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
-------
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.
-------
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
-------
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.
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
ADIRONDACK
MOUNTAINS
SOURCE: NORTH MIEKCAN RQAOA7US. R U. QOU9U CO. 1967
92060100
FIGURE 1
VICINITY LOCATION
PLATTSBURGH API
ABB Environmental Services, Ine.
1-3
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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.
59213 12-1 6091-71
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
APPENDIX D - RESPONSIVENESS SUMMARY
-------
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.
------- |