United StatM
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROO/R02-88/058
March 1968
SEPA
Superfund
Record of Decision
Old Bethpage, NY
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30373-101
REPORT DOCUMENTATION
PAGE
I. REPORT NO.
EPA/ROD/R02-88/058
J. Recipient's Accession No.
4. Title and Subtitle
SUPERFUND RECORD OF DECISION
Old Bethpage, NY
First Remedial Action - Final
S. Rtpoit Date
0 3/1*7/8 8
7. Authorfs)
8. Performing Organization Rept. No
9. Performing Organization Name and Address
10. Project/Task/Work Unit No.
12. Sponsoring Organization Nam* and Address
U.S. Environmental Protection Agency
4U1 M Street, S.W.
Washington, D.C. 20460
11. Contraet(C) or Grant(G) No.
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EPA/ROD/R02-88/058
d Bethpage, NY
rst Remedial Action - Final
16. ABSTRACT (continued)
The selected remedial action for this site includes: hydraulic control of the plume
through installation of ground water recovery wells; ground water pump and treatment
using air stripping and, if necessary, carbon filtration with discharge into an
upgradient injection well system; ground water monitoring; completion of the landfill
capping (29 acres previously capped); continuation and expansion, or enhancement of the
leachate control and gas collection systems; and gas monitoring. The estimated present
worth cost of this remedial action is $23,045,000.
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declaration Staterr.er.t
Record of Decision
Old Bethpage Landfill
SITE NAME AND LOCATION
Old Bethpage Landfill, (the "Landfill") Old Bethpage, Town
of Oyster Bay, Nassau County, New York
STATEMENT OF PURPOSE
This decision document sets forth the selected remedial
action for the Old Bethpage Landfill developed in accordance
with the Comprehensive Environmental Response, Compensation
and Liability Act of 1980, as amended by the Superfund
Amendments and Reauthcrization Act of 1986 ("CERCLA"), and
to the extent practicable, the National Oil and Hazardous
Substances Pollution Contingency Plan, 40 CFR Part 300,
published November 20, 1985.
STATEMENT OF BASIS
This decision is based upon the administrative record for
the Old Bethpage Landfill. A copy of the record is
available for review at the Plainview Public Libraryfc 999
Old Country Read, Plainview, New York; and the New York
State Department of Law, Environmental Protection Bureau,
120 Broadway, New York, New York. The documents, which are
part of the administrative record, and which were primarily
relied upon in making this decision are:
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- those documents listed in Attachment 1 to this
Declaration;
- the Summary of Remedial Alternative Selection
(Attachment 2 to this Declaration); and
- the Public Responsiveness Summary (Attachment 3 to
this Declaration).
DESCRIPTION OF SELECTED REMEDY
The selected remedial alternative presented in this
document in combination with remedial programs already
implemented under various other federal and State
regulations, including particularly 6 NYCRR Part 360 and
those to be completed and monitored as part of the Remedial
Action Plan ("RAP") (See Appendix I of ROD Attachment 2),
will provide a complete and permanent solution for the
release of hazardous substances at the site. The selected
remedial alternative focuses on the control and clean-up of
groundwater contamination emanating from the Landfill and
source control of the Landfill by capping and gas control.
The major components of the selected remedy can be
summarized as follows:
* Installation of a system of groundwater recovery wells
located at the area defined by the leading edge of the
plume of volatile organic chemicals and landfill
leachate in excess of Applicable or Relevant and
Appropriate Requirements (ARARs);
0 Operation and maintenance of these groundwater recovery
wells, to create a hydraulic barrier to attain A?.-.?.s
(the specified grouncwater criteria or zero slope
condition as defined in the RAP);
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8 Treatment of the recovered water by an air stripper,
and if necessary carbon'filtration, in compliance with
the ^.RARs for groundwater and air discharge.
The selected remedy in conjunction with the following
remedial components already in place and/or to be completed
includes:
0 A leachate collection system operating at the landfill
since late 1983. The system is designated to collect,
store, treat, and dispose of the leachate generated by
the landfill in compliance with ARARs;
0 A gas collection system installed in phases since 1982.
The system is designed to monitor and prevent migration
of landfill gas beyond the property boundary in
compliance with ARARs;
* Approximately 29 acres of the 65 acres landfill have
already been capped. The remaining areas will be
capped in compliance with ARARs.
In addition;
* Monitoring programs to determine the effectiveness and
performance of each of "these remedial system
components;
0 Post termination monitoring programs to insure
continued compliance with ARAR's after remedial systems
shutoff and to insure protection of human health and
the environment.
The entire-cost of remediating the landfill is estimated to
be approximately $23 million.
DECLARATIONS
Consistent with the CERCLA and the National Oil and
Hazardous Substances Pollution Contingency Plan, 40 CFR Part
300, the selected remedy in combination with the programs
set forth in the RAP is protective of human health and the
environment, attains federal and. state requirements that
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are applicable or relevant'and appropriate'for air and
•
groundwater contamination at the site and is cost effective.
As set forth in Section 121 of CEHCLA, this remedy satisfies
the statutory preference for remedies that employ as their
principal element treatment which permanently and
significantly reduces the toxicity, mobility and volume of
hazardous substances. This remedy utilizes permanent
solutions and alternative treatment technologies to the
maximum extent practicable. No federal Superfund monies are
being used for this remediation.
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This document constitutes a joint declaration of the
State of New York and the United States Environmental
Protection Agency.
Date - EDWARD C. SULLIVAN
Deputy Commissioner
Office of Environmental
Remediation
Mew York State Department of
Environmental Conservation
Date CHRISTOPHER J. sIDAGGETT"
Regional Administrator,
Region II
United States Environmental
Protection Agency
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POD ATTACHMENT 1 .
Old Bethoace Landfill Remediation
"Groundwater Monitoring Program: Phases 1 & 2," Lockwood,
Kessler & Bartlett, June 1981.
"Comprehensive Land Use and Operations Plan, OBSWDC,"
Lockwood, Kessler & Bartlett, October 1983.
"Final Design Report OBSWDC Offsite Groundwater
Investigation and Monitoring Program," Geraghty & Miller,
March 1984. ' '
"Phase 3 Groundwater Monitoring Program, 1983-1984,
Analytical Results," Lockwood, Kessler, & Bartlett,
May 1984.
"Phase 3 Groundwater Monitoring Program, 1984-85, Analytical
Results" Lockwood, Kessler & Bartlett, June 1985.
New York State Sampling Data: "Offsite Monitoring Program",
CompuChem, June 1985, July 1985, October 1985 and January
1986.
Raw Sampling Data, Eco Test Laboratories, June 1985, July
1985, October 1985, January 1986, and April 1986. .
Remedial Investigation: "OBSWDC Offsite Exploratory Drilling
and Monitoring Well Installation Program," Geraghty &
Miller, August 1985.
Letter, dated July;25, 1986, from Owen Walsh (Nassau County)
to Robert Osar (DOL) regarding Disposal of Treated Water.
Letter, dated July 30, 1986, from William Spitz (DEC) to E.
Gail Suchman (DOL) regarding Long Island Water Supply
Regulations and Nassau County Water Districts "CAPS" Letter.
Remedial Investigation: "OBSWDC Offsite Groundwater
Monitoring Program," Geraghty & Miller, September 1986.
"1986 Annual Report: Summarizing the Status of Landfill Gas
Monitoring Programs and the Establishment of the Zero
Percent Gas Migration Limitation at the Old Bethpago
Landfill," Lockwood, Kessler & Bartlett, April 1987^
"Remedial Action Feasibility Study: Landfill Leachate
Plume, OBSWDC," Lockwood, Kessler & Bartlett/ Geraghty &
Miller, July 1987.
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Recent" Quarterly Sampling Data, Eco Test Laboratories,
September 1986 - July 1987.
"Air Stripping Design Report:' Wells No. 6B, 6C, 6F," Hydro
Group, Inc., July 1, 1987.
"Evaluation on Air Stripper Emission Impacts on Air Quality
at the OBSWDC," RTF Environmental Association,
September 1987.
"OBSWDC Aquifer Test for Evaluating Hydraulic Control of
Leachate Impacted Groundwater," Geraghty & Miller,
September 1987.
"Old Bethpage Landfill: Subsurface Gas Sampling,"Lockwood,
Kessler & Bartlett, September 4, 1987 (draft).
Letter, dated September 8, 1987, from Geraghty & Miller
to John MoHoy (Holzmacher, McLendon & Murrell)
regarding Potential Groundwater Mounding.
Latter, dated October 8, 1987, from RTF to John Lekstutis
(Lockwood, Kessler & Bartlett) regarding the Assessment of
Odor Potential for Proposed Air Stripping Tower (draft).
Letter, dated October 26, 1987, from Geraghty & Miller to
Robert Osar (DOL) regarding Collection and Recharge
Facilities calculations.
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PCD ATTACHMENT
SUMMAPY OF REMEDIAL ALTERNATIVE SELECTION
OLD 5ETHPAGE LANDFILL
OLD BETKPAGE, NEW YCRK
I. BACKGROUND
A. Site, Location and Description
The Old Bethpage Landfill (the "Landfill") is located
in Old Bechpage, Town of Oyster Bay, Nassau County, Long
Island. The property on which the Landfill is located is
bounded primarily by Winding P.oad and Round Swamp Read. The
Landfill area is approximately sixty-five (65) acres.
There are two public drinking water well fields in the
general vicinity of the Landfill, Plainview Well Field 35 to
the north and two Fartungdale wells to the south-south east.
There is a residential community to the northwest of the
Landfill and an industrial park, including the Claremont
Polychemical facilty, to the east. Bethpage State Park,
which consists largely of a public golf course, is south,
west and east of the Landfill. The Nassau County Fireman's
Training Facility is south of the Landfill. See Map,
Figure 1.
B. Site History
1. General
The Landfill has been operated by the Town of Oyster
Bay (the "Town") as a municipal landfill since
approximately 1958. In addition to municipal wastes and
garbage, industrial wastes from local industries were also
disposed in the Landfill in the late I960's and early
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Fiqur- i fv.? CF VICINITY Cf OLD 5IT-.?-,'j=
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1970's. The Tandfill was closed to further landfilling
i
operations-en April 14, 1936.
2. Early Data Gathering
(a) Groundwater
The investigation of groundwater contamination at and
around the Landfill began in 1979. The initial programs
were designed to determine the quality of the groundwater
beneath the Landfill property. These were later expanded to
include the monitoring of existing off-site wells to provide
information on the effect of the Landfill on surrounding
groundwater. These programs end their findings are
discussed in detail in Lockwocd, Kessler & Partlett, Ire-.
(LKB) reports entitled: "Groundwater Monitoring Program,
Phases } and 2", June 1981; "Phase 3 Groundwater Monitoring
Program,. 1933-1984 Analvtical Results", May 7.984; 'and "Phase
3 Groundwater Monitoring Program, 1984-198:5 Analvtical.
Results", June 1985. These reports r.re available for review
in the administrative record.
As a result and based upon the groundwater data
gathered under these programs, the later off-site
groundwater investigation of the groundwater Remedial
Investigation, set forth in Section T..B.I, infra, v;as
implemented.
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(b) Methane Gas
Methane gas r.iaraticn vas found both, on and off of the
•
Landfill site in the early 1980 's. In response to this
migration and the presence of rrethane gas in the Landfill,
the methane gas collection remedial program described in
Section !.B.4(b), infra, was implemented.
3 . Listing on the NPL.
On Septenber 8, 1983 this site was listed en the
National Priorities T-ist (NPL) [see 43 Fed. Peg. 40658] .
* . History of Remedial
There are three remedial actions currently completed or
underway at the Old Bethpage Landfill. These are: leachate
collection, methane gas collection, and Landfill capping.
These actions are fully described in the October 1983 LKB
report entitled "Comprehensive Land rrse and Operations
Plan", prepared in accordance with the landfil-1 closure
regulations found at 6 NYCRR Part 360 and appropriate
guidelines. That plan was approved by the New York State
Department of Environmental Conservation ("DEC"). The
programs were designed to significantly limit migration of
contaminants from the Landfill via air emissions and surface
runoff. In addition, the capping program was designed to
reduce infiltration into the Landfill, thereby reducing
leachate production and subsequent groundwater
contamination. The three programs are described below:
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(a) Leachate Collection
A leach'ate control system has been operating £t the
Landfill since late 1983. The system is designed to
collect, store, treat and dispose of leachate generated by.
the Landfill. Collection wells and an underdrain system
have been installed ever the lined portion of the Landfill
(approximately 12 acres). Eeachate flows from these
collection points to a clav and polyethylene lined temporary
storage basin. The leachate is then treated by standard
metals precipitation and solids separation techr.icrues. The
treated effluent is discharged into the Nassau- County sewage
treatment system in accordance with the requirements of the
State Pollution Discharge Elimination System (?PDES) and
Nassau County Ordinances. The sludge is currentlv dewatered
and returned to the Landfill. This program is described in
detail in Section 4 cf the 1^93 "Comprehensive Land tls'e and
Operations Plan."
Provisions for the future maintenance and operation of
the leachate control system are set forth in Section I.I. of
the Remedial Action Plan ("RAP"), attached hereto as
Appe.mJiic I. Under the RAP, the sludge will be disposed
off-site at an approved waste disposal facility.
The capacity of the leachate collection systerp is
?0,000 gallons/day. The amount of leachate produced is
approximately 150,000 gallons/week. The leachate is and
will continue to be monitored monthly for metals, sulfites
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and total susoended solids, until such tir.e as leachate
f
production .ceases at the Landfill.
(b) Landfill Gas Collection
The Landfill gas collection system has been installed
in phases at the periphery of the Landfill since 1982. The
system is designed to monitor and prevent migration of
Landfill gas beyond the property boundary. Approximately
seventy sampling points around the Landfill are monitored
nonthly for the presence of methane. When monitoring has
indicated that Landfill gas was? migrating beyond the
collection system at any point, the system has been expanded
to address that migration, ^he PAP calls for the continued
expansion and enchancement of that system, as required,
according to the results of future monitoring data.
In 1982, Phase I of the collection system was installed
in the vicinity of the Nassau County Fireman's Training
Center at the southeastern corner of the Landfill. The
system consisted of a series of extraction wells and blowers
which collected gas and vented it into the atmosphere in
uninhabited areas surrounding the Landfill. In 1984, Phase
II extended the collection system along the eastern border
of the Landfill at Winding Road. The original design of
Phases I and II and the monitoring program is fully
described in Section 6 of the 1983 "Comprehensive Land Use
and Operation Plan". In 1986, an incinerator was installed
to incinerate the extracted gases from Phases* I and II in
lieu of venting. Phase III, at the northwest boundary of
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the Landfill, became operational in 1987. A map depicting
the gas collection program is shown in Figure .?. .
Data collected through the gas monitoring program is
compiled into published annual reports. The most recent
report available is the "1986 Annual Report: Summarizing
the Status of Landfill Gas Monitoring Programs and the
Establishment of the Zero Percent Gas Migration .Limitation .
at the Old Bethpage Landfill" released by LKB in April.1987.
The monitoring program has been revised as required since
1982 and will be expanded and carried out in the future as
per Section I.H. of the RAP.
Subsurface gas sampling was conducted in September,
1987 to help design a more comprehensive gas monitorino
program. The results of that sampling progran are cet forth
in a draft report entitled "Old Bethpage Landfill:
Subsurface Gas Sampling". The monitoring program in the RAP
is designed to measure the continued effectiveness and
efficiency of the gas collection system.
In addition to the cas collection system at the site
perimeter, there is a gas extraction system in the renter of
the Landfill which is privately operated under license fron
th« Town. The system extracts gas for the generation of
approximately 2 megawatts of electricity. It is estimated
by the Town that this process will produce gas sufficient
for 10 to 15 years of continued generation and that at that
point in tire .the level of gas in the Tandfill vrill approach
zero.
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.OLD BETHPAOc LANDFILL C~AS.COLLECTION SYSTEM
Venting Trench
LANDFILL AREA
Scale: l" s 600'*
N
LEGSN
• Denotes Existing Single Point
Sampling Proo«, Deptn 30"
• Dcnoits Ejuslinq Cluster
Dipth 10', 20', 30' and 40'
* Denotes Existing 8'V Steel
Sompling Prooe, Oeptn 20'
B Denotes Existing Single Point
Sampling rrooe, Deptn 8'
Denotes Existing Pnosel.l'k? Gas
Conuol Systems
KESSLE?.
SART'.ETT.
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(c) Capping .
Closure and cappinc of the Landfill is required
pursuant to 6 NYCRR Part 360. The capping process involves
regradir.g the slopes of the Landfill to a slope of 3
horizontal to 1 vertical. An 18-inch thick clav cap or
eouivalent material with a permeability of 10 or less
will then be placed over the Landfill to limit infiltration
into the fill. It is presently contemplated that a 12-inch
soil cover will be placed on the cap and the area will be
revegetated. The desion and specifications of the cap are
described in Appendix I, Section I.G.. At the present tine,
a cap has been applied to approximately 29 acres of the 65
acre Landfill. The capping program is proceeding and will
be completed in conjunction with the groundwater remediation
program selected herein.
The retirements and schedule for completion of the
capping program are set forth in Secticn I.K. of the P.AP.
compliance monitoring program for the cap is set forth in
Section I.G. of the RAP.
5. Enforcement History
(a) Inter-Acrericy Coordination
On July 23, 1982, DEC referred the investigation and
remediation of the Old Bethpage Landfill to the New York
State Department of Law ("DOL") for enforcement. An initial
meeting to establish coordination with the United States
Environmental Protection Aaencv ("EPA") W?.F held on
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September 9, 1982. The Attorney General's office was named
lead enforcement agency en the matter. The Attorney
General's office commenced negotiations for an off-site
groundwater investigation during the fall of 1982. Initial
discussions were held with the Town and also with identified
corporate responsible parties: Occidental Petroleum
/formerly Hooker Chemicals and Plastics), Grumman Aerospace,
and Cerro Wire and Cable. More detailed negotiations with
the Town were held during 1983.
(b) Litigation
(i) History
On December 9, 1983 the Attorney General's office filed
a summons and complaint in the United States District Court
for the Eastern District of New York against the Town of
Oyster Bay; Occidental Chemical Corporation; Occidental
Chemical Holding Corporation; Occidental Petroleum
Corporation; Marraon Group., Inc.; Cerro Wire & Cable Corp.;
Cerro Conduit Company; Cerock Wire and Cable Group, Inc.;
The Rockbestos Company; Grunman Corporation; and Grumnan
Aerospace Corporation.
Th~e complaint was brought under the Comprehensive
Environmental Response, Compensation and Liability Act of,
1980 as well as pendant state claims under State statute and
the common law. The defendants served answers. There was
some informal discovery conducted.
The Town sicrned an Interim Consent Decree in May 1984,
which required it to complete some remedial activities then
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underway [i.e., a portion of Jthe capping program (29 acres)
and the c&mpletion and continued operation and maintenance
of the gas collection program] and to perform the off-site
groundwater investigation detailed therein. The purpose of
the off-site groundwater investigation was to identify the
plume of chemical contamination emanating from the Old
Bethpage Landfill. The results of the off-site groundwater
investigation are set forth in the Geraghty & Miller, Inc.
(G&M) reports entitled "OBSWDC Offsite Exploratory Drilling
and Monitoring Well Installation Program, Old Bethpage, Long
Island, New York," (August 1985) and "OBSWDC Offsite
Groundwater Monitoring Program, Old Bethpage, Long Island,
New York," (September 1986). These documents constitute the
Remedial Investigation ("RI") for this site. The details of
the RI are set forth in Section I.B.7 herein. The Town also
committed as part of that Interim Consent Decree to prepare
a Remedial Action Feasibility Study ("PS"). The Interim
Consent Decree was approved by the court on July 19, 1984.
While the RI was being conducted by the Town, the Town
and the other defendants reviewed records of the Town and
identified approximately 160 other parties who were alleged
by them to be responsible parties with respect to
contaminant releases from the Landfill. On or about October
4, 1985 and January 3, 1986, the Town and the other
defendants brought third-party actions against these 160
parties.
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(ii) Current Status
As the FS was being developed, negotiations were
•
conducted among all the parties and third-parties to
determine the possibility of resolving this action by
settlement. The parties developed the terms of a proposed
settlement. Final agreement to that proposed settlement is
contingent upon the 'final selection of remedy by the State
and EPA through the Record of Decision ("ROD") process and
agreement by the State and Town to the attached Remedial
Action Plan ("RAP"), Appendix I. Once these items are
resolved, a consent decree setting forth that settlement can
be executed by the parties.
6. Risk Assessment
A qualitative risk assessment was conducted to evaluate
the risk to public health and the environment, associated
with the Old Bethpage Landfill. The risk assessment
consisted of the following: identification of contaminants
of concern; description of potential pathways and
populations of exposure associated with site contaminants;
and determination of the best means to remove potential
risks-to humans and the environment.
(») Contaminants of Concern
The primary contaminants of concern identified in the
early data gathering were methane gas and variety of
volatile organic compounds in the groundwater.. It was"
determined that due to. the high.concentration of these
cc-taziir.ar.ts found on-site, zhey were probably -,cvir.g
cff—sits. • Th.a ^sthsjza cas csllsstics, system iaz already
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been commenced to prevent further off-site migration of
landfill gas. Partial Landfill capping provided some
interim remediation for groundwater contaminant migration.
A full off-s-ite groundwater investigation was deemed
necessary.
The various chemicals found on-site cause a variety of
adverse health effects/ depending on the type of chemical
and the concentrations found. Some of the chemicals found
were known or suspected human carcinogens, including vinyl
chloride and benzene.
(b) Exposure Pathways/Population
It was determined that the Landfill presented two
primary exposure routes: 1) landfill gas migration and 2)
potential off-site migration of contaminated groundwater.
There were two primary populations potentially exposed:
1) the residential neighborhoods close to the Landfill (air
exposure) and the residents of the Village of Farmingdale
who utilize the public drinking wells directly downgradient
of the Landfill (contaminated groundwater exposure). In
order to insure that these populations were protected/ the
remedial investigation, feasibility study, and interim
measures set forth in the Interim Consent Decree called for
plans designed to measure the extent of those exposure
.... " . *
roTrtes and to provide for their complete and permanent
closure.
(c) Risk Characterisation"
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The investigation and studies set forth herein
identified and defined the air and groundwater exposure
•
pathways emanating from the Landfill. The list of
contaminants found and their concentrations are set forth in
the data packages in the administrative record. The
investigation and studies show that the potentially exposed
populations are not currently being impacted through these
routes of exposure. The RAP, attached hereto/ sets forth a
remedial plan designed to control the source of
contamination (the Landfill) and to control the paths of
population exposure to air and groundwater contaminants.
The remedial plans call for the eventual reduction of the
contamination within the areas of containment to
concentrations at or below health based cleanliness
standards and guidelines. The plan also calls for the
comprehensive monitoring of all remedial systems to evaluate
their continued effectiveness in limiting the routes of
exposure and in cleaning up the contacinant concentrations.
The successful implementation and'completion of the HA?
and compliance with the proposed Consent Decree cited above
will -reduce the potential risks to humans and the
environment presented by these paths of exposure in
compliance with the cleanliness requirements discussed
herein.
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7. gemedial Investigation ("P.I")
The purpose of the groundwater investigation was to
delineate and characterize the leachate plume emanating from
the Landfill. The investigation included the drilling cf
six exploratory borings and the installation of 23
monitoring wells in Bethpage State Park. The drilling and
monitoring well installation program was completed in April
1985 when the Town and State agreed that the extent of the
Landfill leachate plume had been defined. Inorganic
chemical parameters, typical of sanitary landfill leachate,
were used to define the extent of the plume. The
methodology used to define the extent of the leachate plume
is discussed further in the G&M Report of August 1985.
After completion of the well installation phase, five
rounds of. water quality samples were collected (June, July,
October 1985 and January, April 1986) from the 23 monitoring
wells and other selected wells. ; This data is set forth in
the administrative record and is available for review.
Groundwater samples v/ere analyzed for an extensive list of
parameters that included metals and organic compounds. In
addition, water level measurements and water quality samples
were taken in three temporary wells upgradient of the
Landfill to determine if there were any effects from
groundwater mounding.
Water-level data from off-site wells clearly
demonstrated that groundwater flow under the J.andfili is to
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the south-southeast. Water-level data collected" from the three
temporary upgradient wells did not indicate components of
croundwater flew (rr.cur.dinc) tfo the north or west. (See GiM
*
Report, August 1985)
The approximate lateral extent of the Landfill leachate
plume (at three depths) is shown on Figure 3. The plume
exhibits the greatest lateral extent at the middle depth,
extending approximately 2000 feet from the Landfill. The
approximate vertical extent of the Landfill leachate plume is
shown on Figure 4. The thickest section of the plume is
approximately 200 feet. Further discussion on the config-
uration of the plume is provided in G&M's September, 1986
groundwater report, cited earlier.
Results of the five rounds of groundwater sampling of the
23 off-site monitoring wells indicate that the Landfill leactf
ate plume is comprised of inorganic compounds and volatile
organic compounds (halogenated and non-halogenated) (VCCs).
The data generated from these sampling efforts is contained and
discussed in the G&M report of September 1986. The lateral and
vertical extent of the VOC and Landfill leachate plume in
excess of Applicable or Relevant and Appropriate Requirements
(ARAEs)(see Table 1) is shown in Figures 5 and 6, respectively
(hereinafter referred to as the "plume").
The most dominant halogenated organics, in terms of
concentration and distribution, are 1,2-dichloroethene,
1,1-dichloroethane, vinyl chloride, methylene chloride,
trichloroethene and chlcroethane. The non-halogenated
organic compounds occur in a smaller area of the plume than
the halogenated compounds. The most dominant compounds of
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Figurt3 APPROXIMATE EXTENT OF LANDFILL LEACHATE
PLUME WITHIN 3 HYDROGEOLOG 1C ZONES
PREPARED 8Y OERAGHTT ft MILLER, INC., FOR.
LOCKWOOO, KESSUER, a BARTUETT, INC., A TOWN OF
OYSTER BAY, OLD 8ETMPAGE.-HY
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APPROXIMATE VERTICAL EXTENT
OF LANDFILL LEACHATE PLUME
ALONQ CROSS SECTION A-A'
LOCK WOOD. KCSSLER. AND BARILETT. INC
AND THE
TOWN OF OYSTER BAY
014
. N«« York FIGURE 4
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Figur* S APPROXIMATE OlSTRiaUTlON Or VOLATILE
HALCGENATED ORGANICS ( VH 0 i }
3 SY 6ERASMTY. a UH.LS3- INC., FOR
LCCXWOOO, ICESSLER, a BARTUETT, I NC. , a TOWN OF
OYSTER SAY, QL3 S£TH?A<3£, NY
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I I f I AM »l I O M
• !•••< • • ••* .
• •••*• ••!! •
*!•* »i«| t lion
O/ VOIA1UI MALOOCMAfCO
APPROXIMATE VERTICAL DISTRIBUTION OF
VOLATILE HALOOENATED OHQANIC8
-------
this croup are benzene, toluene, ethylbenrrere and iscmers of
xvler.e. -Tetrachlcroethene, although present at sinilar
concentrations, has a different lateral distribution than
the compounds cited above. Jn this regard, comparison of
the distributions of the different VOC groupings within the
Landfill leachate plume indicates that part of the voc
contamination may not be attributable to the Landfill. This
finding is discussed in the G&M report of September 1986,
cited above.
Results of groundwater sampling of the three temporary
wells upgradient of the Tandfill indicate that.ro
significant mounding is occuring at the Landfill. In
addition, the proposed final capping of the Landfill as set
forth in- the RAP will minimise ar.v future potential for
contaminant mioration due to moundinc.
Investiaation and regular sampling by Nassau County of
Farmingdale and Plainview public drinking water has shown
that the contamination from the Landfill is not affecting
those public drinking wells at this time.
8. Supplemental Investigation
(a) Effectiveness of Gas Collection System
The effectiveness of the gas collection system
installed at the Landfill is monitored on a monthly basis as
described in Section I.B.4(b), supra. Annual reports have
been prepared summarizing the results of the data collected.
The most recent annual report, for 1986 (cited earlier),
Demonstrated the effectiveness of the gas collection system
-------
for controlling methane gas migration bevond the boundary of
the Landfill. A supplemental sampling program was '
•
undertaken in June 1987 to'confirm that the system
effectively prevented the escape of gases other than methane
fron the Landfill.
The supplemetal gas sampling program consisted
primarily of 1) the collection of subsurface gas samples
from a depth of 30 inches below the surface at eight
locations around the perimeter of the collection system, 2)
the collection of subsurface gas samples at depths of 10,
20, 30 and 40 feet from one deep well cluster outside the
gas collection system, and 3) the collection of two ambient
air samples beyond the collection system. The samples v/ere
* .
analyzed for volatile organic compounds 'VOO .
The results of this sampling effort are summarized in
the September 1987 draft report entitled, "Old Eethpage
Landfill: Subsurface Gas Sampling" previously cited and
available for review. Minimal levels of VOCs were found in
some of the gas samples. The data demonstrated that the
collection system is effective for controlling volatile
organic compounds as well as methane. However, the data
also demonstrated the need for further monitoring for
potential migration of small amounts of landfill gas
containing VOCs.
In light of these results, a continuing VOC sampling
program to supplement the current methane gap monitoring
-------
program was designed and set forth in the RAP at Section
I . K.
This supplemental program will consist of: 1) the
collection of subsurface gas samples from a depth of 30
inches at 14 locations around the perimeter of the
collection system; 2) the collection of subsurface gas
samples at depths of .10, 20, 30 and 40 feet from one deep
well cluster beyond the collection system; 3) the collection
of ambient air samples at three locations around the
Landfill; 4) the collection of thermal oxidizer emission
samples (stack testing ir the incinerator stack); and 5) the
taking of pressure readings to ascertain whether a. vaccuum
is created by the collection svsten. The sampling will be
performed on a quarterly basis during the initial year of
the program and, if approved hv the State, on an annual
basis thereafter. This data will asnist in monitorina the
continued effectiveness of the gas rollection system and in
determining whether the svstem needs adjustment or
enchancement.
(b) Projected Effects of Pemediation
As described infra, once the RI was completed, an
evaluation of remedial alternatives began for development of
the FS. As different site-appropriate alternatives were
conceptualized, it became necessarv to investigate the
potential environmental impacts associated with thope
remedial alternatives. In particular, the ronedial
ilternativp.s which utilize the elements of arounrlv/ater
-17-
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recovery, treatment and recharge into the aquifer (more
fully described belcw in Section II.D.2), presented
cuertions with respect to potential local impacts. The
areas of concern were: 1) the potential mounding effects
due to recharge of larae amounts of water into the aquifer
at one location; 2) the effectiveness of the treatment
system (in this case air stripping, .described in Section
II.D.2) in attaining the water quality requirements mandated
by ARAHs and contained in the RAP; and 3> the air qualitv
impacts associated with air stripping. The first and third
items above wpre also of concern to the public as discussed
in the Public Responsiveness Sumr.flrv attached hereto.
(i) Mounding Effects of Recharae
The Town's grouncwater consultant, Geraghty & Miller,
prepared mounding calculations which Demonstrated that the
recharge of 1.5 MOD of groundwater into the aquifer at t-.he
water table would have no impact on the groundwater beyond a
point which is, at a maximum, 1300 ,reet upgradient of the
recharge, i.e., the stagnation point. Furthermore, they
found that the effects of the rechargo would occur in the
shallow 'portion, of the aquifer. The calculations performed
are described in a letter dated September 8, 1987 from G&M
to Mr. John Molloy of Koltzmacher, McLendon & Murrell,
contained in the administrative record. These calculations,
as well as calculations demonstrating the area of the
aquifer influenced by the proposed groundwater recovery.
wells, were used in Determining appropriate locations? for
_i p_
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groundwater recharge in the various remedial alternatives
i
evaluated,
(ii) Quality of Water Treated By Air Stripping
. A pilot test was conducted in July 1987 to demonstrate
the potential effectiveness of air stripping for the
treatment of the groundwater. A portable air stripping
tower was used for the pilot test as described in a report
dated July 1, 1957 prepared by Hydro Group, Inc., entitled
"Air Stripping Design Report."
The test was conducted by pumping water from the most
heavily contaminated monitoring well in the plume to the
pilot air stripper for treatment. Doth influent and
effluent water was sampled for VOCs. Results of the test
indicated a potential removal efficiency of 98.9C% for
benzene (used as the indicator for all VOCs), thereby
demonstrating the remedial effectiveness of air stripping.
Continued monitoring of the water quality of discharge from
the treatment unit will be required as part of the
comprehensive remedial program.
(ill) Quality of the Air Discharged by the Treatment
Unit : '. '
A modeling study was performed to evaluate the
potential impacts of emissions from an air stripper, located
at the Landfill, on air quality in the neighborhood abutting
the Landfill. The modeling procedures and results are
presented in a September 1987 draft report entitled,
"Evaluation cf Air Stripper Emission Impacts en Air duality
at the Oyster Bay Solid Waste Disposal Complex", prepared by
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RTP Environmental Associates and made part of the
administrative record. The results indicate that, under
worst case conditions, .air discharge from the air stripper
will fall well below ARARs and that the maximum impact of
these emissions will occur within the boundaries of the
Landfill propertv.. There will be no significant impact on
the abutting communities.
(iv) Odor Study
Subsequent to the air modeling study, RTP conducted an-
odor threshold analysis for the projected air stripper
emissions to confirm there would be no odor problem offsite
of the landfill, if the treatment facility vas located on
Landfill property. The results of the analysis are
presenter! in a letter report prepared by FTP on October 8,
198?/ entitled, "Preliminary Assessment of Odor Potential
for Proposed Air Strinping Tower."
RTP compared peak short term emission? at the Landfill
boundary to recognized odor thresholds for a number of
chemical compounds existing in the Landfill pluir.e. The
study demonstrated that no odor threshold* v;ere exceeded
beyond- the Landfill boundary. The study concluded that at
the low contaminant concentrations to bo emitted by the air
stripper, no odors would be detectable offsite.
Despite these copacetic results, continued monitoring
of the quality of the treated water and the operating
conditions of the stripper will be recuired to assure
-.10-
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continued protection of air quality in the vicinity of the
Landfill. -
II. REMEDIAL ALTERNATIVES EVALUATION
A. Process
The remedial alternatives for the Old Sethpage Landfill
Site were developed and evaluated using as guidance the
Comprehensive Environmental Response, Compensation and
Liability Act of 1980 (CERCLA), as amended by the Superfund
Amendments and Reauthorization Act of 1986 (SARA), the
National Oil and Hazardous Substances Pollution Contingency
Plan (NCP) , 40 CFR §30.0.68, and the EPA "Guidance on
Feasibility Studies Under CERCLA".
The- major objective of the Old Bethpage Feasibility
Study ("FS") was to evaluate remedial alternatives using a
cost-effective approach consistent with the goals and
objectives of CERCLA. According to Section 121 of CERCLA,
the recommended remedial alternative should protect human
health and the environment, should be cost-effective, and
should utilize permanent solutions and alternative treatment
or resource recovery technologies to the maximum extent
practicable. The proposed remedy must also attain the ARARs
that have been identified.for the site on Table 1, Section
300.68(e) of the NCP outlines procedures and criteria- which
are used in selecting the most cost-effective alternative.
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TABLE'1
APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS
IDENTIFIED FOR THE OLD 3E7HPAGE LANDFILL (ARARs)
I. GROUNDWATER AQUIFER AND TREATED GROUNDWATER DISCHARGE
REQUIREMENTS*
Inorganics mg/1
Barium 1.0
Cadmium 0.01
Chloride • 250
Chromium (hex) 0.05
Copper 1.0
Cyanide 0.2
Iron 0.3
Lead 0.025
Magnesium 35
Mangenese 0.3
Mercury
Silver
Zinc
Total Dissolved Solids
Nitrate
Sulfate
Phenols (total)
Volatile Organic
Compounds (VOCs)
Vinyl Chloride
Methylene Chloride
1,1 Dichloroethane
1, 2 Dichloroethane
1, 1 Dichloroethene
1,2 Dichloroethene (trans)
Trichloroethylene
1, 1/--1 Trichloroethane
Chloroform
Carbon Tetrachloride
It 2 Dichloropropane
Bromcdichloromethane
Tstrachloroethene
Chlorodibromomethane
Chloroethane
Bromoform
Benzene
Toluene
Xylene (all isomers)
500**
10
250
0.001
2.0***
50
50
0.8
0.07
50
5.0***
50
100
5
50
50
0.7
50****
50****
50
non-detect
50
50
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Ethylbenzene
Chlorobenzene
Dichlorcbenzene
ortho-and para-
all isomers
Total VOCs (for groundwater)
Total VOCs (for discharge)
50
20
4.7
50****
50
100
* This list of compounds is not exhaustive of the
applicable Standards and Guidance Values. The list
represents the most prevalent compounds found at the site.
The cleanliness criteria listed herein are Standards and
Guidance Values issued by the NYS Department of .
Environmental Conservation for the protection of Class GA
waters found at 6 NYCRR 703 and in the Technical and
Operational Guidance Series (TOGs) dated April 1, 1987. If
during the course of the remediation additional compounds
should be detected, the most stringent.of the requirements
obtained from these two sources shall apply. For any VOC
which does not have a specific Standard or Guidance Value,
the applicable limit shall be 50 u/.l.
**
Federal Standard promulated by the U.S. Environmental
Protection Agency (EPA).
***
For these compounds, the Maximum Contaminant Level
(MCL) under the Federal Safe Drinking Water Act is less than
the State Standards or Guidance Values and therefore shall
apply. - Should additional MCLs be promulgated by the SPA,
then the most stringent standard shall apply.
****
These compounds do not have_a_specific State Standard
or Guidance Value and therefore the"applicable limit is
50 u/1.
II. AI3 DISCHARGE 55QUIHSMENTS
Constituent
Vinyl Chloride
Freon 13
Methyler.e Chloride
1,1-Dichiorcethane
1,2-Dishlcroether.e
Chlorofom
!;,•! , 1, -Trichloroethar.e
Ambient Air Concentrations
•NYSDEC Ascual Guideline*
- (ug/m3)
4.00E-01
3.00E-02
1.171^-03
2.702+03
2'. 53E+G3
1.672+02
. 3.30E+04
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r-' r'
Table 1 con't.
Zthylbenzene
Chlorobenzene- -
Dichlorobenzene
ortho-and para-
all isomers
Total VOCs (for groundwater)
Total VOCs (for discharge)
50
.20
4.7 '
50****
50
100
* This list of compounds is not exhaustive of the
applicable Standards and Guidance Values. The list
represents the most prevalent compounds found at the site.
The cleanliness criteria listed herein are Standards and
Guidance Values issued by the NYS Department of
Environmental Conservation for the protection of Class GA
waters found at 6 NYCRR 703 and in the Technical and
Operational Guidance Series (TOGs) dated April 1, 1987. If
during the course of the remediation additional compounds
should be detected, the most stringent of the requirements
obtained from these two sources shall apply. For any VOC
which does not have a specific Standard or Guidance Value,
the applicable limit shall be 50 u/1.
** Federal Standard promulated by the U.S. Environmental.
Protection Agency (EPA).
***
For these compounds, the Maximum Contaminant Level
(MCL) under the Federal Safe Drinking Water Act is less than
the State Standards or Guidance Values arid therefore shall
apply. Should additional MCLs be promulgated by the EPA,
then the most stringent standard shall apply.
****
These compounds do not have a specific State Standard
or Guidance Value and therefore the applicable limit Is
50 u/1.
II. AIR DISCHARGE REQUIREMENTS
Constituent
Vinyl Chloride
Freon 13
Methylene Chloride
1,1-Dichloroethane
1,2-Dichlcroethe.-e
Chloroform
1,1,1,-Trichloroethane
Ambient Air Concentrations
NVSDEC Annual Guideline*
(ug/m3)
4.00E-01
3.00E-02
1.17E+03
2.70E+03
2.621-5-03
-.1. 672+02
. 3.80E+04
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Table 1 con't.
Carbon Tetrachioride l.OCE-^02
1,2-Dichlcroethane 2.0CE-r01
Trichloroethylene 9.00E-f-02
1,2,-Dichloropropane 1.17E+03
Broraodichloromethane 3.00E-02
Tetrachloroethene 1.12E+03
Chlorodibrbmomethane 3.00E-02
Bromoform 1.67E-I-01
Benzene l.OOE+02
Toluene 7.50E+03
Ethyl Benzene 1.45E+03
(m) Xylene 1.45E+03
(oip) Xylene 1.45E+03
(m) Dichlorobenzene 3.00E-02
(o) Dichlorobenzene l.OOE+03
(p) Dichlorobenzene 1.50E+03
Chloroethane 5.20E+04
1,1,-Dichloroethylene 6.67E+01
Chlorobenzene 1.17E-I-03
Ammonia 3.60E+02
* Establish per NYS Department of Environmental Conservation
Air Guide No. 1 for Control of Toxic Ambient Air
Contaminants. If any federal National Ambient Air Quality
Standards or National Emission Standards for Hazardous Air
Pollutants are promulgated which are more stringent than
these State guidelines, the more stringent standard shall
apply.
III. METHANE GAS CONTAINMENT REQUIREMENTS
- 6 NYCRU Part 360
Zero Percent Methane Gas Migration Limitation
Measured at Landfill Boundary
Condensate Treatment in Compliance with SPDES or
other applicable treatment regulation.
IV. LANDFILL CAP REQUIREMENTS
6 NYCRR Part 360
- Capping Cover Material Equivalent to 18 inches
of Clay at Hydraulic Conductivity of 10-
centimeters per second or less
•12 inches top soil hydrosesded
Side Slopes 3 to 1 or less as long as a stable
side slope is maintained
V. LEACHATE CONTROL REQUIREMENTS
6 NYCRR Part 360
Sludge disposed of-in licensed
disposal facility
Effluent disposed of per
County Ordinances
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A five step process was developed and used tn r.eet the
FS objectives. The foliowir.c is a sumir.arv of that process.
* * L
The first step was to evaluate potential human health
and environmental effects associated with releases and
threatened releases of hazardous substances from the sit*».
The criteria 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 contaminants.
The next step was to develop a range of potential
available remedial technologies that could be used to
remediate.the site. Remedial technologies where treatment
permanently and significantly reduces the toxicity, mobility
or volume of the hazardous substances, were preferred over
remedial technologies not involving such treatment. These
technologies were initially pre-screened on a technical
basis. Pased on the screening, a list of individual
remedial technologies appropriate to site condition? and
consistent with the remedial action objectives was
developed.
the site-appropriate remedial technologies were then
combined into a number of preliminary remedial alternatives.
The bases for the various combinations were: the technical
and logical interrelationship between separate technologies,
Section 300.63.(f) of the NCP requirements regarding the
general categories of. alternatives which nust be considered
-------
^nd CERCLA Section 121 provisions regarding the preference
for remedial actions that utilire permanent solutions and
alternative treatment or resource recovery technologies.
The summary below reflects guidance set forth in a
memorandum issued by EPA on December 24, 1986, entitled,
"Interim Guidance on Superfund Selection of Remedy",
intended to aid agencies in the selection of remedial
actions pending EPA'? upcoming revisions cf the NCP. EPA's
interim guidance reauires analysis of alternatives
involving: 1) treatment options; ?) containment of waste
options with little or no treatment, but providing
protection of human health and the environment primarily by
preventina exposure or reducina the mobility of the waste;
*
and 3) the no-action alternative, ^hese three categories of
alternatives were considered through th*» detailed evaluation
process of the Old Bethpage Fpasibility Study.
The fourth step in the process was to develop an
analysis of these alternatives as delineated in Section
300.68(g) of the NCP. The three broad criteria utilized in
the screening were: the relative effectiveness in
minimizing threats; the engineering feasibility of the
alternatives; and the cost of implementing the remedial
action.
Treatment options and the no-action alternative v:ere
carried through this step. This general analysis was
intended to reduce the number of remedial alternatives to
those appropriate for detailed evaluation.
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The final step as outlined in Section 300.68(h) of the
MC? was integrated with step four above to provide a
detailed analysis of all the site-appropriate alternatives.
Treatment, containment, and no-action alternatives were
included in this analysis. For each alternative, the
following factors, were considered as appropriate?
An evaluation in terms of engineering
implementation, reliability, and constructability;
An assessment of the extent to-which the
alternative was expected to effectively prevent,
mitigate, or minimize threats to, and provide
adequate protection of human health and the
environment. This included an evaluation of the
extent to which the alternative attained or
exceeded ARARs for the site.
An analysis of whether recycle/reuse, v/aste
minimization, waste bicdegradation, destruction,
cr other advanced, innovative, or alternative
technologies were appropriate to reliably minimize
present or future threats to human health and the
environment (performed in initial screening stage);
An analysis of any adverse environmental impacts,
methods for mitigating these impacts, and costs
of mitigation;
An analysis of institutional problems and
considerations such as the difficulty in obtainina
permits, ftas'ements etc., or th<=> contravention cr
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conflict of other State or Local laws or policies;
i
- ^A detailed cost estimate, including operation and
maintenance costs, and distribution of costs over
time. This included a cost comparison of
alternatives within each category.
B. Development of Old Bethpage Landfill Alternatives and
and Initial Screening
Remedial responses for the Old Bethpage Landfill
addressed the control and cleanup of contaminated
grcundwater with the purpose of preventing such
contamination from reaching the Farmingdale public drinking
water supply wells hydraulically downgradient of the plume
of groundwater contamination. Actions to control rhe source
of'Such contamination (the Landfill), and those to enhance
a,nd expedite the cleanup of the groundwater were also
evaluated. The existing remedial source control measures at
the site were evaluated for their effectiveness in achieving
the same purposes.
The objectives of the remedial actions evaluated were:
1) to prevent, to the extent feasible, future contaminant
migration from the Landfill; 2) to control the source of the
contamination, i.e., the Landfill; 3) to prevent further
expansion of the offsite groundwater plume of contamination;
and 4) to remediate the plume to ARARs, Mew York State
Groundwater Standards and Drinking Water Guidelines. These
objectives are based on a review of the requirements for
protection of the public health and the environment and or. a
review of the ARAR's .and EPA Draft Guidelines for Remedial
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Action for Contaminated Grouncv:at-.er at Superfund Sites (FP.a
October 1-986)
For the C_Ld_ Tethpaae Landfill, remedial technologies .
were pre-ncreened for technical suitability. The
pre-screening criteria included the following:
1. Applicability - physical and chemical suitability
for rsite conditions;
2. Feasibility - the ability of the remediation to
achieve the desired objectives;
3. Inplementability - ability of the remediation to
be employed at the site given the facts of the site
and its environs;
4. Safety - the identification of any alternatives
which were precluded for health and safety
considerations.
The evaluations and conclusions for each alternative in
the initial screening process are set forth in '"able .?.
?otne remedial measures identified in the initial
screening were already in place pursuant to the Landfill's
Part 360 permit requirements an pore fully described sunra
in Section 1.3.4. The RAP provides for the continuation *nd
expansion, if necessary, of these measures and monitoring to
confirm their continued effectiveness in meeting the
requirements of the RAP.
Based on Table 2, two categories of response actions
were identified for further consideration. These were: 1)
containment and removal of the contaminated qroundwater
-26-
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Description of Remedial Actions
esponse Ac! ion
.o Action
ontainment
TABLE 2
INITIAL SCREENING OF ALT'RKUATIVaa
Description
No installation of remedial technology,
although some form of monitoring may be
required. ,
Containment of contaminants by physical
means such as capping and subsurface
barrier walls.
Applicabil JtV. Feasihj 1 j ty f Tmplnmp nt ;\\\ i 1 i t-y
iSafety
Not applicable, as remedial technologies have already
been put in place.
Capping Is considered to bo feasible and Is currently
underway at the landfill as described in Section 1.1
and as per specifications required in 6 NYCRR Part 360
closure permit. Ihe great depth (1000 fu) to a con-
tinuous confining layer precludes the installation of
barrier walls using current technology.
umping
ol lection
aversion
'omplete Removal
'artial Removal
Removal of contaminated ground water,
liquids by pumping or removing sedi-
ments by dredging.
Collection of leachate, gases, and
water-borne sediments.
Re-directing surface water flow away
from the site.
Removal of all wastes and contaminated
soils and sediments from the site and
restoration.
Removal of some wastes and/or contami-
nated soil and sediments from the site.
Pumping of contaminated ground water is under consi-
deration.
Systems to collect leachate and gases are already in
place. I ho final capping program is intended to- pre-
vent transport of contaminated sediments.
Not applicable as there is no flowing surface water
body within proximity of the site. Containinal ed sedi-
ment transport by runoff is prevented by the capping
program.
Ihis action has never been undertaken for a sile as
large as the Old Oethpage Landfill, and would have
serious inherent environmental hazards such a:; inicon-
control loble emissions. Since an action of Ihis
magnitude has not been proven effective or possible,
it is not being considered. Additionally, any oil-
site contamination would remain after partial or com-
plete removal of the waste.
•No benefit is discernible from partial removal us
wastes at the site ure relatively uniform, thus this
action is not being considered.
-------
Response Action
On-aite Treatment
Description
iff-site Treatment
Treatment or aolidification of waatea
on-site to render them harmless by phy-
sical, cheaicai or biological treatment.
Feasibility. Imp I erne n t. a b i 1 i ty ,
Treatment of waatea off-aite to render
them harmleaa by physical, chemical or
biological treatment.
& Safety
Waste Treatment requires removal of wastes from their
present place, and for reasons given under "Complete Re-
moval", treatment of wastes is not being considered.
Solidification for the amount of wastes presunt at the
landfill has never been proven effective or possible
and thus is not being considered.
Ground-Water On-site treatment of contaminated ground
water is being considered.
Waste Treatment requires removal of wastes from their
present place, and for the reasons given under "Complete
Removal", off-aite treatment la not being considered.
n-Situ Treatment
.orage
i-site
Treatment of wastes in place by physi-
cal, chemical or biological treatment.
Temporary or permanent storage of
waste.
Disposal of wastes on-site in a land-
fill or other waste management unit.
Ground-Water Off-site treatment of contaminated tj round
water at a Public-Owned Treatment Works (POIW) is being
considered.
In-Situ treatment of an amount of waste such as exists
at tlie landfill has never been accomplished nor been
proven possible* tit us this action is not being con-
sidered. Hydrogeologlc conditions In the off situ plume
also make In-situ treatment of this contamination In-
feasible. The vertical thickness of the plume makes
In-situ treatment Infeaslble. I n- s I tu methods are
suitable for treatment of shallow groundwater plumes.
Conditions In shallow groundwater are more amenable to
supporting the bacterial populations which degrade
wastes.
The site is currently a landfill, so this action is
not applicable by definition.
Ihia site is currently a landfill, and this
wuld presumably require excavation and
for reasons given under "Complete Remaval", thi
action ia not hfiinn
Ull j
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Reaponne Aci. inn
Description
Off-site Disposal Disposal of wastes off-aite in a land-
Alternate Hater
Supply
Relocation
.fill or other waste management unit.
Provision of clean drinking water in
the event of contamination; this would
include treatment of the existing sup-
ply or providing another supply.
Temporary or permanent relocation of
area residents.
Applicability, Feasibility, Implement ability
& Safety
This action would require removal of wastes, and is
not being considered for the reasons given under
"Complete Removal".
Contamination has not been detected in the naareuL
downgradient supply wells, however, monitoring of
these supply wells and intermediate wells is on-going
and long-term monitoring is being considered.
At this time, no hazard which would warrant relocation
has been identified at this site, therefore, this option
will not be considered.
-------
through punping .and subsequent treatment and 2) the
continued'nonitoring of the plune with the provision of an
alternative water supply, if necessary. The~s« two"
categories of response actions were further developed into
the following two conceptual designs:
1. Development of a long-term groundwater monitoring
program to provide detection of potential
contaminant movpment toward the Farmingdale public
v/ater supply wells. Such detection would provide
timely well replacement or treatment system
installation, if contamination imminently
threatened these public wells.
2. Pumping of the contaminated groundwater through a
system of recovery wells, establishment of a water
treatment system on or near the Landfill, and
subsurface or surface Disposal- of the treated
water.
C. Testing and Analysis of Conceptual Dftsian No. ."!
Flow and solute transport models, described in detail
in Appendix II, were executed to evaluate the feasibility cf
actively remediating all or part of the Landfill Teachate
plume through pumping. The results of the flow modeling
indicated that approximately 5 million gallons per day
("fiGD") of groundwater would need to be pumped to
hydraulically contain the entire area affected by Landfill
leachate. The extraction of that amount of water was
concluded to be ir.feasiblp because:
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1. The DEC' ? water conservation policies for this
< '
.area of Long Island restrict the extraction of
such a large amount of water from the aquifer
. without replacing it in the vicinity of the
extraction (see Environmental Conservation Law
Article 15, specifically Section 1527 and
regulations promulcated thereunder at 5 NYCRR
602). The discharge of this amount of water
outside a 1-nile area would contravene that
policy. DEC stated it would prohibit a
consumpti"e withdrawal of that magnitude, outside
the 1-mile radius. (See Spitz letter dated July
20, 1986 contained in the administrative record.)
2. The onlv sizable area within a 1-n.ile radix:s of
the Landfill available for the recharge of such a
large volume of water would be in the Pethpage
State Park. Recharge in the Park would interfere
with the hydraulic control of the recovev wells
thereby.defeating a major purpose of the remedial
effort. Such enormous recharge would also
potentially affect the Farmingdale public drinking
wells downgradient of this recharge area. The
protection of these wells is also one of the major
purposes of the remediation.
The extraction of 5 MOD was also considered inappropriate
for the following reasons:
1. Volatile organic compounds were found within an
-23-
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-irea substantially .smaller than the leachate
'indicator plur.e.
2. Concentrations of leaehate. indicator parameters
outside the .organic plume but within the Landfill
leachate plume, although elevated over background,
did not violate drinking v/ater standards.
In consideration of these limitations, subsequent
modeling efforts were directed at containing total volatile
organic compounds (TVOC) at the defined edge of the organic
plume. Flow modeling indicated this portion could be
contained with a pumpage of approximately ?. .5 MGD. This
amount cf water pumpage appears feasible since it would
effectively contain the edge of the TVOC plume as defined
and would not withdraw substantial amounts of potable water
from the aquifer.
Solute transport" simulations were executed for both
abated and unabated scenarios, using various values for
natural retardation and decay (removal) processes.
Subsequent pump itesting verified important input parameters
to the model. See "OBSWDC Aquifer Test for Evaluating
Hydraulic Control of Leachate Impacted Groundwater", G&K,
September 1987. Pased on these analyses, it has been
concluded that the TVOC plume can be contained within the
boundaries of Bethpage State Park, with an appropriate
recovery well nystem operating at a rate sufficient to
maintain hvrfraulic control.
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A comparison of the possible variations of this
conceptual remedial design is discussed in the next section.
D. Comparison and Detailed Evaluation of. Appropriate
Alternatives for the Old Bethpage Landfill"'
This section identifies and describes the remedial
actions that were considered appropriate for the Landfill
plume and presents the detailed analyses of those
alternatives. *(See page 30a). Seven groundwater remedial
alternatives were identified which represent the two
appropriate general remedial responses set forth in Section
II.B above.. The first remedial response, termed
"Alternative VJater Supply" (Alternative No. 1), consisted of
monitoring the plume using the existing monitoring well
system and the timely replacement or treatment of
downgradient water supply systems should they .become
threatened. The second category of response action was to
hydraulically control, by capture and extraction, the TVOC
plume through the installation and operation of barrier
pumping wells located at the leading edge .of that TVOC
plume. Alternatives Nos. 2 to 7 represented the possible
variations of this response action, setting forth a variety.
of treatment and disposal methods. These alternatives are
listed below together with Alternative No. 1, and are
described in subsequent subsections.
Alternative No. 1 - Continued Monitoring and
Alternative Water Supply.
Figure 7.
-•30-
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All of these alternatives included the basic remedial
•
components for closure of the landfill. These components
are landfill capping, leachate Control and methane gas
collection. These programs are ongoing and were evaluated
as previously described.
Since these remediation elements were already in place
or in the construction process at the site, their existence
and approximate cost were considered constants in the
comparison and detailed evaluation of the groundwater
remedial alternatives evaluated.• The Town estimated the
approximate past and future costs, including estimated
operation and maintenance expenses, of these source
remediations to be 16 million dollars (capping - $10
million; leachate control $2 million; methane gas - $4
million), of which almost 50 percent has already been
expended. This amount does not include the additional costs
of each groundwater remedial alternative, which are set
forth for each alternative in the following analyses below.
-30a-
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BETHPAGE STATE PARK
BETMPAGE STATE PARK LIMITS
——' OBSWOC UMITS
-------
Alternative No. 2 - Removal cf groundwater by pumping
I
and piping to the Landfill
property for use in the
operation of the proposed Resource
Recovery Facility (RRF) and
discharge of waste water from the
the RHF into the sanitary sewer on
Winding Road. Figure 8.
Alternative N'o. 3 - Removal of grcundwater by pumping
and piping to the Landfill
property for treatment
to remove TVOC's and discharge
of the treated waste waters to
the sanitary sewer system on
Winding Road. Figure 9.
Alternative No. 4 - Removal of the groundwater by
pumping and piping it to the
Landfill prcperty for partial use
in the proposed RRF to remove
TVOC's and for treatment and
discharge of the remaining
water to the sanitary sewer
system on Winding Road. Figure
1.0.
Alternative No. 5 - Removal of groundwater by pumping
and pipincr it to a treatment
facility to remove TVCC's, and
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BETHPAQE STATE PARK
8ETHPAGC STATE PARK LIMITS
08SWOC LIMITS
FIGURE 8
1KB
-------
BETHPAGE STATE PARK
8ETHPAGE STATE PARK LIMITS
OBSWDC LIMITS
FIGURE 9
-------
BETHPAGE STATE PARK
BETHPAGE STATE PARK LIMITS
OBSWOC LIMITS
PIG USE 10
ALTERNATIVE NO. 4 (
-------
discharge cf the treated water to
a leaching field within Bethpage
State Park boundaries. Figure 11.
Alternative No. 6 - Removal of grcurdwater by pumping
'and piping it to a treatment
facility to remove TVOC's and
disposal in a storm sewer en
Plainview Road. Figure 12.
Alternative No. 7 - Removal of groundwater by pumping
«nd piping it to the Landfill
property fcr treatment to
remove TVOC's and discharge of the
treated water to a recharge
basin/leaching well system
upgradient of the Landfill.
Figure 13.
Analyses of the remedial action alternatives was
divided into two major categories: non-cost criteria
analysis and cost analysis. The non-cost criteria analysis
addressed considerations of technical feasibility,
institutional issues and environmental and public health
impacts. The cost analysis reviewed the major cost items,
discussed important considerations in the cost estimation
and presented the estimated costs of each alternative.
1. Alternative No. 1
(a) Description
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BETHPAGE STATE PARK
SETHPACE STATS PARK LIMITS
08SWOC LIMITS
FIGURE 1
ALTERNATIVE NO.
-------
BETHPAGC STATE PARK
8ETHPAGE STATE PARK LIMITS
•—« OBSWOC LIMITS
ALTERNATIVE NO. 6
-------
BETHPAGE STATE PARK
BETHPAGE STATE PARK LIMITS
OBSWOC LIMITS
13
• y»-=-a
= ==.=-£
ALTERNATIVE NO. 7
-------
The sole intent cf this alternative would be to insure
i
that the local residents have a -supply of potable water.
•
This could be accomplished by monitoring groundwater quality
and plume dynamics on a periodic basis using the 23
monitoring wells installed in the Park and other selected
wells in the vicinity. A recommended monitoring program
would consist of quarterly sampling and subsequent analyses
for a selected list of contaminants characteristic cf the
plume. Under such a program, contaminants which could
potentially migrate toward a supply well would be detected
before they reached that well. . This would allow for timely
well replacement in a non-contaminated portion of the
aquifer or installation of a water treatment system.
(b) Non-Cost Criteria
(i) Technical Feasibility
Implementation of Alternative No. 1 would be
technically feasible because the network of monitoring wells
located between the Landfill and the downgradient
Farmingdale public supply wells could be monitored on a
regular basis to provide continual data on plume dynamics.
Should monitoring indicate contaminant migration toward
supply wells, well replacement or treatment system
installation could be accomplished before the contamination
reached a supply well.
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(iij _Environmental Impacts
Alternative No. 1 would have the least beneficial
effect on the environment since it provides no improvement
to the groundwater resource. Therefore, it would not
satisfy the reduction of toxicity, mobility or volume
criteria and would not meet the ARAR's criteria fcr the
site. Compared with the other alternatives/ there were some
positive aspects ot Alternative No. 1, such as no loss of
potable groundwater frcrn pumping, no increase in air-borne
contaminants from water treatment processes and no decrease
in Eethpage State Park aesthetics from viyible remedial
structures.
Mil) Public Health Analysis
Alternative No. 1 would provide long-term public health
protection fcr the public supply wellb through timely
detection of the migration ot contaminants attributable to
the Landfill before they reached those supply wells.
(iv) Institutional and Legal Issues
The State found Alternative No. 1 unacceptable as a
response action for the Landfill leachate plume because it
would not meet the ARAR's identified for this site or the
criteria fcr reduction of toxicity, mobility and volume of
contamination.
(c) Cost Analysis
The total estimated cost of Alternative Mo. 1 was
J700,GGC. This was based en quarterly monitoring of
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approximately 30 wells (analysis of samples for organic and
inorganic parameters), 1987 prices, and the present worth
- . i
estimated "over a period of 10 years with an annual interest
rate of 8 percent.
The total cost of this alternative, including the
aforementioned source remedial measures, was approximately
$16,700.000.
2. Alternatives Nos. 2 to 7
The objective of these alternatives would be to protect
downgradient public water supply systems and to clean up the
groundwater plume through containment and collection of the
TVOC plume. After capture and collection of the plume by the
barrier pumping wells, the water would be conveyed through an
underground piping system to a location where it would be
treated to remove its organic and inorganic contaminants.
This would be dona through the use of a variety of treatment
mechanisms including-air stripping towers and, if necessary,
carbon adsorption columns and an iron removal system. After
treatment, the water would be disposed either through recharge
to the ground or discharge to surface waters via sanitary or
storm sewers. The general components of these alternatives
were the same with respect to the recovery well system and
piping transport to treatment systems. They differed only
in the discharge locations studied and the treatment systems
appropriate to the alternative proposed.
General components of this remedy included: ground-
water well pumping., conveyance to a collection tank,
transport to a treatment unit (by gravity or pumping, depending
upon whether the treatment unit was located upgradient or
-------
downqradient of the plume), treatment to attain contaminant
concentration levels that meet APAR ' s and ultimate
conveyance to a disposal point.
As discussed previously, the groundwater well pumping
system would have a combined, capacity of approximately 1.5'
MGD and be located in Bethpage State Park as shown in
Figures 8-13. Pumped water would be discharged into a
collection tank located within Bethpage State Park. The
collection system remained the same for Alternatives Nos. 2
to 7. The treatment system site and the disposal point and
method varied for.each alternative. The treatment
technologies selected for the removal of organic
contaminants from the plume were air stripping through a
packed tower or a cooling tower, followed by> as needed,
activated carbon adsorption. Gross amounts of the lighter,
volatile organic compounds, such as chlorinated solvents- and
light petroleum fractions, could be removed relatively
inexpensively and efficiently by air stripping. The
remaining trace amounts of light organics and the heavier,
less volatile organics might require a more expensive and
technically more comple:: activated carbon process. These
process units would be preceded, as necessary, by an iron
removal system to remove any excess iron concentration. The
technical concepts and design considerations involved in
applying these treatment processes are presented in Appendix
III and in Section I.E. of the RAP; a schematic of the
treatment system is provided in Figure 14.
-36-
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FIGURE
CONCEPTUAL "JfiEATMENT SYSTEM-FLOW SCUEMATIC
-------
3. Alternative No. 2
(s) •Description
Alternative No. 2 (Figure 8) included the well .
collection system and a piping system to convey the
extracted groundwater from the collection tank to the
proposed RRF for utilization as cooling tower "make up" and
process water. If the RRF was permitted by DEC, it would be
built in the Landfill complex in the vicinity of the
present-day incinerators. After being used at the proposed
PRF, the waste waters would then be' discharged to the Nassau
County sanitary sewer system en Winding Road.
(b) Non-Cost Criteria
(i) Technical Feasibility
As discussed previously, flow and transport models as
well as pump testing were executed to test the technical
feasibility of actively remediating all or part of the
Landfill leachate plume fay pumping. The results of these
efforts indicated that t-.he defined edge of the
-------
could not he implemented if the proposed RRF did not require
I
or have capacity for 1.5 MGD of coolinc water. It was
anticipated that the proposed RRF would require only 0.5 MGD
and this quantity would be variable each day. If that
capacity was shown to be the actual capacity of the RRF then
Alternative No. 2 would not be feasible and Alternative No.
4, providing for a limited use of the RRF in combination
with sewer disposal, would need to be substituted.
(ii) Environmental Impacts
The beneficial effect of Alternative No. 2 on the
environment would be its improvement of the quality of the
groundwater. There would be some adverse effects, however,
which include: a loss of some potable groundwater as a
result of pumpage (some quantity of clean croundwater would
unavoidably be pumped) and use by the RRF; an increase in
airborne emissions from the RRF (although the RRF would be
required under its permit to meet all applicable air
emissions standards); and a decrease in Bethpage State Park
aesthetics due to visible remedial structures and
components.
(iii) Public Health Analysis
Alternative No. 2 would provide long-term public health
protection through the combined actions of containment of
the contaminant plume, removal of contaminants from the
groundwater recovery system, and groundwater monitoring to
detect any contaminant migration.
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(iv) Institutional Issues
Alternative No. 2 included discharge of RRF effluent-
*
water to a Nassau County sanitary sewer. Discharge of water
into a publicly-owned treatment works (sewer) would require
a sewer discharge permit. Preliminary discussions with
Nassau County indicated that this discharge into- the
County's sanitary sewer system from the RRF would be
allowed. However, New York State informed the Town that it
was not willing to accept this remedial alternative because
implementation would be contingent upon future permit
approval of the RRF.
(c) Cost Analysis
The total estimated cost for the groundwater portion of
Alternative No. 2 was $2,275,000. The capital and annual
operating costs were estimated based on the Town's estimated
flow of 1.5 MGD. All estimates were based on 1987 prices
and the present worth of.the operating cost was estimated
over a period of 10 years with an annual interest rate of 8
percent. The above cost did not include land purchasing,
building construction, or personnel expenditures required
for operating and maintaining the facilities.
The total cost of this alternative, including source
remedial measures, was $18,275,000.
4. Alternative No. 3
(a) Description
Alternative No. 3 (Figure 9) consisted of the recovery
well system and a conveyance system from the collection tank
to the treatment site and then to the disposal site. The
-39-
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proposed point of disposal was the Nassau County sanitary
cewer on Winding Road. The proposed treatment facility
would be bui.lt at the southeast corr.er of the Landfill
property and would consist of the treatment systems
described in Section II.D.2 above.
(b) Non-Cost Criteria
(i) Technical Feasibility
Flow and transport models and pump tests were executed
to test the technical feasibility of actively rer.ediating
all or part of the Landfill leachate plume by punning. The
results of these efforts indicated that the defined edge of
the TVOC plume could be hydraulically controlled by wells
operating at an appropriate pumping rate. The To\m
estimated that the approximate volume to be pumped to
maintain hydraulic control of this plume would be 1.5 MGD.
Based on that pumped volume, Alternative *!o. 3 was
technically feasible with respect to plume collection.
However, a factor which potentially limited the
appropriateness of this alternative was the actual capacity
of the sanitary ?ewer lines. A prelininarv study was
performed by the Town on the sewer line along winding Road
which showed that the line's excess capacity might be 1.5 :
MGD. Additional investigations would have been needed to
confirm this estimate.
(ii) Environmental Impacts
Alternative No. 3 would have a beneficial effect on the
environment throuah containment of the contaminated plume
-------
and improvement of the quality of the groundwater resource.
i
There would be sotr.e adverse effects, however, which
•
included: a loss of some potable groundwater as a result of
pumpage, an increase in airborne emissions from the
treatment facility (although any treatment facility woul'd be
required to meet all applicable air emissions standards),
and a decrease in Bethpage State Park aesthetics due to
visible remedial structures and components.
(iii) Public Health Analysis
Alternative No. 3 would provide long-term public health
protection through the combined actions of containment and
removal of contaminants from the groundwater recovery system
and groundwater monitoring to detect potential contaminant
migration towards the downgradient public supply wells.
(iv) Institutional Issues
Alternative No. 3 included discharge of treated plume
water to a Nassau County sanitary sewer. Discharge of water
into a publicly owned treatment works (sewer) would require
a sewer discharge permit. Preliminary discussions with
Nassau County indicated that even though the Town would
treat the plume water to acceptable quality, the County
would not permit that water to be discharged into their
sanitary sewer system.
More importantly, DEC'S water conservation policies
would restrict this depletion of the groundwater from a sole
source aouifer.
-41-
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Any treatment facility must also comply with all
applicable air emissions standards and permit requirements.
It was anticipated that such requirements would be
•
attainable.
(c) Coat Analysis
The total estimated cost of the groundwater portion of
Alternative No. 3 was $4,165,000. The capital and annual
operating costs were estimated based on the Town's estimated
groundwater flow of 1.5 MGD. All estimates were based on
1987 prices and the present worth of the operating cost was
estimated over a period of 10 years with an annual interest
rate of 8 percent. The above cost did not include land
purchasing, building construction, or personnel expenditures
required for operating and maintaining the facilities.
The total cost, including source remedial measures, was
$20,165,000.
5. Alternative No. 4
[a) Description
Alternative No. 4 (Figure 10) combined the technologies
of Alternatives Nos. 2 and 3, and included the conveyance of
extracted groundwater from the collection tank to both the
RRF and a proposed treatment plant at the southeast corner
of the Landfill property. This alternative reduced the
quantity of water that would have to be treated at the
proposed RRF, since only a portion of water would be
conveyed to the proposed RRF for use as "make up" process
water. The water from the treatment facility would be
disposed of in the Massau Ccunty sanitary sewer line'on
Winding Road.
-42-
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(b) .Non-Cost Criteria
(i) Technical Feasibility
Flow and transport models and pump tests were executed
to test the technical feasibility of actively remediating
all or part of the Landfill leachate plume by pumping. The
results of these efforts indicated that the defined edge of
the TVOC plume could be hydraulically controlled by wells
operating at an appropriate pumping rate. The Town
estimated that the approximate volume to be pumped in
maintaining that hydraulic control was 1.5 MGD. Based on
that estimate, Alternative No. 4 was technically feasible
with respect to plume collection and control. However the
disposal component of this alternative might not have been
feasible. Alternative No. 4, similar to Alternative No. 3,
required discharge of treated plume water to the Nassau
County sanitary sewer system. Preliminary studies indicated
that the capacity of the sewer on Winding Road was adequate.
However, remaining lines that connect to the municipal water
treatment plant would need to have been analyzed to confirm
adequate capacity.
(ii) Environmental Impacts
The beneficial environmental effect from Alternative
No. 4 would be containment of the contaminated plume and
improvement to the quality of the groundwater resource.
Adverse effects of this alternative included: a loss of
potable groundwatcjr through pumpage, use by the RRF, and
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disposal into the sewer; an increase in airborne emissions
from both the treatment facility and the RRF (although the
treatment facility and the RRF woiild be required to meet all
applicable air emissions standards); and a decrease in
Bethpage Park aesthetics due to visible remedial structures
and components.
(iii) Public Health Analysis
Alternative No. 4 would provide long-term public health
protection through the combined actions of containment and
removal of contaminants from the groundwater recovery system
and groundwater monitoring to detect potential contaminant
migration towards a public supply well.
(iv) Institutional Issues
Alternative No. 4 included discharge of treated plume
water to a Nassau County sanitary sewer. Discharge of
treated water into the s*»wer would have required a permit.
Preliminary discussions with Nassau County indicated that it
would not permit discharge of the treated plume water into
its sanitary sewer system.
More importantly, DEC'S water conservation policies
would restrict depletion of this volume of groundwater from
a sole source aquifer.
Although discharge of the RRF effluent water into the
Nassau County Sanitary Sewer might have been attainable, Mew
York State informed the Town that the State would not accept
a remedial alternative that was contingent upon approval of
the RRF.
-44-
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Any treatment facility would need to comply with all
applicable air emissions standards and permit requirements.
It was- anticipated that such requirements would be
attainable.
(c) Cost Analysis
The total estimated cost of the groundwater portion of
Alternative No. 4 was $4,380,000. The capital and annual
operating costs were estimated based on the anticipated flow
of 1.5 MGD. All estimates were based on 1987 prices and the
present worth of the operating cost was estimated over a
period of 10 years with an annual interest rate of 8
percent. The above cost did not include land purchasing,
building construction, or personnel expenditures required
for operating and maintaining the facilities*
The total cost, including the source remedial measures
was $20,380,000.
6. Alternative No. 5
(a) Description
This alternative (Figure 11) involved the conveyance of
extracted groundwater by gravity from the collection tank to
a treatment facility and a leaching field, both to be
constructed in the Park.
(b) Non-Cost Criteria
(i) Technical Feasibility
Flow and transport models were executed and a pump test
run to test the technical feasibility of actively
remediating all or part of the Landfill leachate plume by
pur.ping. The results of these .efforts indicated that the
defined edge of the TVOC plume could be hydraulically
-45-
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controlled by wells operating at an appropriate punping
rate. The Town estimated that the approxinate volume of
•
groundwater to be pumped in maintaining hydraulic control
would be 1.5 MGD. Based on that volume, Alternative No. 5
was technically feasible with respect to plume collection
and control. However, Alternative No. 5 was not considered
technically or institutionally feasible with respect to its
disposal component.
Alternative No. 5, in general terns, searched for a
recharge location close to the proposed recovery wells so
that the cost of piping the water back to the Landfill could
be avoided. Any potential Alternative No. 5 recharge
location had to meet two preconditions: 1) the location
could not interfere with the efficiency of the recovery
wells themselves and 2) the recharge could not be located in
an area potentially affected by two other suspected (since
confirmed) sources of contamination to the east and west of
the Landfill, the Nassau County Fireman's Training Facility
and Clareraont Polychemical, respectively.
The first criterion eliminated any location within
approximately 2500-3000 feet of the pumping wells, the
estimated combined affect of the recharae and the cone of
influence of the pumping wells. (See G&M letter of Ortober
26, 1987 contained in the administrative record.) Basic
elements of the calculations demonstrating the need for
approximately 3000 feet of separation were verified in the
field pump test. Since it is required that these recoverv
-46-
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wells create a hydraulic barrier for the plume of
contamination, the addition of a mounding effect to this
cone of influence would diminish the effectiveness of the
required hydraulic barrier. Due to the proximity to the
Landfill plume to the Fireman's Training Center and
Clareraont sources of contamination, locations east and west
of the Landfill plume and downgradient of those sources were
similarly rejected.
Therefore, the only area left for potential recharge
under Alternative No. 5 was the southernmost portion of the
Bethpage State Park, an area currently used as a public golf
course. Although it is technically "feasible" to discharge
in this area, it has the major institutional and health
concern disadvantages described in the following sections.
(ii) Environmental Impacts
The beneficial effects of Alternative Mo. 5 on -the
environment are containment of the contaminant plume and
improvement of the quality of the groundwater. It also
provides water conservation because plume water would be
returned to the aquifer via the leaching field. Adverse
effects of this alternative include an increase in airborne
emissions from the treatment facility (although any
treatment facility would be required to meet all applicable
air emissions standards) and a decrease in Bethpage State
Park aesthetics due to the treatment facility, the recharge
basin, and leaching field being located in the Park.
(iii) Public Health Analvsis?
-47-
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Alternative No.'5 will provide long-term public health
protection through the combined actions of containment and
removal of contaminants from the groundwater recovery system
and -groundwater monitoring to detect potential contaminant
migration toward a public supply well. However, since the
treatment facility and the groundwater recharge would both
be located in or close to the public golf course in Bethpage
State Park, this alternative presents a greater potential
for public exposure to the discharges from this remedial
program than the other proposals.
In addition, the discharge water, even though only
slightly contaminated, would be placed at a point only one
thousand feet upgradient of the nearest Farmingdale public
drinking supply well and outside and downoradient of the
containment system. If temporary treatment system
malfunctions occur, this alternative has the potential to
discharge contamination in excess of allowable standards and
guidelines outside the recovery zone and only one thousand
feet upgradient of the drinking wells. This presents
further potential for future public exposure to
contamination.
(iv) Institutional Issues
Alternative No. 5 includes discharge of treated plume
water to the groundwater via leaching fields in Bethpage
State Park. Discharge of treated water into the groundwater
would require a National Pollutant Discharge Elimination
System (NPPFS) permit. In order to obtain the permit,
.-48-
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pollutant concentrations in the discharge would need to meet
i
or exceed the applicable effluent/grcundwater quality
•
standards. The extracted groundwater could be treated to
attain all clean-up goals and, therefore, the NPDES permit
for Alternative No. 5 was anticipated to be obtainable. Any
treatment facility would need to comply with all applicable
air emissions standards and permit requirements. It was
anticipated that such requirements would be attainable.
However, the location of a treatment facility and
discharge basin (covering approximately 5 acres) in Bethpage
State Park would require that easements and rights of way in
the Park be obtained. It would also require major restruc-
turing and redesign of the current golf course facility and
re-routing of public access pathways to avoid contact with
the treatment and discharge facilities. It was determined
that such easments and rights of way would be difficult to
obtain and that the major restructuring of the golf course
was not possible/ as a practical matter.
(c) Cost Analysis
The total estimated cost of the groundwater portion of
Alternative No. 5 was $5,935,000. The capital and annual
operating costs were estimated based on a flow of 1.5 MGD. All
estimates were based on 1987 prices. The present worth of tha
operating cost was estimated over a period of 10 years with an
annual interest rate of 8 percent. The above cost did not
include land purchasing, building construction, or personnel
-49-
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expenditures required for operating and maintaining the
facilities.
The total cost, including the source remedial measures,
was $21,935,000.
7. Alternative No.6
(a) Description
Alternative No. 6 (Figure 12) involved the conveyance
of the plume water by gravity to a treatment facility to be
located in the Park and thereafter, conveyance of the
effluent to a storm sewer on Plainview Road. The storm
sewer would ultimately discharge to a municipal recharge
basin. The treatment plant effluent would be conveyed to
the storm sewer by piping through the Park or around the
perimeter of the Park.
(b) Non-Cost Criteria
(i) Technical Feasibility
Flow and transport models were executed and pump tests
run to test the technical feasibility of actively
remediating all or part of the Landfill leachate plume by
pumping. The results of the modeling effort indicated that
the defined edge of the TVOC plume could be hydraulically
controlled by wells operating at an appropriate pumping
rate. The Town estimated that the volume of discharge
resulting from the maintenance of that hydraulic barrier
would be 1.5 MGD. Based on that discharge volume,
Alternative No. 6 was technically feasible with respect to
plume collection and control.
The disposal aspect of this alternative might not be
feasible if the storm sewer or recharge basin did not have
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adequate capacity to handle the 1.5 MGD flow. A preliminary
cost was estimated over a period of 10 years with an annual
•
site evaluation of these two components by the Town
suggested that adequate capacity was available.
(ii) Environmental Impacts
The beneficial effects of Alternative No. 6 on the
environment were containment of the contaminated plume;
improvement of the quality of the groundwater resource and
water conservation fa portion of the treated plume water
will be returned to the groundwater via .the recharge basin).
Adverse effects of this alternative included: a loss of
water from the aquifer (a portion of the treated plume water
would be discharged to Massapequa Creek which flows into the
South Oyster Bay); an increase in airborne emissions (from
the proposed treatment facility, althouah any treatment
facility would be required to meet all applicable air
emissions standards); and a decrease in Bethpage State Park
aesthetics due to treatment plant construction in the Park,
as well as other visible remedial structures and components.
(iii) Pxiblic Health Analysis
-Alternative No. 6 would provide long-term public health
protection through the combined actions of containment and
removal of contaminants from the groundwater system and
groundwater monitoring to detect potential contaminant
migration towards the public supply wells. The discharge
location, however, would be in an area that is now
accessible to the public. Although the anticipated levels
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of contamination would be welj. within discharge limit?,
dischargirta in this area would increase public exposure to
small levels of contamination and also place contamination
outside the recovery well containment system.
Furthermore, if the treatment system experienced a temporary
malfunction, higher levels of contamination would discharge
into the creek until the system could be shut down.
(iv) Institutional Issues
Alternative No. 6 would require permits for discharge
of the treated plume water to the storm sewer-recharge
basin-Massapequa Creek system. It was anticipated that
these permits would not be obtainable because Massapequa
Creek traverses a populated residential area of Long Island.
Although the discharge water would be treated, there would
be a potential for direct personal contact with the water,
since disposal would be to surface water and access to that
water cannot be controlled. In this regard, this option was
not as desirable as other alternatives in view of health and
institutional considerations. In addition, DEC'S water
conservation policies restrict depletion of a sole source
aquifer.
Any treatment facility would need to comply with all
applicable air emissions standards and permit requirements.
It was anticipated that such requirements would be
attainable.
(c) Cost Analysis
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The total estimated cost of the groundwater portion of
Alternative No. 6 was $6,135,000. The capital and annual
operating costs were- estimated based on a flow of 1.5 MGD. All
estimates were based en 1987 prices and the present worth of
the operating cost was estimated over a period of 10 years with
an annual interest rate of 8 percent. The above cost did not
include land purchases, building construction, or personnel
expenditures required for operating and maintaining the
facilities.
The total cost, including the source remedial measures,
was $21,935,000.
8. Alternative No. 7
(a) Description
Alternative No. 7 (Figure 13) included the conveyance
of the extracted plume water to a treatment facility at the
Landfill to remove TVOC's. After treatment, the water would
be conveyed and discharged to either an existing recharge
basin and/or a leaching field on the Landfill property.
(b) Non-Cost Criteria
(i) Technical Feasibility
Flow and transport models were executed and pump tests
ran to test the technical feasibility of actively
remediating all or part of the Landfill leachate plume by
pumping. The results of the modeling effort indicated that
the defined edge of the TVOC plume could be hydraulically
controlled by wells operating at an appropriate pumping
rate. The Town estimated that the maintaining of hydraulic
control would result in 1.5-MGD of discharge water. Based
on "that discharge volume, Alternative No. 7 was technically
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feasible with respect to plume collection and control.
Alternative No. 7 involved conveyance of treated plume water
to a proposed leaching field and recharge basin located in
the northwestern portion of the Landfill property. The
combined leaching field/recharge basin system could be
designed to accommodate the 1.5 MGD flow. Thus the disposal
component of this alternative was deemed feasible.
(ii) Environmental Impacts
In comparison to Alternatives Mos. 1 through 6,
Alternative No. 7 would provide the largest number of
beneficial affects on the environment. Implementation of
Alternative No. 7 would: contain the plume; improve the
groundwater resource (by removing the contaminated water);
conserve water (by returning virtually all the extracted watc
back to the aquifer via the leaching field/recharge basin
system); and contain the residual contaminants in the discharge
water by disposing them hydraulically upgradient of the
extraction wells so that they could be recovered and treated
continuously in a closed recovery system.
Adverse effects of Alternative No. 7 included an
increase in airborne contaminants from treatment processes,
(although any treatment facility would be required to meet
all applicable air emissions standards) and a decrease in
Bethpage State Park aesthetics due to visible remedial
structures and components. The latter adverse effect would
be very minimal because the bulk of the remedial components
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(treatment facility/recharge/leaching fields) would be located on
the Landfill property.
(iii) Public Health Analysis
Alternative No. 7 would provide long-term health
protection by:
1) the hydraulic control of the plume to protect the
downgradient public supply wells;
2) the removal of contaminants from that groundwater
system;
3) long-term monitoring to detect any potential
contaminant migration towards the public supply
wells; and
4) the recharge of the discharge water into the
groundwater containment and recovery system thereby
eliminating exposure to the recharge water in
places of public access.
(iv) Institutional Issues
Alternative No. 7 would require a NPOES permit or its
equivalent for discharge to the groundwater via the recharge
basin/leaching field system and air permits or their equiv-
alents for treatment of the contaminated groundvater. These
would be obtainable since pollutant concentrations in the plume
water can be reduced to meet applicable effluent/groundwater and
air standards.
(c) Cost Analysis
The. total estimated cost of the groundwater portion of Alternative
No. 7 wag $7,045,000. The capital and annual operating costs were
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estimated based on a flew of 1.5 MGD. All estimates were basj
i
on 1987 prices and the present worth of the operating cost w<
estimated over a period of 10 years with an annual interest rate
of 8 percent. The above cost did not include land purchasing,
building construction, or personnel expenditures required for
operating and maintaining the facilities.
• The total cost, including the source remedial measures,
was $23,045,000.
III. ANALYSIS AND SELECTION PROCESS OF RECOMMENDED
ALTERNATIVE
A. Description of the- Recommended Alternative
According to 40 CFR Section 300.68(i) of the NCP, the
appropriate remedy shall be determined by the lead agency's
selection of a coat-effective remedial alternative that effect
ively mitigates and minimizes threats to and provides adequate
protection of human health and the environment. In addition,
CERCLA, as amended by SARA, requires a costeffective remediation
which protects human health and the environment, utilizes perma-
nent solutions and alternative treatment technologies or resource
recovery options, and attains federal and state ARARs to the
greatest extent practicable.
After review and evaluation of the remedial alternatives
presented in the feasibility study, the State presented Altern-
ative No. 7 in combination with the existing remedial activities
at the Landfill to the public as the preferred remedy for the Old
Bethpace Landfill.
This alternative consists of:
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1. hydraulic control of the defined plume;
2. treatment of the recovered water by an air
stripper and, if necessary, iron removal and
carbon adsorption to meet all applicable federal
and state air emissions standards (see Table 1)
and all applicable federal, state and local
discharge criteria for the discharge of the
recovered water;
3. discharge of the recovered water into an injection.
well system with an auxiliary recharge.basin
available (capacity 1.5 million gallons of water)-
at a location on the Landfill upgradient of the
recovery wells (see Figure 13);
4. clean-up of the plume to meet N.Y. State
groundwater standards and drinking water
guidelines (see Table 1) or attainment of
zero-slope condition throughout the plume and
implementation of any required remedial technology
to further reduce contamination (for full
explanation of cleanup criteria/ see Section III
of the RAP attached hereto);
5. implementation of a groundwater monitoring program
to measure the effectiveness and performance of
the remediation as set forth in Section II of the
RAP;
6. completion of the capping of the Landfill (see
-------
Section I.G. of the' RAP) to r.eet required
permeability and other ECL (6 NYCRR Part 360)
requirements;
7. continuation and expansion or enhancement, if
necessary, of the leachate control and gas
collection systems at the Landfill per Section
I.H. and I.I. of the RAP and continued monitoring
of the gas collection systen as set forth in
Section I.H. of the RAP.
Alternative No. 7 was recommended because it adhered
most closely to the criteria set forth in 40 CFR Section
300.68(i) and the applicable provisions of CERCLA/SARA and
provided more positive environmental, health, and
effectiveness benefits and fewer disadvantages than the
other alternatives. A summary of the non-cost analysis of
the benefits and disadvantages of each alternative is set
forth on Table 3.
B. Reasons for Rejecting Alternatives 1 Through 6
The major reasons for not recommending the other six
alternatives are set forth below.
1. Alternative No.l
Alternative No. 1, the no action alternative, was not
recommended because it failed to achieve a number of the
criteria for selecting a remedy. Since Alternative No. 1
would require only plume monitoring, the present plume
migration and contaminate levels would continue unabated.
Therefore there would be:
-CO-
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Allornallvo Drlof
Ho. Description
TAOLE 3
HOH-COST CRITERIA A/I ALTS IS
Environmental Impacts
Technical Feasibility Positive Negative
Institution*)
Issues
l«
•Alternative
Malof Supply"
Removal of ground-
wator by pumping.
pipe to RIIF and
discharge to II.C.
Removal of ground-
wator by pumping
plpo to proposed
treatment facility
In OQSMOC. and dis-
charge to N.C. sonar
system.
Removal of ground-
wator by pumfIng.
conveyance;to both
tho RAF and a treat--
mont facility pro-
posed for OUSUDCi
discharge to II.C.
sonar.'
lhu Is the qutotlty of
• «lor ustblo by the IUIF
-------
CollnclloH And containment
convoute* to lr**l-
nun i I tell I iy *nd ••
d(*cl>krg* to loich-
li|U Mold to b*
toiislj-ucUd ft*
of Iliu ftlMMa by
wti proved *ll»ctlv*
through tba Hi* o|
.' lkf> rovoaont In
lncr*»t« In »libornb
kudu11 (Section II).
lU)»ov»l of ground* CalUclloit •ml conltliMMint
filer by (tMpliig* . ol Ilitf fell*** by pu»flug
lfu«ltount In Uel- W*t piuvad •llucllv*
'llly:lo b* locttod In thiougli ut* o| niMorlc«|
Ilia l'«ik| •dluont wdoli (Uotluu III.
|l|tcli«rgo lo I lor* ' •
k^xar on I'ltlltvlow fo*iilbl|||y Hty b* hlndur*d
(lo«d. , If ilui* iawar lyito* do*i not
i ' .• h*v* tli* itii|ul|od ctptclly
tu lundl* I.S UMI,
of gri»unuiipliiu
v«i (iiuvud •lloctlv*
Ilia liii of iiu«ui'lc*|
(Suction III,
Uclllty la b* .
| of grounil-
• •lor (•liwo Mttor
rolurnod to •<|u|-
l»r vl« ilorm
tOMar/rochtrga
b«tln
l»provciiaul In
qutllly of ground
n«tar ratourca.
Vttar conii>rv<-
tlon
Incrotta In tlrborno
o*lstIon* fro* tr*tl»o»t
t«clllty.
Cflact on r*ik taithatlcs
duo to Irotlxont Itclllly
which will bo conslruclono~luiii public lioillli
piuliicl Ign Idrouiili co*4ilnod •ctlani uf runuvt) o| cunl t«ln4nl*
|jruuiidM«tiir lyilb* tnd •utilluilnu to duloct pulunll*!
*Uuu (imtrd ifpfily w*iiii
-------
no compliance with ARAP.'s;
_no active reduction of toxicity, mobility or
volume;
no short-terra effectiveness?;
no long-term effectiveness and performance;
no acceptance by the community or the
State;
no active protection of human health and the
environment.
Although this alternative would be capable of
implementation and was the least costly of the alternatives,
it would not achieve any adequate compliance with the above
listed criteria and therefore it was not a remediation
acceptable to the State.
Alternatives 2, 3, 4, 5, and 6 were all active pumping
alternatives which differed in the location where recovered
water would be discharged and in some instances the location
and type of the facility where the recovered water would be
treated (although all treatment facilities would be required
to achieve the same stringent air and water discharae
criteria). Because all these alternatives would employ the
sane groundwater well contaminant and recovery system as the
recommended Alternative No. 7 and be required to meet the
same cleanup and monitoring- reouirements, they were equal
with Alternative No. 7 for the following criteria:
all these alternatives comply with ARAR's to the
same degree, and
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all these alternatives reduce the toxioity,
nobility, and volume of contamination to the same
•
degree.
Each of the Alternatives 2-6 did not comply with the
other criteria as fully as Alternative No. 7. The following
comparison sets forth these deficiencies.
2. Alternative No. ?
Alternative No. Z was« equal to No. 7 in compliance with
the criteria of meeting long-tern effectiveness and
performance. .However, since Alternative No. 2 re
-------
as Alternative No. 7, it is uncertain, because no
i
data currently exists on what effect the
discharge from the RRF would have on health and
the environment;
The State, for the above reasons, has refused to
accept this alternative;
Although the cost of Alternative No. 2 was
presented in the FS as. less than Alternative No.
7, the main reason was that the cost of the
RRF ($150 million) was not included in the cost
estimate. Since Alternative No. 2 did not achieve
the same degree of compliance with all criteria as
No. 7, it was not recommended.
3-. Alternative Nos. 3 and 4
Both Alternatives 3 and 4 required some discharge to
the Nassau County Sewer Treatment Plant (No. 3 calls for
total discharge to the sewer facility and No. 4 would send
the excess not used by the proposed RRF).
Alternative No. 4, since it relied on the existence of
the RRF has all the deficiencies and was rejected for all
the same reasons set forth for Alternative No. n. In
addition, it was also not acceptable to the State because
the discharge to the sewer facility would contravene water
conservation requirements for Long Island sole source
aquifers set forth in. 6 t-TYCPR 602.
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Alternative No. 3 which called for total discharge to
the Nassau County Sewer Treatment Plant was equal to
Alternative 7 on all criteria, except as set forth below:
Nassau County, in meetings with the State and
Town, stated the treatment plant did not have
capacity to handle 1.5 million gallons of
discharge water and therefore the County would not
approve a permit to accept this water. If a
permit were to be obtained, it would need to be
accomplished through the institution of
administrative or legal proceedings (see Walsh
letter dated July 25, 1986 contained in the
administrative record); .
Secondly and, more importantly, the removal of 1.5
million gallons a day (without replacement) from
this portion of the Long Island sole source
aquifer would contravene the water conservation
reouirements set forth in 6 NYCRR 60?.
For these reasons, neither Alternative No. 3 or No. 4
were appropriate for recommendation.
4. Alternative No. 5
Alternative No. 5, which called for discharge in
Bethpage State Park downgradient of the proposed recovery
wells was equal to Alternative No. 7 on all criteria, except
as noted below:
Alternative No. 5 was not as protective of
health and the environment:
-------
The only discharge location downgradient of
the recovery wells fchich would not interfere with
the pumpage and hydraulic control of those wells
and which would not be placed in plumes of
contamination to the east and west of the Landfill
(thus potentially interfering with future
investigations and remediation^ of those sites)
was in Bethpage State Park approximately 1000 feet
upgradient of Farmingdale public drinking supply
wells. Although the cleanup criteria would
require the discharge water to meet New York State
groundwater standards and federal drinking water
guidelines, the discharge water would nonetheless
contain low levels of contamination. In addition,
the possibility of a temporary treatment system
•malfunction might result in higher contamination
discharge levels until system shut down. In view
of the fact that Alternative No. 7 provided a
discharge location which would contain all
contamination within the recovery system,
Alternative No. 5 was not as protective of the
human health and environment as No. 7;
The treatment system for No. 5 would be
located in Bethpage State Park, a public golf
course. The treatment system for Alternative No.
7 would be located in the middle of the Landfill
property at a point furthest from public exposure.
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Although the air discharges from these treatment
i "*
.facilities would meet all State and federal
standards and the risk to the public would be low,
the fact that the treatment facility for
Alternative No. 5 would be located on a public
facility made it less protective of the public
health than Alternative No. 7.
Since both the treatment facility and the
discharge basin (covering approximately 5 acres)
would be on the State Park, it would require the
obtaining of permits or easements, and might
require the substantial reconstruction of the
public golf course. The obtaining of such legal
access and restructuring of the golf course, while
not impossible, would certainly delay and impede
the remediation.
At the formal public meeting, the group of '
citizens who attended and commented on the
recommended Alternative No. 7 expressed a
preference for Alternative No. 5 over No. 7. The
State responded to this comment at the meeting and
in a more detailed fashion in its written
responses. Those .responses are set forth
specifically in the Public Responsiveness Summary.
In sum, these comments cane from citizens and
public officials who lived close to the Landfill
and who drank from or were responsible for the
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Plainview public drinking well field No. 5. They
expressed two mair. concerns, first that
Alternative No. ?, since it called for treatment
and discharge on the Landfill would aid the Town
in its proposed application for a RRF at the
Landfill site and secondly, that Alternative No. 7
called for discharge of groundwater closer to. the
Plainview public drinking supply (which is
upgradient of the proposed recharge) than
Alternative No. 5, which called for discharge
downgradient of the recovery wells (but closer to
and upgradient of Farmingdale Public Drinking
Wells). The State found both concerns to be
unpersuasive. A summation of the the State's
responses is set forth below:
The permit process for the PRF is totally
separate and distinct from the remediation program
set forth by Alternative No. 7 antf would fail or
succeed solely on its own merits. It is not aided
or helped legally or practically by the acceptance
and implementation of Alternative No. 7;
Groundwater recharge mounding calculations
showed that Alternative No. 7 recharge water would
not affect the Plainview Well Field #5.
Monitoring would be performed to confirm those
calculations;
Since Alternative No. 7 would not affect
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Plainview Public Wells, it was more protective of
health and the environment than Alternative No. 5,
*
which would discharge contamination outside the
containment system and 1000 feet upgradient of
Farmingdale Public Drinking Wells.
Alternative No. 5 would be less costly than
Alternative ^?o. 7, but in view of the fact that it
would not achieve the same level of protection for
human health and the environment as Alternative
No. 7, the cost factor was not considered
determinative. For these reasons, Alternative
No. 5 was not recommended.
5. Alternative No. 6
Alternative No. 6, which located the treatment facility
in Bethpage State Park and called for the discharge o.f the
recovery water into the storm sewer system which flows into
Massapequa Creek, was equal to Alternative No. 7 in
compliance with all criteria, with the exception of the
following:
Alternative No. 6, since it called for the removal
without replacement of 1.5 million gallons of
water per day from this portion of the Long Island
sole source aquifer, like Alternatives No. 3 and
4, would be in contravention of 6 NYCRR Section
602.
Alternative No. 6 was not as protective of .human
-66-
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nealth and the environment as Alternative No. 7'
"because, like Alternative No. 5, the treatment
facility would be located in Bethpage State Park,
thereby providing some level of contaminant
exposure to the public. Also, like Alternative
No. 5, the discharge water, although only slightly
contaminated, would be placed outside the
groundwater recovery well containment system in an
area accessible to the public.
Although Alternative No. 6 was less costly than
Alternative No. 7, since it would not achieve th*.
\
same level of protection of health and the
environment, the cost factor was not considered
determinative.
C. Reasons for Recommendation and Selection of
Alternative No. 7 for Remediation of the Old
Bethpage Landfill.
Alternative No. 7 was recommended and ultimately
selected because it rated equal to or better than all other
alternatives for the nine evaluation criteria set forth in
the NCP. The analysis of that comparison is set forth
v
below.
1. Applicable or Relevant and Appropriate Requirements
Alternative No. 7 is designed to meet all
Applicable or Relevant and Appropriate Requirements (Table
1) as follows:
(a) The current plume will be contained and
hydraulically controlled by the
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groundwater recovery well system. The plume
i
will not migrate past the hydraulic Carrier while
pumping occurs. This barrier will protect the public
drinking wells downgradient of the recovery wells. The
area between the recovery wells and the public supply
wells will be protected from any further contaminant
migration which would cause the groundwater in that
area to exceed New York State groundwater standards and
Drinking Water Guidelines.
(b) The plume itself will be cleaned to New York
. State Standards and Drinking Water Guidelines or
to a zero-slope condition (defined in the RAF) if
after 5 or more years of pumping no significant
contaminant reduction is occurring and no other
requisite remedial technology (defined in the RAP)
exists to further reduce the contamination.
(c) The discharge of the recovered groundwater
from the treatment facility will meet New York
State Groundwater Standards and Drinking
Water Guidelines.
(d) The air discharge from the stacks of the
treatment facility will meet Mew York State Air
Guide No. 1 Guidelines for the Control of Toxic
Ambient Air Contaminants.
(e) The cap will be designed to meet all
ECL (6NYC3R Part 360) requirements including 10~7
-68-
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permeability.
. (f) The gas collection system will maintain a -1
pressure at all monitoring points and be sampled
for volatile organic chemicals at agreed
monitoring points to demonstrate that the gas
recovery system is not allowing the escape of
volatile organic chemicals from the Landfill.
2. Reduction of Toxicity, Volume, and Mobility
Alternative No. 7 will reduce the toxicity and volume
of contamination within the plume to New York State
Groundwater Standards and Guidelines, or to a zero slope
condition, if one exists following 5 or core years of
pumping and the application of requisite remedial
technology. In other words/ the remediation will reduce the
toxicity and volume of contamination in this, plume to the
full extent feasible using the mcst appropriate technology
now in existence (i.e. pump and treat) and requisite
technology in the future, if required. Alternative No. 7
will completely reduce the mobility of the plume because it
is required to stop, through hydraulic control, its
migration, until the cleanliness criteria are met. In
addition, the capping of the Landfill will mitigate the
production of Landfill leachate, thus further reducing the
toxicity, volume, and mobility of the plume. Finally, the
gas collection system reduces the mobility of gases from the
Landfill by preventing their migration off-site.
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Eventually, when biodegradatipn is complete, cases will
cease to -be produced in the Landfill.
3. Short-Term Effectiveness
Alternative No. 7 can be implemented within
approximately 2 years and will be immediately effective in
preventing plume migration and reducing the toxicity and
volume of contamination in the plume. Capping of the
Landfill which also can be implemented within two years will
have the same immediate effect. There are no short-term
risks associated with the implementation of Alternative
No. 7.
The gas collection program, already in place, has
demonstrated its short-term effectiveness in controlling
Landfill gas migration and reducing the toxicity and volume
of the Landfill gases.
4. Long-Tern Effectiveness
Alternative No. 7 i's an effective long-term remedy
which would result in the protection of public water
supplies and the permanent restoration of the aquifer to the
lowest possible, technologically achieveable, cleanliness
standards.
Long-term effectiveness will require continued
operation, maintenance and monitoring of the remedial
systems to insure compliance (i.e., hydraulic control, gas
collection and capping ) with ARARs (both at termination and
during post-termination periods), as set forth in the RAP.
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5. Tmplementability
Alternative No. 7 can be readily implemented. It does
not depend on innovative technology. The systems to be used
are reliable and easily available. There are many competent
and dependable companies capable of installing and
maintaining this equipment.
It does not present the possibility of delay due to
insititutional problems, such as difficulty in obtaining
permits or easements.
6. Cost
Alternative No. 7 is the most expensive of the
alternatives evaluated. The cost is estimated to be
$7,045,000 for capital and annual operating expenditures.
This does not include land costs or labor expenses for
operation and maintenance.
Alternative No. 7, in addition to meeting ARAP.s, is the
most protective of health and the environment and does not
contravene other New York State environmental policies,
particularly the water conservation policies of Article 15
of the ECL and regulations promulgated thereunder at 6 NYCRR
602.* Zn addition, although the equipment and installation
costs for Alternative No. 7 are more costly than the other
alternatives, it does not present some of the legal and
technical costs such as the expenses for obtaining permits
and easements (e.g., Alternatives Nos. 3, 5, and 6) which
might become necessary, under some of the other
alternatives.
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7. Community Acceptance
The members of the public and public officials who '
appeared at the public meetings and made comments supported
the pump and treat remediation, capping program, and the gas
collection program.
Some community members and public officials expressed
their preference for Alternative No. 5 over Alternative No.
7. A summary of those comments and the State's responses is
set forth in Section III.B.4 supra. A full discussion of
those comments and the State's responses is found in the
Public Responsiveness Summary attached herewith.
In sum, the State has carefully reviewed Alternative 5
and finds it less protective of human health and the
»
environment than Alternative No. 7.
8. State Acceptance
The State of New York is lead enforcement agency on
this matter and is selecting Alternative No. 7 in
conjunction with the remedial programs already in place and
set forth in the RAP as the appropriate remediation for the
Site.
"9. Overall Protection of Human Health and
the Environment
Alternative No. 1, in conjunction with the remedial
programs in place and as set forth in the RAP, is fully
protective of human health and the environment. This
remediation is designed to linit all routes of contaminant
exposure from the landfill and to eventually reduce that
contamination to or below APARs levels. All. air and water
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discharges from remediation system components will be within
APAP.s. The PAP and the proposed Consent Decree will require
that these programs will be operated, maintained, and
monitored to insure compliance with all these requirements<
D. Public Participation in Development of the
Recommended/Selected Alternative
The first meeting with the public on thir matter was
held in ?983. Representatives of the Department of Lav/
(DOL) and the Department of Environmental Conservation met
with the public and public officials to explain what was
then known about chemical sampling at the Landfill and the
types of investigation and programs planned for the future.
Two meetings were held, one on August 11, 1983 and one in
early 1984. The first was attended by approximately 30
people, the second by approximately 100. Initial contacts
with community groups and interested public officials were
made at these meetings. Groups and individuals were
encouraged to telephone the Attorney General's office to ask
questions and make cnrtraents. Telephone numbers and names of
state representatives were supplied for this purpose. The
public was informed that data existed with respect to this
site and that such data was available for review. During
1983 and 1984, the public contacted the Department of Law by
telephone calls and letters on numerous ocassions. DOT,
responded to oral ccmments orally and written comments in
writing.
-------
The data was reviewed by members of the public arid
t
press. During this tine period, the State was negotiating
•
with the Town for a Remedial Investigation of the site.
Many comments from the public and public officials were
included in the investigation program. For example, the
public requested that the State take split samples from the
investigation and have them analyzed hy an independent lab.
This was included as part of the investigation program.
The negotiations resulted in a proposed Interim Consent
Decree between the State and the Town of Oyster Bay. That
Interim Consent Decree provided for the Remedial
Investigation of the plume of groundwater contamination
emanating frors the site, the preparation of.a Remedial
Feasibility Study for the site, and a commitment by the Town
to perform a remedial program in compliance with federal,
state, and local law and regulations. The Interim Consent
Decree also required the Town to complete a portion of the
capping program then underway and to continue and maintain
the existing gas collection program.
The public was provided with these documents and
initially'given approximately 30 days to comment. Copies of
these documents were delivered to public officials and
public groups who had been present at the public meetings.
These comments and the State's responses are found in the
administrative record. After the public comment period was
complete, U.S. District Court Judge Charles Sifton approved
the Interim Consent Decree.
-74-
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During the course of the Remedial Investigation, there
«
was periodic contact between the public and the Attorney
*
General's office. A meeting was held with members of the
public in Two World Trade.Center in the spring of 1985. A
number of topics concerning the Landfill, including closure,
plans for expansion, and the Remedial Investigation, were
discussed. Periodically, reports and results of the
Remedial Investigation were also announced to the public
through the news media. In addition, the chemical data were
made available to the public at the offices of the Attorney
General. Lecr*l and technical representatives of the State
discussed the meaning of the data with members of the public
who came to review the data. During this time period, DOL
responded to telephone questions and ccmments orally, and
written comments and questions in writing.
On July 15, 1987 the Remedial Action Feasibility Study
("FS") was made available to the public. A public meeting
was held on July 23rd to provide the public a detailed
explanation of the Remedial Investigation; an analvsis of
the results of that investigation; and a description and
explanation of the FS and its preparation process. The
meeting also provided the public with an initial opportunity
to ask questions and provide initial comments on the RI and
FS. A second formal public meeting was held on September
10, 1D87. The purpose of that meeting was to obtain formal
comments on the FS and recommended Remedial Alternative No.
7. The State also explained the procedure for the
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submission of written comments. The State responded to oral
i
comments .at the meeting to the extent possible. The State
responded to all significant comments, both oral and
written, in writing. These comments and the State's
responses are set forth in the Public Responsiveness
Summary. Transcripts of both meetings are available in the
administrative record*
Both meetings were noticed in local newspapers. (See
Public Responsiveness Summary). Certain public officials
and members of the public who represented known citizens
groups were also notified by letter and/or telephone.
E. Participation of the Responsible Parties In the
Development of the Recommended/Selected
Alternatives ;
The corporate defendants were provided copies of the
Interim Consent Decree and the plan for Remedial
Investigation on May 1, 1084. The Interim Consent Decree,
in addition to setting forth the plan for Remedial
Investigation, set forth the requirements for development of
the Remedial Feasibility Study, the partial capping program,
and the continuation of the gas recovery program. As per
the directive of Judge Sifton, the U.S. District Judge
presiding over the litigation, the State was requested to
submit the Interim Consent Decree to the Court by motion.
This was done on July 5, 1984. The defendants and the
public were given to July 19 to submit papers or comments in
response to the motion. The comments of the defendants are i
set forth in the administrative record. The defendants made
-------
no significant objection or opposition to the work set forth
in the Interim Consent Decree'and the RI or to its
•
implementation.
As the work under the RI progressed, the corporate
defendants were provided the data results from that work.
They were provided a full and detailed explanation of the RI
and the findings of that investigation.
When the third-party defendants were brought into the
litigation, they were also provided access to the data from
the RI and given a full and detailed explanation of the RI
and its findings. Copies of the completed RI were made
available to representatives of all defendants and
third-party defendants.
Later, the responsible parties were provided an outline
of the remedial feasibility study and the comparison of
alternatives and projected costs. Settlement discussions
were conducted using the projected costs of the various
alternatives being evaluated as the basis of the
discussions. The various proposed alternatives were
discussed in detail. Maps depicting the various disposal
and treatment locations were displayed.
The parties were requested to comment on the proposals.
Several other meetings which discussed these proposals were
held with the responsible parties. Prior to and at each
meeting requests for comments were made. All the written
questions concerning proposed remediation at the Landfill
which were received from the responsible parties are set
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forth in the administrative record. Questions and comments
i
were responded to orally at the meetings. The responsible
parties, defendants and third-party defendants made no
significant objection or opposition to the remedial
proposals set forth in the outline of the FS.
The final Feasibility Study was provided to the
responsible parties in July 1987. The comment period for
the FS was approximately 75 days. No comments were received
from the responsible parties during the comment period or
thereafter..
Attendance sheets and handouts from significant
meetings with the responsible parties as well as significant
written communication to them concerning the RI/FS are
contained in the administrative record.
F. Relationship of the Settlement of the Litigation
to the Recommended/ Selected Alternatives
The Remedial Action Plan set forth herein which
implements Remedial Alternative No. 7 and the other ongoing
remedial measures at the the site, has been developed mainly
by the State and the defendant Town of Oyster Bay. If the
Town agrees to perform the Remedial Action Plan and if the
terms of -the proposed settlement are agreed to by sub-
stantially all parties to the litigation; that proposed
settlement would have. the effect of resolving, the litigation __
r the parties and" providing .for""" the 'full and complete
er CSSCLA/-
~SARA* • Therefore,- once' SPA -concurs- with—the- State's formal-— — -
-------
selection of the appropriate remedial plan for this site, the
majority of the parties in the litigation will be in a position
i
to reach agreement on the proposed settlement and perform the
«?
RAP.
G. Statutory Findings with Respect to the Recommended/ .
Selected Alternatives
The Alternative No. 7 and the complementary remedial
plans called for in the RAP satisfy the nine evaluation
criteria to a greater degree than the other appropriate
alternatives examined.
The RAP complies with all ARARs.
Alternative No. 7 ulitizes permanent solutions to the
maximum extent practicable as defined by Section 121 of
CERCLA. Implementation of this RAP will permanently and '
significantly reduce the mobility, toxicity, and volume of
the wastes at the site.
This RAP provides the greatest degree of short-term and
long-term effectiveness and permanence, and eliminates the
public health and environmental exposure routes at the
Landfill. Protection of human health and the environment on
a long term basis is best assured by the RAP and its
associated maintenence and monitoring programs and
requirements. The State's analysis of the possible risks
related to the operation of the RAP (i.e., air and water
discharges from the treatment facility) indicate that these
risks can be adequately controlled and pose no significant
health or environmental exposure risk.
This RAP applies technology which is reliable and
available.
-79-
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Although Alternative No. 7 is the most expensive
alternative, it achieves the statutory criteria to a greater
degree than any other alternative. Hence, the State and EPA
find that the balance of costs versus benefits is tipped in
favor of the most expensive alternative.
The State has considered all comments from the
community to the maximum degree possible in light of the
other factors to be weighed. The State finds no public
comment which argues effectively for the selection of an
alternative other than Alternative No. 7.
In summary/ the State has recommended and by this
document the State and EPA select Alternative No. 7 and the
complementary remedial programs in .the RAP because they are
protective of human health and the environment, will attain
applicable or relevant and appropriate requirements, are
cost effective, utilize permanent solutions to the maximum
extent practicable, and 'will significantly reduce 'the
toxicity, mobility, and volume of waste all as defined by
Section 121 of CERCLA.
IV. SELECTION OF REMEDY
Based upon CERCLA, as amended by SARA, and a review of
the entire administrative record herein, including without
It initiation, the comments of the public, the Remedial
Investigation -and Feasibility Study, and a detailed
evaluation of all the alternatives, the State and EPA have
determined by zaeans of this Record of Decision that
Alternative No.'7, and the complementary remedial plans set
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forth in the RAP and detailed( above, constitute the selected
remedy for this site. ^
Th« cost of the groundwater portion of Alternative
.No. 7 is estimated by the Town to be $7,045,000. The entire
remedy, including groundwater remediation and source
remedial measures, is estimated by the Town to cost
approximately $23,0.45,000.
-81-
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: . APPENDIX I OF POD ATTACHMENT 2
OBSWDC
Remedial Action Plan
DESCRIPTION
A. Introduction
This Remedial Action Plan (RAP) describes the
activities undertaken and to be undertaken to restore the
quality of groundwater and air in the vicinity of the Old
Bethpage Solid tfaste Disposal Complex (OBSWDC) which has
been affected by contamination from the Old Bethpage
Landfill. This RAP provides for the Town of Oyster Pay to
implement the following activities in compliance with the
terms ar.d conditions of a Final Consent Decree in N.Y.S. v.
Town of Oyster Bay et al. 83 Civ. 5357("Consent Decree") to
which this plan is attached as Appendix A:
(1) install a system .of groundwater recovery wells in
the "Area to be Remediated" described in Section I.B
herein;
(2) operate and maintain these groundwater recovery
.'wells, to create a hydraulic barrier as defined in
Section I.D and to attain specified Groundwater
Criteria set forth in Section III.B.I or demonstrate
that the Zero Slope Condition and other Termination
Criteria of Section III.B.? have been met;
(3) treat and discharge the extracted and collected
groundwater in compliance with the groundvater and air
discharge requirements net *orth in Sections I.E and
T P«
• • * *
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(4) complete, maintain, and monitor the current capping
and gas and leachate collection programs as per the
closure requirements of New. York State Regulation
6 NYCRR Part 360 and the requirements of the Consent
Decree and Sections I.G, I.H and I.I herein;
(5) carry out and comply with the requirements for
sampling, analysis and health and safety set forth in
Sections IV, V and VI, respectively.
The RAP is preceded by several studies which defined
the nature and extent of groundwater contamination and
examined remedial alternatives:
*
»
"Old Bethpage Landfill, Groundwater Monitoring
Program, Phases 1 & 2," Lockwood, Kessler &
Bartlett, Inc., 1981.
"Comprehensive Land Use and Operations Plan, Old
Bethpage, Solid Waste Disposal Complex," Lockwood,
Kessler & Bartlett, Inc., 1983.
"Groundwater Monitoring Data Report," Lockwood,
Kessler & Bartlett, Inc., 1984.
- 2 -
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"OBSWDC Offiste Exploratory Drilling and
Monitoring Weil Installation Program, Old
Bethpage, Long Island, New York," Geraghty &
Miller, Inc., August 1985.
"OBSWDC Offsite Groundwater Monitoring Program,
Old Bethpage, Long Island, New York," Geraghty &
Miller, Inc., September, 1986.
"Remedial Action Feasibility Study, Landfill ;
Leachate Plume, Old Bethpage Solid Waste Disposal
Complex, Town of Oyster Bay, New York", Lockwood,
Kesaler & Bartlett, Inc. and Geraghty & Miller,
Inc., July, 1987.
"OBSWDC Aquifer Test For Evaluating Hydraulic
Control of Leachate Impacted Ground Water, Old
Bethpage, Long Island, New York", Geraghty &
Miller, September 1987.
B. Area to be Remediated (the "plume")
The 1986 report by Geraghty & Miller, Inc. identified
offsite areas where groundwater quality had been affected by
contamination frein the Landfill. The ?.A? provides for
- 3 -
-------
hydraulic containment of the plume by a system of ground-
water recovery wells located at.the area defined by the
leading edge of the plume of volatile organic chemicals
("VOCs"). The area to be remediated (the "plume") is
delineated in plan view on Figure 1, and is shown in
cross-section on Figure 2. The recovered water will be
piped to a treatment plant and ultimately recharged through
a combination of leaching wells and the recharge basin
located northwest of the Old Bethpage Landfill as shown on
Figure 3. This system is described in detail in the
following sections.
C. Groundwater Recovery Well System
Based upon previous modeling studies and a pilot pump
test conducted in the sunmrmer of 1987, the proposed number
and location of groundwater recovery wells to effectuate
hydraulic control of the area to be remediated is set forth
in Figure 3. The engineering details and design
specifications for this system will be set forth in the
Final Design Plan to be submitted pursuant to Section J.
The Town of Oyster Bay will complete the Final Design Plan
and installation of the groundwater recovery system as set
forth in the schedule in Section K. The Final Design Plan
and the installed recovery system is subject to final State
aooroval as oer oaracraoh XV of the Consent Decree.
- 4 -
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'**•*
;^ * . •••.•:•-
--•" >-
iffu::".--;:-Fl«urt 1 APPROXIMATE DISTRIBUTION OF VOLATILE
•_. . .. HALOGENATEO . ORGANICS (VHOs)/9/V£
D 3Y CERAOMTT A MILLER INC., FOB
LOCKWOOO, KESSLER, a 8ARTLETT, INC.', ft TOWN OF
OT3TEB SAY, OLO 8CTHPAGE, NY
-------
; t
o • 114
?
•4
>
U
-I -1*0
I * flAMAIIOM
• >«•!•• (Mil*
«••««••»! I •
fL«* •IBICIIO*
• lit •iiit»ne«
• IIH ICICICI*
it*
• ill* Hill
APMOIIMAIE OllIMIIUTION
Of VOLATILE HALOCCNATCO
ONOANIO
APPROXIMATE VERTICAL DISTRIBUTION QF
VOLATILE HALOQENATEO ORQANICS
(VHOi) ALONG CROSS SECTION A-A'
Milln. Ut l«
LOCK WOOD. KESSLER. AND BARTLETT. INC.
AND THE
OF OYSTER BAT
ON B«Up«9*. HtM York
-------
BCTHPAGE STATE PARK
S7ATC PAAK UMTTS
OBSWOC UMITS
" I T~~ ik ' »~M ' —
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D. m Hydraulic Containment
The proposed hydraulic containment svsten, subject to
final State approval, will consist of sufficient recovery
wells (the preliminary design based on previous modeling and
monitoring calls for five (5) wells as shown on Figure 3),
each pumping at a rate necessary to maintain and control the
movement of groundwater in the area to be remediated and to
provide a barrier to further plume migration. Sufficient
drawdown will be created and maintained to establish a
hydraulic gradient toward the recovery wells. Monitoring o^
water levels as set forth in Section II.A will be conducted.
to demonstrate that a sufficient drawdown is being
maintained to create a hydraulic barrier to contain the
plume. The procedure to verify the amount of drawdown
sufficient to create such'a barrier and to confirm that this
drawdown is being maintained is also set forth in Section
II.A.
E. Treatment System
A treatment system will be designed and installed to
remove VOCa from the water collected by the remedial
recovery wells. The air and water discharges from this
treatment system will meet all applicable federal, state,
.and local air discharge reouirements as set forth on Table 1
and all applicable State Pollution Discharc* Elimination
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TABLE 1 .
APPLICABLE AIR DISCHARGE
REQUIREMENTS FOR AIR STRIPPING
TREATMENT SYSTEM*
Constituent
-Ambient Air Concentrations-
NYSDEC
Annual
Guideline
(ug/m3)
Vinyl Chloride
Freon 13
Methylene Chloride
1,1-Dichloroethane
1,2-Dichloroethene
Chloroform
1/1,1,-Trichloroethane
Carbon Tetrachloride
1,2-Dichloroethane
Trichloroethylene
1,2,-Dichloropropane
Bromodichloromethane
Tetrachloroethene
Chlorodibromomethane
Bromoform
Benzene
Toluene
Ethyl Benzene
(m) Xylene
(o&p) Xylene
(m) Dichlorobenzene
(o) Dichlorobenzene
(p) Dichlorobenzene
Chloroethane
1,1,-Dichloroethylene
Chlorobenzene
Ammonia
3,
1
4.00E-01
3.00E-02
1.17E+03
2.70E+03
2.63E+03
1.67E+02
80E+04
.OOE+02
2.00E+01
9.00E+02
1.I7E+03
3.00E-02
1.12E+03
3.00E-02
.67E+01
.OOE+02
7.50E+03
1.45E+03
1.45E+03
1.45E+03
3.00E-02
l.OOE+03
l.SOE+03
S.20E+04
6.67E+01
1.17E+03
3.60E+02
.1,
1,
* Established per New York State Department of
Environmental Conservation Air Guide No. 1 for Toxic Air
Contaminants. If any federal National Ambient Air Quality
Standards or National Emission Standards for Hazardous Air
Pollutants are promulgated which are mere stringent than
these State guidelines, the more stringent standard shall
apply.
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System (SBDES) and Technical and Operational Guidance Series
(TOGS) limitations set forth in Table 2.
Initially, the treatment system will consist of an air
stripping unit designed to meet the specified discharge
criteria.
The initial air stripping tower will be located as
shown on Figure 3 and will have the conceptual design
characteristics as shown on Table 3. The precise location
within the area shown and the specific operational design
characteristics will be set forth in the Final Design Plan
to be submitted pursuant to Sections ,T and K, subject to
State approval.
If after two (2) months of operation (after an initial
equipment shakedown period), the air stripper treatment
system does not meet the specified discharge criteria, the
Town will be required to 'add a carbon adsorption unit
capable of allowing the system to meet the specified
discharge criteria. The Town will also be required to
install sufficient iron treatment equipment and/or implement
sufficient equipment maintenance procedures to insure that
the air stripping equipment operates continuously and
efficiently.
The Town will set forth in the Final Design Plan the
complete treatment systsm showing the integration of all the
above described unitr;. The Final Design Plan will also set
- 6 -
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TA3LE 2
GROUNDWATER ACPIFER AND TREATED GROUNDWATER DISCHARGE
REQUIREMENTS* .
Inoraanics . . mg/1
Barium
Cadmium
Chloride
Chromium (hex)
Copper
Cyanide
Iron
Lead
Magnesium
Mangenese
Mercury
Silver
Zinc
Total Dissolved Solids
Nitrate
Sulfate
Phenols (total)
Volatile Organic
Compounds (VOCs)
Vinyl Chloride
Methylene Chloride
1, 1 Dichloroethane
1, 2 Dichloroethane
1/1 Dichloroethene
It 2 Dichloroethene (trans)
Trichloroethylene
I/ 1/1 Trichloroethane
Chloroform
Carbon Tetrachlcride
1, 2 Dichloropropane
Bromodichloromethane
Tetrachloroethene
Chlorodibromomethane
Chloroethane
Bromoform - — -
Benzene
Toluene
Xylene (all isomers)
500**
10
250
0.001
2.0***
50
50
0.8
0.07
50
5***
50
100
5
50
50
0.7
50****
50****
50
non-detect
50
50
-------
Table. 2 con't.
Ethylbenzene 50
Chlorobenzene .20
Dichlorobenzene
ortho-and para- 4.7
all isomers SO****
Total VOCs (for groundwater) 50
Total VOCa (for discharge) 100
* This list of compounds is not exhaustive of the
applicable Standards and Guidance Values. The list
represents the most prevalent compounds found at the site.
The cleanliness criteria listed herein are.Standards and
Guidance Values issued by the NYS Department of
Environmental Conservation for the protection of Class GA
waters found at 6 NYCRR 703 and in the Technical and
Operational Guidance Series (TOGs) dated April 1, 1987. If
during the course of the remediation additional compounds
should be detected, the most stringent of the requirements
obtained from these two sources shall apply. For any VOC
which does not have a specific Standard or Guidance Value,
the applicable limit shall be 50 u/1.
** Federal Standard promulated by the U.S. Environmental
Protection Agency (EPA).
*** For these compounds, the Maximum Contaminant Level
(MCL) under the Federal Safe Drinking Water Act is less than
the State Standards or Guidance Values and therefore shall
apply. Should additional MCLs be promulgated by the EPA,
then the most stringent standard shall apply.
**** These compounds do not have a specific State Standard
or Guidance Value and therefore the applicable limit is
50 u/1.
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• ' • TA6LE 3
Preliminary Air Stripper Design Data
Water Flow Rate = 1.5 MGD
Air/Water Ratio = 60/1
Air Flow Rate -• 8400 cfm
i
Liquid Loading Rate = 20 gpm/ft4"
Stripper Diameter = 8 ft.
Air Exit Velocity = 2.8 fps.
Water Temperature = 50 to 60 F
Stripper Ground Elevation = El.140
(approximately)
Stripper Height * . 38 ft.
Preliminary design data has been established through
pilot plant studies and is subject to future modification
.prior to final design.
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forth the proposed procedure and timetable for integrating
the additional .treatment units in the system, if needed.
In general, these additional treatment units will be
installed adjacent to the operating air stripping tower.
The need for these units(s) will be established within 60
days of the plant start-up Fallowing for a reasonable plant
shakedown period agreed to by Town and State] or, if the
influent/removal efficiencies of the initial treatment
system change in the future, within 60 days of the
confirmation of the failure to meet the specified discharge-
criteria. The installation of the additional treatment
units will be completed within a period of five (5) months
from the time that the failure to comply is established.
The conceptual design parameters for the iron removal system?
and the carbon adsorption units(s) are presented in Tables 4
and 5, respectively. The- final design parameters will be
developed and set forth in the Final Design Plan required by
Sections J and K, subject to State approval.
The Town will make all necessary modifications,
additions, and adjustments to the treatment system until it
meets the specified discharge criteria. The treatment
system will not be permitted to operate without State
approval for longer than a sixty day period if it fails to
meet the specified discharge criteria. Re-start of the
system will on.ly be allowed following the implementation of
State approved modifications.
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TABLE 4-
• Preliminary Iron Reewval Systea Design Data*
Water Flow Rate
Treatment Method
Chemical Feeding
Configuration
Reaction Tank Diameter
Reaction Tank Cross Sectional
Area
Liquid Loading Rat*
Reaction Tank Height
1.5 MGD
Ion Exchange
(Magnesium Zeolite or equivalent)
followed by pressure filtration
Potassium Permagnate
Caustic
3 trains In parallei
8 ft.
50.2 ft 2
6.97 gpm/ft 2
less than 10 ft.
Preliminary design data has been established by the manufacturer and
Is subject to future modification prior to final design.
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TABLE 5
PreHalnary Activated Carbon Adsorption Systea Design Data*
Mater Flow Rate
No. of Carbon Adsorbers
Configuration
Adsorber Diameter
Adsorber Cross Sectional Area
Liquid Loading Rate
Adsorber Height
Carbon Load
Estimated Useful Carbon Life
(to benzene breakthrough)
1.5 MGD
3 (Includes 1 standby)
Parallel
10 ft.
78.5 ft 2
6.68 gpm/ft 2
less than 20 ft.
20,000/ per Adsorber
1 Year
*. Prel1mlnary design data has been establ1 shed through laboratory bench
scale studies and Is subject to future modification prior to final
design.
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F. .Discharge System
1. General
The water to be discharged will be conveyed to a series
of leaching wells and/or to an existing recharge basin for
recharge to the ground. The discharge points will be
located west northwest of the landfill area at the Old
Bethpage Solid Waste Disposal Complex as .shown on Figure 3.
The discharge system, whether leaching pools and/or a
recharge basin will be designed to accommodate the total
daily flow from the recovery wells.
2. Leaching Wells
The leaching wells will be ten feet in diameter and
have an approximate effective depth of 25 feet. A typical
section of the proposed well is shown on Figure 4. The
final quantity and location of the wells will be determined,
subject to State approval' as part of the Final Design Plan
required under Sections J and K. As per the schedule set
forth in Section K, prior to completion of the Final Design
Plan, soil borings will be obtained and percolation tests
will be conducted to establish the exact number of wells and
the expected percolation rates. Should a sufficient area
containing well-drained subsurface soils not be available to
recharge the discharge flow, the recharge basin, described
in the next paragraph, x*ill be used for the overflow.
3. Recharge Basin
Recharge Basin No. 1, as shown in Figure 3, is located
'' '-• 8 - .'.- .
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GRADE ELEV.
IN
a =j a
a a a
a a a
20.0'
EFFECTIVE
DEPTH
3' MIN.
GROUND WATER
^
10.0'
L_
COLLAR MATERIAL
BACKFILL
O CM
(rt
UJ
O
3 MIN.
6 MIN.
(P£N£TRAT10N}
RATEABLE SOIL
I
T
UNDERLYING SAND AND GRAVEL STRATA
RGURS 4
PROPOSED LEACHING WELL
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to the west of the landfill area. The basin currently is
under construction. The Town will design and construct the
basin with a capacity sufficient to handle all local runoff
and the flow from the recovery wells. Any water that cannot
be discharged to the ground through leaching wells will
overflow to the basin for recharge into the ground.
G. Landfill Cap Completion
Approximately 29 acres of the landfill area has already
been capped. The remaining portion will be capped as per
the schedule in Section K (commencing immediately after
signing Consent Decree).
The capping program will comply with the provisions of
6 NYCRR Part 360. The lower portion of the cover must be of
a material which restricts infiltration to the equivalent of
that achieved by 18 inches of clay at hydraulic conductivity
• ^
of 10 ' cm/sec or less. -Soils suitable for plant growth
will be applied on top of the clay layer to a thickness of
12 inches. All areas will be hydroseeded (the simultaneous
application of water/ seed and other specified components by
means of a pump or spray) and side slopes are, to the extent
practical, to be 3 to 1 or less as long as a stable sir'e
slope is maintained. An existing typical cap section is
shown in Figure 5.
The capping program and the final grading are designed
and will be constructed in coordination with ^tornwater
-------
GftS VE
FIGURE 5
OBSWDC EXISTING
TYPICAL CAP SECTION
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control systems, service access roads, earth benches, and
gas control facilities.
The capping will be completed within months of the
initiation of the work. It involves the following steps:
- surveying the completed, area;
- regrading to attain, to the extent practical,
slopes that are 3 horizontal to 1 vertical or less
as lono as a stable side slope i? naintained;
- application of a cap to reduce infiltration
of precipitation into the fill;
- application of growing medium soil over the
impervious cap;
- revegetation of slopes by hydroseeding a mixture
of seed, water, fertiliser and adhesive mulch; and
- other landscaping as necessary such as screen
planting at base, and plateau planting of young
trees, shrubs and grasses. .
Confirmation of compliance with the can reciuirements •
will be confirmed as set forth in RAP Attachment 1.
H. Landfill Gas Collection System
Since 1979, the Town has implemented programs to
prevent offsite migration of landfill gas at OBSWDC. A
perimeter landfill gas collection system has been installed
at the OPSWI5C under four separate construction contracts.
The system is comprised of twenty three
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header and. three condensate collection wells. The
mechanical portion of the system consists of two
independently driven blower packages with a combined flow
rate capacity of nearly 1800 cubic feet/minute; condensate
separation equipment; safety devices and a high temperature
gas incinerator.
Pending approval of its application to dispose
collected condensate through the Nassau County Sanitary
Sewer System, the ccndensate may be discharged pursuant to
its current SPDES permit. If the Nassau County Sanitary
Sewer Permit is not approved, the condensate shall be
treated in the treatment system pursuant to Section E and
discharged pursuant to the discharge criteria pursuant to
Section F.
As part of this remedial program the Town will continue
to operate and maintain this gas collection system in
compliance with the requirements of 6 NYCP.R Part 360 and
maintain a zero percent methane gas migration limitation at
the Landfill boundary. In order to demonstrate that
compliance, the Town will conduct the monitoring program
described in the Lockwood, Kessler and Bartlett April 1987
report entitled "1986 Annual Peport: Summarizing the Status
of Landfill Gas Monitoring Programs and the Establishment of
the Zero Percent Gas Mioration Limitation at the Old
Pethpage Landfill." In addition, the Town will conduct the
Supplemental Gas Monitoring Program set forth in Attachment
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2. The Town will expand and modify this gas collection
"system as required to prevent offsite migration of landfill
gas and to meet the requirements set forth above.
I. Leachate Collection and Treatment System
Since 1983, the Town has processed leachate at its
treatment facility pursuant to a sewer use permit from the
Nassau County Department of Public Works. The plant has the
capacity to treat up to 50,000 gallons per day for heavy
metals and solids, and presently discharges the clear,
settled effluent to the County sewer located on Round Swamp
Road.
As part of this remedial plan, the Town will be
required to continue to operate and maintain- its leachate
collection, treatment, and disposal system in compliance
with 6 NYCRR Part 360 and applicable Nassau County Sewer Use
Ordinances. '
The Town shall dispose of all sludge generated by the
leachate collection .system at an offsite location in
compliance with all applicable federal, state, and local law
and regulation.
J. Preparation of a Final Design Plan
1. Content and Schedule
The Final Desian Plan will be prepared and
submitted in accordance with the Schedule set forth in
Section I*. The Final Design Plan will contain the following
items: Final engineering design and specifications
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(including drawings) for the complete program for
remediation, including but not limited to the design and
specifications for the completion of the capping program,
groundwater recovery system, treatment system (including
piping), recharge system (including injection wells and
basin) and monitoring program as fully described in this
RAP.
2. Preparation and Adjustments
Prior to final design, up-to-date aerial
photographs, supplemented with field survey data will be
obtained to produce the topographic maps of the area. Soil
borings will also be collected in the area of the proposed
treatment plant for use during the foundation? design.
Percolation tests of the subsurface soils will also be
conducted in the area where treated effluent is to be
recharged to aid in the design of those facilities.
The treatment plant design will be made flexible to
accommodate changes in the interconnecting piping, if and
when additional equipment is required to be installed. The
use of temporary piping or hose.is anticipated during the
initial operation of the treatment plant.
The initial construction phase for the treatment plant
will include site clearing and preparation, foundations and
utilities installation for the entire project, and
construction and installation of the air stripping unit,
wellfield, influent piping and recharging facilities. The
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subsequent construction phase, if required, will include the
installation of iron removal and/or carbon adsorption
equipment and appurtenances.
K. Schedule of Implementation
[A schedule of activities with corresponding dates
shall be set forth herein]
II. MONITORING PROGRAM
A. Hydraulic Monitoring
The effectiveness of the hydraulic containment system
in exerting control over the defined area to be remediated
will need to be demonstrated by measuring water levels in
adjacent monitoring wells. In addition, measurement of
water levels will monitor the effects of potential mounding
due to recharge of the treated water. Initially, the wells
to be measured are: all 23 wells in the offsite Remedial
Investigation; all remaining intact Phase I, II and III
monitoring wells; the well at Melville Road; the closest
Farraingdale public drinking wells and all observation wells
installed as part of the remediation, including, e.g., the
observation wells for the pump test and the well(s)
upgradient of the proposed recharge area. VJater levels
measured in these wells will be referenced to mean sea level
and plotted on a base nap, according to depth. Contour
lines (indicating areas of eoual hydraulic potential) will
then be drawn. The limiting flow liner, v/ill then be drawn
indicating the effective capture zone.
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levels will be nonitored on a monthly basis once
the hydraulic containment system becomes operational.
Water levels will be measured using a steel tape and chalk.
Based on these water level measurements, the pumping rates
will be adjusted and the system modified until the required
hydraulic barrier is created and maintained.
The determination of v/hen the appropriate hydraulic
barrier has been created will be as follows: Based on
monthly water level measurements, the Town will demonstrate,
subject to State concurrence, that equilibrium has been
established in the system. Once agreement is reached as to
the establishment of equilibrium, the Town will demonstrate
with appropriate data and analysis, subject to the State's
concurrence, that drawdown, sufficient to create a hydraulic
barrier regardless of seasonal fluctuations, has been
established. Thereafter,' the Town will maintain that
drawdown, unless it is demonstrated by subsequent
measurement or sampling that that drawdown being achieved is
no longer sufficient or is excessive to create the hydraulic
barrier. Then the process of establishing, subject to State
concurrence, a pumping rate to achieve the required drawdown
number appropriate to attain hydraulic control will be
recommenced.
The Town will be required to continue to monitor the
recovery svstem tc confirm the effectiveness of the
hydraulic barrier under any conditions and to adjust and
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modify the recovery well system to maintain that barrier
until the Termination Criteria are met. In addition, the
Town will be required to continue to monitor for recharge
mounding effects. However, after the initial determinations
of eouilibrium and appropriate drawdown are reached, the
Town will only be required to provide quarterly
potentiometric surface maps 'see Reporting Requirements in
Section II.D.) and to measure water levels at the five
recovery wells; monitoring wells 7B and 9B and/or 9C; OBS-1
and OBS-2; a minimum of three additional monitoring points
depending upon the ultimate configuration of the agreed upon
capture zone; and the wells upgradient of the propsoed
recharge area. Either party, during the course of the
operation of the system, may propose that wells for water
level measurement may be added, subtracted or substituted.
E. Groundwater Quality and Monitoring
1. Introduction
Monitoring of groundwater quality is required to
assess the progress of groundwater cleanup, and to
demonstrate whether the Termination Criteria set forth in
Section III.A have been met.
2. First Round Monitoring
Once the recovery system has beer, installed and
prior to commencement of pumping, a comprehensive First
Round sampling shall be undertaken. The wells to be sampled
are all 23 wells in the offsite Remedial Invesigation; all
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remaining intact Phase I, II, and III observation wells; the
well at Melville Road; the closest Farminqdale public
drinking wells and all observation wells installed as part
of the remediation, including, e.g., the observation wells
for the pump test and the well(s) upgradient of the proposed
recharge area. A complete priority pollutant analysis
(Methods ,624, 625 and 200.7 [or other individual metals
analysis approved per 40 C.F.R. § 136.3]) and a concurrent
library search (to tentatively identify and quantify all
peaks with an area equal to or greater than 10% of the
nearest internal standard) will be conducted on the samples
taken from these wells. In addition, leachate indicators
shall be analyzed per .Table 6.
3. Quarterly Monitoring
Three months after the First Round sampling described
above, a program of Quarterly Monitoring will begin and
shall continue until the program for termination monitoring
is commenced.
The following wells will be sampled quarterly:
5B 8A 11A
6A 8B 11B
6B 9B ?B
6C 9C
6E
6F
In addition, one pump test observation well (to be
selected by the State), and the well(s) installed uparadient
of the recharge area will be sampled quarterly. A v/ell (tc
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Par^neter
Chloride
Table 6
Analytical Methods
Sample
Aralvtical Nfethod Preservation
SM 407 A
None
Holding
Time
T8 Days
Aimnnia
SM 417B, EPA 350.2 Cool to 4°C 28 Days
oH. 2 w/H-SO. '
2 4
Iron SM 303B, EPA 236.1
Field filter, 6 Months
Cool to 4CC,
.pH 2 WHNO,
Hardness
SM'314B, EPA 130.2 Cool to 4eC 6 Months
Alkalinity SM 403, EPA 3.10.1 Cool to 4eC 14 Days
(measured in
field)
Specific
Conductance
(measured in
field)
VOCs
Me'tals
and others*
SM 473
SM 205
None
EPA 601 and 602
EPA 40 CFR 136.3
'Individual
Analvses)
As per
Individual
method
Analyze
Imediatelv
Cool to 4°C 28 Davs
Cool to 4°C 14 Davs
As per
Individual
method
*Aluminun, Copper, lead, Manganese, Michel, Sodium, Zinc,
Chromium .(VI) , Chromium, Mercury, Potassium, Magnesium, Calcium,
Total Dissolved Solids, Nitrate, Sulfate, Carbonate/Total Kje-.lcahl
nitrogen, Pf.carbonate Alkalinity, Cyanide, Phenols, and Barium.
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. be selected by the State) for the sampling of leachate
parameters only will also be sampled quarterly.
The samples from these wells (except as noted) will be
analyzed for the parameters set forth in Table 6 utilizing
the analytical methods enumerated in the Table.
Either party, during the course of the operation of the
system, may propose that monitoring wells be added,
subtracted, or substituted. If the parties cannot agree on
these proposals, the disagreement will be resolved pursuant
to the dispute resolution mechanism, Section XXXI of the
Consent Decree.
4. Termination Monitoring
In order to determine whether the .Termination Criteria'
for the remedial system has been attained, a Termination
Monitoring program must be commenced. The recovery well
system will be required- to operate a minimum of five full
years (20 quarters) (unless it is demonstrated that the
standards and guidelines have been met at an earlier date)
before Termination Monitoring can be commenced. Thereafter
the Town may, at any time, request the commencement of the
Termination Monitoring Program.
a. Initial Termination Monitoring
After the Town's notification to the State that it will
commence Ternination Monitorino, an Initial terr.inaticr.
Monitoring duplicating the First Found Sampling Program, se
forth in Section II.B.2, will be conducted. All wells will
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be sampled and analyzed for a complete priority pollutant
analysis as also set forth in Section II.P.2.
b. Quarterly Termination Monitoring
After the analytical results from the Initial
Termination Monitoring are obtained, quarterly Termination
Monitoring will commence. This quarterly monitoring will be
conducted for a minimum of two (2) years (eight (8)
quarters). The State in its discretion after the Initia]
Termination Monitoring will determine whether the final year
of Section II.B.3 Quarterly Monitoring nay be substituted
for the first year of Quarterly Termination Monitoring.
The wells to be sampled and the parameters to be
analyzed for will be proposed by the Town, subject to State
approval.
At a minimum, the wells to be. sampled will include the
wells sampled for the two years of Quarterly Monitoring
immediately prior to the Town's request for Termination
Monitoring. At a minimum, the parameters analysed for will
be those set forth in Table 6 and any that were added or
substituted in the last two years of Quarterly Monitoring.
Parameters identified in the Initial Termination Monitoring
which could affect the ability of the Town to meet
Termination Criteria will also be required on the list of
parameters to be analysed.
P.r-iFed on two (2) full years (eight (8) quarters) of
Termination Monitoring results., the Town may submit a
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Petition for Termination which demonstrates that the
criteria set forth in Section III.A have been met. If the
State agrees with the Town's Petition for Termination, the
remedial system may be terminated. If the State and Town
cannot agree, disputes will be resolved pursuant to the
Dispute Resolution mechanism of Section XXXI of the Consent
Decree. The Town will continue to operate the remedial
system and conduct Quarterly Sampling until such dispute is
resolved or an order from the Court issued. If the Remedial
system is shut down, pursuant to either agreement or court
order, Post-Termination Monitoring, as set forth in Section
II.B.5 will commence.
5. Post-Termination Monitoring
Following termination of the operation of the hydraulic
containment system, a Post-Termination Monitoring Program
will be' undertaken. This program will last a minimum of
three (3) years and consist of a semi-annua] sampling of the
wells sampled during the Quarterly Termination Monitoring
Program and an analysis for the same parameters monitored in
that program. The data will continue to be evaluated to
determine if it is meeting the Termination Criteria. If the
post-termination monitoring analytical results indicate that
groundwater quality is no longer meeting the Termination
Cr.iteria set forth in Section III.A, the remedial svstem
will be re-started within 30 days. After startup the Town
can seek to demonstrate to the State, sub.ject to its
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concurrence, that the Termination Criteria is in fact being
met, or that the groundwater contamination discovered is
attributable to a source other than the Landfill, per
Section- III.B.3.
C. ^reatffient System Discharges
Operation of the air stripper must be maintained
to assure comcliance with: 1) applicable air discharge
requirements set forth in State -Regulations and the State
Air Guide No. 1 for the Control of Toxic Air Contaminants
(Table 2); 2) applicable State Pollution Discharge
Elimination -System f-SPDES). requirements, and 3) State
Technical and Operational Guidance Series limitations for
potable groundwater quality (Table 2). Prior to submission
of the Final Design Plan required by Section I.J. herein,
the Town shall develop a monitoring program, in consultation
with the Department of Environmental Conservation permitting
authorities to assure continued compliance of the air
stripper with applicable air *nd water discharge criteria
including permit or permit equivalent requirements. Upon
approval by the State, such monitoring program shall be
deemed incorporated as.part of this RAP.
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D. Reporting
1. Quarterly Reports
a. Construction Period
Quarterly Reports will be prepared for each quarter of the
construction period containing the following information:
Description of work completed
Delays and reasons
Work projection for the next Quarter
Charges or modifications, including
and dates of approval
Problems and resolutions
Revised schedule, if appropriate
b. Operating Period
Quarterly Reports will be prepared for each cniarter of the
operating period containing the following information and
data:
Pumpage records
Treatment system air and water discharge data
Treatment system performance records
Data analysis (trends, position of plume,
etc.)
Modifications to pvstem, including method and
^ates of approval
Grcundwater quality r.onitorinq r.ata
Uater level data
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. - Potentiometric surface naps as revised
Record of all system downtime
2. Annual Operating Report
An annual operating report will be prepared for each
year of the operating period crntaining a summary and
analysis of the information and data contained in the
quarterly reports. The Town at its option may combine the
4th quarter report of each year and the annual report into
on*r combined report.
E. Notification of System Downtime
In the event that the hvdraulic containment/
treatment, or major operable unit thereof, is down or
experiences failure for a period of 4R hours or more, the
designated agent of New York State will be notified, by
telephone, followed by a letter. During such down time or
failure, the Town and its representatives will make every
reasonable effort to obtain the necessary replacement
eouipment and re-start the system in an expeditious manner,
If the system cannot be restarted within 48 hours after
timely notification, the provisions of Section XXI of the
Consent Decree shall apply, as appropriate.
III. TERMINATION .
A. Termination Criteria . .
The criteria for termination of the hydraulic contain-
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nent/treatment system are as follows:
The Town:
1) Demonstrates that groundwater affected by
contamination from the Old Bethpage Landfill has been
remediated so that all the wells required to be sampled i:
the Termination Monitoring Program meet the standards/"
guideline values given in Table 2 for the parameters
analyzed.
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2) (a) Demonstrates that groundwater affected by
contamination from the Old Bethpage Landfill has been
remediated to the extent feasible with the existing remedial
system so that all the wells within the plume, required to
be sampled in the Termination Monitoring Program, meet the
zero slope condition as described in Attachment 3; and
(b) Demonstrates, subject to State'concurrence,
that any residual contamination is either 1) attributable to
another source or 2) cannot be feasibly remediated with
available Requisite Remedial Technology ("RRT") Tdefined .in
Section VI, paragraph ?. of the Consent Decree to nean known
engineering, scientific and construction principles and
practices, used or acceptable for use in the cleanup or
containment of chemical contamination which are applicable
to the materials and hydrogeological conditions found at the
TCP 'Landfill and its environs, including new and innovative,
technologies which utilize a permanent solution to the
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maximum.extent practicable] as set forth in Section XI of
the Consent Decree; and
(c) Demonstrates that the level of contamination
existing in the Termination Monitoring Wells located within
the defined plume will not cause future exceedances of the
standards/guidelines in the Termination Monitoring Wells
located outside the defined plume, e.g. the observation
wells installed as part of the remediation and Well Cluster
No. 7.
B. Methodologies for Termination Criteria
1. Meeting Standards and Guidelines
The standards/guideline values presented in Table 2 are
the criteria which must be achieved for each compound and
for total VOC concentration in all monitoring .wells
designated for the Termination Monitoring Program for a
period of two years (eight quarters) prior to termination.
?.. Achieving the Zero Slope Condition
The zero slope condition refers to a demonstrated
condition in which contaminant concentrations in all the
Termination Monitoring Wells are lowered by the remediation,
but do not achieve the standards and guidance values set
rorth in Table 2. Instead of continuing to be lowered, the
concentrations reach a certain level and remain at that
level during the two year Termination Monitoring period.
This condition is demonstrated if a plot of concentration
.-••'-' 25 -
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versus time for the two year Termination Monitoring period
shows that the slope of the line is statistically
indistinguishable from zero. The monitoring wells to be
used in the evaluation of zero slope will be the Termination
Monitoring wells agreed to as set forth in Section
II.B.4(b). The contaminants to be used in evaluating the
zero -slope condition will be Termination Monitoring
parameters agreed to as per Section II.B.4(b). The Zero
Slope condition will be determined by the method set forth
in-Attachment 3.
3. Determination of Effects from Other'Sources of
Contamination
If one or more Termination Monitoring Hells does not
meet the Termination Criteria set forth above, the Town mav
still seek termination of the remediation if all the
remaining wells me^t the criteria and the Town can
demonstrate, subject to State concurrence, that the
contamination in the non-complying wells is attributable to
sources of contamination other than the TOB Landfill. The
State will .continue to make available to the Town all data
it obtains with respect to other potential sources of
contamination, including without limitation the Nassau
County Firemen Training Center Facility and the Claremont
Polvchemic?.! Site.
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IV. GROUNDWATFP. SAMPLING PLAN
A. Sampling Preparation
Sampling will be conducted or.lv by authorized
representatives of the Town who are thoroughly knowledgeable
of groundwater sampling procedures, and who have been
thoroughly familiarized with the sampling protocol for this
site. Health and safety procedures for campling personnel
are described in Section VI. The sampling personnel will
coordinate with a ??ew York State certified enalvtical
laboratory to arrange for the appropriate containers. Prior
to the start of the monitoring program, the laboratory will
he provided with written instructions regardino the list of.
analytical parameters and reporting requirements; subsequent
modifications, if any, in the laboratory procedures will he
confirmed similarly, in writing. Such modifications will be
subject to State concurrence. State representatives will be.
provided notice and access and richt to sampling split as
set forth in the consent decree.
B. Sampling Protocol
. The protocol for sampling will be submitted for
approval by the State, prior to the start of the monitoring
program.
C. Quality Control/Quality Assurance
A trip blank will accompany each dav's samples during.
each sampling round. A trip blank ir defined an a standard
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40-ral VOA vial of organic-free water which accompanies the
samples. The trip blank will not be opened at any time
prior to analysis. The trip blank is then analyzed for
^rCCs. A field blank will be taken during each sampling
round. A field blank is defined as two 40-ml VOA vials of
organic-free water taken to the field during sampling. The
water, from the field blank will be poured through the
sample/discharge fitting (after it has been cleaned
according to protocol) and collected in a third vial. The
field blank is then analyzed for VOCs.
During each sampling round, one duplicate sample will
be taken and run for the appropriate parameters and as per
the analytical methods for that sampling round.
There are certain substances which are frequently
reported in laboratory analytical results and which are not
present in the sample when collected. These contaminants
are termed "artifacts" and are typicallv docunented by their
detection in laborator*' blanks. USEPA has recognized a
number of compounds as frequently occurring artifacts and
has consequently relaxed acceptance criteria for OA/QC
blanks for these compounds (see USFPA Contract Laboratory
Program "Statement of Work for Organic Analysis", October
1986). The currently recognized artifact compounds are the
following:
a. Methylene chloride
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b. - Acetone
c. Toluene
d. 2-Butanone
e. Listed Phthalate Esters
Results of method blank analyses are acceptable to
if they contain less than five (5) tines the Contract
Required Detection Limit (CRDL) for each compound (Method
blank is described as "an analytical control consisting of
all reagents, internal standard.", and surrogate standard?,
that is carried through the entire analytical procedure.
The method blank is used to define the level of laboratory
background contamination"). For example, if the CRDL for
methylene chloride is 5 ug/L, a concentration of up to 25
ug/L in a method blank analysis v;ould still be acceptable.
Thus, in evaluating water-quality data for compliance
X7ith the terms of the RAP, the presence of certain compounds
as artifacts will be considered. Contaminants which are
inconsistent with the historical database will be
investigated as possible artifacts. Demonstration of a
compound as an artifact may be in one or more pf the
following ways:
1. By providing laboratory QA/QC data showing
the presence of the compound in method
blank sample(s), per the above discussion
of CL? requirer.ents.
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2.. By citing a government publication of analytical
methodologies or criteria which provides for an
allowable persistent artifact(s), beyond
compounds (a) through (e) cited above, provided
that the particular concentration in question
is within the allowable range.
3. By resampling, provided the new sample indicates
a nondetectable (ND) concentration or meets one
of the above criteria.
Sampling records will be completed for each, and thest
records become part of the project file. Chain of custody
forms will accompany each day's delivery of samples.
V. SAMPLE ANALYSIS PLAN
The analytical methods appropriate to each sampling
program are specified in this document. The appropriate
procedures are incorporated by reference. The laboratory
will report the data in a form consistent with the previous
studies and monitoring, i.e., constituent, concentration,
and units.
VI. HEALTH AND SAFETY CONSIDERATIONS
The PAP presents the plan for collection and treatment
of groundwater affected by contamination from the Old
nethpage Landfill and source control of landfill qas and
7e?chate. As specific job descriptions are cl«-finpd for
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construction, operation, and monitoring of the remedial
system, job-specific health and safety requirements will be
developed. The requirements will be kept in a central file
onsite and copies provided to the State representative.
The health and safety requirements will be designed to
comply with OSHA's General Industry Standards, as well as
more newly-issued hazardous waste regulations (29 CFP.
1910.120). If two standards cover the job, the more
stringent standard will apply. I«Tith regard to the hazardous
waste regulations, every reasonable attempt will be made to
use engineering controls and/or work practices to minimize
the possibility of exposure, as opposed to relying on
personal protective equipment (consistent with OSHA policy).
Further, air monitoring will be conducted to evaluate
exposure hazards, and all personnel who may potentially be
exposed will undergo yearly medical monitoring. The health
and safety plan will be submitted to the State for aporoval
as set forth in the consent decree and the Schedule in
Sections J and K and prior to commencement of the remedial
construction.
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PAP ATTACHMENT I
i
Landfill Cap Specifications
and Testing Requirements
1. The clay cap shall be constructed in-6-8 inch thick
lifts (after compaction), must meet the following
specifications or must Lc mixed with an appropriate material
to meet the following specifications:
a. Permeability: 1 y 10- cm/sec or less
b. Grain Size: P200 content of 50% by weight
or greater
c. Liquid Limit: 25% cr greater
d. Plasticity Index: 10% cr greater
e. Compaction: 90? Modified Proctor density
or greater
f. Moisture Content: varying betxveen optimuir. and
2% of wet of optimum
2. To ensure attainment cf the required permeability for
the clay cap the following documentation testing shall'
be performed:
o. Analysis cf grain sice distribution using the
Unified Soil Clarsification System (AST?4 C2407) and
analysis of Atterberg Limit:, on at least one sample fcr
every 500 cubic yards of clay placed.
b. Development of. reference compaction (dry density
and moisture content) and permeability curves using e;t
least three points per curve for each sample of
material proposed to be used fcr the cap and for at
least one sample fcr every 500 cubic yards of clay
placed.
c. Measurements of'in-situ compaction using a nuclear
densioroeter (ASTM D2922) at the intersection points of
a 100-foot grid pattern. The grid shall be offset for
each lii:t cf in-place material.
d. Measurement ct laboratory saturated hydraulic
conductivity on a minimum of ere undisturbed sample per
acre per lift cf clay placed. The procedure for
ubtaininq the undisturbed sample end perfcrir.ir.c z
test must be approved by the State.
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Any portion of the constructed cap which fails tc
achieve an in-situ density required tc provide a
permeability of 1 :; 10- cm/sec or less, as judged from
the reference compaction curves or from the laboratory
hydraulic conductivity tests shall be reconstructed
until the requisite dry density and permeability are
achieved and verified by the State.
A qualified soil technician or engineer shall be
present during construction of the cap to provide
visual inspection and.direct sampling ana vesting. The
results of the in-situ density and permeability tests
shall be analyzed by a geotechniccl professional and
submitted to the State with the professional engineers'
certification of construction.
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RAP Attachment 2
OLD BETHPAGE LANDFILL
SUPPLEMENTAL"GAS -MONITORING PROGRAM
The supplemental landfill gas monitoring program for
the Old Bethpage Landfill P.feniediaticn Program contains five
components. These are 1) the collection of ambient air
samples; 2) the collection cf subsurface gas samples at a
depth cf 30"; 3) the collection of subsurface gas samples at
depths cf 10', 20', 30' and 40'; 4) the collection of
Lherr.eil cxidizer emission samples (stack testing) ; and
5) the measurement of gas pressure to ascertain negative
pre-ssure created by the gas collection system. These data
requirements supplement the existing methane gas monitoring
program and will be reported in the annual reports produced
under that program.
The location of the proposed sampling points are shown
oh Drawing No. 1, entitled "Old Eethpage Landfill Zero
Percent Methane Gas yigration Contours, 1986 Annual Site
Survey". A description of the various'components of this
program follows.
Ambient'Air Samples
Ambient air samples (24 hr. samples) will be collected
at three locations around the landfill as shewn on Drawing
No. 1. One location will be along Winding P.oad to theieast
and southeast of the landfill (near M-3 shewn en Drawing No.
1). One location will be to the west of the landfill alor.g
Round Swamp Poad (near M-33). A third location will be
north cf the landfill (between K-17 and l'.-22) . Samples at
these locations will be collected quarterly during the
initial year cf the program and, if approved by the State,
en an annual basis thereafter. Samples will be analyzed fcr
volatile organic compounds.
30" Deep Subsurface Gas Samples
Fourteen subsurface gas samples will be collected at a
depth cf 30" at the following locations surrounding the
landfill as shewn on Drawina No. 1: F-l, M-2, M-4, M-5,
M-6, M-13, M-16, M-21, tt-22~, M-28, M-31, M-34, M-37 and
M-39. Samples will be collected on a quarterly basis during
the initial year of tht program and, if approved by the
Ctate, on an annual basis thereafter. -Samples 'will be
a.::«iyzed fcr volatile organic compounds.
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-2-
Subsurface Gas Samples at Various Depths
Subsurface gas samples will be collected at depths of
10', 20', 30', and 40' at location K-9 (to be repaired or
replaced) shown on Drawing No. 1. Samples will be collected
on a quarterly basis during the initial year of the program
and, if approved by the State, on an annual basis
thereafter. Samples will analyzed for volatile organic
compounds.
Thermal Oxidizer Emissions
Thermal oxidizer emissions will be sampled (in the
incinerator stack) on a quarterly basis during the initial
year of the program. The emissions will be related to
oxidizer incinerator temperatures during this initial year
of sapling. Thereafter, the oxidizer temperatures will be
monitored on a monthly basis tc insure that temperatures
needed to volatilize the organics are being maintained in
the oxidizer. The emissions will continue to be sampled on
an annual basis. Samples will be analyzed for volatile
organic compounds.
Pressure Readings
Pressure readings will be taken at three locations
around the perimeter of the gas collection system to
ascertain whether a vacuum is Created around the system.
This data will assist in monitoring the effectiveness of the
system and in determining whether the system needs
adjustment or enhancement. One reading will be taken to the
south of the landfill at either F-6 or F-9 (existing probes)
shewn on Drawing No. 1. A new probe will be installed and a
reading taken to the northwest of landfill between LGV 16
aod LGV 17. The third probe will be installed and a reading
taken to the southeast of the landfill between TGV-1 and
LGV-9. Pressure readings will be taken on a quarterly basis
during the initial year of the program and, if approved by
the State, on an annual basis thereafter.
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RAP Attachment 3
For the purposes of determining the zero slope
condition, the concentrations of the organic parameters will
be totaled for each quarter to produce a concentration
versus time plot for each well, for a total of eight such
plots. It vrill be required that the rtero slope 'condition
exist in each of these Termination Monitoring wells.
The method to be used for determining whether zero
slope has been achieved is as follows:
The data will be tested for normality anrf the selected
statistical test will be determined by the following
procedure:
»
1. Plot concentrations? obtained over time on
probability paper.
2. Evaluate for normality by an agreed upon objective
method.
3. If d£t-a is not normally distributed,
transformation!? such as locnormal mav b*» pmployed in an
attempt to obtain a normal distribution. Transformer1 data
will be tested for normality.
4. If the data is normally distributed, the most
powerful parametric test will be used.
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5. If the data is not normailv distributed, the most
*
powerful non-parametric test will be performed on the data.
During the course of the remedial activities, either
party may request, as provided in the consent decree, to
alter the above procedure, as appropriate, to provide a more
powerful test, as statistically defined.
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APPENDIX II of ROD Attachment 2
NUNERIGM GROINDWATER FLCW fOCEL
f
\
The groun-cwater flow trocel useo by Geragnty 4 Miller, Inc. for tfiis
study 1s tne basic aquifer simulation program, modified for water-table
conditions, as described by Prickett and Lonnqulst, (1971). The model uses
the finite-difference numerical method to obtain approximate solutions to
the equations that define groundwater flow.
The flew mocel was constructed by utilizing hydrogeol oglcal data
obtained from published .sources augmented by field data obtained during the
GSSWOC offs-ite-drill ing and monitoring programs. The Input data Include
water-level elevations, hydraulic conductivity, elevation of the "bottom"
of tne water-table aquifer, transmiss1v1ty, storatlvlty, recharge and model.
imposed boundary conditions.
Model Grid
The region Included 1n the flow mooel encompasses an area which 1s
12,000 feet by 14,500 feet and Is represented by a rectangular grid of 18
columns and 20 rows. The grid* which 1s variably spaced, was superimposed
over a map of me aquifer. A fine grid spacing (500 foot grid Intervals)
was used within the leach ate plume to provide detail. Coarser grid
spadngs of 2000 foot grid Intervals were employed further away from the
plume to complete the flow system and establish boundaries beyond the Im-
pacts from aquifer stresses (I.e., pumpage). The 500-foot spacing was con-
sidered appropriate given the maximum plume width of approximately 4,250
feet. The aquifer system properties were dlscretlzed by assigning specific
values to each node which occur at the Intersection of column and row
grids.
-------
Water-Lev el Data
v
A.groundw"ater elevation map was obtained from Geraghty 4 Miller,
Inc.'s August 19S5 report. Site-spedf1c water-level data frcm the report
were obtained frcm the 23 off-site program monitoring wells, Phase 3
monitoring wells, and Nassau County observation wells on June 5, 1985. The
water-level map indicated that the hydraulic gradient ranged from a low of
0.0013 ft/ft to a high of 0.0027 ft/ft with an overall average hydraulic
gradient of approximately 10.56 feet per mile (Q.002 ft/ft). The overall
gradient was interpolated linerally to establish upgradient and down-
gradient model boundary conditions.
Hydraulic Conductivity
Hydraulic conductivity values were obtained fron published reports
and found to range from 400 to 1,100 gallons per day per square foot
(gpd/sq ft). Sensitivity analyses were performed using the flow model and
a value of 800 gpd/sq ft was found to produce hydrostatic heads that best
represented fiel d conditions. Values Tower than 800 gpd/sq ft resulted 1n
simulated heads that were too high when compared to the measured water
levels of June 5, 1985. Similarly, higher hydraulic conductivity values
produced simulated water-table elevations that were lower than the June'5,
1985 values.
Saturated Thickness
The groundwater system 1n the modeled area has a saturated thickness
of approximately 700 feet. In essence, this aquifer 1s a large, thick
sequence of sand with varying amounts of silt and clay layers that impede
fl.ow in places, but that do not constitute a continuous confining unit
-------
separating shallower water-table and ceeper confined aquifers. Sines
leach ate contamination is/limited to tne upper 250 to 3 CO feet of saturated
material s» a saturated tnickness of 300 feet was used in the model.
In order to control a 3 00 foot thick plume In an aquifer whose
saturated thickness Is 700 feet, the remedial wells would have to be par-
tially penetrating. Additional analyses were performed to account for the
effects of partial penetration (which would be the case under field con-
ditions) on drawdown and the volume of water pumped to control the plume.
Calculated drawdown values were applied to the flow system (as shown by the
June 5, 1985 water-level elevation map) and results indicate that the plume
boundaries are within the simulated pumping barrier.
It should be noted that the model's simulation presents optimistic
results with respect to pumping rates because the model simulates the
aquifer as 1f the botton of the system 1s located 300 feet below the
water-table surface. Hence* flew to the remedial wells in the model 1s
horizontal. However, under f lei d conditions of partially penetrating
remedial wells, some water would move vertically up to the wells 1n
addition to predominant horizontal movement. More water would have to be
pumped to offset tills vertical component of flow, however, the additional
pumpage, if any, cannot be quantified in advance of a pumping test
involving one rsnedlal well.
Transmtss1v1ty, Storage Coefficient and Recharge
Aquifer transnissivlty, T, is defined by the relationship T= Kb,
where K 1s the hydraulic conductivity and b 1s the saturated thickness.
Published values of transmlssivity range from 51,000 to 270,000 gallons per
cay per foot, (gpd/ft) and an initial transmissivity value of 240,000 gpd/ft
-------
was cal cul ated .by tne moael frcm the hydraulic conductivity and the initial
saturated thickness. In tn i s case. :ecause welis^re punplng ana water
levels are declining* the saturated thicknesses within the cones of
influence decrease, resulting in reduced transmissi vities. The model
revised transm issiv ity values to account for this decrease 1n saturated
thickness.
The storage coefficient is important only for transient simulations
where it provides an indication of how quickly an aquifer will respond to
a cnange in stress. The groundwater system was simulated under
steady-state conditions, thus the storage coefficient is Irrelevant.
However, for tfte purposes of the numerical code, one must be entered. A
publ i shed storage coefficient of 0.2 (dimensi onl ess) was used.
Recharge to the water-table aquifer is supplied by precipitation.
The average annual recharge rate 1s on the order of 21 Inches (Isblster,
1966}* which translates to a value of approximately one mil lion gal Ions per
day per square mile (1 mgd/sq ml) or about 0.0359 gpd/sq ft.
Calibration/Approximation of Field Conditions
Several simul atlons were run until the computed heads reached
"steady-state11, no longer changing with time. The resultant head distribu-
tion and-hydraul 1c gradient frcm the model were found to approximate field
conditions. The average simulated hydraulic gradient 1s about 0.0026 as
compared to a field value of approximately 0.002. The general direction of
the groundwater flow 1s toward the south-south east. Additionally, the ob-
served water-level elevations 1n the 23 off-site wells, Phase 3 and Nassau
County observation wells (frcm June 5, 1985) were compared to the simulated
heads, and differences between the two were less than one-half foot while
seme values were reproduced exactly.
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Simulations of Remedial Pumping
\
Prior to simulating remedial pumpaoe options, preliminary values on
the number of wells and potential pumpage rates were calculated
analytically. Calculations of draw-down from partially penetratl ng wel Is
were analyzed* and the areas of groundwater contribution to wells pumping
in an aquifer with uniform flow were investigated (Todd, 1980, pp. 121-123).
Pumpage rates per well fran 500,000 to 1,625,000 gallons per day (gpd) and
transmissivitles ranging frcm 200,000 to 350,000 gpd/ft were used 1n these
analytical techniques. When draw-down exceeded one-hal f foot at the edge of
the plume and the areas of groundwater contribution to the pumping wells
overlapped, the number, locations and p urn page rates were considered to be
potentially successful in controlling the leachate plume. These
combinations were then simulated utilizing the flow (numerical) model, as
1t accounts for changes 1n transm1ss1v1ty and hydraulic gradient, which
better approximates field conditions than the analytical techniques.
Resul ts
Results Indicate that five wells placed along the leading edge of
the landfill leachate plume, would have to be pumped at a total .approximate
rate of five mill ion gallons per day (MGO) to capture the entire plume.
This Is an optimistic estimate because of assumptions and restrictions 1n
the construction of the model, discussed 1n Section 2.2.5. Under field
conditions* the pumpace rate 1s likely to exceed five MGD.
A comparison between the numerically and the analytically derived
results was made to oemonstrate the rel 1ab1l ity of the results obtained
from the numerical analysis. The analytical method employs equations that
define the geometry of the cone of influence from a pumping well In a
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uniform flew field as presented in Todd (I960). Calculations were made
using tne stagnation point fornua anc ,the egression for the boundary of
tne region producing inflow to a pumping well in a uniform field. The
1 imi ting flow 1 ines f or a wel 1 pumpi ng at a rate of 500,000 gpd and
1/000/000 gpd were calculated. Super imposition of the resulting zones of
influence snowed that six and four wells* respectively; are necessary to
capture tne entire landfill leacr te plume. These numbers of wells and
pumping rates result in a total pumpage of three and four MGD, which 1s 1n
reasonably good agreement with the numerical model results of approximately
five NGD. Unlike the numerical model/ the analytical (Todd) calculations
co not account for changes that occur In the groundwater system as a result
of pumping (e.g.* Interference effects* changes 1n saturated thickness and
gradient/ etc.). Thus the numerical approach better represents f1 el d
conditions and the results of this numerical analysis more accurately
approximate-the pumping stress and aquifer response.
The concentrations of volatile organic compound (June* 1985
sampling round) were summed for each well cluster/ and plotted on a site
map; from these data/ the approximate extent of the plume defined by 50*
ug/L of total volatile organic compounds (TVOC) was determined. The flow
model was then used to simulate different combinations of wells and total
pumpage rates to determine the configuration and rate that best captured
this plume.
Pumpage of 1.5 MGD appears to control the organics plume/ while a
pumpage rate of 2 MGD apparently e«eeds the rate necessary to Intercept
the organics contaminated groundwater.
* The precision of tne model construction did not allow for distinction
between 50 ug/L ana 0 in this analysi-s. Therefore, the edge of the plume t<
be captured is cef ined as being .1 n that range.
-------
Eased on the model results, it appears that the minimum pumpage re-
cuired to intercept the organics plume^s .oefinecMs approximately 1...5 f-GD.
The 1.5 MGD 1s-divioea among 5 wells, each pumping 300,000 gpd. Lower
pumpaoe rates and/or fewer wells were judged Ineffective to capture the
plume. The location of the pumping wells are shown on Figure 2-1.
The flow model simulated only a portion of the total saturated
thickness of the flow system. Thus, the 1.5 MGD and 1.0 MGD pumping
schemes were also tested with analytical calculations that take Into
account the partial penetration of the pumping wells. Finally, captu--
zone calculations were also done to test the scheme. These last two
analyses Indicate that the Interpretation of the flow model simulations 1s
correct, thus results of three approaches corroborate one another.
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APPENDIX III of ROD Attachment 2
AIR STRIPPING
V
Air strfpping 1s a simple* rel iabl e mass transfer process by which
volatile organic contaminants are removed from aqueous solution and trans-
ferred to the a tro^ sphere. By Henry's Law, those volatile components having
a high partial pressure have an affinity for the air phase over the water
phase. As a mass transfer phsnonena, a1 r stripping is enhanced when the
greatest oegree of contact between the a1 r and water stream is provided;
however* Henry's Law and the laws of solubility indicate that complete
removal of organic contaminants by a1 r stripping Is impossible.
To promote good contact of a1 r and water* most a1 r stripping ar-
rangements provide for countercurrent operation 1n packed towers. Con-
taminated water Is directed to the top of the tower where 1t trickles down
over the packing providing a large, constantly wet and renewed area for
mass transfer; at the same time a1 r 1s blown through the packing-from the
tower bottom. The exhausted air stream contains much of the Initial or-
ganic contamination.
It 1s obvious that for a given water flow rate, a point can be
reached where Increasing the air volume to the packed tower will eventually
inhibit and then prevent the downward water flow. This condition 1s known
as "flooding" and typically air strippers are designed to operate at an air
to water- ratio representing the air flow at 605 of flooding. Different
packing arrangements will Influence the point at which flooding occurs and
therefore, the volume of a1 r Introduced will also change. Optlmun strip-
ping will occur when the largest wetted surface area 1s exposed to tne lar-
gest a1 r flow.
-------
The primary advantages of enploying air stripping as a treatment op-
tion are the relative simplicity of tne' equi prcent (ana operation, ana sub-
sequent lower cost over other treatment methoas. Air stripping also
preferenti al ly . removes-those lower weight molecular weight organic com-
pounds least ammenable.to treatment by activated carbon. The major disad-
vantages concern the higher degree of maintenance often required to prevent
scale buildup on the tower Internals and packing, which ultimately leads to
channeling of the water flow through the tower which inhibits treatment.
Chemical pretreatment of the water phase 1s often requl red to remove poten-
tial scale products and suspended sol 1ds» and also to reduce the solubility
of some contaminants to improve their transfer to the air phase. Although
preliminary a1 r stripping designs can be predicted on ;. lor experience, the
optimum a1 r to water ratios, packing arrangements and other pretreatroent
requirements are better established by'pilot scale treatabll 1ty studies.
ACTIVATED CARBON ADSORPTION
As previously Indicated, simple a1 r stripping, while capable of
removing gross levels of volatile organics effectively, cannot achieve an
essentially zero level of contamination in the effluent. Treatment by
highly porous activated carbon 1s the most thoroughly understood and
rel iable process currently employed to remove trace organlcs. It 1s ef-
fective over a broad range of chemical species and treatment levels below
10 ppb hav.e been reported. The less vol atH e organic compounds not removed
by a1 r stripping are often very amenable to this treatment process.
Porous carbon removes contaminants by adsorption, a process wherein
matter 1s e'xtracted from solution and concentrated at the carbon/water
interface, and therefore is known as a surface phenomena. Depending on the
-------
nature cf tne chemical removed/ surface deposition-may be due to low
sol uci 1 ity, the weak Van cer Waals forces* and electrical cr cnanical bon-
ding. Most pr'obably, a combination of these mechanisms are at work.
As a surface attraction phenomena* removal efficiency is enhanced
and contact time subsequently reduced when the Individual carbon particles
are "activated". Activation involves the enlargement of the existing pores
into a macroporous structure, which greatly Increases the surface area of
carbon available for adsorption. The larger the surface area, the
generally more effective the carbon will work to remove a contaminant. Al-
though specialty carbons are available with surface areas as large as 2500
square meters/gram, treatment 'designs employing surface areas of 1000
square meters/gram are more typical. This structure results 1n a material
that 1s highly selective for organic compounds and In particular* very we! 1
suited for the removal of mixed organics from aqueous solution.
* ' '
The mechanisms of adsorption take place by Initial attachment of an
organic molecule to the carbon surface, diffusion through the porous struc-
ture and finally, accumulation on the deep Interior capillary spaces of the
activated carbon particles. In addition to the nature of the carbon sub-
strate, the factors Influencing the adsorption process Include the nature
of the chemical adsorbed, such as Its molecular shape, size and polarity,
the nature and pH of the transport medium, and finally the design and con-
figuration of the equipment hardware.
The abll 1ty of activated carbon to adsorb organics without rerelease
or desorptlon remains nearly constant during the useful life of the carbon.
The end of the useful life of activated carbon for treatment is defined as
"breakthrough", wherein a marked Increase 1n effluent organics concen-
tration is noted. Breakthrough -typically occurs when up to. one pound of
-------
organics has been adsorbed per cubic foot of carbon. In large systems the
spent carton is regeneratea in situ with steam, producing a low volume
aqueous solution of organics for disposal. In smaller systems, such as
described for this report, the spent carbon is exchanged with an outside
venoor for fresh carbon. The vendor then regenerates the carbon at his
facilities for eventual resale and reuse.
The prime advantage of activated carbon treatment 1s its unique
ability to produce an effluent containing almost no organic contamination
over a wide range of organic species and Influent concentrations. It 1s
not particularly sensitive to changes 1n concentration or flow rate. Other
advantages Include good selectivity, no requirement for chenical additions*
ease of waste products hand! ing, overal 1 ease of operation and small space
requlrement-s; however, these advantages come at a price. Activated carbon
treatment 1s often the most expensive treatment option (per pound of con-
taminant removed)/ and therefore, 1s usally reserved as a final "polishing"
treatment after gross contaminant removal.
Aside from cost, other disadvantages 1nd ude the need for
specialized tankage and coati ngs to minimize corrosion, and pref 1 Itering,
to minimize plugging of the carbon pores by suspended solids, which will
Impair treatment efficiency and reduce the useful life of the carbon bed.
Although 1t 1s considered a well developed technology, the
phenomenon of adsorption 1s complex and not necessarily predictable. To
accurately predict system performance, carbon life and the operating
economics, field pilot plant studies are necessary.
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ROD ATTACHMENT 3
PUBLIC RESPONSIVENESS SUMMARY
OLD BETHPAGE LANDFILL
The State of New York held two public comment periods
for interested parties to comment on plans and studies
prepared for the remediation at the Old Bethpage Landfill,
Old Bethpage. The first comment period, held from May 1,
1984 to June 28, 1984, concerned the proposed Interim
Consent Decree. The second comaent period, regarding the
Remedial Action Feasibility Study, began on July 16, 1987
and ended after a substantial extension on September 15,
1987. During this second period, public meetings were held
on July 23 at the Plainview-Old Bethpage High School and on
September 10 at. JFK Kennedy High School in Plainview.
Notification of the meetings were included in the Long
Island edition of Newsday and other local weeklies (Exhibit
A) and individual notices were sent to representatives of
all interested croups. Transcripts of these last tvo
meetings were prepared and available for public review. In
addition, all docunents used in developing the remediation
are available for public review at the Plainview Public
Library, 999 Old Country Road, Plainview, New York.
I. Overview
The Interim Consent Decree set forth the plan and_
schedule for the Remedial Investigation f.RI) and Feasibity
Study (FS) as well as requirements for.interim remedial
-------
measures. Once the RI was completed, the Town of Oyster Bay
i
and its consultants prepared the FS which was immediately |
distributed in July 1987 to those croups and individuals
that had previously expressed interest. Subsequently,
copies were made available to the public as requested and
were also handed out at the first public meeting. The FS
described the alternative remedial approaches considered and
specified the State's subsequent recommendation of the most
effective alternative.
Fifteen classes of response actions were identified by
the OS EPA for consideration in remediating this site.
Within the study, each method was reviewed for health,
environmental, technological and economic factors. In an
initial screening several response actions were removed fro;
consideration because they were deemed inapplicable for one
or more of the following reasons:
The response action offered little or no benefit,
- The response action required technologies which
were not proven;
The response action required unprecedented
technologies which would be technically and/or
economically infeasible; or
The response action required technologies which
have significant inherent environmental or health
risks.. ...
-------
Response actions deemed appropriate for further
consideration i.e. capping, pump and treat, monitoring, etc.
•
were integrated into two remedial concepts:
1) capture- of the contaminated groundwater through pumping
and subsequent treatment, and 2) the provision of an
alternative water supply. These two basic remedial concepts
were then developed into seven alternatives (six of which
were variations of the pump and treat method) for detailed
analysis. The seven alternatives are summarized in detail
below. Their numbers correspond to their listing in the
draft FS.
Alternative No. 1 - Alternative water supply
Alternative No. 2 - Removal-of groundwater by pumping; pipe
to the landfill for use in operation of
the proposed Resource Recovery Facility
(RRF);* and discharge of waste water
from the RRJ into sanitary sewer systen
on.Winding Road.
Alternative No. 3 - Removal of grouncvater by pumping; pipe
to the landfill for treatment to remove
TVOC's; and discharge of treated water
. into sanitary sewer on Winding Road.
Alternative No. 4 - Removal of groundwater by pumping; pipe
-------
to the landfill for partial use in the
proposed' RP.F end for treatment and
discharge of the remaining water to
sanitary sewer system on Winding Road.
(Combines Alternatives No. 2 and No. 3.)
Alternative No. 5 - Removal of groundwater by pumping;
treatment to remove TVOC's, and
discharge .to a leaching field within
Bethpage State Park boundaries (in the
middle of a public golf course).
Alternative No. 6 - Removal of groundwater by pumping;
treatment to remove TVOC's and disposal
in a storm sewer on Plainview Road
Alternative No. 7 - Removal of groundwater by pumping; pipe
(Recommended to the landfill for treatment to remove
Remedial Acrtion) TVOC's. and discharge to a recharge
basic-leaching field system upgracient •
of the landfill.
* A Resource Recovery Facility (RSF) is being proposed
by the Town of Oyster Bay. It will be subject to a lengthy
State permitting process. New York State has informed the
Town, that the State is not willing to accept a remedial
alternative that is contingent upon approval of the F.P.F.
-------
After analysis of these site alternatives, and careful
consideration of public comments, Alternative No. 7 was
selected as the appropriate Remedial Action for this site.
II. History of Community Involvement & Concerns
Community response to the planning stages of the
landfill remediation has been moderate. Certain individuals
and groups in the community continued to inquire about and
monitor the RI/FS process to insure the State's awareness of
community concerns and interests. Some participants in the.
comment process have expressed an underlying skepticism of
the Town of .Oyster Bay's intentions.. Past and actions by
the Town relating to the landfill have resulted in a
*
confrontational relationship between the Town and certain
groups in the community.
Residents Against Garbage Expansion (R.A.G.E.), the
citizen group most active during the public comment periods,
was originally formed to contest the Town's efforts to
obtain State approval for expansion, of the Old Bethpage
Landfill. In addition, other local groups and officials
have participated in the process, including Assemblyman
Lewis J. Tevoli, the Comissioners of the Plainview Water
District, the Plainview/Old Bethpage School Board, and -
members of the Old Bethpage Grade School P.T.A.
. Most of the comments' the State has received fall., into
two categories: 1) those of a precautionary nature, request-
ing the State to monitor closely certain aspects of the
-------
investigation and remedial plan and 2) those of an
accusatory nature, questioning the Town of Oyster Bay's
*
actions and motivations in recommending Remedial Alternative
No. 7. The State is satisfied that all primary concerns of
the community were given adequate attention prior to the
implementation of the RI (per the Interim Consent Decreed
and the ultimate selection of the appropriate Remedial
Action. Following is a summary of the major comments, both
written (Exhibit B) and oral (Exhibit C), received during
the public comment period on the FS and recommended
alternative and the State's responses to these comments.
All comments and responses which occurred prior to the
distribution of the FS are located in the administrative
record.
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EXHIBIT A
NOTIFICATIONS OF PUBLIC MEETINGS
TO DISCUSS THE REMEDIAL ACTION
FEASIBILITY STUDY FOR THE
OLD BETHPAGE LANDFILL, BETHPAGE, NY
Two meetings were held to discuss the Remedial Action
Feasibility Study (RAFS) prepared for the Old Bethpage
Landfill. The meetings took place on July 23, 1987 and
September 10, 1987. .
As public notification for the July 23rd meeting, a
legal notice appeared in the Nassau-Suffolk edition of
Newsday (Attachment 1). A press release was also prepared
and distributed with the RAFS (Attachment 2). In addition,
a copy of the RAFS and an explanatory letter were sent to
approximately 25 individual citizens and leaders of citizen
groups who had previously expressed concern regarding the
site.
Prior to the September 10th meeting, a notice conveying
the details of the meeting was distributed to a number of
community weeklies as well as Newsday's Long Island Agenda
(Attachment 3). Also; another notification letter was sent
to approximately 30 concerned citizens and groups.
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LI 598
22-JUL-37 11:51:22
Legal Notice Legal Notice
LU9«.
NOTICE OF PUBLIC MEETING
TO DISCUSS CLEANUP PROPOSALS FOR
OLD BETHPAGE
LANDFILL, OYSTER BAY
Public notice Is hereby given that *f 7:30 p.m. on Thurxlav, July 23.
1917. the New YorK State Department of Law and Department of Environ-
mental Conservation will no id a pueile meeting In the auditorium of
Plamview-Old Betnpage S«rntor Mlgn School. Southern Pamway and
Central Par* Road. Plainvitw. The our COM at the mating Is to expi-nn
and answer questions on a reoort. officially a "remedial action feasibility
ituov" pursuant to <2 U.S.C. 9601 el a«q'.. wnicn was released on July 16.
1987 by Anorney General Robert Abrams and Environmental Commis-
sioner Thomas C. Jorilng.
The aforementioned reoort. prepared by private consulting engineers
and groundwaier consultants tor the Town of Oyster Bay, sets form an
analysis of alternative proposals and a recommendation lor cleanup of
polluted groynowater ("plume") at fne Old Betnpage Landfill In Oyster
Bav."
The study first evaluated the feasibility of the following general reme-
dial alternatives: I) no action/alternative water supply; 2) excavation of
the landfill (removal of trie solid waste); 3) containment of the grounowa-
ter plume By a suosurtace Darner wall; 4) in puce chemical or biological
treatment of grounowater; J) grounowater extraction (via well pumping)
and treatment.
The initial screening resulted In the relectlon of non-feasible and non-
aopilcaoie remediation* and the choice of seven specific remedial alterna-
tive* tor more thorough analysis to evaluate their relative applicability to
the Old Betnpage Landfill. The factors used In analyzing these alterna-
tives were technical feasibility, environmental Impact, public health ef-
fects and Institutional constraints.
The first alternative studied was the no action/alternative water sup-
ply proposal wnicn would monitor the groundwa'er and public water and
provide alternative water supplies In the future if necessary. Alternative
Nos. 3 through 7 analyzed variations of the groundwafer extraction and
treatment methods and proposed differing locations for disposal. Alterna-
tives 2 through 7 are designed to actively remediate the landfill plum*.
The consultants recommend Plan Alternative No. 7 wnicn include::
I) capping the landfill with a clav cover to significantly reduce leacning-
of chemical compounds from the landfill;
2) Installation of 1 barrier wells to hvdrautlcally control the migration
of contaminated grounowater and pumo It to a treatment facility ;
3) treatment of the collected groundwafer In accordance with ail appli-
cable laws and regulations; and
4) recharge of the treated water 10 the aquifer In accordance wltn «ll
applicable laws and regulations.
Copies of the Remedial Action feasibility Study are available at the
Attorney General's Environmental Protection Bureau. 120 Broadway.
N.Y.. N.Y. 10271 and at Oyster Bay Town Hall on Audrey Avenue and ti«
Plamvlew Public Library. 999 Old Country Road In Plainview. The Stare
will consider all written and dral comments provided to the Environmen-
tal Protection Bureau oy August U. 1967.
Attachment 1
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--:•?. IMMEDIATE -EIZASZ: THURSDAY, JULY 15, 1537
ABRAMS AND JORLING INVITE PUBLIC COMMENT
CM OYSTER 3AY CLEANUP PROPOSALS
Attorney General Robert Abrams and Environmental Commissioner
Thcmas C. Jorlirig today (Thursday) released a consultant's recommendation.
for cleanup of polluted groundwater at the Old Bethpage Landfill in Oyster
Bay. .
In a report and recommendation prepared for the Town of Oyster
Bay, private consulting engineers and groundwater consultants considered
the possible ways of dealing with the underground "plume" of contaminated
water t>.at is spreading from the landfill towards a public drinking water
supply. The report is based on information collected from 23 monitoring
wells drilled around the 65-acre site.
*
The consultants recommended a S7-million plan to capture the
polluted groundwater with five "barrier" wells to be installed in Bethpage
State Park. The water would be pumped to the surface, treated to remove
the pollutants, and discharged back into the ground. :
Preparation and release of the report, officially a "remedial
action feasibility study," was part of a 1984 interim consent decree in a
lawsuit brought by the Attorney General against the Town of Oyster Bay and
several corporations which allegedly sent hazardous substances to the
landfill. The town and the corporate defendants, including Occidental
Chemical Corporation, Cerro Conduit Company, Inc., and Grumman Corporation,
have in turn sued more than 160 other parties.
Filed in Federal Court in Brooklyn on December 9, 1983, the suit
charges that the town and the corporations created, maintained and failed
to correct the environmental problems at the landfill. The case was
referred to the Attorney General by the Department of Environmental
Conservation (DSC), which ordered the landfill to close in 1986.
The interim consent agreement also required further capping of •
Attachment 2
-------
The Attorney General stated:
i
"The proposed remediation offers an opportunity not only
pollution, but also to undo much of the damage that has been done since"
1958. Long Island's groundwater is a precious and scarce resource, and
every-effort must be made to insure its purity and safety.
Commissioner Jorling stated:
"Adoption of the proposed remedial program will assure that the
landfill, will be properly closed and capped in accordance with DEC' s
regulations as soon as practicable. Moreover, the plan will assure that
the site is fully remediated so that environmental threats posed by prior
disposal of toxic wastes will be abated."
The Attorney General and the Commissioner said public comment or
the proposals will be received during the next 30 days. Interested group:
and individuals who desire copies of the study, or to comment on it, shou.'
write the Attorneys General's Environmental Protection Bureau, 120
Broadway, New York, N.Y. 10271. Copies are also available to the F^Bic £
the Oyster Bay Town Hall on Audrey Avenue and the. Plainview Public Library
999 Old County Road in Plainview.
In addition, they said, a public discussion has been scheduled
for July 23 at 7:30 p.m.- in the auditorium of Plainview-Old Bethpage Senic
High School, Southern Parkway and Central Park Road, Plainview.
Representatives of the Attorney General's office, DEC and the Town of
Oyster Bay will be present.
Following the 30-day review, DEC and the Attorney General will.
adopt a remediation plan.
The matter was handled for the Attorney General by Assistant
Attorneys General Robert Osar, Gail Suchman and Nancy Stearns, and Laine
Vignona of the technical staff, under the supervision of James Sevinsky,
.Chief of the. Environmental Bureau. It was handled for the for the DEC by
Joseph Slack, John lannotti and 2riah Davidson of the Division of Eastern
Remediation.
. -30-
-------
G len Cove
Record- Pilot
Ci*n Co • t . u r
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.: 'rcrT.t i:p-, inc.
Nc» I Kile I'.ir'K. N. V.
! 10-10
516-GE 7-10-1?
Meeting For Old
Bethpage Landfill
The New Yoik Siaie Department of Uw
and Department of Environmental Conser-
vation will hold i second meetmc 10 licar
}>uuiic comment on cleanup piouosais for
eroundwaier contamination at me Old
Bctii|OCC Umifill. Ovsicr Nav. wiucii were
presented 111 the "Remedial Act ion l-casiuilitv
Siudv" disinbuicu in mid luiy. The me::mc
will be held at ::;o p.m. on Thuridav.
Septemoer loat lohn F. Kenneth- i lish School.
Copies of ihe study are available •: ;hc
Plamvie-.v Public Liorary and at Oyster Sax-
Town Hail. Written comments on the
proposals will be accepted before September
i;at the Attorney .General's Environmental
Protection Bureau. ::o Broadway. New York. /
•Cleanup For Bethpage Landfill
The New Voix State Department of Law
and Department of Environments! Conser-
vation will hold a second meeting to. hear
public comments on cleanup proposals for
groundwater contamination at the Old
Bethpage Landfill. Oyne; Bay. which* were
presented in the "Remedial Action Feasibility
Study" distributed in mid luly. The meeting
will be held at ?:w o.m. on Thursday,
September ipat joiin F. Kennedy I lieii Sdiool.
Copies of the Studv are amiable at the
Plainview Public Library and at Ovsier Bay
Town Hall. Written comments on the pro;
posali will be accepted before September);
at me Attorney General's Environmental Pro-
tection Bureau.:» Broadway. New Voik. Ncv/
Vork. lorn. /
Oy»i«f
Enttrprisi -
0 r«' •' ••»•'"
AUG 2 11907
• A Ptriooolind Clipping
from
prcjsclips, Ir.c.
New llvile Park. N. Y.
II CMP
516-CC 7-1047
wgsur noij cuirrv"»«T""" '
Meetin For Old Bethpage Landfill
The New-York S::ie Department of Law
•no Department c: E:v.-ircnmen;ii Censer-
•ation'will hold a second r.ee'.inc to hear
;-juiic comment on cleanup jropcsais icr
-•c"nc'.vater ior.::mma:ic". a; tnc d!-
creier.'.rJ :ts me "?.::nru;ii Ac 10:; r.-ss:c»nv
:tudv':0!Striouteci:imiij iu;i T!-.c:v.e-::inc
wi!! be iiciii at r;o p m. on Tiuirsdav.
September toai lohn F. Kennedv HIIM Sc:ico
Copies of liie si'jcy are ava'iacic a: -
Plamview Public Library and at Ovster oa
Town Hail. V.'rnts:i comment' on in
nroacJais •••.•:ll be a'cctpicsi jciore :-:rts:::-:
^otec^oi; surelL.::: r:o.id-.vav.: :•-••.•-
New YOIK. :o:?i.
Attachment 3
-------
r umlnyt 11 • . N. Y
•St? 3 1S87
A PtMOnoliitd Clipping v. .
from
Prcssclips, Inc.
New Hyde Park. N. V.
• 11040
516-GE 7-1047 "
/Cleanup Hearing
The New York State Department of Law
and Department of Environmental Conser-
vation will hold a second meeting to hear
public comment on cleanup proposals for
grouodwater contamination at the Old.
Betrtpage .Landfill. Oyster Bay. which
were presented in the "Remedial Action
Feasibility Study" distributed in mid-July.
The meeung will be held at 7:30 p.m. on
Thursday, September 10 at John F. Ken-
nedy High School.
Copies of the Study are available at the
Plainview Public Library and at Oyster
Bay Town Hall. Written comments on the
proposals will be accepted before
September 15 at the Attorney General's
Environmental Protect ion .Bureau, 120
v Broadway. New York. New York. 10271..
\
Jericho Tribunt
jtrieno. N.Y.
AUG 2 8 1007
A Pertonolittd Clipping
Irom
Prcssclips, Inc.
New HyJw l'.-»rk. N. Y.
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New i I vile I1.irk. N. 'i
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516-CC 7-1047
/^Second Landfill Clean-UP Meeting
Set for Sepl. 10
• The New York State Department of
Law and Department ol Environmental
Conservation wilt tiolU a second meeting
10 near public commcni on cleanup prop-
dial! (or grounuwatcr contamination at
the 010 Bet n page Landlill. Oyticr flay.
which were presented m Hie "Itcmcuial
Action Feasibility SiuJy" JuinrmicO m
illij-july. 1'hc nit cunt; will he liclil .il 7.Ill
PM, Thursday. Sept. 10 ui Julin l:.
Kennedy . High School. MJIICIIO Hill
III I'UlllviCW.
Copies ul i lie Study are available at the
Plainview Public Library and at Oyxcr
Uay Town Mull. Wriiien euminem* on the
prupu>.il> will be accepted hciuie S«pt I 5
.it me Aiurttey General'* Litviromuciiuii
I'tuicctMiii lluie:ui. I 20 UmuUway. Nvw
York. New York. 11)271. —•
Meeting For Old
Bethpage Landfill
The New York State Department of Law
;nu Department of Environmental Conser-
vation wiil holt] a second meeting to hear
public comment on cleanup proposals for
groundwatet contamination at the Old
Scthpage Landfill? Oyster Bay. which were
presented in the "Remedial Action Feasibility
Study" distributed in mid-July. The meeting
will be held at 7:30 p.m. on Thursday.
September 10 at |ohn F. Kennedy HighSchooL
Copies of the study are available it the
rumview Public Library and at Oyster Bay
"Town Hall. Written comments on the
ptocosais will be accepted before September
;s it me Attorney Cenerai's Environmental
N ?:ctcc::onouteau. 1:0Sroadway, l',c» York.
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-------
EXHIBIT B
rial-view, New Ycrk 113C3
September 14, 1987
Mr. Robert -L. Osar
Assistant Attorney General
State of New York
Department of Law
120 Broadway
New York, 'New Ycrk 10271
• • Re: Proposal for Cleanup of Polluted Ground
Water at. Old Bethpage Landfi.il
Dear .Mr. Osar:
Cn Thursday, September 10 the President and Vice-president
of the. Piainview-old Bethpage ; Board of Education, school
attorney and Assistant Superintendent f cr . Business had
the opportunity to attend the public meeting at J.F.Kennedy
High School for the purpose of eliciting public cement
on the report entitled "Remedial Action Feasibility Study."
This report sets forth proposals for the cleanup of polluted
ground .water at the Cid Bethpage landfill in the Town .of
Oyster Bay. .The town's consultants have reccrsended a
S7.0 ailiicn plan to capture the polluted grcundwater with
five "barrier" wells to be installed in Bethpage State
Park. The water would be punped to the surface, treated
to rescve pollutants/ and discharged back into the ground. •
As you know, auch concern was expressed at the meeting
f roa sany cuarters of ' a possible tie-In with a proposed
resource recovery facility. Your assurances that any such
proposal was separate and apart »f roa. .the ground water cleanup
net withstanding, the community continued to express its
Distrust of the .stotives of the Tovn of Oyster Bay officials.
Furthermore, officials cf the ?lainT.-iew Water District
expressed their preference for Alternative =5, vhich would
r.ave deposited treated . wa^sr further avay in Bethpage State
rsrk. Thay drew a corrpariscn betveen their concerns for
strict compliance with clean water standards, and. past
difficulties in cbtair.ing ccn^liance with crders to cl^se
ihe landfill and the "izd " " --....
-------
You pointed out the difference between the Town's prior
"operating" problems and the pure enforcement problem,
indicating that the town would have no motive for failing.
to comply in the event the water treatment plant was not
operating properly. It is this point which the Board of
Education wishes to focus upon, because we feel the potential
exists for just such a motive.
Let us assume that Alternative #7 remains the first -choice,
is approved and implemented. Let us further assume that
the town's proposal for a resource recovery facility, though
separate and apart from this proposal, is also approved
and implemented. It is estimated that the resource recovery
facility will use approximately one million gallons of
water a day supplied by the treatment plant, "which was
separately proposed and implemented. Should this treatment
plant fail to- meet the standards required, we now have
an operational problem as well as a pure enforcement problem,
because the separate resource recovery facility will require
its daily one million gallons.
We are very concerned thatLthis is a more accurate parallel
to prior town activities than you realize and since the
result will be the deposition of polluted water near
Plainview Water District wells, the consequences will be
quite severe.
Very truly yours
AGinl Anna ^Goidell, President
BoerS of Education
cc: Ms. 2. Gail Suchman ^ • .•
-------
ROBERT ABRAMS
JAMES A. SCVIWKY
A«ii*iani Ano"»
Erwnonm»nui Protection BU«MU
STATE OF, NET:- YORK
DEPAFTME.NT OF
120 BROADWAY
NTT YoRk. NT 10271
(212) 341-2461
October 27, 1987
Anna Gcidell
President
Board of Education Plainview-Old Bethpage
School District
Plainview, New York 11803
Re: Letter of Septerr-ber 14, 1SB7
Consenting on Old Bethpage
landfill Remedial Action".
Feasibility.S-ucy
Dear Mrs. Gcidell and
.Men±>ers cf the Board of Education:
Thank you for your attendance at the public neetinr en
September 10, 1987, and your letter cf September 14, 19S7,
proridinr specific cements en the Cld 3e~hpace Landfill
Renedial Ac~ion Feasibility Szucv and the rrc-osed cleanuc
plan/ Alterna~iTe No. T. We have sei fcr~h below rhe
ccrsen~s frcn vour le~ter and ^he respcnse cf the S~a~e to
each cne.
Ycur letter expresses ycrr ccr.cem and the ccr.ce
the ccmuzit~ thai proposed Alterna-ive Xo. 7 vill be
as -supporting eridence by zie Tcvr. cf Oyster Bay iz i
azter.pt to loca-e a Resource Recovery Facility ("?^J"
•the Old Bethace Landfill.
rn cf
5tate Response to Cc=aenz 1
Alternative No. 7 has been proposed by the State
because it is rhe best environmental solution to the
crcundwater probl'ea present at the Old Bethpace landf
Alternative Kc, 7 differs frc~ the other alternatives
in the point cf discharge chosen, 'which is hydraulicE
upgracient cf the roose reccr-ery wes
e disch
a
water, although meeting all allowable federa en sta
discharge requirements, r.sy contain low levels cf
-------
contaminants. Cr.ly Alternative Kc. 7 provides a discharg'
location which will result in the recycling of this
potentially contaminated discharge water back through the
recovery system. _ This. ._water will be recaptured and
retreated and, therefore, will not escape into a
non-contained environment. -Furthermore, reinjection of the
water into the system will speed the cleanup of the plume by
"pushing" it nore quickly toward the recovery wells.
In addition to the recognition of the environmental
benefit-resulting from implementation of Alternative No. 7,
Alternative Nos. 3, 4 and 6 were deemed unacceptable because
those alternatives would take approximately one and cne-half
million gallons of water per day from this portion of the
aquifer, without replacement, contrary to the long Island
groundwater conservation policies set forth in 6 NYCR£ Part
6C2. Alternative Nos. 2 and 4 were also rejected because,
as stated is the public meetings and the Remedial Acticn
Feasibility Study (see pages 3-1, 3-7 and 4-1), the State
rejected ar.y remediation which relied en the existence cf a
resource recovery facility for its operation. Alternative
Kc. 7 does net rely en a resource recovery facility fcr its
operation nor does it result in a contravention cf the water
conservation regulations.
Since the reasoning described above resulted in the
rejection of Alternatives Nos. 2, 3, 4 and 6, the only other
active remedial alternative was Alternative No. 5. That
alternative was rejected fcr the reascr.s set forth in the
State's respcr.se to Comment 2, herein. Therefore, the-best
remedial alternative, chosen on its own-merit, is
Alternative No. 7.
V'iile it is true tmat t.-.e implementation cr'Alternative
!:e. 7 vill allsv tie Tevm to argue ir. its ?.?.? permit
application tbat. a source cf water vill be available at the
landfill/ tiat argument .is hardly fisrcsitive cf the
rultit-ce cf. legal, environmental and tecnniral issues that
vi'll need to be decided befcre the Department cf •,
Invireraertal Conservation (DZC) can grant a permit fcr
constractioa cf the ?^T. la.point cf fact, all the "?u=p
and treat" remedial alternatives would provide a source of
vater fcr the ?^J. The small expense cf rrnr.ing a pipe from
any discharge site to the ?JIF vculd allcv the Town to argue
that a sccrce cf vater was available frcm any cne cf the
proposed remedial alternatives.
The granting of a permit for the ?.?.F is s. totally
separate and distinct legal process frcz; the process vhicb^
resulted in tr.e selerticr. cf Alternative T'c. ~. Ths
consideration of the ?.".? recuires a complicated ZTC
adr.imistrati'.'s trccscurs, subject to. cub lie hearing and
-------
comment, which will' decide 'whether the P.RP can be permittee.
That decision, rust as-the decision to select Alternative
No. 7, will be r.ade on the merits of the RRF itself, not on
the fact that there happens to be process water available at
the site. The RET will need to pas-s strict technical and
legal requirements for-discharge, monitoring, performance,
etc. Even if the RET passes all those permit requirements,
in order to be connected with Alternative No. 7, there would
have to be technical confirmation that it would meet all the
very stringent treatment and discharge requirements of the
'remedial- action consent decree.
la-sum, there is absolutely no significant legal cr
technical advantage which accrues to the. Town in its
application for the RET by the selection cf Alternative
Nc. 7 over the other remedial alternatives.
Comment 2; Pace 1', oaracrarh 3.
• The officials cf the ? lair, view Water district expressed
their preference for Alternative ?5. '
State -tespcr.se to Comment 2 . . . '
«
As explained in detail in the response to the comments
submitted by the Plaiaview Water District's consultant (copy
attached hereto), the State strcagly disagrees vita tie
Commissioners' preference for Alternative Kc. 5 over
Alternative So. 7. Alternative !,"o. £ studied the
feasibility cf locating a discharge.basin closer to the
recovery wells so that the cost cf piping the ground.water, to
tbe landfill could be avoided. Areas vithin apprcr-rima.tely .
-:«•>._•; ~ rn — oo" "- —'~,o — a«-"v*~V Vs " " 5 -^-e—o a ' - — «,— > —o- Xc —i-«cc
it was determined that the recnar-s cf ens s^d ens—half
r^.llicn r=.llc~s • cf water a isy vitiir. tr.at iistir.cs wculd
interfere vitn tie effertiveriSss cf the nydraulic barrier to
be created bv these puzipir.g wells. Areas immediately to the
east ar.d west.cf the lar.dfill plur,e --ere also eliminated as
possible discharge locaticr.s because those areas are
potentially impacted by ether sources cf contamination.
Tie only potential area left for recharge under
Alternative Kc. 5 was the southernmost portion cf Sethpage
State ?ar3c, i.e., the n-Lcdle of a public golf course.
Construction cf a five acre treatment and recharge system in
the middle cf a public golf course would create a host cf
institutional prcbler.s. Ir^ addition, the recharge cf
treated croundwater in that area would be outside and
dcvngradient cf the hydraulic containment system, ar.c
approximatel 1GGO feet upgrai^er.t cf the r.e&rest Villar
e. ci
rarr.ingdc.ls public drinking well. . This is cf ccr.cerr.
because ths treated crroundvatsr msv ccntain lev lsvs_s on
-------
contamination. In addition, there is always a , __.
that th'e treatment system could temporarily ciaifunction,
•In contrast, the Alternative-No.7-discharge location
ensures that the treated groundwater is recycled through the
system for additional treatment, at no risk to the
upgradient Plainview wells (see Response to Comment 5). The
environmental benefits of Alternative No. 7 weighed against
the problems associated with Alternative No. 5 justify its
selection as the appropriate remedy for the site.
Comment 3r Page 1, paracrash .2.
The Plainview Water District Commissioners expressed
.concern that .even though strict discharge criteria would be
applied to the cleanup, -the State has experienced a great
deal of difficulty in the past in.obtaining compliance by
the Town with orders to close the landfill and the
incinerator, both of which were operating "illegally."
State Hesrior.se to Ccrrsent 3 •
This is an enforcement action to implement a cleanup of
contaminated groundwater, not cne to enfcrce permit
conditions at an operating facility. The consent decree _
resolving tnis enforcement action will be monitored by the"™^
State and the Court. The decree vill provide that the State
vill have the right to shut down the cleanup.operation, if
it is not meeting the requirements cf the consent.decree.
The consent decree will require the Town to'implement all
necessary modifications required to bring the remedial
program into compliance with all treatment and discharge
criteria trier te re—start. Sines there is no incentive fer
the Tsvn to operate tie remedial program unless it is in
ccrtliance viti State req-uirsr.er.ts and any ne--ecr:tliaz.ee
vill be immediately stepped by the State, tiers is no reason
to believe tiat consistent cr repeated ncn-ccmtlianee vill
?ace 2, paragraphs 1 and 2.
Cnce tie. Resource ?.«covery Facility becomes part of the
remedial program., the possibility cf non-compliance becomes
a concern because the Town will have incentive to keep the
Resource Recovery Facility (like the old incinerator)
State ?.estor.se ts Cement 4
~f the ?»PF is perr.ittec. and if ir is allowed to use
ya-er~frcm the .remedial program, it will then be required to
•set bcth its perr.it ccn-iticns" anf, tie requirszisnts ef the
-------
remedial action consent decree. One cf the conditions that
the State will insist upon, if the recovery water is used in
the RRF, is that the RRF will be shut down immediately if it
fails to meet the air and water discharge requirements of
the consent decree. Therefore, the concern over consistent
or repeated non-compliance is unfounded because the
existence of the consent decree, providing immediate resort
to a U.S. District Court Judge, ensures compliance, with all
federal and state discharge requirements.
Comment 5: ?aoe 2, saracraoh 3.
We believe that this ncn-cc~pliance will result in the
disposal cf polluted crouncwater near Plainview Water
District wells. •.'
State Respor.se to Cc^mer.t 5
• "Polluted" crouncwater vill not be .deposited near
Plainview wells. As stated abcve, the water, whether
discharged from the treatment facility .cf Alternative No1. 7
cr the ?.?.? (if perritted and allowed to accept recovery
water),. will be required to meet all applicable discharge
criteria. If the discharge water does not neet those
criteria, the consent decree will provide that the State can
shut down the cleanup operation (the recovery wells) until
the Town makes sufficient modifications and adjustments to
neet; consent decree standards.
Furthermore, regardless cf the ccr.ta~inant levels in
the discharge water, it will not reach the Plainview public
criticize veils which are 2500 feet hydraulically upgracient
cf the pcint cf discharge. As explained in greater detail
in the rsscsr.se tc the crcuncvater consultant tc the Wacer
t±is recharged water vill zct rescr. the Plair.Tiev wells. I-
asditic-/ =cr_itcrir,g well(s) will be placed between the
pcirt cf discharge sr.d the Plsir.view veils to ir.scre that
these calculaticr.s are accurate and that no izpect vill .
ccczr cr tie Plainriew wells. If either discharge
violations occur cr the ncnitorir.g wells indicate a
potential impact en Plainrjew wells, the cleanup program
will be shut covri izrr.edicteiy rntil apprspriate
modifications are r.ace cr, if necessary, a new discharge
location is found. . • ....
We again wish to thar.k you fcr your ccrjzer.ts and ycur
tarticitatic~ ir. this nublic trscess. .'v'£ have-trcvidec
with this letter the sr.tire package of written responses to
all ccrr-ents r.sds at tr.e zuclic r.eetir.cs ar.i as subr.ittec ir.
-------
After considering all 'the public ccrjnents received tfl
date,.the Stare has formally selected Alternative No. 7 as
the appropriate remedial alternative for this site. This
selection will now be .submitted to the United States
Environmental Protection Agency for review and concurrence
consistent with current regulation and policy. If that
concurrence is .obtained, the remedial alternative will be
set forth in more detail in a Remedial Action Plan which
will be attached to a Consent Decree resolving the pending
litigation. This Consent Decree will prox-ide for
remediation cf the landfill and set forth the obligations c:
'all the parties with respect to that remediation. The
Remedial' Action Plan and the Consent Decree will be subject
to a public comment period prior to final approval by the
United States District Court. . Copies of these documents
will be provided to the public on a tinely basis.
Sincerely,
ROBERT L. OSAR
I . GAIL SUCEKXK
Assistant Attornes General
210 :rl
Zr.clcsures
-------
OLD BETHPAGE PTA
>
i
ROO'P SWAJklF RO/UD. OLJ3 BETHPAGE. NEW YORK 11804
September 20, 1987 "
Ms. Z. Gail Suchman
Assistant A--crr.ey General
Environmental Protection Bureau
120 Broadway
N'ew York, New York 1C271
Dear Ms. Suchmar.:
I know that you wanted any responses on the "Remedial
Action Feasibility Study" and "The Evaluation of Air.Stricter
Emission Impacts on Air Quality en the Oyster 3ay Solid Waste
Disposal Complex" .by September 15th. Since I had just received
my copy on September 10th and wanted to consult with our expert:,
for their opinions, it was impossible to compile ny comments-
that quickly. I hope you will still be able"to take this under
consideration.. .
As to the Air Emission Study, we have two comments -
First, when working with the modeling approach there are
certain drawbacks, the input parameters can be adjusted to have
the desired results referring to Table 2.2 on Page 3 where the
Air Stripper Emissions Data are tabulated with all the maximum
emission rates falling well below the problem amounts. What if
the original amounts guessed were inaccurate? What if the
amounts are much higher than expected going into the air strippe1
wouldn't that chance the emission rate possibly, drastically?__..
Secondly, no where in this report is there any mention of the cc
situation caused by air stripping. Even if the expected amounts;
are accurate and we con't have to worry, about inhaling toxic
emissions, when-you blow off these-constituents into the air-,-th
smell would have to be horrendous. This will impact seriously
en the entire neighborhood abutting the lan-dfill.
Our last comment has. to do wi.th the sludge. The plan
and, therefore, should be treated as hazardous waste ar.d dispose
cf accordingly.
Cn ber.alf of cur senior citiier.s, as veil as the. children
-------
Ms. I. Gail Suchnan September 20, 1937
Assistant Attcrr.ey General • Pace . 2 .
of cur community, we suggest that this problem must be give:
careful consideration.
Once again, we appreciate- the time delay and hcpe that
you will be able to give my comments your consideration.
Sincerely yours,
."
£L/ltc • Zllen Levine
President
Copy To: Assemblyman Lewis J. Yevcli
RAGE
Plainview-Old Bethoage Central
School District
-------
ROBERT ABRAMS
JAMES A. SEVHSKY---
Aintum Anomvv Ge««ril m
i Proi«Cion SufMU
STATE OF NET YORK
DEPARTMENT or
120 B«OAD*IAY
You*. .NT 10271
(212) 341-2461
October 27, 1987
Illen- Levine
President
Old Bethpage Grace School ?TA
Round Swair.p Road
Cld Bethpage, ls*Y 11804
• . • Re: Comments on Old Bethpage
Landfill Remedial Action
Feasibility Study
^»^»^» M»M«W^» MM ^B^M^B^V ^M^V«M ^» ^B ^» ^B> ^M ^B ^M «i» ^9 C
Dear Mrs. Levine:
. Thank you for ycur participaticn in the public aeetir.c
on September 10, 1937, and for your letter of September 20,
1S87, providing specific consents en the" Cld Bethpage
Landfill Reaedial Action Feasibility Study ar.d the proposed
cleanup plan, Alternative No. 7. V,e have set forth below
the ccrrserts fr.oa your letter and the responses of the
State. " '
Ccrtrr.ent So. 1: V
-------
Therefore, the recovery water obtained from this plume
initially will contain a relatively low ccncentraticn cf
chemicals. These low concentrations will be reduced furthli
by treatment of the groundwater prror to discharge.
Calculations were performed to estimate the anticipated
levels cf contaminants in the air and water discharge after
treatment.
Every calculation performed in the feasibility -study
and subsequent studies, including the latest modeling
effort, assumed a worst case scenario, i.e., the worst
contamination in the plume (plus a 30 percent safety factor)
would have to be treated continuously and the worst
treatment conditions would prevail continuously. Sven under
these worst case conditions, these calculations demonstrated
that the air discharge in -this remediation will fall well
below acceptable 'standards. As further assurance, the Town
will be required by the Consent Decree to meet those
standards. Therefore, even if the projected calculations
are in errcr, the Town will be required, regardless of cost
and- effort, to modify and adjust its treatment system until
it meets the required air discharge standards. The State
will not allow the systea to continue operation unless it
meets all appropriate standards.
la short, the studies have shown, based upon the knovn.
cbeaical concentration of the plume, that the air and wat«j
discharge standards vill be set. More importantly, ™
regardless of what the studies indicate, the Town will be
required, as a matter of legal obligation in the Consent
Decree, subject tc enforcement by a United States District
Ceurt Judge, to meet those air and water, discharge
requirements. There is neither a factual r.cr a'legal reason
to believe that the air emission levels' as.sceiated with this
remediation will cause adverse impact en the community.'
2; Ths cder frcm these air emissions vill be
nerrsneeus.
?.esrense ??e. 2
As stated above, the air emissions emanating from the
air stripper will be substantially below relevant standards,
Furthermore, the modeling study demonstrates that the
=az:irrc=i ir-paet cf these air emissions vill occur within the
***— 3 ~* « c r* <" ^Vo * a *•»*» — * T 1 «*^.
W**w C«» «• 5 9 w«> ^ *i S ^&**
-------
threshcld analysis for the air stripper emissions to
reconfirm that there is ng potential odor problem cffsite.
The consultant ccr.parec peak short term emissions at the
landfill boundary to recognized odor thresholds for a number
of chemical compounds existing in the landfill plume. The
study demonstrated -that no odor .thresholds were exceeded
beyond the. landfill boundary. In other. words, at the
concentrations to be emitted by the air stripper, no odors
will be detectable offsite.
If through actual operation of the air treatment •
system, air emissions do not meet appropriate air standards,
the Town will be required to modify the" system until such
standards are met. Furthermore, it is important to note
that because the landfill will be capped with a clay cover
and the methane gas collection system, continued as part of
this remediation, its overwhelming impact will be to reduce
odors frc:n the landfill, net increase them.
Cement !?o. . 5 : The plan placing sludge back into the same
landfill seems shortsighted. This sludge is gcing to be
Sestrcr.se N:e. 3
We assume that, the sludge referred to in your cement
is the sludge from the leachate collection system, discussed
en page 1-4 of the Jteaedial Action Feasibility Study. This
collection syster, operating since 19E3, removes =etals arc
selids frcsi. collected landfill leachate.- The sludge
generated consists primarily cf the treatse-t ager.t,
hydrated lime, and ssali aaour.ts cf metals and solids.' The
system produces about six cubic yards cf sludge per year,
the eruivalsr.t cf approximatel four 53-gal.lcn cru=s.
The practice cf the landfill cperators has been' to
tlacs the sludc s bac/c in the landfill. If this sludcs
rsnsrates nev Isachats, it v:ill be recaptured and retreated
through the leachate collection syste-. Fcr the future,
hsve'/er/ the State will reruire, ir. the Consent Decree, that
the sludrs ~o Icn-sr hs dscositec hacx in ths landfill.
Instead, the sludge will be transported to an approved waste
disposal facility as long as the leachate collection systes
continues to operate. Cnce the landfill is capped, the
Town's ccasultart has estimated -that ceneraticr* cf leachate
vill cease in approximately five years after capping.
Ke again wish to. thank you for your ccrrr.e-ts and your
participation ir. the public process. We have provided vith
this letter the entire package cf written responses tc all
ces3?.er.ts made at the public meeting as well as 'those
I*~B". •••»•"«• ••a** .'-«•» s** — '— a •».. v * « •• **crr*?e** ts received to
-------
-4-
cy. tat
urrence is obtained, the remedial alternative will be
. prove or remea
of the landfill and set forth the obligations of all the
parties to that litigation with respect to that remediat
pares o a tgaton wt respect to that remediation
The Remedial Action Plan a.nd Consent Decree will be subject
to a public comment period prior to final approval by the
United States District Court. Copies of these documents
will be provided to the public en a timely basis.
Sincerelv,
303SP.T L. CSA3
' I. GAIL SUCEKAN
Assistant Attorneys General
3LO,SGS:cw
** *• w* •
2LO:SGS:cw
-------
ru • GROUP
Holzmacher, McLendon and MurreU. P.C. • H2>L"R?gold. Inc. • H2M Labs. Inc.
;~5 Bread Hoiiow Road, Meiviiie. N.V. ii~-i7-5C~6
(516) -56-8000 • (201) 575-5-iOO
September 24, 1987
Robert Osar, Esq. .v
New York State of Law •
120 Broadway
::ew York, New York 10271
Re: Old Bethpage Landfill
Remedial Action Feasibility Study
Dear 'Mr.. Osar:
This letter constitutes the written comments of the Plain-
view Water District in response to the July 15 and August
17, 1987 notices 'df the Department of Law. These comments
are intended to .supplement the oral remarks presented at
public hearings of September 10 .on behalf of the Board of
Commissioners of the Plainview Water District.
Background .
Kolzsacher, McLendon and Murrell, P.C. C-I2M) has served as
consulting engineers for the Plainview Water District for
over thirty years (January, 1955). In that capacity, we
have, designed much of what today constitutes the Plainview
Wacer District. H2M's responsibilites have included design
of cheir wells, production plants, treatment and storage
facilities and the distribution system. K2M has been
intimately involved with the planning and development of the
District. I have served as our firms' engineer for
Plalrview fpr ever six years. I am a licensed professional
engineer with over twenty years experience and an officer
(Vice President) at' H2M."
Statement . ' .
The Board of Commissioners entirely supports 'the concept of
'acciveiy remediating the contamination affecting groundwater
southeast of the landfill. It is their view that re- .
mediation must include at a minimum the removal-of ccnt^r.i-
-------
GROUP
Robert: Osar, Esq.
Page 2
The Board holds that the issues raised in the Remedial
Action Feasability Study (RI/FS) must be held separate from
those of the resource recovery plant. This conforms to the
views expressed by you at the two public hearings held en
the subject. Any opinions raised en the need for remedia-
tion at the landfill site or the merits of the alternatives
proposed by the Town through its consultants must be consid-
ered only in the narrow context of the RI/FS. The District
is concerned by the tenor of a number of alternatives set
forth in the RI/FS, specifically alternative No. 7.
In regard to alternative No. 7, the District feels that
there is a decided bias in conjunction with an en site
resource recovery plant. In fact this alternative appears
to have an ulterior purpose.- providing a source of supply
water for the proposed resource recovery plant. The Dis-
trict opposes having RI/FS alternatives tied into this
separate matter, directly or indirectly, and requests assur-
ances that no such tie in is contemplated or will enter into
the decision of the Department of Law.
It should be pointed out that the review of the RI/FS alter-
natives has. been narrowly focused on the potential effects
of the proposed action on well field No. 5 of the Water
District. This well field on Winding Road is less than 1/2
mile north of the area proposed by the Tows in alternative
No. 7 for recharge of treated groundwater. Well field No. 5
has four active public water supply wells with, an- approved
total capacity in excess of 8 mill ipn_ gal Ions perjiay. This
well field furnishes about forty percent of the capacity of
tie Plaizview Water District.*
Gera'ghty « Miller, Inc. prepared a-letter-report dated
September 8, 1987 in response to expressed concerns
regarding the potential effects of recharging.1-1/2 million
gallons so near to plant No. 5. Their analysis indicates
effects more than half way to plant No. 5 and this is with-
out taking into account the down stream influence of plant
No. 5's pumpage. Despite assurances that monitoring will be
provided and that the Plainvisw Water District will r.avs
.•__.,_ .•_.._, ~ — o — «•••««•••«•••—/•• •»•—••• ^"—a T>ie — "--'f~~ "ST-ia^'-'g
• ^•* «•• W «•• «• «^ *»»*G 1. II r - II • •»«•• ^•••3 w • «•*• f <•••• w M^MWWwWtw AW«.L&«**^
unc-'cmfcrtable wizh the. prcximity cf ~hs pretcssd r5ch=.rcr=..
The District would prefer a greater, distance and believes
_ •_ - _ _ - _ _«_ __;^.e •»-„ - «•„«..-.; -_a _„-_,._
-------
3-JL' GROUP
?.obert_psar, Esq.
Page 3
Alternative No. 5 provides the same, groundwater remediation
benefit at much less risk to the Plainview Water District
and at significantly lower cost. The RI/FS report provides
no technical argument against . this option. Evidently,
according -to the RI/.FS, alternative No. 5 will allow for
maintaining a suitable hydraulic barrier.. Further, since
the contaminated water is to be. treated to groundwater class
GA recharge standards,, there should be no problem with
groundwater quality impacts. The concept of treating the
water continuously, as is suggested by alternative No. 7,
has . not been shown to provide a benefit sufficient to
justify the additional cost. This marginal benefit night
very -well be or should be accomplished through more
efficient treatment in the first instance.
The cost data provided in the RI/FS indicates that. alterna-
tive No. 7 will c.ost over one million dollars more than No.
5. The Plainview Water District would hope that the
Attorney General ' s office would take . into account the
greater risk that alternative No. 7 presents, as well as the
additional cost, particularly when no demonstrable benefit
has been presented. It is for this reason that the District
feels, that the only justification for alternative 7 is the
assistance it may provide for the proposed resource recovery
plant. •
The Plainview Water District appreciates, the opportunity
creviced by the Department of Law -.to review and comment en'
the RI/FS." . - .. ...
Very truly yours
C*» • "2 /•* t~>>— /•*/•%••*••» *—^^A—av^ "DTa^-^^T'OLJ ^Ca^o^* ^i^^**^^r"te
«« • ^w w« ww**»*«^oo^U^It±«.o# - — <^ — «-v *"w A&H.V.. «/.d«-*.u.w
-------
STATE or NIT YORK
DEPARTMENT or LA^
120
ROBEUT ABRAKS
NET ^oiu. NT 10271
JAMES A. Scvwsrr ^ ^ ^^
""'" "" (212) 341-2461
October 27, 1987
7~'-»- T MC"^ 1 QV "5 ^
U — ar-ni W • »-t*^>^W^ f • • «* •
^<^*\«w*pkj|-»«i»«^ W^"mF**-r»^
nM_^^lfiW*lC« / .*M.tfWC**«k<«***
i Hurrell, ?.C.
575 2road Hollow Road
helrille, N.Y. 117S7-5076
Re: Old Sethpage Landfill
Remedial Acticn
Feasibility Study
you for ihe ccrments set rcr-ih is your letter
dared September 24, 1557, ar.d rereiTed by cur cfrice cr.
Sertez^er 30, IS 57, ccncerziag the above referenced
feasibility study, we ur.derstar*d -rhese— ccmer.^s r
s1: -ibe cral re^arxs ycu r^de ic tbe public bearir.r
cn Sepie=ber 10, 1SH7, and zhat.b'czii se-s' cf ccrmezts • were
race en bebaif cf the Beard of Cc=issisners cf the
?lair,riev Wacer District. Cur responses :.n this letter vi
be directed st«ecificillv tc- tbe consents in vcur Ss-teiber
14 letter. To the extent that your cral consents at the
reetinr raised other issues not addressed by this letter,
those cc=:er,ts have been responded to in the enclosed
do curient entitled "?.espcnses to Oral Cozrents."
state at page 1: "The Board of Commissioners
entirely supports the.concept of actively remediating the
contamination affecting groundvater southeast of the
landfill. It is their view that remediation must include a:
a minimuci the ramoral of contaminated groundvater, its
treatment and recharge. The remediation plan must prevent .
the further spread of contamination into the Magcthy
-------
John J. Mclloy, P.I. '
October 27, 1967 . .
Page -2-
Rftsoor.se to Cosaner.t 1
We thank the Board cf Commissioners for its support of
the method of active remediation chosen. The pump and treat
remediation, providing for recharge cf the treated ground-
water, will achieve""the goals, the Board has emphasized,
i.e., the removal and treatment of contaminated grouiiawater
and the prevention of its spread, both horizontally and
vertically.
Comment No. 2
The Board holds that the issues raised in the 'Remedial
Action Feasibility Study must be held separate from the
Town's proposal to build a resource recovery plant at the
Landfill. The Board believes that the proposed remedial
Alternative No. 7 will be used by the Town to provide a
source cf water for the proposed plant and therefore create
a "bias" in favor of using the landfill site as the
preferred location for the .plant.
Response to No. 2 .
As stated in your letter, the State has reiterated on
all occasions, in public and in-writing, the fira position
that.the proposed remediation, Alternative No. 7, has bees
and will continue to be evaluated solely on its own merits.
Similarly, the decision as to whether the proposed resource
recovery plant will be located at the landfill is subject to
an entirely separate Department.of Invircnmental
Conservation permitting proces.s. The State has told the
Town, throughout tnis remedial selecticn process, that it
would not accept a remedial alternative which relied en the
cperaticn. Cne cf the reasons that Alternative Kc. 7.
survived the selection process is that it did .net rely en
the existence cf the resource recover-.- facilitv for its
T>€ fail to see a favorable "bias" fcr locating this
plant at the landfill created by the se/1-ecticn of
Alternative Kc. 7. Ycu have indicated the Board's support
for a ?u=p and treat/recharge syster,. Any .cf the ?'^r,p and
treat alternatives, no natter where the recharge is located,
will provide a potential source of water fcr the resource
recovery facility. The projected cost cf the resource
recovery facility is over 150 n\illion dollars. The cost cf
piping frcm the recovery wells to the proposed location cf
the plant is approximately cne millicr. cellars. Obviously,
ir.. £ project cf this sire, the cne r.illicn cellar ecst cf
piping is inecnseruisntial. Additionally, there already
e::ists a well (criginally us&d .for the r.ov . closed
£• • a • • a ^ » ^s»» ** *» o ^ ^ *» ^ ** A **W«««»«^M^«S «b*«k^«*
*• c ^.S. A w-«, WS — ww »..S v*w«w5Cte -• — £«.. - •
-------
John J. Moiioy, F.L.
October 27, 19B7
Page -3-
Finally, and most .importar.tly, the Town cannot obtain
approval to locate the resource recovery plant at the
landfill without meeting a host of "legal, technical, and
environmental perir.it and policy criteria. The mere
availabiity of water ct the site is an insignificant, if not
irrelevant, fact in meeting those exacting criteria.
Comment No. 3
The Board expresses its continued concern that the
recharge water from Alternative No. 7 is too close to the
public drinking wells in. the- District's Well Field No. 5,
and therefore may impact those wells.
P.esoor.se to Comment No. 2
Piainview Weil Field No. 5 is 2500 feet upgradier.t of
the recharge location proposed in Alternative No. 7. The
Town's gro.undwater consultant, Geraghty « Killer (GiM) , has
prepared mounding calculations, presented to you, which have
demonstrated that the Alternative No. 7 recharge water vill
have no impact on the groundwater beyond a point which is,
at a maximum, 1300 feet upgradier.t of the recharge. 'This
point, i.e> the "stagnation point", is at least 1200 feet
downeradient from the nearest Piainview water supply wei
The State has accepted these calculations. You have nct.
provided us vita any infcrr.at.ion which would indicate to
that these calculations are in errcr.
You state, in your letter that the GiM analysis did r.ct
take into account the "down stream influence" cf Well Field
No. 5's pumpage. That statement is literally accurate but
-ct technically accurate. The information ycu have prorided
tc the State and the Tcvs indicates that the nearest -ublic
well purps at a depth cf ever 550 feet in the aruifer. In
contrast, the Aitsrzat-ve No. 7 rec.-.s.r=s vill be cccurrizr
feet. There is zo tecr.r.ical reason to take "dsvt strea=n
..__«» •— Va** ?*A*- Vf» ~ - — — ~ ..__.._. ^_ i.-_0 ^^..'—^^^.
in,.act c_ ^-s__ . _e__ J>G. ; ....w 0————.- _.. «^e _.——.——..-
caicuiaticz because/ net criy ars the wells in Field No. 5
located at a substantial distance upcradiezt frc= the
stagnation point calculated for the recharge, tb>ey are also
influencing a deeper portion of .the aquifer than, the r.ound
cf the recharge. Therefore, there is no basis for cur
technical staff to assume a greater vertical impact frcr,
this recharge r.cund on the Plainriew wells. This issue has
'"•oe** ~*s"e^'ii* f~~+ *»*«"^o"»r^*^c ^*^**»ae^^^*^c *^ ^'^o '•^^'"•^"co /^" r^**"
^ «&•* • G*^ S 6^ W.« A* «M**t5* O *•» fe W ^ ^&«p •» «^.. O _.. **A C «rW*»*Aw ' *» — W •-.
discussions vith you ever the last two -cnths. You have
provided us with no information or calculaticn which would
cause tbe State to alter its assessment. If you have ar.j
informaticn cr calsulcticn wr.icz csr.or.stretes £ greater
vertical-impact, we would cf course expeditiousiy consider
-------
John J. Mciioy, P.£.
October 27, 19-87
Pace -4-
Additionally , as stat'ed in ycur letter, ground-water
monitoring will be conducted to verify the GiM calculations
and the true impact of any recharge" mounding. The final
consent decree will provide that_, if_ there is any
demonstration of threat to the public cirinking wells, the
Town will immediately cease operation of the remedial
program at the State's demand until the threat is.
eliminated. As we stated at the public meeting .and in our
previous discussions, you are welcome to participate in the
development of a monitoring program to define the mounding
effects of the Alternative No. 7 recharge.
r.t No. 4 • • •
The Board believes that Alternative No. 5 should be
selected as -the appropriate remedial plan. The Board points
out that the feasibility study raises no technical argument
against that option and since the recharge water will be
relatively free of contamination, it will net impact
grouncwater cuality. The Board. points out that Alternative.
Kc." 5 will cost approximately one million dollars less- than
Alternative No. 7.. . . .
se to Cosaent Nc. 4
The State strongly disagrees with the Board's
preference fcr Alternative No. 5 arid will attezr.pt below to
point out all tie reasons why Alternative No. 5 is less
desirable from an environmental, technical, • and public' .
health standpoint than Alternative No. 7. In pointing out
these reasons, we must admit that all cf them were net
specifically articulated in tbe remedial feasibilty study
itself. The feasibility study is a dccur.fent wbich resulte
frcm a Icnc and detailed r.erctiatic=. s.~z. tec.~r.ic
cccunent. Tne ccc*—ezt zcr ~~° nest cart cresentec. t~,e
"conclusions" cf that process. Kir.y cf these reasons were,
bcwever, presented by the State at the public neeting
(September 10) ir. the discussion cf the rejection cf
Alternative Nc. 5. A reconsideration cf tie appropriateness
cf Alternative No. 5 after the September 1.0. meeting, has
Alternative Jic. 5, in general terns, searched fcr a
recharge location close to the recovery wells so that the
cost cf piping the water back to the landfill could, be
avoided. Ir. cur ir.iticl discussicr.s cf this alternative,
.the technical staffs cf the State &r.d the Town agreed t.-.a.t
=.r.y pcter.tis.1 Alternative :^"o. 5 recharge location crust .-rest
two preconditions: 1) the location cculc-net- interfere wit_~-
•the efficiency cf the recovery wells themselves; &nc 2) t.-.e
-------
John J. Molloy, P.Z.
October 27, 1SS7
Pace -5-
contamination to the east and west cf the landfill, the
Nassau .County Fireman's Training Facility (west) and
Ciaremont•Polychemical (east).
The first criterion eliminated any location within
approximately 2500-<30CO feet of the pumping wells, the
estimated combined impact of the recharge and the cone of
influence of tne pumping wells. (Unlike the Plain-view Well
Field No. 5, these recovery wells would be pumping at a
depth closer to that impacted by the recharge mounding, see
Response to Comment No. 3). Basic elements of the
calculations demonstrating the need for approximately
2500-3000 feet of separation were verified in the recent
field pump test. Since it is required that the these
recovery veils create a hydraulic barrier fcr the plume of
contamination, the addition cf a mounding effect to this
cone cf influence would, in the opinion of the State and
Town, diminish the effectiveness of the required hydraulic
barrier. Due to the proximity to the landfill plume of the
Fireman's Training Center and Claremont sources of
contamination, locations east and west of the landfill plume
and down-gradient cf those .sources were sutiiarily rejected.
Therefore, the only area left for potential recharge
under Alternative No. 5 was the southernmost portion cf t;
Bethpage State'Park, an area currently used as a public
course. Since approximately five acres of contiguous land"
would be needed to construct such a treatment and recharge
system, the feasibility study focused on" the "institutional
prcbier," inherent in attempting .to locate a five acre
recharge system in the middle cf a public golf course. This
reascn alone provided'a sufficient basis fcr the State to
reject Alternative No. 5, particularly when an acceptable
1 - -Is .= .• ' 1
e
rrradisnt cf the recover*/ veils (. -.Items. tive No.
).
There are certainly ether reasons why Alternative No. 5.
should be rejected. Zn fact, cne cf the reasons in succcrt
cf Alternative No. 7 is a reascn fcr the rejection cf
Alternative Ss. 5.-
Alternative No. 7 is preferable because it heeps all
the discharge water, even if only "slightly contaminated, "
within the groundwater containment system thereby creating a
closed system. This allows fcr the continuous recapture and
rstreatr.ent cf the ccntar-inated water. Furthermore, the
reir.jecticr. cf water in the system will speed .the .cleanup cf
the plume by "pushing" it mere quickly toward the recovery^
wells. In. contrast, Alternative No. 5 would place the ""
slightly ccntar.ir.ated discharge water outside -the
containment system, at a point only 1CCO feet upgraiier.t cf
-------
John «- Mollov, P.E.
October 27, 19£7
?aoe -6-
wcuid have the. potential t® reach those wells. This
situation differs from that iii Alternative Nc. 7 in which
the discharge point is "cowngradier.t" of the Plainview wells
and contamination will not move upgradier.t past the
stagnation point. The additional treatment of the
Alternative No. 7 discharge water at no increased cost (your
suggestion of further treatment of the Alternative No. 5
discharge water would require significantly increased ..
treatment costs) is certainly cost-effective and a desirable
environmental- result..
The discharge location in Alternative No. 5 is also of
concern -if the treatment facility should malfunction thus
temporarily placing contaminated groundwater only 1000 feet
upgradient of public wells. This is not a concern with
respect to Alternative No. 7 because this contaminated water
would not move past the upcradient stagnation point.
Additionally, even if monitoring did indicate movement of
contamination past the stagnation point-, the pumping and
recharge system could -be temporarily shut off allowing the
contaminated recharge water to flow back into the
dcvncradient regional flow. Ar.y contaminated vater released
at the discharge location is Alternative Nc. 5 could not be
recaptured without' installing a nev remedial system at 'great
exper.se.
In sum, we disagree with your conclusion that
Alternative No. 7 presents no demonstrable benefit over
Alternative Ko. £. We believe that Alternative No. 7
represents r.o risk that can be demonstrated at this time and"
can be mczitcrsd ar.d easily remedied if ar,y risk appears.
It provides .a contained er.vircrjr.er.tal clear.up which is cf
cegrse cz c— eajiup. «»e cn_y pcssiw»e discharge •ccaticii rcr
Alterr.ative ;»c. 3 (tie other lscatic~s are technically and
er/rircrjrer.tally u-acceptable) is institutionally
uiLTs2.scr>2J?le sir;cs tr.£ lar.d is currentl*-* a tublic self
ezvirorjz.er.tal or health risks .may not be so easily remedied.
Suci risks ars r,ct accsptaile is viev cf. a demczstrated
alternative. The decision to select Alternative !>o. 7 is
scumdly based and is r.ct corjaected is any way vith the
pctantial Iccaticz cf the resource recovery facility.
We again vish to tha-k you for your csn=er.ts and your
participation in this public process en behalf cf the .
rlainview vr&tsr District. We have provided vith tr.is letter
the entire ackage cf written responses, to all comments made
After considering all the public comments received to
State has formally selected Alternative Nc. " as
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John J. hclloy, P.I.
October 27, 1967
Pace -7-
selection will now be submitted to rhe United States
i-vironaental Protection Agency for review ar.c concurrence
consistent with current regulation "and policy. If that
concurrence is obtained, the remedial alternative will be
set forth in mere detail in a Remedial Action Plan which
will be attached to a Consent Decree resolving the pending
litigation. The Remedial Action Plan and the Consent Decree
will be subject to a public comment period prior to .final
Court approval. We will contact you directly, however, as
scon as a proposal exists for the upgradient monitoring of
Alternative No. 7.
Sincerely,
303SP.T L. CSAR
Assistant Attorneys Genera!
Enclosures
=10/ZGS:bjs
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EXHIBIT C
STATE RESPONSES TO ORAL COMMENTS
REMEDIAL ACTION FEASIBILITY STUDY
CLP BETHPAGE LANDFILL, BETHPAGE, NY
The State of New York held two public meetings to
discuss the Remedial Action Feasibility Study and the
recommended remedial alternative for the Old Bethpage
Landfill. The purpose of the first meeting, held at
Plainview-Old Bethpage High School on July 23, 1987, was to
1) explain in detail the grounewater investigation conducted
at the landfill, 2) define the environmental problem
identified, 3) present the remedial feasibility study
prepared by consultants for the Town of Oyster Bay, and 4)
describe in detail the recommended cleanup proposal.
Approximately seventy-five (75) people attended che meeting.
Comments and questions were taken and a transcript made.
This meeting lasted for approximately four hours. A second
public meeting was held on September 10, 1987, at the
Kennedy High School in Plainview, to receive formal comments
on the feasibility study and recommended cleanup.
Approximately fifty (50) people attended this second meeting
which lasted approximately two and a half hours.
Transcripts of both meetings "and all documents referenced in
these responses will be made available at the Plainview
Public Library. .
At the first public meeting, the bulk of the comments
focused on the short period of time (one week) provided for
review of the feasibility study prior to the meeting. It
was also requested that the comment period be extended
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beyond the summer vacation period. in response to those
comments,, the public comment period was extended to
September 15, 1987, and the second meeting was scheduled for
September 10, 1987.
Since the purpose of the first meeting was to provide
information to the public, a consultant for the Town
provided a detailed presentation, through slides, maps, and
technical information, which described the investigation
conducted, its results, and the various cleanup proposals.
Many of the public comments and questions at the meeting
were directed tc the technical issues presented. These
questions were answered by the Town's consultants and the
State's legal and technical representatives, as reflected
the transcript. Several comments presented at the first
meeting were reiterated at the second meeting or in the
written comments received.
A brief description of significant comments and
questions presented at both meetings is set forth below.
This listing does net include the initial comments solely
concerning scheduling carters which are no longer relevant
in view of the State's agreement to extensions. In order to
avoid repetition, if a comment listed below has been
addressed elsewhere in this document or in response to
written comments, only a reference t& that response will b(
indicated.
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Julv 23, 1987 Public Meeting
Comment: Anna Goidell, President, Plainview-Old Bethpage
.School Board
What guarantee is there that the hydraulic containment
system in the proposed cleanup plan will be effective?
State Response
Modeling studies and calculations were performed by the
Town's groundwater consultants which indicate that the "pump
and treat" system described in the feasibility study will be
effective in maintaining hydraulic control of the
contaminated groundwater plume. Actual pump tests conducted
in the field this -summer have verified the input data of the
model and those calculations. More importantly, the Town
will be legally required, under a consent decree resolving
the pending litigation, to achieve and maintain effective
hydraulic control. The proposed consent decree provides
that the Town will be required to modify, enchance, and
repair the system to achieve and maintain this control.
Failure to do so will constitute a violation of the consent
decree which can be enforced expeditiously by the Federal
Judge who will maintain jurisdiction over the consent
decree.
-3-
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Comment: Julius Wallach
Where do the contaminants end up after the air
stripping process?
State Response
The recommended remediation initially utilizes an air
stripping process to treat the contaminated groundwater.
The treatment process volatilizes the contaminants in the
groundwater and disperses them into the air. Calculations
and modeling have demonstrated that the treatment facility
(air stripper) will meet all applicable air standards. Thei
consent decree will require the Town to meet and maintain
compliance with those standards. Continued compliance will
be monitored. For further/ more detailed discussion, see
the State's October 27, 1987 letter to Ms. Ellen Levine,
Response to Comment No. 1, enclosed herewith as.attachment
1.
Comment; Carol Spielberger
Why is a "Proposed Resource Recovery Facility" depicted
on the maps included in the feasibility study? Has the
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State looked at discharge locations for the treated water
other than that set forth for the recommended renediation,
•
Alternative No. 7.
State Response
See extensive responses provided in the State's
October 27, 1987 letter to Mr. John Kolloy, Response to
Comment Nos. 2 and 4, and the October 27, 1987 letter to Ms.
Anna Goidell, Response to Comment Nos. 1 and 2, both letters
enclosed herewith as attachments 2 and 3, respectively.
Comment: Ellen Levine, PTA President
What will be the impact of air emissions from the
cleanup on the community?
State Response
See responses provided in the State's letter of October
27> '1987 to Ms. Ellen Levine, Response to Comment Nos. 1 and
2 (attachment 1).
Comment: Assemblyman Lewis T. Yevoli
Assemblyman Yevoli requested information concerning the
credentials of one of the Town's consultants, Lockwood
-5-
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Kessler and Bartlett (LKB), and its experience in hazardous
waste site cleanups. He also asked whether the State took
split samples during the groundwater investigation program
and whether sampling results indicated any contamination to
the north of the landfill resulting from "mounding".
State Response
The Town of Oyster Bay has provided the State with a
packet prepared by LKB in response to Assemblyman Yevoli's
request for LKB's professional credentials «nd experience.
It is enclosed herewith as attachment 4. In response to the
other comments, the State undertook extensive split sampling
and independent laboratory analysis during the landfill
investigation. This effort confirmed the sampling results
obtained by the Town. The results of all sampling to date
have not shown any significant contamination north of
landfill resulting from mounding. Monitoring will be
conducted during the remediation to continue to confirm this
assessment.
Comment; Marlene Mendelsohn, Residents Against Garbage
Expansion (RAGE)
Is there a possibility that the groundwater plume of
contamination from the landfill is moving in a direction
other than the direction identified in the investigation?
-6-
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State Response
•
Principles governing movement of groundwater, in
conjunction with the voluminous data, particularly water
level measurements, obtained in the remedial investigation,
show that groundwater under the landfill is moving toward
the south-southeast. This conclusion is consistent with
what has been shown in other studies to be the regional
groundwater flow in this area. There is no evidence of any
significant component of groundwater flow in a direction
inconsistent with this regional flow.
Comment; Ogo Perzan
Mr. Perzan asked a number of specific technical
questions. The major questions are as follows:
1) Based upon the estimate that the grcundwater
in the Long Island aquifer moves approximately one foot per
day, why hasn't the plume of contamination extended over a
mile horizontally from the landfill by this time?
2) Recognising possible contribution to the plume
from industrial sources in the Claremcnt road area [to the
east], why is there contamination at well N-189 [to the
west]? Since well N-1S9 is a shallow well, is there a
-7-
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possibility that shallow constituents are moving in a
i
different direction than deeper constituents?
3) Was the use of leachate indicators a proper
way to define the plume of contamination at this landfill?
5) Was the Random Walk model used to demonstrate
the distribution of the plume? Was. the model calibrated to
consider the low levels of contamination found in the plume?
State Response
Mr. David Miller of Geraghty and Miller (G & M), the
Town's groundwater consultant, answered all of Mr. Perzan'
questions at the public hearing. The State generally
concurs with the answers he provided. Mr. Perzan did not
provide any followup comments at the September 10, 1987
public meeting or in writing to the State. The answers to.
his questions are available for review in depth in the
transcript of the July 23rd meeting at pages 67-77 and
86-90. Briefly, the State's responses to the above
questions are as fellows:
I) The gzour.cwater investigation cowngradient of
the landfill showed the rate of groundwater flow .in that
area to be less than one foot per day. Furthermore, i
contaminants do not move at the same rate as groundwater.
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Contaminants cling to particles of sand and other soil
materials as they move through the groundwater thereby
slowing their migration. This slowing of contaminants is
called retardation and the rate of retardation is one factor
in measuring the rate of contaminant movement per day as
opposed to groundwater flow per day.
2) Well N-189 is located in and controlled by the
Bethpage State Park. That well was closed to further use in
1984. It is directly downgradient of the Nassau County
Fireman's Training Center ("FTC"). Based on current data,
it is more likely that the low levels of contamination found
in this well resulted from the FTC or an unknown local
source than from the landfill plume.
3) It was agreed by the State and Town that
sampling for known landfill leachate indicators was an
appropriate investigating tool to define the leachate plume
emanating from this municipal landfill. Once the leachate
plume from the landfill was defined, the wells in that plume
were sampled fcr a full range of organic and inorganic
chemicals. This approach was effective in defining a
distinct plume of organic and inorganic contamination
emanating from the landfill as opposed to contamination from
other potential sources in the area such as Claremont
Polychemica-1 to the east and the Fireman's Training Center
-9-
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to the west. Although the landfill leachate plume is larger
than the organic and inorganic plume being remediated, thl^P
leachate indicators found outside the area to-be remediated
do not exceed State groundwater standards.
4) There are several acceptable computer models
capable of demonstrating the distribution of the contaminant
plume. Random Walk is one. The Town's consultant, G & M,
utilized the Prickett-Lonnguist model. A field pump test
was conducted this summer which verified certain input
used in that model. This field data has provided both State
and Tcwn technical personnel with a certain degree of
confidence in the anticipated effectiveness of the remedial
program. It is important to note/ however, that modeling
only a predictive tool. Extensive monitoring has yielded
data on the actual contaminant levels in the groundwater.
Future monitoring will continue to define those levels of
contamination and the effectiveness of the cleanup.
Comment; Mary DeKanner
Is there a connection between the remedial plan and the
proposed resource recovery facility?
-10-
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State Response
See extensive responses provided in the State's
October 27, 1987 letter to Mr. John Molloy (attachment 2),
Response to Comment No. 2, and the October 27, 1987 letter
to Ms. Anna Goidell (attachment 3), Response to Comment No.
Comment: Brian Culhane, State Legislative Commission On
Water Resources
Will the recharge of the recovery water upgradient of
the landfill cause a mounding problem under the landfill and
cause more leachate?
State Response
Calculations performed by the Town's consultant have
indicated that water levels cue to recharge will not rise
sufficiently to result in grouncwater contacting refuse in
the landfill. Furthermore, the recommended remedial
alternative, which will recharge treated groundwater
upgradient of the landfill and the recovery wells, provides
for a hydraulic system to contain and treat all groundwater
contaminated by the landfill until cleanliness standards are
met. Therefore, if- the recharge should produce new
leachate, the Town will need to adjust its recharge to
prevent new leachate
-11-
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formation or continue pumping its system as long as leachate
«
production continues.
Comment; Russ Haven, New York Public Interest Research Group
Referring to the number of wells used to investigate
groundwater contamination on industrial sites in western New
York and to Department of Environmental Conservation
estimates of the costs of cleaning up municipal landfills,
not enough wells were used to define the contamination
problem at the landfill and the estimated cost of the
cleanup/ $7 nillion, is too low.
State Response
As described by Mr. Miller/ 46 wells were used to
evaluate the groundwater contamination er.araating from the
landfill. State technical staff were, involved in the
formulation and implementation of the remedial investigation
which yielded reliable results. The $7 million figure
represents solely the estimated cost of the cleanup of the
groundwater plume. The entire cost of remediating the
landfill, estimated to be about $20 million, is comparable
to DEC estimates.
-.12-
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Comment: Ron Dimonda
How long will the cleanup take?
State Response
The Town's consultant has estimated approximately ten
years for cleanup. The consent decree will require the Town
conduct the cleanup until the. termination criteria of the
decree are net.
September 10, 1987 Public Meeting
Comment: John Molloy, on behalf of the Plair.view Water
District
The Board of Commissioners supports the concept of
fully remediating the contamination affecting groundwater
southeast of the landfill by utilizing a pump, treat and
recharge system. The Board is concerned about the impact of
the recharge of the treated recovery water on the Plainyiew
public drinking wells, cr.e-h.alf mile upgracient of the
recharge. The Board requests a commitment to monitoring
upgradient of the recharge and wishes to hove input into' the
development of the monitoring plan, assuming the recommended
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remedial alternative calling for recharge upgradient of the
landfill -is chosen (Alternative No. 7). the Board considers
recharge in the State Park downgradient of the landfill to
be a better alternative (Alternative No. 5)* The Board
requests that all data and reports developed during the
remediation program be provided to the Board. The Board
requests a commitment for full reimbursement by the State of
all expenses incurred in correcting any drinking water
problem in the Plainview wells caused by the remediation.
State Response
' With the exception of the last two comments, all of Mr.
Molloy's comments have been addressed in the State's Octobe^
27, 1987 letter to Mr. Molloy (attachment 2). In response
to Mr. Molloy's last two comments, all data and reports
generated as a result of the remediation will be made
available to the Board. Upgradient monitoring wells will
provide an effective warning system, so that contamination,
if any, will be prevented from migrating toward the
Plainview wells. (See State's letter to Mr. Molloy). .
Since there is no technical basis to assume that
contamination will reach these wells, there is no basis to
request the State to commit to provide compensation for
"hypothetical damage".
-14-
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Comment; Assemblyman Lewis J. Yevoli .
•
Assemblyman Yevoli expressed concern about the Town's
future attempt to connect the recommended remedial
alternative and the proposed resource recovery facility for
the landfill. [Messrs. Robert Goldstein Julius Wallach,
Bernard Chetkoff, Bernard Abrams, Donald Rosen, and Ms.
Ellen Levine expressed a similar concern.]
State Response
See extensive responses provided in the State's October
27, 1987 letter to Mr. John Molloy (attachment 2), Response
to Comment No. 2, and the October 27, 1987 letter to Mrs.
Anna Goidell (attachment 3), Response to Comment Nos. 1 and
4. ' .'
Conmer.t; Robert Goldstein cf RAGZ
The cleanup plan must protect air and water and must be
independently monitored. All data must be open to public
inspection.
State Response
The State agrees with the above comments and will
insure that these goals and requests are met.
-15-
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Comment: Bernard Chetkof, Chairman of the Plainview Water
Remedial Alternative No. 5 from the feasibility study
should be chosen by the State -instead of Alternative No. 7
[Mr. Jacques Wolfner expressed a similar concern].
State Response
See extensive responses provided in the State's October
27, 1987 letter to Mr. John Moll'oy (attachment 2) , Response
to Comment No. 4, and the October 27, 1987 letter to Ms.
Anna Goidell (attachment 3), Response to Comment No. 2.
Comment: Ellen Levine, PTA President
Will -che State consider Mr. Molloy's comments regarding
Alternative No. 5? Has any new information been developed
concerning possible air-, contamination from the air stripper?
State Response
The State has considered Mr. Molloy's comments
regarding Alternative No. 5 and has responded in the October
27, 1987 letter to Mr. Molloy (attachment 2), Response to
Comment No. 4. In response to the second question, the
State provided Ms. Levine with a copy of a modeling study
conducted by the Town's air consultant. This study is
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further discussed in the State's October 27, 1987 letter to
Ms. Levine's (attachment 1), Response to Comment Nos. 1 and
2. . • •
Comment; Jules Bernstein
Will capping of the landfill be included as part of the
remediation. Kow long will the cleanup take? Dees the $7
million cost included monitoring? Will the State check the
results of the Town?
State Response -
The.landfill will be capped as part of the proposed
remedial program. The remediation will continue until the
State required termination criteria are met. The Town's
consultant estimates that time to be approximately 10 years.
The cost of the groundwater remediation includes a complete
monitoring program the results of which will be checked and
verified by the State.
Dated: October 27, 1987
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ROBERT ABRAHS
Anomey General
J*SES A. SEVISSKY
Atdttanl Attorney General in Cnaroe
Environmental Protection Bureau
STATE op NET YORK
DEPARTMENT OF
120 BHOADWAY
NET YORK. NT 10271
(212) 341-2461
October 21, 1987
Zllen Levine
President
Old Bethpage Grade School ?TA
Round Swamp Road
Old Bethpage, NY 11804
Re: Comments on Old Bethpage
Landfill Remedial Action
Feasibility Study
Dear Mrs. Levine: •
Thank you for your participation in the public meet:.r.=-
cn September 10, 1537, and for your letter cf September 20,
19S7, providing specific comments en the" Old Bethpage
Landfill Remedial Action Feasibility Study and the proposed
cleanup plan, Alternative No. 7. We have set forth below
the comments from vcur. letter and the responses cf the
State.
'•* • ^ "^ woee**g«»^ ^ ** * V .a ^ *• • • «S » • ****'«• «S**^etao*3
S» ^^ « «^«sa ^^^ •
__.-*pt:_ J /
parameters (i..e. , the ccr.tar.ir.ar.t levels in the r
to" be treated) will be r.et. If these ccr.t amir. ant
higher than assured, won't the impacts cf the air
from the stripper be changed drastically?
Response No. 1
rcur.dwater
levels are
emissions
As stated at the public meeting arc ir. the ether
written comments attached herewith, extensive chemical
analyses were performed en the plume cf contamination
emanating from the landfill. These analyses demonstrate
^•*a^ ^ V^ c» ^**n **t o i*'^'1» <•*•*"'•! ^aT*o •'^ c**»o r^ooc **O^ ^i*^***»a*rij
_..c >. w..s «. J. \— ^lc , c _ _. ,C w w n _ c . •-• e ... s^4.e, u^ca «.u» ^.^...c — .i i
high concentration cf ccr.tar.inants . As th'is plume is pumj
through the recovery wells, the contaminated grouncwater
will be mixed with sicnificant amounts of clean water.
Attachment. 1
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Therefore, the recovery water•obtained from this plume
initially will contain a relatively low concentration cf
chemicals. These low concentrations will be reduced further
by treatment of the groundwater prror to discharge.
Calculations were performed to estimate the anticipated
levels cf contaminants in the air .and water discharge after
treatment. • .
Every calculation performed in the feasibility study
and subsequent studies, including the latest modeling
effort, assumed a worst case scenario, i.e., the worst
contamination in the plume (plus a 30 percent safety factor)
would have", to be treated continuously and the worst
treatment conditions would prevail continuously. 2ven under
these worst case conditions, these calculations demonstrated
that the air discharge in this remediation will fall well
below acceptable standards. As further assurance, the Town
will be required by the Consent Decree to meet those
standards* Therefore, even if the projected calculations
are in error, the Town will be required, regardless of cost
and. effort, to modify and adjust its treatment system until
it meets the required air discharge standards. The State
will not allow the systen to continue operation unless it
meets all appropriate standards.
. In short, the studies have shown, based upon, the known
chemical concentration of the plume, .that the air and water.
discharge standards will be- met. More importantly,.
regardless of what the studies indicate, the Town .will be
required, as a. matter of legal obligation in the Consent'
Decree, subject to enforcement by a United Spates District
Court-Judge, to meet those air and water cischarg.e
requirements. There is neither a factual nor a legal reason
to believe that the air emission levels associated with this
remediation will cause adverse i=oact or. the cor.nur.itv.
he cdcr frcr. these air emissions w;
.-crrsr.zcus.
P.espcr.se No. 2
As stated above, the air emissions emanating from the
air stripper will be substantially below relevant standards.
Furthermore, the modeling study demonstrates" that the
maximum ir.pact cf these air emissions will occur' within the
boundaries cf the landfill nrcoertv. There will- be r.o
... Te
presence cf odors is directly related to the concentrations
of contaminants in the air emissions. Since the maximum
ir.pact of these low level air emissions will be well within
the landfill boundary, the air stripper emissions will r.ct
create an odor problem beycnd the landfill.
Subsecuent to receipt of your written comments, we
asked the -Town's air modeling consultant' to conduct an odor
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threshcld analysis for the air stripper emissions to
reconfirm that there is no potential odor problem cffsite.
The consultant compared peak short terr. emissions at the
landfill boundary to recognized odor thresholds for a number
of chemical compounds existing in the landfill plume. The
study demonstrated that no odor thresholds were exceeded
beyond the landfill boundary. In other words, at the
concentrations to be emitted by the air stripper, no odors
will be detectable offsite.
If through actual operation of the air treatment
system, air emissions do not meet appropriate air standards,
the Town will be required to modify the system until such
standards are. met. Furthermore, it is important to note
that because the landfill will be capped with a clay ccver
and the methane gas collection system continued as part of
this remediation, its overwhelming impact will be to reduce
odors from the landfill, not increase them.
Cornent !?o. 3; The plar. placing sludge back into the same
landfill seems shortsighted. This sludge is gcing to be
loaded with toxic contaminants.
Hespcr.se Ko. 3
We assusne that the sludge referred to in your coment
is the sludge from the leachate collection system, discuss
en page 1-4 of the Remedial Action Feasibility Study. This
collection syster., operating since 19S3, recove.s metals and
solids from collected landfill leachate. •? The sludge
generated consists primarily cf the treatment agent,
hycrated lime, and snail amounts cf metals and solids. The
system produces about -six cubic yards cf sludge per year,
the equivalent cf approximately four 53-gallcr. dru=s.
The practice of the landfill operators has been to
rises tr.e slucce back ir. the l^r.cfill. If this sludge
generates new leachate, it will be recaptured and retreated
through the leachate collection system. ~cr the future,
r.o-wever, the State will require, ir. the Consent Decree, that
the sludgs ro longer be deposited back ir. the landfill.
Instead, the sludge will be transported to an approved waste
disposal facility as long as the leachate collection systen
continues to operate.. Once the landfill is'capped, the
Town's consultant hes estimated that generation cf leacrate
will cease in approximately five years after capping.
We again wish to thank you for your ccr-.ents and your
participation in the public process. We have provided v:ith
this letter the entire package of written responses to all
submitted in writing.
After considering all the public ccranents received to
date, the State has formally selected Alternative No. 7 as
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-4-
the appropriate remedial alternative for this site. Thi«
selection will now be submitted to the United States
Environmental Protection Agency for review and concurrence
consistent with current regulation -and policy. If that
concurrence is obtained, the remedial alternative will be
set forth in more detail in a Remedial Action Plan which
will be attached to a Consent Decree resolving the pending
litigation. The.Consent Decree will provide for remediation
of the landfill and set forth the obligations of all the
parties to that litigation with respect to that remediation.
The Remedial Action Plan and Consent Decree will be subject
to a public comment period prior to final approval by the
United States District Court. . Copies of these documents
will be provided to the public on a timely basis.
Sincerely,
>L»4i
ROBERT L. OSAR
. • E. GAIL SDCEKAK
Assistant Attorneys General
RLO,SGS:CW .
T'WI f
?JLO:SGS:cw
-------
STATE or NET YORK
DEPARTMENT OF
ROBOT AMAXS 120 BUOADWAY
NET Yo«. NT 10271
JAMES A. StviMcr
i Anomwv G«n«r»i m I
(212). 341-2461
October 27, 1987
John J. Mclloy, P.E.
Holzmacher, McLendon
& Murrell, ?.C.
575 Broad Hollow Road
hteiville, N.Y. 11767-5076
Re: Old Sethpage Landfill
Remedial Action
Feasibility Study
•» 4M ^ ^ » •* »> »^ • ^
You state at pace 1: "The Soars cf Cc=rissicners
entirely supports the concept cf actively remediating the
contamination affecting grcundwater southeast cf the
landfill. It is their view that remediation rust include a:
a rir.ir.uz: the removal of1 contaminated crcunsva-rer, its
treatment and recharge. The remediation plan r.ust prevent
the further spread cf contamination into the Kagothy
acruifer."
Attachment .2
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John J. Kclloy, P.E.
October 27, 1957
Page -2-
Response to Comment 1
We. thank the Board of Commissioners for its support of
the method of active remediation chosen. The pump and treat
remediation, providing for recharge cf the treated ground-
water, will achieve the goals the Board has emphasized,.
i.e., the removal and treatment of contaminated grouse-water
and the prevention of its spread, both horizontally and
vertically.
Comment No. 2 .
The Board holds that the issues raised in .the Remedial
Action Feasibility Study must be held separate from the
Town's proposal to build a resource recovery plant at the
Landfill. The Board believes that the proposed remedial
.Alternative No. 7 will be used by the Town to provide a
source of water for the. proposed plant and therefore create
a "bias" in favor of using the landfill site as the'
preferred location for the plant.
Response to No. 2
As stated in your letter, the State has reiterated on
all occasions, in public and in writing, the firm position
that the proposed remediation/ Alternative No. 7, has been
and will continue to be evaluated solely on its own merits.
Similarly, the decision as to whether the proposed' resource
recovery plant will be located at the landfill is subject to
an entirely separate Department of • Zr.virbhr.snta!
Conservation permitting process. The State has told the
Town, throughout tnis remedial selection process, that it
would not accept a reriedial alternative which relied en the
existence cf the resource recovery facility fcr its
cperaticr.. One cf the reasons that Alternative No. 7
survived the selection process is that it did net rely en
the .existence of the resource recovery facility for its
cperaticr..
We fail to see a favorable "bias" for locating this
plant at the landfill created by. the selection of
Alternative Kc. 7. You have indicated the Beard's support
for a pur.p and treat/recharge system. Any cf the pump and
treat alternatives, ho matter where the recharge is located,
will provide a potential source of water fcr the resource
recovery facility. The projected cost cf the resource
recovery facility is over 150 million collars. The cost of
piping from the recovery wells to the proposed location of
the plant is approximately cne million collars. Obviously,
in a project of this size, the one million collar cost .of
piping is inconsequential. Additionally, there already
exists a well (originally used for the now closed
incinerator) on the landfill property which could be used as
a .water source for the proposed plant.
-------
John J. Molloy, P.E.
October 27, 1987-
Page -3-
Firjally, arid most impo'rtaiitiy, the Town cannot obtain^
approval to-locate the resource recovery plant at the
landfill without meeting a host of"legal, technical, and
environmental permit and policy criteria. The mere
availabilty of water at the site is an insignificant, if not
irrelevant, fact in meeting those exacting criteria.
Comment No. 3
The Board expresses its continued concern that the
recharge water from Alternative No. 7 is too close to the
public drinking wells in the District's Well Field No. 5,
and therefore nay impact those wells.
Response to Ccmment. No. 3
Plainview Well Field No. 5 is 2500 feet upgradient of
the recharge location proposed in Alternative No. 7. The
Town's groundwater consultant, Geraghty & Killer (G&K), has
prepared mounding calculations, presented to- you, which have
demonstrated that the Alternative No. 7 recharge water will
have no impact on the grour.dwater beyond a point which is, '
at a .maximus, 1300 feet upgracient of the recharge. This
point, i.e, the "stagnation point", is at least 1200 feet
downgradient from the nearest Plainview water supply well
The State has accepted these calculations. You have not
provided us with any information which would indicate to us
that these calculations are in error. .
You state in your letter that the GSM analysis did r.ct
take into account the "down stream influence" cf Well Field
No. 5's pur.page. That statement is literally accurate but
r.ct technically accurate. The ir.fcreation you have provided
tc. the State and the Tcvs indicates that the nearest public
well ?ur.ps at a. depth cf ever 55.0 feet in the aquifer. In
contrast, the Alternative Kc. 7 recharge vill be cccurrir.g
in the --per per tics cf the aquifer at depths cf cr.ly 40-50
feet. There is r.o technical reason to tar.e "dovn stream"
ir.pact cf V.'ell Field No. 5. ir.to account in the r.cunding
calculation because, not only are the wells in Field No. 5
located at a substantial distance upgradient fro= the
stagnation point calculated for the recharg.e, they are also
i::fluer.cir.g a deeper portion of the aquifer than the mound
of. the recharge. Therefore, there is no basis fcr cur
technical staff to assusie a greater vertical impact frcrn
this recharge mound on the ?Iair.view wells. This issue r.as
been raised en numerous occasions in the course cf our
discussions with you over the last two months. You have
provided us with no information or calculation which would
cause the State to alter its assessment. If you have an
information cr calculation which demonstrates a greater
•vertical impact, we would of course expeditiousiy consider
it. . . .
-------
John J. Mclloy, P.E.
October 27, 1987
Paoe -4-
Additionoiiy , as stated in ycur letter/ grouncwater
monitoring will be conducted to verify the G&M calculations
and the true impact of any recharge" mounding. The final
consent decree will provide that, if there is any
demonstration of threat to the public drinking wells, the •
Town will immediately cease operation of the remedial
program at the State's demand until the threat is
eliminated. As we stated at the public meeting and in our
previous discussions, you are welcome to participate in the
development of a monitoring program to define the mounding
effects of the Alternative No. 7 recharge. "~.
Comment No. 4
The Board believes that Alternative No. 5 should be
selected as the appropriate remedial plan. The Board points
out that the feasibility study raises no technical argument
against that option and since the recharge water will 'be
relatively free of contamination, it will not impact
grouncwater quality. The Board points out that 'Alternative
No. 5 will cost approximately one million dollars less than
Alternative No.
7.
Response to Comment No. 4
The State strongly disagrees with the Board's
preference for Alternative No. 5 and will, attempt below to
point out all the reasons why Alternative No. 5 is less
desirable from an environmental, technical, and public
health standpoint than Alternative No. 7. In pointing out
these reasons, we must admit that ail cf them were net
specifically articulated in tbe remedial feasibilty study
itself. The feasibility study is a document which resulted
from a Icng and detailed negotiation ani technical dialscue
between the Town anc the State. All the preliminary
discussions which transpired are net set forth in that
document. The ccc'ur.ent fcr tbe mcst part presented the
"conclusions" cf that trccess. Many cf these reasons were,
however, presented by the State at the public meeting
(September" 10) in the discussion of the rejection cf
Alternative Kc. 5. A reccnsideraticn cf the appropriateness
of Alternative No. 5 after the September 10 meeting has
reconfirmed the reasons fcr its rejection.
Alternative No. 5, in general terms, searched for a
recharge iocaticn close to thfe recovery wells so that the
cost of piping the water back to the landfill could be
avoided. . In cur initial discussions cf this alternative,
the technical staffs of the State and the Town agreed that
any potential Alternative Xc. 3 recharge location must meer
two preconditions: 1) the location cculd not interfere with
the efficiency of the recovery wells themselves; and 2) the
recharge could not be located in an area potentially
impacted by two ether suspected (since confirmed) sources of
-------
John J. Molloy, P.E.
October 27, 1S67
Page -5-
contamination to tne east a'nc west cf the landfill, the
Nassau County Fireman's Training Facility (west) and
Claremont Polychemical (east) .
The first criterion eliminated any location within
approximately 2500-3000 feet cf the pumping wells, the
estimated combined impact of the recharge and the cone of
influence of the pumping wells. (Unlike the Plainview Well
Field No. 5, these recovery wells would be pumping at a
depth closer to that impacted by the recharge mounding, see
Response to Comment No. 3) . Basic elements of the
.calculations demonstrating the need for approximately
2500-3000 feet of separation were verified in the recent
field pucp test. Since it is required that the these
recovery wells create a hydraulic barrier fcr the plume of
contamination, the addition of a mounding effect to this
cone of .influence would, in the opinion of the State and
Town, dininish the effectiveness of the required hydraulic
barrier. Due to the proximity to the landfill plune of the
Fireman's Training Center and Claremont sources of
contamination, locations east and west of the landfill plume
and cowngradient of those sources were sijr.ilarily rejected..
Therefore, the only area left for potential recharge
under Alternative No. 5 was the southernmost portion cf
Sethpace State Park, an area currently used as a public, go
course. Since approximately five acres of contiguous land
would be needed to construct such a treatment and recharge
system, the feasibility study focused on" the "institutional
problem" inherent in attempting to locate a five acre
recharge system in the middle of a public .golf course. This
reason alone provided a sufficient basis for the State to
reject Alternative No. 5, particularly vhsr. an acceptable
ir.d preferable recharge Iccaticn existed en the lar.dfi-1
— * * fi ™ ** a *> * •« e ^r ^
»*.«»wC£w*4& •»• » c ** ^ •
7) .
There are certiir.ly ether reasons why Alternative No. 5
shculc be rejected. In fact, one cf the reasons ir. support
cf Alternative So. 7 is a reason for the rejection cf
Kc. r.
Alternative No. 7 is preferable because it keers all
the discharge water, even if only "slightly contaninatec,"
within the groundwater containment system thereby creating a
closed system. This allows fcr the continuous recapture and
retreatment of the contaminated water. Furthermore, the
reinjecticn cf water in the system will speed the cleanup cf
the plume.by "pushing" it more quickly toward the recovery
wells. -In contrast, Alternative No. 5 would place the
slightly contaminated discharge water outside the
containment system, at a point only 1000 feet upgradient c.
the nearest District of Farmingdale public drinking wells.
Since this discharge point is upgradient of those wells, it
-------
John J. Moiioy, P.E.
October 27, 1987
Page -.6-
would have the potential to reach -hose wells. This
situatien differs iron that in Alternative No. 7 in which
the discharge point is "downgradient" of the Plainview wells
and contamination will not move upgradier.t past the
stagnation point. The additional treatment of the
Alternative No. 7 discharge water at no increased cost (your
suggestion of further treatment of the Alternative No. 5
discharge water would require significantly increased
treatment costs) is certainly cost-effective and a desirable
environmental result.
The discharge location in Alternative No. 5 is also of
concern if the treatment facility should malfunction thus
temporarily placing contaminated groundwater only 1000 feet
upgradient of public wells. This is not a concern with
respect to Alternative No. 7 because this contaminated water
would not move past the upgradient stagnation point.
Additionally, even if monitoring did indicate movement of
contamination past the stagnation point, the pumping and
recharge system could be temporarily shut off" allowing the
contaminated recharge water to flow back into the
downgradient regional flow. Ar.y contaminated water released
at the discharge location in Alternative No. 5 could not be
recaptured without installing a new remedial system at great
expense. '
In sum, we disagree with your conclusion that
Alternative No. 7 presents no demonstrable benefit over
Alternative No. 5. We believe that Alternative No. 7
represents no risk that can be demonstrated at this time and
can be rcnitcred and easily remedied if any risk appears.
It provides a contained environmental cleanup which is cf
significant environmental benefit both, in the speed ar.e
degree cf cleanup. The only possible discharge location f'cr
Alternative ::c. £ (the ether locations are technically and
environmentally unacceptable) is institutionally
unreasonable since the land is currently a public gclf
course. Furtherrore, problems which ray occurr at the
Alternative No. '5 discharge Iccaticn and which r.igr.t present
environmental or health risks may not be so easily remedied.
Sucn risks are net acceptable in view cf a demonstrated
alternative. The decision to select Alternative Ko. 7 is
soundly based and is net -connected in any way with the
potential location cf the resource recovery facility.
We again wish to thank you for your comments and your
participation in this public process on behalf of the
Plainview Water District. We have provided with this letter
the entire package of written responses to all coirjnents made
at the public meetings, and as submitted in writing.
• After considering all the public comments received to
date, the State has formally selected Alternative No., 7 as
the appropriate remedial alternative for this site. This
-------
John J. hclloy, P.E.
October 27, 1987
Pace -7-
seiection will now be submitted to the United States
Environmental Protection Agency for review and concurrence
consistent with current regulation "and policy. If that
concurrence is obtained/ the remedial alternative will be
set forth in more detail in a Remedial Action Plan which
will be attached to a Consent Decree resolving the pending
litigation. The Remedial Action Plan and the Consent Decree
will be subject to a public comment period prior to final
Court approval. We will contact you directly, however, as
scon as a proposal exists for the upgradient monitoring of
Alternative No. 7.
Sincerely,
ROBERT L. OSAR
E. GAIL SUCHKAN
Assistant Attorneys General
Enclosures
RLO/EGS:bjs
-------
ROBERT ABRAMS
A. SEVINSKY
Anomvy G«n«r«l m Cnarg*
BurMu
STATE OF NET YORK
DEPARTMENT OF LAW
120 BROADWOT
NET YORK. NY 10271
(212) 341-2461
October 27, 1987
Anna Goidell
President
Board of Education Plainview-Old Bethpace
School District
Plainview, New York 11803
Re: Letter of September 14, 1SS7
Commenting on Old Bethpage
Landfill Remedial Action
Feasibility Study
Dear Mrs. Goidell and .
Members of the Board of Education:
Thank you for your attendance at the public meeting 'c:
September 10, 1987, and your letter of September 14, 19E7,
providing specific cements en the Cld Bethpage Landfill
Remedial Action Feasibility Study and the proposed cleanup
plan, Alternative No. 7-. We have set forth below the
cements from your letter and the response cf the State to
each er.e.
Cerr.sr.t 1; Pace 1, taracratr 2.
Ycur letter expresses your concern and the concern of
the- corrr.ur.ity that proposed Alternative Kc. 7 -will be used
as supporting evidence by the Town of Oyster Bay in its
atter.pt to locate a Resource Recovery "Facility ("?.RT") at
the Old Bethpage Landfill.
State Response to Cogent 1
• Alternative No. 7 has been proposed by the State
because it is. the best environmental solution to the
grcundwater problem present at the Old Bethpage Landfill.
Alternative No. 7 differs from the other alternatives ~air.ly
in the point cf discharge chosen, which is hycrauiically
upgracient of the prpposec recovery wells. The discharge
water, although meeting all allowable federal and state
discharge requirements, may contain low levels of
Attachment 3
-------
contaminants. Only Alternative No. 7 provides a discharge^
location* which will result in the recycling of this
potentially contaminated discharge water back through the
recovery system. This water will be recaptured and"
retreated and, therefore, will not escape into a
non-contained environment. Furthermore, reinjection of the
water into the system will speed the cleanup of the plume by
"pushing" it more quickly toward the recovery wells.
In addition to the recognition of the environmental
benefit resulting from implemenration of Alternative No. 7,
Alternative Nos. 3, 4 and 6 were deemed unacceptable because
those alternatives would take approximately one and cne-half
million gallons of water per day from this portion of the
aquifer, without replacement, contrary to the Long Island '
croundweter conservation policies set forth in 6 NYCRR Part
602. Alternative Nos. 2 and 4 were also rejected because,
as stated in the public meetings and the Remedial Action
Feasibility Study (see pages 3-1, 3-7 and 4-1), the State
rejected any remediation which relied en the existence cf a
resource recovery facility for its operation. Alternative
No. 7 does not rely en a resource recovery facility fcr its
operation.nor does it result in a contravention cf the water
conservation regulations.
Since the reasoning described above resulted in the
rejection of Alternatives Nos. 2,3, 4 and 6, the only other
active remedial alternative was Alternative No. 5. That
alternative was rejected fcr the reasons set forth in -he
State's response zb Ccinnent 2, herein. Therefore? the best
remedial alternative, chosen on its own merit, is
Alternative No. 7.
vr-ile it is true that the ir.pler.enta-ien cf Alternative
tic. T will allcv -r.e Tcvz to arg-.e ir. its ?.?.? rerr.it
landfill, that argument is hardly cispcsitive cf the
multitude cf legal, environmental and tecr.niril issues that
will need to be decided befcre the Department cf
Inviroaaenzal Conservation (DSC) can grant a pemit for
construction of the R2F. In point cf fact, all the "puxp
and treat" remedial alternatives would provide a source of
water for the RRF. The small expense of running a pipe frcrn
any discharge size to the RRF would allow zhe Town zo argue
zhat a source cf wazer was available from any one cf the
proposed remedial alternatives.
The granting of a perr.it for the RRF is a totally
separate and ciszincz legal process from the process vh
resulted in the selection cf Alternative No. 7. The
consideration of the RRF requires a complicated DEC
administrative procedure, subject to public hearing and
-2-
-------
comment,.which, will decide whether the RRF can be permitted.
That decision, just as the decision to select Alternative
No. 7, will be made on the merits of the RRF itself, not on
the fact that there happens to. be process water available at
the site. The RRF will need to pass strict technical and
legal requirements.for discharge, monitoring, performance,
etc. Even if the RRF-passes all those permit requirements,
in order to be connected with Alternative No. 7, there would
have to be technical confirmation that it would meet all the
very stringent treatment and discharge requirements of the
remedial action consent decree.
In sum, there is absolutely no significant legal or
technical advantage which accrues to the Town in its
application for the RRF by the selection of Alternative
Nc. 7 over the other remedial alternatives.
Consent 2: Pace 1, paragraph 3.
The officials of the Plainview Water District expressed
their preference for Alternative ?5.
. State Response to Consent 2
As explained in detail in the' response to the comments
submitted by .the Plainview Water District's consultant (copy
attached hereto), the State strongly disagrees with the
CoEcissioners1 preference for Alternative Nc. 5 over
Alternative So. 7:. Alternative I.'o. 5 studied the
feasibility of locating a discharge basin closer to the
recovery wells so that 'the cost of piping the groundwater to
the landfill could be avoided. Areas within approximately
15C0-2CCO feet cf the recovery' wells were eliminated because
it was determined"-that, 'the recharge cf cr.e and cue-half
sillier, g&licns of water a day vithir. that ii.stir.ce vculz
interfere with tie effectiveness cf the hydraulic barrier to
be created by these puss inc. wells. Areas irseciately to the
east and west cf the landfill plume were also elir.ir.atec &s
possible discharge locations because those areas are
potentially impacted by other sources of contamination.•
The only potential 'area left for recharge under
Alternative Kc. 5 was the southernmost portion of Sethpace
State Park, i.e., the middle of a public golf course.
Construction of a five acre treatment and recharge system irv
the middle of a public golf course would create a host cf
institutional problems. In addition, the recharge of
treated .groundwater' in that area would be outside and
down-gradient cf the hydraulic containment syster., and
.approximately 1000 feet upgracier.t cf the nearest Village cf
Famincdale public drinking well. This is cf concern
because .the treated groundwater'may contain low levels of
-3-
-------
I
contamination. In addition, there is always a possibility
that the treatment system could temporarily malfunction.
In contrast, the Alternative No.7 discharge location
ensures that the treated groundwater is recycled through the
system for additional treatment, at no risk to the
upgradient Plainview wells (see Response to Comment 5). The
environmental benefits of Alternative No. 7 weighed against
the problems associated with Alternative No. 5 justify its
selection as the appropriate remedy for the site.
Comment 3; Pace 1, paragraph 3.
The Plainview Water District Commissioners expressed
concern that even though strict discharge criteria would b
applied to the cleanup, the State has experienced a great
deal of difficulty in the past in obtaining compliance by
the Town with orders to close the landfill and the
incinerator, both of which were operating "illegally."
State Response to Consent 3
This is an enforcement action to implement a cleanup of
contaminated groundwater, not one to enforce permit
conditions at an operating facility. The consent decree
resolving this enforcement action will be monitored by the
State and the Court. The decree will provide -that the State
will have the right to shut down'the cleanup operation, if
it-is. not meeting the requirements cf the consent decree.
The consent decree will require the Town to implement all
.necessary modifications required to bring the remedial ,
rrocran isto compliance with all treatr.er.t and, discharge
criteria trier ts re-start. Sir.ce there is r.c ir.certive fcr
the Tews to operate the remedial program uzless it is is
compliance with State req*cirer.er.ts ar.d ar.y r.cr.-ccr.pl.ar.jce
will be immediately stepped by the State, there is so reason
to believe that consistent cr repeated sen-compliance will
.occur. ' •. • . • • ' ;
Comment 4; Pace 2, oaracrachs 1 and" 2.
Once the Resource Recovery Facility becomes part of the
remedial program, the possibility of non-compliance becomes
a concern because the Town will have incentive to keep the
Resource Recovery Facility (like the old incinerator)
operating, even if it is not in compliance.
.State Response to Ccranent 4
If the RRJ is permittee and i£ it is allowed to use
water from the remedial program, it will then be required to
meet both its permit conditions and the requirements of the
-4-
-------
remedial action consent decree. One of the conditions that
the State will insist upon, if the recovery water is used in
the RRF, is that the RRF will be shut down immediately if it
fails to meet the air and water discharge requirements of
the consent decree. Therefore, the concern over consistent
or repeated non-compliance is unfounded because the
existence of the consent decree, providing immediate resort
to a U.S. District Court Judge, ensures compliance with all
federal and state discharge requirements.
Comment 5: Paoe 2, paracraph 3.
We -believe that this non-compliance will result in the
disposal of polluted grouncwater near Plainview Water
District wells.
State Response to Comment 5
"Polluted" croundwater vill not be deposited near
Plainview wells. As stated abcve, the water, whether
discharged from the treatment facility of' Alternative KOi 7
or the RP.F (if permitted and allowed to accept recovery
water),'will be required to meet ell applicable discharge
criteria. If the discharge water does not meet those . .
criteria, the consent decree will provide that the- State can
shut down the cleanup operation (the recovery wells) until
the Town makes sufficient modifications and adjustments to
meet consent decree standards. . . • .
Furthermore, regardless of the contar.ir.ant levels in
the discharge water, i-t will not reach the Plainview public
drinking wells which are 2500 feet hycraulically upgracient
cf the pcir.t cf discharge. As explained in greater .detail
in the response to the grcur.dvater consultant to the Water
District, calculations have been rare tc dezcr.strate that
this recharged water vill ret reach the Plair.viev wells. In
additior., monitoring well(s) will he placed between the
pcir/r cf discharge and the Plainview veils to insure that
these calculations are accurate and that r.o impact v:i 11
occur or. the Plair.view wells. If either discharge
violations occur or the monitoring wells indicate a
potential impact on Plainview wells, the cleanup program
will be shut down irrjr.eciately until appropriate
modifications are r.ace or, if necessary, a new discharge
location, is four.d. . .
We again wish to thank you for your comments and your
participation in this public process. We have provided
with this letter the entire package of written responses to
all ccrjnents r.ade at the public meetings and as submitted in
writinc.
-5-
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After considering all the public comments received t<
date, tne State has formally selected Alternative No. 7 as
the appropriate remedial alternative for this site. This
selection will now be submitted to the United Stares
Environmental Protection Agency for review and concurrence
consistent with current regulation and policy. If that
concurrence is obtained/ the remedial alternative will be
set forth in more detail in a Remedial Action Plan which
will be attached to a Consent Decree resolving the pending
litigation. This Consent Decree will provide for
remediation of the landfill and set forth the obligations of
all the parties with respect to that remediation. The
Remedial Action Plan and the Consent Decree will be subject
to a public comment period prior to final approval by the
United States District Court. Copies of these documents
will be provided to the public on a tiaely basis.
Sincerely,
ROBERT L. OSAR
• ^»« »• £BW«»«»«#^ «•
~. voAxx< buunriAI*
Assistant Attornes General
RLO:rl . .
Enclosures'
-6-
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GENERAL QUALIFICATIONS
Established 1n 1889. Lockwood. Kessler & Bartlett (LhS) 1s a multi-
disciplinary consulting engineering firm heaoquartered 1n Syosset, New
York* with branch offices 1n Manhattan. New York, and Norwalk, Connecticut.
1KB maintains four departments: Engineering, Construction Aon 1n1 strati on.
Field Survey, and Aerial Mapping. These four departments provide services
1n civil, environmental and transportation engineering design, site
development, environmental consulting, waste management, construction
management and Inspection, facilities and systems planning, flel d_ survey,
and aerial photography and pnotogrammetry. All four oeparonents receive
technical support from LKB's In-house Computer Center.
The Engineering Department offers Integrated engineering and consulting
services for feasibility studies, preliminary design, final oeslgn. project
cost estimates and environmental consulting. The Deparanent1 s staff
consists of civil, environmental, geotecnnlcal, sanitary, structural,
transportation, and chemical engineers, 1n addition to environmental
scientists, landscape architects, planners and support staff.
The Engineering Deparanerrt 1s responsible for the following types of
projects:
t Investigation and design of remedial actions at hazarcous waste sites
• Solid waste management studies and facilities design
•e ' Preparation of environmental. Impact statements ani penr.it applications
• 3r1coe oeslcn and rehabilitation
• Traffic and transportation engineering
• Hicnway planning and eeslcn
e Structural ceslgn of ou1lc1ncs, nicnways, sricges anc waterfront
structures-
e Site planning and Development for res', oentl al, recreatl cr.al, Conner cl al
and Industrial projects
e Development/upgrading of wastewater collection and treatment fad! 1 ties
e Flood control projects
e Water supply engineering
e Lancscape architecture for parks and recreation areas
The Environmental Group within Engineering 1s responsible for environmental
consulting services. LKS's environmental services have Induced preparatlor
of environmental impact statements and assessments, regulatory reviews.
preparation and submlttal of permits, siting studies, and assistance to
clients in negotiations witn regulatory agencies.
Acrachaer.t i
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CONSTRUCTION ADMINISTRATION
LKS's Construction Administration Department specializes 1n aeslgn review,
project scheduVIng, construction plan analysis and quality control.
Services provided by the Department also Incluoe claims analysis. CPM
scnedul 1ng and soils Investigations. LKB's highly experienced staff has
provided resident engineering and Inspection services to a wide range of
projects Including bridge and street rehabilitation, building construction
landfill reclamation, water and sewer line Installation, road and drainage
Improvements, construction of parks and recreational facilities, and
demolition and removal of existing structures. The Department also
conducts building Inspection to assess the condition of exlstl ng. structures
and to monitor the quality of new construction. The Construction
Department staff consists of approximately 45 professional engineers,
certified Inspectors and support personnel.
FIELD SURVEY
LKB's Field Survey Department can provide up to ten fully equipped field
survey crews to perform caaastral and geooetlc surveys, photogrammetMc
control surveys and topographic surveys. Field Survey also provides the
special 1zed services required for hyarographlc surveys, route surveys
(pipeline, utilities and roaaways), and high oraer measurement precision
surveys'. The Department has over 30 years of experience 1n performing
survey services for a wlae range of construction projects Including hlghwajj
transmission lines, pipelines, railroads, harbors, waste disposal
facilities, and site developments for residential, commercial and
Industrial complexes.
AERIAL MAPPING
LK3's Aerial Mapping Deparonerit offers a total service of advanced photo-
crainmetrlc techniques to meet the requirement of engineers, planners and
private concerns. The following mapping services ere available:
e PI an1 metric mappl ng
• Topographic mapping
• Reproduct1on/grapn1c arts
e Aerial photography
• Analytical trlangul atlon
e Photogrammetry
COMPUTER FACILITIES
The Engineering, Construction Acmlni strati on, Field Survey and Aerial
Mapping Departments utilize LK3's 1n-nouse Computer Center for data.
processing and mooel 1ng services. The Computer Center 1s also used for CPM
and project scheduling activities, and for fiscal monitoring and cost
control. The Center is equipped with a PRIME 250 computer, plotter and ^
other peripheral equipment, and employs the services of experienced systerr^j
analysts, programmers and operators. Digitized mappl ng has recently Been
added to the Center's capabilities. •
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HAZARDOUS WASTE PROJECT EXPERIENCE
Hazardous Haste Remedial Investigation* Former Site of Liberty Industrial
Finishing Corporation* Farmlngdale, NY - Four J's Company, Syosset* NY
Preparation of a plan for Investigating soil and groundwater contamination
at an Industrial site 1n Nassau County, New York. Occupants of the site
were Involved 1n the metal plating Industry and had been discharging
plating waste effluent to the groundwater through disposal basins. The
plan developed by LKB Includes the drilling of borings, collection and
analyses of subsurface samples and the Installation of a groundwater
monitoring network. Data are being analyzed to determine the location and
extent of contamination and to Identify remedial actions for removal or
containment of contaminated areas. Subsequent stages of this work will In-
volve assessment of appropriate r em edition measures and the development of
plans and specifications for this Implementation.
Heavy Metal Treatment Facility Design* Comtech Laboratories. Smith-town* NY
LK3 was responsible for the design and start-up of a heavy metal waste
treatment facility and related hazaraous waste sludge containment area for
Comtech Laboratories, a manufacturer of aerospace guidance and communi-
cation equipment. The systems were designed 1n compliance with all
federal, state and local regulations. The project also Included waste
sampling and characterization, data analysis, development of treatment
methodology and the preparation of preliminary plans and specifications,
and operation and maintenance manuals.
Hazardous Haste Treatment Facility Design* Town of Oyster Bay* NY
LKB was responsible for the planning and complete design of a 200,000 gpd
leachate collection and treatment facll 1ty located at a municipal landfill
designated as a CSRCLA hazardous waste site. The site received both
ir.austrlal and municipal wastes whose characteristics areev1oent1nthe
leacnate discharging from the landfill. LK3's work 1 nclu tied process oeslgn
as well as all piping* structural, mecnanlcal and electrical aspects of tne
plant design. LKS prepared all construction plans anc specifications, and
all operations and maintenance manuals for the facility. LKS supervised
construction of tft 1s facility and 1s conducting ongoing monitoring and
performance evaluations. This facility has been operating successfully
since 1964.
Hazardous Haste Investigation* Space Machines* Inc. Site, Syosset* NY
LKS has developed an approved plan and has Implemented a program of Inves-
tigation at a site where spills of solvents may have occurred. Tne site
contains machine shop operations where volatile organic compounds used 1n
facility operations apparently contaminated soils. LKB has supervised
Installation of borings and collection of soil systems. The program 1s
being performed 1n response to Nassau County Department of Health require-
ments.
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Groundvatar Monitoring at the Old Bethpage Landfill, Town of Oyster Bay. NY
IKS nas been responsible for engineering and related services required to
establish a grouawater monitoring program 1n confortnance with state
requirements at the Old Beth page landfill. The landfill overlies a major
aquifer which 1s utilized by numerous public supply wells. The services
provided by LKB Included the development of a monitoring network/ selection
of drilling and laboratory subcontractors* coordination with regulatory
agencies* and analysis of monitoring results. LKB was assisted on specific
hydr©geological Issues by consulting groundwater geologists and hydrolo-
glsts. Two phases of the monitoring program have been completed and a
third phase 1s presently underway.
Hazardous Mast* Remedial Investigation, Anchor/L1th Kem-Ko Industrial
S1ta. H1cksv1lle. MY
LKB conducted a site and groundwater Investigation for an Industrial client
suspected of groundwater contamination by toxic chemicals from leaking
storage tanks. Work Involved the establshment of a monitoring program and
Implementation of remedial measures.
Design of Groundvatar Monitoring Facilities* Site Investigation, and
Design for Capping/Closure* Syosset Landfill* Town of Oyster Bay* NY
Design of a groundwater monitoring program and detailed site Investigation
at a 44-acre municipal landfall designated under Federal Superfuhd as a
hazardous waste site. Work Includes historical data collection and
analyses* geophysical studies* and landfill dimension study. This scope of
work Involves preparation of plans and specifications and supervision of
construction activities* and the development of remedial actions. LKB 1s
also preparing plans for capping* closure and gas control for the site.'
Groundvatar Investigation and Site Assessment* Proposed Office Complex*
Mlddlebury, CT
As part of a detailed site assessment being cor.ductec at a 340-acre site
proposed for corporate development* LK3 1s conducting a soils and ground-
water Investigation 1n areas containing underground fuel storage tanns.
The work Involves Installation of 5or1ngs and monitoring wells* and collec-
tion of soil and water samples to determine the extent to which fuel may
have leaked from the underground tanns. LKB also evaluated other physical*
biological and socio-economic aspects of the site as part of Its develop-
ment feasibility studies.
Capping and Closure of Operating Landfill* Town of Oyster Bay, MY
* .
LKB was responslble for planning, design and construction supervision for
the capping and closure of a municipal landfill which had received
Industrial wastes and 1s Included on the EPA Superfund List. Closure plans
and specifications which addressed all c1v 11, structural, mechanical and
electrical aspects of the worn inclu-oed provisions for gas control, storm-
water drainage, leach ate collection, and establishment of vegetative cover/i
landscaping. Capping of 40 acres nas been compl etea, and an effective,
State-approved cap has been established.
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Industrial Mast* Survey, Suffolk County Department of Public Works,
Suffolk County, MY
i
1KB conducted ap extensive Industrial waste Inventory to Identify
Industrial facilities which use, store or otherwise handle "priority
pollutants" or "hazardous substances". The survey was specifically aimed
at Identifying those industries which discharge such wastes to the sewers.
The inventory* which covered six waste*ater treatment districts* 1s a key
element of the County's Industrial pro-treatment program.
Toxic Vast* Treatment/Containment Area. Salthtrwn, NY
LKB provided the design and supervised start-up of a toxic metal waste
treatment system and sludge containment area for a major manufacturer of
aerospace guidance and communication equipment. The projects included
extensive sampling, data analyses* and development of a treatment method-
ology. Fran these results, and 1n accordance with NYCRR Hark 360 require-
ments and local regulations* plans and specifications were prepared as well
as an operations and maintenance manual.
Comprehensive Land Use and Operations Plan, Town of Oyster Bay, NY
To comply with state permit requirements, LKB prepared a comprehensive plan
for long-term management of the Old Bethpage Solid Waste Disposal Complex.'1
The plan, completed 1n 1983, Includes the development or continuation of
programs for landfill expansion, incinerator waste*ater treatment* control
•of leacnate* stormwater and landfill gas* groundwater monitoring, control
of Industrial wast* disposal, air qual 1ty monitoring, and site closure and
reclamation. These programs are carefully coordinated with ongoing opera-
tions and v 1th the eventual development of resource recovery operations at
the complex. The plan provides a long-term course of action for the Town
1n managing Its solid wastes 1n a manner consistent with state and county
regulatory requirements.
Report/Design and Environmental Impact Statement for Phase II Landfill
Extension, Town of Oyster Bay, NY
In tnls major landfill project, LK3 1s providing all engineering and
environmental work necessary to design, develop and commence operations 1n
an extension of tne Old Beth page landfill. The landfill 1s listed on tne
Superfund National Priority List. Design of the X2.S million extension
Includes provisions for a double liner* leach ate collection system* and
other features required by the regulatory agencies. LKB was also respon-
sible for preparing the 6 NYCRR Part 360 permit application as well as
other work needed to obtain state and county approval for'the landfill
expansion. The draft EIS was rcently prepared by LKB for tne landfill
extension. Major Issues addressed 1n the study Included: analysis of
alternatives to the proposed action* potential groundwater impacts* air
qual1ty (VOC emissions) and odors* visual and aesthetic Impacts* develop-
ment of m1tigat1ve measures* and Implications of the recently enacted New
York State Long Isl and Landfill and Resource Recovery Law. LKB, 1n coop-
eration with tne Town's counsel, provided expert testimony during lengthy
aojudlcatory proceedings.
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Part 360 Per»1t Application and DEIS for the Port Washington Landfill*
Town of Ncrtfc He«pst»ad* MY
1KB prepared plans and a comprehensive report to octal n a permit for tne
Town of North Hempstead1 s 90-acre sanitary landfill under the New York
State's Environmental Conservation Laws, Part 360. The Town, which 1s
located 1n Nassau County 1n the metropolitan New York area, has a popula-
tion approaching 250,000. Engineering planning addressed excavation,
lining with an impervious material* and design of a leach ate collection
unoerdrain system. When filling 1s complete* the site will be capped and
vented for methane gas release. Site development planning Included
provisions for staged utilization, stornwater drainage system* access road
network, new scale house facilities, homeowner disposal area* and final use
and landscape plans. LKB's Survey and Mapping Divisions undertook the
field and aerial surveys for mapping for the entire project area and Its
vicinity. A boring and subsoil investigation program was also conducted by
1KB. 1KB personnel provided numerous hours of expert testimony m support
of -oie application and DEIS. The facility 1s currently under construction.
Grouodvater Pollution Investigation* H1cksv1lle» MY
This study Involved a detailed Investigation for an Industrial client
suspected of polluting the aquifer with toxic chemicals frcm leaking
on-site underground storage tanks. Work Involved the assessment of ground-
water flow patterns* design of a soil and grounowater pollutant Investiga-
tion* construction supervision of monitoring well Installation, Implemen-
tation of a monitoring program, determination of groundwater quality.
Identification of contaminant sources, and Implementation of remedial
measures.
Brookf1eld Avenu« Landfill* Final Cover and Planting* Construction
Inspection, Statan Island* MY
LKB's Construction Acm1n1 strati on Department provided construction Inspec-
tion services for tne capping of the Brookfleld Avenue landfill for the New
York City Departtnent of Sanitation. The work Included construction manage-
ment and consultation, field Inspection, gectechnlcal tasting and required
revision of plans and specifications.
Hazardous Vast* Investigation* CcM«rc1al/Residential D«v«lopswnt Slta*
Mlddlrtown, NY
LKS recently conducted a soil and groundwater sampling program at the
proposed s1t» of a mixed use commercial/resident1 al development on 30 acres
1n Orange County* NY. Site reconnaissance determined evidence of potential
hazardous waste disposal on portions of the site which was formerly a
'construction company storage facility. LK3 developed an extensive sampling
program and conducted Gnomical testing to fully assess the extent of
contamination* and possible need for remediation, on the development site.
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PERSONNEL (UNIFICATIONS
Lockwood, Kessler 4'Bartlett. Inc. has a staff of over ISO engineers.
environmental scientists, planners, surveyors, construction Inspectors.
field technicians* and other support personnel. They are trained and
experienced 1n all the disciplines necessary to provide full support to
LKB's civil engineering and design projects. The distribution of personnel
by discipline 1s summarized below:
Eng1 neers
Chemical 2
C1v1l 11
Electrical 1
Mechanical 3
Sanitary/Environmental 9
Soils • 1
Structural 5
Transportation 7
Landscape Architects 3
Surveyors 25
Arch ITBCTS 1
CSP, S^?*I!^T1 SH In gQQg^s»» g/
F< gl e ~ecrp'< £•< ans 38
Se1 enrl gts
Ecologlsts 2
Geol og1 sts 2
Hyarologlsts 1
Hydrogeologlsts 2
Planners 4
Support . . .
Cartographers/
Photogrammetrlsts 4
Computer Programmers 4
Photo Lab Teenn1 clans 2
Draftsmen 12
Acni1n1 ctrafl ve 20
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JOHN P. LEXSTUTIS. P.E. • = ="r=-£ CONSULTING
Vice President - Senior Environmental Project Advisor = =^ s—^ ENGINEERS
EDUCATION/REGISTRATION
B.E., C1v1l Engineering, Manhattan College. 1965
M.E., Sanitary Engineering, Manhattan College, 1966
Registered Professional Engineer 1n NY, NJ, CT, MA, RI, ME, WA
E5PERIEXCE
Mr. Lekstutls has more than 21 years of experience 1n the fields of civil
and sanitary engineering, environmental science^ and hazardous waste
management. During this time he has addressed and managed technical,
economic, environmental and engineering programs from Inception through
Implementation for major Industrial and municipal projects. Mr. Lekstutls
serves as senior advisor on all environmental projects. He 1s currently
directing environmental projects for: groundwater contamination at
municipal solid waste landfills at Syosset and Old Bethpage; preparation of
a generic EIS for the Melville-Route 110 corporate off1ce"corr1dor 1n
Huntlngton; and engineering and environmental services for a ISOO-acre
corporate office park development 1n Connecticut for IBM Corporation.
Before Joining LW3, Mr. Lekstutls was Director of Environmental Engineering
and Sciences for Envlrosphere Company, a Division of Ebasco Services
Incorporated. He was responsible for managing Envlrosphere1s eastern'
environmental operations on projects represented by a capital Investment 1n
excess of S10 billion. He also planned and directed that firm's entry Into
the hazardous waste field. His responsibilities Included the development*
design and Implementation of remedial engineering measures such as:
groundwater monitoring and management; excavation, removal and safe
disposal of wastes; 1n-pTace encapsulation; lagoon and tank farm closure;
and In situ chemical.treatment. Mr. Lekstutls' other experience Includes
site Investigations, engineering feasibility evaluations, EIS reports, and
economic studies for major project undertakings throughout the U.S.
Specific projects Included: coal storage and shipment -snnlnals; coal
gasification and other alternate fuel production facilities; high voltage
transmission lines; cot! fired electric generating plants; and Industrial
chemical manufacture.
Mr. Lekstutls recently directed a remedial Investigation, feasibility
and engineering design program for a former coal gasification/disposal site
1n central New Jersey. The work scope for this program Included: detailed
site Investigations of the air, soils and groundwater to establish the
.extent and character of burled coal tar residues; a risk assessment to
establish the critical health and environmental pathways of contamination;
an engineering feasibility study to select a remedial program; engineering
design and construction oversight of the remedial measures; and Interface
and negotiation on behalf of the former owners with local communities,
local governments and the New Jersey Department of Environmental
Protection.
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IVAN POUSCHINE. JR. = =-7-=r-a. CONSULTING
Director of Environmental Engineering = S^ 5-£ ENGINEERS
EDUCATION/REGISTRATION
B.A., Engineering, Harvard College* 1952
Graduate Studies* Political Science* Georgetown University* 1956
.EXPERIENCE
Mr. Pouschlne has over 35 years of consulting engineering experience, and
he has served as Project Manager or Director on numerous water supply and
wastewater treatment projects world-wide* Including hazardous waste
remediation. Presently. Mr. Pouschlne 1s LKB's Director of Environmental
Engineering* directing a wide range of environmental projects for both
private and municipal clients.
Among the projects he has directed or managed are:
• Hazardous waste management studies at several Industrial sites Including
development of plans for Investigation and remediation and performing
(the required Investigations.
• Investigations and designs of waste pickle Hqyor collection and disposal
systems at Bethlehem Steel's Sparrows Point Plant and US Steel's Gary
Plant*. Including supervision of construction and start-up.
• Comprehensive Investigations of Industrial wastewater* and preparation of
reports and recommended treatment facilities for US Steel Corporation's
Gary Steel* Gary Tube. National and El wood Works; Bethlehem Steel
Corporation's Sparrows Point Plant Including the shipyard* and Lebanon
and Bethlehem plants; and Cities Service Lake Charles Refinery.
• Pilot plant testing and report on removal of organic contar.lnants In Glen
Cove. NY. aMnklng water, funded by tne USEPA* and arranging for csn-
tlnued testing to remove pesticides In Suffolk County, NY. The Glen
Cove pilot plant operations Included testing of several different
aeration systems, carbon adsorption, proprietary resin absorption,
.regeneration by steam of both carbon and resin over a three year period.
e Evaluation of USEPA wastewater effluent guidelines for the coal and ore
mining, synfuels* and ferrous metals Industries. Technical assistance
to EPA Region III concerning achieving of limitation guidelines at six
steel plants. TreatablUty studies of filtering combined sewer over-
' flows and po!1$h1ng secondary treatment plant effluent.
• Comprehensive master plan, design and start-up of a regional combined
Industrial-municipal wastewater treatment plant for Como* Italy,
handling 127 wet process Industries Including voluminous textile wastes.
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RAYMOW W. WEGENER - ="r-=-s. CONSULTING
Chemical Engineer = s^ s-s ENGINEERS
EDUCATION/REBISTRATTON
B.E., 1973, Chemical Engineering, Manhattan College, 1973
EXPERIENCE
Mr. Wegener has over 14 years experience 1n environmental engineering, and
1s currently Involved 1n the design phase of a groundwater remediation
treatment system for a municipal client.
Since Joining 1KB 1n 1980, he has been responsible for one or more facets
of the off-site methane gas control work at the Old Bethpage Landfill, Port
Washington Landfill and Syosset Landfill 1n Nassau County, NY. His respon-
sibilities Included preliminary and final design, equipment specification,
start-up and operation, data collection, gas sampling and follow-up
Inspections.
Mr. Wegener has prepared extensive theoretical landfill gas estimates for
the Old Bethpage landfill, which were used as a guidance document 1n
developing a RFP to exploit landfill gas as an energy resource. He has
also designed a leachate treatment facility for the Town of Oyster Bay, now
built and operational at the Old Bethpage landfill. The 200,000 gpd plant
treats leachate collected from portions of landfill, which has been desig-
nated as an EPA Superfund site because of a history of Industrial waste
dumping. Mr. Wegener was responsible for Initial feasibility and treata-
bH1ty studies, preliminary and final design, equipment specification,
start up and operation, and preparation of a comprehensive operation and
maintenance manual for the plant. He has performed similar duties for a
municipal Incinerator wastewater treatment plant.
Prior to Joining LK3, Mr. Wegener was Laboratory Director of Ecolotrol,
Inc., Bethpage, New York. His responsibilities there Included wastewater
sanpl.1ng, data collection and Interpretation, treatment plant design,
report preparation, specification coordination and stare up procedures
related to the New York State Discharge Elimination System Program (SPOES)
and NPDES outside New York. In this capacity, Mr. Wegener also directed
treatability studies for a number of Industrial clients such as; Engelhard
Industries, Upton Foods, American Cyanamld, Kind and Knox, and Pfizer, Inc.
Mr. Wegener had conducted pilot and bench scale treatability studies on
leachates and wastewater contaminated with metal refining wastes, high
strength ammonia wastes, animal wastes, and electroplating and coating
wastes. • •
Mr. Wegener has published articles for the proceedings of the New York
State Association for Solid Waste Management and Pollution Engineering
relating to off-site methane gas control and leachate management.
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PAUL LAPPANO. P.E.
Project Manager
EDUCATION/REGISTRATION
= = T =""s CONSULTING
E ,5^ STIs ENGINEERS
B.S. C1v1l Engineering, State University of New York at Buffalo, 1975
Registered Professional Engineer 1n State of New York
EXPERIENCE
Mr. Lappano has 12 years of experience 1n environmental and civil
engineering. As Project Manager for several environmental projects, he 1s
responsible for site Investigations at landfills and hazardous waste sites,
and for the design of solid waste management and remedial facilities. Mr.
Lappano has been responsible for the design of landfill expansions, methane
collection systems, leachate collection systems, liners and caps, and final
land use plans. He has also been responsible for completing necessary
regulatory permits and applications. Mr. Lappano 1s currently involved
with the development of detailed plans and specifications for landfill, gas
control and capping of a 35 acre Inactive hazardous waste disposal site.
Mr. Lappano has conducted site Investigations at several Inactive and
active hazardous waste sites on Long Island. As part of these studies, he
used historic aerial photos to determine prior landfill boundaries and
expansions, and to check for the presence of drum stockpiles, waste
lagoons, and other evidence ^f.individual waste disposal. As part of LKB's
site development projects, Mr. Lappano has also used aerial photography to
check for possible waste dumping on several large parcels of land proposed
for corporate development.
Mr. Lappano's consulting experience prior to Joining LKB Includes the
preparation of engineering designs .and reports for the construction of
solid waste management facilities 1n the Towns of Southold, Rlverhead, and
Huntlncton, New York. He designed an HYAC system, structural roofing, and
the odor control system for a SI.5 minion underground advanced Industrial
waste treatment plant. He also contributed to a waste volume report and
participated 1n an operations study, for the 10,000 TPD New YOTK City
Freshkllls Landfill.
As a solid waste engineer for the New York State Department of Environmental
Conservation* Mr. Lappano gained additional experience Including engineering
review of 15 landfills* 12 transfer stations, three Incinerators, and four
resource recovery facilities. These studies were conducted.to ensure
compliance with state standards under 6 NYCRR Part 350 - Solid Waste
Management Facilities, for groundwater monitoring wells, methane monitoring
and venting, leachate collection and treatment. Incinerator residue
disposal, and transfer station capacities.
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