United States
          Environmental Protection
          Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R02-92/189
September 1992
PB93-963815
x°/EPA    Superfund
          Record of Decision:
          Plattsburgh Air Force Base
          (Operable Unit 1), NY

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                                         NOTICE

The appendices listed in the index that are not found in this document have been removed at the request of
the issuing agency. They contain material which supplement but adds no further applicable information to
the content of the document All supplemental material is, however, contained in the administrative record
for this site.

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50272-101
 REPORT DOCUMENTATION
        PAGE
1. REPORT NO.
    EPA/ROD/R02-92/189
                                           1 Recipient1* Acceuion No.
 4. Title tnd Subtitle
   SUPERFUND RECORD OF DECISION
   Plattsburgh Air  Force Base  (Operable Unit  1),  NY
   First  Remedial Action - Subsequent to follow
                                           5. Report Date
                                            09/30/92
 7. Author(s)
                                                                    8. Performing Organization Rept No.
 9. Performing Organization Name and Address
                                           10. Project/Task/Work Unit No.
                                                                    11. Contraet(C) or Grant(G) No.

                                                                    (C)

                                                                    (C)
 12. Sponaoring Organization Name and Address
   U.S. Environmental Protection Agency
   401 M Street,  S.W.
   Washington,  D.C.   20460
                                           13. Type of Report & Period Covered

                                             800/000
                                                                    14.
 IS. Supplementary Notes
   PB93-963815
 16. Abstract (Limit: 200 words)
   The Plattsburgh Air  Force Base  (AFB)  site is located south of  the City of  Plattsburgh,
   Clinton County, New  York.  Surrounding land use  is primarily residential and light
   industrial.   Ground  water beneath  the site is not  used as a drinking water source.
   Plattsburgh  AFB has  historically been engaged in numerous operations that  have required
   the use,  handling, storage, and disposal of hazardous materials.   The U.S.  Air Force's
   Installation Restoration Program  (IRP)  identified  39 sites at  Plattsburgh  AFB with
   potential contamination by hazardous  materials.  One of these  sites, the 10.1-acre
   LF-023 landfill, is  located approximately 300 feet from the Plattsburgh AFB western
   boundary,  and 600  feet  northeast of a small mobile home development.  From 1966 to
   1981, the landfill received domestic  wastes for  disposal.  Daily operations consisted
   of digging 25-foot-deep trenches,  spreading and  compacting the trash  (typically bagged
   household garbage),  and backfilling with 6-inch  layers of sandy soil.  Hazardous wastes
   were not  routinely disposed of in  this landfill; however, these may have still been
   deposited.   Secondary growth has begun to cover  the landfill,  allowing a northern
   section of the site  to  be utilized as an exercise  training/obstacle course.   Air Force
   site investigations  have revealed  soil,  sediment,  surface water,  and

   (See Attached Page)
 17. Document Analysis a. Descriptor*
   Record of Decision  -  Plattsburgh  Air Force Base  (Operable Unit  1),  NY
   First Remedial Action - Subsequent  to follow
   Contaminated Medium:  soil, sediment,  waste, sw
   Key Contaminants: VOCs (benzene,  xylenes), other  organics  (PAHs,  PCBs), metals
                       (arsenic)
   b. Identifiers/Open-Ended Terms
   c. COSATI Reid/Group
 18. Availability Statement
                            19. Security Class (This Report)
                                   None
                                                     20. Security Class (This Page)
                                                     	  None	
21. No. of Pages
  76
                                                                                22. Price
(See ANSt-239.18)
                                      See Instructions on Reverse
                                                      OPTIONAL FORM 272 (4-77)
                                                      (Formerly NTIS-3S)
                                                      Department of Commerce

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EPA/ROD/R02-92/189
Plattsburgh Air Force Base  (Operable Unit 1), NY
First Remedial Action - Subsequent to follow

  stract  (Continued)

ground water contamination.  This ROD addresses a final source control remedy for the
contaminated soil, sediment, surface water,  and ground water at the site, as OU1.  Future
RODs are planned to address other OUs at the Base.  The primary contaminants of concern
affecting the soil, sediment, and surface water are VOCs,  including benzene and xylenes;
other organics, including PAHs and PCBs; and metals, including arsenic.

The selected remedial action for this site includes clearing and grubbing the site;
establishing a low-permeability vegetated cover system over the landfill; diverting the
surface water runoff to minimize erosion of the cover and to minimize maintenance
requirements;  installing a gas detection and monitoring system; developing a post-closure
plan to monitor, maintain, and inspect the site; monitoring ground water -and surface
water; and implementing institutional controls including deed restrictions.  The
estimated present worth cost for this remedial action is $4,574,000, which includes an
estimated present worth O&M cost of $988,000 over 30 years.

PERFORMANCE STANDARDS OR GOALS:  Chemical-specific soil, sediment,  and surface water
clean-up goals were not developed for the LF-023 source control action because discrete
source areas were not found.  Clean-up levels for other contaminated media associated
with the site, will be established in a subsequent ROD,  if necessary.

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                            ROD  FACT SHEET
STTE
Name:                    Pittsburgh Air Force Base, Landfill LF-023 (0,\}cl)
Location/State:            Clinton County, New York
EPA Region:                USEPA Region  II
MRS Score (date):          30.34, 11/21 /89
NPL Rank:                 N/A
ROD
Date Signed:               PAFB,
Remedy/ies:               Installation of a low permeability barrier cover system on the
                          landfill
Capital Cost:               $ 3.6 million (present worth)
O & M/Yean               $ 105,000/yr for 30 yrs (present worth)
Present Worth:             $ 4.6 million
LEAD
Remedial/Enforcement     Federal Facility (Pittsburgh Air Force Base)
Primary Contact (phone):    Philip Von Bargen, Project Manager, PAFB, (518) 565-6679
Secondary Contact (phone): William Roach, Project Manager, EPA (212) 264-8775
WASTE
Type (metals/ PCB, &c):     Volatile organic compounds, semi-volatile organic compounds,
                          PHCs, metals, and pesticides
Medium (soil/ g,w., &c):     Croundwater, surface water, and sediment
Origin:                    Municipal type landfill
EsL Quantity cu.yd.:         10.1 acre

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INSTALLATION RESTORATION PROGRAM
  LANDFILL LF-023 SOURCE CONTROL
        RECORD OF DECISION

    PLATTSBURGH AIR FORCE BASE
      PLATTSBTJRGH, NEW YORK
               FINAL
             Prepared by:

     ABB Environmental Services, Inc.
         261 Commercial Street
         Portland, Maine 04112
          Project No. 6091-70

          SEPTEMBER 1992

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                     TABLE OF CONTENTS


Section	Title	Page No.

DECLARATION	  vi

1.0   SHE NAME, LOCATION, AND DESCRIPTION	  1-1

2.0   SHE HISTORY 	. .'.	  2-1

     2.1   LAND USE AND RESPONSE HISTORY	  2-1
     2.2   FEDERAL FAOLITIES AGREEMENT HISTORY	  2-2

3.0   COMMUNITY PARTICIPATION	  3-1

4.0   SCOPE  AND  ROLE  OF OPERABLE  UNIT OR  RESPONSE
     ACTION	  4-1

5.0   SUMMARY OF SITE CHARACTERISTICS 		  5-1

     5.1   WASTE/SOIL	  5-1
     5.2   GROUNDWATER 	  5-2
     5.3   SURFACE WATER/SEDIMENT  	  5-2

6.0   SUMMARY OF SITE RISKS 	  6-1

     6.1   HUMAN HEALTH RISK ASSESSMENT	  6-1
     6.2   ENVIRONMENTAL RISK ASSESSMENT	  6-5

7.0   DEVELOPMENT AND SCREENING OF ALTERNATIVES	  7-1

     7.1   STATUTORY REQUIREMENTS/RESPONSE OBJECTIVES	  7-1
     7.2   TECHNOLOGY AND ALTERNATIVE DEVELOPMENT AND
          SCREENING	  7-2

8.0   DESCRIPTION OF ALTERNATIVES	  8-1

     8.1   ALTERNATIVE 1: No ACTION	  8-1


59213                                                     6091-71

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                       TABLE OF CONTENTS
                            (continued)
Section	Title	Page No.

      82   ALTERNATIVE 2:   SITE  GRADING AND VEGETATION
           ESTABLISHMENT FOR CLOSURE  	 8-2
      8.3   ALTERNATIVE 3:  INSTALLATION OF A LOW-PERMEABILITY
           BARRIER COVER SYSTEM	:. -	 8-3

9.0    SUMMARY OF THE  COMPARATIVE ANALYSIS OF
      ALTERNATIVES	 9-1

      9.1   THRESHOLD CRITERIA	,	 9-1
      9.2   PRIMARY BALANCING CRITERIA	 9-1
      9.3   MODIFYING CRITERIA	 9-2
      9.4   CRITERIA SUMMARY	 9-2
           9.4.1    Overall Protection of Human Health and the
                  Environment	 9-3
           9.4.2    Compliance with Applicable  or Relevant and
                  Appropriate Requirements 	 9-3
           9.4.3    Long-term Effectiveness and Permanence 	 9-3
           9.4.4    Reduction  of Toxicity,  Mobility,  or  Volume of
                  Contaminants through Treatment 	 9-3
           9.4.5    Short-term Effectiveness	 9-4
           9.4.6    Implementability	 9-4
           9.4.7    Cost	 9-4
           9.4.8    State Acceptance  	 9-4
           9.4.9    Community Acceptance	 . 9-4

10.0   THE SELECTED REMEDY  	 10-1

      10.1  CLEANUP LEVELS	 10-1
      10.2  DESCRIPTION OF REMEDIAL COMPONENTS	 10-2

11.0   STATUTORY DETERMINATIONS	 11-1

      ll.l  THE SELECTED REMEDY is PROTECTIVE OF HUMAN HEALTH
           AND THE ENVIRONMENT	 11-1
59213                                                           6091-71
                                ii

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                     TABLE OF CONTENTS
                         (continued)
Section	Title	Page No.

     11.2  THE SELECTED REMEDY ATTAINS ARARs	 11-1
     113  THE SELECTED REMEDIAL ACTION is COST-EFFECTIVE	 11-4
     11.4  THE SELECTED REMEDY UTILIZES PERMANENT SOLUTIONS
          AND ALTERNATIVE TREATMENT OR RESOURCE RECOVERY
          TECHNOLOGIES TO THE MAXIMUM EXTENT PRACTICABLE .. 11-5
     1L5  THE SELECTED REMEDY DOES NOT SATISFY THE
          PREFERENCE FOR TREATMENT THAT PERMANENTLY AND
          SIGNIFICANTLY REDUCES  THE TOXIOTY, MOBILITY, OR
          VOLUME OF THE HAZARDOUS SUBSTANCES AS A PRINCIPAL
          ELEMENT	 11-6

12.0  DOCUMENTATION OF NO SIGNIFICANT CHANGES	 12-1

13.0  REGULATORY ROLE  	 13-1


GLOSSARY OF ACRONYMS AND ABBREVIATIONS

REFERENCES

APPENDICES

APPENDIX A     -       ADMINISTRATIVE RECORD INDEX
APPENDLX B      -       STATE CONCURRENCE LETTER
APPENDLX C      -       PUBLIC HEARING TRANSCRIPT
APPENDIX D     -       RESPONSIVENESS SUMMARY
59213                                                    6091-71
                             iii

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                            LIST OF FIGURES


Figure	Title	Page No.

1     Vicinity Location Map	  1-3

2     LF-023 Location Map  	  1-4

3     LF-023 Site Features	 -.	  2-3

4     LF-023 Potential Migration Pathways and Receptors  	  5-5
59213                                                                6091-71
                                    iv

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                             LIST OF TABLES






Table	Title	;	Page No.



1     LF-023 Site Contaminants By Media 	  5-3



2     Summary of LF-023 Site Risk Estimates - Security Police	  6-7



3     Summary of LF-023 Site Risk Estimates - Child Trespasser  	  6-8



4     Summary of LF-023 Site Risk Estimates - Future Residents	  6-9



5     Summary of Alternatives Screening  	  7-3
59213                                                                  6091-71

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                             DECLARATION
SITE NAME AND LOCATION

Plattsburgh Air Force Base (AFB), Landfill LF-023 (0 • 0'')
Pittsburgh, New York


STATEMENT OF BASIS AND PURPOSE

This decision document presents a selected source control remedial action that will
provide containment of wastes at Landfill LF-023 on Plattsburgh AFB in Plattsburgh,
New York.  This  decision document was developed in accordance with the
Comprehensive Environmental Response, Compensation, and Liability Act of 1980
(CERCLA) as amended by the Superfund Amendments and Reauthorization Act  of
1986, and to the extent practicable, the National Oil and Hazardous Substances
Pollution Contingency Plan.  Through this document, Plattsburgh AFB plans  to
remedy the potential exposure risk to human health and welfare and the environment
posed by surface soil at LF-023. This decision is based on the Administrative Record
for the site, which was developed in accordance with Section 113(k) of CERCLA and
which is available for review at Plattsburgh AFB in Plattsburgh, New York. The
attached index identifies the items comprising the Administrative Record upon which
the  selection of the remedial action is based (see  Appendix A).

The New York State Department of Environmental Conservation (NYSDEC) and
the  U.S.  Environmental  Protection Agency (USEPA) concur  with  the selected
remedy.  The state's statement of concurrence with this selected remedy is presented
in Appendix B.


ASSESSMENT OF THE SITE

Actual or threatened releases of hazardous substances from LF-023, if not addressed
by implementing the response action selected in this Record of Decision (ROD), may
present an imminent and substantial endangerment to human health and welfare and
the  environment.
59213                                                                 6091-71
                                   vi

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DESCRIPTION OF THE SELECTED REMEDY

The action described in this decision document addresses the principal threat at
LF-023  by preventing endangennent  to  human health and welfare and  the
environment  through  institutional  controls and  containment of the  landfill to
minimize (1) exposure to surface soil contaminants and (2) leaching of contaminants
present in surface soils and waste.

The selected source control remedy includes  establishing institutional controls,
constructing a low-permeability barrier cover system over the landfill to isolate
contaminated soils and minimize infiltration of water into the landfill. The remedy
also includes the development of a  post-closure  plan specifying  inspection,
maintenance, and monitoring programs to be conducted over a-30-year period.  In
addition, institutional controls for this site will be incorporated into the Plattsburgh
AFB Comprehensive Plan. This will ensure that future owners will be made aware
of the landfill location and are informed that the integrity of the final covers, liners,
or any other component of the  containment or  monitoring system must  not be
compromised.

This ROD addresses the groundwater only in reference to source control.  A
separate Feasibility Study (FS), Proposed Plan, and  ROD will be prepared to address
potential risks associated with groundwater, surface water, and sediment.
STATUTORY DETERMINATIONS

The selected remedy is protective of human health and the environment, complies
with federal and state requirements that are applicable or relevant and appropriate
to the source  control remedial action, and  is cost-effective.   This  remedy was
evaluated along with  others that utilize permanent solutions and alternative
treatment technologies or  resource  recovery technologies.   However,  because
treatment of the principal threats at the site was not found to  be practicable, this
remedy does not satisfy the statutory preference for treatment as a principal element
of the remedy.  Treatment technologies were identified during the development and
initial screening of alternatives, but were  determined to be infeasible for LF-023
because  (1) there  are no  on-site hot spots that  represent major sources  of
contamination and (2) the estimated large volume of waste at the site preclude a
remedy in which contaminants could be excavated and treated effectively.

Because this remedy will result in hazardous substances remaining on site,  a review
wiM be conducted by Plattsburgh AFB, USEPA, and NYSDEC within five years after
closure to ensure that  the source control remedy continues to provide adequate
59213                                                                   6091-71
                                    vii

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   protection of human health and the environment. This review will be conducted at
   least every five years as long as hazardous substances remain on site at levels that
   may pose a risk to human health and the environment.
        STANTINE SIDAMON-E
   Regional Administrator,
 XJAMES E. ANDREWS
//Colonel, USAF
   Commander, 380 ARW
Date
   59213
                         6091-71
                                     VIU

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                                                                 SECTION 1
              1.0  SITE NAME, LOCATION, AND DESCRIPTION
Plattsburgh Air Force Base (AFB) is located in Clinton County in northeastern New
York State, bordered on the north by the City of Plattsburgh, on the south and west
by the Town of Plattsburgh, and on the east by Lake Champlain (Figure 1). The
base is approximately 26 miles south of the Canadian border and 167 miles north of
Albany. Landfill LF-023 is located west of the runway approximately 300 feet from
the Plattsburgh AFB boundary (Figure 2).

Access to the landfill  from the east and south is restricted because the site is
bordered by a controlled access area.  Access from the north and west is somewhat
less restricted, but is limited by an intact 4-foot-high, three-wire fence posted with
"No Trespassing" signs. This area is patrolled regularly by Plattsburgh AFB security
personnel  Vehicles can access the landfill via a dirt road leading from the Perimeter
Road within the controlled access flightline area through a gate near the Fire
Training Area (FT-002).

An obstacle course in the northeast portion of LF-023 is used regularly by U.S. Air
Force personnel during the warmer months.  Other military and civilian personnel
are not likely to  come in contact with the landfill.

LF-023 is approximately 600 feet northeast of a small mobile home development on
Old NY Route 22, near the interchange with Interstate 87. A dirt road formerly led'
from the mobile home park road to the northeast and onto the base, just south of
LF-023. This road intersects with Perimeter Road on base. Vehicle access via this
road from off base is prevented by an earthen barrier and gate. The area between
LF-023 and the mobile home park  is  mostly wooded. The nearest on-base housing
is more than 6,000 feet east of the site. The light industrial area along Route 22 is
approximately 600 feet north of the site.

Site topography slopes  gradually toward the east and south with a surface gradient
of approximately 0.026. There are no surface water features within the LF-023 site;
however, shallow groundwater discharges to the ground surface downgradient  of the
landfill in seeps and drainages approximately 600 feet south of the site.

The  plant community at LF-023 consists of a pitch pine plantation surrounding an
open area with sparse weedy vegetation.  The wetland south of the site is primarily
a red maple-hardwood swamp, and  is regulated by the New York State Department
59213                                 1-1                                6091-71

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SECTION 1
of Environmental Conservation (NYSDEC).  Several species of birds, mammals,
reptiles, and amphibians may inhabit the site; however, no state or federally listed
or proposed endangered or threatened species are known to exist within 2 miles of
Pittsburgh AFB.

Site geology consists of approximately 80 feet of sand, 5 feet of silt, 10 feet of clay,
and 25 feet of till overlying carbonate bedrock.  Soil within the landfill is poorly
graded fine-to-medium sand with trace silt, and appears to be native soil mined in
the area.  Two aquifers at the site include an unconfined aquifer in the sand unit
(below the depth of waste), located approximately 30 feet  below ground surface
(bgs), and a confined aquifer in the bedrock. Groundwater in the unconfined aquifer
flows south and southeast toward Lake Champlain and a topographic low south of
the site.  Groundwater in the confined aquifer flows east toward Lake Champlain.

A more  complete description of LF-023 can be  found in the LF-022/LF-023
Remedial Investigation (RI) Report on pages 1-5 through 1-8 and 4-1 through 4-13
(ABB-ES, 1992a).
59213                                1-2                               6091-71

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         ADIRONDACK
         MOUNTAINS
   SOURCE: NORTH MIEKCAN RQAOA7US. R U. QOU9U CO. 1967
92060100
                                                        FIGURE 1
                                          VICINITY LOCATION

                                               PLATTSBURGH API
                               ABB Environmental Services, Ine.
                                1-3

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                                                                 iltltt
                 SITE LOCATION


         M __  BASE 3OUNOARY
SOURCE: USGS QUADRANGLE PUATTS8URGH. N.Y.
      7.5 MINUTE SERIES.
     SCAU£lN
9091.71
                FIGURE 2
    LF-023 LOCATION MAP
LF-023 SOURCE CONTROL
    RECORD OF DECISION
      PLATTSBURGH AFB
	 ABB EnvtoMMiMfttal S«rvlc««, Inc.
                               1-4
           POOR QUALITY
             ORIGINAL

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                                                               SECTION 2
                            2.0  SITE HISTORY
In accordance with Section 117(a) of the Comprehensive Environmental Response,
Compensation, and Liability Act of 1980 (CERdA), Pittsburgh AFB is publishing
this Record of Decision  (ROD)  to address public review and comment on the
selected containment  alternative, known  as a remedial  alternative, for LF-023.
Pittsburgh AFB,  in  consultation with NYSDEC and the U.S. Environmental
Protection Agency (USEPA),  considered public  comments as part of the final
decision-making process for selecting the LF-023 source control remedy.  This ROD
summarizes  the results conclusions of and the RI, Feasibility Study (FS),  and
Proposed Plan.
2.1 LAND USE AND RESPONSE HISTORY

LF-023, the last active landfill at Plattsburgh AFB, is approximately 500 feet wide
and 800 feet long and reportedly received domestic wastes for disposal from 1966 to
1981  (Figure 3).   Daily operations consisted of digging 25-foot-deep trenches,
spreading and compacting the trash (typically bagged household garbage), and
backfilling with 6-inch layers of sandy soil. Hazardous wastes were  not routinely
disposed of in this landfill; however, hazardous materials might have been deposited.
The maximum volume of fill is estimated at 406,000 cubic yards.  Since landfilling
operations  ceased, secondary growth has begun to cover  the site and an exercise
training course has been constructed in the northern section of the site.

Several site investigations have been conducted at LF-023 as part of the Installation
Restoration Program (IRP) at Plattsburgh AFB.  A Preliminary Assessment verified
that the site was potentially contaminated.  The Preliminary Assessment prompted
a Site Inspection (SI), which confirmed the presence of contamination. SI activities
included soil, waste,  and groundwater sampling.   An  RI was  conducted to
characterize the nature and extent  of contamination at LF-023  and included
groundwater, surface soil, sediment, and surface water sampling. A more detailed
description of the site history can be found in the RI Report on pages 1-10 through
1-11 (ABB-ES, 1992a).
59213                                2-1                                6091-71

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SECTION 2
22 FEDERAL FACILITIES AGREEMENT HISTORY

Field investigation activities at LF-023 have been conducted as part of the Defense
Environmental Restoration Program (DERP), which was established to clean up
hazardous waste disposal and spill  sites at Department  of  Defense facilities
nationwide.  The IRP is the U.S. Air Force subcomponent of the DERP that
specifically deals with investigating and remediating sites associated with suspected
releases of toxic and hazardous materials, such as Plattsburgh AFB.   The IRP
operates  under the scope of CERCLA,  as  amended  by the 1986  Superfund
Amendments and Reauthorization Act (SARA).

The  Strategic Air Command (SAC) entered into an Interagency Agreement (IAG
No.  1758-1758-A1) with the  Department of Energy (DOE), under which DOE
provides technical assistance for implementation of SAC IRPs and related activities.
SAC requested DOE support in assessing the extent of contamination  at sites on
Plattsburgh AFB. Martin Marietta Energy Systems, Inc. (MMES) was assigned the
responsibility for managing the contamination assessment effort under the IAG
through the Hazardous  Waste Remedial Actions Program.   In  1986, the IRP
technical performance at Plattsburgh AFB was  assigned  to ABB  Environmental
Services, Inc. (ABB-ES), an MMES subcontractor (formerly E.G. Jordan Co.). The
IRP at Plattsburgh AFB has included (1) a Preliminary Assessment to evaluate which
sites are potentially contaminated, (2) Sis to  confirm the presence or absence of
contamination at identified sites, and (3) an ongoing RI program at sites confirmed
to have contamination.  In November 1989, Plattsburgh AFB was included on the
National  Priorities  List (NPL) of sites and will be remediated according to the
federal facilities agreement entered into among the U.S. Air Force, the USEPA, and
NYSDEC on September 12, 1991.
59213                                2-2                              6091-71

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    APPROXIMATE
     LANDFILL
     BOUNDARY
                             LIQUID
                             OXYGEN
                             PLANT
                                J
                      RGURE 3
          LF-023 SITE FEATURES
       LF-023 SOURCE CONTROL
           RECORD OF DECISION
             PLATTSBURGH AFB
         ABB Environmental Saryteaa, Inc.
2-3

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                                                               SECTION 3
                    3.0 COMMUNITY PARTICIPATION
Throughout Plattsburgh AFB's history, Plattsburgh AFB has kept the community and
other interested parties apprised of activities at LF-023 through informational
meetings, fact sheets, press releases and public meetings.

On August 1, 1989, Plattsburgh AFB held its first Technical Review Committee
(TRQ meeting to involve members of the Clinton County community and state and
federal regulatory agencies in  decisions concerning IRP environmental response
activities. The TRC currently meets quarterly to discuss plans and results of RI and
FS  activities.  During December 1990, Plattsburgh  AFB released a community
relations plan that outlined a program to address community concerns and keep
citizens informed about and involved in activities during the remedial process.

On August 4, 1992, Plattsburgh AFB made the LF-023  Administrative  Record
available for public  review at Plattsburgh  AFB in  Plattsburgh,  New York.
Plattsburgh AFB published a notice and brief analysis of the Proposed Plan in the
Press-Republican  and made the Proposed  Plan available to the public at the
Plattsburgh Public Library.

On August 4, 1992 Plattsburgh AFB held a public informational meeting to discuss
the results of the RI and the cleanup alternatives presented in the FS, present the
Proposed Plan, and answer questions from the public. Immediately following the
informational meeting, Plattsburgh  AFB  held  a public hearing to discuss the
Proposed Plan and to accept oral comments.  From August 4, 1992 to September 3,
1992, Plattsburgh AFB held a 30-day public comment period to accept public
comment on the alternatives presented in the FS and the Proposed Plan and on any
other documents previously released to the public. A transcript of the public hearing,
the written comments received  during the public comment period, and Plattsburgh
AFB's response to comments are included in Appendices C and D.
59213                                3-1                               6091-71

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                                                                SECTION 4
    4.0  SCOPE AND ROLE OF OPERABLE UNIT OR RESPONSE ACTION
Due to the nature of its primary mission, Plattsburgh AFB is engaged in a wide
variety of operations. A number of operations require the use, handling, storage, or
disposal of hazardous materials.  The IRP  addresses past instances when these
materials came into contact with the environment through accidental spills, leaks in
supply piping, landfill operations, burning of waste liquids during fire  training
exercises, and the cumulative effect of operations conducted at the base's flightline
and  industrial area.  These are the activities and  circumstances through which
contaminants of concern came into contact with site-related soil, sediment, surface
water and/or groundwater.  The suspected sources of contamination at Plattsburgh
AFB sites are  solvents, fuels, pesticides, and polychlorinated biphenyls  (PCBs).
Currently, there are thirty-nine IRP sites.

The  LF-023 source control remedial action will meet most of the remedial response
objectives identified for this site.  These include:

       1.     Minimize  potential  future human health  and current and future
             ecological  risks associated with  exposure  to polynuclear aromatic
             hydrocarbons  (PAHs) in surface soil.

       2.     Minimize potential future human health risks associated with -exposure
             to vinyl chloride in groundwater.

       3.     Minimize potential future human health risks associated with exposure
             to PAHs in dust emissions.

       4.     Minimize potential risks to aquatic organisms associated with exposure
             to inorganics in wetland surface water downgradient of LF-023.

       5.     Minimize infiltration of precipitation into landfilled waste materials.

       6.     Minimize potential for contaminant migration from waste materials.

       7.     Minimize erosion of existing cover soils.

Remedial response objectives  2 and 4 will be fully addressed in a separate  FS,
Proposed Plan, and ROD for groundwater, surface water, and sediment This source
59213                                4-1                                6091-71

-------
SECTION 4
control remedial action will address the following principal threats to human health
and the environment posed by the site: (1) potential future human health risks from
exposure to contaminants in site surface soil, and (2) potential effects to terrestrial
wildlife from exposure to surface soil contaminants.
59213                                 4-2                                 6091-71

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                                                               SECTION 5
               5.0 SUMMARY OF SITE CHARACTERISTICS
Subsection 1.4 of the landfill LF-023 Source Control FS report contains an overview
of the RI (ABB-ES,  1992a).  The significant findings of the RI are summarized
below.  Concentrations and frequencies of detection of site contaminants in the
various media at LF-023 are presented in Table 1.  Figure 4 diagrams potential
contaminant migration pathways and receptors.
5.1 WASTE/SOIL

Most of the landfill boundary is defined by large pine trees that predate landfill
activities. The boundary was confirmed by a magnetometer survey.  The area! extent
of two small sections of the landfill, which are north of the main portion of landfill,
was defined by a combination of a magnetometer survey and a ground-penetrating
radar survey. The area of the landfill is estimated to be 438,000 square feet. The
Preliminary Assessment indicated  that wastes may have been buried as deep as
25 feet bgs  in some areas. Observation during test pit excavation indicated that the
landfill is at least 13 feet deep.  The maximum volume of fill material is estimated
to be 406,000 cubic yards, based on a reported maximum depth of 25 feet.

Test pits were  dug during the SI to  evaluate the nature of contamination in
subsurface  soil and buried waste.  Material uncovered during test pitting indicates
that the type of wastes disposed of at this site ranged from bagged household trash
to construction debris and automobile parts. Site contaminants were not  detected
in subsurface soil; however one waste sample contained 1,2-dichlorobenzene.

A passive soil gas survey was conducted at LF-023  to  identify areas of potential
contamination and assist in identifying the location of future explorations.  Areas of
high flux values for some compounds were detected primarily along the dirt road that
runs north-south through the site.  However, results form subsequent groundwater
and surface water sampling do not suggest the presence of contaminant "hot spots".

The site was divided into quadrants  for surface soil sampling.  Composite surface soil
samples were collected from each  quadrant and analyzed for semivolatile organic
compounds (SVOCs), pesticides, polychlorinated biphenyls (PCBs), and inorganics.
Discrete surface soil samples were collected from four locations and analyzed for
volatile organic compounds (VOCs). The VOC sample locations were  selected based
59213                                 5-1                               6091-71

-------
SECTION 5
on soil gas survey results.  SVOCs (all of which were PAHs), silver, and PCBs
(Aroclor 1254) were identified as site surface soil contaminants.
52 GROUNDWATER

Groundwater monitoring wells were installed at LF-023 to collect groundwater
samples and to measure groundwater elevations. Groundwater at the site contains
the following inorganics identified as site contaminants: aluminum, iron, manganese,
and potassium.   The  VOCs detected  include  chloroform, vinyl chloride,
chlorobenzene, benzene, ethylbenzene, and total xylenes. One SVOC, naphthalene,
was also detected in one groundwater sample.
S3 SURFACE WATER/SEDIMENT

Surface water and sediment samples were obtained at seeps approximately 600 feet
south  of  the  site to investigate  the potential for contaminant  transport  via
groundwater discharge.  Aluminum, arsenic, iron, and zinc were detected in surface
water  at  concentrations  above Ambient Water Quality Criteria.  No target
compounds were  identified as  site contaminants in sediment samples;  however,
petroleum hydrocarbons (PHCs) were detected in sediment samples.

A complete discussion of site  characteristics can be found in the  RI report on
pages 4-13 through 4-64 (ABB-ES,  1992a).
59213                                5-2                               6091-71

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                                                    TABLE 1
                                        LF-023 STTE CONTAMINANT* Bv MEDIA

                                    LF-023 SOURCE CONTROL RECORD OF DECISION
                                                PLATTBBUROH AFB

'•'DereSrtbii^sl^fe^
GROUNDWATER (pq/L)
METALS
Aluminum
Iron
Manganese
Potassium
VOCs
Chloroform
Vinyl Chloride
Chlofobenzsno
Btnzofw
Pti_ jll-i mn-rm n m
cuiyiDvnzvnv
Xylene* (Total)
Naphthalene
•,;::.x :•••:•••; CONCENTTIATION HAHOE' ;-' :
V:':':: : MnoMUW MAXIMUM
<200
<100
<15
< 5,000
<0.2
<0.3
«5
<5

-------
continued
                                                     TABU 1
                                        LF-023 Srre CONTAMINANTS BY MEDIA

                                     LF-023 SOURCE CONTROL RECORD OF DECISION
                                                PlATTSaUROH AFB
DETECTION
Obenzo(a,h)anthracene
Ruorene
Banzo(g,h,i)p«fylene
PESTICIDES/PCBs
PCS (Arodor-12S4)
METALS (mg/kg)
Silver
S.EDIMENT (mq/Vq)
PHC»
SURFACE WATER_(^q
Aluminum
Arsenic
Iran
Zinc
WASJE f|*fl/kpj
1 ,2-Oichlorobenzene
CONCENTRATION RAHOE1 •:- ;
MmiMim MAXIMUM
<330
<330
<330
<160
<2
550
<200
<10
<100
<20
520
2.800
12,325
3,850
190
12.8
1,075
1990
316
672,000
355
520
FREQUENCY or
DETECTION2
1/4
1/4
1/4
1/4
2/4
2/2
1/2
1/2
2/2
1/2
1/1
Notes:
voc
svoc
PCS
PHC
Concentrations of duplicate samples were averaged.  When a compound was detected in one duplicate and not the other,
an average concentration was calculated by using the detection limit, adjusted for dilution.

Number of samples in which the compound waa detected above background concentrations or appropriate standards
divided by the total number of samples analyzed for that parameter. Duplicate samples were counted as one sample.

Concentrations detected In composite samples.

Concentrations reported from Method 8010 analyses.

Concentrrw*ns reported from CLP-COP and Metf..  . 8010 analyses.

Volatile Organic Compound
Semrvolatile Organic Compound
Porychlorinated Biphenyl
Petroleum Hydrocarbon
59213.T/2
                                                     5-4

-------
           Primary
           Souicet
            Wail*
en
     '.Primary
       Release
     Mechanism*
L.   Infiltration/   L
I*"   Percolation   I*"
                          Contact vrflh
                         Waste Material
               H
Secondary
 Sources
 Subsurface
   Sod*
 Surface Soil
 Secondary
  Release
Mechanbmt
Pathway*
             . Potential Receptors
|::I.'::-:  :••::••:;.- ' :-r:-l:.  •.••'••.    ••.•:
liL • V;"..':;v:   """    '    ' ' "
                                                                                      t>pOM« IMJI*
                                                                                                    Human
                                                                             Araa  I  On-laM
                                                                            MrilMnh I  r«i
                                                                                               Biota
                                                                                                                       AquaRe








|
1





|
, killtialkxi/ . 1.
, p« rcolotton |^


1






-


^ > <- 'I
! etouftd^alir !-»•
>V!,^o5 >*V |
f ^
SufaceWalar/ 1 ^
Sealmeni 1 *
1
i;



I
tAftiH ft ^
1 *


Inhalallon
Olf AC! Contact

Inaesllon
Dbecl Contact

Ingeillon
Dkocl Contact






•
9

•
•

•
•






'


•
•

•
•









•
•

•
•









*
•

\
\


\
_J
     noaoito
                                                                                                                    FIGURE 4
                                                                 LF-023 POTENTIAL MIGRATION PATHWAYS AND RECEPTORS
                                                                             LF-023 SOURCE CONTROL RECORD OF DECISION
                                                                                                          PLATTSBURGH AFB
                                                                 	'•	ABB Environmental Services, Inc.-

-------
                                                                SECTION 6
                       6.0  SUMMARY OF SITE RISKS
A risk assessment was performed to estimate the probability and magnitude of
potential  adverse  human health  and environmental effects  from exposure  to
contaminants associated with LF-023.

6.1 HUMAN HEALTH RISK ASSESSMENT

The human health risk assessment followed a four-step process: (1) data evaluation,
that identified those hazardous substances that, given the specifics of the site, were
of significant concern; (2) exposure assessment, which identified actual or potential
exposure  pathways,  characterized  the  potentially exposed populations,  and
determined the extent of possible exposure; (3) toxitity assessment, which considered
the types  and magnitude of adverse health  effects associated with exposure to
hazardous substances; and (4) risk characterization, which integrated the three earlier
steps to summarize the potential and actual risks posed by hazardous substances at
the site, including carcinogenic and noncarcinogenic risks.  The results of the human
health risk assessment for LF-023 are discussed below, followed by the  conclusions
of the environmental risk assessment  The complete risk assessment for  LF-023  can
be  found  in Subsection 4.4 of the RI  report,  with  supporting information in
Appendices J,  M, N, O, and P.

Thirty-two contaminants of concern were selected for evaluation  in the risk
assessment.   These  contaminants  include  all  compounds  identified  as site
contaminants  at LF-023 during the RI, except PHCs  (see  Table 1).   The 32
contaminants of concern were selected to represent potential site-related hazards
based on toxirity, concentration, frequency of detection, and mobility and persistence
in the environment; however, some contaminants were evaluated only in the human
health risk assessment, while others were only evaluated in the environmental risk
assessment A summary of the health effects of each of the contaminants of concern
can be found on pages 4-82 through 4-88 of the RI report Toxitity profiles for each
compound can be found in Appendix O of the RI report.

Potential human health effects associated with exposure to contaminants of concern
were  estimated  quantitatively through the development of several hypothetical
exposure pathways.  These  pathways were developed to reflect the potential for
exposure to hazardous substances based on the present uses, potential future uses,
and location of the site.  The following is a brief summary of the exposure pathways
59213                                6-1                                6091-71

-------
SECTION 6
evaluated. A more thorough description can be found on pages 4-69 through 4-82
of the RI report.

Eight exposure pathways were evaluated:

Current Site Conditions

       1.     Incidental ingestion of and direct contact with surface soil by a security
             policeman.

      2.     Incidental ingestion of and direct contact with surface soil by a child
             trespasser.

      3.     Incidental ingestion of and direct contact with surface water by a child
             trespasser.

     . 4.     Inhalation of vapors and fugitive dusts by a nearby resident.

Future Site Conditions

       1.     Ingestion of, direct contact with,  and inhalation of volatile  compounds
             from groundwater by a future resident.

      2.     Incidental ingestion of and direct contact with surface  soil by a future
             resident.

      3.     Incidental ingestion of and direct  contact with surface water by  a
             future child resident.

      4.     Inhalation of vapors and fugitive dusts by a future resident.

Security police use the obstacle course 48 days per year (four days per week, 12
weeks per year) for four years (the  average tour of duty).  Because they may be
exposed to the  soil to a greater extent than a typical adult, an ingestion rate of 200
milligrams per day (mg/day) was assumed.  Chemical concentrations were averaged
over the four quadrants and  chemical concentrations in the most contaminated
quadrant were used to evaluate risks.  Security police are more likely to  be  exposed
to soil in the northeast quadrant (where the obstacle course is located), where silver
is the only contaminant of concern detected in surface soils.
59213                                 6-2                                 6091-71

-------
                                                                 SECTION 6
Dermal contact and incidental ingestion of soils were evaluated for a child trespasser
between the ages of six and 16 years who may be exposed five days per year for the
10-year period.  A future resident may also be exposed via this pathway.  For the
future resident  scenario,  it was assumed the  child would  be exposed  through
childhood and into adulthood.  The exposure scenario was evaluated for a child
between the ages of one and six years, and an older child/adult between the ages of
seven and 30 years.  Exposure was assumed to occur 175 days per year for a total of
30 years.

Children between the ages of six and 16 years may also be exposed to surface water
in the wetland south of LF-023. Dermal contact and incidental ingestion of surface
water was evaluated for a child trespasser five days per year for one hour per day for
the 10-year period.  Similarly, a future child resident could explore the wetland and
be exposed to contaminants there. An exposure frequency of 26 days per year was
assumed for the future child resident because access would likely be easier than for
a child trespasser.

The inhalation pathway was evaluated for current residents of the mobile home park
600 feet southwest of the site, as well as future residents living on the site. For this
pathway, a model  was used to predict ambient  air concentrations at the  nearest
residence (200 meters away for the current  scenario  and  1 meter away for the future
scenario). Exposure was evaluated for a resident who may spend 16 hours  per day
for 175  days per year breathing the predicted air concentrations. This pathway was
assumed for a  child resident  (one  to  six  years old) and adult  residents (30-year
exposure duration).

Groundwater at the site is not currently used; however, a future resident could be
exposed to  groundwater via  ingestion of the  water,  dermal  absorption during
showering or bathing, and inhalation of volatile compounds during showering. These
pathways were evaluated together because a future resident could be exposed via all
three pathways.   Most  of  the  exposure parameters  used  were default values
established by USEPA  Maximum detected concentrations in  groundwater were
assumed.   Air concentrations were calculated using partitioning equations  (see
Appendix P of the RI report).

Excess  lifetime cancer risks  were  determined for each  exposure  pathway by
multiplying the exposure level with the chemical-specific  cancer slope factor.  Cancer
slope factors have been developed by USEPA from epidemiological or animal studies
to reflect a conservative "upper bound" of the risk posed by potentially carcinogenic
59213                                 6-3                                6091-71

-------
SECTION 6
compounds. That is, the true risk is very unlikely to be greater than the predicted
risk. The resulting risk estimates are expressed in scientific notation as a probability
(e.g., 1 x 10"6 for 1/1,000,000) and indicate (using this example) that an individual is
not likely to have greater than a one-in-a-million chance of developing cancer over
70 years as a result of site-related exposure (as defined) to the compound at the
stated concentration.  Current USEPA practice considers carcinogenic risks to be
additive when assessing exposure to a mixture of hazardous substances.

The Hazard Index was also calculated for each pathway as USEP. A's measure of the
potential for noncardnogenic health effects.  The Hazard Index is the sum of Hazard
Quotients, which are calculated by dividing the exposure level by the reference dose
(RfD)  or other suitable benchmark for noncarcinogenic health  effects for  each
compound.  RfDs have been developed by USEPA to protect sensitive individuals
over the course of a lifetime, and reflect daily exposure levels that are unlikely to
have an appreciable risk of an. adverse  health effect.  RfDs are derived from
epidemiological or animal studies  and incorporate uncertainty factors to help ensure
that adverse health effects will not occur.  The Hazard Index is often expressed as
a single value (e.g., 03) indicating the ratio of the stated exposure as defined to the
RfD (in this example, the exposure as characterized is approximately one-third of an
acceptable exposure level  for the given  compound). The  Hazard Index is only
considered additive for  compounds that have the same or similar toxic endpoints
(e.g., the Hazard Index for a compound known to produce liver damage should not
be added to a second whose toxic endpoint is kidney damage).

Tables 2, 3, and 4 depict the carcinogenic and noncarcinogenic risk summaries for
current and potential future receptors for the exposure pathways described above.
Human health risk calculations can be found in Appendix N of the RI.

All current human health risks were estimated to be below or within the acceptable
limits established by USEPA (Le., carcinogenic risks below or within 104 and  10* and
noncarcinogenic effects with a Hazard  Index of below or equal to 1.0).   Three
potential future human health risks were estimated to be above acceptable limits.
Evaluation of ingestion, direct contact, and inhalation of VOCs in groundwater
yielded a risk estimate of 7 x 104. Ninety-eight percent of the total cancer risks via
the  three exposure pathways are attributable to  vinyl  chloride.  Average and
maximum cancer risks for both future child and adult residents via direct contact and
incidental ingestion are above acceptable limits.  Essentially 100 percent of these
risks are attributable to carcinogenic PAHs. Carcinogenic  and noncarcinogenic risks
59213                                 6-4                                6091-71

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                                                                SECTION 6
estimated for a future child resident via inhalation of vapors and dusts from the
landfill above acceptable Limits.

The interpretation of these risk estimates is subject to a number of uncertainties as
a result of the multiple layers of assumptions inherent in risk assessment.  Many of
these assumptions are intended to be protective of human health (i.e., conservative).
Therefore, risk estimates are not truly probabilistic estimates of risk, but rather
conditional estimates given a series of conservative assumptions about exposure and
toxicity. Further information on the uncertainty of risk estimates can be found on
pages 4-97 through 4-100 in the RI report.

62 ENVIRONMENTAL RISK ASSESSMENT

A habitat-based environmental risk assessment (ERA.)  was performed for LF-023.
Terrestrial wildlife could be exposed to surface soil at the landfill and groundwater
seeps in the wetland south of the landfill.  There are no  aquatic habitats on site, and
the wetland to the south  is not expected to support fish because standing water is not
present throughout the year.  However, aquatic invertebrates may live in the wetland
and could be exposed to  chemicals  in the surface  water.  Selection of aquatic
receptors and  modeling  of  exposures was not  necessary  because chemical
concentrations could be  compared directly to water quality criteria.

Chronic and acute Hazard Indices for each indicator species exposed to surface soil
were between 10"5 and  10+0, indicating that effects to  individuals may occur, but
population effects are unlikely.   Effects to terrestrial organisms as a result of
exposure to  contaminants in the  wetland are not likely, based on Hazard Indices
between 10"3 and 10"2.  However, acute and chronic toxicity to aquatic organisms in
the wetland may be  occurring because the Hazard  Indices  calculated for this
exposure were between  1 and 10.

The ERA for LF-023 is presented on pages 4-100 through 4-111  and Appendix J of
the RI report.

Actual or threatened releases of hazardous substances from this site, if not addressed
by implementing the response action selected in this ROD,- may present an imminent
and substantial endangerment to  human health and welfare, and the environment.
The following risks must  be addressed through this or  subsequent remedial activities:
(1) potential future human health risks via exposure to vinyl chloride in groundwater,
(2) potential future  human health risks via exposure to carcinogenic PAHs in site
59213                                6-5                                6091-71

-------
SECTION 6
surface soil, (3) potential future human health risks via inhalation of vapor and dusts
from landfill surface soil, (4) potential environmental risks to terrestrial wildlife via
exposure to surface soils, and (5) potential environmental risks to aquatic organisms
in the wetland. As stated, this ROD addresses risks associated with landfill surface
soils.  Mitigation of risks  associated with groundwater and surface water and
sediment in the downgradient wetland will be addressed in a separate ROD.
59213                                  6-6                                 6091-71

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                                                     TABLE 2
                               SUMMARY or LF-023 SITE RISK ESTIMATES - SECURITY Poucc

                                     LF-023 SOURCE CONTROL RECORD OP DECISION
                                                 PLATTSBUROH AFB
                             EXPOSURE ROUTE, MEDWM A»W     PATHWAV-SPEOW: CANCER    :   TOTAL CANCER RISK OR
                    	EXPOSURE POBIT             RISK on HAZARD INDEX             HAZARD INDEX    :

  CARCINOGENIC EFFECTS

  Site-wide Average           Direct contact with surface soil              8E-05
                            digestion of surface soil                    1E-05                       9E-05

  Southeast Quadrant         Direct contact with surface soil              3E-04
 	Ingestion of surface soil	4E-05	3E-04	

  NONCARC1NOGENIC EFFECTS

  Site-wide Average           Direct contact with surface soil              0.06
                            Ingestion of surface soil                    0.01                        0.07

  Southeast Quadrant         Direct contact with surface soil               0.3
                            Ingestion of surface soil                    O.OS                         0.3
                                                       6-7
59213.T/3

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                                                    TABLES
                              SUMMARY OP LF-023 Srrc RISK ESTIMATES - CHILD TRESPASSER

                                    LF-023 SOURCE CONTROL RECORD or DECISION
                                                PLATTBBURQM AFB
TVprorEmcr
CARCINOGENIC EFFECTS
Site-wide Average
Southeast Quadrant

EXPOSURE ROUTE, MEDIUM AND
ExposuRE'PaNT-™- -^::>; •;• -™

Direct contact with surface soil
Ingestion of surface soil
Direct contact wrtn sunace soil
Ingestion of surface soil
Incidental ingestion of surface water
Direct contact with surface water

• PATHWAY-SPECIFIC CANCER
: RIMPOR HAZARD INDEX

6E-06
36-06
2E-05
16-05
1E-06 .,
3E-08
Total - Site-wide Average
Total - Southeast Quadrant
TOTAL CANCER RISK OR
•••:• HAZARD INDEX

9E-06
3605
1E-06
16-05
3E-05
NCj^CARClNOGENICEFFECTS
She-wide Average
Southeast Quadrant
a
Direct contact with surface soil
Ingestion of surface soil
Direct contact with surface soil
Ingestion of surface soil
Incidental ingeatiori of surface water
Direct contact with surface water

0.002
0.001
0.01
0.003
0.006
0.0001
Total - Site-wide Average
Total - Southeast Quadrant
0.003
0.01
0.006
0.009
0.02
59213.T/4
                                                    6-8

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                                                    TABLE 4
                               SUMMARY OF LF-023 Srrc RISK ESTIMATES - FUTURE RESIDENT

                                    LF-023 SOURCE CONTROL RECORD OP DECISION
                                                PlATTSBUROH AFB
EXPOSURE ROUTE, MEDIUM AMD- v
TYPE or EFFECT EXPOSURE POINT
CARCINOGENIC EFFECTS
Direct contact with groundwater
Ingastion of groundwater
Inhalation of volatile* - showering
Site-wide Average . Direct contact with surface soil
Ingestion of surface soil
Northwest Quadrant Direct contact with surface soil
Ingestion of surface soil
Incidental ingestion of surface water
Direct contact with surface water
Inhalation of vapors and dusts



NONCARC1NOGENIC EFFECTS
Direct contact with groundwater
Ingestion of groundwstsf
Inhalation of volatile* • showering
Site wide Average Direct contact with surface soil
Ingestion of surface soil
Northwest Quadrant Direct contact with surface soil
Ingestion of surface soil
Incidental ingestion of surface water
Direct contact with surface water
Inhalation of vapors and dusts

-PATHWAY-SPECIFIC CANCER
•• RISK OR HAZARD INDEX
CHILD ADULT
4E-07 • 1E-06
. 6E-04 7E-04
5E-05 4E-05
4E-04 6E-04
3E-04 1E-04
1E-03 2E-03
1E-03 5E-04
2E-07
7E-06
2E-04 1E-04
Total: Site-Wide Average-
Total: Northwest Quadrant
Total: Site-wide Average
Total: Southeast Quadrant
CHILD ADULT
0.003 0.002
0.9 0.2
• 0.3 0.06
0.2 0.08
0.2 0.02
0.8 0.4
1 0.09
0.0007
0.03
5 0.8
Total: Site-wide Average
Total: Northwest Quadrant
TOTAL CANCER RISK OB
. HAZARD INDEX
CHILD
7E-04
7E-04
2E-03
8E-06
2E-04
2E-03- —
3E-03
3E-03
6E-03
CHILD
1.2
0.4
2
0.03
5
7
8
ADULT
7E-04
7E-04
3E-03

1E-04
2E-03 	
4E-03

ADULT
0.3
0.1
0.5

0.8
1
2
59213.T/5
                                                        6-9

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                                                               SECTION 7
        7.0 DEVELOPMENT AND SCREENING OF ALTERNATIVES
7.1 STATUTORY REQUIREMENTS/RESPONSE OBJECTIVES

The primary goal at NPL sites is to undertake remedial actions that are protective
of human health and the environment. Section 121 of CERCLA establishes several
other statutory  requirements and preferences, including:  a requirement that the
remedial action, when complete, must comply with all federal .and more stringent
state environmental standards, requirements, criteria or limitations, unless a waiver
is invoked; a requirement that the selected remedial action is cost-effective and uses
permanent solutions and alternative treatment technologies or resource recovery
technologies to  the maximum extent practicable; and a preference for remedies in
which treatment that permanently and significantly reduces the toxicity, mobility, or
volume of hazardous substances is a principal element over remedies not involving
such treatment.  LF-023 source control alternatives were developed to be consistent
with these Congressional mandates.

Based on the types of contaminants, environmental media of concern, and potential
exposure pathways,  remedial response objectives were developed  to aid in the
development and screening of alternatives. These remedial response objectives were
developed to mitigate existing and future potential threats to human health and the
environment:

      1.    Minimize potential future  human health and  current and future
            ecological risks associated with exposure to surface soil contaminants
            (primarily PAHs).

      2.    Minimize potential future human health risks associated with exposure
            to vinyl chloride in groundwater.

      3.    Minimize potential future human health risks associated with exposure
            to PAHs in dust emissions.

      4.    Minimize potential risks to aquatic organisms associated with exposure
            to aluminum, arsenic, and zinc in wetland surface water downgradient
            of LF-023.

      5.    Minimize infiltration of precipitation into landfilled waste materials.
59213                                7-1                               6091-71

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 SECTION 7
       6.     Minimize potential for contaminant migration from waste materials.

       7.     Minimize erosion of existing cover soils.

 Remedial response objectives 2 and 4 will be fully addressed in a separate FS,
 Proposed Plan, and ROD for groundwater, surface water, and sediment.


 12  TECHNOLOGY AND ALTERNATIVE DEVELOPMENT AND SCREENING

 CERCLA and the National Oil and Hazardous Substances Pollution Contingency
 Plan (NCP)  set forth  the process by which remedial actions are evaluated and
 selected (USEPA,  1990a).  In accordance with these requirements, a range of
 alternatives was developed for the site. With respect to source control, the RI/FS
 developed a  limited number of remedial alternatives appropriate for large landfill
 sites, focusing on attaining response objectives for source control and mitigating risks
 associated with potential exposure to surface soils.  A No Action Alternative was also
 developed to provide a baseline for comparison against the other alternatives.

 As discussed in Subsection 4.1 of the LF-023 Source Control FS (ABB-ES, 1992b),
 the RI/FS identified, assessed, and screened technologies based on the approach
 outlined in the NCP and USEPA's Streamlining the RI/FS for CERCLA Municipal
 Landfill Sites (USEPA, 1990b).  Subsection 4.2 of the FS presents the remedial
 alternatives developed by combining the technologies retained from the screening
 process in  the categories identified in  Section  300.430(e)(3)  of  the NCP.
 Technologies were combined into source  control alternatives ranging from an
 alternative that eliminates the need for  long-term management  by removing or
 destroying contaminants to the maximum extent feasible, to alternatives that provide
 no treatment but do protect human health and the environment. Section 5.0 of the
 FS presents the initial screening of LF-023 alternatives. The purpose of the initial
 screening was to narrow the  number  of potential remedial actions for detailed
 analysis while preserving a range of options.  Each alternative was evaluated and
 screened based on its effectiveness, implementability, and cost.

'In summary,  of the five source control remedial alternatives screened in Section 5.0
 of the FS,  three were  retained for  detailed  analysis.   Table 5 identifies the
 alternatives that were retained through the screening process, as well as those that
 were eliminated from further consideration.
 59213                                 7-2                                6091-71

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                                                        TABUS
                                           SUMMARY OP ALTERNATIVE* SCREENING

                                       LF-023 SOURCE CONTROL RECORD of DECISION
                                                    PtATreauRQH AFB
                              ALTERNATIVE.
                    STATUS:
  Alternative 1:   No Action
Retained for detailed analysis.
  Alternative 2:   Site Grading and Vegetation Establishment
Retained for detailed analysis.
  Alternative 3:   Installation of a tow-Permeability Barrier Cover System
Retained for detailed analysis.
  Alternative 4:   Excavation and Incineration
Eliminated from further consideration.
  Alternative &   Stabilization/Solidification
Eliminated from further consideration.
                                                         7-3
59213.T/8

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                                                                SECTION 8
                   8.0  DESCRIPTION OF ALTERNATIVES
This section provides a narrative summary of each alternative evaluated.  A detailed
description of each alternative can be found in Section 6.0 of the FS report.

The source control alternatives  analyzed for LF-023  include Alternative 1:  No
Action, Alternative 2: Site Grading and Vegetation Establishment for Closure, and
Alternative 3: Installation of a Low-permeability Barrier Cover System.
8.1 ALTERNATIVE l: No ACTION

The No Action Alternative (Alternative 1) provides a baseline against which the
other alternatives can be compared, and also assesses the effects on human health
and the environment if no remedial actions are taken.  The No Action Alternative
includes a program to monitor the status of groundwater and surface water quality,
with five-year reviews to evaluate how human health and the environment are
protected.   This  monitoring program would meet the relevant and  appropriate
requirements of Part 360 of the New York State Solid Waste Management Facility
Rules for closure  and post-closure of solid waste landfills (hereinafter referred to as
Part 360) requirements for long-term monitoring. The No Action Alternative would
not meet the remedial response objectives.

Estimated Time for Construction (installation of a groundwater monitoring well): 3 days

Estimated Time of Operation:  30 years

Estimated Capital Cost:  $9,000

Estimated Operation and Maintenance  (O&M)  Costs (30 years, net present worth
assuming a 10 percent discount factor):  $784,000

Estimated Total Costs (30 years, net present worth assuming a 10 percent discount
factor): $793,000
59213                                8-1                               6091-71

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 SECTION 8
8.2    ALTERNATIVE 2:   SITE GRADING  AND VEGETATION ESTABLISHMENT FOR
       CLOSURE

This alternative (Alternative 2) consists of a soil cover (i.e., no low-permeability
layer) to support grass growth and reduce precipitation infiltrating to buried wastes.
The alternative includes:

       1.     Clearing and grubbing of the site.

       2.     Surface water  runoff-management to minimize erosion of the cover
             and minimize maintenance requirements.

       3.     Soil cover installation.

       4.     Vegetation establishment to minimize erosion of the final cover and
             enhance evapotranspiration.

       5.     Post-closure plan development to monitor, maintain, and inspect the
             site.

       6.     Groundwater and surface water monitoring.

       7.     Five-year site reviews.

This alternative would only slightly reduce the infiltration of precipitation through
the wastes from current levels, and therefore would not minimize the potential for
contaminant migration from wastes to groundwater.

Estimated Time for Construction: 3 months

Estimated Time of Operation: 30 years

Estimated Capital Cost:  $987,000

Estimated O&M Costs (30 years, net present worth  assuming a 10 percent discount
factor): $988,000

Estimated Total Costs (30 years, net present worth assuming a 10 percent discount
factor): $1,975,000
59213                                 8-2                                6091-71

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                                                               SECTION 8
8.3   ALTERNATIVE 3: INSTALLATION OF A LOW-PERMEABILITY BARRIER COVER
      SYSTEM

Alternative 3 consists  of a low-permeability cover system to achieve the response
objectives identified in Section 7.0.  The alternative includes:

      1.     Clearing and grubbing of the site.

      2.     Surface water runoff management to minimize  erosion of the cover
             and minimize maintenance requirements.

      3.     Installation of a gas detection and management system.

      4.     Construction of a barrier layer.

      5.     Placement of a barrier protection layer.

      6.     Installation of a vegetative cover layer.

      7.     Vegetation establishment to minimize erosion of the final cover and
             enhance evapotranspiration.

      8.     Post-closure plan development to monitor, maintain,  and inspect the
             site.

      9.     Groundwater and surface water  monitoring.

      10.    Five-year site reviews.

This alternative would greatly reduce both infiltration of precipitation through the
wastes,  and minimize  the potential for contaminant migration from wastes to
groundwater. This alternative would meet the source control response  objectives.

Estimated Time for Construction: 4 months

Estimated Time of Operation:  30 years

Estimated Capital Cost: $3,586,000
59213                                8-3                                6091-71

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 SECTION 8
Estimated O&M Costs (30 years, net present worth assuming a 10 percent discount
factor):  $988,000

Estimated Total Costs (30 years, net present worth assuming a 10 percent discount
factor):  $4,574,000
59213                                  8-4                                 6091-71

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                                                              SECTION 9
  9.0 SUMMARY OF THE COMPARATIVE ANALYSIS OF ALTERNATIVES
Section 121(b)(l) of  CERCLA presents several factors  that,  at a minimum,
Plattsburgh AFB is required to consider in its assessment of alternatives.  Building
upon these specific statutory mandates, the NCP articulates nine evaluation criteria
to be used in assessing the individual remedial alternatives.

A detailed analysis of alternatives was performed using the nine evaluation criteria
to select a site remedy.  These criteria and their definitions are discussed in the
following subsections.
9.1 THRESHOLD CRITERIA

The two threshold criteria described below must be met in order for the alternatives
to be eligible for selection in accordance with the NCP.

      •     Overall protection of human health and the environment addresses
            whether or not a remedy provides adequate protection and describes
            how risks posed through each pathway are eliminated, reduced, or
            controlled through treatment, engineering controls, or institutional
            controls.

      •     Compliance with  Applicable  or  Relevant and Appropriate
            Requirements (ARARs) addresses whether or not a remedy will meet
            all of the ARARs of other federal and state environmental laws
            and/or provide grounds for invoking a waiver.
92 PRIMARY BALANCING CRITERIA

The following five criteria are used to compare and evaluate the elements of one
alternative to another that meet the threshold criteria,

      •     Long-term effectiveness and permanence assesses alternatives for the
            long-term effectiveness  and permanence they afford, along with the
            degree of certainty that they will prove successful.
59213                                9-1                               6091-71

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SECTION 9
             Reduction of toxicity, mobility, or volume through treatment addresses
             the degree to which alternatives employ recycling or treatment that
             reduces toxicity, mobility, or volume, including how treatment is used
             to  address the principal threats posed by the site.

             Short-term effectiveness addresses time needed to achieve protection
             and any adverse impacts on human health and the environment.

             Implementability addresses the technical and administrative feasibility
             of  a remedy, including the availability of materials and services needed
             to  implement a particular option.

             Cost includes estimated  capital and O&M costs, as well as present-
             worth costs.
93 MODIFYING CRITERIA

The modifying criteria are used on the final evaluation of remedial alternatives after
Plattsburgh AFB has received public comment on the RI/FS and Proposed Plan.

      •      State  acceptance addresses New York State's  position and key
             concerns related to the preferred alternative and other alternatives,
             and New York State's comments on ARARs or the proposed use of
             waivers.

      •      Community acceptance addresses the public's general response to the
             alternatives described in the Proposed Plan and RI/FS report.
9.4 CRITERIA SUMMARY

A detailed tabular assessment of each alternative according to the nine criteria can
be found in Tables 6-4, 6-7, and 6-9 of the FS report (ABB-ES, 1992b).

Following the detailed analysis of each individual alternative, a comparative analysis,
focusing on the relative performance of each alternative against the nine criteria, was
conducted. This comparative analysis can be found in Table 7-1 of the FS report.
59213                                9-2                                6091-71

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                                                                SECTION 9
The subsections below present the nine criteria and a brief narrative summary of the
alternatives  and  the  strengths and  weaknesses according to the detailed and
comparative analyses.

9.4.1  Overall Protection of Human Health and the Environment

Alternatives 2 and 3 would both minimize the potential human health and ecological
risks associated with surface soil exposures.  Alternative 2 would only slightly reduce
precipitation infiltrating to the wastes; consequently, the potential for contaminant
migration from  waste material  to groundwater would not  be minimized.
Alternative 3 would minimize the infiltration of precipitation, thereby reducing the
potential  for  contaminant migration  from waste  material to  groundwater.
Alternative 1, the  No Action Alternative, would not include any measures to protect
human health or the environment

9.4.2  Compliance with Applicable or Relevant and Appropriate Requirements

Alternative 3 meet the relevant and appropriate  requirements of Part 360 for final
cover systems governing landfill closure. Alternative 2 would comply with some but
not all  Part 360  requirements.  Alternative 1 would not comply with Part 360
regulations for landfill closure.

9.43  Long-term Effectiveness and Permanence

Alternative 3 would provide the greatest long-term effectiveness by (1) reducing
potential human health and ecological risks associated with surface soil exposures,
(2) significantly reducing the infiltration of precipitation through the cover system,
and (3)  reducing the net leachate discharge  to the wetland.  Alternative 2 would not
effectively reduce the potential for contaminant migration to groundwater because
only  a  slight  reduction of infiltration  through the cover system is  expected.
Alternative 1 would provide the least long-term protection because it would not meet
any remedial response objectives.

9.4.4  Reduction of  Toxicity, Mobility,  or Volume of  Contaminants through
      Treatment

Reduction of Toxicity, Mobility, or Volume  of Contaminants through Treatment are
three principal measures of the overall performance of an alternative. This criterion
essentially does not apply to the source control  alternatives evaluated for LF-023,
59213                                9-3                                6091-71

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SECTION 9
because treatment would not be employed as a principal element.  Treatment is a
statutory preference under CERCLA; however, cover systems are often more
appropriate for landfill sites such as LF-023.

9.4.5  Short-term Effectiveness

Short-term impacts-are not  anticipated for Alternative 1 because no remedial actions
would be implemented.  Alternatives 2 and 3 would result in similar direct short-term
impacts to potential ecological receptors from clearing and grubbing activities.

9.4.6  Implementability

The implementability of Alternatives 2 and 3 would be similar; however, a suitable
borrow source for the low-permeability hydraulic barrier material must be identified
before implementation of  Alternative 3, unless a  synthetic liner is used instead.
Alternative  1 would be readily implementable because no remedial actions would be
conducted.

9.4.7  Cost

Alternative 1 would be the least expensive because it would  involve no remedial
actions.  Alternative 3 would be the most costly of the two cover system alternatives;
however, the increased cost is associated primarily with the hydraulic barrier cover
materials.

9.4.8  State Acceptance

The State Acceptance  criterion has been addressed by incorporating  comments
received from NYSDEC on behalf of the state on the Proposed Plan. The state has
had the opportunity to review and  comment on all documents produced for LF-023.
New York State concurs with the  selected remedy for LF-023 source control (see
Appendix B).

9.4.9  Community Acceptance

Plattsburgh AFB has not received public comment on the LF-022 Proposed Plan.
If the public had commented on the Proposed Plan, the comments would have been
addressed in the Responsiveness Summary attached as an appendix to this ROD.
59213                                9-4                               6091-71

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                                                               SECTION 10
                       10.0 THE SELECTED REMEDY
Plattsburgh AFB has chosen Alternative 3 as the selected remedy for LF-023 because
it addresses source control response objectives for LF-023.  Response objectives for
groundwater, surface water, and sediment contamination will be addressed further
in a separate FS, Proposed Plan, and ROD. Source remediation at LF-023 will be
consistent with future groundwater remedies and will mitigate releases of hazardous
substances from the former landfill to groundwater.
10.1 CLEANUP LEVELS

Cleanup levels have not been established for the surface soil contaminants of concern
(primarily PAHs).  Chemical-specific ARARs are not available for contaminants in
soil. In the absence of a chemical-specific ARAR, or other suitable criteria to be
considered (TBC),  a  10"* excess  cancer risk level for carcinogenic effects or a
concentration corresponding to  a  Hazard  Index of  1.0 for  compounds with
noncarcinogenic effects is typically used to set cleanup levels.  Risk-based target
cleanup levels were not developed  for LF-023 source control because discrete source
areas (i.e., hot spots) were not found. Remedial alternatives developed for LF-023
included  containment options to  address the entire landfill area and treatment
options to address all landfilled soil and waste.  These alternatives were developed
to address mitigation of surface soil risks and the potential for contaminants leaching
to groundwater.  The Hydrologic Evaluation of T andfill Performance (HELP) model
was used to evaluate expected performance (i.e., amount of water that can percolate
through the waste) of the three alternatives.  HELP model results were used to
calculate dilution factors for the  shallow LF-023  aquifer for two scenarios (i.e.,
Alternatives 1  and 3).   Based  on this  analysis,  a 2.7-fold  improvement in
downgradient groundwater quality is expected for Alternative 3 over  baseline
conditions.

Cleanup  levels for other contaminated media associated with the site will be
developed in the FS for groundwater, surface water, and sediment, if appropriate.

Periodic  assessments of the protection afforded by remedial actions (i.e., five-year
site reviews) will be made as the remedy is being implemented and at the completion
of the  remedial action.  If the source control remedial action is not found to be
protective, further action will be required.
59213                                10-1                                6091-71

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SECTION 10
10.2 DESCRIPTION OF REMEDIAL COMPONENTS

The Installation of a Low-permeability Barrier Cover System (i.e., Alternative 3)
consists primarily of a low-permeability  cover  system to achieve the response
objectives identified in Section 7.0 of this document.

Existing vegetation such as trees and brush would be cleared, grubbed, and removed
from the site.  The cleared site would be regraded to control rainwater runoff and
minimise  erosion. The installation of a gas detection system, around the landfill
would  be used to monitor for the  presence or  migration of  methane and other
landfill gases after closure of LF-023. A gas management system also would be part
of the landfill cover including venting pipes between a gas-venting soil layer and the
cover system surface.

The cover's barrier layer would be constructed of  a synthetic liner to keep rainwater
or snowmelt from infiltrating  the landfill.  The low-permeability barrier  layer is
covered by a soil barrier protection layer to protect the barrier layer from frost or
root penetration. The additional soil over the barrier layer will provide an area for
small plants to root However, large plants requiring deeper soil for their root
systems will not be allowed to grow over the barrier cover in order to prevent root
penetration into the synthetic liner.  Six niches of topsoil would be placed on top of
the barrier protection layer to plant  grass, which will minimize soil erosion and
enhance evapotranspiration.

A post-closure  plan  will be developed specifying the inspection, monitoring, and
maintenance programs for the closed  landfill to be continued for 30 years.  These
post-closure activities  will' be subject to five-year site reviews as  required by the NCP
when contaminants remain at the site.  In addition, institutional controls for this  site
will be incorporated into the Plattsburgh AFB Comprehensive Plan. This will ensure
that future owners will be made aware of the landfill location and are informed that
the integrity of the final covers, liners, or any other component of the containment
or monitoring system must not be compromised.
59213                                10-2                                6091-71

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                                                             SECTION 10
                   11.0 STATUTORY DETERMINATIONS
The  remedial  action selected for implementation at LF-023 is consistent with
QERCLA and,  to the extent practicable, the NCP. The selected remedy is protective
of human health and the environment, attains ARARs, and is cost-effective. The
selected remedy uses permanent solutions and alternative treatment technologies or
resource recovery technologies to the maximum extent practicable for this site.
However, it (as well as the other alternatives evaluated) does not satisfy the statutory
preference for a treatment which permanently and significantly reduces the toxicity,
mobility, or volume of hazardous substances as a principal element.
11.1  THE SELECTED REMEDY is  PROTECTIVE  OF HUMAN HEALTH  AND THE
      ENVIRONMENT

The remedy at LF-023 will permanently reduce the risks posed to human health and
the environment by eliminating, reducing, or controlling exposures to human and
environmental receptors through engineering controls (i.e., low-permeability barrier
cover system).   Moreover, the selected  remedy  will minimize infiltration of
precipitation into  landfilled  waste material  and minimize  the  potential for
contaminant migration from waste materials.  Finally, implementation of the selected
remedy will not pose unacceptable short-term risks or cross-media impacts because
the selected  remedy includes elements to mitigate potential impacts  (e.g., erosion
control measures, gas detection and management, and maintenance and monitoring
programs).
112 THE SELECTED REMEDY ATTAINS ARARs

This remedy will attain all federal and state requirements that apply or are relevant
and appropriate to the site and selected source control remedy.  ARARs that pertain
to groundwater, surface water, and sediment will be identified for these media in
separate FS and ROD documents, and selected remedies for those media will be
required to comply with ARARs.  Environmental laws from which ARARs for the
59213                               10-1                               6091-71

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SECTION 11
selected source control remedial action are derived, and the specific ARARs, are
listed below.

Applicable or Relevant and Appropriate Requirements:

      Location-specific;

      •     Fish and Wildlife Coordination Act (16 U.S.C. 661, et seq.), relevant
            and appropriate because of the regulated wetland downgradient of
            LF-023.

      •     National Environmental Policy Act (40  CFR Part 6), Appendix A
            (except for fioodplain requirements), relevant and appropriate because
            of the regulated wetland downgradient of LF-023.

      •     dean Water Act,  Section 404, relevant and appropriate because of the
            regulated wetland downgradient of LF-023.

      •     NYSDEC Freshwater Wetlands Regulations (6 NYCRR Parts 662
            through  665), relevant  and appropriate  because of the  regulated
            wetland downgradient of LF-023.

      Chemical-specific;

      No federal or state chemical-specific ARARs have been promulgated for
      contaminants in soil. However, the following chemical-specific ARARs and
      guidelines pertain to  potential air emissions resulting from construction
      activity at the site:

      •     Clean Air Act  (40 CFR Part 50), applicable for particulate matter
            (e.g., fugitive dusts) entrained in air during clearing, grading, cover
            system construction activities.

      •     NYSDEC Ambient Air Quality Standards  (6 NYCRR  Part  257),
            applicable for particulate matter (e.g., fugitive dusts)  entrained in air
            during clearing, grading, cover system construction activities.

      Action-specific:
59213                                11-2                               6091-71

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                                                             SECTION 11
      •     NYSDEC Solid Waste Management Facility Rules (6 NYCRR Part
            360),  applicable to solid waste landfills, specifies closure and post-
            closure criteria.

      •     Fish and Wildlife Coordination Act (16 U.S.C. 661, et seq.), relevant
            and appropriate because of the regulated wetland downgradient of
            LF-023.

      •     National Environmental Policy Act (40 CFR  Part 6), Appendix A
            (except  for  floodplain  requirements) is  relevant and  appropriate
            because of the regulated wetland downgradient of LF-023.

      •     Clean Water Act, Section 404, relevant and appropriate because of the
            regulated wetland downgradient of LF-023.

      •     Clean Air Act (40 CFR Part 50), applicable for particulate matter
            (e.g., fugitive dusts) entrained in air during clearing,  grading, cover
            system construction activities.

      •     Occupational Safety and Health Administration Regulations (29 CFR
            Parts 1904, 1910, and 1916), applicable for all work conducted on site.

      •     NYSDEC Freshwater Wetlands Regulations (6 NYCRR Parts 662
            through  665), relevant  and  appropriate  because  of the regulated
            wetland downgradient of LF-023.

      •     NYSDEC Use and Protection of Waters, Excavation, and Placement
            of Fill in Navigable Water (6 NYCRR Section 608.4), relevant and
            appropriate because of the regulated wetland downgradient of LF-023.

      •     NYSDEC Division of Air  Resources  Regulations (6 NYCRR
            Parts 200-202, 257), applicable for  particulate  matter (e.g., fugitive
            dusts) entrained  in air  during clearing, grading,  cover  system
            construction activities, and emissions from landfill gas  vents.

      •     New  York State  Air Pollution  Control  Regulations (6 NYCRR
            Chapter  3, Part 212), applicable if pollution control equipment is
            required as part of the gas management system.
59213                                11-3                              6091-71

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 SECTION 11
A more detailed discussion of why these requirements are applicable or relevant and
appropriate may be found in the FS report on pages 3-1 through 3-8 and 4-9 through
4-16. Within these pages of the FS report, other laws that are not applicable or
relevant  and appropriate to this site are discussed and the rationale for their
exclusion as ARARs is presented.

Federal and State Nonregulatory Criteria:

In addition to the federal and state ARARs, federal and state non-promulgated
advisories or guidance may be considered when ARARs for specific contaminants are
not  available.  The following policies, criteria, and guidance (i.e., TBCs) were
considered:

      •      New York Air Guide - 1, Guidelines for the  Control of Toxic Ambient
             Air Contaminants, guidance  to  be  considered  for  landfill gas
             management.

      •      USEPA Health Advisories, USEPA RfDs, and USEPA Human Health
             Assessment Group Cancer Slope Factors,  criteria used in the
             preparation of the baseline risk assessment  for LF-023.
113 THE SELECTED REMEDIAL ACTION is COST-EFFECTIVE

In Plattsburgh AFB's judgment, the selected remedy is cost-effective (i.e., the remedy
affords overall effectiveness proportional to its costs). In selecting this remedy, once
Plattsburgh AFB identified alternatives that are protective of human health and the
environment and  that attain ARARs, Plattsburgh AFB  evaluated  the overall
effectiveness of each alternative by assessing the relevant three criteria: long-term
effectiveness and permanence; reduction  in toxicity, mobility, or volume through
treatment; and  short-term effectiveness, in combination. The relationship of the
overall effectiveness of this remedial alternative was determined to be proportional
to its costs.  The costs of this remedial alternative are:

Estimated Capital Cost: $3,586,000

Estimated O&M Costs (30 years, net present worth assuming a 10 percent discount
factor):  $988,000
59213                                11-4                               6091-71

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                                                               SECTION 11
Estimated Total Costs (30 years,  net present worth assuming a 10 percent discount
factor): $4,574,000

Alternative 3 is considered the most cost-effective alternative because it provides the
most protection against contaminant leaching and meets the relevant and appropriate
requirements of Part 360 regulations, as compared to Alternatives 1 or 2. Alternative
3 is similar to Alternative 2 in regard to short-term impacts. None of the alternatives
evaluated in detail include a treatment component.
11.4   THE SELECTED REMEDY UTILIZES PERMANENT SOLUTIONS AND ALTERNATIVE
       TREATMENT OR RESOURCE RECOVERY TECHNOLOGIES TO THE MAXIMUM
       EXTENT PRACTICABLE

The selected remedy is protective of human health and the environment, complies
with federal and state requirements that are  legally  applicable or relevant and
appropriate to the source control remedial action, and is cost-effective. The selected
remedy uses permanent solutions  and alternative treatment technologies or resource
recovery technologies to the maximum extent practicable for this site.

The source  control remedy was  selected by deciding which one of the identified
alternatives  provides the best balance of trade-offs among alternatives in terms of:
(1) long-term effectiveness  and permanence; (2) reduction of toxicity, mobility, or
volume through  treatment; (3) short-term effectiveness; (4) implementability; and
(5) cost  The balancing test emphasized long-term effectiveness and permanence and
the reduction of toxicity,  mobility,  and volume through treatment; and considered the
preference for treatment as a principal element, the bias against off-site land disposal
of untreated waste, and community and  state  acceptance.  The selected remedy
provides the best balance of trade-offs among the alternatives.

The principal element of the selected remedy is source control.    This element
addresses the primary threats at LF-023:  human health and environmental risks
associated with surface soil contamination and potential leaching of contaminants
from the waste to groundwater. The selected remedy was chosen primarily because
it affords the most protection to human health and the environment, even though its
increased level of protection over  the other alternatives makes it  slightly more
difficult to implement and more costly.  The short-term effects of implementing the
selected remedy are comparable to Alternative 2.  None of the three source control
59213                                11-5                               6091-71

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SECTION 11
alternatives evaluated in the FS included a treatment component to reduce toxicity,
mobility, or volume.

The selected alternative complies with state regulations governing closure and post-
closure of solid waste landfills, and NYSDEC has had the opportunity to review and
comment on all documents produced  for LF-023.  State  and public comments
received on LF-023 Source Control to date have been incorporated into this ROD
for the site.
11.5  THE SELECTED REMEDY DOES NOT  SATISFY THE PREFERENCE  FOR
      TREATMENT  THAT  PERMANENTLY  AND  SIGNIFICANTLY  REDUCES  THE
      TOXICITY, MOBILITY, OR VOLUME OF THE HAZARDOUS SUBSTANCES AS A
      PRINCIPAL ELEMENT

Because treatment of the principal threats at the site was not found to be practicable,
this remedy does not satisfy the statutory preference for treatment as a principal
element of the remedy.   Treatment technologies were  considered during the
identification of remedial technologies and the development and initial screening of
alternatives, but were considered to be infeasible for the LF-023 landfill site.  The
size of the landfill and the fact that there are no on-site hot spots representing the
major sources of contamination preclude a remedy in which contaminants could be
excavated and treated effectively. The FS report to be prepared for other  site media
(i.e., groundwater, surface water, and sediment) will consider treatment options if
cleanup goals are appropriate for those media.
59213                                11-6                               6091-71

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                                                              SECTION 12
         12.0 DOCUMENTATION OF NO SIGNIFICANT CHANGES


Plartsburgh AFB presented a Draft Final Source Control Proposed Plan for the
preferred alternative for remediation of LF-023 in August  1992.  The preferred
alternative for source control included:

      1.     Gearing and grubbing of the site.

      2.     Surface water runoff management to minimize erosion of the cover
             and minimize maintenance requirements.

      3.     Installation of a gas detection and management system.

      4.     Construction of a barrier layer.

      5.     Placement of a barrier protection layer.

      6.     Installation of a vegetative cover layer.

      7.     Vegetation establishment to minimize erosion of the final cover and
             enhance evapotranspiration,

      8.     Post-closure plan development to monitor, maintain, and inspect the
             site.

      9.     Groundwater and surface water monitoring.

      10.     Five-year site reviews.

The chosen remedial action does not differ from the preferred alternative presented
in the Proposed Plan.
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                                                           SECTION 13
                       13.0 REGULATORY ROLE
The EPA and NYSDEC have reviewed the various alternatives and have indicated
their support for the selected remedy. The EPA and NYSDEC have also reviewed
the RI, risk assessment, and FS to determine if the selected remedy is in compliance
with applicable or  relevant  and  appropriate federal and New York State
environmental laws and regulations. The EPA and NYSDEC concur with the
selected remedy for LF-023 source control The EPA indicates .its concurrence with
the LF-023 source control ROD by cosigning the document with Plattsburgh AFB.
A copy of the NYSDEC declaration of concurrence is attached as Appendix B.
59213                               13-1                             6091-71

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                                                           REFERENCES
ABB  Environmental Services, Inc. (ABB-ES), 1992a.  "Installation Restoration
      Program (Remedial Investigation/Feasibility Study) at Plattsburgh Air Force
      Base, New York; Final Landfills LF-022/LF-023 Remedial Investigation
      Report"; Portland, Maine; February.

ABB  Environmental Services, Inc. (ABB-ES), 1992b.  "Installation Restoration
      Program (Remedial Investigation/Feasibility Study) at Plattsburgh Air Force
      Base, New York; Draft Final landfill LF-023 Source Control Feasibility Study
      Report"; Portland, Maine; March.

U.S. Environmental  Protection Agency (USEPA),  1990a.   "National  Oil  and
      Hazardous  Substances Pollution Contingency Plan:"  40 CFR Part 300;
      Washington, D.C.; March 8.

U.S. Environmental Protection Agency (USEPA),  1990b. "Streamlining the RI/FS
      for CERCLA Municipal Landfill Sites"; Office of Emergency and Remedial
      Response Hazardous Site Control Division; Washington, D.C.; September.
59213                                                                 6091-71

-------
                                                             ACRONYMS
   ABB-ES    ABB Environinental Services, Inc.
   AFB       Air Force Base
   ARAR     Applicable or Relevant and Appropriate Requirement

   bgs         below ground surface

   CERCLA   Comprehensive Environmental Response, Compensation, and Liability
              Act of 1980 (the Superfund statute)

   DERP      Defense Environmental Restoration Program
   DOE       Department of Energy

   ERA       environmental risk assessment

   FS         Feasibility Study

   HELP      Hydrologic Evaluation of Landfill Performance

   IAG       Interagency Agreement
   IRP  .     Installation Restoration Program

   mg/day     milligrams per day
   MMES     Martin Marietta Energy Systems, Inc.

   NCP       National Oil and Hazardous Substances Pollution Contingency Plan
   NPL       National Priorities List
   NYSDEC   New York State Department of Environmental Conservation

   O&M      operation and maintenance

   PAH       polynuclear aromatic hydrocarbon
   PCB       polychlorinated biphenyl
   PHC       petroleum hydrocarbon

   RfD       risk reference dose
   RI         Remedial Investigation
   ROD       Record of Decision

   SAC       Strategic Air Command
   59213
6091-71
. C..V17T'•"'/•*>" ' •?*.*>'

-------
                                                         ACRONYMS
SARA     Superfund Amendments Reauthorization Act
SI         site inspection
SVOC     semivolatile organic compound

TBC       to be considered
TRC       Technical Review Committee

USEPA    U.S. Environmental Protection Agency

VOC       volatile organic compound
59213
6091-71

-------
APPENDIX A - ADMINISTRATIVE RECORD INDEX

-------
                                 PITTSBURGH AFB ADMINISTRATIVE RECORD DOCUMENT  INDEX
                                                             SITE LF-023
DOC it   ; TYPE  !
                    SUBJECT
IFROrt
;   •   TO
[DATE
LF-023
                 1.0 Site Identification
 1.10  [R     [IRP Records 3ear.ch-see Ooc.  H-i

                   .1.6 Site Inspection
                                                            IRadian  Corp,  HcCiean  Va   [Piattsturgh AFB
1.61  |R     [See oocuaent No H-6,  iite  Inspection  Report    ;E.C.  Jordan  Co  ror.iaric   ,f'icttsDur§n AF6, NT
1.62  |R     [See docuaent No M-9,  Appendix  I                :                          :
1.63  |R  . •  |See docusent No fl-10,  Appenai»  II              ,
                                                        APR 85
                                                                                                                    JUL 89
                  o.O
                              I[ive5ii9atiOi!  (xij
LF-023         3.1 Saapiing and Analysis-see also  LF-022/LF-023 RI  Report  Appenci';es-LF-02I
3
3
3
3
•5
V
3
3



'3
.10
.11
.12
.13
.14
.15
.16



.40
ID
[L
IL
ID
IL
IL
ID



!L
3-.41 JL
3
3
3
3
3
3
3
3

4
4
4
4
4
4
4
4
4
4
4
4
4

8

.42
.43-
.44
.45
.46
.47
.48
.49

.05
.10
.11
• i«i
.13
.14
.15
.16
.17
.18
.20
.21
.22

.10

IL
IL
IR
IL
[L
[L
!R
IR

\l
IL
[L
IL
IL
IL
!L
IL
[R
IL.R
IR
[L
IL

IL.R

[LF-022/LF-023 RI Kepori-Laooratory cianK oata
lAnaiyticai Data for FT-C02 ana LF-023
[Analytical Data for FT-002 and LF-023
[LF-023 well 23-OOS groundwater results
[Validated saaple results- LF-022 and LF-023
[Validated saaple results- LF-022 and LF-023
[Laboratory Results-Old Rt. 22, 3 FEB 92


3.4 RI reports and coasents
I NYSDEC Coaients on LF-022/LF-023 RI Report
[Scope of Uork for Further investigation
[Resp. to CoBBents on LF-022/LF-023 RI Report
IResp. to EPA CoBaents on LF-022/023 RI Report
[Meeting Minutes, LF-022/LF-023 RI/FS
! NYSOEC coaaents-LF-022/LF-023 Final RI Report
IUSEPA coaaents-LF-022/LF-023 Final RI Report
IEPA approval of LF-022/LF-023 Final RI Report
[LF-022/LF-023 RI Report-Final
[LF-022/LF-023 RI Report-final-Appendices-
4.0 Feasibility Study (FS)
[Identif ication of ARARo for LF-022 ana LF-023
[Resp to CoiDB-LF-023 screening of Alternatives
[NYSOEC Coaaents on Lr-023 FS Report
,USE?A Coaiaents on Lr-023 FS Source Control
[NYSOEC Coaaents on LF-023 FS Source Control
[USEPA Approval of LF-023 FS Source Control
[NYSOEC COBB. -LF-023 screening of Alternatives
[USEPA COBB. -LF-023 screening of Alternatives
[Landfill LF-023 Source Control FS-Final
[Landfill LF-023 Supp. Field Inv.(Uork Plan)
[Landfill LF-023 Proposed Reaedial Action Plan
I NYSDEC Coaients on LF-023 Draft PRAP
[ USEPA Coiients on LF-023 Draft PRAP
8.0 Health Assessaents
[Landfill LF-022/LF-023 Risk Assessaent, based
on unfiltered saapling results
:«o£ Env. Svcs, Inc.
[J. Huru, PE, ?AFB
U. Huru, PE, PAFE
|J. Huru, PE, PAF3
ICoi. Hrapia, PAFB
[Col. Hrapia,
i Aqua tec,



|J Lister,
[Alliance
[J. Huru,
[J. Huru,
Inc.



PE,
Tech
PE,
PE,
PAFB





.




NYSDEC
Corp
PAFB
PAFB
[Pittsburgh AFB
|J Lister,
[Ua. Roach
[Ua. Roach
[ABB Env.
[ABB Env.

iABo Env.
iA65 Env.
[J Lister,
[Us. Roacn
[J Lister.,
I'M. Roach
[J Lister,
[Ua. Roach
PE,
, PE
, PE
Svcs
Svcs

Svcs
Svcs
PE,
, PE
PE,
, ?E
PE,
, PE
[ABB Env. Svcs

)
)
1
1

)
^

t

(

»
1
NYSOEC
USEPA
USEPA
Inc.
Inc.

MIC.
Inc.
NYSDEC
USEPA
NYSDEC
USEPA
NYSDEC
USEPA
Inc.
|J. Huru, PE, PAFB
[ABB Env. Svcs
[Michael J
|Ua. Roach

»
Inc.
O'Toole NYSDEC
, PE

»

USEPA

|J. Huru, PE, PAFB
J. Huru, PE, PAFB
iwin. Roach, PE. UStPA i :2
;J Lister, ?E. NiSCiEC i i2
Idistribution list ( inc) ! 13
[UB. Roach, PE, USEPA ! 13
|J Lister, PE, NYSDEC
[Stanley Holland, PAFB



[P. Von Bargen, PAFB
[Ua. Roach, PE, USEPA
[Ua. Roach, PE, USEPA
|J Lister, PE, NYSDEC
[Attendees
[Al Rascoe, PE, PAFB
[P. Maloy, PAFB
|A1 Rascoe, PE, PAFB
[Pittsburgh AFB
[Pittsburgh AFB

[Doug Draper, hAZURAP
;toug Draper, riAZwRpip
IA1 Rascoe, PE, PAFE
\n\ Rascoe, PE , PAFB
[Ai Rascoe, PE, PAFB
[Al Rascoe, PE, PAFB
[Al Rascoe, PE, PAFB
[Al Rascoe, PE, PAFB
i Pittsburgh AFB
[UB. Roach, PE, USEPA
[Pittsburgh AF8
[Al Rascoe, PE, PAFB
[Al Rascoe, PE, PAFB

lUa. Roach, PE, USEPA
[J Lister, PE, NYSOEC
1 13
1 19



15
02
31
31
04
23
26
08



i 26
i :i
; 29
1 : 7
! A '
: 07
13
13
13

15

3
2
•*
! 15
15
NOv
OE;
DEC
JAN
FEB
FEB
FEB



OCT
JAN
DEC-
DEC
MAR
MAR
MAR
APR
FEB
FEB

SEP
CCT
NOV
DEL-
APR
APR
APR
MAY
MAY
..UN
JUN
JUN
JUN

JUN
JUN
V 1
92
92
92
92



91
91
91
91
92
92
92
92
92
92

9i
91
91
- i
"u
n
92
')?.
n
9?
92
92
92

92
92
        NOTE:   TYPE  BLOCK MEANINGS- L-Letter  M=Messafle  D=Data  R=Report

-------
APPENDIX B - STATE LETTER OF CONCURRENCE

-------
The State letter of concurrence will be placed here after NYSDEC reviews and
concurs with the Draft Final ROD.

-------
APPENDIX C - PUBLIC MEETING TRANSCRIPT


-------
                  TRANSCRIPT OF TOWN MEETING AUGUST  4,, 1992
 COL LIAS:   We simply stated to the reporters  that we're  very  concerned.
             We're going to restore.  We're going  to comply,   (inaudible)
             And we're very proud of our accomplishments in  these  areas,
             and I'll mention two of those here  in a second.  Hopefully,
             you're all familiar with them.  The other  goal  that we  had
             related to the community.  We want  to be'good neighbors.  We  are
             members and we are co-inhabitants of  the lovely  north country,
             wedged here between Lake Champ!ain  and the Adirondacks.   And  to
             be a good neighbor, we've got to be just as kind to the  environ-
             ment as possible.  So, those are our goals.  They're  right up
             there with the rest of our goals, and we take them very  seriously.
             The (inaudible) this past year are a team of real professionals
             working on environmental  issues and they-we won numerous  awards.
             And I'm going to have to get a card to read them because  I can't
             remember them all.   The Strategic Air Command in 1991, they won
             the Thomas E.  White award competition for winner of the
             installation  individual  awards for environmental compliance;
             winner of the installation individual  awards for environmental
             restoration.   We won the installation individual awards for
             pollution prevention.   At the Air Force level, we won the
             installation  award  for environmental compliance.  We also
             received honorable  mentions in the award for pollution--
             environmental  restoration,  pollution prevention.  And at the
             Department of Defense  level,  we're currently competing for the
             1991  Thomas E.  White award for—installation award environmental
             compliance.   We're  keeping our fingers crossed,  because we know
             that  we're a  leading force in  that competition,  and we're very
             proud  of it.   And our  people  are  very  proud of that because it
             takes  more than just our  environmental  technicians that work in
             Civil  Engineering.   It takes  (inaudible)  wrench  bender who works
             down  in  the maintenance  shops  to  be aware.   It takes  the guys--
             our civilians  that  worked  here for years  to bring areas  of
             possible  problems to the  staff, our environmental  people, and we
             go out there  and  research  it.   (inaudible)  talk  about  it
             tonight.   The  purpose  of  this  meeting  is  to inform the people of
             our findings and  our recommended  remedies,  and the  environmental
             impacts  of our  selected remedial  alternatives  regarding  two
             landfills.  And I'll turn  it over  to our  experts.   Hopefully,
            you'll  find (inaudible).

PURSER:      Thank  you, sir.  My  name is Lieutenant Darren  Purser and  I'm  the
            Deputy Chief of Public Affairs here  at Plattsburgh  Air Force
            Base.  Basically, I  just wanted to  introduce you  to the
             speakers,  as well as some of our guests.  To my  left is
            Mr. Phil Von Bargen, who is our IRP  remedial project manager,
            Ms. Rachel Becker,  our IRP chemical  engineer,  and  in the
            audience we're  pleased to have Mr. Jim  Lister,  a  state  regula-
             tor, Mr. Bill  Roach with the EPA,  and Mr. Tom  Lawson from URS,
            which  is one of our engineering facilities.  At  this point,

                                     1

-------
 PURSER:      basically,  1  wanted  to  run  down the list»of our community
             involvement between  us  and  our neighbors regarding the. IRP, one
             of  which  is fact  sheets.  We've had a series of fact sheets in
             print,  and  tonight we are releasing four more.   It basically
             gives  an  overview and kind  of sums up what the  IRP program is
             all  about.  The administrative record is here at Plattsburgh Air
             Force  Base and contains  all  the documents leading up to remedial
             as  well as  removal actions.   The information repository is a
             condensed version of this record and tha-t is available at the
             Plattsburgh Public Library.   Quarterly TRC meetings,  one which met
             on  the  16th of last  month—they did a site tour and visited I
             believe seven sites.  And the TRC  is made up of local  community
             leaders,  as well  as  cue-base  environmental  group,  and  again, the
             state and federal  regulators.   News releases—anytime  the
             program reaches a milestone or a note of interest,  we  have varied
             channels with the local  media so there is very  good com-
             munication at that end.   Public  meetings-like the  one  we're
             having tonight kicks off what is a 30 day comment  period in which
            we  invite the public to offer their input into  projects that we
             are undergoing, and these are all  included  in the  final  deci-
             sion.  The nailing list—if you  signed the  sign-up  sheet,  you'll
             be  added to the IRP mailing list.   And again, anytime  there is
            notes of interest or important information,  we  like to  stay in
            close touch.  And at this point,  I'm going  to turn  it  over to
            Mr. Von Bargen and he will  give  you  the  breakdown  of our program.

VONBARGEN:  Thank you.  We'll  work right  from  the overhead.  First,  I'd like
            to start off with  just a simple  overview of  the  Installation
            Restoration Program,  and that's  to  explain what  its purpose is..
            And that's simply  to identify, investigate,  evaluate, and
            preempt any task  releases that are  necessary  to  do  so.   Our pro-
            cess is driven by  the CERCLA  legislation of  1980, and that
            was reauthorized  in  1986.  It  was  that legislation  that  created
            the National  Priority List process,  of which  Plattsburgh Air
            Force Base was proposed  to  be  on that  list in July  of 1989,  and
            was final  on that  list in November of  1989.  That puts  us  as  a
            priority site  among  locations  across  the  United States  to  deal  with
            these environmental  releases.   Along with that then we  have  a
            Federal  Facilities Agreement,  which became effective on
            12 September 1991.  And  that was an agreement that  was entered
            between the  Air  Force,  the  USEPA "and  the State of  New York.
            And that Federal Facilities  Agreement then drives the process  by
            which we deal  with each  and  every site on of Plattsburgh Air
            Force Base.   It's  broken  up  very simply  into these  four stages--
            identification,  investigation, cleanup,  and then eventually
            the closeout of that  site.   We currently  are working—at this
            public  meeting right  here—we're in that  stage of which we've
            gone out and investigated these two landfills, documented  our
            findings,  and  then evaluated the number  alternatives, of which
            we're going  to be  addressing tonight,.and then come up with an
            Air Force  preferred remedy  that we're putting up for public

-------
VONBARGEN:  comment and consultation and concurrence,with  the  State  of  New
            York and the USEPA.  So what we're dealing with  tonight  are the
            investigative and feasibility stages of this p'rocess.  Resources
            to get this process moving along—the Department of  Defense has
            its own separate account, that is an analgous  to like  the  super-
            fund account.   We have here at the base an environmental manage-
            ment flight where we have a staff of approximately 17  people
            working in the Civil Engineering Squadron under  the  direct
            leadership of the Environmental  Protection Committee Chairman,
            Colonel Lias.   We have our Environmental Working Group,  members
            of which are her? tonight, that meets on a bi-weekly basis  and
            goes over these issues with our sites.   We have other  government
            agencies involved,  which is obvious with the State of  New York
            and USEPA here.   We also have the Army  Corp of Engineers and  the
            Department of Energy,  and then finally,  we have our engineering
            contractors,  from which we go ahead an.d..procure--receive services
            from under a contractual  relationship.   Okay.  Well, this par-
            ticular program then is moving in the direction that the two
            sites  that we're working with tonight—well,  actually  this  is a
            map of  24 sites, and we're working tonight with sites—landfills
            22 and  23,  which are located  on  the west side of the base.  Now,
            I'm going to  go  right  into a  little bit  of background about
            landfill  23.   And what we're  going to do is we're going to  treat
            each  landfill  separately.   So,  right now we'll  address landfill
            23.   This  site was  active  from 1966 until  1981, and it received
            residential  and  municipal  waste.   And I  want  to clarify that,
            that  municipal waste is totally  from the base facility itself,
            not from any outside entities.   Now,  these wastes were deposited
            into  trenches, which were  approximately  25 feet and were covered
            daily.   Hazardous wastes were  not routinely disposed of in  this
            landfill.   However,  in  our  phase  I  records search,  there was a
            report  of  a suspected  incident of hazardous material  being
            disposed  of in the  landfill.   Ground  water associated with this
            landfill,  I do want  to  mention,  is  being treated separately.
            However,  the remedy  that we select  for the landfill  unit itself
            is  going  to kind of  address some  of  the  problems associated with
            ground  water.  However,  there  is  a  feasibility  study  process
            being conducted  just for that ground  water  unit itself.  Okay.
            Well, what  kind  of  activities have  occurred there?   Again,  I go
            back to  1985, a  phase  I  records search,  at  which there  were
            interviews  that  were conducted.   A  site  inspection  was  performed
            and documented in July  of 1989, when  we  went  out and  confirmed
            basically that there was ground water contamination  and some
           wastes  were identified  at that time.  A  remedial  investigation
           was then performed,  with the final  report  being released  this
           past February, and then the feasibility  study report, which
           Rachel—which Ms. Becker will  be  talking about  in a-little
           while.  And that feasibility study, which  evaluates a number of
           alternatives, then has   a selected remedy that is  put  forth  in  a
           proposed plan, which is what is open  for public  comment right
           now.  Actually,  the  feasibility study and  the proposed  plan  are
           both up for public comment.  Okay.  Well, very  quickly, the  type
           of events that took place to investigate the  site involved  the

-------
 VONBARGEN:   surface soils, subsurface soils, ground tfater,  the  surface water
             associated with downslope--a distance away fronj  the site, the  actual
             waste material in the landfill, and some sediments  in  some seepage
             areas south of that landfill.  The methods -that  we  used  to
             determine what the extent of the landfill was included test
             trenching, a seismic survey to give us a profile of the  geology
             at the site, a magnetometer survey where we went out and looked
             for metal  anomalies to see if there were-any sites  of  perhaps
             buried drums,  discreet soil  sampling, composite  sampling of  the
             soils at the surface,  a passive soil  gas study,  and ground water
             testing.  And  all  of that information is contained  in  the
             remedial investigation report.   Okay.  Well, our findings--
             basically, we  identified 16 different semi-volitile organic
             compounds  in the  surface soils, and we also found some trace
             silver.   And one  sample has a trace level of PCB, which was
             about 220  parts per billion.   Test trenches dug show that the
             waste included bagged  household trash, construction debris,  and
             scrap metal.   And  there were  no anomalies such as buried drums
             in  large quantities found there.   A nearby seep in the water
             sample included aluminum, arsenic,  zinc,  and iron.  Also, in the
             sediment sample located near—by  that surface water sample were
             some  (inaudible).-  Again, I  do  mention that the ground water is
             being treated  separately at this  site.   And the general conclu-
             sions 'that we  can  make about  this  particular landfill  were that
             we  found no areas  of concentrated  elevations that we considered
             to  be hot  spots of any signifance  were found in  that site.   Our
             primary  concern at that landfill  is surface soil  and minimizing
             infiltration of rainfall  through  that landfill  basin.   At this
             point, Ms.  Becker  is going  to  give  us  an  overview and  infor-
             mation pertaining  to a risk assessment and  a feasibility  study
             process  and that result.

BECKER:      Thanks,  Phil.   After we  obtained  the  data  from  our remedial
             investigation,  we  proceed on  in the process  by  performing a  risk
             assessment.  And risk  assessments are  basically  performed to
             determine  whether  remedial action at  a  site  is  necessary.  These
             are broken  into two  groups.  There  is  a human  health risk
             assessment  and  a habitat  risk assessment, which  are  further
             broken down  into risk  groups.  There  is carcinogenic risk,  the
             non-carcinogenic risk  for humans, and  the acute  risks  and
             chronic  risks  for  the  environmental ba^ed risk assessment.
            The EPA  has determined  that a risk  value  for carcinogenic risk
             of 10 to the negative  6  to 10 to the negative 4  is considered
            acceptable.  This  is basically a unit!ess probability of  any
            adverse  effects occurring for a population.  This  level has been
             determined  to be acceptable.  In'addition,_the non-carcinogenic
             risk  is  measured as a  hazard index, and a hazard  index  of less
             than one is considered acceptable.  For the ecological  risk,
             it's broken down just  a little bit  differently.   A hazard index
            of less  than .1 indicates that no possible effects will occur.
            A hazard index  between  .1 and 10 indicates that  possible  adverse
            effects may occur,  and a  hazard index greater than 10 indicates
            that probable adverse effects may occur to some  individuals.

-------
BECKER:     There are handouts on the table  that break  this  process  down  in
            a little bit more detail.  But,  just for  simplicity,  I'd
            generalize that the risk rankings, according ,tb  the  different
            scenarios that we looked at—part of the  risk  assessment is
            developing scenarios in order to assess the risk.  And based  on
            landfill 23, we have three risk  scenarios.  One  involves
            the security police, which use an obstacle  course  that's located
            on this landfill.   Another is that of a child  trespasser.  And
            we also include a hypothetical future resident in  our risk
            evaluation to ensure that we're  looking in  the long  term.  Based
            on these numbers,  the security police and child  trespasser risks
            are within acceptable levels.  However, the future resident does
            show an unacceptable risk based on EPA risk levels for car-
            cinogenic risk  as  well  as non-carcinogenic  risk  for children.
            For the ecological  assessment, we looked at several  receptors
            that we felt were  representative of our .landfills.  These
            were the white  footed mouse,  the wood thrush,  the garter snake,
            and red fox,  as well  as  the red tail  hawk.  And we tried to take
            a  nice representative of carnivores as well  as birds and things
            of that nature.  And based  on-our risk assessment, which  again
            is in  more detail  in the handout, it indicates that the  hazard
            index  is primarily  between  .1 and 10,  which means that possible
            effects could occur to  some individuals.   However, wide-spread
            population effects  were  not anticipated.   After we get done the
            risk  assessment, we determine whether remedial  action is
            necessary.   In  this case, we  have determined that it is.   The
            first  thing  that we need to do is develop  remedial response
            objectives.   With those  objectives,  we develop a string  of
            alternatives, screening  the ones  out that  we don't feel   are
            appropriate  for the site, analyze the  several  alternatives we
            pick,  and  then  compare them to chose  our  preferred alternative.
            For  this site we developed  several  objectives..  Primarily,
            they're  based on minimizing  the  potential  threat and  future
            human  and  ecological  risks  of the contaminants  found  on   site,  as
            well as  minimize the  infiltration of  parcipitation through the
            waste  and  into  the  ground water,  which  is  what  Phil was  trying
            to  impress upon you.  The purpose of  this  feasibility study is
            not  to  clean up the  ground  water.   However,  it  addresses  source
            control  aspects of  the landfill.   Thereby,  one  of our objectives
            being  preventing more migration through the  waste and into the
            ground water.   From  our  objectives, we came  up  with several
            alternatives.   One  is no action,  whictt includes just  monitoring
            the  site.  The  second one is.site grading  and  a vegetation
            establishment,  which  is just  basically adding  approximately  a
            foot of  soil and putting a vegetative cover.   Installation of  a
            low permeability barrier cover system, which entails  a lot more
            soil as  well as an  inpermeable membrane.   Excavation  and  inci-
            neration means  basically removing  all the waste and destroying
            it through incineration.  And  stablization/solidification, which
            is an on-site process of solidifying the waste  in  place.   We
            screened these  alternatives using  essentially  three different
            criteria,  that  is, effectiveness,  implimentability, and cost.

                                    5

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 BECKER:      This is our way of not having to spend a'lot of time evaluating
             alternatives that probably won't be applicable.to  the site.  And
             based on our evaluation, we determined'-that the no action vege-
             tative cover and the permeability cover systems were the most
             appropriate for our site because excavation and incineration and
             stabilization/solidification are really dependent upon having
             hot spots or things of that nature.  It also entails a lot of
             extra excavation that may—may bring short term effects to the
             workers in the area.   And we didn't feel that it was any more
             protective than the other three alternatives, in addition to its
             being extremely costly.   Our three alternatives were evaluated
             using nine criteria.   Basically, the nine criteria is to eva-
             luate whether it's protective of human health and the environ-
             ment, its permanence  and long-term effectiveness,  it's
             implement-ability cost,  and compliance with regulations.   In
             addition, the last two criteria are state acceptance and the
             community acceptance.  At this point,  we~have gotten concurrence
             from the State and EPA on our preferred alternative, and the
             community acceptance  criteria will  be  evaluated after all  com-
             munity  comments have  been submitted.   Based on  our evaluations,
             Plattsburgh  Air Force  Base feels that  the preferred remedial
             alternative  is  alternative three,  the  installation of a low per-
             meability variable cover system, which  in addition to it  being
             very protective,  it also fulfills  the  Part 360  New York  State
             requirement.   It provides overall  protection  of human health  and
             the  environment.   It  provides long-term effectiveness.   And it
             has  the  greatest  effect  on  reducing the potential  for additional
             contaminants  to migrate  through  the waste into  the ground  water
             at this  landfill.   And at this  point,  that concludes the  presen-
             tation on  landfill  23.   And  Mr.  Yon Bargen  will  come back  and
             brief the  background on  landfill 22.

YONBARGEN:   There are—aside  from  the  background,  there are  a  lot of
             similarities between the  two  landfills  as  we  progress along
             here.  The age  of  this landfill  is  slightly older.   It was
             active from  1959  through  1966.   It  again  also received  primarily
             residential  and again, waste  from the base  entity,  in trenched
             cells.   It also  reportedly received sludge waste from our  base
             industrial waste  water pretreatment facility, which  was basi-
             cally a kind of oil and water separator  process.   And sludges
             from  that, as they were  put out  into tanks, were then just
             apparently disposed of over in that landfill.   It  also received
             spent aircraft  starter cartriges, which were at one  time thought
             to have been the  disposition  of  munitions waste.   However,  it
             really was aircraft starter cartriges.  Again, the  process is
            very similar to the landfill  23.  This  site was looked at  in  the
            phase I report  in 1985.  However, at that time, it was not
            ranked—it was not considered for further action.   In Devaluating
            the records and understanding the waste water treatment facili-
            ties operations and the waste going over there, we reconsidered
            that site in the site inspection stage.  We went out  and did
            some sampling of the waste and thought that we needed to go

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 VONBARGEN:  farther into a remedial investigation report.  That was  final-
             ized in February of 92, just recently, and that identifies  the
             nature and extent of the contamination we found in that  report.
             It also contains the risk assessment that Miss Becker speaks
             about.   The feasibility study report was just recently
             completed, which identifies the various alternatives that were
             considered.  And then the proposed plan, which is being  put out
             right now, is for the recommended remedy for that site,  and
             Rachel  Becker will  speak about that.  And again, what did we do
             out there.  It was  somewhat similar, except that at this par-
             ticular site, we.didn't have surface water and sediments to go
             out and sample,  but we sampled the surface soil  and subsurface
             ground  water, and the waste.  We used very similar techniques as
             we did  over at landfill  23.   And our findings for this par-
             ticular landfill  were—in this case, there were  no volitile or
             semi-volitile organic compounds in the surface soils.   There was
             DDT,  a  pesticide, detected at less than  20 parts per million in
             the surface soils.   The wastes themselves were analyzed and
             detected  carbon  tetrocholoride and cholroform.   This (inaudible)
             petroleum hydrocarbons  and (inaudible)  metals.   However, the
             only  contaminant  that was  site related for basically throughout
             the site  was  lead.   Our general  conclusion would be,  again,  that
             there are  no  zones  of elevated contamination  or  what are known
             as  hot  spots,  and that  we  also believe that the  site condition—
             the low oxygen  site  conditions  which are  typical  of  many land-
             fills may  be  increasing  the  solubility  of the naturally
             occurring  iron and maganese,  which are  in elevated con-
             centrations at that  site.   I  should also  say  that  the  ground
             water—and I  don't  see  it  on  the  bullet  there—that  the  ground
             water did  have levels of—levels  of iron  and  maganese  that
             exceeded New  York State  ground  water standards.  And again,  that
             may be  because of the anerobic  conditions  at  the site  and the
             iron  and maganese that  naturally  occur going  into  the  solution,
             or  it could also  possibly  be  from  metals  that are  rusting away
             basically  at  the  landfill  site.  There also—we  don't  believe
             that  there  is any horizontal—or limited  horizontal migration  of
             site  contaminants at  that  particular  landfill.   Ms. Becker now
             is  going to go into—again,  the site  risks  and the feasibility
             study leading to  a recommended  perferred  alternative.

BECKER:      This  is basically the same as the  other site.  These are  con-
             sidered acceptable risk  levels.  And  again, for  ecological risks
            we have the three different levels  of risks.  For  landfill 22,
            we had  similar scenarios.:  There was  the child trespasser and
             the future  resident.  This risk assessment  indicates that the
            hazard  index for the child—for a  future  resident.is borderline.
            The hazard  index is 1, which  is considered acceptable.   It's the
             same  receptors were elevated  for landfill 22 as  for landfill 23,
            with  similar results.  Our risk assessment determined a  few
             individuals may possibly have adverse effects, but there  would
            be no population problems.  And again, we go through the  same
            process for landfill 22  and we did  for landfill 23.  In  fact,
            all of  our sites went through this process to go through  the

                                     7

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 BECKER:     feasibility study process.  The remedial response objective  for
             this site was basically to minimize the exposure to  pesticides
             in the surface soils at this site.  And again, since most  land-
             fills of this nature are similar, we had the same remedial
             alternatives to evaluate.   And again, we evaluated these using
             the three criteria of effectiveness, implementability,  and cost.
             And not surprising,  this screened flown to the first  three  alter-
             natives, the same as we did for landfill-23.  After  evaluating
             the three alternatives as  in the criteria, that is also
             identifying in the proposed plan, we determined that alternative
             two for this landfill  was  appropriate,  the vegetative establish-
             ment cover system.  We determined this  because it provides an
             overall protection of human health and  the environment.  It  pro-
             vides lotig-term effectiveness.   It's the least costly of the
             cover system alternatives, and there are actually less adverse
             ecological  impacts with this particular alternative, since
             alternatives using geomembranes prevent us from planting trees
             in  the  area.  These—for the feasibility study process, we deve-
             lop a feasibility study, and that's  also—that's located on  the
             table,  if anybody wants to flip through it.   It's just basically
             a  detailed  version of  what I've just told you,  and a condensed
             version of  the proposed plan,  which  everyone is  welcome to take.
             And that is  actually what  people are to comment  on.   And that
             concludes the  landfill  22  briefing.

PURSUER:     At  this point,  I'm going to turn it  over to  Mr.  Von  Bargen to
             moderate  the question  and  answer period.   Again,  the public is
             invited to  give  inputs  that will  be  used in  the  final decision,
             and comments can  be  made by either using a comment sheet,  which
             are up  here  in  front by  the  sign-in' table, or  they call  the
             Public  Affairs  office  directly,   (inaudible)

VON BARGEN:  Thank you.   We  are open  to  questions.
MEYERS:
ROACH:

MEYERS:
BECKER:
Can you clear up a little
plan 3—alternative 2 and

For both sites?         .  •
bit
3?
the difference between plan 2  and
Yeah.  What is actually the difference.between  alternatives  2
and 3?

The difference is alternative 2 is strictly a vegetatior.  cover.
Basically, it's a matter.of placing about a foot of  soil  on  top
of the existing soil and establishing vegetation over  that  to
enhance the amount of transporation.  It essentially protects
receptors from the surface soil  itself.  On the other  hand,
alternative 3, the low permeability cover system—in addition to
having soil  being placed on the surface, has a  geomembrane,
which is a impermeable—which is a low permeability membrane.   It
prevents approximately 7U percent of the percipitation  from
                                     8

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 BECKER:     infiltrating through the landfill waste.. And  in  the  case  of
             landfill 23, we--one of our response  objectives  to  reduce  the
             infiltration.  That's why we chose the geomembrane  alternative,
             as .opposed to just the vegetative cover  for protection  of  the
             surface soil.

 MEYERS:     So, is this  like a plastic coating or something like  a  covering
             that goes over the —

 BECKER:     It goes in between the soil  layers.   In fact,  Tom Lawson could
             probably give you a little bit more detail on  the actual com-
             ponents of the cap.

 LAWSON:     I'm Tom Lawson.   Basically,  what alternative 3 is,  is a full
             NYS Part 360 cap.  Without getting into all  of the  design
             details, this is basically what it does is it's a layered
             approached.   First, what you do is you regrade the  landfill so
             that it has  a consistent drainage on the cap,  and then what you
             do is  you  build  up layers,  okay.   And what you're going to do is
             first  is you're  going to put down a varied layer.   You want to
             be able to track (inaudible).   And then what is put on top of
             that is an inpermeable  layer built up.  And then you put a vege-
             tative lawyer on top  of that.   And the rationale for alternative
             3  as opposed to  2,  as Rachel  mentioned,  is because you had con-
             cern for landfill  23  being  a generator—a waste generator for
             ground water contamination,  so  you want to be  able to track the
             source down,  and based  on  that, the perculation rate down from
             about  13i  inches per  year  down  to about 2i inches per year based
             on  probability.   The  necessity  for that—alternative 2 for land-
             fill 22 is not the  driving  force  because  the big concern of the
             risk assessment  is  what we call  direct terminal contact, which
             is  like touching  your skin or  ingestion  things  in the soil.  So
             that a reason for that  (inaudible),  which solves the problem for
             the  assessment and  also  allows  (inaudible),  which is always a
             concern when  you  have landfills that  are  closed.   They-weren't
             closed to  state  standards because they preclude most state regu-
             lations.   So, what you  want  to  do is you've  got positive
             readings so you  don't want pockets  of  percipitation  laying
             there.   So,  that  minimum soil grade  is 4  percent,  and the  maxi-
             mum  (inaudible)  percent  and  is  generally  accepted in New York
             State.
                                                  »•
MEYERS:      Did you  mention  that you won't  be able to  grow  vegetation  on
             level  3, or  alternative 3?

VONBARGEN:   You would be  able to  put a grass.cover to  stabilize  the  soil.

MEYERS:      A grass cover, but you won't be able to plant trees  (inaudible)?

VONBARGEN:   Right.  Because you don't want  some—you  don't  want  the  root
             systems of the plant to go down and affect the  geotextile
             membranes that created that lawyer barrier from that infiltra-
             tion.   We should kind of just point out that these two—and Tom
             did mention—that these two particular landfills were  operational

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 VONBARGEN:
MEYERS:
VONBARGEN;
LIAS:
 and closed at a period of time at which there really wasn't much
 guidance in terms  of how to close these landfil-ls, and that has
 changed significantly in this day and age today.  We're open to
 your questions.

 (inaudible)

 I  had another question regarding—you mentioned the ground
 water.   There are  other things that you're going to be doing
 with the ground  water?  Can you explain how you're going to be
 handling that?  That's another program or how is that?

 Well,  we have conducted an  investigation at that landfill  23 and
 it  has  included  addressing  the ground water as a medium.   And we
 have found  at that  location that there is ground water con-
 tamination  in some  low levels that we at this time are trying to
 address  the source  and whether it is directly from the landfill
 or  maybe perhaps from an  outside source.  We're trying to assess
 that situation and  determine what might be directly contributed
 from the landfill  itself, and what comes from some other  source
 nearby.   The  ground  water at that particular site moves in a
 direction  towards the  runway,  in the south to southeasterly
 direction.  The  process will  be now to look  at the issues  of
what is  there  in the  ground water,  and to evaluate what perhaps
may  be  driving—taking  an action,  whettier it will  be some  state
or EPA  regulation,  something that's driven by risk,  and then
developing  the same  process,  this  selection  of remediesi  and
evaluating  them  and  determining what would be an appropriate
action at that site.   So, that will  be foTlowing in  the very
near  future.

I'-d  like  to thank you  all for  coming.   And again,  if you  haven't
signed in,  by doing  so, you'll  be  added  to the mailing  list.   I
appreciate you all  coming out.   Thank  you  very much.

(The meeting was terminated.)
                                     10

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APPENDIX D - RESPONSIVENESS SUMMARY

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                    RESPONSIVENESS SUMMARY
The purpose of this Responsiveness Summary is to address comments received during
the 4 August 1992 through 3 September 1992 public comment period for LF-023
source control  However, no comments from the public were received.


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