United States Office of
Environmental Protection Emergency and
Agency Remedial Response
EPA/ROD/R02-92/190
September 1992
v°/EPA Superfund
Record of Decision:
Pittsburgh Air Force Base
(Operable Unit 3), NY
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NOTICE
The appendices listed in the index that are not found in this document have been removed at the request of
the issuing agency. They contain material which supplement but adds no further applicable information to
the content of the document XVII supplemental material is, however, contained in the administrative record
for this site.
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50272-101
REPORT DOCUMENTATION
PAGE
1. REPORT NO.
EPA/ROD/R02-92/190
3. Recipient'^ Accession No.
4. Title and Subtitle
SUPERFUND RECORD OF DECISION
Plattsburgh Air Force Base (Operable Unit 3), NY
Second Remedial Action - Subsequent to follow
S. Report Date
09/30/92
7. Author(s)
S. Performing Organization RepC No.
9. Performing Organization Name and Address
10. Project/Taak/Work Unit No.
11. Contract(C) or Grant(G) No.
(C)
(G)
12. Sponsoring 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
IS. Supplementary Note*
PB93-963816
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. Although the site overlies two aquifers, ground water is not used for
drinking water. 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 13-acre LF-022 landfill, is located on the western side of the Base,
1,350 feet north of a small mobile home development. From 1959 to 1966, the landfill
received domestic wastes from Plattsburgh AFB for disposal. Daily operations consisted
of digging 25-foot-deep trenches, spreading and burning the trash in the trenches, and
covering it with sandy soil. Appropriate methods for hazardous waste disposal were
available at the Base during the operating period of the landfill; therefore, it is
unlikely that LF-022 received any hazardous waste. Air Force site investigations
revealed surface and subsurface soil contamination as well as limited ground water
contamination. This ROD addresses the contaminated soil at the site, as OU3,
(See Attached Page)
17. Document Analysis a. Descriptors
Record of Decision - Plattsburgh Air Force Base (Operable Unit 3), NY
Second Remedial Action - Subsequent to follow
Contaminated Media: soil, debris
Key Contaminants: VOCs, other organics (pesticides), metals (chromium, lead)
b. Identifiero/Open-Ended Terms
c. COSATI Reid/Group
IS. Availability Statement
19. Security Class (This Report)
None
20. Security Class (This Page)
None
21. No. of Pages
76
22. Price
(See ANSI-Z39.18)
See Instructions on Reverse
OPTIONAL FORM 272 (4-77)
(Formerly NTIS-35)
Department of Commerce
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EPA/ROD/R02-92/190
Plattsburgh Air Force Base (Operable Unit 3), NY
Second Remedial Action - Subsequent co follow
Abstract (Continued)
to minimize potential current and future ecological risks associated with exposure to
pesticides in surface soil. Future RODs are planned to address other OUs at the Base.
The primary contaminants of concern affecting the soil and debris are VOCs; other
organics, including pesticides; and metals, including chromium and lead.
The selected remedial action for this site includes clearing and grubbing the landfill
site; diverting surface water runoff to minimize erosion of the cover and minimize
maintenance requirements; covering the landfill with a 12-inch soil cover; revegetating
the area to minimize erosion and enhance evapotranspiration; developing a post-closure
plan to monitor, maintain, and inspect the site; monitoring ground water; and
implementing institutional controls including deed restrictions. The estimated present
worth cost for this remedial action is $2,114,000, which includes a present worth OSM
cost of $866,000 for 30 years.
PERFORMANCE STANDARDS OR GOALS: Chernical-specific soil and ground water clean-up levels
were not developed because none of the contaminants of concern identified in the baseline
risk assessment were found to pose an unacceptable risk to either human health or the
environment.
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ROD FACT SHEET
SITE
Name:
Location/State:
EPA Region:
MRS Score (date):
NPL Rank:
Pittsburgh Air Force Base, Landfill LF-022 (o^(J•
Clinton County, New York
USEPA Region II
30.34, 11/21/89
N/A
ROD
Date Signed:
Remedy/ies:
Capital Cost:
O & M/Year:
Present Worth:
PAFB,
Site grading and vegetation establishment for closure of
Landfill LF-022
$ 1.2 million (present worth)
$ 92,000 average/yr for 30 yrs (present worth)
$ 2.1 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):
Medium (soil, g.w., &c):
Origin:
Est Quantity cu.yd.:
Volatile organic compounds, PHCs, pesticides, and metals
Soil and groundwater
Municipal type landfill
13.0 acres
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INSTALLATION RESTORATION PROGRAM
LF-022 RECORD OF DECISION
PLATTSBURGH AIR FORCE BASE
PLATTSBURGH, NEW YORK
FINAL
Prepared by:
ABB Environmental Services, Inc.
261 Commercial Street
Portland, Maine 04112
Project No. 6091-70
SEPTEMBER 1992
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LF-022 RECORD OF DECISION
PLATTSBURGH AFB
TABLE OF CONTENTS
Section Title Page No.
DECLARATION FOR THE RECORD OF DECISION vi
1.0 SITE NAME, LOCATION, AND DESCRIPTION 1-1
2.0 SITE HISTORY 2-1
2.1 LAND USE AND RESPONSE HISTORY 2-1
2.2 FEDERAL FACILITIES 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 5-4
6.0 SUMMARY OF SITE RISKS 6-1
6.1 APPROACH OF THE BASELINE RISK ASSESSMENT 6-1
6.2 LF-022 DATA EVALUATION 6-2
6.3 LF-022 HUMAN HEALTH RISK ASSESSMENT 6-3
6.4 LF-022 HABITAT-BASED ENVIRONMENTAL RISK
ASSESSMENT 6-8
6.5 CONCLUSIONS OF THE BASELINE RISK ASSESSMENT 6-11
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 7-1
8.0 DESCRIPTION OF ALTERNATIVES 8-1
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LF-022 RECORD OF DECISION
PLATTSBURGH AFB
TABLE OF CONTENTS
(continued)
Section Title Page No.
8.1 ALTERNATIVE 1: No ACTION 8-1
8.2 ALTERNATIVE 2: SITE GRADING AND VEGETATION
ESTABLISHMENT FOR CLOSURE 8-1
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 COMPARATIVE ANALYSIS OF ALTERNATIVES SUMMARY 9-3
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 Mobility, Toxicity, or Volume of
Contaminants through Treatment 9-4
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 9-5
9.4.9 Community Acceptance 9-5
10.0 THE SELECTED REMEDY 10-1
10.1 CLEAN-UP LEVELS 10-1
10.2 DESCRIPTION OF REMEDIAL COMPONENTS 10-1
11.0 STATUTORY DETERMINATIONS 11-1
11.1 THE SELECTED REMEDY is PROTECTIVE OF HUMAN HEALTH
AND THE ENVIRONMENT 11-1
11
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LF-022 RECORD OF DECISION
PLATTSBURGH AFB
TABLE OF CONTENTS
(continued)
Section Title Page No.
11.2 THE SELECTED REMEDY ATTAINS ARARs ll-l
113 THE SELECTED REMEDIAL ACTION is COST-EFFECTIVE 11-3
11.4 THE SELECTED REMEDY UTILIZES PERMANENT SOLUTIONS
AND ALTERNATIVE TREATMENT OR RESOURCE RECOVERY
TECHNOLOGIES TO THE MAXIMUM EXTENT PRACTICABLE .. 11-4
11.5 THE SELECTED REMEDY DOES NOT SATISFY THE
PREFERENCE FOR TREATMENT WHICH PERMANENTLY AND
SIGNIFICANTLY REDUCES THE TOXICITY, MOBILITY OR
VOLUME OF THE HAZARDOUS SUBSTANCES AS A PRINCIPAL
ELEMENT 11-5
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
APPENDIX B - STATE LETTER OF CONCURRENCE
APPENDIX C - PUBLIC MEETING TRANSCRIPT
APPENDIX D - RESPONSIVENESS SUMMARY
111
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LF-022 RECORD OF DECISION
PLATTSBURGH AFB
LIST OF FIGURES
Figure Title Page No.
1 Vicinity Location Map 1-2
2 LF-022 Location Map 1-3
3 Site Features 1-4
4 LF-022 Migration Pathways and Potential Receptors 5-3
IV
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LF-022 RECORD OF DECISION
PLATTSBURGH AFB
LIST OF TABLES
Table Title Page No.
1 LF-022 Site Contaminants by Media 5-2
2 Summary of LF-022 Site Risk Estimates - Security Police 6-6
3 Summary of LF-022 Site Risk Estimates - Future Resident 6-7
4 Summary of Ecological Risk Assessment for LF-022 6-10
5 Summary of Alternatives Screening 7-3
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DECLARATION FOR THE RECORD OF DECISION
SITE NAME AND LOCATION
Plattsburgh Air Force Base (AFB), Landfill LF-022
Plattsburgh, New York
STATEMENT OF BASIS AND PURPOSE
This Record of Decision (ROD) presents a selected remedial action that will provide
containment of landfill wastes at LF-022 on Plattsburgh AFB in Plattsburgh, New
York. This document was developed in accordance with the Comprehensive
Environmental Response, Compensation, and Liability Act of 1980 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
(NCP). Through this document, Plattsburgh AFB plans to remedy the threat to
human health, welfare, or the environment posed by surface soil at LF-022. This
decision is based on the Administrative Record for the site, a copy of which is
located at Plattsburgh AFB.
The New York State Department of Environmental Conservation (NYSDEC) on
behalf of the State of New York and the U.S. Environmental Protection Agency
(USEPA) concur with the selected remedy. The state's concurrence with this
selected remedy is presented in Appendix B.
ASSESSMENT OF THE SITE
Actual or threatened releases of hazardous substances from LF-022, if not addressed
by implementing the response action selected in this ROD, may present an imminent
and substantial endangerment to human health, welfare, or the environment.
DESCRIPTION OF THE SELECTED REMEDY
This action addresses the principal threat posed by LF-022 by preventing
endangennent to human health, welfare, or the environment through containment
of the landfill to minimize exposure to pesticides present in the surface soils.
The selected source control remedy includes establishing institutional controls,
constructing a soil and vegetative cover system over the landfill to minimize exposure
to pesticides in the surface soils. The remedy also includes development of a post-
closure plan specifying inspection, maintenance, and monitoring programs to be
conducted over 30 years. 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 will be informed that
VI
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STATUTORY DETERMINATIONS
The selected remedy is protective of human health and the environment, complies with
federal and state applicable or relevant and appropriate requirements 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 maxinmm extent
practicable for this site. 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 considered
during the identification of remedial technologies and the development and initial screening
of alternatives, but were not considered feasible for the LF-022 site. The size of the landfill
and the fact that there are no on-site "hot spots" that represent the major sources of
contamination preclude a remedy in which contaminants could be excavated and treated
effectively.
Because this remedy could result in hazardous substances remaining on site, a review will
be conducted by Plattsburgh AFB, USEPA, and NYSDEC within five years after closure to
ensure that the source control remedy continues to provide adequate protection of human
health and the environment. This review will be conducted at least every five years
thereafter as long as hazardous substances remain on site at levels that could pose a risk to
human health and the environment.
SIDAMON-EI
Regional Administrator, USEPAf
/JAMES E. ANDREWS
(/ Colonel, USAF
Commander, 380 ARW/CC
Date
vu
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SECTION 1
1.0 SITE NAME, LOCATION, AND DESCRIPTION
Plattsburgh Air Force Base (AFB) is located in Clinton County in northeastern New
York State, bordered on the north by the City of Plattsburgh, on the south and west
by the Town of Plattsburgh, and on the east by Lake Champlain (Figure 1). The
base is approximately 26 miles south of the Canadian border and 167 miles north of
Albany. Landfill LF-022 is located west of the runway approximately 500 feet from
the western Plattsburgh AFB boundary (Figure 2).
Access to the landfill from the east and north is restricted because the site is
bordered on two sides by controlled access areas, the active runway to the east and
the small arms range to the northwest (Figure 3). Access from the south 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 using a road leading from
the western Perimeter Road, which is within the controlled access flightline area.
Plattsburgh AFB controls access to the Perimeter Road because it is next to the
runway. Only military personnel who need to work within the area are allowed
access to Perimeter Road. Occasionally, civilian law enforcement agencies (e.g., state
police) are permitted to use the nearby small arms range on the northwestern edge
of the landfill Other military and civilian personnel are not likely to come in contact
with the landfill.
LF-022 is approximately 1,350 feet north of a small mobile home development on
NY Route 22, near the interchange with Interstate 87. The nearest on-base housing
is more than 6,000 feet east of the site. A light industrial area is located
approximately 700 feet west of the site along Route 22. Interstate 87 is
approximately 200 feet further west of NY Route 22.
Site topography slopes gradually toward the east and southeast with a surface
gradient between 0 and 3 percent. The site's northern boundary has a steep
descending slope into a natural depression area. There are no surface water features
within the LF-022 site. However, groundwater may collect in a natural depression
approximately 600 feet north of the site during high water conditions (i.e., spring
runoff).
59227 6091-71
1-1
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ADIRONDACK
MOUNTAINS
vMt«v(C" •w
> . vrr#
A sWl-V^
v-.^"^*
•- v. * % w\
% \ s *•."••*
SOURCE: NOIHW AUERCAN OOADATIAS. H. U. QOUS4A CO.. 1M2
92060100
FIGURE 1
VICINITY LOCATION MAP
_ ELATTSBURGH AFB
ABB Environmental Services, Inc.
1-2
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.k-.-^.-;,T~
CITY OF PLATTSBURGH
=•
FT
\ **u • r*
* "
*?sp
•;tf';-:;Ux!>;;
^.u« C>A»OV -;.\.» \ •.;
r^'^ti A!\M i ..
N^UA
r^'-1"18"'
I 4]Cafiwn
LEGEND
SITE LOCATION
___ BASE BOUNDARY
SCALE tN FEET
0 2000 4000
6091-10
1-3
FIGURE 2
LF-022 LOCATION MAP
PLATTSBURGH AFB
ABB Environmental S*rvica«, Inc.
POOR QUALITY
• CRiGiNAL
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LANDFILL 4 I )
BOUNDARY J W .
OLD SMALL
*~ ARMS RANG!-
t
LEGEND
FOHEST on SHRUBBY VEGETATION
APPTOXIMATE LOCATION OF FOHMER
MUNITIONS LANOFILL.(D-7)
SCALE !N FEET
200
400
6091-70
FIGURE 3
SITE FEATURES
LF-022 RECORD OF DECISION
PLATTSBURGH AFB
. '. ABB Environmental Services, Inc. —
1-4
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SECTION 1
The plant community at LF-022 consists of staghorn sumac, mullein, grasses,
cottonwood, and pines. The plant community of the depression north of LF-022 is
dominated by cattail, red-osier dogwood, pussy willow, black willow, and sensitive
fern. Sumac and trembling aspen occur in upland areas surrounding this area. No
wetlands regulated by the New York State Department of Environmental
Conservation (NYSDEC) are present on or adjacent to LF-022. Several species of
birds, mammals, reptiles, and amphibians could 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, 10 feet of clay, and 30 feet of
till overlying carbonate bedrock Soil within the landfill is poorly graded, medium-to-
fine sand with trace to some silt, and appears to be native soil. Two aquifers at the
site include an unconfined aquifer in the sand unit on which LF-022 was constructed
and a confined aquifer in the bedrock The water table in the unconfined aquifer is
approximately 30 feet below ground surface (bgs) (below the depth of waste) and the
upper surface of the confined aquifer in the bedrock is approximately 125 feet bgs.
Groundwater in the unconfined aquifer flows east toward Lake Champlain and
dominates local flow patterns at the site. LF-022 is located on a topographic high
on the western side of the base, which also affects local groundwater flow.
Groundwater in the confined aquifer also flows east toward Lake Champlain.
A more complete description of LF-022 can be found in the LF-022/LF-023
Remedial Investigation (RI) Report on pages 1-5 through 1-8, and 3-1 through 3-15
(ABB-ES, 1992a).
59227 6091-71
1-5
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SECTION 2
2.0 SITE HISTORY
In accordance with Section 117(a) of the Comprehensive Environmental Response,
Compensation and Liability Act (CERCLA), Plattsburgh AFB is publishing this
Record of Decision (ROD) to address public review and comment on the selected
alternative. Plattsburgh AFB, in consultation with the U.S. Environmental Protection
Agency (USEPA) and NYSDEC, considered public comments as part of the final
decision-making process for selecting the remedy for LF-022. This ROD summarizes
the results and conclusions of the RI, Feasibility Study (FS), and Proposed Plan.
2.1 LAND USE AND RESPONSE HISTORY
LF-022, approximately 500 feet wide and 1,200 feet long, is on the western side of
Plattsburgh AFB, approximately 500 feet from the base boundary (see Figure 3).
This landfill received domestic wastes from Plattsburgh AFB for disposal from 1959
to 1966. Daily operations consisted of digging 25-foot-deep trenches, spreading and
burning the trash in the trenches, and covering it with sandy soil. While the landfill
was active, several different disposal methods were available for hazardous waste.
Explosive ordnance was deactivated or detonated by the explosive ordnance disposal
personnel on base; residue was then disposed of in the landfill as nonhazardous
waste. Other hazardous wastes were handled by civil engineering service contractors,
or taken to the Defense Reutilization and Marketing Office and disposed of or
recycled off site by hazardous waste contractors. liquids such as out-of-spedfication
fuel, waste solvents, and waste oil, were also taken to fire-training area FT-002 and
burned during fire-training activities. Because appropriate methods of hazardous
waste disposal were available during operation of the landfill, it is unlikely that
hazardous wastes were disposed of in LF-022. The maximum volume of fill is
estimated at 524,000 cubic yards. Since landfilling operations ceased, vegetative
growth (i.e., trees and brush) covers the site, a small arms range has been constructed
on the northwestern side of the site, and an access road to the small arms range has
been built across the landfill.
Several site investigations have been conducted at LF-022 as part of the Installation
Restoration Program (IRP) at Plattsburgh AFB. A Preliminary Assessment
evaluated whether the site was potentially contaminated and required further
investigation. The Preliminary Assessment prompted a Site Inspection (SI) to
confirm the presence of contamination. SI activities included a magnetometer survey,
59227 6091-71
2-1
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SECTION 2
test pits, and groundwater sampling. Because SI results indicated the presence of
contaminants, an RI was conducted to characterize the nature and extent of
contamination at LF-022. RI activities included groundwater and soil/waste
sampling. A more detailed description of the site history can be found in the RI
Report on pages 1-8 through 1-10, and 5-29 through 5-32 (ABB-ES, 1992a).
22 FEDERAL FACILITIES AGREEMENT HISTORY
Activities at LF-022 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 handles 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.
The U.S. Air Force 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) (formerly E.G. Jordan Co.), an MMES
subcontractor. 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. On November 21, 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, USEPA, and NYSDEC.
59227 6091-71
2-2
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SECTION 3
3.0 COMMUNITY PARTICIPATION
Plattsburgh AFB has kept the community and other interested parties apprised of
activities at LF-022 through informational meetings, fact sheets, press releases and
public meetings. On August 1, 1989, Plattsburgh AFB held its first Technical Review
Committee (TRC) 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 the RI/FS activities. In December 1990, Plattsburgh AFB released a community
relations plan outlining a program to address community concerns and keep citizens
informed about and involved in activities during remedial activities.
On August 4, 1992, Plattsburgh AFB made the LF-022 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 Plattsburgh
Public Library.
On August 4,1992, Plattsburgh AFB held a public informational meeting to discuss
the results of the RI and the clean-up alternatives in the FS, present the Proposed
Plan, and answer questions from the public. Immediately following the information
meeting, Plattsburgh AFB held a public hearing to discuss the Proposed Plan and to
solicit and accept any 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.
59727 6091-71
3-1
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SECTION 4
4.0 SCOPE AND ROLE OF OPERABLE UNIT OR RESPONSE ACTION
Due to the nature of its primary mission, Plattsburgh AFB is engaged in a wide
variety of operations. A number of operations require the use, handling, storage, or
disposal of hazardous materials. The IRP addresses past instances when these
materials came into contact with the environment through accidental spills, leaks in
supply piping, landfill operations, burning of waste liquids during fire training
exercises, and the cumulative effect of operations conducted at the base's flightline
and industrial area. These are the activities and circumstances through which
contaminants of concern came into contact with site-related soil, sediment, surface
water and/or groundwater. The suspected sources of contamination at Plattsburgh
AFB sites are solvents, fuels, pesticides, and polychlorinated biphenyls (PCBs).
Currently, there are thirty-nine IRP sites at Plattsburgh AFB.
The selected remedy for the LF-022 source control operable unit will meet the
remedial response objective identified for this site: Minimize potential current and
future ecological risks associated with exposure to pesticides in surface soil. The
remedy will achieve the response objective by: (1) clearing and grubbing the site;
(2) managing surface water runoff to minimize erosion of the final cover and
minimize maintenance requirements; (3) establishing a cover thickness;
(4) establishing vegetation to minimize erosion of the final cover and enhance
evapotranspiration; (5) developing a post-closure plan to monitor, maintain, and
inspect the site; (6) monitoring groundwater; and (7) conducting five-year site
reviews.
Groundwater contaminants were not found in levels that warrant remedial action.
However, the groundwater will be monitored as part of the landfill closure plan.
59227 6091-71
4-1
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SECTION 5
5.0 SUMMARY OF SITE CHARACTERISTICS
Subsection 1.4 of the landfill LF-022 FS report contains an overview of the RI.
Concentrations and frequencies of detection of site contaminants in the various
media at LF-022 are presented in Table 1. Figure 4 diagrams potential migration
pathways and receptors. RI activities included a topographic survey, geophysical
surveys, and groundwater and soil sampling. The significant findings of the RI are
summarized in the following subsections. Subsection 5.1 describes soil and waste
characteristics; Subsection 52 discusses results of groundwater sampling. A complete
discussion of site characteristics can be found in the RI report on pages 3-15 through
3-54 (ABB-ES, 1992a).
5.1 WASTE/SOIL
Geophysical survey techniques were used to investigate the depth and areal extent
of the landfill. Seismic refraction and terrain conductivity surveys did not provide
useful information; a magnetometer survey conducted during the SI, site walkovers,
and a review of aerial photographs provided the information necessary to delineate
the areal extent of the landfill. The landfill area is estimated to be 566,000 square
feet Information from the Preliminary Assessment indicated that wastes could have
been buried as deep as 25 feet bgs in some areas. A profile of the depth of the
landfill, however, could not be discerned by the seismic refraction survey. The
volume of material at the landfill is also difficult to estimate because of the
nonuniform manner in which wastes were disposed. Therefore, based on a maximum
depth of 25 feet and the areal extent of the landfill, the maximum volume of fill
material in LF-022 is estimated to be 524,000 cubic yards.
A passive soil gas survey was conducted for LF-022 to identify areas of potential
contamination and help identify the locations of future explorations. Areas of high
flux values for some compounds were detected primarily along the access road.
However, results from subsequent surface soil and groundwater 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, and inorganics. Discrete
surface soil samples were collected from four locations and analyzed for volatile
59227 6091-71
5-1
-------
TABLE 1
LF-022 SITE CONTAMINANTS BY MEDIA
LF-022 RECORD OF DECISION
PLATTSBURQH AFB
DETECTIOM
GROUNDWATER u/q/Ll
Iron
Manganese
SURFACE SOILS' u/q/kq)
ODD
DDE
DDT
SUBSURFACE SOILS (mq/kql
Lead
WASTE (mq/ko. unless otherwise noted)
Carbon tetrachloride
C/nlOfUiOf Ml
Bls(2-Bhv1he>cyflPhthalate (w/kq)
PHCs
Aluminum
Cadmium
Chromium
Coooer
Iron
Lead
Manqanesa
Silver
Sodium
Zinc
CONCENTRATION RAMQE'
MINIMUM MAXIMUM
<1003
<15
<16
<16
<16
4.1
<5
<5
<300
<1
<40
<1
<10
<5
140
<1
<3
<2
<1000
18
8.760
877
16.000
855
3,505
116
18,000
19.000
1,700
2.100
128,000
151
412
5,150
130,500
974
7.365
18
23.300
33.300
FREQUENCY OF
DETECTION2
3/12 ' -
6/12
2/4
1/4
2/4
2/3
1/7
1/7
1/2
5/6
3/7
3/7
1/7
3/7
2/7
4/7
1/7
3/7
1/7
5/7
Notes:
' Concentrations of duplicate samples were averaged.
2 Number of samples in which the compound was detected above background concentrations or appropriate standards
divided by the total number of samples analyzed for that parameter; Duplicate samples represent one sample.
3 < 100 denotes that the minimum sample concentration was below the identified Contract Required Quantitation Limit (e.g.,
ODD
DDE
DDT
PHC
Concentrations detected in composite samples.
Dlchlorodiphenyldlchloroethane
Dichlorodiphenyldichloroethene
Dichlorodiphenyltrichloroethane
Petroleum Hydrocarbons, as detected by USEPA method 418.1
59227.T/3
5-2
-------
Primary Primary Secondary Secondary Pathway*
Source* Release Source* Release
Mechanism* Mechanism*
.
d ''.'". t :."..-. 1 | •;:..*.:. :.;.,•«;• .-? :..-;.:. |
I lnlillratlon/ 1 :; Sub»wtoce : |_ InUlralloo/ 1^ ;v'ir.;;SiLi:tiii. 1 ..
Waste »-*• .i^calaVon I** ^ Sofav I*' PercoteHon •*" 5^^^*^!% T
| : | •<.**, , ifr •- | • I .is;: «s-J*::-^ |
^ Contact vHlh 1^ 6u( M 1 *
|.:-::;:fc;^,;J:::-::: |
to. ;i' i'.^L^.v!:-;. I ,
^ :• • •.:.J:..W'M •::•:•:••.• I •
.;; t:i&-;;M v>;;:-:-:-:;;-. 1
Af^^^-^^^^t
LF-022 MIGRATIOI
: : ;. ; : Potential Receptoi*
:: ';'':::;; ^"' ):-?.%yM:-;*-.;-- '
: .;: Human Biota |
JBH^^^^IH jsmwwwlw vmmMwLt Bwwwro^m mB^^m-I
1
. Inhalation •
Obecl Contact •
\. •'.'• •'''. •'' I:'V :-i • ^ I'.l'Sf ^
FIGURE 4
^ PATHWAYS AND POTENTIAL RECEPTORS
LF-022 RECORD OF DECISION
PLATTSBURGH AFB
-------
SECTION 5
organic compounds (VOCs). The VOC sample locations were selected based on soil
gas survey results. No VOCs or SVOCs were detected above background detection
limits in LF-022 surface soil samples. The man-made organochlorine pesticide
dichlorodiphenyltrichloroethane (DDT) and associated analogs dichlorodiphenyl-
dichloroethane (DDD) and dichlorodiphenyldichloroethene (DDE) were identified
as site surface soil contaminants. No inorganic analytes were detected in surface
soils at concentrations above background.
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 most of the wastes disposed of at this site were household trash that was burned
prior to burial under at least 1 foot of sandy fill. No organic contaminants were
identified in subsurface soil. Lead was detected at concentrations above background
in soil collected from just below the waste; lead is considered a site contaminant.
52 GROUNDWATER
Groundwater monitoring wells were installed at LF-022 to collect groundwater
samples and to measure groundwater elevations. Two inorganic analytes, iron and
manganese, were detected in groundwater at concentrations exceeding New York
State groundwater quality standards. No organic compounds were identified as site
contaminants.
59227 6091-71
5-4
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SECTION 6
6.0 SUMMARY OF SITE RISKS
A baseline risk assessment was conducted for LF-022 to evaluate whether site
contaminants pose a risk to human and/or ecological receptors. This section
summarizes the human health and ecological risk assessments for the site. Although
the baseline risk assessment is presented in the RI report, it is summarized here to
provide the rationale for selecting contaminants of concern and developing remedial
action strategies. In addition, any assumptions used to describe the distribution
and/or fate of contaminants in the environment have been identified to the extent
possible.
The risk assessment was conducted in accordance with USEPA and NYSDEC
guidance. The human health risk assessment was conducted in accordance with
USEPA's Risk Assessment Guidance for Superfund, Volume 1: Human Health
Evaluation Manual (Part A) (USEPA, 1989b). Guidance followed in conducting the
ecological risk assessment included the Risk Assessment Guidance for Superfund:
Environmental Evaluation Manual (USEPA, 1989a) and the Habitat-Based Assessment
Guidance Document for Conducting Environmental Risk Assessments at Hazardous
Waste Sites (NYSDEC, 1989).
6.1 APPROACH OF THE BASELINE RISK ASSESSMENT
The baseline risk assessment for LF-022 consisted of three components: (1) data
evaluation, (2) human health risk assessment, and (3) habitat-based environmental
risk assessment (ERA). The purpose of the Data Evaluation was to identify the
environmental data suitable for use in the risk assessment based on results of the RI.
The purpose of the baseline human health risk assessment was to evaluate whether
contamination at the landfill poses risks to human health in the absence of any
remedial action. The baseline human health risk assessment was composed of the
following components:
• exposure assessment
• toxicity assessment
• risk characterization
Collectively, these components describe (1) human populations that might come in
contact with contaminants at the site and the pathways by which they could be
exposed; (2) site contaminants that pose a potential risk to public health and the
59227 6091-71
6-1
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SECTION 6
potential toxic effects and toxic potency of contaminants; and (3) potential risks
associated with contaminant exposure.
The purpose of the habitat-based ERA for LF-022 was to define potential ecological
effects resulting from exposure to chemicals in environmental media at the site. The
ERA contained the following elements:
• ecological exposure assessment
• hazard identification
• ecological risk characterization
The following subsections summarize the approach used and principal assumptions
and conclusions of the LF-022 baseline risk assessment The data evaluation, human
health, and ecological components of the baseline risk assessment are discussed
separately.
62 LF-022 DATA EVALUATION
Contaminants associated with LF-022 were detected in groundwater, surface soil, and
subsurface soil/waste material during the RI. No surface water is associated with
this site. Site contaminants were initially identified in the RI based on comparisons
with New York State or federal standards or background levels. These contaminants
were further evaluated for their potential effects on human health and the
environment Based on this analysis, contaminants of potential concern were chosen
for the baseline risk assessment.
The only organic contaminants detected in groundwater were bis(2-
ethylhexyl)phthalate (BEHP) and 2-butanone, both of which were attributed to
laboratory contamination. The only elements considered to be site-related in
groundwater were iron and manganese. Neither of these inorganic compounds are
highly toxic to humans. However, these two elements were detected above New
York State groundwater quality standards (i.e., 300 micrograms per liter [/ig/L] for
each element or 500 jig/L for both elements). Therefore, iron and manganese
represent contaminants of potential concern.
Nine inorganic contaminants were detected in subsurface soil/waste material at
concentrations above the expected range for soils in the Plattsburgh AFB area:
aluminum, cadmium, copper, iron, lead, manganese, silver,, sodium, and zinc. Of
these, only cadmium, copper, lead, manganese and silver are .-of toxicological concern
59227 6091-71
6-2
-------
SECTION 6
to humans or ecological receptors. Aluminum, iron, sodium, and zinc were not
detected at concentrations that are of lexicological concern; therefore, they do not
warrant further consideration. The only organic compound detected in subsurface
soils/waste was BEHP, a probable human carcinogen. This compound was detected
once in association with a sample of white ash believed to be incinerator ash. Its
presence is likely the result of leaching from waste materials and it is considered to
be a site-related contaminant Therefore, cadmium, copper, lead, manganese, silver,
zinc, and BEHP represent contaminants of potential concern in LF-022 subsurface
soils/waste.
The only organic contaminants detected in surface soils at LF-022 above analytical
quantitation limits were DDD, DDE, and DDT. VOCs and SVOCs were not
detected. The concentrations of inorganic compounds were within typical
background ranges, and therefore were not considered site-related. Because DDD,
DDE, and DDT were the only contaminants detected in surface soils, these three
compounds represent the only contaminants of potential concern for surface soils at
the LF-022 site.
6.3 LF-022 HUMAN HEALTH RISK ASSESSMENT
The LF-022 site was evaluated to identify the populations that could come in contact
with site-related contaminants and the pathways through which exposure could occur.
There are three potential sources of exposure associated with the LF-022 site:
groundwater, subsurface soil/waste materials, and surface soil. However, based on
current site uses, surface soil is the only media to which individuals could be exposed.
Groundwater is not used as a drinking water source downgradient of the site;
however, USEPA guidance suggests that reasonable future-use exposure scenarios
should be incorporated into the human health risk assessment. Therefore, future
exposure to groundwater contaminants was evaluated in the risk assessment.
Exposure to subsurface soil/waste materials was not evaluated because
construction/excavation at this site is not currently planned or proposed.
As a result of the exposure assessment, the following four exposure scenarios were
identified as being possible at LF-022 under current and future site conditions:
59227 6091-71
6-3
-------
SECTION 6
Current Site Conditions
1. Incidental Ingestion of and Direct Contact with Surface Soil by a Child
Trespasser.
Future Site Conditions
1. Ingestion of and Direct Contact with Groundwater by a Future
Resident.
2. Incidental Ingestion of and Direct Contact with Surface Soil by a
Future Resident.
3. Inhalation of Vapors and Fugitive Dusts by a Future Resident.
Potential intake of contaminants as a result of these exposure pathways was
calculated using a series of standard equations identified in USEPA risk assessment
guidance. Estimates of the intake of surface soil contaminants were calculated using
two surface soil data sets: (1) the sitewide average soil concentrations from four
composite samples collected from the four quadrants of the site; and (2) the
concentrations from the most contaminated quadrant of the landfill. The former
provides an estimate of intake if exposure were to occur across the entire landfill,
while the latter provides an estimate of intake if exposure were to occur in one
quadrant.
A toxicity assessment was conducted to identify the relevant oral and inhalation
toxicity values for carcinogenic and noncarcinogenic effects of the LF-022
contaminants of potential concern. These values were identified from either the
USEPA's Integrated Risk Information System database or USEPA's Health Effects
Assessment Summary Tables. When values could not be identified from either of
these two sources, surrogate values were identified based on similarities in toxicity
and/or chemical structure of the compounds.
Risk characterization involves the qualitative or quantitative evaluation of potential
health risks associated with exposure to chemicals in the environment. For LF-022,
quantitative estimates of both carcinogenic and noncarcinogenic risks were calculated
for each contaminant of potential concern identified in the toxicity assessment and
each complete exposure scenario identified in the exposure assessment.
59227 6091-71
6-4
-------
SECTION 6
To evaluate the significance of risk estimates, a comparison was made with
established target risk levels. USEPA has established target risk levels for the
evaluation of both carcinogenic and noncarcinogenic risks at hazardous waste sites.
USEPA's guidelines state that the total incremental carcinogenic risk for an
individual resulting from exposure at a hazardous waste site should be below or
within a range of 10* to 104 (USEPA, 1989b). Cancer risks below 10^ are
considered acceptable; risks above 10"*-are considered unacceptable. The target risk
level for noncarcinogenic effects is a Hazard Index (HI) of below or equal to 1.0
(USEPA, 1989b).
The total site risk estimates calculated for the one exposure scenario under current
site conditions are below the USEPA target risk levels (Table 2). The estimated
total current site cancer risks for the child trespassing on the site, using the two sets
of surface soil data, are below the USEPA target cancer risk range and therefore are
not considered significant. Total site cancer risks range between 2x10"* and 7xlO~8.
The two sets of total site His of 0.001 and 0.004 are also below the USEPA target
ffl of 1.0.
Under future site conditions, a nearby resident was selected as the receptor at
greatest potential risk. This individual was assumed to be exposed to surface soil,
groundwater, and fugitive emissions while residing near the landfill, both as a child
and as an adult. The estimated total site cancer risks for this receptor, calculated by
combining all pathway-specific risks, were between 6x10"* and lxlO"s. Both estimates
are below or within the USEPA target risk range (Table 3).
The total site His for this hypothetical receptor were 1.0 and 2.0 for the child using
the sitewide average soil concentrations and the soil concentrations from the more
contaminated northwest quadrant, respectively, and 03 for the adult using either data
set. Only the latter HI for the child, which incorporates the surface soil pathway
using maximum concentrations, is above the USEPA target of 1.0. Most of the
elevated index for a child receptor is associated with ingestion of manganese in
groundwater.
59227 6091-71
6-5
-------
TABLE 2
SUMMARY OF IF-022 SITE RISK ESTIMATES - SECURITY POLICE
Lf-022 RECORD OF DECISION
PUATTSBUROH AFB
.... ..• ... EXPOSURE ROUTE, MEDIUM ANO : PATHWAY-SPECIRC CANCER TOTAL CANCER RISK OR
TYPE:OF EFFECT. EXPOSURE POINT: RISK OR HAZARD INDEX HAZARD INDEX
CARCINOGENIC EFFECTS
Site-wide Average Direct contact with surface soil 2E-08
Ingestion of surface soil 8E-09 2E-08
Northwest Quadrant Direct contact with surface soil 5E-08
Ingestion of surface soil 2E-08 7E-08
NONCARCINOGENIC EFFECTS
Site-wide Average Direct contact with surface soil 0.0009
Ingestion of surface soil 0.0004 0.001
Northwest Quadrant Direct contact with surface soil 0.003
Ingestion of surface soil 0.001 0.004
6-6
59227.T/2
-------
TABLES
SUMMARY OF LF-022 SITE RISK ESTIMATES - FUTURE RESIDENT
LF-022 RECORD or DECISION
PukTTSBUBOH AFB
• : ' . •••••"'• -;••::•::••••;-:••- •.;-: -;;•; EXPOSURE ROUTE, MEDIUM AND
>x":'"-TVpir:brB«er"' ••••'•••'•'•'•' >'-«---:- ••:•'•'•••'•'• EXPOSURE Power .-' ••••'
CARCINOGENIC jFFjCTS
Site-wide Average Direct contact with surface soil
Ingastion of surface soil
Northwest Quadrant Direct contact with surface soil
Ingastion of surface soil
Inhalation of vapors and dusts
NONCARCINPGENIC EFFECTS
Direct contact with groundwater
Ingestion of groundwater
She-wide Average Direct contact with surface soil
Ingestion of surface soil
Northwest Quadrant Direct contact with surface soil
Ingestion of surface soil
Inhalation of vapors and dusts
• PATHWAY-Soeanc CAWCCH
RISK: OK HAZARD INDEX
CHILD ADULT
1E-06 2E-06
8E-07 3E-07
3E-06 4E-06
2E-06 9E-07
1E-06 1E-06
Total: Site-Wide Average
Total: Northwest Quadrant
Total: Site-wide Average
Total: Southeast Quadrant
CHILD ADULT
0.0006 0.0003
1 0.2
0.09 0.03
0.07 0.008
0.3 0.1
0.2 0.02
0.09 0.02
Total: Site-wide Average
Total: Northwest Quadrant
TOTAL CANCER RISK OR
HAZARD INDEX
CHILD
2E-06
5E-06
1E-06
3E-06
6E-06
CHILD
1
0.2
0.5
0.09
1
2
AD_ULT
2E-06
5E-06
1E-06
3E-06
6E-06
6E-06
1E-05
ADULT
0.2
0.04
0.1
0.02
0.3
0.3
5922T.T/1
6-7
-------
SECTION 6
6.4 LF-022 HABITAT-BASED ENVIRONMENTAL RISK ASSESSMENT
The following paragraphs summarize the three components of the habitat-based
environmental risk assessment for LF-022.
An ecological exposure assessment was conducted to evaluate the potential for
exposure of ecological receptors to the site-related chemicals at LF-022. This
involved identification of actual or potential exposure routes to receptors and
evaluation of the magnitude of exposure. Exposure concentrations were developed
for each receptor via each pathway.
Terrestrial organisms may be exposed to chemicals in surface soils through several
exposure pathways. No exposure pathways exist for groundwater or subsurface soil
at the site because terrestrial organisms are not expected to come in contact with
subsurface (i.e., below an approximate 2-foot depth) media and no prey of these
species exist in subsurface areas. Additionally, because there are no aquatic habitats
at the site, there are no exposure pathways for aquatic organisms.
Exposure to constituents in surface soil may occur via direct contact with and
ingestion of surface soils, and ingestion of biota that have bioaccumulated chemicals
in their tissues. Because of the lack of species-specific data concerning uptake of
chemicals via dermal contact and the inherent variability in uptake rates among
species, the dermal contact exposure pathway was not evaluated. Five indicator
species were selected to represent exposures to terrestrial organisms via ingestion of
food and soil:
White-footed mouse (Peromyscus leucopus), small mammal, omnivore
Wood thrush (Hylodchla mustelina), small bird, omnivore
Garter snake (Thamnophis s. sirtalis), herptile, carnivore
Red fox (Vulpes), predatory mammal, omnivore
Red-tailed hawk (Buteo jamaicensis), predatory bird, carnivore
These species were selected because they are representative of exposures to the
range of mammals, birds, and herpetofauna (reptiles and amphibians) that may occur
at the site. They are relatively common species in the vicinity of Plattsburgh AFB
and were selected based on the types of habitat at the site and feeding preferences.
These species are used to represent small mammals, small birds, herpetofauna,
predatory mammals, and predatory birds.
59227 6091-71
6-8
-------
SECTION 6
In the Hazard Identification, the toxicity of each site-related chemical was described.
Information necessary to evaluate the potential effects to receptors consisted of
published laboratory-derived lexicological data and threshold toxicity values
developed using extrapolation techniques. Based on these data. Reference Toxicity
Values (RTVs) were developed for terrestrial organisms that represent a toxic
threshold concentration in soil or food.
Toxicity data for terrestrial receptors consist of acute and chronic ingestion studies.
From the toxicological data set, the lowest acute or chronic value for each type of
receptor (e.g., small mammals and small birds) was selected as the acute or chronic
RTV, respectively. However, because of their structural similarity, the same RTVs
were used for DDD, DDE, and DDT for a given indicator species.
The risks to terrestrial receptors potentially exposed to DDD, DDE, and DDT in
surface soil at LF-022 were identified. Risks to terrestrial biota were evaluated by
comparing the acute and chronic Potential Dietary Exposures (PDEs) for each
indicator species with the acute and chronic RTVs, respectively. By dividing the
PDE by the appropriate RTV, an HI was calculated. The His for individual
chemicals were then summed to yield a total HI for the receptor. A technique
developed for the ecological evaluation of pesticides (USEPA, 1986) was adopted to
evaluate the significance of the calculated HI risk estimates:
ffl < 0.1 No Adverse Effects
0.1 < HI < 10 Possible Adverse Effects
ffl > 10 Probable Adverse Effects
This ranking scheme reflects effects on individual organisms, and does not provide
an indication of potential population-level effects. Because the number of affected
individuals presumably increases with increasing ffl values, the likelihood that
population-level effects are occurring is expected to increase as the ffl increases.
Application of this ranking scheme indicates that chronic effects to small mammals,
small birds, and herpetofauna are possible in the northwest and southeast quadrants,
as well as from sitewide exposure (Table 4). Because the summary His for the
northwest and southeast quadrants and the entire site are on the lower end of the
0.1 to 10 range, effects are expected to be limited to a few individuals, with effects
on populations unlikely. No effects are predicted for the southwest and northeast
quadrants, and no effects are predicted for predatory birds or mammals exposed to
chemicals in any quadrant. Acute effects are possible for all modeled receptors in
59227 6091-71
6-9
-------
TABLE 4
SUMMARY OF ECOLOGICAL RISK ASSESSMENT FOR LF-022
L5-022 RECORD OF DEOSION
PLATTSBURQH AFB
INDICATOR SPECIES
Entire Site
CHRONIC SUMMARY HAZARD INDEX BY AREA
Northwest Southeast Southwest Northeast
White-footed Mouse
Wood Thrush
Garter Snake
Red Fox
Red-Tailed Hawk
2.9 x 10°
3.4 x 10"'
1.4x Iff1
1.6 x 1ffJ
5.5 x 10°
8.5 x 10''
9.9 x Iff1
3.8 x Iff'
1.4 x Iff2
5.6 x 10°
3.3 x 10"'
3.9 x 10''
1.1 x 10"'
3.6 x 10°
1.5 x 10°
1.2x 10J
1.4 x 10°
S.1 x 10"
1.8x10-'
7.4 x Iff*
1.2x 10J
1.4x 10J
4.2 x 10-*
1.4x 10'6
5.9 x Iff*
INDICATOR SPECIES
Entire Site*
Northwest
ACUTE SUMMARY HAZARD INDEX BY AREA
Southeast Southwest Northeast
White-footed Mouse
Wood Thrush
Garter Snake
Red Fox
Red-Tailed Hawk
1.4x 10*°
3^x10-'
1.4x Iff1
1.0x10*°
2.0 x Iff1
1.4x 10*°
Six Iff1
1.4 x Iff1
1.0x 10*8
2.0 x Iff'
4.9 x Iff1
1.2 x Iff'
4.9 x Iff2
3.8 x Iff1
7.3 x Iff2
Z1 xlff3
4.9 x Iff*
Z1x1ff*
1.6x10°
3.1 x Iff*
2.0 x Iff3
4.6 x Iff*
2.0 x Iff*
1.5x10"
2.9 x 10"*
Notes:
* Acute summary HI for entire site is the highest HI of the four quadrants.
RELATIVE HAZARD RANKING (USEPA, 1986d):
HI < 0.1 No Adverse Effects
0.1 sHI <10 Possible Adverse Effects
HI ^10 Probable Adverse Effects
59227.T/5
6-10
-------
SECTION 6
the northwest quadrant, and for small mammals^ small birds, and predatory mammals
in the southeast quadrant. DDD is the greatest contributor to total chronic risks hi
the northwest quadrant and from sitewide exposure, while DDT is the greatest
contributor to risks in the southeast quadrant Effects are expected to be limited to
a few individuals, with no population-level effects expected.
6.5 CONCLUSIONS OF THE BASELINE RISK ASSESSMENT
For the human health baseline risk assessment, all estimated total site risks for the
one current and three future exposure scenarios were at or below USEPA target
risks with one exception: the HI for a child receptor assumed to be simultaneously
exposed to surface soil, groundwater, and fugitive emissions was above the USEPA
target of 1.0. This elevated HI is mostly associated with ingestion of manganese in
groundwater. This elevated HI does not indicate a significant risk and human health
is expected to be protected under current and future site conditions at LF-022.
Adverse ecological effects associated with surface soil exposure are not expected in
the southwest and northeast quadrants of the site. Acute effects predicted for the
northwest and southeast quadrants are expected to be limited to individuals and not
populations at the site. Therefore, there are current and future ecological risks
associated with exposure to chemicals in LF-022 surface soils.
59227 6091-71
6-11
-------
SECTION 7
7.0 DEVELOPMENT AND SCREENING OF ALTERNATIVES
Five alternatives were developed and screened in the FS. Three of these alternatives
were retained for detailed analysis. The following subsections describe the response
objectives and the development and screening of alternatives.
7.1 STATUTORY REQUIREMENTS/RESPONSE OBJECTIVES
Under its legal authorities, Plattsburgh AFB's primary responsibility at this NPL site
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 that include
treatment that permanently and significantly reduces the mobility, toxicity or volume
of hazardous substances is a principal element over remedies not involving such
treatment. Response alternatives were developed to be consistent with these
congressional mandates.
Based on types of contaminants, environmental media of concern, and potential
exposure pathways, a remedial action objective was developed to aid in the
development and screening of alternatives:
• Minimize potential current and future ecological risks associated with
exposure to pesticides in surface soil.
"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. 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
59227 6091-71
7-1
-------
SECTION 7
on attaining response objectives for source control and mitigating risks associated
with surface soils. A no action alternative was also developed.
As discussed in Subsection 4.1 of the LF-022 FS, 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, 1990).
Subsection 42 of the FS presented the remedial alternatives developed by combining
the technologies retained in 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 maxiniuni extent
feasible, to alternatives that provide no treatment but do protect human health and
the environment. Section 5.0 of the FS presented the initial screening of LF-022
alternatives. The purpose of the initial screening was to narrow the number of
potential remedial actions for further 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 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 eliminated from further
consideration.
59227 6091-71
7-2
-------
TABU 5
SUMMARY OF ALTERNATIVE* SCREENING
Lf-022 FEASIBILITY STUDY REPORT
PLATTSBUROH AFB
AlTERNATTO
Alternative 1:
Alternative 2:
Alternative 3:
Alternative 4:
Alternative 5:
No Action
Site Grading and Vegetation Establishment
Installation of a Low-Permeability Barrier Cover System
Excavation and Incineration
Stabilization/Solidification
STATUS
Retained for detailed analysis.
Retained for detailed analysis.
Retained for detailed analysis.
Eliminated from further consideration.
Eliminated from further consideration.
59227.T/4
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SECTION 8
8.0 DESCRIPTION OF ALTERNATIVES
This section provides a narrative summary of each alternative evaluated. A detailed
description of each alternative can be found in Section 6.0 of the FS report. The
source control alternatives analyzed for LF-022 include No Action (Alternative 1),
Site Grading and Vegetation Establishment for Closure (Alternative 2), and
Installation of a Low-Permeability Barrier Cover System (Alternative 3).
8.1 ALTERNATIVE 1: NO ACTION
The No Action Alternative 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
objective.
Estimated Time for Construction: immediate
Estimated Time of Operation: 30 years
Estimated Capital Cost: $0
Estimated Operation and Maintenance (O&M) Costs (30 years, net present worth):
$676,000
Estimated Total Costs (30 years, net present worth): $676,000
82 ALTERNATIVE 2: SITE GRADING AND VEGETATION ESTABLISHMENT FOR
CLOSURE
Alternative 2 consists of a 12-inch soil cover (i.e., no low-permeability layer) to
support grass growth and :reduce precipitation infiltrating to buried wastes. The
alternative includes:
59227 6091-71
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SECTION 8
1. Clearing and grabbing of the landfill site
2. Surface water runoff management to minimize erosion of the cover
and minimize maintenance requirements
3. Cover thickness establishment
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 monitoring
7. Five-year site reviews
Existing vegetation such as trees and brush would be cut, chipped, and removed from
the site. The cleared site would be suitably regraded to control rainwater runoff and
minimize erosion. Because the existing organic soil layer is thin or nonexistent over
most of the landfill, additional soil is needed. Six inches of compacted common
borrow covered by 6 inches of topsoil would be laid down to support grass growth,
which, through evapotranspiration, would reduce the amount of precipitation
reaching the buried waste. Consequently, the potential for contaminants to migrate
from buried waste would be reduced.
A post-closure plan would be developed specifying the inspection, monitoring, and
maintenance programs for the closed landfill, to be continued for at least 30 years.
Post-closure activities would be reviewed every five years as required by. the NCP
when contaminants remain on site. This alternative would meet the response
objective.
Estimated Time for Construction: 4 months
Estimated Time of Operation: 30 years
Estimated Capital Cost: $1,248,000
Estimated O&M Costs (30 years, net present worth): $866,000
59227 6091-71
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SECTION 8
Estimated Total Costs (30 years, net present worth): $2,114,000
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
objective 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 hydraulic barrier layer consisting of recompacted
low-permeability soil or a synthetic liner
5. Placement of a barrier protection layer of soil over the low-
permeability layer
6. Installation of a topsoil 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 monitoring
10. Five-year site reviews
These components are identical to those of Alternative 2 except for components 3,
4, and 5. Under this alternative, a gas detection system would be installed to monitor
gas migration beyond the boundaries of the closed landfill. The barrier layer, placed
above the gas-venting layer, would b,e formed of low-permeability soil (i.e., a
recompacted, fine-grained soil such as clay that is difficult to penetrate) or a synthetic
liner to keep rainwater or snowmelt .from infiltrating the landfill. Over this, a
59227 6091-71
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SECTION 8
3.5-foot barrier protection layer would be installed to protect the barrier layer from
frost action 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. This alternative would reduce the
exposure to pesticide contaminants in surface soils at LF-022.
Estimated Time for Construction: 5 months
Estimated Time of Operation: 30 years
Estimated Capital Cost: $4,196,000
Estimated O&M Costs (30 years, net present worth): $866,000
Estimated Total Costs (30 years, net present worth): $5,062,000
59227 6091-71
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SECTION 9
9.0 SUMMARY OF THE COMPARATIVE ANALYSIS OF ALTERNATIVES
Section 121(b)(l) of CERCLA presents several factors that, at a minimum,
Plattsburgh AFB is required to consider in its assessment of alternatives. Building
upon these specific statutory mandates, the NCP articulates nine evaluation criteria
to be used in assessing the individual remedial alternatives.
A detailed analysis was performed on the alternatives using the nine evaluation
criteria to select a site remedy. The following is a summary of the comparison of
each alternative's strengths and weaknesses with respect to the nine evaluation
criteria. These criteria and their definitions are as follows:
9.1 THRESHOLD CRITERIA
The two threshold criteria described below must be met 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 utilized 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.
59227 6091-71
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SECTION 9
• Reduction of mobility, toxicity, or volume through treatment addresses
the degree to which alternatives employ recycling of 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 the period of 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 addresses the estimated capital and O&M costs on a present-
worth basis.
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 the state's position and key concerns
related to the preferred alternative and other alternatives, including
the 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 RI/FS and Proposed Plan.
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. 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 (ABB-ES, 1992b).
59227 6091-71
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SECTION 9
9.4 COMPARATIVE ANALYSIS OF ALTERNATIVES SUMMARY
The subsection below presents the nine criteria and a brief narrative summary of the
alternatives and their strengths and weaknesses according to the detailed and
comparative analyses.
9.4.1 Overall Protection of Human Health and the Environment
Alternative 1, the No Action Alternative, would not include any measures to protect
human health or the environment. Alternatives 2 and 3 would both minimize the
potential human health and ecological risks associated with surface soil exposures.
Alternatives 2 and 3 would both reduce precipitation infiltrating to the landfilled
wastes and subsequently reduce the potential for contaminants to migrate from waste
material The low-permeability barrier layer associated with the Alternative 3 cover
system would reduce the precipitation infiltration and the potential for contaminant
migration from waste material to a greater degree than the Alternative 2 cover
system.
9.4.2 Compliance with Applicable or Relevant and Appropriate Requirements
All of the alternatives comply with provisions of the Clean Air Act, New York
Ambient Air Quality Standards, and Occupational Safety and Health Administration
regulations.
Alternatives 2 and 3 would comply with the surface water runoff management, topsoil
thickness, post-closure care, and groundwater monitoring relevant and appropriate
requirements of the New York Regulations for solid waste landfills (6 NYCRR
Part 360). Alternative 3 would also meet the relevant and appropriate requirements
of Part 360 for. a gas-venting layer, a low-permeability barrier layer, and a barrier
protection layer. Alternative 1 would not meet the Part 360 requirements.
9.4.3 Long-term Effectiveness and Permanence
Alternative 1 would provide the least long-term protection because no remedial
measures would be •implemented to reduce, eliminate, or control access to
contaminated media. Some animals would remain at risk from exposure to pesticides
at LF-022 surface soil. Alternative 2 provides long-range protection of human health
and effectively reduces ecological risks by covering contaminated surface soil with a
12-inch soil barrier and seeding the new topsoil. The cover would also reduce the
59227 6091-71
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SECTION 9
amount of precipitation reaching the landfilled wastes. The post-closure monitoring
program would maintain the cover system. Alternative 3 provides the greatest long-
term effectiveness because the cover system is the least permeable and it reduces the
amount of water infiltrating to landfilled wastes. The post-closure monitoring
program would also maintain the cover system.
9.4.4 Reduction of Mobility, Toxicity, or Volume of Contaminants through
Treatment
Reduction of Mobility, Toxicity, 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-022,
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-022.
9.4.5 Short-term Effectiveness
No short-term impacts are anticipated for Alternative 1 because remedial actions
would not be implemented. Because Alternatives 2 .and 3 involve removing existing
vegetation and grading the landfill surface, dust containing pesticides could be
generated and inhaled by on-site workers. Dust suppression measures and worker
protective equipment would minimize this. 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
Alternative 1 would be readily implementable because no remedial actions would be
conducted. The implementabuity 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.
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.
59227 6091-71
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SECTION 9
9.4.8 State Acceptance
The State Acceptance criterion has been addressed by incorporating comments
received from NYSDEC, on behalf of the state, into the Proposed Plan. The state
has had the opportunity to review and comment on all documents produced for
LF-022.
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.
59227 6091-71
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SECTION 10
10.0 THE SELECTED REMEDY
Plattsburgh AFB has chosen Alternative 2 as the selected alternative to address
source control for LF-022. Source remediation at LF-022 will be consistent with
future groundwater remedies and will mitigate releases of hazardous substances from
the former landfill to groundwater.
10.1 CLEAN-UP LEVELS
Clean-up levels have not been established for the surface soil contaminants of
concern identified in the baseline risk assessment that were found to pose an
unacceptable risk to either human health or the environment. 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, a 10"6 excess cancer risk
level for carcinogenic effects or a concentration corresponding to an HI of 1.0 for
compounds with noncarcinogenic effects is typically used to set clean-up levels. In
this case, risk-based target clean-up levels were not developed because discrete
source areas (i.e., hot spots) were not found. Remedial alternatives developed for
LF-022 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.
Periodic assessments of the protection afforded by remedial actions 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 shall
be required.
10.2 DESCRIPTION OF REMEDIAL COMPONENTS
Alternative 2, Site Grading and Vegetation Establishment for Closure, consists
primarily of placing 12 inches of soil over, the landfill and planting it with grass to
achieve the response objective 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
minimize erosion.
59227 6091-71
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SECTION 10
Six inches of compacted common borrow covered by 6 inches of topsoil would be laid
down to support grass growth, which, through enhanced evapotranspiration, will
reduce the amount of precipitation reaching the buried waste. Consequently, the
potential for contaminants to migrate from buried waste will be reduced. Additional
fill for design subgrade elevations would consist of common borrow or regraded site
soils. Figures 5 through 7 illustrate the proposed final grading schematic, proposed
cover system cross-section, and the proposed cover system components for
Alternative 2.
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 a 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 cover or any other component of the containment or
monitoring system must not be compromised.
59227 6091-71
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SECTION 11
11.0 STATUTORY DETERMINATIONS
The remedial action selected for implementation at LF-022 is consistent with
CERCLA 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 treatment which permanently and significantly reduces the mobility,
toxicity 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-022 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., reduced permeability
vegetation cover system). Moreover, the selected remedy will reduce 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, and maintenance and monitoring programs).
112 THE SELECTED REMEDY ATTAINS ARARs
This remedy will attain all applicable or relevant and appropriate federal and state
requirements that apply to the site and selected remedy. Environmental laws from
which ARARs for the selected source control remedial action are derived, and the
specific ARARs, are listed below.
Applicable or Relevant and Appropriate Requirements:
Location-specific:
No location-specific ARARs apply to site LJF-022.
59227 6091-71
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SECTION 11
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
activities at the site:
• Clean Air Act (40 CFR Part 50), applicable for paniculate 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 paniculate matter (e.g., fugitive dusts) entrained in air
during clearing, grading, and cover system construction activities.
Action-specific;
• NYSDEC Solid Waste Management Facility Rules (6 NYCRR Part
360), applicable to solid waste landfills, specifies closure and post-
closure criteria.
• Clean Air Act (40 CFR Part 50), applicable for paniculate matter
(e.g., fugitive dusts) entrained in air during clearing, grading, and 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 Groundwater Classification and Water Quality Standards (6
NYCRR Parts 701 and 703), promulgated for iron and manganese, are
exceeded in LF-022 groundwater. However, the results of the baseline
risk assessment provide the rationale for not developing groundwater
response objectives (see Section 6.0).
• New York State Department of Health Drinking Water Supplies (10
NYCRR Chapter 5, Subpart 5-1) standards for iron and manganese are
exceeded in LF-022 groundwater. However, the results of the baseline
risk assessment provide the rationale for not developing remedial
response objectives (see Section 6.0).
59227 6091-71
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SECTION 11
• NYSDEC Division of Air Resources Regulations (6 NYCRR
Parts 200-202, 257), applicable for participate matter (e.g., fugitive
dusts) entrained in air during clearing, grading, and cover system
construction activities.
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 4-7 through
4-10. 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 Nonregulatory Criteria:
In addition to the federal and state ARARs, federal non-promulgated advisories or
guidance must be considered when ARARs for specific contaminants are not
available. The following policies, criteria, and guidance to be considered in the
baseline risk assessment for LF-022 are USEPA Health Advisories, USEPA
reference doses (RfDs), and USEPA Human Health Assessment Group Cancer
Slope Factors.
11J 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: $1,248,000
Estimated O&M Costs (30 years, net present worth): $866,000
Estimated Total Costs (30 years, net present worth): $2,114,000
59227 6091-71
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SECTION 11
Alternative 2 is considered the most cost-effective alternative because it provides the
protection against contact with surface soil contamination. Alternative 2 is similar
to Alternative 3 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 mobility, toxicity, 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 threat at LF-022: environmental risks associated with surface
soil contamination. The selected remedy was chosen primarily because it affords
protection to human health and the environment. The short-term effects of
implementing the selected remedy are comparable to Alternative 3. None of the
three source control alternatives evaluated in the FS included a treatment component
to reduce mobility, toxicity, 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-022. State and public comments
received on the LF-022 FS and Proposed Plan to date have been incorporated into
this ROD.
59227 6091-71
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SECTION 11
11.5 THE SELECTED REMEDY DOES NOT SATISFY THE PREFERENCE FOR
TREATMENT WHICH 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-022 landfill site. The
size of the landfill and the fact that there are no on-site hot spots that represent the
major sources of contamination preclude a remedy in which contaminants could be
excavated and treated effectively.
59227 6091-71
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SECTION 12
12.0 DOCUMENTATION OF NO SIGNIFICANT CHANGES
Plattsburgh AFB presented a Draft Final Source Control Proposed Plan for the
preferred alternative for remediation of LF-022 in August 1992. The preferred
alternative for source control included:
1. Clearing and grubbing of the site
2. Surface water runoff management to minimize erosion of the cover
and minimize maintenance requirements
3. Cover thickness establishment
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 monitoring
7. Five-year site reviews
The chosen remedial action does not differ from the preferred alternative presented
in the Proposed Plan.
59227 6091-71
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SECTION 13
13.0 REGULATORY ROLE
The EPA and NYSDEC has 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-022. The EPA indicates its concurrence with the LF-022
ROD by cosigning the document with Plattsburgh AFB. A copy of the NYSDEC
declaration of concurrence is attached as Appendix B.
59227 6091-71
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ACRONYMS
ABB-ES ABB Environmental Services, Inc.
AFB Air Force Base
ARAR Applicable or Relevant and Appropriate Requirement
BEHP bis(2-ethyhexl)phthalate
bgs below ground surface
CERCLA Comprehensive Environmental Response, Compensation, and Liability
Act of 1980 (the Superfund statute)
DDD Dichlorodiphenyldichloroethane
DDE Dichlorodiphenyldichloroethylene
DDT Dichlorodiphenyltrichloroethane
DERP Defense Environmental Restoration Program
DOE Department of Energy
ERA environmental risk assessment
FS Feasibility Study
HI Hazard Index
IAG Interagency Agreement
IRP Installation Restoration Program
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
PDE Potential Dietary Exposure
RfD reference dose
RI Remedial Investigation
ROD Record of Decision
RTV Reference Toxicity Value
59227
6091-71
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ACRONYMS
SAC Strategic Air Command
SI Site Inspection
SVOC semivolatile organic compound
TRC Technical Review Committee
USEPA U.S. Environmental Protection Agency
VOC volatile organic compound
59227 6091-71
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REFERENCES
ABB Environmental Services (ABB-ES), 1992a. "Installation Restoration Program
(Remedial Investigation/Feasibility Study) at Plattsburgh Air Force Base, New
York; Final LF-022/LF-023 Remedial Investigation Report"; ABB
Environmental Servicesjnc., Portland, Maine; February 1992.
New York State Department of Environmental Conservation (NYSDEC), 1989.
"Habitat-Based Assessment Guidance Document for Conducting
Environmental Risk Assessments at Hazardous Waste Sites"; Draft Division
of Technical and Administrative Guidance Memorandum (TAGM);
December 28, 1989.
U.S. Environmental Protection Agency (USEPA), 1986. "Hazard Evaluation Division
Standard Evaluation Procedure: Ecological Risk Assessment"; Office of
Pesticide Programs; EPA-540/9-85-001; Washington, DC; June 1986.
U.S. Environmental Protection Agency (USEPA), 1989a. "Risk Assessment
Guidance for Superfund: Volume 2 - Environmental Evaluation Manual";
Interim Final; Office of Emergency and Remedial Response; EPA/540/1-
89/001; Washington, D.C; March 1989.
U.S. Environmental Protection Agency (USEPA), 1989b. "Risk Assessment
Guidance for Superfund: Volume 1 - Human Health Evaluation Manual
(Part A); Interim Final"; Office of Emergency and Remedial Response,
EPA/540/1-89/002; Washington, D.C.; December 1989. '
U.S. Environmental Protection Agency (USEPA), 1990. "Streamlining the RI/FS for
CERCLA Municipal Landfill Sites"; Office of Emergency and Remedial
Response Hazardous Site Control Division; Washington, D.C.; September
1990.
59227 6091-71
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APPENDIX A - ADMINISTRATIVE RECORD INDEX
-------
PLATTS8URGH AFB ADMINISTRATIVE RECORD DOCUMENT INDEX
SITE LF-022
DOC 1
; TYPE
LF-022
1
1
1
1
.10
.61
.62
.63
!R
[R •
[R
[R
1 SUBJECT
ij 5iu identification
[IRP Records Search-see Doc. «-l
1.6 Site Inspection
[See docunent No M-8, Site Inspection Report
[See docuient No M-9, Appendix I
[See docuient No M-10, Appendix II
3.0 Reiedial Investigation (RI)
[Author
i KdOlaH uOTp ,
acCieari va
E.C. Jordan Co Portland
. 3.1. Saipling.and Analysis— see also LF-022/LF-023 RI Report
3
3
3
3
3
.3
3
3
3
3
3
3
3
3
3
.10
.11
.12
.13
.14
.15
.40
.41
.42
.43
.44
.45
.46
.47
.48
4.05
4.10
4.11
4.20
4.21
8.10
[D
[L
!L
JO
[L
[L
!L
[L
!R '
!L
[L
[L
[R
!R
[L
[L
[R
[R
[L
[L.R
[LF-022/LF-023 RI Report-Laboratory blank data
[LF-022 Surface soil pesticides/pcb saiples
[LF-022 Surface soil pesticides/pcb saiples
[LF-022 Surf, soil pesticides/pcb saiples data
[Validated saiple results- LF-022 and LF-023
[Validated saiple results- LF-022 and LF-023
3.4 RI reports and conents
[ TO
;?iattsburgh >
[DATE
r -i
1
Piattsburgh AFB, NY
APR
JUL
JUL
JUL
35
89
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Appendices-LF-022 3.48-
[ABB Env. Svcs, Inc.
[J. Huru, PE, PAFB
[J. Huru, PE, PAFB
[A88 Env. Svcs, Inc.
[Col. Hrapla, PAFB
[Coi. Hrapla, PAFB
[NYSDEC Coiients on LF-022/LF-023 RI Report [J Lister, PE, NYSDEC
[Resp. to Coiients on LF-022/LF-023 RI Report [J. Huru, PE, PAFB
[Resp. to EPA Coiients on LF-022/023 RI Report [J. Huru, PE, PAFB
[Meeting Minutes, LF-022/LF-023 RI/FS ~[?tattsburgh AFB "—
[NYSOEC couents-LF-022/LF-023 Final RI Report [J Lister, PE, NYSOEC
[USEPA couents-LF-022/LF-023 Final RI Report [Ui. Roach, PE, USEPA
[EPA approval of LF-022/LF-023 Final RI Report [Ua. Roach, PE, USEPA
[LF-022/LF-023 RI Report-Final _- -4*88 Env. Svcs, Inc.
[LF-022/LF-023 RI Report-Finai-Appendices . [A88 Env. Svcs, Inc.
4.0 Feasibility Study (FS)
[Identification of ARARS for LF-022 and LF-023-'
[NYSDEC Coiients on LF-022 Draft FS
[Landfill LF-022 FS Report Draft Final
[Landfill LF-022 Proposed Reiedial Action Plan
[NYSDEC Coiients on LF-022 Draft PRAP
8.0 Health Assessients - --. —
[Landfill LF-022/LF-023 Risk Assessient, based
on unfiltered saipling results
[AfiB'Ejw.
[J Lister,
[ABB Env.
[ABB Env.
[Michael J
--=- — •-••
[J. Huru,
J. Huru,
-
Svcs, Inc.-
PE, NYSDEC
Svcs, Inc.
Svcs, Inc.
O'Toole NYSDEC
— -..- .=-
PE, PAFB
PE, PAFB
[Doug Draper, HAZURAP
[J. Lister, PE, NYSDEC
[Ui. Roach, PE, USEPA
[Doug Draper, HAZURAP
[Ui. Roach, PE, USEPA
[J Lister, PE, NYSDEC
[P. Von Bargen, PAFB
[Ui. Roach, PE, USEPA
[J Lister, PE, NYSDEC
[Attendees
[Al Rascoe, PE, PAFB
[P. Maloy, PAFB
[Al Rascoe, PE, PAFB
[Piattsburgh AFB
[Piattsburgh AFB
[Doug Draper, HAZURAP
[Al Rascoe, PE, PAFB
[Piattsburgh AFB
[Piattsburgh AFB
[Al Rascoe, PE, PAFB
. -=-=1-
[Ui. Roach, PE, USEPA
[J Lister, PE, NYSDEC
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NOTE: TYPE BLOCK MEANINGS- Letter M=Hessage D=Data R=Report
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APPENDIX B - STATE LETTER OF CONCURRENCE
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The State letter of concurrence will be placed here after NYSDEC reviews and
concurs with the Draft Final ROD.
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APPENDIX C - PUBLIC MEETING TRANSCRIPT
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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 OLT 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 Champlain 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've 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--
en vironmental 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
tajces 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'VI turn it over to our experts. Hopefully,
you'lT 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
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PURSER: basically, I 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 Pittsburgh 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 that is available at the
Plattsburgh Public Library. Quarterly TR'C meetings, one which ret
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 our.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 mail ing-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.
YONBARGEN: 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
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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 process. 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 here 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 ana the
Department of Energy, and then finally, we have our engineering
contractors, from which we go ahead and 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 feas-ibility 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
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VONBARGEN: surface soils, subsurface soils, ground Water, the surface water
associated with downslope--a distance away from 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 landftll 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 sam-ling, 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 samp.le 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 based 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 unitless 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.
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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 .to 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, which 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, imp!imentability, and cost.
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BECKER: This is our way of not having to spend a'lot of time evaluating
alternatives that probably won't be applicable.to the site. And
based on our evaluation, we determined that the no action vege-
tative cover and the permeability cover systems were the most
appropriate for our site because excavation and incineration and
stabilization/solidification are really dependent upon having
hot spots or things of that nature. It also entails a lot of
extra excavation that may--may bring short term effects to the
• workers in the area. And we didn't feel that it was any more
protective than the other three alternatives, in addition to its
being extremely costly. Our three alternatives were evaluated
using nine criteria. Basically, the nine criteria is to eva-
luate whether it's protective of human health and the environ-
ment, its permanence and long-term effectiveness, it's
implement-ability cost, and compliance with regulations. In
addition, the last two criteria are state acceptance and the
community acceptance. At this point, we have gotten concurrence
from the State and EPA on our preferred alternative, and the
community acceptance criteria will be evaluated after all com-
munity comments have been submitted. Based on our evaluations,
Plattsburgh Air Force Base feels that the preferred remedial
alternative is alternative three, the installation of a low per-
meability variable cover system, which in addition to it being
very protective, it also fulfills the Part 360 New York State
requirement. It provides overall protection of human health and
the environment. It provides long-term effectiveness. And it
has the greatest effect on reducing the potential for additional
contaminants to migrate through the waste into the ground water
at this landfill. And at this point, that concludes the presen-
tation on landfill 23. And Mr. Von Bargen will come back and
brief the background on landfill 22.
VONBARGEN: 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 reevaluating
the records and understanding the waste water treatment facili-
ties operations and the waste going over there, we reconsidered
that site in the site inspection stage. We went out and did
some sampling of the waste and thought that we needed to go
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VONBARGEN: farther into a remedial investigation report. That was final-
ized in February of 92, just recently, and that identifies the
nature and extent of the contamination we found in that report.
It also contains the risk assessment that Miss Becker speaks
about. The feasibility study report was just recently
completed,, which identifies the various alternatives that were
considered. And then the proposed plan, which is being put out
right now, is for the recommended remedy for that site, and
Rachel Becker will speak about that. And again, what did we do
out there. It was somewhat similar, except that at this par-
ticular site, we didn't have surface water and sediments to go
out and sample, but we sampled the surface soil and subsurface
ground water, and the waste. We used very similar techniques as
we did over at landfill 23. And our findings for this par-
ticular landfill were—in this case, there were no volitile or
semi-volitile organic compounds in the surface soils. There was
DDT, a pesticide, detected at less than 20 parts per million in
the surface soils. The wastes themselves were analyzed and
detected carbon tetrocholoride and cholreform. 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-border! ine.
The hazard index is 1, which is considered acceptable. It's the
same receptors were elevated for landfill 22 as for landfill 23,
with similar results. Our risk assessment determined a few
individuals may possibly have adverse effects, but there would
be no population problems. And again, we go through the same
process for landfill 22 and we did for landfill 23. In fact,
all of our sites went through this process to go through the
7
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BECKER: feasibility study process. The remedial respoase 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 down 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 long-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)
YON BARGEN: Thank you. We are open to questions.
MEYERS: Can you dear up a little bit the difference between plan 2 and
plan 3—alternative 2 and 3?
ROACH: For both sites?
MEYERS: Yeah. What is actually the difference.between alternatives 2
and 3?
BECKER: ' The difference is alternative 2 is strictly a vegetation cover.
Basically, it's a matter of placing about a foot of soil on top
of the existing soil and establishing vegetation over that to
enhance the amount of transporation. It essentially protects
receptors from the surface soil itself. On the other hand,
alternative 3, the low permeability cover system—in addition to
having soil being placed on the surface, has a geomembrane,
which is a impermeable—which is a low permeability membrane. It
prevents approximately 7U percent of the percipitation from
8
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BECKER:
MEYERS:
BECKER:
LAWSON:
MEYERS:
VONBARGEN:
MEYERS:
VONBARGEN:
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.
So, is this like a plastic coating or something like a covering
that goes over the —
It goes in between the soil layers.
probably give you a little bit more
ponents of the cap.
In 'fact,
detail on
Tom
the
Lawson
actual
could
com-
be able to track (inaudible!
that is an inpermeable layer built
tative lawyer on top of that.
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
And then what is put on top of
up. And then you put a vege-
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 2$ 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.
»
Did you mention that you won't be able to grow vegetation on
level 3, or alternative 3?
You would be able to put a grass.cover to stabilize the soil.
A grass cover, but you won't be able to plant trees (inaudible)?
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 landfilTs were operational
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VONBARGEN:
MEYERS:
YONBARGEN:
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, whether it will be some state
or EPA regulation, something that's driven by risk, and then
developing the same process, this selection of remedies, and
evaluating them and determining what would be an appropriate
action at that site. So, that will be following in the very
near future.
I '-d like to thank you all for coming. And again, if you haven't
signed in, by doing so, you'll be added to the mailing list. I
appreciate you all coming out. Thank you very much.
(The meeting was terminated.)
10
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APPENDIX D - RESPONSIVENESS SUMMARY
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RESPONSIVENESS SUMMARY
The purpose of this Responsiveness Summary is to address comments received during
the 4 August 92 through 3 September 92 public comment period for Landfill LF-022.
However, no comments from the public were received.
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