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:
                             -1-

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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);
                             -2-

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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
                             -3-

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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.
                             -4-

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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
                             -5-

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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.
                             -2-

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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
                             -1-

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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
                             -5-

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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.
                             -6-

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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
                             -7-

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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
                             -a-

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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
                             -13-

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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


                             -14-

-------
          ^ Vs**'- '-i^
          .h. *    j •.
\. STATE /   PARK   ^
                                  r -N^S^rJ ----/•-"// ^T/"
                                  >  — r>Cj^ /•/  /^^ / •••
                                ? ^ ^ .. g, . _ x^xi" r • x1 • •*
                                .O.U J/^ .>/S*jT^( •  /  V *"
                                 /-1  -:    . f   *  I
  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

-------
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

-------
     ^
f r\ .
fC^.l -~\r: .-Uui oe'.hpage. u  .
i A . l^s .   • «             . w
;6iT.
                Par
   •»*v
 •I -J.
                              inci^
               :f^:.:.:
               1 t « ». _ -
                     ft.
         •*«>*-
                     •V

                     T".\'" ^
  . -\
                                               .-/ *
                                            !«*>
                                         K
 xTA  ^'.'-"
 •'-STATE/  PARK   Ci
                                       #
                                             r
                               i ••
             Golf Course
                  *
                     Q
                     ' 'vy
                      *• %
                     //
                          'BHTTHPACEST.
                , »•
                                    /:
^B.Bf iiaAGE^'f^StAT E;'§0^^  V.ftfe-^lf--  jj
                                           ;^«


                                        ^
                                                            -IV
    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

-------
                                                                   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-

-------
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_

-------
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
                             -19-

-------
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-

-------
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.
                             -21-

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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

-------
                              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.
                             -23-

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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
                             -24-

-------
         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
                              -25-

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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.

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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.

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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:
                             -27-

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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.
                             -29-

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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

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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
                        -31-

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                           BETHPAQE STATE PARK
              8ETHPAGC STATE PARK LIMITS





              08SWOC LIMITS
                                                                        FIGURE 8
1KB

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             BETHPAGE STATE PARK
8ETHPAGE STATE PARK LIMITS





OBSWDC LIMITS
                                                           FIGURE 9

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            BETHPAGE STATE PARK
BETHPAGE STATE PARK LIMITS





OBSWOC LIMITS
                                                      PIG USE 10
                                           ALTERNATIVE NO. 4    (

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                          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
                             -32-

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           BETHPAGE STATE PARK
SETHPACE STATS PARK LIMITS





08SWOC LIMITS
                                                     FIGURE 1
                                          ALTERNATIVE  NO.

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                 BETHPAGC STATE PARK
	8ETHPAGE STATE PARK LIMITS





•—« OBSWOC LIMITS
                                               ALTERNATIVE NO. 6

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                          BETHPAGE STATE PARK
              BETHPAGE STATE PARK LIMITS


              OBSWOC LIMITS
                                                                           13
• y»-=-a
= ==.=-£
                                                          ALTERNATIVE NO. 7

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     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.
                             -33-

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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
                             -34-

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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

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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

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     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 
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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.
                             -38-

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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

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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
                             -43-

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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

                             -50-

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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
                             -51-

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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
                             -52-

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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

                             -53-

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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
                             -54-

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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
                                   -55-

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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:
                             -36-

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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
                             -59-

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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.
                             -61-

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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.
                    -63-

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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
                    -64-

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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
                   -65-

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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
                             -67-

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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.
                             -69-

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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.
                              -70-

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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.
                             -71-

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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
                             -72-

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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
                             -75-

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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
                             -77-

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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
                             -80-

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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 -

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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

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             BCTHPAGE STATE PARK
         S7ATC PAAK UMTTS





OBSWOC UMITS
                                                  " I T~~ ik ' »~M ' —

-------
     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

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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  
-------
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
                            - 11 -

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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

-------
 (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
                            - 12 -

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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.




                            - 14 -

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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




                            - 15 -

-------
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




                            - 16 -

-------
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

                            - 17 -

-------
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.

-------
. 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




                             - 18 -

-------
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

-------
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




                            - 20 -

-------
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




                            - 22 -

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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-




                            - 23 -

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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.



                              - or -



     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.
                            - 26 -

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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



                            - 27 -

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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






                            - 30 -

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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.

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                             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

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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

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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.

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       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.

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       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

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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

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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

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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..          ...

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      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.

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      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

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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-

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       G len Cove
     Record- Pilot
     Ci*n Co • t . u  r
   A Ptrtongliitd C.'iopmg
           I'om
 "O       '•      i
 -  rcr.ici-pr-,  .Inc.
  N'i'«v H\4)c Park. N. V.
         110.10
     S16-CE 7-10.17
                                        A Penonoliltd Clipping
                                                I? om

                                       ->       1:      1
                                       .: '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

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  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.
        11040
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                                                0 r »I•'  B*y . N. Y .

                                                AUG  2- 6 Q7

                                                A Penonolind Clipping
                                                       Irom
                                               •n       v     i
                                               i  rcssci:ps, :nc
                                                New i I vile I1.irk. N. 'i
                                                       1 1040
                                                   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 "         "        --....

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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 ^     •    .•

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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

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 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

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 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

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 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

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 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.

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      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

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              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

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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

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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
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 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

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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

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 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 -• — £«.. - •

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 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

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 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

-------
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

-------
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.
                            -2-

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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
                            -4-

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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.
                            -6-

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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
                            -13-

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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

-------
 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
                            -17-

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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

-------
 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

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                               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

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 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-

-------
     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

-------
 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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