20,500 square feet The
associated costs of the extended cap would also increase as
have been indicated above. The proposed cap would
consist of the following layers above the existing soil: a
geosynthetic clay liner (comprised of geotextile outer layers
with an inner layer of low permeability sodium bentonite),
a 60-mil high-density polyethylene (HDPE) geomembrane
liner, 6 inches of gravel acting as a drainage layer, a 20-mil
filter fabric, 12 inches of gravel subbase and 6 inches of
asphalt
The cap would provide for the protection of groundwater
quality by removing the exposure of the contaminants in
the soils to the infiltration of precipitation. The downward
movement of water through the soils (percolation) would
not occur with the cap in place. Leaching of contaminants
from the soil into the groundwater would be eliminated.
Capping would not reduce the concentration of the com-
pounds in the soils, but would reduce their mobility. The
TBC criteria for soils would not be met, however, ground-
water quality would be protected by removing the migra-
tion pathway to the groundwater.
The installation of a cap would require a moderate design
effort followed by approximately two to three months of
construction and moderate effort in reporting and docu-
mentation. Periodic inspections to ensure the integrity of
the cap would be required as part of the O&M.
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 imple-
mented to remove or treat the wastes.
Deep Soil Alternative 3: Soil Vapor Extraction and
Capping
Capital Cost:
Sump 1 - $ 332,000,
Sump 1 and Sump 2 - $ 515,000
O&M Cost
Sump 1 - $ 48,000/yr,
Sump 1 and Sump 2 - $ 56,000
Present Worth Cost-
Sum? 1:10-year - $ 703,000
30-year - $ 1,070,000
Sump 1 and Sump 2:10-year - $ 948,000
30-year - $ 1,378,000
Construction Time: Less than one year.
Alternative 3 for the deep soils is the same as Alternative
2 above, with the addition of the soil vapor extraction
(SVE) system. This alternative involves the installation of
soil vapor extraction wells in Sump 1 (and possibly Sump
2, based on subsequent soil sampling) and treating the
collected vapor prior to discharge to the atmosphere. Air
inlet wells would be installed at the .cap perimeter to
enhance the availability of air to the soils and the vapor
removal. The SVE and air inlet wells would be drilled to
an approximate depth of 50 feet bg, be approximately 4
inches in diameter, and be screened from 20 feet below
ground (bg) to the bottom. The SVE piping would be
installed beneath the cap (described in Alternative 2). The
SVE wells would be joined by a common header pipe
located in the treatment shed. This pipe would be con-
nected to a vapor phase separator (demister) where
moisture would be removed from the air stream. The
demister would be connected to a positive displacement
blower, which provides a negative vapor pressure gradient
to the subsurface soil. For the purposes of the FS, it was
conservatively assumed that the discharge from the blower
would undergo treatment using vapor-phase carbon prior
to being vented to the atmosphere. The cap would act as
a seal to prevent air from entering near the extraction
wells (where the pressure gradient is greatest) and would
promote a radial horizontal subsurface air flow. A radial
flow forces air to be drawn over a greater distance, thereby
contacting a greater volume of soil. The actual system
parameters would be determined in the remedial design
phase.
SVE has been a proven technology for soils impacted by
volatile organic carbon (VOC) contaminants. This process
has been employed at many sites at both small and large-
scale field applications. The effectiveness of SVE is highly
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11
dependent upon the volatility of a particular contaminant
SVE would be effective for treating PCE, TCE and 1,2-
DCE but not for phenol, di-n-bu1yl phthalate and TICs. It
is expected then, that the TBC criteria (protection of
groundwater) would be achieved for some of the con-
taminants, but not for others as indicated above. The SVE
system would be required to meet the substantive require-
ments for air emission discharge criteria which are con-
sidered an ARAR. Because the soil in the potential
remediation area consists of medium to coarse sand and
fine to coarse gravel, SVE is well suited for the geologic
conditions at the site. The necessary equipment is readily
available and the process is easily implemented.
Because this alternative may result in contaminants
remaining on-site above health-based, 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.
Deep Soil Alternative 4: Soil Flushing
Capitd Cost:
Sump 1 - $ 16,000,
Sump 1 and Sump 2 - $ 25,000
O & M Cost:
Sump 1 - $ 1,000/yr,
Sump 1 and Sump 2 - $ 3,000
Present Worth Cost:
Sump 1: 10-year - $ 26,000
30-year - $ 37,000
Sump 1 and Sump 2: 10-year - $ 45,000
30-year - $ 65,000.
Construction Time: Less than one year.
This alternative would consist of flushing the contaminants
from the soils in Sump 1, and possibly Sump 2, by the
deliberate discharge of water to the sumps. The dis-
charged water would then percolate down through the
contaminated soil and flush the soluble contaminants. The
contaminant compounds, now dissolved in the water, could
be recovered through the use of extraction wells.
This alternative requires the use of a groundwater or
vadose zone recovery system which could be either a
separate extraction system design for the soils only, or, in
this case, as part of the extraction and treatment system
described in the alternatives to treat the groundwater.
This type of system would essentially be an injection and
recirculation process. In this case, treated groundwater
from the groundwater extraction and treatment system
would 'be discharged primarily to a sump to be constructed
in the northwest portion of the site, with a portion of the
discharge to be diverted to Sump 1. Sump 2 would also be
included if the results of subsequent soil borings indicate
the presence of soils contamination in excess of the soil
cleanup criteria that is considered protective of groundwa-
ter. The conceptual model developed in the FS, for the
purposes of evaluating this alternative, estimated that a
total of approximately 10 gpm could be discharged to
Sump 1 and Sump 2 without overloading the groundwater
recovery system. In comparison with the estimated rate of
extraction (100 gpm), the rate of recharge to Sumps 1 and
2 is 10 gpm or about 10 % of the extraction rate. Dis-
charge to the sump(s) would be distributed over the
sump(s) areas through piping networks. The discharged
water, after percolation through the sump soils, would be
recovered by the groundwater extraction wells. The exact
type of discharge system, placement of the extraction wells
and rates of discharge and extraction would be determined
during the design process.
This alternative would be effective for those contaminants
that are relatively soluble, or likely to dissolve in water.
The contaminants that are most soluble, such as the VOCs
(e.g., TCE, PCE, VCM, phenol, 1,2-DCE and, based on
preliminary information, the TICs) would be readily
dissolved and flushed from the soil. These compounds
have all been observed in the groundwater beneath the
site. The more insoluble compounds, such as the phthal-
ates, would not dissolve as easily, or in some cases, not at.
all. These insoluble compounds tend to adsorb onto small
soil particles and be persistent in the soil. The soil
flushing alternative for these compounds would be less
effective. However, the flushing of the soil would recover
some of these adsorbed contaminants through the move-
ment and capture of these small soil particles. Any
contaminants that could not be dissolved, or particles that
could not be mobilized through the soil flushing would not
be expected to enter the groundwater system in sufficient
quantity to degrade the future groundwater quality.
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 imple-
mented to remove or treat the wastes.
SHALLOW SOILS
The alternatives identified in the FS to address the shallow
soils also examined two potential scenarios. The first
scenario would involve addressing the soils in the former
drum storage area only; The second scenario would
include the soils around monitoring well E as well as the
former drum storage area based on the results of pre-
design soil sampling.
The alternatives to address the shallow soils are:
Shallow Soil Alternative 1: No Action
Capita] Cost $ 0
0 & M Cost $ 0/yr
Present Worth Cost:
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12
• 10-year - $ 0
. 30-year - $ 0
Construction Time: None
The Superfund program requires that the "no-action"
alternative be considered as a baseline for comparison of
other alternatives. The no action alternative requires no
changes to be made to the existing site conditions.
Therefore, there would be no technical, engineering or
treatment components of this alternative. The TBC
criteria (soil cleanup values that would protect groundwa-
ter), would not be achieved by implementing this alterna-
tive. Precipitation would continue to infiltrate the soils
and most likely flush the soluble contaminants into the
deeper soils and eventually into the groundwater. Workers
at the Ruco Polymer site would potentially be exposed to
contaminants in the surficial soils.
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 imple-
mented to remove or treat the wastes.
Shallow Soil Alternative 2: Capping
Capital Cost-
Former Drum Storage Area Only - $ 86,000,
Drum Storage Area plus Well E Area - $ 95,000
0 & M Cost
Drum Storage Area - $ 3,000/yr,
Drum Storage Area plus Well E Area - $ 3,000/yr
Present Worth Cost:
Former Drum Storage Area: 10-year - $ 107,000
30-year - $ 128,000
Former Drum Storage Area plus the Well E Area:
10-year - $ 121,000
30-year - $ 146,000
Construction Time: Two to three months.
This alternative involves installing a cap over the potential
soil remediation area, the former drum storage area, in
accordance with RCRA performance specifications. The
proposed cap would occupy an area of approximately 3,850
square feet Based on the results of additional post-ROD
soil borings to be performed in the area near monitoring
well E, a cap may be required. If contaminants are found
to be present in the surficial soils around monitoring well
E above the protection of groundwater criteria, this area
would also require capping. Additional soil sampling may
be required to delineate the extent of the cap. This would
require an additional area to be capped of approximately
1,160 square feet The proposed cap would consist of the
following layers above the existing soil: a geosynthetic clay
liner (comprised of geotextile outer layers with an inner
layer of low permeability sodium bentonite), a 60-mil high-
density polyethylene (HOPE) geomembrane liner, 6 inches
of gravel acting as a drainage layer, a 20-mil filter fabric,
12 inches of gravel subbase and 6 inches of asphalt.
The cap would provide for the protection of groundwater
quality by removing the exposure of the contaminants in
the soils to precipitation. The downward movement of
water through the soils (percolation) would not occur with
the cap in place. Leaching of contaminants from the soil
into the groundwater would be eliminated. The cap would
also eliminate any potential exposure of site workers to
surficial soil contaminants. Capping would not reduce the
concentration of the compounds in the soils, but would
reduce their mobility. The TBC criteria for soils would not
be met, however, groundwater quality would be protected
by removing the migration pathway to the groundwater.
The installation of a cap would require a moderate design
effort followed by approximately two to three months of
construction and moderate effort in reporting and docu-
mentation. Periodic inspections to ensure the integrity of
the cap would be required as part of the O&M.
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 imple-
mented to remove or treat the wastes.
Shallow Soil Alternative 3: Excavation and Off-Site
Disposal in a Chemical Waste Landfill
Capital Cost:
Former Drum Storage Area only - $ 482,000,
Former Drum Storage Area plus Monitoring Well E Area -
$ 758,000
O&M Cost: There are no O&M costs associated with
excavation and off-site disposal
Present Worth Cost:
Former Drum Storage Area: 10-year and 30-year present
worth costs are $482,000. This represents the one-time
investment of the capital costs.
Former Drum Storage Area plus Monitoring Well E Area:
10-year and 30-year - $ 758,000
Construction Time: Less than one year.
This alternative would require the excavation of the
surficial soils in the former drum storage area, specifically
the area around TB-10. The proposed excavation would
remove an estimated total soil volume of 445 cubic yards
from the former drum storage area. Based on the results
of additional post-ROD soil borings in the area near
monitoring well E, an additional area of excavation would
be required. If contaminants are found to be present in
the area around monitoring well E above the protection of
groundwater criteria, this area would also require excava-
tion. This would increase in the total volume of the soil to
be excavated by approximately 265 cubic yards. Additional
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soQ sampling may be required to delineate the extent of
the soils to be removed.
The excavated soil would then be tested to determine if it
could be classified as a characteristic hazardous waste. If
the soils were determined to be a characteristic hazardous
waste, the RCRA Land Ban restrictions would be an
ARAR. This would mean the soils would require treat-
ment before disposal.
This alternative would be effective in permanently remov-
ing the contaminants from the site, thereby eliminating
the potential for the contaminants to migrate to the
groundwater and removing any risks associated with direct
contact with the soils. Excavation is easily implemented
through the use of standard construction equipment and
would require one or two months of field work to com-
plete. No O&M requirements are involved with the
excavation of the shallow soil alternative.
This alternative would result in the complete removal of
contaminants in the shallow soils identified as the former
drum storage area and the area around monitoring well E,
therefore, the site would not require a five year review.
EVALUATION OF ALTERNATIVES
During the detailed evaluation of remedial alternatives,
each alternative is assessed against nine evaluation criteria,
namely, overall protection of human health and the envi-
ronment, compliance with applicable or relevant and
appropriate requirements, long-term effectiveness and
permanence, reduction of toxicity, mobility, or volume,
short-term effectiveness, implementability, cost, and state
and community acceptance.
The evaluation criteria are described below.
0 Overall protection of human health and the envi-
ronment addresses whether or not a remedy
provides adequate protection and describes how
risks posed through each pathway are eliminated,
reduced, or controlled through treatment, engi-
neering controls, or institutional controls.
o Compliance with applicable or relevant and appro-
priate requirements (ARARs) addresses whether
or not a remedy will meet all of the applicable or
relevant and appropriate requirements of other
federal and state environmental statutes and
requirements or provide grounds for invoking a
waiver.
o Long-term effectiveness and permanence refers to
the ability of a remedy to maintain reliable protec-
tion of human health and the environment over
time, once cleanup goals have been met.
o Reduction of toxicitv. mobility, or volume through
treatment is the anticipated performance of the
treatment technologies a remedy may employ.
o 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 im-
plementation period until cleanup goals are
achieved.
o Implementabilitv is the technical and administra-
tive feasibility of a remedy, including the avail-
ability of materials and services needed to imple-
ment a particular option.
o Cost includes estimated capital and operation and
maintenance costs, and net present worth costs.
o State acceptance indicates whether, based on its
review of the RI/FS reports and Proposed Plan,
the state concurs, opposes, or has no comment on
the preferred alternative at the present time.
o Community acceptance will be assessed in the
Record of Decision (ROD) following a review of the
public comments received on the RI/FS reports
and the Proposed Plan.
A comparative analysis of these alternatives based upon
the evaluation criteria noted above.
o Overall Protection of Human Health and the
Environment
Groundwater Alternatives
Alternative 1, no action, would not provide for the
protection of human health for the future potential
residential use of the area at the Ruco Polymer down-
gradient fenceline. Contaminated groundwater would
continue to migrate downgradient degrading the aquifer.
Exposure to the contaminants in the groundwater would
present an unacceptable health risk to the users. Alterna-
tive 2, Deed Notations with Monitoring, would provide
some level of protection to the Ruco property owners by
restricting groundwater uses at the site. However, future
risks to the public would still remain as described in
Alternative 1, above. Alternatives 3 and 4 would provide
adequate protection to potential downgradient residents by
controlling the migration of groundwater contaminants.
Groundwater beneath the Ruco property would be cap-
tured and treated before downgradient receptors could be
exposed. Groundwater pump and treat also has the
potential to prevent further degradation to a sole source
aquifer and restore the aquifer to its beneficial use.
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Deep Soils
The no action alternative (Alternative 1) would not provide
protection of human health because the contaminants in
the soil would continue to leach into the groundwater and
therefore degrade the groundwater quality. The potential
for exposure through the groundwater migration pathway
would then present a human health risk. Alternatives 2,
3 and 4 all offer protection by either limiting the mobility
of the contaminants, as is the case with capping, or by
removing and capturing the contaminants through SVE or
soil flushing. This would eliminate the potential contribu-
tion of the contaminants in these areas to the degradation
of the groundwater (sole source aquifer) quality.
Shallow Soils
The no action alternative for the shallow soils would most
likely not be protective of human health due to the
existence of a potential exposure pathway. While this
exposure pathway is somewhat limited (to workers at the
Ruco plant) and unquantifiable (risk information for the
TICs does not exist), the potential for exposure still exists.
More importantly, the contaminants in these areas present
a potential source of future groundwater contamination.
The resultant groundwater contamination would then
present potential human health risks. Alternative 2,
capping, would provide the necessary level of protection to
the groundwater and human health by eliminating the
potential migration and exposure pathways. Alternative 3,
excavation would also provide protection by removing the
contaminants from the site.
o Compliance with ARARs
Groundwater
Alternatives 1 and 2 would not meet the chemical-specific
ARARs that have been identified for this site, namely the
NYS Groundwater Quality Criteria and Federal MCLs.
Contaminants in the groundwater would remain in the
aquifer at levels above established ARARs. Alternatives 3
and 4 would be expected to achieve the groundwater
chemical-specific ARARs through the application of
extraction and treatment The extraction and treatment
of the groundwater would, of course, require the discharge
of the treated water on the Ruco property. The appropri-
ate discharge standards, identified in Table 3.2 of the FS
Report, would be expected to be achieved through the
treatment process. The substantive requirements of any
State Pollutant Discharge Elimination System (SPDES)
permit, which are chemical-specific ARARs, would be met
for these alternatives. If the treatment of groundwater
should require the application of air stripping technology,
the appropriate air emissions ARARs, National Ambient
Air Quality Standards (NAAQS) and New Yorks State
regulations 6NYCRR would be met TBC criteria for air
emissions, NYS Draft Guidelines for Air Emissions and
EPAs Air Stripper Directive, would also be used to regu-
late the air emissions at the site.
There are no action-specific or location-specific ARARs
identified for the groundwater alternatives.
Deep Soils
There are currently no promulgated standards for con-
taminant levels in soils. For this site, EPA is instead using
the soil cleanup values developed by NYSDEC that are
considered protective of groundwater quality as a TBC
criteria for organic chemicals in soil. The TBC values, as
discussed above, are taken from NYSDEC's TAGM.
Alternative 1, no action, would not meet the TBC soil
criteria. Contaminants in the soil would not be treated or
contained in any manner, resulting in continued leaching
into the groundwater system. Alternative 2, capping,
would not meet the TBC criteria either. However, the
mobility of the contaminants would be reduced by elimi-
nating the exposure to infiltrating precipitation. Alterna-
tives 3 and 4 would not be expected to achieve the TBC
criteria for all the contaminants in the soil. Some of the
compounds would be remediated to the TBC levels.
Contaminants with low solubility would not be removed by
flushing while contaminants with low volatility would not
be removed by SVE. Based on the chemical characteristics
of the compounds at the site (more soluble compounds
than volatile compounds), the soil flushing alternative
would have more potential to achieve the TBC criteria
than SVE.
Shallow Soils
Alternatives 1 and 2 would not meet the TBC soil criteria
as the contaminants would remain in the soil. Alternative
2, however, would reduce the mobility of the contaminants
by eliminating the exposure to precipitation. Alternative
3, excavation, would meet the TBC criteria by removing
the contaminated soil from the site.
o Long-Term Effectiveness and Permanence
Groundwater
Alternative 1 would not be effective or permanent in
providing protection to public health over the long-term.
Contaminated groundwater would continue to migrate
from the site posing a risk to potential receptors. Alterna-
tive 2 would provide some degree of effectiveness by
limiting the potential groundwater exposure pathway
through institutional restrictions. However, the ability to
enforce such restrictions over the long-term is considered
unreliable. Therefore, the permanence of this alternative
is questionable. EPA's policy is not to rely on the use of
institutional controls alone to address contamination at a
site. Monitoring would be required to track the presence
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and 'Concentration of contaminants in groundwater enter-
ing find leaving the Ruco property. Contaminants would
remain in the groundwater posing a potential risk to a
receptor. Alternatives 3 and 4 would be expected to be
effective in providing protection to human health by
controlling the migration of contaminants in the ground-
water. Permanence of protection would be achieved by
removal of the contaminants from the groundwater
through treatment These alternatives have the potential
to restore the groundwater to usable quality or, at a
minimum, clean up the aquifer under the Ruco properly
to upgradient contaminant levels. The ability of the
treatment system to meet the remedial action objectives
has not yet been proven. However, based on current
knowledge of remedial technologies, it is expected that a
treatment system can be designed to achieve the necessary
performance specifications. Operation and maintenance of
the extraction and treatment system would be required
including the servicing of pumps and motors, periodic well
development and treatment operation. The extraction and
treatment system would be monitored to measure its
performance. A five-year review would also be required to
evaluate the effectiveness of these alternatives.
Deep Soils
While: the deep soils at the site have not been identified as
a direct risk to human health or the environment, they are
evaluated here for their potential to be a continuing source
-of contamination to the groundwater.
Alternative 1 would not provide any long-term effective-
ness or permanence. Contaminants in the soil would
continue to enter the groundwater system and pose a risk
to potential receptors. Alternative 2 would reduce con-
taminant mobility and, therefore, be effective in preventing
the migration of contaminants into the groundwater. The
effectiveness of capping for contaminants in the deeper
soils near the groundwater table and capillary fringe
contains a degree of uncertainty. It is possible that the
seasonal fluctuations (rise and fall) in the groundwater
table, or the lateral migration of infiltrating precipitation,
could potentially flush contaminants from the soil and into
the groundwater system. The installation of a cap would
require operation and maintenance to insure the integrity
of the cap. A five-year review would also be required since
contaminants would remain on the Ruco property.
Alternative 3, SVE, would provide long-term effectiveness
for some of the compounds by permanently removing them
from the soil. However, other contaminants at the site are
not effectively removed by SVE due to their low volatility.
These remaining contaminants may possess solubilities
that would allow them to be transported into the ground-
water. Following the application of the SVE, capping of
the sumps would be expected to reduce or eliminate the
mobility of the remaining contaminants. A degree of
uncertainty exists for the effectiveness of capping as
discussed for Alternative 2, above. O&M would be re-
quired to operate the SVE system and maintain the cap.
Periodic monitoring would be required to evaluate the
performance of the SVE. A five-year review would be
required to determine the alternative's effectiveness in
protecting the groundwater quality. Alternative 4 would
be expected to be effective in the long-term by removing
the contaminant compounds that are most soluble and
therefore, most likely be transported into the groundwater.
By capturing the contaminants once they have been
flushed out of the soil, they are permanently removed from
the site through treatment. Any remaining contaminants
would not be expected to leach from the soils due to their
low solubility. This alternative would require the O&M of
the recharge system extraction systems. Periodic monitor-
ing would be involved to check the functioning of the
systems. A five-year review would be required to evaluate
the effectiveness of the soil flushing and determine if
further steps would be required to protect the groundwater
quality.
Shallow Soils
No action, Alternative 1, would not provide long-term
effectiveness or permanent protection of the groundwater
quality. Soluble contaminants would be able to be leached
into the groundwater system by exposure to precipitation.
Alternative 2 would be effective in addressing the surficial
soils by eliminating the mobility of the contaminants and
thus, their ability to enter the groundwater system. This
is expected to be effective in the long-term provided the
cap is maintained permanently. The maintenance of any
structure permanently has inherent uncertainties such as
the ability to enforce and regulate. O&M would require
the maintenance of the cap's structural integrity. Alterna-
tive 3 would yield long-term effectiveness and permanence
through the removal of the contaminants from the site.
Disposal of the soil in an off-site landfill would be required.
No O&M or five-year review would be involved with the
excavation alternative.
o Reduction in Toxicity, Mobility, or Volume
Groundwater
Alternatives 1 and 2 do not reduce the toxicity, mobility or
volume of contaminants present in the groundwater. The
movement of contaminated groundwater would be unre-
stricted allowing downgradient migration and the existence
of a potential exposure pathway. Such an exposure
pathway would create an unacceptable risk to human
health. Also, these alternatives do not satisfy the statutory
preference for treatment that reduces toxicity, mobility or
volume as a principal element Alternatives 3 and 4 would
both reduce the mobility of the contaminants by control-
ling the movement of the groundwater beneath the Ruco
property through a pumping system. (The conceptual
design developed in the FS estimated that a minimum of
100 gal/min would be required to prevent the migration of
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16
contaminated groundwater beneath the Ruco Property. At
100 gal/min, the pump and treat alternatives would treat
approximately 53,000,000 gal/year) Migration of the
contaminants in the groundwater to downgradient poten-
tial receptors would be eliminated. The extraction and
treatment of the groundwater would also reduce the
volume of the contaminants present in the groundwater
system. The volume and toxicity of the actual contaminant
compounds may or may not be reduced depending of the
type of technology employed by the treatment system. A
technology such as UV oxidation would physically destroy
some of the contaminant compounds resulting in a reduc-
tion of volume and toxicity, while a technology such as
GAC would merely filter and collect the contaminants.
The exact type of technology to be used in the treatment
system would be determined in the design phase through
the use of treatability studies. The primary objective of
Alternatives 3 and 4 would be to reduce the mobility of the
contaminants. This would address the primary objective
of preventing further contribution to downgradient
groundwater contamination and eliminate the exposure
pathway to potential receptors. These alternatives also
have the potential to restore the groundwater (a sole
source aquifer) to a usable quality through extraction and
treatment
Deep Soils
Alternative 1 would not result in the reduction of the
toxicity, mobility or volume of the contaminants present at
the site. If no action were taken at the site, contaminants
in the sump(s) would continue to leach into the ground-
water resulting in greater mobility. While the contami-
nant concentrations would decrease in the soil the resul-
tant volume of contaminated material would also increase
as contaminants spread through the groundwater. Alter-
native 2 would not decrease the toxicity or volume of the
contaminant compounds in the soil because treatment
would not be employed, but would reduce the mobility of
most contaminants in the soil. Capping would prevent the
infiltration of precipitation and the resultant leaching of
compounds into the groundwater. This would meet the
primary objective of protecting groundwater quality.
Alternatives 3 and 4 would initially increase the mobility
of some of the contaminant compounds in the process of
extracting them. In the process of recovering and treating
the contaminant?, these alternatives would reduce contam-
inant mobility and volume of the contaminated media.
Alternative 3 would increase the mobility of compounds
with a higher volatility through vaporization, then capture
the contaminants through vacuum extraction. If neces-
sary, the vapor would be treated through GAC which
would not reduce the actual contaminant compound
volume. As part of Alternative 3, a cap would be installed
to enhance the operation of the SVE system. This would
also reduce the mobility of any contaminants remaining in
the soil after completion of the SVE operation. Alternative
4 would also increase the mobility of the more soluble
compounds initially so that they may be recovered through
extraction of groundwater. The extraction and treatment
of the water flushed through the soil would reduce the
volume of contaminated soil. The volume and toxicity of
contaminant compounds may also be reduced depending
on the type of treatment technologies selected in the
remedial design (see Groundwater Alternatives above).
Alternatives involving the generation of treatment residu-
als would require that the generated material be disposed
of in an appropriate off-site disposal facility. This would be
determined by conducting a Toxicity Characteristic
Leaching Procedure (TCLP) test on the residuals. Both
Alternatives 3 and 4 would meet the primary criteria of
protecting groundwater quality.
Shallow Soils
Alternative 1 would not reduce contaminant toxicity,
mobility or volume. Contaminant compounds would
remain in the soils and act as potential sources to ground-
water contamination and contribute an unknown, un-
quantifiable risk to site workers. Alternative 2, without
treatment, would reduce only the mobility of the contami-
nants by eliminating their exposure to the elements. This
would require the construction of a cap to cover an area of
approximately 3,850 square feet for the former drum
storage area and 1,160 square feet for the well E Area.
The volume of contaminated media and volume of the
contaminant compounds would remain the same. The
toxicity of the compounds in the soil would also remain
unchanged. Although Alternative 2 would not reduce the
volume or toxicity of contaminant compounds, the em-
placement of a cap would achieve the primary objective of
protecting groundwater quality and eliminate a potential
exposure pathway as well. Alternative 3 would reduce the
mobility of the contaminant compounds in the shallow
soils at the site by excavating the soils and disposing of
them off-site. The toxicity and volume of the contaminant
compounds at the site would be reduced by off-site
disposal. The relative toxicity and volume of the contami-
nants in the soil to be disposed of would not change.
Excavation would remove the contaminated soil from the
site, but, would not reduce the actual levels of contaminant
compounds in the soil being disposed of. Before disposal
the soil would have to be tested to determine if it qualifies
as a hazardous waste. If it is not a hazardous waste, it
would not be subject to the Land Disposal Restrictions
(LDRs). If it was determined to be a hazardous waste,
treatment would be required pior to off-site disposal.
Alternative 3 would also result in achieving the primary
objective of protecting the groundwater quality.
o Short-Term Effectiveness
Groundwater
No immediate risks to human health have been identified
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17
through exposure of contaminated groundwater beneath
the Huco property because there is currently no use of the
groundwater beneath the Ruco property. Therefore, all of
the groundwater alternatives should be effective in protect-
ing human health and the environment in the short-term
(until construction is complete). For Alternatives 3 and 4,
no short term risks to the public are expected to be created
by constructing the groundwater extraction and treatment
systems. The operation of the extraction and treatment
systems is expected to be a long-term activity which is not
anticipated to present a risk to the public. Depending on
exactly what technologies are selected for the treatment
system, wastes may be generated that have to be treated
(e.g., vapors from air stripping) or disposed or disposed of
off-site (e.g., sludge from filtering processes). The genera-
tion of vapors would be regulated and controlled through
the application of vapor control technology such as a
carbon absorption unit. The off-site disposal of generated
wastes would not create a significant increase in the
vehicular traffic in the area as only small quantities would
be generated. These activities would be conducted in a
manner that would not present a risk to the public.
Deepi Soils
Alternatives 1, no action, would not present any risk due
to the fact that the contaminants are present at depth
which leaves no opportunity for short-term exposure.
Alternatives 2 and 4 are not expected to present any short-
term risks through the construction and implementation
of the remedies. Alternative 2 may involve a slight
incretise in truck traffic in the area to transport in materi-
als to construct the cap. This impact is expected to be
minimal as the area is industrial and truck traffic is a
routine occurrence. Alternative 3 would not present any
risks during construction, however, the operation of the
SVE system would generate volatile organic vapors by
extracting them from the soil. These vapors, depending on
their concentration, may require treatment in the form of
carbon adsorption or a burn unit to destroy the vapors.
The SIVE system is not expected to present a risk when
properly monitored and operated.
Shallow Soils
Alternatives 1 and 2 are not expected to create any short-
term hazards or risks through their implementation. As
discussed above, capping may slightly increase the truck
traffic at the site though this would not be a significant
problem. Alternative 3 may present some low level, short-
term risks through the excavation activities. Excavation
would create the potential for the generation of fugitive
dust emissions. However, such emissions could be con-
trolled through simple dust suppression techniques. Off-
site transport of excavated materials may also present a
potential risk to residents along the transport route,
although such a risk would not be considered large.
o Implementabilitv
Groundwater
The no action alternative, Alternative 1, would not involve
construction or the use of technologies of any kind. No
modifications to the site would be required to be made.
Therefore, this alternative would be easily implemented.
However, the downgradient migration of contaminants in
the groundwater would continue to occur, creating a
potential risk to receptors.
Alternative 2 is similar to Alternative 1 as no construction
would be required. Alternative 2 would require the
development and implementation of deed notations and
well permitting restrictions (i.e., institutional controls), in
conjunction with a groundwater monitoring program.
Monitoring the status of the area! extent of impacted
groundwater by collection and analysis of groundwater
samples is a standard technology that is easily implement-
able. Monitoring could be conducted through a series of
existing wells. The implementation of institutional
controls would not be as easy or reliable as the monitoring
aspect of this alternative. Currently, the use of private
supply wells for the purposes of drinking water supply, is
regulated through Article IV, Nassau County Public Health
Ordinance, Private Drinking Systems. Further institution-
al controls to restrict the construction of water wells on
the Ruco property would be required to assure no expo-
sure to contaminated groundwater would occur. This
would require the development and implementation of
some sort of well permitting and approval process con-
trolled by the NYSDEC or Nassau County. Additional
institutional controls would require obtaining deed nota-
tions to limit the land use activities at the Ruco property.
Obtaining the deed restrictions would require the coopera-
tion and consent of Ruco Polymer Corporation. Historical-
ly, the enforcement of institutional controls is considered
unreliable. While Alternative 2 would be easy to imple-
ment technically, the administrative requirements would
not be as easily achieved.
Alternatives 3 and 4 involve the extraction and treatment
of groundwater. This type of technology has been applied
at a variety of sites with mixed results. From a geologic
and hydrologic viewpoint, the groundwater aquifer under
Long Island would be the optimum type of aquifer in
which to operate a pump and treat system with a high
degree of confidence in success. The aquifer possesses
good characteristics that would allow for a relatively simple
and straight-forward design. Adequate control of ground-
water beneath the Ruco property could be established
through the use of a system of extraction and monitoring
wells. The treatment systems required in these alterna-
tives would all be the same. Many standard water treat-
ment technologies exist that have been employed ar other
sites. It would be expected that these same technologies
would be able to treat the groundwater at this site.
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However, because of the presence of the TICs in the
groundwater, there exists a degree of uncertainty in the
application of standard technologies. Therefore, treatabili-
ty studies would be required to determine the optimum
technology or combination of technologies to treat all the
contaminants in the groundwater. This factor makes the
groundwater pump and treat alternatives slightly more
difficult technically than non-treatment alternatives to
implement
Deep Soils
Alternative 1 has no technical or construction require-
ments making it the easiest alternative to physically imple-
ment Alternative 2, capping, is also a very easy technolo-
gy to implement and has been used at many sites across
the country. The cap would require long term mainte-
nance and periodic inspections by the agencies to ensure
it's integrity. This would certainly restrict any future
potential uses of the property. Alternatives 3 and 4 would
be only slightly more difficult to implement from a techni-
cal stand-point With Alternative 3, the same long-term
requirements for the maintenance of the cap would exist
that have been identified for Alternative 2, above. Alterna-
tive 4 would require some additional testing to ensure
sufficient recapture of the water being flushed through the
sump(s). Alternative 4 would also have to be integrated
with the groundwater extraction and treatment (Alterna-
tive 5 or 6 for groundwater) system, therefore, any difficul-
ties in implementing those alternatives would be applicable
here. These alternatives would require more design and
construction work but both use well established technolo-
gies. Construction of either alternative is not expected to
be a problem.
Shallow Soils
Alternative 1, no action, would be the technically simplest
alternative. No design, construction, or monitoring
requirements are involved. Alternative 2 would be easy to
design and construct however, long-term maintenance,
inspection and therefore agency involvement would be
required. Alternative 3 could be completed using simple,
widely utilized excavation techniques, with some minor
modifications to ensure the proper dust suppression was
executed.
o Cost
The costs for all of the alternatives are presented in the
description of the Summary of Alternatives Section above.
For comparison purposes the costs of the various alterna-
tives are presented as follows:
Groundwater
Looking at the various groundwater alternatives, Alterna-
tive 1, no action, presents the lowest costs at $ 0 for
capital, present-worth and O&M. This alternative provides
a baseline to compare the costs of other alternatives.
Alternative 2 is the next least expensive alternative to
implement with a capital cost of $ 39,000,10-year and 30-
year present worth costs of $ 325,000 and $ 608,000
respectively, and an O&M cost of $37,000 annually. The
costs associated with Alternatives 3 and 4 are very similar.
The capital costs for Alternative 3 are $ 4,748,000 and
$4,867,000 for Alternative 4. The O&M costs are
$ 549,000 for both alternatives. Alternative 4 has slightly
higher costs for the present worth analysis at $ 9,105,000
for the 10-year estimate and $13,304,000 for the 30-year
estimate. Alternative 3 has estimated 10 and 30-year
present worth costs at $ 8,986,000 and $ 13,185,000 respec-
tively. A list of the alternatives assembled in increasing
order of cost indicates that Alternative 1 is the least
expensive, followed by Alternatives 2, 3, and 4.
Deep Soils
Alternative 1 is the least expensive alternative evaluated
with $ 0 capital costs, $ 0 O&M costs and $ 0 present
worth costs. Alternatives 2, 3 and 4 have two sets of costs
associated with each alternative based on the need for
addressing Sump 1 alone, or Sump 1 and Sump 2 together.
Alternative 2, capping, has an associated capital cost of
$ 213,000, an O&M cost of $ 5,000 per year and 10 and 30-
year present worth costs of $ 251,000 and $ 289,000 for
Sump 1. If Sump 2 is added to this alternative, the costs
are: $ 345,000 capital cost, $ 7,000 annual O&M cost and
10-year and 30-year present worth costs of $ 396,000 and
$ 446,000. Alternative 3 would be the highest cost alterna-
tive with a capital cost of $ 332,000, O&M cost of $ 48,000
and 10-year and 30-year present worth costs of $ 703,000
and $ 1,070,000 for Sump 1 alone. For Sump 1 and Sump
2, Alternative 3 would have the following costs: capital
cost of $ 515,000, annual O&M cost of $ 56,000, a 10-year
present worth cost of $ 948,000 and a 30-year present
worth cost of $ 1,378,000. Alternative 4 was the least
expensive alternative that incurred any costs. To address
Sump 1, Alternative 4 was estimated to require a capital
cost investment of $ 16,000 and an annual O&M cost of
$ 1,000, and incur 10 and 30-year present worth costs of
$ 26,000 and $ 37,000. To address Sump 1 and Sump 2
the capital cost of Alternative 4 would be $ 25,000. The
annual O&M cost would be $ 3,000 and the 10-year and
30-year costs would be $ 45,000 and $ 65,000.
Shallow Soils
The costs developed for the shallow soils alternatives show
that the no action alternative, Alternative 1, has $ 0 capital
costs, $ 0 O&M costs, and $ 0 present worth costs.
Alternatives 2 and 3 generated two sets of costs for each
alternative based on addressing the former drum storage
area alone, or the former drum storage area and the area
around monitoring well E together. The costs requ!red for
the construction and operation of Alternative 2 a the
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former drum storage only are $ 86,000 capital costs,
$ 3,000 per year O&M costs, and $ 107,000 and $ 128,000
10 and 30-year present worth costs. If the area around
monitoring well E is also included, Alternative 2 would
then cost $ 95,000 for capital cost, $ 3,000 annual O&M
cost, $ 121,000 10-year present worth cost and $ 146,000
30-year present worth cost. Alternative 3, excavation and
off-site disposal, was the most expensive alternative. To
address the former drum storage area alone, a capital cost
of $ 482,000 would be incurred. This alternative would
not require annual O&M cost, which would therefore be
$ 0. The present 10-year and 30-year present worth costs
would represent a one-time investment cost of $ 482,000.
To include the area around monitoring well £ in the
excavation and disposal, the capital cost would be $
758,000, with annual O&M costs again equalling $ 0. The
10 and 30-year present worth costs would be $ 758,000.
o State Acceptance
After review of all available information the NYSDEC has
indicated that they do support the selection of the pre-
ferred alternative.
o Community Acceptance
Community acceptance of the preferred alternative will be
assessed in the Responsiveness Summary portion of the
ROD following review of the public comments received on
the RI/FS report and the Proposed Plan.
PREFERRED ALTERNATIVE
Based upon an evaluation of the various alternatives, EPA
and the NYSDEC recommend Alternative 3, groundwater
extraction and treatment with discharge to an on-site
sump, for the groundwater; in conjunction with Alternative
4, soil flushing, for the deep soils. Alternative 3, excava-
tion, is the preferred alternative to address the shallow
soils. The key components of the preferred alternative as
the preliminary choice for the Site remedy include the
following:
o Groundwater extraction to control the movement of
contaminated groundwater from migrating downgradient
past the southern Ruco property boundary. The control of
the groundwater would be achieved through the installa-
tion ol: groundwater extraction wells. The exact number,
size, depth and pumping rates of these wells would be
determined in the remedial design of the preferred alterna-
tive. Existing monitoring wells on the Ruco property
would be used to monitor the performance of the ground-
water extraction system and establish that sufficient
control occurs. Additional monitoring wells may be
required. The need for additional monitoring wells would
be determined during the design and implementation of
the groundwater extraction system.
o Treatment of the extracted groundwater with an on-
site treatment system to achieve the appropriate discharge
standards. The exact type of treatment technologies to be
used and their effectiveness on TICs would be determined
in the design phase through treatability studies. If the
results of the treatability studies indicate the discharge
standards can not be achieved, the preferred alternative
will have to be revisited.
o Additional soil testing in the bottom of Sump 2 to
determine if contaminants are present in the soils and to
compare those levels to the soil cleanup criteria that is
considered protective of groundwater quality. If contami-
nants are present at levels above the protection of ground-
water criteria, the soils in Sump 2 will be addressed in the
same manner as the soils in Sump 1.
o Discharge of treated groundwater primarily to a sump
to be constructed in the northwest portion of the site, with
a small portion to be diverted to Sump 1 and possibly
Sump 2 (based on the results of the soil tests). The
majority of the discharge would be required to be diverted
to a sump in the northwest corner of the site to avoid
overloading Sumps 1 and 2 and the groundwater extrac-
tion system. The method of discharging the treated water
would be through a system of piping placed at or just
below the soil surface. The details of the piping layout
would be determined in the design phase. Discharged
groundwater is expected to meet the appropriate discharge
criteria through treatment (see treatment above).
o Soil flushing for the deep soils in Sump 1, and
possibly Sump 2 (based on the results of the soil testing).
The soils will be flushed by the discharge of treated
groundwater. The contaminants flushed out by this
process would be recaptured by groundwater extraction
wells. The exact location, depth, size and pumping rates
of the wells will be determined during the design phase of
the preferred alternative. The contaminant levels in the
sumps will be re-evaluated at the five-year review to
determine the effectiveness of the flushing.
o Additional soil testing in the area around monitoring
well E to determine if contaminants are present. If
contaminants are present, the concentrations will be
compared to the soil TBC cleanup criteria considered to be
protective of groundwater quality to determine whether a
significant potential contaminant source to the ground-
water exists. If the contaminants are present above the
protection of groundwater quality criteria, and exist in the
shallow soils, the area around well E will be addressed in
the same manner as the former drum storage area. If the
contaminants are present in the deeper soils, further
evaluation potential remedial alternatives would occur.
o Excavation of the shallow soils in the former drum
storage area adjacent to plant 2 and possibly the area
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around monitoring well E (depending on the results of the
soil testing). The extent of the excavation in the former
drum storage area would be based on the results of the soil
samples collected during the Remedial Investigation. The
extent of the excavation in the area around monitoring
well E would be based on samples collected during the pre-
design or design phase.
o Periodic monitoring of the groundwater extraction
system, to assure adequate control is maintained; periodic
sampling of the groundwater treatment system discharge,
to assure treatment standards are achieved; and periodic
sampling of the groundwater and soils in Sump 1 and
•possibly Sump 2, to measure the progress of the preferred
alternative in achieving the cleanup standards.
o Institutional controls in the form of deed restrictions
and groundwater use restrictions at the Ruco property.
The deed restrictions would be required to permanently
prevent the Ruco properly from residential development as
long as contaminants remain on the property and the
treatment systems are in place. Groundwater use restric-
tions in addition to the existing Nassau County Ordinance,
would be implemented through deed restrictions as well.
The use of groundwater for human contact would be
restricted until such time as the groundwater beneath the
site has been determined to be fully remediated.
The preferred alternative addresses the principle threats
posed by contaminated groundwater beneath the Ruco
property and at the downgradient property boundary,
which are; the potential human health risk and prevention
of further groundwater (sole source aquifer) contamination
downgradient (source control). The implementation of the
groundwater remedy also has the potential to return the
aquifer to a usable quality. The preferred alternative
combines the groundwater remediation with the soils
remediation to address the principle threat posed by the
soDs, which is the further contribution to groundwater
degradation from contaminants in the soil. This'alterna-
tive also satisfies the statutory preference for treatment as
a principal element to reduce the toxicity, mobility and
volume of contaminants at the site. By addressing the
shallow soils the preferred alternative also provides an
unquantifiable, but added level of protection to site
workers from potential exposure to contaminants and
reduces the potential contribution to groundwater contami-
nation.
The groundwater extraction and treatment portion of the
preferred alternative is expected to meet the discharge to
groundwater ARARs, however, some uncertainty does exist
due to the presence of TICs. The same uncertainty exists
for all extraction and treatment alternatives. The ARARs
for groundwater quality would also be expected to be
achieved with the preferred alternative, although the
presence of groundwater contaminants upgradient of the
site may make this goal impossible to reach.
The flushing of the soils in the sump(s) is also expected to
achieve the TBC criteria for the soluble contaminants in
the soils. The effectiveness of flushing on the more
insoluble contaminants is unknown at this time, however,
a small portion of these insoluble contaminants could be
removed through flushing. Remaining insoluble contami-
nants would not be expected to readily leach from the soils
and mobilize into the groundwater.
Excavation of the shallow soils would achieve the TBC
criteria for protection of groundwater by removing the
contaminants from the site. A reduction in the toxicity,
mobility and volume of the contaminants would be
achieved and the leaching of contaminants into the
groundwater would be prevented.
Groundwater extraction and treatment, soil flushing and
excavation would provide long-term effectiveness in the
protection of human health and the environment The
extraction and treatment of groundwater and the flushing
of the soils in the sump(s) and excavation of shallow soils
would also be permanent solutions through the removal of
contaminants in the affected media. Capping of soils is not
considered permanent because the contaminants are left in
place.
It is anticipated that the groundwater extraction and
treatment portion of the preferred alternative would
effectively reduce the mobility and volume of the contami-
nated groundwater. Uncertainty does exist concerning the
ability of the treatment system to achieve the appropriate
treatment standards. The ability to achieve the standards
through treatment would be determined in the pre-design
phase by treatability tests. Depending on the treatment
technology chosen, the toxicity of the contaminants may
also be reduced through destruction. The contaminants in
the deep soils would initially become more mobile as they
are flushed out of the soils reducing the volume of the
compounds in the soil. The contaminants would then be
recaptured and treated in the groundwater treatment
system, permanently reducing their volume, mobility and
potentially their toxicity.
It is not anticipated that any significant short-term impacts
on human health or the environment would occur during
the construction and implementation of the preferred
alternative. The cleanup goals for the pumped and
discharged groundwater are expected to be met once the
treatment system begins operation. It is uncertain if, or
how long, it would take to restore the aquifer to the
groundwater standards. It is also uncertain if the soil TBC
goals would be achieved for all of the contaminants in the
soils. The shallow soils would achieve the TBC soils
criteria upon completion of the excavation. The preferred
alternative could be constructed and operational in less
than a year.
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The implementation of the preferred alternative is both
technically and administratively feasible. The alternative
relic:; on established technologies that are widely used and
available. The construction of the various components of
the remedy could be accomplished without great difficulty
and relatively quickly once the predesign/design work is
completed.
The costs for the preferred alternative are as follows:
Groundwater extraction and treatment with discharge to
on-site sumps: Capital cost $ 4,748,000, Annual O&M costs
of $ 549,000, with 10-year and 30-year Present Worth costs
of $ »,986,000 and $13,185,000.
Soil flushing of Sump 1 only: Capital cost $ 16,000,
Annual O&M costs of $ 1,000, with 10-year and 30-year
Present Worth costs of $ 26,000 and $ 37,000.
Soil flushing of Sump 1 and Sump 2: Capital cost
$ 25,000, Annual O&M costs of $ 3,000, with 10-year and
30-year Present Worth costs of $ 45,000 and $ 65,000.
Excavation of shallow soils in the former drum storage
area only: Capital costs of $ 482,000. Annual O&M costs
of $ 0, and 10-year, 30-year present worth costs of
$ 482,000 (one-time investment cost.)
.Excavation of shallow soils in the former drum storage
area and the area around monitoring well E: Capital costs
of $ 758,000. Annual O&M costs of $ 0, and 10-year, 30-
year present worth costs of $ 758,000 (one-time investment
cost).
If all of the targeted areas are included (i.e. Sump 2 and
the area around monitoring well E contain contaminants
above the TBC values), the total cost of the remedies for
operable unit one would be:
Capital cost: $ 5,531,000,
Annual O&M cost: $ 552,000,
10-year present worth cost $ 9,031,000,
and 30-year present worth cost: $ 13,250,000.
The preferred alternative achieves the ARARs more
quickly, or as quickly, and at less cost than the other
options except for the shallow soils where excavation
would cost more than the other alternatives. However, the
excavation would be more permanent, require no O&M
and would not require a five-year review. No contami-
nants in the shallow soil areas targeted would be left on-
site. Therefore, the preferred alternative will provide the
best balance of trade-offs among alternatives with respect
to the evaluating criteria. EPA and the NYSDEC believe
that the preferred altern; ive will be protective of human
health and the environment, will comply with ARARs, will
be cost effective, and will utilize permanent solutions and
alternative treatment technologies or resource recovery
technologies to the maximum extent practicable. The
remedy also will meet the statutory preference for the use
of treatment as a principal element.
GLOSSARY
Of Terms and Acronyms Used In the Proposed Plan
This glossary defines the technical terms and acronyms
used in this Proposed Plan. The terms and abbreviations
contained in this glossary are often defined in the context
of hazardous waste management, and apply specifically to
work performed under the Superfund program. Therefore,
these terms may have other meanings when used in a
different context
Acids: Substances, characterized by low pH (less than 7.0)
that are used in chemical manufacturing. Acids in high
concentration can be very corrosive and react with many
inorganic and organic substances. These reactions may
possibly create toxic compounds
or release heavy metal contaminants that remain in the
environment long after the acid is neutralized.
Administrative Order on Consent (AOC): A legal and
enforceable agreement between EPA and the potentially
responsible parties (PRPs). Under the terms of the Order,
the PRPs agree to perform or pay for site studies or
cleanup work. It also describes the oversight rules,
responsibilities and enforcement options that the govern-
ment may exercise in the event of non-compliance by the
PRPs. This Order is signed by the PRPs and the govern-
ment; it does not require approval by a judge.
Administrative Order: A legally binding document
issued by EPA directing the potentially responsible parties
to perform site cleanups or studies.
Administrative Record File: The file containing all Site
findings and reports that were considered in the Agency's
decision regarding the preferred alternative. Typically
these documents are available for public review at a
convenient location within the town or city that a site is
located as well as at EPA Region 2 headquarters.
i1
Adsorption: The adhesion of molecules of a gas, liquid or
dissolved matter to the surfaces of solid bodies or liquids
with which they are in contact.
Air Stripping: A process whereby volatile organic chemi-
cals are removed from contaminated material by forcing a
stream of air through it in a pressurized vessel. The
contaminants are evaporated into the air stream. The air
may be further treated before it is released into the
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atmosphere.
Ambient ain Any unconfined part of the atmosphere.
Refers to the air that may be inhaled by workers or
residents in the vicinity of contaminated air sources.
Aquifer. An underground layer of rock, sand, or gravel
capable of storing water within cracks and pore spaces, or
between grains. When water contained within an aquifer
is of sufficient quantity and quality, it can be tapped and
used for drinking or other purposes. The water contained
in the aquifer is called groundwater.
Backfill: To refill an excavated area with removed earth;
or the material itself that is used to refill an excavated
area.
Bioaccumulate: The process by which some contami-
nants or toxic chemicals gradually collect and increase in
concentration in living tissue, such as in plants, animals,
or humans as they breathe contaminated air, drink
contaminated water, or eat contaminated food.
Bioremediation: A cleanup process using naturally
occurring or specially cultivated microorganisms to digest
fnntatninantg naturally and break them down into nonhaz-
ardous components.
Borehole: A hole drilled into the ground used to sample
soil and groundwater.
Cap: A layer of material, such as clay or a synthetic
material, used to prevent rainwater from penetrating and
spreading contaminated materials. The surface of the cap
is generally mounded or sloped so water will drain off.
Carbon adsorption/carbon treatment: A treatment
system in which contaminants are removed from ground-
water and surface water by forcing water through tanks
containing activated carbon, a specially treated material
that attracts and holds or retains contaminants.
Carbon disulfide: A degreasing agent formerly used
extensively for parts washing. This compound has both
inorganic and organic properties, which increase cleaning
efficiency. However, these properties also cause chemical
reactions that increase its hazard to human health and the
environment.
CERCLA: Comprehensive Environmental Response,
Compensation and Liability Act
Consent decree: A legal document, approved and issued
by a judge, formalizing an agreement between EPA and
the potentially responsible parties (PRPs). The consent
decree describes remedial actions that the PRPs are re-
quired to perform and/or the costs incurred and/or will be
incurred by the government that the PRPs will reimburse,
as well as the roles, responsibilities, and enforcement
options that the government may exercise in the event of
non-compliance by PRPs. If a settlement between EPA
and the PRPs includes remedial actions, it must be in the
form of a consent decree. A consent decree is subject to a
public comment period.
Consent Order: A legal and enforceable agreement
between EPA and the potentially responsible parties
(PRPs). Under the terms of the Order, the PRPs agree to
perform or pay for site studies or remedial work. It also
describes the oversight rules,, responsibilities and enforce-
ment options that the government may exercise in the
event of non-compliance by the PRPs. This Order is
signed by the PRPs and the government; it does not
require approval by a judge.
Containment: The process of enclosing or containing
hazardous substances in a structure, typically in ponds and
lagoons, to prevent the migration of contaminants into the
environment.
Decommission: To revoke a license to operate and take
out of service.
Degrease: To remove grease from wastes, soils, or
chemicals, usually using solvents.
Dewaten To remove water from wastes, soils, or chemi-
cals.
Downgradient/downslope: A downward hydrologic
slope that causes groundwater to move toward lower
elevations. Therefore, wells downgradient of a contaminat-
ed groundwater source are prone to receiving pollutants.
Effluent: Wastewater, treated or untreated, that flows out
of a treatment plant, sewer, or industrial outfall. General-
ly refers to wastes discharged into surface waters.
Feasibility Study (FS): The second part of a two-part
Remedial Investigation/Feasibility Study (RI/FS). The FS
involves identifying and evaluating the most appropriate
technical approaches for addressing contamination prob-
lems at a Superfund site.
Good faith offer: A voluntary offer, generally in response
to a Special Notice letter, made by a potentially responsible
party (PRP) that consists of a written proposal demonstrat-
ing their qualifications and willingness to perform a site
study or cleanup.
Hazard Index: The Hazard Index reflects noncarcinogenic
health effects for an exposed population and is the fraction
of the chronic daily intake of a chemical divided by the
calculated daily dose believed ' be protective of human
-------
23
health including sensitive sub-populations. If the HI
exceeds one (1.0), there is a possibility of adverse health
effect;.
Hot Spot: An area or vicinity of a site containing excep-
tionally high levels of contamination.
Hydrogeology: The geology of groundwater, with particu-
lar emphasis on the chemistry and movement of water.
Influent: Water, wastewater, or other liquid flowing into
a reservoir, basin, or treatment plant.
Landfill: A disposal facility where waste is placed in or on
land.
Leachate: The liquid that trickles through or drains from
waste, carrying soluble components from the waste.
Leach/Leaching: The process by which soluble chemical
components are dissolved and carried through soil by
water or some other percolating liquid.
Migration: The movement of contaminants, water, or
other liquids through porous and permeable rock.
Mitigation: Actions taken to improve site conditions by
limiting, reducing, or controlling toxitity and contamina-
tion sources.
NCP: National Contingency Plan
Neutrals: Organic compounds that have a relatively
neutral pH, complex structure and, due to their organic
bases, are easily absorbed into the environment. Naphtha-
lene, pyrene, and trichlorobenzene are examples of neu-
trals.
Notice Letter A General Notice Letter notifies the
potentially responsible parties (PKPs) of their possible
liability. A Special Notice Letter begins a 60-day formal
period of negotiation during which EPA is not allowed to
start work at a site or initiate enforcement actions against
the PElPs, although EPA may undertake certain investiga-
tory and planning activities. The 60-day period may be
extended if EPA receives a good faith offer (see Good Faith
Offer) within that period.
NPL: :EPA's National Priorities List.
NYSDEC: New York State Department of Environmental
Conseivation.
O&M: Operation and maintenance.
Outfall: The place where wastewater is discharged into
receiving waters.
Percolation: The downward flow or filtering of water or
other liquids through subsurface rock or soil layers,
usually continuing downward to groundwater.
Phenols: Organic compounds that are used in plastics
manufacturing and are by-products of petroleum refining,
tanning, textile, dye, and resin manufacturing. Phenols
are highly poisonous and can make water taste and smell
bad.
Plume: A body of contaminated groundwater flowing from
a specific source. The movement of the groundwater is
influenced by such factors as local groundwater flow
patterns, the character of the aquifer in which groundwa-
ter is contained, and the density of contaminants.
Polycyclic Aromatic Hydrocarbons or Polyaromatic
Hydrocarbons (PAHs): PAHs, such as pyrene, are a
group of highly reactive organic compounds found in motor
oil. They are common component of creosotes and can
cause cancer.
Polychlorinated Biphenyls (PCBs): A group of toxic
chemicals used for a variety of purposes including electrical
applications, carbonless copy paper, adhesives, hydraulic
fluids, microscope emersion oils, and caulking compounds.
PCBs are also produced in certain combustion processes.
PCBs are extremely persistent in the environment because
they are very stable, non-reactive, and highly heat resis-
tent. Burning them produces even more toxins. Chronic
exposure to PCBs is believed to cause liver damage. It is
also known to bioaccumulate in fatty tissues. PCB use and
sale was banned in 1979 with the passage of the Toxic
Substances Control Act
Polyvinyl Chloride (PVC): A plastic made from the
gaseous substance vinyl chloride. PVC is used to make
pipes, records, raincoats, and floor tiles. Health risks from
high concentrations of vinyl chloride include liver cancer
and lung cancer, as well as cancer of the lymphatic and
nervous system.
Potentially Responsible Parties (PRPs): Parties,
including owners, who may have contributed to the
contamination at a Superfund site and may be liable for
costs of response actions. PRPs may sign a Consent
Decree or Administrative Order on Consent (see Consent
Decree and Administrative Order on Consent) to partici-
pate in site remedial activity without admitting liability.
Remedial Action (RA): A series of steps taken to
monitor, control, reduce, or eliminate risks to human
health and the environment These risks were caused by
the release or threatened release of contaminants at a
Superfund site.
RD: Remedial Design
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24
Remedial: A course of study combined with actions to
correct site contamination problems through identifying
the nature and extent of cleanup strategies under the
Superfund program.
Remedial Investigation (RI): The first part of a two-
part Remedial Investigation/Feasibility Study (RI/FS).
The RI involves collecting and analyzing technical and
background information regarding a Superfund site to
determine the nature and extent of contamination that
may be present The investigation also determines how
conditions at the site may affect human health and the
environment through a risk assessment.
Record of Decision (ROD): The document that present
EPA's final selection of a response action.
Runoff: The discharge of water over land into surface
water. It can carry pollutants from the air and land into
receiving waters.
Sediment: The layer of soil, and minerals at the bottom
of surface waters, such as streams, lakes, and rivers that
absorb contaminants.
Sludges: Semi-solid residues from industrial or water
treatment processes that may be contaminated with
hazardous materials.
SPDES: The New York State Pollution Discharge Elimina-
tion System.
Stripping: A process used to remove volatile contaminants
from a substance (see Air Stripping).
Sumps: A pit or tank that catches liquid runoff for drain-
age or disposal.
Superfund: The common name for the federal program
established by the Comprehensive Environmental Re-
sponse, Compensation and Liability Act (CERCLA) of
1980, as amended in 1986. The Superfund law authorizes
EPA to investigate and remediate the nation's most serious
hazardous waste sites.
Trichloroethylene (TCE): A stable, colorless liquid with
a low boiling point TCE has many industrial applications,
including use as a solvent and as a metal degreasing agent
TCE may be toxic to people when inhaled, ingested, or
through skin contact and can damage vital organs, espe-
cially the liver [see also Volatile Organic Compounds].
Unilateral Order. A legally binding document issued by
EPA directing the potentially responsible parties to
perform site cleanups or studies (generally, EPA does not
issue unilateral orders for site studies).
Upgradient/Upslope: Upstream; an upward slope.
Demarks areas that are higher than contaminated areas
and, therefore, are not prone to contamination by the
movement of polluted groundwater.
UV: ultraviolet
Volatile Organic Compounds (VOCs): VOCs are made
as secondary petrochemicals. They include light alcohols,
acetone, trichloroethylene, perchloroethylene, dichloro-
ethylene, benzene, vinyl chloride, toluene, and methylene
chloride. These potentially toxic chemicals are used as
solvents, degreasers, paints, thinners, and fuels. Because
of their volatile nature, they readily evaporate into the air,
increasing the potential exposure to humans. Due to their
low water solubility, environmental persistence, and wide-
spread industrial use, they are commonly found in soil and
groundwater.
Wetland: An area that is regularly saturated by surface
or groundwater and, under normal circumstances, capable
of supporting vegetation typically adapted for life in
saturated soil conditions. Wetlands are critical to sustain-
ing many species of fish and wildlife. Wetlands generally
include swamps, marshes, and bogs. Wetlands may be
either coastal or inland. Coastal wetlands have salt or
brackish (a mixture of salt and fresh) water, and most
have tides, while inland wetlands are non-tidal and
freshwater. Coastal wetlands are an integral component
of estuaries.
-------
LONG ISLAND RAILROAD
~sgx ^S^ .X
OCCIDENTAL CHEMICAL .CORPORATION
HOOKER /RTTrn -CTTP
AAV/l/
HICKS
BRASBZAXS * GRAEUI JKC
, CT
."~ (203) 762-2207 *
-------
CURRENT DRUM-
STORAGE AREA
ABOVEGROUND TANKS
FORMER DRUM
STORAGE AREA
WATER TANK
SUUP J
SUMP 1
SUMP 2
LEGEND .
TEST BORING LOCATIONS
100
SCALE IN FEET
OCCIDENTAL CHEMICAL CORPORATION
HOOKER/RUCO SITE
.HICKSVILLE. NEW YORK
TEST BORING LOCATIONS SOUTH
D1TP , BFPMCT
FJZER4RED BY:
IEGG1TTZ, URASHEARS Ic GRABAU, INC.
nt-Wtitr dunttut*
72 J>oabtU7 Ro*d
Wilton. CT O6B97
(203) 762-1207
7/29/82 {FIGURE: 3
-------
APPENDIX C - MEETING SIGN-IN SHEET
W1574J.YN
-------
^^ •».
*"* T| UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION it
*>., tc^
0(10 JACOB K. JAVITS FEDERAL BUILDING
NEW YORK. NEW YORK 10278- OO 1 2
HOOKER-RUCO PUBLIC MEETING - 9/8/93
SIGN- IN 8EEET
print your nan* and full address clsarly so that *• can
add you to our Bailing list if you ar« not already on it:
NAME ADDRESS
<-1 i.< i?, fCi'.r -1 JCfr
S
Ccp"-
/O ,W
hLs+L
&
-44
£L
1)
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- - -
MINTED ON MCCYCLCD PAPER
-------
I UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION II
JACOB K. JAVITS FEDERAL BUILDING
. NEW YORK. NEW YORK 10278-0012
HOOXER-RDCO PUBLIC MEETING - 9/8/93
SIGN-IN SHEET
Please print your nan* and full address clearly so that ve can
add you to our nailing list if you are not already on it:
NAME ADDRESS /;
^Jj T
'
///v/L>x
57 t(teiA/fi> PL
PRINTED ON RECYCLED PATCH
-------
I UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
/ REGION II
JACOB K. JAVITS FEDERAL BUILDING
NEW YORK. NEW YORK 1O278-OO12
HOOKER-RUCO PUBLIC MEETING - 9/8/93
SIGN-IN SHEET
Pl«as« print your nan* and full address cl«arly so tnat v« can
add you to our nailing list if you arc not already on it:
NAME
J'" ' tic
f/,.4/>0
PMINTCD ON RECYCLED PAPCK
-------
\ UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION II
*' PR°lt JACOB K. JAVITS FEDERAL BUILDING
NEW YORK. NEW YORK 1O278-O012
HOOKER-RUCO PUBLIC MEETING - 9/8/93
SIGN-IN SHEET
Please print your name and full address clearly so that we can
add you to our nailing list if you are not already on it:
NAME ADDRESS
X ' ' - ' f *— /^/ / , s
'TVc/ljV' //%__
^i frL.VA u JL-V *ir_\<:,t\-~_
HUKTCD ON RECYCLED PAPCM
-------
APPENDIX D - WRITTEN COMMENTS ON PROPOSED PLAN
W1574.LYN
-------
POLYMER
CORPORATION
September 7, 1993
Mr. Dale Carpenter, Project Manager
U.S.E.P.A., Region II
Emergency and Remedial Response Division
26 Federal Plaza, Room 747
New York, N.Y. 10278
RE: COMMENTS ON THE FEASIBILITY STUDY FOR OPERABLE UNIT 1.
Dear Mr. Carpenter:
Ruco Polymer Corporation has reviewed the Final Feasibility Study
(F). We offer the following general comments and suggestions:
GROUNDWATER REMEDIATION
1) Groundwater remediation alternative #3 is preferable
due to the location of the discharge point, sump #3, which
is located in area marked as Tract A in the attached map.
Sumps 3 and 4 are SPDES permitted groundwater discharge
sumps. They are located within Tract A and should not
interfere with our manufacturing operations. Plans for
alternative #3 use an existing drainage basin in Tract A.
The sumps in Tract A are not visible to the public. We
primarily are concerned about maintaining adequate
security. Children in the neighborhood have previously been
observed playing in other sumps near the Long Island
Lighting Co. As per our phone conversation, locating a sump.
near our parking lot would allow easy access from the fence
along the Long Island Rail Road and New South Road. The
proposed sump is in close proximity to adjacent homes.
Accordingly, operation of this sump is likely to give rise
to complaints from Ruco's neighbors as to both security and
potential odor problems.
2) Please recall that prior discussions between Occidental
Chemical Company and the Environmental Protection Agency
concerned discrete remediation areas at this plant site
marked as Tract A and B on the attached map. Based on the
original RIFS prepared by Leggette, Brashears and Graham,
the consultants for Occidental Chemical Co., Ruco Polymer
determined that the area defined as Tract A contained the
majority of the contamination. Tract B was and is
essentially clean and only requires minor remediation.
Accordingly, we believe that remediation activities should,
to the extent possible, be confined to the area of Tract A.
Secondly, since Tract A is the furthest distance from any
residential area, we strongly recommend that all treatment
systems be contained within Tract A.
NEW SOUTH ROAD, HICKSVILLE, NEW YORK 1-1802 • (516)931-8104 • FAX (516) 931-8179
-------
Page 2
Mr. D. Carpenter
9/7/93
Finally, please note that installation of leaching galleries
in Tract B as .proposed by the remediation plan for the
implementation of alternative #4 will interfere with our
current operation and damage plant aesthetics. This is a
high traffic area for our employees, contractors and truck
drivers. In conclusion, any proposed treatment plant should
be located on the north side of the fire extinguisher water
tank in tract A.
i
DEEP SOIL REMEDIATION
Considering the four proposals for cleanup of the soils below
twenty feet in depth, we feel that alternative #4 is the most
suitable.
3) Soil flushing will give results similar to those of
alternative #3, Soil Vapor Extraction, at substantially less
cost.
4) Treated effluent will be discharged to'the already existing
Sump #3.
5) Reduction of contaminants to below safe levels will be
achieved over the long term.
6) Alternative #4 is effective in the removal of contaminants
such as PCE, TCE, and 1,2-DCE.
7) Alternative #4 is effective for the target compounds
whatever the prospective chemicals Henry's Law constant may
be.
SHALLOW SOIL REMEDIATION
8) The only option that is viable for the shallow soil
remediation is Alternative #3, soil removal and disposal at
a hazardous waste site. This will give permanent results..
Alternative #2 will also work, but the cap will require bi-
annual inspections and will not remove contaminants from the
site. This will preclude any potential for future use.
-------
Page 3
Mr. D. Carpenter
9/7/93
If you have any questions, please contact me directly at (516)
931-8104.
Sincerely,
Stephen P. Bates
Manager of Environmental Engineering and Safety
cc: A. Forgione
A. Albanese
A. Weston, Oxy
CERTIFIED MAIL, RECEIPT
REQUESTED P 844 060 949, 50
Attachment
-------
EXSilCIT 1
oir^Tio
Building II
Building 12
Building 13
Adaunlscration Bldg.
Laboratory Arc*
Marks Manager
zsss^
LONG ISLAND RAILROAD
-i ••
-------
OxyChem
September 21, 1993
Mr. Dale J. Carpenter
Project Manager
United States Environmental
Protection Agency, Region n
Emergency Remedial Response Division
26 Federal Plaza, Room 747
New York, NY 10278
RE: Proposed Remedial Action Plan
Hooker/Ruco Site
Hicksville, New York
Dear Mr. Carpenter:
Occidental Chemical Corporation (OCC) has reviewed the referenced document and
has prepared comments on the Proposed Remedial Action Plan (PRAP) which are
attached. These comments cover not only specific issues in the PRAP, but cover
issues raised during the feasibility study process and at the public meeting held on
September 8, 1993 in Hicksville.
General areas of concern are as follows:
• OCC believes that it would be imprudent to discharge treated groundwater in
the northwest portion of the Ruco Polymer facility because 1) this area has not
been affected by past waste storage or handling; 2) this location would disrupt
current plant operations and restrict future land use; and 3) if the treatment
technology does not achieve ambient levels of all plume constituents, site
indicator compounds may be released to the groundwater at levels which may
meet current standards, but which may not meet future requirements.
• OCC was not permitted to extend the feasibility study to include treatability
studies or onsite testing of hydrogeologic parameters. As a result, there is
uncertainty in the ability of available treatment technologies to achieve
discharge to groundwater standards and uncertainty in the degree of capture
Occidental Chemical Corporation
Corporate Environmental Affairs
Occidental Chemical Center
350 Ramoow Boulevard Scutn. PO Sox 723. Niagara rails. NY 1^302-0728
716/286-3000
-------
Mr. Dale J. Carpenter -2- September 21, 1993
that a groundwater extraction and recirculation system may be capable of.
Therefore, the Record of Decision (ROD) should neither specify discharge
standards nor specify a discharge location. These items should be specified
during the remedial design phase.
• OCC believes that shallow soils should not be included in the site remedy. No
risk has been assigned to the soils, and any chemistry which may exceed the
"to-be-considered" protection of groundwater standards would leach to the
groundwater for capture by the groundwater extraction system. This will lead
to attainment of the TBCs under the no action alternative.
• The ROD should state that all of the groundwater which emanates from the
Hooker/Ruco site is, and has been, captured by the Grumman wells. This
concept has been definitively demonstrated by the United States Geological
Survey model as presented in several public forums.
OCC requests that you take into consideration all of our comments in development of
the Record of Decision. If you would like to discuss any of the specific technical
issues raised, please feel free to call me.
Very truly yours,
OCCIDENTAL CHEMICAL CORPORATION
Dr. Alan F. Weston
Manager, Analytical Services
Special Environmental Programs
AFW:lms
Enclosures
cc: D. Drazan
K. Gupta
A. Forgione
prapocc.ltr/93-48
-------
OCCIDENTAL CHEMICAL CORPORATION
HOOKER/RUCO SITE
mcKSvnxE, NEW YORK
Comments on the
Proposed Remedial Action Plan
Site Background
Page 2. Paragraph 7. 1st Sentence
There are currently no data to support the statement that there is
downgradient chemistry. This sentence should instead read: "as a result of these
releases, groundwater beneath the site contains chemistry related to waste disposal
activities. This chemistry has the potential to migrate downgradient of the site."
Page 3. Paragraph 2. 3rd Bulleted Sentence
In stating areas of concern, the third item refers to groundwater
downgradient of the Ruco boundary. This statement should be modified to state
that there are many and substantial contributors to the groundwater chemistry
downgradient from Ruco.
Summary of Site Risk
Human Health Risk Assessment
Page 6. Paraeranh 2
The Proposed Remedial Action Plan (PRAP) states that there is no known
risk associated with the TICs, but unknown risk, combined with acceptable risk
levels due to ingestion of shallow site soils, is a cause for potential concern.
Occidental Chemical Corporation (OCC) does not see the logic in
concluding that there is a cause for concern when no definitive risk has been
assessed, especially when the site is assumed to remain industrial. Every
occurrence of site-related chemistry in the shallow soils cannot be addressed on
an active chemical manufacturing facility, when no specific risks have been
identified.
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-2-
Page 6. Paragraph 5
The final paragraph under Human Health Risk Assessment concludes that
releases of site-related chemistry from this site, if not addressed by the preferred
alternative or one of the other active measures considered, may present a potential
threat to public health. There is no current risk associated with any aspect of this
site, nor is there likely to be. This statement should be expanded to include "...
in the unlikely event that a potable supply well is installed immediately
downgradient of the Ruco property."
Scope and Role of Action
Page 7. Paragraph 1. 2nd Numbered Statement
This section concludes, in pan, that OU-1 will address the surficial soils
in the former drum storage area.
These soils were found not to pose a risk to human health, and were only
considered in the Feasibility Study (FS) because the levels of tentatively identified
compounds (TICs) exceed the "to be considered" protection of groundwater
quality criteria.
Downgradient of these soils will be a groundwater recovery and treatment
system, which will contain any mobilized chemistry from this limited area of
shallow soils. OCC does not believe that these soils should be included in the
PRAP or Record of Decision (ROD) for this site.
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-3-
Remedial Action Objectives
Deep and Shallow Soils
Page 7. Paragraph 1. Sentences 8 through 10
The shallow soils mentioned in the PRAP, in the former drum storage area
and possibly the Well E area, are included because of "unknown" risk levels and
"to-be-considered" protection of groundwater criteria. This is an active chemical
manufacturing facility, not owned or operated by OCC, and there is always a
t
small possibility that there may be isolated occurrences of shallow soil chemistry
which may exceed the TBCs. It is neither practical nor necessary to address
every occurrence of chemistry in shallow soils, especially with the groundwater
controls that will be in place, and continued use of the facility will most likely
negate any short-term benefit from removal of the soils.
Summary of Remedial Alternatives
Groundwater Alternative 1; No Action
Page 8. Paragraph 1. 3rd and 4th Sentences
Under the no action alternative, EPA assumes that no additional actions
will be taken at the Hooker/Ruco site to address groundwater and that
groundwater beneath the Ruco property would continue to move "uncontrolled"
downgradient. .
This assumption is untrue, because even without "additional actions" any
groundwater leaving the Hooker/Ruco site would be captured by the existing
Grumman production wells. This concept has been clearly and definitively
demonstrated by the U.S. Geological Survey groundwater flow and particle
tracking model, as presented in public forums. OCC cannot understand the
United States Environmental Protection Agency's (USEPA) reluctance to embrace
the conclusions of an independent study performed by another Federal agency.
These groundwater controls would also be in place under the Alternative 2
scenario.
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-4-
Groundwater Alternative 3: Groundwater Extraction and Treatment with
Discharge to an Onsite Recharge Basin
Page 9. Paragraph 1. Sth Sentence
Under this alternative the optimum technology to treat the pumped
groundwater would be determined during the design phase. OCC believes that
it was imprudent to complete the FS, and to complete its pending ROD, without
the benefit of groundwater treatability studies. The extracted groundwater will
contain chemistry which is unique to the Hooker/Ruco site, and it is unknown at
this time if commercially available treatment technologies will be effective in
achieving New York State Discharge to Groundwater Standards. Without this
knowledge, the USEPA may be placing an unachievable goal on OCC if the ROD
specifics that certain standards must be achieved, either in onsite groundwater or
in the treated water discharge. OCC suggests that the ROD contain language to
the effect that the groundwater will be treated to the extent possible using
currently commercially available methods.
Furthermore, it is important that the treated water be discharged to
Sump 3 so that it will be recaptured by the groundwater extraction wells. OCC
strenuously objects to the concept of discharging the water to a pan of the plant
that currently shows no impact on soil or groundwater quality from past waste
handling activities. If currently available treatment technologies cannot achieve
ambient water quality (which'contains low levels of volatile organic compounds
(VOCs) but none of the site-indicator tentatively identified compounds (TICs)),
the remedy may cause TIC's to be discharged to the groundwater beyond the
control of the capture zone of the anticipated groundwater extraction system.
Disruption of this pan of the facility would restrict future land use and
limit Ruco's ability to engage in economically-productive activities.
-------
-5-
Deep Soils Alternative 1: No Action
Page 9. Paragraph 1. Sentences 3 and 4
The summary section states that the TBC criteria (soil cleanup values that
would protect groundwater), would not be achieved by implementing the no
action alternative. However, EPA acknowledges that precipitation would continue
to infiltrate the soils and most likely would flush the soluble contaminants into the
groundwater. OCC believes that the TBC criteria would be achieved in the long
term, which is one of the balancing criteria used in evaluating the alternatives.
The fact that soil chemistry may continue to leach out leads to the conclusion that
TBCs would eventually be attained under the No Action scenario. Any leached
constituents would be captured by the groundwater extraction network.
Deep Soil Alternative 4; Soil Flushing
Page 11. Paragraph 1. 6th Sentence
This alternative includes a provision, not in the FS, that treated
groundwater from the groundwater extraction and treatment system would be
discharged primarily to a sump to be constructed in the northwest portion of the
site. There is no support in the FS record to justify such modifications to the
alternative. OCC strongly objects to this concept because it will involve an area
of the facility which has had no impacts from past plant activities. This
alternative could potentially cause discharge to the groundwater of site chemistry
and would disrupt future land use decisions by Ruco Polymer.
Alternative formulation to date has had to rely on computer modeling of
the groundwater system. The scenario of recharging the water in Sump 3 is
presented in the FS report, Appendix B, Page 8. OCC was not permitted to
extend the FS process to perform treatability studies, pumping tests or injection
tests. Therefore, there is enough uncertainty in the evaluation of the site-specific
hydraulic reaction to man-induced stresses that the ROD should not specify a
discharge location. During the design phase it will be necessary to perform onsite
-------
testing to determine the optimum discharge scenario. If it is determined that
discharge of the treated groundwater to Sumps 1, 2 and 3 will possibly result in
incomplete capture of groundwater, design modifications would be considered.
Such modifications, however, would likely be confined to active manufacturing
areas on the eastern portions of the plant.
Shallow Soil Alternative 1: No Action
Page 12. Paragraph 1. Sentences 4 and 5
The summary says that the TBC criteria for protection of groundwater
would not be met with this alternative, but, as with the deep soils, this would be
in the short-term. EPA acknowledges that precipitation would continue to
infiltrate the soils and most likely flush the soluble compounds into the deeper
soils and eventually into the groundwater. There will be groundwater controls
in place onsite and over the long-term the TBC criteria would be met.
Shallow Soil Alternative 2; Capping
Page 12. Paragraph 1. Sentences 3 and 4
This alternative includes reference to the Well E area. OCC believes that
sufficient evidence exists to demonstrate that the MW-E area is an isolated
occurrence and that the soil quality below the surface does not pose a threat to
groundwater at the site for the following reasons:
• The Risk Assessment prepared by the USEPA identified current and future
use of groundwater as the only risk to human health and the environment
at the site. Carcinogenic and noncarcinogenic risks from the site soils,
under all pathways, were within or below levels of concern. The shallow
soils in the vicinity of MW-E do not present an unacceptable risk.
-------
-7-
• Investigative results, based on samples collected during the drilling of
MW-E, contained tetrachloroethene (PCE) at a concentration of
244 mg/kg (milligrams per kilogram) in the sample collected from 0.5 to
2.0 ft bg (feet below grade), 1.07 mg/kg in the sample collected from 5
to 7 ft bg and 0.16 mg/kg in the sample collected from 25 to 27 ft bg.
The TBC criteria for PCE in soil is 1.4 mg/kg.
• PCE is less mobile in a soil matrix than other chloroethene constituents
(Koc for PCE is half of the Koc for TCE). The 1983 soil sampling
results demonstrate that soils below 2.0 ft bg at MW-E do not pose a
threat to groundwater. The results of the 5 ft bg, 25 ft bg and 50 ft bg
sampling completed at MW-E were below the TBC soil cleanup value for
PCE, which is 1.4 mg/kg.
Shallow Soil Alternative 3: Excavation and Offsite Disposal in a Chemical
Waste Landfill
Page 12. Paragraph 1
As with the other alternatives involving shallow soils, OCC does not
believe that any remedial action is warranted because no risk to human health has
been linked to the soils and because groundwater controls will be in place.
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Evaluation of Alternatives
Overall Protection of Human Health and the Environment
Shallow Soils
Page 14. Paragraph 1. Sentence 2
EPA concluded that the exposure pathway is somewhat limited and
unquantifiable. In fact, no risk was assessed to shallow soils. The limited areas
which may exceed the TBCs would contribute only minor chemistry to the
groundwater, which would be captured by the groundwater control system.
Therefore, all of the alternatives for shallow soils are protective of human health
and the environment.
Compliance with ARARs
Groundwater
Page 14. Paragraph 1. Sentences 5 and 6
The PRAP asserts that the discharge standards, as identified in Table 3.2
of the FS Report, would be expected to be achieved through the treatment
process. OCC was not permitted to conduct treatability studies during the FS
process, and it is, therefore, unknown if available technologies will be able to
achieve ARARs in the groundwater or meet SPDES requirements. OCC believes
that the ROD should not be definitive in this regard. Specification of cleanup
goals and discharge criteria should be addressed during the remedial design phase.
Shallow Soils
Page 14. Paragraph 1. Sentence 1
The TBC criteria would eventually be met even under Alternative 1.
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Long-Term Effectiveness and Permanence
Deep Soils
Page 15. Paragraph 2. Sentences 1 and 2
OCC believes that, contrary to the PRAP, that Alternative 1 - No Action,
would eventually lead to the attainment of the TBCs and, therefore, would be
effective in both the long term and as a permanent remedy. Soluble components
would leach from the soils at decreasing concentrations over time, though at a
slower rate than under Alternative 4, soil flushing.
Shallow Soils
Page 15. Paragraph 1. Sentence 1
As with the deep soils, any components in the shallow soils which can
potentially leach and reach the water table 50 feet below would decrease in
concentration over time and eventually attain the TBC levels. Thus, no action
would be effective in the long term as well as permanent.
Reduction in Toxicitv. Mobility or Volume
Shallow Soils
Page 16. Paragraph 1. Sentence 1
OCC believes that the no action alternative for the shallow soils will result
in reductions of:
Toxicitv - by an eventual reduction in concentrations (also, there has been
no toxic effects assessed to the shallow soils at the site).
Mobility - any mobile compounds would eventually be leached leaving
only insoluble components. The leached components would be captured
by the groundwater extraction system at the downgradient property line.
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Volume - soluble components would leach out and if they reached the
groundwater would be extracted and treated at the property line.
Cost
Shallow Soils
Page 18. Paragraph 1
With the exception of the no action alternative, none of the costs of
addressing shallow soils can be justified because no risk has been assessed to the
shallow soils, and protection of groundwater quality criteria would eventually be
achieved through the long-term leaching of precipitation through the soils, with
eventual downgradient extraction and treatment.
Preferred Alternative
Page 19. Paragraph 3
The second bulleted item concludes that if the results of the treatability
studies indicate the discharge standards cannot be achieved, the preferred
alternative will have to be revisited.
Had OCC been allowed the opportunity to extend the FS process to
conduct treatability studies, the USEPA would be in a better position to assess the
effectiveness of available treatment technologies. Because of the uncertainties in
treatment effectiveness, OCC believes that the ROD cannot specify attainment
of ARARs. Specification of discharge criteria and cleanup goals should be
addressed during the remedial design phase.
Page 19. Paragraph 5
The fourth bulleted item discusses construction of a sump in the northwest
portion of the site. OCC understands the USEPA's concerns regarding the
potential overloading of the groundwater extraction system if all of the treated
water is discharged to Sumps 1, 2 and 3. This is another concern which should
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have been addressed during the FS process through the implementation of onsite
hydrogeologic testing of both the extraction and discharge options.
OCC believes that no location for the discharge of treated groundwater
should be included in the preferred remedy or the ROD. Locating the discharge
in the northwest portion of the site should be avoided for the following reasons:
there is uncertainty regarding the ability of currently available
technologies to achieve either the discharge standards or ambient levels.
If ambient levels are not achieved constituents of site-related chemistry
may be discharged to groundwater at concentrations which may meet
current standards, but which may not meet future, more stringent,
standards;
a location in the northwest part of the facility would increase the cost of
the remedy, and would be disruptive of Ruco's ability to use this area of
the plant;
the entire northwest portion of the plant has been demonstrated to be
unaffected by past handling or disposal of wastes. It would be
inconsistent with the intent of the remedial process to extend the CERCLA
remedy into these areas.
Page 19. Paragraph 7
The sixth bulleted item discusses sampling of soils in the Well E area, and
comparison of soil chemistry to the TBC protection of groundwater criteria. As
stated above, this work was completed in 1983. The data revealed an exceedence
of the TBC criteria in only the surficial sample. It is, therefore, unnecessary to
repeat the sampling or to address this area in the ROD.
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Paee 19. Page 8
The seventh bulleted item states that as pan of the preferred alternative,
the shallow soils in the former drum storage area and possibly around Well E
would be excavated and disposed of off site. This action is unnecessary because:
there is no risk to site workers by leaving the soils in place;
any chemistry which exceeds the TBC criteria would leach from the soils
through infiltration of precipitation, thereby attaining the TBC criteria in
the long term; and
any leached chemistry would be captured by the groundwater extraction
system.
prapocc.rpt/93-49
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COMMENTS ON ISSUES RAISED DURING THE
PUBLIC HEARING ON THE PRAP
HELD ON SEPTEMBER 8, 1993
Odors
Most of the local residents are apparently concerned with air emissions from the
operating portion of the manufacturing facility. As USEPA personnel explained at the
public hearing, this issue is unrelated to past activities at the site, is not a subject to be
addressed under CERCLA, and should not be an issue addressed hi the ROD.
Residential Area Soils
A number of people raised the concern about possible chemistry in shallow soils
in residential areas. All waste handling at this site occurred in the eastern areas of the
plant, the most distant area from residential neighborhoods. There have been no risks
associated with exposure to shallow soils onsite, so that there is no reason to suspect any
off site occurrence of site-related chemistry.
The primary means of liquid waste disposal at the Hooker/Ruco site was through
the discharge of liquids into below grade sumps. The liquid wastes migrated vertically
downward 50 feet to the water table. The groundwater then migrated in a southerly and
downward direction in the aquifer to be captured by Grumman's cooling-water supply
wells. Therefore, there was no mechanism for transport of site-related chemistry to
residential neighborhoods.
The components of the waste streams generated at the site were principally
organic compounds which are generally not associated with accumulation in soils or
uptake to vegetative matter. Those types of concerns are generally associated with heavy
metals, which were only detected at trace levels on the Ruco Polymer site.
All residences hi the area are, and have been hi the past, served by public water-
supply systems, which are required to test their water. Therefore, area residents should
not be concerned with the possible ingestion of chemicals from the site.
OCC believes that there is no justification for soil sampling off of the plant
property, testing of residential tap water, or testing for organic vapors in area residences
or commercial establishments.
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Dense. Non-Aqueous Phase Liquids
One person requested that the presence of DNAPLs be investigated and
remediated. None of the manufacturing processes used solvents or other dense chemicals
at concentrations which would result in the accumulation of DNAPLs in the subsurface.
Levels of VOCs and semivolatile organics in the wastestreams were at low dissolved
levels, precluding the formation of DNAPLs.
At sites where DNAPLs are present in the subsurface, water-quality samples
generally contain chemicals in the high parts per million range, formed by gradual
dissolution of the DNAPLs. At the Hooker/Ruco site, all site-related chemistry was
detected in groundwater at levels of less than 6 parts per million, indicating that
DNAPLs are not present.
Public Health Survey
A request was made that the USEPA have a survey conducted of public health
impacts in the area. A Public Health Assessment was prepared by the New York State
Department of Health and the Agency for Toxic Substances and Disease Registry in April
of 1993. Pan of this document consists of a Public Health Action Plan, which describes
various activities which would be conducted in the future. Neither the Public Health
Assessment Report nor the Public Health Action Plan recommended a health effects
survey.
There is currently no documentation to suggest that any adverse health effects
have occured in the area which could be attributable to industrial operations or past waste
disposal. Even if statistically significant increases in health effects were present, it would
be impossible to ascribe public health effects to former waste handling and disposal at
the Hooker/Ruco site. There are numerous industrial facilities in the area as well as
other environmental factors such as past land use for agricultural purposes, air effects
from the transportation corridors, lifestyle factors, etc. which would contribute to health
effects. OCC does not believe health effects studies in the area are necessary or
beneficial.
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Soil Transport
The issue was raised about transporting large quantities of soil through the
residential neighborhoods. OCC does not believe that soil excavation and removal is
necessary at this site, which would negate this issue. However, if any soil removal were
to take place, OCC would adhere to all appropriate DOT regulations pertaining to
transport.
Cleanup Goals
A person from the audience at the public hearing asked about cleanup goals, and
USEPA personnel responded that there are promulgated standards for ground water. The
uncertainties involved in the level of treatment which can be achieved, as well as the
limitations inherent in the ability of the pump-and-treat technology to achieve New York
State ground water standards, may make these standards an unrealistic cleanup goal.
OCC requests that the ROD contain language to the effect that the goals may not be
achievable and that waivers for achieving the goals will be available to OCC. In this
regard, we include suggested language for the ROD which is taken from a Region II
ROD for a CERCLA site and from a New York State Department of Environmental
Conservation (NYSDEC) Fact Sheet on an inactive hazardous waste site, as follows:
EPA Record of Decision:
Groundwater Treatment Alternatives
The ultimate goal of the USEPA Superfund Program's approach to
groundwater remediation as stated in the NCP (40 CFR Part 300) is to return
usable groundwater to its beneficial use within a time frame that is reasonable.
Therefore, for this aquifer, which is classified by New York State as UB
(drinking water aquifer), the final remediation goals will be federal and state
drinking water standards. Recent studies have indicated that pumping and
treatment technologies have inherent uncertainties in achieving the parts per
billion concentrations required under ARARs for groundwater over a reasonable
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period of time. However, these studies also indicate significant decreases in
chemical concentrations early in the system implementation, followed by a
leveling out. For these reasons, the selected groundwater treatment alternative
stipulates contingency measures, whereby the groundwater extraction and
treatment system's -performance will be monitored on a regular basis and adjusted
as warranted by the performance data collected during operation. Modifications
may include any or all of the following:
a) at individual wells where cleanup goals have been attained,
discontinue pumping;
b) alternating pumping at wells to eliminate stagnation points;
c) pulse pumping to allow aquifer equilibration and to allow adsorbed
constituents to partition into groundwater; and
d) installation of additional extraction wells to facilitate or accelerate
cleanup of the plume.
If it is determined, on the basis of the preceding criteria and the system
performance data, that certain portions of the aquifer cannot be restored to their
beneficial use in a reasonable time, all or some of the following measures
involving long-term management may occur, for an indefinite period of time, as
a modification of the existing system:
a) engineering controls such as physical barriers, source control
measures, or long-term gradient control provided by low-level
pumping, as containment measures;
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b) waiving chemical-specific ARARs for the cleanup of those portions
of the aquifer based on the technical impracticability of achieving
further concentration reduction;
c) recommending institutional controls, in the form of local zoning
ordinances, be implemented and maintained to restrict access to
those portions of the aquifer which remain above remediation
goals:
d) continued monitoring of specified wells; and
e) periodic revaluation of remedial technologies for groundwater
restoration.
The decision to invoke any or all of these measures may be made during
a periodic review of the remedial action, which will occur at intervals of no less
often than every five years.
NYSDEC Fact Sheet:
Groundwater
Reduce the concentrations of chemicals in groundwater to below New
York State groundwater standards, to the extent technically feasible.
If long-term monitoring indicates that continued operation of the remedy
is not producing significant reductions in any remaining concentrations of
constituents in soils and groundwater, the NYSDEC will evaluate whether
discontinuance of the remedy is warranted. The criteria for discontinuation will
include an evaluation of the operating conditions and parameters as well as a
statistical determination that the remedy has attained the feasible limit of
constituent reduction and that further reductions would be impracticable.
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Limits of the Plume and Other PRPs
A question was raised regarding definition of the groundwater plume, and if other
facilities may be potential contributors to the groundwater chemistry. OCC believes that
the regional plume has been well defined and that further definition is unnecessary. OCC
also supports the inclusion of any and all potentially responsible parties in the cost
sharing responsibilities of any regional remedies.
Extension of the CERCLA Site
A request was made that the entire area of the regional groundwater plume be
given a CERCLA NPL designation so that all PRPs can be identified. OCC does not
believe that inclusion of the regional plume on the NPL is necessary to determine if other
potential contributors of groundwater chemistry exist. This should be done through the
NYSDEC and USEPA regulatory programs, such as RCRA, underground tank
regulations, etc.
prapcomm. occ/93-49
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POLYMER
CORPORATION
September 14, 1993
Mr. Dale Carpenter, Project Manager
US Environmental Protection Agency
Emergency & Remedial Response Division
26 Federal Plaza, Room 747
New York, NY 10278
RE: FURTHER COMMENTS ON THE FINAL FEASIBILITY STUDY
Dear Mr. Carpenter :
In addition to our written comments dated September 7, 1993,
I respectfully reauest that the comment period be extended
30 additional days so that we can address the issues con-
cerning the area near the alleged buried latex tanks. Ruco
Polymer has made plans for future development of this area.
Sincerely,
Stephen P. Bates
Manager of Environmental Engineering
& Safety
SPB:sg/S4382
CERTIFIED MAIL, RECEIPT
REQUESTED P 844 060 951
NEW SOUTH ROAD, HICKSVILLE, NEW YORK 11802
(516)931-8104
FAX (516) 931-8179
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