United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R02-90/130
September 1990
&EPA
Superfund
Record of Decision
Vestal Water Supply 1-1, NY
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50272-101
REPORT DOCUMENTATION
PAGE
1. REPORT MO.
EFA/ROD/R02-30/130
3. Recipient'* Acceulon No.
4. TMe and Subtitle
SUPERFUND RECORD OF DECISION
Vestal Water Supply 1-1, NY
Second Remedial Action - Final
5. Report Date
09/27/90
7. Author(s)
8. Perlorming Organisation Rept No.
». Performing Organization Name end Address
10. ProjecVTaak/Work Unit No.
11. ContractyC) or Grant(G) No.
(C)
(C)
12. Sponeoring Organization Name end Addrea*
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
13. Type ol Report 6 Period Covered
800/000
14.
15. Supplementary Note*
16. Abetract (Urrtt: 200 word*)
The Vestal Water Supply 1-1 site is located in Vestal, Broom County, New York. The site
is on the south bank of the Susquehanna River, and lies east of Choconut Creek. The
site lies within the floodplain of the Susquehanna River, and contains several wetland
areas. Well No. 1-1 is one of three production wells that provide drinking water to
several water districts in the Vestal area. A State Road Industrial Park thought to be
a source of contamination is located 1,500 feet southeast of the Vestal Well No. 1-1.
Chlorinated solvents were first detected in Well No. 1-1 in 1978, after a chemical spill
at a plant in nearby Endicott led to the testing of wells in the vicinity for specific
synthetic compounds. Subsequently, contaminated ground water was pumped from this well
and discharged offsite to the Susquehanna River. Further investigations determined that
the chlorinated solvents present in Well No. 1-1 could not be attributed to the chemical
spill at the IBM plant. A 1986 Record of Decision (ROD) documented the selection of
ground water treatment using-air stripping to remove VOCs, addressed Well 1-1
contamination, and required additional studies of four potential source areas in the
State Road Industrial Park. This ROD addresses contaminated soil in the four source
areas and is a final remedy. This ROD also addresses a contingency remedy for potable
(See Attached Page)
NY
17. Document Analyst* a. Descriptor*
Record of Decision - Vestal Water Supply 1-1,
Second Remedial Action - Final
Contaminated Medium: soil
Key Contaminants: VOCs (PCE, TCE), other organics (PAHs), metals (chromiun, lead)
b. MentifienVOpen-Ended Term*
c. COSATI Held/Group
18. AvaUabUty Statement
19. Security Class (This Report)
None
20. Security Claa* (Thi* Page)
None
21. No. of Page*
56 .
22. Price
(See ANSI-Z3S.18)
See Inttructiona on Reverse
WIIUNAL ItJHM il£ (*-r 1}
(Formerly NTIS-3S)
Department ol Commerce
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EPA/ROD/R02-90/130
Vestal Water Supply 1-1, NY
Second Remedial Action - Final
Abstract (Continued)
water, if needed. The primary contaminants of concern affecting the soil are VOCs
including TCE and PCE; other organics including PAHs; and metals including chromium and
lead.
The selected remedial action for this site includes treating the soil by in-situ vacuum
extraction to remove VOCs in two of the four source areas within the State Road
Industrial Park, followed by carbon absorption to control air emissions; disposing of
the residual carbon offsite; and ground water monitoring. This ROD provides a
contingency remedy for ground water treatment using precipitation and filtration to
remove heavy metals in addition to the current treatment, as necessary. The estimated
present worth cost for this remedial action is $1,700,000. There are no
annual O&M costs associated with this selected remedial action. The estimated present
worth cost for the contingency remedy is $17,900,000, which includes an estimated
annual O&M cost of $925,000.
PERFORMANCE STANDARDS OR GOALS: Chemical-specific cleanup goals for soil in the two
source areas include TCE 140 ug/kg, 1,1,1-TCA 170 ug/kg, and 1,2-DCE 188 ug/kg (for
Area 2 only).
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ROD FACT SHEET
SITE
Name:
Location/State:
EPA Region:
HRS Score (date)
NPL Rank (date):
ROD
Date Signed:
Capital Cost:
O and M:
Present Worth:
LEAD
Remedial, EPA
Primary contact:
Secondary Contact;
WASTE
Type and media:
\
Origin:
Vestal Well No. 1-1
Vestal, Broome County, N.Y.
II
Range: 37.69-39.65
441 (9/83)
September 27, 1990
Selected Remedy- in situ removal of VOCs from
soil through induced volatilization,
collection, and removal via carbon
adsorption. No action for groundwater
contamination, with contingency remedy for
metals removal at Well 1-1 via chemical
precipitation and clarification, should
future monitoring indicate the need for it.
$1,700,000 ($5,400,000 with contingency rem.)
$0. ($925,000 with contingency remedy)
$1,700,000 ($19,600,000 with contingncy rem.)
Edward G. Als- (212) 264-0522
Douglas Garbarini- (212) 264-0109
Soil - *VOCs: 1,1,1-Trichloroethane,
Trichloroethylene,
Tetrachloroethylene, and
trans-1,2-Dichloroethylene
*Semi-VOCs: Napthalene, 2-
Methylnapthalene, Phenanthrene, and
bis(2-ethylhexyl)phthalate
*Inorganics: Chromium, Copper, and
Lead
Groundwater - *VOCs: 1,1,1-Trichloroethane,
Trichloroethylene, 1,1-dichloroethane, trans-
1,2-dichloroethylene
*Semi-VOCs: Trace
*Inorganics: Chromium, Copper, Lead, and
Mercury
Alleged poor housekeeping practices of Vestal
Asphalt and Chenango Industries in the Stage
Road Industrial Park
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DECLARATION FOR THE RECORD OF DECISION
VESTAL WATER SUPPLY WELL NO. 1-1
SITE NAME AND LOCATION
Vestal Water Supply Well No. 1-1
Vestal, Broome County, New York
STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected remedial action for
the Vestal Water Supply Well No. 1-1 site, 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.
ASSESSMENT OF THE SITE
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
A remedy for groundwater contamination was previously selected and
documented in the June 27, 1986 ROD for this site. That remedy
included returning Well 1-1 to service as a potable water supply
through the construction and operation of a water treatment
facility. The facility has been constructed and will return Well
1-1 to distribution to Water District 1 in the near future.
Monitoring results indicate that the treated water meets all
applicable standards.
The earlier ROD also recommended that a second site investigation
be undertaken to determine the location of potential source areas
and to evaluate the need for remedial action. The 2nd
investigation has documented the existence and nature of additional
contamination at this site.
This ROD contains the remedy selected for the releases or threats
of release documented by the 2nd investigation. The major
components of the selected remedy include:
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* In situ vacuum extraction of volatile organic contamination
from soil in source areas 2 and 4 within the Stage Road
Industrial Park, followed by carbon adsorption, with
subsequent treatment and disposal of contaminated carbon at
a permitted off-site facility
* Monitoring program to evaluate the progress of the vacuum
extraction remedy
* Monitoring program to periodically assess inorganic
contaminants in the aquifer upgradient of Well 1-1 (the
decision to implement a monitoring program for organic
contamination was contained in EPA's June 27, 1986 ROD)
* A contingency remedy involving treatment of inorganic
contaminants to be implemented, if necessary, in the future
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.
Since this remedy will result in hazardous substances remaining
for an indefinite time at the site above health-based levels, a
review will be conducted no later than five years after
commencement of the remedial action to ensure that this remedy, as
well as the water treatment remedy implemented pursuant to the
first ROD, continues to provide adequate protection of human health
and the environment.
^donstantine Sidamon-Eristof Date
^/Regional Administrator '/
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Decision Summary
VESTAL WATER SUPPLY WELL NO. 1-1
VESTAL, BROOME COUNTY, NEW YORK
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION II
NEW YORK
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TABLE OF CONTENTS
Section Page
SITE NAME, LOCATION AND DESCRIPTION 1
SITE HISTORY AND ENFORCEMENT ACTIVITIES 2
HIGHLIGHTS OF COMMUNITY PARTICIPATION 3
SCOPE AND ROLE OF OPERABLE UNIT 4
SUMMARY OF SITE CHARACTERISTICS 5
SUMMARY OF SITE RISKS 6
DESCRIPTION OF ALTERNATIVES 11
SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES.. 16
SELECTED REMEDY 23
STATUTORY DETERMINATIONS 28
DOCUMENTATION OF SIGNIFICANT CHANGES 30
ATTACHMENTS
APPENDIX 1 - TABLES
APPENDIX 2 - FIGURES
APPENDIX 3 - JUNE 27, 1986 ROD (operable unit 1)
APPENDIX 4 - GROUNDWATER MONITORING PLAN
APPENDIX 5 - NYSDEC LETTER OF CONCURRENCE
APPENDIX 6 - RESPONSIVENESS SUMMARY
APPENDIX 7 - ADMINISTRATIVE RECORD INDEX
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SITE NAME, LOCATION. AND DESCRIPTION
The Town of Vestal is located in Broome County, New York about
five miles southwest of the city of Binghamton, on the south bank
of the Susquehanha River (figure 1). Drinking water for most of
the western part of the Town of Vestal is supplied by Water
District No. 1, which is comprised of wells 1-1, 1-2, and 1-3.
Well 1-1 was taken out of service in 1978 because it was found to
be contaminated with volatile organic chemicals (VOCs). Well 1-
1 has subsequently become the focus of Federal Superfund
activity, which has included a preliminary assessment and
subsequent ranking of the well as a National Priorities List
(NPL) site, followed by two separate investigations into the
nature and extent of the contamination affecting the site. This
Record of Decision (ROD) is specifically for the second remedial
investigation and feasibility study (RI/FS), which primarily
focused on the possible sources of the contamination affecting
Well 1-1.
The study area for this Superfund site includes all that area
located to the south of the Susquehanna River, to the east of
Choconut Creek, to the north of Vestal Parkway, and to the west
of NY State Route 26 (figure 2). The area is generally flat,
contains several small wetland areas, and lies within the
floodplain of the Susquehanna River. Well 1-1 is located on
Pumphouse Road, a short distance west of North Main Street, and
is the easternmost well in Water District No. 1. The Stage Road
Industrial Park, which is the location of the four potential
source areas investigated in the second RI/FS, is located a short.
distance east of North Main Street, approximately 1500 feet from
Well 1-1.
After being taken out of service in 1978, Well 1-1 was
continuously pumped to waste into the Susquehanna River in order
to hydraulically "capture" and discharge the plume of
contaminated groundwater before the contaminants could reach the
remainder of the wellfield. This strategy was possible since
Well 1-1 was located hydraulically downgradient of the
groundwater contamination and between the contamination and the
remaining Water District No. 1 wells (figure 3). The ROD for the
first RI/FS called for construction and operation of an air
stripping facility at Well 1-1 in order to return Well l-l to
service as a potable water supply. This decision also allowed
Wsil .1-1 -, ••:;*>rtii:u« capturing the plume of contaminants, thereby
preventing their downgradient migration to the other Water
District, -ir- 1 surply vails. The ROD also determined that a
second RI/FS should be performed to determine, if possible, the
source(s) of the contamination affecting Well 1-1.
At the present time, the air stripping facility at Well 1-1 has
been constructed and has recently completed start-up testing,
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while continuing to discharge to the Susquehanna River. Well 1-
2 became physically impaired in 1988, and as a result now
provides a limited yield of potable water as a reserve supply.
Well 1-3 is presently Water District .One's primary water supply. .
Additional reserve capacity, if needed, can be obtained on a
limited basis through an interconnection with other supply wells
in the area. The treated water from Well 1-1 will become
available for public distribution in the near future.
The second RI/FS commenced in November, 1988, and focused on four
potential source areas in the Stage Road Industrial Park (figure
4). These four areas are:
Area 1- the part of the Vestal Asphalt property adjacent to
Route 17
Area 2- the truck parking area between Stage Road and the
Erie Lackawanna railroad tracks
Area 3- the area between the north side of the Chenango
Industries building and an existing drainage ditch
Area 4- the area between the south side of the Chenango
Industries building and the Erie Lackawanna railroad tracks.
These four areas were suspected of being areas where organic
contaminants were present in the soils and entering the water
table, based primarily on the concentrations of VOCs in
groundwater found in the first RI, as well as on the
concentrations of VOCs in soil gas found during the initial
stages of the second RI.
SITE HISTORY AND ENFORCEMENT ACTIVITIES
N
A chemical spill at the IBM plant in Endicott, New York in 1978
led to a testing program for all drinking water wells in the
vicinity for "organic compounds. As a result of this testing,
chlorinated solvents were discovered in Well 1-1, and the well
was taken out of service and pumped to the Susquehanna River.
Subsequent investigation has since determined that the presence
of chlorinated solvents in Well 1-1 is not related to the spill
at the IBM plant.
The New York State Department of Environmental Conservation
(NYSDEC) commenceu tr.a rl.c-t. i-.I/ri- ^ the site in April, 1985
pursuant to a cooperative agreement with EPA. This investigation
focused primarily on the contamination of groundwater by VOC's in
the Vestal 1-1 study area. This investigation indicated that the
VOC contamination was apparently originating in the Stage Road
Industrial Park area, located immediately east of North Main
Street and south of Route 17 in Vestal, N.Y. The second RI/FS
recently completed by EPA has confirmed the Stage Road Industrial
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Park as the source of VOC contamination. The physical evidence
collected during the second RI, moreover, indicates that releases
of VOCs have taken place in at least two of the four potential .
source areas.
Special Notice letters were sent to Vestal Asphalt Inc. and
Chenango Industries, Inc. in May and June, 1988, respectively.
These letters are intended to provide official notification from
EPA to individuals or corporations of their status as potentially
responsible parties (PRP) for a release of contamination and for
the cleanup deemed necessary by EPA. The basis for this
notification was that potential source area 1 was partially
within the Vestal Asphalt property, potential source areas 3 and
4 were located on the Chenango property, and potential source
area 2 was partially within a truck parking area owned by the New
York State Department of Transportation (NYSDOT) and
predominantly used by Vestal Asphalt Inc. Neither Chenango
Industries Inc. nor Vestal Asphalt Inc. indicated a willingness
to negotiate a settlement to provide for their implementation of
the remedy for operable unit one at that time. After the
issuance of these Special Notice letters, the second RI/FS has
subsequently determined that only potential source areas 2 and 4
warrant remediation.
An additional Notice letter, including demand for payment, was
sent on June 6, 1990 to the NYSDOT as owner of the truck parking
area (source area 2). Demands for payment of costs incurred by
EPA had previously been issued to both Chenango Industries Inc.
and Vestal Asphalt Inc. on September 14, 1989. Chenango
Industries Inc. met with EPA on the matter of EPA's demand for
payment; however, no settlements have been reached at the present
time with any PRPs regarding payment of EPA's incurred costs at
the Vestal 1-1 site.
Special Notice was recently given to the three PRPs mentioned
above in a letter dated July 26, 1990 in order to determine the
PRPs' intent to negotiate the performance of the selected remedy
contained in this ROD.
HIGHLIGHTS OP COMMUNITY PARTICIPATION
A Community Relations Plan was developed for this site by EPA
which designated the Ves^l tv?...•_.;.- 7-\-:^L-s - :•# the Vestal Town
Hall as public information repositories. All public information
concerning the site, including t*«» site Administrative Record
file, is presently located at the repositories.
Notice of the availability of EPA's Proposed Plan for the second
RI/FS was placed in the Binghamton Press on Friday, May 18, 1990
(figure 5), and an EPA press release was issued on Monday, May
21, 1990. A public meeting was held on May 31, 1990, to solicit
public comment on the second RI/FS and Proposed Plan. The public
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comment period, normally 30 days from the notice of availability
of the Proposed Plan, was extended at the request of the Town of
Vestal and of Chenango Industries, a PRP conducting business in
the Stage Road Industrial Park. The new closing date for the
comment period was designated as July 12, 1990.
Earlier, in 1986, a similar public meeting had been held to
invite public comment on the first RI/FS.
The most recent public meeting was attended primarily by Town and
State officials and the news media. The primary concern at that
meeting was the present worth cost of one of the potable water
treatment alternatives (GW-5), which was proposed at the time of
the meeting as a possible potable water contingency remedy. This
alternative has not been incorporated into the selected remedy.
SCOPE AND ROLE OF OPERABLE UNIT
EPA issued a ROD on June 27, 1986 that selected air stripping
technology as the remedy which would enable Well 1-1 to be
returned to service as a potable water source (Appendix 3). The
ROD also indicated the need for a second RI/FS to evaluate
suspected source areas of contamination in the Industrial Park.
Therefore, the Vestal 1-1 Superfund site was segmented into two
remedial efforts, or operable units, which enabled the
remediation of Well 1-1 to proceed through the design and
construction of an air stripping facility (first operable unit),
while a concurrent investigation sought to determine the specific
sources of the localized groundwater contamination affecting Well
1-1 (second operable unit), and to identify any additional site
contaminants which could potentially affect Well 1-1 which were
not compatible with the air stripping treatment technology.
The construction of the first operable unit air stripping
facility was completed in January, 1990, and is presently
undergoing startup testing. EPA anticipates the return of Well
1-1 to service in September, 1990.
Fieldwork for the second operable unit RI/FS was initiated by EPA
in November, 1988, after significant delays were encountered
obtaining access to property in the Industrial Park. The
fieldwork was concentrated in four areas of the Industrial Park
which were considered potential source area. . .r -.rrj-tion
based on existing groundwater and soil gas data.
The fieldwork for the second RI included: geophysical and soil
vapor surveys (to assist in optimum placement of boreholes); the
installation of 4 groundwater monitoring wells; the drilling of
36 boreholes (figure 6); and the sampling of both the soil from
the boreholes and the groundwater from the entire network of
groundwater monitoring wells that now exists as a result of the
first and second RI's.
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This operable unit addresses the sources of the contamination
which have affected the Vestal Well 1-1 water supply. The
contamination which EPA believes warrants remediation, based in
large measure on the public health risk assessment performed for
this site, is the volatile organic contamination of the soils in
source areas 2 and 4.
This operable unit was also intended to provide a confirmatory
examination of the contamination of groundwater in the study
area. This confirmatory examination determined, among other
things, that heavy metal contamination in the study area,
although presently not posing a health risk at Well 1-1,
nevertheless merited consideration during the feasibility study
phase of this operable unit. This contamination is further
discussed below.
SUMMARY OF BITE CHARACTERISTICS
As a result of EPA's second RI/FS at this site, the extent and
nature of contamination has been characterized in sufficient
detail to analyze remedial alternatives. The following is a
summary of this characterization.
Subsurface soil samples were collected and analysed from each of
the four potential source areas for volatile organic,
semivolatile organic, and inorganic contamination. A risk
assessment was then conducted to determine the degree of risk
posed by the measured levels of contamination to human, floral
and faunal receptors via reasonable exposure pathways.
Analytical results of soil sampling indicated significant VOC
contamination in suspected source areas 2 and 4 (figures 7 and
8) . Source areas 1 and 3 also showed some evidence of VOC
contamination, although the measured concentrations and frequency
of occurrence indicate that areas 1 and 3 are only slightly
contaminated. Areas 2 and 4 had the highest levels of VOC's,
with maximum concentrations (in the low % range, by weight) of
1,1,1-trichloroethane, trichloroethylene, trans-1,2-
dichloroethylene and tetrachloroethylene found in borehole SB-
219, with lesser concentrations in surrounding boreholes.
Xylene, toluene, and benzene were also found in their highest
concentrations in area 2.
Semi-volatile compounds were found in sigr.i ~\c.^rj- -•-:...
throughout the four potential source areas (figures 9 and 10) .
Napthalene, 2-methylnapthalene, phenanthrene, and bis(2-
ethylhexyljphthalate were found in their highest concentrations
(low % range, by weight) in areas 1 and 4 (boreholes 115 and 409,
respectively) .
To determine whether the presence of a particular hazardous
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inorganic element in the soil constituted "significant
contamination", the RI/FS considered representative background
concentrations of these elements for the geographic area
containing the Superfund site. Inorganic elements are naturally
found in soils in varying amounts. Several inorganic elements,
such as chromium, copper and lead, were found at this site in
significant amounts in areas 2 and 4 (figures 11 and 12). The
highest concentration of chromium was 1,130 mg/kg in borehole SB-
206 (area 2); the highest concentration of copper was 487 mg/kg
and was found in borehole SB-422 (area 4); and the highest
concentration of lead was 91 mg/kg and was found in SB-206. It
should also be noted that since SB-206 was located on the
perimeter of area 2, further sampling should be conducted (during
the design phase of this operable unit) to define the full extent
of chromium-contaminated soils in area 2. Background
concentration ranges for the above elements in the upstate New
York area are 30-100 mg/kg, 15-20 mg/kg, and 15-30 mg/kg,
respectively.
Analytical results for several of the groundwater monitoring
wells in the study area indicated low level contamination by
heavy metals, including copper, chromium, lead, and mercury, in
excess of Federal and State groundwater and drinking water
standards (figure 13). The maximum total concentrations (both
suspended and dissolved) reported for these metals were: copper-
1.58 mg/1, chromium-.15 mg/1, lead-.191 mg/1, and mercury-.204
mg/1. The results from the groundwater monitoring wells also
confirmed the VOC contamination which was documented during the
first RI.
In summary, the analytical results of the second RI indicate that
soils in all four source areas contain volatile and semi-volatile
organic contamination, while concentrations of several heavy
metals exceed background levels in source areas 2 and 4.
v\
SUMMARY OF SITE RISKS
The risk assessment (RA) for this operable unit primarily
addresses the potential impacts to human health associated with
soil exposure from the Vestal Well 1-1 site in the absence of
remedial actions. The risks associated with the use of Well 1-1
as a potable water supply without treatment were evaluated during
the first operable unit. This assessment ccnstitr.' .^-
evaluation of the no-action alternative and deals primarily with
soil contamination in the four identified source areac (.^"-.-s I -
4). This RA has been conducted using conservative assumptions
according to the general guidelines outlined by EPA. The purpose
of using these assumptions is to explore the potential for
adverse health effects.
For known or suspected carcinogens, acceptable exposure levels
am generally concentration levels that represent an excess upper
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bound lifetime cancer risk to an individual of between 10"4 to 10"6
using information on the relationship between dose and response.
The 10"6 risk level is used as the point of departure for
determining remediation goals for alternatives when regulatory
standards or requirements are not available or are not
sufficiently protective. For systemic toxicants, acceptable
exposure levels generally represent concentration levels to which
the human population, including sensitive subgroups, may be
exposed without adverse effect.
Selection of Contaminants of Concern
Contaminants which have inherent toxic/carcinogenic effects that
are likely to pose the greatest concern with respect to the
protection of public health and the environment were selected as
contaminants of concern. The chemicals selected as contaminants
of concern and their concentrations in the soil at the Vestal
Well 1-1 site are presented in table 1.
Exposure Assessment
In this assessment, both current and potential future exposure
pathways are considered. Current activity patterns at the site
are examined to identify current exposure potential to residents
and workers from the site as it presently exists. In developing
future exposure pathways, it is assumed that no further remedial
actions will be undertaken. It is further assumed that a
commercial or light industrial building, such as those currently
present at the Industrial Park, may be constructed on the source
areas and that exposure to contaminants in soils may occur during
the construction. This latter scenario was assessed.
To quantitatively assess the potential risks to human health
associated with the exposure scenarios considered in this
assessment, estimates of chronic daily intakes (CDIs) are
developed. CDIs are expressed as the amount of a substance taken
into the body per unit body weight per unit time, or mg/kg/day.
A CDI is averaged over a lifetime for carcinogens and over the
exposure period for noncarcinogens. An average case and a
reasonable maximum case are considered. The average case is
based on average (but conservative) conditions of exposure and
the average exposure point concentrations. The reasonable
maximum case is based on upper-bound conditions of expo«5vr" •• /'••
the reasonable maximum exposure point concentration, and as such
represents the extreme upper limit of potential exposure.
Workers excavating soils may be exposed to contaminants in the
soil through three possible routes; namely, dermal absorption,
incidental ingestion of soils, and inhalation of volatile
chemicals from excavated soil. The exposures from each of these
routes are calculated separately and are then summed to give the
total potential exposure. The dermal absorption and ingestion
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scenarios represented the greatest risk. The assumptions for
assessing these routes of exposure are presented below:
* future on-site construction workers would work in a pit
such as an excavated building foundation for a 6-week
period, 5 days per week, and that the worker would be
involved in a manual task which would result in dermal
contact with soil.
* future on-site construction workers would be involved in
manual tasks which would result in soil contact with the
hands and incidental ingestion of soils following eating or
smoking.
* future on-site construction workers would be exposed to
volatile organics via inhalation over 30 work days for 8
hours a day, for one year. It was also assumed that workers
would engage in light to moderate activities during which
each worker would inhale 7 m3 and 20 m3 of air (per day) for
the average and reasonable maximum exposure scenarios. It is
further assumed that the chemicals inhaled are 100 percent
bioavailable in the lungs.
Toxicity Assessment
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.
Noncarcinogenic risks were assessed using a hazard index (HI)
computed from expected daily intake levels (subchronic and
chronic) and reference doses, or 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 hazard
index is useful as a reference point for gauging the potential
effects of environmental exposures to complex mixtures. In
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general, hazard indices which are less than one are not likely to
be associated with any health risk, and are therefore less likely
to be of concern than hazard indices greater than one-.
In accordance with EPA's guidelines for evaluating the potential
toxicity of complex mixtures, it was assumed that the toxic
effects of the site related chemicals would be additive. Thus,
lifetime excess cancer risk and the CDI:RfD ratios were summed to
indicate the potential risks associated with mixtures of
potential carcinogens and noncarcinogens, respectively.
Under current EPA guidelines, the likelihood of carcinogenic and
noncarcinogenic effects due to exposure to site chemicals are
considered separately.
The summary of health effects criteria for chemicals of potential
concern at the Vestal site is presented in table 2.
Risk Characterization
The risk characterization quantifies present and/or potential
future threats to human health that result from exposure to the
contaminants of concern at the four areas. The site-specific
risk values are estimated by incorporating information from the
toxicity and exposure assessments. The combined excess lifetime
cancer risks from potential soil exposure to construction workers
(via dermal absorption, incidental ingestion, and inhalation of
volatiles) range from 10"4 to 10"6 for the four source areas.
Hazard indices for the noncarcinogenic exposure of construction
workers (via dermal absorption, incidental ingestion and
inhalation of volatiles) exceeded one only for the reasonable
maximum cases in areas 2 and 4. In addition, exposure to
groundwater contaminated with hazardous organic compounds
immediately below source areas 2 and 4, and exposure to inorganic
elements inxgroundwater at a variety of locations in the study
area also resulted in cancer risks approximating 10^ and hazard
indices of greater than one. Table 3 summarizes carcinogenic and
noncarcinogenic risks for the site.
It is unlikely that the soil and groundwater contamination has
adversely affected any plant life in the study area, particularly
wetlands, due to the considerable depths at which the higher
concentrations of volatile and semi-volatile organics, and heavy
metals have been detected (below root levels). The study area is
considered by EPA to have limited ecological significance (both
flora and fauna).
For more specific information concerning public health risks,
please see the volume entitled Public Health Evaluation for the
Vestal Well l-l Site located at both Town Hall and the Public
Library.
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Uncertainties
The procedures and inputs used to assess risks in this
evaluation, as in all such assessments, are subject to a vide
variety of uncertainties. In general, the main sources of
uncertainty include:
- environmental chemistry sampling and analysis
- environmental parameter measurement
- fate and transport modeling
- exposure parameter estimation
- toxicological data
Uncertainty in environmental sampling arises in part from the
potentially uneven distribution of chemicals in the media
sampled. Consequently, there is significant uncertainty as to
the actual levels present. Several chemicals, in particular 1,1-
DCE, 1,1-DCA, PCBs, and 1,1,2,2-PCA, contribute to excess
lifetime cancer risks greater than 10"6 under the specific
conditions of exposure addressed in the RA, although they were
detected infrequently and at low concentrations. In particular,
1,1-DCE was detected in only one boring in Area 2 at depths of 4
to 6 feet and 14 to 16 feet. However, the conservative models
used assume the contaminant is present at the mean concentration
throughout the volume of soils in Area 2. Environmental
chemistry analysis error can stem from several sources including
the errors inherent in the analytical methods, chain of custody
problems, and characteristics of the matrix being sampled.
Environmental parameter measurements primarily contribute to
uncertainty because little verified information is available.
In the Vestal RA there are uncertainties regarding the estimates
of how often, if at all, an individual would come in contact with
the chemicals of concern and the period of time over which such
exposure would occur. In particular, this applies to the future
construction exposures. There is also significant uncertainty in
the models used to estimate exposure point concentrations.
Toxicological data error (potentially occurring in extrapolating
both from animals to humans and from high to low doses) is also a
large source of potential error in this risk assessment. There
is also a great deal of uncertainty in assessing the toxicity of
a mixture of chemicals. In this assessment, the effects of
exposure to each of the contaminants present in the environmental
media have initially been considered separately.
In summary, the calculated risks to public health from this
Superfund site based on average, but conservative, exposure
assumptions primarily involve exposure to organic chemicals in
hypothetically excavated soils from areas 2, 3, and 4 [N.B.-It
should be noted that the risk from hypothetically excavated soils
in area 3 is based on a single contaminant, 1,1-dichloroethylene,
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whose computed risk is tempered by the low frequency of its
observation and the uncertainty associated with the very low
levels at which it was detected]; exposure to groundwater
contaminated with hazardous organic compounds immediately below
source areas 2 and 4, and exposure to inorganic elements in
groundwater at a variety of locations in the study area. Also,
based on the transport modelling of all contaminant species of
concern, EPA has determined that VOCs in areas 2 and 4 will
continue to enter the aquifer in amounts which not only will
cause contravention of applicable groundwater standards, but will
also perpetuate the need for water treatment at Well 1-1 for a
period of time estimated to be at least 20 years.
DESCRIPTION OP ALTERNATIVES
Given the risk summary presented above and after consideration of
all relevant site factors which could impact on the eventual
selection of a site remedy, the following remedial response
objectives were formulated:
1) Ensure protection of groundwater from the continued release of
VOC contamination from soil;
2) Ensure protection of Vestal Well 1-1 water quality from any
groundwater contamination not addressed in the first operable
unit; and
3) Ensure protection of human health, presumably that of site
workers who are exposed to contaminated soils through excavation.
Alternatives were then formulated to meet these remedial response
objectives, using various technologies and approaches. The
alternatives which were formulated were therefore intended to
remediate the source and to address the possible need for
additional treatment of potable water at Well 1-1, given the
updated contaminant profile provided by the second HI.
The alternatives were also formulated so as not to interfere with
or otherwise affect the plume containment objective contained in
the first operable unit ROD, which is being accomplished by the
continuous pumping of Well 1-1. Plume containment was intended
to prevent the VOC contaminant plume from reaching the remainder
- '-istrict 1 water supply veils.
7r. or':r *r Accomplish protection of groundwater from the
continued release of VOC's from the source areas, EPA determined
that certain cleanup levels of soil contaminants should be
specified, below which adverse impacts to the aquifer would not
be expected to occur from contamination leaching from the soil
into the aquifer. EPA further determined that "adverse impacts
to the aquifer" would occur if any applicable or relevant and
appropriate requirements (ARARs) for groundwatei: protection would
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be exceeded in the aquifer due to the leaching of contaminants
from soil (within a mixing zone). EPA determined that such
adverse impacts to the aquifer will result from the continued
leaching of VOCs from areas 2 and 4. Alternatives for source
remediation were then developed and evaluated based, among other •
things, on their ability to attain the soil cleanup levels for
VOCs developed by EPA for areas 2 and 4. These soil cleanup
levels, which will also significantly reduce the hypothetical
risk from human exposure to excavated soils, are as follows:
INDICATOR CHEMICAL ACTION LEVEL
Trichlorethylene 140 ug/kg
1,1,1-Trichloroethane 170 ug/kg
1,2-Dichloroethylene 188 ug/kg (for area 2 only)
The remedial action objectives for the second operable unit did
not include aquifer restoration, other than that which would be
accomplished through the continuous pumping of Well 1-1, since
EPA determined during the formulation of the first operable unit
FS that the hydrogeology of the study area would not be amenable
to an appreciably faster aquifer restoration through selective
placement of extraction wells into the plume of contamination.
The selection of the first operable unit remedy, as described in
the first operable unit ROD, was based in part on this
determination. Remedial action objectives also did not include
remediation of heavy metals or semivolatiles in soils at the
Industrial Park, since the detected concentrations do not pose an
unacceptable public health risk under present or future land use
scenarios.
A "no action" alternative was also evaluated in the FS as
required by regulation, in order to provide an appropriate
alternative in the event that no contravention of standards nor
significantx health or environmental risks were found to exist at
the site.
The alternatives presented below are those which were evaluated
in detail following the preliminary screening of alternatives.
The preliminary screening step typically removes several
alternatives from further consideration based on the general
criteria of effectiveness, implementability, and cost. The
rewM-.iing alternatives which are listed and described below have
retained their pre-screening alphanumerical designations in order
to correspond with the descriptions of alternatives contained in
tile I"o L'cpOiTi.,
Provided below is a description, including cost and schedule
information, for each alternative that was evaluated in detail.
The present worth costs are estimates which take into account
both the capital cost and the operation and maintenance (0 and M)
costs for 30 years. The time to implement reflects an estimate
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of the time needed to physically construct, or implement, the
remedy. In addition, all remedies, except no action, require a
design phase which typically takes 12-18 months to complete.
Source Remediation (SO
o 8C-1: No Action
o SC-2: Off-Site Incineration
o 8C-3: Low Temperature Thermal Extraction
o SC-4: Soil Tilling
o 8C-5: In-Situ Vapor Extraction
SC-l: No Action
Capital Cost: $0
Present Worth Cost: $331,000
Time To Implement: Immediate
In this alternative, no remedial action would be taken which
would address contaminated soils. A monitoring program for soils
and groundwater would be conducted once a year for a maximum of
thirty years with a site review conducted at least every five
years as required by regulation.
SC-2: Off-Site Treatment (Incineration)
Capital Cost: $49,400,000
Present Worth Cost: $49,400,000
Time To Implement: 3 months
Under this alternative, soils contaminated above selected cleanup
levels, as well as a certain amount of "buffer" soils (those
relatively clean soils which underlie the contaminated soils),
would be excavated and transported to an offsite hazardous waste
treatment facility. The methods of offsite treatment of VOCs
required to meet RCRA land disposal requirements may vary;
however, offsite incineration has been chosen as part of this
alternative for the purpose of developing cost and schedule
information. Clean fill would be used to backfill the site
excavation. The estimated volume of soils from areas 2 and 4 to
be excavated and treated offsite is 25,220 cubic yards (cy).
8C-V "-- T.-r ,.-/- ?.:• ~ •- -1 Extraction
Capital fr=f $3,400,000
Present Worth Cost: $8,400,000
Time To Implement: 6 months
Under this alternative, the same volume of soils as in
alternative 8C-2 would be excavated from areas 2 and 4. These
soils would be treated onsite using low temperature thermal
extraction technology to remove volatile hazardous contaminants
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in the soil until selected cleanup levels are attained. The
gaseous and particulate contaminants removed from the soil would
be passed through a baghouse, followed by a condenser, and
finally an afterburner. Afterburner emissions would be monitored
to insure compliance with all applicable State and Federal air
regulations. The aqueou.s fraction from the condensor would be
treated via carbon adsorption, and the spent carbon as well as
the organic fraction from the condensor would be disposed of at
an offsite hazardous waste treatment facility. The treated soil
would be used as backfill in the excavated areas, once it was
determined that the soils no longer contained hazardous waste.
8C-4: Soil Tilling
Capital Cost: $3,300,000
Present Worth Cost: $3,300,000
Time to Implement: 8 months
Under this alternative, the same volume of soils as in
Alternative 8C-2 would be excavated from areas 2 and 4. The
excavated soils would then be placed in a 1.5 foot thick layer on
a concrete pad with curbing. The soil would then be mechanically
"tilled" or agitated periodically. Tilling would continue
intermittently over a period of time causing a gradual
volatilization of VOCs to the atmosphere. Monitoring would be
performed to indicate when selected action levels were attained.
No controls on air emissions are envisioned under this
alternative; moreover, preliminary calculations indicate that,
due to the slow rate of volatilization expected, no contravention
of NYS standards would occur if this alternative were
implemented. The treated soil would be used as backfill in the
excavated areas, once it was determined that the soils no longer
contained hazardous waste.
v\
Rainwater collected on the curbed pad would be allowed to
evaporate. The curbing would be designed for a 100 year, 24 hour
storm event. .
8C-5: In Situ Vapor Extraction
Capital Cost: $1,700,000
Present Worth Cost: $1,700,000
Time to
under this alternative -'?por extraction wells would be located
in areas 2 and 4. Subsurface vapor monitoring equipment would
also be installed in both areas. The extraction wells would be
manifolded together and attached to vacuum pumps in order to pump
subsurface soil gases contaminated with VOCs through a carbon
adsorption unit prior to discharge to the atmosphere. Pumping
and treating subsurface soil gases would continue until the
monitoring equipment indicates that the selected soil cleanup
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levels have been attained. Soil sampling and analysis would then
be conducted to confirm that soil cleanup levels had been
achieved. Contaminated activated carbon would be disposed of at
an offsite hazardous waste facility.
Bench scale and possibly pilot tests would be required to develop
the appropriate design parameters for this alternative.
Potable Water Treatment (GW
GW-l: No Action
GW-2: Precipitation + Filtration
GW-5: Filtration + Ion Exchange
GW-l: No Action
Capital Cost: $20,000
Present Worth Cost: $20,000
Time to Implement: Immediate
Under this alternative, groundwater would be monitored
periodically for inorganics in the Vestal Water District 1 study
area. Existing groundwater monitoring wells, as well as two
additional wells that would be installed in the northeast part of
the study area, would be utilized for this monitoring.
The monitoring for inorganics under this alternative would be
included in the monitoring plan that has recently been developed
for the first operable unit remedy (Appendix 4). This plan also
includes a monitoring schedule for the organic compounds of
concern.
GW-2: Precipitation + Filtration
Capital Cost: $3,700,000
Present Worth Cost: $17,900,000
Time To Implement: 8 months
Under this alternative, the monitoring plan as described under
GW-l would be implemented. In addition, the dissolved inorganic
constituents of the groundwater at Well 1-1 would be treated via
the addition of the chemicals trfTr-ercaoto-s-triazine and lime to
form a precipitate of metal. c-.:. - ;'. 1"1.. i—u^i^itate could
then be removed, along with any other particulate matter, via
settling and filtration, niui-v- • -,^.tores .;;:ci p-iMic filter
backwash would then be dewatered in a filter press and the
filtrate recycled back to the beginning of the treatment system.
The filtered solids would be disposed of offsite at a hazardous
waste handling facility.
Treatability studies would be needed to determine appropriate
design parameters for this alternative.
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This alternative would require 8 months to construct. Its design
life would be 30 years.
GW-5: Filtration + Ion Exchange
Capital Cost: $4,000,000
Present Worth Cost: $70,000,000
Time To Implement: 8 months
Under this alternative, the monitoring plan described under GW-i
would be implemented. In addition, any particulate matter in the
influent water from Well 1-1 would be removed via filtration and
the dissolved inorganics would then be treated via ion exchange
technology. This technology would need to employ a mercury-
specific ion exchange resin, as well as a more generic ion
exchange resin for the removal of other metals in the influent
water. The resins would then be periodically regenerated for
reuse.
The filtered particulate matter and spent ion exchange
regeneration solutions would be disposed of at an offsite
hazardous waste facility.
Treatability studies would be needed to develop appropriate
design parameters for this alternative.
This alternative would require 8 months to construct. Its design
life would be 30 years.
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 Vestal
Water Supply Well No. 1-1.
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 rrr4--•••""«•, ;..-, ;,..•• ; -• >i
controls. A comprehensive risk analysis is included in the
Public Health Evaluation.
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
waiver. A complete listing of ARARs for this site can be found
in section 2 of the FS.
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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
a remedy to maintain reliable protection of human health and the
environment over time, once cleanup goals have been met. It also
addresses the magnitude and effectiveness of the measures that
may be required to manage the risk posed by treatment residuals
and/or untreated wastes.
o Reduction of toxicitv. mobility, and volume refers to the
anticipated performance of the treatment technologies, with
respect to these parameters.
o Implementabi1ity 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 0 and 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 and 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 indicates whether, based on a review of
public comments received on the RI/FS report and on the Proposed
Plan, the public concurs with, opposes or has no comment on the
preferred alternative.
Analysis
I. Source Remediation
The source remediation alternatives were developed to address the
contamination found in soils in the Stage Road Industrial Park
which was felt to present significant risk or curtcrwise pose o.u
unacceptable impact to public health or the environment. The
remedial response objectives for which the sourc- i*sinfeu\Vi:iu:i
alternatives were formulated are:
-Ensure protection of groundwater from the continued release
of VOC contamination from soil; and
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-Ensure protection of human health, presumably that of site
workers who are exposed to contaminated soils through
excavation.
o Overall Protection of Human Health and the Environment
EPA believes that source alternatives 8C-2 through 8C-5 would be
sufficiently protective of human health and the environment.
However, this protection varies in that alternatives 8C-2, 8C-3
and 8C-5 provide similar protection through the removal of VOC's
from the site, while 8C-4 provides somewhat less protection by
gradual on-site venting of VOC's to the atmosphere. 8C-1 (No
Action) provides limited protection in that, given no changes in
future uses of the Industrial Park which would involve water
withdrawals for potable water use or significant amounts of soil
excavation in contaminated areas, public health could be
sufficiently protected by the remedial actions implemented under
operable unit one. Under the no action alternative, however, the
aquifer would continue to be degraded for an indefinite period of
time from volatile organic contaminants leaching from the soils
in areas 2 and 4. This prolonged degradation of the aquifer
could conceivably extend beyond the design life of the operable
unit one air stripping facility, thereby requiring treatment at
Well 1-1 far into the future. Conversely, treatment of the soils
could significantly reduce the time which the air stripper would
be required to operate.
o Compliance With ARARs
Possible ARARs for remediation of the source at this site include
appropriate and relevant portions of the Resource Conservation
and Recovery Act (RCRA) and its implementing regulations, and
State and Federal air quality laws and regulations.
Compliance "with RCRA ARARs influenced the development of
alternatives SC-2, 8C-3, and SC-4, since these alternatives would
involve excavation and subsequent placement of RCRA hazardous
wastes.
RCRA Subtitle C requirements are considered applicable for off-
site treatment and disposal alternative 8C-2. Moreover,
conformance with RCRA closure and Land Disposal Restriction (LDR)
requirements for alternative 8C-2 would ultimately *-. • '••:'.,
responsibility of the RCRA hazardous waste treatment and uisposai
facility.
Under alternatives 8C-3 and 8C-4, the soil would no longer be
deemed to contain hazardous wastes after it is treated to below
health-based levels and the treatment standards required by LDRs.
The treated soil would be subjected to the Toxicity
Characteristic Leaching Procedure (TCLP) to determine whether it
st.ill contains any listed RCRA hazardous wastes above the
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treatment standards required by the LDRs. All soil emerging from
the treatment that fails the TCLP test would be retreated so as
to meet these standards. All soil would be treated so that it
does not contain RCRA hazardous wastes above the health-based
levels determined by the risk assessment. Because the soil would
no longer contain any listed RCRA hazardous wastes above health-
based levels, and because it would meet the LDR treatment
standards (TCLP concentrations) it would not be subject to
regulation under Subtitle C of RCRA and may be used to backfill
the excavated areas on-site.
Alternative 8C-5 is not subject to RCRA land disposal
restrictions or closure requirements since no excavation and
subsequent placement of hazardous wastes would occur under this
alternative.
In addition, alternatives 8C-2, 8C-3 and SC-5 would also conform
to RCRA Section 3003 (40 CFR 262 and 263, 40 CFR 170 to 179)
regulating the offsite transportation and management of hazardous
waste.
It is presently anticipated that all the alternatives would meet
Federal and State air quality ARARs.
o Short-term Effectiveness
Alternative 8C-1 poses the least short-term risks due to
implementation of the remedy (potential for no action), while 8C-
4 poses the greatest short-term risk due to inhalation of VOCs
from the soil tilling operation. SC-2, 8C-3 and SC-5 are similar
in their short-term risks and intermediate between the other two
alternatives in this regard.
o Loner-term Effectiveness And Permanence
Alternatives 8C-2 through SC-5 all provide permanent protection
and would therefore be effective over the long term.
Implementation of alternative 8C-1 would not only pose a long-
term hypothetical risk of worker exposure to excavated
contaminated soils, but would also prolong the time necessary for
aquifer cleanup, since contaminated soils left in place would
continue to contribute to aquifer contamination. In terms of the
other source remediation alternatives, SC-5 would require
treatability testing to determine the length of time necessary co
reach selected action levels. Excavation and treatment
alternatives 8C-2, 8C-3 and 8C-4 would all be effective within
relatively short periods of time. 8C-2 would achieve effective
and permanent cleanup in the shortest period of time.
o Reduction Of Toxicity. Mobility. And Volume
Alternatives 8C-2, 8C-3, and SC-5 would all be effective in
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reducing the toxicity, mobility, and volume of site contaminants.
8C-2 achieves thermal destruction of the VOCs present in the
soil, while 8C-3 and 8C-5 result in volatilization of VOCs and
subsequent capture by air pollution control devices. 8C-4 would
result in the transfer of VOCs to the atmosphere. However, the
rate of this transfer is gradual enough so that no adverse
impacts or contravention of applicable standards is anticipated.
8C-1 would not affect the toxicity, mobility, and volume of
contaminants other than through normal flushing of soil via
precipitation events.
o Implementability
All of the source control alternatives are considered technically
and administratively implementable. However, alternatives SC-2,
SC-3 and SC-4, which involve on-site excavation would require
extensive coordination with and may adversely affect the
activities of some tenants of the Industrial Park.
o Cost (table 4)
8C-1, or the no action alternative, would obviously be the least
expensive to implement. SC-5 would be the least expensive of the
alternatives for which remedial action would take place. SC-4 is
twice the cost of SC-5, while SC-3 is more than twice the cost of
8C-4. 8C-2 is the most expensive source control alternative, and
is approximately six times the cost of SC-3.
o State Acceptance
The State of New York concurs with the selected remedy (see State
letter of concurrence-Appendix 5).
o Community Acceptance
\
EPA believes that the selected remedy has the support of the
affected community, based on the comments received during the
public comment period, including those comments received during
the public meeting held on May 31, 1990. EPA also believes that
the selected remedy is acceptable in principle to Chenango
Industries, based on the company's recent correspondence with
EPA. Other potentially responsible parties have not given
similar indication as of the date of this ROD.
II. Potable Water'Treatment
The GW-1, GW-2, and GW-5 alternatives are designed to address the
impact of inorganic groundwater contamination, which has been
detected hydraulically upgradient of Well 1-1, on Well 1-1. The
historic source of these inorganic contaminants may have been the
Stage Road Industrial Park, where elevated levels of chromium and
copper have been found in the soils, albeit in amounts which do
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not present unacceptable present or future public health risks.
The source of the mercury detected in certain monitoring wells
during the second operable unit RI is presently unknown.
The remedial response objective for which the potable water
treatment alternatives were formulated to meet is:
-Ensure protection of Vestal Well 1-1 water quality from any
groundwater contamination not addressed in the first
operable unit.
Aquifer restoration, other than the restoration provided for by
the continuous pumping at Well 1-1, was not included as a
remedial response objective for groundwater, since EPA determined
during the 1st operable unit that the hydrogeology in the study
area would not be amenable to an appreciably faster aquifer
restoration through selective placement of extraction wells into
the plume of contamination.
o Overall Protection Of Human Health And The Environment
All of the alternatives, including no action, are currently equal
in their protectiveness of human health and the environment,
since Well 1-1 has never shown contamination with inorganics
above health-based levels. However, no action under GW-1
involves a level of uncertainty regarding long-term
protectiveness, since inorganic contamination in the vicinity of
Well 1-1 may someday be detected at the Well. Therefore, the
inclusion of a groundwater monitoring program for inorganics
under this alternative would serve to mitigate this uncertainty.
o Compliance With ARARs
All of the alternatives would meet ARARs for potable water i.e.,
Part 5 of the NYS Sanitary Code, as measured in the effluent from
the Well 1-1 treatment facility. However, alternative GW-1 would
no longer meet ARARs in the effluent of Well 1-1 if the Well
becomes significantly contaminated in the future with the
inorganics of concern.
Compliance with groundwater ARARs for organic contamination at
any point within the aquifer i.e., not necessarily at Well 1-1,
was addressed during the first operable unit Record of Decision,
which indicated that 20 or more years would be needed to meet
these requirements within the aquifer given continuous pumping at
Well 1-1, as required under the first operable unit ROD.
Compliance with groundwater ARARs for inorganic contamination at
any point within the aquifer was not previously addressed in the
first operable unit Record of Decision. Moreover, the ability to
meet these ARARs at all points throughout the area of attainment,
or plume, cannot be specifically determined at this time.
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However, EPA believes it is reasonable to assume that inorganic
contaminants will also meet ARARs within the aquifer in 20 years,
given continuous pumping at Well 1-1.
Alternatives GW-2 and GW-5 would also conform to RCRA Section
3003 (40 CFR 262 and 263, 40 CFR 170 to 179) regulating the
offsite transportation and management of hazardous waste.
o Short-term Effectiveness
Alternatives GW-2 and GW-5 may have minor short term construction
impacts associated with their implementation, including possible
disruption of service to the operation of Well l-i. However,
these impacts should be mitigable through the observance of
proper health and safety protocols and the formulation of an
acceptable remedial action workplan.
o Long-term Effectiveness And Permanence
Both GW-2 and GW-5 would be effective and permanent in the long
term. GW-l's long term effectiveness is uncertain, since
inorganic contamination in the vicinity of Well 1-1 may someday
be detected at the Well; however, the monitoring plan associated
with GW-1 should provide ample assurance of the effectiveness of
the remedy.
o Reduction Of Toxicity. Mobility. And Volume
None of the alternatives would reduce the toxicity, mobility or
volume of inorganic contaminants until such time as the
contaminants reached Well 1-1. Present site information cannot
confirm whether inorganic contamination of Well 1-1 will ever
occur.
o Impleroentability
EPA believes that all of the potable water treatment alternatives
would be implementable; however, GW-1 would be the easiest and
least expensive to implement, since a groundwater monitoring
program is already in place. Implementation of GW-5 would be
less space intensive than GW-2 i.e., room needed for additional
treatment units, although EPA presently believes that both
alternatives can be implemented in this regard. The
implementation of GW-2 and GW-5 would require coordination with
the design engineer of the air stripping facility and the Town of
vj-icil, in order to ensure system and operational compatability.
o Cost (table 4)
The cost associated with alternative GW-5 is greater than three
times the cost of GW-2 in terms of present worth costs. O and M
makes up a significant portion of the present worth costs of
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alternatives GW-2 and GW-5, due chiefly to the cost of waste
residuals disposal associated with the respective treatment
processes. There are minimal costs associated with GW-1.
o State Acceptance
The State of New York concurs with the selected remedy (see State
letter of concurrence-Appendix 5).
o Community Acceptance
EPA believes that the selected remedy has the support of the
affected community, based on the comments received during the
public comment period, including those comments received during
the public meeting held on May 31, 1990. EPA also believes that
the remedy is acceptable in principle to Chenango Industries, a
potentially responsible party, based on the company's recent
correspondence with EPA. Other potentially responsible parties
have not given similar indication as of the date of this ROD.
SELECTED REMEDY
The selected remedy for the Vestal Well 1-1 combines the source
remediation alternative 8C-5 with the potable water treatment
alternative GW-1. As explained below, EPA believes that a
contingency remedy for potable water treatment should also be
specified at this time.
The EPA believes that this combination of alternatives represents
the best balance among the criteria used to evaluate remedies.
Cost estimates associated with the selected remedy are:
Capital Cost: $1,700,000
Present Worth Cost: $1,700,000
In addition/ EPA has made provision for a contingency remedy (GW-
2) as part of the potable water portion of the selected remedy,
in the event that Well 1-1 becomes contaminated with inorganic
contaminants in the future. Cost estimates associated with the
contingency remedy are:
Capital Cost: $3,700,000
P-reseni- Wnrth Cost: $17,900,000
See table 5 for a more complete breakdown of costs associated
wJ!..r th- r.vli^LfcJ remedy.
Specifically, the selected remedy will involve the following
actions:
-------
24
Source Remediation
The source remediation alternative 8C-5 (figure 14-shown just for
area 4) will be implemented in source areas 2 and 4 and is
intended to provide in situ removal of all VOCs present, as
indicated by attainment of the following action levels for
indicator chemicals:
INDICATOR CHEMICAL ACTION LEVEL
Trichlorethylene 140 ug/kg
1,1,1-Trichloroethane 170 ug/kg
1,2-Dichloroethylene 188 ug/kg (for area 2 only)
These action levels represent the average concentration of an
indicator chemical in the soil within a given source area which
would theoretically produce a concentration in groundwater at the
property boundary of the Industrial Park equal to applicable
potable water standards.
First, additional boreholes will be drilled to further define the
extent of the VOC soil contamination in areas 2 and 4. These
additional samples will be analyzed for both inorganic and
organic hazardous compounds of concern. Areas 2 and 4 should be
more accurately defined using the results of these samples.
Should this additional sampling indicate any unexpected
concentrations or types of contamination not amenable to the SC-
5 source remediation, then EPA will determine whether the
unexpected contamination requires remediation and what
administrative steps are required to effect the remediation.
Second, a bench and/or pilot scale treatability study will be
needed to ascertain design parameters for the full scale
implementation of this alternative. Some of the parameters to be
determined are: optimum number and spacing of extraction wells;
depth of extraction and monitoring wells; capacities of vacuum
pump(s) and carbon adsorption treatment system(s) needed for full
scale implementation, etc. These tests will also serve to help
estimate the amount of time required to meet the selected action
levels. Next, a remedial design will be prepared, followed by
implementation of the remedial action.
r-.r.~o-..:-Vs»]'-.- *v-. *-r:r-, lamentation of 6C-5 will consist of soil gas
^..wiiwwiwn weiis installed in the unsaturated zone above the
wafer table. It is assumed that approximately fourteen wells
*ili u& neoieu i;i area 4 and approximately four wells in area 2,
based on a radius of influence of 25 feet per well. Depth of the
wells is assumed to be 20 feet. Five gas monitoring wells
(estimated four in area 4 and one in area 2) will also be needed
to monitor subsurface soil gas conditions. The extraction wells
will be constructed of 2 inch PVC pipe designed with a vacuum
seal near the surface and an extraction zone corrcspoiidiiv..: >o the
-------
25
profile of the subsurface contamination. The monitoring wells
will also be constructed of 2 inch PVC pipe and will be placed in
accordance with the treatability study design to monitor the
contaminant concentrations in soil gas. A method and schedule of
securing additional soil borings will also be developed for the
purpose of determining the progress of the selected remedy toward
achieving the selected action levels in the soil.
The extraction wells will be connected to a common header which
will be attached to the vacuum pump(s). The vacuum pump(s) will
extract the contaminated vapors from the soil and relay the
contaminated air through activated carbon canisters, and
afterwards discharge the clean soil gas to the atmosphere. It is
assumed that two vacuum pumps will be used, one for each
contaminated area. Spent activated carbon will then be disposed
of at a RCRA hazardous waste facility.
The actual details of the design of the soil remediation portion
of the selected remedy may vary from the conceptual details given
above; however, the use of vacuum extraction technology will
remain the basis for the remedial design.
A public information program will be included in the revised
community relations plan for remedial action. This information
program will inform the public and the users of the Stage Road
Industrial Park about the expected impacts of this remedial
action on the Park.
The selected soil action levels to be achieved in areas 2 and 4
are based on meeting applicable requirements for groundwater
contaminants at the Stage Road Industrial Park border, which EPA
considers to be the potential location of the closest theoretical
groundwater receptor. As such, these action levels provide a
margin of safety for potable water withdrawals from Well 1-1,
which is approximately 1000 feet northwest of the Industrial Park
border. This margin of safety is in addition to the
protectiveness provided by the operation of the Well 1-1 air
stripping facility.
Moreover, in the event that the selected action levels can not be
achieved within the period of time estimated in the treatability
study, EPA believes that the protectiveness of this remedy at
Well 1-'1 '-^.1 r.ot i.u compromised, i.e., the remedy will reduce
the volume ot contaminants in areas 2 and 4 to levels that do not
threaten thr. water supply at Well 1-1. The vacuum extraction
system will be operated until the selected action levels are met
or until the system is no longer effective in removing volatile
organic contamination, whichever comes first.
The risks associated with the average and reasonable maximum case
exposures to volatile organics from excavated soils in area 4,
which were determined to be marginally acceptable when compared
-------
26
to EPA's acceptable risk range, will be further mitigated by the
implementation of the SC-5 alternative.
EPA also believes that the existing land use in the area of
groundwater attainment, or plume i.e., industrial/light
commercial, as well as the present availability of the Town's
water supply to the area, together provide substantial safeguards
against groundwater withdrawals from the presently contaminated
area of groundwater attainment (other than Well 1-1) for potable
water purposes.
Potable Water Treatment
The potable water treatment selected remedy GW-1 (no action) will
involve installation of two additional groundwater monitoring
wells, and the periodic review of the groundwater data collected
under the monitoring program for the first operable unit to
determine whether any changes in inorganic groundwater
contamination have taken place in the Vestal Well 1-1 study area.
EPA believes that no further remedial action is necessary at the
present time.
Contingency Remedy
Groundwater will be monitored once every six months at selected
monitoring wells in order to measure any changes in the inorganic
groundwater contamination. If the groundwater monitoring program
indicates that any inorganic contaminant of concern is increasing
above baseline levels in close proximity to Well 1-1, then a
contingency remedy for potable water treatment i.e., GW-2, will
proceed to the design stage. For the purpose of this paragraph,
the inorganic contaminants of concern will be mercury, chromium,
and lead.
The criteria of "increasing" and "close proximity", as used in
the preceding paragraph, will be defined as follows:
"increasing"-an upward trend in total concentration above
the present baseline concentration presently established for
a monitoring well of any inorganic contaminant of concern
over two consecutive monitoring periods. For a monitoring
well where baselines were not established during the second
RI, the init' ':. • •.. _ ":- -.-" •••••- :^.cl.~d remedy's monitoring
program will serve ro establish this baseline.
"close proximity"-wells 1-24, 1-29, and l-29a.
Actual implementation (construction) of the contingency remedy
would then be initiated should any of the inorganics of concern
be detected and confirmed at Well 1-1, unless institutional
constraints are present at that time which prevent implementation
from taking place.
-------
27
The above approach has been developed by EPA because of the
uncertainties involved in predicting the likelihood of
significant concentrations of inorganic contamination reaching
Well 1-1 and the relatively low cost of design as compared to the
overall cost of contingency remedy implementation. In addition,
the above strategy will result in faster implementation of the
contingency remedy, should it ever be required.
Monitoring well baseline concentrations and Well
-------
28
determine whether any groundwater contamination appears to be
reaching the Susquehanna River.
The potable water treatment portion of the selected alternative
will also be subject to the 5-year review provisions of Section
121(c) of CERCLA. Moreover, these provisions will be implemented
through the monitoring program developed for operable unit one.
Compliance with groundwater ARARs for inorganic contamination as
measured within the aquifer was not previously addressed in the
first operable unit Record of Decision. Moreover, the ability to
meet these ARARs a't all points throughout the area of attainment,
or plume, cannot be specifically determined at this time.
However, EPA believes it is reasonable to assume that inorganic
contaminants will meet ARARs within the aquifer in approximately
20 years, which is also EPA's present estimate for meeting
organic ARARs in the area of attainment. This estimate assumes
that Well 1-1 is continuously pumped for that period of time.
Under the 5-year review provisions of CERCLA, EPA will review the
inorganic data collected pursuant to the above-described
monitoring plan in order to, besides the other reasons mentioned,
determine the progression of the area of attainment toward
meeting all ARARs (both inorganic and organic) within the 20 year
estimated period. Should EPA determine at any time that meeting
ARARs within the area of attainment is not likely within the
estimated time period, then EPA will re-evaluate the time needed
to meet ARARs and the remedial action objectives. If necessary,
EPA will then require that additional remedial action be
implemented.
EPA believes that the selected remedy for potable water
treatment, including the provision for a contingency remedy at
this time, ensures that the Vestal Well 1-1 water supply, which
now meets all applicable potable water standards through the
recent addition of the air stripping facility, will continue to
meet all potable water standards in the future. Inclusion of a
monitoring program ensures that a contingency remedy for potable
water treatment of inorganics will be available in a timely
manner should it ever be needed.
* * * * * *
The source remediation and potable water treatment elements of
this selected remedy fulfill the source investigation
requirements of and are consistent with the 19U6 ~.;.c rj -"if
Decision for the first operable unit.
STATUTORY DETERMINATIONS
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,
-------
29
the selected remedial action for this site must comply with
applicable or relevant and appropriate environmental standards
established under Federal and State environmental laws unless a
statutory waiver is justified. The selected remedy also must be
cost-effective and utilize permanent solutions and alternative
treatment technologies or resource recovery technologies to the
maximum extent practicable. Finally, the statute includes a
preference for remedies that employ treatment that permanently
and significantly reduce the volume, toxicity, or mobility of
hazardous wastes as their principal element.
Protection of Human Health and the Environment
Both parts of the selected remedy protect human health and the
environment. The source remedy will reduce the concentrations of
VOC's in the soils in area 2 and 4 such that the underlying
aquifer will eventually no longer be adversely impacted by
leaching of VOC's into the groundwater. It may also eventually
eliminate the need for treatment of VOC's at Well 1-1 by
reduction of the source of this contamination. In addition, the
reduction of VOC's will also reduce the hypothetical risk of
human exposure to any soils excavated from areas 2 and 4.
The potable water treatment remedy, although it specifies no
action at this time, includes a contingency remedy for treatment
of inorganic (heavy metals) contamination should EPA determine
that a need exists for such a remedy. This remedy is therefore
structured to provide further assurance that Well 1-1 will
provide potable water meeting all applicable regulatory standards
to Water District 1 on a long-term basis.
Compliance With Applicable or Appropriate and Relevant Standards
The selected remedy including the contingency remedy is expected
to comply with all applicable or appropriate and relevant state
and federal requirements. Some of the requirements which will be
accounted for in the design of the source remedy are those of 6
NYCRR parts 212 and 231 for new source emission rates in non-
attainment areas and for emission rate standards, respectively.
In.addition, all RCRA and U.S. Department of Transportation
regulations governing the offsite transportation and disposal of
hazardous wastes will be observed. Federal OSHA standards will
also be complied with during construction-
State potable water standards i.e., 10 NYCRR part 5, will not be
contravened at Well 1-1 during its use as a potable wauei. supply.
In the event that inorganic contamination of Well 1-1 occurs in
the future, the potable water treatment contingency remedy
selected at that time would ensure that these standards continue
to be met at Well 1-1, although the Well might briefly be out of
service (less than one year) while the contingency remedy is
being constructed.
-------
30
Other state and federal criteria which will be considered during
the design of the remedy include Executive Order 11988 on
Floodplain Management.
Cost Effectiveness
The selected remedy is cost-effective because it has been
determined to provide overall effectiveness proportional to its
costs (present worth= $1,700,000).
Utilization of Permanent Solutions and Alternative Treatment
Technologies for Resource Recovery Technologies) to the Maximum
Extent Practicable and Preference for Treatment as a Principal
Element
The use of.in situ vapor extraction/carbon adsorption technology
to separate the contaminants of concern from the site soil matrix
and to subsequently dispose of the contaminants at an approved
RCRA facility satisfies the statutory preference of CERCLA for
utilizing permanent solutions and alternative treatment
technologies to the maximum extent practicable. This part of the
selected remedy will also permanently and significantly reduce
the toxicity, mobility and volume of hazardous wastes in the
soils at the site.
The selection of GW-1 (no action) for potable water treatment
meets the objectives of the second operable unit dealing with the
Well 1-1 potable water supply through the specification of a
procedure for contingency remedy GW-2 selection and
implementation. EPA believes that the addition of this remedy to
the remedy previously chosen for the first operable unit i.e.,
air stripping facility, represents a permanent solution to the
present and potential contamination of Well 1-1. The potable
water contingency remedy would also provide treatment of
inorganic contamination as the principal element of the remedy,
should such treatment ever be required.
DOCUMENTATION OF SIGNIFICANT CHANGES
The Proposed Plan for the Vestal Well 1-1 Superfund site was
released to the public in May 1990. The Proposed Plan identified
Alternatives 8C-5 and GW-1 (with provision for ei.t-^r "•~^-"- •:•• ^
5 as the contingency remedy) to remediate the source anu auuress
additional potable water treatment, respectively. EPA rf>vl?w?r.^
all comments submitted during the public comment perioa. upon
review of these comments, EPA determined that, based upon public
comment concerning the high cost of potable water alternative GW-
5, that potable water alternative GW-2 would be selected as the
contingency remedy. No other significant changes to the selected
remedy, as it was originally identified in the Proposed Plan,
were necessary.
-------
APPENDIX 1
-------
AVCRAGC AND PlAUSIfill MAXIMUM SOU COHCfNIRA1 IONS TOR CXPOSURC HOOtUNG
VCS1AI WELL l-l SMC
AREA 1
ClltMlCAL .............
Average Case (*)
<«g/K9l
Acetone '
Beniene 0.003
2-Butanone 0.034
Chloroform *
I.l-Olchloroethane '
l.l-Olchloroelhylene '
trans-l ,2-Olchloroelliy lene 0.003
Cthylbenfene 0.005
1 . 1 ,2.2-ltlrachlorOL-lhane '
letrachloroelhylene '
toluene 0.005
l.l.l-lrli:hloroetha«o
Ir ichloroethylene
lyrene 0.007
Bl:!Z-eth>-lhe»yl)phtlijlale
Ol-n-bulylphthalate
Noncarcinogenic PAHs 3.9
Carclnogenoc PAHs l.t
PCBs
Chromium ?4
Copper *
AREA 2
Plausible 'Average Case (a)
Maximum Case (b)
(mg/kg) (mg/kg)
* ft
0.003 0 003 c
0.034 0.026 e
* 0.007 e
* 0 009 c
* 0.003 c
0003 0.118
0 022 0 087
• 0 04 c
0 067
0 01 0 052
0.075
0.171
0 054 e 0.197
0.4
0.065 c
95 B 3.4
5.5 08c
0.15
24 47
23
ARC A 3
Plausible Average Case (a) Plausible
Maximum Case (b) Maximum Case (b)
(mg/kg) (mg/kg) (mg/kg)
0.195 7.08
0.003 « •
0 026 e 0.01 0.012
0.007 e * *
0.009 0.004 c 0.004
0.003 c 0.003 e 0.003 e
0.312 0.004 c 0.013 d
0 1 59
0 04 d
0.298
0 33
0.425 0.002 e 0 002 e
5.045
2 038 * *
0 73 0.39 1 1
0.065
5.16 0.32 e 0.32 e
1 5 d 0 05 e 0 Or, e
0.378
47 9.2 14.2
23 77 77
ARC A 4
Average Case (a) Plausihle
Maximum Case (b)
(mg/kg) (mg/kg)
1.382 12.852
* t)
•
* •
0 12 0.186 ^
0 005 c 0.005 >
1
• • m
M
0.00? e '0 002 e
• •
0 I5H 0.216
0.134 0.864
• *
0 ?1 .1 'B?
• "
0.2 0.23 e
*
0.05 0 SS e
20 20
46 46
' Chemical not detected in this area.
(a) Geometric mean with one half the detection limit for non-detects unless otherwise noted.
(l>) Geometric mean ol detected values only, unless otherwise noted.
(i | fieomplrtc mean ul detected values only
(til Ger»nolric mean mlh non-delect s.
(p) Onl-; deluded » • '«»•
-------
TABLE 2
SUWURT w HT.AIIN trrccn c«nf«i« ff* CUKICAIS or POUNIIAI COKCIOH
•ISIAl MU 1-1 SMI
ORAi CRIICRIA
CJ« HICAl
K*lt*l
l.l-DICKimOt III«M(
1.1-DIUtOROtlll'lCHC
1RANS-I.?-OICI»U«OC1HTUIIC
C1MTI Bt«.'C«C
TUBACHYOeOnilTI CHC
toucut
I.I.I-IIICHIOBOI IMAHC
IR ICHLOROf IIITLI UC
ITlCKCS
il S12-F.THTI 1IC I'l )r*HlHAlAlt
CABCmoGfuiC P»»s (e)
•0«CA»CUO&i»IL PAIIi (f)
AC UOHC
2-BUIAIKMC
DI-N-BUIUPHIIUII ATE
1 . 1 . ? . ?- 1C TRAllll OR OC TluUIC.
AK 1 1 MQBT
ASSCHIC
BARIUM
BCUUUUH
CIHOMIu* (g)
COPPO (h)
ICAO 111
HAKuAMCSC
PgRCURI
•ICICl
SCUNIUH
IIIAUlu*
VAMADIUI
/.nc
*T
la) Safely f»i lorj used lo
Reference CPA/CAG
Oose Safely Source (bl Cancer
(010) faclor (a) Potency
(mg/kg/d) factor (.
(«g/kg/d)-l
1
9
2
1
1
3
9
7
2
?
4
1
5
1
4
1
5
i
i
3
j
3
?
3
7
7
J
.
ooc-oi
OOC-03
ooc -o?
ooc-oi
OOC -0?
ooc-oi
oor -o?
3SC -03 "
OOC '00
001-02
ooc-oi
ooc-oi
OOC -02
OOC-OI
ooc -04
OOC-03 •
ooc-o?
OOC-03
OOC-03
70C-0?
OOC-OI
OOC -04
ooc-o?
OOC -03
OOC -OS
OOC 03
ooc-oi
.OOC -03
OOC -03
OOC-03
.OOC >03
OOC '03
ooc .02
OOC '03
OOC -03
OOI >0?
OOC' 03
..
ooc-o?
.OOC '03
.OOC-03
.OOC '03
OOC '03
OOC '00
OOC >0?
001-0?
.OOC'O?
-•
OOf -0?
.OOC -03
OOC - 0?
sot -oi
OOC-03
OOI -0?
.OOC-OI
Develop reference doses consist
in Ihe d*'* available Ihe standard uncertainly factors
IRIS
Hl»
IRIS
IRIS
IRIS
IRIS
IRIS
IRIS
HA
IRIS
IRIS
HCA
IRIS
IRIS
IRIS
IRIS
HfA
IRIS
IRIS
IRIS
HCA
m A
HCA
IRIS
HCA
HTA
HI A
HCA
••
of ni It i
inc Imle
?.90C-
9 IOC-
6.00C-
S.IOC-
1 I0t-
1 40C-
1 . 1 SC •
.-
2 OOC-
1 /«•
..
7 70C -
pies of 10
0?
0?
01
0?
o:
0?
01
02
00
oo •
each
iv I'l y among the
IM
of (RIO) fallu. (a)
A -- (,l|
C i ooi -oi i out -o)
c :.
B?
1 OOC-00 1 OOC-03
3 OOC 01 1 OOI -O.I
8?
« ooc-oi i noi -oj
B?
B?
9 ooi-o: i.ooc-o)
c
A
1. OOC -04 1 OOC -OJ
B?
'3 OOC -04 1 001 -0.'
I ooi 03 i one -oi
. .
B?
factor represent inq « *p-?ctfic 4if<*
«e4»r, ol II- h..—. p-imlatinn.
Al Al IOK
S.,u,c,
Ml A
HI A
HI <
lit A
HCA
HI A
HI A
HI A
nl u*i< e
? 901-0?
I ?Ol-OJ
J 301 OJ
4 601 OJ
6 101-00 '
,- OOI -01
•> OOI -01
8 401-00
4 101-01
0 A Irn-lold l«Ctor to Account for tn« uncetAlnty in e>lrjpo Ut inf) «n mid I d4l<« to (br Cdse nf KIMIMMS.
O A len-fold C«ctor to account for the uncerl4inty in eitrjpo l«t tng from less th«n chronic No Oliser«^'l Ailwe'se C'le'l'. l^«-l. (NOAfts)
il.ronic NOAflt: «nd
e A ion-fold fjclor to account for the uncertainly in eitr«pol«tmq from Lowest Observed Adverse Cl'ect levels (lUAClsl lu NQAIis
(b) Sources ol Reference Ones IRIS • chemical files of the Integrated Risk Informal 1011 System (Hoy 1. I9b*i). HI A • Hedlin
effects A.^essments. HA • Health Advisory.
(cl Uetqht ol evidence c Ussif ical ton scheme for carcinogens
A •- H-m-an Carcinooen. sufficient evidence from hunwn epidemic log ica I sluHies.
Bl •• PiobAble Human Carcmouen. limited evidence from epidenno logical stuilies and atleauale ev tilence Iron animal $lurysn.p
(f) Based on Hie toiicily of naphthalene NCPAHs deleted at the Vestal site are naphlhalene. pnenanthrene. f luoranlhene. pr'ene. anthracene. I
2-oethy liMiuhtha lene.
(g) Criteria
-------
TABLE 3
llSt ASSESSMENT SUMMMT
•EStAl VUL l-l SITE
TOTAL EXCESS
UPPER BOUND IIFEIIME
CANCER RISK
PLAUSIBLE
AVERAGE MAXIMUM
fXPOSUSE PAIIrJAT CASE (4) CASE (b)
•
via soil contact (dermal absorption and Ingest ton)
and Innalatlon of vo Tallies.
Area 1 IE-06 2E-05
Area 2 IE-04 4E-04
Area 3 IE-04 3E-04
Area 4 2E-04 SE-04
Potential exposure to construction workers
via inhalation of contaninated dust.
Area 1 2E-I6 3E-1S
Area 2 2E-16 3E-I2
Area 3 1E-1/ 3E-17
Ar«a « 3E-19 9E-I9
leaching of contaminants to groundwater
•Ith eiposure directly below the source area.
Area 1 4E-08 JE-06
Area 2 4E-06 2E-04
Area 3 IE-06 2E-OS
Area 4 tt-06 4E-04
Leaching of contaminants to groundwater
v.th eipasure at the well field.
Area I 4E-10 7T-48
Area 2 4E-08 21-06 (d)
Area 3 1C -08 2C-07
Area 4 6E-08 4E-06
Potential exposures and risks from Ingest Ion
of groundwaler at concentrations detected In
monitor Ing wel Is.
Total Concentrations 1E-04 8E-04
Dissolved Coneentnt Ions IE-OS 4E-04
HAZARD
AVERAGE
CASE (a)
1E-02 (<
9E-02 «
IE-02 <
3E-01 <
IE-IS (<
3E-I5 <
4E-16 (<
5E-15 (<
IE-02 (<
3E-02 ' «
5E-02 '
4E-01 (<
>E-04 (<
3E-04 <
5E-04 ' <
4E-03 (<
INDEX
Pi AUSiniE
MAXIMUM
CASE (bl
SE-02 «
IE. 00 ' >
4E-02 ' <
1 IE'00 >
1 6E-I5 «
1 7E-I4 <
1 IE-IS «
1 2E-14 •
1 4E-OI <
1 4E*00 i >
1 SE-OI i«
1 H'Ol >
1 4E-03 «
1 4E-02 i<
1 SE-03 <
1 7E-01 '
7.4 (>1) 140 .
6.2 (>l) 78 ('
CMfMICALj
CONIOinill IHG
10 HIE
RISK (c)
1 Carcinogenic PAMs -*
I (rj) l.l-OCE. PCE. TCE. I.I.2.Z-PCA. CPAMS
1 I.I -DCE
1 I.I -DCE. ICE. 1.1 -OCA
1
1
I
1
1 Carcinogenic PAHs
1 Chloroform. I.) -OCA. l.l-DCE. I.1.T.2-PCA. PCE. ICE. PCD
1 I.I-OCA. l.l-OCE
1 1.1-OCA. l.l-OCE. ICE. PCD. Acetone
1
1
1
1 I.I-OCA. Carcinogenic PAMs
1) Arsenic, antimony, barium, beryl liion. chromium.
manganese, mercury, nickel, thallium.
vanadium, fine
1) Arsenic, antimony, manganese.
mercury, nickel, thallium
(a) Average case risks are based on average (but conservative) conditions of exposure and the geometric nean soil concentration.
(b) Plausible nvailnuit case risks are based on uooer-bound conditions of exoosure and the Geometric mean concentration of detected
values where, except for inorganics In groundwater, maximun detected value is used.
(c) Chenlcals resulting In an exceu lifetime cancer risk of greater than IE-06 or a COhRfO ratio greater than one.
(d) An excess lifetime cancer risk of greater than IE-06 ar a COI:BfO ratio greater than one It due only to the summation of two or more
Chenlcals (I.e.. no Individual chemical results in an exceedance).
--- • Hot relevant.
DOTE: l.l-OCE • 1.1-Olchloroethrlene: 1.1.2.2-PCA • 1.1.2.2-Ietrachloroethane; t.l-OCA . I.l-D.chloroethane.
-------
COST ESTIMATE SUMMARY
TREATMENT ALTERNATIVES
VESTAL FEASIBILITY STUDY
5-YEAR TOTAL PRESENT WORTH
ALTERNATIVE CAPITAL COST ANNUAL O&M REVIEW 5% DISCOUNT PRICE ($)
/
SOiL CONTAMINATION
SC-1- LIMITED ACTION 0 19,700
SC-2 - OFF-SITE INCINERATION 49,400,000 0
SC-4 - LOW TEMPERATURE
THERMAL EXTRACTION 8,384,000 0
SC-5 - SOIL TILLING 3,229,000 0
SC-5 - IN-SITU VAPOR
EXTRACTION 1,642,000 0
GROUNDWATER CONTAMINATION
GW-1 NO ACTION 20,000 0
GW-2 FILTRATION,
PRECIPITATION 3,675,000 924,500
GW-5 FILTRATION PLUS ION
EXCHANGE 4,008,000 4,290,300
10,000 331,000
0 49,400,000
0 8,384,000
0 3,299,000
0 1,642,000
0 20,000
0 17,912,000
0 70,078,000
9
CO
NOTE: All caoitvI costs are fully loaded with contingency and design factors.
-------
CAPITAL AND OPERATING COST SUMMARY
ALTERNATIVE SC-5 - IN-SITU VAPOR EXTRACTION
VESTAL WELL 1-1 FEASIBILITY STUDY
(tea
Oty Unit
Suit.
Unil Cost
Mnl.. Labor Equip.
Suh.
Total Cost
Mat. Labor
Equip.
Total
Direct
Coat
•100
ono
no
280
2
B
I.F
I.F
LS
I.S
I.F
I.F
HO
LS
LS
INSTRUCTION
I) Public Education Prngra*
SITE PREPARATION
21 :'..-ea 2 Fence
1) Area 4 Fence
4) E'tiipnent Mob/Oenob.
5) C,contamination facilities
IN-SITU VAPOR EXTRACTION
fil M,-*a 2 Extraction Wells
71 Area I F..it.rnrt Inn Wrlls
R| Vuruiin Pu»|i
91 In - Situ Treatment
10) Carbon Treatment
III Mobile Laboratory
RESIDUAL HANDLING/SITE CLOSURE
12) Carbon Disposal
Burden f I3X of Labor Coat
Labor • liX of Labor Coal
Material * SX of Material Coat
Subcontract 0 IOX of Sub. Coat
Total Direct Coat
Indirect* f 75X of Total Direct Labor Cost
Profit t IOX Total Direct Cost
Health I Safety Monitoring * IOX
Total Field Cost
Contingency t 20X of Total Field Cost
Engineering 9 I5X of Total Field Cost
Pei-iiUing & Legal • SX of Total Field Cost.
Construction Miuiageaent <» '. f>X of Tolnl FiHil (Tout
TnTAI. COST THIS PAGE
LS iflonn.no
10.on
10.00
ino.oo
ino.oo
200000.00
100000.00
2500.00 3000.00
1500.00 2000.00
5000.00 nno.oo
20000.00 5000.00
18000
4000
nooo
nooo
28000
200000
100000
2500
1500
5000 1200
160000
3000
2000
40000
LS 60000.00
i nooo
4000
9000
5500
3500
flOOO
2HOOO
6200
200000
200000
100000
60000 60000
427000 5000 165200 45000 642200
2147G 21476
21780 24180
250 250
42700 42700
469700 5250 211456 45000 731406
158592 158592
731-11
963139
96314
1059452
211890
I5H9IB
5201:1
ISH'MIl
. IM2I5I
Coanenta
4 P 20'
14 P 20*
Co
£
en
-------
APPENDIX 2
-------
N
U.S. QEOLOQICAL SURVEY 7.5 MINUTE SERIES (TOPOGRAPHIC) ENDICOTT QUADRANGLE
SCALE 1 24000
__
«. () IlKXj riHI" I""' «»•( '.!•!" N'>- ''"' 'II'
Vrf T'~.r. . L- -'1T'.--I - "~ l-i=-==--.V-i: J.-_r. - I . - : '
I % 0 I fll "M( l| P
tr -I >:.( F- I I.-I.. J~l l:f-- . ^r "I
CMNIOUP INTRPVAI 10 rrrr
NATIONAL GtOOEIlC VFBIIi:»l. DAIIJM OF |0?9
u s ENVIHONMENTAL PHOTECTION
AGENCY
VHSTAL WEIL 1 1 SITE
BROOME COUNTY. VE5IAI.. NY
Central Slu loccllon
riiAsr.o GCIWICI
-------
US ENVIRONMENTAL PRO I EC TON
AOTNCV
SWAUPY AREA
ORAINAOE OITCH
VESTAL Will I I SITE
\ BROOMt COtJNtY. VESIAl. NY
Vestal Well 1-1
Study Area
-------
FIGURE 3 9
FECORD OF DECISION
REMEDIAL ALTERNATIVE SELECTION
SITE: Vestal Water Supply Well 1-1, Vestal, Broome County,
New York
DOCUMENTS REVIEWED
I am basing my decision primarily on the following documents
describing the analysis of cost effectiveness of remedial
alternatives for this site:
- Well Field Contamination Investigation (R.J. Martin)
- Vestal Water Supply Well 1-1 Focused Feasibility Study
- Vestal Water Supply Well 1-1 Remedial Investigation/
Feasibility Study
- Staff Summaries, Letters and Recommendations
- Responsiveness Summary
DESCRIPTION OF SELECTED REMEDY
This Record of Decision calls for the following actions:
0 Construction of a packed column air stripping system on well
1-1 in order to return the well to full service as Vestal
Water District 1's primary water supply. This cost effective
alternative will have the following positive impacts:
1) restoration of District 1 water supply capacity to the
level that existed prior to loss of well 1-1;
2} provision of a water supply to the district that exceeds
applicable or relevant and appropriate standards, thereby
providing a very high level of public health protection;
3) hydraulic containment of the plume of contaminants via
pumping well 1-1, thereby protecting other District 1
water supply wells; and
4) cessation of untreated discharge from well 1-1 to the
Susquehanna River.
• initiation of a supplemental Remedial Investigation and Feasi-
bility Study to further investigate the extent of soil contami-
i-.di.icr. in i'-iyii-tea source areas and to evaluate possible source
control measures.
-------
-2-
DECLARATIONS
Consistent with the Comprehensive Environmental Respo^e, Com-
pensation, and Liability Act of 1980 (CERCLA) and the national
Contingency Plan (40 CFR Part 300), I have determined that the
construction of an air stripping system to treat Vestal water
supply well 1-1 and its subsequent use as the Town's primary
water supply is a cost-effective remedy and provides adequate
protection of public health, welfare and the environment.
Furthermore, I have determined that it is necessary to undertake
a supplemental Remedial Investigation and Feasibility Study to
investigate the extent of soil contamination in suspected source
areas and to evaluate possible source control measures. A
determination regarding future source control actions will be
made upon completion of this work.
The State of New York has been consulted and agrees with the
approved remedy. In addition, the action will require future
operation, maintenance, and monitoring activities to ensure
the continued effectiveness of the remedy. These activities
are presently considered eligible for Trust Fund monies for a
period of one year; however, pending CERCLA legislation may
affect this eligibility and/or the period of eligibility.
Funding of this remedial action will occur at the time of CERCLA
reauthorization; moreover, I have determined that the action
being taken will be appropriate when balanced against the future
availability of Trust Fund monies for use at other sites.
Date ' Christopher J.^Daggeytt
Regional Administrator
-------
1-=
M
o
G
*J
M
*>
US ENVIRONMENTAL PROTECTION
AGENCY
VESTAL WEIL 1 I SITE
RROOME COUNTY. VESTAL.
Potential Source
Areas
-------
FIGURE 5
AFFIDAVIT OF PUGL I CA7 I Oil
State of Mew York
Town of Vestal
County of Broome
rh y i iis Johnson
. being duly s -a o r n , a e 3 c ; e s
says that she is the Principal Clerk of the Binghamton ?res; Co.^oan./.
Inc., publisher of the following newspaper printed and publisned
in the Town of Vestal, New York and of genera' circulation i r, :.-,c
County of Broome, State of New York: Press a Sun-Bulletin.
A notice, of which the annexed is a printed copy, was ? u & 1 i s n e d
on the following dates: :iay ia, '99i
Swo.-n to before me this ' -1 h
day of Ma-j , 19 9_
Notary Public
. -
THf UNITED STATES
ENVIRONMENTAL
PROTECTION AGINCT
tnvilci
PUIIIC COMMENT ON THE PROPOSED REME-
DIATION OF THE VESTAL WELL NO. 1-1 (2ND
OPERAIIE UNIT -SOURCE REMEDIATION)
located Ntar
NORTH MAIN STREET In
VESTAL N.Y.
?>,* U.S tn.»o~"«ntol »t«i.ttK>« -oond IHO
.,u koW o
tit« fh* N y s Dvpar»*««i,i
OO*n'
ond Haiardjowt SwtotlvACOft Polvfon
o propotod oe**oi
nofi**. whtch <«rlud*t COMWQOncv
and NVSOfC ««|COWMI 1*10 pvbi«c*i COMMHOM OM
finoJ romooV O*»»* t"* pvbAc commonl ponad ondl
and toowlnmox — * NTSPIC o coxkia^d. C"
*^ov foloet on OPIN9A ottMr 4wn IKo p»ooo»od a***'-
notivo or^or contMJo i um>'i o' aM c !!•""»•'"« n) voiofl nndin^t it
protoniod trt tfio fl/fS looo* end •* tni fropoiod
Plan ThotO docun*ontl or« O«O**Obfo O* Otfhor
-------
NOTE:
ALL CONCENTRATIONS IN UQ/KQ (PPBI.
-206
SB-20S
SB-407
U S ENVIHONMENFAl PROTECTION
AGENCY
VESTAL WEIi 11 SUE
BROOUE COUNTY. VESIAL. NV
Soil Borings
O
c
»
w
c\
EOASCQ tiERVICES INCOnPOfUTED
-------
NOTE: ALL CONCENTRATIONS IN DO/KG (PPB)
U - NONE DETECTED.
SOUTHERN TIER WELDING
sazce
tOC£
ICC
X|4ra
4«*
II
It
*
l»l]l
U
IMO
U
I»M»
400
1200
U
SB20*
I.IOCE
I.I OCA
«OCA
ICA
ICE
B*nt«n«
fC.t
luluOT*
tlytMnlWW
>r«m
44*
2
1
900
40
IRM
U
730
I4OO
J'O
I6OOO
12 141
U
U
MO
U
30000
U
U
U
»IO
noa
U 14 •
•
U
too
130
• 100
4
110
330
I4OO
6tOO
US. ENVIFKHMENTAL PRO TEC I ION
AGENCY
VESTAL WELL II SITE
BROOME COUNTY. VESTAL. NY
VoUIIU Ogjinlc* In Soil
AIM 7
II1ASCO SERVICPS
-------
S84I»
I.IOCf
I.I OCA
ICA
ICf
rcc
!•*<•<•
1-4*
u
u
u
110
u
•
IJIO
u
u
u
no
u
' u
II KR
15
SI
1)0
160
2
1
SS4Z2
ICA
ICC
I»l2i
U
U
1*0
!•*>«
MO
140
U
"J
M
o
G
»
M
03
SCALE (FEET)
NOTE: ALL CONClI.MTR ION3 IN UQ/KQ (PPB).
u - NONE ;>ETI :TED.
U S ENVIRONMENTAL PHOrECflON
AOENCV
VESTAL WEIL II SHE
BROOME COUNIV, VESTAL. NY
Volltlt* Oroanlc* In 9o»
Are« 4
-------
SAMS
tMrt
cPAMl
• ••
119700
ISOO
• 10*
• /•40
MO
Su>C.
Ml
ISM*
JSO
NOTE:
ALL CONCENTRATIONS IN UQ/KQ IPPB)
S8J09
loM
10 12 II
730
lira*
MO
- (KU.T1
US ENVIROhMENTAL PROTECTION
AGENCY
VESTAL WELL II SHE
OnOOME COUNTY. VESTAL. NY
Told Cone*ntr*Hon« ol TCL
•nd CPAH SwnlvoUllto* In Soil
Ara>« I and 1
F.BASCO 9£nviCES INCOMPOIUIEO
»
M
vo
-------
SKta
lotel
!»*>•
M
, SB-J22
Chenango Industries
NOTE:
ALL CONCENTRATIONS IN UQ/KG (PPBI.
304 II
ToM
• ION
U
12 14 •
M
KM!
IJOD
US ENVIROf*ȣNlALPnOTECriON
AGIiNCV
VESTAL WCll I I SITE
BROOME COHNfY. VESIA1..NY
TaUl Cona«n(r«AH BwnlvoUttto* In Ml
j Af»*« 1 «nd 4
i IIASCO sEiwK'.i s iNc»nponAii:n
-------
CONCENTRATIONS SHOWN ARE ELEVATED
SSSSf BOEBNGEN & SHACKLETTEM981I
BACKGROUND VALUES.
ALL CONCENTRATIONS IN MG/KG (PPM)
CONCENTRATION NOT ABOVE BACKGROUD
SOUTHERN TIER WELDING
US ENVIRONMENTAL PROIECTK3M
AGENCY
VESTAL Wl.tl l-l SITE
8 DOOM E C O UN IV. VFSTAL.MY
Inorganic Concenlralions In
Soil Above Background
O
G
MASCO srnvir.t ;;iu:rini'onArF»
-------
J
-r
SB "6
CM .urn
Cooc««
Ujqnvtium
N.0.1
10- 1] U*l
16300
se 4i*
CtlCKIfll
COOOM
Z«c
J « l«tl
«e ion
31.'
541
II JO l.tl
104,
SB 417
Ch«omii> i
Coco*
II 14 !••(
S0«
U)
1(10 !••<
S^l
J1
34 '
II tO !••!
)! I
SB-417
SB-422
SB 40«
C'lcoim
Cootil
COCXM-
M.tq>%«t,um
10 11 !••!
151
1)4
It 10 !••!
69 ?CO
3/1
19 100
S8-400
58-411
SB-
(DSB—4O4
SB 411
C«lc>uni
Coopw
t 1 !••>
1'3
II II !••!
1.460
54 •)
li
^— ^
SB 411
Ats»n<
CMoim
Cocuw
l.xl
Ujqp*\ium
N.^Vol
10 11 l«.l
U '
605
3? 1
II 10 !••(
nooo
3'l
?l 000
o
100
NOTE:
CONCENTRATIONS SHOWN ARE ELEVATED ABOVE
BOERNGEN & SHACKLETTEI1981)
BACKGROUND VALUES.
ALL CONCENTRATIONS IN MG/KG (PPM)
= CONCENTRATION NOT ABOVE BACKGROUND
SB-407
©
US
PROTECTION
AGENCY
VCSfAL Wtll II S'lt
llMOOMi; COUNIY. VCGI/I.. f4Y
lno'f)anic Concentrations in
Soil Above H.ieMji OUCH!
• Area *
si livid '.", i
O
G
»
M
-------
Uinrun»sflpT)
CONC.uoA
1.880.0
Mc.cur, (T)
W«H 1-21
B«iylum(T)
l«*d(T)
Magnmwm (T)
luUngjncwiir)
CONC, uo/l
120
1560
59.9000
68SOO
I'l
M60
20 2
w*n I-MA
Cliiofivuni (T)
l.on(r>
Manganoi* (T)
Mflicuiy(r)
CONC. ug/L
7B6
38 .OOOO
7470
704
W*IIS-II
IW>um (T)
le«)(l)
M.iyn4tsiunl (F)
M.iny.im;s« (1)
-. // .
CONC. UO/L
46
740
I60CXX10
II.IIH)0
W.IIS-
WcllS-8
0«.yllnim(T)
1 r.iuni f FJ
M.IIM].IIM^O (f )
CONC. ogA
245
1.3000
228
1 .5110 0
309
2?5 OOO 0
51.41)00
SCALE
NOTE: VALUES SHOWN ARE ONLY THOSE ABOVE STATE REGULATIONS
US ENVinOtMENTAl PROTECTION
ACiCNCY
VFSfAl WIU. II SITE
nnooME coon i Y, VPSIAI. NY
TOTAL MFTAIS
IN
-------
TOTAL TREATMENT AREA = 25,000 5Q. FT.
WELL WITH RADIUS OE INELUENCE = 25 ET.
N
G
»
M
TO ACTIVATED CARBON
TREATMENT UNIT
VACUUM
PUMP
VAPOR EXTRACTION WELLS
U.i. ENVIRONMENTAL PROrECIlON
VESTAL WELL 1-1 SITE
DROOME CQUNrY. VESTAL. NY
VAPOR Exnv>cnoN
COK ARI-> 4
s •
sisn;vi
KUASCO Slil'.VICKS INCOKI'OKAII.'U
-------
APPENDIX 3
-------
RECORD OF DECISION
REMEDIAL ALTERNATIVE SELECTION
^
SITE; Vestal Water Supply Well 1-1, Vestal, Brooroe County,
New York
DOCUMENTS REVIEWED
I am basing my decision primarily on the following documents
describing the analysis of cost effectiveness of remedial
Alternatives for this site:
- Well Field Contamination Investigation (R.J. Martin)
- Vestal Water Supply Well 1-1 Focused Feasibility Study
- Vestal Water Supply Well 1-1 Remedial Investigation/
Feasibility Study
- Staff Summaries, Letters and Recommendations
- Responsiveness Summary
DESCRIPTION OF SELECTED REMEDY
This Record of Decision calls for the following actions:
• Construction of a packed column air stripping system on well
1-1 in order to return the well to full service as Vestal
Water District 1's primary water supply. This cost effective
alternative will have the following positive impacts:
1) restoration of District 1 water supply capacity to the
level that existed prior to loss of well 1-1;
2) provision of a water supply to the district that exceeds
applicable or relevant and appropriate standards, thereby
providing a very high level of public health protection;
3) hydraulic containment of the plume of contaminants via
pumping well 1-1, thereby protecting other District 1
water supply wells; and
4) cessation of untreated discharge from well 1-1 to the
Susquehanna River*
• Initiation of a supplemental Remedial Investigation and Feasi-
bility Study ^ fv-.u-.er -.nvrsLiSiis the extent of soil contami-
nation in suspected source areas and to evaluate possible source
control measures.
Attachment 4
-------
-2-
DECLARATIONS
Consistent with the Comprehensive Environmental Respo^gse, Com-
pensation, and Liability Act of 1980 (CERCLA) and the national
Contingency Plan (40 CFR Part 300), I have determined that the
construction of an air stripping system to treat Vestal water
supply well 1-1 and its subsequent use as the Town's primary
water supply is a cost-effective remedy and provides adequate
protection of public health, welfare and the environment.
Furthermore, I have determined that it is necessary to undertake
a supplemental Remedial Investigation and Feasibility Study to
investigate the extent of soil contamination in suspected source
areas and to evaluate possible source control measures. A
determination regarding future source control actions will be
made upon completion of this work.
The State of New York has been consulted and agrees with the
approved remedy. In addition, the action will require future
operation, maintenance, and monitoring activities to ensure
the continued effectiveness of the remedy. These activities
are presently considered eligible for Trust Fund monies for a
period of one year; however, pending CERCLA legislation may
affect this eligibility and/or the period of eligibility.
Funding of this remedial action will occur at the time of CERCLA
reauthorization; moreover, I have determined that the action
being taken will be appropriate when balanced against the future
availability of Trust Fund monies for use at other sites.
_
Date Christopher J.lDaggat
Regional Administrator
-------
SUMMARY OF
REMEDIAL ALTERNATIVE SELECTION
VESTAL WATER SUPPLY WELL 1-1
SITE LOCATION AND DESCRIPTION -^
The study area for this Remedial Investigation/Feasibility Study
(RI/FS) covers 225 acres (.4 square miles) in the Town of Vestal,
New York (figure 1). Vestal water supply veil 1-1 is located
on the south bank of the Susquehanna River about 400 feet west of
the Endicott-Vestal Route 26 Bridge. Other significant features
of the area include an industrial park immediately to the southeast
of the veil, and several marsh areas and drainage ditches encom-
passing and interlacing the industrial park (figure 2) .
Well 1-1 is one of three production wells in Water District 1
that are intended to provide drinking water to several water
districts in the Vestal area. Well 1-1 presently is being pumped
to waste into the Susquehanna River in accordance with a SPDES
permit, while well 1-2 usually provides enough water to satisfy
the District 1 service area. Well 1-3, which produces a relatively
low quality (corrosive) yield, is used as reserve capacity in
periods of maximum demand.
The aquifer underlying the study area is extremely permeable,
resulting in high production capacities as well as rapid con-
taminant migration. There also exists many variations in the
subsurface geology in this area, giving rise to a highly complex
groundwater hydrology. The direction of groundwater flow is
generally from east to west (figure 3).
SITE HISTORY
In 1954, well 1-1 was constructed with a capacity of 1.4 MGD as a
back-up well to supplement the Vestal water supply which was pro-
vided at that time by the Town of Endicott across the Susquehanna
River. A few years later, Water District 1 became an independent
water supplier for the Town of Vestal, utilizing wells 1-1, 1-2
and 1-3 with a combined capacity of 4.6 MGD.
A chemical spill at the IBM plant in Endicott in 1978 led to a
testing program for all drinking wells .in the vicinity for syn-
thetic organic compounds. As a result of this .*, signifi-
cant concentrations of chlorinated solvents were discovered in
well 1-1, and the well pumpage war. divert?'-" tc *.-;. s-.'-^uc-hanna
River where it presently continues to discharge under a SPDES
permit. Subsequent investigation has since indicated that the
presence of chlorinated solvents in well 1-1 is not related to
the spill at the IBM plant.
-------
-2-
In December, 1982, the site was placed on the National Priorities
List (NPL) in combination with Vestal Water Supply Well 4-2,
which was a similarly contaminated well a few miles away in
another water district; however, these two sites were ^-ater sepa-
rately listed due to the recognition that the sites were most
likely contaminated by different sources existing in the immedi-
ate area of each well. Just prior to the listing of well 1-1 on
the NPL, the Town of Vestal contracted with R.J. Martin to con-
duct an investigation of the contamination of well 1-1. His
conclusions in part tended to implicate the area around the
southeast corner of Stage Road as a suspected source. This is
an area which borders the industrial park along stage Road.
A Focused Feasibility Study (FFS) was conducted by New York
State Department of Environmental Conservation consultants in
order to determine the need for an initial remedial measure.
The FFS recommended the construction of a large capacity water
main between Water Districts 1 and 5 in order to improve the
reliability of the District 1 supply. EPA rejected this recom-
mendation on July 9, 1985, because the Agency believed that a
sufficient capacity of good quality water still existed for
the service area, and that there was no short-term threat of
losing this capacity.
At the present time, well 1-2 is the primary water supply and
well 1-3 is used as a backup to provide extra capacity during
peak demand periods (figure 4).
CURRENT SITE STATUS
During the RI, 27 "Wells were sampled, including well 1-1 and
26 groundwater monitoring wells (figure 3). In addition, five
surface water samples, 17 soil samples, four sediment samples,
and three sewer water samples were collected. All samples vere
analyzed for priority pollutant volatile organics, and a com-
plete priority scan was conducted on samples taken from wells
1-1, S-2, and S-4. Nineteen of 57 samples contained priority
pollutant volatile organics.
Seven new monitoring wells (S-l, S-2, S-4, S-6, S-7, S-8 and
S-ll) were installed east of Main Street tr» prov<4« »^Hon»i.
hydrogeologic groundwater quality data for t.>e pu.pouts ot xocat-
ing the source or sources of groundwater contamination. Wells
S-l, S-2, S-6, S-7, S-8 and S-ll were sited to iuiLh«r Jciine
the contaminant plum* near suspected source areas. Well S-4
was located upgradient of any Known contamination and was used
to determine background levels. After purging, monitoring
wells were sampled for priority pollutant volatile organics.
Wells 1-1, S-2 and S-4 vere also sampled for all EPA priority
pollutants.
-------
-3-
Soll samples were collected at 5-foot intervals from boreholes
B-l through B-7 and analyzed for priority pollutant volatile
organics to determine if any soil contamination existed upgradi-
ent of the suspected source areas. Additional soil saoples
were obtained from depths of 3 feet or 5 feet in power auger
holes drilled in the Chenango Industries drainage ditch area
and at the tank truck parking area as part of the source area
identification study.
The RI confirmed the presence of eight volatile organic com-
pounds in the groundwater southeast and east of well 1-1*
based on the measured concentrations and known health effects,
the primary contaminants are the chlorinated solvents trichloro-
ethylene; 1,1,1-trichloroethane; trans-1,2-dichloroethylene; and
1,1-dichloroethane. Historical values for these compounds in
veil 1-1 are given in table 1. The concentration of total vola-
tile organics (TVO) in well 1-1 was 241 ppb in April 1985. The
highest recorded concentration of TVO in the groundwater plume
was 12,840 ppb in monitoring well 1-33 located approximately
1,500 feet southeast of well 1-1 (figure 5). Computer modeling
of the data and areal mapping of contaminant* indicate that two
pockets of chlorinated solvents are the major sources of contami-
nation currently affecting veil 1-1 (figure 6). Subsequent use
of*a solute transport model showed that the plume will continue
to migrate slowly toward well 1-1, provided that well 1-1 con-
tinues to be pumped to waste, with no impact to wells 1-2 and
1-3.
No identifiable wastes contributing to the well 1-1 contaminant
plume were present at the surface, either at the well site or in
the upgradient suspected source areas. There is no indication
of lagoons in historical aerial photographs, and the RI revealed
no surface indications of buried waste pits, lagoons or drums.
In addition,\nd "hot spots* were found at the surface, indicating
that the contaminants are confined to the groundwater and pos-
sibly in unsaturated soils at depths greater than 5 feet. How-
ever, some deep soil contamination found in at least two areas
of borehole investigation have led to the decision to perform a
supplemental HI/PS study to evaluate the extent of this contami-
nation and possible source control measures. This supplemental
work will be the subject of a future Record of Decision.
1,1-dichloroethane, trans 1,2-dichloroethylene, and 1,1,1-tri-
chloroethane all have produced similar damaging tcr.ic «r:-.-.-•-
on the livers, kidneys and central nervous systems of laboratory
animals, usually as acute effects. Acute human toxicity has
also been observed in the workplace after high exposure to 1-1
dichloroethane and trans 1,2,-dichloroethylene. There is very
little weight of evidence from animal studies to suggest through
extrapolation that any of these compounds produce carcinogenic
<» "*?cn in humans.
-------
-4-
Trichloroethylcne also has been shown to affect the same target
organs in laboratory animals and humans in the workplace as do
the other three chlorinated compounds of concern. In addition,
there is some evidence from aniraal studies to suggest the pos-
sibility that trichloroethylene is a potential human carcinogen.
Most of the exposures to contaminants associated with the plurae
of contamination have been or will be at low levels. Since
carcinogenic effects are often related to low level exposures,
trichloroethylene is therefore considered the major contaminant
of concern.
Exposure to these contaminants is almost non-existent at the
present time, since well 1-1 has been taken out of service and
(he putnpage to waste discharges from a pipe beneath the surface
of the Susquehanna River. Possible exposure routes and receptors
could change, however, with implementation of various remedial
alternatives. These potential exposures have been analyzed in
the risk assessment performed for this site and will be discussed
in the alternatives evaluation.
ENFORCEMENT
No negotiations with potentially responsible parties (PRP) have
been conducted up to the present time. Information request let-
ters were sent out in May, 1986, to two companies in the Stage
Road industrial park; namely, Chenango Industries and Neil Guiles
Asphalt Company. The latter presently leases its property from
O'Brian Oil and Supply, who will also be receiving an information
request in the near future.
Enforcement efforts have been hampered by the lack of obvious
sources of contamination. The RI/FS has succeeded in determin-
ing the two most likely locations where contamination entered
the groundwateri therefore, enforcement activity is now ex-
pected to increase as a result. The supplemental RI/PS which
will further Investigate suspected source areas will be designed
to facilitate this enforcement effort.
The Town of Vestal has also initiated a claim against Chenango
Industries pursuant to Section 112 of CERCLA for loss of well 1-1.
ALTERNATIVES EVALUATION
The public health and environmental objectives of the RI/FS were
as follows:
• Contain the plume of contamination to mitigate further contami-
nation of public water supplies;
• Provide a safe, reliable water supply to the Town of Vestal; and
• Ensure th*t the quality and best use of the Susquehanna River
are not impaired.
-------
-5-
The objective of the proposed supplemental source control RI/FS
will be to determine.which, if any, source control measures would
be feasible and cost effective. __
^
Initial Screening of Alternatives *•
General remedial technologies that were initially considered in
the feasibility study were a variety of contaminant source con-
trols, groundwater decontamination methods and alternative
drinking water supplies (table 2). Since a supplemental source
control RI/FS will be performed in the near future, source
control technologies were eliminated from further consideration
at the present time.
Feasible remedial technologies were further developed into an
array of ten alternatives (table 3) which were then subjected to
a preliminary screening based on environmental, public health
and cost criteria. All of the alternatives were considered to
meet or exceed applicable or relevant and appropriate standards
as measured at the water supply well. An off-site disposal
alternative will be developed as part of the supplemental RI/PS,
since source control technology night involve off-site disposal
of contaminated •oils.
The preliminary screening of alternatives resulted in the elimi-
nation of six alternatives. Installation of extraction (inter-
ceptor) wells was eliminated based on technical problems in
modeling the complex subsurface hydrogeology, with no guarantee
that extraction wells in combination with well 1-1 would effect
aquifer clean-up significantly faster than the continuation of
pumping well 1-1 alone. At the present time, it is estimated that
continued pumping'of well 1-1 will cleanse "Che aquifer in 20+
years. Also, there would be significantly higher costs to imple-
ment an extraction well alternative, with minimal benefits gained
through its implementation.
Provision of a supplemental water supply from either Johnson City
or Binghanton was eliminated because they would be an order of
magnitude higher in cost with no additional environmental benefits.
Installation of a new water supply well was eliminated due to
the uncertainty in siting a new well. There is no guarantee
that it would not encounter similar problems to those of wells
1-1 and 1-3.
The use of granular activated carbon to remove volatile organics
from well 1-1, either alone or in conjunction with a packed
column air stripper, was removed from further consideration
because of higher costs and greater difficulty of operation and
maintenance. At the present time, the environmental benefits of
air stripping with *~tiv?ited Carbon over air stripping alone
are questionable; however, if the detailed design phase of this
project indicates a possibility of unreliable performance of
the packed col-tan air striper in achieving design standards,
-------
-6-
then the use of activated carbon with air stripping will be re-
examined at that tine. At a minimum, the packed column air strip-
per will be designed with the capability of future addition of
an activated carbon system should the Town of Vestal eventually
decide to implement additional treatment. ^
Detailed Analysis of Alternatives
The initial screening, therefore, refined the list of remedial
alternatives to the following:
• No action;
' Air stripping of well 1-1 as a primary water supply;
* Air stripping of well 1-1 as a secondary water supply; and
• Provision of supplemental water supply from District 5.
A detailed analysis of these alternatives was then performed,
consistent with 40 CFR Part 300.68(1). The detailed analysis
of each alternative included refinement and specification of
alternatives in detail, with emphasis on use of established
technology; detailed cost estimation, including operation and
maintenance costs, and distribution of costs over tine; evalua-
tion in terms of engineering implementation, reliability, and
constructability; assessment of the extent to which the alterna-
tive is expected to effectively prevent, mitigate, or minimize
threats to, and provide adequate protection of, public health;
and an analysis of any adverse environmental impacts.
Applicable or relevant and appropriate standards for this site
include this Agency's Maximum Contaminant Levels (MCLs), which
have been proposed pursuant to the Safe Drinking Water Act, and
New York State's groundwater quality standards established pur-
suant to the Clean Water Act* The applicable proposed NCLs are
for trichloroethylene (5 ug/1) and 1,1,1-trichloroethane (200 ,
ug/1). The applicable State standard is for trichloroethylene -
(10 ug/1).
Complete costs associated with the alternatives are presented
in table 4. A summary of the alternatives evaluation follows.
No Action
The no action alternative is the continuation of the present
situation, which involves pumping well 1-1 to waste into the
Susquehanna River and using well 1-2 as the primary District
1 water supply, with well 1-3 acting as reserve capacity.
-------
-7-
This alternative has been proven to be technically feasible
and effective since it has already been implemented and has
been reliable over six years in terms of controllings the migra-
tion of the contaminant plume. Operation and maintenance (O&H)
is straightforward and approximates the normal operation of a
water supply well. This alternative alsp provides a source of
drinking water, i.e. well 1-2, whose water quality exceeds
applicable or relevant and appropriate standards. However, the
long-term reliability of using well 1-2 with 1-3 as reserve
capacity is questionable because of the limited options avail-
able in the event of mechanical failure or future contamination
of well 1-2. Also, this alternative includes the continued dis-
charge to the Susquehanna River of low levels of volatile
organic chemicals (VOCs) which, although not expected to create
a significant adverse environmental impact, is nevertheless a
negative feature of this alternative.
The present worth costs of the no action alternative are the
least of the four alternatives, although the costs of all four
alternatives are very similar and are not expected to play a
significant role in selection of a remedial alternative.
Air Stripping as Primary Water Supply
This alternative involves the installation of an air stripping
column approximately 40 feet in height (figure 7) near well
1-1, combined with retrofitting of the well's pump for the
desired flow rate and discharge pressure. To provide stripping
air to the column, a blower would be installed with the column.
A wet well and new effluent pump would be provided to pump the
treated water into the water supply distribution system. The
present discharge of veil 1-1 into the Susquehanna River would
therefore be eliminated. Preliminary design calculations were
based on maximum expected influent VOC concentrations of approxi-
mately twice the maximum levels of contaminants found in the
last three years. To provide flexibility in the unlikely event
that VOC levels should rise above design levels, the column
would be designed so that either the column height could be in-
creased or activated carbon technology could be added as second-
ary treatment.
The technical feasibility and effectiveness of a properly de-
signed packed column air stripper is well documented for vola-
tile organic contaminants. OfcM is not complicated, and actual
construction would be relatively easy and rapid. Since well
1-1 would continue to be pumped as it is under the no action
alternative, the plume of contamination would still be effec-
tively controlled. The effluent from the stripper would provide
capacity for the average daily demand of District 1, with well
1-2 used as reserve capacity. The air stripper will be designed
-------
-8-
to achieve an effluent limit which will approximate the level
associated with a 10~6 increase in cancer due to chronic tri-
chloroethylene exposure. The system will also be capable of
achieving an effluent limit of less than 1 ug/1 for |richloro-
ethylene, which Is considered the detection limit. ££erefore,
this alternative will exceed applicable or appropriate and rele-
vant standards, providing a very high level of public health
protection with no significant increase in cost. The long-term
reliability of District 1's water supply will also be returned
to the level that existed prior to contamination of well 1-1.
Emissions from the air stripper will consist of extremely low
levels of chlorinated hydrocarbons which will pose no chronic
or sub-chronic health threats to downfield receptors. Any
potential impacts to the biota of the Susquehanna River will
also be eliminated.
The present worth costs of this alternative are slightly greater
than the no action alternative, but less than the other alterna-
tives that survived preliminary screening.
<
Air Stripping as Secondary Water Supply
This alternative involves the same air stripping technology,
design criteria and operation and maintenance as the previously
discussed alternative. It would differ primarily in that well
1-1 would supplement veil 1-2 as reserve capacity and would
function as a primary water supply only in the event of a shut-
down of well 1-2. At times when well 1-1 was being pumped to
the distribution system/ it would first be treated by the
packed tower aeration system. At other times, well 1-1 would
be pumped to the Susquehanna River without treatment.
^
The technical feasibility and effectiveness of this alternative
do not vary from the previous one. The reliability of the
system in exceeding applicable or appropriate and relevant
standards is slightly greater, since the treated water from
veil 1-1 would only be used occasionally, and at those times it
would be blended vith uncontaminated water from well 1-2. Bow-
ever, reliability of air stripping technology is high enough
so that this advantage is considered minor*
Periodic untreated discharge of veil 1-1 into the Susquehanna
r' ••*• night have minimal adverse environmental impacts. Emis-
sions from the sir stripper would be similar to those associated
vith t>"» previous alternative, but on an intermittent basis.
This alternative is greater in present worth costs than the
operation of well 1-1 as a primary water supply due to the
additional power costs associated with periodic pumping to
waste of well 1-1.
-------
-9-
Supplemental Water Supply From District 5
Under this alternative, well 5-1 would be retrofitted fwith a pump-
ing capacity of 1 MGD, and Districts 1 and 5 would be^ntercon-
nected with an additional transmission pipe to make one district.
Wells 1-2 and 5-1 would then act as backup to each other with
each having the capacity (1 MGD) to supply the current peak
demand of both districts. A new 10-inch diameter transmission
pipe would be installed between Districts 1 and 5 (figure 8) to
supplement the existing connection. The new pipe would be
sized to carry approximately 500 gpm, while the existing pipe
carries approximately 200 gpra. The exact pipeline route would
be determined during the design phase in addition to a more
detailed evaluation of the pressure differentials and water
usage. Well 1-1 would continue to be pumped to waste into the
Susquehanna River.
The technical feasibility and effectiveness of this alternative
is virtually guaranteed* O&M would be straightforward and
would approximate the normal operation of a water supply well.
In addition, it would provide a high degree of long-term relia-
bility for District 1's water needs. However, this reliability
is contingent upon well 5-1, presently untreated, continuing to
produce high quality water. This alternative would also take
somewhat longer to implement than the air stripping alternatives,
and would involve temporary construction impacts along the pipe-
line route, which would mostly traverse previously disturbed
rights-of-ways. Untreated discharge of well 1-1 into the
Susquehanna River would continue under this alternative, which
would not be expected, to create a significant adverse environ-
mental impact. ^
This is the most expensive of the four alternatives in terms
of total present worth.
RECOMMENDED ALTERNATIVE
The appropriate extent of remedy shall be determined by EPA's
selection of a cost-effective remedial alternative that effec-
tively mitigates and minimizes threats to and provides adequate
protection of public health and welfare and the environment.
T'.'~ viii normally-require selection of a remedy that attains
or exceeds applicable or relevant and appropriate federal and
stir-:: *'biic~beaJth.and environmental requirements that have
been identified for the site.
Each of the alternatives selected for detailed evaluation is
considered an appropriate extent of remedy within the above
definition. Based on meetings with New York State, its con-
sultants, the Town of Vestal and the public on the RI/PS,
-------
-10-
it is recommended that air stripping of well 1-1 with subsequent
distribution of the treated water as District 1's primary water
supply be selected as the remedial action for this project.
Detailed capital cost estimates for the recommended alternative
are given in table 5.
This alternative is only slightly higher in cost than the low-
est cost alternative i.e. no action, yet provides greater relia-
bility and flexibility for the District 1 water supply by means
of the restoration of District 1's water supply to full capacity,
discontinues the present untreated discharge of veil 1-1 to the
Susquehanna River, and has a wide measure of Town and public
support.
COMMUNITY RELATIONS
Community perception of the Vestal well 1-1 contamination
problem has been an important factor in placing this site on
the Superfund National Priorities List. Chlorinated solvents
were discovered in water from well 1-1 in April 1980. In •
response to several groundwater contamination problems in
Vestal, the Purity of Waters Committee was set up. Numerous
public meetings were held to discuss the issue and a large
measure of public concern was expressed. Considerable local
press regarding the issue contributed to public awareness.
Since the NPL listing in December 1982, public concern has
subsided, and the townspeople have been generally satisfied
that appropriate action is being taken and that no contaminated
water is being consumed. However, there is still concern
regarding the potential spread of contamination. In order to
avoid additional-public concern, the Vestal Town Board adopted
a 1 ug/1 cleanup criterion for any single VOC prior to putting
well 1-1 back on/line. The selected alternative will be capable
of achieving that criterion.
Specific concerns that were raised during the public comment
period, including comments made at the public meeting held on
June 10, 1986, at Town Hall in Vestal (figure 9), are answered
in the Responsiveness Summary.
CONSISTENCY WITH OTHER ENVIRONMENTAL LAWS
At the present time, there are no federal environmental laws
other than the Safe Drinking Water Act which are appli.dLtib ie
implementing the selected remedial action at this site.
Trichloroethylene has been chosen by EPA for evaluation and
possible future regulation pursuant to the Clean Air Act's
National Emission Standards for Hazardous Air Pollutants (NESHAP)
However, such regulation will likely not be promulgated for 1-2
-------
-11-
years. At the present time, EPA believes that the risk assess-
ment performed for the operation of the packed column air strip-
per has sufficiently demonstrated the extremely low riik associ-
ated with the predicted level of air emissions on likely receptor
areas, using worst case assumptions throughout the analysis.
FUTURE ACTIONS
A second operable unit consisting of source control remedial
measures nay be implemented following the supplemental RI/F5 and
issuance of a subsequent EPA Record of Decision. Source control
measures may be a cost-effective means of expediting the treatment
of the contaminated groundwater.
OPERATION AND MAINTENANCE
Preliminary cost estimates for the O&M of the packed column
air stripper are given in table 6.
A detailed description and schedule of O&M procedures, including
such activities as instrument readings, influent/effluent
sampling, equipment inspections, and maintenance of a spare
parts inventory will be developed as part of the design phase
of the project.
Once CERCLA trust fund eligibility for O&M costs expires, OfcM
costs will then be borne by either the Town of Vestal or the
State of New York or both.
\
-------
-12
SCHEDULE __
^
Record of Decision 6/30/86 *
Initiate Negotiations with PRP's 7/86
negotiations Successful* Negotiations Unsuccessful**
Sign Administrative Order
on Consent
Amend Cooperative Agreement 9/86
Design
Construction
Select Contractor
Approve Contract and
Initiate Design
Initiate Construction
Complete Construction
12/86
8/87
12/87
6/88
•Subsequent activity dates are subject to length of negotiations.
"Assumes State lead on design and the availability of funds in
September, 1986.
-------
KlbOMITtN
Figure
i
WELL 1-1 SITE STUDY AREA
-------
ISTIMATtOKAll
IM« MIT
Flgur* VESTAL WELL 1-1 STUDY AREA AND ENVIRONS
2
-------
CrnMATtOKAtf
•00 9M 1*00
IOO »00 300 4MIMTIM
Ffew« WATER TABLE CONTOUR MAP, APRIL 1985
-------
OEM M4D» 0.0ft MOO
OVfNlCI NQLO
•-I. OJWMOO
•
/
CURRENT MAX DAILY
DEMAND -140 MOO
-.,
IflTONAOC VOiUMI
US MO
OMTIIIC
f-f. CONTAI
1-1. 1JMMO
1-4. l.ftMO
i (
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4-1. CONTAMtNATtl
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-------
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VOL 1.1 HISTORICAL VOC ITTILS
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1,1,1-
Triehler*.
1,400/1,500
1,«00
19
«20
oil*1'"
TCC «th«n«
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> —
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• Tr«n>.
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-------
•CAll
MM IMCMIT
Ffeura
5
•i
ii
AREAL EXTENT OP GROIJNDWATER CONTAMINATION - TOTAL
VOLATILE ORQANICS fppb)
I 411
-------
KA1I
IMCMIT
WMIflM
FlfiM
6
LOCATIONS OF SURFACE DISCHARGES APPARENTLY RESULTING IN
GROUNOWATER CONTAMINATION
-------
a
RESPONSE ACTIO« WO
ASSOCIATED REMEDIAL TECHNOLKltS
Centt*intnt Soure« Control *»thed«
• Instil gmr***l9t cutoff
• Source
Creund»>ltr O^eontminttlen Mtthodi
9* intirapter «•!!
• Cortina U pu^ Wtll 1-1 ta wnti (Na •etian)
• Tnit Hell 1-1
• Tr»«t th*
Drinking W«t*r Suwlitt
*-v
1.3
• fetir Mpfif frw District MB. 5
• Vattr wpply fro* JWvwen City
• _*«t»r Kipply fro* lingharton
• Irvtcll • IM Mttr wpply •>" i" ••t« Oiitrlet ND. 1
-------
MIDI Dtstmcf w. t orCTAUw CNMncrcmstics
Nttrnativt
to Action
Air Strlpplnf
toll 1-1*
Air Strlpplnf
toll !-!••
CAC Moorptlon
toll 1-t
Coablnod Air
Stripplng/CAC
Arfaorptlon toll
1-1
Air Stripping
(•tract Ion toll
ond Voll 1.1
Vat or Supply fro*
Olatrlct to. »
totor Supply fro*
Jbhnoon City
it£%?' "~
a— *~"
toll 1-1
toll 1-1 10 Dlotrl-
to toot* but Ion
I -,
i r
«
I T
I V
i r
i
i
i
i
totor Supply Sourcoo In Optra! Ion
toll 1-2 toll 1-1 Citroetlon
to Olotrl- to Otalrl- toll Supplai Vtol
but Ion button to tooto totor C>-oly
I T
I
T
1
I
I «
t V
I V
1 T
I f
Koyt I a At full capacity.
T a Ao oupploMontol oupply*
•Ualno, Nail 1-2 oo
••Ualno. toll 1-1 oo
tno primary oupply ond toll
tha prlnory oupply ond toll
1-1 oo oupplaoont.
I** •• •uppittwftt*
0'"
-------
Tab It
*
CSTIMATO COSTS FOR UDOIAL ALTC«H*TI\CS
Capital Cast
AUsmstl* ($)
No Action 0
Air Stripping Vail 1-1" 349,400
Air Stripping Vail 1-1t »9,400
Vatar S«a?ply fr« District
Mo. 5 424,500
0 AN
Costs
U0.500
151,200
119,750
153,400
frassnt
Hbrth* of
0 A N
Costs
(S)
1,515,000
1 ,491 ,500
1,124,900
MM, too
Total
Prcatnt
North
(f)
1,515,000
1 ,180,700
1,511,500
1.195,100
•frwerrt wrth bi**tf on 50 r»»« «t 1B (P/A • 9.4269).
••Uilng Well 1-2 • tnt primary supply and Wtll 1.1 M aupplavnt.
fUting Vili 1.1 aa tna priaarjr auppijr and Mtll 1-2 aa aupplaMnt.
-------
TCE
• AW
WILL
HATH
f+fr
,JACKID
COLUMN
1 ' f '
TMCATIO MATH
•LOfftft
•OOtTf N
_£LIANWfU..
OH
MCUMVOIM
TMIATID
WAHM
TO
•vrriM
Figurt SCHEMATIC OF PACKED COLUMN AERATION PROCESS
7
-------
1
I
\
i
• 1000 1000
ICAlf
O 700 400 1100 1700 IftOOMITCMI
A
PROPOSED WATER SUPPLY TRANSMISSION MAIN FROM WELL 6-1 TO
DISTRICT NO. 1
-------
Toblt
CSTJHATED CAPJT* COST OF AIR STUlfP2NC «U 1-1
•wilding Obstruction and fetorlalo $135,500
Equipment (P«fc»
-------
PUBLIC MEETING
7:00 PM—June 10, 1986
TOWN HALL -i
Vestal Parkway West—Vestal, N.Y.
The New York State Department of Environmental Conservation
(DEC) will be holding • public meeting to explain and discusa the
remedial investigation and fcosibility study (RI/FS) that was carried
'out to determine the source and extent of contamination that was
identified in one of the town of Vestal's water supply wells. In 1980
volatile organic chemicals, primary trichloroethane (TCA),
dlchloroethylene (DCE). dichloroethine (DCA) uid trichloroethylene
(TCE) oil common degreasers, were found in the town's water supply
well 1-1 located between the end of pump house road and the
.Susquehana River, • little west of North Main Street. The well was
taken out of service and not used to avoid Introducing contaminants
Into the town's drinking water supply.
•
During the remedial investigation, Ecology I Environment, Inc.,
an engineering firm under contract to DEC, installed seven monitoring
wells, seven coil borings, and collected samples of air, surface water,
grounclwuter and aoils for chemical analysis. It was found that
contamination was primarily limited to groundwoter in an area to tht
northwest of Stage Road. It was determined that the contamination
was not migrating toward the town's two other municipal supply wells
JocntecTto the west of well 1-2. Currently, the possibility of public
contact with the contaminants is very limited. The town wfll,
however,xcontinue to monitor the water supply wells closely to insure
that they remain uncontaainated.
In addition to the field investigation, a Feasibility Study was •
conducted to evaluate various remedial plana for containing the plume
and ensuring, a safe, adequate supply of drinking-water for the Town
of Vestal. Several plans capable of achieving these objectives wert
developed and are presented in a report entitled, "Remedial-
Investigation Report, "Risk Assessment, and Feasibility Study for
Water Supply Well 1-1 Site, Vestal, New York". The report it
available for review in the Vests! Public Library and the Vestal Town
Clerk's of/See.
During the next month these alternatives will be evaluated and
one will be aelected aa the recommended alternative. You art
encouraged to attend the public meeting, read the report and provide
any input that nay help to select the best alternative.
* • •
If you have any questions or need additional information please
call Jeffrey Brandow P.E. at 518/457-5677 or call 1-800-342-9296 and
leave a recorded message and we will get back to you.
-------
CSTIHATO) 0 4 M COSTS OT ADt STRIP PI« HEU 1-1
fomt* $ 1O.JOO" f 10A,l»Ot
Sapling 2,500 * 2.500
L*or v 1,000 1,000
f Milntmmt lUttrlal* 11.AOO 11.AOO
t 1)l,200/yr S 119,750/jrr
PrtMnt ItorUin S 1,«»1,>00 $1,121,900
TOT blown, teitlr^, vvntllttlen, lighting, vrrf
inert«tntal ee*ti for poeplng nttr la t^ of colon.
•«Bi»«J en Mill 1.1 •• the swppl«i*ntil wppljr (fr«
tB««*d en "til 1.1 M the prlaary "upplf (fr
J»1).
ttBMitf en 30 y*»n • 101 (P/A • 9.A2A9).
\
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APPENDIX 4
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VESTAL WELL 1-1
VESTAL, NEW YORK
Monitoring Plan
Rev. 2, July 12, 1990
Morlando Construction Enterprises, Inc.
Joe Guarnieri, Project Manager
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Table of Contents
ESJ
1. Statement of Purpose 1
S. Site Description 2
3. Monitoring Well Location 3
4. Ground Water Sampling Frequency
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Purpose of Monitoring Plan
The purpose of this monitoring plan for the Vestal Well
1-1 located at Pumphouse Road is to provide the Town of
Vestal with sampling and analysis requirements of the
untreated and treated water from it in order that a
confirmation of potable quality according to the guidelines
set forth in the New York State Sanitary Code. Part 5 can be
made. It also outlines a program for ongoing collection of
data from several existing monitoring wells about the site to
provide a basis for determining changes in the contaminated
groundwater plume over time.
The treatment objective for this facility is to reduce
the level of each volatile organic contaminants to 1-2 PPE
and the total organics to between 10 and 20- PPB in the
finished water.
If at any time this objective is not met? modifications
to the treatment system may be required as determined by the
Bureau of Public water Supply Protection of the New York
State Department of Health.
Page 1
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Site Description - (see Fig. 1}
Well 1-1, a municipal water supply well, is contaminated with
volatile organic compounds - primarily trichloroethylene (TCE) and
1,1,1-trichlorethane. Water samples are collected from Well 1-1
every 30 days by the Town of Vestal. Well samples taken in 1988
show the following contaminant concentrations;
73 PPB Trichloroethene
7 PPB 1,1 Dichloroethene _ .
63 PPB 1,1 Dichloroethane
190 PPB 1,1,1 Trichloroethane
75 PPB trans-l,2-Dichloroethene
These levels exceed NYSDEC TEC groundwater standards
and Town of Vestal organic compound "non-detection" goals.
Drinking water for most of the western part of the Town of
Vestal is supplied by District 1, which draws water from wells
1-1, 1-2, and 1-3. At present, Well 1-3 is the water source, Well
1-2 is used to supplement supply in periods of peak demand, and
Well 1-1 is being pumped to waste in the Susquehanna River.
Well 1-2 now yields 500-700 gpms but pumps an appreciable
amount of sand. Therefore, Well 1-2 is used as an emergency
source only.
The three wells are on one aquifer, which is partly
contaminated. The pumping of Well 1-1 to waste affects the
contaminant plume that could otherwise contaminate Well 1-2 and
1-3.
Because Well 1-2 has a limited capacity, and the water in
Well 1-3 is highly corrosive, it is important that contamination
in the aquifer is contained and that Well 1-1 be reinstated to
meet futurex peak demands in Water District 1 and other
interconnected districts.
page 2
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- (see Fig. 2)
Ten monitoring wells are located east of Main Street to
provide hydrogeolog ic groundwater quality data for the
purpose of locating the source or sources of groundwater
contamination. Of these Wells S-l . S-2 . S-6. S-7 , S-8, S-l 1 ,
EB-l.EB-31, and EB-23 are cited to define the contaminant
plume near suspected source areas.
Sixteen monitoring wells are located west of Main Street
to be used for gathering hydrogeo logic groundwater quality
data. Among these are wells 1-25, 1-24, 1-29, and l-29(a>.
The total depths for the wells of interest are as
f o 1 lows :
S-l 25 FT
S-2 32 FT
S-6 41 FT
S-7 32 FT
S-8 25 FT
S-ll 40 FT
EB-1 33 FT
EB-31 53 FT
EB-23 35 FT
1-22 132 FT
1-24 129 FT
1-29 119 FT
1-29 (a) 64 FT
page 3
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Groundwater Sampling Frequency
Groundwater should be sampled from each of the nine
monitoring wells of interest east of Main Street once a year. The
volatile contaminants of concern which constitute the basis of Rev> ^
design of the Air Stripping Tower are:
- Trichloroethylene
- 1,1,1-Trichloroethane
- 1,1-Dichloroethane
- 1,2-Dichloroethane
- 1,2-Dichloroethylene Rev. 2
- Chloroform
Laboratory analysis protocols are to be in accordance with EPA
methods 502.1 Volatile Halocarbons and 503.1 Volatile Aromatics.
Also, groundwater should be sampled once every six months for both
dissolved and total concentrations of the following inorganics:
Chromium, copper, lead, zinc, nickel and mercury at the following -
well locations; 1-22; 1-24; 1-29; l-29(a); and EB-1 (see figure 2)
page 4
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WATER SAMPLING FREQUENCY AT WELL 1-1
The following water sampling frequency should be implemented at
Well 1-1 to insure reliability of the Air Stripping Technology.
Location Frequency Subnect Analysis
Well 1-1 once every three months** volat. & inorganics* Rev. 2
Clearwell once per day-first week .volat.
Clearwell once per week-next month volat.
Clearwell every 30 days volat.
Clearwell once first week See Note 3
Clearwell once next month See Note 3
Clearwell once 90 days there after See Note 3
* Inorganics include chromium, copper, lead, zinc, nickel, and
mercury. Volatiles are those included per EPA method 502.1 and Rev.
503.1 analyses.
** Noted frequency to be followed for at least the initial three Rev.
years; thereafter determination of a different frequency may be
made.
Note 1: Sampling of both raw and treated water shall be taken and
analysis sha'll be conducted by a New York State approved lab in
conformance with EPA method 502.1 Volatile Halocarbons and 503.1
Volatile Aromatics. Microbiological testing of raw and finished
water samples are to be conducted monthly to determine if any
biological growth is occurring within the tower. The results are to
be submitted to the Broome County Health Department.
Note 2: The first physical sample of the Clearwell commenced
2/19/90.
The first physical sample of Well 1-1 commenced 2/2C-, ->-j
Note 3: Required analysis is per the full range of contaminant^
described in the New York State Sanitary Code, Subpart 5-1 of
January 19, 1990.
page 5
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00
ftTIMATIO SCALE
3 op too too j»oo wont?
100 100 300 400 METE US
VESTAL WELL 1-1 STUDY AREA AND ENVIRONS
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U.S. ENVIRONMENTAL PHOTECTION
AGENCY
VESTAL WELL l-l SUE
BROOME COUNIY. VESML. NY
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APPENDIX 5
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SEF-25-l?5e
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APPENDIX 6
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RESPONSIVENESS SUMMARY
VESTAL WATER SUPPLY WELL MO. 1-1
Vestal/ Broom* County, N.Y.
The U.S. Environmental Protection Agency (EPA) originally
scheduled a public comment period from May 18, 1990 through June
16, 1990 for interested parties to comment on EPA's final
Remedial Investigation/Feasibility Study (RI/FS) and Proposed
Plan for the Vestal Well No. 1-1 site. However, EPA honored
requests from the Town of Vestal and Chenango Industries to
extend the comment period through July 12, 1990.
EPA held a public meeting on May 31, 1990 at the Vestal Town
Hall, located at 605 Vestal Parkway West, Vestal, N.Y. to
describe the remedial alternatives and present EPA's Proposed
Plan for cleaning up the Vestal Well No. 1-1 site.
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 were considered prior to the selection of the remedy
for the Vestal Well No. 1-1 site.
The comments have been summarized and organized into three major
categories: Proposed Plan; Remedial Investigation/Feasibility
Study; and Public Health Evaluation.
Proposed Plan
Comment; How will the financial obligation, including both
capital and operation and maintenance costs, be achieved for the
potable water remedy selected (particularly the contingency
remedy)? Ubat funding guarantees are there for a project of this
magnitude? What impact will there be on the Town of Vestal
should it be giv«»n. responsibility for operation and maintenance?
Response; The contingency remedy selected as part of the potable
water selected rcceuj i» 3W-2. rh« cost of the contingency
remedy, in particular the operation and maintenance costs of the
precipitation and clarification technology, is relatively
expensive.
Capital costs for contingency remedy implementation would be
funded by EPA (90%) and the State of N.Y. (10%), unless these
costs are paid by a potentially responsible party. This funding
is in the same proportion as for the selected soils remedy.
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Assurance of the operation and maintenance of the remedy (after
initial testing and start-up was complete) would be the
responsibility of the State; however, should EPA determine that
the remedy assists in restoring groundwater quality to a level '
that assures protection of public health, then the continued
operation of the remedy for up to 10 years (or achievement of
health-based levels in the aquifer, whichever comes first) could
be considered remedy implementation, and. therefore funded
accordingly (90%-10%). This determination would be made by EPA
at the time of contingency remedy construction. Potential
impacts on the Town would depend on the agreement reached between
the Town and New York State.
The amount of EPA funding for the contingency remedy, in the
absence of an agreement with a potentially responsible party,
would be based on determination of the remedial implementation
period. The EPA cost share for capital costs associated with the
contingency remedy is committed to by this Record of Decision,
subject to the availability of federal funds at the time of
contingency remedy design, and again at the time of contingency
remedy construction.
The State's obligation to fund the contingency remedy, including
the yet to be determined State cost share for long term operation
and maintenance, would be contractually guaranteed by the
execution of a Superfund State Contract. Such a contract
presently exists for this site, but would have to be amended at a
future date to include the contingency remedy, if the remedy
becomes necessary. If the State elects not to fund its portion
of the contingency remedy, whether through State or local
contribution, then construction of the remedy would not proceed.
Comment; Exploration for a new water supply well should also be
considered at this time as a possible alternative.
Response; In certain limited instances, EPA, pursuant to its
responsibilities under the Comprehensive Environmental Response,
Compensation, and Liability Act ("CERCLA") can assist in the
arrangement of alternate water supply provisions. However, for
long-tern remedial actions e.g., Vestal 1-1, EPA's response
actions are usually directed toward protection of public health
and the environment through prevention/remediation of the
uncontrolled release or c^': ?£••' of ^mt^-.iruition into the
environment, which nay include ground and surface waters used for
potable water purposes. ET-". h-"7. •' KV&& ar * poliry matter that
planning, development and management of potable water supplies
are generally the responsibility of state and local governments,
and are outside the scope of Superfund long-term remedial goals.
An alternate water supply to replace Well 1-1 has not been
considered a necessary response to the release of hazardous
substances at this site. EPA's appropriate response, initiated
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at the time of the first operable unit, has been to ensure
containment and continuous pumping of the plume of contamination,
as well as to provide treatment of water from Well 1-1 to attain
applicable water quality requirements. During the first operable
unit FS, EPA considered two discharge receptors for treated water
from Well 1-1; namely, the Susquehanna River, or potable water
distribution. EPA's analysis of alternatives concluded that it
was cost-effective and protective of public health and the
environment to treat the pumpage to potable water standards so
that Well 1-1 could be restored to service as a potable water
supply.
In summary, EPA believes that the State of New York and, by
extension, the Town of Vestal must generally plan, develop, and
manage the Town's potable water resources. On the other hand,
water resources affected by the release of hazardous substances
at this site (most notably Well 1-1) are within the scope of EPA
remedial goals.
Comment; The action levels which trigger the potable water
contingency remedy should be set at Well 1-1, not some
intermediate monitoring well.
Response; The selected remedy under this Record of Decision
documents the criteria for implementation of contingency remedy
GW-2 at Well 1-1. There are two basic criteria; namely, the
exceedance of selected baseline levels of inorganics at any of 3
monitoring wells designated under the selected remedy for this
purpose, and the exceedance of potable water supply criteria for
inorganics at Well 1-1. The first criterion is intended to
assist EPA's decision to initiate the contingency remedy
selection process and subsequent design, and the second criterion
is intended to trigger EPA's decision to construct the designed
remedy, for additional details, including a description of
selected baseline levels of inorganics, please see the SELECTED
REMEDY portion of the Record of Decision.
In this way, EPA believes that the amount of time required to
make the contingency remedy operational would be considerably
shortened using the conservative criteria specified in the ROD,
and the corresponding impact on the water resources of the Town
of Vestal would be lessened. ... .
Comment; If a need for treatment of inorganics arises in the
future, the contingency remedy should be fiexibi.- sr.owicjii co
consider more than the two options presently considered under the
contingency remedy.
Response: The contingency remedy, if required, will be
alternative GW-2, as described in the SELECTED REMEDY portion of
the Record of Decision. However, new technologies may be
considered in the future should circumstances warrant their
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consideration.
Comment: The selection of in situ vapor extraction for source
remediation is not necessarily supported by the FS, specifically
the assumptions concerning the size of the nixing zone (for the
soil to groundvater model). The selected source remedy for Area
4 should be no action, while the selected source remedy for area
2 should be either no action or capping.
Response: There are numerous assumptions inherent in all
groundwater models; however, EPA believes that the current model
provides a reasonable scenario for predicting fate and transport
of contaminants from the vadose zone to a groundwater receptor.
Remedial Investigation/Feasibility Study
Comment ; The Feasibility Study calculated overly conservative
soil cleanup levels by limiting consideration of dilution
effects, as well as by using an unjustified assumption concerning
the amount of annual water infiltration from precipitation. The
FS alternatives analysis is biased as a result.
Response; The calculations of soil cleanup levels in the
Feasibility Study represented one of the recommended
methodologies of developing soil cleanup levels based on
theoretical groundwater exposures. In order to confirm the soil
cleanup levels for this Record of Decision, EPA has employed
additional modelling techniques which use similar and additional
conservative assumptions. EPA believes these conservative
assumptions are justifiable, particularly when employed in
matters potentially affecting public health.
Comment; Source remediation efforts in Area 2 must begin prior
to, or contemporaneously with, any remediation efforts in Area 4,
since cleanup of Area 4 alone could not achieve EPA's objective
of protecting groundwater and surface water from the continued
release of contaminants from soils.
Response; It is EPA's intention to proceed with design and
implementation of the soil remediation remedy in areas 2 and 4
concurrently. Moreover, the remediation of area 2 prior to area
4 is not believed to be a necessary sequence of remediation in
order to achieve EPA's objectives.
Comment; The partial containment option was inaccrcrri
screened from further consideration from the FS. This technology
had been screened out of the FS based on the possibility of
groundwater table fluctuations solubilizing groundwater
contaminants, a hypothesis which was not supported by any of the
site data.
Response; During the remedial investigation no site data was
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collected to specifically test the above hypothesis, so that a
lack of supporting information is not unusual. The fluctuating
water table hypothesis, while not fully supported by the site
data, nevertheless remains a valid consideration.
Moreover, EPA believes that containment technology was
appropriately screened out, based on its lack of effectiveness
compared to other, more promising treatment technologies. EPA's
consideration of effectiveness included the degree to which the
various technologies reduced the toxicity, mobility, or volume of
contaminants in two relatively small, discrete areas of
contaminated soil. Capping would not reduce the toxicity or
volume of contaminants, and there is a level of uncertainty as to
reduction of mobility. Given the other treatment technologies
that were considered effective and implementable at this site,
EPA believed screening out the capping option would meet the
intent of the National Contingency Plan, and also be consistent
with the statutory bias under CERCLA for permanent remedies
employing treatment as a principal element.
Comment; The discussion of the no action alternative fails to
account for the remedial activity being conducted as part of
Operable Unit 1.
Response; The no action alternative discussion in the FS does not
specifically mention the operable unit one remediation i.e., air
stripping facility at Well 1-1. However, EPA has conducted its
decision-making at this site fully aware of the consequences of
the first operable unit operation. In fact, EPA's Proposed Plan
specifically mentioned the protection afforded by the remedial
action implemented under operable unit one in the event of a no
action Record of Decision for operable unit two. The Proposed
Plan went on to indicate that one serious ramification of no
action would be the prolonged degradation of the aquifer
conceivably extending beyond the design life of the operable unit
one facility, thereby requiring treatment at Well 1-1 far into
the future.
Comment; Th« evaluation of in situ vapor extraction arbitrarily
assumes that the exhaust gas from the vacuum pumps will require
treatment prior to release, while such treatment is not being
required at the air stripping facility installed at Well 1-1, nor
is it being required in the soil tilling alternative.
Response; The only assumption that EPA made at the po?.r.t of
remedy proposal and subsequent selection in this regard is that
all Federal and State applicable or relevant and appropriate
requirements will be met (as stated in EPA's Proposed Plan). For
costing purposes, the FS made further assumptions concerning the
likelihood of air emission controls being required, based on the
type of remedial technology being considered. These assumptions
in no way represent a determination by EPA as to the need for
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such controls. A final determination of the need for air
emission controls will be made during design.
Comment;, The RI and FS data both support the conclusion that the
groundwater contamination attributable to Area 4 has had little
or no impact on Well l-l. However, the RI report states that the
groundwater contamination attributable to area 4 is at least
partly responsible for the contamination at Well l-l.
Response: The above two sentiments are not necessarily exclusive
of each other. It is likely that the contribution of
contaminants to Well l-l from area 2 is greater than the
contribution from area 4. However, the magnitude of the
difference in impacts to Well 1-1 is difficult to assess
accurately. Moreover, soil cleanup levels were based on their
contaminant contribution to the aquifer as measured at the
boundary of the Stage Road Industrial Park, not at Well 1-1.
Comment; Given the sizes of Areas 1 through 4, the level of
effort expended by Ebasco to select borehole locations was far
greater than necessary. Surface soil sampling alone could have
been effective in borehole location selection.
Response; The purpose of the geophysical survey, as outlined on
page 2-1 of the RI report, was to locate the leach field north of
the Chenango building and to locate buried storage tanks or other
large metal objects on nearby properties. This information would
therefore be useful in determining whether there were active
sources of contamination, or just contaminated soils. This
information could also have some bearing on where boreholes could
be placed i.e., avoidance of underground containments. The
surface soil samples assist in delineating areas whose surficial
soils show evidence of contamination. Together, the two sets of
information are important to preliminarily identify the nature
and extent of subsurface contamination.
Comment; The RI report does not explain the methodology by which
the surface soil sampling data was used to select boring
locations, and does not provide a rationale for selecting soil
boring samples for lab analysis.
Response; The explanation regarding the method by which the
surface soil sampling data was used to select boring loc^t-i---
and the rationale for the selection of soil boring samples to*.
lab analysis are presented in Sections 2.2 and 2.3 of the RI
report (pages 2-2 to 2-6). Additional details were provided in
the Field Operations Plan, which was part of the site workplan
prepared in April, 1988.
Generally, boring locations were selected based on high screening
results. However, alternate locations were selected if
accessibility was a problem. A total of 36 boreholes were
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drilled using this approach. Samples collected from these borings
were screened using a field gas chromatograph in order to
minimize the number of samples sent for lab analysis. In
general, borings with high VOC readings were selected.
Additional samples were selected in Area 4 in order to cover the
whole area. A total of 62 samples, including blanks and
duplicates, from 24 borings were selected for lab analysis.
Comment; Only three new wells and two public water supply wells
appear to be properly installed in the study area for the site.
Response; The wells installed by Ecology and Environment, inc.
during the first operable unit i.e., S-l through S-8, were
constructed in accordance with EPA quality assurance protocols
appropriate for this site, including the proper grade of
stainless steel well casing and screens. These 8 wells, as well
as the 3 additional wells installed by EPA during the second
operable unit, are all considered by EPA to be first class
groundwater monitoring wells. In addition, the three potable
water wells in the area, 1-1, 1-2, and 1-3 were properly
installed, although well 1-2 has experienced recent difficulties
in achieving an effective yield. Although the wells associated
with the R.J. Martin investigation ("1" series) were constructed
of polyvinyl chloride (PVC), EPA believes that those wells which
were not obstructed or otherwise defunct would provide acceptable
data in order to confirm the moderate-to-high levels of organic
compounds documented during the first operable unit RI.
Comment; An inconsistency regarding access to wells exists
between the text on page 2-9 of the RI report and the data on
table 2-1, concerning obstruction of the wells.
Response; The "inconsistency" noted was that, if certain wells
(1-26 and 1-30) were obstructed, then how could water level
measurements be reported for these wells. It is possible that a
well which is damaged enough to preclude sample collection may
still be amenable to water level measurements, which was the case
for these two wells. Access to S-6, moreover, was initially
denied, but the well was able to be sampled at a later date.
Comment; Since one of the two monitoring wells upgradient of
Chenango Industries was obstructed, EPA should have replaced it,
instead of using 1985 data from this well.
Response; The intent of the second operable unit was to delineate
sources of site contamination, and to confirm the existing
profile of groundwater contamination, including identification of
any contaminants in the groundwater that might be incompatible
with the first operable unit selected remedy. As such, the
decision was made not to replace Well S-4 since, based on the
earlier sampling, this'well was outside the plume of
contamination in an upgradient direction.
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8
Comment; It appears that a mathematical error was made in the
conversion of cm/rain to ft/day and the values reported in Table
3-1 of the RI report should range from 16 to 35 feet/day.
Response; The comment is correct. There was a mathematical error
in this conversion factor. Corrected values for Table 3-1 should
read as follows:
AREA SOIL BORINGS DEPTH (ft) HYDRAULIC
CONDUCTIVITY
(ft/day)
1 SB-107 12-14 30.7
2 SB-205 12-14 16.5
SB-213 10-12 26.0
3 SB-310 14-16 23.6
SB-316 16-18 28.3
SB-322 16-18 35.4
4 SB-404 14-16 25.0
SB-410 12-14 26.0
SB-412 16-18 30.7
SB-417 12-14 26.0
Comment; In Table 4-4 of the RI report, the total xylene
concentrations at SB-115 (6-8 feet) is noted as 350U. Wasn't the
detection level 5 (ppb)?
Response; The comment is correct. The total xylene concentration
was 350 ppb.
Comment; Was the pesticide found in SB-206 at 4-6 feet dieldrin
or 4,4'-DDE, (text, figures and tables appear inconsistent)?
Response; The pesticide found was 4,4'-DDE, and not dieldrin as
indicated in the text.
Comment; W«r« there four or six exceedances of nickel above
background concentrations in Area 4 (text and figures appear
inconsistent)?
Response; There were actually five exceedances of nickel above
background concentrations in Area 4; however, the five
exceedances were located within four boreholes. These
exceedances were only marginally above the upper end of the
background range. Figure 4-16 should also be corrected to add
nickel (32.5 ppm) at borehole SB-409 (10-12').
Comment; On page 72 of the RI report, the compound
trichloroethylene appears to be confused with trichloroethane in
the comparison between the water quality of Wells EB-31 and S-7.
-------
Responses The comment is correct. The sentence should be revised
to read "did not contain any TCA which is the primary constituent
of well S-7".
Comment; On page 6-4, the RI report states that the maximum
concentration of PCB's below source areas 2 and 4 exceeds the
N.Y. State standard. However, there is no N.Y. State standard
for PCBs in soil.
Response; The concentrations of PCBs, as well as the standards,
referred to on page 6-4 are for groundwater.
Public H«altb Evaluation
Comment; The health-based cleanup levels for groundwater were
calculated on the basis of a 10"6 risk level, instead of
considering other values within the NCP risk range of 10"4 to 10*.
Response; Under the NCP, the 10* risk level is the point of
departure for determining remediation goals when applicable or
relevant and appropriate requirements do not exist or are not
sufficiently protective. Therefore, it is entirely appropriate
for the PHE to calculate theoretical groundwater cleanup levels
based on the 10*6 risk level for EPA consideration. Further, EPA
determined that effective management of the risks posed by
contaminated groundwater at this site, as well as other site
considerations, did not warrant groundwater remedial action at
the present time, other than the groundwater remedial action
being currently provided through implementation of the first
operable unit.
Comment; The Superfund risk assessment guidance manual specifies
the use of a residential exposure duration factor of 30 years
adult exposure as the 90th percentile upper limit of the average
time spent at one residence. The Public Health Evaluation's use
of a nine year exposure duration and the assessment of the period
from age 0-30 are not consistent with this guidance.
Response: The use of a nine year exposure duration from ages 0-9
was used for non-carcinoaenic risk, and is an appropriate way to
develop worst-case hazard indices. The use of a 30 year exposure
duration averaged over a 75 year life span was used for
carcinogenic risk. Both methods are consistent with the Risk
assessment Guidance for Suoerfund Human Health Evaluation Manual.
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APPENDIX 7
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