PB94-963803
EPA/ROD/R02-94/226
December 1993
EPA Superfund
Record of Decision:
Pollution Abatement Services,
Oswego, NY
12/29/1993
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RECORD OF DECISION
Pollution Abatement Services
City of Oswego, Oswego County, New York
United States Environmental Protection Agency
Region n
New York, New York
December 1993
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RECORD OF DECISION FACT SHEET
EPA REGION II
Site:
Site name: Pollution Abatement Services (PAS)
Site location: Oswego, Oswego County, New York
MRS score: 70.80
Listed on the NPL: September 1983
Record of Decision:
Date signed: December 29 ,1993
Selected remedy: Enhanced Source Control With Bedrock Groundwater
Extraction and Treatment
Capital cost: $1,110,000
Construction Completion - Estimated June, 1995
O & M cost in 1994: $200,000 (1993 dollars)
0 & M cost in 1995: $200,000 (1993 dollars)
O & M cost in 1996: $200,000 (1993 dollars)
O & M cost in 1997: $200,000 (1993 dollars)
Present-worth cost - $3,600,000 (7% discount rate for 30 years):
Site is enforcement lead - EPA is the lead agency
Primary Contact: Richard Ramon, P.E., Esq., (212) 264-1336
Secondary Contact: Joel Singerman, Chief, Western N.Y. Superfund Section I
Main PRPs: There are almost 100 PRPs, de maximus is the
PRP consultant (615) 691-5052
Waste: -
Waste type: metals, volatile organics, semi-volatile organics and PCBs
Waste origin: Hazardous waste
Contaminated medium: soil, ground water, and surface water
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DECLARATION FOR THE RECORD OF DECISION
SITE NAME AND LOCATION
Pollution Abatement Services (PAS)
City of Oswego, Oswego County, New York
STATEMENT OF BASIS AND PURPOSE
This Record of Decision (ROD) documents the U.S. Environmental Protection Agency's
(EPA's) selection of a remedial action to augment the previously implemented remedial
action and to address contamination detected outside the containment system at the PAS
site in accordance with the requirements of the Comprehensive Environmental Response,
Compensation and Liability Act of 1980, as amended (CERCLA), 42 U.S.C. §9601 el seq.
and to the extent practicable the National Oil and Hazardous Substances Pollution
Contingency Plan (NCP), 40 CFR Part 300. This decision document explains the factual and
legal basis for selecting the remedy for the Site. The attached index (Appendix HI)
identifies the items that comprise the Administrative Record upon which the selection of
the remedial action is based.
The New York State Department of Environmental Conservation (NYSDEC) has been
consulted on the planned remedial action in accordance with CERCLA § 121(f), 42 U.S.C.
§9621(f), and it concurs with the selected remedy (see Appendix IV).
ASSESSMENT OF THE SITE
Actual or threatened releases of hazardous substances from the site, if not addressed by
implementing the response action selected in this ROD, may present an imminent and
substantial endangerment to public health, welfare, or the environment.
DESCRIPTION OF THE SELECTED REMEDY
The selected remedial action represents the third operable unit of site remediation. The
first operable unit was for removal actions taken from 1973 to 1982 by EPA and NYSDEC.
The remedy for the second operable unit which addressed the on-site contaminated
groundwater was specified in a ROD issued in June 1984.
The selected remedy for this operable unit will incorporate all of the existing components
of the second operable unit of site remediation. These components include:
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the existing containment system (including a cover, slurry wall and leachate and
groundwater collection system);
treatment and disposal of the collected leachate and groundwater;
site security and access control by a perimeter fence;
site maintenance; and
long-term monitoring.
The selected remedy will also incorporate the following additional components:
enhancing the present source control system by optimizing the leachate and
groundwater extraction rate and other operating parameters in order to achieve, to
the degree practicable, inward horizontal gradients in the overburden and upward
vertical gradients from the bedrock toward the containment system;
bedrock groundwater extraction and treatment;
connecting downgradient residents in the Smith's Beach area, who are using
residential wells, to the public water supply to ensure that potential future exposure
to contaminants in the bedrock groundwater does not occur; and
recommending institutional controls on groundwater usage through deed restrictions
at the PAS site and downgradient from the site to and including the Smith's Beach
area.
During the remedial design, an investigation will be undertaken to better define the extent
of contamination of the bedrock aquifer, to verify that the increased interim groundwater
removal pumping from the overburden aquifer within the containment system has created
upward vertical gradients between the bedrock and overburden aquifers, to determine the
potential effectiveness of pumping to contain impacted groundwater in the bedrock outside
the containment system, to evaluate the hydraulic potential to restore the bedrock aquifer's
water quality, and to determine potential impacts of bedrock groundwater pumping on verti-
cal gradients beneath the containment system and the creeks and wetlands. Should the
results of this investigation determine that bedrock pumping will be an effective means of
addressing the contamination in the bedrock aquifer without adversely impacting the existing
containment system or the creeks and wetlands, then an analysis to determine the rate of
extraction and the location of the bedrock extraction wells will be performed, followed by
implementation of the bedrock groundwater extraction and treatment. Should the
investigation indicate that bedrock groundwater pumping will have a significant, adverse
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impact on the containment system or the creeks and wetlands, this decision will be
documented in a pre-remedial design study report concurred upon by New York State1.
The preferred option for the treatment and disposal of the leachate and groundwater is
discharge to the City of Oswego's Eastside Wastewater Treatment Plant. The contingent
option is construction of an on-site treatment system and discharge to White or Wine Creek
or to groundwater. The current system for treatment and disposal of the leachate and
groundwater via the off-site Resource Conservation and Recovery Act (RCRA) treatment,
storage, and disposal (TSD) facility will continue until a final treatment option is selected
and implemented.
Since there is some uncertainty related to the source of the pesticides detected in the
surface water of the adjacent creeks and the PCB contamination in the sediments in the
adjacent creeks and wetlands, a study will be conducted to determine the sources of
pesticide and PCB contamination. If it is determined that the contamination in the adjacent
creeks and wetlands is attributable to the PAS site, then these areas will be designated as
a separate operable unit and a focused feasibility study will be conducted to evaluate
appropriate remedial alternatives.
In accordance with CERCIA Section 117(c) and Section 300.435(c)(2)(i) of the NCR, if bedrock groundwater pumping
is not implemented, then an Explanation of Significant Differences, describing the modification to the selected remedy
and the basis for the change, will be published.
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DECLARATION OF STATUTORY DETERMINATIONS
The selected remedy meets the requirements for remedial actions set forth in CERCLA
§121, 42 U.S.C. §9621: (1) it is protective of human health and the environment; (2) it
attains a level or standard of control of the hazardous substances, pollutants and
contaminants, which at least attains the legally applicable or relevant and appropriate
requirements (ARARs) under federal and state laws, (3) it is cost-effective; (4) it utilizes
permanent solutions and alternative treatment (or resource recovery) technologies to the
maximum extent practicable; and (5) it satisfies the statutory preference for remedies that
employ treatment to reduce the toxicity, mobility, or volume of the hazardous substances,
pollutants or contaminants at a site.
A review of the remedial action pursuant to CERCLA § 121(c), 42 U.S.C §9621(c), will be
conducted five years after the commencement of the remedial action, and every five years
thereafter, to ensure that the remedy continues to provide adequate protection to human
health and the environment, because this remedy will result in hazardous substances
remaining on-site above health-based levels.
Wilh'anKJ. Muszyns^P.E. Date
Actidg Regional Administrator
IV
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RECORD OF DECISION FACT SHEET
EPA REGION II
Site;
Site name: Pollution Abatement Services (PAS)
Site location: Oswego, Oswego County, New York
HRS score: 70.80
Listed on the NPL: September 1983
Record of Decision:
Date signed: December 29, 1993
Selected remedy: Enhanced Source Control With Bedrock Groundwater Extraction and
Treatment
Capital cost: $1,110,000
Construction Completion - Estimated June, 1995
O & M cost in 1994: $200,000 (1993 dollars)
O & M cost in 1995: $200,000 (1993 dollars)
O & M cost in 1996: $200,000 (1993 dollars)
O & M cost in 1997: $200,000 (1993 dollars)
Present-worth cost - $3,600,000 (7% discount rate for 30 years):
Lead:
Site is enforcement lead - EPA is the lead agency
Primary Contact: Richard Ramon, P.E., Esq., (212) 264-1336
Secondary "Contact: Joel Singerman, Chief, Western New York Superfund Section I
Mam PRPs: There are almost 100 PRPs, de maximus is the PRP consultant (615) 691-5052
Waste;
Waste type: metals, volatile organics, semi-volatile organics and PCBs
Waste origin: Hazardous waste
Contaminated medium: soil, ground water, and surface water
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RECORD OF DECISION
DECISION SUMMARY
Pollution Abatement Services
City of Oswego, Oswego County, New York
United States Environmental Protection Agency
Region II
New York, New York
December 1993
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TABLE OF CONTENTS
page
SITE NAME, LOCATION AND DESCRIPTION 1
SITE HISTORY AND ENFORCEMENT ACTIVITIES . . ; 1
HIGHLIGHTS OF COMMUNITY PARTICIPATION 2
SCOPE AND ROLE OF OPERABLE UNIT 3
SUMMARY OF SITE CHARACTERISTICS 3
SUMMARY OF SITE RISKS 10
REMEDIAL ACTION OBJECTIVES 15
DESCRIPTION OF REMEDIAL ACTION ALTERNATIVES 16
SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES 21
SELECTED REMEDY , 27
STATUTORY DETERMINATIONS 29
DOCUMENTATION OF SIGNIFICANT CHANGES 32
ATTACHMENTS
APPENDIX I. FIGURES
APPENDIX II. TABLES FOR GROUNDWATER SAMPLE RESULTS
APPENDIX III ADMINISTRATIVE RECORD INDEX
APPENDIX IV. STATE LETTER OF CONCURRENCE
APPENDIX V. RESPONSIVENESS SUMMARY
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SITE NAME, LOCATION AND DESCRIPTION
The PAS site is located on 15 acres near the eastern edge of the City of Oswego, New York.
The site is bounded on the south by East Seneca Street, and on the east, north, and west
by wetlands formed along the stream channels of White and Wine Creeks (see Figure 1).
Just to the north (downstream) of the PAS site is the confluence of White and Wine Creeks.
Wine Creek flows approximately 1800 feet farther north to a wetland adjacent to the com-
munity of Smith's Beach, and then into Lake Ontario (see Figure 2). Prior to passing
through the PAS site, White and Wine Creeks originate in and flow through farmland to the
south. White Creek is proximate to the East Seneca Street Dump (also referred to and
operated as the Oswego County Landfill) and both White and Wine Creeks flow through
or are proximate to the Niagara Mohawk Fire Training School. The Oswego Castings site
is upstream of the wetland adjacent to Smith's Beach.
The area between the PAS site and Lake Ontario (to the north) is mostly undeveloped and
currently includes three land uses. These uses, from west to east include a cemetery, a
wetland, and a residential community. The residential community, Smith's Beach, consists
of approximately 25 dwellings and is located on the shore of Lake Ontario, about 1/2 mile
north of the PAS site. Public water supply is available in Smith's Beach, but some residents
may not be connected to that public supply.
SITE HISTORY AND ENFORCEMENT ACTIVITIES
The PAS facility, a high-temperature liquid chemical waste incineration facility, operated
from 1970 through 1977. Beginning in 1973, a series of incidents, including liquid waste
spills and the overflow of liquid wastes from lagoons into White Creek, led to the
involvement of EPA and NYSDEC at the site. Removal actions taken from 1973 to 1982 by
EPA and NYSDEC resulted in the removal of the incineration facilities, drummed wastes,
bulk liquid wastes, and contaminated soils and the closure of two on-site lagoons (Operable
Unit 1). In 1981, the PAS site, which was ranked number seven on the original National
Priorities List, was selected as one of the first sites in the nation to receive CERCLA Trust
Fund monies for cleanup actions.
From 1982 to 1984, NYSDEC's contractor performed a Site Investigation and Remedial Alter-
natives Evaluation of the PAS site which was the initial RI/FS conducted at the site. Based
on the results of this study, EPA signed a ROD in 1984, which specified the following
remedial actions: limited excavation and off-site disposal of contaminated materials, instal-
lation of a perimeter slurry wall, site grading and capping in accordance with RCRA
requirements, installation of a leachate and groundwater collection and treatment system,
and groundwater monitoring (Operable Unit 2). NYSDEC implemented the remedial
actions identified in the ROD, with the exception of the on-site treatment system. Rather
than install an on-site treatment system, leachate and groundwater were collected by
NYSDEC from 1986 through 1991 and transported off-site to an approved RCRA treatment
and disposal facility.
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During the period 1984 to 1986, NYSDEC's contractor performed an environmental as-
sessment of the area in the vicinity of the PAS site, which included White and Wine Creeks.
Based on the results of the environmental assessment, NYSDEC determined that no
remediation of the creeks was required. The long-term monitoring program, which
commenced in 1989 by NYSDEC, includes routine monitoring of the groundwater, surface
water, and sediments in the vicinity of the PAS site.
In 1987, the results of water sampling and down-hole camera investigations of the existing
monitoring wells at the site indicated that contamination may exist outside the slurry wall
containment system.
In September 1990, an Administrative Order on Consent (AOQ was entered into between
EPA and a group of potentially responsible parties (PRPs) to conduct a supplemental RI/FS
to evaluate the integrity of the existing containment system at the site, to determine the
nature, extent, and source of contamination and any threat to the public health or the
environment caused by-the release of hazardous substances outside the containment
system, and to identify and evaluate remedial alternatives.
In September 1991, EPA and a group of PRPs entered into an interim groundwater
(leachate) removal AOC. This AOC requires routine removal of leachate and groundwater
from within the containment system for 36 months or until 1,080,000 gallons of leachate
and groundwater have been removed, whichever comes first. The extracted leachate and
groundwater (approximately 15,000 gallons every two weeks) is currently transported to an
approved RCRA treatment and disposal facility.
HIGHLIGHTS OF COMMUNITY PARTICIPATION
The Rl report, FS report, and the Proposed Plan for the site were released to the public for
comment on August 23,1993. These documents were made available to the public in the
administrative record file at the EPA Docket Room in Region II, New York and the
information repository at the Oswego City Hall. The notice of availability for the above-
referenced documents was published in the Oswego Palladium Times oh August 21,1993.
The public comment period related to these documents was held from August 24,1993
to September 22,1993.
On September 8,1993, EPA and NYSDEC conducted a public meeting at Oswego City Hall
to inform local officials and interested citizens about the Superfund process, to review
current and planned remedial activities at the site, to discuss the Proposed Plan, to receive
comments on the Proposed Plan, and to respond to questions from area residents and
other interested parties.
Responses to the comments received at the public meeting and in writing during the public
comment period are included in the Responsiveness Summary (see Appendix V).
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SCOPE AND ROLE OF OPERABLE UNIT
The primary objectives of this action are to control the source of contamination at the site,
to reduce and minimize the downgradient migration of contaminants in the groundwater,
and to minimize any potential future health and environmental impacts.
The first operable unit was for removal actions taken from 1973 to 1982 by EPA and
NYSDEC. The remedy for the second operable unit which addressed the on-site
contaminated groundwater was specified in a ROD in issued in June 1984.
This third operable unit addresses conditions not permanently resolved by previous site
actions. First, this action will modify the groundwater treatment requirements called for in
the 1984 ROD. Second, this action will include measures to address contamination located
outside the containment system. And third, this action will convert the current interim
groundwater (leachate) removal program into a permanent means of treating and disposing
of leachate removed from the existing containment system.
SUMMARY OF SITE CHARACTERISTICS
The purpose of the Supplemental Remedial Investigation (SRI) was to evaluate the hydraulic
integrity of the containment system and assess the nature and extent of the site-related
contaminants outside the containment system.
From May 1991 through March 1992, field activities were conducted at the site. These
field activities consisted of drilling soil borings, collecting soil samples, installing monitoring
wells, measuring water levels, conducting a pumping test of the leachate collection system,
and collecting groundwater, surface water, and sediment samples for laboratory analysis.
Hydrogeologic Evaluation of the Site and Containment System
Three hydrogeologic units are present at the site: the unconfined overburden unit consisting
of man-made fill and low permeability ablation till (from surface to 15 ft.); the lower per-
meability lodgement till (from 15 ft. to 36 ft.); and the low permeability confined bedrock
aquifer (below 36 ft.)2. The containment system slurry wall extends through the overbur-
den into the top of the lodgement till.
Groundwater flow in the overburden outside of the containment system is generally to the
north/northwest. It responds seasonally to variation in precipitation, and is locally influ-
enced by changes in the surface water levels in White and Wine Creeks. Groundwater
All depths are at monitoring well SWW-1 (see Figure 1).
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from the overburden outside of the containment system discharges into White and Wine
Creeks, which appear to act as hydraulic barriers.
Overburden groundwater levels within the containment system are controlled by pumping
from the leachate and groundwater recovery systems. Horizontal gradients within the
containment system are generally to the northwest. September 1991 data indicated that
the horizontal groundwater flow gradients across the slurry wall were outward along most
of the eastern and northern (downgradient) sides of the slurry wall.
Based upon April 1993 data, it appears that the increased interim groundwater removal
pumping under the September 1991 AOC has modified the horizontal-gradients across the
slurry wall resulting in inward gradients along much of the length of the slurry wall (i.e.,
groundwater tends to flow inward rather than outward toward the slurry wall).
The bedrock groundwater flow direction is northward, toward Lake Ontario, and the hydrau-
lic gradient (and flow velocity) decreases with distance from Lake Ontario. In general,
naturally-occurring upward hydraulic gradients from the bedrock toward the overburden
deposits exist in the vicinity of White and Wine Creeks adjacent to the site, and downward
vertical gradients exist in the remaining areas. Based on April 1993 data, it appears that
upward vertical gradients between the bedrock and overburden may have been produced
over part of the containment system. These upward gradients are believed to be due to
increased interim groundwater removal pumping from the overburden within the contain-
ment system.
The hydraulic integrity of the containment system was assessed using data from continuous
monitoring of water levels at selected monitoring well pairs located on opposite sides of the
slurry wall, monthly water level measurements, and associated meteorological data. The
monitoring data demonstrated that the slurry wall is performing effectively. The lack of re-
sponse of groundwater levels inside the containment system to precipitation suggest that
the cover system is performing effectively. Therefore, based on extensive monitoring data
collected at the site, the existing containment system with the interim groundwater removal
pumping (30,000 gallons per month) appears to provide hydraulic control of the contained
area.
Subsurface Soil Quality
A soil boring program was conducted by Geraghty & Miller at the PAS site from August 26,
1991 through September 17,1991. Eleven soil borings designated B-1 through B-7, B-9,
M-21, M-22, and M-23 were drilled at the locations indicated on Figure 3-3.
One hundred ten (110) subsurface soil samples from nine borings drilled during the SRI
were subjected to field headspace screening analysis using both a total organic vapor
detector and a field gas chromatograph (GC). Subsurface soil samples collected above the
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overburden water table to the north and east of the containment system (lowest points of
the slurry wall) contained only trace levels (at or below detection limits) of contamination.
The two samples from each SRI boring with the highest VOC headspace concentration
were subjected to laboratory analyses for the TCL VOCs by CLP. CLP data are usually
considered to provide higher quality data than field screening analyses. Low concentrations
of VOCs were reported for these SRI subsurface soil samples by the off-site CLP laboratory.
A summary of the analytical results is presented in Tables 5-1 thru 5-5 of the SRI. Of the
19 samples analyzed/15 samples had no VOCs detected, three had trace concentrations
(i.e., below the contract required quantitation limits [CRQLJ) with total VOCs (TVOCs)
ranging from 1 to 6 /Jg/kg/ and one sample had TVOCs of 102 /ig/kg. The compound
detected at the highest concentration in the latter sample was 4-methyl-2-pentanone (76
fg/kg). It was the only VOC detected above the CRQL in the SRI subsurface soil samples,
it was not detected in any other SRI subsurface soil samples, and it was not detected in
groundwater above the New York State Class GA Groundwater Quality Standard of 50
micrograms per liter (NYCRR, Title 6, Parts 701-703), suggesting that its presence in soil is
not having an adverse impact on groundwater quality. Other VOCs detected at trace
concentrations (i.e., at or below 9 pg/kg) in subsurface soils outside the containment
system consist of ethylbenzene," xylene, toluene, and 2-butanone.
TCL SVOCs were detected in 10 of the 19 SRI soil samples. Of the 64 targeted
compounds, only 13 were detected, 12 of which are phenols, PAHs, or phthalates. In the
samples in which SVOCs were detected, their total concentrations ranged from 88 Mg/kg
to 2,869 Mg/kg. Only three compounds were reported at concentrations greater than the
CRQL: phenol in boring B-1, and bis(2-ethylhexyl)phthalate in borings B-3 and B-4.
Bis(i-ethylhexyl) phthalate was detected most frequently and also had the highest
concentrations.
Four TCL pesticides (methoxychlor, endrin, 4,4'-DDD, 4,4'-DDT) were detected at
concentrations ranging from 2.1 /fg/kg to 6.3 /ig/kg (all below the CRQL, but above the
method detection limit) in 3 of 19 samples. Aroclor-1260 was the only PCB detected in the
subsurface soil. It was detected in one sample at 36 Mg/kg, and in another sample at 690
Mg/kg. These pesticides/PCBs were not detected in groundwater samples collected under
the SRI and Long Term Monitoring Plan (LTMP).
Nineteen soil samples were analyzed for TAL inorganic parameters (metals and .cyanide).
No site-specific background samples were collected as part of the SRI. A summary of the
analytical results can be found* in the SRI (Tables 5-1 thru 5-5). Antimony, mercury,
selenium, thallium, and silver were not detected in any of the SRI subsurface soil samples.
Cadmium was detected in only one sample at a concentration of 1.2 mg/kg. Cyanide was
detected in six soil samples ranging in concentration from 0.75 mg/kg to 4.2 mg/kg.
There are no federal or New York State ARARs for soils. In addition, site-specific
background data for soils do not exist. SRI soil samples collected between the containment
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system and White Creek to the north and east of the PAS site contained TCL compounds,
mostly at trace concentrations below the CRQL Additionally, TAL metals were not detected
in subsurface soils at concentrations greater than the background range for the Eastern
United States.
Groundwater Quality
Groundwater quality has been assessed through a review of data generated under the
LTMP being conducted by NYSDEC and URS, as well as data generated during the SRI/ in
order to evaluate the potential release of site-related contaminants from the containment
system. A complete listing of the analytical results summarized and discussed below is
presented in tables 5-6 thru 5-19 of the SRI.
As part of the LTMP, URS sampled wells located in both the overburden and bedrock
hydrogeologic units. The three new SRI bedrock monitoring wells (M-21, M-22, and M-23)
were sampled as part of the SRI. Three rounds of LTMP data (November 1990, May 1991,
and November 1991) and two rounds of data collected during the SRI (October 1991 and
November 1991) have been evaluated. The LTMP includes collection of groundwater
samples for VOCs and SVOCs from 15 overburden monitoring wells, 4 bedrock monitoring
wells, and a leachate collection well LCW-2 (inside the slurry wall). Although the SRI/FS
study area is outside the slurry wall, data from LCW-2 have been included for comparative
purposes. During the SRI, samples were collected from bedrock monitoring wells M-21,
M-22, and M-23 and analyzed for TCL VOCs, SVOCs, pesticides/PCBs, and TAL inorganic
parameters (total metals, dissolved metals, and cyanide). Overburden groundwater
samples were not collected during the SRI.
Benzene, toluene, ethylbenzene, xylenes (total BTEX -1790 /Jg/l), nickel (173 Mg/0/ arsenic
(34 /Jg/l), and phenolic compounds (79 fig/I) were detected north of the containment
system in both the overburden and bedrock'aquifers; chlorinated ethanes/ethenes (278
/jg/l) exceeding ARARS were detected in areas northwest of the containment system. (See
Table 1.) There is no indication that groundwater quality in the overburden north of White
Creek has been affected because the Creek appears to act as a hydraulic barrier to shallow
groundwater flow beyond the Creek.
Chemical-specific ARARs for groundwater at the PAS site include Federal Safe Drinking
Water Act Maximum Contaminant Levels and Maximum Contaminant Level Goals (MCLs
and MCLGs, respectively, 40 CFR Part 141), New York Safe Drinking Water Act MCLs
(NYCRR, Title 10, Part 5-1), and New York State Groundwater Quality Standards (NYCRR,
Title 6, Parts 701-703). The above standards are tabulated, along with site monitoring data
for downgradient and upgradient monitoring wells, in Table 1 for the overburden and
bedrock units. The significance of the presence of groundwater contaminants is also
summarized in the next section of the ROD.
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TVOCs reported in the other ten overburden monitoring wells outside the slurry wall have
ranged from 2 /ig/l to 3,409 /ig/l. WOCs detected in groundwater within the slurry wall
at LCW-2 ranged from 43,770 /ig/l to 45,930 /ig/l. Xylene, toluene, ethylbenzene, acetone,
4-methyl-2-pentanone, 1,1-dichloroethene, and 1,2-dichloroethene were present at
concentrations greater than 5,000 /ig/l during at least one sampling event. Benzene
concentrations were much lower (100 and 470 /ig/l/ respectively). ChemicaUspecific ARARs
were exceeded for several VOCs.
Groundwater samples collected from bedrock well M-21 contained TVOC concentrations
ranging from 387 /ig/l to 1,035 /ig/l. VOCs were not detected in upgradient bedrock well
LR-2 during any of the LTMP events. The primary compounds .detected, in order of
decreasing concentration, were xylene, ethylbenzene, benzene, chloromethane,
chlorobenzene, toluene, acetone, and styrene.
Chemical-specific ARARs for several VOCs were exceeded in M-21. Based upon the SRI
bedrock groundwater data, in conjunction with the LTMP data for LR-8, OD-3 and OD-4,
the VOCs found in the vicinity of these wells occur in a narrow plume.
Total SVOC concentrations detected in the overburden monitoring wells ranged from 1 /ig/l
to 129 /ig/l. The only SVOC above ARARs is 2,4-dimethylphenol in LR-8. The highest total
SVOC concentration detected was in LR-3 (92 /ig/l), which is located side-gradient to the
containment system. The highest detected concentration for a single SVOC was di-n-
butylphthalate (76 /ig/l), also in LR-3. With the exception of benzene detected during only
one sampling round, VOCs were not detected at monitoring well LR-3 and di-n-butylphtha-
late was detected above chemical-specific ARARs in upgradient overburden wells LD-2 and
SWW-1. Therefore, these SVOCs in LR-3 are likely not to be site-related.
Chemical-specific ARARs were exceeded in LR-6 (naphthalene for all three sampling rounds)
and LR-8 (naphthalene for all three sampling rounds and 2,4-dimethylphenol for Spring
1991 and Fall 1991).
Six SVOCs were detected in samples collected from bedrock well M-21 in levels ranging
from 1 jug/l for butylbenzylphthalate to 45 /ig/l for 2,4-dimethylphenol.
Chemical-specific ARARs were marginally exceeded only in M-21 . Phenol was detected at
3 /ig/l; 2,4-dimethylphenol was detected at 45 /ig/l; and naphthalene was detected at 7
The following metals were detected in both filtered and unfiltered samples collected from
all of the wells that were sampled: aluminum at concentrations ranging from 59.9 /ig/l to
10,900 /ig/l, barium at concentrations ranging from 454 /ig/l to 1,640 /ig/l, calcium at
concentrations ranging from 118,000 /ig/l to 199,000 /ig/l, iron at concentrations ranging
from 67 /ig/l to 8,780 /ig/l, magnesium at concentrations ranging from 33,500 /ig/l to
69,400 /ig/l, manganese at concentrations ranging from 110 /ig/l to 4,480 /ig/l, nickel at
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concentrations ranging from 9.4 /ig/l to 173 /ig/l, potassium at concentrations ranging from
4,500 /tg/l to 198,000 /ig/l, sodium at concentrations ranging from 88,000 /ig/l to
155,000 /ig/l; and zinc at concentrations ranging from less than 2 /ig/l to 26.3 /ig/l. In
general, higher concentrations were observed in unfiltered samples.
Chromium was detected in unfiltered samples at concentrations ranging from 4.4 to 21.1
/ig/l, and copper was detected in unfiltered samples at concentrations ranging from 7.4 to
84 /ig/l. Vanadium was detected in unfiltered samples at concentrations ranging from 6.8
to 17.8 /ig/l. Chromium, copper, and vanadium were not detected in any filtered samples,
indicating that they are present in suspended sediments or colloids.
Arsenic was detected in filtered and unfiltered samples at concentrations ranging from 6.4
to 20.2 /ig/l. Arsenic was not detected in filtered or unfiltered samples from well M-22,
which is located immediately downgradient of the containment system. Concentrations of
arsenic ranged up to 18 /ig/l in upgradient bedrock groundwater samples collected during
the initial RI/FS at the. PAS site. Therefore, the arsenic concentrations detected are
considered to be within the range of local background concentrations. Cobalt was
sporadically detected in filtered and unfiltered samples at concentrations ranging up to 6.6
/ig/l. Lead was also sporadically detected in both filtered and unfiltered samples from all
three wells at concentrations ranging up to 4.1 /ig/l. Antimony, beryllium, cadmium,
mercury, selenium, silver, thallium, and cyanide were not detected in any of the
groundwater samples.
Chemical-specific ARARs for barium, chromium, iron, manganese, and nickel were exceeded
in well M-21. However, with the exception of nickel, the concentrations of these metals
detected at well M-21 were less than the upgradient wells including those at the East
Seneca Street Dump. The maximum reported concentration of nickel was 173 /ig/l which
is above the 100 /ig/l MCL. Therefore, nickel appears to be the only site-related metal in
groundwater. Nickel was detected in the leachate collection system at concentrations
greater than that detected in groundwater outside the containment system.
Surface Water and Sediment Quality
No VOCs or PCBs have been detected in surface water at the PAS site, but PCBs have been
detected in upstream surface water and sediment near the Fire Training School. The
surface waters near the PAS site were found to contain only trace amounts of SVOCs and
pesticides. TAL inorganics were detected at concentrations which are less than both
chemical-specific ARARs and upstream sample concentrations. Butylbenzylphthalate was
detected at slightly higher concentrations in downstream samples, but no chemical-specific
ARARs are available for this compound. Its detection in upstream surface water samples
indicates that it is probably due to a source located upstream of the PAS site. Phthalates
are commonly reported as false positive results because they are common laboratory
contaminants, and are also contained in plastic sampling gloves.
8
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Benzene (0.09/ig/kg at location SS-4B) was the only VOC detected in sediment during the
LTMP. However, benzene was detected in White Creek sediments upstream of the PAS
site during the original RI/FS (URS, 1985a). The only VOC detected in samples collected
during the SRI was 2-butanone at a concentration of 27 jig/kg.
Trace levels of Methoxychlor, endrin, ketone, 4,4'-DDE, 4,4'-DDT were detected in
upstream sediment samples from White Creek. Trace levels of Dieldrin, endosulfan II, 4,4'-
DDD, 4,4/-DDE, and 4,4'-DDT were detected in upstream sediment samples from Wine
Creek.
The Hazard Index, which reflects noncarcinogenic effects for a human receptor, was
estimated to be 1.7 for children from surface water, sediment, and-fish ingestion. It should
be noted that, while the Hazard Index associated with the ingestion of surface water,
sediment, and fish by children exceeds the acceptable level, it is uncertain whether the PAS
site is the source of this contamination, since there are several potential sources of surface
water and sediment contamination located upstream of the site.
PCBs were detected in six of the eight sediment samples. The most frequently detected
PCB was Aroclor-1254, which was reported in six samples at concentrations ranging from
7 Mg/kg to 5,500 /(g/kg. Aroclor-1260 was detected on White Creek at a concentration of
1,300 figAg/ and at the Smith's Beach wetland at a concentration of 36 /ig/kg. However,
Aroclor-1260 was also detected in upstream sediment samples at the Fire Training center
adjacent to White Creek. No PCBs were detected in Wine Creek just upstream of its
confluence with White Creek." Based upon the results of the qualitative ecological
assessment, a potentially significant impact may occur to mink, if present at the site,
because of their extreme sensitivity to PCBs.
The highest concentrations of SVOCs, pesticides, and PCBs are primarily located in areas
of low stream velocity, which allows deposition of fine-grained sediments and colloids to
which these constituents are adsorbed. Sediments upgradient of the PAS site have
elevated levels of PAHs, pesticides, PCBs, and metals.
Contaminant Fate and Transport
The data suggest that contaminants in the bedrock aquifer originated from within the con-
tainment system and have migrated vertically downward through the lodgement till.
The inferred source area for contaminants in the bedrock aquifer is the center of the
containment system where the lodgement till is relatively thin. Analytical results from a
monitoring well located northeast of the containment area indicate the contaminants from
this area are primarily volatile organic compounds.
Investigations at Adjacent Sites
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The upgradient East Seneca Street Dump, Niagara Mohawk Fire Training School, and Oswe-
go Castings site (see Figure 2) are potential sources of contamination to the PAS site.
Reports prepared for the NYSDEC indicate that both the East Seneca Street Dump and the
Fire Training School may have contributed to the contamination of the soil, groundwater,
surface water, and sediments in the vicinity of the PAS site. According to these reports,
volatile organic compounds, semi-volatile organic compounds, and metals were detected
in the groundwater at the East Seneca Street Dump. Because of the lack of data, it is not
clear if the volatile organic compounds are also contaminants of concern at the Fire Training
School. Available information suggests that the Fire Training School may be a source of
PCBs in the surface water and sediments in White Creek in the vicinity of the PAS site. In
addition, the Oswego Castings site remains a concern as a potential source which may be
contributing to PCB contamination in the wetlands adjacent to the Smith's Beach communi-
ty. PCB concentrations in the sediments are close to the values reported to cause adverse
reproductive and survival effects. Based upon the results of the qualitative ecological
assessment, a potentially significant impact may occur to mink if present at the site
because of their extreme sensitivity to PCBs.
SUMMARY OF SITE RISKS
Based upon the results of the Rl, a baseline risk assessment was conducted to estimate the
risks associated with current and future site conditions3. The baseline risk assessment
estimates the human health and ecological risk which could result from the contamination
at the site, if no remedial action were taken.
Human Health Risk Assessment
EPA conducted a baseline risk assessment to evaluate the potential risks to human health
and the environment associated with the PAS site in its current state. The Risk Assessment
focused on contaminants in the groundwater, subsurface soils, surface soils, and sediments
which are likely to pose significant risks to human health and the environment.
EPA's baseline risk assessment addressed the potential risks to human health by identifying
several potential exposure pathways by which the public may be exposed to contaminant
releases at the site under current and future land-use conditions. The baseline risk
assessment began with selecting contaminants of concern that would be representative of
site risks. The summary of the contaminants of concern for human health in sampled
matrices is listed in Tables 2 thru 8 for human health and the environmental receptors,
respectively. These contaminants include: arsenic, benzene, vinyl chloride, barium and
manganese. Several of the contaminants are known to cause cancer in laboratory animals
and are suspected to be human carcinogens. Several exposure pathways were evaluated
The baseline risk assessment assumed that the groundwater containment system was in place and that the
groundwater leachate was being pumped at a sufficient rate to contain the contamination within the containment
system.
10
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under possible on-site current and future land-use conditions. The exposure pathways
considered are shown in Table 3. The reasonable maximum exposure (RME), defined as
the maximum exposure that could be reasonably be expected to occur, was evaluated.
Under current EPA guidelines, the likelihood of carcinogenic (cancer-causing) and noncarc-
inogenic effects as a result of exposure to site chemicals are considered separately. An
assumption is made that carcinogenic toxic effects of the site-related chemicals would be
additive. The same assumption is made for noncarcinogens at the site.
Potential carcinogenic risks were evaluated using the cancer slope factors (SFs) developed
by EPA for the contaminants of concern. Cancer SFs have been developed by EPA's
Carcinogenic Risk Assessment Verification Endeavor for estimating excess lifetime cancer
risks associated with exposure to potentially carcinogenic chemicals. SFs, which are
expressed in units of (mg/kg-day)'1, are multiplied by the estimated intake of a potential
carcinogen, in mg/kg-day, to generate an upper-bound estimate of the excess lifetime
cancer risk associated with exposure to the compound at that intake level. The term
"upper bound" reflects the conservative estimate of the risks calculated from the SF. Use
of this approach makes the underestimation of the risk highly unlikely. The SF for the
compounds of concern are presented in Table 4.
For known or suspected carcinogens, EPA considers excess upper-bound individual lifetime
cancer risks of between 10"4 to 10*6 to be acceptable. This level indicates that an individual
has approximately a one in ten thousand to one in a million chance of developing cancer
as a result of site-related exposure to a carcinogen over a 70-year period under specific
exposure conditions at the site. The results of the baseline risk assessment indicate that
only the potential future exposure to the bedrock aquifer via ingestion posed an
unacceptable risk to human health (see Table 5).
The cumulative upper-bound cancer risk at the site is 7x10"4 for children and 8x10"4 for
adults. Hence, the risks for carcinogens at the site are not within the acceptable risk range
of 10"4 to 10"6 (see Table 5). The estimated total risks are primarily due to arsenic, which
contributed 29.45% to the carcinogenic risk calculations, and which was attributable to
ingesting water from the bedrock aquifer. This presents an unacceptable carcinogenic risk
for children, for example, of 7x10"4 (i.e., 7 additional persons out of ten thousand are at risk
of developing cancer if the groundwater is not remediated). Other than groundwater
bedrock ingestion, the other carcinogenic risks associated with the site are in the acceptable
range. These estimates were developed by taking into account various conservative
assumptions about the likelihood of a person being exposed to these media.
Noncarcinogenic risks were assessed using a hazard index (HI) approach, based on a
comparison of expected contaminant intakes and safe levels of intake (Reference Doses).
Reference doses (RfDs) have been developed by EPA for indicating the potential for adverse
health effects. RfDs, which are expressed in units of milligrams/kilogram-day (mg/kg-day),
are estimates of daily exposure levels for humans which are thought to be safe over a
11
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lifetime (including sensitive individuals). The reference doses for the compounds of concern
at the site are presented in Table 6. Estimated intakes of chemicals from environmental
media (e.g., the amount of a chemical ingested from contaminated drinking water) are
compared to the RfD to derive the hazard quotient for the contaminant in the particular
medium. The HI is obtained by adding the hazard quotients for all compounds across all
media that impact a particular receptor population.
An HI greater than 1.0 indicates that the potential exists for noncarcinogenic health effects
to occur as a result of site-related exposures. The HI provides a useful reference point for
gauging the potential significance of multiple contaminant exposures within a single
medium or across media. A summary of the noncarcinogenic risks associated with these
chemicals across various exposure pathways is found in Table 7.
Referring to this table, the Hazard Indexes were estimated to be 26 for adults and 15 for
children (both for future use) from ingestion of groundwater from the bedrock aquifer and
1.7 for children (for both current and future uses) from surface water, sediment, and fish
ingestion. All other Hazard Indexes were less than 1. It should be noted that while the
Hazard Index associated with the ingestion of surface water, sediment, and fish by children
exceeds the acceptable level, it is uncertain whether the PAS site is the source of this
contamination, since there are several potential sources of surface water and sediment
contamination located upstream of the site.
Uncertainties
The procedures and inputs used to assess risks in this evaluation, as in all such
assessments, are subject to a wide variety of uncertainties. In general, the main sources
of uncertainty include:
environmental chemistry sampling and analysis;
environmental parameter measurement;
fate and transport modeling;
exposure parameter estimation; and
toxicological data.
Uncertainty in environmental sampling arises in part from the potentially uneven
distribution of chemicals in the media sampled. Consequently, there is significant
uncertainty as to the actual levels present. Environmental chemistry-analysis error can stem
from several sources including the errors inherent in the analytical methods and
characteristics of the matrix being sampled.
Uncertainties in the exposure assessment are related to estimates of how often an
individual would actually come in contact with the chemicals of concern, the period of time
over which such exposure would occur, and in the models used to estimate the
concentrations of the chemicals of concern at the point of exposure.
12
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Uncertainties in toxTcological data occur in extrapolating both from animals to humans and
from high to low doses of exposure, as well as from the difficulties in assessing the toxicity
of a mixture of chemicals. These uncertainties are addressed by making conservative
assumptions concerning risk and exposure parameters throughout the assessment. As a
result, the Risk Assessment provides upper-bound estimates of the risks to populations near
the site, and is highly unlikely to underestimate actual risks related to the site.
More specific information concerning public health risks, including a quantitative evaluation
of the degree of risk associated with various exposure pathways, is presented in the Risk
Assessment Report
Central tendency is a statistical measure that identifies the single most representative value
for an entire distribution of values. It represents the mid-range risk scenario. In the PAS
risk assessment, the central tendency calculations for adult carcinogenic risks for residential
ingestion and inhalation of overburden groundwater decreased by an order of magnitude
when compared to RME risks.
13
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Ecological Risk Assessment
A four-step process is utilized for assessing site-related ecological risks for a reasonable
maximum exposure scenario: Problem Formulation a qualitative evaluation of contaminant
release, migration, and fate; identification of contaminants of concern, receptors, exposure
pathways, and known ecological effects of the contaminants; and selection of endpoints for
further study. Exposure Assessment"* quantitative evaluation of contaminant release,
migration, and fate; characterization of exposure pathways and receptors; and measurement
or estimation of exposure point concentrations. Ecological Effects /Assessment-literature
reviews, field studies, and toxidty tests, linking contaminant concentrations to effects on
ecological receptors. Risk Characterization-measurement or estimation of both current and
future adverse effects.
The ecological risk assessment began with evaluating the contaminants present in the
vicinity of the site in conjunction with the site-specific biological species/habitat information.
A qualitative field survey and habitat characterization of the PAS site identified potential on-
site habitats of concern: a grassy field overlying the capped area of the landfill and two
wetland habitats (White Creek stream run and the White Creek ponded marsh). Off-site
habitats of concern included the Wine Creek wetlands and the Smith's Beach marsh at Lake
Ontario, located to the north of the site.
Contaminants of concern related to the surface waters of these habitats included
aluminum, cyanide, and the pesticide DDT. The contaminants of concern in the
sediments located adjacent to and downstream of the site included four volatile organic
compounds, nineteen semi-volatile compounds, seven pesticides, three PCB mixtures, five
metals, and cyanide. A summary of the majority of contaminants of concern and the
environmental receptors is presented in Table 8.
Following a biological characterization of the resident species associated with the site, a
select list was developed for the purpose of assessing actual or potential risks that may
accrue to these receptors (and other similar species) when exposed to site-related
contaminants. Consideration was given to the economic and/or cultural value of species,
statutory concerns (e.g., threatened or endangered status), representation of different
trophic levels, habitat suitability, the actual species occurrence within the site environs, and
home ranges/ The selected organism list consisted of the Shortfall shrew and mink (as
terrestrial fauna), the mink, green-backed heron, and Spring Peeper (as organisms
dependent upon the aquatic environment, i.e., surface water and sediment), and the
fathead minnow (as a surface water only ecological receptor). In the qualitative ecological
assessment, literature-based values, indicative of contaminant concentrations that are
known to produce adverse effects to the receptors, were used to screen the affected site
media. Individual toxicity endpoints such as survival, reproductive effects, and growth
impacts were considered.
14
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The qualitative ecological assessment found that aquatic species and aquatic invertebrates/
in particular, are the most at risk as indicated by the similarity of detected surface water
and sediment values in the vicinity of the site to toxicity values. Sublethal effects of
contaminant toxicity may be occurring at the site. As some of the contaminants present
bioaccumulate, affected aquatic invertebrates may be posing a risk to upper trophic level
species who use them as a food source. The potential for transmitting risk through the
food chain is present for the fathead minnow, a resident species at the site, as PCBs have
been detected in fish collected from creeks at the site. In addition, the minnows are
expected to have continual exposure to elevated levels of aluminum, DDE, and DDT,
although this exposure is not likely to threaten fish survival. Although a definitive statement
cannot be made regarding impacts to the Spring Peeper and other amphibious life, the
contaminants aluminum and DDT/DDE are present at levels that strongly indicate toxicity
to these aquatic receptors. There is a potential risk to the green-backed heron through its
diet (a significant portion of its exposure) from DDT/DDE, PCBs, aldrin, and metals. PCB
concentrations in the sediments are close to the values reported to cause adverse
reproductive and survival effects. The shrew, typifying smalj mammals at the site, is
expected to have relatively low exposures to surface water/sediment, and thereby any
adverse health risks are assumed to be sublethal. Contaminant body burdens, however,
may transfer contaminants to higher trophic level organisms (e.g., mink and green-backed
heron). Reproduction or survival of these higher forms could be impacted via this transfer,
mostly caused by the bioaccumulable DDT/DDE, PCBs, aldrin, and some metals. Based
upon the results of the qualitative ecological assessment, a potentially significant impact
may occur to mink if present at the site because of their extreme sensitivity to PCBs.
Detected sediment levels are well within the range of values reported to cause reproductive
impairment and mortality, via their dietary (aquatic sources) exposure. An additional
investigation will be conducted to determine whether PAS is a source of this contamination.
It should be noted that, while the levels of PCBs, PAHs, and pesticides present in the
sediments (in the depositional areas of the creeks and wetlands) in the vicinity of the site
may pose an unacceptable risk to individual mink that might use the creeks and adjacent
wetlands as foraging areas, it is uncertain whether the PAS site is the source of this
contamination, since there are several potential sources of surface water and sediment
contamination located upstream of the site.
In summary, actual or threatened releases of hazardous substances from this site, if not
addressed by implementing the response action selected in the ROD, may present an
imminent and substantial endangerment to public health, welfare or the environment.
REMEDIAL ACTION OBJECTIVES
Remedial action objectives are specific goals to protect human health and the environment.
These objectives are based on available information and standards such as ARARs and risk-
based levels established in the risk assessment.
15
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Groundwater contamination has been detected outside the containment area in
concentrations above ARARs and background concentrations in the overburden and bedrock
aquifers. Therefore/ the following remedial action objectives have been established for
groundwater:
prevent potential future exposures to contaminated groundwater on-site, as well as
off-site in the area between the site and Smith's Beach;
restore groundwater quality to levels consistent with federal and state groundwater
quality and drinking water standards;
mitigate the off-site migration of contaminated groundwater.
DESCRIPTION OF REMEDIAL ACTION ALTERNATIVES
CERCIA §121(b)(1), 42 U.S.C. §9621(b)(1), mandates that a remedial action must be
protective of human health and the environment, cost-effective, and utilize permanent
solutions and alternative treatment technologies or resource recovery technologies to the
maximum extent practicable. Section 121(b)(1) also establishes a preference for remedial
actions which employ, as a principal element, treatment to permanently and significantly
reduce the volume, toxicity, or mobility of the hazardous substances, pollutants and
contaminants at a site. CERCLA §121(d), 42 U.S.C §9621 (d), further specifies that a
remedial action must attain a level or standard of control of the hazardous substances,
pollutants, and contaminants, which at least attains ARARs under federal and state laws,
unless a waiver can be justified pursuant to CERCLA §121(d)(4), 42 U.S.C §9621(d)(4).
This ROD evaluates in detail, three remedial alternatives for addressing the contamination
associated with the PAS site. The time to implement a remedial alternative reflects only
the time required to construct or implement the remedy and does not include the time
required to design the remedy, negotiate with the responsible parties, procure contracts for
design and construction, or conduct operation and maintenance activities at the site.
For each of the three remedial alternatives evaluated, three options for treatment/disposal
of the extracted groundwater and leachate are presented: discharge to the City of
Oswego's Eastside Wastewater Treatment Plant without any pretreatment, other than flow
equalization (the "POTW Option"); on-site treatment and discharge to the White/Wine
Creek (the "On-Site Treatment Option"); and off-site treatment and disposal at an approved
TSD facility (the "TSD Option"). Each of the three disposal options are discussed in detail
following the discussion of the remedial alternatives.
The remedial alternatives are:
16
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Alternative 1 - No Further Action
' Y" ,. s s^^ tf *vs t'A '?"* ^ ^ * >' ' yf'* " "- " s
^ * * ill11 v^»" - '%-*& *>A\\-> v^st^-is^ sj&s ^
P^IV^Uoii^^^^C .^\
Capital
Annual Operation & Mainte-
nance
Present Worth
Estimated Construction Time
^fcrv^&"
$115,000
$110,000
$1,450,000
2 months
;feoii^tey^
$1,220,000
$205,000
$3,750,000
6 months
..,? ^v^gf^*^TT"'» ^:
.'V^^5O^^?V
$0
$395,000
$4,870,000
On-going
The Superfund program requires that the "no-action" alternative be considered as a baseline
for comparison of other alternatives. At this site, the "no-action" alternative has been inter-
preted as the "No Further Action," since previously implemented remedial and removal
actions continue to provide hydraulic control of the existing containment system.
No Further Action involves continued operation of the source control remedial systems,
which includes:
a containment system (including a cover and a soil-bentonite slurry wall);
extraction and collection of leachate and overburden groundwater from within the
containment system;
treatment and disposal of the collected leachate and groundwater;
site security and access control by a perimeter fence;
continued site maintenance; and
long-term monitoring.
17
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Alternative 2 - Enhanced Source Control
Capital
Annual Operation & Mainte-
nance
Present Worth
Estimated Construction Time
V>>, x»V:'-?^f -; "V :
£,,r PQTW^:
$870,000
$140,000
$2,590,000
4 months
"'S-- "",<£'? ?'.." ','V- :
V Ori-site £:
?f * f s
$1,970,,000
$245,000
$5,040,000
8 months
4j>'y--n>*-v'-x^'>-, ?-"
& V'«n$0'H& **
" f X- ,.-^T-.^" «*/ V
$755,000
$560,000
$7,730,000
2 months
Enhanced source control includes the actions and technologies as described for No Further
Action, plus the following additional measures:
enhancing the present source control system by optimizing the leachate and
groundwater extraction rate and other operating parameters in order to achieve, to
the degree practicable, inward horizontal gradients in the overburden and upward
vertical gradients from the bedrock toward the containment system;
connecting downgradient residents in the Smith's Beach area using who are
residential wells to the public water supply to ensure that potential future exposure
to contaminants in the bedrock groundwater does not occur; and
recommending institutional controls on groundwater usage through deed restrictions
at the PAS site and downgradient from the site to and including the Smith's Beach
area.
This alternative relies on enhanced source control through optimization of pumping rates
and frequencies and other methods as well as natural attenuation of contaminants to
restore groundwater quality outside the existing containment system. The current pumping
rate is achieving hydraulic control, however, it is estimated that the rate(s) would be
optimized between the present 30,000 gal/month and about 50,000 gal/month to achieve
inward and upward gradients. An evaluation of potential methods for development of
hydraulic controls outside the containment system will be evaluated during the remedial
design. Potential methods which could be employed to provide enhanced source control
might include:
raising water levels in White Creek using the present dam in order to enhance
inward gradients along the northern side of the containment system;
18
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constructing a groundwater control trench along the upgradient, southwestern side
of the containment system to eliminate potential overtopping of outside groundwater
into the containment system in this location; and
maintaining low water levels in the leachate and groundwater collection systems by
controlling the pumping frequency and/or rate (potentially with automated controls)
in order to enhance inward horizontal gradients across the slurry wall (i.e./
groundwater flow inward rather than outward toward the slurry wall), and at the
same time enhancing upward vertical gradients from the bedrock.
Alternative 3 - Enhanced Source Control With Bedrock Groundwater Extraction and
Treatment
^^0^&n ;^x-:-'^^. /'/
Capital
Annual Operation & Mainte-
nance
Present Worth
Estimated Construction Time
>?PQf₯W/s
$1,110,000
$200,000
$3,600,000
8 months
v. ^ v
- " \On-site^ ^!
$1,940,000
$300,000
$5,660,000
1 year
. \ \ S S S V. SS
>f^>fsiJ^!f
990,000
$1,260,000
$16,670,000
6 months
This alternative includes the same components as Alternative 2 and adds extraction,
treatment, and disposal of groundwater from the bedrock aquifer downgradient from the
containment system, with the goal of achieving groundwater ARARs more quickly than with
Alternative 2 (all groundwater will be combined and treated and disposed of in the same
manner).
Under this alternative, bedrock extraction wells would be placed to intercept the
contaminants detected in the bedrock aquifer downgradient of the containment system.
The extraction wells would be located and pumped to effect drawdown in the area where
contaminated groundwater has been detected. So as not to adversely impact the vertical
hydraulic gradients beneath the existing containment system, a preliminary estimate of the
potential amount of bedrock groundwater that may be removed from the bedrock aquifer
in this area is very low, only one to two gallons per minute (gpm).
Summary of Treatment and Disposal Options
Three options for the treatment/disposal of the extracted groundwater and leachate were
evaluated: the POTW Option; the On-Site Treatment Option; and the TSD Option. These
treatment and disposal options do not impact the remedial alternatives' effectiveness or
19
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implementability with respect to other components. Each treatment and disposal option
provides a permanent solution which reduces the toxicity and volume of contaminants, and
provides for the discharge of treated effluent and the disposal of any treatment residue.
The treatment and disposal options are described in the following paragraphs.
POTW Option
This option provides for the discharge of ieachate and groundwater removed from the site
to the City of Oswego's East Side Wastewater Treatment Plant. The Wastewater treatment
plant is less than a mile from the PAS site and discharge from the site storage tank would
be conveyed to the wastewater treatment plant via a sewer connection to the Mitchell
Street sewer extension, which was constructed in 1989. Alternatively, if deemed appropri-
ate, the bedrock groundwater could be directly discharged by connection to the Mitchell
Street sewer; with a pipeline to the on-site storage tank, thus, eliminating the need to
cross White Creek and its wetland. The POTW Option cannot be implemented until the
facility completes an .upgrade and expansion of the existing system to 5.35 mgd by
November 30,1994, as required under a consent order with the NYSDEC. Additionally, the
PAS site would be considered a significant industrial user (SID) and would require an
industrial wastewater discharge permit. The permit would be obtained from the City of
Oswego and would regulate the Ieachate quality from the site. All the permits necessary
to allow the connection of the Ieachate to the sewer line can be obtained before the
completion of the upgrade/expansion. The construction of the sewer line connection can
be completed prior to the completion of the POTW expansion/upgrade.
A study conducted by the PRPs regarding the feasibility of discharging Ieachate from the
PAS site to the wastewater treatment plant indicated that the PAS Ieachate includes organic
contaminants that are amenable to treatment in a biological treatment system, such as the
one at the wastewater treatment plant. Also, the study indicated that the metals in the
Ieachate are low in comparison to the allowable levels at the wastewater treatment plant,
and would not inhibit wastewater treatment effectiveness or restrict sludge incineration.
Although the Ieachate would be classified as a RCRA-listed waste (waste code F039), it
would fall within the Domestic Sewage Exclusion, 40 CFR 261.4, and would not require a
RCRA permit for purposes of discharge to the wastewater treatment plant. The study
concluded that the PAS Ieachate would:
not affect wastewater treatment plant employee health and safety;
conform with the City of Oswego's pretreatment requirements; and
not impact the wastewater treatment plant's ability to comply with its effluent limita-
tions or sludge disposal requirements.
On-Site Treatment Option
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This option provides for the construction of an on-site treatment system for the leachate
and groundwater removed from the site and discharge to White or Wine Creek or to
groundwater. A preliminary, conceptual design was performed for the on-site treatment
and disposal option. The design study considered a flow rate up to 50,000 gallons per
month (1.2 gpm) with a treatment system. The design considered the New York State
Class C surface water quality standards as discharge criteria. The conceptual system for
on-site treatment and disposal at the PAS site might include equalization in an on-site tank,
coagulation/flocculation, filtration, ultraviolet (UV)/chemical oxidation, ion exchange,
pressure filtration of residual solids, and batch discharge from an on-site tank. The actual
components and sizing of the on-site treatment system would be determined during the
remedial design.
TSD Option
At present, the leachate and groundwater pumped from within the PAS site containment
system are being transported to the E. I. duPont de Nemours Co., Inc/s RCRA-permitted
TSD facility located in Deepwater, New Jersey for treatment and disposal. This option has
the flexibility to accommodate future changes in volume and contaminant loading of the
leachate and groundwater removed from the site.
SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
In selecting a remedy, EPA considered the factors set out in CERCLA §121,42 U.S.C. §9621,
by conducting a detailed analysis of the viable remedial alternatives pursuant to the NCP,
40 CFR §300.430(e)(9) and OSWER Directive 9355.3-01. The detailed analysis consisted
of an assessment of the individual alternatives against each of nine evaluation criteria and
a comparative analysis focusing upon the relative performance of each alternative against
those criteria.
The following "threshold" criteria are the most important and must be satisfied by any
alternative in order to be eligible for selection:
1. Overall protection of human health and the environment addresses whether or not
a remedy provides adequate protection and describes how risks posed through each
exposure pathway (based on a reasonable maximum exposure scenario) are
eliminated, reduced, or controlled through treatment, engineering controls, or institu-
tional controls.
2. Compliance with ARARs addresses whether or not a remedy would meet all of the
applicable (legally enforceable), or relevant and appropriate (pertaining to situations
sufficiently similar to those encountered at a Superfund site such that their use is
well suited to the site) requirements of federal and state environmental statutes and
requirements or provide grounds for invoking a waiver.
21
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The following "primary balancing" criteria are used to make comparisons and to identify the
major trade-offs between alternatives:
3. Long-term effectiveness and permanence refers to the ability of a remedy to maintain
reliable protection of human health and the environment over time, once cleanup
goals have been met. It also addresses the magnitude and effectiveness of the
measures that may be required to manage the risk posed by treatment residuals
and/or untreated wastes.
4. Reduction of toxicity, mobility, or volume via treatment refers to a remedial
technology's expected ability to reduce the toxicity/ mobility/ or volume of hazardous
substances/ pollutants or contaminants at the site.
5. Short-term effectiveness addresses the period of time needed to achieve protection
and any adverse impacts on human health and the environment that may be posed
during the construction and implementation periods until cleanup goals are
achieved.
6. Implementability refers to the technical and administrative feasibility of a remedy/
including the availability of materials and services needed.
7. Cost includes estimated capital and operation and maintenance costs/ and the
present-worth costs.
The following "modifying" criteria are considered fully after the formal public comment
period on the Proposed Plan is complete:
8. State acceptance indicates whether/ based on its review of the RI/FS reports and the
Proposed Plan/ the State supports/ opposes/ and/or has identified any reservations
with the selected alternative.
9. . Community acceptance refers to the public's general response to the alternatives
described in the Proposed Plan and the RI/FS reports. Factors of community
acceptance to be discussed include support/ reservation/ and opposition by the
community.
A comparative analysis of the remedial alternatives based upon the evaluation criteria noted
above follows.
o Overall Protection of Human Health and the Environment
For the present land-use scenario/ all alternatives are considered to provide nearly equal
protection to human health and the environment/ since there were no present risks defined
by the risk assessment. For the future land-use scenario/ Alternative 2 is considered to be
22
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more protective than Alternative 1 for mitigation of the future human health risk of inges-
tion of contaminated groundwater. Alternative 2 provides protection of human health
through the connection of downgradient residents in the Smith's Beach area using
residential wells to the public water supply and institutional restrictions related to the use
of the groundwater at the site and downgradient of the site to Smith's Beach. Alternative
2 also includes enhanced source control to mitigate any future release of contaminants
from within the existing containment system.
Since Alternative 3 involves pumping the groundwater in the bedrock aquifer/ it would
provide a greater degree of protection to human health and the environment than
Alternative 2. The three treatment and disposal option components are considered to be
equal for this evaluation criterion.
o Compliance with ARARs
Alternative 2 would attain ARARs more quickly than Alternative 1 due to the enhanced
source controls provided under Alternative 2. Both alternatives rely on natural attenuation
and source control to achieve compliance with groundwater ARARs outside the contain-
ment system. Alternative 3 includes extraction of the bedrock groundwater which should
achieve groundwater ARARs more quickly than the other options. The ARARs for restoring
groundwater quality to drinking water standards are listed in Table 1.
The three treatment and disposal option components are considered to be equal for this
evaluation criterion.
o Long-Term Effectiveness and Permanence
Potential future migration of the contaminants from the containment system would be
reduced by Alternatives 2 and 3 in comparison to Alternative 1, by optirhizing leachate/
groundwater removal system pumping rates and frequencies. For all alternatives,
contaminant concentrations due to previous releases to the groundwater would be at
present levels in the short-term. In the long-term. Alternative 3 would better reduce
contaminant concentrations in the bedrock aquifer. Bedrock groundwater pumping at this
site, however, could adversely affect the hydraulic control capability of the containment
system, as well as adversely impact the creeks and wetlands. If studies indicate that
bedrock groundwater pumping would adversely affect the containment system or the
wetlands, then it would not be implemented. Alternative 2 has less long-term reliability
than Alternative 3 because it relies to some extent on institutional controls on groundwater
usage, until drinking water standards are reached through natural attenuation.
Treatment and disposal of the collected leachate and groundwater by any of the treatment
and disposal options would be reliable and essentially equal in eliminating environmental
risks from treatment residuals.
23
-------
o Reduction in Toxicity. Mobility, or Volume Through Treatment
Alternatives 2 and 3 would reduce, toxicity, mobility, and volume of the contaminants more
quickly than Alternative 1 due to treatment of potentially higher volume of leachate and
ground water removed from within the containment system. The highest reduction would
be achieved via Alternative 3, since it involves the extraction and treatment of the bedrock
aquifer. The three treatment and disposal options would permanently reduce the toxicity,
mobility, and volume of contaminants for all alternatives and, therefore, be considered
equal.
o Short-Term Effectiveness
It is anticipated that the study, design, and implementation of hydraulic source control
enhancements for Alternatives 2 and 3 would be able to be accomplished relatively quickly
in the short term. In the short term, the bedrock groundwater pumping will stop further
contamination of the bedrock aquifer.
There are differences between the treatment and disposal options with respect to short-
term effectiveness. Since the off-site TSD Option is presently used, no time would be
needed for construction and implementation of this option to achieve protection. Hence,
there would be no adverse impact on human health and the environment
The POTW Option requires construction of the sewer connection pipeline, and'connection
of the tank to the pipeline which might take several weeks to complete. There would be
some potential for on-site accidents and worker exposure to contaminated media from
these construction activities. These risks would be minimized with proper health and safety
training and personal protective equipment. Also, there is some uncertainty as to the
period of time needed to complete the POTW expansion and receive the necessary
approvals for accepting the leachate and groundwater from the site. It is estimated that 1 k
years will be required to complete these activities. All the permits necessary to allow the
connection of the leachate to the sewer line can be obtained before the completion of the
upgrade/expansion. The construction of the sewer line connection can be completed prior
to the completion of the POTW expansion/upgrade. Additionally, the POTW must be
willing to accept the PAS leachate and issue the PRPs an SIU permit under its pretreatment
program.
As with the POTW Option, there would be some potential for on-site accidents and worker
exposure to contaminated media from the construction activities associated with the On-
Site Treatment Option. These risks would be minimized with proper health and safety
training and personal protective equipment. The On-Site Treatment Option would likely
take several months longer to design, construct and begin operation (early 1995) than the
POTW Option (late 1994).
24
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o Implementability
Each of the alternatives employs commonly available technologies, methods, and proce-
dures. No Further Action is already implemented and the additional actions included in
Alternative 2 could be implemented easily. Alternative 3 would be slightly more difficult
to implement than Alternative 2, since Alternative 3 involves the additional action of
pumping from the bedrock aquifer. A study will be conducted to determine whether
bedrock groundwater pumping would affect the hydraulic control capability of the
containment system adversely, or adversely impact the creeks and wetlands. If this study
concludes that there will be no adverse impacts, then the installation of the bedrock wells
will be easy to implement.
Implementability of the three treatment and disposal options is considered equivalent in
terms of their reliability, constructability, and operation. The on-site treatment option,
however, would require the performance of treatability studies to determine the design and
operating parameters of the treatment system. Connection of the leachate and groundwa-
ter collection system(s) 'to the sewer would be easily implemented. However, the Oswego
POTW must receive approval from the NYSDEC and EPA to accept the PAS leachate.
There are differences in administrative implementation for the three treatment and disposal
options. The POTW Option requires approval from the City of Oswego, EPA, and NYSDEC
to accept the PAS leachate and groundwater discharge. Additionally, the City of Oswego
must be in compliance with their discharge permit and have completed an up-
grade/expansion (scheduled for November 1994). An on-site treatment facility would
require compliance with New York State stream standards, but no formal permit would be
required. The TSD Option is presently implemented, and no additional administrative
requirements have been identified.
25
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o Cost
Cost estimates were developed for each of the remedial alternatives and treatment and
disposal options. The present-worth costs are calculated using a discount rate of 7 percent
and a 30-year time interval. The estimated capital/ annual operation and maintenance
(O&M), and present worth costs for each of the alternatives are presented below.
ix;t^v^
Capital
Annual O&M
Present Worth
;'^fe??f"5£H
Capital
Annual O&M
Present Worth
>.?£$'** 'f^sf*
Capital
Annual O&M
Present Worth
^"'^A&^Bth
POTW Option
$115,000
$110,000
$1,450,000
3^^&&i*tm
POTW Option
$870,000
$140,000
$2,590,000
";\:,y^ ^ ,;| Alternate
POTW Option
$1,110,000
$200,000
$3,600,000
**<^V;:>'V
On-site Option
$1,220,000
$205,000
$3,750,000
te-2 Casts :*>**: 'I-- .*
On-site Option
$1,970,000
$245,000
$5,040,000
'teSGxte ' ;v /';
On-site Option
$1,940,000
$300,000
$5,660,000
'Vg;V':^a^
TSD Option
$0
$395,000
$4,870,000
^i:S^^li
TSD Option
$755,000
$560,000
$7,730,000
'J^X'^""V*^?
TSD Option
$990,000
$1,260,000
$16,670,000
For each of the three alternatives, the POTW Option has the lowest present worth cost and
the TSD Option would be the most costly. For each of the treatment/discharge options,
the increase in costs from Alternative 1 ("No Further Action") to Alternative 2 (enhanced
source control) to Alternative 3 (enhanced source control plus bedrock pumping) is due to
the increase in volume of groundwater and leachate.
The capital costs of the POTW Option for each alternative includes the design and
construction of the sewer line connection to the Mitchell Street sewer. The annual cost for
this option includes operation and maintenance of the groundwater extraction, treatment,
and discharge system, operation and maintenance of the site cover, user fee paid to the
East Oswego POTW, and for long-term monitoring.
26
-------
The capital costs of the On-site Treatment Option for each alternative includes the design
and construction of the on-site treatment plant. The annual cost for this option includes
operation and maintenance of the groundwater extraction, treatment/ and discharge system
in addition to the operation and maintenance of the site cover, and for long-term
monitoring. The capital costs of the TSD Option for Alternatives 2 and 3 include installation
of additional investigatory wells, pumping tests and analysis and preparation of a report.
The annual costs for this option includes operation and maintenance of the groundwater
extraction, (at an increased pumping rate), and transportation and disposal fees, in addition
to the operation and maintenance of the site cover, and for long-term monitoring.
The least costly alternative and option is the "No Further Action" Alternative with the POTW
Option. The most costly alternative and option is Alternative 3 with groundwater and
leachate treatment/disposal at an off-site TSD facility.
o State Acceptance
NYSDEC concurs with the selected remedy.
o Community Acceptance
Comments received during the public comment period indicate that the public generally
supports the preferred remedy, however, there were some concerns that were expressed
related to the treatment and disposal of the leachate and groundwater from the PAS site
at the City of Oswego's wastewater treatment plant. The primary concerns were related
to the wastewater treatment plant's ability to adequately treat the contaminated
groundwater and leachate. Comments received during the public comment period are
summarized and addressed in the Responsiveness Summary, which is attached as
Appendix V to this document.
SELECTED REMEDY
After reviewing the alternatives and public comments, EPA and NYSDEC have determined,
that (subject to the outcome of the bedrock aquifer investigation referred to below)
Alternative 3 is the appropriate remedy for the site, because it best satisfies the require-
ments orCERCLA §121, 42 U.S.C. §9621, and the NCP's nine evaluation criteria for
remedial alternatives, 40 CFR §300.430(e)(9).
The major components of the selected remedy are as follows:
Alternative 3 incorporates all of the existing components currently at the site, including the
existing containment system (slurry wall, cover, and leachate and groundwater collection
systems); treatment and disposal of the collected leachate and groundwater; site security
and access control by the perimeter fence; site operation and maintenance; and long-term
27
-------
monitoring. Alternative 3 would also incorporate the following additional components:
enhancing the present source control system by optimizing the leachate and groundwater
extraction rate and other operating parameters in order to achieve inward horizontal
gradients in the overburden and, to the degree practicable; upward vertical gradients from
the bedrock toward the containment system; bedrock groundwater extraction and
treatment; connecting downgradient residents in the Smith's Beach area using residential
wells to the public water supply to ensure that potential future exposure to contaminants
in the bedrock groundwater does not occur; and recommending institutional controls on
groundwater usage through deed restrictions at the PAS site and downgradient from the
site to and including the Smith's Beach area.
This alternative also includes other potential methods for providing, to the degree
practicable, enhanced hydraulic gradient control of the existing containment system. The
feasibility of potential methods for development of hydraulic controls outside the contain-
ment system will be evaluated during the remedial design. Potential methods which could
be employed to provide enhanced source control include: raising water levels in White
Creek using the present dam in order to enhance inward gradients along the northern side
of the containment system; constructing a groundwater control trench along the upgradient,
southwestern side of the containment system to eliminate potential overtopping of outside
groundwater into the containment system in this location; and maintaining low water levels
in the leachate and groundwater collection trenches by controlling the pumping frequency
and/or rate, potentially with automated controls, in order to enhance inward horizontal gra-
dients across the slurry wall, and at the same time enhancing upward vertical gradients
from the bedrock.
During the remedial design, an investigation will be undertaken to better .define the extent
of contamination of the bedrock aquifer, to verify that the increased interim groundwater
removal pumping from the overburden aquifer within the containment system has created
upward vertical gradients between the bedrock and overburden aquifers, to determine the
potential effectiveness of pumping to contain impacted groundwater in the bedrock outside
the containment system, to evaluate the hydraulic potential to restore the bedrock aquifer's
water quality, and to determine potential impacts of bedrock groundwater pumping on
vertical gradients beneath the containment system and the creeks and wetlands. Should
the results of this investigation determine that bedrock pumping will be an effective means
of addressing the contamination in the bedrock aquifer without adversely impacting the
existing containment system or the creeks and wetlands, then an analysis to determine the
rate of extraction and the location of the bedrock extraction wells will be performed,
followed by implementation of the bedrock groundwater extraction and treatment. Should
the investigation indicate that bedrock groundwater pumping will have a significant, adverse
28
-------
impact on the containment system or the creeks and wetlands, this decision will be
documented in a pre-rerhedial design study report concurred upon by New York State4.
The preferred option for the treatment and disposal of the leachate and groundwater for
the selected alternative is the POTW Option, which provides for discharge of the leachate
and groundwater removed from the PAS site to the City of Oswego's wastewater treatment
plant. Selection of the POTW Option is contingent upon final acceptance of the PAS
discharge by the City of Oswego, as well as approval by EPA and NYSDEC. In the event
that the POTW Option cannot be implemented, the On-Site Treatment Option would be
implemented for treatment and disposal. The On-Site Treatment Option provides for the
construction of an on-site treatment system for the leachate and groundwater removed
from the site and discharge to White or Wine Creek or to groundwater. The components
and sizing of the treatment system would be determined during the remedial design. The
treatment and disposal of the leachate and groundwater via the off-site TSD will continue
until a final treatment option is selected and implemented.
Since there is some uncertainty related to the source of the pesticides detected in the
surface water of the adjacent creeks and the PCB contamination in the sediments in the
depositional areas of the creeks and wetlands, in conjunction with evaluating the data
generated by the ongoing and planned studies related to the adjacent East Seneca Street
Dump, Niagara Mohawk Fire Training School, and Oswego Castings sites, a study will be
conducted to determine the source of contamination to the surface water and sediments
located in the adjacent creeks and wetlands. If, based upon these investigations, it is deter-
mined that the contamination in the adjacent creeks and wetlands is attributable to the PAS
site, then remedial alternatives to address this contamination will be evaluated.
«
Also, a floodplain delineation will be completed during remedial design, to determine
whether the site is located within the 100- or 500-year flood contours. If the site is located
within the 100- or 500-year floodplain and it appear that remedial activities will be
conducted in the floodplain, a floodplain assessment will be completed so that appropriate
measures can be incorporated into the remedial design, to protect against potential flood
impacts.
STATUTORY DETERMINATIONS
As previously noted, CERCIA §121(b)(1), 42 U.S.C. §9621 (b)(1), mandates that a remedial
action must be protective of human health and the environment, cost-effective, and utilize
permanent solutions and alternative treatment technologies or resource recovery
technologies to the maximum extent practicable. Section 121(b)(1) also establishes a
In accordance with CERCIA Section 117(c) and Section 300.435(c)(2)(i) of the NCR, .if bedrock groundwater pumping is not
implemented, then an Explanation of Significant Differences, describing the modification to the selected remedy and the basis for
the change, will be published
29
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preference for remedial actions which employ treatment to permanently and significantly
reduce the volume, toxicity, or mobility of the hazardous substances, pollutants, or
contaminants at a site. CERCLA §121(d), 42 U.S.C. §9621(d), further specifies that a
remedial action must attain a degree of cleanup that satisfies ARARs under federal and state
laws, unless a waiver can be justified pursuant to CERCLA §121(d)(4), 42 U.S.C.
§9621(d)(4).
For the reasons discussed below, EPA has determined that the selected remedy meets the
requirements of CERCLA §121, 42 U.S.C. §9621.
Protection of Human Health and the Environment
The selected alternative will mitigate future human health risk of ingestion of contaminated
groundwater through the connection of downgradient residents in the Smith's Beach area
using residential wells to the public water supply and institutional controls related to the
use of the groundwater at the site and downgradient of the site to Smith's Beach. The
selected alternative also includes enhanced source control to mitigate any future release
of contaminants from within the existing containment system and extraction of contaminat-
ed groundwater from the bedrock aquifer.
Compliance with ARARs
Attainment of chemical-specific ARARs outside the containment system in the overburden
and bedrock aquifers will be hastened by optimizing the leachate and groundwater
extraction rate and other operating conditions of the present source control system in order
to achieve, to the degree practicable, inward horizontal gradients in the overburden and
upward vertical gradients from the bedrock toward the containment system. In addition,
bedrock groundwater extraction will hasten the attainment of chemical-specific ARARs in
the bedrock aquifer. A summary of chemical-specific ARARS for specific contaminants is
presented in Table 1. Actjion- and location-specific ARARs will be complied with during
implementation.
Action-specific ARARs:
National Emissions Standards for Hazardous Air Pollutants
6 NYCRR Part 257, Air Quality Standards
6 NYCRR Part 212, Air Emission Standards
6 NYCRR Part 373, Fugitive Dusts
40 CFR 50, Air Quality Standards
30
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State Permit Discharge Elimination System
Resource Conservation and Recovery Act
Chemical-specific ARARs:
Safe Drinking Water Act Maximum Contaminant Levels and Maximum Contaminant
Level Coals (MCLs and MCLGs, respectively, 40 CFR Part 141)
6 NYCRR Parts 700-705 Croundwater and Surface Water Quality Regulations
10 NYCRR Part 5 State Sanitary Code
Location-specific ARARs:
- Clean Water Act Section 404, 33 U.S.C. 1344
Fish and Wildlife Coordination Act, 16 U.S.C. 661
National Historic Preservation Act, 16 U.S.C. 470
- New York State Freshwater Wetlands Law ECL, Article 24, 71 in Title 23
New York State Freshwater Wetlands Permit Requirements and Classification, 6 NYCRR
663 and 664
New York State Endangered and Threatened Species of Fish and Wildlife Requirements,
6 NYCRR 182
Other Criteria, Advisories, or Guidance To Be Considered:
Executive Order 11990 (Protection of Wetlands)
Executive Order 11988 (Floodplain Management)
EPA Statement of Policy on Floodplains and Wetlands Assessments for CERCLA Actions
New York Guidelines for Soil Erosion and Sediment Control
New York State Sediment Criteria, December 1989
New York State Air Cleanup Criteria, January 1990
SDWA Proposed MCLs and MCL Goals
31
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NYSDEC Technical and Operational Guidance Series 1.1.1, November 1991
Cost-Effectiveness
The selected remedy provides effectiveness proportional to its cost. The total present-
worth cost for the selected remedy is $3,600/000 for the POTW Option and. $5,660,000 for
the On-Site Treatment Option.
Utilization of Permanent Solutions and Alternative Treatment Technologies to the Maximum
Extent Practicable
The connection of downgradient residents in the Smith's Beach area using residential wells
to the public water supply is a permanent solution to meeting their drinking water needs.
Also, groundwater will be collected via permanent extraction wells and collection systems
and either treated off-site at a POTW or at a treatment system located on-site.
The selected remedy utilizes permanent solutions and treatment technologies to the
maximum extent practicable. The extraction and subsequent treatment of groundwater.will
permanently and significantly reduce the toxicity, mobility, and volume of contaminants in
the groundwater. The selected remedy provides the best balance of trade-offs among the
alternatives with respect to the evaluation criteria.
Preference for Treatment as a Principal Element
The statutory preference for remedies that employ treatment as a principal element is
satisfied by all three groundwater and leachate treatment options.
DOCUMENTATION OF SIGNIFICANT CHANGES
There are no significant changes from the selected alternative presented in the Proposed
Plan.
32
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APPENDIX I
FIGURES
-------
LCV-I LOCATION AND OESGNATION OF LEACHATE COLLECTION WEJ.
LD-3 LOCATION AND OESGNAT1ON OF OVERBURDEN MONITORING *LLS
A M-a LOCATION AND OESGNAHON OF BEDROCK MONITORING WEU.
A SVM-1 LOCATION AND COGNATION OF SURFACE-WATER MEASURING PONT
-* X- FENCE 200
scale
CD
2 0
200
SOURCE: GERAGHTY & MILLER, INC. (1992)
feet
933-6131
OR Br.
MRM
8T:
REV 6T:
AS SHOWN
OATTJ
04/08/93
FU£ No.:
NY01-309
OR SU87I11£:
02
EXISTING MONITORING WELLS
AND CROSS SECTION LOCATIONS
Golder Associates
SRI / FS PAS SITE
ncuBE
-------
SOURCE: BASE MAP. TAKEN FROM U.S.G.S.
7.5 MINUTE QUADRANGLE OSWEGO
EAST. NEW YORK, DATED 1954,
PHOTOREV1SED 1978.
2000
^
scale
2000
J3
feet
JOB Nix:
933-6131
OR BY:
MRM
CHK err.
REV BY:
SCALE;
AS SHOWN
04/08/93
FILE No
NY01-318
OR Suai)Tl£:
02
AREA MAP
Golder Associates
SRI / FS PAS SITE
FIGURE-
-------
LOCATION AND DESIGNATION
" OF SOIL BORING
-* X- FENCE
0 V
SOURCE: GERAGHTY & MILLER, INC. (1992)
200
E5
scale
200
3
feet
933-6131
OR BY:
MRM
CMK ST.
REV BT:
AS SHOWN
04/08/93
NY01-308
OR SU8T1TUE:
Q2
SRI SOIL BORING LOCATIONS
Golder Associates
SRI / FS PAS SITE
-------
APPENDIX n
TABLES
for Groundwater Sample Results
-------
AlKiUbl IUUJ
I'ROJBCT NO. 033-0131
SIJMMAIIY tX: OVEITUUnOEN GHOUNDWA1KII DATA ANDFEOEITAIJSTATE
CHEMICAL-SPECIFIC AIMIta
1*11 I U1ION ABATEMENT SEHVICCS SITE
OaWEOO. NEW YOIIK
CAS No
75 01-4
7S-OCI -3
75- nil- 2
07- U4-- 1
75-34-3
Mil 5U-O
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ina-io-i
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HOICS: 1
CONSinUliNr INHUMATION
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AuUtuilly
(Slulu>):
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(Y« » / No)
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( N
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FEDERAL SAFE
DUNKING WATER
ACT
MCI.
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40 (Til
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(Hulavonl ft
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s
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uiiliiica with Mio NCP.
2 S i. Slumbiil. (| - NYSDEO (julduncw vuluu. wlilcli Ii 'To be uoiiblJuiutr. mil AIIAII.
3 luiil I'Untiiul Oipiulc Coiituiiiliuiila (POCs) mill (IntiwcllluUOiuinkJ Oiinkiiiiliiuiils (IKXJa) inuy not u>cnuil IINI ii(|A.
4 Piuliiiiliiuiy lloiuu Juilkxi (ioulj aia llaloil lix uimlyloi willed oncuuil AllAlla ul unil ilownuiuilluill ol tliu bltu. hill wtiluli U\i nol oxcuod ARARa U|j()iuilluiil ol Iliu ill*.
ft HA - m>ui|,|ilUulilo;NI> - nol ikiluciuil. uiinik 5|«cu» li»ai:ulu llmliiiivnhiiiliua houn iiulillsliiwl iimlur Iliutliuiluiiiliuilly.
f«g. I el I
-------
IUU3
. U33-S13I
SIIMMAMY tx: III.OIKM:K QIIOUNOWA ii:it DATA ANII HtomwivaiATE
CIIEMICAI.-SPECIFIC AIIAIU
1-011.U1ION AUATEMENT SERVICES SITE
USWEUO. NEW YOIIK
CONtnilllLNI INTOMMA1ION
CAS Mo
75 01-4
75-1)0-3
/i-00-2
67-04-1 '
75-35-4
75-34-3
540-59-0
107-00-2
71-55-0
V9-UI--0
M:43:2
IOO-OU-3
ioa-uo-7
IIXI-41 -4
11)0-4? i
1330-20-7
05-bO-l
IOO-B5-2
KM -44-5
IOS-<>7-8
01- 20-3
IOO-47-U
UI-S7-0
B4-IUI-2
U4 -74-2
05-00-7
117 Ul 7
117-04-0
3IU-B4-0
3OO-OO-2
SI03-71-0
5103-74 -2
7420-00-5
7440-30-2
744O-30-3
ConsllliMiil:
Authority: .
(Slulus):
WIYI Cl II OHIOE
Cl II orK>E IIIANE
MEIIIYlENECIIIOIVnE
ACETONE
i.i-nciiionoETiiENE
1. 1 -mci ii OHOE DIANE
1 2-nclllonOEHIENE (lolal)
i 2-ncnioROEiHANE
i i.i- in/a ii onoE THANE
llllCHIOnOETIIENE
(ItN/EHE ' . ,
TOIIIEtlE
CIHOIKHICNZENE
Ellin lllll^ENI:
SIVIttlJE
XYI tNt'S (lolil)
.2-f»Clim(IOUEN2ENE
1 IENOI.
-MEIimi'llENOl
4-OIMEIIIYI PI IENOI.
AI'IIIIIAII;NE
-CIIIOIIOANIIINE
-MKIIIYINAPIITIIAIENE
EIIIYIPHIHALATE
N- IIUIYIPIIIIIAIAIE
UTYI.UEN/YIPHTIIAIAIE
S-(2- EIIIYIIIEXYtjI'llTIIAI ATE
- N - OC 1 Yl n (THAI. A TE
I.PIIA--UIIC
1 OHM
AMI.1A CIIIOIUIANE
UMINIIM
ARIUM
IJpUiudtanI
Cor :untallon
llunuu ul
CoiisUlutml
NA
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
. NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
MO
NO
NO
Nl> "
NO
NO
NO
NO -1000
NO- 14
34-3700
OownuiuUluii
Coiicuillulloi
Hunouol
Consliluunl
(u(VI)
NA
ND-32
NO -47.
ND -!(.))
NO-2JJJ
NO-O.B(J)
NO-4J)
ND-ll
NO-4(JJ
NO- 100
NO-2J.I)
NO-IUO
NO -US
NO -34
NO-IUO
NO-:i(J)
NO -670
ND-pyj
ND-3(J)
NO-2(.I)
NO -45
N0-7(.l)
NO-3(.I)
NO-Ofl(.l)
NO-I(J)
NO -711
ND-16
NO- 12
NO-3|.I)
NO-0.0043(.IP)
D-00064(.)N)
NO-O02O(.II'|
O-OUU34(.IP)
SO.O-IOUOO
NO-2II2
454-1040
MuKlfiium Cuiiceiikallaii
Gfuulur Dun ARAlb
Oownuiacllenl
(Yus / No)
NA
Y
Y
N
N
N
Y
Y
N
Y
N
Y
Y
Y
Y
N
Y
N
Y
Y
Y
N
'N
N
N
Y
N.
N
N
Y
Y
N
N
N
N ;
Y
Upuiutllsnl 7
(Yei / No)
NA
N
N
N
N
N
N
N
N
/N"
N
N"
N
N
N
N
N
N
N
N
N
N
N
N
N
N
N
N
N
7
7
7
7
Y
N
Y -
EEWVOnK
kTE CI.ASU
(MINI) WATUH
lUAUTY
MCL
(UyVl)
40CFH
Sec. 141.11-
141.10
(Holuvonl &
A|i|iio(Mlale]
2
S
7
S
200
5
5
IOOO
KM)
700
IOC
IOWXJ
60(1
100
2
2
no
2ixm
SMCI..
40CFR
Sec. 143.3
(Raluvoiil &
.
SO-2OO
MClQs
(ilU/l)
40CFH
iec. 141
(noiiivuiii &
A|j(ilo|)iluli>) (1)
leio
tutu
7
zero
200
1010
lulu
IOOO
100
71X1
100
IOOOO
600
leiu
IUIO
IUIO
/BIO
zono
Slununrd (2)
(uo/l)
NYCnn. Title 0
Seel. 701-703
(Applicable)
2(9)
5(9)
5(9)
f^ 5 (9|
1 5(9)
5(5)
6(9)
5(9)
0.7 (9)
S(9)
5(9)
5)9)
5(9)
5(9)
4.7 (9)
NEW YOIIK
STATE
DUNKING
WATIill ACT
MCU
(UQV1) (3)
NYCIW. Title 10
Part 5-1
(Relevant &
Ap|.io|iilulu)
21-1
5 (POC)
S(I-OC)
so (uoc)
s (PCX:)
P1UHIMINAHY
ICMIilNATIHN
GOAL
(U||/l) (4)
40CFO
Pail 300
'2.
S1 _
1 NA
NA
! NA
5 (POC) 1 S
S(POC)
5 (POC)
/ 6 (POC)
5 (POC)
5 (POC)
5 (POC)
S (POC)
SjPOC) 1
5 (POC) 1
S(POC)
S(POC) |
i (9) so (UOC) I
5
S
NA '__
0.7
5
S
S
NA
S
NA
1
i(» so (UOC) i
1 (9) SO (UOC) |
10(0)
6(»)
50(0)
. 60 (0) '
50(0)
N0(»
NO (9)
O.I (9)
O.I (9)
2S(.)
IOOO (>)
so (UOC)
I
NA
5 (I'OC) I NA
so (uoc) 1
50 (UOC) I
so (uoc) 1
SO (UOC) 1
so (uoc)
NA
NA
50
NA
NA
SO(UOC| I NA ,
5 (POCJ
S (POC) '
2
2
so
2OOO
NA .
NA I'
NA }
NA '
NA 1
NA 1
Qoklff A«««Cl»bl
a* * *'
-------
AllUtlSl 1W)3
NO. 031-0131
8IIMMAHY ITT- llCnrWCK UROUNDWATER DATA AND FEDERAL/STATE
CHEMICAL-SPECIFIC AIWU
POI.I.llilON ABATEMENT SERVICES SITE
OSWEQO, NEW VOHK
CONSTITUENT INFORMATION
CAS No
7«0-fO-2
7440-47-3
7440-50-6
M3U-8U 6
7439-02-1 1
7439 - US \ 4
7430-66-5
7440-02-0
744O-00-7
7440 - 23 -S
7440-tia-a
Conallluenl:
Authority: .
(Stulu»): '
CALCIUM
CHROMIUM
COWEH
IRON
EAD
MAGNESIUM
MANQANESE
NICKEL .
OTASSIUM
SODIUM
AHC
Upomilonl
Concentallon
Range ol
Constituent
(uort)
NA
150OO-47IOOO
NO-22
NO -20
244-12000
NO-B
10400- IBSOOO
45.55- 10700
NO -92.2
I30O-59IOO
4010-2771001)
4.2-4S
Oowno>utienl
Concanlalkxi
Rungeol
Conallluent
I11CUMINAITY
(HMEINAT10N
GOAL
(U0fl) «)
40CFR
Part 300
NA
NA
NA
NA
NA I
NA I
NA 1
too
NA
NA
NA |
NOTES: 1. Only non - »io MCLQa aia ARAR In accotdunca wllh lha NCP.
2 S - SluiKbid, B « NYSOEC guldi'ice vuhie. wlilch la "To ba conaldoieiT. not ARAH
3 loUl Piinclijal Ofuunte ConUniliiaiita (P()Cs) and Unipecllled Otuunlc CunUmlnunb (UOCa) muy not exceod IOO uoA.
4 I'lulliiiliiuiy lluinoOaUoii Uoula ate lilted lot unntylaa which exceuil AHARa ul and duwnuiadleiil ul the alle. l»il wlilcli ilo not exceed ARAHs li|>um«l> «>> '//» >
-------
August 1993
IABLE 1 (cont'd)
933-6131
REMEDIAL ACTION OBJECTIVES
MEDIA TO PROTECT HUMAN HEALTH:
Groundwater Prevent ingestion of water containing the following
contaminants which are either (1) present at
concentrations greater than ARARs (or background,
whichever is greater). (2) calculated to present a
potential carcinogenic risk greater than 1E-04 to IE-OS.
or (3) calculated to present a potential for non-carcinogenic
health effects, based upon a Hazard Quotient greater than 1.
WATER-BEARING MAXIMUM
UNIT
Overburden
CHEMICAL
Benzene
Chlorobenzene
Chloroethane
1,1-Dichloroethane
1,2-Dichloroethane
1,2-Dichloroethene (total)
Ethylbenzene
Methylene Chloride
Toluene
Trichloroethene
Vinyl Chloride
Xylenes
2,4-Dimethylphenol
4-Methylphenol
Bedrock
CHEMICAL
Benzene
Chlorobenzene
Chloroethane
1,1-Dichloroethane
1,2-Dichloroethene (total)
Eihylbenzene
Toluene
1 ,1 .1 -Trichloroethane
Vinyl Chloride
Xylenes
Di-n-butylphthaiate
4-Methylphenol
2.4-Dimethylphenol
Phenol
Nickel
DETECTED
DOWNGRADIENT
CONC(ug/I)
680
16
180
56
8
23
640
3
160
9
33
1900
63
33
MAXIMUM
DOWNGRADIENT
CONC (ug/I)
100
34
47
49
8
180
95
180
32
670
76
2
45
3
173
LIMITING
ARAR(ug/l)
0.7
5
5
5
5
5
5
5
5
5
2
5
1
1
LIMITING
ARAR (ug/1)
0.7
5
5
5
5
5
5
5
2
5
50
1
1
1
100
CANCER RISK
1.60E-04
2.00E-04
CANCER RISK
1.60E-04
2.00E-04
Re:REMOB9-1.WK1
Golder Associates
Page 1 of 1
-------
TABLE 2
PAS OSWEGO SITE
EXPOSURE POINT CONCENTRATIONS (E?Cs)
!hemical» ot Potential Concern:
S3% UCU
Maximum
S.=C
Valalil» Oreaniea
USenzana
I Chloride
||Arsenic
Barium
fuc-1)
18
9.0
NA
NA
MA
(uc;t)
6eO
33
NA
NA
NA
48
S.O
jggQROCX
I Volatile Oroanica
|8enzena
Vinyl .Chloride
JSgmivQlatHe Crcarics
llNone
[iBarium
<1 angaries*
(ug.1)
120
Z9
'.200
1.2M.OOO
("9')
34
32
20
1500
4400
(us.1)
84
1=
20
13GO
dor-1248
or-1260
!|Dieldrin
a-Chlorcar.8
Arsenic
jBarium
jBarylfium
Cadmium
niutivVI
V
al
" »GII
(ucAg)
73,000.000
3300
180
ISO
.4.7
71
0.3S
0.92
2.0
'.ICO
15
a
(ucyVg)
2200
£50
43
2S
(mgykg)
5.1
SO
0.38
1.2
1100
18
22
(ug/Vg)
2200
650
43
4.7
71
0.36
O.S2
2.0
1100
16
'.8
1 0.042
0.17
78
11
260
0.0073
0.013
76
12
230
O.C073
0.013
11
220
gggmivoianle Organics
lBeozo(a>pyr«n«
i|P»sneTe>3/PC3 s
HHeptacnlor Epoxida
4Aroci6r-1248
j|AroeoM2£4
iArocor-1260
flrjofcjrtcs
lAraanic .
IBarium
IMancanaaa
iJNicVet
JVan»cium
.uc/to;i
7300
7400 1
280
19
2200
7tOO
170
(mcyXg)
!
1200
1SOO
730
35
1SCO
=500
1300
Img/Vg)
3.9 j 12
5oO ! . 2500
1.9 3.1
17CO 1 3400
33 j . 39
2E 48
^=.<5) |
:KO ]
1SOO |
«0 |
:V \
'SOO |
3:00 1
:ro 3
!rnc,-Vg) 1
;.9
=30
:.9 3
TOO j
23 ij
-
ftaimx
NA: Cvorourcen weils not analyaa Icr inorganics.
-------
TABLE 3
PRESENT-USE SCENARIO
PAS OSWEGO SiTc
IDENTIFICATION OF EXPOSURE PATHWAYS
MEDIA
GROUNDWATE5
SOILS
SURFICIAL
SUBSURFACE
SURFACE WATEH
SEDIMENTS
RECEPTOR
POPULATION
Resident
Commercial/
Industrial
Employees
Trespassers
Construction
and Utility
Workers
Residents
Residents
EXPOSURE
ROUTE
Ingestion
Dermal Contact
Inhalation
Ingestion
Dermal Contact
Inhalation
Incidental Ingestion
Dermal Contact
Inhalation
Incidental Ingestion
Dermal Contact
Inhalation
1
Incidental Ingestion
Dermal Contact
Inhalation
Fish ingesiion
Incidental Ingestion
Dermal Contact
RETAINED FOR
QUANTITATIVE
ANALYSIS
No
No
No
No
No
No
No
No
No
No-
No
No
Yes
Yes
No
Yes
Yes
Yes
COMMENT
Residences on public water, except one well at Smith's Beach.
Commercial and industrial properties on public water.
-
Known contaminated areas covered by cap system and
other areas within the fence covered with vegetation.
Pathway will be qualitatively evaluated.
No excavation activites being conducted at site.
Low levels of contaminants detected in surface waters.
Two VOCs detected in site samples. a
-------
TABLE 4
PAS OSWEGO SITE
TOXICITY VALUES FOR POTENTIAL CARCINOGENIC HEALTH EFFECTS
DOSE - RESPONSE RELATIONSHIP (t)
CHEMICALS
Volatll* Orginlc*
Acetone
Benzene
2-Buianona
Chtorobenzane
Chloreetfiane
Chlcrofonn
1.2-Oichloreaihane
1.1-Diehtoroeihena
1.2-Otchloroe-3-me»iylphenoi
1 . 2-Oichlorobenz8ne
1 ,4-Dichlorooenzene
2.4-Oimetnylphenol
Fluoranthene
lndano<1 ,2.3-ed)pyrene
2-Meihylaaphlhalena
4-Meoiylnapiuhalane
2-Metfiylphanol
4.Me«iylahenol
N-Nitrasodipnenylamin*
Naphthalene
Nitrobenzene
PhenanOirena
Phenol
Pyrene
PntlcUfiiKB*
Aldrin
Alpha-3HC
Baia-BHC
Dalta-aHC
Gamma-SHC (Lindana)
Alpha-Chlordana
Gamma-ChlonJane
4.4'-000
4.4--OOE
4.4--OOT
Dioidnn
Endoadlan
Endrin
Endrin Alosnyde
Keptacnlor
HeptacMor Epoxide
Memorychwr
PC3s (Anxiors)
OralSf
(moAq-davl-1
2.SOE-02
-
-
.
6.10E-03
9.10E-02
6.00E-01
.
6.70E-02 (2)
.
7.50E-03
.
.
.
.
S.70E-02
1.106-02(3)
1.90E.OO (2)
-
.
7.ME-OJ"
-
7.30E.OO
7.30E-01-
-
7JOE-01"
.
1.40E-02
-
.
7.30E-02-
-
7.30E.OO"
-
.
.
.
2.40E-02 (2)
.
-
7.30E-01-
.'
.
.
.
490E-03
-
.
.
.
I.70E.01
6.30E>00
1.80E<00-
1.3QE>00(2)
1.30E>00
I.30EUM
2.40E-01
3.40E-01
3.40E41
1 60E.O1
-
.
".
4.SOEWX)
9.10E.OO
7.70EXX3
CARCINOGENS:
SLOPE FACTORS (SF)
Inhalabon SF
.
Z90E-02
.
.
8.10E-02
9.IOE-02
1.20E.OO
.
.
.
1.65E-03
.
,
5.70E-02
6 OOE-03 (3)
3.00E-01 (2)
-
.
.
6.10E-01"
.
S.10E,00(2)
6.10E-01"
.
6.10E-01"
.
-
.
.
S.10E-02"
.
6. IDE .00"
.
.
.
.
.
6.IOE-01"
.
.
.
-
.
.
-
1. TOE ,01
630E.OO
t.SOE^OO
.
.
I.30E.OO
1.30E.OO
.
3.40E-OI
1.60E.01
.
.
4.SOE>00
9.10E.CO
-
Weight ol
-
0
A
0
0
62
B2
C
0
B2
D
B2
_
0
0
C
82
A
0
0
D
B2
0
B2
B2
B2
B2
.
82
C
.
B2
0
B2
0
.
.
D
C
.
0
82
.
.
C
C
B2
0
0
0
0
0
32
B2
C
D
B2-C
82
B2
B2
32
32
32
.
B2
B2
0
32
-------
TABLE 4 (Cont'd)
'PASCSWEGOSIIt
TOXtC:TY VALUES FOR POTENTIAL CARCINOGENIC I lEALTl I ErFE<~TS
COSE RESPONSE RELATIONS! IIP (I)
CIltUICAI.S
fnarg>n/c>
Arsonic .
Banum
Bwyllium
Cadmium (load)
Cadmium (waiaf )
Chromium III (insol. »alir '
CVomium VI (insol. tall)
Cobalt
Coppw
Laad (and compoundj-inorg.)
ManQonesa
Mercury (inorrjanic)
Mckal (sal. salt)
Mckol (raenocy duji)
Vonaaum
Zinc (and compounds)
Cyanide llreet
CARCINOGENS:
SI OI'E FACTOIIS (UH) j
Oral Sr Inhalaucn Sr
(mr.Vn Oav)-l Iir.o/Vo Onvl 1
17£E.OO . 1EOE.OI
.
430E.OO 840E.OO
6 30£ .00
6206,00
42oe,oi
-
-
a-io&oi
V/airjni ol
Eviikiticn
A
.
B2
Ol
Ol
- .
A
.
0
93
0
0
A
0
0
NOTES.
Aluminum, calcium, iron, magnesium, puiassum ana soaium ara csnsidarud sssunnal miirumts ana v»ul 1101 Du qui/iuiatrvuly
in ma n» assoumant
'Taiiaiy Equivalency Factors (TE.-s) usofl in caniuncun win s;ooo laciars per £?A guiusnca
(I) Alt toiidiy value* obiainad from IRIS ion-line Ocisoer 20. Novamow 2-11. 1992. April 12. 1993) unloss jihunwv, .-.oioa
(2) Toiksiy valu«s obtained tram HEAST Annual FY-1992.
(3) Toiiciy values obuined Irom na Supill>auiil uvtuuncu at carcnorjuiai:iiy n anun.iii .uid in.uii
-------
CWAVAIJI^.XIS
PAS OSWEQO SITE
COMBINING CARCINOGENIC RISKS ACROSS PATHWAYS
ML:f)IA
GROUNDWATER-
OVERBURDEN
GHOUNDWATER-
BEOROCK
SURFACE WATER.
SEDIMENT, AND FISH
INGESTION
SUBSURFACE SOIL (
I
RECEPTOR I EXPOSURE
POPULATION 1 ROUTE
Resident: 1
Adults llngosllon
(Inhalation (Showor model)
(Total Carcinogenic Rlik »
Children |lngesllon
jlnhalallon (Showor modol)
Molal Carcinogenic Risk
Rosldanl: 1
Adult) llnnosllon
(Inhalation (Showor modol)
(Total Carclnoganlc Risk
Children llnoosllon
Jlnhalallon (Shower model)
(Total Carclnorjanlc RUk
Rosldonl. 1
Adtills llnoeallon (Sui/oce Water)
lOarinal Contact (Surface Water
flngusllon (Sediment)
(Dermal Contact (Sodlnionl)
llngesllon (Fish)
(Total Carctnoganlc Rick
Children llnoosllon (Suiluco Water)
Joermel Contact (Surface Water
llngesllon (Sediment)
[Oermal Contact (Sediment)
llngesllon (Fish)
JTolal Carcinogenic RUk -
2onslriicllon/
Jlilily Workers Ingoslion
Oeimol Contact
Inhalation
Tola) Carcinogenic Rl«k a
INDIVIDUA
CANCER RIS
2.20E-04-
2.20E-OS
2.4E-04'
1.90E-04
1.90E-05
2.1E-04'
7.7E-04
3.7E-OS
O.IE-O'I'
6.8E-04
3.2E-05
7.IE-04'
I.4E 08
0.8E-10
1.2E-05
1.4E-OG
7.0E-OS
9.6E-05-
3.8E-08
1.2E-09
2. IE -OS
6.1E-06
6. IE-OS
8.8E-OS'
I.7E-06
I.OE-06
8.3E-09
2.7E-06'
Cl IEMICAL CONTRIBUTING THE GREATEST
AMOUNT TO RISK
Vinyl Chloiido
Benzene. Vinyl Chloilde
Benzene, Vinyl Chlorldo 1
Vinyl Chloride 1
Bonzene, Vinyl Chloride I
Benzene, Vinyl Chloilde 1
Ai sonic, Vinyl Chloilde 1
Donzono, Vinyl Chloride 1
Arsenic, Uonzono, Vinyl Chloildu 1
Arsenic. Vinyl Chloride I
Bonzene, Vinyl Chloride 1
Arsenic, Benzene, Vinyl Chlorldo 1
Aroclor-1248, Aroclor-1254, Bonzo(a)pyrone, Arsenic I
Aroclor-1254 I
Oleldrin 1
Aroclor-1240. Aroclor-t2S4, Benzo(ti)pyrano, Arsenic, Dloldiin 1
1
1
Aldrin, Aroclor-1248, Aroclor-1254, Arsenic, Benzo(a)pyrene 1
Afoclor-1248. Aroclor-1254 1
Oleldrin
Idrin, Aiocln(-1240, Aroclor-1254, Arsonlc, Bonzo(o)pyrene, Dloldrln 1
Aroclor-1248. Aroclor-1260, Arsonlc 1
Aroclor-1248 ; 1
1
Aroclor-1248. Aroclor-1260, Arsenic I
.Halfii
Sile woikers (cornmerclal/lndiislrlul) were only evaluated lor groundweler Inrjesllon exposure, therefore no exposure pathways could be combined.
* Indicates Diet the total carcinogenic ilsk exceeds 1.0E-O6.
Indicates Uiol the total hazerd Index exceeds 1.
- Indicates (hat the carcinogenic risk or noncarclnogunlc hazard Index does not exceed target values; therefore no chemicals were seluclod as conlrihulors.
128
-------
TABLE 6
PAS OSWEGO SITE
CHRONIC TOXICITY VALUES FOR POTENTIAL NONCARCINOGENIC HEALTH EFFECTS
DOSE RESPONSE RELATIONSHIP (1)
CHEMICALS
Volilllf Orytnlcf
Acetone
Benzene
2-Sutanone
Chlera benzene
Chloroethane
Chlofu'onn
1 . 1 -Oichloroe tfiane
t.2-0ichloroethane
1.1-Oehloroetiene
l.2-0ichloroeh»ne (mixed)
1.2-Oichloropropane
Elhylbenzene
Melhylene Chloride
4-MetfiyM-P»ntanon9
Sryrene
Toluene
t . 1 . 1 -TrieWoroe tfiane
1.1.2-Trichtenaeihane
Trichloroethene
Vinyl Chloride
Xylenes (Total)
' SftnivoMUt Orgtnla
Acenapihene
Anthracene
Benzo(a)tnthncene
Benzole Acid
Benzo(»)pyren»
Benzo(b)Huoranitiene
Benzo(g.h.i)perylene
3enzo(k)nuoranttene
Benzyl alcohol
Bis(2-einylhexyl)phthalale
Buiyfcenzylphthetaie
4-Chloroaniiine
Chrysene
Di-n-buivlphtfialata
DibenzoJt.h'piHDiracsne
Oiathyl phlhalata
Di-n-ocrylpntfialaie
4-Chloro-3-methylphenol
1.2-Oichlarabenzene
l.4-0iehlorebenzene
Fluoranthene
Indanol i ,2,3-cd)pyi«ne
2-Melhylnaphlhalene
4-Melnylnaphihalene
2-Meinylphenol '
4-Meihylphenol
N-Nitrosodphenylamine
Naphthalene
Nitrobenzene
Phenuiftrone
Phenol
Pyrene
Ptitlcldn/PCS*
Aldrin
Alpha-BHC . .
Beia-BHC
Oelta-SHC
Gamma-BHC
Alpha-Chlordane
Gamma-Cnloiaane .
4.4--000
4.4--OOE
4.4--OOT
Oieidrin
Endotullan
Endm
Enorin Aldehyde
Hepucnlor
Heptachlor Epoxide
Meihoiychlor
PC8c (Arodort)
NONCARCINOCENS:
REFERENCE DOSES/CONCENTRAT1ONS (RIO, RfQ
Oral RIO
(muVo/dav)
I.OOE-01
.
SOOE-02 (2)
2.00E-02
.
1.00E-02 .
1.00E01(2)
900E-03
9.00E-03
I.OOE-01
SOOE-02
5.00E-02 (2)
2.00E-OI
2.00E-01
9.00E-02(2)
4.00E-03
6.00E-03 (4)
2.00E.OO
S.OOE-02
3.00E-01
.
4.00E.OO
.
.
.
.
2.00E-02
2.00E-01
4.00E-03
.
I.OOE-01
a.ooE-01
2.00E-02 (2)
.
9.00E-02
3 onfji?
£.UUCAJ£
4.00E-02
.
S.OOE-02
S.OOE-03
-
4.00E-02 (2)
5.00E-04
.
6.00E-OI
3.00E-02
3.00E-OS
-
.
3.00E-04
S.OOE-05
6.00E-OS
.
1
S.OOE-04
S.OOE-05
50CE-OS
3.00E-04
.
S.OOE-04
1 .306-05
S.OOE-03
Uncertainly
Factor
1000
« *
1000
1000
.
1000
1000
1000
1000
.
1000
100 ..
1000
' 1000
1000
1000
1000
3000
.
100
-
3000
3000
-
1
.
.
.
.
'.
1000
looo
3000
.
1000
1000
1000
.
1000
3000
3000
-
1
1000
1000
1000
10000
.
too
_3000
1000
-
.
1000
1000
1000
-
-
100
100 '
3000
100
-
300
1000
1000
'
Inhalation RIC
(meAo/dav)
.
.
2.90E-01
5.70E-03(3)
2.90E-00
.
1.40E-01 (3)
.
.
.
1.10E-03
2.90E01
8.60E-OI (2)
Z30E-02 (2)
2.50E-OI (2)
1.00E-01
2.90E-01 (3)
'.
.
.
.
.
.
.
.
.
.
.
.
-
-
5.70E-02I3)
2.00E-01 (2)
-
-
-
S.70E-04 (3)
-
.
.
.
-
-
-
-
-
-
*
i
Unceruiniy
Factor
'".
.
1000
10000
.
.
1000
.
.
.
300
300
100
1000
30
300
1000
.
.
.
-
.
.
.
.
.
.
.
.
.
.
.
.
.
.
-
» "
1000
too
-
-
-
10000
-
-
-
-
.
.
.
.
-
-
-
-
.
-
-
-
-------
PAS OSWEGO SITE
CHRONIC TOXICITY VALUES FOR POTENTIAL NONCARCINOGENIC I IEAI.TI I EFFECTS
DOSE - RESPONSE RELATIONSHIP (1)
. i
CHEMICALS ;
Inorgtnlc*
Arsenic
Barium
Beryllium
Cadmium (food)
Cadmium (wolor)
Chromium III (Insol. soil)
Chromium VI (Insol. sail)
Cobalt
Coppar
Load (and compounds-inorfl.)
Manganese (lood)
Manganese (water)
Mercury (inorganic)
Nickel (sol. salt)
Nickel (refinery dust)
Vanadium
Zinc (and compounds)
Cyanldo (Iroo)
NONCARCINOCENS:
REFERENCE DOSES/CONCENTRATIONS (RID, RFC)
Oral R'O
(mfj/Krj/day)
3.00E-04
7.00E-02
5.00E-03
1.00E-03
5.00E-04
t.OOE+OO
500E-03
-
1.3 mg/r (2)
-
1.40E-01
S.OOE-03
3.00E-04 (2)
2.00E-02
-
7.00E 03 (2)
3.00E-01
2.00E-02
Uncertainly
Factor
3
3
100
10
to
too
500
-
-
-
1
1
1000
300
'
too
3
too
Inhalation RIC
(mo/kfj/day)
-
1.40E-04(3)
. ' ::
-
-
-
-
-
1.10E-04
l.tOE-04
8.60E-05 (2) .
.
-
-
-
-
Uncertainty
Factor
.
1000
-
-
-
-
.
-
-
300
300
30
-
-
-
- - '
-
n
§
rt
NOTES:
- Aluminum, calcium, iron, mngnosium. potassium und sodium ore considorod essential nutrients and will not bu quantitatively evaluated
in Hie risk assessment.
- Hie inorganics lead and copper cannot bo quantitatively evaluated due to insufficient loxicily data.
* Current drinking water standard ol 1.3 nip/I OWCO (1987) concluded loxicily data were inadequate for calculation of an RIO for copper.
(I) All loxicily values obtained from IRIS (on-line October 30. November 2-11. 1992, April 12, 1993) unless otherwise noted.
(2) Toxlcity values obtained from HEAST Annual FY-1992.
(3) Toxicily values obtained from HEAST Annual FY-1992: Toxicity values are found in Agency documents but wore calculated by alternative
methods not currently practiced by the RID/RIG Woik Group.
(4) Toxicily value obloinod from Superlund Health Technical Support Conliir. Ducombor 7. 1992.
-------
TABLE 6 (Cont'd)
PAS OSWEGO SITE
SUBCHRONIC TOXICITY VALUES FOR POTENTIAL NONCARCINOGENIC HEALTH EFFECTS
DOSE - RESPONSE RELATIONSHIP (1)
«
NONCARCINOGENS: SUBCHHONIC PFFPBFNCP DOSES fflfQsl AND REFERENCE CONCENTRATIONS (RfCst
Oral RIO
(mg/kg-day)
Uncertainty
Factor
Inhalation RIC
(mg/Vg-day)
Uncertainly
Factor
CHEMICALS
VolaUlt Orgmlc*
Benzene
1.2-0lchloroath«na (mixed)
Ethylbenzen*
Toluene
1.1.1-TrlcnIoroethane
Trichloroelhene
Vinyl Chloride
Stmlvolattif Organic*
Beruo(a)pyrena
Beruo(b)fluoranthene
Bls(2-«thylh8xyl)phthaJate
2.4-Olmethylphanol
4-Methylphanol
P»ttlcldaa/PC8»
Aldrin
bata-BHC
Chlordana (3)
Dlaldrin
Haptachlor Epoxida
PCBs (Arodors) (4)
Inorganic*
Arsenic
Barium
Beryllium
Cadmium
Chromium VI (Insol. salt)
Manganese
Nickel
Vanadium
Zinc (metallic)
Cyanide (free)
9.00E-03
1.00E+00
2.00E+00
g.ooE-01
100
100
100
- 100
2.SOE-01
5.70E-01
2.90E+00 (2)
300
100
100
2.00E-02
2.00E-01
3.00E-05
6.00E-OS
S.OOE-05
1.30E-05
3.00E-04
7.00E-02
S.OOE-03
2.00E-02
1.00E-01
2.00E-02
7.00E-03
2.00E-01
2.00E-02
1000
300
1000
1000
100
1000
3
3
100
100
1
300
100
10
£00
1.40E-03(2)
1.10E-04
100
900
NONCARClNOGgNS; SUSCHRONIC REFERENCE POSES fflfDsl AND REFERENCE CONCENTRATIONS fRfCa)
NOTES:
Aluminum, calcium. Iran, magnesium, potassium and sodium are considered essential nutrients and will not ba quantitatively evaluated
In the risk assessment.
- The Inorganics lead and copper cannot be quantitatively evaluated due to insufficient toxidty data. '
- All Inhalation RtCs were converted from mg/m3 to mg/kg/dayOising the formula presented in HEAST Annual FY-1992.
(1) Toxlcity values obtained from HEAST Annual FY-1992.'
(2) Toxlcity values obtained from HEAST Annual FY-1992: Toxicity values are found in Agency documents but were calculaled.by alternative
methods not currently practiced by the RID/RIC Work Group.
(3) The toxJdty value tor chlordane was used for the alpha-chlordana Isomer.
(4) All Arodors detected at the site were assigned (he toxidty values for Arodor-1260.
EPA WEIGHT OF EVIDENCE:
A Human Carcinogen
B1 - Probable Human Carcinogen. Limited human data are available.
B2 - Probable Human Carcinogen. Sufficient evidence of carcinoganicity in animals and inadequate or no evidence in humans.
C - Possible Human Carcinogen
0 - Not Classifiable as lo human carcinogenicity.
E - Evidence of noncardnogenicity for humans.
-------
WIWM
PWAVADO2.XLS
PAS OSWEQO SITE
COMBINING NONCARCINOGENIC HAZARD INDICES ACROSS PATHWAYS
MEDIA
GROUNDWATER-
OVERBURDEN
QROUNDWATER-
BEDROCK
SURFACE WATER.
SEDIMENT, AND FISH
INQESTION
SUBSURFACE SOIL (
I
RECEPTOR
POPULATION
4 1
Resident:
Adults
Children
Resident
Adults
Children
Resident:
Adults
illclfon
Construction/
Jlllily Workers 1
C
ll
T
EXPOSURE
ROUTE
digestion
Inhalation (Shower model)
Total Hazard Index
Ingesllon
Inhalation (Shower model)
Total Hazard Index
Ingestlon
Inhalation (Shower model)
Total Hazard Indax «
Ingesllon
Inhalation (Shower model)
Total Hazard Index «
..
ngestlon (Surface Water)
Dermal Contact (Surface Water
ngeslton (Sediment)
Dermal Contact (Sediment)
ngesllon (Fish)
Total Hazard Indax »
ngestlon (Surface Water)
Dermal Contact (Surface Water
noosllon (Sediment)
ermal Contact (Sediment)
gesllon (Fish)
otal Hazard Index
igesllon
termal Contact
ihalallon
otal Hazard Index «
INDIVIDUAL
HAZARD INDE!
NA
NA
NA
NA
NA
NA
28
NA
26"
15
NA
15"
7.3E-03
4.5E-04
2.2E-02
1.6E-04
3.0E-OI
0.33
8.4E-03
2.6E-04
2.0E-01
NA
1.5
1.7"
1.2E-01
NA
3.6E-02
0.16
CHEMICAL CONTRIBUTING THE GREATEST
< AMOUNT TO HAZARD INDICES
»
.
Arsenic, Manganese
"
Arsenic, Manganese
Arsenic, Barium, Manganese
Arsenic, Barium, Manganese
-.-
-
-.
-
--
Dleldrln, Manganese
Dleldrln, Manganese
-
;
'
Indicates that the total carcinogenic risk exceeds 1.0E-06.
" Indicates that the total hazard Index exceeds 1.
Indicates that the carcinogenic risk or noncarclnogenlc hazard Index does not exceed target values; therefore, no chemicals ware selected as contributors.
NA: The total hazard Index could not be calculated for residents es only carcinogenic VOCs were detected In overburden wells.
: The total hazard Index could not be calculated for residents as only .carcinogenic VOCa and Inorganics were delected In bedrock wells.
: The hazard Index .could not be calculated for child dermal contact with sediment as no trbchronlc loxlclty value was avallble for cadmium.
: The hazard Index for conslrucUonAitlllly worker dermal contact with subsurface soil could not be calculated as Aroclors do not have noncarclnogenlc loxlclty values.
-------
'CABLE 8
SUMMARY OF ECOTOXCITV VALUES
REPORTED M THE LITERATURE
PAS SITE. Olw*go. N*w Vork
MINX
SHOHTTAl SHREW
GREEN HERON
SPRING PEEPER
FATHEAD MINNOW
AQUATIC INVERTEBRATES
PAS SITE COCS
(Muimum d«*aad vahMll
Out Ha Availabl*
Out Hal Availabl*
Data Noi Available
Oat Ha Avail**
1. Acua 1C SO ol 32-37 ug,1 tot
latfwed mmott.
2 ChronicLC. SO 01022 toe. '
ravbow Iroul.
1. CIuoracLC 50 ol 57 ug,1 tor
Oaphnia maona
SEO-730ug/kg
Dau Not Available
Data Not Avertable
Data Noi Available
leopard**.
2.LCSO ol627uorfal|H<3lar
buflboa. larva*.
I. Sfenncam lo.oly u pin* banwa
IIM bog 0.2 mo* pH 4.4.
1. Acute LC SO olSS.OOOuoyl tor
juv*nl* lathead minnow.
2 Reduced weigM rt chrome
ipaun* ol Z300 ua/l la lattwait
l>o»LCSOol t.MOug/llor
CariodaphniaduUa.
sw-«au»)
Daia Not AvailaBI*
Oaia Not Availabl*
Oaia Not Availabl*
Daia Not Availabl*
Oaia Not Available
SED- 2470mg/Vg
Data N« Ava
-------
TABLE 8 (Cont'd)
SUMMARY OF ECOTOXCITY VALUES
REPORTED IN THE LITERATURE
PAS SITE. Oiwego. New York
MINK
SHORTTAI SHREW
GREEN HERON
SPRING PEEPER
FATHEAD MINNOW
tOUATC WVERTEBRATES
PAS SITE COCS
IMaiimum oeieaed value*)
CHROMIUM
Out Not Available
Ova Net Available
Oaia No) Available
1. lOO%morla»ylnR»na
igrina udpote* aler 72 -hour
ipature u 2 ug/l.
1. Acute LC SO o(41. 090 ugit
lor encomium (VI) end 10.320
ug/l lor ovorokjm (01) en
lauvMd mhnow'
2. Clvonic 1C X al 1.987 u»vl
to chromium (VI) lor uuhead
minnow.
t . Acute LC SO ol 23 07 ug/l lot
SED- 42.5 mgAg
CALCIUM
Daii Not Available
Data Noi Available
Data Noi Available
Dau Not Available
Oaia Noi AvatfaM*
Dan Not Available
SEO- 20.600 ing/kg
COBALT
Dill Not Avaibbla
0
lainaad minnow.
2. Chionlc LC SO ol IS 39 H» laihuo
1 . Acui> LC SO ranot Irom S3 10
2 490 uoyt tor Irtsnwaior
nvafieoratM.
2. Chronic LC SO rang* bom 16 lo 40
uo/1 lor lr*shwai«r invwiaoraia*.-
SW- I2uo4
RECEPTOR
MINK
SHORTTAIL SHREW
GREEN HERON
SPRING PEEPER
FATHEAD MINNOW
AQUATIC INVERTEBRATES
PAS SITE COCS
- iMaxtfnumoaMaed vahmt
OOT/OOE
Data Not AvailabK
DM. Na AmtaoM
. knpairad nprooueoon oUapano*
quail M Oai ol 300 mg OOTAo body
MlgM. NotggiWdwtwnladTOO
fflgAg.
1. AOM LC SO ol 7.6 me/kg body
MlgM.
1. ACUM LC SO ol 48 uo/1 tor laowad
mkmow.
2.ChmmcLCSOol0.74uoyllor
laihMiliMwow.
1. Acuw 1C SO ol 2.4 ujxl lor Oapnraa
nwona.
SW - DOT: 0.0020 uo/1. ODE: 0.0047
uoyi
SED DOT: 74 119*0, DDE: 41 ua/ka.
HEPOHTEO VALUES II)
DIETHYLPHTHALATE
Data Noi Available
Oaia Noi Avatobto
Oua Not Available
Data Noi Available
1. Acme LC SO ol 98.000 uoyl lor biueojll.
1 . Acue LC SO ol 52. 1 00 uo/l lor
Oaonnia magna.
I SED 4« uo/kq
GAMMA CHLOROANE
Oaia Noi Available
Oaia Noi Available
1. LO SO ol 14.1 ing/kg body weigni lor
California quad.
2. 57-day LO SO ol 1 .5 mgikg diet lor
europeon iiartmg.
1 . Acute LC 50 ol 2 mo4 lor common
load.
1 . Acute LC X ol 37 ug/l lor lathead
minnow.
1. Aeura LC SO values tango bom 3 10
ISOugyl.
2. Chronic LC SO ol 16 ugrt lot a
cladoceran jp»ci«
SEO - 076 uo/Vg
-------
TABLE 8 (Cont'd)
SUMMARY OF ECOTOXICITY VALUES
REPORTED IN THE LITERATURE
PAS SITE rtaweoo. New Yom
MINX
SHORTTAH. SHREW
GREEN HERON
SPRING PEEPER
FATHEAD MINNOW
AQUATIC INVERTEBRATES
I PAS SITE COCS
1 iMaiimum d«eaed valueil
HEPTACKLOR EPOXIDE
Oaia NM Available
Oaia Noi Available
Da» Noi Available
Data NM Available
I.ACUMLC 50 value* tor
Irnhwaur ten bom 5 3io 120
0*1.
1. Aoute LC SO V*!UM tor
headwater invenebrale* from
120 ug/1 10 greater man 1 0.000
ugrt.
SED 35 ug/kg
1 MAGNESIUM
Data Noi Available
Data Na Available
Data Noi Available
Data Not Available
Data Not Available
Data Noi Available
SED - 8.960 mo/kg
4-METHYLPHENOL
Oaia Not Available'
Data Not Available
Daia Not Available
Daia Noi Available
1. 24-hour median ilutsoM limit ol 7
mo/1 tor imui embryo*.
2. 24-hour and 96-hour median
threshold Hmiii ol appnuimaiely 1 1 a
mo/1 lor blueoill.
Oaia Not Available
SED-UOugAg
NICKEL
Oaia Not Avalable
1. 92% moruuy over a 30-day
period when mallard dueUlnai
w«re M a dial ol 1.200 maylq
Oaia Not Avaiabl*
1 AcuwLC 50 ol 8.027 uo/l lor
laiMad mmow.
2. Chronic LC SO ol 526 7 u^
tor lainud minnow.
1 Aeuw LC SO ol SS4 4 ug/l lor
Oaphraa mtgna.
2. Chronic LC So ol 14.77 uo/l
tor Daphnia maona n Ml
waiw.
SEO-38.1moyXg
1 . Oial LO 50 ol S40 mo/ng body
woioni tor rail.
Oaia Not Avaiabl*
Oaia Noi Avaiabi* -
1. Median ihrosnok) bni ol20 . 24
mo/l per S-nout period In dlstled
water and 90 100 mgilper 6-hour in
hard water.
1 . Acwe LC SO ol 60 mo/I lor a
Oapnnia specie).
SED-40ug/kg
RECEPTOR
MINK
' SHORTTAL SHREW
GREEN HERON
t
SPRING PEEPER .
FATHEAD MINNOW
AOUATC INVERTEBRATES
PAS SITE COCS
(Mailmum deieoed vui*»
REPORTED VALUES 1 1)
N-NITROSOOIPHENYIAMINEI
Oau Not Anaable
1 . Rata led diata o4 t.OOO
m»(Xfl tar 100 weeka produced
Oaa Noi Avalabto
Data Not AvmOe&U
1. Acute LC 'SO olS.UOua4
lorbttegl
1 . Acute LC SO ol 7.760 uayl tor
0.
Oaia Not Available
PAHl
DaiaNoiAvaaabl*
Oaia No) Available
Data Not Available
Data Not Available
1. Aeue LC 50 ol 7.7 ugyl tor laihead j 1. 55-hour LC 50 ol 1.8 ug/l lor
mrmow. ; laiDead minnow lor benzo(a)
anthracene.
2. Chronic LC 50 value* olO 2 to 2.3 2. 00* mortally m bluegil eipoaed 10
ug/l tor teheed mmow. : benioiaJpYrene.
1 . Acute LC 50 ol 2* ug/l lor a tcud
apede*.
2. Chronic LC SO ol 4.3 ug/l tor
Capnni* magna.
SED Amour 1248: 1.900 uoAo.
Arodor 1254: 5.500 ugikg
Arodor 1260: 1.300 ug/kg,
1. One-hour LC SO ol 4 ug pyreneil
lor Oaphnla magna.
2. 24-hour LC SO ol 0.7 ug/l
b*ruo
-------
SUMMARY OF ECOTOXICITY VALUES
REPORTED IN THE LITERATURE
PAS SITE, Oswego. New York
RECEPTOR
MINK
SI IORTT AIL SHREW
GREEN HERON
SPRING PEEPER
FATHEAD MINNOW
i
AQUATIC INVERTEBRATES
. PAS SITE COCS
|Mu»liiumi doloaod vuluos)
1.t,1-THICHLOROETHANE
Data No) Available
Data Not Available
Data Not Available
Data Not Available
1 . AcUtt LC SO lo< aquallc organisms
u« tow as 16,000 ugd. 1
. Acute LC 50 lor aquatic organisms
as low as 18.000 UQ/!.
SED - 0.4 tig/kg
REPORTED VALUES (1)
TOLUENE
Data Not Available
t. Deaih ol mlc« repotted at 10.000
mo/kg body weight.
Data No) Available
Data Nol Available
. Acute LC SO ol 34.270 ug/l lor falhuad
ilnnow.
. 48-hour EC SO values lor Daphnla
lagna horn 60,000/lo 313,000 ug/1.
SED 1 UQ*O
VANADIUM
Data Nol Available
1 . Oral LD SO ol 23 and 130 mo*0 body
wolglii lor various lornis ol vanadium In
Duia Nol AvalliUilo
Data Nol Avallalilo
1 .06 hour LC SO values lor Iroshwalor
sh from 5,000 to 100,000 119/1
. 06-hour LC 50 values lor Dafrimla
fip. hisallianO.teug/l.
SED 47.7 ug/kg
I
00
f-\
o
(I) Halai lo lex) lor roluicxtco cllul^m
EC SO dorKMim ellttdtve CM«ounlrai|on SO.
IC SO (JoiRMOt UHlwl owKXiMliullon SO.
I 0 SO UtiiMNM lullial doiui SO
SEO dorioliM MtdlmtMN.
ijw Uuiiuo* f4irlaou waior.
-------
APPENDIX m
ADMINISTRATIVE
RECORD INDEX
-------
POLLUTION ABATEMENT SERVICES SITE
OPERABLE UNIT TWO
ADMINISTRATIVE RECORD FILE
INDEX OF DOCUMENTS
1.0 SITE IDENTIFICATION
1.3 Preliminary Assessment Reports
p. 100001- Report Engineering Investigations at Inactive
100169 Hazardous Waste Sites. Preliminary Site Assessment. Niagara
Mohawk Fire Training School. SITE No. 738030.. prepared for
NYSDEC, prepared by URS Consultants, Inc./ October 1991.
p. 100170- Report Engineering Investigations at Inactive
100414 Hazardous Waste Sites. Phase I Investigation^ East Seneca Street
Dump. SITE No. 738027. prepared for NYSDEC, prepared by URS
Company, Inc., September 1989.
1.4 Site Investigation Reports
p. 100415- Report: Engineering Investigations at Inactive
100701 Hazardous Waste Sites, Phase II Investigation, East Seneca Street
Dump. SITE No. 738027. prepared for NYSDEC, prepared by URS
Consultants, Inc., June 1992.
3.0 REMEDIAL INVESTIGATION
3.1 Sampling and Analysis Plans
p. 300001- Report: Addendum to the Field Operations
300010 Plan Supplemental Remedial Investigation and Feasibility Study.
Pollution Abatement Services Site. Oswego. New York, prepared by
Geraghty & Miller, Inc. Environmental Services, January 29,1992,
(revised March 5,1992).
p. 300011- Report: Field Operations Plan Supplemental
300630 Remedial Investigation and Feasibility Study. Pollution Abatement
Services Site. Oswego. New York, prepared by Geraghty & Miller,
Inc. Environmental Services, May 1991.
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3.2
P-
Sampling and Analysis Data/Chain of Custody Forms
P-
3.3
300631-
300654
300655-
300972
300973-
301344
301345-
301554
301555-
301600
Work Plan
301601-
301661
301662-
301715
Letter to Mr. Richard Ramon, P.E., Remedial
Project Manager, Western New York Superfund Section I, U.S.
Environmental. Protection Agency Region II, from Mr. Richard Eby,
Project Scientist, Geraghty & Miller, Ms. Laine Vignona, Principal
Scientist, Geraghty & Miller, Inc., re: Leachate Collection System
Pumping Test Data, Pollution Abatement Services Site, Oswego,
New York, June 21,1991, Tables and Figures attached.
Report: Supplemental Remedial Investigation
Analytical Data Tables and Contract Laboratory Program Data
Validation Standard Operation Procedure Format For USEPA Region
II Pollution Abatement Services Site. Oswego. New York, prepared
by Geraghty & Miller, Inc., June 2,1992.
Report: Supplemental Remedial Investigation
Analytical Data Tables and Contract Laboratory Program Data
Validation Standard Operation Procedure Format for USEPA Region
II Pollution Abatement Services Site, Oswego, New York. Volume I,
prepared by Geraghty & Miller, Inc., February 6,1992.
Report' Supplemental Remedial Investigation
Analytical Data Tables and Contract Laboratory Program Data
Validation Standard Operation Procedure Format for USEPA Region
II Pollution Abatement Services Site. Oswego, New York. Volume II.
prepared by Geraghty & Miller, Inc., February 6,1992.
Report: Data Validation Tables, prepared by
Geraghty & Miller, Inc., (undated).
Report Final Work Plan. Oversight of
Supplementary RI/FS for the Pollution Abatement Services Site^
Oswego. New York, prepared by TAMS Consultants, Inc., June
1991.
Report Revised Work Plan for Supplemental
Remedial Investigation and Feasibility Study. Pollution Abatement
Services Site, Oswego. New York. Volumes I & II. prepared by the
USEPA, March 21,1990, revised by Geraghty & Miller, Inc.,
September 1990.
-------
p. 301716- Report: Final Supplemental Remedial Investigation
301776 Work Plan for Pollution Abatement Services Site. Oswego. New
York. Volume II, prepared by TAMS Consultants, Inc./ March 1990.
3.4 Remedial Investigation Reports
P. 301777- Report: Final Supplemental Remedial Investigation
302351 Report, Pollution Abatement Services Site, Oswego, New York.
prepared by Colder Associates/ August 1993.
p. 302352- Report: Report on Field Oversight of Supplemental
302480 RI/FS for Pollution Abatement Services Site. Oswego. New York.
prepared by TAMS Consultants, Inc., May 1993.
p. 302481- Report: Draft Site Summary Report Pollution
302693 Abatement Services Site. Oswego. New York. Volume I of II.
prepared by Ceraghty & Miller, Inc., August 1992.
p. 302694- Report: Draft Site Summary Report Pollution
302867 Abatement Services Site. Oswego. New York. Volume II of II.
prepared by Ceraghty & Miller, Inc., August 1992.
p. 302868- Report: Addendum I. Summary of the East Seneca
302883 Street Dump's Phase I and II Investigation and the Niagara Mohawk
Fire Training School's Preliminary Site Assessment, addendum to
Draft Site Summary Report, prepared by Geraghty & Miller, Inc.,
August 1992.
p. 302884- Report: Site Investigations and Remedial
303026 Alternative Evaluations at the Pollution Abatement Services (PAS)
Site in Oswego. New York. FINAL REPORT, prepared by URS
Company, Inc., January 1984, Revised 1985.
-------
303084-
303092
3.5 Correspondence
p. 303027- Letter to Mr. Richard Ramon, P.E., Project
303083 Coordinator, Western New York Remedial Action Section, New
York/Caribbean Remedial Action Branch, Emergency and Remedial
Response Division, United States Environmental Protection Agency,
from Mr. Robert J. Mozer, Senior Associate, Geraghty & Miller Inc.,
re: Submittal of Responses to Comments on the Draft Site
Summary Report PAS Oswego - Supplemental Remedial
Investigation/ Feasibility Study, November 24,1992. Enclosed
Report: Responses to USEPA/NYSDEC Comments.
Letter to Mr. Mark Valentine, Project Manager, de
Maximus Inc., from Richard Ramon, P.E., Project Manager, Western
New York Superfund Section I, re: the EPA review of the Site
Summary Report for Pollution Abatement Services submitted by
Geraghty & Miller Inc., October 29,1992.
303093- Letter to Mr. Mark Valentine, Project Manager, de
303093 Maximus, Inc., from Mr. Richard Rarnon, P.E., Project Manager,
Western New York Superfund Section I, re: Geraghty & Miller's
initial data validation, September 23,1992.
303094- Letter to Mr. Richard Ramon, P.E., Project
303095 Manager, Western New York Remedial Action Section, New York/
Caribbean Remedial Action Branch, Emergency and Remedial
Response Division, United States Environmental Protection Agency
from Ms. Laine Vignona, Principal Scientist/Project Manager,
Geraghty & Miller, Inc., re: EPA Region II Data Validation Standard
Operating Procedures; Pollution Abatement Services Site, Oswego,
New York, November 6,1991.
303096- Letter to Ms. Laine Vignona, Principal Scientist/
303096 Project Manager, Geraghty & Miller, Inc. Environmental Services
from Mr. Richard Ramon, P.E., Project Manager, Western New York
Superfund Section I, re: letter of August 29,1991 requesting
approval to shift soil boring locations, August 30,1991.
-------
p. 303097-.
303098
p. 303099-
303100
303101-
303101
303102-
303104
p. 303105-
303106
303107-
303111
303112-
303116
Letter to Mr. Mark Valentine, Project Manager, de
Maximus, Inc., from Mr. Richard Ramon, P.E., Project Manager,
Western New York Superfund Section I, re: follow-up of conference
calls on August 13, and 14 regarding the scope of work for the
Ecological Assessment at the Pollution Abatement Services site,
August 26,1991.
Letter to Mr. Mark Valentine, Project Manager, de
Maximus, Inc., from Mr. Richard Ramon, P.E., Project Manager,
Western New York Superfund Section I, re: follow-up to letter of
June 24 1991, and conference call of August 2,1991 regarding
comments from NYSDEC concerning Tentatively Identified
Compounds (TICs), August 8,1991.
Letter to Mr. Mark Valentine, Project Manager, de
Maximus, Inc., from Mr. Richard Ramon, P.E., Project Manager,
Western New York Superfund Section I, re: revised Field Operations
Plan for the Pollution Abatement Services (PAS) site submitted by
Geraghty & Miller, Inc. in May 1991, June 24,1991.
Letter to Mr. Richard Ramon, P.E., Project
Coordinator, Western New York Remedial Action Branch, U.S.
Environmental Protection Agency, from Mr. Robert J. McNamee,
Senior Engineering Geologist, Bureau of Central Remedial Action,
Division of Hazardous Waste Remediation, re: Pollution Abatement
Services Site Revised Field Operations Plan for Supplemental RI/FS,
Site Code: 7-38-001, June 19,1991.
Letter to Ms. Laine Vignona, Senior Scientist,
Geraghty & Miller, Inc., from Robert J. McNamee, Senior
Engineering Geologist; Bureau of Central Remedial Action, Division
of Hazardous Waste Remediation, re: Pollution Abatement Services
Site, Oswego, New York, Site Code: 7-38-001, concerning eleven
groundwater monitoring wells abandoned at PAS, May 13,1991.
Letter to Mr. Mark Valentine, Project Manager, de
Maximus, Inc. from Mr. Richard Ramon, P.E., Remedial Project
Manager, Western New York Superfund Section I, re: follow-up of
February 28,1991 and conference call of March 15,1991 regarding
the draft Field Operations Plan (FOP) for the Pollution Abatement
Services (PAS) site, April 3,1991.
Letter to Mr. Richard Ramon, P.E., Project
Coordinator, Western New York Remedial Action Branch, U.S.
Environmental Protection Agency, from Mr. Robert J. McNamee,
-------
Senior Engineering Geologist Bureau of Central Remedial Action,
Division of Hazardous Waste Remediation, re: Pollution Abatement
Services Site, Field Operations Plan for Supplemental RI/FS, Site
Code: 7-38-001, resubmission of comments generated by State of
New York regarding the Field Operations Plan, March 22, 1991.
303117- Letter to Mr. Mark Valentine, Project Manager, de
303118 Maximus, Inc., from Mr. Richard Ramon, P.E., Project Manager,
Western New York Superfund Section I, re: February 22,1991
meeting regarding the draft Field Operations Plan (FOP) for the
Pollution Abatement Services Site (PAS) site, February 28,1991.
303119- Letter to Mr. Joel Singerman, Chief, Western New
303119 York Remedial Action Section, U.S. Environmental Protection
Agency, from Mr. Raymond E. Lupe, P.E., Chief Central Remedial
Projects Section, Bureau of Central Remedial Action, Division of
Hazardous Waste Remediation, re: Pollution Abatement Services
Site Supplemental RI/FS Site Code 7-38-001 prepared by Geraghty
& Miller Inc., notification that comments to the EPA will not be
available until January 15,1991, December 13,1990.
303120- Letter to Mr. Joel Singerman, New York/Caribbean
303122 Remedial Action Branch, U.S. Environmental Protection Agency,
from Mr. R. Bruce Fidler, Site Manager, JAMS Consultants, Inc., re:
Pollution Abatement Services (PAS) Site, SRI/FS Work Plan,
regarding JAMS' response to revisions to the SRI/FS Work Plan
(Volumes I and II) proposed by Geraghty & Miller Inc., in letter of
August 2, 1990, August 16, 1990.
303123- Letter to Mr. Joel Singerman, New York/Caribbean
303124 Remedial Action Branch, U.S. Environmental Protection Agency,
from Ms. Laine Vignona, Senior Scientist, Thomas Lobasso, Senior
Associate, Geraghty & Miller, Inc., re: Pollution Abatement Services
(PAS), Oswego, New York, Revised Supplemental Remedial
Investigation/Feasibility Study (SRI/FS) Work Plan, August 2, 1990.
303125- Letter to Mr. Joel Singerman, Chief, Western New
303126 York Remedial Section, U.S. Environmental Protection Agency
Region II, from Mr. Raymond E. Lupe, Chief, Central Remedial
Projects Section, Bureau of Eastern Remedial Action, Division of
Hazardous Waste Remediation, re: Pollution Abatement Services (7-
38-001), Oswego County, comments from the Division of Water,
Division of Fish and Wildlife, and Division of Hazardous Waste
-------
Remediation on the Draft Field Operations Plan (FOP)/ April 10,
1990.
4.0 FEASIBILITY STUDY
4.3 Feasibility Study Reports
p. 400001- Report: Final Supplemental Feasibility Study
400332 Report. Pollution Abatement Services Site. Oswego. New York,
prepared by Colder Associates, August 1993.
5.0 RECORD OF DECISION
5.1 Record of Decision
p. 500001- Record of Decision, Remedial Alternative Selection
500044 for Pollution Abatement Services, Inc (PAS), Oswego, New York,
June 6,1984.
7.0 ENFORCEMENT
7.2 Endangerment Assessments
*>
p. 700001- Report: Final Endangerment Assessment. PAS Oswego
700421 Site. Oswego. New York. Volume I of II. prepared by COM Federal
Programs Corporation, May 26, 1993.
p. 700422- Report: Final Endangerment Assessment. PAS Oswego
700536 Site. Oswego. New York. Volume li of li. prepared by COM Federal
Programs Corporation, May 26,1993.
7.3 Administrative Orders
p. 700537- Removal Order, Index No. 10221, Constantine
700638 Sidamon-Eristoff, Regional Administrator, September 30,1991.
700639- Administrative Order on Consent for Supplemental
700748 Remedial Investigation/Feasibility Study, Index No. II CERCLV00214,
Constantine Sidamon-Eristoff, Regional Administrator, September 27,
-------
1990.
7.7 Notice Letters and Responses - 104e/s
p. 700749- Letter re: General Notice for the Supplementary
700751 Remedial Investigation and Feasibility Study at the Pollution
Abatement Services Site, Oswego County, New York, March 23,
1990.
7.8 Correspondence
p. 700752- Letter to Chief, Western New York Remedial Action
700754 Section, New York/Caribbean Remedial Action Branch, Emergency
and Remedial Response Division, U.S. Environmental Protection
Agency, Attn: PAS Oswego Site Manager, from James W. Moorman
on behalf of the PAS Management Committee (for Respondents) re:
Pollution Abatement Services Sites, Oswego, New York,
Administrative Order on Consent for PAS Oswego Site Interim
Groundwater Removal, October 4,1991.
p. 700755- Letter to James W. Moorman, Esq., Cadwalder,
700755 Wickersham, and Taft, from Joel Singerman, Chief, Western New
York Remedial Action Section, re: March 16,1990 telephone
conversation concerning contamination detected outside the slurry
wall at the Pollution Abatement Services Superfund site, March 21,
1990.
10.0 PUBLIC PARTICIPATION
10.9 Proposed Plan
P. 1000001- Plan: Superfund Proposed Plan for the Pollution
1000013 Abatement Services Site, Town of Oswego, Oswego County, New
York, August 1993.
8
-------
APPENDIX IV
STATE LETTER OF
CONCURRENCE
-------
PosMP brand fax transmittal memo 7671 «« P»S»» > /
New York State Department of Environmental C
50 Wolf Road, Albany, New York 12233 7010
Dept.
Mr. William J. Muszynski, P.E.
Acting Regional Administrator
US Environmental Protection Agency
26 Federal Plaza - Region II
New York, NY 10278
NOV 2 3 1993
Commissioner
Dear Mr. Muszynski:
RS: Pollution Abatement Services
Site No.: 7-38-001
Record of Decision
This letter is to advise you that the proposed change in
language in the Record of Decision, Pollution Abatement Services
Site, Oswego, New York, as outlined in the November 18, 1993
telex to the Division of Hazardous Waste Remediation staff is .
acceptable to the State. Page 6 of the Record of Decision, will
now include:
"Should the results of this investigation determine that
bedrock pumping will be an effective means of addressing the
contamination in the bedrock aquifer without adversely
impacting the existing containment system or the. creeks and
wetlands, then an analysis to determine the rate and the
location of the bedrock extraction wells will be performed,
followed by implementation of the bedrock groundwater
extraction and treatment. Should the investigation indicate
that bedrock groundwater pumping will have a significant,
adverse impact on the containment system or the creeks and
wetlands, this decision will be documented in a pre-remedial
design study report concurred upon by New York State."
The proposed change was discussed between Mr. Raymond Lupe
(NYSDEC) and Mr. Gary Litwin (NYSDOH) , and will satisfactorily
resolve the concerns of the state, outlined in my November 5, 1993
letter to you. Therefore, the State now concurs with the Record
of Decision.
"Please contact Mr. Michael J. O'Toole, Jr., Director,
Division of Hazardous Waste Remediation at (518) 457-5861 if you
have any questions.
Sincerely,
'f&
Ann Hill DeBarbieri
Deputy Commissioner
Office of Environmental Remediation
cc: A. Carlson, NYSDOH
W. McCabe, USEPA
-------
From
Post.lt* brand fax transmittal memo 7671 J««p*9*» »
New York State Department of Environmei
SO Wolf Road, Albany, New York 12233 7010 6/9*
MOV 5 ^993 Thomas C. Jortlna
Commissioner
Mr. William J. Muszynski, P.E.
Acting Regional Administrator
US Environmental Protection Agency
26 Federal Plaza - Region IX
New York, NY 10278
Dear Mr. Muszynski:
RE: Pollution Abatement Services
Site No.: 7-38-001
Record of Decision, Supplemental RI/FS
The purpose of this letter is to advise you that the
revision of page 27 of the Record of Decision, Supplemental
Remedial Investigation/Feasibility Study" (RI/FS), Pollution
Abatement Services Site, Oswego, NY/ to include the following
language is satisfactory to New York State:
"Should the investigation indicate that bedrock groundwater
pumping will have a significant, adverse impact on the
containment system or the wetlands (which would be
documented in a pre-remedial design study report), then,
upon obtaining the concurrence of New York State, bedrock
groundwater pumping will not be implemented1.*1
"In accordance with CERCLA Section 117(c) and Section
300.435(c)(2)(i) of the NCP, if bedrock groundwater pumping
is not implemented, then an Explanation of Significant
Differences, describing the modification to the selected
remedy and the basis for the change, will be published."
Discussions between Raymond Lupe (NYSDEC) and Gary Litwin
(NYSDOH) Jon October 29, 1993 confirmed that the revision to the
Record of Decision will adequately resolve the major concern of
the New York State Department of Health outlined on page 2 of my
October 5, 1993 concurrence letter to you. This concern was .
that:
"The Declaration of the Record of Decision and the
discussion of the selected remedy in the Record of Decision
should include follow-up actions that will be pursued in the
event that the results of hydrogeologic, pre-remedial design
studies show that pumping the groundwater is not an
effective means of remediating the contaminated water in the
bedrock aquifer without adversely affecting the containment
system or the adjacent wetlands and creeks."
-------
NOU-05-1993 15:47 FROM NYS. ENU I R. CONSERVATION
TO
85926872122646192 P. 02
Mr. William J. Muszynski, P.E.
Page 2
The New York State Department of Environmental Conservation
concurs with the Record of Decision upon incorporation of the
revisions outlined above*
Thank you for the efforts of your staff to resolve this
natter. Please contact Michael J. O'Toole, Jr., at
(518) 457-5861 if you have any questions.
Sincerely,
Ann Hill DeBarbieri
Deputy Commissioner
Office of Environmental Remediation
cc: D. Munro, NYSDOL
A. Carlson, NYSDOH
G. Litwin, NYSDOH
-------
APPENDIX V
RESPONSIVENESS
SUMMARY
-------
APPENDIX V
RESPONSIVENESS SUMMARY
Pollution Abatement Services Superfund Site
INTRODUCTION
A responsiveness summary is required by Superfund policy. It provides a summary of
citizens' comments and concerns received during the public comment period, and the United
States Environmental Protection Agency's (EPA's) and the New York State Department of
Environmental Conservation's (NYSDECs) responses to those comments and concerns. All
comments summarized in this document have been considered in EPA's and NYSDECs
final decision for selection of a remedial alternative to augment the previously implemented
remedial actions and to address the contamination detected outside the containment system
at the Pollution Abatement Services site.
OVERVIEW
The public generally supports the preferred remedy, enhanced source control with bedrock
extraction and treatment However, there were some concerns that were expressed related
to the preferred option for the treatment and disposal of the leachate and groundwater from
the PAS site at the City of Oswego's wastewater treatment plant. The primary concerns
were related to the wastewater treatment plant's ability to adequately treat the contaminated
groundwater and leachate. It was explained at the public meeting that the identification of
the City of Oswego's wastewater treatment plant as the preferred option for the treatment
and disposal of the leachate and contaminated groundwater in no way obligates the City to
accept the leachate and contaminated groundwater, nor does it imply that EPA and
NYSDEC will ultimately approve the discharge. Assuming that all of the City's obligations
related to the wastewater treatment plant are satisfied (such as the implementation of an
Industrial Pretreatment Program) and that the City is willing to accept the discharge, EPA
and NYSDEC approval of the subject discharge would be contingent upon a determination
that the proposed discharge (with or without pretreatment) would not adversely impact the
plant's treatment processes or sludge disposal practices and that it would not contribute to
permit violations or cause water quality criteria in the receiving waters to be exceeded. In
the event that this option cannot be implemented, the on-site treatment option would be
implemented as a contingent option for treatment and disposal.
The potentially responsible parties (PRPs) expressed concerns relative to the reasonableness
of a number of the exposure assumptions used in the human health risk evaluation and the
applicability of a number of the comparisons made between the lexicological databases and
scientific literature and the actual on-site case exposures that are occurring to non-human
receptors. EPA, in its response, noted that the Agency adopts a conservative approach in
its risk assessments. The values/criteria that are claimed to be unreasonable are standard
default values that EPA uniformly applies at all sites. Hence, the computed risks represent
-------
the reasonable maximum exposure case. With regard to the ecological threat, the levels of
some constituents exceed those that are believed to be protective of 95% of aquatic life.
Hence, continued exposure to the present contaminant levels are predicted to result in
impacts either through direct exposure to the contaminated medium or through feeding on
forms that have assimilated contamination from the water.
SUMMARY OF COMMUNITY RELATIONS ACTIVITIES
The RI report, FS report, and the Proposed Plan for the site were released to the public for
comment on August 23,1993. These documents were made available to the public in the
administrative record file at the EPA Docket Room in Region n, New York and the
information repository at the Oswego City HalL The notice of availability for the above-
referenced documents was published in the Oswego Palladium Times on August 21,. 1993.
The public comment period related to these documents was held from August 24,1993 to
September 22,1993.
On September 8,1993, EPA and NYSDEC conducted a public meeting at Oswego City Hall
to inform local officials and interested citizens about the Superfund process, to review
current and planned remedial activities at the site, to discuss and receive comments on the
Proposed Plan, and to respond to questions from area residents and other interested parties.
SUMMARY OF COMMENTS AND RESPONSES
The following correspondence (see Appendix V-a) was received during the public comment
period:
Letter dated September 1,1993 to Richard Ramon, EPA, from Ronald J. Scrudato,
concerning the Proposed Plan.
Letter dated September 14,1993 to Richard Ramon, EPA, from Ronald J. Scrudato,
following up his September 1,1993 letter and his comments made at the September
8,1993 public meeting.
Letter dated September 16,1993 to Richard Ramon, EPA, from Mark Valentine of
de maximus, inc. on behalf of the PAS Oswego Management Committee, concerning
the human health and ecological risk assessments.
Letter dated September 18, 1993 to Richard Ramon, EPA, from the Board of
Directors of the Fulton Safe Drinking Water Action Committee for Environmental
Concerns, Inc., concerning the Proposed Plan and comments made at the September
8, 1993 public meeting.
V-2
-------
Letter dated September 21, 1993 to Richard Ramon, EPA, from Anne Rabe,
Executive Director, Citizens' Environmental Coalition, concerning the Proposed Plan.
A summary .of the comments contained in the above letters and the comments provided by
the public at the September 8, 1993 public meeting, as well as EPA's and NYSDECs
response to those comments, follows.
Comment #1: A commenter noted that, at the time of the initial remedial action at the
PAS site, it was stated that the slurry wall and cap would remedy the contamination
problems. Since contamination has been found outside the containment system, the
commenter concluded that the original remediation was either incomplete, because the
extent of contamination was missed during the original RI/FS, or the system failed to
contain the contaminants within the slurry wall and cap, since contaminants are migrating
through the area of the site with thinner till into the bedrock. The commenter expressed
concern that the public is now being told that there is a better understanding of how the
system works and the preferred remedy will solve the contamination problems.
Response #1: The containment system was constructed to not only contain the contaminat-
ed groundwater in the overburden aquifer, but to prevent direct contact, prevent volatile
emissions, and reduce infiltration, which in turn, will reduce the generation of contaminated
groundwater.
Based upon post-closure site inspections and long-term monitoring results, it has been
determined that the containment system is effectively preventing direct contact and
preventing volatile emissions.
The hydraulic integrity of the containment system was assessed during the supplemental RI
using data from continuous monitoring of water levels at selected monitoring wells located
on opposite sides of the slurry wall, monthly water level measurements, and associated
meteorological data. The monitoring data demonstrated that the slurry wall is performing
effectively. The lack of response of groundwater levels inside the containment system to
precipitation suggests that the cover system is performing effectively. Therefore, based on
extensive monitoring data collected at the site, the existing containment system is providing
hydraulic control of the contained area.
While the bedrock aquifer was, apparently, already contaminated at the time the
containment system was constructed, this contamination was not detected when the original
RI was performed. The supplemental RI has yielded a better understanding of the
hydrogeological conditions at the site. The data suggest that contaminants in the bedrock
aquifer originated from the area within the containment system and migrated vertically
downward through the lodgement till. The inferred source area for contaminants in the
bedrock aquifer is the center of the containment system where the lodgement till is relative-
ly thin. Based upon the RI data, it appears that the increased interim groundwater removal
V-3
-------
pumping has modified the horizontal gradients across the slurry wall, resulting in inward
gradients along much of the length of the slurry wall (i.e., groundwater tends to flow inward
rather than outward toward the slurry wall). In addition, it appears that upward vertical
gradients between the bedrock and overburden may have been produced over part of the
containment system. Therefore, the data suggest that the subject contamination will be
addressed by enhancing the present source control system by optimizing the leachate and
groundwater extraction rate and other operating conditions in order to achieve, to the
degree practicable, inward horizontal gradients in the overburden and upward vertical gradi-
ents from the bedrock toward the containment system, and by actively pumping the bedrock
aquifer.
Comment #2: Several commenters wanted to know what future action is planned to
determine whether other potential sources of contamination are contributors to the PAS site
groundwater problem, concluding that it would be a waste of money to address the PAS site
problems now, as long as there continues to be a source of upgradient contamination.
Response #2: It is recognized that the upgradient East Seneca Street Dump, Niagara
Mohawk Fire Training School, and Oswego Castings site are potential sources of contamina-
tion to the PAS site. Reports prepared by an NYSDEC contractor indicate that both the
East Seneca Street Dump and the Fire Training School may have contributed to the
contamination of the soil, groundwater, surface water, and sediments in the vicinity of the
PAS site. According to these reports, volatile organic compounds, semi-volatile organic
compounds, and metals were detected in the groundwater at the East Seneca Street Dump.
Because of the lack of data, it is not clear if the volatile organic compounds are also
contaminants of concern at the Fire Training School. Available information (data from
NYSDECs 1991 preliminary site assessment) suggest that the Fire Training School may be
a source of PCBs in the surface water and sediments in White Creek in the vicinity of the
PAS site. In addition, the Oswego Castings site remains a concern as a potential source
which may be contributing to PCB contamination in the wetlands adjacent to the Smith's
Beach community.
Since the data suggest that contaminants in the bedrock aquifer have originated from within
the containment system and have migrated vertically downward through the lodgement till,
it would be appropriate to address the contamination that is believed to be attributable to
the PAS site, while the ongoing studies at the upgradient sites continue. Any contamination
attributable to the upgradient sites will be addressed upon completion of the ongoing studies
at these sites.
Comment #3: A commenter noted that a number of interim remedies were conducted at
the PAS site to reduce the off-site migration of contaminants to the two local tributaries and
to Lake Ontario including the removal of leaking drums, surface and subsurface storage
tanks, and the incinerator, and the draining and backfilling of the two on-site lagoons. The
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commenter further noted that, although it was clear that the lagoons contained highly
contaminated soils and sediments, the removal and treatment of the highly contaminated
lagoon sediments was not considered. The commenter expressed concern that, as long as
highly contaminated soils and sediments remain buried at the site, they will continue to be
a source of contamination to the groundwater. The commenter suggested that select
excavation of the areas which were occupied by the two lagoons would significantly reduce
the source of contaminants, thereby accelerating the eventual reduction of substances in the
surrounding groundwater. The commenter added that, continuing with the containment
strategy selected in the 1984 Record of Decision (ROD) will require that groundwater be
withdrawn and treated for decades, particularly since there is a large volume of highly
contaminated sediments buried beneath the cap.
Response #3: While the lagoons contained highly contaminated soils and sediments after
they were drained and backfilled in 1982, to remove the sediments at that time would have
only eliminated a portion of the contamination on-site. The original RI data indicate that
soil contamination was significant, widespread, and non uniform across the site, suggesting
multiple on-site sources of contamination. Although the removal of the contaminated soils
and sediments would have provided the most effective and complete removal of contami-
nants from the site, given the size of the site, containment of the waste mass was determined
to be the only practical means to remediate the site.
Since the containment of the waste, as called for in the 1984 ROD, is providing adequate
protection to the public and the environment, and since there are other sources of
contamination at the site, to eliminate the lagoon sediments at this time would not provide
a greater degree of protection to public health and the environment.
k
Since the extent of the source of contamination present in the containment cell is largely
unknown, determining how long the leachate and contaminated groundwater must be
controlled is indeterminate.
Comment #4: Several commenters expressed concern that EPA would consider using the
City of Oswego's wastewater treatment plant, which discharges to a major source of drinking
water, particularly when there is such great emphasis on the reduction and virtual
elimination of persistent toxic chemical discharges to the Great Lakes. Although the current
plume does not appear to contain PCBs, one commenter was concerned that the PCBs
which are contained at the site might be mobilized by the volatile organics or that PCBs
from the upgradient sources might find their way into the wastewater treatment plant and
pass through to the sludge. In addition, a commenter expressed concern that the sludge
would concentrate the trace metals known to exist at the site.
A commenter also expressed concern that one will never be able to monitor whether the
wastewater treatment is treating the influent from the PAS site since a contribution of
50,000 gallons per month of leachate and contaminated groundwater from the site would
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be substantially diluted by the 3 million gallons per day flow at the wastewater treatment
plant At this dilution, the analytical protocols would not allow effective monitoring of the
wastewater treatment plant's discharges to determine whether the contaminants have been
degraded.
Several commenters suggested that the contingent treatment option, on-site treatment, be
employed.
Response #4: The purpose of wastewater treatment plants is to serve as central facilities
which remove pollutants and contaminants from municipal and industrial wastes that are
generated in specific areas. The results of treatability studies that were performed on the
site's leachate and a study of the feasibility of discharging leachate from the PAS site to the
wastewater treatment plant indicated that the PAS leachate includes organic contaminants
that are amenable to treatment in a biological treatment system, such as the one at the
wastewater treatment plant Also, the study indicated that the metals in the leachate are
low in comparison to the allowable levels at the wastewater treatment plant, and would not
inhibit wastewater treatment effectiveness or the sludge incineration process. Although the
leachate would be classified as a Resource Conservation and Recovery Act (RCRA) listed
waste (waste code F039), it would fall within the Domestic Sewage Exclusion, 40 CFR 261.4,
and would not require a RCRA permit for purposes of discharge to the wastewater
treatment plant. The study concluded that the PAS leachate would:
not affect wastewater treatment plant employee health and safety;
conform with the City of Oswego's pretreatment requirements; and
not impact the wastewater treatment plant's ability to comply with its effluent limita-
tions or sludge disposal requirements.
Assuming that all of the City's obligations related to the wastewater treatment plant are
satisfied (such as the implementation of an Industrial Pretreatment Program) and that the
City is willing to accept the discharge, EPA and NYSDEC approval of the subject discharge
would be contingent upon a determination that the proposed discharge (with or without
pretreatment) would not adversely impact the plant's treatment processes or sludge disposal
practices and that it would not contribute to permit violations or cause water quality criteria
in the receiving waters to be exceeded.
In the event that the wastewater treatment plant option cannot be implemented, the on-site
treatment option would be implemented as a contingent option for treatment and disposal.
If the wastewater treatment plant option is implemented, the groundwater and leachate
would be monitored at the PAS site using strict protocols defined by the City of Oswego,
NYSDEC and EPA Specific monitoring protocols would be developed, which would
include frequency of sampling and reporting, sampling methods and locations, analytes, and
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analytical testing methods. For example, instrumentation used for analysis of organic
compounds could include a gas chromatograph or a gas chromatograph/masspectrometer.
Analytical detection limits would be in the low parts per billion range with this type of
instrumentation and analytical techniques. With detection limits in the low parts per billion
range, treatment effectiveness at the wastewater treatment plant could be adequately
monitored and demonstrated even considering that the proposed PAS discharge would
comprise less than one percent of the total wastewater entering the treatment plant If the
influent concentrations are, at any time, determined to be unacceptable, pretreatment of the
influent or on-site treatment may be required.
Monitoring at the wastewater treatment plant would be performed both on the influent and
the effluent. Current monitoring protocols at the wastewater treatment plant would be
modified, as necessary, to insure that the treatment system performance is not inhibited and
that the proposed PAS discharge is treated properly. The monitoring program would be
coordinated with the timing of specific PAS discharge events and related monitoring at the
PAS site, since the proposed PAS discharge would be intermittent The wastewater
treatment plant's effluent would be monitored in accordance with requirements provided
in its State Pollutant Discharge Elimination System (SPDES) discharge permit, which
contains monitoring requirements for specific parameters required to insure that Lake
Ontario's water quality is being protected.
Comment #5: Several commenters asked what impact to Lake Ontario would be expected
from the proposed discharge of PAS site groundwater and leachate to the wastewater
treatment plant? One commenter also asked what impact to the adjacent Wine Creek or
White Creek and, subsequently Lake Ontario, would be expected if the PAS site's
contaminated groundwater and leachate were treated on-site and discharged to Wine Creek
or White Creek?
Response #5: One condition of approval of the wastewater treatment plant treatment
option will be a determination that the proposed discharge would be treated properly at the
wastewater treatment plant prior to discharge to Lake Ontario. The SPDES permit for the
subject plant was issued by NYSDEC with specific discharge requirements that were
developed based on the protection of water quality in Lake Ontario.
A discharge from an on-site treatment system to Wine Creek or White Creek would have
to comply with SPDES discharge requirements to insure protection of White and Wine
Creeks and Lake Ontario. The discharge requirements would be based upon water quality
criteria that would maintain the quality of these waters and prevent any adverse impacts.
Comment #6: A commenter wanted to know whether or not the City of Oswego will incur
any costs related to sewerline construction and maintenance.
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Response #6V If the City of Oswego's wastewater treatment plant treatment option is
ultimately selected, the construction of the sewer connection to the Mitchell Street sewer
extension and.all associated costs would be incurred by either the potentially responsible
parties (PRPs) (if, following EPA's post-ROD negotiations they agree to design and
implement the selected remedy) or EPA and the State (if the PRPs do not agree to design
and implement the selected remedy). The maintenance of the sewerline would be the
responsibility of the City. The cost related to this maintenance should be covered by the
fees that will be charged to the PAS site as a customer of the wastewater treatment plant
Comment #7: A commenter asked whether EPA would pay for the upgrade, since the City
of Oswego has been told to upgrade its treatment processes and EPA is supporting the
utilization of the wastewater treatment plant to treat the leachate and contaminated
groundwater from, the site, contingent upon, among other things, the upgrade of the
wastewater treatment plant
Response #7: The connection to the wastewater treatment plant assumes that the upgrade
has been completed. Since the upgrade is necessary regardless as to whether or not the
PAS leachate and contaminated groundwater is treated at the wastewater treatment plant,
paying for the upgrade would not be the responsibility of EPA.
Comment #8: One commenter noted that New York State allows sludge to be spread on
agricultural lands. The commenter expressed concern that landspreading sludge contaminat-
ed with hazardous substances from the PAS site could eventually cause groundwater and
surface water contamination. The commenter urged utilizing on-site treatment as a means
of solving the "sludge problem."
Response #8: Sludges will be generated regardless of whether the PAS leachate and
contaminated groundwater is treated at an on-site treatment facility or at the City of
Oswego's Eastside wastewater treatment plant It is likely that sludges generated from an
on-site treatment facility would be taken off-site for treatment The sludges from the City
of Oswego's Eastside wastewater treatment plant are incinerated, not landspread.
Comment #9: A commenter wanted to know whether or not there is any monitoring of air
emissions from the wastewater treatment plant's sludge incinerator.
Response #9: The air emissions are monitored to ensure compliance with its air emission
permit requirements.
It should also be noted that monitoring of the sludge incinerator ash quality is performed
in accordance with EPA and NYSDEC requirements. Sludge incinerator ash is and would
continue to be monitored to compare ash quality with state and federal regulatory
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requirements. A June 1993 evaluation of the wastewater treatment plant option performed
by O'Brien & Gere Engineers, Inc., on behalf of the PRPs, concluded that the introduction
of contaminated groundwater and leachate from the PAS site into the Eastside Wastewater
Treatment Plant would not cause the incinerator ash quality to exceed state or federal ash
quality standards.
Comment #10: Several commenters asked what the current health risk associated with the
site was. Of particular concern was the threat to Smith's Beach.
Response #10: Private wells in Smith's Beach have been tested, with no site-related
contamination indicated. The results of the baseline risk assessment performed during the
supplemental RI indicate that only the potential future exposure to the bedrock aquifer via
ingestion poses an unacceptable risk to human health. The cumulative upper-bound cancer
risk at the site is 7x10^ for children and 8x10"* for adults. Hence, the risks for carcinogens
at the site are not within the acceptable risk range of 10~* to 10"6. Connecting downgradient
residents in the Smith's Beach area using residential wells to the public water supply and
implementing institutional controls on groundwater usage through deed restrictions at the
PAS site and downgradient from the site to the Smith's Beach area will protect public health
while the contaminated groundwater is extracted and treated.
Comment #11: Several commenters expressed concern that the treatment of the leachate
and contaminated groundwater at the City of Oswego's wastewater treatment plant was a
foregone conclusion, since it was identified as EPA's and NYSDECs preferred remedy.
Response #11: The purpose of a Proposed Plan is to inform the public of EPA's and
NYSDECs preferred remedy and to solicit public comments on all of the remedial
alternatives evaluated, as well as the preferred remedy. Changes to the preferred remedy
or a change from the preferred remedy to another remedy can be made if public comments
or additional data indicate that such a change will result in a more appropriate remedial
action. A final decision regarding the selected remedy is made only after EPA has taken
into consideration all public comments.
The Proposed Plan for the PAS site identifies the treatment and disposal of the leachate
and groundwater from the site at the City of Oswego's wastewater treatment plant as the
preferred treatment option, with on-site treatment/disposal as a contingent option. After
reviewing the three leachate and contaminated groundwater treatment and disposal options
that were considered, as well as public comments, EPA has determined that treatment of
the leachate and contaminated groundwater at the City of Oswego's wastewater treatment
plant is the most appropriate treatment and disposal alternative, with on-site treat-
ment/disposal as a contingent alternative. The selection of the City of Oswego's wastewater
treatment plant for the treatment and disposal of the leachate and contaminated
groundwater, however, in no way obligates the City to accept the leachate and contaminated
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groundwater, nor does it imply that EPA and NYSDEC will ultimately approve the
discharge. Assuming that all of the City's obligations related to the wastewater treatment
plant are satisfied (such as the implementation of an Industrial Pretreatment Program) and
that the City is willing to accept the discharge, EPA and NYSDEC approval of the subject
discharge would be contingent upon a determination that the proposed discharge (with or
without pretreatment) would not adversely impact the plant's treatment processes or sludge
disposal practices and that it would not contribute to permit violations or cause water
quality criteria in the receiving waters to be exceeded.
In the event that the wastewater treatment plant alternative cannot be implemented, the on-
site treatment/disposal alternative would be implemented as a contingent option for treat-
ment and disposal.
Comment #12: One commenter expressed concerns relative to the reasonableness of a
number of the exposure assumptions used in the human health risk evaluation, including
exposure duration, exposure frequency, and the methodology for the selection of chemicals.
The commenter also expressed concern relative to the impact of upgradient sources of
surface water contamination of the risk assessment conclusions.
Response #12: EPA, in following its risk assessment guidelines (Risk Assessment Guidance
for Superfund), adopts a conservative approach in its risk assessments. The values/criteria
that are claimed to be unreasonable are standard default values that EPA uniformly applies
at all sites. Hence, the computed risks represent the reasonable maximum exposure (RME)
case, defined as the maximum exposure that can reasonably be expected to occur. In those
cases where EPA's acceptable target/range is exceeded, remedial action is appropriate.
Therefore, the potential future exposure to overburden and bedrock aquifers via ingestion
needs to be addressed. The computing of a less conservative "average" case was done in
accordance with EPA policy, which requires this be done when the RME analysis exceeds
EPA's risk thresholds.
The results of the baseline risk assessment indicate that only the potential future exposure
to the bedrock aquifer via ingestion posed an unacceptable risk to human health. The other
carcinogenic risks associated with the site are in the acceptable range.
The Hazard Index, which reflects noncarcinogenic effects for a human receptor, exceeded
unity for adults and children for ingestion of groundwater from the bedrock aquifer and for
children ingesting surface water, sediment, and fish.
While the Hazard Index associated with the ingestion of surface water, sediment, and fish
by children exceeds the acceptable level, it is uncertain whether the PAS site is the source
of this contamination, since there are several potential sources of surface water and
sediment contamination located upstream of the site. In conjunction with evaluating the data
generated by the ongoing and planned studies related to the adjacent East Seneca Street
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Dump, Niagara Mohawk Fire Training School, and Oswego Castings sites, a study will be
conducted to determine the source of contamination to the surface water and sediments
located in the adjacent creeks. If, based upon these investigations, it is determined that the
contamination in the adjacent creeks or wetlands is attributable to the PAS site, then
remedial alternatives to address this contamination will be evaluated.
Comment #13: One commenter expressed concerns relative to the ecological risk
assessment in terms of the applicability of a number of the comparisons made between the
lexicological databases and scientific literature and the actual on-site case exposures that are
occurring to nonhuman receptors. The commenter also expressed concern relative to
upgradient sources of surface water and sediment contamination.
Response #13: The qualitative ecological assessment found that aquatic species and aquatic
invertebrates, in particular, are the most at risk as indicated by the similarity of detected
surface water and sediment values in the vicinity of the site to toxicity values. In the case
of surface water, levels of some constituents exceed those that are believed to be protective
of 95% of aquatic life forms (i.e., Federal Ambient Water Criteria). Sublethal effects of
contaminant toxicity may be occurring at the site. As some of the contaminants present bi-
oaccumulate, affected aquatic invertebrates may be posing a risk to upper trophic level
species who use them as a food source. The potential for transmitting risk through the food
chain is present for the fathead minnow, a resident species at the site, as PCBs have been
detected in fish collected from creeks at the site. In addition, the minnows are expected to
have continual exposure to elevated levels of aluminum, DDE, and DDT, although this
exposure is not likely to threaten fish survival. Although a definitive statement cannot be
made regarding impacts to the Spring Peeper and other amphibious life, the contaminants
aluminum and DDT/DDE are present at levels that strongly indicate toxicity to these
aquatic receptors. There is a potential risk to the green-backed heron through its diet (a
significant portion of its exposure) from DDT/DDE, PCBs, aldrin, and metals. PCB
concentrations in the sediments are close to the values reported to cause adverse
reproductive and survival effects. The shrew, typifying small mammals at the site, is
expected to have relatively low exposures to surface water/sediment, and thereby any
adverse health risks are assumed to be sublethal. Contaminant body burdens, however, may
transfer contaminants to higher trophic level organisms (e.g., mink and green-backed heron).
Reproduction or survival of these higher forms could be impacted via this transfer, mostly
caused by the bioaccumulable DDT/DDE, PCBs, aldrin, and some metals. Based upon the
results of the qualitative ecological assessment, a potentially significant impact may occur
to mink if present at the site because of their extreme sensitivity to PCBs. Detected
sediment levels are well within the range of values reported to cause reproductive impair-
ment and mortality, via their dietary (aquatic sources) exposure.
It should be noted that, while the levels of PCBs, PAHs, and pesticides present in the
sediments in the depositional areas of the creeks in the vicinity of the site may pose an
unacceptable risk to individual mink that might use the creeks and. adjacent wetlands as
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foraging areas, it is uncertain whether the PAS site is the source of this contamination, since
there are several potential sources of surface water and sediment contamination located
upstream of the site. In conjunction with evaluating the data generated by the ongoing and
planned studies related to the adjacent sites, a study will be conducted to determine the
source of contamination to the surface water and sediments located in the adjacent creeks.
If, based upon these investigations, it is determined that the contamination in the adjacent
creeks or wetlands is attributable to the PAS site, then remedial alternatives to address this
contamination will be evaluated.
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APPENDIX V-a
RESPONSIVENESS SUMMARY
LETTERS SUBMITTED DURING THE PUBUC COMMENT PERIOD
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Mr. Richard Ramon, P.E.
Project Manager
Western New York Superfund Section 1
Emergency and Remedial Response Division
USEPA
26 Federal Plaza
New York, N.Y. 10278
September 1, 1993
Dear Mr. Ramon:
I appreciate the opportunity to comment on the Proposed Plan for
the Pollution Abatement Services Site, August, 1993. Although I
have not had the opportunity to review the supplemental RI/FS,
there are a number of points I would like to address regarding the
preferred remedy.
At the time the PAS site was being investigated, a number of
interim remedies were conducted to curb the offsite migration of
contaminants to the two local tributaries and to Lake Ontario. In
addition to the removal of leaking drums, removal of surface and
subsurface storage tanks and the actual incinerator,. the two on-
site "lagoons" were drained and backfilled. At the time the lagoons
were emptied and in subsequent investigations, it was known that
the lagoons contained some of the highest concentrations of
contaminants. The NYS Department of Environmental Conservation
assumed lead status for the remediation of the PAS site and
although it was clear that the lagoon areas contained highly
contaminated soils and sediments, DEC refused to consider the
removal and treatment of the highly contaminated lagoonal
sediments. The sediments were simply buried and I'm confident
continue to contribute to the problems related 'to groundwater
contamination. As long as highly contaminated soils and sediments
remain buried at the PAS site, the groundwater will continue to be
contaminated requiring withdrawal and treatment of the groundwater
or leachate for decades. If this is the case, why wasn't
excavation of known sources of highly contaminated sediments
considered in the remedial alternatives? Select excavation of the
ares which were occupied by the two lagoons would significantly
reduce the 'source of contaminants thereby accelerating the eventual
reduction of substances in the surrounding groundwater.
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At the tine of the initial remedial action at the PAS site, it was
stated that the slurry wall and the tight cap would clearly remedy
the problem. In addition, DEC also refused to conduct a detailed
investigation of the upgradient source(s) of contaminants to the
PAS site including the relationship of the East Seneca Street Dump
to groundwater contamination. How is it known that groundwater
contamination of the PAS site doesn't, at least in part, derive
from upgradient sources?
Based on these points, it is likely that the source of the
contaminants in the groundwater derive from either highly
contaminated sediments or from offsite migration into the PAS
property. Why isn't sediment source reduction being .considered at
this time to remove the source(s) of the groundwater contamination?
In addition, if the slurry wall and cap were designed and
constructed to significantly reduce the quantity of groundwater
within the site, why is it that contaminated groundwater continues
to flow from the site into the surrounding areas. Where are the
contaminants originating from? From within the slurry wall or from
off site? If the cap is working, as designed, then the major source
of groundwater has to be from outside the cap perimeter and slurry
wall suggesting that groundwater, and possibly contaminated
groundwater from the East Seneca Street Dump and elsewhere, is
migrating through the slurry wall into the PAS site. What future
action is planned to determine whether the East Seneca Street Dump
and other potential sources, are contributors to the PAS site
groundwater problem?
Regarding the use of the POTW for the disposal of contaminated
groundwater and leachate collected from the site, it is
unconscionable that USEPA would consider using the sewage treatment
plant that discharges to a major source of drinking water
particularly when there is such great emphasis on the reduction and
virtual elimination of persistent toxic chemical discharges to the
Great Lakes. At the estimated 50,000 gallons per month
groundwater withdrawal and at the estimated total BTEX
concentration of 1790, almost 10 pounds of BTEX will be discharged
to the POTW annually. In addition, over a pound of nickel and
arsenic (combined), and about a pound and a half of chlorinated
ethanes and ethanes will be discharged to the POTW and eventually
to Lake Ontario.
The alternative that should be implemented, is the one requiring on-
site treatment coupled with discharge to the groundwater rather
than to local tributaries and Lake Ontario. The treated effluent
should be discharged to the groundwater upgradient of the slurry
wall and not be transported to a local POTW. Local POTWs were not
designed or ever intended to be used for the disposal of hazardous
wastes and although it would reduce the overall remedial cost, this
alternative does not advance the overall reduction of contaminants
to an already stressed system.
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As I commented to DEC at the time they insisted on ignoring the
highly contaminated sediments known to be associated with the
lagoons in the early to mid-1980s, the remedy is flawed and driven
by expediency as well as a lack of experience on the effectiveness
of caps and slurry walls. What is being proposed now is a
continuation of a remedy that has proven to be ineffective. USEPA
is continuing to build on a poor initial remedy on the Number One
NPL Site in New York. It is now time to meet the mandates of SARA
and strive to cleanup the PAS site rather than conducting piecemeal
containment strategies. The containment strategy will require that
groundwater be withdrawn and treated for decades particularly since
there is a large volume of highly contaminated sediments buried
beneath the cap. Nowhere is it mentioned how long the pump and
treat system will have to operated. The public should be made
aware of the time that will be required to remediate the site to
ensure they understand the long term ramifications and required
commitments.
Hopefully these comments will receive serious consideration before
USEPA makes its final decision on this site and if you have
questions relating to my comments, please don't hesitate to contact
me.
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Mr. Richard Ramon, P.E.
Project Manager
Western New York Superfund Section 1
Emergency and Remedial Response Division
USEPA
26 Federal Plaza
New York, N.Y. 10278
Dear Mr. Ramon: September 14, 1993
I want to follow up on my letter of September 1, 1993 and comments
I made at the September 8, 1993 public meeting on the supplemental
RI/FS for the Pollution Abatement Services NPL Site.
As I mentioned, I believe USEPA is not giving enough consideration
to the store of contaminated sediments within the slurry wall and
the contributions deriving from upgradient sources. If you review
the comments of the public meeting you will note that there were
two explanations provided to explain the source of contaminants
outside the slurry wall including;
1. the contaminants were always there and were not detected at the
time the original RI/FS was conducted; or/and
2. contaminants are migrating through the area of the site with
thinner till into the bedrock.
In either case, the original remediation was either incomplete
because the extent of contamination was missed during the original
RI/FS, or the system failed to contain the contaminants within the
slurry wall and cap. Now we are being told that there is a better
understanding of how the system works and the preferred remedy will
resolve the problem.
To date, there has been no adequate explanation of whether or how
the Old Dump or the Niagara Mohawk Fire Fighting School relates to
the PAS site problem. DEC has delisted the Old Dump and with that
action, it is assumed the problem is resolved even though it is
documented that the Old Dump continues to be problemened by
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leachate breakouts and that there is a reasonable likelihood that
the Dump may be partially responsible for the PAS groundwater
problem. Again, I want to restate that it is foolish and a waste
of money to address the PAS site problems as long as there
continues to be a source of upgradient contamination.
Regarding the use of the Oswego POTW for getting rid of the PAS
leachate, I want to reemphasize that these systems were never
intended to be used for treating hazardous wastes. The plume of
contaminants from the PAS site consist primarily of VOCs although
it is known that the site contains PCBs and also that there is an
upgradient source of PCBs. Although the current plume does not
appear to contain PCBs at this time, it is well known that VOCs
serve as a solvent and can cause the mobilization of these
compounds. In addition, as PCBs undergo degradation, they become
increasingly more soluble. It is therefore possible that the PCBs
may become mobilized through time. Disposal of VOCs to a POTW
should take into consideration the potential for other contaminants
reaching the system, and if the City of Oswego agrees to receive
this leachate, no batch of leachate should be discharged to the
POTW without full analysis being conducted including congener-
specific PCB analysis. It is important to conduct congener
specific analysis to be able to determine whether other sources of
PCBs will also be mobilized in time. PCBs will not be affected by
the biological degradation of the POTW and will concentrate in the
sludge essentially unaffected as will the trace metals known to
exist at the site.
There are viable alternatives to POTW discharges including the
photocatalytic process described in the enclosed. Photocatalytic
degradation is much faster than biodegradation and can be conducted
on site without modifications to the current "pump and treat"
process. I realize photolysis was used at the PAS site in the
past. The photocatalytic process is more effective and is capable
of degrading a broader range of contaminants including PCBs (see
enclosed CHEMOSPHERE article).
What also concerns me about the POTW issue is that this will set
precedent and that it will set the stage for similar preferred
remedies for the other area sites including the FTS and Silk Road
Landfill NPL sites. The City of Oswego must weigh this factor since
both of these sites are upstream of the City and Lake Ontario. The
use of POTW for disposal of hazardous waste should not be
considered because as I stated at the public meeting, you will
never be able to monitor whether the system is working. the
dilution factor of 30,000 gallons per month against 3,000,000
gallons per day from the POTW, results in a dilution factor of
0.0003 or about .03 of one percent. At this dilution, the
analytical protocols do not allow effective monitoring of the POTW
discharges to determine whether the contaminants have been
degraded.
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Hopefully/these comments help clarify my concerns relative to the
preferred remedy and I hope that USEPA will not continue the
policies and practices that almost guarantee that we will be
revisiting this matter periodically over the next several decades
because poor decisions continued to be made.
Ve
tanald j7. Scrudato
encl.
cc: T. Hammill
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\7
de maximis, inc.
9041 Executive Park Drive
Suite 401
Knoxville. TN 37923
(615) 691-5052
September 16, 1993
Mr. Richard Ramon, P.E.
U.S. Environmental Protection Agency
26 Federal Plaza
Region II
New York, NY 10278
RE: PAS Oswego SRI/FS Comments on
final USEPA Human Health Risk Assessment
and Endangerment Assessment
Dear Mr. Ramon:
Enclosed please find comments prepared by Menzie-Cura & Associates on the final US
EPA Human Health Risk Assessment and Endangerment Assessment. (June 16, 1993).
Additional comments related to the USEPA Endangerment Assessment are also provided
in Menzie-Cura's letter of August 4, 1993. The August 4, 1993 Menzie-Cura comments
are specifically related to the USEPA's response to the "Estimate of PCB-Related Risks
to Mink for the White and Wine Creeks" dated June 22, 1 993.
If you have any questions, please call me.
Sincerely,
Mark Valentine
MV/mt
cc: PAS Oswego Management Committee
File:pas91 693/3023
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COMMENTS ON
EPA HUMAN HEALTH RISK ASSESSMENT
AND ENDANGERMENT ASSESSMENT
FOR THE PAS SITE, OSWEGO NEW YORK
June 16,1993
Prepared For:
PAS Oswego SRI/FS Trust
Prepared By:
Menzie-Cura & Associates, Lie.
Chelmsford, MA 01824
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Menrie-Cura & Associates, Inc. has reviewed Volume I - Risk Assessment of the "Final
Endangerment Assessment, PAS Oswego Site, Oswego, New York" and Volume n "Final
Endangerment Assessment" prepared for the U.S. Environmental Protection Agency (EPA)
by CDM Federal Programs Corporation (May 26, 1993). Comments regarding the EPA
human health risk assessment are based on our review of Volume I - Risk Assessment and
Volume n - Risk Assessment Appendices. Previous comments from Menzie-Cura &
Associates, Lie., as summarized in a technical memorandum to EPA (May 5, 1993), are
incorporated herein.
PART A COMMENTS ON EPA HUMAN HEALTH RISK ASSESSMENT
Organization of Comments
Comments are presented in the following format:
Summary of Evaluation for Reasonable Maximum Case
Summary of Evaluation for Central Tendency Case
Comments (these are presented in italic typeface)
The Summary of Evaluations provided for both the Reasonable Maximum Case and Central
Tendency Case are based on the information and assumptions included in the EPA risk
assessment. Any restatement or summary of the information provided in the text, tables, or
calculations, does not necessarily represent agreement or concurrence with the information
presented.
We have also performed a quality assurance check on data transcription and on the
calculations. The results of this evaluation are presented at the end of this document.
L General Comments
Use of Reasonable Maximum Exposures (RME)
The goal of using "reasonable maximum exposures" in risk assessment is to combine upper-
bound and mid-range exposure factors, which result in an estimation of risk which is both
protective and realistic. The RME is not intended to represent unlikely or improbable worst-
case scenarios (EPA, 1991). The EPA's RME scenarios for this risk assessment do not
combine mid-range and upper-bound exposure factors to arrive at risks; rather, only upper
bound estimates are used. Specifically, the RME scenarios are evaluated using upper-bound
estimates of exposure durations, exposure frequencies, intake and uptake of contaminated
media, and exposure point concentrations. By evaluating only upper-bound assumptions for
the RME scenarios, risks are generated based on highly unlikely exposures.
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Use of Central Tendency or Average Exposure Assumptions
The EPA's risk.assessment uses a central tendency, or average case, to assist in
interpretation of uncertainty. However, the exposure parameters used for these scenarios are
not indicative of "average" conditions. Instead of incorporating average values, such as the
arithmetic or geometric means, the EPA risk assessment uses 95% upper confidence limits
on the mean and maximum concentrations. In addition, as detailed later in the document,
many of the exposure factors such as ingestion rate of soil and water are above reported
average values. This results in an arbitrary estimate of exposure, and does not represent
"average" exposure conditions.
Selection of Compounds of Potential Concern
EPA's Compounds of Potential Concern may include several compounds not related to
previous site activities, and therefore should not be included in the risk assessment.
According to Section 2.3, Criteria for the Selection of Chemicals of Potential Concern (p.
42), nine different screening criteria were to be used to select the Compounds of Potential
Concern. Some of these criteria were discussed within the risk assessment. The most
significant criteria, not discussed or apparently evaluated in this section, was the comparison
of chemical concentrations relative to upgradient concentrations. Several compounds, such
as manganese and arsenic, were detected in upgradient surface water samples at similar
concentrations to those found on-site. However, this does not appear to have been
considered even though the risk assessment identified this as a criterion. The risk assessment
should also note the data available for PCBs in upstream sediments. References for these
data are provided later in the comments.
II. Risks to Residents and Future Commercial/Industrial Site Workers - Exposure to
Groundwater
Summary of Evaluation for Reasonable Maximum Case
1. Risks were calculated separately for the overburden and for bedrock. Excess
lifetime cancer risks (ELCR) exceed 1.0 E-4 (one in ten thousand) over a
lifetime, and hazard indices for systemic toxic effects exceed the benchmark of
"1."
2. Most of the ELCR risk for overburden wells was related to vinyl chloride, and
secondarily to benzene. For groundwater in bedrock, most of the ELCR risk
was due to a combination of arsenic and vinyl chloride as well as benzene.
3. The risks associated with exposure to groundwater are calculated, based on
measurements from wells outside the slurry wall. They do not reflect an
actual exposure to a real population, but rather a possible future exposure in
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the event of development in the area (assuming such development would not
rely on the existing city water supply in the area).
4. Risks to site workers were estimated for a hypothetical future scenario
involving placement of a commercial or industrial well in the contaminated
groundwater. ELCR risks exceed l.OE-04 and hazard indices exceed "1".
Chemicals contributing to the risks for site workers are the same as those for
residents.
Summary of Evaluation for Central Tendency Case
1. Risks associated with exposure to overburden groundwater exceed 1.0 E-05 for
adults and 1.0 E-04 for children. Values exceed 1.0 E-04 for bedrock
groundwater exposure.
Comments
1. Risks to residents and site workers have been calculated for hypothetical future
cases and do not reflect current conditions. If the results of the risk analyses
are to be used to evaluate the need for remediation1, then it is appropriate to
consider the following:
the locations of possible future wells - the presence of wetlands
and other features at and around the site significantly restricts
where, if at all, any future wells might be placed; an assessment
of possible future well locations would provide a better basis for
evaluating where exposure could occur;
the likelihood of possible future wells - this should first consider
the likelihood of future development within the area of
potentially impacted groundwater, as well as likelihood that
future homes or commercial properties would be serviced by
individual wells, or rather, would be tied into the city water
supply inasmuch as city water is now available to this general
area now;
1 Remedial decisions regarding contamination of groundwater typically include a
consideration of ARARs, as well as estimates of risk. In the present case, risks are to
hypothetical future residents or workers. Resolution of the risk issues with respect to their
likelihood, as well as the best means to reduce risk, should provide useful guidance on how
to proceed.
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an appropriate model to estimate exposure point concentrations
for constituents in ground-water at possible future well sites or
with distance from the site - this model would also serve to
indicate the zone or area within which MCLs and other ARAJRs
may be exceeded.
2. The suggested drinking water volume of 2 I/day is too high for children in the
1-6 year age group. A value of I I/day is more appropriate for both the
maximum and central tendency cases (Exposure Factors Handbook, 1989).
3. Inhalation of chemicals from shower water is included as an exposure
pathway. Given the hypothetical nature of the scenario and uncertainty in the
data, does the analysis support this level of sophistication?
4" Arsenic concentrations in groundwater are less than the MCL values and may
reflect background conditions.
. Risks to Residents - Exposure to Surface Water
Summary of Evaluation for Reasonable Maximum Case
1. Risks associated with ingestion of surface water from the creeks, or direct
contact with creek water, are de minimus.
Comments
1. No comment.
IV. Risks to Residents - Exposure to Sediments
Summary of Evaluation for Reasonable Maximum Case
1. ELCR risks associated with ingestion of sediment exceed l.OE-05 (one in one
hundred thousand) for both adults and children. These risks are due primarily
to PCBs and to a lesser extent, arsenic and benzo(a)pyrene. The PCB values
are the maximum detected in the creek at the site (from the beaver pond).
2. Exposure to sediment via dermal contact were calculated to exceed risk levels
of 1.0 E-05 for adults and 1.0 E-06 for children. These risks were due
exclusively to PCBs.
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3. Overall, combined risks associated with exposure to sediments via incidental
ingestion and dermal contact exceed 1.0 E-05 but fall within the 1.0 E-06 to
1.0 E-04 range.
Summary of Evaluation for Central Tendency Case
1. The sediment ingestion and dermal contact pathways result in less than 1.0 E-
06 lifetime ELCR risk individually. When the two pathways are combined,
the risk slightly exceeds 1.0 E-06 for children.
Comments
1. EPA has used standard EPA values for daily incidental ingestion of soil (100
mg/dayfor adults and 200 mg/dayfor young children) to estimate incidental
ingestion of sediment associated with visits to the site. The EPA's default
numbers for soil ingestion are generally recognized as conservative estimates
for daily exposure. We suspect that they are very conservative when applied to
sediment ingestion associated with short-term visits to the site. The
conservative nature - or at least uncertainty - associated with this exposure
pathway should be explicitly considered in the risk assessment report. The
conservative nature of this exposure pathway should be taken into account as
part of the risk management stage of the analysis.
2. For both adults and children, an exposure frequency of 78 days per year is
used by EPA for the maximum reasonable exposure (from the time a child is
one year old to a maximum exposure duration of 30 years). This value of 78
days per year is carried through all other aspects of the exposure scenario.
The exposure scenario combines this frequency of visits with ingestion of, and
dermal contact with, sediment. In addition, data for the maximum value of
PCBs in White Creek are used as an exposure concentration. This
combination results in the estimated risk levels in excess of 1.0 E-5 for
children and adults that may trespass on the site.
At the February 1993 EPA meeting regarding this site, the likely frequency of
visits to the site were discussed at a conceptual level. In particular, the
discussion included: i) the number of total visits, ii) the number of visits that
would involve fishing, and Hi) the number of likely visits during which the visit
would involve coming into direct contact with sediments, resulting in an
ingestion rate of 100 mg/dayfor adults and 200 mg/dayfor children. It seemed
reasonable to presume that these were not all identical, as specified in Table
3-12 by EPA. Fishing, for example, was recognized to be very seasonal; and
entry into the water with subsequent contact with sediment was also recognized
to be a less likely event than a visit (walk through) of the area. As another
example, if EPA concluded that exposure to surface soils needed to be
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considered, would the exposure route have included incidental ingestion of
both surface soils (at 100 or 200 mg/day) as well as sediment (at 100 or 200
mg/day)? This would have amounted to a soil/sediment ingestion in excess of
anything reported in the literature for non-pica behavior. Clearly, relaxing
one or more of the assumptions on frequency of visits, sediment ingestion, or
selection of data, would result in a much lower estimate of risk for the
reasonable maximum case.
EPA should separate out visits to the general area, fishing events, and events
involving sediment contact for the reasonable maximum exposure2. These
should be specified differently to reflect the available site-specific knowledge
concerning use of the area for fishing, and logic concerning reasonable
maximum exposure.
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'3. Arsenic should not be a chemical of potential concern for sediments because it
is present at background concentrations, well within the range of typical
elemental abundance for sediments and soils. The maximum concentration at
and below the site is essentially the same as the maximum value in upstream
sediments. Both maximum values fall within the typical background range for
this metal reported in the literature for states in the Northeast. The available
data for New York, Massachusetts and New Jersey should be considered.
4. Risk management decisions related to the presence of chemicals in sediments
should take into account potential upstream sources as well as the spatial
distribution of sediment type. There are a number of sources upstream from
the PAS site which contribute PCBs, pesticides, other organic compounds, and
metals.
Two of these sites - East Seneca Street Dump and the Niagara Mohawk Fire
Training School - have been investigated by URS Consultants3'*. With regard
. to PCBs, the Fire Training School appears to be particularly important as a
source to White Creek. High levels of PCBs (in excess of 50,000 ug/kg) have
been found at this site and have been detected in creek sediments adjacent to
*EPA. has made this distinction for the Central Tendency Case and we suggest that the
logic used there should also be reflected in the Maximum Reasonable Exposure Case.
3URS Consultants. 1991. Engineering Investigations at Inactive Hazardous Waste Sites:
Preliminary Site Assessment for Niagara Mohawk Fire Training School, Oswego. Prepared
for New York State Department of Environmental Conservation, Albany, New York.
4URS Consultants. 1992. Engineering Investigations at Inactive Hazardous Waste Sites:
Phase n Investigation for East Seneca Street Dump Oswego. Prepared for New York State
Department of Environmental Conservation, Albany, New York.
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the Fire Training School (51 - 535 ug/kg). PCBs introduced to White Creek at
the Fire Training School could be transported downstream and become
deposited in the slower moving portions of the creek behind the beaver dams.
The main source of the pesticides is probably the agricultural land that drains
into the creek systems. The distribution of contaminants in White and Wine
Creeks reflects possible source areas, as well as grain size and organic content
of the sediment.
5. For soil ingestion there are several published papers by Calabrese, Thompson5
and others that provide statistics on the median values for soil ingestion.
Calabrese6 has completed a re-evaluation of soil ingestion data, and these
values should be consulted. The available data indicate that the median values
for soil ingestion in children are less than 50 mg/day. Sediment ingestion is
probably much les.
6. For the central tendency case, ELCR risk estimates slightfy exceeded 1.0 E-06
for children. If the mean, rather than maximum concentrations for chemicals
in sediments are used, ELCR risks would be less than 1.0 E-06.
7. Page 150 of Section 7.0 summarizes the risks for residents' exposure to
sediment as being below the EPA target risk range. However, the risk
estimates listed in Table 12 for this exposure scenario are 1.2 E-05 and 2.1 E-
05 for adults and children, respectively. If the risks are truly below the target
risk range, an updated table showing these risk estimates should be included in
the appendices.
V. Risks to Residents - Eating Fish
Summary of Evaluation for Reasonable Maximum Exposure
1. ELCR risks due to ingestion of fish exceeded 1.0 E-05. These risks were due
primarily to the pesticide dieldrin in water. A bioaccumulation model was
used to estimate body burdens in fish from the water concentration.
2. The Hazard Index for noncarcinogenic (systemic) health risk exceeded the
benchmark of "1" for children in the 1 to 6 age group. This was due to
estimated exposure to dieldrin and manganese.
^Thompson, K.M.; Burmaster, D.E. Risk Analysis 1991, 11, 339-42.
^Personal communication with Edward Calabrese, University of Massachusetts at
Amherst, (413) 545-3164.
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Summary of Evaluation for Central Tendency Case
1. ELCR risks were slightly less than 1.0 E-05 for adults, and slightly greater
than 1.0 E-05 for children.
Comments
1. Dieldrin should not be included as a site-related chemical of potential concern
for surface water or fish. Dieldrin, and other pesticides, are present in the
creeks at low levels, probably as a result of historical use-in agricultural
applications. The concentration ofdieldrin in surface watertat and below the
site, was essentially the same as upstream from the site.
2. Manganese should not be included as a site-related chemical of potential
concern for surface water or fish. Manganese concentrations in surface water,
on-site and downgradient, do not appear to be elevated as compared to
upstream samples. Concentrations downstream ranged from 115 ug/l to 230
ug/l, as compared to 160 ug/l to 189 ug/l for the upstream stations. This
information suggests manganese concentrations in surface water may be
naturally occurring, or from an upstream source.
3. The draft risk assessment tables do not indicate the species offish that are
being caught for White and Wine Creeks. Based on discussions with local Fish
and Game personnel, it appears that Wine and White Creek are fished only
occasionally (reasonable maximum exposure is expected to be less than 78
days per year) and only for fish (e.g., Salmon or Rainbow Trout) that enter the
creeks from Lake Ontario to spawn. Thus, the fish that would actually be
fished for in the creeks will reflect primarily Lake Ontario conditions.
4. The fishing frequencies for the maximum reasonable exposure (78 times per
year) and central tendency (48 times per year) are probably high for this
creek. It is more likely that the creek is fished on an occasional basis, near
the mouth, in years when salmon or trout enter from the lake.
5. When all pathways are combined for surface water and sediments, the ELCR
risk is still within the 1.0 E-06 to 1.0 E-04 range. However, the hazard index
for children eating fish exceeds the benchmark of "1," due primarily to
dieldrin and manganese.
6. Site-specific information is available on where fishing is likely to take place for
the species of interest. When this occurs it will be primarily in the
downstream stretch of White Creek below the beaver dam. Particular interest
would be in those areas that are accessible to people, near Lake Ontario.
Such site-specific information should be considered when identifying
information and data for use in the risk assessment.
8
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VL Risks to Construction/Utility Workers
Summary of Evaluation for Reasonable Maximum Exposure
1. Risks were calculated for exposures to subsurface soils during any potential
future excavations outside the slurry wall. Presumably these would be related
to placement or maintenance of subsurface utilities, or new construction.
2. Risks slightly exceeded 1.0 £-06, due primarily to PCBs.
Summary of Evaluation for Central Tendency Case
1. Risks slightly exceeded 1.0 E-06.
* ~ . .
Comments
1. The exposure variable for days-per-year specifies a relatively large number of
days for the maximum reasonable exposure (195 days) and central tendency
(130 days) cases. This reflects a major construction project rather than
placing a utility line or pipe. Is that the intent? .Based on site-specific
information, there were relatively few areas where construction could occur
adjacent to the site and few locations where utility lines or pipelines could be
placed or serviced.
Vn. Quality Assurance Review of PAS Risk Tables
The Quality Assurance (QA) review included:
1. A QA check of the analytical data used to develop Compounds-of-Concern and
Exposure Point Concentrations;
2. Review of the exposure assumptions used in the assessment; and,
3. ~ Spot-check of the risk assessment calculation spreadsheets.
Analytical Data Tables
A Quality Assurance check was run on the data used by EPA in the human health risk
assessment. These values were compared to the analytical data reported by Geraghty &
Miller in both the draft "Site Summary Report" (August 1992) and revised report (November
1992). Each value used by EPA to arrive at exposure point concentrations was checked
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against values presented in the Geraghty & Miller reports. This data includes surface water,
groundwater, sediment and subsurface soil.
All of the data used by EPA in the draft risk assessment tables are identical to the values
presented in the "Site Summary Report." Three of the values, however, differ from those
presented in the "Data Validation Tables." These values are:
Data Validation
Table
Concentration
Media
Compound
Station
Concentration
Subsurface Soil .Dieldrin B-5
Groundwater Benzene M-21
*
Grouridwater Vinyl Chloride M-21
43 JP
37
5ND
R
100
14 ND
All other values appear identical to those presented in the "Data Validation Table.'
PART B COMMENTS ON
Comment 1
ENDANGERMENT ASSESSMENT
In several areas, the assessment attributes observations or data to the Additional Ecological
Assessment (Menzie-Cura, 1992) as if it were the primary source. For example:
on page 7 it attributes flow estimates to Menzie-Cura, 1992 which were not made by
the authors;
on page 8, Menzie-Cura, 1992 did not make a characterization of the cap; and,
on page 80, Menzie-Cura, 1992 did not gather primary data on fish.
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Comment 2
The Endangerment Assessment recognizes that the "food web" (figure 3-1) is simplistic.
However, the text should elaborate on the level of simplicity. For example, the figure shows
mink feeding on creek chub, short-tail shrew, and green heron, but the accompanying text
does not indicate what fraction of the diet these species are likely to contribute to mink. It is
important to understand these quantitative relationships in at least a relative manner, to arrive
at reasonable exposure scenarios and risk characterizations.
Comment 3
The ecotoxicity profiles nearly all summarize only aquatic databases drawn from EPA's
Ambient Water Quality Support Documents. There is little terrestrial data, and no attempt to
develop toxicity values from literature values. In several subsequent places, the document
suggests mat there should be more site-specific data collected. This may not be necessary, if
more effort was expended in developing toxicity values for receptor species from literature
data on closely related species.
Comment 4
On page 71, the statement, "The media quality standards/guidelines have been developed to
protect ecological receptors exposed to contaminated surface water or sediments" in reference
to NOAA criteria, is not consistent with NOAA's description of the use of ER-L's and ER-
M's. NOAA explicitly states 7 that "...guidelines were developed for use in assessing the
potential for effects," not as guidelines to protect ecological receptors. NOAA further
indicates that their system for using ER-L and ER-M is a relative ranking system for various
sites. Long and Morgan state that "The potential for biological effects was assumed to be
highest for those sites in which the sediments exceeded the individual ER-M values. The
potential was assumed to be lower for those sites that exceeded many of the ER-L values, but
not the ER-M values." This explicit method for using the NOAA guidelines does not suggest
that a single ER-L or a single ER-M is a criteria developed to be protective of ecological
receptors. Rather, it is a true weight of evidence approach which requires looking at as
many contaminants as possible to develop a relative ranking and the implied opinion
regarding the potential for effects
7Long and Morgan, 1990. The Potential for Biological Effects of Sediment-Sorbed
Contaminants Tested in the National Status and Trends Program. NOAA Technical
Memorandum NOS OMA 52. Seattle, Washington.
11
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Comment 5
The statement on page 71 that "However, detected PCS levels in the sediments arc at levels
that could affect avian and mink reproduction and cause death of sensitive invertebrate and
fish" is highly speculative. In particular, a statement such as this regarding higher order
predators such as birds or mink should explicitly state the underlying assumptions. For
example, is this statement based upon the assumption that all of the mink's diet is derived
from the site? Does it assume that all of the diet is creek chub, shrew, and green heron as
implied in figure 3-1? Does it assume that the mink or green heron reside at the site, or
associated wetlands, all year? The attachment to these comments is a quantitative analysis,
which provides such assumptions and constraints.
Comment 6
On page 79 in the third paragraph, the statement "Characterization of risks to site ecological
receptors was determined on the basis of comparison of ecotoxicological values from the
literature with site surveyed contaminant levels" is misleading. The statement applies only to
surface water, which is the only media for which the assessment provides ecotoxicological
values.
Comment 7
On page 79, the section on invertebrates is speculative and unsupported by the information
presented in the risk assessment. The authors characterizing risk to invertebrates when they
are admittedly not using invertebrates as a receptor. It is contrary to EPA methodology to
assess risk to a group which has not been characterized as a receptor. If status of and risk to
invertebrates is uncertain, they should be discussed in the uncertainty section of the report,
not the risk characterization section. The statement that "Aquatic invertebrates are most at
risk to PAS site contaminants as indicated by the similarity of detected values to toxicity
values," is not accurate. The only toxicity values used in the R/A are from the Ambient
Water Quality Criteria (Table 4-1 in the Endangerment Assessment), and the only surface
water value exceeding the AWQC is aluminum. The AWQC were developed to protect
sensitive receptors, and in the present instance, all COCs except aluminum are below these
very protective values. On the contrary, Table 4-1 indicates that based on comparison to
ecotoxicity values, the invertebrates are unlikely to experience risk.
Comment 8
The risk characterization of fathead minnow is highly speculative. The detection of PCB in
creek chub indicates that these fish have been exposed to PCB. However, the statement that
this indicates a potential for risk through the food chain should be accompanied by some
explanation of the underlying assumptions and a sense of the uncertainty in this statement.
The issue of uncertainty in speculations such as this should be addressed in the uncertainty
section.
. 12
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Comment 9
The section on spring peepers does note that the pH on-site and in adjacent areas, is outside
the range commonly associated with aluminum toxicity. It should also note that evidence of
a mating population (i.e. spring peepers calling) has been observed on-site.
Comment 10
On page 82, the speculations regarding mink exposure and potential effects due to PCB's
should include the assumptions behind the speculation that transfer of PCS and other COCs
through the food chain "...could provide a significant exposure...". The attachment to these
comments is a quantitative analysis which provides such assumptions and constraints.
13
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Men&e-Cura & Associates, Inc.
1 Courthouse Lane, Suite 2
Chelmsford, MA 02824
(508) 453-4300
(SOS) 453-7260 (fax)
August 4, 1993
Project No: 265 (PAS)
To: Mark Valentine and Bob Glazier
From: Charles Menzie
Subject: EPA Comments Related to Mink Model
EPA provides two paragraphs of comments related to the mink model we
applied to PCBs in sediments in White and Wine creeks. I have reviewed these
comments and am providing our responses below. In some cases these involve
clarifications concerning the nature of the modeling.
EPA is concerned about the degree to which the model is conservative as well
as the uncertainty associated with the analysis. These are discussed under
several headings:
Dietary Intake
EPA Comment: The model estimates dietary intake from food. EPA suggests
that exposure may be underestimated because other sources of PCBs are not
included. In particular, they mention the possibility of exposure due to
incidental ingestion of sediment.
Response: The model is designed to link dietary concentrations to potential
effects. This is die form of the model that has been used by EPA at other
Superfund sites and is the basis for the development of the Aquatic Water
Quality Criteria. Exposure via the food is expected to be the predominant
source of exposure to mink that may use the White and Wine Creeks as part of
1
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their foraging areas. Exposure to soil as a result of burrowing has not been
included because the focus of the effort has been on sediments in the creek beds
and because soils at the site have been capped. Because the mink preys on
animals such as frogs, birds, mammals, and fish, it is not expected to dig into
sediment or soil in order to obtain its prey.
Limited data exist on the amount of soil incidentally ingested by Teammate
EPA in concert with U.S. Fish and Wildlife have reported out some of this
information. Most of the available data are for smaller burrowing mammals.
To our knowledge, there are no reported data for mink and we have not seen
such information incorporated into mmir models used by EPA or others.
Composition of the Diet
EPA Comment: The use of equal proportions of fish, frog, and small
mammaic rather than proportions adjusted for site-specific prey availability may
reduce or increase estimated exposure.
Response: The use of equal proportions is a simplification but is expected to
be representative and probably conservative for the site. We relied upon the
literature as well as our field study of the area and that of URS as a basis for
establishing a diet. la particular we considered the following:
frogs were the most abundant vertebrates observed in White Creek
during our field studies and site visits; to the extent that mink are
feeding on aquatic biota, their diet is expected to be weighted
heavily toward frogs and this is consistent with what is reported in
the literature for mink; frogs are expected to have lower PCB
body burdens than fish; therefore, by including equal proportions
of frogs and fish in the diet, the model is made more conservative
than what is probably actually occurring;
fish were not observed in stretches of the White Creek above the
beaver dam; these animate occur more frequently in the lower
stream segments near Lake Ontario; these stream segments have
lower or non-detectable PCB levels in sediments as compared to
locations farther upstream; however, the model assumes that fish
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are evenly distributed throughout the creeks and that mink would
be exposed to PCBs in fish body burdens in locations where we
know that fish are not abundant; this assumption makes the estimate
of exposure more conservative than what is actually occurring;
the one macroinvertebrate that might be present in White and Wine
creeks and that mink might feed on is the crayfish; mussel beds do
not occur within these small creeks; a previous study attempted to
collect crayfish for tissue analysis of PCBs but could not find
sufficient organisms; based on this information and our own
observations of the site (which included turning over rocks to look
for these animals), we have concluded that crayfish are not an
important component of the diet for mink foraging along White and
Wine creeks.
Selection of Toxicological Endpointg and jLifestage
EPA Comment: By using only adult mink in the analysis, potentially more
sensitive life stages are excluded, as well as the potential restrictions of the
foraging area during denning.
Response: The lexicological endpoint that is used in this assessment is
impairment of reproduction in female mink. This has been the "critical effect"
most often associated with exposure of mink to PCBs in the diet and is the basis
for the EPA's Chronic Aquatic Water Quality Criterion for PCBs. Thus, the
approach taken is consistent with what is generally viewed as the appropriate
endpoint.
Because reproductive effects in female mink was identified as the critical
endpoint,- the foraging area of female minks was used as the basis for the
analysis. The analysis assumes that females would be restricted to the area
around White and Wine creeks.
Treatment of Non-Detect Values
EPA Comment: The assessment uses a zero value for creek segments with
non-detects rather than one-half the detection limit.
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Response: With a few exceptions, non-detect values were entered at one-half
the detection limit Those exceptions involved data where detection limits were
not reported. If a default non-detect value of 16.5 ug/kg is substituted for "0"
the exposure concentration of PCBs in food increases slightly but is still less
than 640 ug/kg
Discussion of Uncertainty
EPA Comment: The mink model document does not discuss uncertainties.
Response: The mink model document does not include a formal discussion of
uncertainties although such a discussion could be included. However, the
document does discuss the issues related to the assumptions and does attempt to
provide a conservative analysis. It is expected that the analysis overestimates
actual exposure to mink. As such, the analysis provides a better and more
technically sound basis for judging risk than the qualitative statements provided
in EPA's risk assessment. A formal discussion of uncertainties could be
included in support documentation.
for Stream Divsions
EPA Comment: The justification for specific divisions used for the creek
foraging segments was not presented.
Response: The division of stream segments was based on three factors: 1)
physical features of the streams such that PCB data collected at one location of
the stream could be representative of other locations of that stream segment; 2)
the levels of PCB contamination such that segments with higher PCB
concentrations in segments were not merged with segments of lower PCB
concentrations; and 3) locations relative to the site. These criteria provided a
logical basis for organizing the available information relative to stream
morphometry, PCB levels in sediments, and proximity to the site.
Because the methodology uses a weighted-average approach, alternative
divisions of the creeks would likely yield similar results.
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Uncertainty Associated with Toxicjty
EPA Comment: Dietary concentrations in the range of 596 ug/kg has been
cited as showing severe reproductive effects in cattle.
Response: Mink are reported to be particularly sensitive to PCBs and are the
most sensitive wildlife species tested for which data are available1. Birds and
other mammals are much less sensitive. The analysis focuses on mink and uses
the LOEL value used by EPA for other assessments of risks associated with
exposure of mink to PCBs (640 Tig/kg in the diet). We have attempted to be
consistent with the approach that EPA has taken in other situations in
identifying an appropriate endpoint and associated target concentration.
I could not find within Eisler, the reference made by EPA to effects on cattle.
Identification of Receptors
EPA Comment: The selection of the mink as a receptor is to show the risk to a
sensitive species. While the actual presence of individual minir or a lack of
population effects is a factor to consider, it is the potential for impact to site
receptors, as represented by the minlr and demonstrated in this assessment,
which is of special concern.
Response: The mink and mink model should not be used to represent other site
receptors. The mink is especially sensitive to PCBs and the lexicological data
relied upon in the model were specific to mink. Data exist for other small
mammals and it would be appropriate to consider that information if a
quantitative analysis is contemplated for other receptors. In addition, the
exposure assessment incorporated into the mink model is designed specifically
for mink ang would not be appropriate for other site receptors. An assessment
of risks to these other receptors should be based on a consideration of their
foraging habits and behavior as well as observations already reported on site
conditions.
lEisler, R. 1986. Polychlorinated biphenyl hazards to fish, wildlife, and
invertebrates: a synoptic review. U.S. Fish and Wildlife Biological Report
85(1.7).
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Conclusions
Ultimately, the information developed using the mink model and other
evaluations will be used to determine if some form of sediment remediation is
needed at this site. We offer the following comments related to that matter
1. Based on our analysis, the risks to mink and the mink population
associated with PCBs in sediments of White Creek is judged to be
low. We would not recommend sediment remediation on the basis
of this information.
%
"2. Our site observations revealed mat the area is supporting an
apparently healthy wildlife community. These site observations do
not support the need for sediment remediation at this time.
3. . In our view, the primary issue related to PCBs in sediments of
White Creek is the potential of 30 ongoing source to the sediments.
In the absence of an ongoing source, natural processes should
decrease the exposure levels with time and, since they do not
appear to be a significant source of risk to wildlife, reliance on
these natural processes is preferable to significant physical
alteration of the habitat that would result from a sediment removal
program.
The potential for an ongoing source should be considered as part of
the FS. If an ongoing source exists either as a result of the PAS
Site or some other site, the significance of that source could be
determined and appropriate actions defined.
4. La summary, we do not recommend that a sediment removal
program be implemented on the basis of available information.
However, we suggest that efforts be directed at identifying ongoing
sources to the sediments that may need to be addressed.
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F S D W A C for Environmental Concerns. Inc.
819 W. Third St..S. - Fulton. NY 13069-3220 - (315) 592-9731
September 18, 1993
Mr. Richard Ramon, P.E.
Project Manager
Western New York Superfund Section 1
Emergency and Remedial Response Division
U.S. Environmental Protection Agency
26 Federal Plaza
New York, New York 10278
RE: Pollution Abatement Service
Dear Mr. Ramon:
As we support the comments made by Oswego County residents at the
September 8, 1993 public meeting held to discuss USEPA's preferred
remedy for the PAS site, we offer the following brief comments:
1) In regards to the contaminants found outside the containment
system, we believe it is the result of NYSDEC's failure, during the
original RI/FS, to ascertain and accurately depict the contaminated
status of the aquifer under the site, and USEPA's failure to treat
and/or remove highly contaminated soils.
2) As the upgradient East Seneca Street Dump (delisted), Niagara
Mohawk Fire Training School and Oswego Casting may be potential
sources of contamination to the PAS site and the surrounding area,
we encourage USEPA to strongly recommend to the NYSDEC that they
investigate these properties in a timely fashion to rule-out these
properties as potential "sources" and if confirmed, develop a
binding agreement with the NYSDEC as to how and in what timeframe
the agency proposes to address them before a ROD is signed for the
site. To support our position, we ask USEPA to review NYSDEC's
involvement at the NPL Fulton Terminals Site relative to upgradient
sources.
3) Although the POTW option provides the PRPs with a cost-effective
way to handle the leachate, POTW s were not designed to treat
hazardous waste. We strongly object to USEPA's advocacy of the use
of POTW's to remediate hazardous waste sites as the use of POTWs
will add to the overall contaminant loading of Lake Ontario (a
major drinking water source for millions of U.S. and Canadian
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residents) and counter the intent of the GLI which calls for a
reduction in the contaminant loading to the Great Lakes. We support
treating the leachate on-site. In addition, we would like to direct
your attention to the problems associated with the disposal of
leachate from the NPL Volney Landfill Site to the City of Fulton's
POTW and NYSDEC's position in the matter (see enclosed).
4) In regards to the residents of Smith's Beach, we find it
appalling that the USEPA, in knowing that contaminants had migrated
outside the containment area soon after the source control remedy
was implemented, did nothing to confirm that all of the residents
living doWn-gradient and in proximity to the site were connected
to municipal water and took no action to increase the number of
samples taken from private wells and in wetlands adjacent to their
homes to safeguard their health.
In closing, we hope that we have made our position clear. Although
USEPA's track record suggests that the agency will proceed with the
remedy they selected for a site despite public objection, we ask
USEPA to carefully consider our comments and respond accordingly.
Sincerely:
Board of Directors
Fulton Safe Drinking Water Action Committee
for Environmental Concerns, Inc.
Mary O
CV
Carol Piasecki
Gene Piasecki
Sandra Westan
Kathleen Wilcox
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New York State Department of Environmental Conservation
50 Wolf Road, Albany, New York 12233 - 7010
Thomas C. Jorling
JUN ! 5 1990 Commissioner
Mr. Robert Howe
Project Manager
US Environmental
Protection Agency
Region II
26 Federal Plaza
New York, NY 10278
Dear Mr. Howe:
Re: Volney Landfill Site
NYSDEC Site Code: 7-38-003
and
City of Fulton Water Pollution
Control Plant
SPDES Permit Number: NY0026301
Enclosed is the State Pollutant Discharge Elimination System
(SPDES) Discharge Permit for the City of Fulton Water Pollution
Control Plant (FWPCP) in Oswego County, New York. As per our
discussion at the public availability session held on May 24, 1989, I
have researched the history of the FWPCP and the general requirements
for wastewater treatment plants.
The FWPCP entered into a Judicial Order (Index No. 88-422) with
the State of New York on July 10, 1988. The judicial order was
imposed, pursuant to the United States Environmental Protection Agency
(USEPA) National Contingency Policy, as a result of the FWPCP failing
to meet its SPDES discharge permit requirements.
The present upgrade ordered at the FWPCP must be completed by
October 1, 1989. The discharge limits and requirements specified in
the enclosed SPDES permit must be met by March 31, 1990. If any
discharge limits, permit requirements, reporting deadlines or
construction milestones are not met, a schedule of fines can be levied
on the FWPCP in accordance with the judicial order.
In accordance with 6 NYCRR subdivision 754.4{g) and (h), prior to
the acceptance of the landfill leachate, an off-site, SPDES-permitted
wastewater treatment facility must notify the NYSDEC of its intention
to accept the waste. This shall include qualitative and quantitative
information necessary to characterize the waste. It is at the
discretion of the NYSDEC to either prohibit or condition the
acceptance of the waste and to modify the SPDES permit in accordance
with 6 NYCRR subdivision 754.4(i) to reflect the discharge of the
waste. These regulations apply to publicly owned treatment works
(POTW's) as well as privately owned treatment plants.
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Mr. Robert Howe Page 2
There is a contract in place between the City of Fulton and
Oswego County allowing the landfill leachate to be treated at the
FWPCP. There is also a letter dated May 14, 1986 from the NYSDEC to
the FWPCP approving the treatment of the landfill leachate. The FWPCP
is currently not accepting the landfill leachate because the treatment
required to properly treat the waste and achieve their SPDES permit
limits is not yet complete.
Since approvals granted to the FWPCP by the NYSDEC were prior to
the judicial order, the FWPCP must reapply to the NYSDEC upon
completion of the construction required by the order. Any proposal by
the FWPCP to receive landfill leachate will not be approved by the
NYSDEC until the judicial order is completely fulfilled.
The FWPCP is subject to a USEPA-approved Pretreatment Program.
The implementation requirements are specified as enforceable
conditions of its SPDES permit. The landfill would be considered a
Significant Industrial User (SIU) and would need to be issued an
Industrial Discharge Permit by the City of Fulton. The discharge
permit is then subjected to State review and appropriate revision, as
necessary.
.It should be noted that if the leachate migrating from the
landfill is contaminated by a listed hazardous waste, pursuant to
either the Resource Conservation and Recovery Act (RCRA) or Article
27, Title 9 of the New York State Environmental Conservation Law
(ECL), the leachate may be classified as a listed hazardous waste
under 40 CFR 261.3 (c)(2) or 6 NYCRR 371.1 (d)(3)(ii)(a). In that
case, the sewage treatment plant which receives the leachate must
comply with the permit-by-rule requirements (40 CFR 270.60 or
6 NYCRR 373-1.1 (d)(3)(iii)). The sludges generated at the sewage
treatment facility may also be classified as a listed hazardous waste
if any hazardous constituents, for which the leachate would qualify as
a listed hazardous waste, are found in the sludge. Shipments of
leachate would have to be manifested and a transporter, licensed under
6 NYCRR Part 364, would be required.
t A decision is currently being made by the USEPA and the NYSDEC on
whether or not the leachate is classified as a listed hazardous waste
under RCRA.or the ECL. jjhe decision to accept the waste, and the
potential RCRA implications at the treatment plant from that
acceptance, lies with the treatment plantTl
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Mr. Robert Howe Page 3
Please call me at (518) 457-5677 if you have any questions.
Sincerely,
Mark D. Kauffman '"
Assistant Sanitary Engineer
Central Remedial Projects Section
Bureau of Eastern Remedial Action
Div. of Hazardous Waste Remediation
Enclosure
cc: J. Singerman - USEPA - Region II
S. Patane - City of Fulton Engineer
E. Walsh - Oswego County Health Department
C. Rush - Oswego County Public Administrator
S. Weston - Fulton Safe Drinking Water Action Committee
M. Austin - Volney Town Board
C. Rose - Volney Town Board
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33 Central Avenue, Albany, New York 12210
Richard Ramon, P.E.
Project Manager
Western New York Superfund, Section 1
Emergency & Remedial Response Division
U.S. E.P.A.
26 Federal Plaza
New York, New York 10278 September 21, 1993
Dear Mr. Ramon:
Citizens' Environmental Coalition strongly opposes the EPA's proposal to
discharge hazardous waste from the Pollution Abatement Services (PAS) Superfund site
in Oswego, New York into a local sewage treatment facility. Sewage treatment facilities
are not equipped to handle hazardous wastes. Disposing of hazardous waste into such
a facility will cause additional environmental contamination. Currently, New York is
allowing sludge to be spread on agricultural lands. Sludge contaminated with hazardous
wastes could then be spread on land and may eventually cause groundwater or surface
water contamination. We strongly support the Fulton Safe Drinking Water Action
Committee's recommendation to conduct waste treatment at the site.
CEC is a statewide organization of over 90 community and environmental
organizations working on pollution problems in New York State. Since 1983, we have
worked to upgrade the Federal and State Superfund programs. We are especially
concerned about recent governement proposals to use sewage treatment plants for toxic
waste disposal. We believe the environmental and public health risks caused by disposal
of hazardous waste into a sewage treatment plant are significant and justify a prohibition
on their use. I would be happy to provide you with information on the serious
contamination of sewage sludge which already exists in New York State today, as well
as the state programs allowing its use on agricultural lands. We urge EPA to withdraw
their proposal to use the sewage treatment plant for any hazardous waste from the site,
and to support on-site waste treatment.
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Thank you for your anticipated consideration. I look forward to hearing from you.
Sincerely,
Anne Rabe
Executive Director
f.S. COVER.NMUIT PRINTING OFFICE: T994-386-54T/03098
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