United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD,R02-85/015
September 1985
Superfund
Record of Decision
Clean Well Field, NY
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TECHNICAL REPORT DATA
(Please read Instructions on the reverse before completing)
1. REPORT NO.
EPA/ROD/R02-85/015
3. RECIPIENT'S ACCESSION NO.
4. TITLE AND SUBTITLE
SUPERFUND RECORD OF DECISION
Clean Well Field, NY
5. REPORT DATE
September 24, 1985
6. PERFORMING ORGANIZATION CODE
7. AUTHOR(S)
8. PERFORMING ORGANIZATION REPORT NO.
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10. PROGRAM ELEMENT NO.
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U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
13. TYPE OF REPORT AND PERIOD COVERED
Final ROD Report
14. SPONSORING AGENCY CODE
800/00
IS. SUPPLEMENTARY NOTES
S-.M»......,!-Jt-.
16. ABSTRACT
The Olean Well Field is located in the eastern portion of the City of Olean, and
also encompasses part of the Town of Olean, in Cattaraugus County, New York. Early
in 1981, the three municipal wells (Well numbers: 18M, 37M and 38M) at the site were
found to contain levels of trichloroethylene (TCE) at concentrations above the New
York State Department of Health (NYSDOH) Drinking Water Guidelines (50 ppb). These
wells were closed and an old surface water filtration plant was reactivated to provide
water to city residents. Private wells in the area were subsequently tested and many
were found to be contaminated. Approximately one half of the contaminated private
wells have shown TCE levels of over 1,000 ppb. The highest level of TCE detected in
a private well was 3,100 ppb (sample taken June 1985).
The selected remedial action for this site includes: reactivating the municipal
wells and constructing a packed tower air stripping system north of the Allegheny River
at municipal well 18M to treat the ground water to a maximum contaminant level (MCL)
of 5 ppb for TCE; construction of a similar air stripping system south of the river to.
treat water from wells 37M and 38M; discharging all treated water into the public
water supply system; extending the City of Olean water lines into the Town of Olean
and hooking up 93 private well users to the public water supply system; inspecting the
McGraw-Edison industrial sewer and analyzing repair and replacement options;
(see separate sheet) .<_-'£••"•*<- 'j-iS^.v^ - .•••"• ...rjS-v.^. .
17.
KEY WORDS AND DOCUMENT ANALYSIS
DESCRIPTORS
b.lDENTIFIERS/OPEN ENDED TERMS C. COSATI Field/Group
Record of Decision
Olean Well Field, NY
Contaminated Media: gw
Key contaminants: trichloroethylene
VOCs
(TCE)
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SUPERFUND RECORD OF DECISION
Olean Well Field, NY
Abstract - continued
recommending institutional controls restricting the withdrawl of ground water
for drinking purposes where MCLs are exceeded; and initiating a supplemental
Remedial Investigation and Feasibility Study to evaluate source control measures.
Total capital cost for the selected remedial alternative is estimated to be
$1,996,780 with O&M costs approximately $799,040 per year.
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RECORD OF DECISION
Remedial Alternative Selection
Site: Olean Well Field, Clean, Cattaraugus County, New York
Documents Reviewed;
I am basing my decision primarily on the following documents
describing the analysis of cost-effectiveness of remedial alter-
natives for the Olean Well Field Site* :-r.;i,.:. 4,.^; ,.,
- Olean Well Field Remedial Investigation
- Olean Well Field Feasibility Study ~^- -' -. ^EJ
- Staff Summaries and Recommendations
Description of Selected Remedy;
This Record of Decision calls for the following actions;
•£vs, iijyi>- •,;•.>. ... :.-••'•• .-
0 Reactivate the municipal wells and construct a packed tower air
stripping system north of the Allegheny River at municipal well
18N to treat the ground water to a maximum contaminant level of
5 ppb for TCE. This level is as close to the Recommended Maximum
Contaminant Level (RMCL) for TCE as is technically feasible while
providing a high level of protection to the public. Also construct
a similar system south of the river to treat water from wells 37M
and 38M. All treated water will be discharged into the public
water supply system.
0 Extend the City of Olean water lines into the Town of Olean
and hook up 93 private well users to the public water supply
•system (90 private wells north of the Allegheny River and 3
private wells south of the river).
0 Inspect the McGraw-Edison industrial sewer and analyze repair
£fend replacement -.options.
0 Recommend institutional controls restricting withdrawal of
ground water for drinking purposes where maximum contaminant
levels (MCL) are exceeded.
0 Initiate a supplemental Remedial Investigation and Feasibility
Study to evaluate source control measures. The duration of the
ground water treatment period will be projected as part of this
additional study.
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Declarations;
Consistent with the Comprehensive Environmental Response, Compen-
sation, and Liability Act of 1980 (CERCLA), and the National Con-
tingency Plan (40 CFR Part 300), I have determined that the place-
ement of air strippers on the City of Olean municipal wells, the
hookup of 93 private well users to the public (City) water supply,
as well as inspection of the McGraw-Edison industrial sewer and
analysis of repair or replacement options at the Olean Well Field
site is a cost-effective remedy and provides adequate protection
of public health, welfare and the environment. Furthermore, I
have determined that it is necessary to undertake a limited,
supplemental Remedial Investigation and Feasibility Study to
evaluate source control measures. A determination regarding
future source control actions will be made upon completion of
this work. !3¥ ""-8" '
|, The State of New York has been consu1^^%nd agrees with the -;|i|
approved remedy. In addition, the action will require future ~"
operation, maintenance, and monitoring activities to ensure the
continued effectiveness of the remedy. These activities will be
considered part of the approved action and eligible for Trust
Fund monies for a period of one year.
I have also determined that the action being taken is appropriate
when balanced against the availability of Trust Fund monies for
use at other sites.
Date' Christopher J
• ' Regional Admr
I • /
pher'J
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SUMMARY OF
REMEDIAL ALTERNATIVE SELECTION
SITE: Olean Well Field
SITE LOCATION AND DESCRIPTION
The Olean Well Field is located in the eastern portion of the
City of Olean, and also encompasses part of the Town of Olean.
The City and Town of Olean are in Cattaraugus County/ New
York, approximately 65 miles southeast of Buffalo (see Figure
1). Residences, industrial and commercial establishments,
as well as an abandoned landfill are located within the site's
boundaries. The Allegheny River, one of its tributaries
(Haskell Creek), and some streams.,flow .through the site. Two <-.,
aquifers exist beneath this area. The 'relatively thin upper '•-••—
aquifer is generally composed of sand with some gravel and
silt. It begins just south of the AVX Ceramics Corp., extends
southward to the Allegheny River and resumes again south of
the river. The lower or City aquifer, composed'of sands and
gravels, extends beneath the entire site and provides water
for three municipal wells which, until 1981, served as the
primary source of drinking water for the City's 20,000 residents,
Private wells in the Town are also screened in the aquifers.
The upper and lower aquifers are separated by a less permeable
layer or aquitard, composed of glacial till containing
approximately 50% silt and clay.
SITE HISTORY
Early in 1981, the three municipal wells (18M, 37M, & 38M) at
the site were found to contain levels of trichloroethylene
(TCE) at concentrations above the New York State Department
of Health (NYSDOH) Drinking Water Guidelines (50 ppb).
These wells were closed and an old surface water filtration
plant was reactivated to provide water to city residents.
Private wells in the area were subsequently tested and many
were also found to be contaminated.
CERCLA immediate removal actions were conducted prior to and
during the RI/FS in response to unacceptable levels of conta-
mination in private wells. In 1982, EPA performed an immediate
removal action which entailed monitoring of private wells
and installation of one cubic foot carbon filters on 16
private wells. In 1984, EPA initiated a second immediate
removal action which included the installation of eleven
(11) carbon adsorption units consisting of two 3-cubic foot
filters in series and a monitoring program. The replacement
of one of the original filters, which had suffered breakthrough,
was included in the 11 systems. These filter systems were
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designed in accordance with NYSDOH 1984 guidelines. A
third removal action was implemented in March 1985 and involved
installation of 2 filter systems similar to those installed
in 1984.
Focused Feasibility Study/Initial Remedial Measure
In 1984, a Focused Feasibility Study was undertaken by New
York State Department of Environmental Conservation (NYSDEC)
in order to develop an interim program which would minimize
the public health risk to users of private wells which were
contaminated or threatened by the movement of the contaminant
plume. The study recommended upgrading the 15 remaining 1- '
cubic foot carbon filter systems to two 3-cubic foot carbon
p filters in series, installing 3 new carbon filter systems ,,
similar in size to"the upgraded systems^:and setting aside
funds for 4 additional systems to be used as necessary.
Maintenance and monitoring of the above filter systems and
monitoring of unfiltered private wells within the area of
concern were also recommended. It was agreed that the State
of New York would take over the maintenance and monitoring
costs after one year until such time that the remedial
recommendations were -.=
implementation began in June
1985.
Iflterna|ive is |impl«mented. -These
^authorized on April 4, 1985 and imj
Remedial Investigation
During the remedial investigation 19 monitoring wells were
installed around the study area. Analyses of the hydrogeology
within the site's boundaries show that there are two aquifers
separated by an aquitard of varying thickness comprising the
upper 100 feet of the Allegheny River Valley. It was determined
by utilizing groundwater elevations that the natural gradient
of the upper and lower aquifers is extremely flat. The upper
^aquifer flows Coward and discharges into.^h^;Allegheny |tit
'and the lower or City'aquifer flows iri^a southwesterly r"^
direction. When the municipal wells are pumping, ground water
flow in the lower aquifer is accelerated and the gradient is
significantly increased due to the large cone of influence of
the wells.
Chemical analyses of the ground water show that the contaminant
plume is widespread throughout both aquifers and forms a
triangle loosely defined by Alcas Cutlery to the west, AVX
Corp. to the north, and McGraw-Edison to the east. The plume
is composed primarily of TCE with some upper aquifer wells
also showing lower levels of other volatile organics such as
1,1,1 trichloroethane and trans-l,2-dichloroethylene. (See
Figures 2 and 3 and Tables 1 and 2 for monitoring well data
and industrial site data.)
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TCE is a suspected carcinogen and a known cause of liver and
kidney damage and central nervous system depression. The highest
concentrations of TCE contamination appear to be located in
the upper portion of the lower aquifer and in areas of the
upper aquifer. This is of great concern since the majority of
private wells are screened in the upper portion of the lower
aquifer.
Contamination migration in the study area occurs primarily in
the subsurface environment. Contaminants entering the upper
aquifer are transported both horizontally (vn=50 ft/day],
towards the river, and vertically [vv-10 ft/day], downward
through the upper aquitard [kn=1.0 ft/day; kv=0.001 ft/day]
and into the lower aquifer. In the lower aquifer, movement
is directed to the west and southwest and can be fairly rapid
when the municipal wells are pumping. .(The above-stated ;,::,,,.•..
values are based on a modelling study performed for EPA by -• —-'
INTERA Technologies.)
In addition to contaminating the 3 municipal wells, the TCE
plume, to date, has also heavily contaminated over 30 private
wells in the study area. The levels of well water contamination
have fluctuated greatly since monitoring began in 1982.
Approximately one half of the contaminated private wells have
shown TCE levels of over 1,000 ppb. The highest level of TCE
detected in a private well during the most recent (June 1985)
monitoring run was 3,100 ppb.
ALTERNATIVES EVALUATION
Objectives
The objectives of the proposed remedial action are to provide
a permanent and safe drinking water supply for the City and
Town of Olean, and to' mitigate and control contamination in the
ground water. The level of response for NPL sites is determined
the requirements of CERCLA Section 104,A*vhich. mandates
PA to protect public health and welfare and the environment
At this site, the level of response is dictated by the desire
to keep the public health risk set at a level at which no
known or anticipated adverse effects occur and which allows
an adequate margin of safety. Also, it is necessary to choose
a level that is technically feasible and detectable using the
best technology that has a low margin of error. Therefore,
it is recommended that 5 ppb, the highest level of TCE allow-
able in the drinking water that best supports the above and
is consistent with a 10~* risk level, be utilized for the
remedial action. ( Reduction of TCE to a level of 5 ppb
should also reduce other contaminants sufficiently to comply
with the 10"6 risk level. However, monitoring will determine
the effectiveness of the treatment system in meeting this
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requirement. If the levels of other contaminants are above
acceptable risk levels then the operating parameters of the
treatment system will be adjusted accordingly.
The objective of the proposed supplemental source control
RI/FS is to determine which, if any, source control measures
would be cost-effective.
Alternative Screening Process
Remedial alternatives were initially divided into the follow-
ing three categories: Public Water Supply, Private Water
Supply and Groundwater Contamination Control. Any overlaps
among the sets of alternatives were eliminated in the recommended
alternative. All remedial alternatives were screened in a
two-phase process. The first phase was based primarily on
engineering judgement. Alternatives were rated on cost,
environrnental impact, -public -h«al^^
and technology. Alternatives passing the initial screening
process were then reevaluated in greater detail during the
second phase. All considered alternatives are listed on
Tables 4 a, b, and c.
No Action Alternative
Selection of the "No Action" alternative would preclude further
Trust Fund expenditures for remedial action. This alternative
consists of retaining the status quo at the site, i.e., continued
operation of the surface water treatment plant and continued
use of the existing carbon adsorption systems on private
wells. However, there would be no future installations or
monitoring and maintenance programs. This alternative was
eliminated for the following reasons:
0 The City of Olean water supply would be endangered
because of the uncertain reliability of the surface water
treatment plant;'
• • The private-well users in^the^TownSf"Olean Would
continue to be threatened by the contaminant plume;
• Plume migration would not be controlled, thereby
threatening the St. Francis municipal wells downgradient
of the site, which augment the City's water supply;
0 Ground water contamination would not be alleviated;
0 O&M costs for the surface water treatment plant are high,
Another no action scenario that was considered and eliminated,
because it did not effectively reduce the risk to public
health, was the reactivation of wells 18M, 37M and 38M without
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treatment of the ground water. Since previous observed
levels of TCE contamination in the municipal wells were in
the 200 ppb range, this scenario would result in public health
risks well above the 10~6 risk level.
Detailed Analysis
The detailed analysis of the remaining alternatives included a
review of technical feasibility, regulatory and permit require-
ments, public health analysis, community relations, institutional
analysis and cost analysis. In order to compare each alternative
on an equal basis, the total costs for supplying the City and
Town with water were developed. Costs unrelated to the TCE
contamination problem were deducted after the lowest cost
alternative was chosen. Cost estimates for each alternative
were developed at the same level of detail. Annual operation
and maintenance costs were also estimated where
Present worth calcuTatlbni?^s'5 ^i^^^^lilSl^BiilamJ^B/
include annual O&M costs and assume a 30 year life span. The
project life span may change as a result of future source
control analyses.
The following is a discussion of the various alternatives
considered during the RI/FS and retained after the initial
screening. Tables 5A and 5B summarize the remaining remedial
alternatives. The present worth calculations listed on these
tables should also be used to compare the cost-effectiveness
of these alternatives. As previously stated, the alternatives
have been grouped into the following three general categories
for the purpose of simplication: (1) City or public water
supply; (2) Town or private water supply; and (3) Ground
water contamination control.
City or Public Water Supply
t ' *
Various alternatives whose goal was to provide a permanent and
safe drinking water,supply while satisfying the peak water
supply demands of the .City of Qleanjvere.fm
..alternatives are described
• Construction of a surface water treatment plant to
replace the aged plant currently in use was considered
a viable option. A conceptual design of the plant was
used as a basis for the cost estimate. That design
included the capacity to generate enough water to serve
the users of the private Town wells within the study
area, if necessary. This plan entailed the highest
overall cost and also would have necessitated a plume
management program. A plume management program would
use one or more pumping wells to control and/or stop
the movement of the plume.
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0 Utilizing the existing municipal wells (18M, 37M, &
38M) and treating the ground water to acceptable risk
levels was also considered. The demonstrated technologies
for treatment of ground water which is contaminated with
TCE and related volatile chlorinated solvents are air
stripping and activated carbon adsorption systems. Three
alternatives were evaluated for treatment of ground water
for use as the public water supply. These alternatives
are packed tower air stripping (the recommended alternative),
packed bed granular activated carbon adsorption systems
and packed tower air strippers combined with activated
carbon adsorption systems.
Since the municipal wells are located on both sides
of the Allegheny River, analyses were done, to determine
-the most Economical IbcaViohf
The construction of a water pipeline under the river in
conjunction with a single water treatment system was
analyzed and eliminated due to the increased expenses
associated with river construction. It was* concluded
that the most feasible cost effective approach would be
to build one treatment system north of the river near
well 18M and another system south of the river near
wells 37M and 38M.
The air stripper towers were designed assuming a
maximum TCE concentration in the influent of 750 ppb.
Even though the highest TCE concentration detected in the
municipal wells has been 210 ppb, this assumed concentra-
tion level was deemed necessary to sufficiently treat
the high levels of TCE seen in other areas of the aquifer
and till that may arrive at the municipal wells.
The carbon adsorption systems, while technically
feasible, have -a 'much higher capital cost and are also
more expensive to maintain than air strippers.
• The last remaining alternative considered for the:
public water supply was the construction of new municipal
wells beyond the contaminated area. These new wells would
also be capable of supplying water to the users of the
private Town wells within the area of concern, if necessary.
Determining the exact location of these new wells was
deemed beyond the scope of this study. Therefore it was
assumed for economic purposes that these wells would be
located within a 5 mile radius of the City but outside
the contaminated ground water areas in West Olean (ammonia
and chromium contamination unrelated to this site) and
East Olean.
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Town or Private Water Supply
Four alternatives were retained for detailed analysis. These
alternatives can be grouped into two categories: continued
use of carbon filter systems on private wells and the connection
of private users to the public or City water supply.
0 The continued monitoring of filtered and unfiltered
private wells within the area of concern, installation
of carbon adsorption systems as necessary, and maintenance
of new and existing filter systems were analyzed in
detail. A variation of this alternative was also consid-
ered, the difference being the placement of carbon
adsorption system on all private wells within the area
of concern. These alternatives allow for the possible
risk of short-term exposure to volatile organic carbons ^,,>
prior to a new installation and/or at the end of^a H* *^--~
maihtenance cycle. Frequent monitoring and maintenance
is necessary to minimize the risk of short-term exposure
to VOC's, thereby raising O&M costs significantly.
• Connection of private users to the Publfc or City
water supply is the alternative that is the most cost-
effective and requires the least maintenance. Two
versions of this alternative were analyzed for cost-
effectiveness. Each version also necessitates the need
for establishment of a water district in the Town of
Olean.
The first version would hook up all users located in
Zone 1 (50 hookups; see Figure 4). Zone 1 contains those
private wells which show the highest levels of contamination.
Private wells in Zones 2, 3, and 4 would continue to be
monitored for contamination. These wells would
also continue to have their existing carbon filter
systems monitored, and maintained and new systems installed,
as necessary. In addition to having high maintenance
costs, this alternative would not eliminate the risk
of short-term exposure in Zones-2, 3 and 4.
The second version of this alternative would extend
the City water line to Zones 1, 2 and 4 (93 hookups).
Zone 3 would continue to receive monitoring. While this
alternative has a higher capital cost, it is less expensive
over the life of the project since monitoring costs are
lower. This alternative best protects public health by
connecting all private wells with the highest risk of
contamination.
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Ground Water Contamination Control
Various ground water contamination control alternatives
were analyzed in the RI/FS. However, EPA has determined
that the data used in the RI/FS was insufficient to accurately
analyze remediation of the contaminated soils and ground
water. Given the high concentrations of VOCs at the industrial
sites, further study is necessary to better delineate
contaminated soil areas and to determine the most cost-
effective source control actions.
The RI/FS addressed the industrial sewer that crossed the
study area (See Figure 5 - Location Map). Flow studies conducted
during the RI/FS process showed that the sewer exfiltrates
(loses water) in some sections and infiltrates (gains water)
in others. Although these data do not accurately reveal |.he
areas of interaction between the sewer ^ahd the ground water*
they do show that the sewer can act as a conduit for contamin-
ated ground water. The sewer also may be a source of TCE
contamination, since TCE concentrations as high as 14,000 ppb
recently have been detected in the sewer. It is recommended
that the sewer be inspected and repair or replacement options
be evaluated based on the results of the inspection.
Recommended Alternative
The recommended remedial alternative is the lowest cost alter-
native that is technologically feasible and reliable and
provides adequate protection of public health, welfare and
the environment. Table 6 contains a cost breakdown of the
recommended alternative.
The recommended alternative consists of initially treating
the ground water to 5 ppb for TCE by placing air strippers on
the municipal wells .and discharging the treated water into
the City drinking water system, and extending the City water
lines to the Town and hooking up 93 private wells, including
three residences south of the Alleghenyi^liyer -currently
carbon adsorption systems. Monitoring of private wells in
Zone 3 (north of the areas known to be contaminated) will
continue, and carbon adsorption units will be installed as
necessary. The McGraw-Edison industrial sewer will also be
inspected and repair or replacment options analyzed since
its role in dispersing contaminants introduced into it is
unknown. It is known that high levels of TCE have been
found in the sewer and that it infiltrates and exfiltrates
at different sections along its length. It is also recommended
that institutional controls be established prohibiting
withdrawal of ground water from portions of the aquifer
where the level of TCE contamination is greater than 5 ppb.
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This recommended option provides the best protection to
public health by removing the risk of exposure to contamination
in unfiltered and filtered wells within the area of concern.
The aquifer will also be treated and the plume managed as
approximately 3.25 million gallons per day of water are
stripped of contaminants.
The need for source control, which may include options such as
capping, treating or excavating contaminated soil, will be
evaluated following further field work to better delineate
contaminated areas on the industrial sites. Also, further
sampling will be performed to determine if the Seneca Avenue
landfill is or was a source of contamination. These activities
need to be initiated in order to determine whether source control
measures will expedite the treatment of the contaminated aquifer,
and to identify if another possible source of contamination
exists which may necessitate further-action. - -'
Enforcement Analysis .
Six Potentially Responsible Parties (PRPs) have been identified
to date. Three industrial facilities in the Olean area have
been identified as sources of volatile organic contamination
to the Olean Well Field: Alcas Cutlery, AVX Ceramics and
McGraw-Edison. Investigatory work was performed by each of
these companies at their respective facilities under Resource
Conservation and Recovery Act (RCRA) $3013 Consent Orders.
The results of those studies indicate soil and groundwater
contamination at each of the facilties (See Table 3).
Notice Letters have been issued to each of these companies
and, in addition, to Cooper Industries, present majority stock
holder of McGraw-Edison, and Aluminum Company of America (Alcoa)
and W.R. Case Cutlery,and Sons, owners of Alcas during the
period of disposal at the Alcas facility.
EPA has initiated negotiations with the PRPs. While the PRPs
have not rejected EPA's invitation to design and implement"*
recommended alternative, disagreement among the PRPs over
apportionment appear to be impairing the settlement process.
In July 1985, EPA imposed a September 15 deadline for PRPs to
commit to implementation of the recommended alternative. This
deadline has passed without a substantial offer from the PRPs.
EPA will consider issuing an order under Section 106 of CERCLA
directing the PRPs to perform all activities set forth in
the Record of Decision.
-------
Community Relations
The media and local officials have shown interest in the
site. A Citizen's Advisory Committee (CAC) was established
in April 1984 to serve as a link between the community and the
NYSDEC and USEPA during the RI/FS process.
The CAC was concerned about the prospect that the responsible
parties, i.e. local industry, would eventually have to pay
for the remedial measures. The CAC generally has expressed
interest in limiting government expenditures in Olean so as
to relieve the potential burden on industry, apparently
fearing loss of jobs and tax base. Further, the recommended
alternative necessitates cooperation between the City and
the Town of Olean. While this in not an impossible task, it
does raise some institutional issues among the local governments.
Specific concerns raised during the vpublic*comment ^period
-------
OPERATION & MAINTENANCE (O&M)
Activities
Public (or City) Water Supply
* Bimonthly influent/effluent analysis for VOCs.
" Daily equipment flow, pressure, temperature logging,
and general equipment observation.
* Annual fan and pump maintenance inspection as per
manufacturers' instructions.
Private (or Town) Water Supply
" Maintenance and miscellaneous repairs to water line. ,
as necessary. .>.*
* Monitor selected unfiltered private wells in Zone 3.
•
Ground Water Control
* Quarterly monitoring and maintenance of monitoring wells.
Reporting
* Bimonthly consolidation and reporting of sampling
data (public, private & monitoring wells).
Future Actions
f
* Operate and maintain ground water treatment systems
year round.
-------
SCHEDULE
Approve Remedial Action 9/85
Initiate Negotiations with PRPS 7/85
I I
NEGOTIATIONS ." " -., - .^ /^ ^ .^: NEGOTIATIONS &
SUCCESSFOL ; ' UNSUCCESSFUL**
Sign Consent 106 AO Amend Cooperative 9/85
Agreement^
Select Contractor 12/85
Design initiated * Negotiate Contract 2/86
Approve Contract 8/86
Construction * Complete Design of 12/86
Initiated Recommended Alt.
w/ Plans & Specs.
Construction * Construction . 4/87
Completed Initiated
. - Construction 12/87
Completed
* Depends upon outcome of negotiations.
** This schedule assumes the availability of funds in September, 1985.
-------
-------
-^ nUNJA,J.r«t. --
JfflUlfija I *^~
'landinR ano
• VMTMI Mftff* SMnCS WITH
SUIMtNT SMflfS
A tlklMHT UWPltS
Ml • MMTt mTIM SMfll
PLOT PLAN
OUan. N«w York
.S.«.l. 7.9
MT*> OI«M. NT 0*80)
fort. III*. MT
-------
TABLE 1A
or rmar-noow »mn,im MD IWM.YIU or
PD* CMBttCM, VMUMOmM
Aquifer Unit
M.V. State •«•
OroeedMter
Standard
Upper Aquifer
Upper Aqultavd
Upper Portion of
Lover Aquifer
Nld-Portloe lover
Aquifer
Jofmt Portion of
Lover Aquifer
•ell
1.0.
/
CM-IA
CM-1*
CM-IS
CM-4A
CM-9A
CM-7A
8M-S
CM-IDS
CM-US
8M-I4
CM-ISA
CM-ISA
CM-11A
CM-IA
CM-7
CM-9A
CM-IDA
CM-1 2 A
CM-US
CN-19A
CM-17A
CM-1
CM-1
CM -4
CM-9
CM-9
CM-10
SM-II
CM-1 2
CM-1)
CM-IS
01-11
CM-10
CM-19
trlokloro-
othyl~e
10
29(2*)
24
j
S90OM)
•
230(290)
<2
<2
<2
160(190)
190
MOO
<2
<2
ss
410
19
<2
<2
<2
ethane
90 ' /
<2«4)
-------
TABLE IB
MOOITC 0V 8KOND-MUND MHfUm MO MM.YSM Of
ton CKJMICM.
•oil
Aval far Quit I.O.
M.T. Stata "OV
Standard ' /
Oppar Aquifer CM-IK
CM-10
CM-IS
CM-4K
CM-SK
CM-TK
SN-O
CN-100
cM-i as
SM-14
CM-ISA
CM-UK
Oppar Kqaltart CM-UK
Oppar Portion of CM-IK
lover Ktraifar CM-7
CM-*/K
CM-10K
CM-UK
CM- ITS
CN-m
Nid-rortlon bower
Koaifar CM-1TK
bower Portioa of CM-1
. bower Kqaifar CM-1
CM-4
CM-S
CM-*
CM-10
SM-11
cM-ta
CM-1 9
CM-IS
CM-1T
CM-IS
CM-10
TricMoro-
othrtaM
10
ao
IT
•
9SO
O
9TO
10
ta Dap*, of Health Milooa paraiMlbla eoneantration for indl
anaiyaaa ahowi in paranthaaaa.
a^^^bynthatle
in 4rinki»9 water.
-------
SUPPLEMENTAL GROUNDWA
CONTAMINATION DATA
Concentrations of TCE Found In Lower Aquifer1,,"
- ..... -
MEC C-2
700
3200
«AVX-
180
-------
TABLE 2
CNMtCMi VMMRm OMA
ton MousnuM. mcitm IACKTIONS
tirf^trUl faattity 9*11 Iktneklete-
•y«ro«Mlo«ia Unit I.O. YriCftloratiirlMW •thTt«M
•thylww
athMw
Chlorite
NoOnv-MiM* 1 04-11 104-11 1
Ofp*r fcplf«r A-1 9900 1400 9.
C-1 190 740
Vppw MwlUH 0-1 9000 1000 9.
0-1 1400 9MO »•: •
•-1 39 <
1#nt Aq«tC4W M-l 900 1400 *'
M-9 17 »
H-l 910 MO
0-9 110 94
0-9 0400 1400
C-1 700 9100 11
0-9 70 70 <
1«
4.
-
*
14
t <
t 94 < «
1 10 99 4
94 < 71
< 4
< <
910 <
< <
9.9 <
< <
» 09 99 9!
1 19 « 4
t < < 4
1
(
I
1
t
I
t
17 tl
91 <
M r
<
<
99
<
9.9
<
140
111
*
r v
1 4
1 •!
0.
11
91
4
\ r
c i
i i
»
i
r 4.
i
i
9
4.
1.
9.
4<
4
.
•
-
•
-
-
•
-
_
-
•
•
M*
HI/MI
«fittar«
9
1
9
110
100
14
1100
990
in
Ilt/Mt
Uww Mq«l(«r
0-1
0-9
0-9
1190110001
t-l Indicate data not
IW) tnftleato* tr«o»
••film** Mly*** •toovn In pMwUMMO*
•11 «•!••• «n 1« p«rt*-pwMlllo«.
OMK«N or Datai U»l«r/QtWM4v«t«r
O«r*|1itf 4 Nlll4Kf tM.t
tcoloqy and
"4
loglo
•t th» Nearaw-MUoti
i, 1909,
ln*«Mtl
-------
TABLE 2 (cont'd)
RBOLTC Of IMWSmiM. Bin SOIL COtmMtHWrtON TtSTtWJ
{•11 raloaa In parta-par-billion, axeapt *iara Indicated)
IMwtrUl
•it*
Ittracnloro-
atnylana
Trana-
l.a-dlchloro-
1,1,1-trlehloro- 1,a-41chloro- 1,1-dicMoro- Ntthylana
athana •than* athana Ct lorlda Tolaana
fclcaa*
-------
TABLE 2 (cont'd)
RRULTC OP nMMrmtM. «m ton. eammvntnm
fall valnaa in parta-par-bllllon, axeapt vhara
(Contlraad)
Trane-
InflMtrlal Tttravhtoro- 1,l-4lehloro- 1,1,1-trlehloro- 1,l-41chloro- 1,1-4leMoro- fttthylana
•Ito Id othylona othylona athana othana othana Clilorloa loloana
••-79 1 49 « 3* « <
s
10
IS
m-oo i
10
IS 1401
9
10
IS
tt-0! 1
s
10
IS < 401
•049 1 <
S «
10 900
IS 400
M-M 1 MOOppai «OM
S ISOppa 2901
10 1400
•0-05 1 <
S <
10 <
M-W 1 COO «
S STOO
10 COO
01-07 1 0.9
S <
10 <
.
<
< <
45000 4*00
4400 900 900C
< <
< <
< •
<
1*00 900
1COO
<
97
<
<
901
•S4 <
4.
0.
C.
0.
140
<
C
<
•Mpp* S90
72ppo 1900
700
< <
< <
< «
110 ISO 4400
< <
< <
< . 17
£ 4
^ % *
* *
Laboratory analyala of • Ooll Oorla« oJMptaa fro* Meaa-Bl attovod eoneontratlona of tWC'a laaa than 100
UM of aaapllnf Indleatad *OC oontavlaatlon (10 to 20 ppa, aa Maaorad by OVn in air) In vppar fi«o faat of aoll
• of Data i lAsior/Oromdratar JkcMeiataa, Byatoaoeloalo lnt>aatlgatlon at tha MeOraw-Mlaon
facility. •oMBtut 10, 1M4.
Oaraahty a Millar. Ino., Hydrooaoleqlo Iiwaatlqatloo at tha Kn. Facility, January 19,
Keoloay and ftnrlrunaaat. Inc., Bydroa^oloqla In^aatia^^^at tha nteaa Catlary
facility. January 10, 19M.
air aeMmlnf of aoll at
-------
TABLE 3
HIGHEST LEVELS OF TCE CONTAMINATION
DETECTED AT CLEAN INDUSTRIAL SITES
SOIL GROUND WATER
McGRAW-EDISON 2,400 ppm 6,400 ppb
AVX 250 ppb 15,000 ppb
ALCAS CUTLERY 10-20 ppm 12,000 ppb
(OVA readings)
-------
1.
I.
TABLE AA
tMnmricwnoM MD WBLWIUMT SCKKBUNQ or nomiu. MOTION nn
re* route mrai iur*tiis
Alternative
No. Description
Bavtrawantal
Coat Inpact
tnglnaerlaaj Jot 9»ai
Public Health Regulatory
Rlak Compliance Technology Coaatanta
it
Retain
Option
No actlon/contlnoe
operation of
aurface watar
treatment plant
No action/
reactivate walla
without traatnant
of
Purchaaa •ilittnq
wella bayond
contavlnatad araa
Cona tract raplaca-
•ent aurfaea watar
o «lqh oparatlon and Kalatam noa coat a
o Sarfaea watar auacaptlbla 'o ahort-
tara pollatlon
e Mllabllltr of plant «ncar-«la {not
a lono;-tani aolotlon)
o Dlacharovj of alu* altto^a t» Olaan
Craak la an an
-------
TA
IDOmriCATtON MO POKLININMIT ftCRMMIHG OP
BMW
ACTION ALTERMATlVn FOR PRIVim WILLS
Alternative
No. Description Coat
1. No action 9
a. Continue a
monitoring. In-
stallation and
maintenance of
carbon adsorption
units aa required
3. Install carbon a
adsorption unite
on all valla in
Cone 1 and con-
tinue to monitor
• and replace carbon
vhen detectable
levela ere found
4. lxtend vater tin* 3
from City limit*
to Dugan Road and
tie into City of
Oleen vater supply
network (SO hookup*)
9. eitend vater line 3
from City Halts to
Kartell Road and
tie into City of
Olean vater supply
network (91 hookups)
6. Develop public vater 1
supply for resident*
end buat nesses In
Impacted erea In
Town of Oleen,
Including eourca end
distribution network
V. Kottled drinking a
water
^"^^ engineering Judgment
environmental Mbllc Health Regulatory Reteln
Impact Rlak Compliance Technology Comment* Option
a t t 3 o No coat alternative HO
o Drinking water quality not acceptable by
current regulations and guidance
o Potential health rlak due to consumption
and inhalation during hot water uaaga
a a 3 a o High, long-term analytical and maintenance Tea
costs
o Difficult to pradlet tie* to breakthrough.
because of varying eonceritrationa
e Drinking water quality acceptable
by current regulation* and guidance
a . a 3 a o High, long-term analytical and malnte- Tee
nance coats
' % „ e Difficult to pradlet time, to breakthrough.
because of varying concentration*
o Drinking water quality acceptable
by currant regulation* and guidance
a 3 3 3 o Low coat alternative Tea
o Eliminate* sampling and analytical
requirements for approximately 90
private valla
o Drinking vater quality acceptable by
currant regulations and guidance
a 3 33o Lev coat alternative Tea
o eliminate* sampling and analytical
requirement* for approximately 93
private valla
o Drinking vatar quality acceptable by
current regulation* and guidance
a 3 3 3^0 Water from vall(e) in impacted area will HO
require treatment
o eliminates sampling and analytical
requirements for private valla •
o Drinking vater quality acceptable by
currant regulations and guidance
] I 31o Minimises sampling and analytical Ho
requirements for private valla
o Drinking vater quality acceptable
current regulations and guidance
o rotentlal public health rlak, due
to Inhalation during hot vater usage
o Hot a long-term solution
teqendt I • unfavorable
a • fair
3 • favorable
-------
TABLE AC
toormtcNTtoN MD muNiNMT MUMMING or RBWDIM. NCTIQH M.TSMWTIVBI FOR eROWMwrt* CONTAMINATION COMTROI,
Alternative
Description
OMt
rubllo
Naelth Environmental
Milk Impact
ttoauUtory
Compliance
Engineer Ine Jeiaamant
Retain
Option
1 No Action 3 •» ' '
* Nail tor lint/Sit* Maintenance » 31 >
3 Delineation of Soareee 3 .3 > »
t a
3 «
e
o
3 a
o
Unacceptable riake to traawi health and envi-
ronment, and enfavorable riqvUtory ooapllanee
Contlmie •onttorlne extant of eontaalnatlon
Deterloratlne eroona»ater |aallty trlqeera
Contaalnatlon Source Inveatl^atlon and aub-
aeqttent tovree control tot Ion
No active reaponae to eootsea or eontaelnated
^roundwater
Define eontaalnatloft aoarcea
trovlde InforMtlon neeeeaary for aoorce eontrol
No
Tee
Tea
Contamination Soarce Oontroli
4 Removal and Dlapoaal of
ContMlnated Soil
S Treatment of Contamlt
Soil
ft Contamination Soarce
Containment
o Removal of highly-contaminated aoll* and
realdeal waato material to eoenre landfill
• bono-tera aoltttlon to alto contamination
o Coat dependent open extent of contamination
eoarce clean-«p
o some rlek eeeoeleted with tranaportatlon
and dlapoeal
« option not retained due to Inadequate eource
charaeterltatlon
« In-elto or om-alte aoll deeontamlnatlon
o Biological, phyeleoehemlcal, end thermal
proceaaea for aoll treatment ere developing
technoloalee
o Mould require extenalve teatlnq prior to uae
o Containment employing capping and leaehate
collection to laolate aourcea
o failure of eontelnment reneva eontamlnatlon
haiard
O Option not retolned due to Inadequate aoorce
eharacterlaatlon
No
NO
-------
iDRNTiPtCATii
Alternative
Wo. Description
7 Repair/Replacement of beaky
Indoetrlal Sewer
Oroundvater Rehabilitation
of Contaminated
Oroundwater
TABLE ^^ffit'd)
DM AMU PMLININMI SCRRRNINU OP RCMRuiA^^^^^pALTERNATlVRS POM CMUHMATBl CONTAMINATION CUNTMOL
Public tMlnmerinf MQMMt
Health environmental Keovlatory
Coat Technology Klak Impact Compliance Commenta
191 I 3 o Eliminate eondalt for contamination mtqratton
o Repair or replacement depend i upon decree of
damaoe euetalned by pipeline
J 3 3 1 3 o Retract and decontaminate graandvater,
removing VOC contaminant* from aquifer*
e long-term operation and maintenance commitment
o Rf feetlveneee dependent upon dlecontlnuetlon
of aronndvater contamination eource*
Retain
Option
Tec
Tea
1 • Favorablei I - Palri 1 » Onfavorablei HK • Hot Applicable.
-------
•flPMMV Of PMBPIPMD IHMID1
TABLE 5A
IKL
POM CITT VKTM tttfttit
MterMtioa
*».
Oeaorlptlo*
Coato
Rejvlatory
Aeeepubiutr
ftivt
tat ti
•1
Valoa (II Coat If/yrt
••tor Treatment »U«t
9 Treatoont of OoBteBlMtoi
o Mr
o co^lMd Mr
•n4 Metlvatad CarbMi
MwrptloH
ftooeptable
o Oroonjdwator coojton)liia%loii
•till • problem.. Mo«ld
reqalro other action* for
ion of
14,170,000 1.9>f,000
•robably
kooaptcbl*
o Hilt oontribvto to
o Ito •£«•*•• iapaota «i air
or mrfaoo ««t«r
rcotablf
Aoeoptabto
o Mil oontrlbato to
«rat«r roMOdlatto*
o Ho •o'voroo lopaeta oa air
or Mrtaoa «at«r
IkiMptablo
o Hill cnntrltato to
«Mtor ro»*dlattaii
o No •o'voroo iMpaoto o» air
or mr(*eo water qwalitf
13.400,000 1,410,000
• RopUeraMt plant *or*
rolUblo thm •«Utln«
plant. Watar co«W ba
•aoa amllablo to waara
of private Hollo
• Mobaot «**nll ooot
0,9*0,000 MO.OOO •
tratad taehnolooy
o Hill eontrlbota to
vronndvatar ravadlatlcM
• bomat capital ooot
• toaat ooatly oltamatlva
overall
• Vllot teotlno roojolroA
prior .to daaloii and eon-
•troetloH to eonflraj VOC
la
tl,SM,000 1,4)0,000 •
tratad tadmoloov
e Mill eontrlbata to
tromoVatar rahablllta-
tlon
• Hlqhar capital and OM
eoata than air atrlpplno
• Hlot taatlnf required
prior to deelen and con-
atrootloti to conflro VOC
la
• Deoonatrated teetMoloey
o Dill eontrlbMte to
froanoVatar rehabilita-
tion
o Higher capital and lower
OaN eoata than carbon
alone
o Pilot teatlito. required
prior to daalon and eon-
atnictlon to conflro VOC
reoovala
-------
(cont'd)
RflFHMBD RMd^^^^lrBtMTIVn UHl CtTff WMBI
MteffMtlV* OMt*
Iptiw Korapubilltr fciHraMinUI tapMta Vkiw (II Coct 19/tv)
• CMwtraet «m Mil* «otwrtabl« • OroMflMter e(MtMlMtl
-------
MNNMtf or rMnmiBD P.ONB>IM. KLmmiknva POM purnn wttu
mo.
Mtornatlvo
OaaartptlaM
COOto
fteeaptablllty InvtranoMtot topaoto
loo III OMt (J/frl
Comttnoa Nonltorlnf. faotolU-
tlan art MalntoOMoo of
Carbon Moorptloo Old to M
•oaoirod
tMtotl TTMtMHt tfi
•11 •*!!• !• •<*• I
OMti
Ion Onlto OB Hoaptnfl
Probably o «o
1.419.000 IM.OOO
rrotably
Ull
lona-taro •
and oalntonaneo eoato
• Orlnklnf vatar a>*allty
•anarally acoaptabla, tot
. potantlal Cor ahort-tarn
•ro to VOC'a
1.C91.000 Ml .000 • •l«h
•nalytleal
ooto
• Orlnklnf vatar ajaallty
oanarally aecaptabla, tat
potanttal for abort-tarn
OMDOMM to *OC'a atlata
Uvlto to rM«aM Ioa4 and TU
Into City off Olaa* Matar
Hatwork (W •ookvptl
Eitend Hater Line Preai City
Liaita to Haskell Road and
to 3 hoses south of the
River and tie into City of
Olean Mater Supply Network
(93 Hookups).
Probably
ftooaptabl*
lapaota
•tot
I,411.000
m.
Probably
•ecaptabte
o Ito
iBpaota
•tol
962.000
101,950
• ftlahar capital eoat than
oonclMMa vaa) OK carbon
•daorptlon In lona I
• P-aducad lonv-tam analy-
tical and nalatananea
eoato
• Radoeajd Me* off abort-
tarn aipomra to «OC'«
• NloHar capital coat, tat
•Ignlfleantly lovar anal-
ytical and nalntananoa
eoato
o Beet protacta pablte
•gainst rlak of ahort- or
lon^-toro aipoavra to
VOC'O
-------
(cont'd)
09NMM Of MIPBIMD MMDlMi ULTBIIMflVKi VQR CITY
MtMMtif* OMt«
HO. OMOTlrtiM lUMMptebllity »ITir
-------
PRIVATE WELL ZONE DESIGNATIONS
met «•*.««. oio .1
0
FIGURE 4
-------
INDUSTRIAL SEWER AND
INDUSTRIAL SURFACE DISCHARGE
V: *v4SAMPLING LOCATIONS
MEC(EPA-STORET) !•
/« ,„ Boirow .\
'"• Pif\
•*/»
f- " * ••
.-' Landing Strip
' I
FIGURE 5
-------
TABLE 6
COST OF RECOMMENDED ALTERNATIVE
CAPITAL COST
(1985 Dollars)
OPERATION &
MAINTENANCE COST
(Annual expense)
CITY PUBLIC WATER SUPPLY
Reactivation of Municipal
Wells w/TCE Removal Equip.
TOWN PUBLIC WATER SUPPLY
Extend City water line
to 93 private Town wells
Monitor remaining private
Wells
1,245,400
656,380
$ 721,700!
27,200
5,2002
GROUND WATER CONTAMINATION
CONTROL
Inspect Industrial
Sewer
Permanent Easements on
Monitoring Wells
Additional field work and
Analyses (2nd operable unit)
15,000
80,000
500,000
36,9403
TOTAL
(w/o additional field work)
1,996,780
799,040
NOTES:
1. Additional 06M cost for TCE removal is $110,200. The City of Olean
is responsible for the remaining $611,500 which is their regular
maintenance cost.
2. Quarterly sampling of 10% of the wells in Zone 3 (North of areas
known to be contaminated).
3. Maintenance and monitoring of monitoring wells.
New York State Department of Environmental Conservation has agreed to
pay for 10% of the Capital costs for this project in addition to the
O&M costs ($799,040-$611,500«$179,540) after the first year.
-------
COMMUNITY RELATIONS RESPONSIVENESS SUMMARY
CLEAN WELL FIELD
INTRODUCTION
This responsiveness summary documents the concerns and issues
raised during remedial planning and the comment period.
CONCERNS RAISED PRIOR TO THE FEASIBILITY STUDY COMMENT PERIOD
A Citizen's Advisory Committee (CAC) was established in April
1984 to serve as a link between the community and the NYSDEC and
EPA during the RI/FS process. The CAC and the Mayor of Olean
generally have expressed interest in limiting government expenditures
in Olean so as to relieve the potential burden on industry, apparently
fearing loss of jobs and tax base. A representative of EPA or
NYSDEC was present at each of the seven CAC meetings to answer
questions and receive comments.
CONCERNS RAISED DURING THE COMMENT PERIOD
The public comment period began on May 24, 19,85. Letters were
sent to 250 residents, Town and City officials, a'nd the business
community located within the area of concern notifying them of the
public meeting, the locations of the three repositories holding the
RI/FS for public review and the closing date of the public comment
period. Simultaneously, the PRPs were forwarded the RI/FS report.
Shortly thereafter, local government officials and CAC members
requested additional time to review the RI/FS and present the
proposed alternative to their respective legislatures. EPA then
extended the public comment period to August 5, 1985.
A public meeting was held on June 24, 1985 at the Olean
Municipal Building to discuss the RI/FS report for the Olean Well
Field Site and to accept public comments. After introductions by
Paul Schafer, Chairman of the CAC, Richard Dana, Project Manager
for NYSDEC, and George Pavlou of EPA, Ernest Schroeder of Engineering-
Science (New York State's consultant for this project) gave his
presentation. Mr. Schroeder briefly described the hydrogeology
present at the site, the areas and types of contamination, each of
the remedial alternatives considered during the RI/FS and the
recommended alternative. A schedule for the design and construction
of the recommended alternative was also given.
Five residents offered questions or comments. Most of the
comments centered on the Town residents' concern that they would
have to pay high prices (or pay at all) for their water once they
are hooked up to the City water supply. At the present time they
don't pay any fees and they maintain their own well pumps. A fee
schedule for City water is an institutional problem to be worked
out by the City and the Town officials since the Operation & Main-
tenance (O&M) for TCE removal will not cover the regular costs
incurred by the City Water Department. The Town residents felt
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that they shouldn't have to pay for clean water as their private
wells were not contaminated through any fault of their own.
Another concern raised by the residents and previously
raised by the CAC is the risk to public health resulting from
trihalomethanes (THM) present in the treated water from the surface
water treatment plant vs. the risk from TCE present in the municipal
well water. It was explained to the residents that the level of
THM3 present in the City's drinking water is well below New York
State's and EPA's Standard of 100 ppb while the level of TCE present
in the municipal wells and private wells greatly exceeds the
Guidelines set forth by New York State and EPA. It was also
explained that THMs are a byproduct of chlorination and are to a
large degree controllable according to the level of chlorine
disinfection required. TCE, on the other hand, entered the ground
water through uncontrolled deposits, dispersing unevenly. Therefore,
the ground water may show greatly fluctuating levels of
contamination when extracted.
There was also concern that some private wells which would not
be connected to the public water suipply under the recommended
alternative might go dry when the municipal wells, are turned on.
This problem has in fact occurred in the past when all three
municipal wells were pumping. If reestablishment of the municipal
wells as a.source of water for the City does cause some private
wells to go dry, it would not present a new problem to private well
users. The possible reoccurence of an old problem should be settled
by City and Town governments as an institutional issue.
In addition to the comments received at the meeting, written
comments were received from the CAC, Cattaraugus County Department
of Health (CCDOH), AVX Ceramics Corp. and Cooper Industries .in
conjunction with McGraw-Edison. The following summarizes the
issues raised by those commenters.
All commenters stated that they believed the source control
analysis in the RI/FS. to be inadequate. Cooper Industries stated
"that the remedial investigation simply concentrated on three
industrial users and.diliberately chose to ignore the widespread
use and disposal of TCE". The Seneca Avenue Landfill, an oily
lagoon located on Mastel Ford property on East State Street, Clean
Clean All, a dry cleaner on East State Street, residential septic
tanks possibly cleaned with TCE, Clean Tile Company disposal sites,
the Butler and Andrews Street dump and the dumping area on Clean
Clean Steel, Sales and Service property northeast of McGraw-Edison
were identified by the PRPs as other possible sources of TCE
contamination. In addition, the respondents stated that the RCRA
S3013 data were not taken into consideration during the Remedial
Investigation.
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On the other hand, the PRPs stated that EPA's recommendation to
conduct an additional sampling program and further evaluate source
control measures is unnecessary and should not be considered unless
the air strippers on the municipal wells are ineffective.
EPA believes that identifying major sources and evaluating the
cost-effectiveness of source control measures, and, if necessary,
implementation of such measures, is a cost-effective approach for
addressing the issue of ground water contamination at this site.
Eliminating active sources and managing contaminant migration from
passive sources may effectively reduce future migration of contam-
inants away from these sources and into the ground water.
In order to evaluate the merits of source control measures at
the site, additional information is necessary. Suspected areas of
contamination should be examined further in order to confirm
whether or not these areas are sources of contamination. It is
also necessary to further delineate the fcnown sources of contamina-
tion. Therefore, EPA is recommending an additional investigatory
phase to address evaluation of source control measures. Work has
already commenced in an effort to identify any other possible
contributors to the TCE problem at the site. Information request
letters have been issued in order to determine other users and
potential sources of TCE contamination. The responses to those
requests are being evaluated. However, those responses appear not
to indicate further TCE use or disposal. In addition, sampling and
analysis has been performed on the contents of the lagoon at Mastel
Ford to determine if the lagoon is an active source of contamina-
tion. The analytical results indicate only minor concentrations
(14 ppb) of TCE (minor as compared to confirmed sources of TCE
contamination). Consequently, at this point in time, EPA has
targeted the industrial sites, as well as, the Seneca Avenue Land-
fill and Butler/Andrew Street Dump as the subject of the proposed
investigation. Additional areas may be included in the study once
EPA ascertains their potentiallity for contributing to the
contamination problem at the site.
«
A major issue raised by AVX was the validity of the ground
water model used by Dames & Moore, subcontractors to Engineering-
Science. They felt that the RI/FS relied too heavily on the results
of this modelling effort. Additionally, they objected to their
inability to evaluate the model due to D&M's claim that the model's
code is proprietary information. The intended use of a ground water
model at the Olean Well Field site was as a supplemental tool in
characterizing the ground water flow regime and the transport of TCE
in the study area. The results of the modelling effort were expected
to assist in the determination of potential sources of contamination
and in assessing the effectiveness of remedial measures.
; - "* Vii/x.
For the purpose of the EPA Record of Decision regarding this
site, source identification and evaluation of remedial alternatives
can be based entirely on interpretation of existing data (including
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the studies performed by Alcas, AVX, and McGraw-Edison pursuant
to Section 3013 of RCRA).
Furthermore, EPA recognizes that restricting the availability
of the data. used in the modelling study and access to the model
itself under a "business confidentiality claim" can severely limit
independent evaluation of the validity of the model and its
application.
Therefore, EPA has not relied on the results of the Dames &
Moore modelling study in recommending the remedial action or
identifying source areas. .
The use of the Pelmont Oil Company water wells in West Clean
to supplement the City's water supply was raised as an alternative.
AVX and CCDOH both commented that this alternative was not fully
investigated during the RI/FS. As stated in the RI/FS, the two .-.:>- ?..
Twentieth Street Felmont wells are too ^close to other sites in West
Olean contaminated with chromium and ammonia to be considered a
viable alternative. Other Felmont wells, adjacent to the Allegheny
River, were considered and also rejected since the Felmont Oil
Company indicated that it was not interested in spelling the wells,
but, rather, only the water produced by these wells. Felmont
proposed to initially grant a short-term lease of three years. EPA
believes that this does not constitute a reliable, long-term
solution to the problem at hand. This alternative also lacks a
plume management program.
The CAC still favors the possibility of using a purge well to
"quickly clean out" the aquifer. They state that "further study
for installing a purge well .... is warranted* and that "if the
consultant feels uncertain whether the benefits of enhanced ground
water rehabilitation justifies the additional expense, then perhaps
the consultant should undertake further study before closing the book
on this option". EPA agrees with this approach and therefore is
recommending a supplemental investigation which will more accurately
determine the amount of'TCE remaining in the soil and aquifers and
will then re-evaluate the cost-effectiveness. of using
' '
. .-
AVX raised several 'issues concerning the hydrologeology)i'a8
described in the draft RI/FS report prepared by NYS DEC's consultant.
Based on an evaluation of the available geologic data, EPA believes
that the geologic description in the draft RI/FS report should be
modified with respect to the area of the AVX facility and south of
the facility to the railroad tracks. The results of drilling
around the AVX facility, the topographic -character of the land, and
the water levels in wells in that area all suggest that the upper
aquifer as described in the draft report does not exist in this
area. The water table occurs in the till, which is close to the
surface in the region north of the railroad. However, EPA does not
consider this to be an aquifer because of its low permeability.
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EPA has considered what effect this modified version of the geology
might have .on the selection of a remedial action, and concludes
that the remedial action would not be influenced by these changes.
AVX also commented on the method used to measure water levels
and the water level (potentiometric) contour maps constructed
from this data and presented in the draft RI/FS report. EPA has
constructed a set of water level (potentiometric) contour maps of
the area using steel tape water level measurements during stressed
aquifer conditions (pumping of the municipal wells 18M and 37M) and
non-stressed conditions (current site status, municipal wells in
area of concern not pumping). Although these contour maps do differ
from those presented in the draft report, EPA has evaluated the
consequence of these differences on the selected remedy and finds
them to be negligible. It is evident from pumping tests performed ..
by both EPA and COM that ground water .flow from almost the entire
study area will be directed towards the municipal wells when they
are reactivated. The exception to this trend will -be in the
immediate vicinity of small pumping well centers^(AVX, McGraw-
Edison, Clean Wholesale), r.A computer modelling study of
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