PB96-963813
EPA/ROD/R02-96/280
November 1996
EPA Superfund
Record of Decision:
Kentucky Avenue Wellfield,
Operable Unit 3, Horseheads, NY
9/30/1996
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RECORD OF DECISION
KENTUCKY AVENUE WELLFIELD
HORSEHEADS. NEW YORK
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION II
NEW YORK, NEW YORK
SEPTEMBER 1996
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DECLARATION FOR THE RECORD OF DECISION
Site Name and Location
Kentucky Avenue Wellfield
Operable Unit 3
Horseheads, Chemung County, New York
Statement of Basis and Purpose
This decision document presents the selected remedial actions for
the Kentucky Avenue Wellfield Site (the "Site"), Operable Unit No.
3, located in the Town and Village of Horseheads and the Village of
Elmira Heights, New York. The remedial actions were chosen in
accordance with the requirements of the Comprehensive Environmental
Response, Compensation, and Liability Act of 1980 (CERCLA), as
amended by the Superfund Amendments and Reauthorization Act of 1986
(SARA), and the National Oil and Hazardous Substances Pollution
Contingency Plan (NCP). This decision document explains the
factual and legal basis for selecting the remedy for the Site. The
New York State Department of Environmental Conservation (NYSDEC)
concurs with the selected remedy.
The information supporting this remedial action decision is
contained in the administrative record for the Site. A copy of the
administrative record index is attached (see Appendix III).
Assessment of the Site
Actual or threatened releases of hazardous substances from the
Site, if not addressed by implementing the response actions
selected in this Record of Decision (ROD), may present an imminent
and substantial endangerment to the public health or welfare, or to
the environment.
Description of the Selected Remedy
The remedial actions described in this document address the third
of three operable units (OUs) planned for the Site.
The major remedial component of the first operable unit (OU1) ROD,
dated November 30, 1986, called for the connection of residences
using private drinking water wells to the public water supply.
The second operable unit (OU2) ROD, dated September 28, 1990,
called for an interim remedy to restore the Kentucky Avenue Well as
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a public drinking water supply well and contain the contamination
within the aquifer via ground-water extraction and treatment.
The third operable unit (OU3) remedy will address conditions
present at the Westinghouse Facility and a related industrial
drainageway and pond, known locally as Koppers Pond.
The major components of the selected remedy for OU3 include the
following:
Westinghouse Facility - Disposal Area F
Performance of additional sampling and analysis prior to
remedy implementation to better delineate the horizontal and
vertical extent of contaminated soils and waste materials and
to characterize and classify such materials for off-Site
disposal and/or treatment further.
Excavation of all waste materials and soils containing
trichloroethylene (TCE), polycyclic aromatic hydrocarbons
(PAHs) and arsenic above cleanup objectives established for
said contaminants.
Transportation of contaminated soils and waste materials to
permitted waste management facilities (e.g., a RCRA hazardous
waste incinerator, a RCRA hazardous waste landfill or a
industrial landfill).
Performance of confirmatory sampling and subsequent
backfilling of the excavated areas with clean soil.
Westinghouse Facility - Former Runoff Basin Area
Design and testing of an enhanced Soil Vapor Extraction (SVE)
system using either dual-phase SVE or SVE with air sparging,
depending on site-specific characteristics, to extract VOCs
above and below the water table for treatment.
Construction and operation of the enhanced SVE treatment
system for removal and treatment of VOCs from soil to meet the
cleanup levels established in this ROD. The exact location,
depth, and number of SVE wells will be determined during
remedial design and testing.
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Transportation (piping) of recovered ground water to the water
treatment facility constructed as part of the ground-water
remedy for OU2 for treatment.
Implementation of a monitoring program to assess the
effectiveness of SVE treatment in attaining established
cleanup levels in soil and Federal and State drinking water
standards for ground water.
Industrial Drainageway
Excavation of sediments containing Polychlorinated Biphenyls
(PCBs) from the industrial drainageway above the cleanup level
of 1.0 part per million for PCBs.
Placement and operation of diversion pumping and necessary
erosion and sedimentation controls during excavation.
Performance of confirmatory sampling.
Transportation of contaminated sediments to off-Site permitted
waste management facilities for disposal.
Reshaping the flow channel using clean soil, as needed.
Additionally, the EPA believes that further ecological
investigations are warranted at Koppers Pond and will conduct a
supplemental study in that area to assess the need for remedial
action.
Based on the findings of the remedial investigation for OU3, the
EPA has also determined that no further ground-water treatment
beyond that specified for the OU2 interim remedy is necessary as a
response action for OU3. The interim remedy, as set forth in the
1990 ROD and the approved remedial design report for OU2, will
therefore, become the final remedy for restoring the aquifer to its
beneficial use as a drinking water aquifer at the Site.
Declaration of Statutory Determinations
The selected remedies meet the requirements for remedial actions
set forth in CERCLA §121, 42 U.S.C. §9621: (1) they are protective
of human health and the environment; (2) they attain a level or
standard of control of the hazardous substances, pollutants and
contaminants, which at least attain the legally applicable or
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relevant and appropriate requirements (ARARs) under Federal and
State laws, (3) they are cost-effective; (4) they utilize permanent
solutions and alternative treatment (or resource recovery)
technologies to the maximum extent practicable; and (5) they
satisfy the statutory preference for remedies that employ treatment
to reduce the toxicity, mobility, or volume of the hazardous
substances, pollutants or contaminants at a site.
Jeanne M. /ox //f ./ Date
Regional ^Administrator
IV
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RECORD OF DECISION
DECISION SUMMARY
Kentucky Avenue Wellfield Site
Operable Unit 3
Horseheads, Chemung County, New York
September 1996
United States Environmental Protection Agency
Region II
New York, New York
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TABLE OF CONTENTS
Page
DECISION SUMMARY 1
SITE NAME, LOCATION AND DESCRIPTION 1
SITE HISTORY AND ENFORCEMENT ACTIVITIES 2
HIGHLIGHTS OF COMMUNITY PARTICIPATION 6
SCOPE AND ROLE OF RESPONSE ACTIONS 6
SUMMARY OF SITE CHARACTERISTICS 8
REMOVAL ACTION 18
SUMMARY OF SITE RISKS 19
REMEDIAL ACTION OBJECTIVES 25
DESCRIPTION OF REMEDIAL ALTERNATIVES 28
SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES 37
SELECTED REMEDIES 50
STATUTORY DETERMINATIONS 54
DOCUMENTATION OF SIGNIFICANT CHANGES 57
ATTACHMENTS
APPENDIX I. FIGURES
APPENDIX II. TABLES
APPENDIX III. ADMINISTRATIVE RECORD INDEX
APPENDIX IV. STATE LETTER OF CONCURRENCE
APPENDIX V. RESPONSIVENESS SUMMARY
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DECISION SUMMARY
KENTUCKY AVENUE WELLFIELD
OPERABLE UNIT 3
HORSEHEADS, NEW YORK
SITE NAME. LOCATION AND DESCRIPTION
The Kentucky Avenue Wellfield Site (Site) is located within the
Village and Town of Horseheads and the Village of Elmira Heights in
the County of Chemung in the State of New York. As shown in the
attached Figure 1 (Appendix I), the Site includes the Kentucky
Avenue Well (KAW), a public drinking-water supply well located east
of New York Route 14 and approximately one mile south of the
intersection of New York Routes 14 and 17, and the Westinghouse
Electric Corporation's (Westinghouse's) former Industrial and
Governmental Tube Division facility (Facility). The Site also
includes the contaminated portion of the underlying aquifer, known
locally as the Newtown Creek Aquifer.
The Site lies at the confluence of two major river valleys which
are bounded by mountains. In the vicinity of the Site, residential
and commercial areas occupy more than half of the overall valley
floor. The area has extensive industrial developments and is
crossed by major transportation routes, including highways and
freight railroad lines. As of the 1990 census, the population of
the Town of Horseheads was 19,936; the Village of Horseheads was
6,802; and the Village of Elmira Heights was 4,359. Chemung County
reported a population of 95,195. Since 1970, the population of
Chemung County has declined at a rate of 0.2 to 0.3 percent per
year.
The Westinghouse Facility is approximately 59 acres and is bounded
by New York Route 17 to the north, New York Route 14 to the east,
Conrail railroad tracks to the south and property of the New York
State Electric and Gas Company to the west. Immediately north of
Route 17 are commercial properties (hotels and restaurants),
followed by residences. Across the railroad tracks to the south,
along Philo Road, are residences and light industrial facilities.
The Facility is characterized by areas of grass lawn, pavement and
buildings. The ground surface in the vicinity of the Facility has
little relief and slopes very gently to the east and northeast.
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Surface runoff from precipitation is routed by shallow swales and
captured by surface-water runoff drains at various locations around
the main plant building. A large portion of the runoff is routed
through two plant outfall flumes and ultimately flows to the
industrial drainageway. The main plant building covers
approximately 16 acres in the eastern portion of the property and
includes two wastewater treatment plants. Treated wastewater
(process and non-contact cooling water) is discharged to the
industrial drainageway via the two permitted outfalls at the
Facility at an average flow rate of 1 to 2 million gallons per day
(see Figure 2, Appendix I).
The industrial drainageway begins at the outlet of an underground
pipe (located at the Chemung Street outfall) approximately 1,500
feet southeast of the Westinghouse Facility. It is a 7 to 10-foot
wide open ditch which extends approximately 2,200 feet to the
southeast until discharging into Koppers Pond. The industrial
drainageway is bounded to the west by the Conrail tracks and by the
Chemung County highway maintenance department to the east.
Virtually all of its base flow consists of the industrial
wastewater discharges received from the Westinghouse Facility via
its underground piping (see Figure 3, Appendix I).
The area surrounding the industrial drainageway is characterized as
having little relief and 'is poorly drained. Numerous areas
adjacent to the drainageway contain standing water and marsh-
features. Jurisdictional wetlands include the industrial
drainageway, Koppers Pond, and 2.7 acres of emergent wetland
adjacent to the Pond.
Koppers Pond covers approximately seven acres and is bounded by the
old Horseheads Landfill to the north and northeast, the Conrail
tracks to the west and an area of the KAW to the south (see Figure
3). The Pond is approximately 3 to 6 feet deep and discharges into
an outlet stream to the south, which ultimately drains to Newtown
Creek.
SITE HISTORY AND ENFORCEMENT ACTIVITIES
The KAW is part of the Elmira Water Board (EWB) public-water supply
system. It was constructed in 1962 and provided approximately 10
percent of the potable water produced by the EWB until its closure
in 1980, following the discovery of elevated levels of
Trichloroethylene (TCE).
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Contamination of the KAW with TCE was first detected in May 1980
during an inventory of local wells initiated by the New York State
Department of Health (NYSDOH). Further ground-water sampling in
the area by the Chemung County Health Department (CCHD) in July
1980 revealed elevated levels of TCE at the KAW and several private
residences and commercial facilities. This finding led to the
closing of the KAW in September 1980 by the EWB. In July 1982, the
Site was proposed for inclusion on the Superfund National
Priorities List (NPL). The Site was placed on the NPL in September
1983.
The analysis of ground-water samples collected from private
drinking-water wells by the United States Environmental Protection
Agency (EPA), the New York State Department of Environmental
Conservation (NYSDEC), the NYSDOH, and the CCHD through 1985
revealed TCE and other volatile organic compounds (VOCs) throughout
the Newtown Creek Aquifer. The analytical results also revealed
that TCE levels exceeded permissible drinking water standards
established by the NYSDOH. Based on such findings, the EPA
connected 49 residences with contaminated drinking water wells to
the public-water supply in 1985 and 1986.
In 1986, a remedial investigation and feasibility study (RI/FS)
were conducted by the NYSDEC under a cooperative agreement with the
EPA to determine the nature and extent of ground-water
contamination at the Site. The results confirmed the presence of
a contaminant plume in the vicinity of the KAW and extending
approximately one mile beyond the KAW to the southern limit of the
study area. The ground water contained several VOCs, including TCE
at concentrations up to 340 parts per billion (ppb), trans-l,2-d-
ichloroethylene (DCE), a degradation product of TCE, and inorganic
chemicals (i.e., metals) at concentrations exceeding Federal and
New York State (NYS) drinking water standards.
Based on the results of that 1986 RI/FS, the EPA issued the first
Record of Decision (ROD) on November 30, 1986. The 1986 ROD called
for the following: (1) the installation and sampling of ground-
water monitoring wells in the vicinity of the Sullivan Street
Wellfield, a second wellfield owned by the EWB and located south of
the KAW; (2) identification of all residences using private
drinking water wells within the area of ground-water contamination
for connection to the public water supply; and, (3) initiation of
a supplemental RI/FS to determine the nature and extent of
contamination at the Site and to identify the primary sources of
contamination in the Newtown Creek Aquifer. The identification of
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source areas would allow development of an effective program of
source control and contaminated ground-water migration control.
In accordance with the 1986 ROD, the EPA and the NYSDEC conducted
the following actions at the Site:
1. The NYSDEC installed monitoring wells upgradient of the
Sullivan Street Wellfield in July 1989 to monitor ground-water
quality. Analysis of ground-water samples collected from
those wells in January 1990 indicated that TCE was present in
excess of Federal and NYS drinking water standards. The
public water supply at the Sullivan Street Wellfield was also
found to be contaminated by TCE at levels exceeding such
standards. In April 1990, the EPA published an Explanation of
Significant Differences to the 1986 ROD announcing its
intention to design and construct a ground-water treatment
facility at the Sullivan Street Wellfield. This treatment
facility was constructed and operational by mid-1994.
2. The EPA connected an additional 46 residences and three
commercial properties which were using private drinking water
wells in the affected area of ground-water contamination to
the public water supply. Overall, a total of 95 residences
and three commercial properties were connected to public water
supplies between 1985 and 1994.
3. The EPA completed the supplemental RI/FS at the Site in
February 1990. Based on the results, the EPA concluded the
following:
the primary source of TCE contamination at and near the
KAW was the Westinghouse Facility;
the Facet Enterprises, Inc. (Facet) facility and LRC
Electronics, Inc. (LRC) facility were contributory
sources of contamination to the aquifer, but such
contamination had not impacted the KAW; and,
the sediments in the industrial drainageway were
contaminated by inorganic chemicals, possibly as a result
of the permitted industrial discharges originating from
the Westinghouse Facility.
The Facet facility, which is located downgradient of the KAW, is
another NPL Superfund site being remediated under the direct
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oversight of the EPA. The LRC facility is located northeast of the
KAW and is being remediated under the direct oversight of the
NYSDEC.
Based on the results of the 1990 RI/FS, the EPA issued a second ROD
on September 28, 1990 selecting an interim ground-water remedy,
which consisted of the following: (1) restoration of the KAW as a
public drinking water supply; (2) prevention of further spreading
of contaminated ground water within the Newtown Creek Aquifer by
pumping of the KAW and the installation of ground-water recovery
wells between the KAW and the Facility; (3) construction of two
water-treatment facilities, one located near the KAW and the other
located between the KAW and the Facility, to treat recovered ground
water to Federal and NYS drinking water standards; and, (4) a long-
term monitoring program to monitor contaminant migration and
evaluate the effectiveness of the remedy.
The 1990 ROD designated that remedy as an interim remedy because it
did not address the source areas which were contributing to ground-
water contamination. The 1990 ROD also called for an additional
RI/FS to address source control at the Facility, which would result
in a final remedy for restoring the Newtown Creek Aquifer to its
beneficial use as a drinking water aquifer. Additionally, the
study was to address the health threat posed by the contaminated
sediments present in the industrial drainageway and Koppers Pond.
On June 28, 1991, the EPA issued a unilateral administrative order
under Section 106(a) of CERCLA, 42 U.S.C. §9606, to Westinghouse
directing it to implement the remedy set forth in the 1990 ROD.
The remedial design was completed in June 1996 and remedial
construction activities began in September of this year.
On August 6, 1991, the EPA and Westinghouse entered into an
administrative order on consent for Westinghouse to perform an
RI/FS at its Facility, the industrial drainageway, and Koppers Pond
consistent with the mandates of the 1990 ROD. The results of that
RI/FS are presented in this OU3 ROD.
On September 27, 1995, the EPA and Westinghouse entered into a
second administrative order on consent for Westinghouse to perform
a removal action at its Facility. The removal was conducted in
late 1995 and early 1996. The results are presented herein (see
section on Removal Action, below).
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HIGHLIGHTS OF COMMUNITY PARTICIPATION
The 1996 RI report, FS report, and the Proposed Plan for OU3 were
released to the public for comment on August 28, 1996. These
documents were made available to the public at two information
repositories maintained at the Town of Horseheads Town Hall,
located at 150 Wygant Road, Horseheads, New York and the NYSDEC
office, located at 50 Wolf Road, Albany, New York. The EPA issued
a press release to the local media on August 27, 1996 to announce
the start of the public comment period, the date of the public
meeting, and availability of the above-referenced documents. A
flyer containing such information was also sent to all parties on
the EPA's Site mailing list on August 28, 1996. A notice of
availability for the above-referenced documents was also published
in the Star Gazette on August 29, 1996. The public comment period
established in these documents was from August 28, 1996 to
September 26, 1996.
On September 11, 1996, the EPA held a public meeting at the Village
of Horseheads Town Hall to present the Proposed Plan to local
officials and interested citizens and to answer any questions
concerning such Plan and other details related to the RI and FS
reports. Responses to the comments and questions received at the
public meeting, along with other written comments received during
the public comment period, are included in the Responsiveness
Summary (see Appendix V).
SCOPE AND ROLE OF RESPONSE ACTION
As with many Superfund sites, the problems at this Site are
complex. As a result, the EPA has divided the remedial work into
three discrete segments or operable units (OUs). The remedies
selected for these three OUs have been, or will be, implemented
separately.
The OUs are defined as follows:
OU1 - Nature and Extent of Contamination
The major remedial component of the first operable unit (OU1) ROD,
dated November 30, 1986, called for the connection of residences
using private drinking water wells to the public water supply.
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OU2 - Source Identification
The second operable unit (OU2) ROD, dated September 28, 1990,
called for an interim remedy to restore the Kentucky Avenue Well as
a public drinking water supply well and prevent the spreading of
contamination within the Newtown Creek Aquifer via ground-water
extraction and treatment.
OU3 - Source Control
The remedy selected in this OU3 ROD will address the two areas of
soil contamination at the Facility and the sediment contamination
in the industrial drainageway. Because each of the areas to be
remediated differs with respect to the nature and extent of
contamination, general physical characteristics, and location, they
will be addressed by separate response actions.
The primary objectives of these actions are as follows:
1. Remediate the sources of ground-water contamination at the
Facility to compliment the interim ground-water remedy
selected by the EPA in the 1990 ROD for OU2;
2. Prevent exposure to contaminated soil at the Facility; and,
3. Minimize health threats posed by exposure to contaminated
sediment in the industrial drainageway and consumption of
contaminated fish from Koppers Pond. The contaminated
sediment in the industrial drainageway is believed to be a
source of the polychlorinated biphenyls (PCBs) present in the
fish.
The purpose of OU3 was also to determine the final remedy for
aquifer restoration at the Site. However, based on the findings of
the 1996 RI/FS, no further ground-water treatment beyond that
specified in the 1990 ROD for the interim ground-water remedy is
warranted as a response action for OU3. Therefore, the interim
remedy will become the final ground-water remedy for the Site (see
section on Selected Remedy, below). It is noted that since the
issuance of the 1990 ROD, the EPA has signed a ROD for the Facet
site which calls for the recovery and treatment of contaminated
ground water originating from that facility.
Based on an initial screening of ecological risk associated with
Koppers Pond, the EPA determined that further investigation of the
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environmental conditions in the Pond and the outlet stream south of
the Pond are warranted. The EPA plans on conducting this
investigation as part of a supplemental ecological study.
SUMMARY OF SITE CHARACTERISTICS
This section summarizes the findings of the 1996 RI. A summary of
the analytical data collected for OU3, listed by area and medium,
can be found in Table 2 of Appendix II for the contaminants of
concern identified by the EPA. The results of the 1996 RI
indicated the following:
Westinghouse Facility
Over the years of manufacturing production, various Facility
operations, including machining, electroplating, and chemical
cleaning, generated solid and liquid wastes. Such plant wastes
included TCE and TCE-related still-bottoms and degreaser sludges.
The solid and liquid wastes were disposed at several locations on
the Facility property until 1975. These on-Site waste disposal
areas and several other areas of potential concern at and near the
Facility were investigated during the RI.
Magnesium Chip Burial Area
Westinghouse plant records indicated that from 1973 to 1975,
ignitable and reactive magnesium chips and titanium turnings
were first containerized in 30-gallon drums. The 30-gallon
drums were then placed in 55-gallon drums that were
subsequently filled with concrete and buried in an 8-foot by
215-foot trench located at the northern portion of the
Facility and within approximately 400 feet of New York Route
17. It was estimated that approximately 200 drums were buried
in this area.
Ground-Penetrating Radar (GPR) surveys and subsequent
trenching activities confirmed the presence of drums within a
narrow trench at a depth of 2 to 4 feet. The drums were
intact and did not appear to have impacted the surrounding
soils. Analysis of soil samples collected from depths between
1 and 8 feet revealed low levels of several semi-volatile
organic compounds (SVOCs), including PAHs, PCBs and metals.
Magnesium concentrations were below those found in background
soils generally in the area at the Site.
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A total of 179 55-gallon drums were removed from the Magnesium
Chip. Burial Area and sent off-Site for disposal as part of the
removal action conducted by Westinghouse in 1995 (see section
on Removal Action, below).
Calcium Fluoride Sludge Disposal Areas Nos. 1 and 2
Two of the ten areas investigated at the Facility included the
two calcium fluoride sludge disposal areas located at the
north end of the West Parking Lot. The materials placed at
these disposal areas included sludges from the treatment of
hydrofluoric acid wastewaters at a former fluoride treatment
operation.
One soil boring in Area No. 1 and two soil borings in Area No.
2 revealed a white powdery material at depths between 3 and 7
feet. Analytical results revealed the white material to
contain high levels of cadmium and several other metals.
Subsequent analyses using the toxicity characteristic leaching
procedure (TCLP) revealed the material to exhibit the
characteristics of a RCRA hazardous waste because of leachable
cadmium. Other chemicals detected in the soils at depths
between 2 and 12 feet included PAHs, PCBs and metals at low
concentrations. No TCE was detected in soil samples from
these two areas.
Approximately 1,240 tons of the white, powdery material and
soil mixed with such material were excavated from the two
Calcium Fluoride Sludge Disposal Areas and sent off-Site for
disposal as part of the removal action conducted by
Westinghouse in 1995 (see section on Removal Action, below).
Former Runoff Basin Area
The Former Runoff Basin Area is a storm-water runoff basin
consisting of an oval-shaped depression located north and west
of the main plant building. It is approximately 0.7 acre in
areal extent and is currently covered by lawn, asphalt
pavement and small man-made structures. A 7,500-gallon above-
ground tank used for storing chlorinated solvents was located
in this area at one time.
The GPR survey did riot indicate the presence of any buried
objects in this area. TCE was detected in 43 of 59 subsurface
soil samples, with a maximum concentration of 79,000 parts per
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billion (ppb), and maximum depth of 12 feet. The water table
was encountered at a depth between 8 and 11 feet. The soils
containing the highest concentrations of TCE are proximal to
the former location of the 7,500-gallon storage tank.
Additionally, TCE was detected at concentrations of 4 and 6
ppb in ground-water samples collected from the shallow and
deep portions of the aquifer. Dibenzofuran, PAHs, PCBs and
metals were also present at low concentrations.
The soil and ground-water sample results confirmed that the
Former Runoff Basin Area is a source of TCE contamination in
ground water.
Disposal Area F
Plant records indicated that between 1971 and 1974, TCE-
related still bottoms and degreaser sludges were disposed in
shallow (2 to 3 feet deep) trenches covering an area about 75
feet by 100 feet. Subsurface trenching activities to a depth
between 11 and 12 feet encountered various waste-like
materials, including a coal slag or tar-like material at the
surface, coal-like material at a depth of approximately 2
feet, amber beads, a dark brown and black sand and pea gravel,
and a layer of white, powdery material suspected of being
waste pumice.
Several VOCs, SVOCs and metals were detected in soil samples
collected at Disposal Area F. TCE was primarily detected in
soil and waste materials at the northern portion of the
disposal area from depths between 1 foot and 2.5 feet and at
a maximum concentration of 20,000 ppb. Ground water was
encountered at depths between 11 feet and 12.5 feet.
PAHs were also detected in surface soil samples, including
fluoranthene (700 parts per million or ppm), pyrene (610 ppm) ,
benzo(b)fluoranthene (420 ppm), benzo(a)pyrene (310 ppm) and
benzo(a)anthracene (290 ppm). Arsenic was detected in surface
and subsurface soils, with the maximum concentration (18.9
ppm) in a soil sample collected from a depth of 1.0 foot.
The soil sample results, along with the soil-gas and ground-
water headspace survey results from the MW-10 Area (see
section on MW-10 Area findings, below) confirmed that Disposal
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Area F is a contributing source of TCE contamination to ground
water.
Former Coal Pile Area
Plant records indicated that during the 1960s, TCE and TCE-
related still bottoms and degreaser sludges were placed on the
coal at the Facility power house fuel pile.
The GPR survey did not indicate the presence of any buried
objects at the Former Coal Pile Area. Twenty-one boreholes
were drilled to evaluate subsurface conditions. Analysis of
fifteen soil samples collected at depths between 2 and 10 feet
revealed low concentrations of several VOCs, including toluene
(13 ppb) and TCE (6 ppb) , SVOCs, PCBs and several metals.
Ground water was encountered at depths between 8 and 11 feet.
Based on these findings, the Former Coal Pile Area does not
appear to be a significant source of TCE contamination in
ground water.
MW-10 Area
Monitoring well MW-10 is located approximately 250 feet
hydrologically downgradient of Disposal Area F, and ground-
water samples from this well have historically revealed the
presence of TCE. The purpose of conducting the soil-gas and
ground-water headspace surveys was to determine whether the
TCE contamination at MW-10 was originating at Disposal Area F,
another upgradient source, or whether additional sources were
present in the immediate vicinity of the MW-10 Area.
Soil-gas and ground-water headspace samples collected between
Disposal Area F and MW-10 at depths between 7 and 12 feet
confirmed that TCE (98 ppb) in soil gas was originating from
Disposal Area F. Analytical results of three ground-water
grab samples collected from the survey boreholes at the MW-10
Area were consistent with the TCE concentrations found in the
soil-gas and ground-water headspace surveys.
Analysis of soil samples collected at a depth of approximately
3 feet at the MW-10 Area revealed the presence of TCE (32 ppb)
and other VOCs, PAHs, PCBs and several metals at
concentrations below remedial action objectives (RAOs) (see
section on RAOs, below).
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The results of the soil sample analyses and the soil-gas and
ground-water headspace surveys indicate that Disposal Area F
is the source of the TCE contamination in ground water at the
MW-10 Area. No other source of TCE was identified upgradient
of Disposal Area F or in the immediate vicinity of the MW-10
Area.
Soil Pile
Soil removed from previous on-site construction activities was
stockpiled south of the West Parking Lot. A soil-gas survey
conducted at depths of 5 and 10 feet in the Soil Pile did not
detect any VOCs. Analysis of soil samples collected from a
depth of 0 to 2 feet revealed low concentrations of VOCs,
SVOCs, PCBs and several metals. TCE (0.008 ppm) was below the
established RAO of 0.8 ppm for TCE. SVOCs included the
following PAHs: benzo (a) anthracene (1.9 ppm), benzo (b)
fluoranthene (1.5 ppm) and benzo(a)pyrene (1.2 ppm). The 1.2
ppm level for benzo (a)pyrene exceeded the RAO of 0.78 ppm.
The .maximum PCB concentration was 3.2 ppm. Manganese was
detected at a concentration of 1,220 ppm.
The PCB and PAH contaminated sediments at the Soil Pile were
removed and transported off-Site for disposal as part of the
removal conducted by Westinghouse in 1995. The remaining
uncontaminated soil was used as backfill material at the two
Calcium Fluoride Sludge Disposal Areas after the removal of
materials was conducted in those areas (see section on Removal
Action, below).
Area Southwest of the West Parking Lot
A 1970s memorandum from a former plant environmental officer
suggests that plant wastes may have been disposed of at this
area. Soil-gas and ground-water headspace surveys detected
low concentrations of TCE (<10 ppb) at six survey locations.
Analysis of ten (10) soil samples collected from a depth of 3
to 4 feet revealed low levels of VOCs, SVOCs, PCBs and several
metals, including arsenic at 10.5 ppm.
Based on these findings, this area does not appear to
represent a significant source of TCE in ground water.
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Surface-Water Runoff Drains
Site reconnaissance identified 31 surface-water runoff (storm)
drains present at the Facility. Since concrete or cobbles
lined five of these drains, only the other 26 were
investigated during the RI. The soil in these drains were
found at depths between 4 and 6 feet and each drain had a
manhole cover. The drains were investigated to determine if
they serve as receptors or conduits for liquid waste materials
to reach the underlying soil and ground water.
Analyses of 26 soil samples collected from depths of 5 to 15
feet showed concentrations of various VOCs, SVOCs, pesticides
and metals. The most frequently detected VOC was toluene (13
of 26 samples) at a maximum concentration of 270 ppb. TCE was
also detected, but at very low concentrations. SVOCs detected
included PAHs, phthalates and phenols. Fluoranthene (810
ppm) , pyrene (650 ppm) and phenanthrene (630 ppm) were
detected at the highest concentrations. Eighteen pesticides
and two PCBs were detected, with PCB levels all less than 1.0
ppm. Twenty-two inorganics were detected, with twelve of
these detected in all 26 samples, including lead (421 ppm) and
zinc (422 ppm).
Based on these findings, it does not appear that the surface-
water runoff drains act as conduits for TCE or other VOCs to
leach to ground water. The PAHs present are believed to be
the result of storm water runoff across the large areas of
asphalt pavement at the Facility.
New York Route 17
An area of NYSDOT right-of-way for New York Route 17, which is
beyond the Facility property, was investigated based on an
anonymous source which reported witnessing an alleged disposal
of 350 to 500 fifty-five gallon drums in this area during
construction of New York Route 17.
The results of soil-gas and ground-water headspace analyses
from depths between 19 and 35 feet at twenty-two locations
beneath New York Route 17 revealed low levels of VOCs,
including tetrachloroethane (14 ppb), total xylenes (11 ppb),
benzene (6 ppb) and TCE (<3 ppb). Benzene and total xylenes
are associated with petroleum and petroleum product
derivatives. Such levels are believed to be too low to
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represent a source of contamination to the ground water. No
buried drums were encountered during this investigation.
Ground Water
The results of a hydrogeologic investigation conducted by
Westinghouse at its Facility in 1987 and 1988 revealed the
presence of TCE and several other VOCs and metals in ground
water beneath the eastern and southern portions of the
Facility. Based on that investigation and the results of the
EPA's 1990 RI/FS for OU2, the EPA concluded that the Facility
was the primary source of TCE contamination in the aquifer at
the KAW. Additionally, as discussed above, the purpose of OU3
was to evaluate options for source control at the Facility and
final restoration of the Newtown Creek Aquifer. Therefore,
evaluation of the ground water was included as part of the
RI/FS for OU3 to identify contaminant source areas and
determine what further remedial efforts, in addition to the
interim ground-water remedy selected for OU2, were warranted
for ground water.
Ground-water samples were collected for analysis from twenty-
seven (27) Facility monitoring wells and one Facility
production well in 1994 and/or 1995. Analytical results
confirmed that several VOCs, including TCE (120 ppb), 1,1,1-
trichloroethane (8.5 ppb), 1,2-dichloroethene (4 ppb) and
chloromethane (140 ppb), have contaminated the shallow and
deep portions of the ground-water aquifer beneath the
Facility. The highest TCE concentrations were detected in
wells located along the southern portion of the property.
Isoconcentration contour maps define the distribution of TCE
in both the shallow and deep aquifer zones as narrow,
elongated plumes originating from the vicinity of Disposal
Area F and extending eastward, in a downgradient direction,
through the MW-10 Area and beyond the southeast corner of the
Facility.
Analysis of ground-water samples collected from the on-Site
monitoring wells also revealed several metals, including
chromium, nickel and cadmium at concentrations exceeding
Federal and NYS drinking water standards. However, the metals
are believed to be attributable to particulate matter either
in the aquifer (clays) or in the well screen as a result of
artifacts of well construction. An analysis of ground-water
samples from a downgradient plant production well (SW-5) for
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both total metals (unfiltered samples) and dissolved metals
(filtered samples) revealed concentrations below such
standards. Therefore, although metals are present in ground
water beneath the Facility, they do not appear to be migrating
off-site.
Based on the findings of the RI/FS, the EPA has determined
that ground-water treatment is not warranted beyond that
specified for the OU2 interim remedy in the 1990 ROD, the 1991
administrative order, and the approved remedial design for
OU2. Therefore, the interim remedy is deemed by the EPA to be
the final remedy for restoring the Newtown Creek Aquifer to
its beneficial use as a drinking water aquifer at the Site.
Industrial Drainageway and Koppers Pond
Surface Water and Sediments
The industrial drainageway and Koppers Pond were investigated
as part of OU3 because the results of the 1990 RI/FS for OU2
revealed that several metals, primarily cadmium, were present
in the sediments of the industrial drainageway at levels which
posed a health risk from direct contact exposure.
Additionally, because TCE had historically been a permitted
discharge parameter at varying levels in the treated
wastewaters released to the industrial drainageway from the
Facility, the industrial drainageway was considered as a
possible migration pathway for TCE to impact ground water at
the KAW (i.e., surface water to ground water). Surface-water
and/or sediment samples were collected for analysis from
twenty (20) locations within the industrial drainageway
system, including the underground piping between the
drainageway and the Facility, Koppers Pond and the outlet
stream south of Koppers Pond.
Surface-water samples contained several VOCs, including TCE (8
ppb) and toluene (44 ppb), SVOCs, pesticides and metals. The
metals included cadmium (20 ppb), chromium (28 ppb), copper
(55 ppb) , and lead (345 ppb) from samples collected in the
open drainageway. The current permitted discharge limit for
TCE at the Facility wastewater treatment plants is 11 ppb.
The sediment samples contained elevated concentrations of
several VOCs, SVOCs, pesticides, PCBs, and metals. The VOCs
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included toluene (38 ppb), carbon disulfide (27 ppb) and TCE
(25 ppb).
The 1994 sediment samples, which were collected from a depth
of 0-2 feet, contained PCBs (total) at concentrations ranging
up to 8.6 ppm, with the highest concentrations found in the
samples collected from the upstream portion of the industrial
drainageway (sample locations 6-12; see Figure 3) . The
highest concentration of PCBs detected in the sediments
collected from Koppers Pond was 1.6 ppm. PCBs were not
detected in the sediment samples collected from the outlet
stream south of Koppers Pond. PCBs were also not detected in
any surface-water samples collected from this area.
The 1995 sediment samples, which were collected from a depth
of 0 to 6 inches, contained lower levels of PCBs than that of
the 1994 samples. The highest PCB concentration detected in
samples collected from the industrial drainageway and Koppers
Pond was 1.2 ppm.
The metals detected in the sediment samples included cadmium
(1,055 ppm), chromium (378 ppm), copper (870 ppm), lead (1,810
ppm), nickel (213 ppm) and zinc (10,775 ppm) . The highest
concentrations were from sediment samples collected from the
industrial drainageway. The metals concentrations in sediment
samples collected from Koppers Pond and the outlet stream
south of Koppers Pond were generally an order of magnitude
lower than those concentrations found in samples from the
industrial drainageway.
Based on these findings, a source of PCB contamination in the
industrial drainageway is believed to be from the Facility,
where PCBs have been detected in soil samples collected from
most of the areas investigated during the RI. The highest PCB
concentration found at the Facility was 3.2 ppm in a soil
sample collected from the Soil Pile. Because the Soil Pile
was generated as part of previous construction activities
believed to be associated with plant expansions in 1987 and
1988, the precise source of the Soil Pile is not known.
Elevated concentrations of metals in the industrial
drainageway sediments and surface water are believed to be the
direct result of previous and ongoing permitted discharges
from the Facility.
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Additionally, unauthorized releases from a currently unknown
source at the Facility are believed to have also impacted the
sediments and surface water in the industrial drainageway.
Beginning in the Spring of 1995, local citizens and
representatives of Federal and NYS regulatory agencies have
observed a significant amount of a whitish-brown material
floating in the industrial drainageway. Analysis of this
material revealed elevated concentrations of several metals,
including lead (14,600 ppm), cadmium (334 ppm), and chromium
(294 ppm). No PCBs were detected in this material.
Subsequent sampling and analysis of the whitish-brown material
by the NYSDEC in September 1995 indicated elevated levels of
several metals, including lead (5,800 ppm), zinc (6,220 ppm),
chromium (347 ppm), and cadmium (116 ppm). Samples obtained
and analyzed by the NYSDEC in June 1996 also contained lead
(2,300 ppm), copper (1,100 ppm), aluminum (11,000 ppm),
chromium (200 ppm), and cadmium (180 ppm).
The NYSDEC is currently conducting an investigation to
identify the possible source(s) of such ongoing releases. As
part of that investigation, a Facility operator has agreed to
perform an investigation of its wastewater treatment plant
operations under the direct oversight of the NYSDEC.
Fish
Analyses of fish samples (carp and large mouth bass species)
collected at Koppers Pond by the NYSDEC in 1988 revealed
concentrations of total PCBs at approximately 4.0 ppm, which
exceeded the Food and Drug Administration (FDA) limit of 2.0
ppm for total PCBs in fish. Based on such data, the NYSDOH
issued a fish consumption health advisory for Koppers Pond
recommending that the consumption of carp be limited to one
meal per month for the general population and avoiding fish
consumption for women of child bearing years and children
under the age of fifteen (see NYSDOH Health Advisory Chemicals
in Sport Fish and Games). In light of such findings, fish-
tissue-sample analysis was included as part of the RI for the
industrial drainageway and Koppers Pond.
White sucker and carp species were collected by an
electroshocking technique at Koppers Pond in June 1995. All
fish samples collected were relatively small (approximately 6-
9 inches). Thirteen fish-tissue samples were prepared by
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filleting and removal of skin. The samples were analyzed for
EPA's Target Compound List (TCL) and Target Analyte List (TAL)
chemicals.
The fish-tissue analyses revealed concentrations of VOCs, PCBs
and metals. The VOCs included carbon disulfide (589 ppb) ,
acetone (474 ppb), and toluene (11 ppb).
The PCB (Aroclor 1254) levels ranged up to 0.54 ppm. Fifteen
metals were also detected, including arsenic at a maximum
concentration of 0.1 ppm.
REMOVAL ACTION
Based on the preliminary findings during the RI, the EPA and
Westinghouse entered into an administrative order on consent on
September 27, 1995 for Westinghouse to remove the buried 55-gallon
drums containing magnesium chips and titanium turnings waste from
the Magnesium Chip Burial Area and hazardous soils at the two
Calcium Fluoride Sludge Disposal Areas containing a white material
having characteristics of a RCRA hazardous waste. The buried drums
and hazardous soils constituted a release and/or threat of release
to the environment and therefore were removed from the Facility as
part of an expedited response action.
In late 1995 and early 1996, Westinghouse excavated and sent off-
Site for disposal the following materials:
A total of 179 55-gallon drums (284.9 tons) were removed from
the Magnesium Chip Burial Area, opened to confirm that the
wastes were encased in concrete, and sent off-Site for proper
disposal;
At the two Calcium Fluoride Sludge Disposal Areas,
approximately 1,240 tons of the white, powdery material and
soil mixed with such material were excavated and sent off-Site
for disposal as RCRA hazardous waste; and,
Four truck loads of soil containing PCBs and PAHs were removed
from the Soil Pile area and taken off-Site for disposal, with
the remaining uncontaminated soil used to backfill other areas
excavated during the removal.
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Confirmation soil sampling and analysis confirmed that the residual
soils at the excavations of the two Calcium Fluoride Sludge
Disposal Areas and the Magnesium Chip Burial Area met the EPA's
established risk-based cleanup objectives.
SUMMARY OF SITE RISKS
A four-step process is utilized for assessing site-related human
health risks for a reasonable maximum exposure scenario: Hazard
Identification--identifies the contaminants 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
assessment of site-related risks.
Based on the results of the RI, the EPA conducted a baseline human
health risk assessment and screening level ecological risk
assessment to evaluate potential risks to human health and the
environment associated with OU3 at the Site assuming current
conditions. Those risk assessments focused on contaminants which
are likely to pose significant risks to human health and the
environment in the soil at the Facility and the sediment, surface
water, and fish in the Industrial Drainageway and Koppers Pond. A
summary of the contaminants of concern identified in sampled media
is listed in Table 1 and the contaminant levels used for the human
health risk calculations are listed in Table 2 (see Appendix II).
Human Health Risk Assessment
The EPA's baseline human health risk assessment for OU3 estimated
the potential risks to human health by identifying several
potential exposure pathways by which the public may be exposed to
Site contaminants under current and future land-use conditions.
The exposure routes evaluated included: (1) ingestion, dermal
contact and inhalation of untreated soils; (2) ingestion and dermal
contact of surface water and sediments; and, (3) ingestion of fish
from Koppers Pond. Specifically, human receptors evaluated for
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exposure to contaminated soils at the Facility were site workers,
employees and on-site construction workers in present and potential
future industrial land use scenarios. Such exposures were also
evaluated for adult and child residents in the potential future
residential land use scenario. At the industrial drainageway and
Koppers Pond, area residents (teenage trespassers) were evaluated
for exposure to contaminated surface water and sediment, and area
residents (adults) were evaluated for exposure to contaminated fish
in present and future residential land use scenarios. These
potential exposure pathways are listed in Table 3 (Appendix II).
Although a future residential land use scenario is included in the
assessment for the Facility, the property is currently industrial
and zoned for industrial uses only. Additionally, it is not
anticipated that the industrial setting will change in the
foreseeable future. Therefore, the remedial alternatives discussed
in this ROD for the Facility address only those risks associated
with the present and future industrial land use settings (see
section on Summary of Remedial Alternatives, below).
To quantitatively assess the potential carcinogenic and
noncarcinogenic health risks associated with the exposure scenarios
considered in this assessment, estimates of chronic and subchronic
daily intakes are developed. Daily intake levels are expressed as
the amount of a substance taken into the body (milligrams) per unit
body weight (kilograms) per unit of time (day), or mg/kg/day. It is
averaged over a lifetime for carcinogens and the period of exposure
for noncarcinogens. Because of the uncertainty associated with any
estimate of exposure concentration, the daily intakes were
calculated using the upper confidence level (UCL) (i.e., the 95
percent UCL) on an arithmetic average, which was derived from
actual Site data. In cases where the 95 percent UCL exceeded the
maximum- detected concentration, the maximum detected concentration
was used in the calculations.
Potential carcinogenic risks were evaluated using cancer slope
factors (SFs) developed by the EPA for the contaminants of concern.
SFs have been developed by the EPA's Carcinogenic Risk Assessment
Group for estimating excess lifetime cancer risks associated with
exposure to potentially carcinogenic chemicals. SFs,. which are
expressed in units of (mg/kg-day) ~i, are multiplied by the estimated
daily intake of a potential carcinogen, in mg/kg-day, to generate
an upper-bound estimate of the excess lifetime cancer risk
associated with exposure to the compound at that intake level. The
term "upper bound" reflects the conservative estimate of the risks
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calculated from the SF. Use of this approach makes underestimation
of the aptual cancer risk highly unlikely. The SFs for the
contaminants of concern at OU3 are presented in Table 4 (Appendix
ID .
For known or suspected carcinogens, the EPA considers excess upper-
bound individual lifetime cancer risks in the range of ICr4 to 10'6
to be acceptable. These risk levels indicate that an individual
has approximately 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.
Noncarcinogenic risks were assessed by comparing expected daily
intake levels (chronic and subchronic) with oral and inhalation
reference doses (RfDs). RfDs are estimates of daily exposure
levels or intake levels for humans which are likely to be without
an appreciable risk of harmful effects over a lifetime (including
sensitive individuals). The estimated daily intake level of a
single contaminant from an environmental medium (e.g., the amount
of a chemical ingested from contaminated drinking water) is
compared to the contaminant's RfD to derive a hazard quotient. A
hazard index (HI) is obtained by adding the individual hazard
quotients for all contaminants across all media that impact a
particular receptor population. The RfDs for the contaminants of
concern at OU3 are presented in Table 5 (Appendix II).
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 effects of exposure to multiple contaminants within
a single medium or across media.
In accordance with the EPA's guidelines for evaluating the
potential toxicity of complex mixtures of chemicals, it was assumed
that the toxic effects of site-related contaminants would be
additive. Thus, carcinogenic and noncarcinogenic risks associated
with exposures to individual contaminants of concern were summed to
indicate the potential risks associated with mixtures of potential
carcinogens and noncarcinogens, respectively.
The summing of carcinogenic risks and noncarcinogenic HI values
calculated for each of the potential exposure pathways identified
for specific receptor groups and media are shown in Tables 6 and 7
(Appendix II) . The only carcinogenic risks which exceed the upper-
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bounds of the EPA's 10'4 to 10'6 target risk range occur for site
workers and employees potentially exposed to contaminated soil at
Disposal Area F and area residents exposed to contaminated fish
from the industrial drainageway and Koppers Pond. The only
noncarcinogenic HI which exceeded the EPA's target value of one,
assuming the future land use at the Westinghouse Facility remains
industrial, is from the ingest ion of contaminated fish from the
industrial drainageway and Koppers Pond by area residents.
Carcinogenic risk as a result of ingestion of surface soil by
present and potential future site workers/employees at Disposal
Area F is estimated to be 5.1 x 10'4. The cancer risk is
attributable primarily to carcinogenic PAHs (i.e., benzo(a)pyrene,
benzo(b)fluoranthene, benzo(a)anthracene and Indeno(1,2,3-
cd)pyrene) and arsenic.
The carcinogenic risk related to ingestion of contaminated fish
from the industrial drainageway and Koppers Pond by area residents
(adults) was estimated to be 3.8 x 10~4. This risk exceeds the
EPA's 10'4 to 10s target risk range and is attributed to PCBs
(Aroclor 1254) and arsenic. The HI calculated for fish ingestion
by an adult is 6.9, which exceeds the EPA's target level of 1.0.
This value is also attributed to Aroclor 1254 and arsenic.
Noncarcinogenic HI values calculated for several other areas at the
Facility also exceed the EPA's 1.0 target level for a resident
child exposed to contaminated soil in a potential future
residential land use scenario. However, as stated above, the land
use is expected to remain industrial for the foreseeable future.
Therefore, the remedial actions selected in this ROD for the
Facility address only those risks associated with the present and
future industrial land use settings (see section on Summary of
Remedial Alternatives, below).
All other areas and environmental media investigated during the RI
presented health risks which were below or within the EPA's 10~4 to
10"6 target risk range for carcinogens or below the EPA's HI target
level of one for noncarcinogenic health hazards.
Screening Level Ecological Risk Assessment
To assess the effect of Site-related contaminants on the ecosystems
in the industrial drainageway and Koppers Pond, the EPA performed
a screening-level ecological risk assessment. The initial step of
this assessment was to screen contaminant concentrations detected
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in the sediment, surface-water and fish samples against ecological
screening criteria, Federal Ambient Water Quality Criteria, and
NYSDEC Ambient Water Quality Standards established, in part, for
the protection of aquatic and terrestrial wildlife and their
habitats.
Following ecological screening, ecological risk characterization
(modeling) was performed using three contaminants of concern (i.e.,
cadmium, lead and Aroclor 1254) along with Site-specific biological
species/habitat information. Two receptor species identified at
the Site, the great blue heron and racoon, were selected for risk
modeling. The potential exposure pathways used for those receptor
species were the ingestion of contaminated fish and ingestion of
surface water and sediment. To perform the exposure assessment,
the EPA estimated exposure point concentrations (daily doses) based
on the sediment, surface water, and fish fillet data obtained
during the 1996 RI and published bioaccumulation factors.
Ecological screening revealed that several contaminants, primarily
cadmium, chromium, copper, lead, nickel, zinc, and PCBs, are
present in the sediment and/or surface water at levels which may
have an adverse effect on aquatic and terrestrial wildlife.
Additionally, Aroclor 1254 levels detected in fish tissue samples
exceeded the NYS whole-body fish criteria for PCBs and indicate
that the contaminant is bioaccumulating at levels known to be
associated with adverse ecological effects.
Aroclor 1254, cadmium and lead dosage calculations performed for
the great blue heron and racoon, when compared to known reference
doses for toxicity, also revealed that estimated daily doses of
such contaminants are at or exceed levels which cause adverse
ecological effects in organisms.
Field observations revealed a fairly diverse wildlife community
around Koppers Pond, but the aquatic habitat appeared to be
stressed. Koppers Pond appeared to be depauperate of fauna. No
small fish, tadpoles or newts were observed in the Pond and no
benthic organisms were sighted in the industrial drainageway, nor
in the sediment samples collected from the industrial drainageway,
the Pond, and outlet stream south of the Pond.
In light of the findings of the screening level ecological risk
assessment and field observations, the EPA has determined that
further field investigations are warranted to assess the extent of
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environmental impacts to Koppers Pond and the outlet stream south
of the Pond. The EPA plans to conduct such an investigation as
part of a supplemental study. Upon completion of this supplemental
study, the EPA will assess the need for remedial action in those
areas.
Discussion of Uncertainties in Risk Assessment
The procedure 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; and,
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
contaminants of concern, the period of time over which such
exposure would occur, and in the models used to estimate the
concentrations of the contaminants of concern at the point of
exposure.
Uncertainties in toxicological data occur in extrapolating both
from animals to humans and from high to low doses of exposure, as
well as from the difficulties in assessing the toxicity of a
mixture of chemicals. These uncertainties are addressed by making
conservative assumptions concerning risk and exposure parameters
throughout the assessment. As a result, the baseline human health
risk assessment provides upper-bound estimates of the risks to
populations near the Site, and it 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
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various exposure pathways, is presented in the EPA's baseline human
health risk assessment report for OU3.
The greatest carcinogenic risks at the Site revealed during OU3,
assuming the future land use at the Facility remains industrial, is
associated with the ingestion of soil at Disposal Area F by site
workers and employees and ingestion of fish from the industrial
drainageway and Koppers Pond by area residents (adults).
Additionally, significant noncarcinogenic effects from the
ingestion of fish by area residents has also been established.
In light of the above, the EPA has determined that actual or
threatened releases of hazardous substances from this Site, if not
addressed by implementing the response actions selected in this
ROD, may present a potential threat to public health, welfare, or
the environment.
REMEDIAL ACTION OBJECTIVES
Remedial action objectives (RAOs) 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 primary objectives of
these actions are to control the source(s) of contamination at the
Site and to reduce and minimize the migration of contaminants into
Site media, thereby minimizing any health and ecological impacts.
The following RAOs were established for OU3:
Preventing direct contact with contaminated soil;
Preventing the leaching of contaminants into ground water;
and,
Preventing contact with contaminated sediment and limiting the
availability of contaminants for uptake by fish, thereby
serving to reduce the health threat posed by fish consumption.
Soil
The RAO is to prevent direct contact with soils that pose an
unacceptable risk (i.e., carcinogenic risk greater than the EPA's
1CT4 to 10'6 target risk range or a noncarcinogenic HI greater than
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one) under the present and future industrial land use scenarios.
In order to determine which areas at the Facility require soil
remediation, cleanup goals were established for those contaminants
of concern identified in the EPA's baseline human health risk
assessment for each area investigated. The cleanup goals or
concentrations are calculated such that the carcinogenic risk posed
by the soil residual contaminant levels after cleanup are no
greater than 1 x 10~6.
Based on such calculations, the only potential source area at the
Facility having soil contamination levels that exceed the
established risk-based cleanup goals is Disposal Area F. The
contaminants of concern which exceed such goals are four PAHs and
arsenic. The calculated risk-based RAOs for the PAHs are as
follows:
Benzo(a)anthracene 7.80 ppm
Benzo(a)pyrene 0.78 ppm
Benzo(b)fluoranthene 7.80 ppm
Indeno(1,2,3-cd)pyrene 7.80 ppm
Because the risk-based cleanup goal for arsenic is below the
background level at the Site, it cannot be achieved. A background
level of 26.5 ppm for arsenic was calculated based on data from 16
soil samples collected at depths between 0 to 2 feet and 10 to 12
feet along the perimeter of the Facility. However, because of
anomalies in the background data, this value was above the normal
background range for arsenic in New York (3 to 12 ppm) , as
described by the NYSDEC Technical and Administrative Guidance
Memorandum (TAGM). Therefore, the EPA decided to use the maximum
background value provided by the TAGM (12 ppm) as a more
conservative cleanup goal.
Soil at several other potential source areas, in addition to
Disposal Area F, has arsenic levels higher than the risk-based
cleanup goal calculated for arsenic, but such levels are below the
established cleanup goal of 12 ppm.
Under the future industrial setting, there are no instances in
which the HI associated with exposure to surface soil at the
Facility exceeds the EPA's target level of one.
Based on the EPA's baseline human health risk assessment for OU3,
no RAOs are required for subsurface soil as a result of or threat
posed by direct-contact exposure.
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Ground Water
The EPA did not quantitatively evaluate human health risks
associated with the ground-water pathway in its baseline human
health risk assessment for OU3 because such an assessment was
previously completed by the EPA for OU2. The carcinogenic risk
calculated for the ground-water pathway in that risk assessment was
1 x 1C)'3 for the reasonable maximum exposure, which exceeded the
EPA's target risk range of 10'4 to 10'6. The chemicals which were
the primary contributors to said risk were TCE, vinyl chloride, and
arsenic. The interim ground-water remedy selected for OU2 was to
mitigate such health risk by achieving Federal and NYS drinking
water standards at the tap.
Based on the findings of the RI for OU3, no further ground-water
treatment beyond that selected as part of the OU2 interim remedy
was deemed to be necessary as a response action for OU3.
Therefore, RAOs were not developed for ground water at OU3.
Although RAOs were not developed for ground water, soil remediation
was necessary as a source control effort to compliment the 1990
ground-water remedy for OU2. Therefore, RAOs have been developed
for those soils identified in the RI as contributing to the
contamination in ground water beneath the Facility. TCE is present
in the soils at Disposal Area F and the Former Runoff Basin Area at
concentrations which have the potential to leach to ground water.
To prevent further leaching of TCE from soils to ground water, an
RAO of 0.8 ppm was calculated for TCE based on a soil leaching
model contained in the EPA's 1994 Technical Background Document for
Soil Screening Guidance. For comparison, the NYSDEC's established
cleanup goal for TCE in soil is 0.7 ppm, as defined in the TAGM.
Sediment
Based on the EPA's baseline human health risk assessment for OU3,
the RAO for sediment in the industrial drainageway and Koppers Pond
is to prevent exposure to PCBs through fish consumption and direct
contact with sediment. For mitigating such human health threats,
a RAO of 1.0 ppm PCB (total) is established for the sediment. The
1.0 ppm level is consistent with the EPA and the NYSDEC TAGM
guidance for PCB cleanup levels in residential areas. Remedial
efforts would be focused on the industrial drainageway sediment
because PCB concentrations exceeded the 1.0 ppm RAO. PCB levels in
the sediment in Koppers Pond were less than or approximately equal
to the RAO. However, to ensure that the RAOs for the Pond are met,
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sampling will be performed for PCBs as part of the additional
ecological investigation planned by the EPA for Koppers Pond and
the outlet stream south of the Pond. Upon completion of that
investigation, additional RAOs will be calculated, if necessary, to
address any environmental impacts.
DESCRIPTION OF REMEDIAL ALTERNATIVES
CERCLA mandates 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 alterna-
tive treatment technologies and resource recovery alternatives to
the maximum extent practicable. In addition, the statute
establishes a preference for the use of treatment as a principal
element for the reduction of toxicity, mobility, or volume of the
hazardous substances, pollutants and contaminants at a site.
The FS report evaluates twelve remedial alternatives for addressing
the contamination associated with OU3 at the Site, four each for
Disposal Area F, the Former Runoff Basin Area and the industrial
drainageway. Because each of the areas to be remediated differs
with regard to the nature and extent of contamination, general
physical characteristics, and location, the EPA is not selecting
one remedial alternative for the entire operable unit, rather a
specific remedial action for each area of contamination.
The remedial alternatives evaluated for OU3 are described below.
It should be noted that the numerical designation of several
alternatives in this ROD differ from those used for the same
alternatives contained in the FS Report.
Also, the time periods referenced below for implementation of the
remedial alternatives does not reflect that period of time required
to negotiate with the responsible party, design the remedy, and
procure any contracts which are necessary to implement the remedy.
Disposal Area F
Alternative 1A - No Action
Capital Cost: 0
O & M Cost : 0
Present-Worth Cost: 0
Time to Implement: None
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CERCLA requires that the "No Action" alternative be considered as
a baseline for comparison of other alternatives. The No Action
alternative for Disposal Area F provides for no further effort to
avoid exposure to soil or to control the leaching of contaminants
to ground water. The access controls for the Facility (e.g.,
security guard and perimeter fence) would remain active. The
existing, temporary fence around Disposal Area F would be left in
place and the area would remain a vacant, unused portion of the
plant site. The TCE present in soil would eventually leach into
ground water and migrate to the OU2 ground-water recovery wells,
where it would be extracted and treated.
Because this alternative, if selected, would result in contaminants
remaining on-Site above health-based levels, CERCLA requires that
the area be reviewed every five years.
Alternative 2A (Option 1) - Containment with Asphalt Cover
Capital Cost: $219,200
0 & M Cost (per year): $19,200
Present-Worth Cost: $514,100
Time to Implement: Less than 1 year
Under this containment alternative, Disposal Area F would be capped
with a 40-mil (one mil = one-thousandth of an inch) thick Flexible
Membrane Liner (FML), 6-inch subbase layer of fill and 6-inch layer
of asphalt pavement. The paved area would cover approximately 0.8
acres of ground surface and could be used for parking. As a
practical matter, the area proposed for asphalt covering is
somewhat larger than the area containing waste materials because
the asphalt cap would be extended to the existing asphalt parking
lot at the Facility. Institutional controls would include a deed
restriction to limit excavation work and further property use or
development, long-term physical monitoring to minimize future
worker contact and enforce the deed restriction, and long-term
ground-water monitoring to determine the ongoing contribution of
this area to TCE contamination in ground water.
Because this alternative, if selected, would result in contaminants
remaining on-Site above health-based limits, CERCLA requires that
the area be reviewed every five years.
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Alternative 2A (Option 2) - Containment with Low-Permeability Cap
Capital Cost: $606,300
0 & M Cost (per year): $34,200
Present-Worth Cost: $1,114,000
Time to Implement: Less than l year
This containment alternative involves placing a 6-foot thick multi-
layer, low permeability cap over an approximate area of 29,200
square feet (0.67 acre). The components of the cap would include
a 2-foot thick clay layer, 40 mil FML, 12-inch thick drainage layer
with overlying geotextile filter fabric, 30-inch thick barrier-
protection soil layer and 6 inches of topsoil. The capped area
would be fenced, the deed restriction instituted and long-term
physical and ground-water monitoring performed.
Because this alternative, if selected, would result in contaminants
remaining on-Site above health-based limits, CERCLA requires that
the Site be reviewed every five years.
Alternative 3A - Removal and Off-Site Disposal
Capital Cost: $549,000
0 & M Cost (per year): $4,600
Present-Worth Cost: $619,600
Time to Implement: Less than 1 year
This alternative involves the excavation and off-Site disposal of
approximately 1,100 cubic yards (1,600 tons) of contaminated waste
materials. Prior to excavation, further sampling and analysis
would be conducted to classify the waste material for off-Site
disposal. PAH- and arsenic-contaminated soils are not listed RCRA
hazardous waste and are not expected to exhibit the characteristics
of a RCRA waste. Therefore, it may be possible to dispose of such
waste in a permitted solid waste landfill. Waste materials
containing TCE would require disposal in a RCRA permitted hazardous
waste landfill, if classified as a listed RCRA hazardous waste. If
TCE concentrations exceed Land Disposal Restriction (LDR)
standards, treatment would be required in a permitted hazardous
waste incinerator in advance of land disposal. For such materials,
the treatment standard is 6.0 ppm. It is estimated that only 32
cubic yards (50 tons) or approximately 3 percent of the total
volume (1,100 cubic yards) of waste material contain TCE at
concentrations above the LDR standard.
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The depth of excavation necessary to meet designated cleanup goals
for TCE, PAHs and arsenic is estimated at approximately 2.0 - 2.5
feet. Following excavation, confirmatory sampling and analysis
would be performed. With complete removal of the waste materials
exceeding cleanup goals, institutional controls or post-remediation
monitoring would not be required.
Alternative 4A - Physical Treatment by Soil Vapor Extraction
Capital Cost:
O & M Cost (per year):
Present-Worth Cost:
Time to Implement:
$525,900
$4,600
$596,500
Installation - less than 1 year
Operation - minimum period of 1 year
To address TCE contamination, a conventional SVE system would be
installed using vertical air extraction wells in the area where TCE
levels in soil exceed the cleanup goal of 0.8 ppm. These
extraction wells would cause the movement of soil vapor and some
ground water through the unsaturated soil towards the wells. The
soil vapors withdrawn from those wells would be sent through an
off-gas treatment system using granular activated carbon to remove
TCE. Any ground water recovered with the soil vapor would be
treated at the water treatment facility installed as part of the
ground-water remedy for OU2. Because the TCE-contaminated soil is
relatively near the surface (0-2.5 feet), a 40-mil FML would be
placed over the treatment area (1,200 square feet) to minimize
short-circuiting of air flow.
To address the PAH and arsenic contamination in the surface soil,
a 2-foot cover of imported clean soil would be placed over the
entire affected area to prevent direct-contact exposure pathways.
The upper six inches would consist of topsoil.
The treatment and cover area would be fenced, deed restrictions
instituted and long-term physical monitoring implemented. Long-
term ground-water monitoring would be performed until SVE is
completed and the cleanup goal for TCE is achieved.
Because this alternative, if selected, would result in the PAH and
arsenic contamination remaining on-Site above health-based limits,
CERCLA requires that the Site be reviewed every five years.
Based on pilot-scale SVE testing, it is estimated that one year of
operation would be required to achieve TCE cleanup goals in soil.
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Former Runoff Basin Area
Alternative IB - No Action
Capital Cost: 0
O & M Cost: 0
Present-Worth Cost: 0
Time to Implement: None
As stated above, the No Action alternative is considered as a
baseline for comparison of other alternatives. The No Action
alternative would provide no further efforts to address TCE
leaching to ground water in this area. The access controls for the
Facility (e.g., security guard and perimeter fence) would remain
active and the asphalt pavement would be left in place. The TCE
present in soil would continue to leach to ground water for
eventual extraction and treatment by the ground-water recovery well
systein installed as part of the OU2 remedy.
Because this alternative, if selected, would result in contaminated
soil remaining on-Site above health-based limits, CERCLA requires
that the Site be reviewed every five years.
There are no capital or operation and maintenance costs associated
with this No Action alternative and no time would be required for
construction.
Alternative 2B - Removal and Off-Site Disposal
Capital Cost: $1,261,800
O & M Cost: 0
Present-Worth Cost: $1,261,800
Time to Implement: Less than 1 year
This alternative involves the excavation of approximately 750 cubic
yards of TCE-contaminated soil for off-Site disposal at a RCRA
hazardous waste landfill or treatment at a RCRA hazardous waste
incinerator, depending on waste classification and LDRs. Any
nonhazardous waste would be disposed at an off-Site solid waste
landfill. Because of the depth of excavation (10 feet) and
proximity of man-made structures, the sidewalls would require
shoring with sheet piling. Underground utilities would be
relocated or replaced prior to driving sheet piling, and
construction dewatering would be performed since the ground-water
table is at a depth of 8.5 feet. Ground water recovered from
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dewatering operations would be treated at the water treatment
facility to be installed at the Facility as part of the ground-
water remedy for OU2.
Confirmatory sampling and backfilling with clean soil will complete
the remedial effort. Post remediation monitoring would not be
required.
Alternative 3B (Option 1) - Physical Treatment by Dual-Phase Soil
Vapor Extraction
Capital Cost: $544,700
0 & M Cost: Included with capital costs
Present-Worth Cost: $544,700
Time to Implement: Installation - less than 1 year
Operation - minimum period Of 1 year
This alternative involves the installation of a "dual-phase" SVE
system (DP-SVE) at the Former Runoff Basin Area because TCE
contamination is present in soil below the water table. In a DP-
SVE system, ground water and soil gas would be withdrawn through
the same extraction wells and the water and air would then be
separated for treatment. The air stream will be treated through an
off-gas treatment system using granular activated carbon. The
ground water would be treated at the water treatment facility
installed as part of the OU2 remedy. The SVE treatment area would
be approximately 55 feet by 75 feet, and the extraction wells would
extend to a depth of 15 feet. The existing asphalt cover would
provide a suitable low-permeability cover to limit short circuiting
of air flow. Ground-water monitoring would be conducted until the
DP-SVE operation is complete and the cleanup goals for TCE in soil
are achieved.
Alternative 3B (Option 2) - Physical Treatment by Soil Vapor
Extraction with Air Sparging
Capital Cost: $565,100
0 & M Cost: Included with capital costs
Present-Worth Cost: $565,100
Time to Implement: Installation - less than 1 year
Operation - minimum period of 1 year
This alternative involves the use of SVE with air sparging (SVE-AS)
to remove TCE from soil above and below the water table to the
cleanup level of 0.8 ppm. The SVE-AS alternative is similar to
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Option 1, except that air sparging would treat the saturated soil
in-situ, rather than extracting ground water for treatment at the
OU2 treatment facility. With this process, air is injected under
pressure into the soil below the water table. The air bubbles
which form traverse horizontally and vertically through the water
column. Dissolved TCE, when exposed to the air bubbles,
volatilizes into the gas phase and is carried into the vadose zone
where it is captured by the vapor extraction system. Although SVE-
AS was not part of the pilot-scale SVE test, it is estimated that
this system would operate for a period of one year to achieve the
0.8 ppm soil cleanup level for TCE.
Alternative 4B - Thermal Desorption Treatment
Capital Cost: $763,200
0 & M Cost: 0
Present-Worth Cost: $763,200
Time to Implement: Installation - less than 1 year
Treatment - several week period
This alternative involves the excavation of TCE-contaminated soil
and treatment on-Site through a transportable thermal desorption
unit. Thermal desorption is a means to physically separate VOCs
and some SVOCs from soil by heating the contaminated media between
200-1000°F and driving off water and volatile contaminants. Off-
gases would be burned in an afterburner, condensed to reduce the
volume to be disposed, or captured by a carbon treatment system.
Excavation would proceed as described in Alternative 2B and would
include the provisions for utility relocation or replacement,
excavation sidewall shoring, and construction dewatering.
The treated soil would be tested, .and, if found to meet cleanup
objectives, returned to the excavation as backfill. Soil not
meeting the cleanup objectives would be retreated.
Confirmatory sampling would be conducted to ensure that the
contaminated soil requiring treatment is excavated and processed.
Because thermal treatment involves removal of contaminants, post-
remediation monitoring would not be required.
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Industrial Drainacreway
Alternative 1C - No Action
Capital Cost: 0
0 & M Cost: 0
Present-Worth Cost: 0
Time to Implement: None
As stated above, the No Action alternative is considered as a
baseline for comparison of other alternatives. The No Action
alternative for the industrial drainageway sediment would provide
no further efforts to reduce the availability of PCBs for direct-
contact exposure by trespassers or uptake by fish which may be
consumed. It is assumed that the existing NYSDOH fish consumption
advisory for Koppers Pond and access controls placed by the current
landowner of the pond area would remain in place.
Because this alternative, if selected, would result in the
contaminants remaining on-Site above health-based levels, CERCLA
requires that the Site be reviewed every five years.
Alternative 2C - Limited Action
Capital Cost: $268,200
0 & M Cost (per year): $13,800
Present-Worth Cost: $480,100
Time to Implement: Less than 1 year
The Limited Action alternative would involve supplementing the
existing NYSDOH fish consumption advisory and access controls with
a fence erected along both banks of the drainageway and around the
perimeter of Koppers Pond. This fence would be an 8-foot high
chain-link fence of approximately 7,600 feet in total length.
Warning signs would be placed along the fence to prevent
inadvertent access. Long-term physical monitoring would be
performed to ensure the integrity of the fence.
Because this alternative would result in the contaminants remaining
on-Site above health-based levels, CERCLA requires that the Site be
reviewed every five years.
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Alternative 3C - Containment with Concrete Ditch Lining
Capital Cost: $373,400
0 & M Cost (per year): $18,700
Present-Worth Cost: $660,600
Time to Implement: Less than 1 year
Under this alternative, the 1,500 lineal feet of the industrial
drainageway from the Chemung Street outfall to the culvert beneath
the railroad tracks would be lined with concrete. The method of
liner placement would be determined during design, but could
include either formed and poured concrete or a Fabriform lining
system. The liner would be designed to conform with the existing
shape of the flow channel so as to minimize the quantity of
sediments requiring removal or regrading.
In constructing such lining, diversion pumping and necessary
erosion and sedimentation controls would be emplaced to avoid
spreading contaminated sediment to downstream locations.
Because this alternative would result in the contaminants remaining
on-Site above health-based levels, CERCLA requires that the Site be
reviewed every five years.
Alternative 4C - Removal and Off-Site Disposal
Capital Cost: $365,600
0 & M Cost: 0
Present-Worth Cost: $365,600
Time to Implement: Less than 1 year
This alternative would involve the removal of sediment containing
PCB concentrations above the cleanup objective of 1.0 ppm from the
industrial drainageway for off-Site disposal in a permitted
industrial waste landfill. The volume of sediment to be removed is
estimated at 1,100 cubic yards. During excavation, diversion
pumping and necessary erosion and sedimentation controls would be
emplaced to avoid spreading contaminants to downstream locations.
Following confirmatory sampling and analysis, the flow channel
would be reshaped using clean off-Site borrow, as needed. Erosion
controls (i.e., erosion control matting) would be emplaced before
redirecting water flows through the channel. With removal of
contaminants to cleanup goals, access controls or post-remediation
monitoring would not be required.
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SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
In accordance with the NCP, a detailed analysis of each remedial
alternative is required. The detailed analysis consists of an
assessment of the individual alternatives against each of nine
evaluative criteria set forth in the NCP and a comparative analysis
focusing upon the relative performance of each alternative against
those criteria.
The following "threshold" criteria must be satisfied by any
alternative in order to be eligible for selection:
1. Overall protection of human health and the environment ad-
dresses whether or not a remedy provides adequate protection
and describes how risks posed through each exposure pathway
are eliminated, reduced, or controlled through treatment,
engineering controls, or institutional controls.
2. Compliance with ARARs addresses whether 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.
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
refers to the anticipated performance of the treatment
technologies a remedy may employ.
5. Short-term effectiveness addresses the period of time needed
to achieve protection and any adverse impacts on human health
and the environment that may be posed during the construction
and implementation of the remedy.
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6. ImplemerztaJbility refers to 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
(O&M) costs, both translated to a present-worth basis. The
detailed analysis evaluates and compares the cost of the
respective alternatives, but draws no conclusion as to the
cost-effectiveness of such alternatives. Cost-effectiveness
is determined in the remedy selection phase, when cost is
considered along with the other balancing criteria.
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 reports and Proposed Plan, the State concurs, opposes,
or has no comment on the preferred alternative at the present
time.
9. Community acceptance refers to the public's general response
to the alternatives described in the Proposed Plan and the RI
and FS reports. Factors of community acceptance to be
discussed include support, reservation, and opposition by the
community.
A comparative analysis of the alternatives evaluated for each of
the three areas to be remediated, which is based upon the
evaluation criteria noted above, is provided below.
Disposal Area F
Overall Protection of Human Health and the Environment
All of the alternatives proposed, with the exception of the No
Action alternative, would provide adequate protection of human
health by eliminating risks posed by the exposure to surface soils.
Additionally, such alternatives address soil contamination as
source control measures for complementing the OU2 ground-water
remedy selected by the EPA for the protection of human health.
Alternatives 2A, Option 1. (Containment with Asphalt Cover) and
Option 2 (Containment with Low-Permeability Cap) would provide
engineering controls (capping) to reduce the risk of exposure to
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contaminated soil and institutional controls (fencing, deed
restrictions and/or monitoring) to ensure cap integrity.
Alternative 3A (Removal and Off-Site Disposal) would eliminate the
risk of exposure to contaminated surface soil. It would also be an
effective source control measure in addressing TCE contamination in
ground water.
Alternative 4A (Physical Treatment Using SVE) is a source control
remedy to address TCE, but includes a capping component (soil
cover) to address risks posed by exposure to surface soil.
Compliance with ARARs
The principal action-specific ARARs for Disposal Area F include
RCRA requirements for the identification, transportation, treatment
and disposal of hazardous waste (40 CFR Parts 261 thru 264 and Part
268) and the corresponding NYS hazardous waste requirements.
Additionally, Federal and NYS requirements for air emissions are
action-specific ARARs (6NYCRR Parts 200, 201, 211, 219 and 257; NYS
Air Guide-1) because of the potential for gaseous and particulate
air emissions to be generated during excavation and transportation
of contaminated soil and SVE off-gassing.
As the source control and final aquifer restoration operable unit
for the Site, the principal chemical-specific ARARs for the aquifer
are Federal and NYS Maximum Contaminant Levels (MCLs) and non-zero
Maximum Contaminant Level Goals (MCLGs). The cleanup goal for TCE-
contaminated soil is established to prevent the leaching of TCE to
ground water. It is anticipated that such source control measures,
in combination with the OU2 ground-water remedy, would achieve MCLs
and MCLGs within the aquifer.
No chemical- or location-specific ARARs address the soil
contaminated with PAHs and arsenic at Disposal Area F.
Alternative 1A would not achieve the cleanup goals for contaminated
soils and therefore would not comply with the chemical-specific
ARARs for ground water. Since this alternative involves no
remedial activities, it does not trigger any location- or action-
specific ARARs.
Alternative 2A, Options 1 and 2, would not initially comply with
the chemical-specific ARARs for ground water because contaminants
at concentrations above the cleanup levels would remain in the
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soil. However, such options would reduce infiltration of
precipitation and impede the leaching of contaminants to the
underlying ground water. Therefore, ARARs may be achieved over
time through natural attenuation (i.e., processes of volatilization
and biodegradation) and by operation of the OU2 ground-water
recovery wells and treatment system. Those ground-water recovery
wells will be located directly downgradient of the contaminant
plume originating at Disposal Area F. The low-permeability cap
(Option 2) would be better than the asphalt pavement (Option l) at
preventing infiltration from occurring. Long-term ground-water
monitoring would be implemented to comply with RCRA requirements.
Alternative 3A effectively removes TCE-contaminated soil to cleanup
levels. It would also be an effective source control measure for
complimenting the OU2 ground-water remedy and achieving ground-
water ARARs more quickly. The excavated waste materials would be
classified to meet RCRA action-specific ARARs and the corresponding
NYS hazardous waste regulations for the identification,
transportation, treatment and disposal of hazardous waste.
Additionally, because of the potential for gaseous and particulate
air emissions to be generated during the excavation or
transportation of contaminated soils, provisions would be included
to comply with Federal and State action-specific ARARs and guidance
for air emissions.
Alternative 4A would achieve TCE cleanup levels in soil over time
(at least one year) and therefore, be an effective source control
measure for complimenting the OU2 ground-water remedy. Effective
source control would enable the ground-water remedy to comply with
ground-water ARARs more quickly. Long-term ground-water monitoring
would be performed to comply with RCRA requirements. Provisions
would also be included to comply with all State and Federal ARARs
for air emissions, including the action-specific ARARs and guidance
for SVE off-gassing.
Long-Term Effectiveness and Permanence
Alternative 1A would not provide long-term effectiveness because
the contamination is not removed, treated or contained. Therefore,
the current risks posed by exposure to such contamination remains
the same.
Alternative 2A would provide limited long-term effectiveness
because institutional controls and monitoring would be required to
maintain the integrity of the asphalt cover or low permeability
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cap. Deed restrictions would be filed to prohibit development of
land in this area. Long-term physical monitoring and maintenance
would be required to ensure cap integrity. Long-term ground-water
monitoring would be required to assess effectiveness of the remedy
as a source control measure for complimenting the OU2 ground-water
remedy and compliance with ground-water ARARs.
Alternative 3A would provide long-term effectiveness because the
contaminants are permanently removed from the Site. It would
eliminate the risks posed by direct-contact with soil and would be
an effective and permanent source control measure for addressing
ground-water contamination at Disposal Area F. No post-remediation
physical monitoring would be required.
Alternative 4A would provide limited long-term effectiveness from
direct contact with PAHs and arsenic because physical monitoring
and maintenance would be required to maintain the integrity of the
soil cover. However, the alternative would be effective as a
source control measure because TCE would be removed from the soil.
Ground-water monitoring would be performed during the period of SVE
treatment.
Reduction of Toxicity. Mobility, or Volume Through Treatment
All of the alternatives other than the No Action alternative would
provide some degree of reduction of the toxicity, mobility and
volume through treatment. Alternative 2A, Options 1 and 2, rely
solely on containment to reduce contaminant mobility. However,
they would not reduce the toxicity or volume of the waste.
Alternative 4A would effectively reduce the toxicity, mobility and
volume of TCE by treatment, but it only reduces the mobility of the
PAHs and arsenic in contaminated soil by relying on containment.
Alternative 3A reduces the toxicity, mobility or volume of the TCE,
PAHs and arsenic by its removal and off-Site treatment and
disposal.
Short-Term Effectiveness
The No Action and containment alternatives (Alternatives 1A and 2A)
have minimal potential for adverse short-term impacts because
workers would not handle affected soil while performing remedial
activities. Potential short-term impacts are associated with the
alternatives for removal and off-Site disposal and physical
treatment by SVE (Alternatives 3A and 4A) , as a result of the
direct contact of soil by workers and the potential for vapor
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and/or particulate emissions. Such impacts would be addressed
through worker health and safety controls and air pollution
controls such as water sprays, dust suppressants, and tarps for
covering truck loads during transportation. Additionally, a
community air-monitoring program would be utilized to ensure public
safety. It is estimated that all of the alternatives could be
easily completed in one construction season. The SVE system, once
constructed, would be operated for a period of at least one year to
remediate soil to established cleanup levels.
Implementability
Each alternative would involve commonly used construction
techniques and would be implementable from an engineering
standpoint. Each alternative would also utilize commercially
available products and accessible technologies. The SVE treatment
alternative is performed in the ground and, therefore, is more
difficult to control and assess. The estimate of one-year for the
removal of 95 percent of TCE mass is based on limited pilot-scale
testing and, therefore, the estimate could be longer in duration
than the actual time period necessary to attain the established TCE
cleanup goal (0.8 ppm) in soil. SVE would also require more
extensive design than the other alternatives. RCRA permitted
facilities are readily available for the off-Site disposal of
hazardous wastes.
Cost
The capital, present-worth and O&M costs of the alternatives for
Disposal Area F are summarized in Table 8. The present-worth of
the remedial alternatives, including capital costs and, where
appropriate, 30-year O&M costs range from $0 to $1,114,000. The No
Action alternative involves no costs. The costs estimated for the
Containment with Asphalt -Cover, Removal and Off-Site Disposal and
Physical Treatment by SVE alternatives are all comparable, ranging
between $514,000 and $620,000. The costs for containment and SVE
alternatives depend to some degree on the volume of affected
materials, but the range in their projected costs are much less
sensitive to volume than the Removal and Off-Site Disposal
alternative. The costs associated with the removal alternative
($619,600) are directly proportional to the quantity of affected
material requiring treatment. While efforts were made to perform
a comprehensive study at Disposal Area F, such efforts did not
fully delineate the horizontal extent of the affected area. Hence,
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there is the potential for the quantity of affected material, and
therefore the cost of this alternative, to increase significantly.
The incineration costs associated with the Removal and Off-Site
Disposal alternative is $63,000 and is based on an estimated volume
of 32 cubic yards (50 tons), or approximately 3 percent, of the
total volume (1,100 cubic yards) of waste material containing TCE
at concentrations exceeding the treatment standard of 6.0 ppm.
The costs associated with the containment alternatives are $514,100
for the asphalt cap and $1,114,000 for the low-permeability cap.
Those costs would be somewhat sensitive to a larger surface area of
affected material. However, the area proposed to be covered by
asphalt would extend well beyond the currently defined limit of
Disposal Area F, and therefore the costs associated with an asphalt
cover are not anticipated to change significantly. The larger area
of asphalt covering is proposed as a practical matter because the
asphalt cap would be extended to the existing asphalt parking lot
at the Facility.
State Acceptance
The State of New York concurs with the selected remedy.
Community Acceptance
All comments submitted during the public comment period were
evaluated and are addressed in the attached Responsiveness Summary
(Appendix V).
Former Runoff Basin Area
Overall Protection of Human Health and the Environment
No exposure pathways under current or future industrial site use
were associated with direct-contact pathways for the Former Runoff
Basin Area. For the restoration of the ground-water aquifer as a
safe drinking-water source, all of the alternatives, with the
exception of the No Action alternative, would provide adequate
protection of human health as source control measures for
addressing ground-water contamination.
Alternatives 2B (Removal and Off-Site Disposal) and 4B (Thermal
Desorption Treatment) would remove the contaminated soil above and
. 43
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below the water table which is accessible with conventional
material-handling equipment. However, any contamination in the
soil in close proximity to, or directly beneath, building
foundations in the Former Runoff Basin Area, if present, would
continue to leach to ground water.
Alternative 3B (Physical Treatment by Dual-Phase SVE or SVE with
AS) would be designed to effectively remove contaminants from soil
in all affected areas, including those near or beneath building
foundations, to below cleanup objectives.
Compliance with ARARs
The principal action-specific ARARs for the Former Runoff Basin
Area are RCRA requirements regarding the identification,
transportation, treatment and disposal of hazardous waste (40 CFR
Parts 261 thru 264 and Part 268) and the corresponding NYS
hazardous waste requirements. Additionally, Federal and NYS
requirements for air emissions are action-specific ARARs or
guidance (6NYCRR Parts 200, 201, 211, 219 and 257; NYS Air Guide-1)
because of the potential for gaseous and particulate air emissions
to be generated during excavation, transportation and/or waste feed
preparation of contaminated soil and SVE off-gassing.
As the source control and final aquifer restoration operable unit
for the Site, the principal chemical-specific ARARs for ground
water are Federal and NYS MCLs and non-zero MCLGs. The cleanup
goal for TCE-contaminated soil is established to prevent the
leaching of TCE to ground water. Such source control measures, in
combination with the OU2 ground-water remedy, will be for achieving
MCLs and MCLGs.
Alternatives 2B (Removal and Off-Site Disposal) and 4B (Thermal
Desorption Treatment) would be somewhat effective in removing TCE-
contaminated soil to cleanup levels, including the saturated soil
affected below the water table, as they are source control measures
for attainment of chemical-specific ground-water ARARs. However,
these alternatives would not address soil contamination in close
proximity to, and directly under, the building foundations at the
Former Runoff Basin Area. Such contamination, if present, would
remain in place and continue to leach to ground water.
Alternative 3B (Physical Treatment by Dual-Phase SVE or SVE with
AS) would effectively remove TCE from all affected soil, including
the soil in close proximity to, or directly under, the building
44
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foundations at the Former Runoff Basin Area. Extraction wells
could be positioned to remove soil vapors and ground water from
those areas for treatment, resulting in more effective source
control and, ultimately, a shorter period of time for compliance
with ground-water ARARs.
For Alternatives 2B and 4B, RCRA action-specific ARARs and the
corresponding NYS hazardous waste regulations would be met for the
identification, transportation, treatment and disposal of hazardous
waste.
Additionally, because gaseous and/or particulate air emissions
could be generated during the excavation, waste feed preparation
and transportation of contaminated soil or the off-gassing during
SVE operations, provisions would be included for Alternatives 2B,
3B and 4B to comply with Federal and NYS action-specific ARARs and
guidance for air emissions.
Long-Term Effectiveness and Permanence
Each of the alternatives proposed for the Former Runoff Basin Area,
except the No Action alternative, would provide long-term
effectiveness and permanence by removing the contaminants from the
soil. The alternatives for removal with off-Site disposal and
thermal desorption treatment (Alternatives 2B and 4B) would provide
permanent remedies, in that excavated soils would be permanently
removed from the Site or treated on Site. However, these
alternatives may not be effective at addressing any contamination,
if present, in the soil near or beneath building foundations. The
SVE treatment alternatives (Alternative 3B, Options 1 and 2) would
provide permanent remedies for the contaminated soil both above and
below the water table, including those areas near, and potentially
below, building foundations.
Reduction of Toxicity. Mobility, or Volume Through Treatment
With the exception of the No Action alternative, each of the
alternatives would reduce the toxicity, mobility, and volume of TCE
in the soil at the Former Runoff Basin Area through treatment.
Short-Term Effectiveness
The No Action alternative would not result in any adverse short-
term impacts. Potential short-term impacts would be associated
with the other alternatives as a result of the direct contact with
45
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soil by workers and/or the generation of vapor and particulate air
emissions. Such impacts would be addressed through worker health
and safety controls, air pollution controls such as water spraying,
dust suppressants, and tarps for covering waste during loading,
transporting and waste feed preparation. The Thermal Desorption
Treatment alternative is anticipated to have the potential for most
significant releases of airborne contaminants during remediation.
Site and community air monitoring programs would be implemented
when conducting such activities to ensure protection of workers and
the nearby community. It is estimated that all of the alternatives
could be completed within one construction season.
Implementability
All of the alternatives would involve commonly used construction
practices and would be implementable from an engineering
standpoint. Each alternative would utilize commercially available
products and accessible technologies.
The SVE treatment alternatives (Alternative 3B, Options 1 and 2)
and Thermal Desorption Treatment alternative (Alternative 4B)
require more extensive engineering design. The estimate of one-
year for the removal of 95 percent of TCE mass is based on limited
pilot-scale testing and, therefore, the estimate could be longer in
duration than the actual time period necessary to attain the
established TCE cleanup goal (0.8 ppm) in soil, especially since
dual-phase SVE and air sparging were not part of the SVE tests.
Commercial-scale thermal desorption units exist and are in
operation.
Cost
The capital, present-worth and O&M costs of the alternatives
described for the Former Runoff Basin Area are summarized in Table
8. The present worth of such alternatives, including capital costs
and, where appropriate, 30-year O&M costs, range between $0 and
$1,261,800. There are no costs associated with the No Action
alternative. The present-worth of the two SVE treatment
alternatives are estimated at $544,700 for Dual-Phase SVE (Option
1) and $565,100 for SVE with air sparging (Option 2). The thermal
desorption treatment alternative is somewhat more expensive at
$763,200. The highest costs ($1,261,800) are associated with the
removal and off-site disposal alternative, resulting mostly from
costs related to incineration of TCE waste materials exceeding the
LDR treatment standard of 6.0 ppm for TCE. It is estimated that
46
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approximately 33 percent of the 750 cubic yards of TCE-affected
soil will be incinerated at a cost of $470,000.
State Acceptance
The State of New York concurs with the selected remedy.
Community Acceptance
All comments submitted during the public comment period were
evaluated and are addressed in the attached Responsiveness Summary
(Appendix V).
Industrial Drainageway
Overall Protection of Human Health and the Environment
Alternative 1C (No Action) is not protective of human health
because it does not eliminate, reduce or control the contamination
at the Site.
Alternative 2C (Limited Action) provides some level of protection
at the industrial drainageway and Koppers Pond by establishing
physical and institutional controls (e.g., fencing and warning
signs) to reduce risks posed by ingestion of contaminated sediment
and consumption of fish. It is also assumed that the NYSDOH fish
advisory and access controls placed by current property owners
would remain in place.
Alternative 3C (Containment with Concrete Lining) is protective.
It would reduce the availability of contaminants for fish uptake in
Koppers Pond and, along with such controls as fencing, warning
signs and the existing NYSDOH health advisory, reduce the risk
posed from fish consumption.
Alternative 4C (Removal and Off-Site Disposal) is protective. It
would eliminate the risk of direct exposure to contaminated
sediment in the industrial drainageway and minimize the
availability of PCBs to aquatic life, thereby reducing the risk
posed by fish consumption.
47
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Compliance with ARARs
The principal location-specific ARARs for the industrial
drainageway would include 40 CFR Part 6, Appendix A - Executive
Order 11990 for the protection of wetlands, and NYS Freshwater
Wetlands Act, Article 24 and Article 71, Title 23 requiring a
wetlands assessment and restoration plan for wetlands impacted by
contamination or remediation.
The EPA and U.S. Army Corps of Engineers regulations under the
Clean Water Act which, in part, regulates the discharge of dredged
or fill materials to the waters of the United States constitute
important action-specific ARARs. Additionally, RCRA regulations
regarding the identification, transportation, treatment and
disposal of hazardous waste (40 CFR Parts 261 thru 264 and Part
268), and the corresponding NYS hazardous waste requirements may be
action-specific ARARs for this alternative, depending on waste
classification. Because of the potential for gaseous and/or
particulate air emissions to be generated during excavation and
transportation of contaminated sediments, Federal and NYS
requirements for air emissions would also be action-specific ARARs
(e.g., 6NYCRR Parts 200, 201, 211, 219 and 257; NYS Air Guide-1).
Location-specific ARARs for the protection, delineation and
assessment of wetlands would be achieved, as appropriate, under all
of the alternatives proposed for the industrial drainageway, except
the No Action alternative. Alternative 4C would comply with RCRA
action-specific ARARs and corresponding NYS hazardous waste
regulations for identification, transportation, treatment and
disposal of hazardous waste. Finally, because of the potential for
gaseous and particulate air emissions to be generated during the
excavation and transportation of contaminated sediments,
Alternative 4C would have to comply with Federal and State action-
specific ARARs and guidance for air emissions.
Long-Term Effectiveness and Permanence
Alternative 1C (No Action) would not provide for long-term
effectiveness and permanence. Over time, the PCB concentrations
may only change as a result of natural sediment deposition
processes, assuming no additional sourcing of PCB contamination to
the industrial drainageway and Koppers Pond.
Alternative 2C (Limited Action) would provide marginal long-term
effectiveness in that it restricts inadvertent access, but it does
48
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not eliminate the potential for trespassers and the impact on the
Pond and the related aquatic life.
Alternative 3C would provide long-term effectiveness in minimizing
the availability of PCB-contaminated sediment for direct human
contact exposure and for availability to aquatic life. The lining
would be designed for resistance to erosion and long-term
stability. Long-term physical monitoring would be required to
ensure the integrity of the liner.
Alternative 4C would permanently eliminate the PCB-contaminated
sediments in the industrial drainageway for direct human contact
exposure or availability to aquatic life.
Reduction of Toxlcity. Mobility, or Volume Through Treatment
With the exception of the No Action and Limited Action
alternatives, each alternative would reduce the toxicity, mobility,
and volume of contaminants in the sediment through treatment or
containment.
Short-Term Effectiveness
No Action and Limited Action alternatives would not require workers
to handle contaminated sediment and would not involve construction
work in a waterway. Potential short-term impacts would be
associated with the alternatives for containment with concrete
lining and removal and off-Site disposal. The containment option
would involve more limited excavation and handling, but it would
also include construction work in the drainageway. The removal
alternative represents the most significant potential short-term
impact because it would involve sediment excavation from within a
waterway. The inherent impacts to workers would be addressed by
compliance with a health and safety plan, including an air
monitoring plan. Additionally, a community air-monitoring program
would be implemented to monitor and control airborne particulates
and vapors for ensuring public safety. Bypass pumping and erosion
and sedimentation controls would also be necessary. It is
estimated that these alternatives could be completed in one
construction season.
Implementability
All of the alternatives would involve commonly used construction
practices and would be implementable from an engineering
49
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standpoint. With the exception of No Action, all of the
alternatives would require access to the properties for varying
lenghts of time. Additionally, the containment and removal
alternatives would require permits by the U.S. Army Corps of
Engineers. These access and permitting issues could delay
implementation.
Cost
The capital, present-worth and O&M costs of the alternatives
described for the industrial drainageway are summarized in Table 8.
The present-worth of such alternatives, including capital and 30-
year O&M costs, where appropriate, range from $0 to $660,000.
There are no costs associated with the No Action alternative. The
present-worth cost for the Limited Action alternative is $480,100,
with an estimated capital cost of $152,000 for the 7,600 feet of
fencing. The Removal and Off-Site Disposal alternative has a
present-worth cost of $365,600. The most costly alternative
proposed is the Containment with Concrete Lining alternative, with
a present-worth of $660,000.
State Acceptance
The State of New York concurs with the selected remedy.
Community Acceptance
All comments submitted during the public comment period were
evaluated and are addressed in the attached Responsiveness Summary
(Appendix V).
SELECTED REMEDY
After careful consideration of all reasonable alternatives, as well
as all comments provided by interested parties during the public
comment period, the EPA has selected Alternative 3A (Removal and
Off-Site Disposal) for the contaminated soil at Disposal Area F;
Alternative 3B (Physical Treatment by SVE) for the contaminated
soil at the Former Runoff Basin Area; and Alternative 4C (Removal
and Off-Site Disposal) for the contaminated sediment at the
industrial drainageway. Said alternatives are appropriate for OU3
because they best satisfy the requirements of CERCLA and the NCP's
nine evaluation criteria.
50
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The combined present-worth cost for the three remedies selected for
OU3 ranges between $1,530,000 and $1,550,000, depending on whether
the Physical Treatment by SVE alternative for the Former Runoff
Basin Area is ultimately designed as the Dual-Phase SVE (Option 1)
or the SVE with AS (Option 2).
The Removal and Off-Site Disposal alternative is the most effective
and permanent source control measure for TCE contamination at
Disposal Area F. As an effective source control, such a remedy
will compliment the ground-water remedy selected for OU2 and
achieve the compliance with ARARs within the aquifer more quickly
than the other remedial alternatives evaluated. Additionally, no
long-term physical monitoring and maintenance will be necessary.
The other alternatives would require such monitoring and
maintenance to ensure the integrity of the asphalt cover, low-
permeability cap, or soil cover and the institutional controls.
The Physical Treatment by SVE alternative is the most cost-
effective and protective remedy for the Former Runoff Basin Area.
It is also the only alternative which will address the contaminated
soil near building foundations and underground utilities.
The Removal and Off-Site Disposal alternative is the most cost-
effective and permanent remedy for addressing the PCB contaminated
sediment in the industrial drainageway and limiting the
availability of PCBs for uptake by fish and other aquatic life in
Koppers Pond. However, for any cleanup at the industrial
drainageway to be effective and permanent, the unauthorized
releases to the industrial drainageway must be eliminated. Those
releases are suspected to be contributing to the sediment
contamination in the industrial drainageway and Koppers Pond.
Without the elimination of such releases, the sediment in the
industrial drainageway may be recontaminated with metals to levels
which may, ultimately, result in an unacceptable human health risk.
The selection of this alternative assumes that all future permitted
discharges from the Facility will meet the discharge limits
established by the NYS permitting authorities under the State
Pollutant Discharge Elimination System program.
In light of the above, and as a practical matter, the preferred
alternative for removal and off-Site disposal will be implemented
after the NYSDEC completes its investigation as to the source (s) of
the unauthorized releases to the industrial drainageway, and such
releases are eliminated. The EPA and the NYSDEC will ensure that
those sources, when identified, are addressed. In addition, once
51
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the remediation is conducted, the EPA and the NYSDEC will endeavor
to ensure that the permanence of that cleanup effort is not
impacted by any future unauthorized discharges to the industrial
drainageway.
Specifically, the preferred alternatives will involve the
following:
Disposal Area F
Performance of additional sampling and analysis prior to
remedy implementation to delineate the horizontal and vertical
extent of contaminated soil and waste materials and further
characterize and classify such materials for off-Site disposal
and/or treatment.
Excavation of all affected soil and waste material containing
TCE, PAHs and arsenic at concentrations above the cleanup
objectives established for such contaminants.
Transportation of affected soil to permitted waste management
facilities (e.g., RCRA hazardous waste incinerator, RCRA
hazardous waste landfill or industrial landfill).
Performance of confirmatory sampling and backfilling of
excavation with clean soil.
Former Runoff Basin Area
Design and testing an enhanced SVE system using either dual-
phase or air sparging, depending on site-specific
characteristics, to extract VOCs above and below the water
table for treatment.
Construction and operation of the enhanced SVE treatment
system to meet the RAOs established in this ROD. The exact
location and depth of the SVE wells will be determined during
remedial design and testing.
Transportation (piping) and treatment of extracted ground
water to the water treatment facility installed as part of the
ground-water remedy for OU2 for treatment.
52
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Implementation of a monitoring program to assess the
effectiveness of SVE treatment in attaining TCE RAOs in soil
and Federal and State drinking water standards for ground
water.
Industrial Drainageway
Excavation of sediments containing PCBs from the industrial
drainageway above the cleanup level of 1.0 part per million
for PCBs.
Placement and operation of diversion pumping and necessary
erosion and sedimentation controls during excavation.
Performance of confirmatory sampling.
Transportation of contaminated sediment to permitted waste
management facilities for disposal.
Reshaping the flow channel using clean soil, as needed.
Additionally, the EPA believes that further ecological
investigations are warranted at Koppers Pond and will therefore
conduct a supplemental study in that area to assess the need for
remedial action.
Ground-Water Remediation
As stated in the 1990 ROD for OU2, the final remediation goals for
the Newtown Creek Aquifer are Federal and State drinking water
standards (i.e., ARARs), based primarily upon the classification of
the ground water as a potential drinking water source. The ground-
water remedy selected in the 1990 ROD was designated by the EPA as
an interim remedy because it provided for a source of drinking
water which met such ARARs at the tap. The EPA estimated that said
remedy would also attain all ARARs for the portion of the Newtown
Creek Aquifer in the vicinity of the KAW over a period of
approximately 30 years once source control measures were in place.
Hence, the 1990 ROD designated OU3 to address source control at the
Westinghouse Facility and make a determination as to any necessary
final remedy for aquifer restoration.
Based on the findings of the RI for OU3, the EPA has determined
that no further ground-water treatment beyond that specified for
the OU2 interim ground-water remedy is necessary as a response
53
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action for OU3. The interim remedy, as set forth in the 1990 ROD
and the approved remedial design report for OU2, will therefore
become the final remedy for restoring the Newtown Creek Aquifer to
its beneficial use as a drinking water aquifer at the Site.
Although this remedy is being designated as the final ground-water
remedy for attaining all Federal and State drinking water standards
in the Newtown Creek Aquifer, the EPA recognizes that achieving
such standards may not be possible even with source control
measures in place because of the difficulties associated with
removing ground-water contaminants to drinking water standards.
Therefore, the EPA will carefully monitor the performance of the
remedy and ground-water quality to determine if it is successful in
attaining the Federal and State drinking water standards.
It should be noted that the EPA's designation of the interim remedy
as the final aquifer restoration remedy for the Site in this ROD
should not be construed to imply that further modification to such
remedy or any additional response actions for restoring the Newtown
Creek Aquifer to drinking water standards can not be considered by
the EPA in the future.
STATUTORY DETERMINATIONS
As previously noted, CERCLA mandates that a remedial action must be
protective of human health and the environment, cost-effective, and
utilize permanent solutions and alternative treatment technologies
or resource recovery technologies to the maximum extent
practicable. CERCLA also establishes a preference for remedial
actions which employ treatment to reduce permanently and
significantly the volume, toxicity, or mobility of the hazardous
substances, pollutants, or contaminants at a site. CERCLA further
specifies that a remedial action must attain a degree of cleanup
that satisfies ARARs under Federal and State laws, unless a waiver
can be justified.
For the reasons discussed below, the EPA has determined that the
selected remedy meets the requirements of CERCLA.
Protection of Human Health and the Environment
The selected remedy is protective of human health and the
environment. The health risks associated with the contaminated
soil at Disposal Area F and the contaminated sediment in the
54
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industrial drainageway will be eliminated by the removal and off-
Site disposal of such media. The removal of contaminants from the
soil at the Former Runoff Basin Area will address health risks
associated with the ground-water exposure pathway by preventing the
leaching of such contaminants to ground water. The removal of
contaminated sediment will also reduce the availability of PCBs for
uptake by fish in the industrial drainageway and Koppers Pond,
thereby reducing the health risk associated with fish consumption.
Compliance with ARARs
The selected remedy will be in compliance with all ARARs. Action-
specific ARARs identified for the selected remedy includes the RCRA
regulations for identification, transportation, and the off-Site
disposal and treatment of hazardous wastes (40 CFR Parts 261-264
and 268) and the corresponding NYS hazardous waste requirements;
and air requirements for excavation of soils and operation of the
SVE system at the Former Runoff Basin Area (6NYCRR Parts 200, 201,
211, 219 and 257; NYS Air Guide-1).
Location-specific ARARs identified for the selected remedy at the
industrial drainageway include 40 CFR Part 6, Appendix A -
Executive Order 11990 for the protection of wetlands, NYS
Freshwater Wetlands Act, Articles 24 and 71, Title 23 (which
requires a wetlands assessment and restoration plan), and the EPA
and U.S. Army Corps of Engineers regulations under the Clean Water
Act which regulates the discharge of dredged or fill materials to
waters of the U.S.
Chemical-specific ARARs for ground water are the Federal and State
MCLs and nonzero MCLGs. The source control measures at Disposal
Area F and the Former Runoff Basin, in combination with the ground-
water remedy selected for OU2, will allow compliance with all
ground-water ARARs for that portion of the aquifer within the
'hydraulic influence of the pumping wells at the Westinghouse
Facility. Additionally, the combined effect of such source control
measures and operation of the OU2 ground-water remedy will also
help accelerate the attainment of the chemical-specific ARARs
within the aquifer between the Westinghouse Facility and the KAW.
In the 1990 ROD, the EPA estimated a 30-year period for aquifer
restoration within the vicinity of the KAW after source control
measures are in place.
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Cost-Effectiveness
Each of the alternatives underwent a detailed cost analysis to
develop costs to the accuracy of +50 to -30 percent. In that
analysis, capital and O&M costs have been estimated and used to
develop present worth costs. In present-worth analysis, annual
costs were calculated for thirty years (estimated life of an
alternative) using a five percent discount rate and based on 1996
costs.
The selected alternative for the Former Runoff Basin Area and the
industrial drainageway are the least costly remedies that achieve
all the goals of the response actions. The estimated cost of the
selected remedy for Disposal Area F is also less than the other
alternatives, with the exception of the Containment with Asphalt
Cover alternative. However, the selected Removal and Off-Site
Disposal remedy provides a greater degree of permanence.
Additionally, the containment alternative would require
institutional controls and monitoring to ensure the integrity of
the asphalt cover.
Utilization of Permanent Solutions and Alternative Treatment
Technologies to the Maximum Extent Practicable
The selected remedy utilizes permanent solutions and treatment
technologies to the maximum extent practicable. As stated above,
the removal and off-Site disposal of contaminated soil and sediment
provides the greater degree of permanence than the other
alternatives evaluated. Additionally, the treatment of VOCs at the
Former Runoff Basin Area by SVE is also a permanent solution.
Overall, the selected remedy is considered to include the most
appropriate solutions to contamination addressed in OU3 because
they provide the best balance of trade-offs among the alternatives
with respect to the nine evaluative criteria.
Preference for Treatment as a Principal Element
The selected remedy satisfies the statutory preference for
treatment to reduce the toxicity, mobility, or volume of the
contaminants at the Site.
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DOCUMENTATION OF SIGNIFICANT CHANGE
There are no significant changes from the preferred alternatives
presented in the Proposed Plan.
57
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APPENDIX I
FIGURES
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WESTINGHOUSE
FACILITY
KENTUCKY
AVENUE
WELL
SITE MAP
FIGURE 1
SULLIVAN STREET WELLS
1.5 MILES SOUTH OF MC CAINS BLVD
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Soil Pile
OUTFALL OOIW
OU1FAU- OOII
IKLAIVINI \
- . 'MW JO
/' uw-is
Area Southwest of West Parking Lot
EXPUNATION
ILNCt
HHOH.HIY UOUNCkMtT
UHAIH UNI
OPIN CHA1INC MAMIIOt£ LOCAIION
tWNUOU LOCAIION
SUHt'ACC WAUK RUNOII DUMH IOC* NUN
U(]M||OH|HC WILL LOCAIION AND NUUUIK
A/1CAS
PKL\K>USLr IDCNIDIIO HOILNIIAL SOUHCl
AHtAS
AUOIIIUNAI eUllNIIAl SOUKCt AHIAS
OB HIHUIIIIU OUIIAIl
Mollified liuiu I'liilip, I9<>5
FIGURE 2
WESTINGHOUSE FACILITY
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EXPLANATION
SAMPll NUMBCK AKU
APPROXIUAlC LUCAllOrl
Koppers Pond
ModifieJ from Burlington Environmental, 199S
KlNlLICKT AVIMUC WELL
FIGURE 3 INDUSTRIAL DRAINAGEWAY AND POND
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APPENDIX II
TABLES
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KENTUCKY AVENUE WELLFIELD SITE - OPERABLE UNIT 3
CHEMICAL CONTAMINANTS OF CONCERN (COCs)'
SURFACE WATER
SEDIMENTS
FISH
Acetone
Trichloroethylene
alpha-BHC
beta-BHC
Antimony
Arsenic
Banum
Cadmium
Mercury
Benzo(a)anthracene
Benzo(b)fluoranthene
Benzo(a)pyrene
Dibenz(a.h)anthracene
Aroclor-1248
Aroclor-1254
Aroc tor-1260
Arsenic
Beryllium
Cadmium
Manganese
Thallium
Zinc
Arock>M254
Arsenic
SURFACE SOILS
Soil Pile
Area Southwest of the MW- 10 Area
West Partcinp Lot
Fluoride Disposal Area »1 Fluoride Disposal Area 02
Benzo(a)anthracene
Benzo(b)fluoranthene
Benzo(a)pyrene
lndeno(l ,2.3-ed)pyrene
Aluminum
Arsenic
Barium
Manganese
Nickel
Vanadium
Znc
Disoosal Area F
Mnonasium Chin Burial
Trichloroethylene Benzo(a)pyrene
Benzo
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TABLE 1
KENTUCKY AVENUE WELLFIELD SITE - OPERABLE UNIT 3
CHEMICAL CONTAMINANTS OF CONCERN (COCs)'
SUBSURFACE SOILS
Soil Piles
Not sampled
Former Coal Pile
Benzo(a)pyrene
Arocior-1242
Aroctor-1254
Aluminum
Antimony
Arsenic
anum
erytlium
Cadmium
Manganese
Nickel
Vanadium
Area Southwest of the
West Parking Lp;
Aroclor-1254
Aluminum
Arsenic
Barium
Beryllium
Manganese
Nickel
Thallium
Vanadium
Former Runoff Bas,n
Triehloroethylene
Dibenzofuran
Benzo(a)anmracene
Benzo(b)fluoranthene
Beruo(a)pyrene
Ruoranthene
Indenofl .2.3-cd)pyrene
Pyrene
ArociOf-1242
Aroctor-1254
Aluminum
Antimony
Arsenic
Cadmium
Manganese
Vanadium
Zinc
MW- 10 Area
Benzo(a)pyrene
Aroclor-1254
Aroctor-1260
Aluminum
Arsenic
Barium
Cadmium
Manganese
Nickel
Vanadium
Disposal Area F
Trichtoroethylene
Benzo(a)anmracene
Benzo(b)fluoranthene
Benzo(a)pyrene
Dibenz(a.h)anthracene
lndeno(1 ,2,3
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TABLE 2
KENTUCKY AVENUE WELLFIELD SITE - OPERABLE UNIT 3
SUMMARY OF CONTAMINANTS OF CONCERN
THE SOIL PILE - SURFACE SOIL
Contaminant
of Concern
Benzo(a)anth-
racene
Benzo(b)fluor-
anthene
Benzo(a)pyrene
Dibenz(a,h)
anthracene
Aroclor-1254
Aroclor-1260
Aluminum
Arsenic
Barium
Beryllium
Cadmium
Manganese
Mercury
Nickel
Thallium
Vanadium
Freq. of
Detects/0 of
Samples
11 1
11 1
11 1
4/ 7
11 1
5/ 1
11 1
6/ 1
11 1
\l 1
21 1
11 1
4/ 7
11 1
\l 1
11 1
Range of
Detections
min- max units
36 - 1900 ug/kg
58 - 1500 ug/kg
36 - 1200 ug/kg
76 -390 ug/kg
24 - 790 ug/kg
90 - 2400 ug/kg
5150-14600 mg/kg
2.2-5.1 mg/kg
85 - 208 mg/kg
0.48 - 0.48 mg/kg
0.53-1.1 mg/kg
600 - 1220 mg/kg
0.1-0.87 mg/kg
12.4 - 38.7 mg/kg
0.19-0.19 mg/kg
10 - 22.3 mg/kg
95%
UCL*
2186
1571
1475
562
651
10193
10429
4.5
184
0.39
0.77
1172
0.98
30
0.73
17
Cone. Used
in the RA **
1900
1500
1200
390
651
2400
10429
4.5
184
0.39
0.77
1172
0.87
30
0.19
17
* This value represents the 95 % upper confidence limit on the arithmetic mean.
**This value represents either the maximum concentration or the 95% UCL; whichever is smaller. See Appendix A
of the Risk Assessment for the 95% UCL calculations.
Page 1 of 16
-------
TABLE 2
KENTUCKY AVENUE WELLFIELD SITE - OPERABLE UNIT 3
SUMMARY OF CONTAMINANTS OF CONCERN
FLUORIDE DISPOSAL AREA NO. 1 - SURFACE SOIL
Contaminant
of Concern
Benzo(a)anth-
racene
Benzo(a)pyrene
Dieldrin
Aroclor-1254
Aluminum
Arsenic
Barium
Manganese
Nickel
Vanadium
Freq. of
Detects/0 of
Samples
1/1
1/1
1/1
1/1
1/1
1/1
1/1
1/1
1/1
1/1
Range of
Detections
min- max units
170 - 170 ug/kg
80 - 80 ug/kg
15 - 15 ug/kg
580- 580 ug/kg
11400-11400mg/kg
2.7 - 2.7 mg/kg
77.4 - 77.4 mg/kg
677 - 677 mg/kg
23.2 - 23.2 mg/kg
17.6-17.6 mg/kg
95%
UCL*
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
Cone. Used
in the RA **
170
80
15
580
11400
2.7
77.4
677
23.2
17.6
* This value-represents the 95 % upper confidence limit on the arithmetic mean.
"This value represents either the maximum concentration or the 95% UCL; whichever is smaller. See Appendix A
of the Risk Assessment for the 95% UCL calculations.
NA - The 95% UCL cannot be calculated with only one sample.
Page 2 of 16
-------
TABLE 2
KENTUCKY AVENUE WELLFIELD SITE - OPERABLE UNIT 3
SUMMARY OF CONTAMINANTS OF CONCERN
FLUORIDE DISPOSAL AREA NO. 2 - SURFACE SOIL
Contaminant
of Concern
Benzo(a)anth-
racene
Benzo(b)fluor-
anthene
Benzo(a)pyrene
Indeno( 1,2,3-
cd)pyrene
Aluminum
Arsenic
Barium
Manganese
Nickel
Vanadium
Zinc
Freq. of
Detects/0 of
Samples
2/2
2/2
2/2
111
2/2
2/2
111
2/2
2/2
2/2
1/1
Range of
Detections
min- max units
140 - 730 ug/kg
190-450 ug/kg
160-650 ug/kg
83 - 370 ug/kg
6940-7880 mg/kg
2.9 - 4.4 mg/kg
88.9-136 mg/kg
498-616 mgkg
12.5-18.2 mg/kg
12.8-12.9 mg/kg
359 .-359 mg/kg
95%
UCL*
2467633
3043
245884
211042
8815
7.25
226
745
28.5
12.98
NA
Cone. Used
in the RA **
730
450
650
370
7880
4.4
136
616
18.2
12.9
359
* This value represents the 95 % upper confidence limit on the arithmetic mean.
This value represents either the maximum concentration or the 95% UCL; whichever is smaller. See Appendix A
of the Risk Assessment for the 95% UCL calculations.
NA - The 95% UCL can not be calculated with only one sample.
Page 3 of 16
-------
TABLE 2
KENTUCKY AVENUE WELLFIELD SITE - OPERABLE UNIT 3
SUMMARY OF CONTAMINANTS OF CONCERN
DISPOSAL AREA F - SURFACE SOIL
Contaminant
of Concern
Trichloro-
ethylene
Benzo(a)anth-
racene
Benzo(b)fluor-
anthene
Benzo(a)pyrene
Dibenzofuran
Fluoranthene
Indeno( 1,2,3-
cd)pyrene
Pyrene
Dieldrin
Aroclor-1254
Aluminum
Arsenic
Barium
Cadmium
Manganese
Mercury
Vanadium
Freq. of
Detects/0 of
Samples
3/4
4/4
4/4
4/4
4/4
4/4
4/4
4/4
2/3
1/3
3/3
3/3
3/3
1/3
1/1
3/3
3/3
Range of
Detections
min- max units
77 - 20000 ug/kg
935 - 290000 ug/kg
1470- 420000 ug/kg
860-310000 ug/kg
107-33000 ug/kg
1900-700000 ug/kg
600-13000 ug/kg
1450-610000 ug/kg
12-170 ug/kg
43.5 - 43.5 ug/kg
2160-5665 mg/kg
13.6-18.9 mg/kg
34.4-118 mg/kg
1.18-1.18 mg/kg
470.5 -470.5 mg/kg
0.26 - 0.74 mg/kg
4.6 - 14.5 mg/kg
95%
UCL*
3.6E+14
4.3E+12
1.56E+11
6.47E+12
9.26E+1 1
8.66E+12
3.00E+10
1.61E+13
7.72E+14
2721
17955
21.3
973
2.08
NA
3.68
89
Cone. Used
in the RA **
20000
290000
420000
310000
33000
700000
13000
610000
170
43.5
5665
18.9
118
1.18
470.5
0.74
14.5
Page 4 of 16
-------
TABLE 2
KENTUCKY AVENUE WELLFIELD SITE - OPERABLE UNIT 3
SUMMARY OF CONTAMINANTS OF CONCERN
MAGNESIUM CHIP BURIAL AREA - SURFACE SOIL
Contaminant
of Concern
Benzo(a)pyrene
Aroclor 1242
Aluminum
Arsenic
Barium
Nickel
Vanadium
Freq. of
Detects/ft of
Samples
1/1
1/1
1/1
1/1
1/1
1/1
1/1
Range of
Detections
min- max units
90 - 90 ug/kg
120 - 120 ug/kg
5450-5450 mg/kg
7.2 - 7.2 mg/kg
93.5 - 93.5 mg/kg
9.7 - 9.7 mg/kg
15.4-15.4 mg/kg
95%
UCL*
NA
NA
NA
NA
NA
NA
NA
Cone. Used
in the RA **
90
120
5450
7.2
93.5
9.7
41.5
* This value represents the 95 % upper confidence limit on the arithmetic mean.
**This value represents either the maximum concentration or the 95% UCL; whichever is smaller. See Appendix A
of the Risk Assessment for the 95% UCL calculations.
NA - The 95% UCL cannot be calculated with only one sample.
Page 5 of 16
-------
TABLE2
KENTUCKY AVENUE WELLFIELD SITE - OPERABLE UNIT 3
SUMMARY OF CONTAMINANTS OF CONCERN
THE AREA SOUTHWEST OF THE WEST PARKING LOT
SUBSURFACE SOIL
Contaminant
of Concern
Aroclor 1254
Aluminum
Arsenic
Barium
Beryllium
Manganese
Nickel
Thallium
Vanadium
Freq. of
Detects/ft of
Samples
1/7
7/7
7/7
7/7
3/7
7/7
111
1/7
7/7
Range of
Detections
min - max units
95 - 95 ug/kg
10300-1 4050 mg/kg
3.8-10 mg/kg
99-192 mg/kg
0.5 - 0.84 mg/kg
617-1200 mg/kg
21.4-31.5 mg/kg
0.34 - 0.34 mg/kg
16.6-24.2 mg/kg
95%
UCL*
51.9
13339
8.7
171
0.67
1044
29
0.6
22.8
Cone. Used
in the RA **
51.9
13339
8.7
171
0.67
1044
29
0.34
22.8
* This value represents the 95 % upper confidence limit on the arithmetic mean.
*This value represents either the maximum concentration or the 95% UCL; whichever is smaller. See Appendix A
of the Risk Assessment for the 95% UCL calculations.
Page 6 of 16
-------
TABLE 2
KENTUCKY AVENUE WELLFIELD SITE - OPERABLE UNIT 3
SUMMARY OF CONTAMINANTS OF CONCERN
THE MW-10 AREA - SUBSURFACE SOIL
Contaminant
of Concern
Benzo(a)pyrene
Aroclor-1254
Aroclor-1260
Aluminum
Arsenic
Barium
Cadmium
Manganese
Nickel
Vanadium
Freq. of
Detects/ft of
Samples
3/7
1/7
1/7
111
7/7
111
111
111
111
111
Range of
Detections
min - max units
37-140 ug/kg
68 - 68 ug/kg
31-31 ug/kg
5550- 13200 mg/kg
3-12.3 mg/kg
73.2-109 mg/kg
3.5 - 3.5 mg/kg
566 - 800 mg/kg
17-27.4 mg/kg
10.6-21.1 mg/kg
95%
UCL*
1007
39
23
11874
8.1
103
1.9
746
24
19
Cone. Used
in the RA **
140
39
23
11874
8.1
103
1.9
746
24
19
* This value represents the 95 % upper confidence limit on the arithmetic mean.
**This value represents either the maximum concentration or the 95% UCL; whichever is smaller. See Appendix A
of the Risk Assessment for the 95% UCL calculations.
Page 7 of 16
-------
TABLE 2
KENTUCKY AVENUE WELLFIELD SITE - OPERABLE UNIT 3
SUMMARY OF CONTAMINANTS OF CONCERN
FLUORIDE DISPOSAL AREA 1 - SUBSURFACE SOIL
Contaminant
of Concern
Benzo(a)pyrene
Aroclor-1260
Antimony
Arsenic
Beryllium
Cadmium
Manganese
Freq. of
Detects/ft of
Samples
3/14
2/14
2/14
14/14
3/14
3/13
14/14
Range of
Detections
min - max units
59 - 330 ug/kg
50 - 83 ug/kg
4.57-45.1 mg/kg
1.1-24.2 mg/kg
0.43- 0.55 mg/kg
1.7-936 mg/kg
278-1560 mg/kg
95%
UCL*
254
41
8.4
10.6
0.43
150
1885
Cone. Used
in the RA **
254
41
8.4
10.6
0.43
150
1560
* This value represents the 95 % upper confidence limit on the arithmetic mean.
**This value represents either the maximum concentration or the 95% UCL; whichever is smaller. See Appendix A
of the Risk Assessment for the 95% UCL calculations.
Page 8 of 16
-------
TABLE 2
KENTUCKY AVENUE WELLFIELD SITE - OPERABLE UNIT 3
SUMMARY OF CONTAMINANTS OF CONCERN
FLUORIDE DISPOSAL AREA NO. 2 - SUBSURFACE SOIL
Contaminant
of Concern
Benzo(a)pyrene
Aroclor-1260
Antimony
Arsenic
Beryllium
Cadmium
Manganese
Freq. of
Detects/3 of
Samples
3/14
2/14
2/14
14/14
3/14
3/13
14/14
Range of
Detections
min - max units
59 - 330 ug/kg
50 - 83 ug/kg
4.57-45.1 mg/kg
1.1-24.2 mg/kg
0.43- 0.55 mg/kg
1.7-936 mg/kg
278-1560 mg/kg
95%
UCL*
254
41
8.4
10.6
0.43
150
1885
Cone. Used
in the RA **
254
41
8.4
10.6
0.43
150
1560
* This value represents the 95 % upper confidence limit on the arithmetic mean.
**This value represents either the maximum concentration or the 95% UCL; whichever is smaller. See Appendix A
of the Risk Assessment for the 95% UCL calculations.
Page 9 of 16
-------
TABLE 2
KENTUCKY AVENUE WELLFIELD SITE - OPERABLE UNIT 3
SUMMARY OF CONTAMINANTS OF CONCERN
THE FORMER COAL PILE AREA - SUBSURFACE SOIL
Contaminant
of Concern
Benzo(a)pyrene
Aroclor-1242
Aroclor-1254
Aluminum
Antimony
Arsenic
Barium
Beryllium
Cadmium
Manganese
Nickel
Vanadium
Freq. of
Detects/0 of
Samples
3/15
2/15
4/15
15/15
1/15
15/15
15/15
3/15
1/15
8/8
15/15
15/15
Range of
Detections
min - max units
28 - 87 ug/kg
80-120 ug/kg
17-24 ug/kg
5440-10300 mg/kg
5.75 - 5.75 mg/kg
1.7-7.85 mg/kg
40.8-113 mg/kg
0.31-0.87 mg/kg
0.76 - 0.76 mg/kg
277 - 791 mg/kg
12.7-31.7 mg/kg
9-15.9 mg/kg
95%
UCL*
219
37.7
19
8598
3.6
5.3
89
0.4
0.59
631
20.9
13.4
Cone. Used
in the RA **
87
37.7
19
8598
3.6
5.3
89
0.4
0.59
631
20.9
13.4
* This value represents the 95 % upper confidence limit on the arithmetic mean.
"This value represents either the maximum concentration or the 95% UCL; whichever is smaller. See Appendix A
of the Risk Assessment for the 95% UCL calculations.
Page 10 of 16
-------
TABLE 2
KENTUCKY AVENUE WELLFIELD SITE - OPERABLE UNIT 3
SUMMARY OF CONTAMINANTS OF CONCERN
THE FORMER RUNOFF BASIN - SUBSURFACE SOIL
Contaminant
of Concern
Trichloro-
ethylene
Dibenzofuran
Benzo(a)anthra
cene
Benzo(b)fluor-
anthene
Benzo(a)pyrene
Fluoranthene
Indeno( 1,2,3-
cd)pyrene
Pyrene
Aroclor-1242
Aroclor-1254
Aluminum
Antimony
Arsenic
Cadmium
Manganese
Vanadium
Zinc
Freq. of
Detects/0 of
Samples
43/59
12/32
20/32
20/32
20/32
22/32
17/32
22/32
1/20
6/20
20/20
2/20
20/20
1/20
13/13
20/20
20/20
Range of
Detections
min - max units
1 - 79000 ug/kg
28 - 32000 ug/kg
20-120000 ug/kg
22-110000 ug/kg
21-95000 ug/kg
36 -'2 10000 ug/kg
58 - 80000 ug/kg
48-200000 ug/kg
3500-3500 ug/kg
15-110 ug/kg
1570-1 3470 mg/kg
0.74-1.8 mg/kg
0.64-13.6 mg/kg
382 - 382 mg/kg
244 - 1040 mg/kg
3.2-22 mg/kg
25.6-1160 mg/kg
95%
UCL*
637
493
1246
1270
827
1949
687
2121
189
75
9646
3.9
8
6.3
704
16
155
Cone. Used
in the RA **
637
493
1246
1270
827
1949
687
2121
189
75
9646
1.8
8
6.3
704
16
155
* This value represents the 95 % upper confidence limit on the arithmetic mean.
"This value represents either the maximum concentration or the 95% UCL; whichever is smaller. See Appendix A
of the Risk Assessment for the 95% UCL calculations.
Page 11 of 16
-------
TABLE 2
KENTUCKY AVENUE WELLFIELD SITE - OPERABLE UNIT 3
SUMMARY OF CONTAMINANTS OF CONCERN
DISPOSAL AREA F - SUBSURFACE SOIL
Contaminant
of Concern
Trichloro-
ethylene
Benzo(a)anthra
cene
Benzo(b)fluor-
anthene
Benzo(a)pyrene
Dibenz(a,h)
anthracene
Indeno( 1,2,3-
cd)pyrene
Pyrene
Heptachlor
Epoxide
Aluminum
Arsenic
Barium
Vanadium
Freq. of
Detects/3 of
Samples
43/59
23/31
22/31
23/31
4/31
20/31
23/31
1/17
17/17
17/17
17/17
17/17
Range of
Detections
min- max units
1-11000 ug/kg
40 - 24000 ug/kg
32 - 33000 ug/kg
30 - 24000 ug/kg
96 - 7300 ug/kg
48 - 14000 ug/kg
72 - 49000 ug/kg
0.58 - 0.58 ug/kg
3010-1 5300 mg/kg
1.3-15.3 mg/kg
44.6-168 mg/kg
5.3-18.6 mg/kg
95%
UCL*
3200
8008
7541
6869
827
2871
16591
3.6
8279
5.9
124
13
Cone. Used
in the RA **
3200
8008
7541
6869
827
2871
16591
0.58
8279
5.9
124
13
* This value represents the 95 % upper confidence limit on the arithmetic mean.
'This value represents either the maximum concentration or the 95% UCL; whichever is smaller. See Appendix A
of the Risk Assessment for the 95% UCL calculations.
Page 12 of 16
-------
TABLE 2
KENTUCKY AVENUE WELLFIELD SITE - OPERABLE UNIT 3
SUMMARY OF CONTAMINANTS OF CONCERN
THE MAGNESIUM CHIP BURIAL AREA
SUBSURFACE SOIL
Contaminant
of Concern
Benzo(a)anthra
cene
Benzo(b)fiuor-
anthene
Benzo(a)pyrene
Indeno( 1,2,3-
cd)pyrene
Aroclor-1242
Aroclor-1260
Aluminum
Arsenic
Barium
Manganese
Nickel
Vanadium
Freq. of
Detects/3 of
Samples
2/6
2/6
2/6
1/6
1/6
1/6
6/6
6/6
6/6
4/4
6/6
6/6
Range of
Detections
rain- max units
34-810 ug/kg
35 - 995 ug/kg
24 - 500 ug/kg
385 - 385 ug/kg
69 - 69 ug/kg
95 - 95 ug/kg
6360-1 1600 mg/kg
1.5-6.4 mg/kg
56.4 - 98.4 mg/kg
409 - 622 mg/kg
14.1-22.8 mg/kg
9.7-18.3 mg/kg
95%
UCL*
1350
1872
1150
284
47
65
9968
8.5
95
564
21
16
Cone. Used
in the RA **
810
995
500
284
47
65
9968
6.4
95
564
21
16
* This value represents the 95 % upper confidence limit on the arithmetic mean.
"This value represents either the maximum concentration or the 95% UCL; whichever is smaller. See Appendix A
of the Risk Assessment for the 95% UCL calculations.
Page 13 of 16
-------
TABLE 2
KENTUCKY AVENUE WELLFIELD SITE - OPERABLE UNIT 3
SUMMARY OF CONTAMINANTS OF CONCERN
INDUSTRIAL DRAINAGEWAY AND KOPPERS POND
SURFACE WATER
Contaminant
of Concern
Acetone
Trichlor-
ethylene
alpha-BHC
beta-BHC
Antimony
Arsenic
Barium
Cadmium
Mercury
Freq. of
Detects/0 of
Samples
2/13
9/13
3/13
1/13
10/14
5/14
14/14
6/14
1/4
Range of
Detections
min - max units
10-710 ug/kg
1 - 8 ug/kg
0.14-0.22 ug/kg
0.28 - 0.28 ug/kg
5.5 - 14.8 mg/kg
1.58-3.4 mg/kg
197-696 mg/kg
1.68-200 mg/kg
4.4 - 4.4 mg/kg
95%
UCL*
1678
19
0.07
0.046
7.1
1.8
526
58
0.2
Cone. Used
in the RA **
710
8
0.07
0.046
7.1
1.8
526
58
0.2
* This value represents the 95 % upper confidence limit on the arithmetic mean.
**This value represents either the maximum concentration or the 95% UCL; whichever is smaller. See Appendix A
of the Risk Assessment for the 95% UCL calculations.
Page 14 of 16
-------
TABLE 2
KENTUCKY AVENUE WELLFIELD SITE - OPERABLE UNIT 3
SUMMARY OF CONTAMINANTS OF CONCERN
INDUSTRIAL DRAINAGEWAY AND KOPPERS POND
SEDIMENTS
Contaminant
of Concern
Benzo(a)anthra
cene
Benzo(b)fluor-
anthene
Benzo(a)pyrene
Dibenz(a,h)-
anthracene
Aroclor-1248
Aroclor-1254
Aroclor-1260
Arsenic
Beryllium
Cadmium
Manganese
Thallium
Zinc
Freq. of
Detects/ft of
Samples
13/16
16/16
15/16
5/16
3/16
12/16
9/16
12/14
2/15
13/15
15/15
2/15
15/15
Range of
Detections
min - max units
20 - 3425 ug/kg
22 - 2700 ug/kg
21 - 2225 ug/kg
120-500 ug/kg
56 - 439 ug/kg
36-7100 ug/kg
51-952 ug/kg
3.6-31.5 mg/kg
0.68-1.0 mg/kg
1.57-1055 mg/kg
137-1470 mg/kg
0.38 - 16.4 mg/kg
71.6-10755 mg/kg
95%
UCL*
2731
2906
2208
359
210
15632
662
9.6
0.53
84430
830
2.3
20138
Cone. Used
in the RA **
2731
2208
2225
359
210
7100
662
9.6
0.53
1055
830
2.3
10755
* This value represents the 95 % upper confidence limit on the arithmetic mean.
**This value represents either the maximum concentration or the 95% UCL; whichever is smaller. See Appendix A
of the Risk Assessment for the 95% UCL calculations.
Page 15 of 16
-------
TABLE 2
KENTUCKY AVENUE WELLFIELD SITE - OPERABLE UNIT 3
SUMMARY OF CONTAMINANTS OF CONCERN
INDUSTRIAL DRAINAGEWAY AND KOPPERS POND
FISH TISSUE
Contaminant
of Concern
Aroclor-1254
Arsenic
Freq. of
Detects/ft of
Samples
11/13
3/5
Range of
Detections
min - max units
64 - 537 ug/kg
0.04-0.1 mg/kg
95%
UCL*
331
0.3
Cone. Used
in the RA **
331
0.04
* This value represents the 95 % upper confidence limit on the arithmetic mean.
**This value represents either the maximum concentration or the 95% UCL; whichever is smaller. See Appendix A
of the Risk Assessment for the 95% UCL calculations.
Page 16 of 16
-------
TABLE 3
KENTUCKY AVENUE WELLFIELD SITE - OPERABLE UNIT 3
POTENTIAL EXPOSURE PATHWAYS
AIM of
PopotattorHa)
Eipoeunt
Hout«
Retained lor
Quantitative Anatyalt
Justification
PRESENT USE SCENARIOS:
Surf** So*
FadltyAOCs:
SoiPM
Area Residents
(Trespassers)
digestion
Dermal Contact
Inhalation ol PartcuiaMs
Inhalation ol VOCs
Yes
Yes
No
No
FacMyAOCr.
(Maonaclum Chip Burial Area.
Disposal Area F.
Fluoride Disposal AIM No. I.
Fluoride Disposal AIM No. 2.
Fonnai Runoff Bask).
Former Coal PHe Ai«a,
MW10 Area, and
AIM SWot West Parking lot)
FadNyAOCl:
(MMWkjm Chip BurW AIM.
DfcposalAreaF.
Fluoride Dlspoeal Area No 1.
Fluoride Disposal AIM No. 2.
Former Runoff Buai.
Former Coal Pie ATM.
MW10 AIM.
Sol Pie. and
ATM SW of West Parking lot)
FadMyAOCl:
(Magnesium Chk> Burial Area
ndOkpOMlArMF)
FadMyAOCc
(FhiortdaDKpoealAraaNo I.
FhJOfUa Dttposal ATM No. 2.
Formar Runoff Basin.
Fomw Coal PHa Aiaa.
MW10 ATM.
So* Pats Araa. and
ATM SW ol Wasl ParWng Lot)
Araa RasManH
(Tratpastats)
Ingastlon
dermal Contact
Inhalalkxi ol Pailiculalas
Inhalation ol VOCs
No
No
No
No
digestion
Dermal Contact
Inhalation ol Partfculales
Inhalation ol VOCs
No
No
No
No
The facility is currently used lor manufacturing and
is hkety to remain so lor the near future. The lacllty
is completely surrounded by a chain link fence with some
minor institutional controls to prevent entry to the grounds.
Each of the AOCs is within the fenced facihty. except the sol
piles area, which is outside ol. but adjacent, to the fence.
The Inhalation ol particulars is not likely to be a significant
exposure pathway given the limited exposure time. No VOCs
wete selected as COCs.
The facility rs currently used for manufacturing and
Is likely to remain so lor the near future The facility
rs comptolety surrounded by a chain link fence wilh some
minor institutional controls to prevent entry to the grounds.
Each of the AOCs is within the fenced (acidly, except the son
piles area, which is outside of, but adjacent, to the fence.
At present, the facility is an operational area and does not
serve as a residential area.
SnaWortwr*
(Employees)
Sit* Workers
(Employees)
Ingestlon
Oarmal Contact'
Inhalation ol Partlcutoles
Inhalation ol VOCs
Ingeslion
Dermal Contact'
Inhalation of Particulars
Inhalation ol VOCs
Page 1 of 7
Yes
Yes
No
No
No
No
No
No
Site workers perform lawn maintenance activities In these two
areas and workers may come In direct contact with soils
The inhalation ol participates is not likely to be a significant
exposure pathway given the limited exposure time. VOCs are
not a primary class of COCs.
These areas are covered by pavement and/or workers
do not perform regular activities in these areas.
-------
TABLE 3
KENTUCKY AVENUE WELLFIELD SITE - OPERABLE UNIT 3
POTENTIAL EXPOSURE PATHWAYS
AIM of
^thtetd ^duu^kWK
Win wwffWvTff
Receptor
Populatlonle)
Exposure
Roul^*)
Retained for
Quantitative Analytle
Justification
-
SubsurtKiSo*
FadMyAOCr
(Magnesium CMp Burial Am.
Disposal Area F.
Fluoride Disposal AIM No. I.
Fluoride Disposal AIM No. 2.
Former Runofl Baakt.
Former Coal Pat Ar*a,
MWIOArea.
Sol HIM ATM. and
Area SW ol Wast Parking Lot)
FadWyAOCs:
(Magnesium CMp Burial ATM.
Disposal Are* F.
Fluoride Disposal Araa No. t,
Fluoride Disposal Area No. 2.
Former Runofl Basin.
Former Coal Pta Area,
MW10 Area.
Sol Pit*, and
Araa SW ol Wasl Parking Lot)
Construction Workers
tngestton
Dermal Contact
Inhalation ol Partculates
Inhalation ol VOCs
No
No
No
No
Area Residents
(Trespassers)
Residents
S«e Workers
Ingestlon
Dermal Contact
Inhalation ol Particulales
Inhalation ol VOCs
Ingestlon
Dermal Contact
Inhalation ol Parteutates
InhalaaonolVOCs
Construction Wortiars
Dermal Contact
Inhalation of Particutetes
Inhalation ol VOCs
Ingestlon
Dermal Contact
Inhalation of Partculates
Inhalation of VOCs
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
Construction work involving excavation activity is
not currently in progress at the facility
No construction work involving excavation activity
is currently in progress at the facility.
A) present, the facility is an operational area and does not
serve as a residential area.
Maintenance work involving excavation activity is not
currently in progress at the tacitly.
Construction work involving excavation activity Is
not currently in progress at the facility
Surface Water Runoff Chains
Araa Residents
(Trespassers)
Site Workers
(Employees)
Ingestlon
Dermal Contact
Inhalation ol Partlculatas
Inhalation of VOCs
Ingestlon
Dermal Contact
Inhalation ol Partlculatas
Inhalation ol VOCs
2 of 7
No
No
No
No
No
No
No
No
A majority of the surface water runoff drains are located within
the fenced and guarded portion ol the facility. Each drain is
covered by a manhole Exposure to the sods In the bottom of
the drains would require site access, tilting of the manhole cover.
and descending to depths of 4 to 6 ft bgs. Therefore, this pathway
rs not considered likely to occur.
No utilities are located in the drains and no other activity
requires workers to enter the drains
-------
TABLE 3
KENTUCKY AVENUE WELLFIELD SITE - OPERABLE UNIT 3
POTENTIAL EXPOSURE PATHWAYS
AIM el
Matrix
Receptor
PopulattorHe)
Exposure Retained lor
Route(«) Quantitative Analyeia
Justification
PRESENT - USE SCENARIOS CONTO:
Groundwarer
FadWyand
WlthM Study A»ea
Residents
SHe Workers
(Employees)
Constructtan Workers
Ingestion
Dermal Conlact (Shower)
Inhalaron of VOCs (Showei)
Ingestion
Dermal Contact (Shower)
Inhalation of VOCs (Shower)
Ingestion
OefrrHll Contact (Shower)
Inhalation of VOCs (Shower)
No Groundwaler wilhin OU III is not a potable source as (he
No contaminated facility supply wells are out of service.
No Potable water lot use in OU III is currently obtained
horn public waler supply weds outside this operable unit.
Therefore, the exposure pathway is incomplete.
No Groundwaler within OU 111 is not a potable source as the
No contaminated facWty supply wels are out of service.
No Potable waler for use in OU III is currently obtained
from public water supply wells outside this operable unit
Therefore, the exposure pathway is incomplete
No Groundwater within OU III is not a potable source as the
No contaminated facility supply weds are out of service.
No Potable water for use In OU III is currently obtained
from public waler supply weds outside this operable unil.
Therefore, the exposure pathway is incomplete.
Surfim WSf Mr
Musklal
Drakwgeway
nd Pond
Ate* Residents
(Trespassers)
Ingestlon
Dermal Contact
Inhalation of VOCs
Yes Trespassers may ingest and dermaUy contact surface water In
Yes the drainageway and pond located outside the fenced facility
No during recreational activities. Exposure lo VOCs released from
surface waler into ambient air wil be qualitatively evaluated.
SMfkTMnf
Industrial
Dnxtnageway
end Pond
Area Residents
(Trespassers)
tngestlon
Dermal ContacT
Inhalation ol Partlcutetes
Yes Trespassers may ingest and dermalty contact sediment In
Yes the drainageway and pond located outside the fenced faciNty.
No These areas are not expected to dry out, therefore no suspended
particulates are likely to be released
Page 3 of 7
-------
TABLE 3
KENTUCKY AVENUE WELLFIELD SITE - OPERABLE UNIT 3
POTENTIAL EXPOSURE PATHWAYS
AIM of
Matrii Concent
Receptor
Population^)
Eipoaure
Route<«)
Retained lot
Quantitative Analyala
JuMilication
FUTURE - USE SCENARIOS:
Surface So*
FacMyAOCs:
(Magnesium Chip Burial Area.
Disposal Area F.
Fluoride Disposal Are* No. 1 ,
FluoiU* ObpoMl AIM No. 2.
No (urtac* coll dua oo«*cttd:
AiMSWolWMtPartUngLot
MWIOAiM
Formar Coal Pila
Formal RunoH B«»in)
Area Residents
(Trespassers)
RMhMnts
Sila Workers
(Employees)
Construction Workers
Ingeslion
Dermal Contact*
Inhalation d Panicutales
Inhalation oi VOCs
Ingaslion
Dermal Contact'
Inhalation of Panlcutatas
Inhalation ol VOCc
IngasUcxi
Oaimal Contact' .
Inhalation ol ParticuUMs
Inhalation ol VOCs
mgasUon
Dermal Contact*
Inhalation ot ParfJculales
Inhalation ol VOCs
No
No
No
No
Yas
Yes
Yas
No
Yas
Yes
Yes
No
Yas
Yes
Yes
No
II the site is lasidanlialty developed in the future, risks to
liespassais would be negfcgibto in comparison to risks
lo midents.
Tha laciWy is tkaly to (amain as a manufacturing ladtty;
hovnvai. this usacouM change in lhalulura. His
lhe« eUcaty poss*te thai lestdenlial oevetopmenl couW
Exposwa to suspended soil parteutatas may oecm » pavanwnl and
ground covai aia ramovad. VOCs aie not a prnwry class ot COCs
If the lacikty continues to ba use as a manulacturing
lacaHy. site workeis may conttnue » parfoirn various
actwiiies Ow oughout tie laciMy during the cousa ol a normal
workday. Exposure to suspended sod particulars may occur I
pavement and ground cover ara removed VOCs are not a
a primary class ol COCs.
Future construction acUvrtias may occm on the lacily
Potential exposure Is expected lobe short-term (I.e.. 6 monais).
VCCsaie not a primary class of COCs.
Page 4 of7
-------
TABLE 3
KENTUCKY AVENUE WELLFIELD SITE - OPERABLE UNIT 3
POTENTIAL EXPOSURE PATHWAYS
Metrii
AfMOl
Concern
Receptor
Population!*)
Expoaure
Houtefa)
Retained for
Quantitative Anatyiie
Justification
Subsurface So*
FadMyAOCs:
(Uagne*ium Chip Burial AIM.
Disposal Area F.
Fluoride Disposal Aieaa No I.
Fluoride Disposal Ai aaj No 2.
Form* Runoff Basin ATM.
Former Co* PHe AIM.
MWIOAfM.
Soil PHe and.
ATM SW ol Weil Parking Lot)
Area Residents
(Trespasser)
Residents
digestion
Dermal Contact*
Inhalation of Parteulates
Inhalation ol VOCs
Ingestion
Dermal Contact *
Inhalalion ol Partlculales
Inhalation of VOCs
No
No
No
No
No
No
No
No
During potential Mure construction work (i e.. excavation activity).
area residents are assumed to come m contact with a negligible
amount of subsurface sort as compared to a construction worker.
During potential Mure construction work (i e.. excavation actMy),
residents are assumed to come in contact with a negligible
amount of subsurface so* as compared to a construction worker
Surface Water Runofl Drains
SUe Worker*
(Employees)
Construction Worker*
Area Residents
(Trespassers)
SHe Workers
(Employees)
Ingestion
Dermal Contact*
Inhalation of PartlcuUle*
Inhalation ol VOCs"
Ingestion
Dermal Contact*
Mialatlon of Pantcutates
Inhalation of VOC*
Ingestion
Dermal Contact
Inhalalion of Pamcutates
Inhalalion of VOCs
Ingesllon
Dermal Contact
Inhalation of Perteutetes
Inhalation of VOCs
No
No
No
No
Yes
Ves
Yes
No
No
No
No
No
No
No
No
No
During potential Mure construction work (i a., excavation activity).
site workers are assumed to come m contact with a neglgMe
amount ol subsurface soil as compared to a construction worker
Future construction activities may occur at the facility.
Potential exposure is expected to be short-term (I e., 6 months)
A majority of the surface water runoff drains are located within
the fenced and guarded portion of the facikly. Each dram Is
covered by a manhole. Exposure to the soils In the bottom ol
the drains would require sue access, lifting, of the manhole cover.
and cHmbmg to depths ol 4 to 6 (I bgs. Therefore, this pathway
Is not considered likely to occur.
No uttMies are located n the drains and no other activity
requires workers to enlar the drains.
Page 5 of 7
-------
TABLE 3
KENTUCKY AVENUE WELLFIELD SITE - OPERABLE UNIT 3
POTENTIAL EXPOSURE PATHWAYS
Af«**t Weee»*e» Cipotura Retained for
RoirteU) Quantitative Anatyate Juetilicalion
rwnmt UM CENAMOS conro:
Wit** Study Are* Aetidenti IngefIton No IIOU III is residential!? developed in the Mure, the
Dermal Conuct (Shower) No potential Bursts lot new residential wels to be Installed In Die
Inhalation ot VOCt (Shower) No chemically contaminated aquifer beneath OU III. However, risks
(Adults only) are Hkery lo be similar lo those estimated tor OU II groundwater
(i.e.. in the range of 10-3 to 10-4).
Site Workers Ingestion No II OU III Is commercially developed in the luture. the
Dermal Contact (Shower) No potential edsls lor new commercial wells lo be Installed In the
Inhalation of VOC« (Shower) No chemfcaly contaminated aquifer beneath OU III. However, risks
calculated tor residential exposure lor OU II would be higher than
risks tor a site worker.
Construction Workers higestton No If OU in Is commercially developed in the future, the
Dermal Contact (Shower) No potential exists tor new commercial wells to be instated In the
Inhalation of VOCs (Shower) No chemically contaminated aquifer beneath OU III. However, risks
calculated for residential exposure lor OU II would be higher than
risks tor a construction worker.
Page 6 of7
-------
TABLE 3
KENTUCKY AVENUE WELLFIELD SITE - OPERABLE UNIT 3
POTENTIAL EXPOSURE PATHWAYS
AIM of Receptor Eipotur* Retained lor
Metrti _ Contain _ PopulaBon(e| _ Route(e| _ Quantitative Analyela _ Juitification _
Surface HfeWr
IndutkW
Dralnageway Aiea Residents tngestion Yes Trespassers may ingest and dermally contact surface water In
and Pond (Trespassers) Dermal Contact Yes the dramageway and pond located outside tna fenced facility.
Inhalation ol VOCs No Exposure to VOCs released Itom surface waters into me
ambient air wifl be qualitatively evaluated.
SMftnenf
Indusklal
Drakiageway Area Residents Ingeslton Yes Trespassers may Ingest and dermally contact sediment in
and Pond (TcespessefS) Dermal Contact' Yes lha dramageway and pond located outside the lanced lacMty.
Inhalation of Particulates No These areas are not expected lo dry out. Iheiefore no suspended
panicutaMs are likely to be released.
The dermal contact pathway lor aol and Mdbntnt at tw site can only be quantitatively evaluated lor PCB* and cadmium as only these chemicals have established dermal absorption (actors (PCBs
and cadmium . 1%). All otter chemicals w") be quaHaflvaty discussed.
6%
Page? of?
-------
TABLE 4
KENTUCKY AVENUE WELLFIELD SITE - OPERABLE UNIT 3
TOXICITY VALUES FOR POTENTIAL CARCINOGENIC HEALTH EFFECTS
DOSE - RESPONSE RELATIONSHIP (1)
COCs
VotoNto Orpanfc*
Acetone
Trichtoroetiytone
SaninflofvMv Ofpante*
Benzo^ejai i w ii ecei le
Denzo(e)pyrene
Benzo(b)fluoran(hen0
. IT_ » » » M
DiMnz(e.n)aninraoene
Dtbanzokiran
Fluofenlnene
lratono( 1 <2,3-cd)pyf ene
Pyrane
alpha BHC
betaBHC
DteMrtn
HeptachtorEpoxMe
PCBa(Arodora)
CARCINOGENS:
SLOPE FACTORS (SF)
OrrtSF
.
1.1E-02 (3)
73E-01 (3)
73E»00
7.3E-01 (3)
7.3E+00; (3)
.
.
7.3E-01 (3)
6.3E+00
1.8E*00
16E*01
91E*00
7.7E*00
Inhalation SF
(mg/kg-day)-1
.
-
.
-
-
-
-
-
63E«OO
1.BE400
16E+01
91E+00
Weight - ol -
Evidence
D
B2
B2
82
B2
B2
D
D
B2
D
B2
C
B2
B2
B2
Page 1 of2
-------
TABLE 4
KENTUCKY AVENUE WELLFIELD SITE - OPERABLE UNIT 3
TOXICITY VALUES FOR POTENTIAL CARCINOGENIC HEALTH EFFECTS
DOSE - RESPONSE RELATIONSHIP (1)
COCs
tmnm*mmmti*m
rnofyawNcv
Aluminum
Antimony
Arsenic
Barium
Beryllium
Cadmium
Manganeaa(water)
Mercury
Nickel (sol. sail)
Silver
ThaMum
Vanadium
Zinc (and compounds)
CARCINOGENS:
SLOPE FACTORS (SF)
Oral SF Inhalation SF
(mg/kg-day)- 1 (mg/kg-day)- 1
-
t.75E+00 I.SE401
.
4.3E+00 84E+00
6.3E+00
-
.
-.
..
-
Weight of
Evidence
D
D
A
D
B2
B1
-
D
D
D
-
0
NOTES:
(1) AN toxicHy values obtained from IRIS unless otherwise noted.
(2) Toxtarty values obtained Irom HEAST Annual FY-1994.
(3) EPA Environmental Criteria and Assessment Office
USCPA WEIGHT OF EVIDENCE:
A - Human Carcinogen
B1 - Probable Human Carcinogen. Limited human data are available.
B2 - Probable Human Carcinogen. Sufficient evidence of cardnogentaty in animals and inadequate or no evidence in humans.
C - Possible Human Carcinogen
D - Not Classifiable as to human cardnogenidry.
E - Evidence of noncardnogenicHy for humans.
Page 2 of2
-------
TABLE 5
KENTUCKY AVENUE WELLFIELD SITE - OPERABLE UNIT 3
CHRONIC TOXICITY VALUES FOR POTENTIAL NONCARCINOGENIC HEALTH EFFECTS
DOSE - RESPONSE RELATIONSHIP (1)
COCS
NONCARCINOGENS:
REFERENCE DOSES (RfO)
Oral RIO
Uncertainty
Factor
Inhalation RID
(mpftg/day)
Uncertainty
Factor
IOC -01
(3)
1000
3000
B«nzo(a)anthrac«rw
B«nzo(a)pyr»n«
Benzo(b)fhiorartihana
Dibenz(a.h)an0w«oane
Dttwnzofuran
Fruoranthene
lndeno(1 ,2.3«d)pyrane
Pyrene
4.0E-03 (3)
4.0E42 3000
alpha BMC
belaBHC
DieMrin
HeptachlorEpoxkto
PCBa(Arodors)
Arodor1242
Arodor1248
Arodor12S4
Arodor1260
3.0E-02
5.0E-05
1.3E-OS
20E-05
3000
100
1000
300
Page 1 of 4
-------
TABLE 5
KENTUCKY AVENUE WELLFIELD SITE - OPERABLE UNIT 3
CHRONIC TOXICITY VALUES FOR POTENTIAL NONCARCINOGENIC HEALTH EFFECTS
DOSE - RESPONSE RELATIONSHIP (1)
cocs
fnofpenfce
Aluminum
Antimony
AnMnlc
Barium
BervMum
Cadmium (food)
Cadmium (water)
Manganese (waler)
Mercury
Nickel (sol. salt)
Silver
Thallium
Vanadium
Zinc (and compounds)
NONCARCINOGENS:
REFERENCE DOSES (RfO)
Oral RIO
(mgyko/day)
10E4OO (3)
4.0E-04
30E04
7.0E-02
50E03
10E-03
S.OE-O4
2.3E-02 (4)
3.0E-04 (2)
4.0E-02
5.0E-03
8.0E-05
7.0E-03 (2)
30E-01
Uncertainly
Factor
1000
3
3
100
10
10
3
1000
300
3
3000
too
3
Inhalation RID
(mgfeo/day)
.
-
-
1.4E-04 (2)
-
-
1.4E-05
8.6E-05 (2)
-
-
-
Uncertainty
Factor
-
-
1000
-
-
-
1000
30
-
-
NOTES:
Caldum. Iron, magnesium, potassium and sodium are considered essential nutrients and will not be quantitatively evaluated
in the risk assessment.
(1) AN toridty values obtained Irom IRIS unless otherwise noted.
(2) Toxtdty values obtained from HEAST Annual FY-1994.
(3) EPA Environmental Criteria and Assessment Office.
(4) Revised oral RID for manganese. Derived by adjusting the food-based RID of 0.14 mg/kp/day for 50% Intake of manganese from the diet
and applying a safety factor of three.
Page 2 of 4
-------
TABLE 5
KENTUCKY AVENUE WELLFIELD SITE - OPERABLE UNIT 3
SUBCHRONIC TOXICITY VALUES FOR POTENTIAL NONCARCINOGENIC HEALTH EFFECTS
DOSE - RELATIONSHIP (1)
COGS
NONCARCINOGENS:
REFERENCE DOSES (RID)
Oral RID
(mp/fcp/day)
Uncertainty
Factor
Inhalation RfD
(mgykoyctey)
Uncertainty
Factor
Aoeton*
TricNorotftylMW
tOE*00
too
B«nzo
-------
TABLE 5
KENTUCKY AVENUE WELLFIELD SITE - OPERABLE UNIT 3
SUBCHRONIC TOXICITY VALUES FOR POTENTIAL NONCARCINOGENIC HEALTH EFFECTS
DOSE - RELATIONSHIP (I)
cocs
MOf0tnlC9
Aluminum
Antimony
Arsenic
Barium
DoryNlunt
Cadmium
Manganese (water)
Mercury
Nfckel (sol. salt)
OlflPBF
Tnalium
Vanadhm
Zinc (and compounds)
Oral RfD
(mg/ko/day)
4.0E-04
3.0E-O4
706-02
SOE-03
-
2.3E-02 (4)
3.0E-04 (2)
20E-02
S.OE-03
a.OE-04
7.0E-03 (2)
3.0E-01
NONCARCINOGENS:
REFERENCE DOSES (RfD)
Uncertainty Inhalation RID
Factor (mg/Vg/day)
1000
3
3 1.4E-03 (2)
too
-
3
tOOO 8.6E-OS (2)
300
3
300
too
3
Uncertainly
Factor
-
-
1000
-
-
-
30
-
-
-
NOTES:
- Calcium. Iron. magnesium, potassium and aodhim are cm
in the risk assessment.
aidered essential nutrients and will not be quantitatively evaluated
(1) Al tojddfy values obtained from IRIS unless otherwise noted.
(2) ToxJdty values obtained from HEAST Annual FY-1994.
(3) EPA Environmental Criteria and Assessment Office.
(4) Revleed oral RID for manganese. Derived by adjusting me food-based RfD of 0.14 mg/kg'day for 50% Intake of manganese from the dtel
and applying a safety factor of three.
Page 4 of 4
-------
TABLE 6
KENTUCKY AVENUE WELLFIELD SITE - OPERABLE UNIT 3
COMBINING CARCINOGENIC RISKS ACROSS PATHWAYS
MEDIA
PRESENT/FUTURE-USE SCENAF
SURFACE SOIL
Soil Pile
Disposal AIM F
' Magnesium Chip Bunal Area
SURFACE WATER
Industrial Drainage Way and Pond
(AD Compounds)
Industrial Drainage Way and Pond
(Exdudng SPOES Compounds)
SEDIMENr
Industrial Drainage Way and Pond
(AH Compounds)
Industrial Drainage Way and Pond
(Eidwkng SPDES Compounds)
FISH
Industrial Drainageway and Pond
RECEPTOR
POPULATION
OS
Area Residents
(Trespassers)
Children (12 17 years)
Site Workers
Adults
Site Workers
Adults
Area Residents
(Trespassers)
Children (12-17 years)
Area Residenis
(Trespassers)
Children (12-17 years)
Area Residenis
(Trespassers)
Children (12- 17 years)
Area Residenis
(Trespassers)
Children (12-17 years
Area Residenis
EXPOSURE
ROUTE
ngeslion
termal Contact
Total Carcinogenic Risk =
Ingestion
Jermal Contact
Inhalation of Particulars
Total Carcinogenic Risk =
Ingestion
Dermal Contact
Inhalation ol Participates
Total Carcinogenic Risk =
1 ngeslion
Dermal Contact
Total Carcinogenic Risk =
Ingestion
Dermal Contact
Total Carcinogenic Risk =
1 ngeslion
Dermal Contact
Total Carcinogenic Bisk =
Ingestion
Dermal Contact
Total Carcinogenic Risk =
1 ngeslion
INDIVIDUAL
CANCER RISK
24E07
1 BE 07
42E-07
5 IE-04
1.4E-07
3SE07
S.IE-04
24E-06
38E-07
I.3E-07
29E46
28E4J7
32E 10
2 BE -07
97E-OB
B9E-11
97E-OB
1 1E06
3 5E 07
15E06
B9E4)7
35E47
12E-06
3 BE -04
FOR SCENARIOS WITH TOTAL RISK > 10-4
CHEMICALS CONTRIBUTING THE GREATEST
AMOUNT TO RISK (Risk > 10-6)
Carcinogenic PAHs
Carcinogenic PAHs
-
..
-
-
Aroclor 1254. Arsenic
-------
TABLE 6
KENTUCKY AVENUE WELLFIELD SITE - OPERABLE UNIT 3
COMBINING CARCINOGENIC RISKS ACROSS PATHWAYS
MECMA
FUTURE-USE SCENARIOS
SURFACE SOIL
Sol Pile
Fluoride Disposal Area No. 1
RECEPTOR
POPULATION
Residents
Adults
Residents
Children (0-6 years)
Resident
(30 yeai combined)
Site Woifcers
(Employees)
Construction
Workers
Residents
Adults
Residents
Children (0-6 years)
Residents
(30 year combined)
EXPOSURE
ROUTE
Ingeslwn
Dermal Contact
nhalalton c4 Particulales
Total Carcinogenic Risk =
tngestion
Dermal Contact
Inhalation ol Particulales
Total Carcinogenic Rlak =
Total Carcinogenic Him* =
Ingeslion
Dermal Contact
Inhalation ol Particulales
Total Carcinogenic Risk =
Ingest ion
Dermal Contact
Inhalation
Total Carcinogenic RUh =
Ingeslion
Dermal Contact
Inhalation ol Particulales
Total Carcinogenic Rlak =
Ingestion
Dermal Contact
Inhalation ol Particulales
Total Carcinogenic Rlek *
Total Carcinogenic Rlah »
INDIVIDUAL
CANCER RISK
22E05
34E-OS
27E-07
56E-05
52E-05
9 BE -06
3IE-07
62E-OS
I2E-O4
83E-06
96E-06
BBE-Ofl
I8EX»
83E-07
31E-07
92E-IO
t tEO§
48E-06
64E-08
5E-07
IE-OS
1EOS
9E-06
7E-07
3E-05
2.4E-OS
FOR SCENARIOS WITH TOTAL RISK > 10-4
CHEMICALS CONTRIBUTING THE GREATEST
AMOUNT TO RISK (Risk > 10-«)
-
-
-
-
-
.
Page 2 of 5
-------
TABLE 6
KENTUCKY AVENUE WELLFIELD SITE - OPERABLE UNIT 3
COMBINING CARCINOGENIC RISKS ACROSS PATHWAYS
MEDIA
RECEPTOR
POPULATION
FUTURE USE SCENARIOS CONTO.
SURFACE SOIL con»Y*
Fluoride Disposal Area No. 1 conic
Fluoride Disposal Area No 2
Disposal Area F
Site Workers
(Emptoyees)
ConsUucUon
Workers
Residents
Adults
nartdante
Children (0-6 years)
R**ktarrti
(30 year combined)
Site Workers
(Employees)
Construction
Workers
Residents
Aduto
EXPOSURE
ROUTE
Ingeslion
Dermal Contact
Inhalation ot Parbculates
otai cefunoQsnic ma* »
ngestion
Dermal Contact
Inhalation
Total Carcinogenic Risk
Ingestion
Dermal Contact
Inhalation of Particutales
roui cafdnocjeiiic niax
ngestion
Dermal Contact
Inhalation ol Partfcutales
Total Carcinogenic Risk «
Ingestion
Dermal Contact
Inhalation of ParUcutales
rom Gavcinocjenic Hie*
Ingeslion
Dermal Contact
Inhalation
Total Cardnoganlc Mali »
Ingestion
Dermal Contact
Inhalation ot Partfculates
Total Carcinogenic Rtok
INDIVIDUAL
CANCER RISK
tee -oe
IBE-06
49E-08
1 ttK J^£t
J.DC-Oo
1.8E-07
60E-08
5IE 10
24E-07
6.4E-06
NA
2.4E07
a AC_/wt
O.DC-UO
ISE-05
NA
2.8E-07
15E-05
22E-05
2.4E-06
NA
80E-08
2.4E-07
NA
84E tO
2.4E-07
I4E-03
4 BE -07
IOE46
I.4E43
FOR SCENARIOS WITH TOTAL RISK > 10-4
CHEMICALS CONTRIBUTING THE GREATEST
AMOUNT TO RISK (Risk > 10-«)
..
-
-
..
..
-
..
--
--
--
-
-
"_
Carcinogenic PAHs. DieWrin. Arsenic
-
--
Carcinogenic PAHs. Dietdm. Arsenic
Page
-------
TSKE6
KENTUCKY AVENUE WELLFIELD SITE - OPERABLE UNIT 3
COMBINING CARCINOGENIC RISKS ACROSS PATHWAYS
MEDIA
RECEPTOR
POPULATION
FUTURE USE SCENARIO CONT'D.
SURFACE SOIL cort'd
Disposal Area F oonl'd.
Magnesium Chip Buna) Area
Residents
Children (06 years)
Residents
(30 years combined)
Site Workers
(Employees)
Construction
Workers
Residents
AduRs
Residents
Children (0-6 years)
Residents
(30 year combined)
Site Workers
(Employees)
Construction
Workers
EXPOSURE
ROUTE
ngeslion
Dermal Contact
Inhalation ol Participates
Total Carcinogenic Risk =
ToUl Carcinogenic Risk =
Ingeslion
Dermal Contact
Inhalation ol Participates
Total Carcinogenic Rl«k =
Ingeslion
Dermal Contact
Inhalation
ToUl Carcinogenic Risk =
Ingeslion
Dermal Contact
Inhalation ol Particulars
Total Carcinogenic Rl»k *
Ingeslion
Dermal Contact
Inhalation ol Particulates
Total Carcinogenic Risk =
Total Carcinogenic Risk =
Ingeslion
Dermal Contact
Inhalation ol Participates
Total Carcinogenic Risk =
Ingeslion
Dermal Contact
Inhalation
ToUl Carcinogenic Rl«k =
INDIVIDUAL
CANCER RISK
32E-03
1 4E 07
1 2E-06
32E-03
46E-03
5 IE 04
1 4E-07
3 SE-07
5 IE 04
S IEOS
45E-09
36E-09
5 IE 4)5
67E-06
t 3E-O6
40E07
84E-06
1 6E-05
39E-07
46E-07
1 7EO5
25E-05
24E-06
3 BE -07
1 3E 07
29E-06
24E07
1 2E-08
I4EX»
2.5E-07
FOR SCENARIOS WITH TOTAL RISK > 10-4
CHEMICALS CONTRIBUTING THE GREATEST
AMOUNT TO RISK (Risk > 10-6)
Carcinogenic PAHs. Dieldnn. Arsenic
-.
Carcinogenic PAHs. Dieldnn. Arsenic
Carcinogenic PAHs
Carcinogenic PAHs
-
--
Carcinogenic PAHs
--
-
-
--
-
-
Page 4 of 5
-------
TABLE 6
KENTUCKY AVENUE WELLFIELD SITE - OPERABLE UNIT 3
COMBINING CARCINOGENIC RISKS ACROSS PATHWAYS
MEDIA
SUBSURFACE SOIL
Aiea Southwest of (he
Wesl Parking Lot
MW 10 Area
Fluoride Disposal Area No. 1
Fluoride Disposal Area No. 2
Form*) Coal Pd*
Former Runofl Basin
Disposal Area F
Magnesium Chip Disposal Ataa
ACCEPTOR
POPULATION
Construction
Woikeis
Consliuchon
Workers
Construction
Workers
Construction
Workars
Construction
Workers
Construction
Woikaii
Construction
Workers
Construction
Woikais
EXPOSURE
ROUTE
oeslion
Dermal Contact
nhalalion
olal Carcinogenic Risk =
ngeslion
Darmal Contact
Inhalation ol Particulars
olal Carcinogenic Risk *
ngeslKxi
Dermal Contact
nhalalion ol Particulars
olal Carcinogenic RUfc =
Ingeslion
Dermal Contact
Inhalation of Paniculate*
Told Carcinogenic Risk =
Ingeslion
>ermal Contact
Inhalation ol Particulars
Total Carcinogenic Risk =
tngeslkm
Dermal Contact
Inhalation ol Parliculalas
Total Carcinogenic Risk
Ingestion
Dermal Contact
Inhalation ol Parliculales
Total Carcinogenic Rlik «
Ingeslion
Dermal Contact
Inhalation ol Participates
Total Cwclnogente Rlik *
INDIVIDUAL
CANCER RISK
33E07
S3E09
1 7E 09
34E07
? 7E 07
64EO9
1 7EO9
28E07
4 IE 07
42E 09
I 4E48
43E07
22E-07
NA
I2EO9
22E-07
2 IE 07
39E-09
I IE 09
22E-07
42E 07
62E 09
20E-09
43E-07
HE 06
NA
1 IE -09
14608
30E 07
I2EXJ6
1 IE-09
3 tE4>7
FOR SCENARIOS WITH TOTAL RISK > 10-4
CHEMICALS CONTRIBUTING THE GREATEST
AMOUNT TO RISK (Risk > 10 6)
'*
-
No carcinogenic risks eiceed the USEPA target risk range ol IE 04 to IE 06
- l«*caie?inal the carcmogenic risk does not e»ceed the target nsk range or could not be catenated; therefore, no chenvcals -ere selected as conlr.bulors
NA:The caranoge«c risk lor dermal contact «Uh sal could not be calculaled as no carcmogen* chemical, ol potenlal concern have esidWisncd deirn-l absoipuon (actors
5 of 5
-------
BLE7
KENTUCKY AVENUE WELLFIELD SITE - OPERABLE UNIT 3
COMBINING NONCARCINOGENIC RISKS ACROSS PATHWAYS
MEMA
PRESENT/FUTURE-USE SCENAF
SURFACE SOIL
Sod Pile
Disposal ATM F
Magnesium Chip Burial Area
SURFACE WATER
Industrial DralnageWay and Pond
(AH Compound*)
Industrial OralnageWay and Pond
(Excluding SPOES Compounda)
SEDIMENT
btduMfial DralnageWay and Pond
(Al Compounda)
Industrial DrainageWay and Pond
(Excluding SPOES Compounds)
FISH
Industrial DralngeWay and Pond
RECEPTOR
POPULATION
JOS
Area Residents
(Trespassers)
Children (12-17 years)
Site Worker*
Adutt*
Site Workers
Adults
Area Resident*
(Trespasser*)
CNMren (12-17 ycara)
Area Resident*
(Trespasser*)
Ch*Jr*n(12-17year»)
Area Residents
(Trespassers)
Children (12-17 years)
Area Residents
(Trespassers)
Children (12-17 years)
Area Residents
EXPOSURE
ROUTE
ngeslion
)ermal Contact
Total Hazard Index >
ngestfon
Dermal Contact
Inhalation ol Particulatea
Total Hazard Index »
Ingestion
Oermal Contact
Inhalation ol Particulales
Total Hazard Index -
Ingeslkm
Dermal Contact
Total Hazard Index-
IngesUon
Dermal Contact
Total Hazard Index
Ingastton
Dermal Contact
Total Hazard Index -
Ingestion
Dermal Contact
Total Hazard Index »
Ingestion
INDIVIDUAL.
HAZARD INDEX
7.3E-03
30E-03
I.OE42
7.3E-02
6.4E-04
I2E01
1.9E-OI
1.6E-02
NA
2.3E-03
I.8E-02
9.7E-O2
10E 04
1.2E02
t. IE-OS
1.2E-P2
I8EOI
35E02
2.2E-OI
5.0E42
23E-02
7.3EK)2
69E+00
CHEUICALS CONTRIBUTING THE GREATEST
AMOUNT TO HAZARD INDICES (HO > 1)
-
--
-
:
--
A/odor- 1254. Arsenic
Page 1 of 5
-------
TABLE 7
KENTUCKY AVENUE WELLFIELD SITE - OPERABLE UNIT 3
COMBINING NONCARCINOGENIC RISKS ACROSS PATHWAYS
MEDIA
FUTURE-USE SCENARIOS
SURFACE SOIL
Soil Pita
Fluoride Disposal Area No. 1
RECEPTOR
POPULATION
Residents
Adulls
Residents
Children (f>6 years)
Site Workers
(Employees)
Construction
Workers
Residents
Adulls
Residents
Children (0-6 years)
EXPOSURE
ROUTE
ngesbon
dermal Contact
Inhalation ol Patliculaies
Total Hazard Indei =
Ingeslion
Dermal Contact
Inhalation ol Patlculales
Total Haiard Indei =
Ingesti on
Dermal Contact
Inhalation ol Particulars
Total Haiard Indei »
Ingesti on
Dermal Contact
Inhalation
Total Haiard IndeM =
Ingestion
Dermal Contact
Inhalation of Particulales
Total Hazard Indei =
Ingestion
Dermal Contact
Inhalation ol Parttculates
Total Hazard Indei «
INDIVIDUAL
HAZARD INDEX
1 7E Ot
1.4E-OI
90EOI
I2E«00
16E+00
1.6E-OI
43E+00
6 IE+00
60E02
37E02
29E01
3.9E-OI
9.5E-02
NA
I3E04
95E02
1 lEOt
1 2E-OI
53EOI
7.6EOI
! IE+00
I4EOI
25E»00
37E+00
CHEMICALS CONTRIBUTING THE GREATEST
AMOUNT TO HAZARD INDICES (HO > 1)
Manganese
Manganese
-
-
Manganese
Manganese
Page 2 of 5
-------
TABLE 7
KENTUCKY AVENUE WELLFIELD SITE - OPERABLE UNIT 3
COMBINING NONCARCINOGENIC RISKS ACROSS PATHWAYS
MEDIA
UTURE USE SCENARIO CONTO
:Kmfide Disposal Area No. t coord
Fluoride Dispose! Aree No 2
Disposal Area F
RECEPTOR
POPULATION
Site Workers
(Employees)
Construction
Workers
Residents
Adults
Residents
(Trespassers)
Children (0-6 years)
Site Workers
(Employees)
Construction
Workers
Residents
Adults
EXPOSURE
ROUTE
ngestion
Dermal Contact
Inhalation ol Particulars
Total Hazard Index =
Ingesbon
Dermal Contact
Inhalation
Total Hazard Index =
Ingeslion
Dermal Contact
Inhalation ol Paniculales
Total Hazard Index *
Ingesli on
Dermal Contact
Inhalation ol Particulars
Total Hazard Index =
Ingeslion
Dermal Contact
Inhalation ol Particulates
Total Hazard Index »
Ingeslion
Dermal Contact
Inhalation
Total Hazard Index »
Ingesbon
Dermal Contact
Inhalation ol Particulars
Total Hazard Index «
INDIVIDUAL
HAZARD INDEX
4.IE-02
33E 02
1 7E 01
2.4E-OI
S3E02
NA
4.9E-05
53E02
7.6E-02
NA
48E-01
56EOI
7.IE-01
NA
23E+00
3.0E+00
27E02
NA
15EOI
I8EOI
56E02
NA
B6E05
S6E02
2 IE Ot
9 96 03
3.7E-OI
59E 01
CHEMICALS CONTRIBUTING THE GREATEST
AMOUNT TO HAZARD INDICES (HO > 1)
-
Manganese
Manganese
--
--
Page 3 of 5
-------
TABLE 7
KENTUCKY AVENUE WELLFIELD SITE - OPERABLE UNIT 3
COMBINING NONCARCINOGENIC RISKS ACROSS PATHWAYS
MEDIA
RECEPTOR
POPULATION
FUTURE USC SCENARIO CONTO
SUP f ACE SOIL eonfd
Disposal AT *a F conrd
Magnesium Chip Burial Area
Residents
Chikften (0 6 years)
Site Workers
(Employees}
Conslructaon
Workers
Residents
Adults
Residents
Children (0-6 years)
Site Workers
(Employees)
Construction
Workers
EXPOSURE
ROUTE *
Ingestion
Dermal Contact
Inhalation ol Partcuiates
Total Hatard Indai *
Ingeslion
Dermal Contact
Inhalation ol Parteulates
Total Hazard Indai =
Ingestion
Dermal Contact
Inhalation
Total Hazard Index =
Ingastion
Dermal Contact
Inhalakon ol Particulaies
Total Hazard Indai =
Ingestion
Dermal Contact
Inhalation ol Particulatas
Total Hazard Indai «
Ingestion
Dermal Contact
Inhalation ot Particulaies
Total Hazard Indai *
Ingeslion
Dermal Contact
Inhalation
Total Hazard Index =
INDIVIDUAL
HAZARD INDEX
1 9E«00
12E02
1 7E.OO
36E.OO
73E02
27E-03
1.2E-OI
20EOI
I.2EOI
NA
82E-05
12E4I
44E02
NA
72E03
5 IE 02
4.4E-OI
NA
33E02
47E^)I
I6E02
NA
23E03
t.BE-02
3.4E-02
NA
S9E05
34E02
CHEMICALS CONTRIBUTING THE GREATEST
AMOUNT TO HAZARD INDICES (HQ > 1)
Manganese
Manganese
.,
..
..
-
.
..
..
--
..
-
--
-
--
--
-
Page 4 of 5
-------
TABLE 7
KENTUCKY AVENUE WELLFIELD SITE - OPERABLE UNIT 3
COMBINING NONCARCINOGENIC RISKS ACROSS PATHWAYS
MEDIA
RECEPTOR
POPULATION
FUTURE USE SCENARIO CONrO
SUBSURFACE SOIL
Area Southwest ol ft*
West Parking Lot
MW- 10 Area
Fluoride Disposal Area No. 1
Fhionde Disposal Area No. 2
Former Coal Pile
Former Runoff Basin
Disposal Area F
Magnesium Chip Burial Area
Construction
Workers
Construction
Workers
Construction
Workers
Construction
Workers
Construction
Workers
Construction
Workers
Construction
Worker
Construction
Worker
EXPOSURE
ROUTE
ngesbon
)ermal Contact
nhatation of Particulars
Total Hazard Index =
Ingestion
Dermal Contact
nhalation of Particulars
Total Hazard totdMB
Ingestion
Dermal Contact
Inhalation of Particulales
Total Hazard Index =
Ingestion
Dermal Contact
Inhalation of Particulates
Total Hazard Indei *
Ingestion
Dermal Contact
inhalation ol Particulates
Total Hazard Index »
1 ngesbon
Dermal Contact
Inhalation of Particulates
Total Hazard Index *
Ingestion
Dermal Contact
Inhalation ot Particulales
Total Hazard Index =
Ingestion
Dermal Contact
Inhalation ol Particulales
Total Hazard Index =
INDIVIDUAL
HAZARD INDEX
IDE Ot
NA
ME 04
1.0EOI
79E-02
NA
66E-05
79E02
1.5E-01
NA
NA
1 5E-OI
67E02
NA
58E-05
67E-02
7.2E42
NA
5.6E-05
72E02
7.9E-02
NA
NA
79E4>2
IOE4M
NA
7.9E-05
IOE-01
6.2E-02
NA
60E-05
62E02
CHEMICALS CONTRIBUTING THE GREATEST
AMOUNT TO HAZARD INDICES (HQ > 1)
--
-
--
--
-
'
-
--
--
-
-
-
-
--
-
--
""
"
**
NA - The noncarcinogenic hazard index lor dermal contact with soil could not be calculated as no noncarcinogenic chemicals of potential concern have established dermal
absorption (actors.
Page 5 of 5
-------
TABLE 8
SUMMARY OF COSTS
Kentucky Avenue Wellfield Site, Operable Unit No. 3
Remedial Alternative
Capital
Cost111
O&M Cost121
Present
Worth Cost'3'
DISPOSAL AREA P
1A - No Action
2A - Containment with Asphalt Cover
(Option 1)
2A - Containment with RCRA Cap
(Option 2)
0
219,200
606,300
0
19,200
34,200
0
514,100
1,114,000
3A - Removal and Off-Site Disposal
4 A - Physical Treatment by SVE(41
549,000
525,900
4,600
4,600
619,600
596,500
FORMER RUNOFF BASIN AREA
IB - No Action
2B - Removal and Off-Site Disposal
3B - Physical Treatment by DP-SVE'4'
(Option 1)
3B - Physical Treatment by SVE-AS14'
(Option 2)
1,261,800
544,700
565,100
0
0
0
1,261,800
544,700
565,100
4B - Thermal Desorption Treatment
763,200
763,200
-------
TABLE 8 (continued)
SUMMARY OF COSTS
Kentucky Avenue Wellfield Site, Operable Unit No. 3
Capital
Remedial Alternative Cost'1'
INDUSTRIAL DRAINAGBWAY
1C - No Action 0
2C - Limited Action 268,200
3C - Containment with Concrete Lining 373,400
4C - Removal and Off-Site Disposal 365,600
Present
O&M Cost121 Worth Cost13'
0 0
13,800 480,100
18,700 660,600
0 365,600
Notes:
1. Capital costs include estimates for remedial design, construction, miscellaneous costs (e.g.,
administrative, permitting), and contingency.
2. O&M costs include estimates for maintenance, monitoring, five-year reviews (where applicable), and
contingency.
3. Present worth calculated at discount rate of five percent for term of 30 years.
4. For alternatives using SVE, costs of one-year operational period included with capital costs.
Estimates do not include costs for water treatment.
-------
APPENDIX III
ADMINISTRATIVE RECORD INDEX
-------
KENTUCKY AVENUE WELLFIELD SITE
OPERABLE UNIT NO. 3
ADMINISTRATIVE RJ2CORD FILE
INDEX OF DOCUMENTS
2.0 REMOVAL RESPONSE
2.1 Sampling and Analysis Plans
P. 200001- Report: Work Plan. Hazardous Waste and Drummed
200077 Waste Removal. Former Westinghouse Plant Site.
Horseheadsf New York,, prepared for Westinghouse
Electric Corporation, prepared by Philip
Environmental Services Corporation, September,
1995.
P. 200078 Report: Addenda to Approved Sampling and Analysis
200110 Plan and Health and Safety Planr Removal Action,.
Former Westinghouse Plant.Site. Horseheads. New
York, prepared for Westinghouse Electric
Corporation, prepared by Philip Environmental
Services Corporation, October, 1995.
2.2 Sampling and Analysis Data/Chain of Custody Forms
P. 200111- Report: Removal Acticn Completion Report. Former
200166 Westinghouse Plant Site, Horseheads, New York,.
prepared for Westinghouse Electric Corporation,
prepared by Philip Environmental Services
Corporation, July, 1996.
2.7 Correspondence
P. 200167- Letter to Mr. Mark Purcell, Remedial Project
200172 Manager, U.S. EPA, Region II, from Mr. Timothy R.
Basilone, Manager, Environmental Remediation, and
Mr. Leo M. Brausch, Project Engineer/Consultant,
Westinghouse Electric Corporation, re:
Administrative Order on Consent for Removal
Action, Index No. II CERCLA-95-0219; Former
Westinghouse Plant Site, Horseheads, New York,
October 20, 1995. (Attachment: Errata, Addendum to
Approved Sampling and Analysis Plan and Health and
Safety Plan, Removal Action, Former Westinghouse
Plant Site, Horseheads, New York, October 20,
1995.)
-------
P. 200173- Letter to Mr. Timothy R. Basilone, Manager,
200174 Environmental Remediation, c/o Mr. Leo Brausch,
Consultant, Law and Environmental Affairs,
Westinghouse Electric Corporation, from Ms. Carole
Petersen, Chief, New York/Caribbean Superfund
Branch II, U.S. EPA, Region II, re: Administrative
Order on Consent for Removal Action, Index No. II
CERCLA-95-0219, Former Westinghouse Plant Site,
Horseheads, New York, October 31, 1995.
3.0 REMEDIAL INVESTIGATION
3.3 Work Plans
P. 300001- Report: Remedial Investigation/Feasibility Studyf
300172 Work Plan. Kentucky Avenue Wellfield Sitef
Operable Unit No. 3. Horseheads, Chemung Countyr
New York, .Revision 2.0, prepared for Westinghouse
Electric Corporation, prepared by Burlington
Environmental Inc., May 6,. 1993.
P. 300173- Report: Remedial Investigation/Feasibility Study,
300669 Field Sampling Plan. Volume II. Kentucky Avenue
Wellfield Site. Operable Unit No. 3f Horseheads,
Chemung County. New VorkT Revision 2.0, prepared
for Westinghouse Electric Corporation, prepared by
Burlington Environmental Inc., February, 1994.
(Note: Appendix G, pp. 300493-300572, Mine Safety
Appliances Co. GasCorder User's Manual, Version
2.0A, is CONFIDENTIAL. It is located at U.S. EPA
Superfund Records Center, 290 Broadway, 18th
floor, N.Y., N.Y. 10007-1866).
P. 300670- Report: Quality Assurance Project PlanP Remedial
301019 Investigation/Feasibility Study,. Kentucky Avenue
Wellfield Site, Operable Unit No. 3f Horseheads.
Chemung Countyf New Vorkf Volume Ilia,. Revision
1.0, prepared for Westinghouse Electric
Corporation, prepared by Burlington Environmental
Inc., October, 1993.
P. 301020- Report: Quality Assurance Project Planf Remedial
301542 Investigation/Feasibility Studyf Kentucky Avenue
Wellfield Site. Operable Unit No. 3. Horseheads.
Chemung County,. New Yorkr Volume IIIbf Air
Program f Revision 1.0, prepared for Westinghouse
Electric Corporation, prepared by Burlington
Environmental Inc., October, 1993. - ^,
-------
P. 301543- Report: Remedial Investigation/Feasibility Study,
301945 Health and Safety Plan, Volume IV, Kentucky Avenue
Wellfield Site. Operable Unit No. 3, Horseheads,
Chemung County, New York, Revision 0.0, prepared*
for Westinghouse Electric Corporation, prepared by
Burlington Environmental Inc., June, 1993.
P. 301946- Report: Revised Work Plan, Supplemental Field
301969 Investigations and Treatability Studies. Remedial
Investigation/Feasibility Study. Horseheadsf New
York, Revision 3.0, prepared for Westinghouse
Electric Corporation, prepared by Philip
Environmental Services Corporation, May 17, 1995.
3.4 Remedial Investigation Reports
P.
301970-
302324
P.
302325-
302861
302862-
303386
303387-
304248
Report: Volume I. Text. Tables and Figures,
Preliminary Site Characterization Summary.
Kentucky Avenue Wellfield Site. Operable Unit No.
3f Remedial Investigation/Feasibility Study,
Horseheads, New Yorkf prepared for Westinghouse
Electric Corporation, prepared by Burlington
Environmental Inc., January 27, 1995.
Volume II. Arpendices A-J-2. Preliminary
Report:
Site Characterization
Summary. Kentucky Avenue
Wellfield Site. Operable Unit No. 3. Remedial
Investigation/Feasibility Study, Horseheadsr New
York, prepared for Westinghouse Electric
Corporation, prepared by Burlington Environmental
Inc., January 27, 1995.
Report: Volume IIIf Appendices J-3-Sf Preliminary
Site Characterization S.ummary. Kentucky Avenue
Wellfield Siter Operable Unit No. 3P Remedial
Investigation/Feasibility Study, Horseheadsr New
York, prepared for Westinghouse Electric
Corporation, prepared by Burlington Environmental
Inc., January 27, 1995.
Report: Volume IVf Appendices T-Yf Preliminary
Site Characterization Summary,, Kentucky Avenue
Wellfield Site, Operable Unit No. 3f Remedial
Investigation/Feasibility Study, Horseheadsf New
York, prepared for Westinghouse Electric
Corporation, prepared by Burlington Environmental
Inc., January 27, 1995.
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304249-
304385
304386-
304513
304514-
304613
304613A-
305178
305179-
305254
305255-
305897
305898-
306314
Report: Draft Conceptual Site Model Technical
Memorandum. Kentucky Avenue Wellfield Sitef
Operable Unit No. 3. Horseheadsf New Yorkr
prepared for Westinghouse Electric Corporation,
prepared by Burlington Environmental Inc., March
1995.
Report: Technical Memorandum, Data Evaluation and
Selection of Chemicals of Potential Concern,
Kentucky Avenue Wellfield Site, Operable Unit
No.3f Horseheads. Cheroung County, New Yorkf
prepared for Westinghouse Electric Corporation,
prepared by Burlington Environmental Inc., March
1995.
Report: Report of Soil Vapor Extraction Pilot
Studies, Kentucky Avenue Wellfield Siter Operable
Unit No. 3f Horseheads, New York, prepared for
Westinghouse Electric Corporation, prepared by
Philip Environmental Services Corporation, August,
1995.
Report: Final Baseline Human Health Risk
Assessment. Kentucky Avenue Wellfield Sitef
Operable Unit IIIf C'hemung County, New Yorkf
prepared for U.S. Environmental Protection Agency,
prepared by COM Federal Programs Corporation,
November 20, 1995.
Report: Screening Level Ecological Risk Assessment
for the Kentucky Avenue Wellfield Superfund Site.
Operable Unit No. 3, Horseheads, New York,.
prepared by U.S. EPA, Region II, March 1996.
Report : Remedial Investigation Report f Kentucky
Avenue Wellfield Sitef Oparable Unit No. 3r
Horseheads , New York. Volume Ir Textf Tables,
Figures. Plates r prepared for Westinghouse
Electric Corporation, prepared by Philip
Environmental Services Corporation, June, 1996.
Report : Remedial Investigation Report,. Kentucky
Wellfield Site. Oerable Unit No. 3 ,
Horseheads , New York. Volume II f Appendices A-Kf
prepared for Westinghouse Electric Corporation,
prepared by Philip Environmental Services
Corporation, June, 1996.
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p.
306315-
306897
Report: Remedial Investigation Report, Kentucky
Avenue Wellfield Site, Operable Unit No. 3f
Horseheads. New York. Volume IIIf Appendices L-Sf
prepared for Westinghouse Electric Corporation,
prepared by Philip Environmental Services
Corporation, June, 1996.
P'.
306898-
306902
Report: Addendum to Remedial Investigation Report,
Kentucky Avenue Wellfield Site. Operable Unit No.
3. Horseheadsf New Ycrkf prepared by U.S. EPA,
June, 1996.
3.5 Correspondence
P. 306903- Letter to Mr. Timothy R. Basilone, Manager,
306904 Environmental Remediation, c/o Mr. Leo Brausch,
Consultant, Law and Environmental Affairs,
Westinghouse Electric Corporation, from Ms. Carole
Petersen, Chief, New York/Caribbean Superfund
Branch II, U.S. EPA, Region II, re: Revised Work
Plan - Revision 3.0, Supplemental Field
Investigations and Treatability Studies, Remedial
Investigation/Feasibility Study, Index No. II,
CERCLA 10215, Horseheads, New York, May 19, 1995
P. 306905- Letter to Mr. Mark Purcell, Remedial Project
306906 Manager, U.S. EPA, Region II, from Mr. Leo M.
Brausch, Consultant/Project Engineer, Westinghouse
Electric Corporation, re: Transmittal, Letter from
Village of Horseheads Regarding Site Zoning,
Remedial Investigation/Feasibility Study,
Horseheads, New York, June 14, 1995. (Attachment:
Fax transmission to Mr. Brausch from Philip
Environmental, re: referenced zoning letter, June
5, 1995.)
P. 306907- Letter to Mr. Mark Purcell, Remedial Project
306911 Manager, U.S. EPA, Region II, from James Pinta
Jr., Ph.D., Project Manager, Philip Environmental
Services Corporation, re: Transmittal, Information
from the Village of Horseheads Regarding Site
Zoning and Comprehensive Plan - Operable Unit No.
3, Administrative Order on Consent for Remedial
Investigation/Feasibility Study, Index No. II
CERCLA-10215, Horseheads, New York, July 5, 1995.
(Attachments: Village of Horseheads zoning maps
and June 2, 1995 letter re: zoning plans.)
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P. 306912- Letter to Mr. Timothy R. Basilone, Manager,
306930 Environmental Remediation, Law and Environmental
Affairs, Westinghouse Corporation, from Ms. Carole
Petersen, Chief, New York/Caribbean Superfund
Branch II, U.S. EPA, Region II, re: Preliminary
Site Characterizations Summary and Draft
Conceptual Site Model - Technical Memorandum,
Kentucky Avenue Wellfield Site, Operable Unit No.
3, Administrative Order on Consent for the
Remedial Investigation/Feasibility Study, Index
No. II, CERCLA-10215, Horseheads, New York, July
21, 1995. (Attachment: EPA Comments on the
Westinghouse Electric Corporation's Preliminary
Site Characterization Summary, Kentucky Avenue
Wellfield Site, Operable Unit No. 3, Remedial
Investigation/Feasibility Study, Horseheads, New
York, dated January 27, 1995, July 17, 1995.)
P. 306931- Letter to Mr. Steven Shost, Bureau of
306961 Environmental Exposure Investigation, New York
State Department of Health, from Mark Purcell,
Remedial Project Manager, U.S. EPA, Region II, re:
Village of Horseheads Site Zoning Map and
Comprehensive Plan, Baseline Human Health Risk
Assessment, Kentucky Avenue Wellfield Site,
Horseheads, Chemung County, New York, September
15, 1995. (Attachments: 1. Philip Environmental
Services Corporation's submittal containing the
Village of Horseheads zoning maps and June 2, 1995
letter re: zoning plans for the Westinghouse
manufacturing facility; 2. Table of Contents and
select sections of the Village of Horseheads
Comprehensive Plan Report transmitted to U.S. EPA
on July 20, 1995.)
P. 306962- Letter to Mr. Richard K. Smith, Manager, Law and
306985 Environmental Affairs, Westinghouse Electric
Corporation, from Ms. Carole Petersen, Chief, New
York/Caribbean Superfund Branch II, U.S. EPA,
Region II, re: Draft Remedial Investigation
Report, Administrative Order on Consent for the
Remedial Investigation/Feasibility Study, Index
No. II CERCLA-10215, Horseheads, New York, January
30, 1996. (Attachment: EPA Comments on the
Westinghouse Electric Corporation's Draft Remedial
Investigation Report, Kentucky Avenue Wellfield
Site-Operable Unit Nc. 3, Horseheads, New York,
January 23, 1995.)
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306986- Letter to Mr. Richard K. Smith, Manager, Law and
307020 Environmental Affairs, Westinghouse Electric
Corporation, from Ms. Carole Petersen, Chief, New
York/Caribbean Superfund Branch II, U.S. EPA,
Region II, re: Draft Remedial Investigation
Report, Kentucky Avenue Wellfield Site,
Administrative Order on Consent for the Remedial
Investigation/Feasibility Study, Index No. II
CERCLA-10215, Horseheads, New York, June 27, 1996.
(Attachments: Remedial Investigation Report
Addendum and Executive Summary.)
307021- Memorandum to the Administrative Record File,
307021 Kentucky Avenue Wellfield Site - Operable Unit No.
3, from Mr. Mark Purcell, Project Manager, U.S.
EPA, Region II, re: Quality Assurance/Quality
Control Analytical Data for the Remedial
Investigation at the Operable Unit No. 3, Kentucky
Avenue Wellfield Superfund Site, Town of
Horseheads, Chemung County, New York, August 29,
1996.
4.0 FEASIBILITY STUDY
4.3 Feasibility Study Reports
P. 400001- Report: Feasibility Study Report. Kentucky Avenue
400234 Wellfield Sitef Operable Unit No. 3, Horseheads,
Chemung Countyf New York, prepared for
Westinghouse Electric Corporation, prepared by
Philip Environmental Services Corporation, August
1996.
4.6 Correspondence
P. 400235- Letter to Mr. Mark Purcell, Remedial Project
400237 Manager, U.S. EPA, Region II, from Mr. Leo M.
Brausch, Project Engineer/Consultant, and Mr.
Richard K. Smith, Manager, Environmental
Engineering and Project Management, Westinghouse
Electric Corporation, re: Transmittal, Feasibility
Study Report, Administrative Order on Consent for
Remedial Investigation Feasibility Study, Index
No. II CERCLA 10215, Operable Unit No. 3, Kentucky
Avenue Wellfield Site, Horseheads, New York, July
9, 1996.
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400238- Letter to Mr. Richard K. Smith, Manager, Law and
400246 Environmental Affairs, Westinghouse Electric
Corporation, from Mr. Kevin Lynch, Chief, New York
Remediation Branch, Western New York Section, U.,5.
EPA, Region II, re: Revised Feasibility Study
Report, Administrative Order on Consent for the
Remedial Investigation/Feasibility study, Index
No. II, CERCLA-10215, Horseheads, New York, August
23, 1996. (Attachments: Feasibility Study Report
cover sheet, executive summary and introduction,
Remedial Investigation Report cover sheets for
Volumes I - III)
400247- Letter to Mr. 'Richard L. Caspe, Director,
400247 Emergency & Remedial Response Division, U.S. EPA,
Region II, from Mr. Michael J. O'Toole, Jr.,
Director, Division of Environmental Remediation,
NYSDEC, re: Westinghcuse Electric Corporation
Site, Site # 8-08-007, August 23, 1996.
7.0 ENFORCEMENT
7.3 Administrative Orders
P. 700001- Administrative Order on Consent in the Matter of;
700027 The Kentucky Avenue Wellfield Site, Index No. II
CERCLA-10215, August 6, 1991.
P. 700028- Administrative Order on Consent in the Matter of:
700049 The Kentucky Avenue Wellfield Site, Index No. II
CERCLA 95-0219, September 27, 1995.
8.0 HEALTH ASSESSMENTS
8.1 ATSDR Health Assessments
P. 800001- Report: Site Review and Update, Kentucky Avenue
800016 Wellfield, Chemung Ccunty. Horseheadsf New Yorkf
prepared by the New York State Department of
Health and the Agency for Toxic Substances and
Diseases Registry, March 1994.
P. 800017- Report: 1996/1997 Health Advisories: Chemicals in
800032 Sportfish and Game, prepared by the New York State
Department of Health, Division of Environmental
Health Assessment, March 1996.
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8.3 Correspondence
P. 800033- Letter to Mr. Mark D. Purcell, Remedial Project
800034 Manager, U.S. EPA, Region II, from Stephen J.
Shost, Bureau of Environmental Exposure
Investigation, New York State Department of
Health, re: Kentucky Avenue Wellfield, Horseheads,
Chemung County, Site ID #808012, July 28, 1995.
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APPENDIX IV
STATE LETTER OF CONCURRENCE
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NEW YORK STATE DEPARTMENT OF ENVIRONMENTAL CONSERVATION
50 Wolf Road, Albany, New York 12233
Mr. Richard L. Caspc SEP 2 7 m .
Director Commissioner
Emergency & Remedial Response Division
U.S. Environmental Protection Agency
Region 11
290 Broadway, 20th Floor
New York, New York 10007-1866
Dear Mr. Caspc:
RE: Westinghouse Electric Corporation, Site # 8-08-007
Kentucky Avenue WeUfield, Site # 8-08-012
The New York State Department of Environmental Conservation (NYSDEC) and the New York
State Department of Health (NYSDOH) have reviewed the U.S. Environmental Protection Agency
(USEPA) Record of Decision (ROD) for the Kentucky Avenue Wellficld (Westinghouse Electric Company,
Site # 8-08-007) site. The ROD selects remedies to address soil contamination in three areas of concern
at the site, identifies the ongoing interim remedial measure (IRM) as the final remedy for the groundwater
and defers the decision on remedation of a nearby pond until the completion of an ecological risk
assessment. The NYSDEC and NYSDOH concur with the no further action decision for the groundwater
and the following remedies selected by the ROD:
Area F- Excavation and Off-Site Treatment or Disposal, at permitted facilities, of soils
containing TCE, PAHs and arsenic at concentrations above the established cleanup objectives.
FnrmerRiinnffRasin Area- A SVE system utilizing either dual-phase or air stripping technologies,
to be determined during design, to address volatile organic compound (VOC) contamination in soils
above and below the water table.
Industrial Urainageway: Excavation of sediments containing concentrations of PCBs above the 1
ppm cleanup objective for the drainageway.
If you have any questions relative to this concurrence, please contact Mr. Robert W. Schick, P.E.
at (5 18)457-4343.
Sincerely,
Michael J.
Director '
Division of Environmental Remediation
cc: Commissioner Zagata
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APPENDIX V
RESPONSIVENESS SUMMARY
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APPENDIX V
RESPONSIVENESS SUMMARY
KENTUCKY AVENUE WELLFIELD SITE
OPERABLE UNIT 3
INTRODUCTION
A responsiveness summary is required by the National Oil and
Hazardous Substances Pollution Contingency Plan (NCP) at 40 CFR
§300.430(f) (3) (F). It provides a summary of comments and concerns
received during the public comment period, and the United States
Environmental Protection Agency's(EPA's) and the New York State
Department of Environmental Conservation's (NYSDEC's) responses to
those comments and concerns. All comments summarized in this
document have been considered in the EPA's and the NYSDEC's final
decision for selection of a remedial alternative for the Kentucky
Avenue Wellfield site (Site).
SUMMARY OF COMMUNITY RELATIONS ACTIVITIES
On September 17, 1986, the EPA held its first public meeting for
the Site in the Village of Horseheads to discuss the results of a
remedial investigation and feasibility study (RI/FS) and the
proposed remedy. Approximately 20 residents attended the meeting.
The following concerns were raised:
Reimbursements for the connections made by residents;
The future use of the KAW;
Whether future sampling and monitoring would be conducted in
the area; and,
The identification of the contaminant sources.
During the second phase of cleanup for the Site (i.e., Operable
Unit 2) , a public comment period was held from July 21, 1990
through September 18, 1990 for interested parties to comment on the
EPA's proposed remedy for OU2. Although the public comment period
was originally scheduled to end on August 19, 1990, the EPA
extended it to September 18, 1990 at the request of a party.
On August 1, 1990, the EPA held its second public meeting at the
Village of Horseheads Town Hall to present the findings of a
supplemental RI/FS, and the EPA's proposed remedy for OU2.
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Approximately 40 citizens were in attendance.
concerns were raised during the meeting:
The following
The health and safety of residents growing vegetable gardens;
The low levels of trichloroethylene (TCE) contamination
detected in the Sullivan Street Wellfield and the design and
construction of an extraction and treatment system at that
Wellfield;
The schedule and duration of the OU2 cleanup;
The alleged dumping practices and contamination at the Old
Horseheads Landfill; and,
The investigations planned for the three industrial facilities
at the Site which were identified by the EPA as the primary
contributors to ground-water contamination.
A public comment period was held from August 28, 1996 to September
26, 1996 for interested parties to comment on the Proposed Plan for
the third phase of cleanup (Operable Unit 3) at the Site. On
September 11, 1996 the EPA held a public meeting at the Village of
Horseheads Town Hall to present the findings of the RI/FS conducted
as part of OU3 and the EPA's Proposed Plan.
During the public meeting, the audience raised questions on a
variety of issues. These issues are -presented by category in the
following sections of this document.
Attached to
Appendices:
the Responsiveness Summary are the following
Appendix A
Appendix B
Appendix C
Appendix D
Appendix E
Appendix F
Proposed Plan
Press Release
Public Notice
September 11, 1996 Public Meeting Attendance
Sheet(s)
September 11, 1996 Public Meeting Transcript
Comment Letter submitted during Public Comment
Period
SUMMARY OF COMMENTS RECEIVED DURING THE PUBLIC COMMENT PERIOD AND
EPA'S RESPONSES '
Comments expressed during the September 11, 1996 public meeting and
written comments received during the public comment period held
-------
from August 28, 1996 and September 26, 1996 have been categorized
as follows:
Buried drums at the Westinghouse Facility;
Other potential sources of ground-water contamination;
Human health risks associated with PCBs contamination in the
industrial drainageway;
Other potential sources of Polychlorinated Biphenyl (PCB)
contamination in the industrial drainageway;
Unauthorized discharges and dumpings of waste into the
industrial drainageway.; and,
Preferred alternatives for OU3.
A summary of the comments and the EPA's responses to those comments
are provided below.
Buried Drums at the Westinghouse Facility
Comment No. 1: Ms. Mary Smith, a resident of Elmira, New York,
wanted to know whether EPA was confident that it had located all of
the drums in the former magnesium chip burial area, stating that
196 30-gallon drums were first reported buried and 179 55-gallon
drums were actually found and removed. Ms. Smith noted the
apparent discrepancy in the size of the drums, as well.
EPA Response: There is no discrepancy with respect to the size of
the drums in the former Magnesium Chip Burial Area. Plant records
indicated that the waste materials buried in this area were first
containerized in 30-gallon drums. The 30-gallon drums were then
placed inside 55-gallon drums, which were subsequently filled with
concrete prior to burial. All 179 drums excavated from the
Magnesium Chip Burial Area by Westinghouse during the 1995 removal
activities were 55-gallon drums. Additionally, upon inspection,
all 179 drums were found to be filled with concrete.
Although there is a discrepancy between the number of* drums
estimated to be buried at the Magnesium Chip Burial Area and the
number actually found during the 1995 removal action performed by
the Westinghouse Electric Corporation {Westinghouse), the EPA does
not believe that there are other drums buried in that area, or any
-------
other area investigated at Westinghouse's Facility. The number of
drums estimated to be buried at the Magnesium Chip Burial Area was
obtained by reviewing plant records, interviewing present and
former employees, performing on-Site reconnaissance activities, and
reviewing historic aerial photographs of the plant. It was only
considered as an approximate number.
Additionally, ground-penetrating radar surveys, trenching
activities, and borehole drilling techniques were used extensively
during the remedial investigation (RI) to locate any drums or other
objects which may have been buried at the Magnesium Chip Burial
Area and/or other potential source areas at the Westinghouse
Facility. The results confirmed the presence of drums only at the
Magnesium Chip Burial Area. The actual number of buried drums in
that area was determined to be 179 upon the excavation and removal
of such drums by Westinghouse in late 1995.
Other potential sources of ground-water contamination
Comment No. 2: A citizen of Horseheads wanted to know if the EPA
investigated the potential source areas to the west of the
Westinghouse Facility, particularly in the vicinity of the Big
Flats No. 1 public water supply well and the Horseheads Automotive
Recycling facility (Recycling Facility), which are located in and
near the Town of Fisherville. Additionally, the citizen inquired
if there were any evidence to suggest that such potential source
areas were contributing to the ground-water contamination at the
Site.
EPA Response: The EPA did not investigate the area in the vicinity
of the Big Flats No. 1 public water supply well or the Recycling
Facility as part of the RI/FS for OU3. However, the NYSDEC has
done a preliminary investigation in these areas. At the Recycling
Facility, the results of soil and ground-water sampling and
analyses revealed the presence of several volatile organic
compounds, but a source of such contamination could not be
identified.
Additionally, ground-water sampling and analyses have been
performed by the New York State Department of Health and the
Chemung County Health Department. The results indicated the
presence of TCE and 1,1,1-trichloroethane in ground water.
Furthermore, a ground-water investigation of the area in the
vicinity of the Big Flats No. 1 well has revealed the presence of
-------
1,1,1-trichloroethane and TCE in several private drinking water
wells. However, as in the case with the Recycling facility, the
source of,such contamination has not been identified.
Based on the results of previous hydrogeologic investigations, it
has been determined that the ground-water flow regime is very
complex. A ground-water divide was identified between the
Fisherville area and the Westinghouse Facility. This divide is
where the ground-water flow direction in the vicinity of the
Westinghouse Facility is to the east, and in the Fisherville area
the flow direction is to the west. The Big Flats No. 1 well and
the Recycling facility are located in the vicinity of this ground-
water divide. With the available data, the NYSDEC has not been
able to determine the direction of ground-water flow in these
areas. The NYSDEC suspects that the flow direction is primarily to
the west, and away from the Westinghouse Facility. However, there
may also be seasonal variations in the flow direction.
Several monitoring wells located along the western, and most
upgradient, perimeter of the Westinghouse Facility were sampled
during the RI for OU3. The results revealed the presence of TCE at
concentrations ranging up to 10 parts per billion (ppb) in two
monitoring wells located at the southwestern corner of the
Facility. If such contamination is coming from a source located
west and upgradient of the Westinghouse Facility, further
investigation would be necessary to identify that source.
The EPA will discuss this matter with the NYSDEC and then decide if
further response actions are necessary.
It is noted that the groundwater recovery wells to be installed at
the southeast corner of the Westinghouse Facility as part of the
OU2 remedy are designed to prevent the entire contaminant plume
beneath the Facility from migrating off-site. Therefore, this
remedy will also capture any ground-water contamination that may be
originating from an upgradient source, if present.
Human Health Risk Associated with PCBs
Comment No. 3: One citizen was concerned that the human health
risk associated with exposure to polychlorinated biphenyl (PCB)
contamination in the Industrial Drainageway may be overstated.
EPA Response: The concentrations of PCBs found in sediment samples
collected from the industrial drainageway ranged from approximately
-------
1 ppm to 9 ppm. In addition, fish tissue samples collected from
Koppers Pond contained concentrations of PCBs ranging up to 0.5
ppm. Based on these findings, the EPA identified unacceptable
health risks associated with exposure to PCBs through fish
consumption. Therefore, a response action will be taken to address
such health risk. The intent of the remediation at the industrial
drainageway is to minimize the health risks associated with
exposure to PCBs through fish consumption.
In assessing human health risks, the EPA makes conservative
assumptions concerning risk and exposure parameters. Therefore,
the risk assessment is highly unlikely to underestimate the actual
risk related to PCB contamination in the industrial drainageway.
Other potential sources of PCB contamination in the industrial
drainageway
Comment No.4: What about PCB contamination from other sources,
such as the Chemung County Department of Highways property or
runoff from the highways and throughout Horseheads?
EPA Response: EPA did not investigate that property as part of the
RI for OU3. However, it was investigated as part of the 1990 RI/FS
for OU2. The results of the 1990 RI indicated that PCBs were
detected in only one soil sample collected from within two feet of
ground surface at a relatively low concentration (0.3 ppm). Based
on these findings, the EPA does not consider this to be a source of
PCB contamination.
The EPA also recognizes that the industrial drainageway may receive
some runoff from nearby roads, especially in the area of the
underground piping between the Westinghouse Facility and the
Chemung Street outfall. Whether such runoff is contributing to the
PCB contamination in the drainageway is not known at this time.
However, during remedial design an 'attempt will be made to assess
whether there are other apparent sources that may be contributing
to the contamination of the industrial drainageway.
Comment No.5: Why is there not more concern for the heavy metals
contamination in sediments in the industrial drainageway.
. *
EEA Response: Based on the results of the OU3 RI, several heavy
metals were identified in the sediments and surface water at the
industrial drainageway at elevated concentrations. Additionally,
an industrial precipitate which has been present in the industrial
-------
drainageway since early 1995 was found to contain very high levels
of several metals, including lead, chromium and cadmium. Although
the concentrations of metals are elevated, the human health risks
calculated by the EPA for exposure to such contamination fell
within the EPA's target risk range. Therefore, the selected
cleanup for the industrial drainageway was not based on metals
contamination.
However, the EPA's screening level ecological risk assessment
indicated that the metals contamination may be adversely impacting
the environment. The EPA will conduct a supplemental study at
Koppers Pond and the outlet stream south of the Pond to determine
if, and to what extent, the environment has been impacted by such
contamination. The results of the supplemental study will then be
used to determine the appropriate cleanup actions, if deemed
appropriate.
Reports of Unauthorized Dumping and Discharge
Comment No.6: A long-time resident has observed evidence of
alleged unauthorized discharges continuing in the drainageway, as
well as suspected illegal dumping at property adjacent to the
industrial drainageway. What is being done to identify the sources
of this activity and prevent it in the future, following the
cleanup?
EPA Response: The NYSDEC permitting authorities are currently
conducting an investigation to determine the source(s) of the
unauthorized discharges to the industrial drainageway. It is also
the EPA's understanding that Westinghouse and the operators of the
wastewater treatment plants at the Westinghouse Facility, the
Toshiba Display Devices, Inc. and the Cutler-Hammer Division of
Eaton Corporation, are cooperating with the NYSDEC officials in
their investigation. Additionally, the NYSDEC is evaluating the
monitoring requirements and discharge limits specified in the
discharge permits issued for the two wastewater treatment plants at
the Westinghouse Facility to determine if modification of such
requirements and/or limits are necessary to prevent the
recontamination of the industrial drainageway.
The remedy selected for the industrial drainageway (removal and
off-Site disposal) will not be implemented until after the NYSDEC
completes its investigation and the sources of contamination are
identified and eliminated.
-------
Concerning the potential for illegal dumping along the 2,200-foot
length of the industrial drainageway, as in numerous other cases,
there is _no way to completely protect against such activities.
While laws exist prohibiting such activities, there are no
practical measures that can be imposed to ensure against them.
Comment No.7: Upon hearing the previous concern expressed at the
public meeting, another citizen has requested aggressive
prosecution of those causing the contamination.
EPA Response: The white "floe-like" material observed floating in
the Industrial Drainageway by local land owners and regulatory
officials since the Spring of 1995 was found to contain elevated
levels of several heavy metals, including lead, cadmium and
chromium. Such levels exceed the allowable limits established for
such chemicals on the discharge permits issued by the New York
State Department of Environmental Conservation (NYSDEC) for the
Westinghouse Facility. The NYSDEC permitting authority is
currently conducting an investigation to identify the source(s) of
such ongoing releases, and it is the EPA's understanding that
Westinghouse and the operators at the Westinghouse Facility are
cooperating in this effort to determine if the unauthorized
releases are a result of their wastewater treatment operations. In
the event that .the source (s) of the release are identified,
appropriate response actions will be taken by the NYSDEC or Federal
permitting authorities to eliminate those discharges. Such
response actions may including legal actions, if deemed to be
appropriate.
Preferred Alternatives for OU3
Comment No.8: A citizen stated concurrence with EPA's preferred
alternative for OU3, namely, Removal and Off-Site Disposal, but is
concerned about EPA's preference for Alternative 3B - Option 2,
Physical Treatment by Soil Vapor Extraction (SVE) with Air Sparging
(AS) , for the Former Runoff Basin Area. Would EPA consider a
combination of Alternatives 2B (Removal and Off-Site Disposal) and
3B to maximize the cleanup?
EPA Response; The EPA selected Alternative 3B because it will
effectively remove TCE from the soils at the Former Runo-ff Basin
Area to the established cleanup level, including those soils in
close proximity to building foundations and underground utilities.
The removal of TCE to the cleanup level will prevent the further
leaching of TCE to ground water.
8
-------
Alternative 2B is a more difficult remedy to implement because of
the presence of such structures. The excavation of contaminated
soils would require shoring of the excavation walls, rerouting of
utilities, and dewatering operations. Even with implementation of
these measures, it is uncertain if all of the TCE contamination can
be reached. Consequently, Alternatives 2B and 3B are deemed to be
potentially less reliable for ensuring that all of the TCE
contamination is remediated.
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APPENDIX A
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Kentucky Avenue Wei I field
Superfund ~"
Horseheads
Chemung County, New York
EPA
Region 2
PURPOSE OF PROPOSED PLAN
This Proposed Plan describes the remedial alternatives
considered for addressing two areas of soil contamination at
the former Westinghouse Electric Corporation (Westing-
house) Industrial and Governmental Tube Division facility
{Facility) and contaminated sediments in a related industrial
rainageway which are part of the Kentucky Avenue
Wellfield Superfund site (Site).1 This Proposed Plan also
identifies the preferred remedial alternatives and explains the
rationales for such preferences. 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
EPA is issuing this Proposed Plan as part of its public
participation responsibilities under Section 117(a) of the
Comprehensive Environmental Response, Compensation, and
Liability Act (CERCLA) of 1980, 42 U.S.C. §§ 9601 - 9675,
as amended, and 40.CFR 300.430(f) of the National Contin-
gency Plan (NCP). The alternatives summarized herein for
the Facility and industrial drainageway are described in the
remedial investigation and feasibility study (RI/FS) reports,
which should be consulted for a more detailed description of
all the alternatives.
This Proposed Plan is being provided as a supplement to the
RI/FS reports to inform the public of the EPA and the
NYSDEC's preferred remedies and to solicit public comments
pertaining to all the remedial alternatives evaluated, as well
as the preferred alternatives.
The Site is identified by the New York State Department of
Environmental Conservation as the Westinghouse Electric Corporation,
Site No. 8-08-007.
August 1996
The remedies described in this Proposed Plan are the pre-
ferred remedies for the Site. Changes to the preferred
remedies or a change from a preferred remedy to another
remedy may be made if public comments or additional data
indicate that such change will result in a more appropriate
remedial action. The final decision regarding the selected
remedies will be made after the EPA has taken into consider-
ation all public comments. We are soliciting public comment
on all of the alternatives considered in the detailed analysis of
the RI/FS because the EPA and the NYSDEC may select
remedies other than the preferred remedies.
COMMUNITY ROLE IN SELECTION PROCESS
The EPA and the 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 documentation
have been made available to the public for a public comment
period which begins on August 28, 1996 and concludes on
September 26,1996.
A public meeting will be held during the public comment
period at the Village of Horseheads Hall located at 202 South
Main Street in Horseheads, New York on September 11,1996
at 7:30 p.m. to present the conclusions of the RI/FS, to elabo-
rate further on the reasons for recommending the preferred
remedial alternative, and to receive public comments.
Comments received at the public meeting, as well as written
comments, will be documented in the Responsiveness
Summary Section of the Record of Decision (ROD), which is
the document which formalizes the selection of the remedy.
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All written comments should be addressed to:
Mark Purcell
Project Manager
U.S Environmental Protection Agency
290 Broadway, 20th Floor
New York, New York 10007-1866
MARK YOUR CALENDAR
August 28 - September 26,1996
Public comment period on RI/FS report, Proposed
Plan, and remedies considered
September 11,1996 at 7:30 p.m.
Public meeting at the Village of Horseheads Hall
202 South Main Street
Horseheads, NY
Copies of the RI/FS reports. Proposed Plan, and sup-
porting documentation are available at the following
repositories:
Town of Horseheads Town Hafl -».,, '
150 Wygant Road v
Horseheads, New York 14841
Phone:(607)739-8783
Hours: M-F; 8:30-4:30 p.m.
New York State Department of
Environmental Conservation
50 Wolf Road
Albany, New York 12233-7010
Phone:(518)457-4343
Hours: M-F; 8:30-4:45 pm »-,,-.
SCOPE AND ROLE OF ACTION
Site remediation activities are sometimes segregated into
different phases, or operable units, so that remediation of
different environmental media can proceed separately,
resulting in an expeditious cleanup of the entire site. The
EPA has designated three operable units for this Site. The
remedies discussed in this Proposed Plan will address the two
areas of soil contamination at the Facility and the sediment
contamination in the industrial drainageway, which reprej
the third operable unit (OU3). The remedy for the
operable unit provided the community with an alternative
water supply to prevent ingestion of ground water contami-
nated by volatile organic compounds (VOCs), primarily
trichloroethylene (TCE). An interim remedy selected for the
second operable unit (OU2) will restore the Kentucky Avenue
Wellfield (KAW) as a public drinking water supply and
prevent the further spread of contamination within the
ground-water aquifer, known locally as the Newtown Creek
Aquifer.
The purpose of the OU3 investigation was, in part, to evaluate
remedial options for source control at the Facility and a final
restoration plan for the Newtown Creek Aquifer. The
remedies which address the two areas of soil contamination
at the Facility are source control measures to complement the
interim ground-water remedy selected for OU2. They also
address threats posed by direct contact with contaminated
surface soils. The remedies which address contaminated
sediments in the industrial drainageway are to mitigate the
threat posed by consumption of fish in an adjacent 7-acre
pond, known locally as Koppers Pond. The contaminated
sediments in the industrial drainageway are believed to
source of the polychlorinated biphenyis (PCBs) present in
fish.
Based on the findings of the RI/FS for OLJ3, no further
ground-water treatment is warranted beyond that specified as
the interim remedy for OU2, nor is further modification of
such remedy necessary. Therefore, the EPA is proposing that
the OU2 interim remedy becomes the final remedy for
restoring the Newtown Creek Aquifer to its beneficial use as
a drinking water aquifer at this Site.
Based on an initial screening of ecological risk associated
with Koppers Pond, the EPA determined that further investi-
gation of the environmental conditions in the Pond and the
outlet stream south of the Pond are warranted. The EPA
plans on conducting this investigation as part of a supplemen-
tal study.
SITE BACKGROUND
The Site is located in the Village and Town of Horseheads
and the Village of Elmira Heights in the south central portion
of Chemung County, New York. The Site is approximately
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4,500 acres in areal extent and is bounded by Hawes Hill to
the west of New York (NY) Route 14, the Village of Elmira
Heights to the south, the Newtown Creek to the east, and the
Village of Horseheads to the north (see Site Location Map -
Figure 1). The Site includes the KAW and the contaminated
portions of the underlying ground-water aquifer and the
source areas contributing to such contamination.
Not 10 Scale
Figure 1
The KAW is located east of NY Route 14 and approximately
one mile south of the intersection of NY Routes 14 and 17.
The KAW is part of the Elmira Water Board (EWB) public
water supply system and consists of a single production well
and three test wells. It was constructed in 1962 and provided
approximately 10 percent of the potable water produced by
the EWB until its closure in 1980, following the discovery of
elevated levels of TCE.
Contamination of the KAW with TCE was first detected in
May 1980 during an inventory of local wells initiated by the
New York State Department of Health (NYSDOH). Further
ground-water sampling in the area by the Chemung County
Health Department (CCHD) in July 1980 revealed elevated
levels of TCE at the KAW and several private residences and
commercial facilities. This finding led to the closing of the
KAW in September 1980 by the EWB. In July 1982, the Site
was proposed for inclusion on the Superfund National
Priorities List (NPL). The Site was placed on the NPL in
September 1983.
Subsequent ground-water sampling at residential wells by the
EPA, NYSDEC, NYSDOH, and CCHD through 1985
identified TCE and other VOCs throughout the Newtown
Creek Aquifer. The sampling results also revealed that TCE
levels exceeded permissible drinking water standards estab-
lished by the NYSDOH. Based on such findings, the EPA
connected 49 residences with contaminated drinking water
wells to the public water supply in 1985 and 1986.
An Rl/FS'was conducted by the NYSDEC under a coopera-
tive agreement with the EPA to determine the nature and
extent of ground-water contamination at the Site. The results
confirmed the presence of a ground-water contaminant plume
within the Newtown Creek Aquifer and extending beyond the
farthest downgradient monitoring wells (approximately one
mile south of the KAW). The ground water contained VOCs,
including TCE at concentrations up to 340 pans per billion
(ppb), trans-1,2-dichloroethylene (DCE), a degradation
product of TCE, and inorganic chemicals (i.e., metals) at
concentrations exceeding Federal and New York State (NYS)
drinking water standards.
Based on the results of that RI/FS and consideration of public
comments and community concerns, the EPA issued a Record
of Decision (ROD) on September 30, 1986. which required
the following: 1) the installation and sampling of ground-
water monitoring wells upgradient of the Sullivan Street
Wellfield, a second wellfield owned by the EWB and located
three miles south of the KAW; 2) identification of all resi-
dences using private drinking water wells within the area of
ground-water contamination for connection to a public water
supply; and, 3) initiation of a supplemental RI/FS to deter-
mine the nature and extent of contamination at the Site to
identify, in part, the primary sources of ground-water contam-
ination in the Newtown Creek Aquifer. The identification of
source areas would allow development of an effective
program of source control and contaminated ground-water
migration control.
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1986 ROD AND ACTIONS TAKEN
In accordance with the 1986 ROD, the EPA and the
NYSDEC conducted the following actions at the Site through
1994:
1. The NYSDEC installed monitoring wells upgradient of the
Sullivan Street Wellfield in July 1989 to monitor ground-
water quality. Analysis of ground-water samples collected
from those wells in January 1990 identified TCE at concen-
trations exceeding Federal and NYS drinking water standards.
The public water supply at the Sullivan Street Wellfield was
also found to be contaminated by TCE at levels exceeding
such standards. In April 1990, the EPA published an Expla-
nation of Significant Difference (ESD) to the 1986 ROD
announcing the design and construction of an air stripper
facility at the Sullivan Street Wellfield. This treatment
facility was constructed and operational by mid-1994.
2. The EPA connected an additional 46 residences and three
commercial properties which were using private drinking
water wells in the affected area of ground-water contamina-
tion to public water supply. Overall, a total of 95 residences
and three commercial properties were connected to public
water supplies between 1985 and 1994.
3. The EPA completed the supplemental RI/FS at the Site in
February 1990. Based on the results, the EPA concluded the
following:
the primary source of TCE contamination at and near
the RAW was the Westinghouse Facility;
the Facet Enterprises, Inc. (Facet) facility and LRC
Electronics. Inc. (LRC) facility were contributory
sources of contamination in the ground-water aqui-
fer, but such contamination had not impacted the
RAW; and,
the sediments in the industrial drainageway were
contaminated by inorganic chemicals, possibly as a
result of the permitted industrial discharges originat-
ing from the Westinghouse Facility.
The Facet facility, which is located downgradient of the
RAW, is another NPL Superfund site being remediated under
the direct oversight of the EPA. The LRC facility is located
northeast of the KAW and is being remediated under the
direct oversight of the NYSDEC.
Based on the results of the supplemental RI/FS, the EPA
issued a second ROD on September 28, 1990 selecting an
interim ground-water remedy, which consisted of the
ing: 1) restoration of the KAW as a public drinking
supply; 2) prevention of further spreading of contaminated
ground water within the Newtown Creek Aquifer by the
installation of ground-water recovery wells to intercept the
contaminant plume at a location between the KAW and the
Facility; 3) construction of two water-treatment facilities, one
located near the KAW and the other located between the
KAW and the Facility to treat recovered ground water to
Federal and NYS drinking water standards; and, 4) a long-
term monitoring program to monitor contaminant migration
and evaluate the effectiveness of the remedy.
The 1990 ROD designated that remedy as an interim remedy
because it did not address the source areas which were
contributing to ground-water contamination. Because the
Westinghouse Facility was identified as the primary source of
TCE contamination at the KAW, the 1990 ROD also called
for a RI/FS to address source control at that Facility and a
final remedy for restoring the Newtown Creek Aquifer to its
beneficial use as a drinking water aquifer. Additionally, the
study was to address the health threat posed by the contami-
nated sediments present in the industrial drainageway.
7990 ROD AND ACTIONS TAKEN TO DA TE
On June 28, 1991, the EPA issued a unilateral administrative
order under Section 106(a)of CERCLA.42 U.S.C. §9606. to
Westinghouse directing it to perform the remedial design
(RD) and implement the remedy described in the 1990 ROD.
The RD was completed in July 1996 and Westinghouse is
currently preparing to begin remedial construction activities
in late Summer/early Fall of this year. The EPA is preparing
a Fact Sheet which describes the design. Copies of the Fact
Sheet will be made available at the information repositories
identified on page 2. A community availability session will
be held to provide an opportunity for citizens to discuss the
design and aspects of construction with representatives of the
EPA. The time and place of the availability session will be
announced. The EPA will oversee all remedial construction
activities performed at the Site.
On August 6, 1991, the EPA and Westinghouse entered into
an administrative order on consent for Westinghouse to
perform an RI/FS at its Facility, the industrial drainageway.
and Koppers Pond, which are designated by the EPA as OU3.
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REMEDIAL INVESTIGATION SUMMARY FOR OPER-
BLEUNIT3
ie purpose of the Rl for OU3 was, in part, to determine the
nature and extent of contamination in the soils and ground
water at several potential source areas and areas of concern at
and near the Facility, and whether such areas have contrib-
uted to the ground-water contamination present at the KAW.
Overall, ten (10) separate areas were investigated in 1994 and
1995 (see Figure 2). Those areas are described in the next
section of this document.
The nature and extent of ground-water contamination beneath
the Facility were also evaluated to identify contaminant
sources. Ground-water samples were collected for analysis
from twenty-seven (27) on-site monitoring wells and one
Facility production well in 1994 and 1995.
Additionally, the RI further characterized the nature and
extent of contamination in the sediments, surface water, and
biota (fish) in the industrial drainage way and Koppers Pond
(see Figure 3).
Pilot-scale testing was conducted in 1995 to determine
whether soil vapor extraction (SVE) would be an effective
ichnology for the in-situ treatment (i.e., removal) of TCE
om the soils at the Facility. Based on the success of the
pilot-scale testing, SVE is a treatment technology evaluated
under Remedial Alternatives 4A and 3B. See section on
Summary of Remedial Alternatives.
FINDINGS OF THE REMEDIAL INVESTIGATION
Contaminant Source Areas
Magnesium Chip Burial Area: Westinghouse plant records
indicated that from 1973 to 1975, ignitable and reactive
magnesium chips and titanium turnings were containerized in
30-gallon drums and then placed in 55-gallon drums that were
subsequently filled with concrete and buried in an 8-foot by
215-foot trench located at the northern portion of the facility
and within approximately 400 feet of NY Route 17. It was
estimated that 196 drums were buried in this area.
Ground-Penetrating Radar (GPR) surveys and subsequent
trenching activities confirmed the presence of drums within
a narrow trench at a depth of 2 to 4 feet. The drums were
intact and did not appear to have impacted the surrounding
iils. Analysis of soil samples collected from depths between
and 8 feet revealed low levels of several semi-volatile
organic compounds (SVOCs), including polycyclic aromatic
hydrocarbons (PAHs), PCBs and metals. Magnesium
concentrations were below soil concentrations found gener-
ally in the area at the Site.
A total of 179 55-gallon drums were removed from the
Magnesium Chip Burial Area and sent off-site for disposal as
part of the removal action conducted by Westinghouse in
1995 (see section on Removal Action, below).
Calcium Fluoride Sludge Disposal Areas Nos. 1 and 2: Two
of the ten areas investigated at the Facility included the two
calcium fluoride sludge disposal areas located at the north
end of the West Parking Lot. The materials placed at these
disposal areas included sludges from the treatment of hydro-
fluoric acid wastewaters at a former fluoride treatment
operation.
One soil boring in Area No. 1 and two soil borings in Area
No. 2 revealed a white, damp, powdery material at depths
between 3 and 7 feet. Analytical results revealed the white
material to contain high levels of cadmium and several other
metals. Subsequent analyses using the toxicity characteristic
leaching procedure (TCLP) revealed the material to exhibit
the characteristics of a RCRA hazardous waste because of
teachable cadmium. Other chemicals detected in the soils at
depths between 2 and 12 feet included PAHs, PCBs and
metals at low concentrations. No TCE was detected in soil
samples from these two areas.
Approximately 1,240 tons of the white powdery material and
soil mixed with such material were excavated from the two
Calcium Fluoride Sludge Disposal Areas and sent off-site for
disposal as part of the removal action conducted by Westing-
house in 1995 (see section on Removal Action, below).
Former Runoff Basin Area: This is a storm-water runoff basin
consisting of an oval-shaped depression located north and
west of the main plant building. It is approximately 0.7 acre
in areal extent and is currently covered by lawn, asphalt
pavement and small man-made structures. A 7,500-gallon
above-ground tank used for storing chlorinated solvents was
located in this area at one time.
The GPR survey did not indicate the presence of any buried
objects in this area. TCE was detected in 43 of 59 subsurface
soil samples, with a maximum concentration of 79,000 parts
per billion (ppb), and maximum depth of 12 feet. The water
table was encountered at depths between 8 and 11 feet. The
soils having the highest concentrations of TCE are proximal
to the former location of the 7,500-gallon storage tank.
Additionally, TCE was detected at concentrations of 4 and 6
ppb in ground-water samples collected from the shallow and
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deep portions of the aquifer. Dibenzofuran, PAHs, PCBs and
metals were also present at low concentrations.
e soil and ground-water sample results confirmed that the
Former Runoff Basin Area is a source of TCE contamination
in ground water.
Disposal Area F: Plant records indicated that between 1971
and 1974, TCE still bottoms and degreaser sludges were
disposed in shallow (2 to 3 feet deep) trenches covering an
area about 75 feet by 100 feet. Subsurface trenching activi-
ties to the water table encountered various waste-like mate-
rial, including a coal slag or tar-like material at the surface,
coal-like material at a depth of approximately 2 feet, amber
beads, a dark brown and black sand and pea gravel, and a
layer of white, powdery material suspected of being waste
pumice.
Significant levels of VOCs, SVOCs and metals were detected
in soil samples collected at Disposal Area F. TCE was
primarily detected in soil and waste materials at the northern
portion of the disposal area from depths between 1 foot and
2.5 feet and at a maximum concentration of 20,000 ppb.
Ground water was encountered at depths between 11 feet and
12.5 feet.
Hs were also detected in surface soil samples, including
fluoranthene (700 parts per million or ppm), pyrene (610
ppm), benzo(b)fluoranthene (420 ppm), benzo(a)pyrene (310
ppm) and benzo(a)anthracene (290 ppm). Arsenic was
detected in surface and subsurface soils, with the maximum
concentration (18.9 ppm) in a soil sample collected from a
depth of 1.0 foot.
The soil sample results, along with the soil-gas and ground-
water headspace survey results from the MW-10 Area (see
section on MW-10 Area findings, below) confirmed that
Disposal Area F is a contributing source of TCE contamina-
tion to ground water.
Former Coal Pile Area: Plant records indicated that during the
1960s, TCE and TCE-related still bottoms and degreaser
sludges were placed on the coal at the Facility power house
fuel pile.
The GPR survey did not indicate the presence of any buried
objects at the Former Coal Pile Area. Twenty-one boreholes
were drilled to evaluate subsurface conditions. Analysis of
fifteen soil samples collected at depths between 2 and 10 feet
Jvealed low concentrations of several VOCs, including
luene (13 ppb) and TCE (6 ppb), SVOCs, PCBs and several
metals. Ground water was encountered at depths between 8
and 11 feet.
Based on these findings, the Former Coal Pile Area does not
appear to be a significant source of TCE contamination in
ground water.
MW-lQArea: Monitoring well MW-10 is located about 250
feet hydrologically downgradient of Disposal Area F, and
ground-water samples from this well have historically
revealed the presence of TCE. The purpose of conducting the
soil-gas and ground-water headspace surveys was to deter-
mine whether the TCE contamination at MW-10 was originat-
ing at Disposal Area F or another upgradient source or
whether additional sources were present in the immediate
vicinity of the MW-10 Area.
Soil-gas and ground-water headspace samples collected
between Disposal Area F and MW-10 at depths between 7
and 12 feet confirmed that TCE (98 ppb) in soil gas was
originating from Disposal Area F. Analytical results of three
ground-water grab samples collected from the survey bore-
holes at the MW-10 Area were consistent with the TCE
concentrations found in the soil-gas and ground-water
headspace surveys.
Analysis of soil samples collected at a depth of approximately
3 feet at the MW-10 Area revealed the presence of TCE (32
ppb) and other VOCs, PAHs, PCBs and several metals at
concentrations below remedial action objectives (RAOs) (see
section on RAOs, below).
The results of the soil sample analyses and the soil-gas and
ground-water headspace surveys indicate that Disposal Area
F is the source of the TCE contamination in ground water at
the MW-10 Area. No other source of TCE was identified
upgradient of Disposal Area F or in the immediate vicinity of
the MW-10 Area.
Soil Pile: Soil removed from previous on-site construction
activities was stockpiled south of the West Parking Lot. A
soil gas survey conducted at depths of 5 and 10 feet in the
Soil Pile did not detect any VOCs. Analysis of soil samples
collected from a depth of 0 to 2 feet revealed low concentra-
tions of VOCs, SVOCs, PCBs and several metals. TCE
(0.008 ppm) was below the established RAO of 0.8 ppm for
TCE. SVOCs included the following PAHs: benzo (a)
anthracene (1.9 ppm), benzo (b) fluoranthene (1.5 ppm) and
benzo (a) pyrene (1.2 ppm). The 1.2 ppm level for benzo (a)
pyrene exceeded the RAO of 0.78 ppm. The maximum PCB
concentration was 3.2 ppm. Manganese was detected at a
concentration of 1,220 ppm.
The PCB and PAH contaminated sediments at the Soil Pile
were removed and transported off-site for disposal as pan of
the removal conducted by Westinghouse in 1995. The
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remaining uncontaminated soil was used as backfill material
at the two calcium fluoride sludge disposal areas after the
removal was conducted (see section on Removal Action,
below).
Area Southwest of the West Parking Lot: A 1970s memoran-
dum from a former plant environmental officer suggests that
plant wastes may have been disposed of at this area. Soil-gas
and ground-water headspace surveys detected low concentra-
tions of TCE (<10 ppb) at six survey locations. Analysis of
ten (10) soil samples collected from a depth of 3 to 4 feet
revealed low levels of VOCs, SVOCs, PCBs and several
metals, including arsenic at 10.5 ppm.
Based on these findings, this area does not appear to represent
a source of TCE in ground water.
Surface-Water Runoff Drains: Site reconnaissance identified
31 surface-water runoff drains present at the Facility. Since
concrete or cobbles lined five of these drains, only the other
26 were investigated during the RI. The soil in these drains
were found at depths between 4 and 6 feet and each drain had
a manhole cover. The drains were investigated to determine
if they serve as receptors or conduits for liquid waste materi-
als to reach the underlying soil and ground water.
Analyses of 26 soil samples collected from depths of 5 to 15
feet showed concentrations of various VOCs, SVOCs,
pesticides and metals. The most frequently detected VOC
was toluene (13 of 26 samples) at a maximum concentration
of 270 ppb. TCE was also detected, but at very low concen-
trations. SVOCs detected included PAHs, phthalates and
phenols. Fluoranthene (810 ppm), pyrene (650 ppm) and
phenanthrene (630 ppm) were detected at the highest concen-
trations. Eighteen pesticides and two PCBs were detected,
with PCB levels all less than 1.0 ppm. Twenty-two
inorganics were detected, with twelve of these detected in all
26 samples, including lead (421 ppm) and zinc (422 ppm).
Based on these findings, it does not appear that the surface-
water runoff drains act as conduits for TCE or other VOCs to
leach to ground water. The PAHs are believed to be the
result of storm water runoff across the large areas of asphalt '
pavement at the Facility.
New York Route 17: An area of NYSDOT right-of-way for
NY Route 17, which is beyond the Facility property, was
investigated when an anonymous source reported witnessing
an alleged disposal of 350 to 500 fifty-five gallon drums in
this area during construction of NY Route 17.
The results of soil-gas and ground-water headspace analysis
from depths between 19 and 35 feet at twenty-two locations
beneath NY Route 17 revealed low levels of VOCs. including
tetrachloroethane (14 ppb), total xylenes (11 ppb), benzene (6
ppb) and TCE (<3 ppb). Benzene and total xylenes ar^^
associated with petroleum and petroleum product derivative^^H
Such levels are believed to be too low to represent a source of
contamination. No buried drums were encountered during
this investigation.
Ground Water
Ground Water: The results of an investigation conducted by
Westinghouse at its Facility in 1987 and 1988 revealed the
presence of TCE and several other VOCs and metals in
ground water beneath the eastern and southern portions of the
Facility. Based on that investigation and the results of the
EPA's supplemental RI/FS for OU2, the EPA concluded that
the Facility was the primary source of TCE contamination in
the aquifer at the KAW. Additionally, as discussed above.
the purpose of OU3 was to evaluate options for source control
at the Facility and final restoration of the Newtown Creek
Aquifer. Therefore, an evaluation of ground water was
included in the RI/FS for OU3 to identify contaminant source
areas and determine what further remedial efforts, in addition
to the interim ground-water remedy selected for OU2. were
warranted for ground water.
Analysis of ground-water samples collected from monitoring
wells at the Facility in 1994 confirmed that several VOCs,
including primarily TCE (120 ppb) along with 1,1,1 -trichloro-
ethane (8.5 ppb), 1,2-dichloroethene (total) (4 ppb) and
chloromethane (140 ppb), have contaminated the shallow and
deep portions of the ground-water aquifer beneath the
Facility. The highest TCE concentrations were detected in
wells located along the southern portion of the property.
Isoconcentration contour maps define the distribution of TCE
in both the shallow and deep aquifer zones as narrow,
elongated plumes originating from the vicinity of Disposal
Area F and extending eastward, in a downgradient direction,
through the MW-IO Area and beyond the southeast comer of
the Facility.
Analysis of ground-water samples collected from the on-site
monitoring wells also revealed several metals, including
chromium, nickel and cadmium at concentrations exceeding
Federal and NYS Maximum Contaminant Levels (MCLs).
However, the metals are believed to be attributable to
paniculate matter either in the aquifer (clays) or in the well
screen as a result of artifacts of well construction. An
analysis of ground-water samples from a downgradient plant
production well (SW-5) for both total metals (unfiltered
samples) and dissolved metals (filtered samples) revealed
concentrations below MCLs. Although metals are present in
ground water beneath the Facility, they do not appear to be
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migrating off-site and therefore, the Facility is not considered
contributory source of metals contamination at the KAW.
ased on the findings of the RI/FS, the EPA has determined
that further ground-water treatment is not warranted beyond
that specified for the OU2 interim remedy in the 1990 ROD,
the 1991 administrative order, and the approved remedial
design for OU2. Therefore, the EPA proposes that the
interim remedy become the final remedy for restoring the
Newtown Creek Aquifer to its beneficial use as a drinking
water aquifer at the Site.
Industrial Drainageway
Industrial Drainageway and Koppers Pond: The industrial
drainageway is a 7 to 10 foot wide and 3 to 12 inch deep open
ditch or channel which begins at the Chemung Street outfall,
approximately 1,500 ft southeast of the Facility, and extends
approximately 2,200 feet in a southeastward direction to
Koppers Pond. It receives permitted wastewater discharges
and storm-water runoff from the Westinghouse Facility.
Koppers Pond is bounded to the west by railroad tracks and
to the north and northeast by the Old Horseheads Landfill. It
is approximately 3 to 6 feet deep and flows into an outlet
stream to the south, which ultimately drains into Newtown
eek.
The industrial drainageway and Koppers Pond were investi-
gated as part of OU3 because the results of the supplemental
RI/FS for OU2 revealed that several metals, primarily
cadmium, were present in the sediments of the industrial
drainageway at levels which posed a health risk from direct
contact exposure. Additionally, because TCE had historically
been a permitted discharge parameter at varying levels in the
treated waste waters released to the industrial drainageway
from the Facility, the industrial drainageway was considered
as a possible migration pathway for TCE to impact ground
water at the KAW (i.e., surface water to ground water).
Surface water and/or sediment samples were collected for
analysis from twenty (20) locations within the industrial
drainageway system, including the underground piping
between the drainageway and the Facility, Koppers Pond and
the outlet stream south of Koppers Pond.
Surface-water samples contained several VOCs, including
TCE (8 ppb) and toluene (44 ppb), SVOCs, pesticides and
metals. The metals included cadmium (20 ppb), chromium
(28 ppb), copper (55 ppb), and lead (345 ppb) from samples
Collected in the open drainageway. The current permitted
harge limit for TCE at the Facility wastewater treatment
ants is 11 ppb.
The sediment samples contained elevated concentrations of
several VOCs, SVOCs, pesticides, PCBs, and metals. The
VOCs included toluene (38 ppb), carbon disulfide (27 ppb)
and TCE (25 ppb).
The 1994 sediment samples, which were collected from a
depth of 0-2 feet, contained PCBs (total) at concentrations
ranging up to 8.6 ppm, with the highest concentrations found
in the samples collected from the upstream portion of the
industrial drainageway (sample locations 6-12; see Figure 3).
The highest concentration of PCBs detected in the sediments
collected from Koppers Pond was 1.6 ppm. PCBs were not
detected in the sediment samples collected from the outlet
stream south of Koppers Pond. PCBs were also not detected
in any surface-water samples collected from this area.
The 1995 sediment samples, which were collected from a
depth of 0 to 6 inches, contained lower levels of PCBs than
that of the 1994 samples. The highest PCB concentration
detected in samples collected from both the industrial
drainageway and Koppers Pond was 1.2 ppm.
The metals detected in the sediment samples included
cadmium (1,055 ppm), chromium (378 ppm), copper (870
ppm), lead (1,810 ppm), nickel (213 ppm) and zinc (10,775
ppm). The highest concentrations were from sediment
samples collected from the industrial drainageway. The
metals concentrations in sediment samples collected from
Koppers Pond and the outlet stream south of Koppers Pond
were generally an order of magnitude lower than those
concentrations found in samples from the industrial
drainageway.
Based on these findings, a source of PCB contamination in
the industrial drainageway is believed to be from the Facility.
where PCBs have been detected in soil samples collected
from most of the areas investigated during the Rl. The
highest PCB concentration found at the Facility was 3.2 ppm
in a soil sample collected from the Soil Pile. Because the Soil
Pile was generated as part of previous construction activities
believed to be associated with plant expansions in 1987 and
1988, the precise source of the Soil Pile is not known.
Elevated concentrations of metals in the industrial
drainageway sediments and surface water are believed to be
the direct result of previous and ongoing permitted discharges
from the Facility. Additionally, unauthorized releases from
a currently unknown source are believed to have also im-
pacted the sediments and surface water in the industrial
drainageway.
-------
Beginning in the Spring of 1995, local citizens and represen-
tatives of Federal and NYS regulatory agencies have observed
a significant amount of a whitish-brown material floating in
the industrial drainageway. Analysis of this material revealed
elevated concentrations of several metals, including lead
(14.600 ppm), cadmium (334 ppm), and chromium (294
ppm). No PCBs were detected.
Subsequent sampling and analysis of the whitish-brown
material by the NYSDEC in September 1995 indicated
elevated levels of several metals, including lead (5,800 ppm),
zinc (6,220 ppm), chromium (347 ppm), and cadmium (116
ppm). Samples obtained and analyzed by the NYSDEC in
June 1996 also contained lead (2,300 ppm), copper (1,100
ppm), aluminum (11,000 ppm), chromium (200 ppm), and
cadmium (180 ppm).
The NYSDEC is currently conducting an investigation to
identify the possible source(s) of such ongoing releases. As
pan of that investigation, a Facility operator has agreed to
perform an investigation of its wastewater treatment plant
operations under the direct oversight of the NYSDEC.
Fish: Analyses of fish samples (carp and large mouth bass
species) collected at Koppers Pond by the NYSDEC in 1988
revealed concentrations of total PCBs at approximately 4.0
ppm, which exceeded the Food and Drug Administration
(FDA) limit of 2.0 ppm for total PCBs in fish. Based on such
data, the NYSDOH issued a fish consumption health advisory
for Koppers Pond recommending that the consumption of
carp be limited to one meal per month for the general popula-
tion and avoiding fish consumption for women of child
bearing years and children under the age of fifteen (see
NYSDOH Health Advisory Chemicals in Sport Fish and
Games). In light of such findings, fish-tissue-sample analysis
was included as pan of the RI for the industrial drainageway
and Koppers Pond.
White sucker and carp species were collected by
electroshocking technique at Koppers Pond in June 1995. All
fish samples collected were relatively small (approximately 6-
9 inches). Thirteen fish-tissue samples were prepared by
filleting and removal of skin. The samples were analyzed for
Target Compound List (TCL) and Target Analyte List (TAL)
chemicals. The fish-tissue analyses revealed concentrations
of VOCs, PCBs and metals. The VOCs included carbon
disulfide (589 ppb), acetone (474 ppb), and toluene (11 ppb).
The PCB (Aroclor 1254) levels ranged up to 0.54 ppm.
Fifteen metals were also detected, including arsenic at a
maximum concentration of 0.1 ppm.
SUMMARY OF RISK
Based upon the results of the RI, a baseline human health risk
assessment and screening level ecological risk assessn
were conducted by the EPA to estimate the risks associate
with current and potential future site conditions. These risk
assessments estimate the human health and ecological risk
which could result from the contamination at the Facility,
industrial drainageway, and Koppers Pond if no remedial
actions were taken.
Human Health Risk Assessment
A four-step process is utilized for assessing site-related
human health risks for a reasonable maximum exposure
scenario: Hazard Identification-identifies the contaminants
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 poten-
tial 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 relation-
ship between magnitude of exposure (dose) and severity of
adverse effects (response). Risk Characterization-summa-
rizes and combines outputs of the exposure and toxicity
assessments to provide a quantitative assessment of site-
related risks.
The baseline risk assessment began with selecting contam-
inants of concern which would be representative of risks
associated with OU3. These contaminants included VOCs,
SVOCs, PCBs, pesticides and metals in various media.
Several of the contaminants, including TCE, PCBs and
arsenic are known to cause cancer in laboratory animals and
are suspected to be human carcinogens.
The baseline risk assessment evaluated the health effects
which could result from exposure to contamination as a result
of ingestion, dermal contact and inhalation of untreated soils:
the ingestion and dermal contact of surface water and sedi-
ments; and the ingestion of fish. Specifically, human recep-
tors evaluated for exposure to contaminated soils at the
Facility were Site workers, employees and on-site construc-
tion workers in present and potential future industrial land use
scenarios. Such exposures were also evaluated for adult and
child residents in the potential future residential land use
scenario. At the industrial drainageway and Koppers Pond,
area residents (teenage trespassers) were evaluated for
exposure to contaminated surface water and sediment, and
10
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^wai
area residents (adults) were evaluated for exposure to contam-
ted fish in present and future residential land use scenarios.
Although a future residential land use scenario is included in
the assessment for the Facility, the property is currently
industrial and zoned for industrial uses only. Additionally, it
is not anticipated that the industrial setting will change in the
foreseeable future. Therefore, the remedial alternatives
discussed in this Proposed Plan for the Facility address only
those risks associated with the present and future industrial
land use settings (see section below on Summary of Remedial
Alternatives).
Current federal guidelines for acceptable exposures are an
individual lifetime excess carcinogenic risk in the range of 10"
4 to 10"6 (e.g.. over a 70-year period of exposure, the likeli-
hood of an additional instance of cancer developing is one-in-
ten-thousand to one-in-a-million) and a maximum health
Hazard Index (HI), which reflects noncarcinogenic effects for
a human receptor, equal to 1.0. An HI greater than 1.0
indicates a potential of noncarcinogenic health effects.
The results of the baseline risk assessment indicate that
surface soil at the Facility and contaminated fish at the
industrial drainageway and Koppers Pond pose an unaccept-
le risk to human health. Carcinogenic risk (i.e., cancer
sk) as a result of ingestion of surface soil by present and
potential future Site workers/employees at Disposal Area F
was estimated to be 5.1 x 104. This number means that
approximately five (5) additional persons out of 10,000 who
are most likely to receive the maximum exposure are at risk
of developing cancer if the soils are not remediated. The
cancer risk is attributable primarily to carcinogenic PAHs
(i.e., benzo(a)pyrene, benzo(b)fluoranthene,
benzo(a)anthracene and Indeno( 1,2,3-cd)pyrene) and arsenic.
The noncarcinogenic His estimated for ingestion of surface
soils by these receptor groups were below the EPA's target
level of one.
The carcinogenic risk related to ingestion of contaminated
fish in the industrial drainageway and Koppers Pond by area
residents (adults) was estimated to be 3.8 x 10"*. This risk
exceeds the EPA's 10'4 to 10 target risk range and is
attributed to PCBs (Aroclor 1254) and arsenic. The HI
related to fish ingestion by an adult was estimated to be 6.9.
This value exceeds the EPA's target level of 1.0 and is
attributed to Aroclor 1254 and arsenic.
11 other areas and environmental media investigated during
RI presented health risks which were below or within the
'A's \Q~* to 10"* target risk range for carcinogens or below
the EPA's HI target level of one for noncarcinogenic health
hazards.
Actual or threatened releases of hazardous substances,
pollutants and contaminants from the Facility, if not ad-
dressed by the preferred alternative or one of the other active
measures considered, may present a current or potential threat
to public health or welfare.
Ecological Risk Assessment
To assess the effect of site-related contaminants on the
ecosystems in the industrial drainageway and Koppers Pond.
the EPA performed a screening level ecological risk assess-
ment. The initial step of this assessment was to screen
contaminant concentrations detected in the sediment and
surface water samples against ecological criteria established
for the protection of aquatic and terrestrial wildlife and their
habitats.
Following ecological screening, three contaminants of
concern (i.e., cadmium, lead and Aroclor 1254) were used in
conjunction with site-specific biological species/habitat
information for characterizing ecological risk. Two receptor
species identified at the Site, the great blue heron and racoon,
were selected for ecological risk modeling. The potential
exposure pathways used for those receptor species were the
ingestion of contaminated fish and ingestion of surface water
and sediments. To perform the exposure assessment, the
EPA estimated exposure point concentrations (daily doses)
based on the fish fillet data obtained during the RI and
sediment bioaccumulation factors.
Ecological screening revealed that several metals, including
cadmium, chromium, copper, lead, nickel and zinc, along
with PCBs, are present in the sediments at levels which may
have an adverse effect on benthic organisms and/or upper
trophic level receptors (i.e.. aquatic and terrestrial wildlife).
Concentrations of many of these metals exceed severe effects
levels (SELs) screening criteria, which are defined to be
detrimental to the majority of benthic organisms.
Surface-water analytical data indicate that levels of metals
(e.g., cadmium, copper and lead) may also present an adverse
risk to biota. Such levels exceed the NYSDEC Ambient
Water Quality Standards for Class C surface waters and
Federal Ambient Water Quality Criteria chronic effect levels.
Additionally, Aroclor 1254 levels detected in fish tissue
samples exceeded the NYS whole body fish criteria for PCBs
and indicate that the contaminant is bioaccumulating at levels
known to be associated with adverse ecological effects.
Aroclor 1254, cadmium and lead dosage calculations per-
formed for the great blue heron and racoon, when compared
to known reference doses for toxicity, also revealed that
11
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estimated daily doses of such contaminants are at or exceed
levels which cause adverse ecological effects in organisms.
Field observations in 1994 and 1995 revealed a fairly diverse
wildlife community around Koppers Pond, but the aquatic
habitat appeared to be stressed. Koppers Pond appeared to be
depauperate of fauna. No small fish, tadpoles or newts were
observed in the pond and no benthic organisms were sited in
the industrial drainage way, nor in the sediment samples
collected from the industrial drainage way, the pond, and
outlet stream south of the pond.
In light of the findings of the screening level ecological risk
assessment and field observations, the EPA has determined
that further field investigations are warranted at this time to
assess the extent of environmental impacts to this area. Such
investigation will determine the actual toxicity of the sedi-
ments to benthic organisms in Koppers Pond and the outlet
stream south of Koppers Pond. The EPA plans to conduct
such an investigation as part of a supplemental study.
REMOVAL ACTION
On September 27, 1995, the EPA and Westinghouse entered
into an administrative order on consent for Westinghouse to
remove an estimated 196 buried 55-gallon drums containing
magnesium chips and titanium turnings waste from the
Magnesium Chip Burial Area and hazardous soils at the two
Calcium Fluoride Sludge Disposal Areas containing a white
material having characteristics of a RCRA hazardous waste.
The buried drums and hazardous soils constituted a release
and/or threat of release to the environment and therefore were
removed from the Facility.
In late 1995 and early 1996, Westinghouse excavated and sent
off-site for disposal the following materials:
1. A total of 179 55-gallon drums (284.9 tons) were removed
from the Magnesium Chip Burial Area, opened to confirm
that the wastes were encased in concrete, and sent off-site for
proper disposal;
2. At the two Calcium Fluoride Sludge Disposal Areas,
approximately 1,240 tons of the white powder sludge material
and soil mixed with such material were excavated and sent
off-site for disposal as RCRA hazardous waste; and,
3. Four truck loads of soil containing PCBs and PAHs were
removed from the Soil Pile area and taken off-site for dis-
posal, with the remaining uncontaminated soil used to backfill
other areas excavated during the removal.
Confirmation soil sampling and analysis confirmed that the
residual soils at the excavations of the two Calcium Fluoride
Sludge Disposal Areas and the Magnesium Chip Burial Area
met the EPA's established risk-based cleanup objectives.
REMEDIAL ACTION OBJECTIVES
RAOs are specific goals to protect human health and the
environment; they specify the contaminant(s) of concern, the
exposure route(s), receptor(s), and acceptable contaminant
level(s) for each exposure route. These objectives are based
on available information and standards such as applicable or
relevant and appropriate requirements (ARARs) and nsk-
based levels established in the risk assessment.
RAOs were developed for two contaminated media, namely.
soil at the Facility and sediment in the industrial drainageway.
RAOs for soil are designed, in part, to mitigate the health
threat posed by ingestion, dermal contact or inhalation of
particulates where these soils are contacted or disturbed.
Such objectives are also designed to mitigate the potential of
these soilsas continuing sources of contamination to ground
water. The areas requiring soil remediation are Disposal Area
F and the Former Runoff Basin Area. As previously indi-
cated, the Calcium Fluoride Sludge Disposal Areas, the
Magnesium Chip Burial Area, and the Soil Pile were ad-
dressed as part of the removal action and therefore, do not
require soil remediation.
The RAOs established for the industrial drainageway sedi-
ments will reduce health threats posed by direct contact
pathways and limit the availability of PCBs for fish uptake,
thereby serving to reduce the health threat posed by fish
consumption.
Soils: The overall RAO is to prevent direct contact with soils
that pose an unacceptable risk (i.e., carcinogenic risk greater
than the EPA's 10'4 to 10 target risk range or a
noncarcinogenic HI greater than one) under the present and
future industrial land use scenarios. In order to determine
which areas at the Facility require soil remediation, cleanup
goals were established for those contaminants of concern
identified in the EPA's risk assessment for each area
investigated. The cleanup goals or concentrations are
calculated such that the carcinogenic risk posed by the soils
residual contaminant levels after cleanup are no greater than
1 x 10'6.
Based on such calculations, the only potential source area at
the Facility having soil contamination levels that exceed the
established risk-based cleanup goals is Disposal Area F. The
contaminants of concern which exceed such goals are four
12
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PAHs and arsenic. The calculated risk-based RAOs for the
AHs are as follows:
Benzo(a)anthracene 7.80 ppm
Benzo(a)pyrene 0.78 ppm
Benzo(b)fluoranthene 7.80 ppm
Indeno( 1,2.3-cd)pyrene 7.80 ppm
Because the risk-based cleanup goal for arsenic is below the
background level at the Site, it cannot be achieved. A
background level of 26.5 ppm for arsenic was calculated
based on data from 16 soil samples collected at depths
between 0 to 2 feet and 10 to 12 feet along the perimeter of
the Facility. However, because this value was above the
normal background range for arsenic in New York (3 to 12
ppm), as described by the NYSDEC Technical and Adminis-
trative Guidance Memorandum (TAGM), the EPA decided to
use the maximum background value provided by the TAGM
(12 ppm) as a more conservative cleanup goal.
Soils at several other potential source areas, in addition to
Disposal Area F, have arsenic levels higher than the risk-
based cleanup goal calculated for arsenic, but such levels are
below the established cleanup goal of 12 ppm.
nder the future industrial setting, there are no instances in
hich the HI associated with exposure to surface soil at the
Facility exceeds the EPA's target level of one.
Based on the EPA's baseline risk assessment, no RAOs are
required for subsurface soils as a result of or threat posed by
direct-contact exposure.
Protection of Ground Water: As part of the source control
effort to complement the OU2 ground-water remedy, RAOs
have been developed for those soils identified in the RI as
contributing to the contamination in ground water beneath the
Facility. TCE is present in the soils at Disposal Area F and
the Former Runoff Basin Area at concentrations which have
the potential to leach to ground water. To prevent further
leaching of TCE to ground water, an RAO of 0.8 ppm was
calculated for TCE based on a soil leaching model contained
in the EPA's 1994 Technical Background Document for Soil
Screening Guidance. For comparison, the NYSDEC's
established cleanup goal for TCE in soil is 0.7 ppm, as
defined in the TAGM.
Sediment: Based on the EPA's baseline human health risk
ssessment, the RAO for sediments at the industrial
inageway and Koppers Pond is to prevent exposure to
Bs through fish consumption and direct contact with
sediments. For mitigating such human health threats, a RAO
of 1.0 ppm PCB (total) is established for those sediments.
The 1.0 ppm level is consistent with the EPA and the
NYSDEC TAGM guidance for PCB cleanup levels in
residential areas. Remedial efforts would be focused on the
industrial drainageway sediments because PCB concentra-
tions exceeded the 1.0 ppm RAO. However, because the
PCB levels in the pond sediments were approximately equal
to the RAO, no remedial efforts will be considered for
Koppers Pond. The additional field investigation (i.e.,
supplemental study) will be performed, in part, to confirm
that such PCB levels are at or below the RAO.
SUMMARY OF REMEDIAL ALTERNA TIVES
CERCLA requires that each selected site remedy be protec-
tive of human health and the environment, be cost-effective,
comply with other statutory laws, and utilize permanent
solutions and 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.
The FS report evaluates in detail, twelve remedial alternatives
for addressing the contamination associated with OU3 at the
Kentucky Avenue Wellfield Site, four each for Disposal Area
F, the Former Runoff Basin Area and the industrial
drainageway. Because each of the areas to be remediated
differs with regard to the nature and extent of contamination,
general physical characteristics, and location, the EPA is not
recommending one remedial alternative for the entire opera-
ble unit, rather a specific remedy for each area of contamina-
tion.
The remedial alternatives proposed for OU3 are described
below. It should be noted that the numerical designation of
several alternatives in this Proposed Plan differ from those
used for the same alternatives contained in the FS Report.
Also, the time periods referenced below for construction and
operation of the remedial alternatives does not reflect that
period of time required to negotiate with the responsible
party, complete design work, and procure any contracts which
are necessary to implement the remedy.
Disposal Area F
Alternative 1A - No Action:
Capital Cost:
O & M Cost:
Present-Worth Cost:
Time to Implement:
0
0
0
None
13
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The Superfund program requires that the "No Action"
alternative be considered as a baseline for comparison of
other alternatives. The No Action alternative for Disposal
Area F provides for no further effort to avoid exposure to soil
or to control the leaching of contaminants to ground water.
The access controls for the Facility (e.g., security guard and
perimeter fence) would remain active. The existing, tempo-
rary fence around Disposal Area F would be left in place and
the area would remain a vacant, unused portion of the plant
site. TCE present in the soils would eventually leach into
ground water and migrate to the OU2 ground-water recovery
wells, where it would be extracted and treated.
Because this alternative, if selected, would result in contami-
nants remaining on-site above health-based levels, CERCLA
requires that the area be reviewed every five years.
Alternative 2A (Option 1)
Cover:
Capital Cost:
0 & M Cost (per year):
Present-Worth Cost:
Time to Implement:
Containment with Asphalt
$219,200
$19,200
$514,100
<1 year
Under this containment alternative. Disposal Area F would be
capped with a 40 mil (one mil = one-thousandth of an inch)
thick Flexible Membrane Liner (FML), 6-inch subbase layer
and 6-inch asphalt pavement. The paved area would cover
approximately 0.8 acres of ground surface and could be used
for parking. Institutional controls would include a deed
restriction to limit excavation work and further property use
or development, long-term physical monitoring to minimize
future worker contact and enforce the deed restriction, and
long-term ground-water monitoring to determine the ongoing
contribution of this area to TCE contamination in ground
water.
Because this alternative, if selected, would result in contami-
nants remaining on-site above health-based limits, CERCLA
requires that the area be reviewed every five years.
Alternative 2A (Option 2)
Permeability Cap:
Capital Cost:
O & M Cost (per year):
Present-Worth Cost:
Time to Implement:
Containment with Low-
$606,300
$34,200
$1,114,000
<1 year
approximate 29,200 square feet (0.67 acre) area. The
components of the cap would include a 2-foot thick clay
layer, 40 mil FML, 12-inch thick drainage layer with ove
ing geotextile filter fabric, 30-inch thick barrier-protectio
soil layer and 6 inches of topsoil. The capped area would
fenced, the deed restriction instituted and long-term physical
and ground-water monitoring performed.
Because this alternative, if selected, would result in contami-
nants remaining on-site above health-based limits, CERCLA
requires that the area be reviewed every five years.
Alternative 3A - Removal and Off-Site Disposal:
Capital Cost:
O & M Cost (per year):
Present-Worth Cost:
Time to Implement:
$549.000
$4,600
$619,600
<1 year
This alternative involves the excavation and off-site disposal
of approximately 1,100 cubic yards (1,600 tons) of contami-
nated waste materials. Prior to excavation, further sampling
and analysis would be conducted to classify the waste
material for off-site disposal. PAH and arsenic contaminated
soils are not listed RCRA hazardous waste and are not
expected to exhibit the characteristics of a RCRA waste.
Therefore, it may be possible to dispose of such waste in a
permitted solid waste landfill. Waste materials containing
TCE may not be suitable for landfill disposal, if they are
considered to be RCRA hazardous wastes subject to Land
Disposal Restrictions (LDRs). For such materials, the TCE
treatment standard is 6.0 ppm. Therefore, waste containing
TCE at concentrations above such standard may require
treatment in a permitted hazardous waste incinerator in
advance of land disposal. It is estimated that only 32 cubic
yards (50 tons) or approximately 3 percent of the total volume
(1,100 cubic yards) of waste material contain TCE at concen-
trations above the LDR standard.
The depth of excavation would be approximately 2.0 - 2.5
feet to meet designated cleanup goals for TCE, PAHs and
arsenic. Following excavation, confirmatory sampling and
analysis will be performed. With complete removal of the
waste materials exceeding cleanup goals, institutional
controls or post-remediation monitoring would not be
required.
Alternative 4A - Physical Treatment by Soil Vapor
Extraction:
This containment alternative involves placing a 6-foot thick
multi-layer, low permeability cap (i.e., RCRA cap) over an
Capital Cost:
O & M Cost (per year):
$525.900
$4.600
14
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Present-Worth Cost:
Time to Implement:
$596.500
Installation < 1 year
Operation - minimum 1 year
To address TCE contamination, a conventional SVE system
would be installed using vertical air extraction wells in the
area where TCE levels in soils exceed the cleanup goal of 0.8
ppm. These extraction wells would cause the movement of
soil vapor and some ground water through the unsaturated
soils towards the wells. The soil vapors withdrawn from
those wells would be sent through an off-gas treatment system
using granular activated carbon to remove TCE. Any ground-
water recovered with the soil vapor would be sent to the water
treatment facility installed as part of the ground-water remedy
for OU2. Because the TCE contaminated soils are relatively
near the surface (0-2.5 feet), a 40-mil FML would be placed
over the treatment area (1,200 square feet) to minimize short-
circuiting of air flow.
To address the PAH and arsenic contamination in the surface
soils, a 2-foot cover of imported clean soil would be placed
over the entire affected area to prevent direct-contact expo-
sure pathways. The upper six inches would consist of topsoil.
The treatment and cover area would be fenced, deed restric-
ns instituted and long-term physical monitoring imple-
ented. Long-term ground-water monitoring would be
performed until SVE is completed and the cleanup goal for
TCE is achieved.
Because this alternative, if selected, would result in the PAH
and arsenic contamination remaining on-site above health-
based limits, CERCLA requires that the site be reviewed
every five years.
Based on pilot-scale SVE testing, it is estimated that one year
of operation would be required to achieve TCE cleanup goals
in soils.
Former Runoff Basin Area
Alternative IB - No Action:
Capital Cost:
0 & M Cost:
Present-Worth Cost:
Time to Implement:
0
0
0
None
As stated above, the No Action alternative is considered as a
line for comparison of other alternatives. The No Action
temative would provide no further efforts to address TCE
leaching to ground water in this area. The access controls for
the Facility (e.g.. security guard and perimeter fence) would
remain active and the asphalt pavement would be left in
place. The TCE present in soils would continue to leach to
ground water for eventual extraction and treatment by the
ground-water recovery well system installed as part of the
OU2 remedy.
Because this alternative, if selected, would result in contami-
nated soils remaining on site above health-based limits,
CERCLA requires that the Site be reviewed every five years.
There are no capital or operation and maintenance costs
associated with the No Action alternative and no time would
be required for construction.
Alternative 2B Removal and Off-Site Disposal:
Capita] Cost:
0 & M Cost:
Present-Worth Cost:
Time to Implement:
$1,261,800
0
$1,261,800
<1 year
This alternative involves the excavation of approximately 750
cubic yards of TCE contaminated soils for off-site disposal at
a RCRA hazardous waste landfill or treatment at a RCRA
hazardous waste incinerator, depending on waste classifica-
tion and LDRs. Any non-hazardous waste would be disposed
at an off-site solid waste landfill. Because of the depth of
excavation (10 feet) and proximity of man-made structures,
the sidewalls would require shoring with sheet piling.
Underground utilities would be relocated or replaced prior to
driving sheet piling and construction dewatering would be
performed since the ground-water table is at a depth of 8.5
feet. Ground water recovered from dewatering operations
would be pumped to the water treatment facility to be
installed at the Facility as pan of the ground-water remedy for
OU2.
Confirmatory sampling and backfilling with clean off-site soil
will complete the remedial effort. Post remediation monitor-
ing would not be required.
Alternative 3B (Option 1) Physical Treatment by Dual-
Phase Soil Vapor Extraction:
Capital Cost:
O & M Cost:
Present-Worth Cost:
Time to Implement:
$544,700
Included with capital costs
$544,700
Installation < 1 year
Operation - minimum 1 year
This alternative involves the installation of a "dual-phase"
SVE system (DP-SVE) at the Former Runoff Basin Area
15
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because the TCE contaminated soils extend below the water
table. In a dual-phase system, ground water and soil-gas
would be withdrawn through the same extraction wells and
the water and air would then be separated for treatment. The
air stream will be sent to an off-gas treatment system using
granular activated carbon. The ground water would be sent
to the water treatment facility installed as pan of the OU2
remedy. The SVE treatment area would be approximately 55
feet by 75 feet and the extraction wells would extend to a
depth of 15 feet. The existing asphalt cover would provide a
suitable low-permeability cover to limit short circuiting of air
flow. Ground-water monitoring would be conducted until the
DP-S VE operation is complete and the cleanup goals for TCE
in soil are achieved.
Alternative 3B (Option 2) - Physical Treatment by Soil
Vapor Extraction with Air Sparging:
Capital Cost:
0 & M Cost:
Present-Worth Cost:
Time to Implement:
$565,100
Included with capital costs
$565,100
Installation < 1 year
Operation - minimum 1 year
This alternative involves the use of SVE with air sparging
(SVE-AS) to remove TCE from soils above and below the
water table to the cleanup level of 0.8 ppm. The SVE-AS
alternative is similar to Option 1, except that air sparging
would treat the saturated soils in-situ, rather than extracting
ground water for treatment at the OU2 treatment facility.
With this process, air is injected under pressure into the soils
below the water table. The air bubbles which form traverse
horizontally and vertically through the water column.
Dissolved TCE. when exposed to the air bubbles, volatilizes
into the gas phase and is carried into the vadose zone where
it is captured by the vapor extraction system. Although SVE-
AS was not pan of the pilot-scale SVE test, it is estimated
that this system would operate for a period of one year to
achieve the 0.8 ppm soil cleanup level for TCE.
Alternative 4B - Thermal Desorption Treatment:
Capital Cost:
0 & M Cost:
Present-Worth Cost:
Time to Implement:
$763,200
0
$763,200
Installation < 1 year
Treatment - several weeks
This alternative involves the excavation of TCE contaminated
soils and treatment on-site through a transportable thermal
desorption unit. Thermal desorption is a means to physically
separate VOCs and some SVOCs from soil by heating the
contaminated media between 200-10008F and driving off
water and volatile contaminants. Off-gases would be burned
in an afterburner, condensed to reduce the volume to
disposed, or captured by a carbon treatment system.
Excavation would proceed as described in Alternative 2B and
would include the provisions for utility relocation or replace-
ment, excavation sidewall shoring, and construction
dewatering.
The treated soils would be tested and, if found to meet
cleanup objectives, returned to the excavation as backfill.
Soils not meeting the cleanup objectives would be retreated.
Confirmatory sampling would be conducted to ensure that all
contaminated soils requiring treatment are excavated and
processed. Because thermal treatment involves removal of
contaminants, post remediation monitoring would not be
required.
Industrial Drainagewav
Alternative 1C - No Action:
Capital Cost:
O & M Cost:
Present-Worth Cost:
Time to Implement:
0
0
0
None
As stated above, the No Action alternative is considered as a
baseline for comparison of other alternatives. The No Action
alternative for the industrial drainageway sediments would
provide no further efforts to reduce the availability of PCBs
for direct-contact exposure by trespassers or uptake by fish
which may be consumed. It is assumed that the existing
NYSDOH fish consumption advisory for Koppers Pond and
access controls placed by the current landowner of the pond
area would remain in place.
Because this alternative, if selected, would result in the
contaminants remaining on-site above health-based levels,
CERCLA requires that the Site be reviewed every five years.
Alternative 2C Limited Action:
Capital Cost:
O & M Cost (per year):
Present-Worth Cost:
Time to Implement:
$268,200
$13,800
$480,100
<1 year
16
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The Limited Action alternative would involve supplementing
ie existing NYSDOH fish consumption advisory and access
'ontrols with a fence erected along both banks of the
drainageway and around the perimeter of the pond. This
fence would be an 8-foot high chain-link fence of approxi-
mately 7,600 feet in total length. Warning signs would be
placed along the fence to prevent inadvertent access. Princi-
pal property dwners include the Village of Horseheads and
Hardinge Brothers, Inc. Long-term physical monitoring
would be performed to ensure the integrity of the fence.
Because this alternative would result in the contaminants
remaining on-site above health-based levels, CERCLA
requires that the Site be reviewed every five years.
Alternative 3C
Lining:
Containment with Concrete Ditch
Capital Cost:
0 & M Cost (per year):
Present-Worth Cost:
Time to Implement:
$373,400
$18,700
$660,600
<1 year
Under this alternative, the 1,500 lineal feet of the industrial
inageway from the Chemung Street outfall to the culvert
neath the railroad tracks would be lined with concrete. The
method of liner placement would be determined during
design, but could include either formed and poured concrete
or a Fabriform lining system. The liner would be designed to
conform with the existing shape of the flow channel so as to
minimize the quantity of sediments requiring removal or
regrading.
In constructing such lining, diversion pumping and necessary
erosion and sedimentation controls would be emplaced to
avoid spreading contaminated sediments to downstream
locations.
Because this alternative, if selected, would result in the
contaminants remaining on-site above health-based levels,
CERCLA requires that the Site be reviewed every five years.
Alternative 4C - Removal and Off-Site Disposal:
Capital Cost:
O & M Cost:
Present-Worth Cost:
Time to Implement:
$365,600
0
$365,600
<1 year
diments containing PCB concentrations above the cleanup
objective of 1.0 ppm would be removed from the industrial
drainageway and sent off-site for disposal in a permitted
industrial waste landfill. The volume of sediment to be
removed is estimated at 1,100 cubic yards. During excava-
tion, diversion pumping and necessary erosion and sedimenta-
tion controls would be emplaced to avoid spreading contami-
nants to downstream locations. Following confirmatory
sampling and analysis, erosion control matting would be
emplaced before redirecting water flows through channel.
With removal of contaminants to cleanup goals, access
controls or post remediation monitoring would not be
required.
E VALUA TION OF ALTERNA TIVES
During the detailed evaluation of remedial alternatives, each
alternative is assessed against nine evaluative criteria,
namely, overall protection of human health and the envi-
ronment, compliance with ARARs, long-term effectiveness
and permanence, reduction of toxicity, mobility, or volume.
short-term effectiveness, implementability, cost, and state and
community acceptance.
The evaluative criteria are described below.
Overall protection of human health and foe environment ad-
dresses 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.
Compliance with applicable or relevant and appropriate
requirements (ARARs^ addresses whether or not a remedy
will meet all of the applicable or relevant and appropriate
requirements bf other federal and state environmental statutes
and requirements or provide grounds for invoking a waiver.
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.
Reduction of toxicity. mobility, or volume through treatment
is the anticipated performance of the treatment technologies
a remedy may employ.
Short-term effectiveness addresses the period of time needed
to achieve protection and any adverse impacts on human
health and the environment that may be posed during the
construction and implementation period until cleanup goals
are achieved.
17
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Implementabilitv is the technical and administrative feasibil-
ity of a remedy, including the availability of materials and
services needed to implement a particular option.
Cost includes estimated capital and operation and mainte-
nance costs, and net present-worth costs.
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.
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 for each of the
three areas to be remediated, which is based upon the evalua-
tion criteria noted above, is provided below.
Disposal Area F:
Overall Protection of Human Health and the Environment:
All of the alternatives proposed, with the exception of the No
Action alternative, would provide adequate protection of
human health by eliminating risks posed by the exposure to
surface soils. Additionally, such alternatives address soil
contamination as source control measures for complementing
the OU2 ground-water remedy selected by the EPA for the
protection of human health.
Alternatives 2A, Option 1 (Containment with Asphalt Cover)
and Option 2 (Containment with RCRA Cap) would provide
engineering controls (capping) to reduce the risk of exposure
to contaminated soils and institutional controls (fencing, deed
restrictions and/or monitoring) to ensure cap integrity.
Alternative 3A (Removal and Off-Site Disposal) would
eliminate the risk of exposure to contaminated surface soils.
It would also be an effective source control measure in
addressing TCE contamination in ground water.
Alternative 4A (Physical Treatment Using SVE) is a source
control remedy to address TCE, but includes a capping
component (soil cover) to address risks posed by exposure to
surface soils.
Compliance with ARARs: The principal action-specific
ARARs for Disposal Area F include RCRA requirements for
the identification, transportation, treatment and disposal of
hazardous waste (40 CFR Parts 261 thru 264 and Part 268)
and the corresponding NYS hazardous waste requirements.
Additionally, Federal and NYS requirements for air emissions
are action-specific ARARs (6NYCRR Parts 200, 201, 211.
219 and 257; NYS Air Guide-1) because of the potential for
gaseous and paniculate air emissions to be generated during
excavation and transportation of contaminated soils and SVE
off-gassing.
As the source control and final aquifer restoration operable
unit for the Site, the principal chemical-specific ARARs for
ground water are Federal and New York State Maximum
Contaminant Levels (MCLs) and non-zero Maximum
Contaminant Level Goals (MCLGs). The cleanup goal for
TCE-contaminated soils is established to prevent the leaching
of TCE to ground water. Such source control measures, in
combination with the OU2 ground-water remedy, would
achieve MCLs and MCLGs.
No chemical- or location-specific ARARs address the soils
contaminated with PAHs and arsenic at Disposal Area F.
Alternative 1A would not achieve the cleanup goals for
contaminated soils and therefore would not comply with the
chemical-specific ARARs for ground water. Since this
alternative involves no remedial activities, it does not trigger
any location- or action-specific ARARs.
Alternative 2A, Options 1 and 2, would not initially comply
with the chemical-specific ARARs for ground water, because
contaminants at concentrations above the cleanup levels
would remain in the soils. However, such options would
reduce infiltration of precipitation and impede the leaching of
contaminants to the underlying ground water. Therefore,
ARARs may be achieved over time through natural attenua-
tion (i.e.. processes of volatilization and biodegradation) and
by operation of the OU2 ground-water recovery wells and
treatment system. Those ground-water recovery wells will be
located directly downgradient of the contaminant plume
originating at Disposal Area F. The low-permeability RCRA
cap (Option 2) would be better than the asphalt pavement
(Option 1) at preventing infiltration from occurring. Long-
term ground-water monitoring would be implemented to
comply with RCRA requirements.
Alternative 3A effectively removes TCE contaminated soils
to cleanup levels. It would also be an effective source control
measure for complementing the OU2 ground-water remedy
and achieving ground-water ARARs more quickly. The
excavated waste materials would be classified to meet RCRA
action-specific ARARs and the corresponding NYS hazard-
ous waste regulations for the identification, transportation,
treatment and disposal of hazardous waste. Additionally, due
to the potential for gaseous and paniculate air emissions to be
generated during the excavation or transportation of contami-
18
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nated soils, provisions would be included to comply with
Jederal and state action-specific ARARs and guidance for air
^missions.
Alternative 4A would achieve TCE cleanup levels in soils
over time (at least one year) and therefore, be an effective
source control measure for complementing the OU2 ground-
water remedy, Effective source control would enable the
ground-water remedy to comply with ground-water ARARs
more quickly. Long-term ground-water monitoring would be
performed to comply with RCRA requirements. Provisions
would also be included to comply with all State and Federal
ARARs for air emissions, including the action-specific
ARARs and guidance for SVE off-gassing.
Long-Term Effectiveness and Permanence: Alternative 1A
does not provide long-term effectiveness because the contam-
ination is not removed, treated or contained. Therefore, the
current risks posed by exposure to such contamination
remains the same.
Alternative 2A provides limited long-term effectiveness
because ongoing monitoring will be required to maintain the
integrity of the asphalt cover or RCRA cap. Long-term
physical monitoring will be required to ensure cap integrity.
ig-term ground-water monitoring will be required to assess
rffectiveness of the remedy as a source control measure for
complimenting the OU2 ground-water remedy and compli-
ance with ground-water ARARs.
Alternative 3A provides long-term effectiveness because the
contaminants are permanently removed from the Site. It
eliminates the risks posed by direct-contact with soils and is
an effective and permanent source control measure for
addressing ground-water contamination at Disposal Area F.
No post-remediation monitoring is required.
Alternative 4A provides limited long-term effectiveness
because physical monitoring will be required to maintain the
integrity of the soil cover. However, the alternative would be
effective as a source control measure because TCE is re-
moved from the soil. Ground-water monitoring would be
performed during the period of SVE treatment.
Reduction of toxicity. mobility, or volume: All of the alterna-
tives other than the No Action alternative provide some
degree of reduction of the toxicity, mobility or volume (TMV)
through treatment. Alternative 2A, Options 1 and 2, rely
solely on containment to reduce chemical mobility. However,
:y do not reduce the toxicity or volume of the waste.
Itemative 4A would effectively reduce the TMV of TCE by
treatment, but it only reduces the mobility of the PAHs and
arsenic in contaminated soils by relying on containment.
Alternative 3A reduces the TMV of the TCE, PAHs and
arsenic by removal and off-site treatment and disposal.
Short-term effectiveness: The No Action and containment
alternatives (Alternatives 1A and 2A) have minimal potential
for adverse short-term impacts because workers would not
handle affected soils while performing remedial activities.
Potential short-term impacts are associated with the alterna-
tives for removal and off-site disposal and physical treatment
by SVE (Alternatives 3A and 4A), due to the direct contact of
soils by workers and the potential for vapor and/or paniculate
emissions. Such impacts would be addressed through worker
health and safety controls and air pollution controls such as
water sprays, dust suppressants, and tarps for covering truck
loads during transportation. Additionally, a community air
monitoring program would be utilized to ensure public safety.
It is estimated that all of the alternatives, except for SVE
treatment, could be easily completed in one construction
season.
Implementability: Each of the alternatives is implementable.
The SVE treatment alternative is performed in the ground and
therefore, is more difficult to control and assess. The one-
year SVE operation period estimated for removal of 95
percent of TCE mass is based on limited pilot-scale testing
and therefore, could be longer than the actual time period
9 necessary to attain the established TCE cleanup goal (0.8
ppm) in soils. SVE would also require more extensive design
than the other alternatives. RCRA permitted facilities are
available for the off-site disposal of hazardous wastes.
Cost: The capital, present-worth and operation and mainte-
nance (O&M) costs of the alternatives for Disposal Area F
are summarized in Table 1. The net present worth of the
remedial alternatives, including capital costs and, where
appropriate, 30-year O&M costs, range from $0 to
$1,114,000. The No Action alternative involves no costs.
The costs estimated for the Containment with Asphalt Cover,
Removal and Off-Site Disposal and Physical Treatment by
SVE alternatives are all comparable, ranging between
$500,000 and $620,000. The containment and SVE alterna-
tives depend to some degree on the volume of affected
materials, but their costs are much less sensitive to volume
than the Removal and Off-Site Disposal alternative. The
costs associated with such an alternative ($619,600) are
directly proportional to the quantity of affected material
requiring treatment. While efforts were made to perform a
comprehensive study at Disposal Area F, such efforts still did
not fully delineate the horizontal extent of the affected area.
Hence, there is the potential for the quantity of affected
material, and therefore the cost of this alternative, to increase
by as much as 50 percent.
19
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TABLE 1
SUMMARY OF COSTS
Kentucky Avenue Wellfield Site, Operable Unit No. 3
Remedial Alternative
DISPOSAL AREA F
1A- No Action
2A Containment with Asphalt Cover
(Option 1)
2A - Containment with RCRA Cap
(Option 2)
3A - Removal and Off-Site Disposal
4A - Physical Treatment by SVE(4)
FORMER RUNOFF BASIN AREA
1B- No Action
2B Removal and Off-Site Disposal
3B - Physical Treatment by DP-SVE'41
(Option 1)
3B - Physical Treatment by SVE-AS'4'
(Option 2)
4B - Thermal Desorption Treatment
INDUSTRIAL DRAINAGEWAY
1 C - No Action
2C - Limited Action
3C - Containment with Concrete Lining
4C Removal and Off-Site Disposal
Capital
Cost'1'
($)
0
;21 9,200
606,300
549,000
525,900
0
« 1,261,800
544,700
565,100
763,200
0
268,200
373,400
365,600
O&M
Cost01
($)
0
19,200
34,200
4,600
4,600
0
0
0
0
0
0
13,800
18,700
0
Present
Worth Cost131
($)
0
514,100
1,114,000
619,600
596.500
0
1,261,800
544,700
565,100
763.200
0
480,100
660,600
365.600
Notes:
1. Capital costs include estimates for remedial design, construction, miscellaneous costs (e.g., administrative,
permitting), and contingency.
2. O&M costs include estimates for maintenance, monitoring, five-year reviews (where applicable), and contin-
gency.
3. Present worth calculated at discount rate of five percent for term of 30 years.
4. For alternatives using SVE, costs of one-year operational period included with capital costs. Estimates do not
include costs for water treatment.
20
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The incineration costs associated with the Removal and Off-
Site Disposal alternative is $63,000 and is based on an
ti mated volume of 32 cubic yards (50 tons) or approxi-
;ly 3 percent of the total volume (1,100 cubic yards) of
waste material containing TCE at concentrations exceeding
the treatment standard of 6.0 ppm.
The costs associated with the containment alternatives are
$514,100 for the asphalt cap and $1,114,000 for the RCRA
cap. Those costs would be somewhat sensitive to a larger
surface area of affected material. However, the area
proposed to be covered by asphalt would extend well
beyond the currently defined limit of Disposal Area F and
therefore, the costs associated with an asphalt cover are not
anticipated to change significantly. The larger area of
asphalt covering is proposed as a practical matter, because
the asphalt cap would be extended to the existing asphalt
parking lot at the Facility.
State Acceptance: The State of New York concurs on the
preferred remedy.
Community Acceptance:
Community acceptance of the preferred alternative for
isposal Area F will be assessed in the ROD following
view of the public comments received on the RI/FS report
and the Proposed Plan.
Former Runoff Basin Area:
Overall Protection of Human Health and the Environment:
No exposure pathways under current or future industrial site
use were associated with direct-contact pathways for the
Former Runoff Basin Area. For the restoration of the
ground-water aquifer as a safe drinking water source, all of
the alternatives, with the exception of the No Action
alternative, would provide adequate protection of human
health as source control measures for addressing ground-
water contamination.
Alternatives 2B (Removal and Off-Site Disposal) and 4B
(Thermal Desorption Treatment) would remove the contam-
inated soils above and below the water table which are
accessible with conventional material-handling equipment.
However, any contamination in the soils in close proximity
to, or directly beneath, building foundations in the Former
Runoff Basin Area, if present, would continue to leach to
round water.
Alternative 3B (Physical Treatment by Dual-Phase SVE or
SVE with AS) would be designed to effectively remove
contaminants from all soils, including those near or beneath
building foundations, to below cleanup objectives.
Compliance with ARARs: The principal action-specific
ARARs for the Former Runoff Basin Area are RCRA
requirements regarding the identification, transportation,
treatment and disposal of hazardous waste (40 CFR Pans
261 thru 264 and Part 268) and the corresponding NYS
hazardous waste requirements. Additionally, Federal and
NYS requirements for air emissions are action-specific
ARARs or guidance (6NYCRR Parts 200, 201, 211, 219
and 257; NYS Air Guide-1) due to the potential for gaseous
and paniculate air emissions to be generated during excava-
tion, transportation and/or waste feed preparation of
contaminated soils and SVE off-gassing.
As the source control and final aquifer restoration operable
unit for the Site, the principal chemical-specific ARARs for
ground water are Federal and New York State Maximum
Contaminant Levels (MCLs) and non-zero Maximum
Contaminant Level Goals (MCLGs). The cleanup goal for
TCE-contaminated soils is established to prevent the
leaching of TCE to ground water. Such source control
measures, in combination with the OU2 ground-water
remedy, will be for achieving MCLs and MCLGs.
Alternatives 2B (Removal and Off-Site Disposal) and 4B
(Thermal Desorption Treatment) would be somewhat
effective in removing TCE-contaminated soils to cleanup
levels, including those affected soils in the saturated zone
below the water table, as source control measures for
attainment of chemical-specific ground-water ARARs.
However, these alternatives would not address soil
contamination in close proximity to, and directly under, the
building foundations at the Former Runoff Basin Area.
Such contamination, if present, would remain in place and
continue to leach to ground water.
Alternative 3B (Physical Treatment by Dual-Phase SVE or
SVE with AS) would effectively remove TCE from all
affected soils, including those soils in close proximity to, or
directly under, the building foundations at the Former
Runoff Basin Area. Extraction wells could be positioned to
remove soil vapors and ground water from those areas for
treatment, resulting in more effective source control and,
ultimately, a shorter period of time for attainment of
ground-water ARARs.
For Alternatives 2B and 4B, excavated materials would be
classified to meet RCRA action-specific ARARs and the
corresponding NYS hazardous waste regulations for the
identification, transportation, treatment and disposal of
hazardous waste.
21
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Additionally, because the potential for gaseous and/or
paniculate air emissions to be generated during the excava-
tion and waste feed preparation or transportation of contam-
inated soils or off-gassing during SVE operations,
provisions would be included for Alternatives 2B, 3B and
4B to comply with Federal and NYS action-specific ARARs
and guidance for air emissions.
Long-Term Effectiveness and Permanence: Each of the
alternatives proposed for the Former Runoff Basin Area,
except the No Action alternative, provide long-term effec-
tiveness and permanence by removing the contaminants
from the soils. The SVE treatment alternatives (Alternative
3B, Options 1 and 2) would provide permanent remedies for
the contaminated soils both above and below the water
table, including those areas near, and potentially below,
building foundations. The alternatives for removal with off-
site disposal and thermal desorption treatment (Alternatives
2B and 4B) provide permanent remedies, in that excavated
soils can be permanently removed from the site or treated on
site. However, such alternatives may not be effective at
addressing any contamination, if present, in the soils nearer
beneath building foundations.
Reduction of toxicity. mobility, or volume: With the
exception of the No Action alternative, each of the alterna-
tives reduce the TMV of TCE in the soils at the Former
Runoff Basin Area through treatment.
Short-term effectiveness: The No Action alternative would
not result in any adverse short-term impacts. Potential
short-term impacts would be associated with the other
alternatives due to the direct contact with soils by workers
and/or the generation of vapor and paniculate air emissions.
Such impacts would be addressed through worker health
and safety controls, air pollution controls such as water
spraying, dust suppressants, and tarps for covering waste
during loading, transporting and waste feed preparation.
The thermal desorption treatment alternative is anticipated
to have the potential for most significant releases of air-
borne contaminants during remediation. Site and commu-
nity air monitoring programs would be implemented when
conducting such activities to ensure protection of workers
and the nearby community. It is estimated that all of the
alternatives could be completed within one construction
season.
Implementability: All of the alternatives involve commonly
used construction practices and are implementable from an
engineering standpoint. Each alternative would utilize
commercially available products and accessible technolo-
gies.
The SVE treatment alternatives (Alternative 3B, Options 1
and 2) and thermal desorption treatment alternative (Alter-
native 4B) require more extensive engineering design.
one-year SVE operation period estimated for removal of
percent of TCE mass is based on limited pilot-scale
and therefore, could be longer than the actual time period
necessary to attain the established TCE cleanup goal (0.8
ppm) in soils, especially since dual-phase SVE and air
sparging were not part of the SVE tests. Commercial -scale
thermal desorption units exist and are in operation.
: The capital, present-worth and operation and mainte-
nance (O&M) costs of the alternatives described for the
Former Runoff Basin Area are summarized in Table 1 . The
net present worth of such alternatives, including capital
costs and, where appropriate, 30-year O&M costs, range
between $0 and $1,261,800. There are no costs associated
with the No Action alternative. The net present-worth of
the two SVE treatment alternatives are estimated at
$544,700 for Dual-Phase SVE (Option 1 ) and $565, 1 00 for
SVE with air sparging (Option 2). The thermal desorption
treatment alternative is somewhat more expensive at
$763,200. The highest costs ($1.261,800) are associated
with the removal and off-site disposal alternative, due
mostly to costs for incineration of TCE waste materials
exceeding the LDR treatment standard of 6.0 ppm for TCE.
It is estimated that approximately 33 percent of the 750
cubic yards of TCE-affected soil will be incinerated at a cost
of $470,000.
State Acceptance: The State of New York concurs on the
preferred remedy.
Community Acceptance: Community acceptance of the
preferred alternative for the Former Runoff Basin Area will
be assessed in the ROD following review of the public com-
ments received on the RI/FS report and the Proposed Plan.
Industrial Drainageway:
Overall Protection of Human Health and the Environment:
Alternative 1C (No Action) is not protective of human
health because it does not eliminate, reduce or control the
contamination at the Site.
Alternative 2C (Limited Action) provides some level of
protection at the industrial drainageway and pond by
establishing institution controls (e.g., fencing and warning
signs) to reduce risks posed by ingestion of contaminated
sediments and consumption offish. It is also assumed that
the NYSDOH fish advisory and access controls placed by
current property owner would remain in place.
22
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Alternative 3C (Containment with Concrete Lining) is
TOtective. It would reduce the availability of contaminants
lor fish uptake in the pond and, along with such institutional
controls as fencing, warning signs and the existing
NYSDOH health advisory, reduce the risk posed from fish
consumption.
Alternative 4G (Removal and Off-Site Disposal) is protec-
tive. It would eliminate the risk of direct-contact exposure
to contaminated sediments in the industrial drainageway and
minimize the availability of PCBs to aquatic life, thereby
reducing the risk posed by fish consumption.
Compliance with ARARs: The principal location-specific
ARARs for the Industrial Drainageway include 40 CFR Part
6, Appendix A - Executive Order 11990 for the protection
of wetlands, and NYS Freshwater Wetlands Act, Article 24
and Article 71, Title 23 requiring a wetlands assessment and
restoration plan for wetlands impacted by contamination or
remediation.
The EPA and U.S. Army Corps of Engineers regulations
under the Clean Water Act which, in part, regulates the
discharge of dredged or fill materials to the waters of the
United States constitute important action-specific ARARs.
dditionally, RCRA regulations regarding the identifica-
tion, transportation, treatment and disposal of hazardous
waste (40 CFR Parts 261 thru 264 and Part 268), and the
corresponding NYS hazardous waste requirements may be
action-specific ARARs for this alternative, depending on
waste classification. Due to the potential for gaseous and/or
paniculate air emissions to be generated during excavation
and transportation of contaminated sediments. Federal and
NYS requirements for air emissions are also action-specific
ARARs (t.g.. 6NYCRR Parts 200, 201, 211, 219 and 257;
NYS Air Guide-1).
Location-specific ARARs for the protection, delineation and
assessment of wetlands would be achieved, as appropriate,
under all of the alternatives proposed for the industrial
drainageway. Alternative 4C would comply with RCRA
action-specific ARARs and corresponding NYS hazardous
waste regulations for identification, transportation, treat-
ment and disposal of hazardous waste. Finally, due to the
potential for gaseous and paniculate air emissions to be
generated during the excavation and transportation of
contaminated sediments. Alternative 4C would comply with
federal and state action-specific ARARs and guidance for
air emissions.
Long-Term Effectiveness and Permanence: Alternative 1C
does not provide for long-term effectiveness and perma-
nence. Overtime, the PCB concentrations may only change
as a result of natural sediment deposition processes, assum-
ing no additional sourcing of PCB contamination to the
industrial drainageway and pond.
Alternative 2C provides marginal long-term effectiveness in
that it restricts inadvertent access, but does not eliminate the
potential for trespassers.
Alternative 3C provides long-term effectiveness in
minimizing the availability of PCB-containing sediments for
direct-contact exposure and for availability to aquatic life.
The lining would be designed for resistance to erosion and
long-term stability. Long-term physical monitoring will be
required to ensure the integrity of the liner.
Alternative 4C would permanently eliminate the PCB
contaminated sediments in the industrial drainageway for
direct-contact exposure or availability to aquatic life.
Reduction of toxicity. mobility, or volume: With the
exception of the No Action and Limited Action alternatives.
each alternative reduces the TMV of contaminants in the
sediments through treatment or containment.
Short-term effectiveness: No Action and Limited Action do
not require workers to handle contaminated sediment and do
not involve construction work in a waterway. Potential
short-term impacts are associated with the alternatives for
containment with concrete lining and removal and off-site
disposal. The containment option would involve more
limited excavation and handling, but does include construc-
tion work in the drainageway. The removal alternative
represents the most significant potential short-term impact
because it involves sediment excavation from within a
waterway. Such impacts to workers would be addressed by
compliance with a health and safety plan, including an air
monitoring plan. Additionally, a community air monitoring
program would be implemented to monitor and control
airborne particulates and vapors for ensuring public safety.
Bypass pumping and erosion and sedimentation controls
would also be necessary. These alternatives could be
completed in one construction season.
Implementabilitv: All of the alternatives involve commonly
used construction practices and are implementable from an
engineering standpoint. With the exception of No Action,
all of the alternatives would require several construction
easements. Additionally, the containment and removal
alternatives would require permits by the U.S. Army Corps
of Engineers. These access and permitting issues could
delay implementation.
23
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Cost: The capital, present-worth and operation and mainte-
nance (O&M) costs of the alternatives described for the
industrial drainageway are summarized in Table 1. The net
present-worth of such alternatives, including capital and 30-
year O&M costs, where appropriate, range from $0 to
$660,000. There are no costs associated with the No Action
alternative. The net present-worth cost for the Limited
Action alternative is $480,100, with an estimated capital
cost of $152,000 for the 7,600 feet of fencing. The Re-
moval and Off-Site Disposal alternative has a net present-
worth of $365,600. The most costly alternative proposed is
the Containment with Concrete Lining alternative, with a
net present-worth of $660,000.
Stale Acceptance: The State of New York concurs on the
preferred remedy.
Community Acceptance: Community acceptance of the
preferred alternative will be assessed in the ROD following
review of the public comments received on the RI/FS report
and the Proposed Plan.
PREFERRED ALTERNATIVES
Based upon the results of the RI and FS Reports and after
careful consideration of all reasonable alternatives, the EPA
and the NYSDEC recommend Alternative 3A (Removal and
Off-Site Disposal) for the contaminated soil at Disposal
Area F; Alternative 3B (Physical Treatment by SVE) for the
contaminated soil at the Former Runoff Basin Area; and
Alternative 4C (Removal and Off-Site Disposal) for the
contaminated sediments at the industrial drainageway as the
preferred alternatives for the OU3 remedies.
The Removal and Off-Site Disposal alternative would be the
most effective and permanent source control measure for
TCE contamination. As an effective source control, such a
remedy would complement the ground-water remedy
selected for OU2 and allow the attainment of ground-water
ARARs more quickly than the other remedial alternatives
evaluated. Additionally, no long-term physical monitoring
or ground-water monitoring would be necessary. The
other alternatives would require such monitoring to ensure
the integrity of the asphalt, RCRA or soil covers and
institutional controls.
The Physical Treatment by SVE alternative would be the
most cost-effective and protective remedy for the Former
Runoff Basin Area and will address the contaminated soils
near building foundations and underground utilities.
The Removal and Off-Site Disposal alternative would be the
most cost-effective and permanent remedy for addressing
the PCB contamination in the industrial drainageway
sediments and limiting the availability of PCBs for uptake
by fish in Koppers Pond. However, for any cleanup at the
industrial drainageway to be effective and permanent, the
unauthorized releases to the industrial drainageway must be
eliminated. Those releases are suspected to be contributing
to the sediment contamination in the industrial drainageway
and Koppers Pond. Without the elimination of such
releases, it is anticipated that the sediments in the industrial
drainageway would be recontaminated with metals to levels
which may, ultimately, result in a threat to human health.
Such an assessment assumes that all future permitted
discharges from the Facility would meet the discharge limits
established by the NYS permitting authorities under the
State Pollutant Discharge Elimination System program.
In light of the above, and as a practical matter, the preferred
alternative for removal and off-Site disposal, if ultimately
selected, would be implemented after the NYSDEC com-
pletes its investigation as to the source(s) of the unautho-
rized releases to the industrial drainageway and those
releases are eliminated. The EPA and the NYSDEC would
ensure that those sources, when identified, are addressed.
In addition, once the remediation is conducted, the EPA and
the NYSDEC would ensure that the effectiveness of that
cleanup effort is not influenced by future unauthorized
discharges to the industrial drainageway.
Specifically, the preferred alternatives will involve the
following:
Disposal Area F
Performance of soil sampling and analysis to
further characterize and classify the materials for
off-site disposal.
Excavation of soils containing TCE, PAHs and
arsenic at concentrations above the cleanup objec-
tives established for such chemicals.
Transportation of affected soils to permitted waste
management facilities (e.g., RCRA hazardous
waste incinerator. RCRA hazardous waste landfill
or industrial landfill).
Performance of confirmatory sampling and back-
filling of excavation with clean soil taken from an
off-site borrow pit.
24
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Former Runoff Basin Area
Design and test an SVE system using either dual-
phase or air sparging, depending on site-specific
characteristics, to address VOC contamination
above and below the water table.
Installation of SVE wells.
Construction and operation of SVE treatment
system, including off-gas carbon adsorption treat-
ment system.
If a dual-phase SVE system is implemented, recov-
ered ground water would be piped to the water
treatment facility installed as part of the ground-
water remedy for OU2.
A monitoring program to assess the effectiveness of
SVE treatment on achieving TCE cleanup objec-
tives in soil and Federal and State drinking water
standards (MCLs) in ground water.
Industrial Drainageway
Excavation of sediments containing PCB concen-
trations above the cleanup objective at the indus-
trial drainageway.
Placement and operation of diversion pumping and
necessary erosion and sedimentation controls.
Performance of confirmatory sampling.
Reshaping the flow channel using clean off-site
soils, as needed.
Transportation of contaminated sediments to
permitted waste management facilities.
Additionally, the EPA proposes that the interim ground-
water remedy selected for OU2 become the final remedy for
restoration of the Newtown Creek Aquifer at the Site.
Specifically, this final ground-water remedy will involve the
following:
Final Remedy for Ground-Water Aquifer
Construction of a water treatment facility with a 44-
foot high air stripper tower near the KAW having
a 700 gallon per minute (gpm) treatment capacity
for removing TCE and other contaminants to below
Federal and NYS drinking water standards;
Refurbishing the existing well pump, pump station
building and treatment equipment at the KAW in
order that the KAW can supply 700 gpm potable
(drinkable) water;
Installation of two ground-water recovery wells
(i.e., Barrier Wells) at the southeast comer of the
Westinghouse Facility for continuous pumping at
500 gpm and 900 gpm to provide hydrodynamic
control of the contaminant plume(s) beneath the
Westinghouse Facility and extraction of contami-
nated ground water for treatment;
Construction of a water treatment plant at the
Westinghouse Facility with 1,400 gpm treatment
capacity for processing ground water recovered
from the Barrier Wells and use of granular acti-
vated carbon for removing TCE and other contami-
nants to below Federal and NYS drinking water
standards;
Use of treated ground water primarily as non-
potable production water for the Westinghouse
Facility manufacturing operations or for discharge
to the industrial drainageway via the permitted
outfalls; and,
Implementation of a Long-Term Ground-Water
Monitoring Program to monitor contaminant
migration and evaluate effectiveness of the final
remedy for restoring the Newtown Creek Aquifer to
its beneficial use as a drinking water aquifer.
The preferred alternatives for Disposal Area F, the Former
Runoff Basin and the industrial drainageway would provide
the best balance of trade-offs among alternatives with
respect to the evaluating criteria. The EPA and the
NYSDEC believe that the preferred alternatives would be
protective of human health, would comply with ARARs,
would be cost effective, and would utilize permanent
solutions to the maximum extent practicable. The remedy
also would meet the statutory preference for the use of
treatment as a principal element.
Note: At the time the 1990 ROD was issued for the second
operable unit at this Site, the EPA and NYSDEC envisioned
that both water treatment facilities would use air-stripping
technology to remove TCE and other VOCs from recovered
ground water. Additionally, based on the Site-related
ground-water data showing elevated levels of metals in
unfiltered samples, filtration was believed to be a necessary
treatment component to remove suspended solids having
adsorbed inorganic contamination from recovered ground
25
-------
water. Furthermore, vapor-phase carbon adsorption treat-
ment to address off-gassing at the air strippers was envi-
sioned to meet NYS air guideline regulations. However,
information obtained from a pilot study performed by
Westinghouse as part of the remedial design for OLJ2
indicted that filtration and vapor-phase carbon adsorption
were not necessary components of the remedy.
Based on the analysis of raw water quality at the KAW, a
pumping well halfway between the KAW and the Westing-
house Facility and a production well at the Facility, concen-
trations of metals and total suspended solids are below
levels that would require removal for compliance with
drinking water standards. Additionally, based on the
findings of an in-field pilot-scale test using an air stripper
tower at the KAW, it was determined that off-gas treatment
at the air stripper would not be necessary to meet NYS air
quality regulations and guidelines.
Following completion of the remedial design pilot study,
Westinghouse proposed that GAC treatment be used at the
Barrier Well water treatment facility, rather than air strip-
ping. GAC was believed to be more feasible due to the
need for continuous pumping to control contaminant plume
migration. Additionally, there was no significant cost
advantage to air stripping over GAC treatment. Since GAC
was a proven treatment technology for removing
from ground water, the preference for this technology
acceptable.
The EPA and the NYSDEC are taking the opportunity in
accordance with CERCLA Section 117(c), to inform the
public of the agencies' decision to select GAC treatment for
the Barrier Well water treatment facility, rather than air
stripping, and to eliminate filtration and vapor-phase carbon
adsorption treatment from the remedy. In considering this
new information, the EPA believes that the remedy selected
in the 1990 ROD remains protective of human health and
the environment, complies with Federal and NYS require-
ments that are legally applicable, or relevant and appropriate
to the final ground-water remedy, and is cost effective.
The EPA approved the remedial design for this remedy on
July 15, 1996 and construction activities are scheduled to
begin in late August/early September of this year.
26
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APPENDIX B
-------
United States
Environmental Protection Agency
's Region 2: NJ, NY, PR, VI
\£ 290 Broadway
New York, New York 10007-1866
96 (061) Ann Rychlenski 212/637-3672
For Release: Tuesday , August 27, 1996
THIRD PHASE OF CLEANUP AT KENTUCKY AVENUE WELLFIELD SUPERFUND
SITE TO BE PRESENTED AT PUBLIC MEETING LN HORSEHEADS, NEW YORK
NEW YORK -- The U.S. Environmental Protection Agency (EPA) has announced its proposed
plan for the third phase a of cleanup at the Kentucky Avenue Wellfield, located in Horseheads
and Elmira, New York. This third phase of cleanup action will address the Westinghouse Electric
Corporation's manufacturing facility and a related industrial drainageway. The plan calls for the
removal of contaminated soils at one area of the Westinghouse facility and disposal off-site,
'\
treatment of contaminated soils at another area of the facility with soil vapor extraction, and
removal of contaminated sediments in the industrial drainageway for off-site disposal.
EPA will present this plan and take public comment at a public meeting to be held on Wednesday,
September 11, 1996, at 7:30 p.m., at the Village of Horseheads Hall located at 202 South Main
Street in Horseheads, New York. The public comment period runs through September 26 , 1996.
You may submit written comments, postmarked by close of business that date to Mark Purcell,
Remedial Project Manager, U.S. EPA, 290 Broadway, 20th floor, New York, New York
10007. In addition, site-related documents are available for public review at the information
repositories established for the site at the following locations:
NY State Dept. Of Environmental Conservation Town of Horseheads Town Hall
6274 East Avon-Lima Road 150 Wygant Road
Avon, NY Horseheads, NY
-------
APPENDIX C
-------
FOR THE RECORD
Births
ARNOT OGDEN MEDICAL
CENTER, ELMIRA
HOWE - A daughter. Wednesday.
Aug. 28, 1996. to John and Sonia Allen
Howe of Elmira.
FISCUS - A daughter. Wednesday,
Aug. 28, 1996. to Charles and Nancy
Kreidler Fiscus of Elmira.
PRICE - A daughter. Wednesday.
Aug. 28. 1996. to David and llerte Crow-
ley Price of Lowman.
BENSON - A daughter, Wednesday.
Aug. 28.1996. to Mark and Lisa Maust
Benson of Chemung.
CORNING HOSPITAL
QIGUELLO - A daughter, Monday.
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
^.«.,,, INVITES PUBLIC COMMENT
* ** ' on the
i r!?7 | Proposed Cleanup
Operable Unit 3, Kentucky Avenue Wellfield Superfund Site
Town of Horseheads, Chemung, County, New York
The United Slates Environmental Protection Agency (EPA) announces the opening of a 30-day public comment period on the
Proposed Plan for ihe cleanup of Operable Unit 3 (OL'3) at the Kentucky Avenue Wellfield. located in Horseheads and Elmira
Heights. Chemung County! New York. OU3 consists of the Westinghouse Electric Corporation's manufacturing facility and a
related industrial drainn^eway and pond i known locally as Koppers Pond). As pan of this comment period. EPA will hold a public
meeting on Wednesday. September II. 1996 at 7:30 p.m. at the Village of Horseheads Hall located at 202 South Main Street,
Horseheads. New York. Members of the community are invited to attend and to express their concerns.
The EPA and the New York State Department of Environmental Conservation (NYSOEC) evaluated the following alternatives to
clean up contaminated soils at two -eparate areas at the Westinghouse facility (Disposal Area F and Former Runoff Basin Area)
and sediments at the Industrial Dramageway:
t
Industrial Dralnagcway
1C No Action
2C: Limited Action
3C: Containment with Concrete Ditch Lining
4C: Removal and Off-site Disposal
Disposal Area F
1A: No Action
2A: Containment with Asphalt Cover/Cap
3A: Removal and Off-site Disposal
4A: Physical Treatment by Soil Vapor Extraction
Former Runnoff Basin Area
IB: No Action
2B: Removal and Off-site Disposal
3B: Physical Treatment by Soil Vapor Extraction
4B: Thermal Desorption Treatment
Based on the available information the EPA and NYSDEC prefer Alternative 3A to remediate the soils at Disposal Area F.
Alternative .'8 to remediate the soils ai (he Former Runoff Basin Area, and Alternative 4C to remediate (he sediments at the
Industrial Drainaeeway. Such alternatives would provide (he best balance of overall protection of human health; compliance with
applicable or relevant and appropriate requirements: short and long-term effectiveness and permanence: reduction of toxicity.
mobility, or \olume of contaminants through treatment: implementability: and cost effectiveness. Although these are the preferred
alternatives, the EPA and NYSDEC may select any of the alternatives after considering community concerns.
The Proposed Pljn and -ill documents, including the Remedial Investigation and Feasibility Study Report related to (he cleanup of
the Site are available fur review in the information repositories al the NYSDEC Office. JO Wolf Road. Albany. New York 12333.
and jl Ihe Tn\*n nf Htirseheads Town Hall.
The public may comment in person at the meeting and may submit written comments through September 26. 1996 to:
Marie PurceU
Remedial Project Manager
U.S. Environmental Protection Agency
290 Broadway, 20th Floor
New York. New York 10007-1866
(212)637-1282
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-------
..'*"*'</
UNITKD .STATES ENVIRONMENTAL PROTECTION AGHNCY
INVITES PUBLIC COMMENT
on the
Proposed Cleanup
Operable Unit 3, Kentucky Avenue Wellficld Superftind Site
Town of Horscheads. Chcmung. County. New York
Tlic United States Environmental Protection Agency (EPA) announces the opening of a 30-day public comment
period on the Proposed Plan for the cleanup of Operable Unit 3 (OU3) at the Kentucky Avenue Wellficld. located in
Horscheads and Elmira Heights, Chemung County, New York. OU3 consists of the Westinghouse Electric
Corporation's manufacturing facility and a related industrial drainageway and pond (known locally as Koppers Pond).
As pan of this comment period, EPA will hold a public meeting on Wednesday September 11. 1996 at 7:30 p.m. at
the Village of Horseheads Hall located at 202 South Main Street, Horscheads. New York. Members of the community
arc invited to attend and to express their concerns.
The liPA and the New York State Department of Environmental Conservation (NYSDEC) evaluated the following
alternatives to clean up contaminated soils at two separate areas at the Westinghouse facility (Disposal Area F and
Former Runoff Basin Area) and sediments at the Industrial Drainageway:
Industrial Drainageway
1C: No Action
2C: Limited Action
?C: Containment with Concrete Ditch Lining
4C: Removal and Off-site Disposal
Disposal Area F
tA: No Action
2A: Containment with Asphalt Cover/Cap
3A: Removal a:id Off-site Disposal
4A: Physical Treatment by Soil Vapor Extraction
Former Runnoff Basin Area
ID: No Action
2B: Removal and Off-siie Disposal
3B: Physical Treatment by Soil Vapor Extrac:ton
4B: Thermal Dcsoiplion Treatment
Based on the available information the EPA and NYSDEC prefer Alternative 3A to remediate the ioils at Disposal
Area F. Alternative 3B to remediate the soils at the Former Runoff Basin Area, and Alternative 4C to remediate the
sediments at the Industrial Drainaueway. Such alternatives would provide the best balance of overall protection of
human health; compliance with applicable or relevant and appropriate requirements; slioiv ami long-term
effectiveness and permanence; reduction of to.xtcity, mobility, or volume of contaminant through treatment;
impleniemabilily; and COM effectiveness. Although these arc the preferred alternatives, ihc F.PA and NYSDF.C may
select any of the alternatives after consider.ne community concenis.
Tlic 1'ruposed Plan and all document*, including the Remedial Investigation and F-'easihiliiy Study Report related to
the cleanup of the Site are available for review in the information repositories at the NYSDP.C Office, 50 Wolf Road.
Albany. New York 12233, and at the Town of Horscheads Town Hall.
The public may comment in person at the meeting and may submit written comments through September 26, 1996 to.
Mark Purcell
Remedial Project Manager '
U.S. F.nvironmcntal Protection Agency
290 Broadway, 20th Floor
Now York. New York 10007-1866
(212)637-4282
-------
APPENDIX D
-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
R£OION 2
290 BROADWAY
NEW YORK. NEW YORK 10007
KENTUCKY AVENUE WELLFIELD SUPERFUND SITE
PROPOSED PLAN OPERABLE UNIT 3
Sign-In Sheet
September 11,1996
Town of Horseheads, New York
Please be sure to print your name and address clearly so that we can add your name to our
mailing list.
Address
K. 6- <
0*.
/Dp
*x *
<^c
TT7
-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION :
290 BROADWAY
NEW YORK. NEW YORK 10007
KENTUCKY AVENUE WELLFIELD SUPERFINE SITE
PROPOSED PLAN OPERABLE UNIT 3
Sign-In Sheet
September 11,1996
Town of Horscheads. New York
Please be sure to print your name and address clearly so that we can add your name to our
mailing list.
Name Address
1 jo
lAiuiA.e.totAi&eSw* *rtfra.
*n& J* ii nu/I nu " ^
* y/ Ni^fr^ / UJ* op fJuui M £ f- /.v
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-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 2
290 BROADWAY
NEW YORK, NEW YORK 10007
KENTUCKY AVENUE WELLFIELD SUPERFUND SITE
PROPOSED PLAN OPERABLE UNIT 3
Sign-In Sheet
September 11,1996
Town of Horseheads, New York
Please be sure TO print your name and address clearly so that we can add your name to our
mailing list.
Address
S
-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 2
290 BROADWAY
NEW YORK. NEW YORK 10007
KENTUCKY AVENUE WELLFIELD SUPERFUND SITE
PROPOSED PLAN OPERABLE UNIT 3
Sign-In Sheet
September 11,1996
Town of Horsebeads, New York
Please be sure to print your name and address clearly so that we can add your name to our
mailing list.
Address ...
ll /H .-P^rrfir So /tJjjf (ffcf. ft l^A /|/frfljc r
-------
APPENDIX E
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1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
PUBLIC MEETING
KENTUCKY AVENUE WELLFIELD SUPERFUND SITE
Horseheads Village Hall, Horseheads, NY
Wednesday, September 11, 1996
402 West Church Street
Elmira, New York 14901
VERBATIM
COURT REPORTING SERVICE. INC
(607)733-1262
1 -800-368-3302
FAX (607) 733-3966
-------
1 ANN RYCHLENSKI: We are going to
2 call the meeting to order. Hi. Good evening.
3 Thanks for coming out here tonight. This meeting
4 is being held by the U.S. Environmental Protection
5 Agency. We are here to discuss our proposed plan
6 for the third phase of the cleanup over at the
7 Kentucky Avenue Wellfield Superfund Site.
8 Before I turn the program over to my
9 colleagues here who are going to be doing the
10 presentations, I just want to tell you a few
11 things. First of all, my name is Ann Rychlenski.
12 And I am the community relations coordinator for
13 the site. I will introduce the rest of the folks
14 that are here from EPA. To my immediate right,
15 Jim Doyle, and he is our legal counsel. We go
16 over to Kevin Lynch, he is a section chief in the
17 New York Superfund section. And then there is
18 Mark Purcell and he is the remedial project
19 manager for the Kentucky Avenue Wellfield Site.
20 Then all the way down there is Gina Ferreira. And
21 Gina is an environmental scientist.
22 I want to remind you of a couple of
23 things before we go into the program. First'of
24 all, as you can see, we have a stenographer
-------
1 present here tonight. That's so that a clear
2 legal record can be made of this meeting. So what
3 I am going to ask you to do is to please hold all
4 your questions until the very end, until all the
5 presentations are over. Then when you do have
6 your question, please stand and speak clearly and
7 identify yourselves so that the stenographer can
8 take that all down.
9 As I said, tonight we are going to
10 be talking about the third phase of the cleanup
11 over at the Kentucky Avenue Wellfield Site. I
12 hope you all have meeting agendas. You can follow
13 along where we are headed. Kevin Lynch is going
14 to give an overview of how Superfund works, the
15 law that governs this whole process so you know
16 where we are coming from. And Mark will take over
17 the rest of the presentation. He will talk a
18 little bit about the background of the site, what
19 it is we found in our investigations at the site,
20 and what it is that we propose to do for the
21 cleanup.
22 Now, one of the things that EPA does
23 all the time when we get to this stage of the'
24 proposed plan is we take public comment. That's
-------
1 one of the reasons that we are here this evening.
2 Formal public comment is given through the
3 stenographer and also you can send written
4 comments. You may not think of everything here
5 tonight after hearing this information. You may
6 say you didn't get to talk to EPA about this or
7 that; you may still have a question. If that is
8 indeed so, you can send your questions or your
9 comments on to us. You can send them to Mark
10 Purcell. Our public comment'period ends on the
11 26th of this month, so please make certain that
12 whatever you send will be post marked by midnight
13 on September 26th. Please make certain that you
14 take the information that's here. We have copies
15 of the proposed plan and meeting agendas. Also
16 please sign in. There are sign in sheets here.
17 If you have not already done so, please be certain
18 that you do before you leave. This way we can
19 keep your name on our mailing list. Please put
20 your address down in full so that we have your zip
21 code as well, so we can keep you abreast of
22 whatever it is that goes on, more meetings or
23 whatever. * '
24 Is there anything else I need to
-------
1 talk to you about? I guess that's about it. So,
2 again, please keep your questions until the end
3 and sign in if you haven't. I am going to turn it
4 over to Kevin.
5 KEVIN LYNCH: Back in 1979, a couple
6 of environmental disasters occurred, probably the
7 worst one of which was the Love Canal, where
8 people found that they were living on an abandoned
9 hazardous waste site. The federal government
10 didn't have a real good way to respond to any
11 problems like this. So, in 1980, Congress passed
12 the Comprehensive Environmental Response,
13 Compensation and Liability Act, CERCLA, which gave
14 us authority to take action. One thing it did,
15 was to create a fund, at that time a 1.6 billion
16 dollar fund, to address these sites. That's where
17 the name Superfund came from. And we can use that
18 money to go and address the cleanup sites.
19 There are a number of ways we can
20 approach these sites. One, we can take a quick
21 action which we call a removal action. In
22 emergencies or if we find a serious problem out
23 there, such as if we find an area, where people
24 are drinking contaminated water, we can go out and
-------
1 immediately give them an alternate water supply.
2 If we find an area that has a lot of drums in it,
3 that is dangerous, for instance, they can blow up,
4 we go out there and take an action just to clean
5 up those drums. These removals are supposed to be
6 short-term actions, so we can get a quick fix on
7 things.
8 The other way we approach a site is
9 through the remedial process. And this is
10 intended to have a more long-term, more permanent
11 fix on the site. CERCLA also gave us the
12 authority to require other people to go out and
13 take these remedial actions at sites. And the
14 people who can do that are what we call
15 potentially responsible parties. They can be
16 either owners or former owners or operators of the
17 site when the problems started. They can be
18 generators, they can be anyone who created
19 something that is at the site now that is causing
20 part of the problem or they can be someone who
21 transported things to that site.
22 Now, it's a strict liability law.
23 As such, you didn't have to do anything wrong?
24 You could have been doing everything just the way
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1 everyone did at that time. But if these
2 substances are causing a problem now, it's a.
3 recognition that it's causing a problem, the stuff
4 that you had, and you have to be part of the
5 solution.
6 A typical way a site goes through
7 this process is the discovery. Usually, the site
8 is referred to EPA by the state. Once it's
9 referred, we will go out and gather information
10 about the site. They usually have a lot of
11 information on it already. It's why they
12 suspected there is a problem out there. They will
13 know some things that are out there, what kind of
14 waste is there, what kind of substances. We will
15 look for things like what's the population around
16 . the site, where is the closest source of drinking
17 water. We will take a look at that information
18 and do a quick study on the site. We physically
19 go there and take some samples to give us a better
20 idea of what's out there. Then we put.this
21 information into a mathematical model and it comes
22 up with a rating. If the site gets above a
23 certain number, it goes onto the national ' '
24 priorities list and it's a site that we address
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1 using the Superfund or using the Superfund
2 authorities. If the site doesn't make it above
3 that number, it goes back to the state and they
4 usually address it using the state Superfund.
5 This is an attempt to handle the worst sites
6 , first. If it sounds like 1.5 billion dollars is a
7 lot of money, we found out there are a lot more
8 hazardous waste sites than anyone suspected. And
9 there are a lot more expensives involved to clean
10 up these sites than we thought.
11 Once the site gets on the list, we
12 will go out and do what we call a remedial
13 investigation and feasibility study. The remedial
14 investigation is designed to determine the nature
15 and the extent of the problem. We want to find
16 out what's out there, where it is going and what
17 problems it is creating. We will do that by
18 physically going to the site, and taking samples.
19 We will take samples of the soil if there is waste
20 there, we will put monitoring wells in the area,
21 and we will take samples of the water so we can
22 determine where the ground water is going and
23 what's in it. And what problems it may cause/
24 Then we will do a risk assessment,
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1 which is an attempt to find out what threats these
2 things cause, the stuff we found out there. Then
3 we will do a feasibility study, which is simply a
4 study where we look at different alternative
5 solutions to the problem. We compare them to one
6 another using criteria that are given to us in our
7 regulations, and we come up with what we think is
8 the best solution to the problem. We put that
9 into a proposed plan, publish the plan, get public
10 input, then we go back and make a decision on what
11 we will do at the site.
12 Next we prepare a document called a
13 record of decision or ROD. After we sign the ROD,
14 we then.design the remedy, or cleanup and
15 implement the remedy. When I say we, I remind you
16 that in addition to EPA, the state can do some of
17 this work, and responsible parties in general have
18 been doing work all around the country and through
19 the state to accomplish this. In fact, at this
20 site, this is the third time we have done this
21 remedial investigation/feasibility study. We have
22 taken other studies. One was done by the state
23 DEC. One was done by EPA. And another study
24 done by one of the responsible parties.
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1 Mark Purcell now will present a
2 summary of what has happened at the site, results
3 of the latest study, and present the proposed
4 plan.
5 MARK PURCELL: Hopefully all my
6 overheads will fit onto this screen. The first
7 figure I am going to show here is a figure of the
8 site and it includes the contaminated Kentucky
9 Avenue Well, which is located in this red circle.
10 The well is located about a mile south of Route
11 17, and just east of Route 328. The site had its
12 beginnings in 1980 when trichloroethylene, a
13 compound, was 'detected at the Kentucky Avenue
14 Well. The well was closed in that same year. In
15 1983, the site was added to the national
16 priorities list for the cleanup of the site.
17 The first stage of remediation that
18 EPA and the New York State DEC conducted was to
19 identify all the residencies and businesses which
20 had private drinking water wells in the area of
21 contamination. Since 1985, EPA has connected over
22 90 properties to public water supply.
23 During the second phase of the. .»
24 investigation, EPA conducted some remedial
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1 investigations in the mid to late 1980s to
2 determine the sources of contamination 'for the
3 site and also to select a groundwater remedy.
4 Those investigations showed three areas, three
5 locations or facilities, which were contributing
6 to the aquifer contamination. They are shown in
7 yellow. The first facility, LRC Electronics, is
8 located in the northeast corner of the site. The
9 Facet Enterprises facility is located in the
10 southwest corner of the site-. And the
11 Westinghouse facility is located in the northwest
12 corner of the site. Based on these studies, EPA
13 determined that of the' three, the Westinghouse
14 facility was contributing contamination to the
15 Kentucky Avenue Well.
16 In 1990, the EPA selected a
17 groundwater remedy that included restoring the
18 well as a public drinking well and also installing
19 a groundwater recovery and treatment system
20 between the well and the Westinghouse facility.
21 In 1991, EPA issued an administrative order to
22 Westinghouse to implement that remedy. The
23 designs of that remedy were completed in June^of
24 this year. And construction of those activities
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1 are starting this month.
2 The last phase or the third phase of
3 the remedial efforts here is to control the source
4 of contamination at the Westinghouse facility. We
5 conducted a remedial investigation there in 1994
6 and 1995. We also investigated the industrial
7 drainageway and pond, known locally as Koppers
8 Pond. Some of the investigations in the mid to
9 late 1980s identified contamination there. So we
10 investigated the surface water and sediments.
11 This is a figure of the Westinghouse
12 facility. It's a 59-acre site which was used to
13 manufacture television picture tubes and other
14 electronics television components since 1952.
15 There were several areas that received plant waste
16 and other potential areas of concern which we
17 investigated during the remedial investigation.
18 Those areas are covered in yellow.
19 The first of those areas is located
20 to the north of the facility and it's known by the
21 name of the magnesium chip burial area. Their
22 plant records indicated that Westinghouse had
23 disposed of approximately 200 drums of plant' waste
24 encased in concrete. To the east of that area is
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1 a former coal pile area which was also
2 investigated. Just north of the building proper
3 is a circular area, that is known as the former
4 runoff basin area. It is an oval depression which
5 received storm water runoff. Westinghouse also
6 located there a 7,500-gallon tank for storing
7 solvents.
8 In the parking lot area, there were
9 two locations where calcium fluoride sludge.and
10 other plant waste were disposed of, you can see by
11 those boxes. South of that area along the
12 property boundary to the south is a disposal area
13 by the name of disposal area F.
14 Other areas of concern were in the
15 vicinity of one of the monitoring wells which
16 traditionally had TCE in the ground water,
17 monitoring well MW-10. To the southwest of the
18 west parking lot, a plant memorandum indicated
19 that waste might have been disposed there at some
20 time. So we investigated that area.
21 The small orange area sitting back
22 here along the parking lot is a soil pile. That
23 pile was generated during construction activities
24 at the facility probably due to plant expansion,
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1 sometime in the 1980s. The large yellow area
2 along Route 17 also was investigated. An
3 anonymous source reported allegedly witnessing the
4 disposal of 300 to 500 drums of waste while they
5 were constructing that highway.
6 The green dots located around the
7 facility are surface water runoff drains. They
8 are 4 to 6-foot deep drains covered by manholes.
9 They were investigated to determine if they acted
10 as conduits for liquid wastes which could possibly
11 leach into the underlying soils and ground water.
12 And the last area we looked at here
13 was the ground water at the site. There are a
14 number of monitoring wells; they are all circled
15 in red. We collected groundwater samples and had
16 those analyzed as part of the investigation.
17 This is a figure of the magnesium
18 chip burial area. The yellow colored trench shows
19 where we believe the drums were buried. Dark
20 black lines and the red bars show where the ground
21 penetrating radar surveys were conducted and
22 trenching operations were performed to confirm the
23 presence of buried drums. Based on those results,
24 buried drums were confirmed at a depth of 2 to 3
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1 feet.
2 In late 1995, Westinghouse conducted
3 a removal action to send the drums off-site for
4 disposal. They recovered 179 drums. They were
5 all opened to confirm that they were filled with
6 concrete.
7 This is a figure of the two calcium
8 fluoride sludge disposal areas shown in yellow.
9 Black dots show the location of where soil borings
10 were drilled to collect soil'samples. Two or
11 three of the soil boring locations colored in
12 green show where a white powdery material was
13 encountered. Further analysis showed that that
14 material exhibited the characteristics of a
15 hazardous waste due to a leachable cadmium. As
16 part of the 1995 removal action, Westinghouse
17 excavated those materials. A total of 1,200 tons
18 were removed. The excavation areas are shown in
19 orange.
20 This is a figure of the soil pile
21 located at the southwest corner of the parking
22 lot; it's colored in yellow and orange. The
23 little black boxes are where soil samples weird
24 collected and.analyzed. A number of samples
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showed elevated concentrations of polychlorinated
biphenyls or PCBs and polycyclic aromatic
hydrocarbons or PAHs. Those soils were also
included as part of the removal action of late
1995. The remaining soils colored in yellow were
used as backfill materials as part of that removal
operation.
This is a figure of the former
runoff basin area, that circular area was a low
and which received storm water runoff. The figure
shows the corner of the facility down here on the
lower right-hand corner. The red box shows the
former location of the 7,500-gallon solvent tank.
The green shaded area is where we found TCE
contamination in the soils. Maximum
concentrations ranged up to 20 parts per million
or ppm. And, at the depth -- I am sorry, maximum
concentrations ranged up to 80 ppm and at a depth
of 10 to 11 feet. From the distribution of TCE in
the soils, we can determine that the source of
those TCE concentrations is the former location of
where the tank was stored.
This is a figure of the former'
disposal area, disposal area F. The yellow box
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here is where we first estimated that the area of
waste disposal was located. The dark bars show
where trenching operations were performed during
the remedial investigation. Trenches went down to
the groundwater table. The orange area is
actually where we found waste materials placed
here. You can clearly see that the area of waste
was somewhat larger than what was originally
anticipated. The green area is where those waste
materials were found to contain TCE. The TCE
concentrations here were up to a range of about 20
ppm found at the depth of 2 to 3 feet. Other
chemicals we found here were PAHs and arsenic.
This is a figure of the monitoring
well 10 area. Again, it's located in the
southwest corner of the Westinghouse facility,
shown here in the upper right. Disposal area F,
which is located off to the west, is shown in
yellow. The green area where we found TCE
contamination. To determine where the source of
TCE contamination located at the well was
originating from, we collected soil vapors and
analyzed them for TCE. The location of the s6il
vapor survey is shown by black dots. The green
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1 area shows where we found TCE vapors in the
2 unsaturated soils. You can see a very pronounced,
3 elongated east/west trending distribution of TCE
4 vapors. This is in part a reflection of the TCE
5 contamination of the ground water underlying the
6 unsaturated soils. The TCE contamination in
7 ground water is flowing to the east with the
8 direction of groundwater flow as shown by this
9 arrow. This distribution is indicative of where
10 the TCE source is originating from. And that's in
11 the vicinity of disposal area F. This area where
12 TCE contamination was found at disposal area F is
13 almost directly on the line where these TCE vapors
14 are showing up in the MW-10 area.
15 This is another figure of the plant
16 site. The areas investigated are colored in
17 yellow. The red dots indicate the locations of
18 monitoring wells where we collected groundwater
19 samples. This is a map of TCE concentrations in
20 the shallow aquifer zone at the facility. The
21 green lines show TCE concentrations. The highest
22 concentrations are located right in here, at about
23 90 ppm. The highest concentration I think we'
24 found was at MW-10, 110 ppm. You can clearly see
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1 a very defined, elongated east/west trending plume
2 of TCE at the southern portion of the facility.
3 It appears to originate very close to disposal
4 area F and it moves to the east along with the
5 groundwater flow past the Westinghouse facility
6 and off-site. There also is some influence from
7 the TCE contamination at the former runoff basin
8 area, where we had TCE down to 10 or 11 feet.
9 Several of the wells along the north side of the
10 facility had elevated levels' of TCE in ground
11 water.
12 Okay. This is a figure of the
13 industrial drainageway and pond. Again, we looked
14 at this area during the investigation because
15 contamination was found back in the late '80s as
16 part of previous investigations. The industrial
17 drainageway and pond are shown in blue. The
18 industrial drainageway is a 7- to 10-foot-wide
19 open ditch which begins at about where Chemung
20 Street is located. It extends to the southeast
21 about .5 mile and empties into Koppers Pond. The
22 industrial drainageway receives permitted
23 wastewater discharges from the underground piling
24 at the Westinghouse facility. That piping is
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1 shown by the dashed black lines. Westinghouse
2 facility is located in the upper corner of the
3 figure.
4 We collected sediment, surface water
5 and fish tissue samples from the industrial
6 drainageway and pond. The locations of the
7 sediment and surface water samples are shown by
8 the black dots. The results of those analyses
9 confirmed elevated levels of metal in the
10 industrial drainageway and pond, along with PCBs
11 in the sediments and also in the fish tissue.
12 This is another figure of the pond
13 and drainageway outlined by blue color. The
14 sediment sampling locations and surface water
15 locations are shown by the orange circles. It
16 shows PCB concentrations that we found in the
17 sediments and in the fish collected from the
18 pond. The sediments in the upper drainageway
19 range from 1 ppm to about 9 ppm. At the lower
20 drainageway and pond area, the concentrations of
21 PCBs were non detect to less than or equal to
22 about 1 1.5 ppm. The fish samples collected from
23 the pond, which were white sucker and carp ' '
24 species, contained about .5 ppm of PCBs and
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several other chemicals.
As part of the remedial
investigation, EPA conducted a human health risk
assessment. Based on the results of that
assessment, we identified two areas where
long-term exposure to certain contaminants
resulted in unacceptable human health risks. One
of those areas identified was disposal area F and
the industrial drainageway where site employees
and site workers were exposed to soil in disposal
area F via soil ingestion, the contaminants, PAH
and arsenic, provide an unacceptable human health
risk. For the industrial drainageway, the
receptor group there was area residents. The
exposure pathway was fish consumption and the
contaminants were PCBs.
Based on the remedial investigation
and the results of EPA's human health risk
assessment, we identified three remedial
objectives for this phase of the site. The first
remedial objective is to clean up the source of
groundwater contamination at the Westinghouse
facility. That includes disposal area F and' £he
former runoff basin.
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1 The second objective is to clean up
2 the contaminated surface soils at the facility to
3 protect site workers and employees. That is
4 specifically at disposal area F.
5 The last remedial objective is to
6 clean up the contaminated sediments in the
7 industrial drainageway to protect area residents
8 and to limit the availability of chemicals for
9 uptake by fish in the pond.
10 For disposal area F, this overlay
11 shows the contaminants of concern that we are
12 going to attempt to clean up. TCE was detected at
13 a maximum concentration of 20 ppm. The clean up
14 objective is about .8 ppm, that is to prevent the
15 leaking of TCE into groundwater. The three or
16 four PAHs listed here range in concentrations from
17 about 130 ppm to 420 ppm. We have identified
18 cleanup objectives based on human health risks
19 ranging from about .8 to 7.8 ppms. And for
20 arsenic, the maximum concentration was 19 ppm. We
21 are going to clean up arsenic to 12 ppm, which is
22 a recommended background level by the New York
23 State DEC.
24 For the former runoff basin, the
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contaminant that we want to address is TCE. And
we want to prevent it from leaching to ground
water. Maximum concentration was again 79 ppm to
prevent it from leaching to the water table, the
clean up goal is .8 ppm. For the industrial
drainageway, the contaminants are PCBs. The
maximum detected concentrations in the sediments
was 8.6 ppm and in fish 0.5 ppm. The clean up
objective for sediments is 1.0 ppm. That's the
New York State DEC and EPA's' guidance, cleanup
level for PCB contamination.
We have evaluated a number of
remedial alternatives for the three areas that we
feel need to be addressed. The first of these is
the no action alternative. We're required to look
at this alternative. We use it as a baseline for
comparison to all other alternatives.
The next alternative is limited
action. Limited action involves institutional
controls, such as property deed restrictions,
physical monitoring, fencing and warning signs to
prevent access. Groundwater monitoring also would
be included for areas where TCE contamination'was
found. We would monitor the concentrations over
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1 time.
2 Another alternative we considered
3 was containment, for disposal area F and the
4 industrial drainageway. Options at disposal area
5 F were an asphalt cover with an underlying plastic
6 liner just beneath the asphalt to prevent
7 infiltration of precipitation from leaching TCE to
8 ground water. We also looked at a concrete lining
9 of the industrial drainageway to prevent direct
10 exposure to area residents.
11 This is a figure of the asphalt
12 cover at disposal area F. The orange shows where
13 we found waste materials; the dark black line or
14 box is where the asphalt would be placed. Beneath
15 that asphalt, again, we would have a flexible
16 plastic liner. The pavement would be taken to the
17 parking lot already at the facility. I have also
18 shown where TCE vapors in the soils and in the
19 ground water.
20 Excavation and off-site disposal was
21 another alternative that we looked at for all
22 three areas. Contaminated soils or sediments
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23 would be excavated and sent off-site for proper
24 disposal, and treatment, if so required. This is
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1 just an illustration, but it's got some specifics
2 to the former runoff basin area. Excavation and
3 off-site disposal is more difficult there because
4 of the close proximity of the contaminated soils
5 to building foundations and underground
6 utilities. Also, the contamination has gone below
7 the groundwater table. So we would need
8 dewatering operations when we excavate those
9 materials.
10 Another alternative was thermal
11 desorption. That's where we would bring a
12 transportable unit to destroy volatile and
13 semi-volatile compounds. Materials would be
14 excavated and fed into this unit on-site. Soils
15 would be heated to 200 to approximately 1,000
16 degrees Fahrenheit and the residual materials
17 would be backfilled into the excavation.
18 The last alternative that we looked
19 at was soil vapor extraction. I didn't have a
20 real good figure for this so I just thought I
21 would show you a schematic of the process. Soil
22 vapor extraction is being considered for the
23 former runoff basin area and disposal area F'. ' It
24 consists of vertical air extraction wells which
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1 are placed in the area of the soil contamination.
2 Those wells would pull contaminated vapors and
3 moisture from the soils; they would then be sent
4 into a vapor and liquid separator where they would
5 be funneled off for treatment. The vapor
6 treatment would be through an off-gas carbon
7 treatment system. The recovered liquid would be
8 sent to a water treatment facility which
9 Westinghouse is currently building at their
10 plant.
11 This overlay shows several criteria
12 which EPA uses for evaluating remedial
13 alternatives. I am not going read all of them to
14 you. Overall protection of human health and the
15 environment and compliance with all federal and
16 state requirements. Those are two significant
17 criteria.
18 Others are the long-term
19 effectiveness and permanency of the remedy, and
20 the implementability of the remedy. We look at
21 costs. Of course, state acceptance and community
22 acceptance.
23 This shows a summary of the costf of
24 all of the alternatives that we have looked at for
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1 the three areas. It shows capital cost, operation
2 and maintenance cost, net present worth cost. The
3 cost for disposal area F ranged between .5 and 1.1
4 million dollars. The cost for the former runoff
5 basin area, again net present worth costs, ranged
6 between about .5 to 1.3 million dollars. Most
7 expensive of those alternatives was removal and
8 off-site disposal, partly because of the
9 difficulties which I showed you on an earlier
10 figure for dealing with the 'close proximity of
11 building foundation and underground utilities.
12 Also, for that alternative, some of the TCE
13 contaminated soils may have to be incinerated if
14 they don't meet land disposal restriction
15 standards. For the industrial drainageway, the
16 alternatives ranged between about $300,000 to
17 $700,000.
18 My last overlay, our proposed
19 remedies for disposal area F and for the
20 industrial drainageway are removal and off-site
21 disposal. For the former runoff basin area, we
22 also looked at removal and off-site disposal.
23 However, again, with the difficulties in dealing
24 with that area, we felt that soil vapor extraction
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1 was a better remedy. It addressed those soils in
2 ' close proximity to the building foundations, it is
3 one of the remedies of least cost.
4 One last point I wanted to make with
5 the industrial drainageway. The removal and
6 off-site disposal of contaminated sediments would
7 be for the industrial drainageway. We are not
8 proposing any remedial action at Koppers Pond.
9 EPA did conduct an ecological risk assessment
10 which showed us that, based on the levels of
11 contamination out there, that further study is
12 ' warranted. We plan to go back to the pond in the
13 spring of next year and conduct an ecological
14 study. The purpose is to see whether the levels
15 of contamination are acceptable at the pond.
16 That's all. I think I will open up
17 the question and answer period here.
18 ANN RYCHLENSKI: I would just like
19 to add one thing before we do. Is there anyone
20 here present from any of the state agencies, state
21 DOA or state DEC? Just identify yourselves.
22 Thank you. We just want to acknowledge you and
23 your name please. >
24 STEPHEN SHOST: Steve Shost of the
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1 New York State Health Department in Albany.
2 WAYNE MIZERAK: My name is Wayne
3 Mizerak of the New York State DEC in Albany.
4 ANN RYCHLENSKI: Thank you. Just in
5 case anything comes up that's within your
6 jurisdiction, people will know who is here to
7 answer those questions. We will take your
8 questions now. Again, please stand, speak
9 clearly, c*nd give your names so that our
10 stenograp' :3r can get everything down accurately.
11 MARY SMITH: I am Mary Smith. And I
12 live at 3512 Michigan, which is parallel to
13 Kentucky Avenue, at that residential site. And I
14 am concerned about the number of barrels that have
15 been found. According to your statistics, 197
16 were put in the ground, approximately 200, you
17 said. And 179 were found and removed. I would
18 like to know where the other 17 might be hiding.
19 MARK PURCELL: Well, the initial
20 number I think was an estimate based upon
21 records. Clearly, we investigated the entire area
22 and 179 is all that we could find. We assume at
23 this point that that's all that there were. ' '
24 MARY SMITH: So someone just
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1 couldn't count?
2 MARK PURCELL: Right, these are old
3 records and you do the best you can. You saw in
4 disposal area F, or the area F disposal, where
5 that yellow box was. When we actually broke the
6 ground open, we found waste in a larger area than
7 was originally estimated. You really have to go
8 and you have to investigate it. We believe -- and
9 we shot it with ground penetrating radar and dug
10 trenches --we got it.
11 MARY SMITH: Okay.
12 KENNETH ROHRER: My name is Kenneth
13 Rohrer. I live at 530 Perkins Avenue,
14 Horseheads. I was associated with the
15 Westinghouse Environmental Control Program
16 starting in 1971. I also served as the
17 environmental control officer at Westinghouse from
18 1978 through 1994 when I retired. So I am
19 speaking tonight as a Horseheads citizen.
20 I have several concerns reading the
21 reports. Unfortunately, I could only spend about
22 an hour this afternoon going through two cardboard
23 boxes of reports primarily. There was a ques£ion
24 on there for you that you missed. Number one:
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Prior reports. There was some concern about the
presence of TCE in the property from Horseheads
Automotive. This is a crowded area. I don't
care. I also understand there is a Big Flats well
that was also shut-in.
The question to you is: What's
being done in those sources where sewers have
vapors. I didn't see anything off Westinghouse
property to determine what the effect in the plume
may be.
MARK PURCELL: As part of the
remedial investigation, we didn't look at the
automotive junk yard that you have mentioned. In
early 1990, levels of TCE are showing up in some
of the Westinghouse welling at Westinghouse. I
have been on this project too long. The junkyard
was west of the Westinghouse facility. And that's
where it was located. We are picking up some
traces of chemicals coming in, trichloroethylene
is one. I can show you that figure.
KENNETH ROHRER: Chlorethene was
another one as I recall.
MARK PURCELL: Okay.
KENNETH ROHRER: That's chloroform.
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1 MARK PURCELL: We didn't really see
2 that at the Westinghouse facility. TCE was really
3 the only chemical that we saw as a defined plume
4 that was moving away from the facility. We were
5 going from about 5.0 ppm on the western edge until
6 we get to disposal area F. And then we jump up to
7 100, 120 ppm. So we think that the source, at
8 least the lion's share of where this plume
9 originates is the Westinghouse facility. We have
10 the areas that we're focusing on in disposal area
11 F and the other areas, and will address those
12 areas as source control. However, the ground
13 water remedy that EPA selected back in 1990 is to
14 capture the entire contaminate plume coming off
15 the Westinghouse facility. And if there is
16 something coming in from the west side, then that
17 would be captured in this treatment system also.
18 Two pumping wells that are going to
19 be installed as part of the groundwater remedy are
20 located in the southeast corner of the facility.
21 And they're dead on line with the plume, where we
22 found the plume is moving. And we have modeled
23 pur design to show that it will in fact capture
24 the entire groundwater plume coming across the
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1 Westinghouse site. We are confident we have it.
2 Disposal area F and former runoff basin are
3 additional control measures. Those are to help us
4 expedite the clean up of this aquifer. If leaving
5 them there, we may have to pump those wells for a
6 lot longer to pull all the TCE from into those
7 areas. Getting that contamination out of there,
8 definitely will help us.
9 KENNETH ROHRER: I have another
10 concern about your drainageway project.
11 Unfortunately, in that hour, I couldn't really
12 take the time to cover the report. But in your
13 risk assessment in the drainageway, it's my
14 opinion that it may be slightly overstated. I am
15 really concerned about the attention that you are
16 showing to PCB in the drainageway. Are you
17 weighing into the program the extensive draining
18 system from the highway and throughout the
19 village. Runoff potentially containing PCBs that
20 may enter there, not just .from the Westinghouse
21 facility?
22 MARK PURCELL: We recognize that
23 that underground piping cuts across a portion'of
24 the town.
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KENNETH ROHRER: It goes miles from
there.
MARK PURCELL: I don't know how long
it goes. But we recognize that fact. And we have
low levels of PCBs in the industrial drainageway
and pond. I mean 1 to 10 ppm, that's not a high
concentration.
KENNETH ROHRER: That's why I am
saying I think it's overstated.
MARK PURCELL: But the problem is
with 1 to 9 ppm in the industrial drainageway. We
barely found 1 ppm in the pond. We have .5 ppm in
the fish in that pond and that .5 ppp is
generating human health risk. So, they're picking
those PCBs up from their environment. And even
though it's not a very high concentration, it's
contaminating those fish and people if they are
consuming those fish, you know, that exposure
pathway can lead to --
KENNETH ROHRER: I can understand
it. I guess what I am saying, even when you clean
up the drainageway, you are really not going to
succeed in the objective that you have stated.
There are other sources of PCB. One that I
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1 question was the previous report where there were
2 high PCB levels found at the county highway
3 department property. I don't see anything in the
4 report regarding those.
5 ' MARK PURCELL: Yeah, there are. No,
6 we didn't look at that as part of this project.
7 KENNETH ROHRER: Another thing that
8 I have great concern for is that I have personally
9 observed over many, many years and reported to DEC
10 about industrial users of solvents and oils in the
11 immediate area, open landfilling, huge amounts,
12 just bulldozing those things right in the ground
13 in the area on the other side of the pond, on the
14 adjoining road down. I have also reported for
15 years to DEC the access.roads leading into the
16 area that is adjacent to the railroad tracks going
17 down to the Kentucky Avenue Well. I have seen
18 people come in there and dump things and leave
19 them there. And I have seen them remain there for
20 months, open drums of solvents and oils. And I
21 have seen them exist for six months or more until
22 the DEC finally came and got them.
23 . One concern I have is after you go
24 through all this effort, that the dumping is still
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1 going to continue unless you cut off access to
2 those areas. It's too easy to get in there.
3 MARK PURCELL: Okay. That's another
4 concern.
5 KENNETH ROHRER: The other concern I
6 have is that I would think that you would be more
7 concern about heavy metal sediments.
8 MARK PURCELL: Well, concentrations
9 of heavy metals are very high. And back in the
10 mid '80s, when EPA did its investigation, they
11 were higher. And, in fact, we actually generated
12 risk from those contaminants. We went back out
13 '84, and '85. Even though the concentrations
14 were elevated, they fell within our risk range.
15 Didn't seem to be a player like the PCBs were. We
16 acknowledge that there is heavy metal
17 contamination of those sediments without a doubt.
18 KENNETH ROHRER: One thing you
19 mentioned in this report that you didn't mention
20 tonight and that is the description of
21 unauthorized discharges continuing in the
22 drainageway. I have probably observed that
23 drainageway thousands of times over 20 years'. ' And
24 I can say with certainty that in the last 5 months
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1 I have never seen it look so bad. Probably for 30
2 years, this is the worst I have ever seen it. I
3 was there recently, several weeks ago, when all
4 three tenants from the old Westinghouse facility
5 were supposedly shut down for vacation. While I
6 was standing there it was so heavy that I could
7 not see to the bottom of the stream. And we know
8 where it's coming from. And we know that it's not
9 a consistent permanent discharge. It's an
10 intentional dump.
11 So I guess my question is: What do
12 you plan on doing? It just seems senseless to
13 clean it up without locating the source first.
14 MARK PURCELL: That's the approach
15 to this whole process right now. We were out
16 there in 1995 trying to conduct this aspect of the
17 Wellfield site remedy. We conducted samples out
18 there and low and behold we noted a flock material
19 floating in the drainageway. And several
20 landowners had commented to us about it. In fact,
21 they had actually gone out and collected a sample
22 of this flock material and found it to be heavily
23 contaminated with heavy metals; lead at 14,0bd or
24 15,000 ppm. These levels far exceed any permanent
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1 discharge limit. It's been ongoing since mid 1995
2 and it's still going on now. We have, and the
3 State of New York DEC has gone out there several
4 times and collected samples. And we have
5 confirmed what the local landowners found. They
6 are conducting an investigation right now. The
7 DEC authorities are looking into it. Clearly,
8 it's some kind of violation or an unauthorized
9 discharge. Where it's coming from, I'm not sure
10 if we can say at this point. They are looking
11 into it. I do know the concern about going out
12 there and cleaning up this drainageway and having
13 it recontaminated. And we've got to address this
14 ongoing problem right now. We have actually
15 wrote, I think it is in this proposed plan, that
16 whatever cleanup action is selected for the
17 industrial drainageway, we're not going to take
18 that action until this problem is addressed.
19 That's really where we are.
20 KENNETH ROHRER: I have never seen
21 it look the same on any day I have been there.
22 It's either red, green, blue, white, brown, black,
. s
23 take your pick of color.
24 MARK PURCELL: Do you notice it on,
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1 are you seeing it on a certain day of the week or
2 is it every day?
3 KENNETH ROHRER: Obviously, I
4 haven't gone every week. Every time I have been
5 there it looks different.
6 JIM DOYLE: For my benefit, you said
7 you know where it's coming from. If you don't
8 want to say, that's fine.
9 KENNETH ROHRER: Well, there are
10 three manufacturing concerns and buildings, so it
11 must be one or more of them.
12 JIM DOYLE: Okay. We are looking
13 into trying to figure either way.
14 KENNETH ROHRER: Certainly, by the
15 magnitude of the dumps indicates it isn't
16 originating from the drainage system off the
17 highway.
18 JIM DOYLE: I see, I thought you
19 were implying that it was something more obvious,
20 something else going on. Yeah, that's what the
21 state and the permit people are looking at.
22 KENNETH ROHRER: It shouldn't be too
. j
23 difficult to find out where it is coming from.
24 WAYNE MIZERAK: Just to answer your
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1 question about what's being done. Within the past
2 month, our permanent people have met with the
3 operators of I believe Toshiba. They will be
4 submitting an investigation plan to evaluate it.
5 Our permitting people are pursuing the fact that
6 something needs to be done there. So action is
7 working toward what you requested.
8 MARK PURCELL: Thank you. Are there
9 any other questions?
10 ANN RYCHLENSKlY Okay then, we will
11 say good night. I just want to remind you once
12 again, that if you have any comments, you want to
13 write them in, you can send them to Mark. His
14 address is right there. Please make certain that
15 you take one. If you didn't sign in, please do
16 so, so they can have your name on my mailing
17 list. We thank you for coming out and we will
18 keep you abreast of further actions taken out
19 here.
20 Thank you. Good night.
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CERTIFICATION
I hereby certify that the proceedings
and evidence are contained fully and accurately in
the notes taken by me on the above cause and that
this is a correct transcript of the same to the
best of my ability.
ELIZABETH I. REICHERT
VERBATIM COURT REPORTING SERVICE, INC.
402 WEST CHURCH STREET
ELMIRA, NEW YORK 14901
800-368-3302
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APPENDIX F
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16 Sep 1996
Mark Purcell, Project Manager
US Environmental Protection Agency
20th Floor
290 Broaduay
New York NY 10007-1866
Re: Kentucky Avenue Uellfield Superfund Site
I was part of the public meeting 11 Sep at the Village of Horseheads Hall and spoke UP
about the inconsistency of the number of 30-gallon drums containing ignitable and
reactive magnesium chips and titanium turnings buried during 1973-1975 by Uestinghouse.
On page five the estimate is 196 drums buried. On page twelve, (1) states that a total
of 179 55-gallon drums were removed from this area. Both the number of drums and the
size of the drums do not match.
I concur that you have developed a comprehensive cleanup plan and feel the best remedial
alternative to the three areas you have cited on page twenty be: removal and off-site
disposal. I am concerned about your preference for 38 - Physical Treatment by SVE-A5
J Option 2) for the former runoff basin area but understand you feel it would be more
nclusive as it would involve those soils in close proximity to, or directly under, the
building foundations at the Former Runoff Basin Area. Might you consider a combination
of Alternative 28 and 38 to maximize the cleanup?
It is also my understanding from information offered at the public hearing, that there
currently is continued contamination in the area and the source or sources have not been
identified. Aggressive prosecution of those causing contamination must be pursued.
Mary Smith
3512 Michigan Ave
Elmira NY 14903-1107
Citizens Clearinghouse for Hazardous Waste, PO Box 6806, Falls Church VA 22040
Center for Respect of Life and Environment, 2100 L St NU, Washington DC 20037
Environmental Justice Program, Catholic Charities, 1700 College Ave, Elmira 14901
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