United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R02-89/082
September 1989
&EPA
Superfund
Record of Decision:
Port Washington Landfill, NY
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50272-101
REPORT DOCUMENTATION
PAGE
1. REPORT NO.
EPA/ROD/R02-89/082
3. Recipient's Accession No.
4. Title and Subtitle
RECORD OF DECISION
Washington Landfill, NY
Remedial Action - Final
5. Report Date
09/30/89
7. Author(s)
3. Performing Organization Rept No.
9. Performing Orgalnization Name and Address
10. Pro jecVTask/Wof k Unit No.
11. Contr»ct(C) or Grant(G) No.
(C)
12. Sponsoring Organization Name and Address
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
13. Type of Report ft Period Covered
800/000
14.
15. Supplementary Notes
16. Abstract (Limit: 200 words)
The Port Washington Landfill site is on the eastern portion of Manhasset Neck, Nassau
County, Long Island, New York. The 139-acre municipally owned site consists of two
landfilled areas separated by a vacant area. This Record of Decision addresses the
53-acre inactive landfill on the western portion of the site, which is the suspected
source of methane gas thought to cause furnace explosions in residences neighboring the.
during 1979 through 1981. From 1974 to 1983 the landfill operator accepted
residue, residential and commercial refuse, and construction rubble for
disposal. Because extensive air monitoring, performed in 1981, revealed high methane
levels in several areas residences, a venting system was installed to prevent subsurface
gases from migrating west of the landfill and to destroy hazardous chemicals commonly
detected in sanitary landfill gas. In 1981 the county also determined the presence of
VOC contaminants in a drinking water well onsite, which has since been removed from
service. The primary contaminants of concern affecting the soil and ground water are
VOCs including PCE, TCE, and benzene; and other organics including methane gas.
The selected remedial action for this site includes capping the landfill; rehabilitating
the existing gas collection system and installing additional vacuum extraction vents;
ground water pumping and treatment using a metals removal process and air stripping
NY
17. Document Analysis a. Descriptors
Record of Decision - Port Washington Landfill,
First Remedial Action - Final
Contaminated Media: soil, gw
Key Contaminants: VOCs (PCE, TCE, benzene), methane
b. Identifiers/Open-Ended Terms
P
c. COSAT1 Reid/Group
Availability Statement
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136
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EPA/ROD/R02-89/082
Port Washington Landfill, NY
First Remedial Action - Final
Abstract (Continued)
followed by discharge to an aquifer recharge basin; and environmental monitoring using
ground water and landfill gas wells. The estimated present worth cost for this remedial
action is $42,580,000, which includes a present worth O&M cost of $16,247,000 for 30
year's.
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DECLARATION 7OR TEE RECORD 07 DECISION
Port Washington Landfill
SITE NAME AND LOCATION
Port Washington Landfill
Port Washington, Nassau County, New York
STATEMENT OF BASIS AND .PURPOSE
This decision document presents the selected remedial action for
the Port Washington Landfill site (L-4) , developed in accordance
with the Comprehensive Environmental Response, Compensation, and
Liability Act, as amended by the Superfund Amendments and
Reauthorization Act and, to the extent applicable, the National
Contingency Plan. This decision is based on the administrative
record for this site. The attached index identifies the items
that comprise the administrative record.
The State of New York concurs on the selected remedy.
OF THE BITE
Actual or threatened releases of hazardous substances from this
site, if not addressed by implementing the response action
selected. in this Record of Decision (ROD), may present an
imminent and substantial endangerment to public health, welfare,
or the environment.
DESCRIPTION OF THE REMEDY
The major components of the selected remedy include:
•
* Closure of L-4 in accordance with the 6 NYCRR Part 360
requirements for New York State sanitary landfills;
* Rehabilitation of the existing active gas venting system;
* Extension of the existing active gas venting system around
the entire perimeter of L-4;
* Addition of a second gas combustion unit as standby; .
* Placement of extraction wells in the Upper Glacial Aquifer
in areas with elevated levels of groundwater
contamination;
* Treatment of extracted groundwater from the Upper Glacial
Aquifer through metals removal and air stripping prior to
discharge to an aquifer recharge -basin;
* Treatment of groundwater at the Southport Well through air
stripping should the Port Washington Water District decide
to use the Southport Well as potable water;
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* Installation of groundwater monitoring wells to further
define the extent of the L-4 leachate and VOC plumes, as
well as to refine the placement of the proposed extraction
wells;
* Installation of additional groundwater and landfill gas
wells around L-4 to be used in conjunction with the
existing landfill gas and groundwater monitoring network
in order to comprehensively monitor L-4;
* Development and conduct of a comprehensive monitoring
plan for L-4, including performance monitoring of the
gas venting system; and
* Development and conduct of an operation and maintenance plan
which will govern those remedial actions selected in this
ROD as well as those presently employed for L-4.
DECLARATION
The selected remedy is protective of human health and the
environment, complies with Federal and State requirements that are
legally applicable or relevant and appropriate to the remedial
action, and is cost-effective. This remedy utilizes permanent
solutions and alternative treatment technologies to the maximum
extent practicable. However, because treatment of the principal
threats of the site was not found to be practicable, this remedy
dots not satisfy the statutory preference for treatment as a
principal element of the remedy. The size of the landfill and the
fact that there are no on-site hot spots that represent the major
sources of contamination preclude a remedy in which contaminants
could be excavated and treated effectively.
Because this remedy will result in hazardous substances remaining
on-site above health-based levels, a review will be conducted no
later than five years after commencement of the remedial action to
ensure that the remedy continues to provide adequate protection of
human health and the environment.
William J. M/szyAskj^P.E. Date/
Acting Regional Ac
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Decision Summary
PORT WASHINGTON LANDFILL
PORT WASHINGTON, NEW YORK
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION II
NEW YORK
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TABLE OF CONTENTS
Section Pag*
SITE MAKE, LOCATION AND DESCRIPTION 1
SITE HISTORY AND ENFORCEMENT ACTIVITIES 2
HIGHLIGHTS OF COMMUNITY PARTICIPATION 4
SCOPE AND ROLE OF OPERABLE UNIT 5
SUMMARY OF SITE CHARACTERISTICS 5
SUMMARY OF SITE RISKS 8
DESCRIPTION OF ALTERNATIVES 11
SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES.. 13
SELECTED REMEDY 20
STATUTORY DETERMINATIONS 24
DOCUMENTATION OF SIGNIFICANT CHANGES 27
ATTACHMENTS
APPENDIX 1 - TABLES
APPENDIX 2 - FIGURES
APPENDIX 3 - ADMINISTRATIVE RECORD INDEX
APPENDIX 4 - NYSDBC LETTER OF CONCURRENCE
APPENDIX 5 - RESPONSIVENESS SUMMARY
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BITE NAME. LOCATION. XKD DESCRIPTION
The Port Washington Landfill is located in the northwestern
portion of Nassau County, in Long Island, New York (figure 1).
It is situated on the eastern portion of Manhasset Neck,
approximately 5 miles east of the New York City line. The
entrance to the Landfill property is on West Shore Road. The
landfill is located on a 139 acre lot (figure 2), owned and
operated by the Town, of North Hempstead (hereinafter "the Town").
This property contains two landfilled areas separated by a vacant
area. The L-4 parcel, which has been the subject of EPA's
Superfund investigation, is a 53 acre inactive landfill on the
western portion of the property, while the L-5 parcel is an
active sanitary landfill on the eastern portion of the property.
The current land surface elevation at the L-4 landfill ranges
from approximately 50 feet above mean sea level (MSL) at its
eastern border to approximately 160 feet above MSL at the western
border. The topography west of the landfill varies from 150 to
200 feet above MSL.
Geological strata underlying the site are composed of
unconsolidated glacial gravel, sand, silt, and clay of
Pleistocene age (figures 3 and 4). Sediments below the
Pleistocene glacial deposits in the southern portion of Manhasset
Neck consist of marine and continental Cretaceous age clay, silt
and sand of the Magothy Formation. Underlying this is the
Raritan Formation. The Raritan is locally composed of two units,
an upper clay member and the lower Lloyd sand. The Raritan
Formation is underlain by lower Paleozoic and/or Precambrian
metamorphic bedrock. In the northern portion of Manhasset Neck
are the Port Washington Confining Unit and the Port Washington
Aquifer. This aquifer is underlain by bedrock.
The regional hydrogeology of Manhasset Neck is centered around
alternating layers of aquifers. Beneath the L-4 site, the Upper
Glacial Aquifer is the uppermost water bearing zone. The Magothy
Aquifer immediately underlies the Upper Glacial Aquifer, with the
Lloyd Aquifer separated from the Magothy by the Raritan Clay
formation. All of these aquifers are used locally for public
water supply. The Upper Glacial Aquifer generally flows from
west to east in the general area of the landfill as it carries
water from the crown of Manhasset Neck to Hempstead Harbor.
Underneath L-4, this flow regime takes on a localized northern
bend before discharging to the Harbor. The Magothy Aquifer,
which has similar flow characteristics, also discharges into
Hempstead Harbor. The Lloyd Aquifer is insulated from the Harbor
by the Raritan Clay so that waters contained in this unit can
migrate beneath Hempstead Harbor.
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Area potable water wells include the Southport well (Magothy
Aquifer), located 1300 feet west and hydraulically upgradient
fromthe L-4 part of the landfill; the Stonytown well (Lloyd
Aquifer), located 3000 feet southwest and hydraulically
upgradient from L-4; the Hewlett well (Magothy Aquifer), located
3000 feet south and hydraulically upgradient of L-4; and the two
Bar Beach wells (Upper Glacial Aquifer), located 4000 feet north
and possibly hydraulically downgradient of L-4 (figure 5).
SITE HISTORY AMD ENFORCEMENT ACTIVITIES
Prior to the Town's purchase of the landfill property in 1973,
the site area was used as a sand and gravel mining operation that
began in the 1880's. After the mining operation had terminated,
and prior to development by the Town, the area was used by the
All-American Sand and Gravel Corporation as a landfill for
construction debris, such as concrete, wood, and miscellaneous
solid wastes-
The initial design of the landfill (L-4) called for placement of
a 20 mil polyvinyl chloride (PVC) liner between the refuse and
the native soil. Landfilling at L-4 began in March, 1974 with
the disposal of incinerator residue, residential and commercial
refuse, and construction rubble. As landfilling progressed, a
layer of clay was placed between refuse deposited along the
western edge of the landfill and the existing steep gradient of
native soil. A leachate control system was added in March, 1976.
In June, 1977, the Nassau County Department of Health (NCDH)
tested groundwater monitoring wells at the landfill. The
analysis indicated the presence of organic and inorganic
contaminants.
During the winters of 1979, 1980 and 1981, furnace explosions
occurred in homes to the immediate west of the landfill. In
1981, extensive air monitoring was performed in the area by the
Nassau County Fire Commission. This monitoring demonstrated
excessive methane levels in several area residences. As a
result, remedial measures were initiated by the Town to prevent
the uncontrolled migration of subsurface gases to the vest of the
landfill, utilizing a system which employs both active and
passive venting of landfill gases (figure 6). This system was
designed to collect actively vented gases and to flare them in a
horizontal combustion unit (HCU) in order to destroy the
hazardous chemicals commonly detected in sanitary landfill gas.
Also, in 1981, the NCDH tested for and discovered volatile
organic contaminants, primarily chlorinated hydrocarbons, in the
Southport well. This well had previously been a source of
drinking water in the Port Washington Water District. As a
result of the NCDH findings, the well was eventually removed from
service as a potable water supply.
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In September, 1983, the site was given final status on EPA's
National Priorities List (NPL) primarily because of the
contamination of the Southport well.
The Town stopped accepting waste at L-4 in 1983. Since then, the
Town has continued to monitor the landfill's immediate
environment, especially to the west of L-4, for both methane and
hazardous chemicals.
As a result of the site's placement on the NPL, the New York
State Department of Environmental Conservation (DEC) assumed the
lead agency role in enforcement negotiations with the Town, which
was the only potentially responsible party identified at that
time. In February, 1984, the DEC requested that EPA assume the
lead role in enforcement negotiations with the Town. These
negotiations eventually led to EPA's development of a workplan in
October, 1985, to conduct a remedial investigation (RI) and
feasibility study (FS) at L-4. EPA then issued notice of
potential liability to the Town, and indicated that as a
potentially responsible party (PRP) the Town could either conduct
the work which was described in the workplan or EPA would do so
using funding provided through the Comprehensive Environmental
Response, Compensation, and Liability Act (CERCLA). In December,
1985, the Town indicated to EPA that it had elected not to
perform the specified work, although it still wished to remain
active during the RI/FS process.
EPA's field investigation was initiated in December, 1986 (after
the delayed passage of the Superfund Amendments and
Reauthorization Act (SARA)) and included: the installation of 11
groundwater monitoring wells (figure 7), 4 landfill gas
monitoring wells (figure 8), 5 landfill gas pressure monitoring
wells; and deployment of an on-site meteorological station.
These actions were intended to complement the existing network of
water and gas monitoring wells which had previously been
installed by the Town as part of the local effort to monitor L-4.
EPA then commenced a -one year monitoring program of the landfill
in which this network of wells was sampled on several occasions.
The surface of L-4 was also tested with special equipment in
order to estimate the amount of landfill gas being emitted from
the surface of the fill (figure 9). The resulting data collected
during this investigation can be found in the remedial
investigation report prepared by EPA for this site.
EPA recently conducted a PRP search, and is in the process of
sending letters notifying several other PRP's of their potential
liability under CERCLA, including some who apparently generated
or transported hazardous wastes/substances to L-4.
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HIGHLIGHTS OF COMMUNITY PARTICIPATION
Public involvement and interest in this site has been significant
for the duration of the RI and FS. Some of the factors which
account for this are the proximity of the site to a large
residential area; the multiple exposure pathways by which
contaminants could theoretically migrate off-site; the ongoing
activities at the active portion (L-5) of the municipal landfill;
and the involvement of a well organized Citizens' Advisory
Committee (CAC), more formally known as the "Parties in
Interest", which already existed at the time EPA commenced
preparation of a draft vorkplan for this project.
The Town and the CAC were meeting on a regular basis on solid
waste issues when EPA began preparation of the draft workplan.
EPA developed a Community Relations Plan which adopted and
expanded this forum to include the discussion of issues pertinent
to the RI and FS being conducted at L-4, such as the release and
migration of hazardous substances from L-4. During EPA's
performance of the RI and FS, numerous meetings were held
pursuant to this plan to solicit suggestions, encourage
information exchange, and review project status with the Town and
the CAC.
In addition to the Town/CAC meetings, personal interviews were
conducted by EPA contractors to ascertain relevant issues and
concerns among the interested public; and several workshops were
sponsored by EPA during the RI and FS for the purpose of
demonstrating well drilling technology, the methodology of health
risk assessment, and the techniques of groundwater and subsurface
gas modelling.
After completion of the RI and FS, EPA prepared a proposed plan
which was based on the information and analysis contained in the
RI/FS. EPA also formally announced the start of a one month
public comment period on the report and proposed plan commencing
on July 21, 1989. At that time, EPA ensured placement of copies
of the RI and FS and the proposed plan in two information
repositories, i.e., Town Hall of North Hempstead, and the Port
Washington Public Library* Individual copies of the RI/FS and
proposed plan were also sent to CAC members that have
demonstrated a significant interest in the project, as well as to
the Town and relevant public agencies. Copies of the proposed
plan were also distributed to the entire sailing list of various
parties who have at some time expressed an interest in this
project.
A public meeting was held by EPA on August 9, 1989 to formally
present the findings of the RI and FS and the details of the
proposed plan. Questions and comments were also formally
recorded so that they could be addressed in a responsiveness
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summary which is incorporated herein as Appendix 5. EPA honored
requests to extend the comment period by 30 days through
September 20, 1989 because of the large volume of information
contained in the RI and FS reports.
The administrative record for this site has been assembled and is
presently available for review at the Port Washington Public
Library. It will also be available at the Town Hall of North
Hempstead. The decision for this site is based on the
information contained in the administrative record.
Due to the interrelated nature of the landfill gas and
groundwater contamination at this site, the proposed plan
addresses a comprehensive approach, i.e. one operable unit, to
remedial action at the site. In other words, this project has
not been segmented into smaller "operable units" or incremental
portions. EPA believed that although segmenting the project into
several operable units might possibly accelerate certain aspects
of the remedial effort, the possible relationship of landfill gas
migration to groundwater contamination suggested that one
operable unit was more likely to produce a remedial plan whose
elements would be consistent with each other. Based on the
results of future groundwater monitoring, particularly to the
north of the site, a second operable unit RI and FS may be
required to further address groundwater contaminant migration in
this area.
SUMMARY OF SITE CHARACTERISTICS
As a result of EPA's extensive RI at this site, the extent and
nature of contamination has been characterized in sufficient
detail to conduct a study of feasible remedial alternatives. The
following is a summary of this characterization.
Vapor phase volatile organics have been measured predominantly in
the low parts per billion (ppb), with a range of 1 to 692 ppb in
the unsaturated zone underneath both the North Hempstead Country
Club's golf course and area residences as far as 1,000 feet west
of L-4 (tables 3-20, 3-21, and 3-22 of the RI report). The most
prevalent compounds measured were trichloroethylene, 1,1,1-
trichloroethane, 1,1-dichloroethane, tetrachloroethylene,
chloroform, 1,1-dichloroethylene, vinyl chloride, benzene, and
carbon tetrachloride. It is hypothesized that these soil vapors
resulted from subsurface landfill gas migrations from L-4 to the
west (figure 3-7 of the RI report). In addition, high
concentrations of subsurface methane have been detected beyond
part of the southern boundary of the landfill in the unsaturated
zone beneath the Seaview Industrial Park. Significant
concentrations of subsurface methane have been detected on
occasion at the western landfill boundary; moreover, this
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condition appears to coincide with the periodic shut down of the
existing active venting system. EPA believes that all of these
measured methane migrations originate from L-4. It is currently
unknown whether methane or volatile organic compounds are
migrating to areas not monitored by subsurface gas wells to the
north and east of L-4. "
Vapor phase volatile organics emissions from the surface of L-4,
including open vents, were also measured (tables 3-13, 3-14, and
3-15 of the RI report). Compounds which were detected relatively
consistently were benzene, vinyl chloride, tetrachloroethylene,
and trans 1,2-dichloroethylene. The surface emissions from L-4
cover material were generally in the range of 1-50 ppb, while
other areas that might be described as gas conduits i.e.,
landfill cracks, open vents, etc. were generally in the 100-1000
ppb range. One location at a landfill fissure registered several
of these compounds in the low parts per million range during the
second sampling event. Offsite ambient air measurements
performed for seven target compounds during the remedial
investigation resulted in a few low concentration readings, which
EPA believes to have resulted from motor vehicle emissions.
Volatile organic groundwater contamination has been measured
generally in the range of 1 to 100 ppb in the Upper Glacial
Aquifer immediately west of L-4 (table 5-10 of the RI report).
This contamination is particularly concentrated in Town
monitoring wells 6, 9, and 10. The area of contamination is
within the zone of contribution to the Southport well (figure 5-
14 of the RI report). The most prevalent compounds include
trichloroethylene, tetrachloroethylene, 1,1,1-trichloroethane,
1,2-dichloroethane, 1,1-dichloroethylene, vinyl chloride and
chloroform. The full extent of this volatile organic
contamination is not presently known because of a lack of
monitoring wells to the north of L-4. The remedial investigation
has concluded that the naturally existing gradient in the Upper
Glacial Aquifer in the vicinity of L-4 would carry contaminants
in that direction, as well as downward through the aquifer.
m
Elevated concentrations of ammonia and Kjeldahl nitrogen were
detected in a veil northeast of L-4, indicating the presence of
leachate in the groundwater at that location. Although the
leachate does not appear to be contributing volatile organic
contamination to the groundwater northeast or east of L-4, the
conventional inorganic compounds released from L-4 will degrade
the quality of the groundwater. The full extent of the inorganic
leachate contamination is not known, since there are no
monitoring wells within its flowfield to the north.
There were also several isolated instances of hazardous
inorganics, such as lead and chromium in slight excess of maximum
contaminant levels in the L-4 area; however, these results have
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not been identified with any particular source and do not appear
to indicate any pattern of gross heavy metals contamination.
There are existing and potential human exposure pathways for the
contamination that have been documented during the remedial
investigation for this site. These pathways can theoretically
'.result in human exposure either through ingest ion, inhalation, or
dermal contact, and therefore the discussion of exposure pathways
will be generally organized within these categories of exposure.
There may also be environmental exposure pathways at this site.
The only potentially significant environmental receptor that has
been identified in the area is the flora and fauna of Hempstead
Harbor.
The exposure of human receptors via ingestion can occur through
drinking water from the Southport well and incidental ingestion
of soils. Ingestion of well water is only a risk under a future
use scenario at the present time, since the well has been out of
service on a permanent basis as a potable water supply since
1981. This risk has been calculated within the scenario of
returning the well to service without any additional remedial
action being taken at the site. The incidental ingestion of
contaminated soil from the landfill is also considered under a
future use scenario. Currently, the Landfill has- adequate
security to prevent those most likely to ingest soil i.e., young
children, from frequenting the property. This risk has been
calculated within the scenario of future residents living on the
L-4 cell.
The exposure of human receptors via inhalation can occur through
the inhalation of contaminants that become airborne from various
landfill sources, that migrate as constituents of landfill gas in
the unsaturated zone underground and eventually surface inside
enclosed structures, or that volatilize during the use of
contaminated potable water, particularly hot showers. The first
two of these exposure pathways are considered to be presently in
existence, while the shower inhalation pathway is dependent on
the theoretical return of the Southport well to service without
further remedial action. The various landfill sources that were
evaluated for airborne contamination were the surface of L-4,
open passive vents, the leachate pond, the HCU (with flare), and
the gravel filled trench which lies along the western boundary of
L-4.
The exposure of human receptors can occur through dermal contact
with contaminated soils on L-4. This exposure pathway was not
evaluated for workers at L-4, since the levels of chemicals of
concern detected in the L-4 surface soil were extremely minute.
However, this pathway was evaluated within the theoretical
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8
scenario of future residents living on L-4, since this scenario
presents a greater probability of frequent dermal exposure.
The exposure of environmental receptors in Hempstead Harbor can
occur through migration of contaminated groundwater into the
Harbor. However, both EPA and the natural resource trustee for
Hempstead Harbor i.e., the National Oceanic and Atmospheric
Administration, believe that the data collected during the
remedial investigation is insufficient to determine the possible
impacts or potential risks to Harbor flora and fauna. This
insufficiency of data again derives from the lack of groundwater
monitoring wells to the north of the site. There are presently
no habitats of federally endangered species designated in the
project study area.
Many of the chemicals of concern at this site are suspected human
carcinogens, based on animal studies. However, there are only
two compounds i.e., vinyl chloride and benzene, which are
classified as definite human carcinogens based on sufficient
evidence from human epidemiological studies. A complete list of
the chemicals of concern for the L-4 site is contained in table
1.
SUMMARY OP BITS RISKS
Cancer potency factors (CPFs) have been developed by EPA's
Carcinogenic Assessment Group for estimating excess lifetime
cancer risks associated with exposure to potentially carcinogenic
chemicals. CPFs, which are expressed in units of (mg/kg-day) "1,
are multiplied by the estimated intake of a potential carcinogen,
in mg/kg-day, to provide an upper bound estimate of the excess
lifetime'cancer risk associated with exposure at that intake
level. The term "upper bound" reflects the conservative estimate
of the risks calculated from the CPF. Use of this approach makes
the underestimation of the actual cancer risk highly unlikely.
Cancer potency factors are derived from the results of human
epidemiological studies or chronic animal bioassays to which
animal-to-human extrapolation and uncertainty factors have been
applied.
Reference doses (RfDs) have been developed by EPA for indicating
the potential for adverse health risks from exposure to chemicals
exhibiting non-carcinogenic effects. RfDs, which are expressed
in units of mg/kg-day, are estimates of lifetime daily exposure
levels for humans, including sensitive individuals. Estimated
intakes of chemicals from environmental media (e.g., the amount
of a chemical ingested from contaminated drinking water) can be
compared to the RfD. RfDs are derived from human epidemiological
studies or animal studies to which uncertainty factors have been
applied (e.g., to account for the use of animal data to predict
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effects on humans). These uncertainty factors help insure that
the RfDs will not underestimate the potential for adverse
noncarcinogenic effects to occur.
Risk characterization for the Port Washington Landfill site
included an assessment of risk associated with exposures to both
noncarcinogens and carcinogens.
Noncarcinogenic risks were assessed using a hazard index (HI)
computed from expected daily intake levels (subchronic and
chronic) and RfDs (representing acceptable intakes). Potential
concern for noncarcinogenic effects of a single contaminant in a
single medium is expressed as the hazard quotient (HQ). This is
the ratio of the estimated intake (derived from the contaminant
concentration in a given medium) to the contaminant's RfD. By
adding the HQs for all contaminants within a medium or across all
media to which a given population may reasonably be exposed, the
HI can be generated. The HI provides a useful reference point for
gauging the potential significance of multiple contaminant
exposures within a single medium or across media.
Potential carcinogenic risks were computed by multiplying chronic
(long-term) intake levels to a respective carcinogenic potency
factor. Excess lifetime cancer risks are probabilities that are
generally expressed in scientific notation (e.g., IxlO"6) . An
excess lifetime cancer risk of IxlO"6 indicates that, as a
plausible upper bound, an individual has a one in one million
chance of developing cancer as a result of site-related exposure
to a carcinogen over a 70-year lifetime under the specific
exposure conditions at a site.
The context within which to judge the relative risk from each of
the pathways has been established by EPA. For carcinogens, the
target risk range is 1x10 to 1x10 excess lifetime cancer risk.
For noncarcinogens, where the sum of expected dose/RfD ratios
exceeds one, observed concentrations pose unacceptable risks of
exposure.
The following is a summary of significant site risks based on the
endangerment assessment conducted as part of the Port Washington
Landfill remedial investigation. For a complete summary of all
risks calculated for this site, please see chapter 7
(Endangerment Assessment) of the RI report.
*Excess lifetime cancer risks associated with potential ingestion
of groundwater from the Southport well were estimated to exceed
10*6 (one occurrence in one million chances) for both the average
and plausible maximum exposure scenarios (2x10"* and 9xlO"5,
respectively). This assumes, however, that this well is reopened
for use and groundwater from the well is not combined with other
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10
wells prior to distribution. The risks were predominantly due to
ingestion of vinyl chloride, 1,1-dichloroethane, 1,1-
dichloroethylene, and tetrachloroethylene.
*Excess lifetime cancer risks from the potential inhalation of
volatile organics posed by showering with groundwater from the
Southport well exceed 10 for the plausible maximum case
(2xlO"5) . The risks were predominantly due to inhalation of 1,1-
dichloroethylene and vinyl chloride released from shower water.
The same caveats mentioned above are applicable to this exposure
pathway (e.g., assuming the well would be reopened).
*Under hypothetical future use conditions, excess lifetime cancer
risks due to ingestion of groundwater in the landfill site area
exceed 10"6 for both the average and plausible maximum cases
(7xlO"5 and 3xlO~5, respectively). This assumes, however, that a
new well is installed in the immediate landfill area and that
currently observed levels of contamination remain unchanged well
into the future. The average case risk is primarily due to
ingestion of arsenic, 1,1-dichloroethane, 1,1-dichloroethylene,
and vinyl chloride. The maximum case risk is primarily due to
ingestion of arsenic, benzene, 4,4'DDT, 1,1-dichloroethane, 1,1-
dichloroethylene, 1,3-dichloropropane, tetrachloroethylene,
trichloroethylene, and vinyl chloride.
*Excess lifetime cancer risks associated with inhalation of
volatile organics by residents in the sub-division immediately
west of L-4 exceed 10"6 for the plausible maximum case (5xlO*6) .
Exposures to volatile organics emitted from four separate sources
combined were evaluated for this pathway (HCU, leachate pond,
surface of L-4, and soil gas infiltration). The maximum case
risks are primarily due to inhalation of 1,1-dichloroethylene
present in infiltrating soil gas. There are many uncertainties,
however, associated with this risk estimate. For example, the
emission source primarily accounting for the estimated risk was
soil gas infiltration into the home. A complex emission and
indoor air model was used to predict air concentrations in the
home. There are uncertainties in both the models as well as in
the parameters used in them. In general, since conservative
assumptions were used to compensate for these uncertainties, the
risks are considered to be upper bound estimates.
*Under hypothetical future use for a residence at the L-4
landfill, lifetime excess cancer risks due to inhalation of
volatile organics slightly exceeded 10*6 for the plausible
maximum case only (2x10 ). Three emission sources were evaluated
for this pathway (HCU, leachate pond, and surface of L-4). The
risk is primarily due to inhalation of 1,1-dichloroethylene and
vinyl chloride emitted from the HCU and the surface of L-4. This
scenario conservatively assumes that a residence will be built on
L-4, although this is unlikely to occur. In addition, there are
many uncertainties associated with the emission and air
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11
dispersion models used to predict air exposure point
concentrations.
DESCRIPTION OF ALTERNATIVES
The FS alternatives developed for this project were intended to
control the source and manage the migration of contaminants
associated with the L-4 section of the Port Washington Landfill.
A "no action" alternative was also evaluated as required by
regulation, in order to provide an appropriate alternative in the
event that no contravention of standards nor significant health
or environmental risks were found to exist at the site.
Because of the size of the L-4 section and the ubiquitous
distribution of low levels of contaminants throughout the fill
material, alternatives for source control involving excavation
and/or treatment of the fill material were not considered
technically feasible and were dropped from further consideration.
Instead, EPA developed and evaluated several "containment11
alternatives for source control. Specifically, these
alternatives are strategies designed to reduce the off-site
migration of contaminants in both landfill gas and landfill
leachate through the use of containment technology.
EPA also developed and evaluated several alternatives to address
the management of contaminants which have already migrated away
from the L-4 section. These alternatives are strategies which
only address the migration of contaminated groundwater, since the
calculated health risks associated with the present off-site
levels of subsurface gas to the west of L-4 are within EPA's
range of acceptable risk.
Landfill gas migration to the south of L-4 (and possibly to the
north and east) is uncontrolled at the present time; however, EPA
believes that implementation of appropriate source controls as
described in the preferred alternative will effectively and
rapidly remedy this migration of landfill gas.
The preferred alternative will combine what EPA believes is the
most appropriate source control alternative with the most
appropriate Management of migration alternative.
The alternatives presented below are those which were evaluated
in detail following the preliminary screening of alternatives.
They have been indexed to correspond with the descriptions of
alternatives contained in the FS report.
Ho Action
In this alternative, no further source controls or management of
contaminant migration would be implemented beyond that which is
presently occurring. The Southport well, if returned to service,
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would be expected within a short period of time to produce water
which contravenes applicable drinking water standards; therefore,
the well could not be returned to service as a reliable supply of
potable water under this alternative. The Town's gas and
leachate collection systems would continue to operate in their
present mode and condition, and existing monitoring programs
would continue as presently implemented.
Source Control (table 2)
Q-2 ' ' ';'•' • • '
In this alternative, the L-4 section would be closed in
accordance with 6 NYCRR Part 360. The: main.feature of landfill
closure is the placement of a highly impermeable cap over the
landfill to reduce the infiltration of water into the fill. In
addition, the existing gas collection system would be
rehabilitated in order to return it to its design capability and
hence improve its operation and reliability. This rehabilitation
would include the rebuilding of the main gas header in the active
venting system, with elimination of existing low points in the
header where condensate presently collects and partially impedes
gas flow in the system.
a-3 •';••/•.'.-.'..
In this alternative, the L-4 section would be closed in
accordance with 6 NYCRR Part 360. The Town's existing gas
collection system would be rehabilitated, and additional active
(vacuum extraction) vents would be installed around the perimeter
of L-4. .These additional vents would be placed outside the fill
material and would be manifolded with an additional length of gas
collection header. This header would in turn be tied into the
existing blower station which is estimated to have sufficient
capacity to create the required pressure changes in the expanded
system. A new HCU would also be added as a standby unit.
0-4
In this alternative, the L-4 section would be closed in
accordance with 6 NYCRR Part 360. The Town's existing gas
collection system would be rehabilitated, and additional active
vents would be installed in perimeter areas of L-4, as detailed
in O-3 above. Moreover, additional active vents would be created
throughout the interior of the L-4 section through new vent
installations and conversion of existing "cistern" vents to the
active mode, and the existing leachate underdrain system would be
modified to also collect landfill gas. The vent risers installed
as part of the landfill cap would also be connected to the gas
collection system. A second HCU would also be added to handle
the increased gas collection in this alternative.
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Management of Migration (table 31
W-2
In this alternative, water from the Southport well would be
returned to distribution as potable water using air stripping
technology to remove volatile organic contaminants. The need for
treatment of air emissions from the air stripper would be
evaluated during the design phase. In addition, a comprehensive
program of landfill gas and groundwater monitoring would be
implemented in order to effectively monitor offsite migration of
hazardous chemicals, as well as to fully characterize the
groundwater quality and hydrology in the area to the north of L-
4.
W-3
In this alternative, which would also include the comprehensive
program of environmental monitoring, the Southport well would be
returned to distribution as a potable water supply with air
stripping technology to remove VOCs (with possible treatment of
air emissions, if required), and additional extraction wells
would be installed in the area of elevated organic contamination
(to the immediate northwest of L-4). The extracted groundwater
would require air stripping to remove VOCs, and possibly an
additional treatment step for metals removal, depending on the
method of discharge (and the associated regulatory requirements)
for the extracted and treated effluent. The treated effluent
would be discharged either: a) to a recharge basin in the
vicinity of the landfill; or b) to Hempstead Harbor.
SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
This section provides a glossary of the nine criteria and an
analysis, with respect to these criteria, of all of the
alternatives under consideration for remediation of the L-4
section of the Port Washington Landfill.
Glossary of Evaluation Criteria
o Overall protection of human health and the environment
addresses whether or not a remedy provides adequate protection
and describes how risks are eliminated, reduced or controlled
through treatment, engineering controls, or institutional
controls. A, comprehensive risk analysis is included in the
Endangerment Assessment, which is detailed in chapter 7 of the RI
report.
o Compliance with ARARs addresses whether or not a remedy will
meet all of the applicable or relevant and appropriate
requirements (ARARs) and/or provide grounds for invoking a
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14
waiver. A complete listing of ARARs for this site can be found
in section 2 of the FS.
o) Short-term effectiveness involves 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 of the alternative.
o Long-term effectiveness and permanence refers to the ability of
c. 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.
o Reduction of toxicity. mobility, and voly.pe refers to the
anticipated performance of the treatment technologies, with
respect to these parameters, a remedy may employ.
o Jmplementability involves the technical and administrative
feasibility of a remedy, including the availability of materials
and services needed to implement the chosen solution.
o Cost includes both capital and operation and maintenance (O&M)
costs. Cost comparisons are made on the basis of present worth
values. Present worth values are equivalent to the amount of
money which must be invested to implement a certain alternative
at the start of construction to provide for both construction
costs and O&M costs over a 30 year period.
o State acceptance indicates whether, based on its review of the
RI/FS and proposed plan, the State concurs with, opposes, or has
no comment on the preferred alternative.
o Community acceptance is assessed in the ROD following a review
of the public comments received on the RI/FS report and on the
proposed plan.
The following is an analysis with respect to the above criteria
of the various alternatives retained by EPA for further analysis
after preliminary screening. Please note that source control and
management of migration alternatives are evaluated separately,
since it is EPA's intent to select one alternative from each of
these categories. Also, since all of the source control
alternatives include landfill closure as part of the alternative,
closure was not included in the comparative analyses of the
various source control alternatives.
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Overall Protection of Human Health and the Environment
Under the no action alternative, there would be no control or
reduction of contaminants originating from L-4.. Subsurface gas
migration would only be controlled in one direction i.e., the
west, utilizing the existing system. Moreover, the control of
gas migration in that direction would be inconsistent, due to the
need for system rehabilitation and continuous operation.
Explosive levels of subsurface gas would at times be exceeded in
offsite areas not protected by gas containment technology. The
Southport well would not be able to return to service as a
potable water supply without contravening both State and Federal
drinking water standards in a short time. The Upper Glacial
Aquifer would continue to degrade locally in the vicinity of L-4,
and the risks to other receptors to the north and northeast,
i.e., Hempstead Harbor, Bar Beach wells etc. would remain
unquantifled.
Source Control
Alternative 0-2 would not be protective of human health and the
environment, since it is not expected that the existing venting
system, even when operating at peak capacity, could effectively
prevent gas from migrating underground to the south.
Alternatives 0-3 and G-4 are expected to be protective of human
health and the environment. Because each of these alternatives
includes ringing L-4 with a series of gas vents, lateral
subsurface gas migration into offsite areas should be minimal or
non-existent. O-4 would be more protective in the long term than
O-3 given its redundancy and enhanced ability to remove landfill
gases from the interior of L-4.
Management of Migration
Alternative W-2 would allow the Southport well to return to
service as a potable water supply with the incidental benefit of
partial aquifer remediation. However, this alternative would
also tend to "smear" the area of elevated VOC concentration
between the well and L-4, and could result in contaminant
loadings at Southport which night tax the air stripper's removal
efficiency. W-3 is more protective of both human health and the
environment, since it would minimize the probability of the smear
effect from occurring by creating a hydraulic sinJc through the
use of extraction veils in the area of elevated contamination.
The Southport air stripper under this alternative could be
downsized from that of W-2 because of this advantage. Removal of
additional contamination in the aquifer should also have an as
yet unquantified protective effect on hydraulically downgradient
potential receptors, i.e., Bar Beach wells, Hempstead Harbor,
etc. ' • ' • • .'-.--••• • '-
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Compliance with Applicable or Relevant and Appropriate
Requirements
Under the no action alternative, none of the ARARs discussed
below for either source control or management of migration would
be met over ths short term, since no additional actions would be
taken. Natural attenuation of contaminants in the ground water
could result in compliance with ARARs for this media over the
long. term.
Source Control .
All of the alternatives which involve closure will eventually
meet the requirements (ARARs) for the 6 NYCRR Part 360
regulations. A significant requirement of these regulations is
the ability of the alternative to fulfill requirements of 6 NYCRR
Part 360 which pertain to explosive levels of landfill gas.
Alternatives G-3 and Q-4, are designed to meet these requirements
for methane immediately upon implementation. G-3 and 0-4 offer
the most comprehensive protection since they include provisions
to intercept all possible avenues of potential off-site gas
migration; and should be most reliable in meeting Part 360
requirements pertaining to explosive gases.
Management of Migration
Both W-2 and W-3 will meet ARARs for potable water distribution
(Safe Drinking Water Act Maximum Contaminant Levels (40 CFR 141)
and New York State Department of Health Sanitary Code-Drinking
Water Supplies (10 NYCRR Subpart 5-1)) at the Southport well
immediately upon their implementation. However, W-3 will meet
aquifer ARARs more quickly and over a larger area than W-2
because of the strategic placement of additional groundwater
extraction wells.
Air stripper air emissions in W-2 and W-3 will meet ARARs
including 6 NYCRR Parts 201, 202, 211, and 231.
m
The NYSDEC policy of returning extracted groundwater (alternative
W-3) to the aquifer of origin is to be considered in the
determination of the discharge location for W-3's extraction
wells. The recharge basin scenario would meet this policy.
Short-term Effectiveness
Although there are no short-term construction risks associated
with the no action alternative, there are also no short-term
benefits to be derived from it.
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Source Control
The short-term impacts due to construction increase from G-2
through G-4, since the amount and complexity of construction also
increases in the same order. However, utilization of appropriate
techniques can greatly mitigate most of the short-term impacts,
including the potential for system downtime during replacement of
the vent system header. Each of the source control alternatives
will be immediately effective once implemented. Q-4 will take
the longest to design and construct (3-4 years), while G-2 and G-
3 will take approximately 2-3 years to design and construct.
Management of Migration
Both W-2 and W-3 are equally effective in the short term in
returning the Southport well to service as a potable water
supply.
Long-term Effectiveness
The long-term effectiveness of no action would be similar to many
of the other alternatives if the effects are evaluated in the
distant future. The L-4 cell will gradually cease gas and
leachate production; the groundwater contaminant loading will
gradually cease; the existing contaminated groundwater will
eventually make its way to Hempstead Harbor; and any offsite gas
migration will also gradually cease. However, EPA believes that,
if no action was chosen, these developments would not occur to an
acceptable degree for many years.
Source Control
Alternative G-2 would not provide any long-term protection from
subsurface gas migration along the southern or northern perimeter
of L-4. G-3 and Q-4 would effectively prevent subsurface offsite
gas migration in the long term, but G-4 would perform this
function more reliably in the long term because of its expected
ability to consistently maintain combustion in the HCU. When the
flare cannot be maintained, the vacuum on the collection system
has to be temporarily eliminated or reduced in order to allow the
BTU content in the collected gas to build up again. The use of
supplemental fuel under G-3 to maintain the flare, however, would
make both G-3 and G-4 equally reliable in theory.
Management of Migration
Alternative W-3 is more effective in long-term aquifer
remediation than is W-2. This advantage is particularly
noteworthy since the landfill study area is part of the EPA-
designated Long Island sole source aquifer.
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Both alternatives will allow for the return of the Southport well
as a long-term source of potable water.
Reduction of Toxicitv. Mobility, and Volume
There are some reductions of toxicity, nobility, and volume
currently taking place. The HCU is periodically reducing tha
toxicity of the collected landfill gas. Also, the mobility of
subsurface gas moving offsite has been reduced by the existing
venting system.
Source Control
Alternatives Q-3 and 0-4 would equally reduce the mobility of
subsurface landfill gas migration offsite. G-4 would reduce the
greatest amount of toxicity through destruction of collected
gases in two HCUs, followed by O-3, and then G-2, which would
have the smallest gas flow to the HCU and consequently reduce
toxicity the least.
Management of Migration
The W-3 remedy is intended to capture and treat contaminated
groundwater, as well as return the Southport Well to service,
whereas W-2 was only intended to return the Southport Well to
service. Therefore, W-3 would reduce the amount of toxicity,
mobility and volume of contaminants in the Upper Glacial Aquifer
well in excess of the incidental amounts achieved through the
implementation of W-2 (removal of contaminants at Southport well
only).
Implementability
The no action alternative is easily implemented from a technical
and institutional perspective.
Source Control
*
All of the source control alternatives are implementable from a
technical perspective. Institutional issues relating to access
and operation of some of the proposed facilities will be examined
•ore closely during design. At the present time, EPA believes
that all of the source control alternatives will be
institutionally implementable.
Management of Migration
All of the management of migration alternatives are implementable
from a technical perspective. Institutional constraints relating
to access will be examined more closely during design.
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The Port Washington Water District has indicated to EPA its
belief that it is premature at present to contemplate the return
to service of the Southport Well. The Water District's belief
would suggest that alternative W-2 is not readily implementable
from an institutional perspective, while alternative W-3 is
likewise partially constrained (extraction wells are not
envisioned to be operated by the Water District, and therefore
should still be institutionally implementable).
Cost
Summary of Present Worth Costs:
NO Action- $544,000
Source Control:
G-2- $5,496,000
G^3- $7,461,000
G-4- $11,754,000
/Closure $17,940,000*
Management of Migration:
W-2- $7,185,000
W-3- $10,141,000-
$15,429,000*
*A11 of the source control alternatives include landfill closure
as an integral part of the source control. For costing purposes,
the closure cost estimate includes capping the site with clay
after an adjustment to the existing grade, which represents the
highest cost capping option. In addition, the 30 year present
worth cost to operate and maintain the leachate control system,
presently utilized to handle the leachate from L-4, is estimated
to be $1,735,000 and should be added to the present worth cost of
each source control Alternative.
range of present worth costs reflect the options of discharging
treated water from the extraction well system to Hempstead Harbor
or to groundwater recharge basins.
For a detailed breakdown of project costs, please see table 4
(source control alternatives) and table 5 (management of
migration alternatives).
State Acceptance
The State of New York concurs with the selected remedy (see State
letter of concurrence-Appendix 4).
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Community Acceptance
EPA believes that the selected remedy has the support of the
affected community, particularly since it has incorporated
modifications to the proposed plan to address (where feasible
from a technical and a program perspective) the concerns of most
importance to that community.
SELECTED RBMBDY
The selected remedy for this site is a combination of source
control alternative G-3 and management of migration alternative
w-3.. : •
Many of the technical details associated with the selected remedy
will be formulated during the design stage. However, to provide
a basis for a better understanding of the selected remedy, some
preliminary design information has been incorporated into the
description of the selected remedy. It should be further noted
that any preliminary design information represents general
approximations of selected remedy parameters, and therefore could
undergo modification during the actual design phase of this
project.
The following is a detailed description of the selected remedy.
L-4 will be closed in accordance with 6 NYCRR Part 360. Closure
is intended to control water infiltration into, and leachate and
gaseous emissions from, L-4.
As part of this closure regulation, several investigations are
required'prior to placement of a highly impermeable cap over the
site. These investigations include a hydrogeologic investiga-
tion, an explosive gas investigation, a surface leachate
investigation, and a disease vector analysis. These actions are
deemed necessary by New York State prior to placement of capping
material on a landfill. Some of these investigations have
already been completed as a result of EPA's RI. A landfill
closure investigation report will be needed to summarize the
findings of the above investigations, after which the overall
closure plan, including plans for placement of a cap over L-4,
can be completed. This closure plan vill be the subject of a 30
day public comment period. The New York State regulations
require that the final slope Pf a cap should not be greater than
33 percent. At the present time, the side slopes for much of L-4
are very steep and there is limited area in which to expand the
slopes. Other acceptable options may need to be examined during
the development of the closure plan for L-4.
The design of the cap itself will include several layers of
material (figure 11). First, a 12 inch gas venting layer of sand
will be placed on L-4. Within this layer a perforated piping
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21
system will be placed to collect landfill gas and convey it to
vertical vent pipes which will originate in the fill material and
exit through the layers of subsequently placed materials. These
vertical risers should be spaced at a maximum separation of 1
vent per acre; should be installed at least 3 feet into refus.,
while extending 3 feet above the grade of the finished cap; and
should be backfilled with a porous media. A low permeability
layer will be placed on top of the gas venting layer to minimize
infiltration of precipitation into the landfill, thereby reducing
the production of leachate and landfill gas (from biological
decomposition) within the fill. This layer can be either 18
inches of compacted clay with a maximum permeability of 10"
centimeters per second, or it can be a 40 mil geosynthetic liner
with a maximum permeability of 10 centimeters per second. This
decision will be made during the development of the closure plan.
A 24 inch barrier layer will be placed on top of the low
permeability layer to act as a buffer for the underlying layers.
Six inches of top soil will be placed last in order to promote
vegetative growth on top of the cap. A post closure operations
and maintenance plan will also be developed concurrently with the
closure plan, and will govern all aspects of maintaining the
selected remedy for a minimum of 30 years.
New active venting will be installed around the perimeter of L-4
to the north, south, and east in order to completely encircle the
L-4 cell. Presently, EPA estimates that approximately 37 vents
will be necessary to span the remaining perimeter area. These
vents will be installed vertically on approximately 100 foot
centers in the virgin soil around the base of L-4. The vents
will be manifolded and connected to the existing compressor
station,;which presently has sufficient capacity to accommodate
this expansion of the gas collection system. The wells should be
drilled either to a depth of 50 feet below the deepest point of
the landfill within 500 feet of the vent, or to groundwater,
whichever is shallower. These vents should have 1 well control
valve for every 40 feet of vertical vent pipe to maximize gas
capture. These preliminary details may be modified during the
actual design of the- extension of the active venting system.
Although the existing HCU is considered capable of handling the
increased flow of gases that will result from the expansion of
the gas collection system, a second HCU will be added as a
standby unit to assure continuous HCU operation during downtime
of the existing HCU for maintenance or repairs.
In addition, the existing gas collection system will be
rehabilitated in order to return it to its design capability and
hence improve its operation and reliability. Based on the
findings of the RI, the design radius of influence between the
existing active vents has been judged sufficient to provide an
effective and continuous barrier to off-site gas migration if the
system is properly operated and maintained. It should be noted
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22
here that it was not conclusively determined during the RI
whether this barrier extends deep enough to effectively capture
gas at depth, although limited information from deep pressure
monitoring equipment suggests that this is probably so. In any
event, the monitoring of subsurface VOCs offsite during the RI
and the subsequent data analysis for health risk indicate that
even with the gas control system in need of rehabilitation, the
migration of these substances offsite is presently not posing an
unacceptable long-term health risk.
The rehabilitation of this system will include rebuilding the
main gas collection header to allow for the increase in landfill
grade due to capping L-4. Rebuilding the header will also permit
correction of the inconsistent slope of the header, which
presently allows landfill gas condensate to collect at low points
in the header and to partially impede gas flow. The gas blowers
which EPA evaluated during the RI and which at the time of EPA's
evaluation were in a degraded state, have since been replaced by
the Town as part of its operation and maintenance responsibility.
The new blower plans were reviewed by EPA to assure that
significant changes were not being made to the system which could
conceivably affect the validity of data collected during the RI.
However, these blowers have never been evaluated by EPA for
technical acceptability. Such an evaluation will be performed
during the design phase of this project.
Interim operation and maintenance procedures must be employed
until a post closure operation and maintenance plan is agreed on
by the EPA and DEC. It is EPA's belief, based on the RI, that
subsurface landfill gas migration occurs offsite to the west
within a matter of hours after all gas blowers are turned off.
Since these migrations theoretically present an acute threat of
explosion to the residences in immediate proximity to the
landfill boundary, and since the threat is easily remedied by
returning at least one blower to service, the operation of the
gas blower system must be continuous during this phase. It is
recommended that the combustion at the HCU be maintained by
reducing its blower speed by changing the motor and/or sheaves,
or by installing a variable frequency drive for the motor. If
this adjustment fails to sustain combustion on a continuous
basis, then a supplemental fuel source be utilized (typically
propane gas).
As noted, EPA and DEC must agree on a final post closure and
operation and maintenance plan. Prior to finalizing this plan,
additional information needs to be collected and evaluated
including information pertaining to the ability of the proposed
gas collection system (under O-3) to support continuous
combustion at the HCU.
-------
23
If it is determined that the 0-3 system by itself cannot support
continuous combustion at the HCU then two options exist for the
operation and maintenance of the HCU namely:
1) accomplish continous combustion at the HCU through the
use of supplemental fuel, such as propane, or through the
use of additional landfill gas captured via the gas
collection system detailed under alternative 0-4.
2) operate the HCU intermittently while the compressor
station for the gas collection system operates continuously.
The second option (intermittent operation) could not be allowed
to occur unless: (1) a risk assessment, using EPA methodology,
was performed; and (2) the assessment indicated that such
operation would not result in unacceptable risks to public
health.
The following recommendations for operation and maintenance
generally involve the existing landfill gas venting system.
These recommendations will serve at a minimum as the basis for
development of the comprehensive post-closure operation and
maintenance plan to be developed during design.
*cleaning of sediment and water from all active vents
*development of a spare parts list
Maintenance of a spare parts inventory which stocks any
component necessary for system operation that is not readily
obtainable
*return of all active steel vents to service
^development of an active steel vent system performance
monitoring plan and schedule
^development of a contingency plan to maintain operation of the
active venting system during episodes of power outage.
In addition, approximately 3 groundwater extraction wells will be
installed in the known area of high VOC concentrations (figure
12). The wells will pump extracted groundwater to a water
treatment facility which will consist of an air stripping tower
approximately 4 feet square and 18 feet tall. The discharge from
the facility will be to a recharge basin(s), which will return
the extracted groundwater to the aquifer of origin. Additional
treatment at this facility, such as metals removal and treatment
of stripper air emissions, will be evaluated during design to
determine what treatment is necessary to operate the facility in
compliance with all applicable Federal and State requirements.
Exact locations for these wells and treatment facilities will be
determined during design, when additional design sampling will be
conducted to optimally site the wells, and property access
considerations are fully explored.
-------
24
The Selected Remedy also includes the return of the Southport
well to service as a potable water supply through the addition of
air stripping technology at the wellhead in order to remove
volatile organic contamination and allov the treated well water
to meet all Federal and State regulations applicable to potable
water supplies. However, the Port Washington Water District has
indicated to EPA that it is the belief of the Water District that
the return of the Southport Well to service is presently
premature, and should await the results of long term groundwater
monitoring, after implementation of the extraction well program,
before a decision is made when/whether to reactivate the well.
Therefore, EPA will not proceed with the design of the air
stripping facility at the Southport Well until such time that the
Water District decides to reactivate the well, subject to EPA's
review and analysis of monitoring data at that time to insure
that the remedy as currently envisioned in this Record of
Decision is still appropriate.
Under any circumstances, activation of planned extraction wells
would be initiated prior to the return of the Southport well to
service, in order to minimize the probability of drawing
contamination from the localized area of relatively high VOC
contamination at the western edge of L-4 into the"Southport well.
EPA believes that additional landfill gas and groundwater
monitoring locations are needed to satisfy several needs that
have been identified during the RI and FS, and which have been
previously described in this ROD, namely: to establish the exact
placement of groundwater extraction wells; to further delineate
the nature and extent of the northerly migration of groundwater
contaminated with VOCs and leachate; to further characterize the
migration of groundwater contamination towards Hempstead Harbor
and the subsequent possible need to monitor the sediments and
water of the Harbor; to monitor any progression of groundwater
contaminated with VOCs or hazardous inorganics toward the study
area's potable water supplies; and, to monitor the migration of
landfill gas away from L-4 in all directions. Most of these
proposed wells, in addition to wells already in existence, will
also serve to monitor the effectiveness of EPA's selected
remedial action.
The proposed new well locations are shown in figure 13. A
specific monitoring plan and schedule will be developed during
the design phase of this project.
STATUTORY DETERMINATIOHS
Under its legal authorities, EPA's primary responsibility at
Superfund sites is to undertake remedial actions that achieve
protection of human health and the environment. In addition,
section 121 of CERCLA establishes several other statutory
requirements and preferences. These specify that when complete,
-------
25
the selected remedial action for .this site must comply with
applicable or relevant and appropriate environmental standards
established under Federal and State environmental lavs unless a
statutory waiver is justified. The selected remedy also must be
cost-effective and utilize permanent solutions and alternative
treatment technologies or resource recovery technologies to the
maximum extent practicable. Finally, the statute includes a
preference for remedies that employ treatment that permanently
and significantly reduce the volume, toxicity, or mobility of
hazardous wastes as their principal element.
Protection of Human Health and the Environment
The selected remedy protects human health and the environment by
preventing the offsite migration of contamination from L-4, as
well as treating significant contamination presently existing
offsite. Rehabilitation of the existing active venting system in
conjunction with expanding it to completely encircle L-4 will
effectively reduce the subsurface migration of gases to meet
explosive gas requirements from 6 NYCRR Part 360, as well as to
reduce any long-term health risks resulting from exposure to any
hazardous residuals in the landfill gas which could occur if the
gas seeps into offsite structures. Addition of a second HCU and
the development of a comprehensive operation and maintenance plan
as part of the closure plan will increase the reliability of the
gas withdrawal system to prevent offsite gas migration.
The treatment of groundwater at the Southport Well to meet all
applicable potable water regulatory requirements would
effectively safeguard all potential users of the Southport Well.
However, -the Port Washington Water District has indicated its
belief to EPA that it is premature to return the Southport Well
to service. Therefore, while the Well remains out of service,
the protection of public health in this regard would still be
protected, albeit the Well resource would continue to be
unavailable.
Commencement of the groundwater extraction well system prior to
the startup of the Southport well will safeguard against the
migration of the area of elevated VOC contamination toward the
Southport well, if and when the Southport Well is eventually
returned to service.
Compliance With Applicable or Relevant and Appropriate Standards
Closure of the L-4 section will neet the State sanitary landfill
closure requirements as specified under 6 NYCRR Part 360. This
remedial action, particularly the placement of a highly
impermeable cap over the landfill's surface, will hasten
reduction in the amount of leachate and landfill gas generated by
the landfill by restricting the infiltration of water. Leachate
and landfill gas represent the two physical media in which
-------
26
hazardous constituents in L-4, or any other sanitary landfill,
make their way offsite. Utilization of a specially designed cap
as described earlier under the selected remedy will prevent the
buildup of landfill gases initially upon placement of the cap.
Placement of extraction wells, with subsequent treatment and
return of the extracted groundwater into the aquifer of origin
will hasten the cleanup of the Upper Glacial Aquifer in the area
of elevated VOCs to maximum contaminant levels as specified in
the Safe Drinking Water Act (40 CFR 141) and New York State
Groundwater Quality Regulations (6 NYCRR Part 701 which
incorporates 10 NYCRR Subpart 5-1). EPA believes that it is
appropriate at Superfund sites to apply these requirements to
points within an aquifer if the aquifer is used as a source of
potable water. The treated groundwater will also meet these
requirements prior to discharge to the recharge basin. Discharge
of treated groundwater from the extraction system into aquifer
recharge basins satisfies the State policy of conservation of
potable water.quantity in Nassau County.
The air stripping technology at the Southport well will also be
designed to meet the above noted maximum contaminant levels for
drinking water supplies. The addition of the air stripper will
be subject to the availability of Federal funding and the re-
establishment of the need for treatment at the Southport Well at
the point in time when the Port Washington Water District
determines to return the Well to service.
Air emissions from the above noted air stripping systems will be
required to meet the requirements of 6 NYCRR Parts 201, 202, 211,
and 231 since the site is in a non-attainment area for ozone.
Installation of new landfill gas and groundwater monitoring
wells, and development of a long-term monitoring plan using these
and the existing well network, will demonstrate the effectiveness
of this selected remedy, as well as achieve the other monitoring
objectives as described under SELECTED REMEDY.
•
Cost Effectiveness
The selected remedy is cost-effective because it has been
determined to provide overall effectiveness proportional to its
costs (present worth' $42,580,000).
Utilization of Permanent Solutions and Alternative Treatment
Technologies (or Resource Recovery Technologies) to the Maximum
Extent Practicable and Preferrence for Treatment as a Principal
Element
The element treatment technologies to effect permanent solutions
at Superfund sites is not practicable at some sites with large
volumes of low concentration wastes, such as L-4. These remedies
-------
27
are typically difficult to implement and prohibitively expensive.
Therefore, the range of alternatives for source control was
focused on containment options.
On the other hand, EPA has selected treatment technology to
permanently reduce the levels of contamination that have migrated
offsite in the Upper Glacial Aquifer. EPA also believes that the
permanent destruction of organic compounds afforded by the HCU
flare must be maintained until such time that it is determined
whether continuous operation of the HCU is necessary to safeguard
public health.
DOCUMENTATION OF SIGNIFICANT CHANGES
The Proposed Plan for the Port Washington Landfill was released
to the public in July 1989. The Proposed Plan identified
Alternatives G-3 and W-3 to control the source and manage
migration respectively. EPA reviewed all comments submitted
during the public comment period. Upon review of these comments,
it was determined that no significant changes to the selected
remedy, as it was originally identified in the Proposed Plan,
were necessary. The public did raise specific concerns regarding
the ability for the gas collection system (under O-3) to maintain
continuous combustion at the HCU and felt the G-4 collection
system might provide a more effective and reliable means of
maintaining combustion. It should be noted that the Selected
Remedy has addressed these concerns. As stated in the Selected
Remedy, additional landfill gas captured via a gas collection
system detailed under G-4 could be utilized as an optional source
of supplemental fuel should the design phase indicate that this
is the preferred means of achieving the remedial action
objectives of Q-3.
-------
APPENDIX 1 - FIGURES
-------
FIGURE 1
^^?«: . 1:5-5.S, S« CUff Quadrangle. 7.5 series
.'C«('«-s:? ..-""-•«. (.'AS '•'•:
metinAV^ ... - \Ab<:<>
h sl.-^t, sv.-1 •
w-^-'
l-^'Ar\ \^-. vJfcf r -^ ^ *
* 'rf*^- s&-*-*y%s S*f.
\:: ^i'^7^-' • ' - >
ISwmrANo 6«*vcL Kr^lP . *
'is-.i'
r(\.i
.
ort
-^
V-^Pr<
-*» ^_^l'LZ^:*yv^- >w=»-*y
x^Svy^lfw^Tr 1JL-Z£&&
•SJ5rr.'r *?•> i?.'*~^.*»f*
**SSFf \**-•<• ^^ T ' " T~*
^A- r* • V- X»i -„.,„,
^T .. .* v*\>---nc*--
£*$''£&t' ^^ '{ : "
, *i
^5^
:»i. •»
NwtM a*~
-------
•0 0 NO (00 (00
Safe FMI
L-4 LANDFILL
MUM IUMCN1MV
SCHOOL
ACTIVC
NX
II
II
II
II
II
II
II
II
II
y
"•/LfACHATt
LAOOON
eatr caumc
BUILDING
[T
NC* omce ocvciopMiwn
COM
•nvironmenlal engineers, sdenlkta.
planners A management consultants
immediate Landfill Area
Port Washington. Nassau County.
-------
WEST - EAST GEOLOGIC CROSS - SECTION
( Qootoglo contact* bM«d on Information by Henderson end CM«y, end Cfiibol Kliburn )
•CAlfl ( toM
COM
environmental engineers, scientists,
planners A management consultants
West-East Geologic Cross-Section
Port Washington. Nassau County. New York
-------
•OUTHPONY
WfLLJ)
s ,r
•oulh
>
nn
o
fl
*-
*TtM fort Washington Landfill It located approximately 1,300 feet east of the Source: (Mlburn 1979
COM
engineers. scientists.
management consultants
North-South Geologic Cross-Section of Manhasset Neck
^
Foil Washington. Nassau C^B, New Yoik
-------
BAR BEACH WELLS
(N5209. N5210)
WELLTNH-11
WELLTNH-12
WELL TNH-1
•WELLTNH-2
WELLTNI-W
WELL TNH-3
L-5 LANDFILL
L-4 LANDFILL
WELLTNH-8
WELL TNH-7^
OUTHPORT
WELL
WELLTNH-9
WELLTNH-10J
WELLTNH-5^/
WELL TNH-6-/
WELL GP-5
STONEYTOWN WELL
(N9509)
HEWLETT WELL
(N2052)
EXISTING
T.N.M.
INCINERATOR
Location Of Area Wells
Pott Washington LandfiB, Port Washington. Ntw Yorfc
»ngin»»rs. scientists.
pitnntrs A m*nag»m»nt consultants
-------
•ex
U0M*
PVC wnu h«v« tM«n aomwdcd to tft* Ktf<
(MMIW at ttw tlMlv*n4i luv* b««n dt»ooon»c1«
• Concral* ring v«nt* (passive)
UnfandPVCflnd
o
COM
s. sdenlhli
pt*nn»n A management consuttantt
Gas Management System Layout
Port Washington Landfill. Port Washington. N<
-------
N
FIGURE 7
•k
LEGEND
N-1120 . Nassau County Well
A« " Town Of North Hempstead Wall
EPA-105 - US Environmental Protection
Agency Well
10 400 800 1600
Location Of Ground Water Monitoring Wells
Port Washington Landfffl. Port Wasnington, New Yon\
-------
WO WO MO WO
• EPAwcIs
• TNHweta
COM
•nwraMgnfa/ engineers, scientists.
piann^M management consultants
Location of Landfill Gas Monitoring Wells
Port Washington Landfill. Port WashlngloJP^w Yortt
-------
I**1
•s
§
vO
MO «W NO MO
•••I
COM
0nvironm0nl»l engineers, scfonf/sfs.
planners A management consultants
Approximate Location of Flux Box Stations
Port Washington Landfill. Port Washington. New York
-------
^Landfill ^
Gas . ,/($$A Leachale
CCondcnsate '(Inorganics)
(Organlcs)
NOTE: * - Concenlrallons Representative Of Total Volatile Organic Priority Pollutants
0
COM
planner* 4
consuAbtnfs
Conceptual Block Diagram
Of Contaminant Transit
Porl Washington Landlill. Port Washington. New^wk
-------
FIGURE U
8" Olamter Steel Or Cast Iron Collar
6M Diameter PVC Pipe
36" Dlameter-12" Thick 3,000 PSI
Concrete Collar
Vent Covered With Wire Mesh
6" Top Soil
24" Barrier Protection Layer
Filter Fabric
3 Filter Fabric rwwwww-
6" Long Telescoping Section
(For Landfill Settlement)
Gas Migration
Perforated
Pipe
18" Low Permeability Soil
1 x 10 '7cm/sec Maximum
12" Gas Venting Layer
10'^cm/sec Minimum
g
12" Operation Cover
Trash
Pea Gravel
6" Diameter Slotted PVC Pipe
Not To Scale
COM
tnttl tnginnn. tdtrtitn
I m*n*g»tn»ra
Landfill Capping Detail
Port Washington Landfill, Port Washington. New York
-------
Approximate Area of Elevated Levels
of VOC's In the Ground Water
VOC Removal Facility
Estimated Zone
of Capture*
Effluent Discharge.Line
to Relnjectlon Wells
• Extraction Wells
Relnjectlon Wells
• Under average summertime and
wintertime pumping conditions
0 400 100
Location Of Facilities • Alternative W-3
Pan Washington Landfill. Port Washington. New
-------
FIGURE 13
N
N-1120
TNH-3
EPA-105
0
A
0
0 400 800
Nassau County Well
Town Of North Hempstead Well
US Environmental Protection Agency Well
New LF Gas Wells
New Deep GW Wells
New Shallow GW Wells
1600
to*£i
lie (•ppresbiut*) feet
If \
COM
•nvirvnmtnal tnginten. tdfntuts
i fnantgtmtm consultants
L-4 Environmental Monitoring Program
Port Washington LandfUl. Port Washington, New Yor*
-------
APPENDIX 2 - TABLES
-------
TABLE 1
Of POTENTIAL CONCERN SUMURV («)
sou
WOUND
WATER
lEACHATE
6AS (b)
COHOCNSATC (b)
ORGAN ICS.
Acetone
Benzene . . X X
Benzoic tthyl prrthaUtt X
Oi-n-butyl phthitcte X X
Oi-n-octyl ptithilatc X X
Ethylbvnzcnt
2-Htunonc
4-«»thy1-2-p«»»tiftOf>*
Mithylmt chloride X
faphtfeltn*
Tctrachlorotthenc X X
Toluene X
1.1.1-Trichloroetrane X
1.1.2-Trichloroethine
1.1.2.2-Tetrachloroethcne
THctiloreethene X X
Vinyl chloride X
Xylene X
INOR6ANICS
Aluminum
Antimony -
Arsenic
Barium
Cadmium
Calcium
riMM^iiMi
cnromium
Copper
Cyanide
Iron
Lead
Manganese
Mercury
Hickel
Potassium
Selenium
Silver
Sodium
Thallium
Vanadium
Zinc
J
X
X
X
X
X
X
X
( X
X
x .• :
X
X
(a) Blanks indicate that the chemical MS either not detected or MS not selected as
• chemical of potential concern (because of infrequent detections or companion
to backaround levels), with the exception of inorganics •Rich wre net sampled for
In landfill oat and condensate.
(b) These media «ere sampled for organic chemicals only.
-------
Summary off Source Control Remedial Alternatives
GompofWrts
1 ill •!• r TJTJ li-n mnr 11 UVf*PP
LM UM cappng per o NTUHH
part 360
|XBMJlVU wW»
„. J_- . _,_.
EjdSHnQ COnCfne (MeiTO
Blower house
combustion uni (HCU;
•
Ddstlng gas header
a ^ _^
New Qtt V*l to USOCUHu «iMi
landMcap
O4M ol gas cofecfon system
AHemalrveG-1
kM-fcirWI
•XJUOcu
LQdVQ •! (JiUaVIH alulQ
»
LeoVQ m |ji8acii aiara
uoism •• (JiosujiB Mdra
Leave In present stale
Leave n preset! siara
Leave In present stale
.
Anw to vent to atmosphere
Retain exlslng OftM practices
Alternative G-2
bwfctffcwfl
WIUUUBU
r^ta'm m 4 cpffimprri smH Wf3ff flc
Hlace disconnected vents back
Wo service
1 A9uo In rwocArtf data
1 AHUM In WAttkni date
Upgrade blowers so they al
are operational
VJ|Jtn ven N> dRmospnere
ModMy to Include rouflne
Inspections. Gas readtags to
be taken at al gas vents and
monitoring wels. Improve
maintenance program lor al
mechanical equipmert
AHemeOveG-3
lrv*kvterl
(^wm at «uArttl*\«l»fel ftui.»uAA^ k%
aou aouNionai neaaer 10
aooommoddle new active
VCTH5
nKHt n veri R> atrnospnere
Same as alemattve G-2
Alternative G-4
bv^trfewl
muuoeo
IfMV^ M ifenm-itk^ n 1 tm A
OOMU ca cnclilifllW O>I UM
add new active vents through-
out the Wertor ol L-4 and
modty teachate drarn lie
system to become part ol the
active venting system
i Krwi w> aavo venmy system
iitun wt auwe veiviy sysnin
Upgrade blowers so they al
are operational
AjM «VM r"—*- • */H| 1 k*« ••*•*» b%
wn one new HUU ur use in
normal operation. Modtty
enlstlng unit to reduce contus-
ion air btower speed. Use
supplemental luel H necessary
Same as alemative G-3 but
add addrtionat header to
aoconHltodate new Interior
Btwe vents
ite-n n actve venting system
Same as alemative G-2
r4
m
K)
-------
Summary of Ground Water Remedial Alternatives
Alternative W-1
Alternative W-2
Alternative w-3
ARemathwW-4
LandM copping tni gas
migration control per
6NYCRRPart360
Induded
Induded
Included
Included
Action si Souffxxt Wei
Reactivate and pump al 700
gpmmax.tod&ribufon
without treatment alter moni-
toring Indcates the area ol
etovatedVOC concentrations
hasdsstoaled
Reactivate, treat pumped
water with an air stripper,
pump treated water to Distri-
bution at 700 gpm max.
Reactivate, treat pumped
water with an air stripper,
pump treated water to dtetrt-
bution at 700 gpm max.
Reacfvate. teat pumped
water with an air stripper,
pump treated water to dstri-
buVon at 700 gpm max.
Action at zone of elevated
%«^^M »—••—
vut. oonceiifanns
None
None
Instal extraction wels, pump
at 330 gpm. Treat extracted
water with a second air
stripper and posstrfy a metals
removal step. Discharge
treated water to Herhpstead
Harbor, the beat wastewater
treatment plant or recharge to
the Upper Glacial Aqu«ef.
kistal extraction wels, pump
al 330 gpm. Treat extracted
water with an air stripper and
• metals removal step.
Retried treated water back
Ho the Upper Glacial Aquifer
RemeolalonotVw
Upper Glacial Aqufer
Not designed to acHveV
attempt aquifer remediation.
However, the atemative does
Impact a porfon of me aquifer
wJlWn the raoTus of Influence
ol the Southport Wei and thus
I would provide some
remedattoo of that portion of
twaquHer
Not designed to actively
attempt aquifer remediation.
However, the alematrve does
Impact a portion of the aquifer
within the radto of Influence
of the Southport Wei and thus
II woukj provide some
remediation of that portion of
theaqurler
Actively attempts remeolalon
by pumping at a rate sufficient
to estabfsh a cone of Influenoe
In the area of elevated VOC
contamination to withdraw this
'source' from the aquifer
Same as aRemaHve W-3;
however, the thne for aquifer
remedation Is attempted to be
aocetefated through reinjeo-
km. Reinjection wil increase
the throughput of dean water
across those portions of the
aqulerwflh evidence of con-
tamtnatton
Monitoring program
Southport Wei Orty
Southport Wei. air stripper
emissions
Soufnport Wei. Upper Glacial
Aquifer, any dtecharges to
Harbor, wastewater treatment
plant or recharge to the aquifer.
air stripper emissions
Southport Wei. Upper Glacial
Aquifer, discharge to reinjec-
tk>n wels. air stripper emis-
sions
-------
TABLE
COST ANALYSIS: CAPPING THE L-4 PARCEL UTILIZING A
LOV PERMEABILITY SOIL (CLAY) SUBSEQUENT TO
ADJUSTING EXISTING GRADE
tern
No.
Description
Annual
Capital cost OiH cost
. Additional fill to
regrade to 3:1*
. Gas venting layer
.. Low Permeability
• layer
.. Barrier Protection
layer
>. Top soil
>. Filter Fabric
(2 layers)
(400,000 cu yds of fill 9 812/cu yd) $4,800,000
-«£
(67,000 cu yds of sand 9 $18/cu yd) 1,206,000
(100,000 cu yds of clay @ $40/cu yd) 4,000,000
« . •
(134,000 cu. yds of fill 9 $12/cu yd) 1,608,000
(34,000 cu yds 9 $22/cu yd)
(3,600,000 sq ft § SO.lO/sq ft)
748,000
360,000
J. Passive Gas Vents (42 9 $4,000/ea)
3. Cap Maintenance (grass cutting, personnel)
Total
Engineering & Contingencies (35Z)
| Total Cost
Present Worth Cost**
168,000
$12,890,000
4,512,000
$17,402,000
$17,940,000
$ 35,000
$ 35,000/yr
*The additional fill material used to adjust the existing grade to a 3:1 slope replaces
the operational cover.
"Assumes a discount rate of 5 percent and a period of performance of 30 years.
The present vorth factor is 15.372.
-------
TABLE * (cont'd)
COST ANALYSIS: SOURCE CONTROL REMEDIAL ALTERNATIVE G-2
Annual
I ten Capital O&H
No. Description Cost Cost
1. Gas System Repair $276,000
- remove existing gas headers ^ •
- install temporary gas header . * •
- reinstall gas headers
- install condensate drain traps
- adjust gas veil head vaults
- safety equipment
2. Blower Station Repair 252,000 $32,000
- supply new gas blowers
- install new gas blowers
- rework all pipe
- remove existing blowers
- safety equipment/monitoring
3. Monitoring of Vents, Veils, Blowers 108,000
and Incinerator
4. Technical/Administrative Review of Operations 31,000
5. Vent Replacement Costs 29,000
6. Incinerator Repair/Maintenance/Escrow 29,000
7. Source Testing and Lab Analysis 5,000
8. Gas Piping Repair and Maintenance 10,000
9. Spare Parts Inventory 50,000
10. Electricity 75,000
11. Five Year Site Review (escrow) 8,000
Total $528,000 $377,000
Engineering fc Contingencies (3SX) 185.000
Total Capital Cost $713,000
Total Present Vorth Cost* $5,496,000
-------
TABLE 4 (cont'd)
COST ANALYSIS: SOURCE CONTROL REMEDIAL ALTERNATIVE G-2
*Assunes a discount rate of 5 percent and a period of performance of 30
years.
These costs do not reflect the costs for capping the landfill. Landfill
capping costs are presented separately on the ensuing tables.
-------
TABLE 4 (conc'd) .
COST ANALYSIS: SOURCE CONTROL REMEDIAL ALTERNATIVE G-3
Annual
Item Capital O&H
No. Description Cost Cost
1. Gas System Repair (see G-2 for breakdown) $276,000
2. Blover Station Repair (see G-2 for breakdown) 252,000 32,000
"*' '
3. Perimeter Gas Vents 222,000
- drilling
- material (pipe, slotting, bentonite)
- mobilization/demobilization
- veil head assembly
- safety equipment/monitoring
A. Perimeter System Piping (above grade) 182,000 10,000
- pipes, fittings, valves
- drain sumps
- safety equipment/monitoring
5. Horizontal Combustion Unit 285,000 18,000
- equipment :
- foundations
- mechanical/electrical installation
6. Monitoring of Vents, Veils, Blowers and
Incinerator 110,000
7. Technical/Administrative Review of Operations 17,000
8. Site Safety Monitoring .' 42,000
9. Vent Replacement Costs 36,000
10. Incinerator Replacement Cost (escrow) 11,000
11. Source Testing and Lab Analysis 5,000
12. Spare Parts Inventory 50,000
-------
TABLE '4 (coht'd)
COST ANALYSIS: SOURCE CONTROL REMEDIAL ALTERNATIVE G-3
Annual
Item -1 Capital O&M
No. Description Cost Cost
13. Electricity 117,000
14. Five Tear Site Review (escrow) 8,000
Total : $1,217,000 $456,000
Engineering & Contingencies (35X) 426,000
Total Capital Cost $1,643,000
Total Present Worth Cost* $7,461,000
*Assumes a discount rate of 5 percent and a period of performance of 30
years.
These costs do not reflect tSie costs for capping the landfill. Landfill
capping costs are presented separately on the ensuing tables.
-------
TABLE A (cont'd)
COST ANALYSIS: SOURCE CONTROL REMEDIAL ALTERNATIVE G-4
Item
No. Description
1.
2.
3.
4.
5.
Gas Blower Repair
Blower Station Repair
Perimeter Gas Vents
Perimeter System Piping (above grade)
Horizontal Combustion Unit
Capital
Cost
$276,000
252,000
222,000
182,000
285,000
Annual
O&H
Cost
32,000
10,000
18,000
(see alternative G-3 for a breakdown of the
above)
"6. Interior Gas Vents 833,000 61,000
- installation .
- material
- mobilization/demobilization
- veil head assemblies
- safety equipment/monitoring
7. Concrete Cistern Conversion 76A,000
- drilling costs
- material
• mobilization/demobilization
- veil head assemblies
- safety equipment/monitoring
8. Interior Gas Header Piping (above grade) 300,000 15,000
- pipe fittings
- veil head assemblies
- condensate drain traps
- safety equipment/monitoring
9. Lateral Gas Header Piping (above grade) 140,000
- pipes, fittings, valves
- safety equipment/monitoring
10. Leachate Sump Conversion 59,000
11. Monitoring of Vents, Veils, Blovers and 131,000
Incinerator
12. Site Safety Monitoring 42,000
-------
TABLE 4 (cont'd)
COST ANALYSIS: SOURCE CONTROL REMEDIAL ALTERNATIVE G-4
Annual
Item Capital O&M
No. Description Cost Cost
13. technical/Administrative Review of Operations 21,000
14. Incinerator Replacement Cost (escrow) 11,000
15. Source Testing and Lab Analysis 5,000
16. Spare Parts Inventory 50,000
17. Electricity 158,000
18. Five Year Site Review (escrow) 8,000
Total $3,313,000 $562,000
Engineering 4 Contingencies (35X) 1,159,000
Total Capital Cost $4,472,000
Total Present Worth Cost* $11,754,000
*Assumes a discount rate of 5 percent and a period of performance of 30
years.
These costs do not reflect the costs for capping the landfill. Landfill
capping costs are presented separately on the ensuing tables.
-------
TABLE 5
COST ANALYSIS: GROUND WATER REMEDIAL ALTERNATIVE V-2
I ten
No.
Description
Capital cost
Annual
O&M cost
1. Installation of landfill gas and ground vater
monitoring veils
2. Air Stripper at Southport Veil
- Pilot Study
- Earthwork (building and yard piping)
. - Concrete
- Brick and Block, Structural Steel
- Thermal Protection (Insulation, Dampproofing)
• Doors and Finish Hardware, Painting
- Equipment (Blowers, pH adjustment, sod. hypo feed)
- Instrumentation .
- Mechanical and Electrical Systems
3Mfeactivation of Southport Veil
4. Implement Monitoring Program
- Sampling at Southport Air Stripper (Vater Quality)
First Year
Subsequent Years
- Landfill Monitoring (gas and ground vater)
Summary
Capital Cost
Engineering & Contingencies (35X)
Total Capital Cost
First Year O&M Cost
29 Year O&M Cost
Total Present Vorth 04M Cost
Total Present Vorth Cost*
$ 580,000
20,000
185,000
37,000
35,000
7,000
15,000
10,000
185,000
511,000
$1,585,000
555,000
$2,140,000
$ 344,000
$4.701.000
$5,045,000
$7,185,000
S 45,000
27,000
32,000
14,000
240,000
a discount rate of 5X and a period of performance of 30 years.
-------
TABLE 5 (cont'd)
COST ANALYSIS: GROUND WATER REMEDIAL ALTERNATIVE V-3
(Recharge Basin)
I tea
No.
Description
Capital cost
Annual
O&M cost
1. Installation of landfill fas and ground vater
•on!toring veils
2. Air Stripper at Southport Veil
- Pilot Study
- Earthwork (building and yard piping)
• Concrete
-Brick and Block, Structural Steel
- Thermal Protection (Insulation, Daapproofing)
- Doors and Finish Hardware, Painting
- Equipment (Blowers, pB adjustment, sod. hypo feed)
- Instrumentation
- Mechanical and Electrical Systems
3. Installation of Ground Vater Extraction Veils
4. Air Stripper at VOC Plume
- Pilot Study
- Earthwork tbuilding and yard piping)
- Concrete
- Brick and Block, Structural Steel
- Thermal Protection (Insulation, Dampproofing)
- Doors and Finish Hardware, Painting
- Equipment (Blowers, pH adjustment, sod. hypo feed)
- Instrumentation
- Mechanical and Electrical Systems
5. Metals Removal Process at VOC Plume Facility
m
- Building expansion (reflected in item 4 above)
- Additional mechanical and electrical systems
- Instrumentation
6. Recharge Basins
- Earthwork
- Concrete
- Instrumentation i Electrical
7. Reactivation of Southport Veil
$ 580,000
20,000
183,000
37,000
32,000
7,000
15,000
10,000
185,000
506,000
335,000
30,000
275,000
42,000
40,000
8,000
21,000
10,000
277,000
489,000
400,000
102,000
05,000
10,000
5,000
$ 45,000
287,000
-------
TABLE 5 (cont'd)
COST ANALTSIS: GROUND WATER REMEDIAL ALTERNATIVE W-3
(Recharge Basin)
I tea
No.
Description
Capital cost
Annual
O&M cost
8. I«ple»ent Monitoring Program
- Stapling at Southport Air Stripper
First Tear
Subsequent Tears
- Sampling at VOC Plune Air Stripper
First Tear
Subsequent Years
- Landfill Monitoring (gas and ground water)
Summary
Capital Cost
Engineering i Contingencies (352)
Total Capital Cost
First Tear O&M Cost (Present Worth)
29 Tear O&M Cost (Present Worth)
Total Present Worth OtM Cost
Total Present Worth Cost*
$3,704,000
1.296,000
$5,000,000
$ 710,000
$9,719,000
$10,429,000
$15,429,000
32,000
14,000
32,000
14,000
240,000
'Assumes a discount rate of 5X and a period of performance of 30 years.
-------
APPENDIX 3 - ADMINISTRATIVE RECORD INDEX
-------
19/26/89 Index Chronological Order Page: 1
PORT WSHDCTDN Docwents
Docwent Nioter: ttS-«3-«715 To 1716 Oite: / /
Tit If: (Fon letter regarding public access to the Draft Remedial Investigation Report for tht Port
Washington Undfill Superfund Site)
Type: CORRESPONDENCE
Author: Als, Edwrd 6: US EPA
Recipient; none: Public Information Repository
Oociwent Nwiber: UAS-ee3-47A2 To 1743 Oite: / /
Title: Site Nap: Existing Landfill Sas Monitoring Hells Port Washington Landfill
Type: 6RAPHIC
Author: none: Cup Dresser I fcKee (COM)
Recipient: none: none
Document Muitcr: UAS-M3-4781 To 1781 Date: / /
Title: (Nap of site showing mil and sampling locations)
Type: GMPHIC
Author: none: none
facipient: none: none
Docuecnt Nurter: UAS-M3-I951 To 1951 Date: / /
Title: (Attendance List)
Type: ODCR
Arthor: none: none
•cipicnt: none: none
Bocvent N«faer: HAS-M3-1H3 To IMS Brtet / /
Titlii Landfill Citizens Advisory Coeaittee Maces nrf Addresses)
Type:
NKthors none! none
Recipient: none: none
-------
19/26/89 Indti Chronological Order Page: 2
PORT WASHINGTON Docwnts
Docwent Nuiber: WAS-W3-1889 To 1118 Date: M/t2/82
Titli: Doc«ntation Records for Hazard (Unking SystM
Type: PUN
Author: Hauptean, Nelvin: US EPA
Recipient: nont: none
Oocwent Nutter: UfiS-ttMKl To 1168 Date: 11/12/82
Title: ftir Monitoring Progru - Tow> of North htopstead L-4 Landfill, Port Washington, NY - Report
Executive Sugary
Type: PLPN
Author: none: US EPA
lecipient: none: none
Oocvent Nurter: WS-M1-W1 To 1177 Date: 12711/82
Title: Field Investigations of Uncontrolled Hazardous Waste Sites - Port Washington Landfill Final
Report
Type: PUW
Author: Lipsky, David: Fred C Hart Associates
Recipient: none: US EPA
Docwnt Nuiber: HAS-M1-1941 To 1983 Parent: yAS-Ml-19K Date: 13/11/83
Title: Sailing and Analytical Protocol - Landfill Gas Monitoring at Port Watfiiiqton Landfill
Types PL*
Author: nonet SB Engineers
Recipient: none: Morth tapsttad NY, TOOT of
Bocwent Nurter: WAS-M3-1B9 To 1KI Parent: WS-M3-1C7 Dat«: 19/22/83
Title: (Litter regarding an addition to the Draft Consent Order relating to the subsurface lisrition
of pollutants froi the site to public nater supply «lls)
Type: CORRESPONDENCE
Author: Schafer, Jacqueline E: US EPA
Recipient: Villiass, Henry 6: NY Dept of Enviromental Constrvition
-------
19/26/89 Indtx Chronological Order Page: 3
PORT WASHINGTON Docwnts
Oocuvnt Nuiber: WAS-W3-1B7 To HM Date: 11/16/63
Title: (Utter supporting 19/22/63 letter recooeending additions be ude to the concent order relating
to subsurface Migration of pollutants fra site)
Type: CORRESPONDENCE
Author: Caputo, John A: Port Washington Hater District
Recipient: Schafer, Jacqueline E: US EPA
Attached: WAS-«3-lB9
Docwent Hmtien WS-W3-1C6 To 1C56 Date: 11/26/83
Title: Landfill Meeting (attendance list)
Type: ODCR
Author: none: none
Recipient: none: none
Oocwent Nurter: UfiS-«3-lt54 To 1C5 Date: 12/12/83
Title: (Letter co«pllining about the sloii pace by rfiich positive corrective Kasures are being i^ilevnted
at the Town of North Heapstead Landfill)
Type: CORRESPGNDQC
Author: Youdclian, Robert A: Residents for a More Beautiful Port Washington
Rtcipient: Scnafer, Jacqueline E: US EPA
Oocwent N«ber: UAS-M3-1C3 To 1C3 Date: C/U/84
Title: (Letter urging EPA to enforce the appropriate action to §et the TOM of North tapttead to
agree to ivediate the Port Washington Landfill)
Type:
Condition: NRRSINRLIA; NIS5IIG AHAOICXT
Author: Nosenchucfc, Norun H: MY Oept of Enviromental Comervation
tacipient: Librizzi, Hilliai J: US EPA
-------
19/26/89 Indtv Chronological Order Pap: 4
PORT MSHII6TQN Docwnts
Oocueent fcaber: WS-«1-«178 To 1*76 . Date: 16/11/84
Titlt: Reecdial Action taster Plan
Type: PLAN
Author: Ziawrwn, Gregory L: M£ Corporation
Recipient: none: US EM
Attached: WS-M1-I477
Donamt Nia^er: HfS-«l-M77 To K88 P«rent: UP5-«1-<17B Datt: r/25/84
Title: (Lttter forward ing attadttd Apsponws to the Public Covamts on the First Draft of tht Ae*dial
Action Nasttr Plan)
Type: CORRESPONDED
Author: ZiaMnan, Gregory L: NUS Corporation
kcipicnt: Rub, Robert: US EPA
Docwnt Nwber: UAS-Ml-««3 To 1677 Me: 14/11/85
Title: Broundwater Modeling Study
Type: PLflN
Author: Ziiaenan, Gregory L: M£ Corporation
kcipient: none: US EPA
Bocoent Nurter: yRS-«3-ll3l To IBl Datt: 17/12/85
Title: (Letter requesting certain itees pertaining to the preparation of the RI/FS Work Plan)
Type: CORKSP90QCE
Author: Iheoli, Nicnwlr CMP Omier t IkKee (CM)
hcipient: Stubing, Henry t: North htapctctd NY, Tow of
Docvent ftarter: WS-t»3-ll3E To 1152 Data: r/C/85
Title: Landfill CflC Neetin| Uttendance list)
Type: ODD
Author: none: none
Recipient: none: none
-------
19/26/89 Indci Chronological Order Page: 5
PORT MSHIKTON Oocwents
Oocuvnt ftaber: UPS-M3-1M9 To 1*58 Date: 17/13/85
Title: (Letter forwarding attached list of villages and special districts netded for the Coewnity
Inforution program)
Type: CORRESPOKDEfCE
Author: Cuminghai, Bert J: North Hecpsteid NY, Town of
Recipient: Hauptian, felvin: US EPA
Docuecnt Nurter: HPS-W3-1I48 To 1146 Date: 16/23/85
Title: Landfill CAC Meeting (attendance list)
Type: ODER
Author: none: none
Recipient: none: none
Docuvnt Nwber: yPS-tt3-ltt7 To 1147 Date: tt/28/85
Title: (Litter regarding co«ents on Port Washington Draft Work Plan)
Type: CORRESPONDENCE
Author: Foltin, Uilliai Robert: NY Dtpt of Environmental Conservation
Recipient: Als, Eoward 6: US EPA
Oocuent Nvber: URS-«3-il4£ To 1146 Date 16/39/85
Title: (Letter confining telephone conversation concerning extings nth the Town's engineers)
Type: CORSESPOKDEJCE
Author: Oal, Eiil Ft C«p Dresser IIWM (CM)
hcipient: Delaney, John Ft North htapctead MY, Town of
Oocuexnt Nwfaer: URS-ft3-lf42 To 1144 Me: 19/19/85
Title: Otao Memariiing 19/12/85 Port Uuhington eroandwter Nodelin« Meeting)
Type: CDWESPOKJEJCE
Authori Als, EAonJ 6: US EM
Recipient: none: US EPA
-------
19/26/89 Ind*« Chronological Order Page: 6
PORT yASHINETQN Oocuecnts
Oocwnt Nurter: yAS-883-1841 To 1941 . Date: 19/23/85
Title: Unifill CAC Meeting (attendance list)
Type: OT>£R
Author: none: none
Recipient: none: none
Oocwent Number: UftS-883-1838 To 1048 Date: 19/2/85
Title: (New iwarizing 89/16/85 Port Hashington Landfill Sas Netting)
Type: OWRESPQKDENCE
Author: Alt, Edward 6: US EPA
Recipient: NcCabe, Uilliai: US EPA
Oocwent Nuiber: UAS-ee3-1835 To 1837 Parent: UAS-M3-1833 Date: 18/87/85
Title: (Letter regarding information requested at 18/81/SO eceting betMeen COM and Geraghty t Miller)
Type: CORIC5PONDENCE
Author: Hauptian, Ntlvin: US EPA
Recipient: Delaney, John F: North He^sttad NY, Tom of
Oocwent Nutber: UAS-881-867B To 8814 Pvent: UAS-«l-86at . Date: 18/2/85
Title: Remedial Investigation/Feasibility Study Vork Plv Volue* 1
Type: PLAN
Author: Dul, Eiil F: CMP Dresur t McK» (COM)
Recipient: none: US EPA
Docwnt N«ber: HAS-881-8£88 To 8S81 Oitu 11/25/85
Titles (Letter nbiitting U/FS Uork Plan)
Type: CORfESPONDENCE
Author: Dul, Eiil F: Cae* Dreiier I NcKM (COM)
•Kipient: Alvi, N Shaheer: US EPA
Attached: UASH81-8678 «S-881-«15 WS-tt 1-8671
-------
19/3/89 Index Chronological Order Pagei 7
PORT HASHIN6TON Ooc«ents
DociKnt Nuiber: HAS-«1-M15 To I8£9 Parent: UPS-Ml-KM Date: 11/29/85
Titlt: Responses to Questions Raised in Connection »ith Draft Work Plan for Reavdial Investigation/Feasibility
Study
Type: ODCR
Author: none: none
Recipient: none: none
Oocueent Nwber: «S-«3-1833 To 1834 Date: 11/89/85
Title: (Letter notifying that EPA is planning to conduct RI/FS activities at the Port Washington
Undfill site)
Type: CORRESPONDENCE
ConditioT,; KISSING flnflOieWT .
ftuthor: Librizzi, ailJlss J: US EPfl
Recipient: Kiernan, John B: North Hapstead NY, Town of
Attached: WS-flU-lKS . ,
Doctavnt Nurter: HftS-«3-1816 To 1832 Date: 11/31/85
Title: (Letter forwarding attached Evaluation of Applicability of Tom of North htepctead Modeling
Efforts to RI/FS Requirewnts)
Type: CORRESPONDENCE
tethor: Dul, EiilT: Caep Dresser t Md
-------
19/26/69 Index Chronologic*! Order Ptge: 6
PORT UA9UNETON Docutcnts
Docutcnt Muter: HAS-W3-1812 To 1112 Date: 11/21/85
Titlf: Landfill CAT. Netting (attendance list) .
Typt: ODCR
Author: rant: none .
Recipient: rant: none
Oocuecnt Mater: UAS-M3-1I1I To 1111 Parent: yRSHtMWfe Date: 12/14/85
Titlt: (Letter requesting state funds to pre-fininct a portion of the RI/FS, so that retadial studies
can begin)
Type: CORfiESPONDENCE
Author: Daggett, Christopher J: US EPA
Recipient: Uilliais, Henry 6: NY Dept of Environtental Conservation
Oocuecnt Nuter: yftS-«3-lWfl To 1869 Date: 12716/85
Title: (letter regarding extension of tit* to revie* the RI/FS Work Plan, and the expectation that
EPA nil! proceed oith the Hork as outlined therein)
Type: CORRESPONDENCE
Author: Dolan, Robert F: North htopstead NY, Tom of
Recipient: Hauptun, Nelvin: US EPA
fecutsnt Nutter: UAS-M3-1M7 To 1W7 Date: 12/16/85
Title: Landfill CAT. Meeting (attendance list)
, . m
Type: ODER
Aathor: none: none
Recipient: rant: none
Bacevnt Nutter: WSHU-lItt To 1M6 Date: 11/19/86
Title: (Letter in recporae to 12/14/85 letter regarding pre-finvcing txhanisi for the rtaedial
studies it Port HMhintton Landfill)
Typt: CORRESPOfflEJCE
Author: Uillim, Henry 6: NY Oept of Environtental Conservation
RRipientt Daggctt, Christopher J: 1C EPA
AtUcntd: US-483-iill
-------
19/26/83 Intel Chronological Ordtr Page: 9
PORT MSHICTQN Doc«mts
Docwnt Krtxr: »S-e*3-«7a To «978 Oitu C/2S/86
Titlt: Landfill CSC Meeting (attendance list)
Type: OT>CR
Author: now: none
Recipient: none: none
Oocwnt Nuber: MfiS-«3-«971 To 0971 Parent: WS-M3-f97f Date: K/28/86
Title: (Letter requesting proapt action in approving Superfund rtauthorization to prevent farther
delays in the hazardous Mstt cleanup proem)
Type: CORRESPONDENCE
Author: frazek, Robert J: US Congress
Recipient: Dingell, John D: US Congress
Docvent Nurter: URS-«3-«978 To 1978 Date: 13/16/86
Title: (Letter regarding Superfund toxic-waste cleanup reauthorization)
Type: CORRESPONDENCE
Arthor: frazek, Robert J: US Congress
Aicipier.';: ftbel, Fred: US EPfl
Attacned: IAS-«3-l971
Docvent Nurter: UP£-ie3-t%9 To 1969 Date: fc/17/86
Title: (Letter regarding the development of landfill gas ecmtoring for the Port Washington site)
Type: COPJESPQWIOCE
Arthcr: Dul, Eli 1 Ft Ca* Dresser I NcXte (OH)
••cipitntt flit, Edward 6: UB EPfl
fecwnt *Mbfr: WS-MM96S To l%8 Parent: MB M3 KP» Date: 17/11/86
Title: (Letter objecting to the fact that the Tow of North tapstead nftsed a CRT. nqwtt to attend
the enting nth EPA)
Type: CORHESPOOQCE
Condition: IMEINALIA
Arthor: VanOosfn, Patrieii: Citizens1 Advisory Coeiittet
kdpient: Dagjett, Chrittopher J: US EPA
-------
19/36/83 Indei Chronological Order Page: it
PORT U&DCTIM Docuents
Docwent Kurter: WS-«3-l%7 To 0967 Date: 17/11/86
Tit It: Attendance - fceting at Town Hall, EPA and Tom Representatives
Type: OTJCR
Author: nont: none
Recipient: none: none
OocuKnt Nuaber: WftS-«3-l959 To 1966 Dttt: 17/14/88
Title: (Port Washington Landfill Site Conwnity Relations IqrieKntation Planning taorandia)
Type: CORRESPONDENCE
Author: Pohl, Racnel L: ICF Incorporated
Recipient: Johnson, Lillian 0: US EPA
Docwent Nuiber: UftS-«3-«954 To 1958 Date: 17/15/66
Title: (Letter regarding working relationship aaong EPA staff, Tom officials and the Citizens' Advisory
CoaittM)
Type: CORflESPONDE)CE
Author: Kieman, John B: North tapstead NY, Tom of
tecipient: Daggett, Christopher J: US EPA
Attached: «ftS-«3-e%a
OocuKnt Nwfaer: UAS-M3-I973 To 1«2 Date: 16/21/86
Title: tanranda of Understanding bttwen the State of to York and the US Environjvntal Protection
Agency for RvedUl Planning Activities related to the Port Washington Landfill Site
•
Type: LEBPL DOQJGfT
Author: Nosenchuck, Noraan H: NY Dept of Enviromental Conservation
hcipient: Loftig, Stephen Oi US EPA
Docwent Nutter: WAS-«3-t952 To 1953 Date:
Title: Otao retarding action itm thai are being rnolved to progren nth the II)
Type:
Author: &ul, Eiil F: Casp Drtsser t fcftee (OH)
AKipient: Als, Ednani 6: US EPA
-------
I9/2&/89 Index Chronological Order Page: 11
PORT if&INETO Docwents
Docwent Nutter: MAS-«3-W48 To 1958 Date: 11/29/86
Title: (letter posing questions relating to existing *11 const net ion used to seasure volatile organic
contamination in the site vicinity)
Type: CORRESPONDENCE
Author: Ols, Edward 6: US EPA
Decipient: Delaney, John F: North tapstead MY, TOM) of
Docuvnt Niaber: WS-983-fW To 1947 Date: 11/13/86
Title: (Letter regarding deletion of the Southport Mil pup test fro the Final tort Plan, at directed
by EPft)
Type: CORRESPONDENCE
Author: Dul, Eiil F: Cat$ Dresser t NcKee (CDK)
kcipient: All, Edoard 6: US EPA
tewent Ninber: UAS-«l-l87e To 1112 Parent: UAS-Ml-ttae Date: 11/14/86
Title: taedial Investigation/Feasibility Study Uork Plan Vol« 1
Type: PUN
Condition: NW6INPL1A
Author: none: Cwp Dresser I NcKec (COM)
bcipient: none: US EPA
Docwent H«ter: UAS-M1-1I13 To 1253 Parent: HAS-Ml-lllS Date: 11/14/86
Title: hecdial Investigation/Feasibility Study Final Project Operations Plan - Volwe I
•
Typt: PLAN
Arthor: Dul, Eiil F: Cam Dresser I fcXee (COM)
iKipient: none: US EPA
-------
I9/2S/B9
Index Chronological Order
PORT WSHIN6TW Doc-ents
Page: 12
Dccwmt Nwber: HflS-981-1254 To 1735 Parent: US-Ml-lllS
Title: Preliminary Draft Project Operations Plan - Volwe II Appendices
Type: PUN
Author: none: Caap Dresser I NcKee (CD*)
Recipient: none: US EPA
Date: 11/14/86
Docuavnt fcaber: MS-MM744 To 8732 Date: 11/14/86
Title: Volatile Organic Chemicals Acquired Monitoring and POP Sailing Protocols
Type: PLAN
Author: none: none
Recipient: none: none
Ooctavnt Haber: yRS-Ml-1115 To 1816
Title: (Letter suteitting Rl/FS Final Project Operations Plan)
Type: CORRESPONDENCE
. Author: Dul, Eiil F: C«p Dresser ( Ncfet (OX)
Recipient: Alvi, M Shaheer: US EM
Attached: UAS-«1-1813 UftS-Wl-1254
Date: 11/19/86
Docwnt Niafaer: UPS-IB3-9944 To 8945
Title: (HMO regarding Port Washington Landfill Quality Assurance Program)
Type: OKRESPOOBCE
Aathor: Als, Edwrd 6: US EPA
HKipient: Finazzi, Barbara: US EPA
Date: 11/28/86
tewei* NHfaer: HAS-M3H94£ To W45
Parent: W5-«3-*941
Datti 12^4/86
Title: (Letter regarding Port Hashington RI/FS, eipressing concern aboct the possible pollition of
tapstead Harbor)
Type: CORfCSQOOCE
Aathor: Hrazek, Robert J: UG Congren
Recipient: Daggett, Christopher J: US EPA
-------
19/26/89 Indei Chronological Order Page: 13
PORT MAffllNBTON Ooctavnts
Docuecnt Nurter: WS-«3-l9*3 To 1943 Date: 12/16/86
Titlt: (Lftter regarding notification of the coeaanciant of fitld writ by EPA at the Port Washington
L-* Suptrfund iitt)
Type: CORRESPONDENCE
Author: Pavlou, George: IE EPA
Recipient: Nosenchuck, Norean H: NY Dept of Environaental Coma-vat ion
Bocoent Nwber: URS-M3-e941 To 1941 Diti: 12/31/86
Title: (Letter in response to concern regarding the effect of the Port Kashington Landfill Superfund
site on the Mter quality of Heipstead Harbor)
Type: QWESPQNDENCE
Condition: NISSIC RTTAOfCMT
Author: Daggett, Christopher J: US EPA
Recipient: Nrazek, Robert J: US Congress
Attached: HAS-«3-«942 -
Docwmt Niaber: HAS-ttl-1938 To 133S Parent: UASH81-19K Date: 11/89/87
Title: (Letter regarding groundnater sailing and eonitoring proctdures)
Type: CORRESPONDENCE
Author: KacCallio, Douglas R: Geraghty I Miller
Recipient: Stubing, Henry 0: North He^stead NY, Tom of
Oociawit Niaber: MS-W3-491& To 1917 Parent: HA5-«3-«91S Date: 11/29/87
Title: (Letter regarding requested information concerning proundHater eonitoring procedures at the
North Hnpstead Landfill)
Type: CORRESPONDENCE
Author: NacCallia, Douglas R: Beragtty I Miller
Recipient: Stubing, htnry 0: North Hnpttead NY, Tow of
-------
H/26/89 Index Chronological Order p«ge: 14
PORT UASHINfiTDN Docwnts
Docuent Mater: UPS-M3-9918 To W39 Parent: US-M3-4915 Date: 11/29/87
Title: (Utter and attadwd report in response to 11/29/66 letter regarding Landfill gas eonitoris-j
prograi)
Type: CORRESPONDENCE
Author: Conrad, E T: SCS Engineers
Recipient: Stubing, Henry D: North tapstead NY, Tow of
Docueent Nurter: URS-M3-4948 To «5W Date:
Title: (Fore letter announcing drilling of sailing Hells relating to the investigation of soil,
air, and groundnater in the vicinity of the Port Washington Landfill)
Type: CDRRESPOKDOC
Author: Als, Ednard S: US EPA
fecipient: none: resident
Docwnt Nurter: yRS-tt3-«lS To 1915 -, Date: C/19/87
Title: (Letter forwarding information requested in 11/29/86 letter)
Type: CORRESPONDENCE
Author: Delaney, John F: North Hnpstead NY, Tom of
•ecipient: Als, Edward 6: US EPA
Attached: UAS-WH916 WS-«3-«18
OocHent NMber: UAS-M3-I912 To 1914 Date: K/23/87
Title: (Nev> regarding External Veil Casing Decision for «11 no. Ill)
Type: CORRESPONDENCE
Author: Als, EdnanJ 6> US EPA
fccipient: none: US EPA
r: WS-H3-K12 To 1912 Date: C/25/B7
Title: Landfill CAC Anting Attendant List
Type: 07>€R
Acthor: none: none
kcipient: none: none
-------
19/26/89 Inriti. Chronological Oro>r Page: 15
PORT UASHINETCM Docuaents
Docwent Mutter: UPS-«3-9%3 To 1984 Date: 14/11/87
Titlt: (Superfund Update reviwing activitits of the Port Mashington Landfill lite and announcing
•5/87/87 public wrkfhop)
Typt: CORRESPONDENCE
Author: Als, Edurd 6: US EPA
hcipient: none: nont
Oocutcnt Mutter: WS-W3-I985 To 1916 Dati: 14/11/87
Titlt: (Map and tables relating to staples taken fro* area affected by spill at site)
Type: SMPHIC
Author: none: Ca*p Dresser t NcKee (OM)
iecipient: none: none
Ntvfaer: U0S-n3-t982 To f3K Date: 14/31/87
Title: (Fora letter announcing tne installation of a landfill gas eonitoring wll relating to the
investigation of soil, air and groundnater in the vicinity of the Port Uashington Landfill)
Type: CORRESPONDENCE
Author: Als, Ednard 6: US EPA
Iecipient: none: resident
DocuMitt Nutter: WS-?*3-r»3 To 1981 Date: B/ffi/87
Title: (Letter regarding the rationale for the installation of grovndnatrr eomtoring «11 111)
Tyi»:
Author: D«l, Eiil Ft CHp Drmtr t Nctat OU
hcipifnt: Ali, EdMard 61 US EPA
Oocwnt Nuftter: WS-H3-K11 To 1911 Date:
Title: (Fora letter announcing installation of watering «lls relating to the invwti§ation of
the Port Uasflington Landfill)
Typt:
Author: NcCabe, Hilliai: UE EPA
ipient: none: North HMpstead Country Clob
-------
19/3/89 Indei Chronological Order Pap: 16
PORT HASHI«TON Docwents
Docutcnt ftfttcr: UfiS-W 1-1749 To 1985 fcrent: HAS-W1-1731 Date: 16/19/87
Titlt: Updatid Revdial Investigation/Feasibility Study tor* Plan Volue* 1
Type; fy*
Author: >:1, Eiil F: C*p Dresser I NcKee (CM)
hcipitnt: nont: US EPA
Oocwnt t*-t*r: UAS-M1-17S1 To 1732 Datt: K/23/87
Titlt: (Lttttr forwarding Updated RI/FS Work Plan)
Type: CORRESPONDENCE
Author: hi, Eiil F: Cup Dresser i NcKee (CM)
HKipient: Alvi, N Shaheer; US EPA
Attached: UfiS-eei-1749
Docwnt *mbrr: UftS-«3-W?3 To 1699 Datt: 16/25/87
Titlt: (litter reaarding changes in tht Work Plan for Port Vashington Landfill Site)
Type: CORRESPONDENCE
Condition: IIOKPLETE
Author: none: CMP Dresser i NcKee (CDM)
•ecipient: Alvi, N Shaheer: US EPA
Bocwent Kurter: MfiS-«3-M96 To M98 Dati: r/21/87
Titlt: (MHO regarding Double Casing Decision for BM fell 119)
Type: CORRESPONDENCE
Author: Alt, Edwrd 6: US EPA
hcipierrt ' none: US EPA
Bocwtnt NMber: WS-M3-f696 To M97 Dtttt 18/11/87
Tit It: (Litter confining prior telephone conversation regarding findings of dna>ed Mite eat trials
on TOM property)
Type: CORRESPONDENCE
Author: Oolan, Robert Ft North Hnpsttad NT, Tom of
kcipient: Alt, EdMrt 6: IE EPA
-------
19/26/89 Index Chronological Order Page: 17
PORT itiSHINBTON Dociaentf
Oocuecnt *Mtxr: WS-W3-M95 To M95 Diti: 16/13/87
Titlt: (Fon letter notifying of the scheduled installation of a landfill gas •onitoring as mil
as part of the investigation of soil air, and gramdMtrr in tht vicinity of tht site)
Type: CORRESPONDENCE
Author: Als, EdMrd 6: US EPA
Recipient: none: resident
Oocuecnt Nwfaer: WS-«3-l891 To 1894 . Date: 18/19/87
Title: (Letter explaining the rationale for the location of landfill gas Monitoring Mils 1211-214)
Type: CORRESPONDENCE
Author: Dul, Eiil F: Cam Dresser I fcfee (COM)
Recipient: Als, EdMrd 6: US EPA
Docuecnt Nwfaer: UflS-«3-ie98 To 1698 Date: 16/27/87
Title: Attendance List
Type: OT*€R
Author: none: none
Recipient: none: none
Docwent ttrtxr: UAS-«3-lfi89 To 1689 Date: 19/17/87
Title: (Letter forwarding Draft POP Addenda I regarding protocols and procedures for obtaining samples
froi existing Mter District Mils for review and coeaent)
Type: CORRESPONDENCE
Condition: HISSINB ATTACK-NT
Author: Als, Edward 6: US EPA
Recipient: Dilaney, John F: North He^ftead NT, TOM of
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19/36/89 Index Chronological Order Page: IB
PORT UASHIN5TCM Docwnts
Oocwent Nwber: HAS-W3-8888 To 1888 Date: 19/18/87
Titlt: (Letter regarding the planned transportation of eicavated taterials fra the l-5/ne» all
eicmtion art* at the Landfill)
Typt: CDRRESPQHDEICE
Author: Lifter, ThoMS K: US EPA
Recipient: Oolan, Robert F: North Hnpstead NY, Towi of
Oocuvnt Ntober: yRS-tt3-ia85 To 1885 Parent: WS-WM883 Date: 19/28/87
Title: (Letter forwarding POP Draft Addendui regarding sampling protocols and related quality assurance
objectives for groundwater nnitoring Mils and landfill gas Mils in the vicinity of the site)
Type: CORRESPWDQCE
Condition: N1SSIME ATTAOtCNT
Author: Als, Ed«ani 6: US EPA
Recipient: Coakley, Uilliu: US EPA
DocuKnt Nuber: yftS-ea3-*887 To 1887 ~ Date: 19/29/87
Title: (Attendance List)
Type: OTJCR
Author: none: none
Recipient: none: none
fecwent N«ber: WS-«3-l8S5 To Mtf Pvent: UAS-«3-«63 Date: 11/16/87
Title: (Utter regarding coeaents on OM POP - Addend* I)
Type: ORRESPOCOCE
Author: Barber, Andrew J: Sertfhiy I Killer
•Kipient: VAntonio, UilliM J: North feepvtud NY, TOMH of
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•9/26/89 Indti Chronological Order Page: 19
PORT UA94IN5TON Dociaents
DocuKnt Nuitaer: «S-«3-W67 To 1881 Parent: WS-W3-W63 Date: 11/16/87
Titli: (Letter regarding coMents on the draft Project Operations Plan - Addend* I)
Type: CORRESPONDENCE
Author: Conrad, E T: SCS Engineers
fccipient: Stubing, Henry 0: North He^stead NY, Tom of
Oocwent Nwoer: UPS-M3-t856 To 1639 Parent: UR5-M3-I8S7 Date: 11/13/87
Title: (Letter posing questions regarding the discovery of a large mailer of containers of toxic
petroleia-based products at the L-5 landfill area operated by the Town of North Heapstead)
Type: CORRESPONDENCE
Author: Nra:ek, Robert J: US Congress
Ihcipient: Daggett, Christopher J: US EPA
DoctMnt Nuiber: UOS-M1-17X To 1748 Parent: URS-Hl-1738 Date: ll/a/87
Title: Project Operations Plan Addendia 4 - Analytical Protocol for Landfill Gas Collected in Sow
Canisters
Type: PLAN
Author: none: Cap Dresser 4 NcKee (CDH)
lecipient: none: IE EPA
Oocwent Naber: «S-iE3-4S63 To 1664 Date: 11/22/87
Title: (Letter forward ing wit ten ccoents on the Project Operations Plan Addendui I and information
froi the TOM'S files relating to LFB -ells)
»
Type: CORRESPONDENCE
Author: Delaney, John F: North HMpitead NY, Tom of
Ihcipient: Als, Edwrd 6: IE EPA
AttacfMd: IHS-eB3-l865 WS-i*3-ltt7 HAS 1*3 <66C
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•9/26/89 Index Chronological Order
PORT WASHH6TON Docuvnts
Docuent Number: WAS-«1-1738 To 1738 Date: 11/23/87
Title: (Letter forwarding Project Operations Plan Addendum 4)
Type: CORRESPONDENCE
Author: Dul, Eiil F: Camp Dresser I NcKee (COM)
Recipient: Alt, Edward 6: US EPA
Attached: WK-«1-1736
Document Number: WAS-M3-I882 To 1662 Parent: UflG «3 <6G3 Date: 11/13/87
Title: (Letter requesting additional information on Port Washington Hater District Mils)
Type: CORRESPONDENCE
Author: Dul, Eiil F: Caip Dresser I fcfee (CM)
Recipient: Casey, Thons J: Henderson t Casey
DocuMnt H«btr: HPS-«3-«8£3 To 1883 Date: 11/13/87
Title: (Letter requesting additional information on Port Washington Water District wlls)
Type: CORRESPONDENCE
Author: Dul, Eiil F: Cae*i Dresser I NcKee (CM)
Recipient: Thader, Richard: Hydrogroup
Attached: URS-«3-*684 WPSHt3-«S8S
Docwent Numter: WAS-fe3-iB84 To M84 Parent: HAS-M3-M83 Dait: 11/13/87
Title: (Letter requesting additional information on Port Washington Water District «lls)
Type: CORRESPONDENCE
Author: Dul, Eiil F: Camp Dresser t NcXee (DM)
•Ripient: KM, William: Port Washington Water District
»
Document Number: WOG M3-J8CI To Mtt Me: 11/14/87
Title: (Letter forwarding attached eaps showing the location of pressure probe mills it the landfill
site)
Type: CORRESPONDENCE
Aothori Dul, Eiil F: Camp Dresser t NcXcc (OH)
•Ripient: Ms, Edwrd 6: US EPA
-------
/a/89 Indei Chronological Order Page: 21
PORT MASHINBHM Doctaents
Docwent *»ber: WS-9B3-ieS7 To 1657 Dttt: 11/16/87
Titli: (Letter in response to 11/19/87 letter regarding druB discovered at the new field area of
the Port yashington Landfill, and foniarding a partial response fro* the Tom of North htepstead)
Type: CORRE5PONDBCE
Condition: MISSING ATTACHCMT
Author: Daggett, Christopher J: US EPA
Recipient: Nrazek, Robert J: US Congress
Attached: WS-«3-«85B
Oocueent Ntataer: UPS-M3-I656 To HS6 Parent: UAS-M3-I651 Date: 11/Z3/B7
Title: (Letter requesting Informational Meeting uith Colonial Sand ( Gravel to obtain information
on Mils and sand Hashing ponds near site)
Type: CORRESPWDGCE
Author: Oul, Eiil F: CMP Dresser i NcKee (CDM)
Recipient: Als, Ed«rtj G: US EM
Nwber: UP£-«1-1986 To »*4 Date: 11/31/87
Title: Project Operations Plan - Addenda I, Revision 2
Type: PUN
Author: Dul, Eril F: Cae^ Dresser I McKce (COM)
Recipient: none: US EPA
Attacned: WS-Wl-1338 W6-«l-1941
Docwnt *mtxr: WSHU-1853 To 1654 Parent: HAS-H3-ieSl Date: 12/11/87
Title: (*•> regarding Pressure toll Installations Port at Washington Landfill Site)
Author: Vbgt, U Gregory; SCS Engineers
•Kipient: 0* Antonio, Hilli« J: North htapftead NY, Tom of
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19/26/89 Indei Chronological Order Pagt: 22
PORT VASHIN5TQN Donecnts
Docueent Nurter: UPS-«3-l8S5 To KS3 Parent: HRS-W-ttSl Date: 12/12/87
Title: (Utter forward ing the EPA-approved Project Operations Plan Addendum, which specifically address
tht sampling protocols that EPA Hill folloa rfiili tatpling will)
Typt: COffiESPQNDOC
Condition: NISSINE ATTAOfCHT
Author: Alt, EdMrd 6: 1C EPA
hcipient: Delaney, John F: North Hopstcad NY, Tom of
DocMent Niober: yAS-M3-l8Sl To K52 tatc: 12/16/87
Titlt: (Lrtter forwarding no regarding placing of pmturt prates)
Type: CORRESPONDENCE
Author: Dclaney, John F: North Hnpstead NY, Tom of
HKipient: Als, Edward 6: US EPA
Attached: MAS-O3-4853
Oocaent Naber: UAS-«3-«35 To MSB Datt: C/13/Sfl
Title: (Litter and attached graphics regarding calculations of depth of pressure prate Mils at Port
Washington landfill site)
Type: CORRESPONDENCE
Author: Dul, Eml-F: Cup Dresser t NcKee (CM)
Reel pint: Als, Edward 6: US EPA
Bocwent Nuwter: VAS-tti-f&U To 1834 Date: e2/tt/88
Title: (Litter requesting information relating to EPA's ongoing reeedial investigation and feasibility
study of the Port Uashington L-4 landfill)
Type: CORRESPONDENCE
Author: Als, Edward 6: US EPA
•Ripient: Oelaney, John F: North Heepste^ NY, Tom of
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19/26/89 Index Chronological Order Page: 23
PORT UASHINSTON Docwents
fecwent Nuiber: «S-H3-H3e To 1632 Date: K/18/88
Title: (Letter regarding determination of optiM drilling depths for the five boreholes that EPA
intents to drill into the L-4 landfill)
Types CORRESPONDENCE
Author: Alt, Edaard 6: U5 EPA
RKipient: Delaney, John F: North tapstead NY, Tom of
Oocuent Nuiber: URS-W3-»627 To 1829 Date: 12/16/88
Title: (Letter regarding puap test in the area of the Port Washington landfill and initiation of
the pressure probe drilling prograi)
Type: OSTCESPONDGCE
&rthor: Als, EdMrd 6: US EPA
RKipient: Oeliney, John F: North Hnpctead NY, TOM of
Oocwnt Miate". yAS-803-1622 To U26 Date: 6/17/88
Title: (Letter supplewnting 11/16/87 response to 11/19/87 letter regarding drtas discovered at the
ne« field area of the site)
Type: CORRESPONDENCE
Condition: NISS1NB AfTAOICNT
tethor: Daggett, Christopher J: US EPA
lecipient: Nrazek, Robert J: US Congress
fecwent Nwber: WS-«3-«eia To «19 Me: 13/11/88
Titles (Letter requesting that a NYSDOH representative attend a health risk assessvnt wrkshop in
C/88)
Type: CORRESPONDENCE
Aethori Als, Edwrd 6: UB EPA
lecipient: Travntano, Renald: NY Dipt of htolth
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09/26/89 Indei Chronological Order p«gt: 24
PORT WSHIWTDN Docaents
Docuecnt Number: HAS-M3-4&28 To 1821 Date: 13/11/86
Titli: (Letter requesting that a representative from *te County Health Department attend a health
risk tstfstwnt «orkshop in B/86)
Typti CORIC5PONDENCE
Author: Alt, Ediunj 6: US EM
fecipicnt: Dwlinj, John J: Nassau NY, County of
Ooctoent Nwfaer: UPS-«2-K55 To 1729 Partnt: WS-M2-46S7 Dati: 13/11/86
Titlt: Rnedial Investigation Preliminary Field Data Vol-.w I
Type: DATA
Author: none: Caip Dresser t NcKee (COM)
Recipient: none: US EPA
Oocwent Nuefter: WS-982-1657 To K57 tete: 13/11/86
Title: (Letter suteitting RI Preliminary Field Data Voluee I)
Type: CORRESPONDENCE
Author: Oul, Eiil F: Caip Dresser i NcKte (CM)
Recipient: AM, M Shaheer: US EPA
Attached:
Docwent Nwber: WS-M3-I817 To 1617 Date: 13/25/86
Title: (Letter requesting that NVSKC indicate rfut it btlievn are state ARARs for the Port Uuhinfton
Landfill)
Type:
ABthort Alt, EoWrd 61 U6 EPA
cipient: Foltin, Hilliai Robert: NY Otpt of Envirotvntal Conorvition
fcraent Nueter: »S-«3-l613 To M16 Me: 13/31/86
Titltt (Letter fomarding attached inriei for Volw I and II of Nn York BUte ARARs)
Type: CORRESPOMOCE
Aothort Rodabaugh, Scott: NY Dept of EnviroiMntal Conservation
Recipient: Als, EdMrd 6: US EPA '
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19/26/89 Index Chronological Order Page: 25
PORT MAffllHSTW Docuvnts
Oocuecnt Nueier: HAS-«3-Mll To 1812 :_ Dtte: B/ll/88
Title: (Superfund Update regarding activities at the Port Washington Landfill lite and announcing
K/I1/B6 CAC eceting)
Type: CORRESPONDENCE
Author: Als, EdMrd 6: IE EM
Recipient: none: none
Docwent Nwber: UAS-M3-4608 To 1609 Date: 16/11/88
Title: (Letter requesting a eceting with the Torn of North He^ntead and iti cowiltantt, and a tour
of the L-4 and L-5 landfill artas)
Type: COWESPONDENCE ;
Condition: DRAFT . •
Author: none: Citizens' Advisory Coeiittee
Recipient: Kiernan, John 8: North Heapstead NY, Town of
Docuecnt Nueier: UAS-tt3-f61l To 1819 Date: K/fl/88
Title: EPA Superfund Port Uashington CAC Meeting (attendance lift)
Type: OD£R
Anther: none: none
Recipient: none: none
Docwnt Nuefter: «S-«3-l8a7 To 1607 Date: K/K/B8
Title: (Letter to Congressional staffer requtsting help in arranging a eceting nth Chris Daggett
of EPA and Congressaan Pt-azek)
Type: COHESPOOEXI
Avthor: NarfeMski, Ellen: Rnidents for a Nort Beautiful Port Washington
Recipient: Norvan, David: 16 Congress
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89/26/89 Index Chronological Order Page: 26
PORT HA94INETON Docueents
Docueent Nwber: WS-«3-«e3 To M84 . Date: ft/19/88
Tit It: (Lrtter regarding laboratory results of EPA first round of sailing perfected under the taedial
Invest lotion of the Port Washington Landfill L-4)
Type: CORRESPONDENCE
Condition: WSSIN6 ATTAWCNT
Author: Forquer, Betty: Port Washington, Water District -
Recipient: Ms, Ednard 6: US EPA '
OociKnt Nuiber: IMS-«3-«605 To 1686 Date: K/ai/88
Title: (Letter rtgarding aifaient air testing at the landfill dowwind of the site, and in the surrounding
' " ' ''
Type: CORRESPONDENCE
Author: Tietz, Larry 0: Port Washington Union Free School District
kcipient: Als, Edward 6: US EPA
Docwent Nwter: MAS-983-1882 To Ntt Date: 17/17/88
Title: (tao regarding Health Consultation, Port Washington Landfill)
Type: CORRESPONDENCE
Author: Johnson, Denise: Agency for Toxic Substances I Disease Registry (ATSDR)
•ecipicnt: Mullen, Brooks: US EPA
Docvent Nurter: t*S-f*2-*75fi To I7SB Pvtnt: WS-«2-f73l Date: 17/11/88
Titlet (Letter approving Health and Safety Plan)
Type:
Author: Dul, Eiil Ft Ca^i Dresser I fcKa* (CM)
Recipient: Prosser, Richardi Mandeville I Associates
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•9/26/89 Index Chronological Order Page: 27
PORT ynSHINETON Docwnts
Docwent Nwber: WS-W3-6S86 To 1681 Date: 17/13/88
Title: (MHO regarding request for landfill gas analytical services fro* EFT)
Type: CORRESPONDENCE
Author: Pavlou, Seorge: US EPA
Recipient: LaFoaara, Joseph: US EM
Docwent Nuiber: «S-W£-8738 To 1758 Datt: 17/14/88
Title: Project Operations Plan Addendm 6 - Landfill 6as Collection and Venting Systei Aiwsiacnt
Type: PLflN
Avthor: Dul, Eiil F: Co? Dresser 4 ft*** (OM)
Recipient: none: US EPA
Attached: MS-M2-<75£
Oocwent Nuiber: UAS-ie3-e799 To 1799 Date: 17/19/88
Title: Sign-In Sheet
Type: OKCR
Author: none: none
Recipient: none: none
Bocioent Nuber: yAS-«3-l797 To 1797 . Oatt: I7/Z1/88
Title: (Litter regarding delay in obtaining inorganic data froi the M/88 groundwater sampling caepaign)
Type: CORRESPOfflGG
Arthor: Dul, Eiil F: Caef Dresser t NcKee (ON)
•Kipient: fllvi, N Snaheer: US EPA
fcraent NieAer: WS-«l3-l73e To 17% Me: 17/26/88
Title: (Letter regarding 17/21/88 eMting concerning vent syitei assesoent status - options for
future activities)
Types P^^fS^mf^T
fethor: Dul, Eiil F: Caep Dresser I NcKee (ON)
•Kipient: fllvi, H SnaAeer: US EPA
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19/26/69 Intel Chronologic*! Order Pip:
PORT iflSHINBTO Documents
Docuecnt Nurter: yflS-MHTtt To 1768 4ate: I7/Z7/B8
Titlt: (Letter fomarding attached data sheets relating to off-fiti ligration of landfill faces)
Type: CORRESPWDBCE
Author: Dul, Eiil F: Caip Dresser I NcKee (CM)
lecipient: Als, EAortJ 6: US EPA
Oocuetnt Nuiber: HPS-883-1789 To 1789 Date: 17/37/88
Title: Atterdance List - EPA/Port Kashington CAC Mnting
Type: OT)£R
Author: none: none
Recipient: none: none
Oocwent Nurter: UAS-n3-i738 To 1791 Date: 17/27/88
Title: (Letter docueenting attee$ts to secure copies of the blow fog book(s) fro the Tout of North
tapftead)
Type:
Author: Dul, Eiil F: Ca^i Dresser I NcKee (ON)
kcipient: Alvi, N Shaheer: US EPA
Docwnt Nwfaer: WS-H3-I782 To TS4 Date: M/C/8B
Title: (Njao regarding sueaary of 17/19/86 eeeting at Congrenean Nrazek's office in Huntingdon,
MM York)
Type: CDRJESPDCOCE
Author: Alt, Eriwnj 6t UB EPA
kcipient: Pavlou, Seorte: IB EPA
Bocwnt Nueter: W6HI>f7SB To 1738 fcti: teVe/88
Titles Oetter requesting a edteaatic of the Hter diftribution syitn for Port Vufiin|ton, and the
criteria eMd to start particular pueps into operation)
Typei
Condition: N1SSINB AHAOICNT
Aitnor: Dul, Eiil F: Cwp Dmier I NcKee (CM)
hcipient: Forquer, Betty: Port Hashington Hater District
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19/26/89 Indei Chronological Order Page: 29
PORT UASHIttSTON Docuwnts
Booavnt Nwfer: WP£-«3-«753 To ITS? Oitf: W/16/M
title: (We Information Request Letter) '
Type: OJWESPQNDEJCE
Author: Luftig, Stephen D: IE EPS
hcipient: Delaney, John F: North fempstead NY, Tom of
Boraent Number: WS-«3-«773 To 1777 Parent: W6-H3-I774 Date: M/16/86
Title: (Letter regarding/Depth to GroundMter in Active Hells - Evaluation of the LFB Extraction
Systai - RI/FS at the Port Ua«hington LH Landfill)
Type: CORRESPONDENCE
father: Vbgt, U Gregory: SCS Engineers
fccipient: D!flntonio, Uilliai J: North He*4»stead NY, Tom of •
Docwent Nu^er: yp£-«3-4779 To I78« Date: «/17/afl
Title: (Neeo regarding special service request for the Port Washington LF Superfund Site)
Type: CORRESPONDEICE
Condition: MISSING ATTPWCHT
Author: Als, Edwrd B: US EPP.
•ecipient: Pritchard, Thoaas H: IS EPA
lociMnt Nueter: yRS-«3-l778 To 1778 Date: M/18/88
Title: (Letter forwarding plans and specifications for Tom of North tapstead's phase 1 rehabilitation
and enhancement of the active gas venting system on the Port Washington LF)
m
Type: CORKESPDNKNCE
Condition: USSIM3 ATTAOtCNT
tothort Als, Edward 8: IE EPA
fccipienti Bedwrer, Robert: KY Dept of Environmental Conservation
-------
19/26/89 Indtx Chronological Order p«ge: 38
PORT URSHIN6TQN Docwnts
Docuent Nwber: «AS-«e3-l774 To 1774 , Oiti: I8/S/88
Titlt: (Letter forwarding information regarding eetsureeents.of groundNttr depths in various
Type: CORRESPQMDQ^E
Author: Delaney, Jof.n F: North Hnpcttad NY, Tonn of
kcipint: flls, EdMrd 6: US EPA
attached:
Docwnt Nwber: WS-M3-4771 To 1773 Datt: 19/16/86
Titlt: (Ltttcr in response to IB/16/88 letter lite)
Type: CORRESPQNDOTE ,
Condition: HISSING ftTTflCHCNT
Author: Delaney, John F: North Hapftead NY, Tom of
tea pint: Als, Edward 6: US EPA
Oocwent Nofaer: yRS-Pe3-f77e To 1771 Dite: 19/16/88
Title: (AnnognceKnt rejarding 19/14/88 Health Risk Assesoent Korkshop)
Type: CORRESPONDENCE
Author: Alt, EdMard 6: US EM
RKipient: none: no..?
Docwnt *mtxr: UAS-«3-4768 To 1768 Date: 19/14/88
Title: Attendance List - EPA Risk AssMSvnt Workshop
Type: OTtCR '
Author: nonet iw«
Recipient: none: none
Nwber: WS-H3-*769 To 1769 Bite: 19/14/88
Title: (Anou/Leetnl regarding air SMples to be taken in the vicinity of the Port Uashington Landfill)
Type: CffWf^ffBPCF
Author: Fareit, Isabel: US EPA
Recipient: nonet none
-------
19/26/89 Index Chronological Offer Page: 31
PORT UASHIKTON Ooctavnts
Oocwent Nurter: WAS-f83-t763 To 1763 Date: 19/16/88
Title: (Letter forwarding WHO detailing the scope of Hrvicet to be performed by EPA11 Environswt
Response Teai at the Port Washington Landfill Superfund Site)
Type: C09JC5PQNDQCE
Condition: NISSIN6 ATTAWOT
Author: flls, Edward 6: US EPA
teipient: Delaney, John F: North tapstead NY, Tom of
Oociwnt ftarter: WS-«3H7&4 To 1767 Oaie: 11/16/88
Title: (few regarding TABS Monitoring at Port Washington)
Type: C08RESPQM3QCE
Author: Mickunas, David B: Weston Environmental Consultants Designers
kcipient: flls, EoWrd 8: US EPA
vent Nwfaer: UAS-N3-«76a To 1762 Date: 11/17/88
Title: (Letter confining prior discussions regarding side slope flux »*sui i«nts)
Type: COMESPONDOCE
Author: Hyde, Robert A: dff Dresser t NcKee (CDN)
iKipient: Alvi, N Shaheer: US EPA
feoavnt Nwfaer: WASHI3-I7SS To 1761 Date: 11/19/88
Title: (Letter providing update on the activities of the UEEPA at site based on the decisions reached
during the 17/19/88 SMting at the Huntington District Office)
Condition: NISSINB ATTAOICNT
Avthori Huszymki, Hilliai J: US EPA
hcipient: fra:ek, Robert J: 1C Congress
-------
19/26/89 Indei Chronological Order Pap: 32
PORT UA94INETON Oocuecnts
Oocwnt Nwber: HAS-«2-«759 To «% ._ Date: le/ll/88
Titlt: TflGR Analysis of Mint Air in the Vicinity of the Lindfill at Port Washington, NY - Final
» --*
wpon
Type: PLAN
Art her: Nickunas, David 8: Roy F Unton Inc
Recipient: Pritchett, Thous H: US EPfl
OoctKnt Nurter: UAS-4e-4637 To 1973 . Dati: ia/ll/86
Title: Port Washington Sum* Canister Final Report
Type: PLPN
ftathor: Nickunas, David B: Roy F itorton Inc
Recipient: Pritchett, ThoHs H: IE EPA
Attached: WS-W2-0974 yAS-nS-1349 HAS-IC-1491 WSH82-1S39 WS-fK-1752
Docoent Nuber: HAS-M2-«74 To 1248 Parent: MAS-n2-M97 Date: 12/11/88
Title: Port Washington Sumi Canister Report Appendices B-D
Type: DATA
Author: none: none
Recipient: none: none
Ooctmt tarter: UAS-«2-1249 To 1491 Parent: WAG M2 1077 Date: 12/11/88
Title: Port Washington Sueia Canister Report Appendii A
Type: DATA
Atthor: none: none
Recipient: none: none
Docvent Nvber: HAS-«3-f729 To 1741 Parent: UAS-M3-I725 Date: 12/11/88
Title: A Final Swary Report on the Soil Vapor Sorvty - Port Washington, MM York
Type: PUM
Asthor: Coepton, Hnry R> IB EPA
Recipient: none: none
-------
19/3/89 Index Chronological Order Page: 33
POST UASHIMSTON OocuKnts
Docuvnt Nurier: HAS-083-0727 To 0728 Parent: MS-M3-0725 Date: 18/15/38
Title: (Letter forwarding USEPA's final report on the toil gas survey perforwd on 19/21/88)
Type: fflWCSPWDENCE
Author: Als, Edward 6: US EPA
Recipient: frndela, Tony: NY Dept of Environmental Conservation
fccwent Number: yAS-0e3-0725 To 0726 Date: 12/14/88
Title: (Letter forwarding USEPfl's final report on the soil gas survey performed on 89/21/88 in the
Seaview Industrial Park)
Type: CORRESPONDENCE
Author: Als, Edward 6: US EPA
Recipient: Schiergel, F Uilliai: Sctnergel Enterprises Corporation
Attached: UAS-083-4727 UAS-0e3-0729
Oocuwnt Nuiber: UAS-003-0724 To 0724 Date: 12/16/88
Title: (Letter requesting additional information in connection nith USEPfi's ongoing investigation
of the Port Washington Landfill L-4 Superfund site)
Type: CORRESPONDENCE
Author: Als, Edward 6: US EPA
Recipient: Oelaney, John F: North Heipstead NY, Town of
Docuvnt Niober: UAS-M3-0722 To 0723 Date: 11/13/89
Title: (Letter regarding topics discussed at 12/06/88 mting between NYSDEC/EPA and To-n of North
tapstead representatives)
Type: QJRRESPODENCE
Author: Als, Edward 6: US EPA
Recipient: Candela, Tony: NY Dept of Environmental Conservation
-------
19/26/89 Index Chronological Order Page; 34
PORT WASHINGTON Docuvnts
Doctaent Nuaber: MAS-«3-«721 To 8731 Date: 11/11/89
Title: (Letter forwarding eattrials requested in 12/16/88 letter)
Type: CORRESPONDENCE
Condition: MS5INB ATTACHMENT
Author: Delaney, John F: North Heipstead NY, Tom of
Recipient: Als, EdMrd B: US EPA
Oocuecnt Nwber: yftS-«3-f720 To 1720 Date: 11/17/83
Title: CAC Meeting Attendance (list)
type: OTHER
Author: none: none
Recipient: none: none
Docuent ftober: UAS-WH719 To 1719 Date: C/83/89
Title: (For* letter announcing 12/21/89 Citizens' Advisory Coeaittee feeting)
Type: CORRESPONDENCE
Author: Als, Ednard 6: US EPA.
Recipient: none: none
Docwent Nurter: HAS-«1-2W5 To 2269 Date: 13/11/89
Title: Draft Remedial Investigation Report Appendices - Voluec I
Type: PUW
Condition: DRAFT
Author: mm: CMP Drwier I fcKn (CDH)
Recipient: none: IS EPA
Attached: HA6-«81-227I VK 9K mi WS-H2-C98 UAS-M2-1BS2 MRS H3 tMl HAS M3 H13
DocwntHater: WS-«1-£27I To 2S67 Parent: W5-M1-2M5 Dite: 13/11/89
Title: Draft inrfial Iiwicti|ation Report Appendices - Volw II
Type: PJ*
Condition: DRAFT
Author: none: CMP Dresser I NcXce (CM)
Recipient: none: US EPA
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19/26/89
Intel Chronological Order
PORT yPffllNSTON Oocwnts
Page: 35
Docunnt Nurter: «AS-«2-Wl To 8297 Parent: UPS-M1-2M5
Title: Draft Reeedial Investigation Report Appendices - Voliae HI
Type: PLAN
Condition: DRAFT
Author: none: Caip Dresser ( Ndtee (COM).
Recipient: none: IS EPA
Date: 13/11/89
Docwnt Nurter: URS-«2-«29a To 8654 Parent: UPS-881-2885
Title: Draft Reeedial Investigation Report Appendices - Volioe IV
Type: PLPN
Condition: DRAFT
Author: none: CMP Dresser I McKee (CDM)
Recipient: none: US EPA
Date: 13/91/89
Docwent Nurter: MftS-9e2-1491 To 1S38
Title: Port Ibshington Staea Canister Final Report
Type: PLAN
Author: Mickunas, David B: Roy F Ueston Inc
Recipient: Pritchett,- Thoeas H: US EPA
Parent: UftS-«2-«97
Date: 13/11/89
Doctevnt Nueter: yAS-«82-1539 To 1751 Parent: UAS-<82-8697
Title: Port Hashington Sou Canister Report Appendix A
Type: DATA
Author: none: none
Recipient: none: none
Date: 13/11/89
Oocwnt Nuete-: 1*6-188-1752 To 1851 Parent! HAS H2 M97
Title: Port ttuhinjton Saw Canister Report Appendices BH>
Type: DATA
Author: none: none
ipient:
Date: 13/11/89
-------
19/26/89 Index Chronological Order Page: 36
POTT yRSHINBTQN Documents
Doctoent Nuber: MAS-«3-8718 To 8718 Date: 13/14/89
Title: (Letter in response to 12/22/89 letter regarding the disposal of leachate contaminated groundHater)
Type: CORRESPONDENCE
Author: Vogt, Robert U: Port Islington Hater Pollution Control District
Recipient: Als, Edward 6: US EPA
Document Nuiber: yAS-883-8714 To 8714 Date: 13/23/89
Title: (Letter confining telephone conversation regarding an alternate medial eeasurt to be considered
at L-4)
Type: CORRESPONDENCE
Author: VanDusen, Patricia: Southport Civic Aisociation
Recipient: Als, Edward 6: US EPA
Docioent Nuiber: HAS-«3-8717 To 8717 __ Date: 83/23/89
Title: (Font letter regarding public availability of the draft RI report for review and coeaent)
Type: CORRESPONDENCE
Condition: HISSING ATTAQ4CNT
Author: Als, Edward 6: US EPA
Recipient: none: none.
Docwent Nurier: UAS-883-8713 To f713 Date: 85/82/89
Title: (letter forwarding 'contract docwents for Additions to the L-4 Sanitary Landfill Gas Control
Systea* for review and coeacntl
r
Type: CORRESPONDENCE
Condition: HISSING ATTAQICNT
Author: Vrana, Robert Ji North Hnpstead NY, TOM of
Recipient: Als, Ednard 6: US EPA
-------
1/26/89 Index Chronological Order Page: 37
PORT HASHIMSTW Docwents
OocuKnt Nwber: VRS-«M71I To 0710 Date: 05/12/89
Title: (Fon letter announcing the 05/24/89 eeeting of the Port Washington Landfill Superfund site
citizens' advisory coemttee)
Type: CORRESPONDENCE
Author: none: US EPA
Recipient: none: Citizens' Advisory Coeaittee
Docwent Nuaber: UftS-W3-i711 To 0712 Date: 05/12/69
Title: (Letter confining agreement regarding information needed involving recent town initiatives
at L-4)
Type: CORRESPONDENCE
Author: Als, Edward 6: US EM
Recipient: Delaney, John F: North Heipstead NY, Town of
ioent Nuiber: WS-083-0788 To 0709 Date: 05/24/69
Title: (Letter in response to 05/02789 letter pertaining to the contract documents for Additions
to the L-4 Sanitary Landfill Sas Control Systw)
Type: CORRESPONDENCE
Author: Als, Edward. 6: US EPA
Recipient: Vrana, Robert J: North He^tstead NY, Tom of
Oocuecnt Nuaber: UfiS-«E-1852 To 2106 Parent: UAS-«l-20tt> Date: 16/11/89
Title: Final Remedial Investigation Report Appendices - Voluee V
Type: PLflN
Author: none: Cam Dresser I NcKee (ON)
Recipient: none: US EPA
-------
19/26/69 Index Chronological Order p^e: 38
PORT WSHINETQN Oocuaents
Docwnt Nmber: MflS-«82-£187 To 2W8 Paretf;: HK-W2-21W Date: J6/I1/89
Title: Draft Feasibility Study Report
Type: PUN
Condition: DRAFT
Author: Bouvette, Tracy C: Caap Dresser I Ncfee (COM)
Recipient: none: US EPA
DocuKnt Nmber: HRS-W3-W1 To 1379 Parent: UAS-M1-2MS Date: 86/81/83
Title: Final Reiedial Investigation Report
Type: PLAN
Author: Bouvette, Tracy C: Cai? Dresser ( fcKee (COM)
Recipient: none: US EPA
Docwnt Itaber: yAS-e83-f785 To 1787 Date: 16/18/89
Title: (Letter in response to K/12/B9 letter pertaining to the proposed reconstruction of the blotter
house and compressors, and general details of the torn initiative regarding 1-4)
Type: CORRESPONDENCE
Author: Delaney, John F: North Heipstead NY, Town of
Recipient: Als, EdHard.6: US EPA
DocuKnt Wmberi UAS-«3-«e3 To 1883 Pannt: UAS-M1-2885 Date: K/19/83
Title: (Letter sufaiitting Final Remedial Investigation Report)
Type: CORRESPQNOENCE
Author: Hyde, Robert Ai Cae? Dresser » NcKee (CDM)
Recipient: Alvi, N Shaheer: US EPA
fioraent N^ier: yAS-«2-21f9 To 2119 Date: K/21/89
Title: (Litter subiittini Draft Feasibility Study Report)
Type: CORRESPONDENCE
Author: Hyde, Robert A: Caip Dresser I Ndtee (ON)
Recipient: Alvi, N Shaheer: US EPA
Attacned: WS-«e-21l7
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1/26/69 Indei Chronological Order . Page: 39
PORT HASHIWTON Docwents
DOCUKT* Nuaber: HAS-«3-«38t To K93 Date: 16/27/63
Title: Endanger«nt Assessment
Type: PLPN
Author: none: Clearnt Associates
Recipient: none: CMP Dresser I fcKee (CDM)
Docuwnt Kmber: UftS-ee3-K94 To 1794 Date: 17/11/W
Title: (Superfund Update announcing Proposed Revdial Action Plan - Port Vashington Landfill Superfund
Site)
Type: CORRESPONDENCE
Author: flls, Edward 6: US EPA
Recipient: none: none
Nunber: HAS-W3-1111 To 1221 Date: tt/19/89
Title: Minutes of the Public Hearing Held at the Carrie Utter Junior High School, Port Washington
NY
Type: LEGAL DOOJCNT
Author: Raios-Zayas, Cynthia: Court Reporter
Recipient: none: none.
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APPENDIX 4 - NYSDEC LETTER OF CONCURRENCE
-------
:-cr ~iC-
New York State Department of Environmental Conservation
SO Wolf Road, Albany, New York 12233-7010
Thorns* C Jortlng
Commissioner
Mr. William J. Muszynski, P.E.
Acting Regional Administrator
Emergency and Remedial Response Division CCD 0 Q
U.S. Environmental Protection Agency our 60
Region II .
26 Federal Plaza .
New York, NY 10278
Dear Mr. Muszynski:
RE: Record of Decision (ROD)
Port Washington Landfill #130025
The New York State Department of Environmental Conservation (NYSDEC) has
reviewed the draft Record of Decision, dated.August 31, 1989, for the Port . ..
Washington site and concurs with the remedy as follows:
1. Closure of the L-4 landfill area in accordance with 6 NYCRR Part 360
• Regulations for Solid Waste Management Facilities which include requirements
for landfill slopes, cover materials, gas collection systems and ,
gas/groundwater monitoring. These requirements limit the selection of gas
source control to the perimeter gas collection systems outlined in the
remedy.
2. Rehabilitation and extension of the existing active gas venting system
to accommodate the entire perimeter of the L-4 area, including an additional
combustion unit as standby, and rehabilitation of the existing active gas
venting system.
3- Placement of extraction wells in the area of the upper glacial aquifer
where elevated levels of groundwater contamination were found.
4. Treatment of extracted groundwater through metals removal and air
stripping prior to discharge to a recharge basin or leaching pit.
5. Treatment of the Southport well through air stripping prior to discharge
into the Port Washington water distribution system.
6. Installation of additional groundwater monitoring wells to aid placement
of the proposed extraction wells. Additional groundwater and landfill gas
wells around L-4 are to be used in conjunction with the existing landfill
gas and groundwater monitoring network in order to comprehensively monitor
L-4. . ..:•.';•. / ;
7. Development and conduct of a post-closure operation and maintenance plan
which will govern those remedial actions selected in this ROD as well as
those presently employed for the L-4 section.
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-EP'-iS-lrc'r 13:1',' i-rui-l (41 '3. c.: ;=-;iK. '..ji ire..-- 'H i ;._•!;. . - ,._
Mr'. William J. Muszynski, P.E. . . :_-.' Page 2
8. This remedy will result in hazardous substances remaining on-site above
health-based levels, so a review will be conducted no later than five
years after commencement of remedial action to ensure that the remedy
continues to provide adequate, protection of human health and the
environment. : -
In order for New York State to concur with the final ROD, the following
provisions must be included in the document:
9. Air monitoring beyond the gas collection system is necessary. AIT
passive vents used in the remediation process will also be subject to
air regulations.
10. Any emissions resulting from air stripping of the groundwater are required
to meet air quality standards, and emissions are to be monitored to
determine compliance.
11. Additional groundwater and gas investigations wi.ll be conducted; including
areas to the north and northwest of the site to further determine the
extent of volatile organic and inorganic plumes. The RI did not fully
determine the extent of contamination, and these investigations are:
needed to define extent of remediation.
12. The Southport well will not be used as th- primary aqui fer-.clfecuiup-.wen .
13. Allowance for sampling of surface water and sediments in Hempstead Harbor
and determining the fish and wildlife impacts should either the volatile
organic and inorganic, plume be found to be discharging into Hempstead
Harbor. : . ,' • :.'.."
14. The drum area known to be on-site will be addressed including identifying
its contents, location relative to 1-4, and extent of any release of
contamination from the drums.
15. Modification of treatment alternatives is expected for additional
on-site or off-site gas migration and volatile organic and inorganic
plumes not yet defected.
Should you have any questions on these issues, please call Mr. Michael J.
O'Toole, Or., P.E., at 518-457-5861.
EdwardUO. Sullivan
Deputy Commissioner
cc: VL McCabe
E. Als
D. Garbarini
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APPENDIX 5 - RESPONSIVENESS SUMMARY
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RESPONSIVENESS SUMMARY
PORT WASHINGTON LANDFILL
Port Washington, N.Y.
The U;S. Environmental Protection Agency (EPA) originally
scheduled a public comment period from July 21, 1989 through
August 21, 1989 for interested parties to comment on EPA's final
Remedial Investigation/Feasibility Study (RI/FS) and Proposed
Remedial Action Plan (PRAP) for the Port Washington site.
:However, due to the large volume of material contained in the
RI/FS and PRAP, EPA honored requests to extend the comment period
3.0 days through September 20, 1989'.
EPA held a public meeting on August 9, 1989 at the Carrie Weber
Junior High School on Port Washington Boulevard, New York to
describe the remedial alternatives and present EPA's proposed
.remedial action plan for cleaning up the Port Washington site.
Numerous questions were raised and addressed at the public
meeting. A transcript of the meeting is part of the
Administrative Record for the site and documents those questions
addressed at the public meeting. Other comments received during
the comment period, as well as those not addressed during the
public meeting, are summarized and responded to in the
responsiveness summary. All comments will be considered prior to
the selection of the remedy for the Port Washington site.
The comments have been summarized and organized into two major
categories: Proposed Plan and Remedial Investigation/Feasibility
Study; and nine subcategories: Landfill Closure, Landfill Gas
Control, Groundwater 'Remediation, Environmental Monitoring
Program, and Operation and Maintenance; Remedial Investigation,
Feasibility Study, Endangerment Assessment, and Miscellaneous.
COMMENTS ON PROPOSED PLAN
Landfill Closure
Q: All plans for regrading or capping of the site must '
insure the maintenance of the haul road which serves as an
air break and prevents additional gas migration toward the
adjacent neighborhood. Odor control should also be a
consideration when closing L-4.
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A: This comment is noted and will be addressed during
development of the closure plan.
Q: Storm water runoff from the L-4 site and from a
significant drainage area, located west and northwest of L-
4, ponds at a location along the western boundary of L-4.
A: EPA's preferred remedial alternative for source control
(<:-3) incorporates closure as one of the main elements.
Because closure of the L-4 parcel must conform with 6 NYCRR
Part 360 requirements, it must of necessity include capping
of L-4 with a low density material, typically either
compacted clay or a synthetic material. One of the purposes
of such a cap is to minimize to the extent possible the
amount of infiltration which can seep into the landfill
through its cover. Therefore, given the fact that the
landfill will be capped, seepage into the landfill under the
scenario as suggested by the Port Washington Water District
should be essentially eliminated.
With respect to stqrmwater runoff, the existing grading plan
at L-4 results in ponding along the western boundary with
resulting seepage into the landfill. To alleviate this
condition, a grading plan will need to be developed, after
Lhe selection of a capping material, and included as part of
the overall closure plan for L-4. One possible grading plan
was included in the FS as Plate 1. It can be noted upon
review of this plate that existing ponding conditions along
the western boundary were taken into account. Stormwater
runoff under a proper grading scenario will be directed from
the
L-4 -cap and to a properly sized retention pond. At present
the size and location of such a pond has not been
determined. Similarly, the point of discharge of the
retention basin contents has not been finalized pending
discussions with the various agencies involved in this
decision-making process.
Q: In order to comply fully with NYSDEC regulations and the
33% design limitation, the L-4 property line must be
extended outward Joy at least 110 feet beyond the Town's
existing property line. This will require the taking of
property from portions of the golf course, the Wakefield
neighborhood, and possibly the Seaview property.
A: EPA understands from communications with the NYSDEC that
a waiver to this provision may be available under 6 NYCRR
Part 360 if certain criteria are met e.g., side slope
stability, assurance of adequate drainage, etc.
The 33% side slope requirement will be further evaluate
during development of the closure plan.
-------
Q: The interior cap vents should be located away from the
interior gas extraction wells to the extent possible, to
minimize the potential for air intrusion into the extraction
system.
A: This comment is apparently based on the selection of G-4
as part of source control (interior vents). The SELECTED
REMEDY has recognized the need to develop an acceptable
supplemental fuel source to assist in maintaining continuous
combustion at the HCU. This supplemental fuel source may
eventually be provided by utilizing interior landfill
extraction wells as called for under the G-4 alternative.
At that time, the location of the extraction wells could be
selected such that air intrusion from passive capping vents
would be minimal.
Q: The use of geosynthetics should be included for
consideration as an alternative material for final capping.
A: This comment is noted and will be addressed during
development of the closure plan.
Q: Passive vents should be installed in conjunction with the
new cap for the L-4 landfill. These vents should be vented
to ambient air, since improvements in the gas extraction
system will result in reduced surficial emissions.
A: Passive vents are required under State closure
regulations. A minimum of 1 vent per acre of cap is the
specific requirement. Therefore, passive vents will be
designed into the cap during the development of the closure
plan. They will also be monitored after closure, at least
initially, to insure that the emission levels of any
hazardous gases, will not pose a threat to public or worker
safety.
Q: An extensive RI/FS was not required to conclude that a
Part 360 cap is appropriate for the Landfill. L-4 should
have been capped in 1985 at the latest.
A: EPA's involvement at this site between the time of site
placement on the National Priorities List in 1983 and the
development of EPA's workplan in 1985 was as enforcement
support for the NYSDEC, and afterward as primary enforcement
lead. A decision to close and cap L-4 during that period
would have had to have been the result of a signed consent
order with the Town of North Hempstead, which did not occur.
In May, 1985, EPA began development of a workplan to
-------
investigate the site consistent with the National
Contingency Plan through the use of CERCLA funds. Moreover,
upon completion of the workplan in October, 1985, EPA
offered the Town the opportunity to perform the RI/FS, which
the Town declined to do.
One of the concerns raised during EPA1s development of the
workplan for this site was the effect capping might have on
enhancing lateraj. gas migration from L-4. EPA considered
this a valid concern, and therefore sought to evaluate it
during the RI and FS process. EPA developed a final
workplan for this site in October, 1985, but was unable to
initiate fieldwerk until December, 1986, because of the lack
of funding appropriations while CERCLA was being
reauthorized.
The chronology of EPA's involvement at this site made a
remedial decision by EPA in 1985 on the capping issue
impossible. Closure and capping could only have occurred at
that time as the result of a signed order with the Town of
North Hempstead and the regulatory agencies (EPA and
NYSDEC).
Since 1985, the State of New York has amended its closure
requirements (6 NYCRR Part 360, amended in 1988) to
significantly upgrade the capping requirements for sanitary
landfills. This action has played a significant part in
EPA's decision to use state closure regulations as the
applicable or relevant and appropriate requirement to close
(and cap)
L-4 . .' ' ..•;;-.
Q: The specific design requirements for closure set forth in
the FS are excessive. They are not always required by or
consistent with State Part 360 regs. The ROD should only
determine that a Part 360 closure plan should be developed
in cooperation with and subject to the approval of NYSDEC.
•
A: It is EPA's intent to be consistent with the State Part
360 regulations in terms of closure for L-4. Moreover, EPA
intends to develop the closure plan in cooperation with the
NYSDEC, and to develop a plan that is mutually agreeable to
NYSDEC (presently the support agency) and EPA (presently the
lead agency).
Q: Flux box sampling was not warranted to determine whether
or not a cap should be placed over L-4.
A: Flux box sampling provided useful data in EPA's attempt
to quantify the emission rates of landfill gas from the top
of L-4. The quantification of these emission rates was used
-------
predominantly in the Endangennent Assessment in air
dispersion models to estimate the ambient air
concentrations associated with the flux of chemicals from
the L-4 surface. EPA agrees that the flux box sampling
would be of limited use in determining whether a cap should
be placed on L-4. EPA relied instead on its assessment of
the design efficiency of the existing active venting system
to make this determination.
Q: EPA must address surface water and erosion control in
more detail.
A: This comment is noted and will be addressed in greater
detail during development of the closure plan.
Landfill Gas Controls
Q: EPA has not allowed the Town to proceed with the gas
control system extension which would control landfill gas
which may be migrating into the Seaview Industrial Park
.•' - : - .area. •
A: The extension of the gas control system should normally
be implemented pursuant to an agreement under section 122 of
CERCLA after a Record of Decision has been finalized for the
site. Such an agreement would constitute authorization to
the Town of North Hempstead as required in Section 122 (e)
(6) of CERCLA, and would assure the Town and the Public that
the Town will not be undertaking inconsistent response
action. Obviously, under circumstances involving an
immediate threat to public health or the environment and/or
which may constitute an imminent and substantial
endangerment to public health or welfare or the environment,
EPA could either take a removal action or authorize/order
the Town to take action to abate the circumstances posing
threat or danger. The circumstance most obviously
applicable in this case would be one in which an acute fire
or explosion hazard existed.
The issue of subsurface gas migration in the Seaview
Industrial Park area was the focus of a meeting held in
December, 1988 among the EPA, NYSDEC, and the Town of North
Hempstead. At the time, EPA had just finalized a report
containing validated srmpling results which indicated the
presence of substantial amounts of methane in the northwest
corner of the Industrial Park. It was agreed that the
situation was potentially serious, and that a monitoring
program should be commenced to analyze on a frequent basis
for the presence of explosive gas within the potentially
affected structures. NYSDEC personnel initially undertook
this monitoring program, with the understanding that the
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Town would eventually assume this role, with NYSDEC then
providing oversight pursuant to their statutory authority.
The Town has verbally indicated to EPA that, based on the
results of the NYSDEC's and the Town's sampling, no
explosion hazard has existed within the subject buildings
since the initiation of the monitoring program.
Q: The remedial measures explored and proposed for gas
control are exclusively renovations and upgrading of the
existing venting system employed by the Town. Do more
effective or ideas exist i.e., slurry walls? Should the
slurry wall be placed in refuse or native soil?
A: The suggested use of slurry walls would entail excavating
an approximately 3 foot wide trench around the perimeter of
landfill parcel L-4 from the ground surface to the water
table. The wall would then be "keyed" into the water table
so as to prevent landfill gas in the unsaturated zone from
migrating vertically beneath the wall and escaping into the
off-site environment. This wall would of necessity be
installed in native material and not in the refuse. The
refuse material likely contains many void spaces and it
would be difficult to establish a continuous wall in such a
media. Secondly, the native soil which is excavated is
usually mixed with a bentonite clay and reintroduced to the
trench as a soil/bentonite mixture. It is this mixture
which then forms the slurry wall. Excavating refuse instead
of native soil will require the importation of soil to make
up this mixture. Thirdly, excavating a trench in refuse
will likely cause caving of the trench walls, create odors,
and leave an excavated refuse mass which needs to be
disposed of. Clearly, there are advantages to the
installation of a slurry wall in native soil as compared to
the installation of such a wall in refuse.
After a review of current land surface elevations at the L-4
parcel to the elevation of the ground water table at the
site, it is estimated that the wall would generally need to
extend to depths ranging from approximately 25 to 35 feet
along the eastern border of L-4 up to 130 feet at well
locations LFG-202, TNH-4 and TNH-6.
Installation of a slurry wall to a depth of 130 feet raises
concerns about the integrity of the wall and hence the
reliability and effectiveness of such an installation.
While vendors of such construction services claim to be able
to install walls to such a depth, the difficulty of such an
operation often leads to "windows" or holes in the finished
wall due to sloughing of the sidewalls of the excavation.
The presence of any windows clearly will negate the purpose
of the wall and render it an ineffective means of subsurface
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landfill gas containment, it has been EPA's experience at
one CERCLA site in EPA Region II where a slurry wall
installed to a maximum depth of 40 feet for hydraulic
containment experienced side wall sloughing with a resulting
100 fold decrease in the design permeability.
Another concern with using slurry walls to contain landfill
gas migration in lieu of an active venting system is the
difficulty posed in interpreting off-site landfill gas
monitoring data and making adjustments to the remedial
scheme. That is, with an active vent system as proposed in
the FS, should the off-site monitoring wells show
unacceptable levels of landfill gas the amount of gas flow
at each active vent can be quickly measured, the presence of
sediment or water covering a vent screen rapidly assessed,
and the radius of influence of each vent tested in a timely
manner to assure an overlap with each neighboring vent. In
this manner the effectiveness of the active vent system can
be readily analyzed, the specific area along the vent system
where there are difficulties identified, and modifications
and adjustments to the system operation quickly made. On
the other hand, with only a slurry wall in place, a rapid
correction in response to the presence of landfill gas off-
site cannot be made. This data would only inform the
operations staff that the slurry wall is "leaking", and
would not indicate specifically where the leaks were
occurring. To correct this situation would require that a
new wall be installed in the area of the suspected "leak"
arid keyed into the existing wall. Certainly, the time to
implement such a solution would be unfavorable when compared
to the more rapid response time available when using an
active venting system.
Therefore, EPA believes that extraction and control of
landfill gas via a series of active vents as included in the
source control alternatives described in the FS is a more
effective and reliable means of controlling landfill gas
migration. In addition, EPA believes that the design of the
present active .venting system is sufficient to protect
public health, given the proper operation and maintenance
(incl. continuous blower operation).
Q: EPA must include sealing of slabs in residences abutting
the site as an immediate safeguard to be included as part of
the proposed remediation measures.
A: EPA believes that the SELECTED REMEDY, which includes as
part of its operation and maintenance provisions the
continuous operation of the compressor station, will
safeguard the residences abutting the site, not only from
long-term health effects but also from acute threat of fire
or explosion.
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Q: Source control alternative 0-3 does not adequately
protect public health and the environment, since it (as well
as alternatives 0-1 and 0-2) are continuations of past or
current practices which have proven in the past to be
ineffective in controlling gas migration. Any of these
three source control alternatives will result in enhanced
lateral migration after placement of a landfill cap.
Therefore, 0-4 should, be selected, which includes gas
extraction from the interior of L-4. These gas extraction
wells should be placed on the eastern side of the fill. The
use of propane supplemental fuel under 0-3 may not be cost-
effective.
A: EPA does not agree that the O-3 alternative is not
adequately protective of public health and the environment.
However, EPA recognizes that continuous operation of the
HCU, if warranted, may require a supplemental fuel source.
The only supplemental source of fuel under O-3 is commercial
propane gas, which may not be cost-effective when compared
to other supplemental fuel sources.
EPA recognizes that the provision for interior gas
extraction wells under 0-4 is a possible source of future
supplemental fuel. Therefore, the SELECTED REMEDY addresses
the potential utilization of interior gas extraction vents.
Q: It is questionable whether the existing system can be
upgraded to insure a firm gas supply while maintaining gas
pressures at a level low enough to prohibit or severely
restrict offsite migration of gas from the landfill. There
should be greater redundancy built into the expanded system.
A: It is estimated that the addition of 37 wells around the
perimeter of the landfill will add 600 additional SCFM to
the new blower station's loading. EPA generally estimates
that an average of 4 blowers will operate under the SELECTED
REMEDY.
To determine redundancy, the minimum reliability of the
system needs to be determined. At other landfills where
receptors were not as close, several days downtime would not
be a problem; hence no redundancy would be required. Other
times redundancy is looked at very closely and multiple
blowers are installed accordingly. When redundancy is
important but budgets are constrained, one blower may be
installed as a back-up while a second or third blower may be
available at the site for immediate installation. There is
no industry standard for redundancy of blower operation.
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Q: Additional options should be evaluated for disposal
of landfill gas, including the following:
*cleansing and sale to LILCO as fuel
*cleansing and use for local generating capability,
which power could then be sold to LILCO
*incineration in two HCU's, operated alternately.
*incineration in the proposed Resource Recovery
incinerator
*cleansing and use as auxiliary fuel in the proposed
Resource Recovery incinerator.
A: EPA has no objection to any of the various methods of
landfill gas disposal outlined above, provided that they do
not cause contravention of any applicable State/Federal laws
or permit requirements, and does not create any significant
health risks. The scope of the RI involved the assessment
of the present method of landfill gas disposal. EPA's
conclusion was that with continuous combustion no
significant health risks would occur from this method of
disposal.
Q: The complete perimeter gas collection and disposal system
should be installed, activated, tested and. made operational
before capping begins.
Capping should progress in stages most beneficial to
residents of the area and the interior cap vents should be
installed, activated, and made operational before the next
capping stage is begun.
A: A primary concern during the capping operation is
continued control of landfill gas. During the leveling and
closing operation at the landfill there may be a slight
increase in resistance to gas flow in some areas on the
landfill's surface.
To minimize the impact of the capping operation, the first
step should be to upgrade the landfill gas system. This
will consist of regrading the landfill along the path of the
gas headers and installing the closure cap material at these
locations. Once this grading is complete and the gas header
has been reinstalled, the areas between the headers can be
filled to complete the capping operation.
The rehabilitated gas headers may not be where they are
currently located. It may be desirable to build new berms
parallel to the existing header and then move the header.
The construction of these berms should follow the New York
State regulations. Grading for them should be done
according to the closure grading plan.
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Q: The following gas control measures should be evaluated:
*horizontal gas collection in a trench around the
perimeter of the landfill.
*excavation of the solid waste landfilled against the
natural cliff, incineration- or disposal of the
excavated materials in a properly permitted facility
licensed to receive hazardous waste.
A: Horizontal wells can provide an excellent barrier to gas
migration. The disadvantage of horizontal wells is the
limitation on the depth that they can be installed and their
cost.
The depth limitation on horizontal wells is based on the
type of materials being dug and the level of the ground
water. If the materials are sandy then it is likely that
the walls of the trench would collapse. At this site the
very steep side walls of the rock and gravel quarry indicate
that the material is reasonably stable. The ability of the
walls of an excavation to stand when excavating below the
ground water is unknown, however. If caving occurred then
extending the trench into groundwater would not be
practical. Ideally the depth of the trench would extend
below the historical ground water level.
One reason that vertical wells were selected over horizontal
wells was the cost. It was felt that the installation of
vertical wells would be less expensive than horizontal
wells. Part of this is due to the cost of the excavation
and part is due to the safety measures required to keep gas
from escaping through the open cut.
When doing the final detailed engineering, if it is
determined that the depth of the wells is 20 feet or less,
horizontal trenches may be a preferred alternative over
vertical wells. For the purpose of the preliminary design
it was assumed that the vertical wells were 50 feet deep.
EPA believes that the excavation scenario envisioned by the
commenter would not significantly increase protection of
public health over a properly operated gas extraction
system, and would be prohibitively expensive to implement.
Q: The recommendation to put presently disconnected active
vents back into service should be reexamined. Putting these
vents back into service will pull oxygen into the landfill,
creating a fire hazard, while at the same time diluting the
gas collected for HCU combustion.
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A:In July of 1987, EPA performed testing at the Port
Washington Landfill. The following results were obtained:
Well 124 54% Methane
Well 125 55% Methane
Well 126 54% Methane
Well 127 60% Methane
Well 128 69% Methane
The gas extraction rate may be very low from these wells,
hence more sophisticated control valves may be required to
properly regulate the gas flows.
EPA agrees that placing too many wells into service without
proper system balancing creates a risk of underground fires.
In fact one well operating improperly creates a risk of
underground fires. Balancing is an essential part of the
gas system operation, which was previously stated in the FS.
Q: The removal of sediment from the active vents to
improve gas extraction capability has been tried
without success in the past, and therefore should not
be included in the proposed plan.
A: Removing leachate/sediment from a landfill is a very slow
process. Some success may be had by operating pumps
continually over several years. However, a reevaluation of
this aspect of system rehabilitation will be performed
during design.
Q: The need for 37 new active vents to completely ring the
perimeter of L-4 is unwarranted. Specifically, no venting
is necessary to the north and east of L-4, since there is no
development there. The gas extraction system should be
extended along the southern perimeter of the landfill,
however, in order to control gas migration towards the
Seaview Industrial Park.
f •
A: Both EPA and the NYSOEC believe that a perimeter venting
system must be designed for in its entirety because of the
proximity of potential receptors in the area. Gases that
migrate in an initial direction that presently does not
contain any development may eventually arrive under certain
conditions at a receptor. Therefore, both agencies believe
it is a prudent measure to design and implement a complete
perimeter vent system to insure that methane from L-4 does
not migrate offsite. However, this construction may be able
to proceed in stages, based on areas of greatest need i.e.,
the southern perimeter.
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Q: New extraction wells along the western perimeter of L-4
should be installed and tied into the active venting system.
A: The existing perimeter gas wells have s;hown that they are
capable of controlling gas along the western perimeter.
However, the installation of new perimete;: gas vents may be
acceptable in areas where it can be demonstrated that even
with all available rehabilitation methods, certain vents
cannot function as intended.
Q: The EPA recommendation to install a second HCU as standby
does not serve any purpose, since any downtime associated
with the first HCU is caused by insufficient BTU content in
the collected landfill gas, and not because of any problems
with the HCU. :
A: EPA recognizes the abilities of the Town's HCU to perform
efficiently, given an acceptable fuel source. EPA has
addressed the supplemental fuel issue in the 8BLBCTBD
REMEDY. Moreover, EPA believes that the addition of a
second HCU as a standby unit is a prudent measure to avoid
any downtime associated with future maintenance
requirements, or catastrophic failures.
Q: The existing concrete cisterns should be destroyed as
soon as possible to minimize further risks and nuisance to
the public.
A: EPA agrees that if the concrete cisterns are not sealed
or tied into the gas system they do pose a source of risk to
nearby residents. The health risk assessment addressed
these gases. Therefore, they will be either sealed or tied
into the active vent system if it is determined that this is
the most desirable way of maintaining combustion at the HCU.
Connecting the concrete cisterns to the gas system would
require removing the rock from the top 20 feet of cistern,
installing a PVC riser pipe and then backfilling the cistern
with cement grout. The advantage of using the cisterns is
that they collect gas from the very bottom of the landfill.
Q: Reconstruction of the gas header system will involve
temporary removal of system components from service. This
issue should be addressed so as to provide continuous
protection from gas migration during construction of the new
header.
A: This issue was addressed in the FS on pages 4-19 and
4-20.
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Q: Are the replacement compressors adequate to meet the
needs of the gas extraction system.
A: The adequacy of the new blowers will be determined during
the design of the SELECTED REMEDY.
Q: All gas leaks in the header system should be repaired and
condensate traps installed.
A: EPA agrees that this detail will be a focus of the
rehabilitation of the active venting system.
Groundwater Remediation
Q: The proposed plan did not address odor problems
associated with air stripping.
A: EPA did not believe that concerns about odors from the
air stripping tower were warranted, based on the measured
levels of chemicals in the groundwater. In other words, EPA
felt that no odors would be able to be detected, given the
amount of chemicals that would be removed from the
groundwater and subsequently discharged. Conservative
estimates of emission rates of these chemicals from an air
stripping tower indicate that the odor most easily detected
would occur from toluene, which will be emitted in
concentrations approximately 20% less than the odor
threshold value.
However, the issue of odors from the air stripping
operation will be reevaluated again during the design
stage of the project. If warranted, adjustments in the
design stack height and/or air flow rates can be made
to reduce odors.
Q: The plan must address adverse impacts from the
dispersion of VOC's from the groundwater stripping
tower, particularly to homeowners living in the
Wakefield subdivision. How will the impacts be
calculated. How will the emissions be measured, and
how often.
A: The air stripper for the extraction wells will meet all
substantive permitting requirements. During this process,
steps are followed to identify the impacts of air emissions
from the source. This process is known as the Ambient Air
Quality Impact Screening Analysis and is contained in NYSDEC
Air Guide 1. 5 steps, or "screens" are required prior to
permit approval. Air treatment would be required depending
on the results of this analysis.
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The exact method and frequency of testing will be determined
during the design/permitting stage of the project.
Q: What kind of pollution control devices could be added to
the tower. What are their effectiveness and cost. EPA
should not transfer contamination from one environmental
media (groundwater) to the other (air).
A: There are several treatment technologies available
for removal of VOC's from the air stream i.e., vapor
phase carbon treatment, catalytic oxidation, and
incineration. These treatment methods provide various
removals of specific contaminants. Moreover, they are
generally capable of total VOC removals greater than
90%. EPA will meet all ARARs for ambient air emissions
from the proposed air stripping devices. Cost
estimates at this phase of the project would be.
difficult to project: however, a very general estimate
for the extraction well air stripping treatment would
be $200,000/year. .
Q: Will the extraction well implementation accelerate the
movement of existing contamination, including a plume under
-L-5. Could the extraction wells induce salt water
encroachment from Hempstead Harbor.
A: The extraction wells, by design, will only influence the
shallow flow system i.e., Upper Glacial Aquifer in the
immediate vicinity of the wells.
Q: EPA oversight and monitoring of leachate treatment or
control is unclear. Replacement of the existing lagoon
system is long overdue and the future effective treatment
and control of leachate must be insured in the plan. A
leachate balancing reservoir should be added to the new
leachate system, if considered necessary.
A: EPA believes that the closure of the landfill in
conformance with 6 NYCRR Part 360 will effectively address
the problems identified in the RI concerning leachate
control.
For example, capping of L-4 should gradually reduce the
quantity of leachate available for potential release into
the environment.
Details of leachate management involving L-4 closure will be
identified in the closure plan to be developed by EPA and
HYSDEC, or with EPA/NYSDEC oversight of potentially
responsible parties.
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Environmental Monitoring Program
Q: The proposed environmental monitoring plan is
excessive in terms of frequency and testing parameters,
locations of wells, and goes beyond State regulatory
requirements. Specifically, there should be no LFG
wells beyond the Town's landfill property line.
A: According to 6 NYCRR Part 360, the ARAR governing
landfill closure, an adequate closure plan must be developed
which contains in part an environmental monitoring program.
This monitoring program must define "the nature and extent
of current and potential release or migration of
contaminants from the site" and "establish a long-
term. ..well network...to protect public health and the
environment". To this end, the conceptual long-term
groundwater and landfill gas monitoring program as presented
in the FS, was developed.
Specifically, groundwater and landfill gas monitoring well
nests were located to the northwest, north, and northeast of
L-4, in locations potentially impacted by organic
concentration as indicated by the groundwater modeling
exercise. Incidentally, the placement of LFG wells offsite
is a continuation of the existing monitoring strategy for
this landfill. These locations, coupled with wells
constructed at the landfill border will provide valuable
information associated with the extent of observed
contamination which have or may migrate from the L-4
Landfill as required by Part 360. In addition, shallow
monitoring wells are proposed between L-4 and neighboring
public water supply wells which are closest to L-4 as a
means of protecting public health.
Q: A deficiency of the proposed monitoring requirements is
that no ambient air monitoring is recommended by EPA.
A: No ambient air monitoring requirements exist as part of
the 6 NYCRR Part 360 regulations involving landfill closure.
Previous ambient air monitoring has indicated that L-4 is
not a significant source of elevated offsite ambient air
levels of contaminants of concern. Therefore, monitoring
during the RI (as well as any future monitoring) did not
provide useful information to quantify low level risks from
this exposure pathway. Instead, modelling efforts were
employed to quantify the risk.
Any air monitoring requirements for the new passive vents
created as part of the proposed capping of the landfill will
be incorporated into the development of the monitoring
aspects of the closure plan.
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Q: It is inappropriate that post closure groundwater
monitoring be used to complete an investigation that EPA
failed to do i.e., delineate the plume of contamination.
The groundwater monitoring program as proposed is excessive.
A: It *as EPA's intent in the proposed plan to perform
future, groundwater and landfill gas monitoring for several
reasons. Monitoring of releases from L-4 after closure was
one reason. Groundwater monitoring to refine the
positioning of extraction wells, as well as groundwater
monitoring to the north to further define the hydrology and
contaminant transport in this direction were other reasons
for the proposed comprehensive monitoring plan. The part of
the groundwater monitoring plan to further define the
hydrlogy and contaminant transport to the north will most
likely be part of a second operable unit RI/FS.
EPA does not believe that the conceptual groundwater
monitoring plan which appeared in the FS is excessive;
however, issues involving the number and placement of wells
will be reexamined in greater detail during actual plan
development.
Q: What factors will determine the location of proposed
LFG monitoring wells near Salem Lane. Are there public
health hazards associated with constructing these
wells, or sampling them. Specify well sizing and
depth. How long will they take to construct and what
equipment is needed. Who is responsible for
restoration of any damage caused by construction. How
large an area is required for well access, and who is
responsible for access maintenance. Could'tampering
with the wells create a danger to homeowners or to the
environment.
A: A further review of existing information will first be
made to determine the general areas that are desirable for
obtaining information on groundwater or soil gas. Next, EPA
will attempt to,locate specific areas where it would be
physically possible to place a well. Next, access
arrangements would be discussed and arranged with the owner
of the property, including any necessary rights of way.
Finally, utility clearances would be performed in order to
insure agreeable subsurface conditions. Usually, it is
easier to secure access arrangements on public land.
Well sizing for groundwater monitoring wells is usually 4",
while LFG wells are usually composed of teflon tubing one
half inch or less. These details will be specified during
design. Time to drill and depth of wells depend on
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subsurface conditions i.e., presence of incumbrances
(boulders, etc.), depth to groundwater, etc. Again, the
details will be developed during design.
EPA is ultimately responsible for restoration of damages
incurred as a result of contractor's actions. However,
damages are usually paid out of the contractor's contingency
fund or through the contractor's insurance.
During well installation, a health and safety plan will be
in effect which usually specifies that appropriate
instrumentation be on hand to ascertain conditions once the
hole is opened. The method of installation, or the level of
worker protection required is contingent on these readings.
Any tampering with equipment associated with these
investigations should be brought to the attention of EPA so
that an assessment can be made as to danger, repairs, etc.
Operation and Maintenance
Q: Routine inspections, downtimes, and maintenance activity
should all be scheduled, in addition to the present method
of conducting operation and maintenance on an as-needed
basis.
A: EPA strongly agrees with this comment. These types of
maintenance requirements should be incorporated into the
development of the Operation and Maintenance plan for this
remedial action, which will be developed during
construction. EPA recommends also that this type of
maintenance be employed in the interim for the existing
facilities prior to the development of the additional 0 and
M requirements.
EPA has determined that the only necessary operation
requirement to be specified immediately is the continuous
operation of the blower house, as described in the SELECTED
REMEDY.
Q: Performance monitoring of active extraction wells,
specifically for methane and oxygen content, should be
included as part of routine operation and maintenance.
A: Performance monitoring has been recommended by EPA in the
SELECTED REMEDY.
Q: EPA must make a firm commitment to continue maintenance
and monitoring oversight during and after remediation due to
the historical failure of the Town, and the NYSDEC to provide
adequate protection.
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A: In lieu of PRP conduct of the remedial activities with
State oversight, the State is statutorily responsible for
the proper operation and maintenance at Superfuncl sites.
However, EPA still is obliged under the law to perform post
remedial monitoring of site conditions to insure that the
remedial action is effective and working as intended. EPA
plans to pursue this obligation aggressively at '-.his site,
since the remedy involves containment of hazardous wastes.
Miscellaneous
Q: EPA has not offered contingency plans for landfill
capping, gas venting, groundwater stripping, and leachate
removal.
A: EPA did not believe that contingency plans were necessary
at the point, of this remedy selection, although the SELECTED
REMEDY does provide some flexibility in this regard.
Moreover, EPA believes that the SELECTED REMEDY provides an
implementable conceptual framework within which to make
specific design decisions. If, for some reason, any part of
this remedy is not implementable, administrative vehicles
exist for the reformulation of that part of the remedy.
Q: Specific references have not been provided to identify
other sites where remediation measures such as those
proposed have been successfully implemented.
A: The industrial excess landfill in Uniontown, Ohio is
similar with respect to landfill gas migration. Lees Lane
Landfill is another example, located outside of Louisville,
Kentucky on the Ohio River.
The use of air strippers to treat water for potable water
distribution is presently planned at municipal supply wells
in Vestal, N.Y. and Katonah, N.Y. There are numerous
examples of Superfund sites in New York and nationwide at
which groundwater extraction and air stripping treatment are
being selected for implementation.
Q: Specific provisions must be included for continuing
community involvement and acceptance of all phases of
remediation including placement of wells and
interpretation of test results. Also, dispute
rerolution procedures should be established.
A: The involvement of the affected community is a statutory
requirement of CERCLA at Superfund sites. As such, a
community relations planning and implementation effort must
be involved which meets the approval of EPA. EPA will work
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with the community in the future to develop the community
relations plan, as well as to continue the coordination with
the affected community already established at this site.
Dispute resolution procedures are not necessary nor required
at a Superfund site, since the federal government by law is
the ultimate decision-maker.
Q: The plans of the Sierra Club involving the possible
development of a regional park in the area of North
Hempstead where the Port Washington Landfill is located
should be incorporated into EPA1s remediation plan for the
L-4 section.
A: At the present time, EPA does not believe that the
SELECTED REMEDY would adversely impact the plans outlined in
the Sierra Club's proposal. However, EPA recognizes the
need for coordination with the plans of the Sierra Club, and
the accommodations of those plans where possible.
COMMENTS ON REMEDIAL INVESTIGATION/FEASIBILITY STUDY
Remedial Investigation
Q: Sufficient groundwater monitoring data was not collected
in areas to the north and northwest of the L-4 landfill, and
therefore the extent of groundwater contamination, both
horizontally and vertically, is undefined.
A: EPA agrees with this comment, although EPA has
already noted this observation in the RI, the FS, the
Endangerment Assessment, and the Proposed Plan. The
conceptual environmental monitoring plan contained in
the FS and the Proposed Plan, and codified in this
Record of Decision, is intended to, among other things,
further define the extent of horizontal and vertical
migration to the north of the site.
' »
The workplan for the RI developed a groundwater
investigation which was based on the widely held belief that
groundwater flow in the study area was generally west to
east. The RI has since determined that there is a localized
bend of groundwater generally to the north in the vicinity
of L-4. As a result, only two EPA wells (EPA wells 103 and
104) were properly situated to give any information on
groundwater flow directly downgradient of L-4.
The determination of the extent of this northerly flow, and
any associated contaminant transport is one of the goals of
the environmental monitoring program contained in the
SELECTED REMEDY.
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Q: The conceptual model suggested in the RI to account for
groundwater contaminated with low level VOC's west of L-4
i.e., landfill gas (with VOC residuals) solubilization in
water from precipitation events percolating down to the
water table, is incorrect, and the EPA analysis upon which
it is based contains mathematical errors. The model, and in
general the entire design of the RI, allowed EPA to reach
the result it wanted to reach (without supporting data)
i.e., that L-4 is the source of groundwater contamination to
the west.
A: Based upon a review of historical data, as well as data
collected during the RI, EPA believes landfill gas has
historically migrated off-site not only to the west of L-4,
beneath the Country Club and Wakefield Drive, but to the
southeast of L-4 in the vicinity of Seaview Industrial Park.
These occurrences are documented by various investigators
mapping areas of elevated methane gas. EPA also observed
methane gas migration west of L-4 during a period of time
when the active landfill gas extraction system was not
operational. Therefore, before the active extraction system
was operated, landfill gas migrated at elevated levels off-
site, and when the active extraction system does not
operate, landfill gas has a tendency to migrate in elevated
concentrations west of L-4.
The flux box samples collected by EPA on the surface of L-4
provides evidence that L-4 contains elevated levels of Vinyl
Chloride,1,1 Dichloroethene, trans 1,2 Dichloroethene, 1,1
Dichloroethane, 1,1,1 Trichloroethane, Benzene, 1,2
Dichloroethane, Tetrachloroethene, Chlorobenzene, and
Trichloroethene. In addition, these constituents have been
detected historically in the leachate as determined by
Nassau County Department of Health and Town consultants.
These hazardous constituents have and continue to reside
within the L-4 cell.
w
EPA also determined through their field investigations that
the landfill gas extraction system was in a state of
disrepair, where portions of the system failed to operate
reliably.
Based on these observations, excursions of volatile organic
contaminants along with methane gas off-site where not
uncommon historically (i.e. before the landfill gas
extraction system was installed) or recently (given the
system's existing state of disrepair). Therefore, volatile
organic constituents have been and continue to migrate off-
site from L-4 at elevated concentrations.
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.'-21' •'••;. .
One of the concerns associated with any gaseous volatile
organic constituent migrating off-site is its impact on the
shallow groundwater flow system water quality. The
groundwater quality data collected historically, and
recently, indicate that all of the volatile organic
constituents found within L-4 (evidenced by leachate and
flux box samples) are found in the shallow groundwater
adjacent to the site, with few exceptions. Using the data
collected by EPA, albeit data representing a period when
landfill gas extraction was actively operating, landfill gas
concentrations were correlated to groundwater concentrations
for selected coupled well nests and compared to Henry's law
constants as a mean of evaluating, the potential for rainfall
percolate or gas condensate to "load1* the groundwater flow
system with volatile organic contaminants. In other words,
air-to-water partitioning was evaluated to determine if the
vapor contamination which was known to migrate off-site
could contaminate the groundwater flow field.
The results of this analysis (which have been revised based
on comments received) indicate that select volatile organic
contaminants (i.e. 1,1,1 Trichlbroethane at EPA 104, and 1,1
Dichloroethane at EPA 202) could have partitioned from the
landfill gas into the groundwater simply based on observed
concentration gradients. Again, this was at a time when
landfill gas extraction was occurring, presumably lessening
the observed concentration of vapor phase contamination.
It is important to note that pertinent components of the
present character of contamination west of the L-4 are that:
- the natural groundwater hydraulic gradient does not allow
for 'the migration of contamination from L-4 to the west
under conditions without Southport pumpage; and
- the contaminants found west of L-4 recently are
exclusively volatile organic contaminants (with the
exception of some above background observances for
chloride, chromium, lead, and copper at EPA 104).
m
The migration of vapor phase organic contaminants through
the unsaturated zone hydraulically upgradient of L-4,
followed by solubilization via gas condensate or rainfall
percolation, with a resultant contaminant loading of the
groundwater is a viable contaminant transport mechanism
which agrees with observed phenomenon and implicates the L-4
cell as a source of groundwater contamination.
Although data has not been collected which specifically
'identifies the source of contamination which led to the
decision to close the Southport well in 1981, the above
defined contaminant transport mechanism could have
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• . : .-.-.•; 22
potentially impacted the groundwater contained within the
well's zone-of capture, especially since the Southport well
contamination occurred during a period of time when the
active venting system was not yet constructed and presumably
elevated levels of organic constituents were free to move
away from L-4 to"the west through:the unsaturated zone.
There were significant reasons for EPA to test this
particular conceptual model. First, the mechanism had been
proposed previously by other researchers. Second, L-4 was
an obvious possible source of the type of contamination
found in the groundwater, since similar chemicals had
already been measured in gases coming from L-4. Third,
inorganic as well as VOC groundwater contamination had been
measured between the Southport Well and L-4 in 1981,
followed by the dissipation of the inorganic contamination
but the persistence of the VOC contamination after the
closure of the Southport Well (1981), suggesting that L-4
leachate was not the source of the contamination to the west
of L-4. Therefore, the conceptual model described above was
developed and tested as a possible contaminant pathway.
EPA sought to evaluate during the RI other source scenarios
as well, which involved placement of wells upgradient of the
Southport Well (EPA wells 107 and 111) to establish whether
there existed possible upgradient sources; the review of the
sewer district collection system in the area between Port
Washington Boulevard and L-4; and speculation about
difficult-to-trace dumping episodes to the west of L-4.
Q: There is no fourth round of landfill gas data in the RI.
A: The results of the abbreviated fourth round of landfill
gas sampling (4 LFG wells were sampled at various depths-all
these wells were in the Wakefield sub-division) can be found
in the back of RI Appendix Volume V.
Q: The Southport Well was never sampled during the RI. The
RI thus failed to confirm whether the Southport Well is now
actually contaminated. EPA's reliance on Southport Well
data from 1981 is absurd. In addition, EPA never attempted
to find out whether the Well had actually ever been
contaminated.
A: The Southport Well was sampled three times during the RI;
however, the results were reported in the RI report under
the Well's Water District designation-N4223. EPA regrets
any confusion thereby created.
The results of the first two sampling rounds did not detect
any contamination; however, the third round utilized
analytical procedures that produced lower detection limits,
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and the following compounds, with concentrations in
parentheses, were reported: trichloroethylene (.6 ppb),
benzene (.1 ppb estimated), total xylene (.5 ppb estimated),
and chlorobenzene (.3 ppb estimated).
The reason that EPA has proposed treatment of the Southport
Well is not based on the above sampling results for the
Well. The Southport Well is located in a very localized
area of relatively clean water. Rather, it is based on the
sampling results obtained for all wells within the Well's
theoretical zone of contribution, and the conservative
estimation of what the water quality at the Well would be
after its return to service and subsequent continuous
pumping over time. EPA estimates that, based on the above
approach, the Southport Well within a matter of weeks would
begin to experience a degradation in its water quality as
contamination from within the zone of contribution (and
primarily downgradient of the Well) makes its way to the
Well.
EPA believes that this approach is not only reasonable but:
necessary to determine the need for treatment at the
Southport Well.
EPA performed an evaluation of this site in 1981 using the
Hazard Ranking System, which is used to determine whether a
candidate site merits placement on the NPL. Data from 1981
was used at that time because it was current. The resulting
rank of this site was high enough for placement on the NPL,
due in large measure to the contamination at the Southport
Well. The ranking process is subject to quality assurance
checks prior to actual placement of the site on the NPL.
Q: The memo from Nassau County Department of Health alleging
that 10-20 million gallons of leachate from L-4 containing
volatile organic contaminants was discharged to the ground
between 1974 and 1977 is mere speculation, and this
discharge never, occurred. EPA made no attempt to locate any
real evidence in this regard. Moreover, the RI omits
mention of the discharge of leachate into the ground from
the actions of EPA contractors (puncture of the leachate
line). This is an example of EPA's biased approach.
A: EPA considers the Nassau County Department of Health's
memo as a convincing indication of historical problems with
L-4's leachate control between the years 1974-1977.
A description of the puncture of the leachate line was not
in the RI for several reasons. First, it occurred as EPA
was drilling its easternmost groundwater monitoring well
(EPA 101). This well is approx. one mile hydraulically
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downgradient from the Southport Well, and is therefore well
outside the Well's zone of contribution. Second, the
leachate spillage (estimated at 30,000 gallons) was already
pretreated to remove volatile organic compounds via
mechanical aeration. Third, neither the monitoring well
which was subsequently instajled nor any other well in that
area (Town wells 7,8,11, and 12) showed contamination during
the RI with volatile organic^ from the spill.
Q: The RI does not document the direction of groundwater
flow (northward), nor the thrsat to the Lloyd and Port
Washington Aquifers. The model results which indicate that
contaminant transport to the north of L-4 includes a
downward component are speculative, not supported by data,
and directly contrary to significant studies conducted by
others i.e., that the area in question is not a deep
recharge zone.
A: The localized northward component of groundwater flow was
a conclusion of this RI/FS. It is based on two sets of
groundwater level measurements taken during the RI to
develop a piezometric surface in the vicinity of L-4. These
water level measurements are included in chapter 4 of the RI
report, while the piezometric surfaces (both hand drawn and
computer generated) are included in chapter 5. The
potential threat to the Lloyd and Port Washington Aquifers
has been based on these water level measurements, as well as
the water level measurements which indicate that recharge of
groundwater is occurring in the vicinity of L-4. These
measurements are referred to as observed vertical gradients
at well pairs and can also be found in chapter 5 of the RI
report.
The potential threat to downgradient aquifers chiefly
depends on the extent of this northerly component of
groundwater flow. Therefore, EPA has included additional
groundwater monitoring to the north as part of the SELECTED
REMEDY.
The other aspecfs of the SELECTED REMEDY which involve
management of groundwater contaminant migration are
generally independent of this further characterization of
the northerly component of groundwater flow.
Q: The RI only included interpretation of geology and
hydrology, but did not give information on the source of
these interpretations.
A: EPA collected over 700 readings for wells in the Port
Washington Water District alone, as well as interpreted
numerous area public and private water supply and
observation well boring and geographical logs (including -
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25
nearly 100 drillers logs for wells on Manhasset Neck). In
addition, EPA interpreted hydraulic testing data, including
over 100 specific capacity tests of area water wells;
analysis of several pump tests performed at various
locations (especially at the Southport and Stonytown wells);
collection of historical pumpage records (including a total
of 44 wells from the Port Washigton Water District, Sands
Point Water District, Roslyn Water District, and Plandome
Water District).
Q: Stratigraphic interpretations made by EPA are apparently
inconsistent with previous mappings. Was Perlmutter's
criteria (1949) used to define the stratigraphy in the area?
A: The hydrogeologic evaluations in the RI were made using
various tools to identify hydraulic properties of the
juxtaposed formations. As such, differentiation between the
Magothy and the Upper Glacial, or the Port Washington
Confining Unit and the Raritan Clay was performed based
chiefly on hydraulic response and resistance to flow. At
the Stonytown Well, for instance, the RI indicates that the
Raritan Clay exists above the Lloyd Sand. This means that a
significant continuous aguitard such as the Raritan Clay
exists above a continuous sandaguifer, such as the Lloyd
Sand, at the Well. Whether the sand sediments which
comprise these formations are pleistocene or cretaceous is
generally immaterial. As such, washing collected cores on
sieves and subsequent microscopic examination in order to
evaluate the sediments against Perlmutter's criteria was not
warranted, as long as the hydraulic properties of the soils
in question could be characterized. Of greatest importance
in a Superfund groundwater investigation is the water
carrying characteristics of the Stratigraphic units, in
order to
determine contaminant migration pathways and remedial
pumping alternative evaluations.
The inconsistency of this hydraulic approach with previous
investigators for purposes of mapping Stratigraphic units
may be explained as follows:
- EPA had more data with which to characterize the area
beneath and in the immediate vicinity of the Landfill;
• the characterization of the stratigraphy at the site
involved use of vigorous hydraulic analyses not attempted
by previous investigations; and
- the naming convention used by previous investigators may
not be entirely consistent with hydraulic property
segregation techniques employed by EPA.
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It must be stressed, however, that the appropriateness and
accuracy of the stratigraphic mappings presented by EPA are
consistent with the historical data, and the recently
collected site specific hydrogeologic databases, within the
context that the mappings are based chiefly on
differentiation of the stratigraphic units by hydraulic
characteristics. -
Q: The RI should have included additional geohydrological
data from the area, as well as a larger base map than the
one provided, fence diagrams etc.
A: EPA believes that the information provided in the RI
serves to adequately support the FS analysis and
consequently the SELECTED REMEDY identified in this Record
of Decision.
Q: Maps should be made to show the hydrological effects
of the simultaneous pumping of major wells in the area.
A: Some of the effects of various pumping scenarios were
outlined in the FS, chapter 3 (see figure 3-21).
Q: The groundwater model is not verified.
A: The ability of the groundwater model to reproduce both
the static and transient groundwater flow system (including
responding to pumpage at the Stonytown well) lends credence
to its use in evaluating not only contaminant transport
migration pathways in the soluble phase, but also to
identify zones-of-capture for water supply wells located
near the site under various pumping conditions.
Since the extent of both the inorganic and organic
contaminant plumes are not mapped in their entirety as a
result of the RI field investigations, the groundwater model
provides valuable insight into their probable direction, and
rates of migration.
Feasibility Study
Q: The conclusion that all remedial alternatives must
immediately begin with the immediate reactivation of
the Southport Well is inexplicable. Since reactivation
of the Well (without treatment) would result in
increased risk to public health, why reactivate the
veil. Also, there are no ARARs or policies that compel
the reactivation of this Well.
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A: The reactivation of the Southport Well without treatment
was only included in the no action alternative, which serves
as a baseline for risk assessment purposes. The
reactivation of the Well without treatment was considered
part of the no action baseline since EPA had defined the
remedial action objectives in chapter 2 of the FS as: the
protection of human health and the environment by
controlling the sources of contamination at the site,
eliminating the potential exposure pathways, and restoring
lost resources. The restoration of lost resources
(Southport Well) was a remedial action objective since the
Southport Well contamination was a major reason why EPA
originally took response action at this site (see previous
discussion on Hazard Ranking System).
EPA believes that the two management of migration
alternatives evaluated in detail in the FS (W-2 and W-3),
which both involve the reactivation of the Southport Well to
service with treatment, are both fully protective of human
health.
Q: Reactivation of the Southport Well, which is presently
outside any contaminant plume, will spread the contamination
through the aquifer. Thus, reactivation of the Well cannot
be compelled by any desire to improve groundwater quality in
the Upper Glacial Aquifer.
A: The commenter is referring to management of migration
alternative W-2, which both the FS and analysis of
alternatives in EPA's Proposed Plan indicated would have the
undesirable effect of "smearing" contamination in the Upper
Glacial Aquifer between the Well and L-4. This effect would
be much smaller under alternative W-3 because the addition
of extraction wells under this alternative would create a
hydraulic barrier to reduce this smearing effect. However,
there would be incidental removals of contaminated
groundwater and partial aquifer cleanup under alternative W-
2, the Well would be returned to service with treatment and
be fully protective of human health, and there would be
significantly less cost involved than as a result of
implementation of alternative W-3.
After analysis, both EPA and NYSDEC rejected the W-2
alternative, and chose W-3 as part of the Proposed Plan
distributed in July, 1989.
Q: The FS confuses the Southport Well with the Upper Glacial
Aquifer as the natural resource that is irreplaceable. Once
conventional groundwater remediation is performed to abate
the aquifer conditions west of L-4, the Well can then be
reactivated without extensive and unnecessary pretreatment.
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A: The use of extraction wells (conventional groundwater
remediation) to improve aquifer conditions within the zone
of contribution to the Well to the degree necessary for
reactivation of the Well without treatment generally takes a
long time. EPA did not believe that this would represent
achievement of the remedial response objective i.e.,
restoration of a lost resource (Southpdrt Well).
EPA also considers the restoration of the locally degraded
Upper Glacial Aquifer as a remedial response objective.
However, the nature of this restoration is markedly
different than restoration of a community potable water
supply well from the perspective of time. The restoration
of an aquifer cannot proceed quickly; rather, some methods
of aquifer restoration may be better or faster than others,
but they are all measured in years.
Q: Reactivation of the Southport Well would require a
concommitant reduction of withdrawal rates elsewhere in the
Water District because of State imposed water caps, and
therefore it is unnecessary to reactivate the well.
A: EPA did not consider the overall water balance of the
Port Washington Water District in its development of
remedial action objectives. Moreover, EPA has discussed the
reactivation of the Southport Well as part of remedial
action since February, 1989 at several EPA/CAC/Town
meetings, and has never been informed that the Water
District no longer wanted/could no longer use the Well. In
fact, EPA sought to explore several institutional
constraints earlier this year which could affect certain
elements of a possible remedy, among them the Water
District's acceptance of an air stripper
at the Southport Well.
EPA has now been informed (as part of the District's
comments on the Proposed Plan) that the Water District
believes it is premature to return the Well to service.
Therefore, EPA will provide a treatment facility at the
Southport Well at some future date eventually selected by
the Water District, given a re-demonstration of need for
such treatment at that time.
Q: The FS improperly screened out the no action alternative
for groundwater contaminant migration.
A: The FS did not screen out any aspect of the no action
alternative, but rather carried this alternative over to the
detailed evaluation phase as required in the NCP. The
alternatives evaluation in the Proposed Plan only included
those alternatives that survived screening, and the no
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29
action alternative was included in that analysis (and
rejected).
Applicable or Relevant and Appropriate Requirements (ARARs)
i.e., MCL's for volatile organics, are presently being
contravened in the Upper Glacial Aquifer in the vicinity of
L-4. This was sufficient reason to reject the no action
alternative for management of migration during the detailed
evaluation of alternatives.
Q: Proper coordination of the extraction system and the
reactivation of the Southport Well should result in the
ability to use the Southport Well without treatment.
A: EPA does not believe this is true, at least not in the
foreseeable future. While it is true that the treatment
facility required at the Southport Well would be much
smaller under W-3 (the. commenter's scenario) than it would
be under W-2 (no extraction wells), nevertheless EPA
believes that MCL's would still be eventually contravened at
the Southport Well if reactivated with no treatment. See
the analysis in the FS section 4.3.1.
Q: The FS indicates that 60 drums were excavated in 1987
from a small area between L-4 and L-5, but no mention is
made of the fact that the Town did extensive testing which
failed to demonstrate any environmental harm from that area.
This is an example of EPA's biased approach.
A: EPA believed that the appropriate place to provide
details on the drum issue was in section 5.4 of the RI, with
the analytical results that were obtained located in
Appendix Q. EPA realizes that the extensive nature of the
RI, FS, Endangerment Assessment and attendant appendices was
not an easy review task. This was the reason why EPA
granted a thirty day extension (to sixty days) for review of
and comment on the various reports. EPA regrets any
misunderstandings or confusion resulting from the sheer bulk
of the study.
Endanaerment Assessment
Q: The Endangerment Assessment says that landfill gas
enters area homes through cracks between the walls and
the floor. The gas actually is pulled into the homes
through the opening in the foundation located in the
heating rooms. . .. .
A: The evaluation of soil gas infiltration into homes in the
Wakefield subdivision assumed that infiltration occurred
along cracks between the walls and foundation of the home.
This is a well known transport route for soil gas
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infiltration into the home. Some homes in the Wakefield
area have gravel filled openings in the foundation around
the furnace. The gravel filled openings in the foundation
provide a route of transport similar to the cracks evaluated
in the Endangerment Assessment. A recalculation of the
upper bound maximum risk involved with this pathway using
the larger, furnace slab opening indicates an overall
increase in risk associated with this pathway, which is
still within EPA's range of acceptable risk.
EPA's selection of remedial action calculated to further
reduce the levels of offsite gaseous VOCs is an important
consideration when examining these baseline (no action) risk
numbers.
Q: Although EPA's conservative approach is not generally
objectionable, at times it is misplaced, particularly when
it is applied when site conditions are known. The future
residential use scenario is not plausible.
A: The residential use scenario evaluated for the L-4
landfill assumed that a person lived on the L-4 landfill for
9 and 30 years in the average and plausible maximum cases,
respectively (not for 70 consecutive years). These factors
are listed in the EPA's Exposure Factor Handbook and are
recommended for use as the average and reasonable upper
bound of residence time in a single hcae.
While residential use of a former landfill is not highly
likely, there are instances where this has occurred in
the U.S. in the past. The purpose of a baseline
endangerment assessment is to evaluate potential risks under
the-no-action alternative (i.e., in the absence of remedial
actions including institutional controls). As was stated in
the Endangerment Assessment, residential use was evaluated
to provide an upper bound on potential exposures and risks
associated with future landfill use and to enable remedial
actions, including institutional controls, to be identified
if necessary to preclude such future use.
»
Q: Methane gas is excluded from a detailed examination in
the Endangerment Assessment. It is EPA's public role and
responsibility to refrain from ignoring the obvious hazards
due to methane gas.
A: Methane is not toxic, therefore no toxicological health
effects would be expected from potential exposures to this
gas. The primary potential hazards from this gas are from
explosions and asphyxiation. Explosions in the form of
furnace "puff-backs" occurred in homes near the landfill
during the winters of 1979, 80 and 81 (Remedial
Investigation Report, COM 1989). The Town of North
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Hempstead subsequently undertook remedial measures in the
form of passive and active venting systems to reduce the
migration of methane from the landfill and concentrations of
methane in homes to below the lower explosive limits. No
explosions are known to have occurred since this time;
moreover, the possible migration of methane has been since
monitored on a regular basis, and will continue to be
monitored as a condition of landfill closure. Since the
hazards associated with methane are much more easily
detected and are presently being monitored, it was not
considered necessary to provide an analysis of the potential
hazard associated with methane. In addition, because the
methane gas concentrations required for asphyxiation are
approximately five times greater than the upper explosive
limit for methane, there is no potential for asphyxiation
due to methane gas in the homes near the landfill.
Q: EPA relied on desk top calculations in place of direct
field measurements of landfill gas. EPA should have
performed in-house air monitoring within Wakefield Avenue
homes, as well as taken samples from the outlet side of the
HCU.
A: EPA utilized desk top calculations to extrapolate field
data in order to predict what exposures would occur at
receptors where direct field measurement would either: not
be able to detect the low order of chemical exposure; or not
be able to discern the low order of chemical exposure from
background levels. This is common practice at many
Superfund sites when dealing with low level chemical
exposures.
In the Endangerment Assessment, field monitoring data was
used with fate and transport models to determine exposure
levels. In determining indoor air levels inside the
Wakefield homes, soil gas measurements from the Wakefield
area were used with transport and dispersion models that are
commonly used in risk assessments. While long-term
measurements of .indoor air would provide additional
information, the usefulness of it would be questionable
since it would be difficult to determine the contribution of
the landfill to any measured concentrations in the house.
This is because several of the principal chemicals of
concern migrating from the landfill are common constituents
of household products such paints and cleaning products. In
such cases the usa of models is a standard and valid
approach to predicting concentrations from a particular
source.
The HCU stack sampling analysis conducted by Velzy
Associates was used to determine the destruction/removal
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32
efficiency (ORE) of the HCU for the organic chemicals of
potential concern for this source. The ORE values from the
Velzy report were used to reduce the stack emissions to
reflect the operation of the HCU.
Miscellaneous
Q: How will the implementation of the plan be paid for.
What are the specific costs for remediation of the Southport
Well.
A: If EPA pursues the implementation of the SELECTED R
in the absence of a negotiated settlement with potentially
responsible parties (PRPs) , then half the funding for this
action will be provided through Congressional appropriations
mandated under CERCLA. The other half will be provided by
the State of New York. EPA would then seek to recover the
federal government's expenditures from the PRPs at a later
date.
If there is a negotiated settlement with PRPs, then the cost
will be borne by the PRPs, utilizing whatever funding
sources are at their disposal. EPA could also use its legal
authorities to require the PRPs to implement the selected
remedy .
Specific cost information for the management of migration
portion of the SELECTED REMEDY is included in Table 6 of
this Record of Decision.
Q: EPA must expand the boundaries of the L-4 Superfund site
to include the L-5 portion of the Town of North Hempstead's
landfill. The entire Port Washington landfill area should
be addressed in EPA's Proposed Plan and RI/FS. The inclusion
of the L-5 site to the Superfund list is essential.
A: The L-5 portion of the Port Washington Landfill is being
operated by the Town of North Hempstead. The Town's
operations, which are currently restricted to fields 1 and
2, are being overseen by the NYSDEC under the terms of a
1983 Stipulation Agreement between the Town and NYSDEC.
According to NYSDEC there are some problems with respect to
landfill gas migrating from L-5. DEC is working with the
Town to correct these problems and expects to incorporate
the corrective action measures into a permit for field 3,
which is needed by the Town for landfill expansion. For
example, the Town recently installed a slurry wall between
fields 2 and 3 in an attempt to control the gas migration
problem.
The L-5 portion of the Port Washington Landfill is under the
jurisdiction of NYSDEC and, in accordance with the
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aforementioned permit discussions for field 3, is being
managed appropriately by NYSDEC. Therefore, EPA does not
anticipate taking an active role in the operation and
subsequent closure of L-5. In addition, there is no
evidence of an "imminent health hazard" to area residents
which would qualify the L-5 site for "emergency1* action
under EPA's removal program.
EPA has not conducted any investigations with respect to L^
5, since it is under the jurisdiction of DEC. According to
DEC there is a landfill gi.s migration problem, but they are
working with the Town to correct it through a permit for
field 3.
Since L-5 is an active sanitary landfill with a double liner
beneath it and a slurry wall between fields 2 and 3, there
is no reason to believe it is a source of contamination at
L-4. In addition, since DEC is committed to resolving the
current gas migration problems with the Town, EPA has no
justification to usurp the State's authority in this
matter. Should future problems arise or current problems
be exacerbated, EPA would attempt to utilize one of the
aforementioned mechanisms to qualify the site for
remediation under Superfund.
EPA and DEC believe that the proposed remediation for L-4
will be effective without including L-5, since L-4 will be
capped in accordance with New York State law, the gas
collection system will be improved and groundwater will be
remediated.
Once- L-5 has reached its capacity, it too will be capped in
accordance with State law. This action is independent of
any similar measures undertaken at L-4. Should problems
arise (or continue) with respect to gas migration or
groundwater contamination due to L-5, EPA anticipates that
NYSDEC will use its authorities to require remediation of
the problem.
L-5 has a double liner t.o prevent groundwater contamination
and a slurry wall between fields 2 and 3 to control gas
migration; therefore, EPA believes that L-5 will have no
appreciable effects on L-4. Should problems arise (or
continue) with gas migration or groundwater contamination
due to L-5, the proposed remediation systems at L-4 could be
expended to accommodate the increased capacity. Such
expansions would only be eligible for funding under the
Superfund program if the L-5 site qualified for
remediation, as noted previously.
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