United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R02-84/008
June 1984
&ER&
Superfund
Record of Decision:
PAS Oswego Site, NY
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TECHNICAL REPORT DATA
(Please read Instructions on the reverse before completing)
1. REPORT NO. 2.
EPA/ROD/R02-84/008
4. TITLE AND SUBTITLE
SUPERFUND RECORD OF DECISION:
PAS Oswego site, NY
7. AUTHOR(S)
9. PERFORMING ORGANIZATION NAME AND ADDRESS
SPONSORING AGENCY NAME AND ADDRESS
..S. Environmental Protection Agency
91 M Street, S.W.
ashington, D.C. 20460
3. RECIPIENT'S ACCESSION NO.
5. REPORT DATE A
06/06/84 I
6. PERFORMING ORGANIZATION CODE
8. PERFORMING ORGANIZATION REPORT
.
NO.
10. PROGRAM ELEMENT NO.
1 1 . CONTRACT/GRANT NO.
13. TYPE OF REPORT AND PERIOD COVERED
Final ROD Report
14. SPONSORING AGENCY CODE
800/00
SUPPLEMENTARY NOTES
ABSTRACT
The Pollution Abatement Services (PAS) site, which is located in the City of
5wego, NY, was used as a chemical waste storage and processing facility. The
ite is bounded on the east, north,and west by wetlands from two stream channels.
ust to the north of PAS the two streams converge and flow into Lake Ontario. The
oil and ground water are contaminated with waste acids and alkalis, PCB-contami-
ated solids and liquids, halogenated organics, organic resins, and heavy metal-
aden wastewater.
The cost-effective remedial alternative includes: limited excavation and
emoval of contaminated soil, subsurface tanks,and drums to a RCRA approved landfill;
onstruction of a perimeter slurry wall; site grading and capping in accordance
'ith RCRA Part 264; ground water recovery; leachate collection; on-site ground
ater and leachate treatment; and ground water monitoring in accordance with RCRA
'art 264. The capital cost for the selected alternative is $1,363,700 and the
mnual O&M cost is $117,000.
Key Words: Environmental Impacts, Ground Water Contamination, No Action
Alternative, Wetlands, Section 404 Clean Water Act, Wetlands
Regulations, Slurry Wall Design, O&M Expense, Operable Unit, Ground
Water Monitoring, RCRA Regulations
KEY WORDS AND DOCUMENT ANALYSIS
DESCRIPTORS
Record of Decision
PAS Oswego, NY
Contaminated media: gw,. soil, rivers sedi-
ment
Key contaminants: acids, halogenated or-
ganics, resins, VOCs, alkalides,
18. DISTRIBUTION STATEMENT
b.lDENTIFIERS/OPEN ENDED TERMS
19. SECURITY CLASS (This Report!
None
20. SECURITY CLASS (This page)
None
c. COSATI Field/Group
- :
36 J
22. PRICE 1
EPA Form 2220-1 (R«v. 4-77) PREVIOUS EDITION is OBSOLETE
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ROD ISSUES ABSTRACT
Site; Pollution Abatement Services (PAS),
Oswego, New York
Region; II
AA, OSWER
Briefing Date; May 24, 1984
SITE DESCRIPTION
The Pollution Abatement Services (PAS) site, which is located in
the City of Oswego, New York, was used as a chemical waste storage and
processing facility. The site is bounded on the east, north and west
by wetlands from two stream channels. Just to the north of PAS the two
streams converge and flow into Lake Ontario. The soil and ground w .ter
are contaminated with waste acids and alkalis, PCB-contaminated sol ds
and liquids, halogenated organics, organic resins, and heavy metal-
laden wastewater.
SELECTED ALTERNATIVE
The cost-effective remedial alternative includes: limited excava-
tion and removal of contaminated soil, subsurface tanks and drums to a
RCRA approved landfill; construction of a perimeter slurry wall; sitr»
grading and capping in accordance with RCRA Part 264; ground water . e-
covery; leachate collection; on-site ground water and leachate tree -
ment; and ground vater monitoring in accordance with RCRA Part 264.
The capital cost for the selected alternative is $1,363,700 and tht
annual O&M cost is $117,100.
ISSUES AND RESOLUTIONS KEY WORDS
1. The no action alternative was eliminated froc . Environmental
consideration based on environmental concerns. Impacts
The results of the RI/FS indicate that there . Ground Water
is potential for contaminated ground water Contamination
to migrate off-site via unrecognized ground . No Action
water outlets. Also, the data from the study Alternative
shows that the wetlands surrounding the site . Wetlands
have become biologically stressed.
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Pollution Abatement Services (PAS)
May 24, 1984
Continued
ISSUES AND RESOLUTIONS
The wetlands adjacent to and downstream from
the PAS site have been tentatively designated
as a regulated wetland, pursuant to the New
York State Environmental Conservation Law.
These wetlands also meet the criteria for a
Class I wetland area under Section 404 of the
Clean Water Act. Remedial activities at the
site will require compliance with the sub-
stantive requirements of applicable wetlands
regulations.
The depth of the slurry wall must be deep
enough to intercept any unrecognized ground
water outlets from the stratified sediment de-
pression. The final depth of the slurry wall
will be determined by test borings during the
design phase. The outcome of the test borings
will determine if the walls should be anchored
into the strata above bedrock (lodgement till)
or extended into bedrock.
The contaminated ground water collection
end treatment system is a remedial action
operable unit (i.e. paid for 90% fund,
10% state) since the contamination was still
on-site and was estimated to take less than
2 years for cleanup to background. Whereas
leachate collection and treatment is an opera-
tion and maintenance expense since it may re-
quire long-term activities.
The cap and ground water monitoring program
are consistent with RCRA requirements. Wells
will be installed to monitor the bedrock
aquifer.
KEY WORDS
Section 404
Clean Water Act
. Wetlands
Regulations
Slurry Wall Desig:
O&M Expense
Operable Ur.;.
Ground Water
Monitoring
RCRA Regulations
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RECORD OF DECISION
REMEDIAL ALTERNATIVE SELECTION
Site: Pollution Abatement Services, Inc. (PAS)
Oswego, New York
Documents Reviewed
I have reviewed the following documents describing the
analysis of cost-effectiveness of remedial alternatives for PAS.
PAS Remedial Investigation/Feasibility Study prepared by
URS for the NYSDEC, January 1984
Summary of Remedial Alternative Selection
- Responsiveness Summary prepared by the NYSDEC, May 1984
Description of Selected Remedy
Limited excavation and removal of contaminated soil,
subsurface tanks and drums to a RCRA approved landfill
Construction of a perimeter slurry wall to lodgement till
or bedrock, if necessary
Site grading followed by installation of an impermeable
cap in accordance with RCRA Part 264
Ground water recovery
Leachate collection
On-site ground water and leachate treatment
Ground water monitoring in accordance with RCRA Part 264
Declarations
Consistent with the Comprehensive Environmental Response
Compensation, and Liability Act of 1980 (CERCLA), and the National
Contingency Plan (40 CFR Part 300), I have determined that the
combined remedial measures designed to contain contaminants
on-site, reduce the quantity of ground water on-site becoming
contaminated, and the removal of gross contamination from PAS,
is the lowest cost remedy which provides adequate protection of
public health, welfare, and the environment. The State of New
York has been consulted and agrees with the approved remedy.
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I have also determined that the action being taken is
appropriate when balanced against the availability of Trust Fund
monies for use at other sites. In addition, the off-site transport.
and secure disposition is more cost-effective than other remedial
actions, and is necessary to protect public health, welfare, or
the environment.
- *_
Lee M. Thomas, Assistant Administrator
Office of Solid Waste and Emergency Response
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SUMMARY OF REMEDIAL ALTERNATIVE SELECTION
PAS, Oswego, New York
SITE DESCRIPTION (See Figure 1)
PAS, a fifteen (15) acre site located in City of Oswego,
Oswego County, New York, was formerly used as a chemical waste
storage and processing facility. The site is bounded on the
east, north and west by wetlands formed along the stream channels
of White and Wine Creeks. These streams originate and flow
through farmland to the south, flowing adjacent to the Oswego
County Landfill before passing PAS. Just to the north of PAS,
the two streams converge and flow into Lake Ontario approximately
1800 feet to the north. The point at which this tributary enters
Lake Ontario is approximately one mile from the City of Oswego
drinking water intake.
Properties adjacent to the site include a residence to the
north, a union hall to the east, a solid waste transfer station
(Oswego County Landfill) to the south, and a radio station to
the west. The area north of the site is primarily undeveloped
fields and woodlots. There are several residences on Mitchell
Street approximately 1/3 mile north of the site and a residential
community, Smith's Beach, consisting of twentyfive (25) dwellings
approximately 1/2 mile north of PAS. A public water supply is
available to Smith's Beach; however, several residents have
opted to continue using private wells.
The area in which PAS is located is characterized by an
abundance of surface water. Most of the site, including almost
all of the formerly active area of the site, drains directly to
White Creek through an on-site drainage ditch which flows north-
ward through the center of the property.
Six (6) stratigraphic units have been defined at PAS. A
surficial fill layer of variable depth and composition covers
most of the site. This fill material consists largely of demo-
lition debris probably brought to the site before PAS was in
operation. The fill layer is underlain by ablation till over
most of the site. Exceptions to this occur in a small area near
the center of the site and near White Creek, where the fill is
underlain by stratified sediments. Underlying the ablation till
and stratified sediments is a lodgement till layer forms a
continuous barrier of relatively low permeability between the
upper formations and the bedrock beneath. The depth of lodgement
till is apparently 10 feet. Significant exceptions to this occur
in the central section of the site and near White Creek, where
the occurrence of stratified sediments corresponds with a
depression in the lodgement till surface. Typical permeabilities
for the ablation till, lodgement till, and bedrock are 1 x 10-4
cm/sec, 5 x 10-5cm/sec, and 3 x 10-5 cm/sec, respectively.
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Two aspects of site stratigraphy which are of particular
importance are the apparently continuous layer of lodgement
till overlying the bedrock, and the occurrence of a significant
depression containing stratified sediment near the center of
the site. The bedrock in this area is primarily sandstone and
is slightly to moderately fractured.
Subsurface data and information obtained during the remedial
investigation support the occurrence of a continuous, dense
lodgement till layer overlying the bedrock across the site.
However, some questions exist regarding the integrity and actual
permeability of this layer because of evidence of ground water
contamination in one of the monitoring wells which is in hydraulic
contact with the bedrock. It is felt, however, that the contam-
ination detected was the result of faulty drilling practices and
that the till layer not only provides an adequate bottom confining
layer but also deters contaminant flow from migrating into the
bedrock.
The occurrence of stratified sediment at relatively great
depths in the central section of the site reflect a depression
in that area. Surface geophysical data suggests that this
depression, which has been tentatively identified as a glacial
kettle basin, is relatively small and localized, with a maximum
depth of approximately 45 feet. It is recognized, however, that
the lack of confirming borings and the potential effect of
contaminants on geophysical data preclude firm conclusions
regarding the nature and geometry of this geologic structure.
The possiblity of a ground water outlet from the formation
cannot be eliminated. Two ground water monitoring wells located
within this formation are highly contaminated.
Investigation of the ground water indicated that there are
two (2) ground water flow systems beneath the site. The upper,
unconfined flow system, which extends down to the lodgement
till, has a water table configuration closely reflecting the
surface topography. The water table gradient in this system
ranges from 0.02 to 0.13, and slopes generally northward toward
Lake Ontario. The lower flow system is in the bedrock, the
piezometric surface of which is lower than that of the overburden
water table. This system also flows northward. Consideration
of the water table configuration and stratigraphy of the site
leads to the conclusion that White and Wine Creeks are effluent
in nature, and intercept ground water flow through the surficial
soils beneath PAS.
Four (4) drained, subsurface storage tanks, which formerly
contained waste (including PCBs) remain on-site. Heavily
contaminated soils, and black oily leachate in the vicinity of
the tanks, indicate that the tanks may be a continuing source of
contamination.
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SITE HISTORY
In the early 1900's a concrete dam, which is still partially
intact near the northwest property corner, was used to pond water
for a private ice mill. Later, Oswego County assumed ownership
of the property in lieu of unpaid taxes. During the late 1950*s,
rubble and demolition debris were disposed of on the site. In
the late 1960's the site was given by the Port Authority/Oswego
County to a group of local businessmen for the construction of a
high temperature, liquid chemical waste incinerator facility.
This facility, known as Pollution Abatement Services, Inc.(PAS),
was constructed and became operational in 1969-1970. Throughout
its active life, PAS experienced continuous operating problems,
numerous air and water quality violations, and mounting public
opposition. During its operating period from 1970 through 1977,
a large number of drums containing various chemical wastes were
collected and stored onsite. Tankloads of liquid waste were also
received and stored in onsite lagoons. Beginning in 1973, a
series of incidents, which included liquid waste spills and
overflowing of lagoon waste into the adjacent White Creek, led
to the involvement of the United States Environmental Protection
Agency (EPA), and the New York State Department of Environmental
Conservation (NYSDEC). This involvement included a number of
limited and temporary remedial actions during the period from
1973 until 1976.
In December 1976, EPA constructed a dike to prevent overflow
of one of the lagoons. In 1977, PAS was abandoned. In August
1977, EPA utilized the Federal Pollution Control Revolving Fund
covered by Section 311 of the Clean Water Act for cleanup activitie.
at PAS. These activities included:
0 The treatment and disposal of all liquids in the lagoons.
0 The closing, capping, and/or grading of all lagoons.
0 The installation of a leachate filter system.
0 The drainage and disposal of the liquid in two above-ground
storage tanks.
0 The drainage of one underground tank.
0 The overpacking of deteriorating 55-gallon drums.
In November 1978, the DEC entered into a contract with SCA
Chemical Waste Services (SCA) to characterize the approximately
14,000 drums on-site.
From May to August 1980, SCA, under a contract with NYSDEC,
removed approximately 2,600 drums. During this period, samples
were collected from two bulk storage tanks. Analytical results
indicated concentrations of 754 ppm and 22 ppm of PCB-1248.
In the winter of 1980, liquid wastes were emptied from two
large vertical storage tanks and disposed of off-site.
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In 1980, the U.S. Geological Study installed nine (9) on-site
monitoring wells.
In the summer of 1981, PAS was selected as one of the first
sites in the nation to receive CERCLA Trust Fund monies to conduct
cleanup actions. An immediate removal action was initiated
whit:h resulted in the repacking of 503 leaking drums, and the
lining of a seep pit to control leachate. The removal action
was deactivated in September of 1981 when it was realized that
the tasks specified would greatly exceed available funds.
In September of 1981, EPA's contractor, Camp, Dresser &
McKee, prepared plans and specifications for surficial cleanup
of the site.
On March 12, 1982, a Cooperative Agreement covering the
surficial cleanup and subsurface investigation was awarded by
EPA to DEC.
In June of 1982, DEC hired SCA to perform the surficial
cleanup of PAS, which included the demolition and disposal of
on-site facilities, the removal of the remaining on-site drums,
and the drainage and disposal of approximately 80,000 gallons
of liquid chemical waste from ten (10) bulk storage tanks. This
:ask was completed in November of 1982. In November of 1982,
JRS Company was selected to perform a complete site investigation,
characterize remaining contamination, and recommend remedial
actions at the site. A Remedial Investigation/Feasibility Study
was submitted in final form to DEC and EPA in January 1984.
CURRENT SITE STATUS
The types and quantities of wastes recovered and disposed
of during surficial cleanup activities completed at the site
during 1982 are summarized in Table 1. As indicated, these
wastes included waste acids and alkalis, PCB-contaminated solids
and liquids, halogenated prganics, organic resins, and heavy
metal-laden wastewater. Many of these compounds are toxic and
carcinogenic.
Based upon chemical analytical data generated during the
remedial investigation, contamination at PAS has been characterized
as follows:
0 Soil contamination is significant, widespread and non-
uniform across the site, suggesting multiple on-site
sources of contamination. Analytical data, summarized
in Table 2, indicates the presence of a wide range of
organic and inorganic priority pollutants. PCBs were
detected in eleven (11) of the twelve (12) soil samples.
The two highest concentrations of PCB1248, 22,000 and
9,000 ppb, were obtained from samples collected near
four subsurface tanks. Black, oily leachate has also
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been observed in this vicinity, suggesting that the
tanks are a continuing source of PCB contamination.
Interpretation of soil screening data revealed that
soil contamination generally decreased with
increasing depth, with 85% of all positive Volatile
Organic Carbon (VOC) and 100% of all PCBs appearing
in the upper ten (10) feet of soil. A depression,
approximately 45 feet in depth, located in the
central area of the site, has been found to contain
contaminated stratified sediments.
Ground water beneath the PAS site has been contami-
nated with a wide variety of priority pollutants
which are summarized in Table 3. The pattern of
ground water contamination, is widespread across
the site. Two (2) wells located near a former
lagoon location, and within the stratified sediment
depression area, are contaminated. Examination of
data generated from two (2) corresponding ground
water monitoring wells located on opposite sides of
White Creek indicate that the well on the PAS side
is contaminated, while the well on the opposite side
is not, implying that the stream is intercepting
contaminated ground water.
Chemical analytical results obtained from surface
water and sediment samples, and summarized in Table
4, indicate high levels of contamination in the two
on-site drainage ditches, but relatively low and non-
persistent effects upon down-gradient water quality
due to bonding of the contaminants to soil particles.
However, the impact of the site upon down-gradient
water quality may have been obscured by the short
winter sampling period, and by the filtering effect
of the wetlands. The actual impact of the site on
the adjacent stream system may be more accurately
represented by a biological survey of the stream
system which was conducted in May of 1983. Upstream
samples collected from White and Wine Creeks indicated
that both streams were moderately stressed, but within
normal limits for streams of their size receiving
agricultural run-off. Samples collected adjacent
to and down stream from the site, however, indicated
that the streams were severely stressed with the more
pollution-sensitive species missing or greatly reduced
i n numbe r.
The physical characteristics of the PAS site indicate
that surface water, particularly White Creek, is the
most likely pathway for contaminant migration from the
site. Contaminated ground water flowing through the
shallow ground water system under PAS appears to be
intercepted by White Creek. Information to date
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indicates that the upper ground water system is
separated from the bedrock system by a continuous
lodgement till layer, that is assumed at this time
to be impermeable. A relatively deep, stratified
depression has been identified and is assumed to be
completely contained within the site. However,
uncertainties exist regarding the geology of this
formation. This inadequately defined depression may
have one or more subsurface outlets which could
facilitate migration of contaminated ground water from
the depression, beneath White Creek, and into adjacent
drinking water sources.
The most obviously affected receptors of contamination
from PAS are White and Wine Creeks and the adjacent
wetlands. As stated previously, both streams appear
to be within a normal stress range upstream of the
site, but display evidence of severe stress adjacent
to, and downstream from the site. Both streams are used
by a wide variety of wildlife, including avian and fish
species, the latter of which utilizes the streams for
spawning. The lower reach of Wine Creek, near Lake
Ontario, is used for seasonal recreational fishing.
Wildlife, in addition to being adversely affected by
contaminants, may act as vectors for off-site contam-
inant migration and may introduce contaminants into
the food chain.
Contaminated surface water runs off the site onto the
adjacent radio station property, facilitating direct
human exposure to contaminants.
Enforcement
Potentially responsible parties have been identified from
PAS invoices and financial records.
Two meetings have been held among EPA and all interested
PRP's. The PRP's have formed a steering committee to represent
those interested PRP's in negotiations, and a technical steering
committee to review all technical documents. The steering committee
met with EPA on March 28, 1984, in New York to discuss a possible
settlement. As of this date, no settlement has been reached.
It is EPA's intention to negotiate with the potentially
responsible parties if a settlement offer is forthcoming. If
these negotiations are fruitless, or if it appears that the
PRP's are not negotiating in good faith, then EPA is prepared to
file a cost recovery action in Federal Court. In the case of a
settlement agreement with the PRP's", an Administrative Order or
Judicial Order would formalize or actualize the agreement.
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ALTERNATIVES EVALUATION
The major objective of the feasibility study was to evaluate
remedial alternatives using a cost-effective approach consistent
with the goals and objectives of CERCLA. A cost-effective remedial
alternative is defined in the National Contingency Plan (NCP)
(40 CFR 300.68J) as "the lowest cost alternative that is techno-
logically feasible and reliable and which^effectively mitigates
and minimizes damage to and provides adequate protection of
public health, welfare, or the environment." The NCP outlines
procedures and criteria to be used in selecting the most cost-
effective alternative.
The first step is to evaluate public health and environmental
effects and welfare concerns associated with the problem.
Criteria to be considered are outlined in Section 300.68(e) of
the NCP and include such factors as actual or potential direct
contact with hazardous material, degree of contamination of
drinking water, and extent of isolation and/or migration of the
contaminant.
The next step is to develop a limited list of possible
remedial actions which could be used. The no-action alternative
must be included on the list.
The third step in the process is to provide an initial
screening of remaining alternatives. The costs, possible
adverse effects, relative effectiveness in minimizing threats,
and reliability of the methods are reviewed here.
The no-action alternative was evaluated for PAS; however,
based on the following assessment, it was eliminated from further
consideration.
The results of the RI/FS indicate that there is significant
contamination at PAS. Specifically, the ground water and soil
beneath the site are contaminated, as is surface water on-site.
Findings of a biological stream survey conducted in May 1983,
indicate that the adjacent stream system has been adversely
affected by the PAS site. Hydrogeological investigation of the
sediments to approximately 45 feet in depth, exists near the
center of the site. The exact geometry of this formation has
not been conclusively defined, therefore, the possibility of
subsurface ground water outlets can not be eliminated.
Two major concerns which have been identified at PAS are the
potential for contaminated ground water to migrate from the site,
and the adverse effect that PAS appears to be exerting on the
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adjacent stream system. The first concern contaminated ground
water migration, is primarily a public health concern. There
is a potential for contaminated ground water to migrate from the
site, via presently unrecognized ground water outlets from the
stratified sediment depression and into private drinking water
sources to the north of the site. The concentrations of several
of the contaminants identified in the ground water beneath PAS
exceed Primary Drinking Water Standards according to the Safe
Drinking Water Act of 1977 (see Table #3). In addition, most
of the organic compounds detected in the ground water exceed the
New York State Department of Health 50 ppb guideline for single
organic compounds found in water used for human consumption.
The second concern, the impact of PAS on the adjacent stream
system, is both a public health and environmental issue. The
stream system, although biologically stressed, is used by a wide
variety of wildlife including avian species. The streams are
spawning grounds for certain fish species, and are used for
recreational fishing. Human consumption of fish taken from these
streams can introduce contaminants into the food chain.
Based upon the results of the RI/FS, the impact of PAS on
the adjacent surficial environment, and the potential for the
contamination of drinking water sources, it was determined that
measures should be taken to remove and/or isolate contaminants
on site. Conceptually, this included the removal of any remaining
sources of contamination, reduction of the quantity of ground
water becoming contaminated, and the isolation of the site from
the surrounding environment.
To address these objectives, on-site remedial options were
categorized into three (3) broad scenarios that included, excavation
and removal, on-site treatment, and site containment.
Complete site excavation was evaluated and associated costs
were calculated. The cost for excavation, transport, and disposal
of approximately 230,000 cubic yards of contaminated soil in a
secure landfill, has been estimated to be $75 million. While the
implementation of this alternative would provide the most effective
and complete removal of contaminants from the PAS site, the asso-
ciated expenditures were prohibitive. Since an alternative was
available that would be effective in providing adequate protection
to the public and the environment, the complete excavation option
was eliminated.
Although, complete excavation was found to be not cost-
effective, some removal of visible surface soil contamination,
subsurface drums and tanks was considered, and deemed consistent
with previous remediation on-site.
An array of options was then assembled that combined aspects
of both source containment as well as on-site collection and
treatment of contaminated waters.
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Alternatives considered either technically unreliable or
infeasible as well as too costly were excluded.
Six (6) remedial alternatives resulted and were individually
analyzed to determine the degree to which each provided adequate
protection of human health, welfare, and the environment. As
indicated in Table 6, each of the six remedial alternatives
includes limited excavation arid removal as discussed previously.
The development of the alternatives resulted from the combination
of various remedial components that are summarized below:
0 Limited excavation and removal of the visible contam-
ination has been discussed and deemed feasible. An
option to this recommendation (consistent with current
RCRA requirements) would be to provide a secure disposal
area on-site. This would require the installation of
a impermeable bottom liner as well as an impermeable
cap to enclose the excavated material. In addition,
future monitoring of this facility would be mandatory.
This alternate scheme was considered completely
impractical. Associated costs would greatly exceed
the $300,000 estimated for limited excavation and
removal.
0 Grading and capping of the site. The purpose of grading
the site is to channel surface leachate into the proposed
leachate collection system, and discourage off-site
surface water run-off. Capping the site would reduce
the amount of rain water infiltration into the site,
which would reduce the amount of ground water becoming
contaminated. Capping in conjunction with other
measures, would lower the ground water table beneath
the site. Lowering the ground water table is important
because the data from the RI/FS indicates that soil
contamination decreases with increasing depth. Therefore,
lowering the ground water table would reduce the amount
of ground water coming in contact with contaminated soil.
0 Stream diversion of White Creek. In this remedial
measure, White Creek would be intercepted south of the
site, and diverted, through a conduit, into Wine Creek.
This would eliminate substantial stream flow through
the center of the site, thereby reducing the amount of
surface water becoming contaminated. With proper
construction (discussed in the RI/FS) the diversion
trench would intercept shallow northward flowing ground
water, before it reached the site. This, in conjunction
with other measures, would lower the ground water
beneath the site. Stream diversion, however, would not
prevent ground water migration from the site.
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Construction of a perimeter slurry wall would divert
ground water flow away from PAS, consequently lowering
the ground water table beneath the site, and would
isolate ground water contaminants onsite. The depth
of the slurry wall will be deep enough to intercept
any unrecognized ground water outlets from the strat-
ified sediment depression, should any exist. The
stratum (lodgement till or bedrock) into which the
wall should be anchored would depend upon the outcome
of test borings.
Leachate collection from the existing central drainage
ditch, and from the north and northeast boundaries of
the site, would reduce the amount of leachate entering
into the stream system, and onto adjacent properties.
A pump and treat system to remove contaminated ground
water from beneath the site. Of particular concern is
the contaminated ground water in the stratified sediment
depression.
Based upon a conceptual model of this formation devel-
oped by the RI/FS consultant, the volume of ground
water in it has been estimated to be one million gallons.
It has been estimated that the removal of one volume
(1 million gallons) of ground water will remove the
majority of contamination from this area. One year
is the estimated time required to remove this amount
of ground water. This recovery process will continue
until background levels are attained in the ground
water beneath the site or until contaminant levels
stabilize over the course of a complete volume. Under
the latter scenario, an evaluation will be made by EPA
and the State to determine the need for further treat-
ment or closure in accordance with RCRA.
Collection of the leachate and contaminated ground
water require that provisions be made for ultimate
disposal of these materials. Two general methods
were considered in the RI/FS: off-site disposal and
on-site treatment. The cost for off-site disposal is
highly dependent upon the quality of leachate being
handled. Based upon the analytical data from surface
water in the two on-site drainage ditches and ground
water in the monitoring wells, an average unit price
for off-site disposal is estimated to be approximately
$1.30/ gallon, including transportation to, and treat-
ment at a permitted hazardous waste disposal facility.
Evaluation of the same data indicates that on-site
treatment of leachate is feasible at PAS. The cost
for on-site treatment was estimated in the RI/FS to
$0.26/gallon. This figure was based upon the following
assumptions:
-------
-11-
The treatment mode is intermittent, utilizing the
existing (retrofitted), 24,000-gallon wash water
holding tank for flow equalization and retention.
Treatment is provided whenever the 24,000-gallon wash
water holding tank becomes full. During the first
year, when leachate is being collected at a rate of
0.25 million gallons per year (MG/YR) and ground water
is being recovered at a rate of 1.0 MG/YR, treatment
will.be required, on the average, once per 7 days.
During the succeeding 4 years, when only leachate is
being collected, treatment will be required only once
per 35 days, or 5 weeks.
Flow through the plant is set at 50 gallons per minute;
the plant operating cycle is, therefore, 8 hours. An
additional labor allowance of 4 hours per operating
cycle is provided for start-up, shut-down and maintenance
operations.
The precipitation/sedimentation/filtration package
plant has a rated capacity of 100 gpm at a filtration
rate of 5 gpm/ft2. Assumed chemical dosage are 300 mg
lime/gallon and 4 mg polymer/ gallon.
The carbon adsorption treatment costs are based on an
installed, two-stage, in-series, fixed bed, downflow
contacting system. It has been assumed that exhausted
carbon will be picked up and hauled away through a
service agreement with a supplier who will also provide
fresh carbon. The carbon system has been sized based
on the following assumptions:
- 30 minute contact time
- Carbon usage rate - 74 Ibs/hr.
- System lined for corrosion resistance
- Total weight carbon/bed = 3000 Ibs.
The neutralization system is assumed to be fully
automated and will operate in a continuous mode.
The building necessary to house the system occupies
1800 square feet and is fully winterized.
One person will operate the treatment plans and will
be on-site for a total of 12 hours each operating
cycle. The assumed labor rate is $15.00/hr.
An analytical allowance of $500 per operating cycle is
provided.
Table 5 provides a list of unit processes for treatment
of liquid hazardous waste. Based upon surface and
ground water characteristics at PAS, an assumed inter-
mittent treatment mode, and the capabilities of
-------
-12-
individual unit processes, the following processes
train is considered to represent the most feasible and
economical treatment scheme for PAS: flow equalization,
precipitation/ flocculation/sedimentation, activated
carbon adsorption, neutralization, and possible granular
media filtration. The primary rationale for rejection
of the other unit processes included: the generation
of a highly contaminated residual waste stream requiring
further treatment or disposal (e.g. ion exchange,
liquid ion exchange, reverse osmosis, ultrafiltration),
questionable ability to adequately treat the range of
organics present (ozone oxidation), their relatively
high capital costs (ion exchange, liquid ion exchange),
and their sensitivity to various constituents present
in the wastewater (e.g. sensitivity of ion exchange to
aromatic organics).
As part of the design phase for on-site leachate treatment,
oench-scale or pilot-scale testing would be required to determine
the effectiveness of selected unit processes with actual leachate
from PAS, and to establish final design parameters for these
processes. Based upon this testing program, certain processes
iay have to be added, deleted or modified.
As stated previously, six alternatives were developed that
ere felt would provide varying degrees of public and environmental
.rotection.
Alternative #1, as it appears in Table 6, was selected as
..he recommended remedial alternative because it provides adequate
protection to public health and the environment. Limited excavation,
off-site removal, grading, and capping of the site were included
to remove existing sources of contamination and to reduce leachate
generation. A perimeter slurry wall was recommended to isolate
the site from the surrounding area. The wall would prevent
ground water from flowing into the site, and would also prevent
contaminated ground water from leaving the site. The proposed
leachate collection system would contain leachate on-site. A
ground water collection and treatment system has been recommended
to collect and treat contaminated ground water from beneath the
site.
Alternatives 2 through 6, while technically feasible, did
not provide adequate protection. An assessment of these alter-
natives follow:
Alternative *2 is identical to #1 except that the slurry
wall was replaced with stream diversion. This alternative was
found to be inadequate because the stream diversion option would
not contain contaminated ground water on-site.
-------
-13-
In alternative 13 the ground water recovery option was
eliminated. This alternative is unacceptable because it also
does not include a means to prevent contaminated ground water
from migrating off-site, and therefore does not provide adequate
protection against ground water contamination.
Alternative #4 does not include leachate collection, ground
water recovery, or on-site treatment. This alternative does not
prevent contaminated ground water from migrating off-site, and
therefore does not provide adequate protection against ground
water contamination.
Alternative #5 is identical to #4 except that the slurry
wall option replaces stream diversion. Although this alternative
prevents ground water migration from the site, it does not provide
for leachate and ground water collection and treatment, and
therefore does not provide adequate protection against ground
water contamination.
Alternative #6 involves only limited excavation, removal,
grading, and capping. This alternative does not adequately
prevent ground water contamination nor does it prevent contaminated
ground water from migrating off-site. There is also no mechanism
for the removal and treatment of contaminated ground water and
leachate.
As previously stated, additional sampling will be performed
to confirm the integrity of the lodgement till and thus determine
if the slurry wall can be anchored into it. If it is found that
the till cannot support the slurry wall, then it will be necessary
to extend the wall to the bedrock, requiring an estimated additiona
$700,000. This additional expense would not affect the selection
of alternative #1 since it would still be far less expensive than
complete site excavation, the only other alternative that would
provide adequate protection of health, welfare, and the environment
A ground water monitoring program will be conducted in
accordance with RCRA Part 264. As part of this monitoring effort,
a limited number of bedrock wells will be installed to monitor for
contamination of the bedrock aquifer.
Community Relations
The final draft of the RI/FS prepared by URS Company, was
made available for public inspection and review on February 15,
1984, at the following locations: Oswego County Library, Oswego
Clerks Office, Penfield Library, and the DEC, Region 7 Office.
The public was notified of this by public notices which were
mailed to 127 persons and by press releases which appeared in
the Oswego Messengers, Oswego Palladium Times, Post Standard,
and the Accent Edition of the Post Standard/Herald Journal. The
public comment period began on February 17, 1984, and ended on
April 4, 1984. A public meeting was held on February 29, 1984,
in Oswego, New York. Numerous questions and comments were aired
by local citizens. Responses to these comments are contained in
the attached Responsiveness Summary prepared by NYSDEC.
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-14-
Consistency With Other Environmental Laws
The final recommended remedial alternative for PAS will
require that excavated materials be manifested for transport from
the site to a secure landfill. The material to be removed will
be visible, contaminated soil, buried drums and tanks.' Site
closure will be in accordance with RCRA Part 264.
The discharge of treated leachate and ground water into wine
Creek will require compliance with the requirements of the State
Pollutant Dishcarge Elimination System (SPDES), pursuant to.
article 16, Title 8 of the New York State Environmental
Conservation Law* Although compliance is required, an actual
permit is not.
The 37-acre wetland area adjacent to and downstream from
the PAS site has been tentatively designated as a regulated
wetland (No. OE-1), pursuant to Article 24 of the New York State
Environmental Conservation Law. Since it meets the criteria set
forth for a Class I wetland, this area will receive the highest
priority for protection. Remedial activities at the site,
particularly slurry wall construction, will require compliance
with the technical requirements of the above wetlands regulations,
and also compliance with regulations which are appropriate for
sediment control. This site activity will provide a beneficial
impact on the wetland. The additional proposed investigation
will help to assure the integrity of area wetlands in the future.
RECOMMENDED ALTERNATIVE
According to 40 CFR Part 300.68(j), cost-effectiveness is
described as the lowest cost alternative that is technically
feasible and reliable and which effectively mitigates and minimizes
damages to and provides adequate protection of public health,
welfare, and the environment. Evaluation of the six sugggested
remedial alternatives, lead to the conclusion that, although
alternative #1-is the most costly, it is the only alternative
which meets the NCP criteria. The components of alternative #1
are all technically feasible and reliable, and when combined,
provide an adequate level of protection for public health, welfare
and the environment. The other five alternatives were all found
to be deficient in minimizing actual or potential hazards at the
site. An alternative to completely excavate contaminated soil
from the site while being an effective alternative was rejected
because it is very expensive, and the chosen alternative provides
adequate protection at a much lower cost.
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-15-
The following activities are recommended for approval:
On-site
0 Limited Excavation and Off-site Removal
to a RCRA Approved Landfill
0 Grading and Capping in Accordance with RCRA part 264
0 Perimeter Slurry Wall
0 Leachate Collection
0 Ground Water Recovery
0 On-site Treatment
0 Ground Water Monitoring in Accordance with RCRA Part 264
The following listed figures represent a cost estimate for
the proposed actions. NYSDEC has the lead on this project.
Cost sharing for the remedial design of this project is 100%
Federal and for the project implementation is 90% Federal and 10%
State.
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-16-
COST SUMMARY FOR RECOMMENDED REMEDIAL ALTERNATIVE
INDIVIDUAL REMEDIAL MEASURE
Limited Excavation and Removal
Grading & Capping
Slurry Wall to Lodgement Till^
Leachate Collection
Ground Water Recovery
Onsite Leachate Treatment
COSTS
CAPITAL
287,800
767,700
337,500
71,000
59,600<4)
480,200
O&Ml^J
0
0
0
1,400
0
112,700
(3)
TOTAL
287,800
767,700
337,500
72,400
59,600
592,900
2,003,800
114,100 2,117,900
Data to date gives every indication that installation of
the slurry wall to the lodgement till will be sufficient to
contain contaminants onsite. If, however, the design phase
reveals that the slurry wall should be anchored in the bedrock,
then the costs for the slurry wall could exceed $1 million.
NYSDEC understands that the Federal government will pay for
90% of O&M for the first year, after which time, O&M will be
the responsiblity of the state. However, the proposed pump
and treat system is considered a remedial action, and will be
90% Federally funded for its entire operation.
This figure represents 5 years of O&M for leachate treatment,
and 1 year of O&M for the ground water pump and treat system.
This includes an one-year annual operating cost of $3100.
-------
-17-
Schedule
It is anticipated that the final Record of Decision (ROD)
will be approved by the end of May 1984. The Cooperative
Agreement Amendment should be awarded by the middle of June 1984,
Enforcement negotiations between EPA and the potentially respon-
responsible parties are ongoing. If a settlement has not been
reached by the award date of the Cooperative Agreement, negotia-
tions will be suspended at that time. A Design and Study phase
consultant should be selected by DEC during the summer of 1984,
and the design phase should be completed by the end of 1984.
Implementation is scheduled for the 1985 construction season,
and should require approximately six months for completion.
The recommended remedial alternative includes a ground water
collection and treatment system which, it has been estimated,
will require approximately 1 year to sucessfully draw out
contaminated ground water from the site. This system is
considered a remedial operable unit and will be funded as a
remedial action and not as O&M. EPA will fund O & M for the
leachate collection and treatment for one year, after which
time O&M will become the responsibility of the State.
Future Actions
Leachate collection and ground water recovery measure will
require periodic maintenance. On-site treatment will require
both operation and maintenance, with the conceptual operation
schedule involving a plant operator on-site once a week for the
first year, and once every five weeks in the following four
years of plant operation.
-------
ONTARIO
OSWIOO
NOCMESTCft
ST. PAUL'S
CEMETERY
OSWECO COUNTY LANDFILL
Scote: I" 720
LOCATION MAP
FIGURE NO. I
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TABLE 1
SUMMARY OF WASTE TYPES AND QUANTITIES
COLLECTED AND DISPOSED OF DURING
SURFICIAL CLEANUP OF THE PAS SITE
DESCRIPTION
Water Reactive Liquid
Organic Liquid, Low Halogen (<2%)
<50 ppm PCB
Organic Liquid, High Halogen
j[>2X) 50 ppm PCB
Aqueous Acids pH <2.0
Alkalines pH>12.5
Solids,>50 ppm PCB
Solids,<50 ppm PCB
PCB Contaminated Liquid,
50-500 ppm
PCB Contaminated Liquid,
>500 ppm
Lab Packs
Empty Drums
Collection and Handling of Washwater
Neutral Aqueous<50 ppm PCB,
No Cyanide, No Sulfide
Collection and Handling of Sludges
Disposal of Salvageable Steel to Smelter
Disposal of Building Rubble to Landfill
1
TOTAL QUANTITY
OF WASTE
237.1 gal.
20,749 gal.
1,426 gal.
769 gal.
1,819 gal.
60.75 drums
3,662.1 drums
55 gal.
144 gal,
3 drums
2,615 drums
63,918 gal.
165,536 gal.
123.5 drums
62.42 tons
123.42 tons
Reference: "Engineering Report for the Surficial Cleanup and Disposal of
Chemical Wastes/Pollution Abatement Services Site/Oswego, New
York," Camp, Dresser and McKee, June 1983.
-------
Table 2
Summary of Soil Analytical Data
Compound Maximum Detected Concentration (ppb)
Acid Compounds
2,4-Dimethylphenol 660.0
Phenol 3,000.0
Base/Neutral
Naphthalene 590.0
Nitrobenzene 185,000.0
Bis (2-ethylhexyl)
Phthalate 14,000.0
Butyl Benzyl
Phthalate 660.0
Di-N-Butyl
Phthalate 410.0
Di-N-Octyl
Phthalate 3,300.0
Anthracene 250.0
Phenanthrene 500.0
Pesticides/PCBs
PCB-1248 22,000.0
Metals Maximum Detected Concentration (ppm)
Arsenic 17.0
Beryllium 0.15
Chromium .26.0
Copper 87.0
Lead 9.1
Mercury 0.040
Nickel 27.0
Zinc 61.0
-------
Table 3
Compound
Summary of Ground Water Analytical Data
Maximum Detecfed Concentration (ppb)
Volatile Compounds
Benzene
Chlorobenzene
1,2-Dichloroethane
1,1,1-Trichloroethane
Chloroform
1,2-Trans-
Dichloroethylene
Ethylbenzene
Methylene Chloride
Toluene
Trichloroethylene
Xylenes
Acid Compounds
P-Chloro-M-Cresol
2,4-DimethyIphenol
2-Nitrophenol
Pentachlorophenol
Phenol
Base/Neutral Compounds
Bis (2-chloroethyl)ether
1,2-Dichlorobenzene
1,3-Dichlorobenzene
v1,4-Dichlorobenzene
2,6-Dinitrotoluene
Isophorone
Naphthalene
Bis(2-ethylhexyl)
Phthalate
Di-N-Butyl Phthalate
Benzo (A) Pyrene
3,4-Benzoflouranthene
Benzo (K) Flouranthene
Metals/Inorganics
Arsenic
Cadmium
Chromium
Copper
Lead
Nickel
Selenium
Zinc
Cyanide
5,500.0
480.0
3,500.0
560.0
290.0
5,300.0
5,000.0
120,000.0
16,000.0
15,000.0
36,000.0
Trace
1,200.0
550.0
Trace
8,300.0
Trace
160.0
Trace
22.0
Trace
14.0
15.0
60.0
Trace
Trace
Trace
Trace
100.0*
8.5.0
330.0*
99.0
280.0*
11,200.0
61.0*
240.0*
7,300.0
*Indicates exceedance of
Primary Drinking Water Standard.
according to the Safe Drinking
Water Act of 1977.
-------
Table 4
Summary of Surface Water and
Sediment Analytical Data
Maximum Concentration Maximum Concentration
Compound in Surface Water (ppb) in Sediment (ppb)
Volatiles
Benzene 270.0 23.0
Chlorobenzene 51.0 6.5
Chloroethane <10.0 6.7
Chloroform 95.0
1,1-Dichloroethane 150 43.0
1,2-Dichloroethane 2,700 120.0
1,1-Dichloroethylene 6.9 <4
Trans-1,2-Dichloroethylene 540 .74
Ethylbenzene 380 77.0
Methylene Chloride 24,000 1200.0
Tetrachloroethylene 290 5.7
Toluene 4,300.0 130.0
1,1,1-Trichloroethane 45.0
1,1,2-Trichloroethane 7.1
Trichloroethylene 290 7.3
Vinyl Chloride 80
Acid Compounds
2-Nitrophenol 120
Phenol 1,300 1.2
2,4-Dimethylphenol 320 29.0
2,4-Dichlorophenol - .41
Base/ Neutrals
Anthracene - 1.2
Benzo(A)Anthracene - 0.50
Benzo(K)Flouranthene - 0.70
Flouranthene - 0.40
Pyrene - 1.4
Fluorene - 1.0
1,2-Dichlorobenzene 33
Bis (2-ethylhexyl) phthalate 40 0.90
Bis (2-chloroethyl) ether 110
N-Nitrosodiphenyl amine 23 2.4
Isophorone 22 0.53
-------
Table 4 (Continued)
Maximum Concentration Maximum Concentration
Compound is Surface Water (ppm) in Sediment (ppm)
Metals/inorganics
Beryllium
Cadmium
Chromium
Copper
Lead
Mercury
Nickel
Selenium
Silver
Zinc
Cyanide
Conventional Parameters
.002
.001
.015
.013
.185
.326
.243
.088
.61
.127
5.67
21 .8
137.0
37.7
277.0
0.116
49.3
-
258.0
~
COD (mg/1) 607.0 N/A
Iron (mg/1) 28.7 N/A
-------
TABLE 5
UNIT PROCESSES FOR TREATMENT
OF LIQUID HAZARDOUS WASTE
o Flow Equalization
o Precipitation, Flocculation, Sedimentation
o Biological Treatment
Air-Activated Sludge
Pure Oxygen-Activated Sludge
Trickling Filters
Rotating Biological Discs
Biological Seeding
Stabilization Ponds/Aerated Lagoons
o Carbon Adsorption
o Ion Exchange
o Liquid Ion Exchange
o Stripping
Air
Steam
o Ozone Oxidation
o Neutralization (pH Adjustment)
o Wet Air Oxidation .
o Reverse Osmosis
o Ultrafiltration
-------
Pollution
Oswego,
ALTERNATIVE
Services (PAb)
COMPONENTS
(JUKI'S ($1 ,III)U)
CAPITAL ANNUAL (MM
PUtlLIC HKAI.TH
CONSIDERATIONS
CONSIDERATIONS
TECHNICAL
CONSIDERATIONS
PUBLIC COMMENT
OTHfc.<'-doNCERNS
Alternative II Limited Excavation and 1J6J.7 117.2
Removal
Grading and Capping
Perimeter Slurry Mall to
Lodgument Till
Leachate Collect ion
Grcund Mater Recovery
On-site Treatment
Alternative 12 Limited Excavation and 1367.2 117.2
Renuval
Grading and Capping
Stream Diversion
Leachate Collection
Ground Mater Recovery
On-site Treatment
Alternative 13 Limited Excavation and 1335.4 114.1
Removal
Grading and Capping
Stream Diversion
Leachate Collection
On-site Treatment
Alternative 14 Limited Excavation and 9H6.1 0
and Removal
Grading and Capping
Stream Diversion
eliminates threat since
contaminants are fully
contained on-site
minimizes threat
since the predominant
method ot contaminant
transport has been
diverted
minimizes threat
since the predominant
method of contaminant
transport has been
diverted
minimizes threat since
the predominant method
of contaminant
transport has
been diverted
grading and capping
ot the site will
cause a minimal
impact on adjacent
fliiurtplain and
drainage to wetlands
leachate recovery and
ground water collection
will reduce the volume
of ground water
entering into
Mute Creek
Same as II
stream diversion will
greatly change stream
system environment
Same as 12
grading and capping
of the site will
cause a minimal
impact on adjacent
floodplain and
drainage to wetlands
stream diversion will
greatly change stream
system environment
final depth of slurry
wall to be defined
during design
chemical contaminants
impact on wall Is
unknown
very acceptable
" continuing CUM
required
* temporary impacts
during construction
uncertainty regarding
reliability of
conduit trench for
interception of ground
water before reaching
the site
Sane as 12
uncertainty regarding
reliability of
conduit trench for
interception of
ground water
marginally
acceptable
marginally
acceptable
marginally
acceptable
as II
Sane as II
continued
maintenance required
temporary impacts
during construction
Alternative IS
Alternative 16
Limited Kxcavation and
and Removal
Grading and Capping
Perimeter Slurry Mall
to Lodgement Till
Limited Excavation and
and Removal
Grading and Capping
9)12.6
Alternative 17 No Action
Alternative 18
Total excavation and
Off-site Removal
to a RCRA Landfill
763.6
75,000.0
minimizes threat since
the preduni nant mutlnd
of contaminant transport
has been diverted
the threat is reduced
but still exists;
contaminants are
still on-site and
not contained
potential direct
contact to nearby
residents and
recreational
users of streams
siqn'f !*
WDlXCiiJ
residents
grading and capping
of the site will
cause a minimal
imjiact on adjacent
t luu^ilain and
drainage to wetlands
Same as 15
degradation of the
stream and wetland
systems
continued migration
of contaminated ground
water
None
final depth of slurry
wall to be defined
during design
chemical contaminants
impact on wall is
unknown
None
None
marginally
acceptable
unacceptable
unacceptable
Sane as 14
Same as 14
None
I
I'nrwrtainty regarding
c, -'i-t for cleanup
acceptable
community
disruption due
to truck traffic
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