United States Office of
Environmental Protection Emergency and
Agency Remedial Response
EPA/ROD/R02-93/205
September 1993
&EPA Superfund
Record of Decision:
Preferred Plating, NY
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50272-101
REPORT DOCUMENTATION
PAGE
1. REPORT NO.
EPA/ROD/R02-93/205
3. Recipient's Accession No.
4. THIe and Subtitle
SUPERFUND RECORD OF DECISION
Preferred Plating, NY
Third Remedial Action - Final
5. Report Date
09/24/93
6.
7. Authors)
8. Performing Organization Rept. No.
9. Performing Organization Name and Address
10 Protect Task/Worfc Unit No.
11. ContraetfC) or Orant(G) No.
(C)
(G)
12. Sponsoring Organization Name and Address
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
13. Type of Report & Period Covered
800/800
14.
15. Supplementary Notes
PB94-963813
16. Abstract (Limit: 200 words)
The 0.88-acre Preferred Plating site is a chemical plating facility located in Suffolk
County, New York. Land use in the area is predominantly light industrial and
residential. Most of the estimated 10,000 people who reside within a 3-mile radius use
public water companies to obtain their drinking water supply. EPA designated the
Nassau/Suffolk Aquifer System, which underlies the site, as a sole-source aquifer. From
1951 to 1976, P-referred Plating Company (PPC) operated a metal plating facility, which
included degreasing and cleaning and surface finishing of metal parts, that resulted in
the generation, storage, and disposal of hazardous substances onsite. Untreated
wastewater was discharged to four concrete waste storage pits onsite. Because
Preferred Plating is downgradient of Del Laboratories (Del), EPA determined that Del
may have contributed to some of the site contamination. Since 1964, Del Laboratories
has manufactured cosmetics and topical Pharmaceuticals on a 6-acre wooded lot adjacent
to and upgradient of the PPC facility. From 1964 to 1973, process wastewater and
noncontact cooling water from Del were discharged to leaching pools on the Del
property. In 1973, the leaching pools were sealed and converted into wastewater
holding pools, which when full, were pumped and the waste water was removed offsite as
nonhazardous waste. This method of disposal was practiced until 1987, when Del started
(See Attached Page)
17. Document Analysis a. Descriptors
Record of Decision - Preferred Plating,
Third Remedial Action - Final
Contaminated Medium: None
Key Contaminants: None
b. Identifiers/Open-Ended Terms
c. COSATI Field/Group
NY
16. Availability Statement
19. Security Class (This Report)
None
20. Security Class (This Page)
None •
21. No. of Pages
44
22. Price
(See ANSI-Z39.18)
SM Inttructlons on Rtvirse
OPTIONAL FORM 272 (4-77)
NTIS-35)
nt of Commerce
(Formerly NTIS-35)
Department
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EPA/ROD/R02-93/205
Preferred Plating, NY
Third Remedial Action - Final
Abstract (Continued)
discharging wastewater to the public sewer system. In 1987, the State requested that Del
investigate the impact of the sealed leaching pools on soil and ground water. Various
organic compounds and metals were detected in soil samples; however, ground water analyses
showed that the soil had not contaminated ground water. EPA investigations detected the
presence of ground water contamination upgradient of the PPC facility, specifically by
cadmium, chromium, lead, and nickel. As a result, five concrete holding pools were
removed and 1,708 tons of contaminated soil surrounding the leaching pools were excavated
and disposed of offsite. The excavation was backfilled with clean fill, compacted, and
covered with 9 inches of crushed stone. Previous 1989 and 1992 RODs addressed ground
water contamination beneath the Preferred Plating facility, as OU1, and soil contamination
at the Preferred Plating Facility, as OU2, respectively. This ROD addresses a third and
final action for the potential ground water contamination as a.result of waste disposal
practices at the upgradient Del facility, as OU3. Based on the previous cleanup
activities at the Del facility and the cleanup activities that are planned for the two
other OUs at the Preferred Plating site, EPA proposes that no additional remedial action
be taken for the site; therefore, there are no contaminants of concern affecting this
site.
The selected remedial action for this site is no further action. Cleanup activities at
the Del facility, along with remedial activities planned under the other two OUs at the
site, have been deemed adequate for protecting human health and the environment. There
are no present worth or O&M costs associated with this no action remedy.
PERFORMANCE STANDARDS OR GOALS:
Not applicable.
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RECORD OF DECISION FACT SHEET
EPA REGION II
Site;
Site name:
Site location:
EPA Region:
HRS score (date):
Record of Decision;
Date signed:
Selected remedy:
Operable Unit:
Capital cost:
O & M cost:
Present-worth cost:
Lead;
Enforcement, EPA
Primary Contact:
Secondary Contact:
Main PRP:
Waste;
Waste type:
Waste origin:
Estimated waste quantity:
Contaminated medium:
Preferred Plating Corporation (PPC)
Farmingdale, Town of Babylon,
Suffolk County, New York
II
33.76 (September, 1984)
September 24, 1993
"No Action"
OU-3
-0-
-0-
-0-
Lorenzo Thantu, RPM
(212) 264-2719
Damian Duda, Acting Section Chief
(212) 264-5546
Del Laboratories, Inc.
Contact - Gregory Quillinan
(516) 293-1515
cadmium, chromium, lead, and nickel
PPC facility
N/A
groundwater
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RECORD OF DECISION
Preferred Plating Corporation
Farmingdale, Town of Babylon, Suffolk County, New York
United States Environmental Protection Agency
Region II
New York, New York
September 1993
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DECLARATION FOR THE RECORD OF DECISION
SITE NAME AND LOCATION
Preferred Plating Corporation
Farmingdale, Town of Babylon, Suffolk County, New York
STATEMENT OF BASIS AND PURPOSE
This decision document presents the U.S. Environmental Protection
Agency's (EPA's) selection of the remedial action for the third
operable unit of the Preferred Plating Corporation Superfund Site
(Site) in accordance with the Comprehensive Environmental Response,
Compensation, and Liability Act of 1980, as amended, 42 U.S.C. §§
9601-9675, and the National Oil and Hazardous Substances Pollution
Contingency Plan. This decision document explains the factual and
legal basis for selecting the remedy for this Site. The attached
index (Appendix III) identifies the items that comprise the
Administrative Record upon which the selection of the remedial
action is based.
The New York State Department of Environmental Conservation
(NYSDEC) concurs with the selected remedy (see Appendix IV).
DESCRIPTION OF THE SELECTED REMEDY - NO ACTION
This is the third and final operable unit for the Site, which
addresses potential groundwater contamination that has been
detected in the upgradient portion of the Site at Del Laboratories,
Inc. (Del). EPA in consultation with the NYSDEC has determined
that this contamination does not pose a significant threat to human
health or the environment and, therefore, remediation is not
appropriate. This determination is based on previous cleanup
activities at Del's facility, the cleanup activities that are
planned under the two other operable units at the Site, and the
remedial investigation and the human health risk assessment that
were conducted for the third operable unit. Thus, a "No Action"
remedy is the selected remedy for the third operable unit of the
Site.
The remedy for the first operable unit, which addresses
contaminated groundwater at the Site, one of the principal threats
posed by the Site, was specified in a ROD issued on September 22,
1989. The remedy for the second operable unit, which addresses
contaminated soils at the Site, the other principal threat posed by
the Site, was specified in a ROD issued on September 28, 1992.
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DECLARATION
In accordance with the requirements of CERCLA, as amended, and
the NCP, it has been determined that no remedial action is
necessary for the third operable unit to protect human health and
the environment at the Site. Previous cleanup activities
conducted at Del's facility, undertaken at the direction of the
Suffolk County Department of Health Services, have remediated the
significant contamination formerly present at this facility.
Because this "No Action" remedy will not result in hazardous
substances remaining on-site above health-based levels, the five-
year review will not apply to this action.
William J. M(is^y
7^
Acting Reg^fonal
i, P.E.
inistrator
Datfe
/
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RECORD OF DECISION
DECISION SUMMARY
Preferred Plating Corporation
Farmingdale, Town of Babylon, Suffolk County, New York
United States Environmental Protection Agency
Region II
New York, New York
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TABLE OF CONTENTS
SECTION PAGE
SITE NAME, LOCATION AND DESCRIPTION .... 1
SCOPE AND ROLE OF OPERABLE UNIT 2
SITE HISTORY AND ENFORCEMENT ACTIVITIES 2
HIGHLIGHTS OF COMMUNITY PARTICIPATION 7
SITE CHARACTERISTICS 7
SUMMARY OF SITE RISKS 9
DESCRIPTION OF THE "NO ACTION" REMEDY 13
DOCUMENTATION OF SIGNIFICANT CHANGES 13
ATTACHMENTS
APPENDIX I FIGURES
APPENDIX II TABLES
APPENDIX III ADMINISTRATIVE RECORD INDEX
APPENDIX IV STATE LETTER OF CONCURRENCE
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SITE NAME, LOCATION AND DESCRIPTION
The Preferred Plating Corporation (PPC) site (Site) includes the
former PPC facility located at 32 Allen Boulevard in Farmingdale,
Town of Babylon, Suffolk County, New York. This 0.88-acre facility
is in an area zoned for light industrial use, and it is
approximately 1 mile east of the Nassau-Suffolk County line. Route
110 passes just west of the Site (see Figure 1) . Immediately north
of the former PPC facility is a wooded area, owned by Del
Laboratories, Inc. (Del), beyond which lie various industrial
facilities, including the Del facility. To the south are a
residential community and a U.S. Army facility. Commercial or
light industrial properties occupy the land to the east and west.
The Del facility is located at 565 Broad Hollow Road also in
Farmingdale, Town of Babylon, Suffolk County, New York, and it
consists of land Parcels A and B (see Figure 2) . As shown on
Figures 1 and 2, the Del property is situated north of Del Drive,
south of Route 109, and east of Route 110. Del owns two wooded
lots in the vicinity, one 13.5-acre lot located immediately east of
Del's Parcel B property and one 6-acre lot (Parcel A) located just
south of Parcel B (see Figure 2). Other smaller parcels of land
acquired by Del are also shown on Figure 2, as are the dates of
purchase.
The 1980 census recorded a population of greater than 10,000 within
a 3-mile radius of the Site. The population density in the area is
estimated to be 3,000 to 6,000 persons per square mile.
The Site is located in the south-central glacial outwash plain of
Long Island, which constitutes the Upper Glacial Aquifer, estimated
to be 90 feet in thickness under the Site. The naturally occurring
surface soil is a sandy loam which promotes rapid infiltration to
the groundwater. On the Site proper and throughout much of the
region, soils have been classified as urban. This is primarily a
result of the development and pavement which promote greater run-
off of precipitation. The Upper Glacial Aquifer overlies the
Magothy Aquifer, and the two may act as distinct aquifers, or as
one, depending upon the degree of hydraulic connection between the
two. However, in the Site area, it is believed that the two are
not hydraulically connected. Pursuant to Section 1424(e) of the
Safe Drinking Water Act, EPA has designated the Nassau/Suffolk
Aquifer System as a Sole Source Aquifer.
Most of the homes and businesses in the area surrounding the Site
are supplied by two public water companies, East Farmingdale Water
District and Suffolk County Water Authority (SCWA). The East
Farmingdale Water District supplies water to Del as well as to
areas north and immediately south of Del. The SCWA supplies water
to areas further south of Del. Recently, on April 29, 1993, the
New York State Department of Environmental Conservation (NYSDEC)
received information from the Suffolk County Department of Health
Services (SCDHS) indicating that two locations hydraulically
downgradient of the PPC facility, as well as the possibility of at
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least seven other locations, are served by private wells. The
SCDHS is currently conducting a well survey in the vicinity of the
Site to evaluate the extent of the use of private wells.
All public water supply wells in the Site area draw water from the
deeper aquifer, the Magothy Aquifer. The nearest public water
supply well fields are located approximately 1 mile east and 1 mile
south of the Site.
The nearest body of surface water is an unnamed intermittent
tributary of Massapequa Creek which is approximately 6,000 feet
west of the Site. There is no designated New York State
Significant Habitat, agricultural land, historic or landmark site
directly or potentially affected. There are no endangered species
or critical habitats within close proximity of the Site. The Site
is located more than 2 miles from a 5-acre coastal wetland and more
than 1 mile from a 5-acre fresh-water wetland.
SCOPE AND ROLE OF OPERABLE UNIT
This operable unit is the third and last operable unit for the
Site. The remedy for the first operable unit, which addresses
contaminated groundwater beneath the PPC facility, was specified in
a Record of Decision (ROD) issued on September 22, 1989. The
remedy for the second operable unit, which addresses contaminated
soils at the PPC facility, was specified in a ROD issued on
September 28, 1992. The third and final operable unit, which is
the subject of this ROD, addresses potential groundwater contamina-
tion that has been detected in the upgradient portion of the Site.
The primary objective of this third operable unit is to determine
if operations at Del have impacted the groundwater quality beneath
the Site.
SITE HISTORY AND ENFORCEMENT ACTIVITIES
Discussion of remedial and enforcement activities at the PPC
facility and the Del facility is provided below. The first part of
this discussion addresses the PPC facility, including the history
of PPC's operations and the subsequent groundwater and soils
investigations that were conducted by EPA. The second part of the
discussion addresses the Del facility, which is an industrial
facility located upgradient of the PPC facility. The Del facility
and the groundwater associated with it are the subject of EPA's
investigation for this ROD. Since the history of Del's operations
and associated enforcement activities are pertinent to the third
operable unit, the Del discussion includes the findings of a
separate groundwater and soil investigation conducted at the Del
facility and the source remediation that resulted from that
investigation.
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PPC Facility
PPC conducted operations from September 1951 through June 1976.
The primary activities at the PPC facility were to treat metal
parts chemically to increase their corrosion resistance and provide
a cohesive base for painting. The plating processes included
degreasing, cleaning, and surface finishing of the metal parts.
These processes involved the use of various chemicals which
resulted in the generation, storage, and disposal of hazardous
substances. Untreated wastewater was discharged to four concrete
waste storage pits directly north of the original building (see
Figure 3).
Groundwater contaminated with heavy metals was detected at the Site
by the SCDHS as early as June 1953. SCDHS indicated that the waste
storage pits on the Site were severely cracked and leaking.
Samples taken from the sludge in the pits showed that they were
mainly contaminated with heavy metals. From 1953 to 1976, SCDHS
instituted numerous legal actions against PPC in an effort to stop
discharges of wastes into the pits and to install or upgrade the
on-site treatment facility. SCDHS also sought to ensure that no
improper discharges were being made to the steam condensate
leaching pool or the sanitary leaching pool used by PPC. PPC
prepared an engineering report in May 1974 in order to apply for a
State Pollutant Discharge Elimination System (SPDES) permit, which
was issued in June 1975. PPC chemically treated the wastewater in
the pits and indicated that it then had the treated wastewater
removed. The removal of the treated wastewater residuals has not
been confirmed. The facility was never in full compliance with the
terms and conditions outlined in the SPDES permit.
In 1976, PPC declared bankruptcy. Since then, several firms have
occupied the PPC facility, none conducting similar operations to
PPC. In 1982, the original building was extended by 200 feet,
which covered the concrete waste storage pits. Nearly the entire
PPC facility is covered either by the existing building or paved
driveways and parking areas.
In September 1984, Woodward-Clyde Consultants, Inc. performed a
Phase I - Preliminary Investigation of the Preferred Plating Site
for the NYSDEC to compute a Hazard Ranking System (HRS) score
needed to evaluate whether to place the Site on the National
Priorities List (NPL) . In the Phase I report, an HRS score of
33.76 was documented, thereby requiring that the Site be proposed
for inclusion on the NPL. The Site was proposed and listed on the
NPL on October 15, 1984 and June 10, 1986, respectively.
From June 1987 to June 1989, EPA's contractor, Ebasco Services,
Inc., conducted the initial remedial investigation and feasibility
study (RI/FS) of the Site. The study detected heavy metals and
chlorinated organics in the groundwater underlying the PPC
property. A ROD for the treatment of the contaminated groundwater,
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designated as the first operable unit, was signed on September 22,
1989. The major components of the selected remedy include
extraction of the contaminated groundwater, groundwater treatment
for heavy metals and chlorinated organics, and reinjection of the
treated groundwater. The design for this treatment system was
completed in March 1992 and construction of the system is expected
to begin in 1994 after completion of the source remediation.
In order to further characterize the soils underlying the former
storage pits, EPA undertook a second RI/FS to investigate the
subsurface soils within and directly beneath the former storage
pits and leaching pools at the PPC facility. EPA's contractor,
Malcolm Pirnie, Inc., performed the second operable unit RI/FS from
April 1990 to July 1992. A ROD for the treatment of the
contaminated subsurface soils was signed on September 28, 1992.
The remedy includes excavation of the subsurface soils, off-site
treatment of the heavy metals and organics, and off-site disposal.
The remediation of the contaminated subsurface soils is expected to
begin and be completed in 1994.
Additionally, the initial RI/FS also detected the presence of
groundwater contamination upgradient of the PPC facility.
Analytical results of groundwater samples collected during the
first operable unit RI indicated the presence of heavy metals,
predominantly cadmium, chromium, lead, and nickel, at concentration
levels greater than Federal maximum contaminant levels (MCLs) in
both upgradient and downgradient wells at the Site. Specifically,
cadmium, chromium, lead, and nickel were detected at concentrations
of 71 micrograms per liter (ug/1) , 291 ug/1, 144 ug/1, and 274
ug/1, respectively, in groundwater samples collected from
monitoring well MW1SP (see Figure 4), which is located upgradient
of former leaching pools at the PPC facility. Therefore, EPA
determined that it was necessary to undertake a third study to
investigate the potential of an upgradient contributing source of
contamination, which was designated as the third operable unit.
Because Del is located north of the PPC facility (see Figure 1) ,
and the groundwater flow is generally in a southerly direction, EPA
subsequently entered into an Administrative Order on Consent (AOC)
with Del on September 27, 1990 to conduct an RI. Geraghty and
Miller, Inc., Del's consultant, performed the third operable unit
RI from September 1990 to July 1993. The preferred remedy in the
Proposed Plan, released to the public on July 21, 1993, was based
on this RI.
Del Property
Since its beginning in 1964, Del has been using essentially the
same process to manufacture cosmetics and over-the-counter topical
Pharmaceuticals for wholesale and retail markets. Del's
manufacturing operations are located on Parcel B, and Parcel A is
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a 6-acre wooded lot just south of Parcel B (see Figure 2). Of the
four metals of concern (i.e., cadmium, chromium, lead, and nickel)
found in the groundwater upgradient of the PPC facility, only
trivalent chromium is used in the manufacture of Del's products.
Both industrial wastes and sanitary waste are generated at the Del
property. Industrial wastes include process wastewater and
noncontact cooling water. Process wastewater is generated at Del's
quality control laboratory and from washing, mixing, and packaging
equipment which contacts product. Noncontact cooling water is
generated from cooling mixing vessels used in manufacturing
products.
From the start of manufacturing in 1964 until 1973, process
wastewater and noncontact cooling water were discharged to leaching
pools located on the western portion of the Del property.
Noncontact cooling water was also discharged to pools located on
the northern portion of the property (see Figure 5). Beginning in
November 1972 and continuing into early 1973, all industrial
leaching pools were sealed and converted into wastewater holding
pools (see Figure 5) . When full, the pools were pumped and the
wastewater was removed by a New York-licensed hauler as
nonhazardous waste. This method of disposal continued until
November of 1987 when Del started discharging both process
wastewater and noncontact cooling water to its sewer system in
accordance with the Suffolk County Department of Public Works
certification.
Sanitary wastes were formerly discharged to sanitary leaching pools
(see Figure 5) ; the operation of these leaching pools ceased in
September 1987. Since September 1987, sanitary effluent has been
discharged to Del's sewer system (see Figure 6).
In December 1987, the SCDHS requested that Del investigate the
impact of the western leaching pools on soils and groundwater. The
contaminants of concern were identified as various organic
compounds and four metals (copper, silver, lead, and cadmium). In
March 1988, Donnelly Engineering was retained by Del to conduct a
study. As part of a Phase I effort, Donnelly Engineering installed
three monitoring wells (wells W-l, W-2, and W-3) at the Del
property, the locations of which are shown on Figure 4. Analysis
of groundwater samples collected from these wells indicated an
elevated level of lead of 20 ug/1 in well W-3. The Phase I study
also included the collection of subsurface soil samples, in which
various organic and inorganic contaminants were detected.
In May 1989, Phase II of the study was initiated to determine
whether groundwater had been impacted by soil contaminants detected
at and in the vicinity of the western leaching pools and, if so,
the extent to which the affected groundwater had migrated. This
phase of the study included the installation of six additional
monitoring wells, namely wells W-4 through W-9 (see Figure 4), and
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the collection of additional soil samples in the vicinity of the
western leaching pools.
As requested by the SCDHS, groundwater samples collected from these
wells were analyzed for cadmium, chromium, lead, and nickel.
Analytical results indicated that concentrations of these
contaminants were below detection limits and/or below NYSDEC and
EPA standards. Therefore, it was concluded that the groundwater
had not been impacted by soil contaminants detected at the western
leaching pools. However, soil data indicated the presence of
contaminated soils in the immediate vicinity of the western
leaching pools. After review of the Phase II results, the SCDHS
requested the installation of two additional monitoring wells, W-10
and W-ll (see Figure 4), on Del's Parcel B property to confirm the
direction of groundwater flow. The SCDHS also requested that
groundwater samples be collected from monitoring wells W-l through
W-ll and analyzed for chromium, only. The analytical results of
these samples indicated that chromium concentrations were below
detection limits.
Although it was concluded, based on the results of the Donnelly
Engineering's study, that soil contaminants detected at the western
leaching pools had not impacted groundwater, the SCDHS required the
excavation of soils containing organic compounds around these
pools. The excavation was conducted from November 11 through
November 20, 1992, under the direction of the SCDHS and the
supervision of Donnelly Engineering and Del. It included the
removal of five concrete holding pools and excavation and off-site
disposal of 1,708 tons of contaminated soil.. Grab samples of
excavated soil were analyzed using the Toxicity Characteristic
Leaching Procedure (TCLP). Sample analytical results were below
detection limits, with the exception of barium, which was detected
at 0.30 milligrams per liter (mg/1). Since the TCLP analytical
results did not exceed EPA Toxicity Characteristic (TC) limits, the
excavated soil was disposed as a nonhazardous waste at an off-site
disposal facility. Liquid waste, which was generated during the
washing of the excavated concrete holding pools, was disposed as
nonhazardous waste at the Bergen Point treatment plant. The
excavation was backfilled with clean fill, compacted, and covered
with 9 inches (256 tons) of crushed stone blend.
HIGHLIGHTS OP COMMUNITY PARTICIPATION
The RI and the Proposed Plan for the third operable unit were
released to the public on July 21, 1993. These documents were made
available in both the administrative record file at the EPA Docket
Room in Region II, New York and two information repositories
maintained at the Babylon Town Hall and the West Babylon Library.
The notice of the public meeting and availability of the above-
referenced documents appeared in This Week publication and Newsday
newspaper on July 31, 1993 and August 3, 1993, respectively. A 30-
6
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day public comment period was held from July 22, 1993 to August 20,
1993.
On August 10, 1993, EPA conducted a public meeting at the W.E.
Howitt Junior High School in Farmingdale, New York, to inform local
officials and interested citizens about the Superfund process,
present the results of the third operable unit RI and EPA's
preferred "No Action" remedy, and respond to any questions from
area residents and other attendees.
EPA did not receive any comments on the RI and the Proposed Plan at
the public meeting, nor were any written comments concerning the
remedy selection received during the public comment period. As a
result, no Responsiveness Summary was prepared. The NYSDEC,
however, expressed a concern about potential groundwater
contamination at private wells downgradient of the Site, which is
outside of the scope of this third operable unit. . Consequently,
EPA is investigating this potential contamination as a separate
matter.
SITE CHARACTERISTICS
Under the terms of the AOC, Geraghty & Miller, Inc. conducted an RI
to characterize potential groundwater contamination in the
upgradient portion of the Site. The intent of the study was to
characterize groundwater quality upgradient from the PPC facility,
specifically underlying Parcel A (see Figure 2) , and determine
whether operations at Del have impacted the groundwater quality at
the Site.
The scope of the RI included the following: (1) installing three
two-well clusters, each containing one shallow and one deep well,
on Parcel A; (2) sampling the six newly installed wells and eight
existing wells at the Del property; and (3) collecting water-level
measurements from the six new wells on Parcel A. and from selected
monitoring wells on Parcel B to determine the direction of the
groundwater flow in the vicinity of the Del property.
The three shallow monitoring wells (MW-12, MW-13, and MW-14) were
drilled to a depth of 25 feet and the three deep monitoring wells
(MW-12D, MW-13D, and MW-14D) were installed to a depth of 50 feet.
Two rounds of groundwater samples were collected and analyzed for
filtered (dissolved) and unfiltered (total) cadmium, chromium,
lead, and nickel. The first round of groundwater sampling was
conducted at the six newly installed wells on Parcel A and eight
existing wells (W-4, W-5, W-6, W-7, W-8, W-9, W-10, and W-ll) on
Parcel B in March/April 1992. The well locations are shown on
Figure 4. The second round of groundwater sampling was conducted
at only the six wells on Parcel A in October 1992. Prior to each
round of sampling, groundwater level measurements were obtained,
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and as a result EPA has confirmed that the direction of the
groundwater flow in the vicinity of the Site is southerly.
Analytical results for groundwater samples collected during the
March/April 1992 sampling event are presented on Figure 7. The
analytical results for the October 1992 groundwater sampling event
are presented on Figure 8.
Groundwater sampling results were compared with the following
Federal and State drinking water standards: EPA's MCLs of 5 ug/1
for cadmium, 100 ug/1 for chromium, and 100 ug/1 for nickel, and
recommended drinking water action level of 15 ug/1 for lead; and
the NYSDEC's groundwater quality standards of 10 ug/1 for cadmium,
50 ug/1 for chromium, and 25 ug/1 for lead. No NYSDEC drinking
water standard is available for nickel.
The first round of groundwater sampling revealed higher levels of
specific contaminants in Parcel B wells than in Parcel A wells.
The maximum total concentration (unfiltered) of cadmium was 3.1
ug/1 which was detected at a well on Parcel B and is below EPA's
and the NYSDEC's drinking water standards (5 ug/1 and 10 ug/1,
respectively). The maximum total concentration of nickel was 91
ug/1 which was detected at a well on Parcel B and is below EPA's
drinking water standard of 100 ug/1. The maximum total
concentration of chromium was 129 ug/1 which was detected at a well
on Parcel B and is above EPA's and the NYSDEC's drinking water
standards (100 ug/1 and 50 ug/1, respectively) . The maximum total
concentration of lead was 117 ug/1 which was detected at a well on
Parcel B and is above EPA's recommended action level and the
NYSDEC's drinking water standard (15 ug/1 and 25 ug/1,
respectively).
Dissolved (filtered) concentrations of cadmium, chromium, and
nickel were reported below the analytical detection limits of 2
ug/1, 3 ug/1, and 7 ug/1, respectively, for these contaminants.
The maximum dissolved concentration of lead was 4.8 ug/1 which was
detected at a well on Parcel B and is well below EPA's action level
of 15 ug/1 and the NYSDEC's drinking water standard of 25 ug/1. As
the dissolved concentrations were relatively low for all metals, it
is possible that the elevated levels of the contaminants in
unfiltered samples correlated to elevated total suspended solids in
the samples and were not representative of the quality of the
groundwater.
The second round of groundwater sampling showed that both
unfiltered and filtered concentrations of cadmium, chromium, lead,
and nickel for most of the samples were found at levels below the
detection limits of 2 ug/1, 3 ug/1, 2 ug/1, and 8 ug/1,
respectively. Only chromium, lead, and nickel were detected at
levels above the detection limits. The maximum concentrations of
chromium, lead, and nickel were detected in an unfiltered sample
and were 12.2 ug/1, 15.1 ug/1, and 8.9 ug/1, respectively. These
8
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concentrations, with the exception of lead, are below EPA's and the
NYSDEC's drinking water standards. The lead concentration of 15.1
ug/1 is virtually equal to EPA's recommended drinking water action
level of 15 ug/1.
The body of data suggest that the excavation of the five concrete
holding pools and associated contaminated soils at Del facility,
which was undertaken at the direction of the SCDHS, remediated the
significant source of contamination at the facility. Further,
based on the groundwater sampling data, no discernible "plume" of
contamination was evident in the vicinity of the Del property. The
few data which exceeded EPA's and the NYSDEC's drinking water
standards in Parcel B were spotty in occurrence, and were found in
unfiltered samples only. These data may be attributable to
leaching of artifact turbidity in the samples. All filtered
samples were below applicable standards. Therefore, EPA has
concluded that operations at Del are not adversely impacting the
groundwater upgradient of the PPC facility.
SUMMARY OF SITE RISKS
Based on the results of the RI, a baseline risk assessment was
conducted to estimate the risks associated with future Site
conditions. The baseline risk assessment estimates the human
health and ecological risk which could result from the
contamination at the Site, if no remedial action were taken. This
information is used to make a determination as to whether
remediation of a site may be required.
As part of the baseline human health risk assessment, the following
four-step process is utilized for assessing site-related human
health risks for a reasonable maximum exposure scenario: Hazard
Identification—identifies the contaminants of concern at the site
based on several factors such as toxicity, frequency of occurrence,
and concentration; Exposure Assessment—estimates the magnitude of
actual and/or potential human exposures, the frequency and duration
of these exposures, and the pathway (e.g, ingesting contaminated
well-water) by which humans are potentially exposed; Toxicity
Assessment—determines the types of adverse health effects
associated with chemical exposures, and the relationship between
magnitude of exposure (dose) and severity of adverse effects
(response); and, Risk Characterization—summarizes and combines
outputs of the exposure and toxicity assessments to provide a
quantitative (e.g., one-in-a-million excess cancer risk) assessment
of site-related risks.
Under current EPA guidelines, the likelihood of carcinogenic
(cancer-causing) and noncarcinogenic effects as a result of
exposure to site chemicals are considered separately. An
assumption is made that carcinogenic toxic effects of the site-
-------
related chemicals would be additive. The same assumption is made
for the noncarcinogens at a site.
The baseline risk assessment began with selecting contaminants of
concern which are representative of conditions in the third
operable unit study area. These contaminants of concern included
cadmium, chromium, lead, and nickel (see Table 1) . All of the
contaminants, with the exception of lead, are noncarcinogenic by
the ingestion route of exposure. Lead is considered by EPA to be
a Group B2 carcinogen (i.e., there is sufficient evidence in
animals and inadequate or no evidence in humans that lead can cause
cancer). As EPA has not currently established quantitative indices
of toxicity for exposure to lead, risks associated with lead in
groundwater were assessed qualitatively in the baseline risk
assessment. The reference doses (RfDs) and EPA's and the NYSDEC's
drinking water standards for the contaminants of concern in the
third operable unit study area groundwater are presented in Table
2. The reference doses for ingestion of cadmium, chromium, and
nickel were obtained from the EPA's Integrated Risk Information
System (IRIS) database.
The baseline risk assessment evaluated the health effects which
could result from exposure to contamination as a result of
ingestion of groundwater upgradient of the PPC facility. The
previous risk assessment for the second operable unit conducted by
EPA for the Site addressed health risks related to groundwater use
by future residents and future workers at the Site. The most
conservative of these scenarios is the future adult residential
scenario. Therefore, the future adult residential scenario was
evaluated for ingestion of contaminants of concern in the
groundwater samples collected and analyzed from the wells
upgradient from the PPC facility.
An exposure assessment was conducted to estimate the magnitude,
frequency, and duration of actual and/or potential exposures to the
chemicals of concern present in groundwater upgradient of the PPC
facility. Reasonable maximum exposure is defined as the highest
exposure that is reasonably expected to occur at the Site for
individual and combined pathways. As stated previously, metals are
the only groundwater contaminants of concern identified in the
groundwater samples obtained from the wells upgradient of the PPC
facility. As dermal exposure to metals in groundwater is expected
to be minimal and there is no pathway for inhalation of metals in
groundwater, only ingestion of contaminants in upgradient
groundwater was considered in this baseline risk assessment.
Potential carcinogenic risks are typically evaluated using the
cancer slope factors (CSFs) developed by EPA for the contaminants
of concern. CSFs have been developed by EPA's Carcinogenic Risk
Assessment Verification Endeavor for estimating excess lifetime
cancer risks associated with exposure to potentially carcinogenic
chemicals. EPA considers excess upper bound individual lifetime
10
-------
cancer risk in the range of 10"* to 10"6 to be acceptable. However,
as explained previously, because cadmium, chromium, and nickel are
considered noncarcinogens by ingestion, and EPA has not currently
established quantitative indices of toxicity for exposure to lead,
which is a Group B2 carcinogen, no quantifiable carcinogenic risk
estimates have been made in the baseline risk assessment. Instead,
potential health risks associated with lead in groundwater were
assessed qualitatively in the baseline risk assessment.
The baseline risk assessment suggests that lead may present a
hazard to potential future residents using unfiltered groundwater
for potable purposes. While a highly conservative assessment of
groundwater use by potential future residents suggests that
exposure to lead in groundwater may be of concern, the detected
concentrations of lead in the unfiltered samples may be a result of
turbidity, and the series of events required to realize the risks
are extremely unlikely. There are currently no residences between
the Del and PPC facilities. Even if the few data which exceeded
EPA's recommended action level and the NYSDEC's drinking water
standard for lead are not attributable to artifact turbidity, any
low-level contamination would be expected to migrate to the
groundwater extraction system to be constructed for the first
operable unit.
To assess the overall noncarcinogenic effects posed by more than
one contaminant, EPA has developed the Hazard Quotient (HQ) and
Hazard Index (HI). The HQ is the ratio of the chronic daily intake
for a contaminant to the reference dose for that chemical; the
reference dose is a measure of the chemical's "threshold" for
adverse effects with many built-in safety factors. The HQs are
summed for all contaminants within an exposure pathway (e.g.,
groundwater ingestion) to give the HI. When the HI exceeds one,
there may be concern for potential noncarcinogenic health effects,
if the contaminants in question are believed to cause a similar
toxic effect.
The HQs for exposures to individual contaminants of concern in
groundwater and the His for the combined exposure are presented in
Table 3. The His for the combined exposures to groundwater
contaminants of concern upgradient of the PPC Site are 0.18 for
unfiltered samples and 0.14 for filtered samples. These His are
well below one, suggesting that even under the most conservative
exposure scenario, upgradient groundwater contaminated with
cadmium, chromium, and nickel is highly unlikely to be associated
with any adverse health effects.
The ecological risk assessment considered potential exposure routes
of Site contamination to terrestrial wildlife. Since the majority
of the PPC facility is paved or covered by structures, there is
little, if any, potential for wildlife to be exposed to
contaminated subsurface soils on-site. The only potential route of
11
-------
exposure to wildlife in the Site vicinity is by contaminant
transport through groundwater and discharge via groundwater into
surface waters, particularly Great South Bay. The potential
effects of contaminated groundwater on aquatic life were discussed
in the ecological risk assessment performed as part of the initial
RI completed in 1989, in which it was determined that no
significant effect on aquatic organisms in the Great South Bay or
creeks in the vicinity of the Site could be attributed to
groundwater discharge from the Site.
Uncertainties
The procedures and inputs used to assess risks in this evaluation,
as in all such assessments, are subject to a wide variety of
uncertainties. In general, the main sources of uncertainty
include:
• environmental chemistry sampling and analysis
• environmental parameter measurement
• exposure parameter estimation
• toxicological data.
Uncertainty in environmental sampling arises in part from the
potentially uneven distribution of chemicals in the media sampled.
Consequently, there is significant uncertainty as to the actual
levels present. Environmental chemistry-analysis error can stem
from several sources including the errors inherent in the
analytical methods and characteristics of the matrix being sampled.
Uncertainties in the exposure assessment are related to estimates
of how often an individual would actually come in contact with the
chemicals of concern, the period of time over which such exposure
would occur, and in the models used to estimate the concentrations
of the chemicals of concern at the point of exposure.
Uncertainties in toxicological data occur in extrapolating both
from animals to humans and from high to low doses of exposure, as
well as from the difficulties in assessing the toxicity of a
mixture of chemicals. These uncertainties are addressed by making
conservative assumptions concerning risk and exposure parameters
throughout the assessment. As a result, the Risk Assessment
provides upper-bound estimates of the risks to populations near the
site, and is highly unlikely to underestimate actual risks related
to the site.
DESCRIPTION OF THE "NO ACTION" REMEDY
The risk assessment indicates that the levels of cadmium, chromium,
and nickel contaminants present in the groundwater in the
upgradient portion of the Site present risks which fall within or
12
-------
below EPA's allowable risk range. In addition, groundwater
sampling results indicate that, with the exception of a few
excursions for lead in the groundwater above EPA's recommended
drinking water action level and the NYSDEC's groundwater quality
standard, lead data do not exceed these standards in the
groundwater. Further, previous cleanup activities, which included
excavation of the five concrete holding pools and associated
contaminated soils, conducted at the Del facility have remediated
the significant source of contamination previously present at that
facility.
Based upon the findings of the third operable unit RI, EPA, in
consultation with NYSDEC, has determined that the groundwater in
the upgradient portion of the Site does not pose a significant
threat to human health or the environment. EPA, therefore, has
selected a "No Action" remedy for the third operable unit of the
Site. Because this "No Action" remedy will not result in hazardous
substances remaining on-site above health-based levels, the five-
year review will not apply to this action.
DOCUMENTATION OF SIGNIFICANT CHANGES
There are no significant changes from the preferred alternative, as
presented in the Proposed Plan.
13
-------
APPENDIX I
FIGURES
-------
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FIGURE 3
-------
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FIGURE
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FIGURE
8
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APPENDIX II
TABLES
-------
Table 1
Preferred Plating Operable Unit III
Summary of Groundwater Contaminant of Concern Concentrations
COMPOUND
CADMIUM
(TOTAL)
CADMIUM
(DISSOLVED)
CHROMIUM (TOTAL)
CHROMIUM
(DISSOLVED)
LEAD
(TOTAL)
LEAD
(DISSOLVED)
NICKEL
(TOTAL)
NICKEL
(DISSOLVED)
MEDIUM
GROUNDWATER
(UNFILTERED)
GROUNDWATER
(FILTERED)
GROUNDWATER
(UNFILTERED)
GROUNDWATER
(FILTERED)
GROUNDWATER
(UNFILTERED)
GROUNDWATER
(FILTERED)
GROUNDWATER
(UNFILTERED)
GROUNDWATER
(FILTERED)
FREQ. OF
DETECTION
7/25
0/25
16/25
0/25
23/24
7/24
13/25
0/25
MEAN CONC.
(UG/L)
2.2
<2
27.9
<3
25.9
1.6
23.1
<8
95% UCL*
(UG/L)
2.3
<2
68
<3
90.5
1.9
34.2
<8
MAX. CONC.
(UG/L)
3.1
<2
129
<3
117
4.8
91
<8
UCL - Upper ConMtne* Uirtt
-------
Table 2
Preferred Plating Operable Unit III
Indices of Toxicity and Drinking Water Standards for Groundwater Contaminants
of Concern
COMPOUND
CADMIUM
CHROMIUM
LEAD
NICKEL
REFERENCE DOSE
(Mg/Kg/d)
5X10" (I)
10)
NA
2X10* (I)
FEDERAL MCL
(ug/i)
5
100
15'
100
STATE GROUNDWATER
QUALITY STANDARDS
10
50
25
NA
Notes:
0) Toxletty Data from Ms Database
(NA) Data are not Available
(NC) Compound Is a Noncardnogen by the mgcstion Route
• • 15 ug/l Is uSEPA's Recommended Drinking water Action Level tor Lead
-------
Table 3
Preferred Plating Operable Unit III
Hazard Indices for Exposures to Contaminants In Groundwater
COMPOUND
CADMIUM
CHROMIUM
LEAD
NICKEL
TOTAL (HAZARD INDEX)*
HAZARD QUOTIENT
(UNF1LTERED)
0.13
0.0019
NAt
0.05
0.18
HAZARD QUOTIENT
(FILTERED)
0.13
0.0009
NA
0.012
0.14
(HA) Quantitative Toxfctty Data are not AvaUaMe for Lead
r - tead exceeds me groundwater action level of 15 ppb m several untmered samples.
"•• Agortthm for determination of me hazard Index associated with residential Ingestlen of groundwater upgraOent of the Preferred Platmg s^
GWC • IR • ED * EF • IQ^mq/ud
BW • AT • 365 d/yr • RfD
wnere.
AT
BW
ED
EF
RfD
GWC
Avwagmg Thn*
Exposufv Duration
Exposure Frequency
Reference Dow
Consmutrt Cone, m GroonOwaltf (ug/l)
DrtnMng water MgesUon (I/a)
Body welgnt. Adutt (kg)
Exposure frequency (d/y)
Exposure duration (y):
Averagttig ttrne (y):
Standard Default Exposure Assumptions for
Ingestton of Groundwater by Residents
2
70
350
30
30
-------
APPENDIX IV
STATE LETTER OF CONCURRENCE
-------
New York State Department of Environmental Conservation
50 Wolf Road, Albany, New York 12233 7010
Thomas C. Joriing
Commissioner
SEP 2 2 1993
Mr. George Pavlou
Acting Director
Emergency and Remedial Response Division
U.S. Environmental Protection Agency
Region II
26 Federal Plaza
New York. NY 10278
Re: Preferred Plating Corporation OU 3 ID No. 1 52030
Dear Mr. Pavlou:
The New York State Department of Environmental Conservation and New York
State Department of Health have reviewed the draft revised Record of Decision for
Operable Unit 3 of the Preferred Plating Corporation site and concur with the No Action
Plan.
If you have any questions, please contact Kamal Gupta, of my staff, at
(518) 457-3976.
Sincerely,
Ann DeBarpieri
Deputy Commissioner
cc: A. Carlson, NYSDOH
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