Superfund Record of Decision Gallup's Quarry Superfund Site Plainfield CT


                                    EPA/ROD/R01-97/161
                                    1997
EPA Superfund
     Record of Decision:
     GALLUP1 S QUARRY
     EPA ID: CTD108960972
     OU01
     PLAINFIELD, CT
     09/30/1997

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                            DECLARATION FOR THE RECORD OF DECISION

                                Gallup's Quarry Superfund Site
                                    Plainfield, Connecticut
                                       September 30, 1997

STATEMENT OF PURPOSE

This decision document represents the selected remedial action for the Gallup's Quarry Superfund Site in
Plainfield, Connecticut, developed in accordance with the Comprehensive Environmental Response,
Compensation and Liability Act of 1980 (CERCLA) ,  as amended by the Superfund Amendments and
Reauthorization Act of 1986, and to the extent practicable, the National Oil and Hazardous Substances
Contingency Plan (NCP) ,  40 CFR Part 300 et seq. ,  as amended.  The region I Director of the Office of Site
Remediation and Restoration has been delegated the authority to approve this Record of Decision.

STATEMENT OF BASIS

This decision is based upon the Administrative Record which has been developed in accordance with Section
113  (k) of CERCLA and which is available for public review at the Plainfield Public Library and at the
region I Office of Remediation and Restoration Records Center in Boston, Massachusetts.  The
Administrative Record Index (Appendix E to the ROD) identifies each of the items comprising the
Administrative Record upon which the selection of the remedial action is based.

ASSESSMENT OF THE SITE

Actual or threatened releases of hazardous substances from this Site, if not addressed by implementing
the response action selected in this ROD, may present an imminent and substantial endangerment to the
public health or welfare or the environment.

DESCRIPTION OF THE SEIiECTED REMEDY

This ROD sets forth the selected remedy for the Gallup's Quarry Superfund Site, which addresses both the
source control and management of migration of contamination at the Site.

The selected remedy consists of natural attenuation of contaminants of concern in soil and groundwater,
implementation of institutional controls, long-term monitoring of groundwater and soil and Five-Year Site
reviews.

The major components of the selected source control remedy include:

       •      Institutional controls including land use restrictions to limit the use and disturbance of
              contaminated soils at the  Site;

       •      posting of warning signs;

       •      periodic maintenance of warning signs and entry gate;

       •      periodic sampling and analysis of contaminated unsaturated soils for contaminants of
              concern; and

The major components of the selected management of migration remedy include:

       •      institutional controls,  including land use restrictions to prevent future use of impacted
              groundwater until Interim Groundwater Cleanup Levels are met;

       •      long-term monitoring of groundwater and surface water quality to assess compliance with
              groundwater cleanup levels  and to ensure the surface water has not been adversely impacted;
              and

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DECLARATION

The selected remedy is protective of human health and the environment, attains Federal and State
requirements that are applicable or relevant and appropriate for this remedial action and is
cost-effective.  This remedy does not satisfy the statutory preference for remedies that utilize
treatment as a principal element to reduce the toxicity, mobility, or volume of hazardous substances.
The selected remedy was equally protective and more cost effective and implementable than the treatment
alternatives evaluated.  This remedy utilizes permanent solutions and alternative treatment technoloqies
to the maximum extent practicable.

As this remedy will result in hazardous substances remaininq on-site above health based levels, a review
will be conducted every five years after commencement of remedial action to ensure that the remedy
continues to provide adequate protection of human health and the environment.

EPA has determined that its future response at this site does not require physical construction.
Therefore, the site now qualifies for inclusion on the Construction Completion List.

The State of Connecticut has concurred with the selected remedy for this site.

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            GALLUP'S QUARRY SUPERFUND SITE

              TABIiE OF CONTENTS
Contents                                                                     Page Number

I.      SITE NAME, LOCATION AND DESCRIPTION  	1
II.     SITE HISTORY AND ENFORCEMENT ACTIVITIES  	1
       A.   Land Use and Response History 	1
       B.   Enforcement History 	2

III.   COMMUNITY PARTICIPATION 	3

IV.     SCOPE AND ROLE OF OPERABLE UNIT OR RESPONSE ACTION  	4

V.      SUMMARY OF SITE CHARACTERISTICS 	4
       A.   General 	4
       B.   Geology and Hydrogeology 	5
       C.   Groundwater Quality 	6
       D.   Soil 	7
       E.   Surface water, Sediment, and Wetland Soils  	7
       F.   Air Quality 	9
       G.   Ecology 	9

VI.     SUMMARY OF SITE RISKS 	10

VII.   DEVELOPMENT AND SCREENING OF ALTERNATIVES 	14
       A.   Statutory Reguirements/Response Objectives  	14
       B.   Technology and Alternative Development and  Screening  	16

VIII.   DESCRIPTION OF ALTERNATIVES  	16
       A.   Source Control (SC) Alternatives Analyzed 	16
       B.   Management of Migration  (MM)  Alternatives Analyzed  	24

IX.     SUMMARY OF THE COMPARATIVE ANALYSIS OF ALTERNATIVES  	32
       A.   Evaluation Criteria 	32
       B.   Summary of Comparative Analysis 	33

X.      THE SELECTED REMEDY 	39
       A.   Interim Groundwater Cleanup Level  	39
       B.   Unsaturated Soil Cleanup Levels 	41
       C.   Description of Remedial Components  	43

XI.     STATUTORY DETERMINATIONS 	46
       A.   The Selected Remedy is Protective of Human  Health and the Environment ....46
       B.   The Selected Remedy Attains ARARs  	47
       C.   The Selected Remedial Action is Cost-Effective	49
       D.   The Selected Remedy Utilizes Permanent Solutions and Alternative Treatment
            or Resource Recovery Technologies to the Maximum Extent Practicable	50
       E.   The Selected Remedy does not Satisfy the Preference for Treatment Which
            Permanently and Significantly reduces the Toxicity, Mobility, or Volume
            of the Hazardous Substances as a Principal  Element  	51

XII.   DOCUMENTATION OF SIGNIFICANT CHANGES	51

XIII.   STATE ROLE	51

APPENDIX A-    TABLES
APPENDIX B-    FIGURES
APPENDIX C-    LETTER OF CONCURRENCE
APPENDIX D-    RESPONSIVENESS SUMMARY
APPENDIX E-    ADMINISTRATIVE RECORD INDEX

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ROD DECISION SUMMARY
September 30, 1997

I. SITE NAME, LOCATION AND DESCRIPTION

The Gallup's Quarry Superfund Site (hereafter referred to as the "Site") is located at 86 Tarbox Road, in
the Town of Plainfield, Windham County, Connecticut. The Site is bounded by Mill Brook and its
associated wetlands to the north, single family residences and Route 12 to the east, an active railroad
(Providence and Worcester Railroad) and woodlands to the west, and single family residences and Tarbox
Road to the south. The Site encompasses approximately 29 acres and is located one mile southwest of
Plainfield Center and approximately 1,800 feet southeast of Plainfield's sewage treatment plant, which is
situated at the confluence of Mill Brook and Fry Brook (see Figure 1). Approximately 700 feet north of
the Site, on the opposite side of Mill Brook is an industrial park which contains the Intermark Fabric
Corporation facility and the Safety Kleen Corporation.

The Site is currently vacant and much of it is heavily vegetated. There are numerous overgrown mounds
and excavations throughout the Site which were the result of former quarry activities. There are no
structures on-Site. The nearest water supply wells to the Site are private wells located along Route 12
and Tarbox Road. In addition there are four nearby community water supply wells, including: the Gallup
Water Service (4,000 feet northwest); Brookside Acres (0.9 miles northeast); Hillsdale Water Company (2.8
miles north); and the Gallup Water Service/Lillibridge Division (0.7 miles southwest). Groundwater at
the Site is classified by the State of Connecticut as GA, which means that the groundwater is presumed to
be suitable for direct human consumption without treatment. The State's goal is to restore the
groundwater to drinking water quality.

Surface water bodies located within, or near the Site, include Mill Brook, Fry Brook and Packers Pond.
Mill Brook flows from east to west-southwest along the northern and western edges of the Site. Mill
Brook and Fry Brook ultimately discharges to Packers Pond. The State of Connecticut has classified the
section of Mill Brook that is north of the Site as B/A, which indicates that these water bodies may not
be meeting Class A water quality criteria. The lower portion of Mill Brook, below its confluence with
Fry Brook is classified as BC, indicating that the water meets Class B and it is suitable for cold water
fisheries.

A more detailed description of the Site history can be found in the Remedial Investigation Report on
pages 1-3 and 1-4.

II. SITE HISTORY AND ENFORCEMENT ACTIVITIES

A. Land Use and Response History

Limited information is available regarding the early operational history of the Site. Historical aerial
photographs and records at the Town of Plainfieid Assessor's office indicate that from 1951 to 1964 the
Site was operated as a sand and gravel quarry. In 1964, Mr. C. Stanton Gallup purchased the property.
While detailed usage of the Site from 1964 to 1977 is poorly documented, records indicate that Mr.
Gallup's also operated a gravel mining operation and leased a portion of the property to the Connecticut
Department of Transportation (DOT) to operate an asphalt batching plant.

As a result of complaints from neighboring residents, the Connecticut Department of Environmental
Protection (DEP) and the Connecticut State Police initiated an investigation of the Site in January of
1978. The DEP investigation concluded that the Site was used from the summer of 1977 until December 1977
for unlicensed waste disposal. Evidence collected by DEP indicates that Chemical Waste Removal, Inc.
(CWR) of Bridgeport, Connecticut transported drummed and bulk liquid waste material to the Site. These
materials included a variety of industrial wastes.

Emergency clean up efforts were performed during the summer of 1978 under the direction of the DEP and
the Connecticut State Police. This involved the removal and off-site disposal of 1,584 drums, 5,000
gallons of free liquid, and 2,277 cubic yards of contaminated soil from three distinct locations on the
Site (see Figure 2). These disposal sites are known as the former primary disposal area (FPDA), the
former secondary disposal area (FSDA) and the former Seepage Bed (Seepage Bed). The drums, as well as
liquid waste and contaminated soil, were removed from the Primary and Secondary Disposal Areas, located
in the northern portion of the Site. Remedial measures performed at the Seepage Bed, located in the
central portion of the Site, included the excavation of contaminated soil and in-situ treatment of the
remaining soils through the addition of 20 tons of lime. A buried inverted dump truck body was also
removed from the Site. In addition to these remedial activities, mine detectors were utilized to search
for additional buried drums. There was no evidence of additional buried drums, and it was believed that
all drums were recovered during the cleanup operations.

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Since the 1978 cleanup operations, periodic monitoring of soil and groundwater by the DEP, the
Connecticut Department of Health and EPA were performed.  In May of 1988, EPA initiated a limited Site
Investigation to evaluate the Gallup's Quarry Site with respect to conditions for additional removal
actions under the National Contingency Plan  (NCP).   Soil samples collected by EPA confirmed the presence
of volatile organic compounds (VOCs),  semi-VOCs and metals.  Based on the results of the 1988 Site
Investigation, on June 24, 1988 the Site was proposed to be added to EPA's National Priorities List
(NPL).   On October 4, 1989 the Site was listed on the NPL.

While the Site has been vacant since 1978 it has been utilized by trespassers for recreational purposes.
In 1994, a fence was erected at the entrance to the Site, and other foot/vehicle paths were blocked with
boulders, to limit Site usage by trespassers.  Additionally, warning signs were posted around the
property.

A more detailed description of the Site history can be found in the Remedial Investigation Report at
pages 1-3 to 1-7.

B.     Enforcement History

On April 1, 1993, June 2, 1993 and June 17, 1993, EPA notified forty parties, as either an owner/operator
of the facility or as generators of wastes that were disposed of at the Site, of their potential
liability with respect to the Site.  Thereafter, negotiations commenced with these potentially
responsible parties  (PRPs) regarding the settlement of the PRP's liability at the Site.

On September 7, 1993, EPA and the twenty-three PRPs, entered into an Administrative Order by Consent,
U.S. EPA Region I CERCLA Docket No. 1-93-1080 for the performance of a remedial investigation and
feasibility study (RI/FS).  EPA also recovered past costs from the same parties under a separate
Administrative Order by Consent, U.S.  EPA Region I CERCLA Docket No. 1-93-1079.

The PRPs have been active in the remedy selection process for this Site.  The PRPs representatives and/or
contractors attended the public meeting at the Site and the PRPs contractor prepared the RI/FS Reports.

III.    COMMUNITY PARTICIPATION

Throughout the Site's history, community concern and involvement has been relatively low.  Prior to EPA's
involvement with the Site, residents and town officials have kept up with Site activities by following
the local papers.  There were no organized citizens groups during the emergency removal effort by the DEP
or at any other time in the Site's history.  The DEP kept citizens informed of Site activities through
the media, the First Selectman,  the Fire Marshall and the police.  EPA has kept the community and other
interested parties apprized of Site activities through fact sheets, press releases and a public meeting.

During November 1993, EPA conducted interviews of various Plainfield town officials, business owners, and
residents.  These interviews were conducted to identify community concerns for preparation of EPA's
Community Relations Plan  (CRP).   In June of 1994, EPA released the CRP which outlined a program to
address community concerns and to keep citizens informed of and involved in activities during remedial
activities.  Notice of the release of this document was sent to local residents, town officials and to
the media on August 3, 1994.
In August of 1994, EPA issued a fact sheet release announcing the start of the remedial investigation at
the Site which summarized Site history; the Superfund process and the field activities to be performed at
the Site.  In March of 1996 EPA notified the public and media of the availability of the Initial Site
Characterization Report which detailed the results of the first phase of the field investigation.  In
November of 1996 EPA issued a fact sheet announcing the completion of the Remedial Investigation report
(RI) and detailing the results of this investigation.

On June 17, 1997, EPA issued the Proposed Plan for addressing residual soil and groundwater contamination
at the Site.  The Proposed Plan was made available to local residents and town officials by mailing
copies of this document to the mailing list and placing a copy in the Plainfield public library.  On June
25, 1997, EPA made the RI/FS and Human Health and Ecological Risk Assessment (RA) reports available for
public review at EPA's offices in Boston and at the Plainfield Town Library.

On June 25, 1997 EPA held an informational public meeting at the Plainfield Town Hall to discuss the
results of the RI report and the cleanup alternatives presented in the Feasibility Study Report  (FS) and
to present the Agency's Proposed Plan.  From June 25 to July 25, 1997, the Agency held a 30 day public
comment period to accept public comment on the alternatives presented in the Feasibility Study and the
Proposed Plan and on any other documents previously released to the public.  Also on June 25, 1997, the
Agency held a public hearing at the Plainfield Town Hall to accept any oral comments.  A transcript of
these comments and the Agency's response to comments are included in the responsiveness summary  (Appendix

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D) .

IV. SCOPE AND ROIiE OF OPERAKLE UNIT OR RESPONSE ACTION

The selected remedy was developed by combining components of different source control and management of
migration alternatives to obtain a comprehensive approach for addressing Site contamination. In summary
the remedy calls for natural attenuation of contaminants in soil and groundwater, a long-term sampling
and analysis program, and institutional controls to restrict Site use. Concentrations of contaminants in
the soil and groundwater will be reduced to target cleanup levels through natural processes in the
environment within an anticipated time period of approximately 27 years. Compliance with remedial action
objectives will be tracked through implementation of a long-term monitoring program of soil, groundwater
and surface water. The primary institutional control is to establish land use restrictions to prevent
the use of contaminated groundwater and to limit the use and disturbance of residual soil contamination
at the Site. This remedial response action was selected to address the primary potential risks to human
health and the environment, which has been identified as the future potential ingestion of contaminated
groundwater by a industrial or commercial worker at the Site.

V. SUMMARY OF SITE CHARACTERISTICS

The Executive Summary in the remedial investigation report (RI) contains an overview of this
investigation. The significant findings of the RI are summarized below.

A. General

The field investigation of the RI was conducted between 1994 and 1996. The RI assessed the type and
extent of contaminants present at the Site. The field program included primarily: geophysical surveys;
installation of temporary groundwater well points; installation of monitoring wells and piezometers (see
Figure 2); a soil gas survey; soil borings; groundwater, soil, surface water/sediment sampling and
analyses and a residential well sampling and analyses program. The Human Health and Ecological Risk
Assessment (RA) evaluated the potential impacts of Site contaminants posed to human health and the
environment. The RI provided baseline data reguired to evaluate potential cleanup actions. Principal RI
field activities included the collection and analysis of samples of groundwater, soil, sediment, surface
water, and air. These analyses show that the primary contaminants detected in Site groundwater, soils,
surface water and sediments are VOCs. Other contaminants identified include metals, polychlorinated
biphenyls (PCBs), pesticides and semi-VOCs.

The following sections summarize the findings of the field investigations.

B. Geology and Hydrogeology

The overburden deposits in the area consist of materials deposited as a result of glacial processes
during the Pleistocene epoch. A range of glacially-derived materials, including till, meltwater or
stratified drift deposits, and post-glacial deposits of floodplain alluvium, comprise the major surficial
geologic units in the vicinity of the Site. The most significant surficial deposits encountered within
the Study Area during the RI are till and stratified drift (the overburden soils). Overburden soils can
be further classified as coarser-grained or finer-grained components. The Site is dominated by
coarser-grained deposits which are representative of the retreat of the ice-mass. Finer-grained
components also exist to a limited extent, primarily in the low-lying areas of the Site.

The thickness of the overburden deposits range from non-existent in the vicinity of bedrock outcrops in
the eastern portion of the Site, to approximately 70 feet. The overburden thickness increases with a
decrease in the elevation of the bedrock surface. Till was encountered just above the bedrock surface at
nearly every location. The till horizon ranges in thickness from approximately 10 to 20 feet, with the
thickest accumulations located along bedrock highs. The till is relatively dense and is comprised of a
fine sandy matrix with abundant gravel, cobbles and boulders.

Bedrock in the vicinity of the Site consists of hornblende gneiss, biotite gneiss and amphibolite, and is
strongly faulted and folded. Based on the drilling program, depths to bedrock range from zero to 83 feet
below ground surface at the Site. Bedrock elevations are greatest in the eastern central portion of the
Site, and decrease to the north and west, and to a lesser degree to the south.

Hydraulic conductivity measurements indicate that coarse-grained stratified drift deposits in the lower
portion of the aguifer are the most permeable subsurface materials at the Site. The highest hydraulic
conductivities were found in the lower portion of the overburden aguifer northwest of the FPDA. The till
appears to be hydrogeologically distinct from the other overburden deposits, and on the average, provides
increased resistance to groundwater flow. This added resistance is not considered to be significant,

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however, because the consistency of the till and overburden deposits are highly variable and the
hydraulic conductivity contrast is relatively small. The bedrock has the lowest average hydraulic
conductivity.

Overburden groundwater flow south of the Seepage Bed is primarily east to west. In the vicinity of the
FPDA and FSDA groundwater flow is in a northwesterly direction. The hydraulic gradient in these areas is
steep and is strongly influenced by the dip of the bedrock surface. Northwest of the railroad tracks,
groundwater flow in the middle to lower portions of the aguifer converges from the northeast and
southwest toward a centerline area generally defined in the downgradlent direction. The flow direction
near these wells is from the former disposal areas to the northwest. Northeast of this centerline
groundwater flows in a southwesterly direction from the vicinity of Mill Brook and the industrial park.
North of Mill Brook and west of the railroad tracks the predominant groundwater flow direction becomes
more westerly (see Figure 3).

Groundwater in bedrock moves primarily in a northwesterly direction in the northern Study Area and
exhibits no apparent influence from the locally identified fracture zones. Groundwater is discharging
from bedrock into the overburden at most well locations. In the overburden aguifer, the downward
vertical flow component is significant within shallow deposits near the FPDA and the upward flow is
important in the upper portion of the aguifer near Mill Brook. The downward groundwater flow within the
FPDA appears to be primarily associated with infiltration of precipitation and collection of surface
water runoff from upland areas. This causes VOC concentrations to be highest in the middle to lower
portions of the aguifer. Stream piezometer data and groundwater flow modeling indicate that Mill Brook
generally gains water from the overburden aguifer within the Study Area.

C. Groundwater Quality

Groundwater guality data collected during the Remedial Investigation indicate the following:

• No significant groundwater contamination was detected within the overburden or bedrock units
in either the southern portion of the Site or in the vicinity of the Seepage Bed.

• In the northern portion of the Site, a narrow, low to moderate-concentration VOC plume was
detected in the overburden aguifer, extending from the FPDA northwest towards Mill Brook.
VOC compounds including 1,1,1-trichloroethane (TCA) and 1,2-dichloroethene (DCE) were
consistently detected at all locations along the plume centerline at concentrations as high
as 240 ppb and 1,300 ppb, respectively.

• Comparison of present concentrations with historical data indicate that VOC levels are
significantly decreasing with time. From 1978 through 1995, TCA, trichloroethylene (TCE),
and tetrachloroethylene (PCE) concentrations have decreased on the average by more than a
factor of two, every two years.

• Available information indicates that the leading edge of the VOC plume associated with the
FPDA is located in the vicinity of monitoring well clusters MW-102 and MW-101 (see Figure
2). Concentrations of TCA and DCE are below safe drinking water standards at MW-101.

• Results of surface water/sediment sampling and analyses, stream piezometer measurements, and
groundwater flow modeling indicate that some discharge of the shallow portion of the plume
into Mill Brook is occurring. However, the concentrations of Site contaminants detected in
the brook are well below those reported to cause adverse effects in fish or wildlife.

• Bedrock is not considered a preferred pathway for contaminant migration due to its
characteristically low hydraulic conductivity and the predominantly upward component of
groundwater flow from bedrock to overburden which exists throughout the Study Area.

D. Soil

Results of the soil gas survey and soil boring program indicate that the previous removal activities
taken by the State of Connecticut have removed all drums of waste and the bulk liguid waste from the
Site. Studies indicate that trace levels of VOCs, semi-VOCs, pesticides, PCBs and cyanide exist at the
Seepage Bed and FSDA on Site. In general, metal concentrations in soil are comparable to background
levels measured at upgradient locations at the Site, although low levels of cyanide were also detected at
various depths within the FPDA and FSDA. Other than the three known disposal areas at the Site, no other
disposal areas were found to exist.

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The FPDA is the only area with notable levels of residual contamination, primarily VOCs, including ethyl
benzene, toluene, xylene, TCE, TCA, and PCE. In general, the highest VOC concentrations are located at
or just below the groundwater table, in native materials immediately beneath the fill materials. These
concentrations diminish guickly with depth. Toluene, ethyl benzene, xylene, and in one case a low level
of PCE were also detected at or near the ground surface, within the fill material (the source of these
contaminants could be related to recreational uses of this parcel since disposal occurred). Total VOC
concentrations were either below the sample method detection limits, or were less than 1 parts per
million (ppm) for the majority of samples. Trace to low-levels of PCBs were also detected in both near
surface samples, and (at one location) at a depth of 32 feet below the ground surface. The highest
concentration of any single PCB compound was 6.4 ppm in the 1-3.5 foot interval at the FPDA. Most other
PCB detections at the Site were below 1 ppm. There does not seem to be any spatial trend or relationship
among the detections of PCBs at the FPDA.

E. Surface water, Sediment, and Wetland Soils

Surface water, sediment, and wetland soils upstream, adjacent to, and downstream of the Site were sampled
and analyzed during the RI and long-term monitoring program to assess the potential for transport of
contaminants from the Site. The samples were analyzed for VOCs, semi-VOCs,
metals/cyanide, and pesticide/PCBs.

In the surface water, VOCs were not detected in the upstream portions of Mill Brook. Six VOCs were
detected at least once in the five rounds of surface water samples that were collected from the 11
locations sampled. The most consistent detections were DCE and PCE in one upstream location in Fry
Brook. This location is approximately 1,500 feet upstream of the confluence of Fry Brook and Mill Brook
and therefore these detections are considered not to be Site-related (believed to be the result of nearby
industrial activities). The other detections of PCE and DCE were at trace concentrations at locations
below the confluence of Fry and Mill Brooks. In addition, TCA was detected once at trace levels at a
location adjacent to the Site along Mill Brook. TCE was detected twice at the upgradient Fry Brook
location and once at a location adjacent to the Site in Mill Brook. Toluene was detected twice at
upgradient Mill Brook locations at trace levels. All of the VOC concentrations detected are well below
those expected to cause adverse effects in fish or wildlife.

Only low levels of one semi-VOC compound, 4-methylphenol, were detected in surface water samples. The
locations where this contaminant was detected are far upstream along Mill Brook and downstream in Packers
Pond, which are locations not expected to have been impacted by the Site. While bis(2-ethyl
hexyl)phthalate was detected in the surface water at low levels, it was detected at upgradient Mill Brook
locations and in downgradient locations along lower Mill Brook and Packers Pond and is not believed to be
Site-related. No pesticides or PCB compounds were detected in any surface water samples. While metals
(aluminum, barium, calcium, iron, lead, magnesium, manganese, potassium, sodium and zinc) were detected
in the surface water, they were not detected at concentrations that are unexpected in non-contaminated
waters.

In the sediments, metals were detected infrequently and, when detected, had concentrations close to the
respective detection limit and/or were detected at remote upstream or downstream locations. With the
exception of maximum concentrations detected in Packers Pond (which receives stormwater runoff from
Lillibridge Road) general metal concentrations in sediments were at concentrations within the ranges
expected in naturally occurring soils or sediments. VOCs were generally detected infrequently and at
relatively low concentrations. Only toluene was detected at trace levels in a sample collected adjacent
to the Site in Mill Brook near the downgradient edge of the Gallup's plume. This occurrence is believed
to be Site related. The primary semi-VOC constituents detected were polyaromatic hydrocarbons (PAHs).
The detections of PAH likely reflect non-point contributions from local sources, such as stormwater
runoff from the railroad tracks and nearby roads. Elevated concentrations of bis(2-ethyl hexyl)phthalate
were measured in Fry Brook (1,300 ppm) and lower Mill Brook (64 ppm), below the confluence of these two
streams. The source appears to originate in Fry Brook. Organochlorine pesticide compounds were detected
infrequently, with no apparent trend with regard to location or source. Their occurrence likely reflects
residues of persistent compounds that were routinely used for insect control before being banned from
commercial production.

With respect to wetland soil sampling, a total of 10 wetland soil samples were collected during the field
survey, most of which were close to the water table at the time of collection. Similar to sediments,
metals analysis indicate no levels in excess of what would be expected in naturally occurring wetland
soils. VOCs including acetone, 2-butanone, TCE, and carbon disulfide, were detected infrequently and at
low concentrations. While acetone was detected in two remote locations and are considered to be non-Site
related detections, it was also detected at moderate concentrations at one location approximately 200
feet southeast of the FPDA, along with low concentrations of 2-butanone. A trace level of TCE was
detected in a wetlands soil sample collected approximately 50 feet east of the FPDA. This detection may

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be related to the FPDA, since TCE has been detected in this area. Based on the topography, however,
surface water runoff from the former disposal area is unlikely to impact the wetland. No other wetland
soil samples had concentrations detected above the instrument detection limit.

PAHs were detected infrequently at generally below 0.1 ppm. Phthalate esters were also detected
infrequently, ranging from non-detect to 2.2 ppm. The presence of these compounds is likely to be
associated with periodic or seasonal flooding of wetlands as the wetland sampling locations are remote
and generally inaccessible. Since these compounds are relatively immobile except in surface water or as
airborne particulates, these compounds may have originated from non-point sources such as the railroad
line or runoff from nearby highways. Trace levels of PCB compounds in wetland soil samples that were
detected adjacent to the Site may be Site-related. Other sources of contaminant input into the local
environment might include atmospheric deposition, transport from upstream sources and deposition
following flood events. Organochlorine pesticide compounds were also detected infrequently, with no
apparent trend with regard to location or source, and their occurrence likely reflects residues of
persistent compounds that were routinely used for insect control before being banned from commercial
production.

F. Air Quality

Ambient air quality was determined prior to the start of the field studies to establish a baseline for
air quality. For the baseline survey, air quality in the breathing zone (between approximately three and
six feet above the ground surface) was determined based on measurements of total VOC and respirable dust
at eight locations across the Site. These eight stations were located at each of the three known former
disposal areas and at upwind and downwind locations along the perimeter of the Site. During the baseline
survey, no VOCs were detected above the EPA approved action level of 1 ppm at any of the eight monitoring
locations. Also, no respirable dust readings greater than the EPA-approved action level were recorded
during the baseline survey at any of the monitoring stations.

Based on the baseline and periodic air monitoring performed during the investigation, undisturbed ambient
air quality in the vicinity of the Site does not appear to have been impacted by former disposal
practices at the Site. To confirm this, compound specific air monitoring was performed during the later
stages of the field investigation. Quantitative air monitoring was performed in the vicinity of the
Former Primary Disposal Area. Toluene, ethyl benzene, total xylenes, PCE, and PCBs were analyzed for.
Data indicate that none of these compounds were detected at any of the air sampling locations for the
duration (approximately eight hours) of the sampling event.

A complete discussion of Site characteristics can be found in the RI report in Sections 3 and 4.

G. Ecology

An ecological study was performed to delineate wetlands and to make local observations of the types and
abundance of plants and animals in the area. Wetlands delineations were performed to the extreme
northern and western boundaries of the Site, up to the Mill Brook channel, using both the State of
Connecticut's accepted criteria and the Federal criteria using U.S. Army Corps of Engineer methods. The
wetland bordering the southwestern portion of the Site is a white cedar swamp supporting a varying
density of trees. Additional hydrophytic plant species identified within this wetland include red maple,
common reed, duckweed, jewelweed, cattail, and coast pepper-bush. The swamp is hydraulically connected
to the Mill Brook system by a narrow stream. The swamp remains inundated during most years with the
possible exception of drought years, and receives water through seepage from surrounding uplands and from
surface water runoff.

Adjacent to the cedar swamp is an upland system that supports a sub-climax to near climax hardwood
forest. Topography of the upland area includes steep slopes to gently undulating land. Canopy
vegetation (trees) are dominated by red, white and chestnut oaks, with white oaks nearer to the wetland
area and the red and chestnut oaks occurring on the higher portions of the uplands. Other canopy species
include white ash, quaking aspen, hickories and dogwoods. Common understory vegetation included sheep
laurel, black cherry, and green briar. North of this upland area is the broad floodplain of Mill Brook
which coincides with the northern boundary of the Site. The floodplain is generally flat with many small
raised hummocks. This area reflects more seasonal water fluctuations than the cedar swamp and has a more
efficient drainage system. As a result, this system supports a higher diversity of hardwood canopy,
under story and herbaceous species. Wetlands also occur in the area northeast (upgradient) of the FPDA
and FSDA and along the northern border of the Site, east of the railroad bed.

Historical use of the property for quarrying activities are responsible for the character of the plant
communities found throughout the study area. The Site has numerous excavated depressional areas, and
areas of mounded earth material. The features significantly distinguish the quarried area from the area

-------
off Site to the west, which is undeveloped and relatively undisturbed. The quarry consists of many
excavated zones which are devoid of vegetation, with adjacent areas which support a mix of successional
pioneer species. Density of vegetation ranges from bare soil to dense brush and sapling sized trees.
Areas of highest vegetation density are associated with both low elevation (greatest soil moisture
regime) and age (length of time since disturbance).

Trees throughout the guarry are young and small, in comparison with those found in the forested areas
west of the railroad. Vegetation on Site is characterized as early successional species. The more
common species include black willow, northern bayberry, eastern cotton-wood, guaking aspen, goldenrod,
and black cherry.

Few wildlife species were observed or noted during wetland delineation activities. Wildlife activity at
the Site was limited during the survey period but should be expected to support a much greater diversity
of wildlife during the spring and summer seasons when birds (especially migratory) conduct nesting and
rearing activities. Most of the species observed during the survey are expected to overwinter at the
study area. Bird species recorded include mourning dove, eastern peewee, tufted titmouse, black-capped
chickadee, blue jay, white-breasted nuthatch, gray catbird, American robin and northern cardinal. No
endangered species were observed nor are reported to reside at the Site.

VI. SUMMARY OF SITE RISKS

A Human Health and Ecological Risk Assessment (RA) was performed to estimate the probability and
magnitude of potential adverse human health and environmental effects from exposure to contaminants
associated with the Site. The RA followed a four step process: 1) contaminant identification, which
identified those hazardous substances which, given the specifics of the Site were of significant concern
; 2) exposure assessment, which identified actual or potential exposure pathways, characterized the
potentially exposed populations, and determined the extent of possible exposure; 3) toxicity assessment,
which considered the types and magnitude of adverse health effects associated with exposure to hazardous
substances, and 4) risk characterization, which integrated the three earlier steps to summarize the
potential and actual risks posed by hazardous substances at the Site, including carcinogenic and
non-carcinogenic risks. The results of the human health RA for the Gallup's Quarry Site are discussed
below followed by the conclusions of the ecological RA.

Fifty-two contaminants of concern (COG) , listed on Table 1 in Appendix A were selected for evaluation in
the risk assessment. These contaminants constitute a representative subset of the 95 contaminants
identified at the Site during the RI. The fifty-two COCs were selected to represent potential Site
related hazards based on toxicity, concentration, frequency of detection, and mobility and persistence in
the environment. A summary of the health effects of each of the COCs can be found in Appendix C of the
RA report.

Potential human health effects associated with exposure to the COCs were estimated quantitatively or
qualitatively through the development of several current or future hypothetical exposure pathways. These
pathways were developed to reflect the potential for exposure to hazardous substances based on the
present uses, potential future uses, and location of the Site. Future residential development of the
Site is considered unlikely because the Site is currently zoned for industrial use by the Town of
Plainfield, a large portion of the Site is wetlands, and an active railway runs along the property.
However, the Site is known to be utilized by residential trespassers for recreational purposes and
therefore current exposures to those individuals were assessed.

Limited future development for commercial/industrial use may occur at the Site. Future Site excavation
workers or Site employees may be exposed if the Site is developed or operations at the quarry are
resumed. Five potential exposure pathways were quantitatively assessed for the Site. A more thorough
description can be found in Chapter 4 of the RA. The following is a brief summary of the exposure
pathways evaluated.

Current and future potential exposure to a trespasser from ingestion of and dermal contact with
contaminated surface soils was evaluated. This pathway assumes that the trespasser is a youth, aged 9 to
18 years old, and that trespassing occurred over a period of 10 years. The exposure period is 39 days
per year (assumes contact for 1 day per week for Spring, Summer, and Autumn). It was also assumed that
the trespasser would come into contact with contaminated Site sediments 13 days per year (one day each
week during the Summer months), with exposure to the hands, arms, legs and feet during wading activities.
Incidental ingestions and dermal contact with surface soils represents the only current exposure pathway
evaluated in the baseline risk assessment.

Assuming the Site were developed for commercial/industrial use, a future potential exposure from
incidental ingestion of and dermal contact with contaminated surface and subsurface soils by an

-------
excavation worker was evaluated. This pathway assumes that over a period of one year that the excavation
worker would be exposed to Site soils for 5 days a week for a total of 3 months.

Future potential exposure to surface soils by a Site employee through ingestion and dermal contact was
evaluated. This pathway assumes that the Site employee is exposed to contaminated surface soil 250 days
per year for 25 years.

While contaminated ground water at the Site is not currently being ingested, future potential exposure to
employees of a hypothetical business from ingestion of groundwater as a drinking water supply was
evaluated.

This pathway assumes that a future user of Site groundwater would drink 1 liter of contaminated water for
250 days per year for 25 years.

For exposures to soils and sediments, an average and a reasonable maximum exposure (RME) estimate was
generated corresponding to exposure to the arithmetic average and the 95 percent upper confidence limit
on the arithmetic average concentration detected in that particular medium. For exposure to groundwater,
an average and a reasonable maximum exposure estimate was generated corresponding to exposure to the
arithmetic average and the maximum concentration detected in groundwater. Excess lifetime cancer risks
were determined for each exposure pathway by multiplying the exposure level with the chemical specific
cancer potency factor. Cancer potency factors have been developed by EPA from epidemiological or animal
studies to reflect a conservative "upper bound" of the risk posed by potentially carcinogenic compounds.
That is, the true risk is unlikely to be greater than the risk predicted. The resulting risk estimates
are expressed in scientific notation as a probability (e.g., 1 x 10 -6 or 1/1,000,000) and indicate
(using this example), that an average individual is not likely to have greater than a one in a million
chance of developing cancer over 70 years as a result of site-related exposure of the compound at the
stated concentration. Current EPA practice considers carcinogenic risks to be additive when assessing
exposure to a mixture of hazardous substances.

The hazard index (HI) was also calculated for each pathway as EPA's measure of the potential for
non-carcinogenic health effects. To calculate the HI for each individual compound the exposure level is
divided by the reference dose (RfD) or other suitable benchmark for non-carcinogenic health effects.
Reference doses have been developed by EPA to protect sensitive individuals over the course of a lifetime
and they reflect a daily exposure level that is likely to be without an appreciable risk of an adverse
health effect. RfDs are derived from epidemiological or animal studies and incorporate uncertainty
factors to help ensure that adverse health effects will not occur. The HQ is often expressed as a single
value (e.g., 0.3) indicating the ratio of the stated exposure as defined to the reference dose value (in
this example, the exposure as characterized is approximately one third of an acceptable exposure level
for the given compound). The HQ is only considered additive for compounds that have the same or similar
toxic endpoint and the sum is referred to as the HI. (For example: the HQ for a compound known to
produce liver damage should not be added to a HQ of another compound which has kidney damage as a toxic
endpoint).

The results of the Human Health RA indicate that the only risks exceeding EPA's threshold for remedial
action (i.e., 1 x 10 -4, OSWER Directive 9355.0.30) are those potentially posed to a future employee. Of
the exposure pathways evaluated for a future Site employee, the future potential ingestion of groundwater
represents the only pathway exceeding EPA's goals for remedial actions (10 -4 to 10 -6 target cancer risk
range). Vinyl chloride in groundwater is the predominant contributor to the unacceptable groundwater
cancer risk estimates. This is a future use scenario since no individuals are currently ingesting
contaminated groundwater at the Site. For non-carcinogenic hazards, the total Hazard Index for
groundwater was estimated at 10 and 4, for the maximum and average detected concentrations, respectively.
The primary risk driver is silver, which was detected infreguently and at concentrations above drinking
water standards 1. All other pathways evaluated in the human health risk assessment were within the 10
-4 to 10 -6 target risk range, which is the range considered acceptable by EPA pursuant to the National
Contingency Plan (NCP). Table 2 is a summary of the carcinogenic and non-carcinogenic risks for all
pathways evaluated.
1 There were anomalously high detections of a range of metals, including Silver, in select
groundwater samples which is believed to be the result of turbid samples (despite the use
of low flow sampling procedures). While this is recognized, the data with the high
detection of metals were conservatively utilized.

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                                           TABIiE 2
                                         RISK SUMMARY

                                     Non-Carcinogenic
                                       Hazard Index

Exposure Pathway                     Avg.        RME

Ground Water Future Ingestion         4           10
by an employee

Surface Soils Current/Future         0.06         0.3
Ingestion and Dermal Contact
by a Youth Trespasser

Future Ingestion and Dermal           0.3          1
Contact by a Site Employee

Surface and Subsurface Soil           0.6         0.8
Future Ingestion and Dermal
Contact by Excavation Worker

Sediments Future Ingestion and      0.002        0.004
Dermal Contact by a Youth
Trespasser

RME = Reasonable Maximum Exposure
  Carcinogenic
   Total Risk

  Avg.           RME

5.0x10  -4     2.0x10 -3


1.0x10  -6     6.0x10 -6



6.0x10  -6     7.0x10 -5


4.0x10  -7     1.0x10 -6



4.0x10  -8     9.0x10 -8
An Ecological Risk Assessment was also prepared for the Site.  The Ecological RA evaluated the potential
ecological impacts from the release of hazardous substances to the environment.  The Site is located
adjacent to and upgradient of wetlands and a small perennial stream (Mill Brook).   These habitats support
a variety of ecological receptors which may be exposed to Site-related contaminants.  Risk to aguatic
receptors was evaluated by comparing mean and maximum surface water and sediment concentrations with
appropriate criteria (Ambient Water Quality Criteria (AWQC) for surface water impacts and National
Oceanic and Atmospheric Administration (NOAA) effects range low and medium sediment guality criteria for
sediment impacts).  Risks to receptors inhabiting the Site wetlands were assessed by modeling food chain
transfer to selected indicator species (deer mouse, short-tailed shrew, woodcock).

Concentrations  (total and dissolved) of aluminum and lead detected in surface water samples collected
adjacent to or downgradient of the Site exceeded their respective chronic AWQC indicating that potential
adverse effects are possible within Mill Brook.  However, upstream concentrations of aluminum and lead
exceed levels detected adjacent to and/or downgradient of the Site, indicating an upstream source or
regionally elevated levels of these constituents.

Concentrations of various inorganics (particularly chromium, copper and nickel),  PAHs and PCBs/pesticides
detected in adjacent/downgradient Mill Brook sediment samples exceeded sediment guality guidelines
associated with adverse affects to sensitive benthic biota.  However,  upgradient concentrations of these
contaminants are generally similar and also exceed sediment guality guidelines, indicating these
constituents are not believed to be Site-related.

Impacts to birds and mammals (herbivores and insectivores) foraging within the adjacent wetlands are not
anticipated based on the low concentrations of Site-related contaminants.

Actual or threatened releases of hazardous substances from this Site,  if not addressed by implementing
the response action selected in this ROD, may present an imminent and substantial endangerment to public
health, welfare or the environment.  In particular, the future potential ingestion of contaminated
groundwater as a drinking water supply would represent an unacceptable risk to human health.

For a complete explanation of risks posed by contamination at the Gallup's Quarry Site please refer to
the RA report dated June 1997.

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VII. DEVELOPMENT AND SCREENING OF ALTERNATIVES

A. Statutory Requirements/Response Objectives

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

Based on preliminary information relating to types of contaminants, environmental media of concern, and
potential exposure pathways, remedial response objectives (RRO's) were developed to aid in the
development and screening of alternatives. These RRO's were developed to mitigate existing and future
potential threats to public health and the environment.

As discussed above in the summary of potential risks at the Site, surface soils, subsurface soils,
sediments and surface water did not pose a human health risk above EPA's acceptable risk range. The only
unacceptable risk posed by the Site is the future potential ingestion of contaminated groundwater by a
hypothetical Site worker.

Although soils do not pose an exposure risk, contaminants may have the potential to leach from soils into
groundwater at levels which may cause exceedences of groundwater remediation goals. To this end, the
State of Connecticut has enacted soil Remediation Standard Regulations (RSRs) that consider leaching to
groundwater. A review of the Site data shows that some soil concentrations within the FPDA and the
Seepage Bed exceed the RSRs. Further discussion of these standards is provided in Section 2.2.3 of the
Feasibility Study. Therefore, two response media have been identified for further evaluation: soil and
groundwater. Soil refers to soils within the FPDA, and within the Seepage Bed. The following specific
Remedial Response Objectives have been identified for each response media:

Source Control (Soil)

• Prevent and/or minimize, to the extent practicable, the potential for leaching of hazardous
substances, from the soil or waste into the groundwater, at concentrations that will cause
groundwater concentrations greater than the cleanup levels;

• Comply with Federal and state "applicable or relevant and appropriate requirements," or
(ARARs) .

Management of Migration (Groundwater)

• Prevent ingestion of contaminated groundwater in excess of applicable or relevant and
appropriate drinking water standards or posing a potential total cancer risk greater than 10
-4 to 10 -6.

• Prevent ingestion of groundwater containing contaminants at concentrations in excess of
applicable or relevant and appropriate drinking water standards for each noncarcinogenic
compound and a total Hazard Index greater than unity (1) for non-carcinogenic compounds
having the same target endpoint of toxicity.

Comply with Federal and state ARARs.

B. Technology and Alternative Development and Screening

CERCLA and the NCP set forth the process by which remedial actions are evaluated and selected. In
accordance with these requirements, a range of alternatives were developed for the site.

With respect to source control, the RI/FS developed a limited range of alternatives in which treatment
that reduces the toxicity, mobility, or volume of the hazardous substances is a principal element. This
range included an alternative that removes or destroys hazardous substances to the maximum extent
feasible, eliminating or minimizing to the degree possible the need for potential long term management.
This range included a limited action alternative that involves no treatment but provides limited

-------
protection through engineering or institutional controls. This range also included a no action
alternative.

With respect to groundwater response action, the RI/FS developed a limited number of remedial
alternatives that seek to attain site specific cleanup levels using different technologies; and a no
action alternative.

As discussed in Section 2 of the Feasibility Study, the RI/FS identified, assessed and screened
technologies based on implementability, effectiveness, and cost. These technologies were combined into
source control (SC) and management of migration (MM) alternatives. Chapter 3 of the Feasibility Study
presented the remedial alternatives developed by combining the technologies identified in the previous
screening process with the categories identified in Section 300.430(e)(3) of the NCP. The purpose of the
initial screening was to narrow the number of potential remedial actions for further detailed analysis
while preserving a range of options. Each alternative was then evaluated and screened in Chapter 3 of
the Feasibility Study.

In summary, of the nine source control and six management of migration remedial alternatives screened,
seven of the SC alternatives and four of the MM alternatives were retained for detailed analysis. Table
3 in Appendix B of this document identify the alternatives that were retained through the screening
process, as well as those that were eliminated from further consideration.

VIII. DESCRIPTION OF ALTERNATIVES

This Section provides a narrative summary of each alternative retained for detailed analysis. A detailed
assessment of each alternative can be found in Table 4-1 of the Feasibility Study.

A. Source Control (SC) Alternatives Analyzed

The Source Control alternatives that underwent detailed analysis for the Site include:

Alternative SC-1: No Action
Alternative SC-2: Natural Attenuation with Institutional Controls
Alternative SC-3: Capping of FPDA Soil
Alternative SC-4: On-Site Treatment Via Soil Vapor Extraction
Alternative SC-5: Excavation, Off-Site Treatment/Disposal of FPDA Soils
Alternative SC-5a: Off-Site Treatment Via Low-Temperature Thermal Desorption
Alternative SC-5b: Off-Site Treatment Via Asphalt Batching
Alternative SC-5c: Off-Site Disposal at a Landfill

1. Alternative SC-1: No-Action

This alternative was evaluated in detail in the Feasibility Study to serve as a baseline for comparison
with the other remedial alternatives under consideration. Under this alternative, no remedial measures
beyond the removal effort performed in 1978 would be conducted to address residual contamination
remaining in the former disposal areas. Residual contamination would remain on-Site and no contaminants
would be removed, treated or destroyed. However, the risk assessment showed that there are no
unacceptable heath or environmental risks associated with potential exposure to soils. Future use of the
impacted area is not expected to include residential development primarily because the area is
industrially zoned. In addition, the property is not conducive to residential development due to the
presence of a shallow water table, wetlands, and active railway.

Under this alternative, COG in the unsaturated soil would migrate to groundwater via rainwater
infiltration, and concentrations of COG exceeding the soil remediation standards would remain in the
soil. However, natural attenuation processes would continue to reduce the volume, toxicity and mobility
of the contaminants, and groundwater effects, at a significant rate. Average concentrations of COCs in
soil are expected to be reduced to cleanup levels in approximately 15 years (see Appendix D of the
Feasibility Study). The presence of COG in soil does not impact groundwater remediation time frames, as
demonstrated by the three-dimensional groundwater model developed for the Site (see Appendix B of the
Feasibility Study).

ESTIMATED TIME FOR DESIGN AND CONSTRUCTION: NA
ESTIMATED TIME FOR OPERATION: NA
ESTIMATED CAPITAL COST: $0
ESTIMATED 0 & M (Present Worth): $0
ESTIMATED TOTAL COST (Present Worth): $0

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2.   Alternative SC-2 :   Natural Attenuation with Institutional Controls

Alternative SC-2 builds on Alternative SC-1 by adding institutional controls and access restrictions to
control future activities in the vicinity of the FPDA and Seepage Bed, periodic monitoring of unsaturated
soils in both these areas to track natural attenuation, and Five-Year Site Reviews to evaluate the
effectiveness and adeguacy of remedial measures.  Under Alternative SC-2, concentrations of COG in the
soil would not be addressed through active remedial measures, but would continue to be reduced at a
significant rate through natural attenuation processes.  The presence of COG in FPDA soils has been
demonstrated by the three-dimensional groundwater model not to impact overall groundwater remediation
time frames (see Appendix B in the Feasibility Study).

Under this alternative a State environmental land use restriction would be placed on the FPDA and Seepage
Bed portions of the Gallup's property to limit use and disturbance of the soils, warning signs would be
posted and maintained and periodic sampling and analysis of soils for those constituents that exceed the
cleanup levels would be performed.  Additionally, Five-Year Site Reviews would be conducted to evaluate
the effectiveness and adeguacy of remedial measures and to ensure the continued protection of human
health and the environment.

As with Alternative SC-1, COG in soil would be allowed to naturally attenuate via rainfall infiltration
and groundwater flushing.  Similar to SC-1, under this alternative average concentrations of COG in the
unsaturated soil are anticipated to be achieved in approximately 15 years.
ESTIMATED TIME FOR DESIGN AND CONSTRUCTION:
ESTIMATED TIME FOR OPERATION:
ESTIMATED CAPITAL COST:
ESTIMATED 0 & M  (Present Worth):
ESTIMATED TOTAL COST  (Present Worth):
4 Months
Approximately 15 years
$53,500
$75,000
$129,000
3.  Alternative SC-3:  Capping of Former Disposal Area Soils

Under this alternative, all soils contaminated above cleanup levels would be covered with a
low-permeability cap conforming to Resource Conservation and Recovery Act (RCRA) Subtitle C standards.
Contaminated soil would remain on Site, and no contaminants would be removed, treated, or destroyed.  The
construction of the impermeable cap would limit rainwater infiltration and leaching of COG from the
unsaturated zone to groundwater, and therefore slow contaminant migration in the groundwater.  COG in the
saturated zone would continue to impact groundwater, although natural attenuation processes would
continue to reduce the volume, toxicity, and mobility of the COG in the saturated zone.  Results of a
three-dimensional groundwater model  (see Appendix B of the Feasibility Study) have demonstrated that the
presence of VOC COG in FPDA soils (either unsaturated or saturated) will not impact groundwater
remediation time frames.  While there are no unacceptable direct contact risks to residual contamination
in the soil, a cap would prevent direct contact with residual soils to lower the existing exposure risks.
Alternative SC-3 would contain the following components:

       •      consolidating soil from the former Seepage Bed that exceed cleanup goals with soil within
              the FPDA;
       •      filling of the FPDA depression with clean fill material from an on-Site borrow pit;
       •      installation of an impermeable cap over the FPDA;
       •      seeding and mulching of the regraded and capped area;
       •      construction of drainage swale/stormwater controls to channel  surface water around the new
              capped area;
       •      institutional controls  including deed restrictions would be placed on the FPDA portion of
              the Gallup's property to limit use and disturbance of the soils;
       •      construction of a fence around the FPDA and posting of warning signs;
       •      periodic maintenance,  including maintenance and repair of the  fence and cap system and
              access road; and,
       •      Five-Year Site Reviews  to evaluate the effectiveness and adeguacy of remedial measures.

Institutional controls, along with fencing and warning signs, would be used to prevent development over
the FPDA and damage to the cap.  A State environmental land use restriction including deed restrictions
would be placed on the land to limit use.  A 12-foot high chain-linked fence would be installed around
the cap, just outside the perimeter drainage.  The fence would include a gate to allow access for
maintenance.  Warning signs would be posted every 100 feet along the fence.   Five-Year Site Reviews would
also be performed to confirm the effectiveness and adeguacy of measures implemented under Alternative
SC-3.
Installation of a cap would reduce the transfer of constituents from soil to the groundwater by reducing
the volume of rainwater that infiltrates through the soils.  Therefore, COG would remain in the soil for

-------
a longer time period.  Although soils containing residual COG beneath the groundwater table would
continue to impact groundwater, contaminant reduction rates throughout most of the groundwater plume
would not be accelerated beyond natural attenuation rates, as demonstrated by results of
three-dimensional groundwater modeling.  In fact, the reduction of flushing through the FPDA saturated
zone soils may lengthen the remediation time
frame for groundwater.

ESTIMATED TIME FOR DESIGN AND CONSTRUCTION:            18 Months
ESTIMATED TIME FOR OPERATION:                          30 years
ESTIMATED CAPITAL COST:                                $726,000
ESTIMATED 0 & M  (Present Worth):                       $150,000
ESTIMATED TOTAL COST  (Present Worth):                  $876,000

4.  Alternative SC-4a:  Excavation, On-Site Treatment of FPDA Soils with Ex-Situ Soil Vapor Extraction
(SVE)

This alternative involves excavation of Site soils exceeding cleanup levels and ex-situ treatment using
soil vapor extraction  (SVE) to remove VOCs.  Following the remediation of soil to cleanup levels, as
confirmed by sampling and analysis, treated soil would be replaced on Site.  This alternative would be
effective in treating soil for VOCs only, and would not reduce concentrations of semi-VOCs (i.e.,
bis(2-ethyl hexyl)phthalate).  Semi-VOCs would continue to degrade via natural attenuation as discussed
under alternatives SC-1 and SC-2.   The following elements would be included under Alternative SC-4a:

       •      excavation and  stockpiling of clean soils overlying the FPDA soils;
       •      excavation of FPDA soils which exceed remediation standards for VOCs,  above the historical
              average, seasonal low water table;
       •      excavation of saturated soils below the contaminated zone in the FPDA to an elevation of two
              feet below the  historical average,  seasonal low water table;
       •      sampling and analysis for VOCs of the excavation side walls;
       •      replacement of  the stockpiled clean excavated soils into the excavated area;
       •      sampling and analysis of excavated contaminated materials for baseline characterization;
       •      ex-situ SVE treatment of Site soils;
       •      institutional controls including deed restrictions would be placed on the FPDA portion of
              the Gallup's property to limit use and disturbance of soils;
       •      construction of a security fence with posted warning signs around the FPDA and treatment
              area;
       •      periodic maintenance, including maintenance and repair of the fence  and treatment area,  SVE
              system optimization,  and periodic soil and vapor sampling;
       •      confirmatory sampling and analysis of FPDA soils after treatment;
       •      returning the treated soils to the FPDA,  with regrading;
       •      Site restoration,  including disassembly of the treatment area and fence;
       •      Five-Year Site  Reviews to evaluate the effectiveness and adequacy of remedial measures.

Soils which require treatment would be excavated to two feet below the surveyed elevation of the
historical average, seasonal  low groundwater table.  An estimated 3,750 cubic yards of clean soil,
currently located above the areas of soil exceeding Remediation Standards, would be stockpiled during
excavation activities.  Clean soils would be segregated from soils requiring remediation. Following
excavation, the clean, stockpiled soils would be returned to the FPDA in sections as soon as confirmatory
sampling were conducted, thereby minimizing the resulting depression during soil treatment activities.
The clean soils account for approximately 75 percent of the excavated soils.

The volume of soil requiring excavation for treatment is estimated to be approximately 1,300 cubic yards.
Assuming a 10% expansion during removal, approximately 1,430 cubic yards would require treatment.  Soils
to be treated, including contaminated soils and saturated soils, would be placed within a bermed area
that would be underlain by an impermeable liner.  Via a sump, water draining from the soils would be
collected and disposed off site.  A chain link fence with a gate and warning signs would be placed around
the soil pile and treatment area.

SVE is a technology that uses air as the carrier to remove VOCs from soil.  SVE involves inducing airflow
in soil with an applied vacuum, thereby flushing the air in the soil pore spaces,  removing contaminants
entrained in the air stream.   The effluent vapor stream is passed through granular activated carbon (GAG)
where the contaminants are transferred from the vapor stream to the carbon.  The clean air is then
discharged to the atmosphere.

Vacuum extraction would be performed ex-situ in an above-ground soil pile located in a containment area.
The soil would be covered with an impermeable plastic liner to prevent air emissions from the soil and to
enhance the effectiveness of the treatment.  Treatment will be completed when sampling and analysis

-------
indicate that VOC COCs are at or below the cleanup levels.  Treated soil would be returned to the FPDA,
which would then be regraded.

While the RA indicates that there are no unacceptable human health or environmental risks associated with
potential exposure to FPDA soils, excavation and treatment of unsaturated zone soils from the FPDA under
Alternative SC-4a would eliminate the potential for direct contact with unsaturated zone soil.  Under
this alternative VOC COCs would be removed from the FPDA soil, and the migration of VOC COG from the FPDA
unsaturated zone soil to groundwater via rainwater infiltration would be essentially eliminated once the
remediation is complete.  Although the unsaturated zone soils would no longer be a significant source of
VOC COG for groundwater once the SVE soil treatment is complete, groundwater modeling has demonstrated
that the estimated groundwater remediation time frame would not be impacted by implementation of this
alternative and would be the same as that for Alternatives SC-1 and SC-2 (see Appendix B in the
Feasibility Study).

Because contaminated materials would remain on Site (i.e., bis(2-ethyl hexyl)phthalate),  long-term
monitoring and Five-Year Site reviews would be implemented.  Additionally,  a State environmental land use
Restriction would be placed on the FPDA portion of the Site to limit use and disturbance of soils.  Data
obtained in the monitoring program would be evaluated during Five-Year Reviews, and the need for further
remedial actions would be assessed.

ESTIMATED TIME FOR DESIGN AND CONSTRUCTION:                   5 Months
ESTIMATED TIME FOR OPERATION:                                 9 months
ESTIMATED CAPITAL COST:                                       $1,358,000
ESTIMATED 0 & M  (Present Worth):                              $205,000
ESTIMATED TOTAL COST  (Present Worth):                         $1,600,000

5. Alternative SC-5:   Excavation, Off-Site Treatment/Disposal of Soils

Alternative SC-5 involves excavation of Site soils exceeding cleanup levels and transportation off-site
for treatment and/or disposal.  Treatment/disposal methods include low temperature thermal desorption
(LTTD) ,  asphalt batching, or disposal at a licensed waste management facility. The following common
elements would be included under Alternative SC-5:

       •      temporary dewatering and subseguent treatment of extracted groundwater during soils
              excavation in the FPDA;
       •      excavation and stockpiling of clean soils currently above the FPDA soils which exceed
              remediation standards;
       •      excavation of FPDA impacted soil to two  feet below the historical average,  seasonal low
              water  table;
       •      excavation of impacted soil in the FPDA
       •      sampling and analysis of excavated soil  for RCRA characteristics;
       •      sampling and analysis for VOC and bis(2-ethyl hexyl)phthalate of the excavation side walls;
       •      replacement of excavated soils with clean fill materials,  with regrading;
       •      transportation of impacted soils for off-Site treatment via Low Temperature Thermal
              Desorption (SC-5a),  or Asphalt Batching  (SC-5b),  or disposal  at a landfill  (SC-5c),  as
              described below,
       •      Five-Year Site Reviews.

Soils reguiring treatment in the FPDA will be excavated to two feet below the surveyed elevation of the
historical average,  seasonal low water table.  The soil would need to be dewatered prior to excavation,
using a well point system with extracted groundwater treated on-site using GAG. Excavated soils would be
loaded into trucks,  and transported for treatment and/or disposal. Sampling of excavated soils would be
reguired for treatment/disposal facility acceptance and to determine whether they are RCRA characteristic
hazardous wastes.  If soils are designated RCRA characteristic hazardous wastes, facilities which accept
soils for treatment via asphalt batching would not have the appropriate permits to accept this material.
Facilities which accept soils for treatment via LTTD may reguire special conditions for RCRA
characteristic hazardous wastes. Land disposal ban restrictions for hazardous materials would also become
pertinent, and may reguire additional testing or processing prior to disposal.

The volume of soil containing COG above cleanup levels is estimated to be approximately 1,850 cubic
yards.   With an assumed 10% expansion during removal,  the total soil volume reguiring treatment would be
approximately 2,030 cubic yards  (or 3,150 tons).  Clean soils will be segregated from the dirty soils
using field screening methods and confirmatory sampling and  analyses.  Clean soils that would need to be
excavated are estimated at approximately 3,750 cubic yards. Replacement of the 3,750 cubic yards of clean
soil removed from above and between the contaminated soil areas, would be performed utilizing traditional
construction eguipment. Additional Site restoration would be performed as necessary.

-------
Excavation and treatment of soils under Alternative SC-5 would eliminate the potential for direct contact
with unsaturated zone soil. However, according to the Risk Assessment, there are no unacceptable health
or environmental risks associated with potential exposure to soils.

The leaching of COG from the unsaturated zone to groundwater through rainwater infiltration would be
eliminated under this alternative. COG in the saturated zone would continue to impact groundwater;
however, natural attenuation processes would continue to reduce the volume, toxicity, and mobility of the
COG, and therefore groundwater effects, at a significant rate. The three-dimensional groundwater model
has demonstrated that removal of FPDA soils would not impact groundwater remediation time frames. The
need for erosion and sediment controls or other measures to protect wetlands during excavation activities
would be assessed during pre-design studies.

Alternative SC-5a: Off-Site Treatment via Low Temperature Thermal Desorption (LTTD)

Under Alternative SC-5a, following excavation of soil exceeding the cleanup levels, the soil would be
transported off-Site to a licensed facility for treatment using LTTD. LTTD is a process similar to
incineration, except that much lower temperatures are used. Contaminants are stripped or driven off
heated soils. The treatment process begins with material sizing via crushing or screening to produce a
uniform material which can flow through the treatment mechanism. Miscellaneous debris, unsuitable for
treatment via thermal desorption, is separated from the recyclable soil. Temperatures usually range from
2005F to 6005F, which allows contaminants to be volatilized off of the soils without reaching their flash
point. Air is blown through the soil as a carrier for the desorbed organic contaminants, then captured
and treated. Concentrated streams are then further treated in an afterburner. Remediated soils would be
disposed of by the treatment facility. Decontaminated soil retains its physical properties and ability
to support biological activity.

ESTIMATED TIME FOR DESIGN AND CONSTRUCTION: 6 Months
ESTIMATED TIME FOR OPERATION: 3 months
ESTIMATED CAPITAL COST: $2,559,000
ESTIMATED 0 & M (Present Worth): $13,500
ESTIMATED TOTAL COST (Present Worth): $2,572,000

Alternative SC-5b: Off-Site Treatment via Asphalt Batching

Under alternative SC-5b, excavated soil would be transported off Site and treated using Asphalt batching.
The treatment process begins with material sizing via crushing or screening to produce a maximum 3-Inch
size material. Miscellaneous debris, unsuitable for inclusion in the final paving product, is separated
from the recyclable soil. Contaminated soils are then blended with aggregate (if used) and chemically
engineered asphalt emulsion. Fixatives are added via a cement silo for heavy metals stabilization and
structural integrity, as needed. As soil passes through a series of counter rotating blades in a mill,
the emulsion is applied and the asphalt emulsion coated mixture exits the mill and is stockpiled for 72
hours to cure. After curing, the stabilized asphalt material can be used immediately or maintained for
later use. Contaminants are chemically and physically bound in the cured asphalt matrix where they are
rendered environmentally unavailable. The stabilized asphalt is then available for use as a paving base.

ESTIMATED TIME FOR DESIGN AND CONSTRUCTION: 6 Months
ESTIMATED TIME FOR OPERATION: 3 months
ESTIMATED CAPITAL COST: $2,573,000
ESTIMATED 0 & M (Present Worth): $13,500
ESTIMATED TOTAL COST (Present Worth): $2,586,000

SC-5c: Off-Site Disposal

Under alternative SC-5c, excavated soil would be transported off Site and disposed of in a
licensed waste disposal facility. The excavated soils would be handled as appropriate based on
their analysis for RCRA characteristics. If determined to be hazardous, compliance with federal
land disposal restrictions would be reguired, and soils may reguire additional testing or processing
prior to disposal.

ESTIMATED TIME FOR DESIGN AND CONSTRUCTION: 6 Months
ESTIMATED TIME FOR OPERATION: 3 months
ESTIMATED CAPITAL COST: $2,493,000
ESTIMATED 0 & M (Present Worth): $13,500
ESTIMATED TOTAL COST (Present Worth): $2,507,000

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B. Management of Migration (MM) Alternatives Analyzed

Management of Migration (MM) alternatives address contaminants that have migrated from the original
source of contamination. At the Gallup's Site, contaminants have migrated from the former disposal areas
into groundwater primarily northwest toward Mill Brook. According to the risk assessment, groundwater is
the only response media that presents an unacceptable risk to human health. This risk is associated with
one scenario; a potential future on-site worker ingesting one liter of groundwater per day, 250 days per
year, for 25 years. Vinyl chloride is responsible for the majority of the carcinogenic risk. The MM
alternatives evaluated for the Site include the following:

Alternative MM-1: No Action
Alternative MM-2: Natural Attenuation and Institutional Controls
Alternative MM-3: Containment: Groundwater Extraction, Treatment, and Discharge
Alternative MM-4: Remediation: Groundwater Extraction, Treatment, and Discharge

Significant reductions in COG concentrations over time have been observed in the northern portion of the
Site from the late 1970's through the 1996 sampling rounds. Evaluation of reductions in COG
concentrations with time indicate that natural degradation and dilution by rainwater infiltration are
reducing most VOC concentrations (with the exception of vinyl chloride) by about a factor of two every
two years. This rapid rate of reduction is also attributable to the success of the source removal
actions which took place in 1978. As confirmed by the soil concentration data collected during the RI,
only residual VOC soil contamination remains in a relatively thin zone in the FPDA. The levels of VOC
contamination in this zone continue to be reduced at a rapid rate due primarily to rainwater infiltration
(flushing).

In addition to VOCs, which are responsible for most of the potential risk associated with the potential
ingestion of groundwater, bis(2-ethyl hexyl)phthalate and metal COG (lead, chromium and vanadium) have
been detected at concentrations which exceed the Interim Groundwater Cleanup Levels (i.e., cleanup levels
as described in Section X.A of the ROD). These exceedences have been sporadic, and there is no
discernable spatial pattern associated with these four COCs.

1. Alternative MM-1: No Action

This alternative was evaluated in detail in the FS to serve as a baseline for comparison with the other
remedial alternatives under consideration. Under this alternative, no remedial measures would be
conducted to address residual contamination remaining in the Site groundwater. No institutional
controls, beyond the industrial zoning currently in place, would be used to restrict groundwater use and
groundwater quality would not be monitored. However, groundwater within and downgradient of the present
plume boundaries is not currently used as a drinking water supply. Residual contamination would remain
on-Site and no contaminants would be actively removed, treated or destroyed. However, concentrations of
COG in the groundwater would continue to be reduced at a significant rate through natural attenuation
processes. Natural attenuation is the reduction of contamination levels in the groundwater through
dispersion, dilution, transformation (natural chemical breakdown), sorption (bonding of the contaminants
to the particles in the soil) , and biodegradation (the action of naturally occurring microorganisms that
break down the contaminant).

Based on the measured reduction rates in the aguifer since 1980, and three-dimensional groundwater
modeling (see Appendix D of the Feasibility Study), vinyl chloride and DCE, the two COG which would take
the longest time to remediate, would meet cleanup levels in approximately 27 years. As discussed in
Section 5.2.3 of the RI Report, groundwater VOC concentrations immediately downgradient from the former
disposal areas reduced by a factor of two or more every two years during the period from 1980 to present.
Since 1993, these reduction rates have been higher, with the exception of vinyl chloride, which is being
formed by the breakdown of its parent compounds (PCE and TCE). Analyses of these reduction rates
indicate that flushing by rainwater infiltration and other degradation processes listed above are likely
primarily responsible for the declines in groundwater VOC levels. These high natural reduction rates in
VOC concentrations would continue under Alternative MM-1. There would be limited further migration of
the plume, since the plume is naturally contained by Mill Brook, as demonstrated by three-dimensional
groundwater modeling.

ESTIMATED TIME FOR DESIGN AND CONSTRUCTION: NA
ESTIMATED TIME FOR OPERATION: NA
ESTIMATED CAPITAL COST: $0
ESTIMATED 0 & M (Present Worth): $0
ESTIMATED TOTAL COST (Present Worth): $0

-------
    Alternative MM-2:   Management Controls with Natural Attenuation
Alternative MM-2 builds upon Alternative MM-1 by including institutional controls to limit the use of
Site groundwater, long-term monitoring and Five-Year Site Reviews to ascertain the performance of natural
attenuation.  Under Alternative MM-2, the following measures would be implemented:

       •      institutional controls,  including deed restrictions and a State environmental land use
              restriction to prevent future use of impacted groundwater until cleanup levels are met;
       •      long-term monitoring of groundwater and surface water guality to confirm that levels of  COG
              are continuing to decline and ensure the surface water has not been adversely impacted,  and
       •      Five-Year Site Reviews to evaluate the effectiveness and adequacy of remedial measures.

Treatment processes would not be employed under Alternative MM-2 to reduce the toxicity, mobility, and
volume  (TMV) of COG.  However, significant reductions in COG concentrations in groundwater would occur
through natural degradation processes described above under alternative MM-1.  Since source materials
were removed in 1978, considerable reduction in concentrations of VOC COG in groundwater due to flushing
and natural degradation have been observed.  In addition, COG concentrations in soil within the FPDA are
also significantly decreasing, as is their potential to impact groundwater.  There would be limited
further migration of the plume because the plume is naturally contained by Mill Brook.

Three dimensional groundwater fate and transport modeling developed for the Site  (see Appendix B of the
FS) estimate that cleanup levels for VOCs will be attained in approximately 27 years. Concentrations of
Bis(2-ethyl hexyl)phthalate and metal COG would also be reduced through Natural Attenuation processes.
However, it is difficult to estimate reduction rates for these constituents because of their sporadic
occurrence and lack of defined plume.  Concentration reductions of Bis(2 ethyl hexyl)phthalate and metal
COG downgradient of the Site would be tracked as part of a long-term groundwater monitoring program
developed for the Site.

Institutional controls including deed restrictions would be placed on all parcels of land impacted by the
plume to restrict the use of contaminated groundwater.  There are five properties potentially impacted by
the groundwater plume.  One of these is the Gallup's property.  Of the other four, three are independent
land owners and one is the Town of Plainfield.  Deed restrictions would be maintained until all cleanup
levels have been attained for a period of three consecutive years.

A long-term monitoring program would be developed to evaluate the migration of and concentration of the
COG at the Site and to ensure compliance with the cleanup levels identified in Section X of the ROD.  The
long-term monitoring program for this alternative would use the existing monitoring well network and
additional wells to be installed downgradient of the current groundwater plume.  Groundwater would be
sampled from each of the existing and new wells and analyzed for COCs.  Surface water would also be
sampled and analyzed for COCs at locations along Mill Brook and Fry Brook.

EPA would review the Site every five years after initiation of the remedial action to assure that the
remedial action continues to protect human health and the environment.
ESTIMATED TIME FOR DESIGN AND CONSTRUCTION:
ESTIMATED TIME FOR OPERATION:
ESTIMATED CAPITAL COST:
ESTIMATED 0 & M  (Present Worth):
ESTIMATED TOTAL COST  (Present Worth):
3 months
Approximately 27 years
$272,000
$1,751,000
$2,023,000
3.  Alternative MM-3:  Containment via Groundwater Extraction, Treatment and Discharge

Alternative MM-3 builds on Alternatives MM-1 and MM-2 by providing containment of the groundwater VOC
plume by extraction of groundwater, with subsequent treatment and discharge to Mill Brook or the local
sewage treatment facility.  Alternative MM-3 would include the following measures:
              installation of two well clusters,  each cluster consisting of three groundwater extraction
              wells and pumps,  extracting groundwater at approximately 100 gallons per minute (gpm);
              installation of a groundwater treatment system,  consisting of:   air stripping,  liquid phase
              granular activated carbon (GAG)  or UV/oxidation,  or an equivalent treatment process as
              determined during the design phase,  and pretreatment for metals;
              sampling and analysis of groundwater at the treatment system;
              discharge of groundwater treatment effluent to Mill Brook or to a sewage treatment facility;
              off-Site disposal and/or further treatment or destruction of treatment residuals,  if
              required;

-------
• institutional controls, including deed restrictions placed on impacted properties to prevent
use of impacted groundwater until cleanup levels are achieved;
• operation and maintenance of the groundwater treatment system;
• long-term monitoring of groundwater and surface water guality; and
• Five-Year Site Reviews to evaluate the effectiveness and adequacy of remedial measures.

A three-dimensional groundwater model was used to determine the number, location, and pumping rate of
extraction wells necessary to prevent further migration of the groundwater plume. To optimize the
containment of the plume, it was determined that three wells would be required at each of two pumping
locations. To create a sufficient capture zone to intercept upgradient groundwater, the two well
clusters would pump at a combined rate of 100 gallons per minute (gpm). A final pumping rate and capture
zone would be verified during a pumping test that would be completed as part of the remedial design.

Above-ground treatment of extracted groundwater would involve flow equalization, followed by one of three
treatment processes (air stripping, GAG, or UV/oxidation) with discharge to Mill Brook or the local
sewage treatment facility (POTW) located adjacent to Fry Brook. The treatment system would be located
west of the railroad tracks. A road would be constructed to allow vehicles and utilities to access the
facility. Groundwater would be pumped from the wells to the plant for treatment, then discharged from
the plant to Mill Brook.

Groundwater would be conveyed from the wells to a flow equalization tank within the plant. The
equalization tank serves to provide adequate storage and attenuate fluctuations in flow rates.
Groundwater would be pumped from the equalization tanks through two filters which would remove
particulates that may clog downstream processes. After flowing through the bag filters, water would be
treated by one of the following three options:

Air Stripping

While there are different air stripping methods available, including packed tower air strippers and
low-profile tray aerators, a horizontal aerator was evaluated for this Site in the FS. With this system,
groundwater enters the horizontal aerator unit where the groundwater travels through a pipe and is
exposed to turbulent air throughout its length. The treated water falls through the bottom of the pipe
where the air and groundwater make contact, and the VOCs are transferred from the water to an air stream
(or vapor phase). The vapors flow out of the pipe through the top where they are collected for further
treatment (i.e., vapor phase carbon adsorption). A vapor phase carbon treatment system consisting of
three 1,500-pound units would be installed to remove organic vapors.

Granular Activated Carbon

Activated carbon consists of granular carbon that adsorbs organic compounds from the groundwater. The
carbon has a large surface area which provides many sites for the adsorption process. GAG is typically
contained within a plastic or metal vessel. GAG units are usually arranged in series. When the first
unit depletes its adsorptive capacity (i.e., breakthrough occurs), it is removed from service and
regenerated to remove the contaminants for further treatment off Site. The last unit is rearranged to
become the first unit and is used until it has reached its capacity.

For this alternative, with a flow rate of 100 gpm two 24,000-pound GAG units would be needed to reduce
VOC to discharge standards. The actual design may vary based on influent concentrations and pumping rate
as determined during the design phase.

UV/Oxidation

UV/oxidation is a destruction technology that utilizes ultraviolet light and an oxidizer (usually
hydrogen peroxide) to break the chemical bonds of organic compounds. The UV light breaks down the
hydrogen peroxide to form free hydroxyl radicals. These radicals, coupled with the energy from the UV
light, break down organic compounds. The end products from the reaction are CO 2 and water.

A typical UV/oxidation unit consists of a metering pump for the hydrogen peroxide, an in-line mixer, and
a UV reactor. The hydrogen peroxide is mixed with the contaminated water prior to entering the UV
reactor. The UV reactor operates at a high voltage (typically between 1,000 and 3,000 volts) to produce
the energy necessary to break the chemical bonds. Depending on the flow rate and influent
concentrations, multiple units might be needed. The actual design may vary based on influent
concentrations and pumping rate as determined during the design phase.

After treatment by either of the three processes described above, water would now to an effluent holding
tank. The tank would act as a reservoir for clean water that may be needed for maintenance of the
treatment system (e.g., backwashing, cleaning).

-------
From each of the three remedial technologies discussed above treated water would be pumped to Mill Brook
through a discharge pipe. The treated water would meet the substantive reguirements of all state and
federal discharge limits. Initial and long-term sampling of the treatment system would be reguired to
ascertain efficiency of the system and to ensure that discharge reguirements were met.

The majority of the VOC groundwater plume lies on property west of the railroad tracks, which is not
owned by the Gallup's estate. To reduce administrative difficulties with the railroad, the treatment
building and access road would be located west of the tracks. This eliminates crossing the tracks either
for access or utilities. Access agreements with property owners, however, would be reguired. The
treatment building would consist of a concrete slab with a prefabricated shell.

Institutional controls would be used on properties within the plume boundary to limit access to or use of
impacted groundwater. Land use restrictions would be placed on each parcel of land to limit use. There
are five properties impacted by the plume. One of these is the Gallup's property. Of the other four,
three are independent land owners and one is the Town of Plainfield. Several other properties may
reguire institutional controls to prohibit installation of a production well to prevent potential
contamination if operation of a production well were to cause the plume to migrate toward the well.

Monitoring at the treatment plant would include influent and effluent water guality analysis to determine
efficiency of the treatment system and attainment of discharge reguirements as well as compliance with
the state discharge permit. Samples would be analyzed for Site COG. Additionally, groundwater samples
would be collected from the existing monitoring well network that was installed during the RI field
investigation, as well as from new wells that would be installed during the remedial design phase.
Samples would be analyzed for each of the COG. Samples would be collected guarterly for the first two
years, semi-annually for the next three years, and annually thereafter. The freguency of monitoring
would be determined during the remedial design phase.

Five-Year Site Reviews would also be performed to confirm the effectiveness and adeguacy of measures
implemented under Alternative MM-3.

Three dimensional modeling estimates that concentrations of Site COG would meet the cleanup levels in
approximately 22 years. The levels of COG would continue to be reduced at a rapid rate through natural
attenuation processes that would be augmented by extraction of the groundwater. Further migration of the
VOC plume would be prevented under MM-3. As with Alternatives MM-2 and MM-4, potential human health
risks associated with ingestion of impacted groundwater would be addressed through the use of
institutional controls until remediation goals were met. Pre-treatment would reduce metal COG
concentrations in the extracted groundwater.
ESTIMATED TIME FOR DESIGN AND CONSTRUCTION:
ESTIMATED TIME FOR OPERATION:
24 months
Approximately 22 years
Air Stripping

ESTIMATED CAPITAL COST:
ESTIMATED 0 & M (Present Worth):
ESTIMATED TOTAL COST (Present Worth):

Granulated Activated Carbon

ESTIMATED CAPITAL COST:
ESTIMATED 0 & M (Present Worth):
ESTIMATED TOTAL COST (Present Worth):

UV/Oxidation

ESTIMATED CAPITAL COST:
ESTIMATED 0 & M (Present Worth):
ESTIMATED TOTAL COST (Present Worth):
$1,751,000
$7,201,000
$8,952,000
$1,742,000
$19,474,000
$21,216,000
$1,941,000
$8,296,500
$10,238,000
4. Alternative MM-4: Remediation via Groundwater Extraction, Treatment and Discharge

Alternative MM-4 builds on Alternative MM-3 by providing active remediation of the groundwater plume by
extraction of groundwater, with subseguent treatment and discharge to Mill Brook or the POTW.
Alternative MM-4 is the most aggressive MM alternative developed for the FS. The only difference between
this and the previous alternative (MM-3) is the addition of more extraction wells. Other components of
the groundwater treatment system are similar to Alternative MM-3 except that the system would be designed

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to treat a higher groundwater flow rate.  Alternative MM-4 would include the following measures:

       •      installation of three well clusters,  each cluster consisting of three groundwater extraction
              wells and pumps,  extracting groundwater at combined flow rate of approximately 150 gpm;
       •      installation of a groundwater treatment system consisting of air stripping,  liguid phase GAG
              or UV/oxidation,  or an eguivalent treatment process as determined during the design phase,
              and pre-treatment for metals;
       •      sampling and analysis of groundwater at the treatment system,
       •      discharge of groundwater treatment effluent to Mill Brook or the POTW;
       •      off-site disposal and/or further treatment or destruction of treatment residuals;
       •      institutional controls,  including deed restrictions placed on impacted properties to prevent
              use of impacted groundwater until cleanup levels are achieved;
       •      operation and maintenance of the groundwater treatment system;
       •      long-term monitoring of groundwater and surface water guality; and
       •      Five-Year Site Reviews to evaluate the effectiveness and adequacy of remedial measures.

For a detailed description of the components listed above please refer to  the description of MM-3.

Implementation of a groundwater extraction and treatment system under this  alternative would prevent
potential further migration of the Site-related VOC plume and reduce the remediation time frame for
groundwater relative to the other alternatives.  The estimated groundwater  remediation time frame for
Site VOC COG is approximately 17 years, based on three-dimensional groundwater modeling.

Under Alternative MM-4  (and Alternatives MM-2 and MM-3), potential human health risks associated with
ingestion of impacted groundwater would be addressed through the use of institutional controls until
cleanup levels are met.  Pre-treatment would reduce metal COG concentrations in extracted groundwater.

ESTIMATED TIME FOR DESIGN AND CONSTRUCTION:            24 months
ESTIMATED TIME FOR OPERATION:                          Approximately 17 years

Air Stripping

ESTIMATED CAPITAL COST:                                $1,932,000
ESTIMATED 0 & M  (Present Worth):                       $7,772,000
ESTIMATED TOTAL COST  (Present Worth):                  $9,704,000

Granulated Activated Carbon

ESTIMATED CAPITAL COST:                                $1,968,000
ESTIMATED 0 & M  (Present Worth):                       $22,328,000
ESTIMATED TOTAL COST  (Present Worth):                  $24,296,000

UV/Oxidation

ESTIMATED CAPITAL COST:                                $2,147,000
ESTIMATED 0 & M  (Present Worth):                       $8,921,000
ESTIMATED TOTAL COST  (Present Worth):                  $11,068,000

IX.   SUMMARY OF THE COMPARATIVE ANALYSIS OF ALTERNATIVES

Section 121(b)(1) of CERCLA presents several factors that, at a minimum, EPA is required to consider in
its assessment of alternatives.  Building upon these specific statutory mandates, the National
Contingency Plan  (NCP) articulates nine evaluation criteria to be used in  assessing the individual
remedial alternatives.

A detailed analysis was performed on the alternatives using the nine evaluation criteria in order to
select a site remedy.  The following is a summary of the comparison of each alternative's strength and
weakness with respect to the nine evaluation criteria.  These criteria are  summarized as follows:

A.  Evaluation Criteria

Threshold Criteria

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

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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 pathway are eliminated, reduced or
controlled through treatment, engineering controls, or institutional controls.

2. Compliance with applicable or relevant and appropriate requirements (ARARS) addresses whether or not
a remedy will meet all of the ARARs of other Federal and State environmental laws and/or provides
grounds for invoking a waiver.

Primary Balancing Criteria

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

3. Long-term effectiveness and permanence addresses the criteria that are utilized to assess
alternatives for the long-term effectiveness and permanence they afford, along with the degree of
certainty that they will prove successful.

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

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 period, until cleanup goals are achieved.

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

7. Cost includes estimated capital and Operation Maintenance (O&M) costs, as well as present worth
costs.

Modifying Criteria

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

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

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

A detailed assessment of each alternative according to the nine criteria can be found in Chapter 5 of the
Feasibility Study.

Following the detailed analysis of each individual alternative, a comparative analysis, focusing on the
relative performance of each alternative against the nine criteria, was conducted. This comparative
analysis can be found in Chapter 5 and Plate 5-1 of the Feasibility Study.

The section below presents the nine criteria and a brief narrative summary of the alternatives and the
strengths and weaknesses according to the detailed and comparative analysis.

B. Summary of Comparative Analysis

1. Overall Protection of Human Health and the Environment addresses how an alternative as a whole will
protect human health and the environment. This includes an assessment of how public health and
environmental risks are properly eliminated, reduced, or controlled through treatment, engineering
controls, or institutional controls.

All of the alternatives except for the No Action Alternatives provide a similar level of human health
protection. According to the RA, there are no unacceptable risks associated with direct contact with
soils under current conditions. All of the alternatives except for No Action would rely primarily on
institutional controls to prevent ingestion of groundwater until remediation goals are met. Interim
Groundwater Cleanup Levels would be attained in approximately 17 to 27 years, with MM-4 being the most
aggressive alternative evaluated. Soil cleanup levels would be attained in approximately 9 months to 15
years, with Alternative SC-5 being the most aggressive.

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There are currently no unacceptable impacts to wetlands, according to the Risk Assessment. Under
alternatives involving excavation and/or construction (Alternatives SC-3, SC-4a and SC-5), there would be
potential short-term impacts to wetlands that would need to be controlled through the use of drainage and
siltation controls or other wetlands protection procedures. Alternatives including extraction and
treatment of groundwater (MM-3 and MM-4) would involve construction and operation of a treatment plant,
extraction wells, piping and access roads near wetlands areas. This would reguire wetlands protection
procedures and may reguire mitigation of wetlands damage. Short-term risks to workers during
construction activities under SC-3, SC-4a, SC-5, MM-3 and MM-4 would need to be addressed through
appropriate health and safety procedures.

Although some alternatives would involve removal, treatment or isolation of unsaturated zone soils,
impacts to groundwater in the vicinity of the FPDA would be similar for all of the alternatives, since
COG in the saturated zone would continue to impact groundwater. However, the three-dimensional
groundwater model indicates that even removal of all source material would not shorten overall estimated
groundwater cleanup times. Capping may actually result in extending groundwater remediation times.
Alternatives including groundwater extraction and treatment (MM-3 and MM-4) would prevent further
migration of the VOC plume. However, even with no extraction and treatment only limited further
migration beyond the present plume boundaries would occur. The three-dimensional groundwater model
estimates that the plume is naturally contained by Mill Brook and Fry Brook. COG concentrations would
continue to decrease further and groundwater between the present plume boundaries and the furthest
projected extent of the plume is not currently, and is not expected to be, used as a drinking water
supply. Institutional controls would be implemented to prevent exposure to contaminated groundwater.

2. Compliance with Applicable or Relevant and Appropriate Requirements (ARARs) addresses whether or not
a remedy complies with all state and federal environmental and public health laws and reguirements that
apply or are relevant and appropriate to the conditions and cleanup alternatives at a specific Site. If
an Applicable or Relevant and Appropriate Reguirement (ARAR) cannot be met, the analysis of the
alternative must provide the grounds for invoking a statutory waiver (see Table 2-1, 2-2, & 2-3 in the
Feasibility Study).

All alternatives, except for the No Action alternative, that include institutional controls which would
limit Site use to industrial would be protective of human health and the environment.

According to the risk assessment, there are no unacceptable risks associated with direct contact with
soils. Only alternatives including the removal and treatment/disposal of unsaturated zone soils (SC-4a
and SC-5) would include treatment to meet most soil cleanup levels associated with impacts to
groundwater. Alternative SC-4a would have some effect on the removal of bis(2-ethyl hexyl)phthalate, but
the cleanup level for this constituent is unlikely to be achieved through this treatment (it would be
achieved through natural attenuation). Although alternatives including SC-4a and SC-5 would remove VOC
COG from the unsaturated zone, groundwater remediation time frames would not be reduced by taking these
actions. Alternative SC-5 is the only source control alternative that would meet all soil cleanup levels
in the short-term.

Groundwater cleanup levels for VOC COG (as described in Section 10.A of this document) would be met under
all alternatives, including Natural Attenuation, within approximately 27 years. Alternatives involving
extraction and treatment of groundwater (MM-3 and MM-4) would meet VOC COG in a somewhat shorter time
period (22 years and 17 years, respectively) than with alternatives MM-1 and MM-2. The period to reduce
concentrations of metals and bis(2-ethyl hexyl)phthalate under any of the alternatives has not been
calculated due to the difficulties of modeling accurate estimates for these constituents. However, like
VOCs, these constituents are affected by natural attenuation processes and are expected to attain cleanup
levels over time and would be evaluated during the long-term groundwater monitoring program. Under
alternatives MM-3 and MM-4, metals and bis(2-ethyl hexyl)phthalate would be treated in extracted
groundwater with pretreatment. Groundwater at the Site is not currently used, and institutional controls
would effectively prevent development of the aguifer as a drinking water supply.

3. Long-term Effectiveness and Permanence refers to the ability of an alternative to maintain reliable
protection of human health and the environment over time once the remedial action objectives and cleanup
levels have been met.

All of the alternatives considered, except for No Action, would result in a similar level of residual
risk, since there is no unacceptable risk associated with soil contact. Institutional controls,
including deed restrictions to prohibit the use of the contaminated groundwater as a drinking water
supply, would prevent the ingestion of impacted groundwater. Institutional controls should perform
reliably, since they are consistent with current use and zoning of the Site, and a municipal water supply
is available.

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With respect to this criterion, the alternatives vary primarily in the degree of groundwater control
(other than institutional controls) that they provide. The cap under SC-3, excavation/treatment under
SC-4a, and treatment/disposal under SC-5 would prevent rainwater infiltration and leaching of COG from
the unsaturated zone soils in the FPDA to groundwater. However, this would not reduce the groundwater
remediation time frames as evidenced by modeling. Alternative SC-4a would not address bis(2-ethyl
hexyl)phthalate in the Seepage Bed. The cap may in fact extend the time period for groundwater treatment
or containment alternatives by reducing rainwater infiltration and groundwater flushing.

Alternatives MM-3 and MM-4 would prevent the migration of the plume beyond its present boundaries.
However, only limited migration would occur even without this active control, since the plume is
naturally contained by Mill Brook. Groundwater Extraction and Treatment under MM-3 and MM-4 would reduce
the groundwater remediation time frames for VOC COG relative to Natural Attenuation (from 27 years to 22
years and 17 years, respectively), but not significantly. Under Natural Attenuation, three-dimensional
groundwater modeling indicates that VOC COG levels within the plume would continue to decrease, and would
meet cleanup levels in approximately 27 years.

The technologies/measures that would be implemented under any of the alternatives considered have been
implemented effectively at other hazardous waste sites, and would therefore perform reliably, although
the long-term effectiveness of asphalt batching is unproven.

4. Reduction of Toxicitv, Mobility, or Volume (TMV) through Treatment are three principal measures of
the overall performance of an alternative. The 1986 amendments to the Superfund statute emphasize that,
whenever possible, EPA should select a remedy that uses a treatment process to permanently reduce the
level of toxicity of contaminants at the Site, the spread of contaminants away from the source of
contamination, and the volume, or amount, of contamination at the Site.

Alternatives including excavation and treatment via on-site Soil Vapor Extraction (SC-4a) and Off-Site
treatment of the FPDA soil (SC-5), and/or extraction and treatment of groundwater (MM-3 and MM-4) would
reduce TMV through treatment. However, with certain groundwater treatment technologies (air stripping
and activated carbon), the toxicity would be transferred to spent carbon treatment residuals which would
then reguire appropriate treatment/disposal. The treatment technologies primarily target removal of VOCs
and would be less effective for treating bis(2-ethyl hexyl)phthalate.

If asphalt batching is employed for FPDA soils, the mobility of COG would be reduced through treatment.
However, the toxicity would not be reduced, and the volume of soil would be increased by the asphalt
additive. The mobility of COG in the unsaturated zone would be reduced through capping under SC-3.

The low temperature thermal desorption process, under SC-5c, would remove approximately 200 pounds of COG
from Site soils. Groundwater treatment, under MM-3 (Containment) would remove approximately 303 Ibs/year
total VOC and generate approximately 37,000 Ibs/yr spent carbon with air stripping and 864,000 Ibs/yr
spent carbon with granular activated carbon (GAG). Under MM-4, groundwater treatment would remove
approximately 304 Ibs/year total VOC and generate approximately 73,000 Ibs/yr spent carbon with air
stripping and 1,450,000 Ibs/yr spent carbon with GAG. These treatment processes would be irreversible.
The large volume of GAG treatment residuals would reguire special handling procedures and would likely
cause significant implementability concerns related to the logistics associated with handling such large
guantities of carbon.

5. Short-term Effectiveness refers to the likelihood of adverse impacts on human health or the
environment that may be posed during the construction and implementation of an alternative until remedial
action objectives and cleanup levels are achieved.

Alternatives SC-1, SC-2, MM-1 and MM-2 would pose the lowest short-term risk to community and workers
during implementation, since they would involve minimal activities. Short-term risks to workers during
implementation of excavation or construction activities (under SC-3, SC-4a and SC-5) would be minimized
by ensuring that workers employ appropriate safety precautions. Short-term risks to the community would
be controlled through special precautions, such as dust control measures.

A stormwater/erosion control management study would need to be performed to ensure that impacts to Mill
Brook or associated wetlands are avoided or minimized during excavation/construction activities and/or
construction of the groundwater treatment facility, extraction wells, piping, and access roads under MM-3
and MM-4.

None of the alternatives would meet remedial response objectives in the short-term, since groundwater
cleanup levels would not be met under the most aggressive remediation (MM-4) until approximately 17
years.

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6. Implementabilitv refers to the technical and administrative feasibility of an alternative, including
the availability of materials and services needed to implement the alternative. Other than No Action,
Natural Attenuation with Institutional Controls (SC-2 and MM-2) would be the easiest alternative to
implement, since it would only involve institutional controls, monitoring, and Five-Year Site Reviews.
Monitoring of the soils, groundwater and surface water could be easily implemented, since a long-term
monitoring plan is already in place and can be easily adapted. Institutional controls could be
implemented, and would be readily enforceable, since they would be consistent with current use of the
Site.

The remaining alternatives, in addition to the above measures, would also include engineering measures to
address soils and/or groundwater. For the most part, they employ standard, proven technologies, although
the long-term effectiveness of asphalt batching (SC-5b) is unproven.

Alternatives SC-4a, SC-5a and SC-5b would require sampling and laboratory testing of soils to determine
the effectiveness of the soil vapor extraction (SVE), low temperature thermal desorption (LTTD) or
asphalt batch mix process and to develop design and operational parameters. If analytical results show
the soils are a RCRA characteristic hazardous waste, the number of LTTD facilities which are permitted to
accept hazardous waste are limited. Asphalt batching would also be precluded, since asphalt batching
facilities are not permitted to accept RCRA hazardous waste. Likewise, many asphalt batching facilities
are limited in the concentration of halogenated VOCs and semi-VOCs which they are able to accept, or will
not accept soils with any halogenated VOCs that originated at a Superfund site, even if they are
nonhazardous.

7. Cost includes the capital (up-front) cost of implementing an alternative as well as the cost of
operating and maintaining the alternative over the long term, and net present worth of both capital and
operation and maintenance costs.

Other than No Action (which would have no cost) , Natural Attenuation with Institutional controls for both
soil (SC-2) and groundwater (MM-2) would be the least expensive to implement. The present worth cost
estimates for SC-2 and MM-2 combined would cost $2,152,000. Costs would be primarily associated with the
implementation of institutional controls and long-term monitoring programs, and could vary according to
the number of wells sampled, parameters analyzed for, and reporting requirements.

The addition of active source control measures for soils (SC-3, SC-4a or SC-5) to Natural Attenuation
with Institutional Controls for groundwater (MM-2) would increase the costs, with cost estimates ranging
from approximately $2.9 million to $4.6 million, depending on the type of source control measure
included, and the extent to which sampling and analysis is performed under SC-5. Of the source control
alternatives evaluated, capping would be the least costly, and excavation and off-site treatment via
asphalt batching or low temperature thermal desorption would be the most costly to implement, depending
on waste characterization.

The addition of active groundwater extraction and treatment measures (MM-3 or MM-4) to Natural
Attenuation with Institutional Controls (SC-2) would increase the present worth cost estimates to a range
of approximately $10.4 million to $24.4 million, depending on the number of wells and flow rate, and the
method of groundwater treatment employed. The present worth cost of groundwater containment (MM-3),
combined with SC-2, is estimated to cost approximately $10.4 million. The present worth cost of
groundwater remediation (MM-4) combined with SC-2 is expected to range from $9.8 million to $24.4
million. The median estimate presented in the FS for MM-4 is less than the MM-3 median estimate because
groundwater remediation would be completed in less time than groundwater containment.

The most costly alternative to implement at the Site would be Excavation and Off-Site Treatment/Disposal
of soils (SC-5) combined with groundwater remediation: Groundwater Extraction, Treatment, and Discharge
(MM-4). The median present worth cost associated with this alternative is estimated to range from $12.2
million to $26.9 million.

8. State Acceptance addresses whether, based on its review of the RI/FS and Proposed Plan, the State
concurs with, opposes, or has no comment on the alternative EPA has selected as the remedy for the Site.

The Connecticut Department of Environmental Protection (DEP) has been involved in all Site activities to
date. The Commissioner of the DEP has provided EPA with a letter of concurrence with the selected
remedy. This letter is attached as Appendix C.

9. Community Acceptance addresses whether the public concurs with EPA's Preferred Alternative.
Community acceptance of this cleanup proposal will be evaluated based on comments received at the
upcoming public meetings and during the public comment period.

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As presented in the Responsiveness Summary, attached as Appendix D, the public did not strongly oppose
the selected remedy.  Three members of the public opposed the selected remedy and were in favor of
selecting the most aggressive alternatives considered  (i.e., SC-5 and MW-4) as they both had shorter
remediation time frames.

EPA considered all of the public comments received and a response to all comments received is presented
in the Responsiveness Summary.

X.  THE SEIiECTED REMEDY

The remedy selected to address contamination at the Gallup's Quarry Site is Alternative's SC-2 and MM-2.
The selected remedy combines natural attenuation processes to reduce contaminant concentrations at the
Site to protective levels with institutional controls to prevent exposure to Site contaminants for both
source control and management of migration.  This combination of source control and management of
migration actions will result in the restoration of the groundwater to drinking water standards within
approximately 27 years.

A.  Interim Groundwater Cleanup Level

Interim cleanup levels have been established in groundwater for Contaminants of Concern  (COG) identified
in the RA found to pose an unacceptable risk to either human health or the environment. Interim
Groundwater Cleanup Levels have been set based on the ARARs (e,g., as shown on Table 5, Maximum
Contaminant Levels  (MCLs), and Connecticut Groundwater Protection  Criteria).   Because the aquifer
beneath the Site is classified by the State of Connecticut as a class GA aguifer, which is considered
suitable for drinking or other domestic uses without treatment, State Groundwater Remediation Standards
(22a-133k-3)  are ARARs.  The standards include four types of remediation levels.  They comprise of
surface water protection criteria; volatilization  criteria; groundwater protection criteria (GWPC),  and
background concentrations  (see Section 2 of the FS for more detail.  Additionally, federal MCLs and
non-zero MCLGs established under the Safe Drinking Water Act are ARARs based on the State of
Connecticut's determination that the Site groundwater is of "medium" Use and Value 2 (see DEP's August
1997 Groundwater Use and Value Determination).

While these interim cleanup levels are consistent with ARARs or suitable TBC criteria for groundwater, a
cumulative risk that could be posed by these compounds may exceed EPA's goals for remedial action due to
the risk posed by vinyl chloride at the MCL and Connecticut Groundwater Protection Criteria of 2 parts
per billion (see Table 5).  Consequently, these levels are considered interim cleanup levels and periodic
assessments of the protection afforded by remedial actions will be made as the remedy is being
implemented and at the completion of the remedial action.  At the time that Interim Groundwater Cleanup
Levels identified in the ROD, and newly promulgated ARARs and modified ARARs which call into question the
protectiveness of the remedy, have been achieved and have not been exceeded for a period of three
consecutive years, a risk assessment shall be performed on the residual groundwater contamination to
determine whether the remedial action is protective.  This risk assessment of the residual groundwater
contamination shall follow EPA procedures and will assess the cumulative carcinogenic and
non-carcinogenic risks posed by an individual ingesting groundwater.

The residual risk assessment will include sampling of a sufficient number of Site monitoring wells for
VOCs, Semi-VOCs, PCBs/pesticides and metals to determine if constituents not previously identified as
cleanup levels represent an unacceptable carcinogenic or non-carcinogenic risk, or exceed federal or
state drinking water standards.  If, after review of the risk assessment, the remedial action is not
determined to be protective by EPA, the remedial action shall continue until either protective levels are
achieved, and are not exceeded for a period of three consecutive years, or until the remedy is otherwise
deemed protective.  These protective residual levels shall constitute the final cleanup levels for this
Record of Decision and shall be considered performance standards for this remedial action.

All Interim Groundwater Cleanup Levels identified in the ROD,  and newly promulgated ARARs and modified
ARARs which call into question the protectiveness of the remedy, and the protective levels determined as
a consequence of the risk assessment of residual contamination, must be met at the completion of the
remedial action at every point in the Site groundwater.  EPA has estimated that these levels will be
obtained within approximately 27 years.
2 Pursuant to EPA Region I's 1995 Beneficial Reuse Superfund Initiative and the Groundwater Use and Value
  Determination Guidance (4/96) ,  the responsibility for determining the use and value of groundwater at
  Region I Superfund Sites is delegated to the State.  Their determination, upon agreement by EPA,
  establishes the Remedial Action Objectives (RAO).  Where either a "medium" or "high" determination is
  made for a site, the groundwater RAO's will include the restoration of contaminated groundwater to
  drinking water standards and trigger ARARs.

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B. Unsaturated Soil Cleanup Level

Based on the RA, no unacceptable human health risk is present from Site soils. The only ARARs for
remediation of soils are the newly enacted Connecticut Remediation Standard Regulations
(22a-133k-2)(RSRs). For contaminants in soil, the CT RSR has Direct Exposure Criteria (DEC) and
Pollutant Mobility Criteria (PMC). DEC were established to be protective of individuals who may be
directly exposed to contaminants in site soils via ingestion or dermal contact. PMC are standards
established by the State to prevent the leaching of contaminants in the soil to groundwater at levels in
excess of groundwater protection criteria. The PMC vary depending on the groundwater classification for
the area where the soils reside. Groundwater beneath the Site has been designated as Class GA and,
therefore, GA PMC apply to this Site. Based on the anticipated future use of the Site, the FS has
presumed that industrial DEC are applicable. None of the contaminants detected at the Site exceed the
industrial DEC. Using the standards and formulas provided in the State's regulations, and the data
collected during the RI field investigation it was determined that 6 contaminants at the Site exceed the
State PMC. The volume of soil containing VOC COG in excess of the PMC is approximately 770 cubic yards.
In addition to the 770 cubic yards containing VOC COG above the PMC, approximately 425 cubic yards of
soil may contain bis(2-ethyl hexyl)phthalate in excess of the PMC; approximately 355 cubic yards in the
FPDA and 70 cubic yards in the Seepage Bed. In summary, approximately 1,200 cubic yards of soil are
estimated to contain COCs in excess of the Soil Cleanup Levels (see Section 2 and Appendix E of the FS).

The Soil Cleanup Levels listed below must be attained at every point throughout the contaminated
unsaturated zone in the FPDA and the Seepage Bed. Periodic sampling and analysis for the COG must be
performed during the remedial action to determine compliance with the Soil Cleanup Levels. It is
estimated that average concentrations of Soil Cleanup Levels will be attained in approximately 15 years.

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                TABIiE 5:  INTERIM GROUNDWATER CIiEANUP IiEVELS
Carcinogenic
Contaminants
of Concern

benzene

1,2-dichloroethane

1,1-dichloroethene

methylene chloride

tetrachloroethene  (PCE)

trichloroethene

vinyl chloride

bis (2-ethyl hexyl)

phthalate

lead


Non-Carcinogenic
Contaminants
of Concern

1,1,1-trichloroethane

xylene  (total)

1, 2-dichloroethene

chromium

vanadium
Cleanup
Level (Ig/1)

        1

        1

        6

        5

        5

        5

        2
        2

       15
   Basis

CT GWPC

CT GWPC

CT Vol. Criteria

CT GWPC & EPA MCL

CT GWPC & EPA MCL

CT GWPC & EPA MCL

CT GWPC & EPA MCL




CT GWPC

CT GWPC/EPA ACTION LEVEL
      Cleanup
      Level(Ig/1)
      200

      530

       70

       50

       50
        Basis

CT GWPC & EPA MCL

CT GWPC

CT GWPC

CT GWPC

CT GWPC
   Level of Risk

        4E-07

        8E-07

        4E-05

        9E-07

        5E-06

        2E-06

        2E-03



        2E-06

        NA 1
    Sum 2E-03



Level of Risk

      NA 2

      3E-03

      8E-01 3

      NA 2

      NA 2
1 - While lead is a potential carcinogen, an individual cancer risk was not calculated because  an  oral
slope factor is not available.  However, concentrations detected in Site groundwater exceed both State
and Federal ARARs

2 - These contaminants were not determined to be a contaminants of concern pursuant to EPA Region  I  risk
assessment policy, therefore no individual non-carcinogenic risks were calculated.  However,
concentrations detected in Site groundwater exceed both State and Federal ARARs.

3 - The individual risk level provided is for the total of cis-l,2-DCE and trans-1,2-DCE.  However,  the
specific cleanup levels listed above are 70 ppb for cis-1,2-DCE and 100 ppb for trans-1,2-DCE.

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TABIiE 6:  UNSATURATED SOIL CLEANUP LEVELS
Contaminants
of Concern

ethyl benzene

tetrachloroethane  (PCE)

trichloroethene

chloromethane

bis (2-ethyl hexyl)
phthalate

total xylenes
Cleanup Level (Ig/kg)

         10.1

          0.1

          0.1

          0.01
         10
         1
         19.5
Basis

CT PMC

CT PMC

CT PMC

CT PMC
CT PMC (FPDA)
CT PMC (SEEPAGE BED)  1
CT PMC
1 - Pursuant to the CT RS for PMC's, a non-VOC contaminant in a soil located in a GA area may be
remediated to the PMC multiplied by 10 provided that it meets certain conditions.  One of the conditions
is that the water table is at least 15 feet above the surface of bedrock.  The water table at the Seepage
bed is less than 15 feet from the surface of bedrock and therefore the PMC for bis(2-ethyl
hexyl)phthalate at this location cannot be multiplied by 10.
C.  Description of Remedial Components

i.  Source Control

The selected remedy, SC-2, consists of natural attenuation of contaminants in the FPDA and the Seepage
Bed to Soil Cleanup Levels, periodic sampling and analysis of soil, and institutional controls to
restrict Site use.  The selected source control alternative includes the following major components:

       •      Institutional controls including a State environmental land use restriction to limit the use
              and disturbance of the affected portions of the Site (i.e.,  the FPDA and Former Seepage
              Bed) ;
       •      posting of warning signs;
       •      periodic maintenance of warning signs and entry gate;
       •      periodic sampling and analysis of the FPDA unsaturated soils for COCs (VOCs,  and bis(2-ethyl
              hexyl)phthalate)  and the Former Seepage Bed unsaturated soils for bis(2-ethyl
              hexyl)phthalate;  and
       •      Five-Year Site Reviews to evaluate the effectiveness and adequacy of remedial measures.

Under the selected SC alternative, COG in the unsaturated soils would migrate to groundwater via
rainwater infiltration, and concentrations of COG exceeding the Connecticut soil remediation standards
would remain in the soil.  While no remedial measures would be taken beyond the removal action performed
by the State in 1978, natural attenuation processes will continue to reduce the volume and toxicity  of
the COG, and groundwater effects, at a significant rate.  VOC COG levels in soil are expected to be
reduced to Soil Cleanup Levels in less than 11 years, and average concentrations of bis(2-ethyl
hexyl)phthalate is anticipated to be reduced to Soil Cleanup Levels in approximately 15 years  (see
Appendix D of the FS).  The presence of COCs in soil does not impact groundwater remediation time frames,
as estimated by the three-dimensional groundwater model  (see Appendix B of the FS).

During each Five-Year Site Review, soil at the FPDA and Seepage Bed would be sampled and analyzed to
evaluate reductions in contaminant concentrations and compliance with Soil Cleanup Levels.  Samples  of
FPDA unsaturated soils would be analyzed for COCs  (VOCs and bis(2-ethyl hexyl)phthalate)  and the Seepage
Bed unsaturated soils would be analyzed for bis(2-ethyl hexyl)phthalate until all Soil Cleanup Levels are
attained.  A more comprehensive sampling event and statistical analyses will be performed once the
limited sampling program indicates that the cleanup levels have been met to ensure adequate compliance
with ARARS (see Table 7).

While residual concentrations of COG will remain on Site, the RA shows that there are no unacceptable
heath or environmental risks associated with potential exposure to soils by current/future trespassers
and future employees/excavation workers.  The Site is currently zoned for industrial/commercial use  and
is unlikely to be developed for residential use due to the shallow groundwater table, active railway and

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presence of wetlands. Institutional controls, including a deed restriction and State environmental land
use restriction, will be implemented to limit the use of the affected portions of the Site (i.e., former
disposal areas) to commercial/industrial purposes and to prevent disturbance of the soil.

Additional warning signs will be installed at the Site to alert the public of the existence of residual
contamination, and periodic maintenance will be performed to ensure the integrity of the signs and of the
entrance gate.

Because residual levels of contaminated material will remain on Site, Five year Site Reviews will be
conducted to evaluate the effectiveness and adeguacy of remedial measures and to ensure the continued
protection of human health and the environment. The 1986 CERCLA amendments reguire that Site conditions
be reviewed every five years at NPL sites where wastes remain on site. All data collected during the
long-term soil monitoring program will be evaluated in the Five-Year reviews. These reviews will
consider all relevant data and determine if additional remedial measures are necessary.

ii. Management of Migration

The selected MM remedy, MM-2, consists of natural attenuation of contaminants in Site groundwater to
Interim Groundwater Cleanup Levels, long-term groundwater and surface water monitoring, and institutional
controls to prevent the ingestion of contaminated groundwater. The selected MM alternative includes the
following major components:

• institutional controls, including deed restrictions and a State environmental land use
restriction to prevent future use of impacted groundwater until Interim Groundwater Cleanup
Levels are met;
• long-term monitoring of groundwater and surface water guality to confirm that levels of COG
are continuing to decline and to ensure the surface water has not been adversely impacted;
and
• Five-Year Site Reviews to evaluate the effectiveness and adeguacy of remedial measures.

Under this alternative, the levels of COG in groundwater would reduce through natural attenuation
processes. Natural attenuation is the reduction of contamination levels in the groundwater through
dispersion, dilution, transformation (natural chemical breakdown), sorption (bonding of the contaminants
to the particles in the soil) , and biodegradation (the action of naturally occurring microorganisms that
break down the contaminant). There would be limited further movement of the plume since the plume is
naturally contained by Mill Brook. Natural attenuation has been occurring at the Site, and is
demonstrated by the significant reductions in groundwater VOC concentration over time that have been
observed at the Site from the late 1970's through the recent 1996 sampling rounds. Most VOCs (with the
exception of vinyl chloride) concentrations are reducing by approximately a factor of two every two
years. Vinyl chloride is expected to take the longest to reach the cleanup levels in the aguifer under
natural attenuation because it is the final breakdown product of other chlorinated COG within the plume,
and because its biodegradation rate is much slower than that of parent VOCs.

A three dimensional groundwater fate and transport mode has estimated that Interim Groundwater Cleanup
Levels for VOCs will be attained in approximately 27 years (see Appendix B of the FS). The remedial
times calculated in this model conservatively assumes that there will be no biodegradation of vinyl
chloride (concentration reductions would be due to groundwater flushing only). Initial concentrations of
vinyl chloride in the plume were developed based on the existing concentration of vinyl chloride plus the
additional vinyl chloride which could be formed based on degradation of the DCE present. Graphical
simulations of the groundwater VOC plume under natural attenuation showing the extent of the plume for
various times from present until the cleanup levels would be achieved are presented in Figures 4-2
through 4-4 of the Feasibility Study.

Concentrations of bis(2-ethyl hexyl)phthalate and metal COG would also be reduced through natural
attenuation processes. However, it is difficult to estimate reduction rates for these constituents
because of their sporadic occurrence and lack of defined plume. Concentration reductions of Bis(2-ethyl
hexyl)phthalate and metal COG downgradient of the Site will be tracked as part of a long-term groundwater
monitoring program developed for the Site.

Institutional controls including deed restrictions and a State environmental land use restriction will be
placed on all parcels of land impacted by the plume (currently and in the future) to restrict the use of
contaminated groundwater. There are five properties potentially impacted by the groundwater plume (see
Figure 4-1 in the FS). One of these is the Gallup's property. Of the other four, three are independent
land owners and one is the Town of Plainfield. All deed restrictions will be implemented and maintained
until the groundwater cleanup levels are met and the remedy is deemed protective of human health and the
environment.

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A long-term monitoring program will be instituted to evaluate the migration of and concentrations of
VOCs, Semi-VOCs, and metals, to ensure compliance with the Interim Groundwater Cleanup Levels and to
ensure the remedy remains protective of human health and the environment. During the RI/FS, groundwater
was sampled quarterly and surface water was sampled semi-annually. The long-term monitoring program for
this alternative will use the existing monitoring well network, with the addition of new monitoring wells
located downgradient of the current groundwater plume in areas where the plume is expected to migrate.
Groundwater will be sampled from each of the existing and new wells and analyzed for VOCs, Semi-VOCs, and
metals. Surface water will also be sampled and analyzed for COCs at locations along Mill Brook and Fry
Brook. This sampling program will be implemented until all Interim Cleanup Levels are attained for a
period of three consecutive years to ensure compliance with cleanup levels.

Again, to the extent required by law, EPA will review the Site at least once every five years after
initiation of the remedial action to assure that the remedial action continues to protect human health
and the environment.

The time required to implement MM-2 is estimated to be six months. This is attributed to development of
a long-term groundwater monitoring program and negotiating deed restrictions with five property owners.

XI. STATUTORY DETERMINATIONS

The remedial action selected for implementation at the Gallup's Quarry Site is consistent with CERCLA and
the NCP. The selected remedy is protective of human health and the environment, will attain ARARs and is
cost effective. The selected remedy will return contaminated groundwater to beneficial uses within a
time frame that is considered reasonable compared to the other alternatives. The selected remedy does
not satisfy the statutory preference for treatment which permanently and significantly reduces the
mobility, toxicity or volume of hazardous substances as a principal element. Treatment alternatives for
the groundwater were not considered cost effective given the similar extended time periods for attaining
cleanup levels for both natural attenuation and the most aggressive groundwater extraction and treatment
alternative (i.e., 27 years vs. 17 years for MM-4). Additionally, treatment alternatives for soil were
not considered cost effective in the absence of an unacceptable human health and environmental risk from
the residual levels of contaminants and because removal of the source would not increase the cleanup
times for groundwater under any of the MM alternatives. Both the selected alternatives and those
involving treatment would require institutional controls which would equally ensure the necessary
protection of human health and the environment until cleanup levels are attained.

A. The Selected Remedy is Protective of Human Health and the Environment

The remedy at the Gallup's Quarry Site will permanently reduce the risks posed to human health and the
environment by eliminating, reducing or controlling exposures to human and environmental receptors
through natural attenuation and institutional controls; more specifically the selected remedy will
provide for the restoration of groundwater in approximately 27 years and of soil in approximately 15
years and prevent unacceptable exposures to human health and the environment through the implementation
of institutional controls.

Moreover, the selected remedy will achieve potential human health risk levels that attain the 10 -4 to
10 -6 incremental cancer risk range and a level protective of noncarcinogenic endpoints, and will comply
with ARARs and to-be-considered criteria. At the time that Interim Ground Water Cleanup Levels
identified in the Record of Decision, and newly promulgated ARARs and modified ARARs which call into
question the protectiveness of the remedy, have been achieved and have not been exceeded for a period of
three consecutive years, a risk assessment shall be performed on the residual groundwater contamination
to determine whether the remedial action is protective. This risk assessment of the residual groundwater
contamination shall follow EPA procedures and will assess the cumulative carcinogenic and
non-carcinogenic risks posed by occupational ingestion of groundwater. If, after review of the risk
assessment, the remedial action is not determined to be protective by EPA, the remedial action shall
continue until protective levels are achieved and have not been exceeded for a period of three
consecutive years, or until the remedy is otherwise deemed protective. These protective residual levels
shall constitute the final cleanup levels for this Record of Decision and shall be considered performance
standards for any remedial action.

B. The Selected Remedy Attains ARARs

This remedy will attain all applicable or relevant and appropriate federal and state requirements that
apply to the Site. Substantive portions of environmental laws identified as ARARs and those
to-be-considered for the selected remedial action include:

-------
              Clean Water Act (CWA)
              Safe Drinking Water Act (MCLs/non-zero MCLGs)
              Federal Executive Order 11990 (Protection of Wetlands)
       •      Connecticut Groundwater Quality Standards
       •      Connecticut Standards  for Public Drinking Water Quality
       •      Connecticut Remediation Standard Regulations
       •      Connecticut Surface Water and Wetlands Regulations
       •      Resource Conservation  and Recovery Act (RCRA)
       •      Closure/Post Closure Reguirements for Hazardous Waste Facilities
       •      Connecticut Hazardous  Waste Management reguirements
       •      Connecticut Control of Noise Regulations
       •      Connecticut Regulations for the Well Drilling Industry
       •      Federal Clean Water Regulations governing activities in Wetlands

A more detailed discussion of why these reguirements are applicable or relevant and appropriate may be
found in Section 4 of the FS Report.  The RCRA Land Ban reguirements do not apply to the selected remedy
as no excavation, placement, or disposal of Land Ban waste will occur as a result of the remedial action.

The following policies, criteria, and guidances will also be considered (TBCs) during the implementation
of the remedial action:

       •      Federal Drinking Water Health Advisories
       •      Federal Groundwater Protection Strategy
       •      Federal Groundwater Use and Value Determination

Below is a brief narrative summary of the ARARs and TBCs for the selected remedial action.

CHEMICAL-SPECIFIC ARARS

Chemical-specific ARARs identified for Alternative MM-2 include federal and state Drinking Water
Standards, Connecticut Groundwater Quality Standards, Connecticut Groundwater Criteria, and Connecticut
Groundwater Remediation Standard Regulations, all of which prescribe numerical standards for the COG.  In
most cases, the most stringent of these are the Connecticut Groundwater Criteria and site-specific
background concentrations for class  GA groundwater. Because no remedial action would be employed under
this alternative, COG concentrations would exceed State Standards.  However, concentrations would
continue to decline under natural conditions.  Three-dimensional groundwater modeling estimates that
groundwater guality standards for vinyl chloride  (the VOC COG reguiring the longest remediation time
frame) would be met in approximately 27 years under this alternative.  Institutional controls would
effectively prevent development of the aguifer as a drinking water supply.  Bis(2-ethyl hexyl)phthalate
and metal COG reduction rates are difficult to estimate, but are also expected to naturally attenuate to
cleanup levels and will be tracked through long-term monitoring.  Connecticut groundwater remediation
regulations (RCSA Section 22a-133k-3(d))  provide that groundwater in a GA area may be remediated to
chemical specific Groundwater Protection Criteria provided certain conditions exist.  EPA and the
Connecticut Department of Environmental Protection concur that one of these provisions was not identified
by the state in a timely manner and therefore RCSA Section 22a-133k-3(d)(1) is not applicable to this
Site and will not be reguired.

While Maximum Contaminant Levels  (MCLs) and Maximum Contaminant Level Goals (MCLGs) promulgated under the
federal Safe Drinking Water Act are  not applicable to groundwater, they are relevant and appropriate to
groundwater cleanup whenever groundwater may be used as a drinking water source.   In addition,  the NCP
reguires that usable groundwater be  restored to its beneficial uses whenever practicable.  See 40 CFR
300.430(a) (iii) (F) .

Chemical specific ARARs for SC-2 include Connecticut Soil Remediation Standards.   These standards are
based on the risk from direct contact and pollutant mobility, and depend on land use or groundwater
classification.  Alternative SC-2 would not promote immediate compliance with chemical specific ARARs,
but would depend on natural attenuation to achieve concentration reductions necessary to meet the
Connecticut Remediation Standards over time.  Natural attenuation has been demonstrated to effect a
significant reduction in contaminant concentrations. It is estimated that VOC COCs will be reduced to
below Soil Cleanup Standards in 11 years and that average concentrations of bis(2-ethyl hexyl)phthalate
will be met in approximately 15 years.

ACTION SPECIFIC ARARS

Action-specific ARARs identified for Alternative MM-2 include federal and state reguirements for
groundwater monitoring associated with disposal facilities.  These reguirements are relevant and
appropriate and would be considered in the development of a long-term groundwater monitoring program,

-------
which would address the number of wells, their location and depth, as well as the analytical parameters
to be analyzed and frequency of monitoring.  These include federal RCRA closure/post-closure requirements
at hazardous waste facilities, Connecticut Hazardous Waste Management regulations, Connecticut Surface
Water Protection Criteria, and Connecticut Regulations for the Well Drilling Industry.  Connecticut's
Control of Noise Regulation is applicable with respect to installation of additional groundwater
monitoring wells at the Site. These regulations establish allowable noise levels.  Additionally, while
federal Water Quality Criteria establishes specific pollutant concentrations which are considered to be
adequate to protect surface water quality, they have been identified as a relevant and appropriate action
specific ARAR because exceedences of these criteria may cause an additional action to be taken at the
Site.

Because the selected source control action does not include active treatment involving extraction and
treatment of soils, there are no action specific ARARs for source control.

LOCATION SPECIFIC ARARS

The only federal location specific ARARs identified for MM-2 are the Federal Clean Water Regulations,
Federal Executive Order 11990 and Federal Executive Order 11988 which govern activities in wetlands and
floodplains.  These regulations are applicable at the Site because additional groundwater monitoring
wells will be installed in wetlands and potential adverse impacts from this activity must be mitigated by
utilizing the appropriate procedures.  The Federal Groundwater Protection Strategy was identified as a
to-be-considered requirement, which identifies groundwater as ecologically vital if the aquifer supports
a particularly sensitive ecosystem which, if polluted, would destroy a unique habitat.  Another
to-be-considered guidance identified for MM-2 is the Federal Groundwater Use and Value Determination.
This regional guidance was utilized to evaluate the reasonable use of groundwater at the Site and to
identify state and federal Safe Drinking Water standards.  Applicable State requirements identified for
MM-2 include the Connecticut Aquifer Protection Areas standard, the Connecticut Public Health Code, and
the Connecticut Surface Water and Wetlands-Inland Wetlands and Watercourses Regulations.  The first two
listed above were identified to regulate activities that might occur within a protected aquifer,
including restrictions on the installation of water supply wells.  The third regulation listed above
regulates any operation within a wetland, including the installation of monitoring wells which is a
component of the selected remedial action.

Because the selected source control action does not include active treatment involving extraction and
treatment of soils, there are no location specific ARARs.

C.  The Selected Remedial Action is Cost-Effective

In the Agency's judgment, the selected remedy is cost effective, in that it affords overall effectiveness
proportional to its costs.  In selecting this remedy, once EPA identified alternatives that are
protective of human health and the environment and that attain ARARs, it evaluated the overall
effectiveness of each alternative by assessing the next three balancing criteria:  long term
effectiveness and permanence, reduction in toxicity, mobility, and volume through treatment, and: short
term effectiveness.  The relationship of the overall effectiveness of this remedial alternative was
determined to be proportional to its costs.

The costs of this remedial alternative are:
ESTIMATED TIME FOR OPERATION:
ESTIMATED CAPITAL COST:
ESTIMATED 0 & M  (Present Worth):
ESTIMATED TOTAL COST  (Present Worth)
Approximately 27 years
$325,500
$1,826,999
$2,152,000
The selected alternative provides the same level of protection and achieves groundwater restoration in a
comparable time frame to SC-3, SC-4, SC-5, MM-3 and MM-4, which costs would range from an estimated
$8,952,000 (SC-3 and MM-3)  to $26,882,000  ((SC-5b and MM-4).  While the selected source control
remediation will take significantly more time to meet the Soil Cleanup Levels  (e.g., 15 years) than
excavation and off-site treatment or disposal (e.g., 9 months), there is no unacceptable direct contact
risk from the residual levels and calculations indicate that residual contamination will not impact the
groundwater cleanup time frames.  The Soil Cleanup Levels identified for this Site are Connecticut
Pollutant Mobility Criteria, which are requirements developed to protect the groundwater from further
degradation.

-------
D. The Selected Remedy Utilizes Permanent Solutions and Alternative Treatment or Resource Recovery
Technologies to the Maximum Extent Practicable

Once the Agency identified those alternatives that attain or, as appropriate, waive ARARs and that are
protective of human health and the environment, EPA identified which alternative utilizes permanent
solutions and alternative treatment technologies or resource recovery technologies to the maximum extent
practicable. This determination was made by deciding which one of the identified alternatives provides
the best balance of trade-offs among alternatives in terms of: 1) long-term effectiveness and
permanence; 2) reduction of toxicity, mobility or volume through treatment; 3) short-term effectiveness;
4) implementability; and 5) cost. The balancing test emphasized long-term effectiveness and permanence
and the reduction of toxicity, mobility and volume through treatment; and considered the preference for
treatment as a principal element, the bias against off-site land disposal of untreated waste, and
community and state acceptance.

The selected remedy provides the best balance of trade-offs among the alternatives. The selected remedy
provides long-term effectiveness and permanence by implementing institutional controls to prevent future
exposures to contaminated media. Through natural attenuation of Site contaminants of concern, there will
be a permanent reduction in the toxicity and volume of hazardous constituents. While there will be some
additional mobility of COG at the Site until Cleanup Levels are attained, calculations indicate that
there will be only limited further movement of the Site plume as it is naturally contained by Mill Brook.
Additionally, calculations show that further leaching of Site COG from the former disposal areas will not
impact groundwater cleanup times. The selected remedy will achieve the restoration of groundwater in
approximately 27 years and will achieve the restoration of soil in approximately 15 years. The selected
remedy complies with all identified ARARs.

As described above, the selected remedy achieves long-term effectiveness through natural attenuation
processes known to be occurring at the Site and with the implementation of institutional controls to
prevent unacceptable exposures to human health and the environment. The selected remedy does not include
treatment of the groundwater or soil. However, the selected remedy for groundwater will achieve the
restoration of the groundwater in a time period comparable with the alternative that included treatment
(27 years vs. 17 years for MM-4). While the selected remedy for soil will take a significantly longer
time period to attain the cleanup levels, as stated above, there is no unacceptable human exposure to the
residual contamination and calculations show that removal of the source area will not impact cleanup time
frames for groundwater. The selected remedy provides protection until the remedial response objectives
are achieved through natural attenuation and implementation of institutional controls to prevent
groundwater use, and long-term monitoring to detect any changes in groundwater flow paths or contaminant
distribution. The selected remedy is readily implementable and was the most cost effective of the
alternatives evaluated.

The State of Connecticut supports the selected remedy. Public comments were carefully considered in
developing the selected remedy and EPA's response is provided in the Responsiveness Summary (Appendix D) .

E. The Selected Remedy does not Satisfy the Preference for Treatment Which Permanently and Significantly
reduces the Toxicity, Mobility, or Volume of the Hazardous Substances as a Principal Element

The selected remedy does not include treatment which Permanently and significantly reduces the toxicity,
mobility or volume of the hazardous substances as a principal element. However, permanent and
significant reductions in toxicity and volume will be achieved through natural attenuation processes and
contaminated groundwater will be returned to its beneficial uses. While further migration of
contaminants are anticipated, data and calculations show that the plume is being naturally contained by
Mill Brook and natural attenuation.

XII. DOCUMENTATION OF SIGNIFICANT CHANGES

EPA presented a Proposed Plan (preferred alternative) for remediation of the Site on June 25, 1997. The
preferred alternative includes natural attenuation of contaminants of concern in soil and groundwater,
implementation of Institutional controls and long-term monitoring of groundwater and soil.

No significant changes from the Proposed Plan have been made to the selected remedy as detailed in this
Record of Decision.

-------
XIII.  STATE ROIiE

The Connecticut Department of Environmental Protection has reviewed the various alternatives and has
indicated its support for the selected remedy.  The State has also reviewed the Remedial investigation,
Human Health and Ecological Risk Assessment, and Feasibility Study to determine if the selected remedy is
in compliance with applicable or relevant and appropriate State Environmental laws and regulations.  The
State of Connecticut concurs with the selected remedy for the Gallup's Quarry Site.  A copy of the
declaration of concurrence is attached as Appendix C.

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                                APPENDIX A

                                  TABIiES

   TABIiE 1 CONTAMINANTS OF CONCERN - HUMAN HEALTH EVALUATION

     VOCs                       Ground       Surface             Surface/           Site-Related
                                 Water        Soils         Subsurface  Soils         Sediments

1,2-Dichloroethane                 X
1,1-Dichloroethene                 X
1,2-Dichloroethene  (total)         X
1,2-Dichloropropane                X
Benzene                            X
Carbon tetrachloride               X
Chloroform                         X
Methylene chloride                 X
Tetrachloroethene                  X
Trichloroethene                    X
Vinyl Chloride                     X
Xylenes  (total)                    X
BNAs
Acenaphthene                                                                            X
Acenaphthylene                                                                          X
Benzo(a)anthracene                                                                      X
Benzo(a)pyrene                                                                          X
Benzo(b)fluoranthene                                                                    X
Benzo(g,h,i)perylene                            XX                     X
Chrysene                                                                                X
Benzo(k)fluoranthene                                                                    X
Bis (2-ethylhexyl)phthalate         X                              X
Fluoranthene                                                                            X
Fluorene                                                                                X
Di-n-butylphthalate                X                              X
Di-n-octylphthalate                X
1,4-Dichlorobenzene                X
Indeno(1,2,3cd)-pyrene                                                                  X

Methylnaphthalene,2-                                              X                     X

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   TABLE 1 CONTAMINANTS OF CONCERN - HUMAN HEALTH EVALUATION
     VOCs                       Ground       Surface            Surface/          Site-Related
                                 Water        Soils         Subsurface Soils        Sediments

Naphthalene                                                                            X
Phenanthrene                       XX                 X                    X
PCBs/PEST
Aroclor 1242                       X                              X
Aroclor 1248                                                      X
Aroclor 1254                                    XX                    X
Aroclor 1260                                    XX                    X
alpha-Chlordane                                                                        X
Dieldrin                                        X                 X
4,4'-DDD                                                                               X
4,4' -DDE                                                                               X
4,4' -DDT                                                                               X
Endosulfan sulfate                                                                     X
Endrin ketone                                                                          X
Inorganics
Aluminum                                                                               X
Antimony                                                                               X
Arsenic                            XX                 X                    X
Beryllium                          XX                 X                    X
Cyanide                                         X                 X
Iron                               XX                 X                    X
Lead                               XX                 X                    X
Manganese                          X                                                   X
Silver                             X
Thallium                                                          X
Zinc                               X

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                                                                                  TABLE 3
                                                          PRELIMINARY  SCREENING OF REMEDIAL ALTERNATIVES
                                                                  Gallup1s  Quarry Superfund Project
                                                                         Plainfield,  Connecticut
                                                                                                Implementability
                                                There would be no reduction  in
                                                COCs through treatment,  although
                                                COCs would continue to  decrease via
                                                soil flushing.
                                           Readily implemented; no permits
                                           would be required.
                                                                Retained:
                                                                Required by NCP;  COCs
                                                                would  decrease  under
                                                                natural attenuation.
               Management  Controls with
               Natural Attenuation
Same as SCI, with institutional
controls to restrict current  and
future site use and periodic  soil
sampling and analysis.
                                                                Retained:
                                                                Readily implemented and
                                                                effectively limits  potential
                                                                exposure  to COCs.
   SC3
               On
                                                Same as SC2, installation  of a cap
                                                would reduce rainwater  infiltration
                                                through residual COCs in FPDA
                                                only.
                                                VOCs would be reduced  but
                                                treatment residuals would  require
                                                disposal.  Would be less effectiv
                                                treating DEHP.
                                           Large volume of clean fill  and
                                           regrading of FPDA would be
                                           required prior to installation  of  cap;
                                           construction permits for  fence  and
                                           capping would be required;  periodic
                                           maintenance and 5-year site reviews
                                           would be conducted.
                                           Shallow water table would nee
                                           excavation of soil
                            •cessitate
c^^cj v C^U-LWII W.L ^>J_L_LO prior  to  on-site
treatment.  Permitting would  be
required for construction  activities,
air emissions and wastewater
                                                                Retained:
                                                                Effective  in  minimizing
                                                                impact of  COC in  the
                                                                FPDA unsaturated  soils
                                                                on groundwater.
Retained:
Effective in remediating
VOC COC in unsaturated
soils.
Note:   Alternatives retained  for detailed analysis are highlighted in  bold.

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                                                                                               TABLE 3
                                                                   PRELIMINARY  SCREENING  OF REMEDIAL ALTERNATIVES
                                                                              Gallup1s  Quarry Superfund Project
                                                                                     Plainfield,  Connecticut
Alternative
                                                                                              Implementability
                                               VOC COCs would be destroyed by
                                               LTTD.   Volume requiring treatment is
                                               normally the volume required for pilot
                                               testinq.
Permitting would be required for
construction activities, air emission;
and wastewater discharqes;  periodic
maintenance and 5-year site reviews
would be conducted.
Not Retained:
Small volume of soils
requiring treatment would
make equipment
mobilization and associated
permitting costs
prohibitive.
                                               reduced in volume.
                                                                                         and wastewater discharges;  stabilized
                                                                                         material would remain on-site as road
                                                                                         base, significantly restricting future site
                                                                                         use; periodic maintenance and 5-year
                                                                                         site reviews would be conducted.
                                                                       toxicity or volume of
                                                                       COCs on-site.   Small
                                                                       volume of soils requiring
                                                                       treatment would make
                                                                       equipment mobilization and
                                                                       associated permitting costs
                                                                       prohibitive.
                                               COCs would be removed and
                                               ultimately destroyed by LTTD.
                                               Dewatering activities would require
                                               treatment of wastewater.
Sampling and laboratory testing
would be required to determine the
effectiveness of LTTD.  Excavation,
materials handling, and dewatering
activities could be readily
implemented; 5-year site reviews
would be conducted.
                                               COCs would be removed from Site,
                                               but would not be rendered less toxic
                                               or reduced in volume; long-term
                                               effectiveness of asphalt batching is
                                               unproven.  Dewatering activities
                                               would require treatment of
                                               wastewater.
Samplinq and laboratory testing
would be required to determine the
effectiveness of asphalt-batching.
Excavation, materials handling, and
dewatering activities could be readily
implemented; 5-year site reviews
would be conducted.
conducted.

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                                                             TABLE 3
                                         PRELIMINARY SCREENING OF REMEDIAL ALTERNATIVES
                                                Gallup1s Quarry Superfund Project
                                                     Plainfield, Connecticut
                            Description
                                                                                                 Implementability
                                               COCs would be removed from the
                                               Site,  but would not be would not  be
                                               rendered less toxic or reduced  in
                                               volume.   Dewatering activities  would
                                               require treatment of wastewater.
Sampling and laboratory  testing
would be required to  determine  if it
is a hazardous wage prior  to
disposal.  Excavation, materials
handling, and dewatering activities
could be readily Implemented;  5-year
site reviews would be  conducted.
                                               There would be no reduction  in
                                               COCs through treatment, although
                                               COCs would continue to decrease via
                                               natural degradation processes and
                                               dilution.
                                                                                                                                    $0
                                                                    Retained:
                                                                    Required by NCP;  COCs
                                                                    would  decrease  under
                                                                    natural attenuation.
                  Management  Controls with
                  Natural Attenuation
                                               Same as MM1.
Readily implemented;  institutional
controls would prevent  use  of
impacted groundwater, long-term
monitoring would confirm that  levels
of COCs are continuing  to decline,
and 5-year site reviews would  be
conducted.
Retained:
COCs would continue to
decrease under natural
attenuation.
                  Containment:   Groundwater   COCs would continue to decrease  via
                                                                                         Moderately difficult to Implement;
                                                                                         permitting and exemption from
                                                                                         wetland regulations would be
                                                                                         required;  access roads and treatment
                                                                                         building would need to be
                                                                                         constructed; discharge permits would
                                                                                         be required; institutional controls,
                                                                                         long-term monitoring and 5-year site
                                                                                         reviews would be conducted.
                                                                   Retained:
                                                                   Effective  in  removing
                                                                   Vocs.
Note:   Alternatives retained  for  detailed analysis are highlighted in bold.

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                                                           TABLE 3
                                         PRELIMINARY SCREENING OF REMEDIAL ALTERNATIVES
                                                Gallup1s Quarry Superfund Project
                                                     Plainfield, Connecticut
                                                                                                 Implementability
                                               COCs would be extracted  from
                                               groundwater and potential  further
                                               migration of COCs would  be
                                               prevented; COCs would only be
                                               destroyed i f UV-oxdation were  used,
                                               air stripping and activated carbon
                                               would transfer COCs to treatment
                                               residual requiring disposal.
                                               Pretreatment would reduce metals in
                                               extracted groundwater.
                                          Moderately difficult to implement;
                                          permitting and exemption from
                                          wetland regulations would be
                                          required; access roads and treatment
                                          building would need to be
                                          constructed; discharge permits would
                                          be required; institutional controls,
                                          long-term monitoring and 5-year  site
                                          reviews would be conducted.
                                               COCs would continue to decrease  via       Difficult to implement; deeper walls
                                               natural degradation processes;            are more expensive to excavate and  fill
                                               containment would prevent potential       with reactive material; potentially
                                               further migration of Site-related COCs.   signi fleant impacts to wetlands during
                                                                                         construction; permitting and exemption
                                                                                         from wetland regulations would be
                                                                                         required; access roads would need to
                                                                                         be constructed; institutional controls,
                                                                                         long-term monitoring and 5-year site
                                                                                         reviews would be conducted.
                                                                                                       Not Retained:
                                                                                                       Difficult to implement  in
                                                                                                       wetland area; potential
                                                                                                       construction problems with
                                                                                                       installing walls deeper  than
                                                                                                       30-40 feet below the
                                                                                                       surface; would not
                                                                                                       signi fleantly reduce
                                                                                                       groundwater remediation
                                                                                                       time frames.
               Enhanced  In-Situ
               Biodegradation
Organic COCs would be effectively
tested, although it would be  difficult
to ensure that an adequate  supply of
nutrients would reach microorganisms
because of preferential  flow  paths in
heterogeneous aqui fers.
Moderately difficult  to  implement;
permitting and exemption from wetland
regulations would be  required;  access
roads and treatment unit would need to
be constructed; institutional controls,
long-term monitoring  and 5-year site
reviews would be conducted.
Not Retained:
Technology is still being
developed; difficult to
regulate in a heterogeneous
aqui fer.
Note:   Alternatives retained  for  detailed analysis are highlighted in bold.

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                                                                                                           TABLE  4
                                                                  SUMMARY OF DETAILED  ANALYSIS  -  SOURCE CONTROL (SC)  REMEDIAL  ALTERNATIVES
                                                                                            Gallup's  Quarry Superfund Project
                                                                                                Plainfield,  Connecticut
State environmental land use
restriction would be placed on
affected portion of the property
to limit use and disturbance of
soils.
State environmental land use
restriction would be placed on
affected portion of the property
to limit use and disturbance of
soils.
                                                                                                                                 SC5:  Excavation, Offsite Treatment/Disposal
State environmental land use
restriction would be placed on
affected portion of the property
to limit use and disturbance of
soils.
   SC5a:   Low-Temperature
   Thermal Desorption

Temporary dewatering and
subsequent treatment of
extracted groundwater during
soils excavation.
Temporary dewatering and
subsequent treatment of
extracted groundwater
during soils excavation.
Temporary dewatering and
and subsequent treatment
of extracted groundwater
during soils excavation.
Periodic sampling and analysis
of unsaturated soils in FPDA
for VOC and DEHP, and in
Former Seepage Bed for DEHP,
                                     Filling of FPDA depression
                                     with clean fill.
                                     Construction of a fence and
                                     posting of warning signs around
                                     FPDA.
                                    Installation of security fence and
                                    warning signs around FPDA.
                                                                         Collection and
                                                                         treatment/disposal of
                                                                         groundwater drainage from soil
                                                                         pile.
                                                                         Excavation and stockpiling of
                                                                         clean soils currently above the
                                                                         FPDA soils which exceed
                                                                         remediation standards.
                                                                         Replacement of excavated soils
                                                                         with clean fill materials, with
                                                                         regarding.

                                                                         Transportation of FPDA soils
                                                                         for off-site treatment via low
                                                                         temperature thermal desorption.
                                                                        Excavation and stockpiling of
                                                                        of clean soils currently
                                                                        above the FPDA soils
                                                                        which exceed remediation
                                                                        standards.
                                                                        Replacement of excavated
                                                                        soils with clean fill
                                                                        materials,  with regarding.

                                                                        Transportation of FPDA soils
                                                                        soils for off-site treatment
                                                                        via asphalt batching.

                                                                        Sidewall sampling to
                                                                        confirm COC Extent.
                                                                    Excavation and
                                                                    stockpiling of clean soils
                                                                    currently above the
                                                                    FPDA soils which exceed
                                                                    remediation standards.
                                                                    Replacement of excavated
                                                                    soils with clean fill
                                                                    materials,  with regarding.
                                                                                                                                                                                   Sidewall  sampling  to
                                                                                                                                                                                   confirm COC  Extent.
                                                                          Site restoration and regrading.

                                                                          Five year site reviews.

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                                                                                                                                                        TABLE 4
                                                                                                              SUMMARY  OF DETAILED ANALYSIS - SOURCE  CONTROL  (SC) REMEDIAL ALTERNATIVES
                                                                                                                                         Gallup's Quarry  Superfund Project
                                                                                                                                            Plainfield, Connecticut
                                                                                                                                                                                                            SC5b:   Asphalt  Batching
Overall
Protection of
Human Health
and the
Environment
                    COCs in unsaturated zone
                    would migrate to
                    groundwater;  but natural
                    attenuation process would
                    continue to reduce the
                    volume, toxicity and
                    mobility of COC.

                    Presence of COCs in soil
                    has no impact on
                    groundwater remediation
                    time frames.
Same as SCI,  except that
institutional controls would
effectively prevent contact with
FPDA soil until remediation
goals are met.   Soil guality
would be monitored.
Potential for direct contact with
soil would be restricted but
there are no unacceptable risks
associated with exposure to
soils.

Stormwater/erosion control
study would help minimize
impacts to Mill Brook and
wetlands during and after cap
construction.

Leaching of COC to
groundwater would be reduced
by cap but COC in saturated
zone would continue to impact
groundwater.
Potential direct contact with
soil would be eliminated, for
VOCs,  but there are no
unacceptable risks associated
with exposure to soils.

Migration of COC in
unsaturated soils to groundwater
would be eliminated but residual
contamination in saturated soils
would continue to impact
groundwater.

Implementation of remedy
would have little overall
groundwater remediation time
frame.
                                                                                                                                                                     Same  as  SC4 a.
                    There would be no
                    impacts on wetlands.

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                                                                                                                                     TABLE  4
                                                                                           SUMMARY OF  DETAILED ANALYSIS -  SOURCE CONTROL (SC)  REMEDIAL  ALTERNATIVES
                                                                                                                     Gallup's  Quarry Superfund Project
                                                                                                                         Plainfield,  Connecticut
                                                                                                                                                                                        SC5b:  Asphalt Batching
Would not achieve
immediate compliance
with chemical-specific
ARARs,  but would
depend on natural
attenuation to achieve
COC reductions to meet
CT Remediation
Standards.

Would meet most soil
ARARs in approximately
11 years.  DEHP would
be expected to require
longer time to meet
ARARs (2-20 years on
average).
Would not meet chemical
specific ARARs because COCs
above CT standards would
remain in soils.

Would increase time required to
achieve ARARs by reducing
infiltration and resultant
flushing.

Federal RCRA and State Solid
Waste requirements would
apply, as would Control of
Noise Regulations.

No applicable location-specific
ARARs unless impacted area is
located within 100 feet of
wetlands.
Action-spec!fie ARARs include
RCRA land ban restrictions,
State Control of Noise
Regulations, Air Pollution
Regulations and Gudelines for
Soil Erosion and Sediment
Control.
Federal and State Hazardous
Waste Regulations would apply
if soils are determined to be
RCRA characteristic.
Would meet all chemical-
specific soil ARARs in short
term.

Action-specific ARARs include
Federal NPDES Regs., Federal
RCRA standards, State Control
of Noise Regs., Air Pollution
Regs.,  Water Pollution Control
Regs.,  Well Drilling and Well
Permitting Regs.,  Water
Diversion Policy and Guidelines
for Soil Erosion and Sediment
Control, Federal and State
transportation reqs.
                                                                                                                                                 Federal and State Hazardous
                                                                                                                                                 Waste Regulations and
                                                                                                                                                 transportation would apply if
                                                                                                                                                 soils are determined to be
                                                                                                                                                 RCRA characteristic.

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                                                                                                                                                         TABLE 4
                                                                                                               SUMMARY  OF DETAILED ANALYSIS  - SOURCE  CONTROL  (SC) REMEDIAL ALTERNATIVES
                                                                                                                                         Gallup's Quarry  Superfund Project
                                                                                                                                             Plainfield, Connecticut
Reduction of
Toxicity,
Mobility, or
Volume
No reduction in TMV
through treatment,  since
no treatment would be
employed.
TMV of VOCs in excavated
soils would be reduced;
however toxicity may be
transferred to treatment
residuals,  which would require
disposal.
                                                                                                                           Reduction  in  concentrations  of
                                                                                                                           COC  in  unexcavated  soil  would
                                                                                                                           occur through infiltration,
                                                                                                                           bioactivity,  and  groundwater
                                                                                                                           flushing.
Would be reduction in TMV
through excavation and soil
treatment,  total mass of COCs
destroyed would be
approximately 50 Ibs .
                                                                                                                                              COC  in  unexcavated soils  would
                                                                                                                                              reduce  through  infiltration,
                                                                                                                                              bioactivity  and groundwater
                                                                                                                                              flushing.
                                                                              Treatment should be
                                                                              permanent, but long-term
                                                                              effectiveness data are not
                                                                              yet  available.
  No reduction in TMV
  through treatment,
  toxicity in soil
  transported off-site to
  secure facility.

  COC in excavated soils
  would reduce through
infiltration, bioactivity
  and groundwater
  flushing.
                                                                                                                                                                                                         COC in unexcavated soils
                                                                                                                                                                                                         would reduce through
                                                                                                                                                                                                         infiltration, bioactivity and
                                                                                                                                                                                                         groundwater flushing.
                     No short term risk to
                     community and workers
                     or environmental impacts
                     during remedial actions
                     associated with
                     implementation.

                     Would not achieve
                     remedial response
                     obj ectives in the short-
                     term, since CT
                     Remediation Standards
                     would not be met.
                                                                Potential short-term risks during
                                                                construction minimized through
                                                                adherence to health and safety
                                                                plan and sedimentation and
                                                                erosion controls.

                                                                Infiltration of precipitation into
                                                                soil would be eliminated
                                                                immediately upon construction
                                                                of cap, but this alternative
                                                                would not achieve remedial
                                                                response objectives in short-
                                                                term, since CT Remediation
                                                                Standards would not be met.
Potential short-term risks during
installation and operation would
be minimized through adherence
to health and safety plan,
monitoring, use of dust control
procedures, and erosion control
procedures.

Soil remedial response
obj ectives for VOCs would be
achieved upon completion of
remedy.   DEHP would continue
to decline via natural
attenuation.

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                                                                                                                                   TABLE  4
                                                                                             SUMMARY OF DETAILED ANALYSIS -  SOURCE CONTROL  (SC) REMEDIAL ALTERNATIVES
                                                                                                                     Gallup's Quarry Superfund  Project
                                                                                                                          Plainfield, Connecticut
   Assessment
     Factor
                          SCI:  No Action
                                SC2:   Management Controls
                                 with Natural Attenuation
                                                                                                     Capping
                                                                                                                                                                   SC5a:   Low-Temperature
                                                                                                                                                                     Thermal  Desorption
Long-Term
Effectiveness and
permanence
No direct engineering or
institutional controls
would be implemented,
but there are no
unacceptable health or
environmental risks.
                     Groundwater plume would
                     Continue to migrate,
                     regardless of the presence
                     of COC in soils.
Same as SCI,  except that
institutional controls would be
effective in the long-term in
preventing contact with FPDA
soil.
COC would remain in FPDA
soils for longer period than
with other alternatives

Reduction in flushing may
lengthen groundwater
remediation time frame.
TMV of VOCs in soils would
be reduced; however toxicity
may be trans ferred to treatment
residuals,  which would require
disposal.

Long-term effectiveness in
treating VOC with SVE is
proven; SVE is EPA's
presumptive remedy for VOC-
contaminated soils; would be
considerably less effective for
DEHP.

VOC migration from
unsaturated soils
eliminated.  DEHP would
continue to decline via natural
altenuation.
                                                                                                                                                                                                                                    Landfill disposal will
                                                                                                                                                                                                                                    permanently remove
                                                                                                                                                                                                                                    COCs  from Site but will
                                                                                                                                                                                                                                    not destroy them; COC
                                                                                                                                                                                                                                    transported to another
                                                                                                                                                                                                                                    location.

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                                                                                                            TABLE  4
                                                                                             SUMMARY  OF DETAILED ANALYSIS  - SOURCE CONTROL (SC)  REMEDIAL  ALTERNATIVES
                                                                                                                     Gallup's  Quarry Superfund Project
                                                                                                                          Plainfield,  Connecticut
   Assessment
     Factor
Implementability
                          SCI:  No Action
                     Easily implemented.
                     Would not  obstruct
                     additional remedial
                     actions,  if necessary,
                     although  unrestricted
                     future development  could
                     make some  remedial
                     measures  more  difficult  to
                     implement.
  SC2:   Management Controls
   with Natural Attenuation
                                                   Readily  implemented.
Effectiveness and adequacy of
measures would be assessed
during periodic monitoring and
five-year site reviews.
                                                                                       Periodic inspections and
                                                                                       maintenance would be necessary
                                                                                       to ensure integrity of cap.
                                                                                                                         Effectiveness of system would
                                                                                       Effectiveness would be assessed   be assessed through sampling
                                                                                       during periodic monitoring and    and analysis.
                                                                                       five-year site reviews.
                                                                                                                                                                  SC5a:  Low-Temperature
                                                                                                                                                                    Thermal Desorption
Physical hazard risks for
on-site workers would be
minimized by employing
appropriate safety
precautions.
Physical hazard risks for
on-site workers would be
minimized by employing
appropriate safety
precautions.

Increase in truck traffic
and associated noise
during excavation and
removal.

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                                                        TABLE  4
                     SUMMARY OF  DETAILED ANALYSIS - SOURCE  CONTROL  (SC)  REMEDIAL ALTERNATIVES
                                            Gallup's Quarry  Superfund Project
                                                 Plainfield,  Connecticut
MM2:   Management Controls with Natural
      Attenuation

Institutional controls,  including a State
environmental land use restriction to prevent  use
of impacted groundwater  during future
development until remediation goals are  met.
Same as MM2,  with:
Long term monitoring of groundwater and surface
water guality.
gpm.

Installation of groundwater treatment  system,
consisting of air stripping,  liguid phase  granular
activated carbon (GAG)  or UV/oxidation,  and
pretreatment for metals.

Sampling and analysis  of  treatment  effluent.

Discharge of treatment effluent  to  Mill  Brook  or
the POTW.
                                                                                                                               Installation of groundwater treatment system,
                                                                                                                               consisting of air stripping,  liquid phase granular
                                                                                                                               activated carbon (GAG)  or UV/oxidation,  and
                                                                                                                               pretreatment for metals.

-------
COC in groundwater would continue  to
reduce at a significant  rate  (metal COC
and DEHP may be slower)  through  natural
attenuation,  but would  remain  in
groundwater for approximately  27 years.
                                                                                      TABLE 4
                                                SUMMARY  OF DETAILED  ANALYSIS -  SOURCE CONTROL  (SC)  REMEDIAL ALTERNATIVES
                                                                        Gallup's Quarry  Superfund  Project
                                                                             Plainfield,  Connecticut

                                                   MM2:  Management Controls with Natural

                                                              Attenuation
COC in groundwater would continue  to  reduce  at
a significant rate (metal COC and  DEHP  may be
slower)  through natural attenuation,  but would
remain in groundwater would be approximately 27
years.
                                                 Source Control measures,  if implemented,  would
                                                 not impact groundwater remediation time frame.
VOC COC would meet ARARs  in approximately
22 years,  metal COC and DEHP may take  longer
but are difficult to predict;  further  migration  of
the plume  would be prevented.
                                                                                                                                      MM4:   Remediation,

                                                                                                                                                Treatment,

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                                                                                                                                                            TABLE  4
                                                                                              SUMMARY OF DETAILED  ANALYSIS  -  SOURCE CONTROL (SC)  REMEDIAL  ALTERNATIVES
                                                                                                                      Gallup's  Quarry Superfund Project
                                                                                                                           Plainfield,  Connecticut
                                    MMl:   No Action
                                                                                  MM2:   Management Controls with Natural
                                                                                        Attenuation
Compliance with ARARs
Would not achieve immediate compliance
with chemical-specific ARARs,  but would
depend on natural attenuation to achieve
COC reductions to meet Remediation
Standards.
                                                                                  Would not  achieve immediate compliance with
                                                                                  chemical-sped fie ARARs,  but would depend on
                                                                                  natural attenuation to achieve COC reductions to
                                                                                  meet Remediation Standards.
                                                                                  Federal and State requirements for groundwater
                                                                                  monitoring associated with disposal facilities
                                                                                  would apply, as would State requirements for
                                                                                  well installation.
Would not achieve immediate compliance with
chemical-sped fie ARARs ,  but chemical-sped fie
ARARs would be achieved in approximately 22
years (metal COC and DEHP times are difficult
to predict)
Same as MM3,  except that it would meet
groundwater ARARs in approximately 17 years
(metal COC and DEHP times are difficult to
predict).
            Action-specific ARARs include Federal and State
            requirements for discharge of treated groundwater
            to surface water or POTWs, groundwater
                        diversion, groundwater monitoring associated
            with disposal facilities, well installations,  impacts
                        to wetlands,  noise and air pollution permitting
                        and/or controls,  and Federal, State and local
                        standards for construction of treatment facilities.
                                                                                                                                                                     Location-sped fie ARARs identified include
                                                                                                                                                                     Federal and State wetlands protection regulations,
                                                                                                                                                                     Federal floodplain regulations and State surface
                                                                                                                                                                     water/stream encroachment regulations.
                                                                                                                                                                     Federal and State hazardous waste regulations,
                                                                                                                                                                     and transportation requirements would apply if
                                                                                                                                                                     treatment residuals are determined to be RCRA
                                                                                                                                                                     characteristic.

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                                                                                    TABLE  4
                                                SUMMARY  OF DETAILED  ANALYSIS -  MANAGEMENT  OF MIGRATION  (MM)  REMEDIAL  ALTERNATIVES
                                                                        Gallup's Quarry  Superfund  Project
                                                                             Plainfield,  Connecticut
No short term risk to community  and
workers or environmental impacts,  since
no remedial measures  would be
performed.
                                                   MM2:  Management Controls with Natural
                                                              Attenuation
MM3:   Containment,  Groundwater  Extraction,
          Treatment,  and Discharge
                                                                                                                     Remedial response obj ectives would not be
                                                                                                                     achieved in the short-term, but institutional
                                                                                                                     controls would effectively prevent groundwater
                                                                                                                     use .
Would not obstruct additional  remedial
actions,  if necessary.
                                                                                                                     Same as MM2, except that groundwater treatment
                                                                                                                     would be conducted in accordance with applicable
                                                                                                                     permit reguirements and periodic repair of pumps
                                                                                                                     and treatment eguipment would be reguired.

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                                                                                    TABLE  4
                                                SUMMARY OF DETAILED ANALYSIS - MANAGEMENT  OF MIGRATION  (MM)  REMEDIAL  ALTERNATIVES
                                                                        Gallup's Quarry  Superfund Project
                                                                             Plainfield,  Connecticut

                                                    MM2:   Management  Controls  with Natural                           MM3:   Containment, Groundwater Extraction,
                                                               Attenuation                                                     Treatment, and Discharge
COC in groundwater would not be                  COC in groundwater  would not  be  addressed
addressed through active remedial                through active remedial  measures,  but  would
measures,  but would continue to reduce           continue to reduce  due to natural  attenuation
due to natural attenuation processes.             processes.
Groundwater use within the plume would
not be controlled,  and groundwater and
surface water guality would not be
monitored.

TMV would not be reduced through                 Same as MM2                                                 TMV  of  COC  in groundwater would be reduced;
treatment,  since no treatment would be                                                                      however, air stripping and GAC treatment would
employed; however,  significant reductions                                                                   trans fer toxicity and volume be treatment residual,
in COC (VOC may reduce greater than                                                                         which would reguire disposal.  Would be reduction
metal COC and DEHP)  would occur                                                                             in TMV  through groundwater treatment
through natural degradation processes.

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                                                                                                                      TABLE  4
                                                                                               CHEMICAL-SPECIFIC ARARs:  CRITERIA,  ADVISORIES AND  GUIDANCE
                                                                                                            FOR  THE  SELECTED ALTERNATIVE
Authority
                                                                                                         Gallup's Quarry  Superfund Project

                                                                                                               Plainfield,  Connecticut

                                                                                                        Requirement Synopsis
                                    Federal Safe Drinking Water
                                    Maximum Contaminants
                                    Levels  (MCLs)  for organic
                                    and inorganic chemicals  (4 0
                                    CFR 141 Subparts B,G, and
                                    1) -
                                    Federal Safe Drinking Water
                                    Maximum Contaminant Level
                                    Goals  (MCLGs)  for organic
                                    and inorganic chemicals  (4 0
                                    CFR 141 Subpart F).
                                    Federal Drinking Water
                                    Health Advisories.
                                                                         Applicable
McLs have been promulgated for a number of
common organic and inorganic contaminants.
These levels regulate the concentrations of
contaminants in public drinking water supplies,
and are considered relevant and appropriate for
groundwater aguifers potentially used for
drinking water.

MCLGs are health-based goals for public water
supplies.   MCLGs are levels considered to have
no known or anticipated adverse health effects
which includes a margin of safety.  These goals
are available for a number of organic and
inorganic contaminants.   MCLGs greater than
zero are relevant and appropriate for this site.

EPA publishes contaminant-specific health
           that indicate the non-carcinogenic
                 with consuming contaminated
                                                                                               Standards have been promulgated  in  accordance
                                                                                               with Section 22a-425 of  Connecticut  General
                                                                                               Statutes to preserve and  enhance  the guality of
                                                                                               state water.  The aguifer under  the  Study  Site is
                                                                                               classified  as GA.  Class  Ga  groundwater  is
                                                                                               suitable for existing private  supplies and
                                                                                               potential public and private supplies and  is
                                                                                               suitable for drinking or  other domestic  uses
                                                                                               without treatment.
These standards will be met
through natural attenuation
processes.   Institutional controls
will present the aguifer from being
used as a water supply until MCL's
are attained.
These standards will be met
through natural attenuation
processes.   Institutional controls
will prevent the aguifer from being
used as a water supply until these
standards are attained.
                                                               These standards will be met
                                                               through natural attenuation
                                                               processes.  Institutional controls
                                                               will prevent the aguifer from being
                                                               used as a water supply until these
                                                               standards are attained.

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                                                           TABLE 7
                                       CHEMICAL-SPECIFIC  ARARs:   CRITERIA, ADVISORIES  AND GUIDANCE
                                                          FOR THE  SELECTED  ALTERNATIVE
                                                         Gallup's  Quarry Superfund Site
                                                              Plainfield, Connecticut
                                        Revision:   1
                                         Date:  06/97
Authority
                                           Requirements
                                     Connecticut Standards for
                                     Public Drinking Water Quality
                                     (RCSA °19-13-B102 (e) (1 -
                                     6) ) .
                                                                       Applicable
                                                                       Applicable
State MCLs have been promulgated for a
number of inorganic contaminants,  and
maximum permissible health-based limits have
been set for a number of pesticides and organic
chemicals.  Action levels are also established
under this act.  These levels regulate the
concentrations of contaminants in public
drinking water supplies,  but may also be
considered appropriate for groundwater aguifers
potentially used for drinking water.

Establishes remediation standards for
contaminated groundwater.  Standards are based
on surface water protection, volatilization, and
groundwater protection.  The regulations include
a procedure for establishing criteria where none
exist for a particular pollutant,  and for
establishing alternative criteria where those
specified in the regulations are not appropriate.

Establishes remediation standards for
contaminated soils.   Standards are based on risk
from direct contact and pollutant mobility and
depend on land use or groundwater
classification.  These regulations provide
specific numeric cleanup criteria for a wide
variety of contaminants in soil.  They provide
separate criteria for threats to human health and
environmental receptors posed by direct contact
with contaminants, and for risks to
environmental receptors posed by migration of
contaminants via groundwater or soil vapor.
Action Taken to Attain
       Requirement

These standards will eventually be
met through natural attenuation
processes.   Institutional controls
will prevent the aquifer from being
used as a water supply until these
standards are attained.
                                                                                                                                                       Natural attenuation processes will
                                                                                                                                                       eventually reduce concentrations  of
                                                                                                                                                       COCs to meet remediation
                                                                                                                                                       standards.
                                                                                                                                                       Natural attenuation processes,
                                                                                                                                                       rainfall infiltration,  and
                                                                                                                                                       groundwater  flushing will
                                                                                                                                                       eventually reduce concentrations
                                                                                                                                                       COCs in soil.  VOC COC  levels
                                                                                                                                                       are anticipated to be reduced to
                                                                                                                                                       below remediation standards  in
                                                                                                                                                       approximately  15 years.

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                                      TABLE  7
           ACTION-SPECIFIC ARARs:  CRITERIA,  ADVISORIES AND GUIDANCE
                         FOR THE SELECTED ALTERNATIVE
                        Gallup1s Quarry  Superfund Site
                           Plainfield, Connecticut
                                                                                                   Revision:   1
                                                                                                   Date:   06/97
                                            Status
                                                            Requires hazardous waste disposal facility
                                                            operators to develop a plan for closure and post-
                                                            closure care and monitoring of the facility,
                                                            including groundwater and soil monitoring.
                                                        Closure and post-closure
                                                        monitoring requirements will be
                                                        implemented through the Long-
                                                        Term Monitoring Plan (LTMP).
Federal Water Quality Criteria  (40  CFR   To  be
131)                                      Considered
                                                        Long-term groundwater
                                                        monitoring will be performed to
                                                        ensure standards are not
                                                        exceeded.
Hazardous Waste Management:
Generator £ Handler Requirements-
General Standards, Listing S
Identification  (RCSA °22a-449(c)100-
101)
                                         Applicable
These sections establish standards  for  listing  and
identification of hazardous waste.   The  standards
of 40 CFR °°26Q-261 are incorporated by
reference.   Chromium is not exempted from  listing
as a hazardous waste.  These standards  are
applicable to investigation derived waste.
Per 40 CFR °°260-261, any
derived waste identified as
hazardous waste will be managed
as listed.
                                         Applicable
                                                            This section establishes standards for various
                                                            classes of generators.  The standards of 40  CFR
                                                            0 2 62 are incorporated by reference.  Storage
                                                            requirements given at 40 CFR °2 65.15 are also
                                                            included.   These standards are applicable to
                                                            investigation derived waste.
                                                        Management of investigation
                                                        derived waste will comply with
                                                        the standards of 40 CFR °°262
                                                        and 40 CFR 0<)265.15.

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                                        TABLE 7
             ACTION-SPECIFIC ARARs:   CRITERIA,  ADVISORIES AND GUIDANCE
                           FOR  THE  SELECTED ALTERNATIVE
                         Gallup's Quarry Superfund Site
                              Plainfield,  Connecticut
                                                                        Revision:  1
                                                                        Date:  06/97
                                                                                                                           Action Taken to Attain
                                                                                                                                Requirement
                                           Applicable
Hazardous Waste Management:   Interim
Status Facilities and Groundwater
Monitoring requirements, Closure and
Post Closure Requirements  (RCSA
°22a-449(c)105)
                                           Applicable
                                                               This section establishes standards  for treatment,
                                                               storage, and disposal of hazardous  waste,  and
                                                               establishes standards for closure,  post  closure,  and
                                                               groundwater monitoring.  The standards of  40
                                                               CFR °2 64 are incorporated by reference.
This section establishes interim  status  standards
for treatment, storage, and disposal  of  hazardous
waste, and establishes standards  for  closure,  past
closure, and groundwater monitoring.   The
standards of 40 CFR °265 are  incorporated  by
reference.
Standards for treatment, storage
and disposal of hazardous waste
and closure, post-closure and
groundwater monitoring will be
complied with.  Groundwater
monitoring will be performed
with implementation of the long-
term monitoring of groundwater
plan (LTMP).

Requirements for ground water
monitoring, closure, and post-
closure will be compiled with.
Ground water monitoring will be
performed with the LTMP.
                                            Applicable
                                                               These regulations establish allowable noise  levels.
                                                               They would apply to construction activities  on  the
                                                               site, including installation of groundwater
                                                               monitoring wells.
                                            Applicable
                                                               These rules apply mainly to any new water  supply
                                                               or withdrawal wells.   The rules specify  that  non-
                                                               water supply wells must be constructed so  that
                                                               they are not a source or cause of groundwater
                                                               contamination.  Procedures for abandonment of
                                                               wells apply to both water wells and other  types of
                                                               wells.
                                                           Non-water supply wells will not
                                                           be constructed on the site unless it
                                                           can be shown that they will not be
                                                           a source or cause of groundwater
                                                           contamination.
                                         Applicable
                                                               Prohibits issuance of a permit for drilling  of  a
                                                               water supply well for any property where  the
                                                               boundary is within 200 feet of an approved water
                                                               supply.   Specifies separation distances between
                                                               wells and pollution sources.  Gives  construction
                                                              standards for water supply wells.
                                                           Institutional controls will ensure
                                                           that water supply wells are not
                                                           constructed at the Gallup's
                                                           Quarry site and on downgradient
                                                           properties.

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                           TABLE  7
ACTION-SPECIFIC ARARs:  CRITERIA,  ADVISORIES AND GUIDANCE
              FOR THE  SELECTED ALTERNATIVE
            Gallup's Quarry  Superfund Site
                 Plainfield,  Connecticut
                                                Revision:   1
                                                Date:   06/97
                                                                                                                              Action to be Taken to Attain
                                                                                                                                       Requirement
           Federal Clean Water  Regulations             Relevant
           governing dredge  and fill  activities  in    and
           wetlands  (33 CFR  320-328).                  Appropriate
No discharge of dredged or  fill materials  to
wetlands or other waters or the US  is  allowed
if there is a practicable alternative  to the
discharge which would have  a  less adverse
impact to the aguatic ecosystem, so long as
the alternative does not have  other significant
adverse impacts.   Appropriate  and
practicable steps must be taken to  minimize
adverse impacts,  during construction
activities in wetlands.
Appropriate and practicable
steps will be taken in
accordance with these
regulations to minimize adverse
impacts to wetlands from well
drilling efforts.
           Federal Executive  Order  11990,
           Statement  of  Proceedings  for  Wetland
           Protection  (40  CFR 6,  Appendix  A).
Requirements to avoid adversely  impacting
wetlands,  minimize destruction and mitigate
impacts to wetlands.
Appropriate and practicable
steps will be taken in
accordance with these
regulations to minimize adverse
impacts to wetlands from well
drilling efforts.
           Federal Executive  Order  11988,
           Floodplains  Protection  (40  CFR,
           Appendix A)
Requirements to avoid adverse  effects,
minimize potential harm, and preserve
beneficial values of floodplains.
Appropriate and practicable
steps will be taken in
accordance with these
regulations to minimize advers
impacts to wetlands from well
drilling efforts.
                                                                          EPA's GPS includes  a  component  which              Adequate controls will be
                                                                          states that groundwater  is  ecologically vital if  utilized to prevent damage to
                                                                          the aquifer provides  the  base  flow for  a          any particularly sensitive
                                                                          particularly sensitive ecosystem  which,  if        ecosystem which, if polluted,
                                                                          polluted, would destroy  a unique  habitat.          would destroy a unique habitat.

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                                   TABLE  7
         ACTION-SPECIFIC ARARs:  CRITERIA, ADVISORIES  AND GUIDANCE
                       FOR THE SELECTED ALTERNATIVE
                     Gallup's Quarry  Superfund Site
                          Plainfield,  Connecticut
                                                       Revision:   1
                                                       Date:   06/97
                   Federal Groundwater Use  and  Value
                   Determination  (EPA Region  1,  1995).
                                                           Applicable
Combines two regional initiatives,  the
Super fund Beneficial Reuse  Initiative and the
Comprehensive Groundwater Protection
Strategy.   The guidance is  intended to  result
in more cost-effective groundwater  cleanups
and facilitate beneficial reuse  of  contaminated
parcels.

These statutes provide for  the municipal
regulation of various activities  in aguifer
protection areas.
These regional initiatives will
be applied while implementing
the groundwater control
measures.
                                                           Applicable       Reguires that water wells be  located  away
                                                                            from groundwater flow  from  a  source of
                                                                            pollution.  Installation of water  wells  is
                                                                            prohibited within 200  feet  of a  community
                                                                            water system.
                                                  Institutional controls will
                                                  ensure that water supply wells
                                                  are not constructed at the site
                                                  and in downgradient areas.
Surface Water
                   Connecticut Surface Water  and
                   Wetlands - Inland Wetlands  and
                   Watercourses Regulations  (RCSA
                   22A-39-1 through 15).
Regulates any operation within  or  use  of  a
wetland or watercourse involving removal  of
material, or any construction,  alteration,  o
pollution of such wetlands  or watercourses.
During monitoring well
construction adeguate controls
will be utilized to minimize
adverse impact to wetlands,
                   Connecticut Environmental  Land Use
                   Restriction Regulations  (RCSA °22A-
                   133q-l)
Reguirements to prevent disturbance  of
contaminated soil and to ensure  that
contaminated groundwater is not  used for
human consumption.
Implementation of
environmental land use
restrictions including deed
restrictions.

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                              APPENDIX B

                                   FIGURES


                             APPENDIX C
              STATE OF CONNECTICUT CONCURRENCE  IiETTER

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                             APPENDIX D

                        RESPONSIVENESS SUMMARY

                    GALLUP'S QUARRY  SUPERFUND SITE

                       PLAINFIELD, CONNECTICUT

                         September 30, 1997

                U.S. Environmental Protection Agency

                              Region I

                    GALLUP'S QUARRY  SUPERFUND SITE
                        RESPONSIVENESS SUMMARY
                        PLAINFIELD,  CONNECTICUT

                           TABLE OF  CONTENTS

                                                                         Page

PREFACE 	   1

  I.  OVERVIEW OF REMEDIAL ALTERNATIVES CONSIDERED
      IN THE FEASIBILITY STUDY, INCLUDING  THE
      PREFERRED ALTERNATIVE  	   2

 II.  SITE HISTORY AND BACKGROUND ON COMMUNITY
      INVOLVEMENT AND CONCERNS  	   3

III.  SUMMARY OF COMMENTS RECEIVED DURING  THE PUBLIC
      COMMENT PERIOD AND EPA RESPONSES 	   5

      Part I.    Citizen Comments  	   5

      Part II.   State Officials 	   6

      Part III.  Potentially Responsible Parties  	   7


ATTACHMENT A - TRANSCRIPT FROM  THE INFORMAL PUBLIC  HEARING

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                         RESPONSIVENESS SUMMARY
                     GALLUP'S QUARRY SUPERFUND SITE
                         PLAINFIELD, CONNECTICUT
                                Preface

The U.S. Environmental Protection Agency  (EPA) held a 30-day public comment period from June 25, 1997 to
July 25, 1997 to provide an opportunity for the public to comment on the Remedial Investigation  (RI),
Feasibility Study  (FS) ,  the Proposed Plan, and other documents developed for the Gallup's Quarry
Superfund site in Plainfield, Connecticut  (the Site).   The FS examined and evaluated various options,
called remedial alternatives, to address contamination at the Site.  EPA made a preliminary
recommendation of its Preferred Alternative for Site remediation in the Proposed Plan issued on June 25,
1997 at the start of the comment period.  All documents on which the preferred alternative was based have
been placed in the Administrative Record for public review.  The Administrative Record is a collection of
all the documents considered by EPA to select the remedy for the Site.  It is available at the EPA
Records Center at 90 Canal Street in Boston, Massachusetts and at the Plainfield Public Library on
Railroad Avenue in Plainfield, Connecticut.

The purpose of this Responsiveness Summary is to document EPA responses to the guestions and comments
raised during the public comment period.  EPA has considered all of the comments in this document before
selecting a final remedial alternative to address contamination at the Site.

The Responsiveness Summary is organized into the following sections:

I.  Overview of Remedial Alternatives Considered in the Feasibility Study and Proposed Plan, including the
   Preferred Alternative - This section briefly outlines the remedial alternatives evaluated in the FS
   and the Proposed Plan, including EPA's Preferred Alternative.

II. Site History and Background on Community Involvement and Concerns - This section provides a brief
    Site history and a general overview of community interests and concerns regarding the Site.

III. Summary of Comments Received During the Public Comment Period and EPA Responses - This section
     summarizes and provides EPA's responses to the oral and written comments received from the public
     during the public comment period.  In Part I of this Section, the comments received from citizens
     are presented.  Part II summarizes comments received by State officials.  Part III summarizes
     comments from the Potentially Responsible Parties (PRPs).

In addition, two attachments are included in this Responsiveness Summary.  Attachment A provides a
chronology of community relations activities at the Site.  Attachment B contains a copy of the transcript
from the informal public hearing held on June 25, 1997 in Plainfield, Connecticut.  The comments
submitted during the public comment period are available in the Administrative Record for the Gallup's
Quarry Site.

I.   OVERVIEW OF REMEDIAL ALTERNATIVES CONSIDERED IN THE FEASIBILITY STUDY AND PROPOSED PLAN

Using the information gathered during the RI, EPA identified several objectives for the cleanup of the
Gallup's Quarry Site.  The primary cleanup objective is to reduce the risks to human health and the
environment posed by potential future exposure to groundwater contamination that has already or may in
the future migrate off site.  Cleanup levels for groundwater and soil are set at levels that EPA
considers to be protective of human health and the environment.

After identifying the cleanup objectives, EPA developed and evaluated potential cleanup alternatives,
called remedial alternatives.  The FS describes the remedial alternatives considered to address the
contaminants of concern and the pathways in which they pose a threat.  The FS also describes the criteria
EPA used to narrow the range of alternatives to five potential source control (SC) remedial alternatives
and four potential management of migration  (MM) remedial alternatives.

The five source control remedial alternatives considered are:

   SC-1:           No Action
   SC-2:           Natural Attenuation with Institutional Controls
   SC-3:           RCRA Cap
   SC-4:           Excavation, On-site Treatment of soils with Ex-Situ Soil Vapor Extraction
   SC-5:           Excavation, Off-site Treatment/Disposal of Soils

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The four management of migration remedial alternatives are:
MM-1: No Action
MM-2: Natural Attenuation with Institutional Controls
MM-3: Containment via Groundwater Extraction, Treatment, and Discharge
MM-4: Remediation via Groundwater Extraction, Treatment, and Discharge

The preferred alternative selected by EPA to address Site contamination includes natural attenuation of
contamination in soil and groundwater, implementation of institutional controls, long-term monitoring of
groundwater and soil and Five-Year Site Reviews (SC-2 and MM-2).

The cleanup plan will rely on natural processes known to be occurring at the site to reduce the
concentrations of contaminants in soil and groundwater to protective levels, and institutional controls
to prevent unnecessary use and disturbance of Site soil and any use of groundwater until target cleanup
levels are attained. A long-term monitoring program will also be implemented and will continue until the
target cleanup levels have been attained and EPA determines that the remedy is protective of human health
and the environment.

After a careful review of the comments made during the public comment period, EPA documented the selected
remedy in the Record of Decision. The selected remedy shows no significant changes from the preferred
alternative. All of the remedial alternatives considered for implementation at this Site can be found in
the Record of Decision Summary, the Proposed Plan, and the FS.

II. SITE HISTORY AND BACKGROUND ON COMMUNITY INVOLVEMENT AND CONCERNS

The Gallup's Quarry site was used as a former gravel mining operation in the 1950's and 1960's. In 1977,
complaints from neighboring residents led to an investigation by the Connecticut Department of
Environmental Protection (DEP) and the Connecticut State Police. The DEP investigation concluded that
the Site was used from the summer of 1977 until December 1977 for unlicensed waste disposal. Evidence
collected by DEP indicates that Chemical Waste Removal, Inc. (CWR) of Bridgeport, Connecticut transported
drummed and bulk liguid waste material to the Site. These materials included a variety of industrial
wastes.

Emergency clean up efforts were performed during the summer of 1978 under the direction of the DEP and
the Connecticut State Police. This involved the removal and off-site disposal of drums of liguid wastes,
free liguids, and contaminated soil from three disposal locations on the site. A buried inverted dump
truck was also removed from the Site.

Since the 1978 cleanup operations, periodic monitoring of soil and groundwater was performed by the DEP,
the Connecticut Department of Health and EPA. In May of 1988, EPA initiated a limited Site Investigation
to evaluate the Gallup's Quarry Site with respect to conditions for additional removal actions under the
National Contingency Plan (NCP). Soil samples collected by EPA confirmed the presence of volatile
organic compounds (VOCs), semi-VOCs, and metals. Based on the results of the 1988 Site Investigation, on
June 24, 1988 the Site was proposed to be added to EPA's National Priorities List (NPL). On October 4,
1989 the Site was finally listed on the NPL.

While the Site has been vacant since 1978 it has been utilized by trespassers for recreational purposes.
In 1994, a fence was erected at the entrance to the Site, and other foot/vehicle paths were blocked with
boulders, to limit Site usage by trespassers. Additionally, warning signs were posted around the
property.

In 1993 EPA notified forty parties, who were either an owner/operator of the facility, transporter, or a
generator of wastes that were disposed of at the Site, of their potential liability with respect to the
Site. Thereafter, negotiations commenced with these potentially responsible parties (PRPs) regarding the
settlement of the PRP's liability at the Site. On September 7, 1993, EPA and twenty-three of the forty
PRPs, entered into an Administrative Order by Consent for the performance of the RI/FS.

Throughout the Site's history, community concern and involvement has been relatively low. Prior to EPA's
involvement with the Site, residents and town officials have kept up with Site activities by following
the local papers. There were no organized citizens groups during the emergency removal effort by the
DEP. The DEP kept citizens informed of Site activities through the media, the First Selectman, the Fire
Marshall and the police. EPA has kept the community and other interested parties apprized of Site
activities through fact sheets, press releases, and a public meeting.

During November 1993, EPA conducted interviews of various Plainfield town officials, business owners, and
residents. These interviews were conducted to identify community concerns for preparation of EPA's

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Community Relations Plan  (CRP).   In June of 1994, EPA released the CRP which outlined a program to
address community concerns and to keep citizens informed of and involved in activities during remedial
activities.  Notice of the release of this document was sent to local residents, town officials, and to
the media on August 3, 1994.

In August of 1994, EPA issued a fact sheet announcing the start of the RI at the Site.  The fact sheet
also summarized site history, the Superfund process, and the field activities to be performed at the
Site.  In March of 1996 EPA notified the public and media of the availability of the Initial Site
Characterization Report which detailed the results of the first phase of the field investigation. In
November of 1996, EPA issued a fact sheet announcing the completion of the RI and detailing the results
of this investigation.

On June 17, 1997, EPA issued the Proposed Plan for addressing residual soil and groundwater contamination
at the Site.  The Proposed Plan was made available to local residents and town officials by mailing
copies of this document to the mailing list and placing a copy in the Plainfield Public Library.  On June
25, 1997, EPA made the RI/FS and Human Health and Ecological Risk Assessment (RA)  reports available for
public review at EPA's offices in Boston and at the Plainfield Town Library.

On June 25, 1997, EPA held an informational public meeting at the Plainfield Town Hall to discuss the
results of the RI report and the cleanup alternatives presented in the FS and to present the Agency's
Proposed Plan.  From June 25 to July 25, 1997, the Agency held a 30 day public comment period to accept
public comment on the alternatives presented in the FS and the Proposed Plan and on any other documents
previously released to the public.  Also on June 25, 1997, the Agency held a public hearing at the
Plainfield Town Hall to accept any oral comments.

III.  SUMMARY OF COMMENTS RECEIVED DURING THE PUBLIC COMMENT PERIOD AND EPA RESPONSES

This Responsiveness Summary addresses comments received by EPA during the public comment period.  While a
number of concerns were raised to EPA during the June 25, 1997 public meeting,  only one citizen of
Plainfield commented on EPA's Preferred Alternative during the public hearing on June 25, 1997.  Three
sets of written comments were received by EPA during the public comment period including:  local
residents, the Connecticut Department of Environmental Protection and the Gallup's Quarry PRP Group.

Part I - Citizens

Comment 1:  One citizen, representing the "homeowners of Tarbox Road", reguested that the eguipment,
trailers, and fencing located at 86 Tarbox Road  (the Gallup's Site) be removed as guickly as possible, as
they believe it to be visually unattractive.

EPA Response:  All eguipment and trailers that were utilized to conduct the RI of the site will be
removed in 1997.  The fence erected at the entrance to 86 Tarbox Road was installed to 1) protect the
eguipment and trailers during the field investigation and to 2) limit the use of the site by trespassers
for recreational purposes.  While EPA has determined that the presence of hazardous substances remaining
at the site does not pose an unacceptable risk to human health, low levels of contaminants do exist at
the site and potential exposures to those contaminants by trespassers should be limited to the extent
practicable.  While modifications to the fence will be sought to reduce the obtrusive nature of this
fence, a modified fence will remain to restrict use of the site by users of recreational vehicles.

Comment 2:  A former resident adjacent to the Site stated their preference for alternatives SC-4 or SC-5
and MM-4, which include active treatment of Site contaminants.  This resident feels that these
alternatives are the only feasible options to ensure the safety of Plainfield residents.  This former
resident stated that additional unidentified areas of disposal may exist at the site and that incidences
of cancer and other illnesses in the family may be attributable to contamination at the Site.

EPA Response:  EPA has determined that neither alternatives SC-4 or SC-5 and MM-4 would yield results
that are proportionate to the selected remedy in terms of their overall protectiveness, implementability,
effectiveness and cost.  Section 121(b)(1) of CERCLA presents several factors that EPA is reguired to
consider at a minimum in its assessment of alternatives.  Building upon these specific statutory
mandates, the National Contingency Plan articulates nine evaluation criteria to be used in assessing the
individual remedial alternatives.  A detailed analysis is performed on the alternatives using the nine
evaluation criteria in order to select a site remedy.   [A summary of the comparison of each alternative's
strength and weakness with respect to the nine evaluation criteria is found in Section IX of the attached
Record of Decision].

While alternatives SC-4/SC-5 and MM-4 would permanently reduce the concentrations of contaminants to
acceptable levels, the selected remedy  (SC-2 and MM-2) will also achieve the target cleanup levels.  EPA

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recognizes that the estimated time period to achieve the cleanup goals is considerably longer for the
selected remedy (15 years/SC-2 and 27 years/MM-2) than for the most conservative alternatives (9
months/SC-5 and 17 years/MM-4).   However, each of these alternatives would provide the same level of
protection to human health and the environment through the implementation of institutional controls to
prevent unacceptable potential future exposure to site contaminants for significantly less money.  The
total cost of implementing SC-5  and MM-4 is estimated to range between $12.2 million and $26.9 million.
Whereas, the total cost of implementing SC-2 and MM-2 are expected to cost approximately $2,152,000.

With respect to the citizen's concern that there may be additional unidentified disposal areas at the
Gallup's Quarry Site, the results of the comprehensive Site investigation (documented in the June 1997 RI
Report) indicate that no additional sources of contamination are known to be present at the Site.  Given
the illegal nature of the former disposal activities at the Site, one of the primary objectives of the
Site investigation was to identify a potential disposal areas.  This investigation included a thorough
multi-phased approach designed to meet this objective, as well as to characterize the nature and extent
of all sources of contamination identified.  These studies included:  a visual Site reconnaissance;
geophysical surveys to identify potential buried drums/waste locations with follow-up test pits; a soil
gas survey to analyze Site soil  gas for VOC contamination at 106 locations;  soil sampling and analysis at
identified disposal areas; installation of 50 temporary groundwater well points and 39 multi-level
monitoring wells for sampling and analysis; and sampling and analysis of adjacent residential water
supplies.  This investigation documents that there were only three disposal areas at the Site and that
all adjacent residential water supplies have not been impacted by the Site contaminants.

While past exposures to site contaminants by local residents are not known and cannot be evaluated by
EPA, the human health and ecological risk assessment prepared for the Gallup's Quarry Site indicate that
there are no current unacceptable adverse impacts to the public.  The only unacceptable potential risk to
the public would be from the ingestion of groundwater by a future hypothetical worker if the Site were
developed for commercial/industrial uses and the contaminated groundwater were utilized.  Site data
provided to the Agency for Toxic Substances and Disease Registry (ATSDR) for the purpose of performing a
health consultation, indicate that exposures to residual concentrations of contaminants in soils at the
former disposal areas do not constitute a public health threat.  Additionally, an investigation of cancer
occurrences in Plainfield and its surrounding communities, prepared by the State of Connecticut
Department of Health Services (March 24, 1993), reported no increase of cancer incidences in Plainfield.

Part II - State Officials

Written comments were received from the Connecticut DEP.  The DEP agrees that the environmental land use
restrictions described in its regulations  (i.e., RCSA Section 22a-133q-l) could be used to prevent both
the disturbance of contaminated soil and the ingestion of contaminated groundwater.  However, the DEP
submits that an easier and more  cost effective alternative to prevent the ingestion of groundwater is to
extend public water to properties affected by groundwater contamination.  It has been DEP's experience
that the public health code, which prohibits the installation of a drinking water well if a community
water system is located within 200 feet of the property, effectively prevents the installation of
drinking water wells where public water is available.

EPA Response:  There are no current human health risks from exposure to groundwater at the site as the
contaminated groundwater is not  currently being used as a public or private water supply.  Under
controlling state and federal law, EPA is required to prevent future ingestion of groundwater until safe
drinking water standards are met.  EPA did not propose an extension of the public water supply as part of
the selected remedy because the  most conservative means to prevent the ingestion of groundwater is to
require deed restrictions.  Although EPA is not opposed to an extension of the public water supply to
serve future growth, such an extension is not required for this site as deed restrictions will
effectively prevent the ingestion of groundwater.

Part III - Potentially Responsible Parties  (PRPs)

Written comments were received from the Gallup's Quarry PRP Group,  comprised of 23 PRPs at the Site.
This group expressed their support of the June 1997 Proposed Plan as a technically sound remedy, that
reflects the significant prior remediation conducted by the DEP and is consistent with the scientific
investigations conducted at the  Site.  The group further states that the proposed remedy will ensure
cleanup of the groundwater within a reasonable time frame and will be protective of human health and
natural resources while allowing for beneficial use of the Site for future industrial development.

EPA Response:  EPA concurs with the statements made by the Gallup's Quarry PRP Group.

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 1                          TOWN OF PLAINFIELD
                              PUBLIC HEARING
 2                         PLAINFIELD TOWN HALL
                              JUNE 25, 1997
 3                               7:00 p.m.

 4

 5

 6

 7                                                       ORIGINAL
 9

10
     Re:   Gallup's Quarry Superfund Site
11             Information Session
               and Formal Comment Session
12

13

14

15

16

17

18
     Leslie McVickar, Remedial Project Manager
19                    U.S.  Environmental Protection Agency
                      JFK Federal Building, HBT
20                    Boston, MA  02203

21

22

23

24

25

                            Shea & Sullivan
                            10 Lanyard Lane
                       Waterford, CT  06385-3208

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 1                         INFORMAL SESSION

 2            (Portions of which were recorded and audible

 3  by court reporter.)

 4            (Beginning at approximately 9:05 p.m.)

 5  PAUL SWEET:   For the record,  Paul Sweet,  First

 6  Selectman for the Town of Plainfield.  Just another

 7  question:  Are the owners of the property also

 8  responsible in part for contamination?

 9            LESLIE McVICKAR:   Right now on our list the

10  owners of the Gallup's Quarry site is one of those

11  parties that we have found to be legally responsible.

12  And in terms of their successors, it's a tricky issue

13  of which I can't answer.   I'm not an attorney.

14            PAUL SWEET:   I  understand that.  I guess if

15  the property is in a probate situation--(Inaudible by

16  court reporter)--! guess  in the best interest of the

17  Town of Plainfield is what I'm trying to protect here.

18  I understand the deed restrictions.  And I know what

19  you're saying.  I'm just  saying if there's an

20  opportunity here for the  future of Plainfield for that

21  site.  No one's ever going to buy that site.  No one's

22  ever going to buy that site without water.  What I'm

23  saying to you, if the minimal layout here I understand

24  is $129,000 to let nature take its course, it will be

25  well into the next century before anything can possibly

                     Shea & Sullivan
                     10 Lanyard Lane
                Waterford, CT  06385-3208

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 1  happen without the influence of water and possibly

 2  sewer lines being out there.

 3            LESLIE McVICKAR:   I do understand what your

 4  point is and do sympathize  with that.  But

 5  unfortunately, the way Superfund's set up, we're not in

 6  the business to extend water lines to make it easier

 7  for the property to be developed.

 8            PAUL SWEET:  I guess what I'm saying is if

 9  there is somebody in position that has the liability

10  and responsibility--! don't know if it's—sure it's a

11  big number.  But I don't know if it's that big a number

12  to deal with the issue now  somehow in order--! don't

13  want to say penalty—is that what I'm calling it, is

14  it?  And I guess what I'm saying to you is the parties

15  that were responsibility for it, let them mediate the

16  problem now by getting water out to the site so the

17  site can be usable.  I'm not disputing the way you want

18  to do that.

19            LESLIE McVICKAR:   Yes.  It's an interesting

20  prospective.  It's just a different prospective than

21  what EPA has.   We can't do  that within our authority.

22  We're trying to take an action here to, you know,

23  ensure that no one is drinking the water.  That's our

24  goal.

25            PAUL SWEET:  I appreciate that.  I really do.

                     Shea & Sullivan
                     10 Lanyard Lane
                Waterford, CT  06385-3208

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 1            LESLIE McVICKAR:   One of the things developers

 2  do look at is they because  the property will have

 3  been--is degraded,  because  there will be deed

 4  restrictions on it,  a developer is going to get a,

 5  possibly,  a better price better, price on that parcel.

 6  And running a water line, it's just an operational  cost

 7  that it would be factored into the plan.  It might  not

 8  make or break whether that  site gets developed or not

 9  because there is, as far as I know, there's water line

10  to inner mark just across the river.

11            MARY JANE McDONALD:  In terms of this

12  overhead,  one of the two threshold criteria is

13  protecting the health of the environment and meeting

14  the state and federal requirements.  Those are the

15  threshold criteria.   Not included in that criteria  is

16  any sort of economical development which is really  what

17  you're alluding to in terms of extending a water line.

18            PAUL SWEET:  No ma'am.  What I'm telling

19  you--(Inaudible by court reporter)--deed restrictions

20  will accomplish that.  What I'm saying to you is and

21  I'm asking you to follow-up on somehow on

22  that--(Inaudible by court reporter)--! trust you at

23  your word.  But is it in your authority--don't tell me

24  EPA can't order cleanup.  I don't want your money.   I'm

25  not asking--Plainfield's not asking for EPA money.   I'm

                     Shea & Sullivan
                     10 Lanyard Lane
                Waterford, CT  06385-3208

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 1  basically saying I understand there's a group of people

 2  that are part of this problem.   I'm sure there's

 3  insurance involved.  Sure there's other things

 4  involved.  I'm just saying to you:   Is there an avenue

 5  to deal with the problem now to show that the site is

 6  not barren or whatever else in the future.

 7            MARY JANE McDONALD:  What I'm trying to say

 8  is that in terms of our threshold criteria--

 9            PAUL SWEET:  Twenty-seven years is a long

10  time.

11            MARY JANE McDONALD:  Just let me finish.

12  There's two criteria:  protecting human health and the

13  environment and the state and federal requirements.

14  Those are the threshold criteria that we have to meet.

15  Not included in those criteria is economic development.

16  In answer to your question, the answer to your question

17  is no,  you don't have the authority to order somebody

18  to do something unless it's in violation of those

19  criteria.  Unfortunately	

20            PAUL SWEET:  So basically,  what you're saying

21  is that the deed restrictions are appropriate--

22            MARY JANE McDONALD:  I'm sorry.  I didn't

23  hear the question.

24            PAUL SWEET:  You're saying that the deed

25  restrictions are appropriate; and that's as far as your

                     Shea & Sullivan
                     10 Lanyard Lane
                Waterford, CT  06385-3208

-------
 1  taking it?

 2            MARY JANE McDONALD:   In terms of this

 3  situation, we think that that is an appropriate vehicle

 4  to deal with it.

 5            RICHARD MERCIER:   Am I correct in assuming

 6  that the responsible parties are far more numerous than

 7  just the person who owns the land?

 8            LESLIE McVICKAR:   Yes.  There are--EPA

 9  identified 40 parties.

10            PAUL SWEET:  How many?

11            LESLIE McVICKAR:   Forty.

12            PAUL SWEET:  Do you have a legal attorney

13  here?

14            LESLIE McVICKAR:   No.   Our attorney is not

15  here.

16            PAUL SWEET:  I guess my guestion is:   Can the

17  town take a legal action against those 40 parties?

18            LESLIE McVICKAR:   You know, I can't answer

19  that.  I'm not an attorney.  I apologize.

20            PAUL SWEET:  I understand.  I'm just trying to

21  protect the area.  (Inaudible by court reporter).

22            LESLIE McVICKAR:   We really don't have

23  authority to extend a water line just to aid in trying

24  to develop this parcel.  And I don't disagree with you.

25  It's a wonderful idea.   But maybe to attract

                    Shea & Sullivan
                    10 Lanyard Lane
               Waterford, CT  06385-3208

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 1  developers,  the owner might want to do that and expend

 2  the money.

 3            PAUL SWEET:  It's the only way it's ever

 4  going to happen.

 5            LESLIE McVICKAR:   Yeah.  Yeah.

 6            TRISHA HAUGHT:  (Inaudible by court reporter.)

 7            LESLIE McVICKAR:   Trisha, could you speak up?

 8            TRISHA HAUGHT:   If I could just add

 9  something--(Inaudible  by court reporter)--if there was

10  some law that they have violated and that law provided

11  cause of action if my client contaminated ground water

12  knowing he did something bad,  you would be able to say,

13  You broke the law.  I'm going to sue you for breaking

14  the law, perhaps, hypothetically, of course.  What you

15  have to understand Superfund law and how parties become

16  so-called potentially responsible party--(Inaudible by

17  court reporter).

18            MARSAL MARTIN:   Who do you represent?

19            TRISHA HAUGHT:   I represent Pitney Bowes.

20            MARSAL MARTIN:   So they're one of the

21  contributors to the chemicals on the front end.

22            TRISHA HAUGHT:  Well, let me

23  explain--(Inaudible by court reporter)--is that a

24  company can legally dispose of its waste, everything's

25  legal.   (Inaudible by court reporter)--they transfer

                     Shea & Sullivan
                     10 Lanyard Lane
                Waterford, CT  06385-3208

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 1  this waste to in fact a site that someone tells them to

 2  dispose of that.  The state can say you disposed of the

 3  waste at this site,  the company does that dots every

 4  "I", crosses every "T", absolutely by the book,

 5  legally.

 6            If that site is later to be called a

 7  Superfund site,  the law allows them to go after those

 8  companies that did everything legally and go after

 9  those companies to recover the cost of cleaning up that

10  site.

11            LESLIE McVICKAR:  Trisha, I just want to add

12  one thing to this.  When I mentioned that we found

13  these parties to be legally responsible for the site in

14  some way, it's — you know, this is a very debatable

15  issue of who's responsible for this.  There are

16  elements of liability and whether it's an owner

17  operator, generator,  transporter EPA--or Congress

18  decided when it passed this law to take a--(Inaudible

19  by court reporter)--even if these parties, you know,

20  didn't know that their waste was ending up in this

21  spot, it did.  And we've got evidence to tie them into

22  it.  And it's just the way the law was enacted.

23  (Inaudible by court reporter).

24            PAUL SWEET:  So my point is, Counselor, is

25  that there's lot of big outfits out there that revolve

                      Shea & Sullivan
                      10 Lanyard Lane
                 Waterford, CT  06385-3208

-------
 1  in this.   I'm not calling them polluters.   I'm not

 2  trying to label them.   I'm trying to say—(Inaudible by

 3  court reporter)--if you want to settle the issue,  and

 4  if it's two hundred thousand--(Inaudible by court

 5  reporter)--then I'm going to do what I can to do what's

 6  best for the town.

 7            TRISHA HAUGHT:  Absolutely.

 8            PAUL SWEET:    (Inaudible by court

 9  reporter)--the number may be insignificant in the life

10  of 40 people involved.  I'm not accusing anyone.

11            TRISHA HAUGHT:  I understand that.   (Inaudible

12  by court reporter.)--the people that owned the site.

13  In fact,  we have documents that told us that our stuff

14  was going elsewhere but landed at this site.    So that's

15  why I said you--it's very difficult to unless you have

16  a law that allows you to pursue someone you can't

17  just--(Inaudible by court reporter.)

18            MARSAL MARTIN:  You're trying to say your

19  client did everything right.  Is that it.

20            TRISHA HAUGHT:  I'm not here to defend my

21  client or support anything.  I'm simply responding to

22  the guestion.

23            LESLIE McVICKAR:  I think we're-

24            MARSAL MARTIN:   (Inaudible by court

25  reporter)--two hundred thousand dollar water main going

                      Shea & Sullivan
                      10 Lanyard Lane
                 Waterford, CT  06385-3208

-------
 1  to the property,  the EPA is recommending natural

 2  attenuation at the cost of two million dollars.   Why

 3  should the neighborhood accept that?  Why wouldn't we

 4  want to go after the twelve million dollars to get it

 5  cleaned up as fast as we could.  Why should we accept

 6  the natural attenuation?  (Inaudible by the court

 7  reporter.)

 8            LESLIE McVICKAR:  I think there's no real good

 9  answer for this.   You know,  we're dealing with the

10  government.  What you have to remember is the state DEP

11  did do an initial removal.  And they did a very good

12  removal.  But 1978 is not 1997.  And things changed

13  drastically over in the—in the '80's and '90's.  And

14  residual levels were tracked.  And you know,  we--we

15  wanted—it's a very long process.   There's not a good

16  answer few you.  It's a very slow process.  What we

17  were most concerned about is mitigating any immediate

18  threat to the public.  And we knew that there wasn't an

19  immediate threat to the public during those years.

20  People were not drinking the contaminated ground water.

21  And what was left in the soil were residually low

22  levels.

23             (Inaudible by the court reporter.)

24            LESLIE McVICKAR:  We had wells out there.  We

25  had collected soil samples.   So we did actually have a

                      Shea & Sullivan
                      10 Lanyard Lane
                 Waterford, CT  06385-3208

-------
 1  study out there that--(Inaudible by court reporter)--so

 2  it wasn't until it ran to the Superfund side that we

 3  had to get into the very nitty-gritty of it, which is

 4  what you saw tonight to look at future, you know, what

 5  future actions really need to be done.

 6            PAUL SWEET:  Does the EPA feel

 7  comfortable--(Inaudible by court reporter)--

 8            LESLIE McVICKAR:  Very much.  I feel two years

 9  worth of comfortable about--(Inaudible by court

10  reporter).

11            LESLIE McVICKAR:—you can have your well

12  water tested.  Sure.  The answer to number one,

13  depending on where you live, you can have your well

14  water tested privately.   Most people do that when they

15  have their own--have drilled their own well.

16           (Inaudible by court reporter).

17           LESLIE McVICKAR:  Sure.  You can hire someone

18  to test for whatever chemicals you want if that's what

19  you're concerned about.   But before you do that,  you

20  have to look at where you live.  I don't know where you

21  live.  But I can certainly sit down and tell you

22  whether there's a potential impact from us onto your

23  side.  And I can tell you right now there isn't because

24  the plume is not impacting any of the nearest wells

25  around it.

                      Shea & Sullivan
                      10 Lanyard Lane
                 Waterford,  CT  06385-3208

-------
 1            If you're concerned about other sources,  you

 2  know,  I mean—individual wells are contaminated by

 3  often times so many things.  You can dump some waste

 4  soil on your--when you're changing the oil in your car

 5  or you spill some paint thinner and it can somehow

 6  migrate into your own well.  So it's really tricky in

 7  terms of what might be the source of contamination.

 8  But yes, you can have it tested, you know, by

 9  independent consultants.

10           (Inaudible by court reporter).

11           LESLIE McVICKAR:  I think that was just

12  bought.  I  think I just spoke with the gentleman a

13  couple weeks ago.  He's a developer.  But you're

14  question is?

15            (Inaudible by court reporter.)

16            LESLIE McVICKAR:  No.  The condemnation of the

17  house has nothing to do with the site.

18            (Inaudible by court reporter).

19  LESLIE McVICKAR:  Okay.  Any more questions?

20  All right.   Well, we have a court stenographer here.

21  And what we'd like you to do is come up and speak so

22  she can hear you possibly in the microphone and state

23  your comment or concern.  And your concerns are again

24  something we will address in our response and summary

25  along with the final record and decision.  And we

                     Shea & Sullivan
                     10 Lanyard Lane
                Waterford, CT  06385-3208

-------
 1  really do welcome--

 2            MARSAL MARTIN:   Can I do the same thing in

 3  writing?

 4            LESLIE McVICKAR:   Yes.  You can do the same

 5  thing in writing or E-mail  to me.

 6            MARSAL MARTIN:  Well, I  think at this point I

 7  would prefer to write.

 8            LESLIE McVICKAR:   Okay.   Does anybody have any

 9  statements they would like  to make?

10

11                   FORMAL COMMENT SESSION:

12            LAURIE LAVALLEE:   My name is Laurie Lavallee.

13  I live on Norwich Road in Plainfield.  And I just feel

14  as with that gentleman that they should go the

15  aggressive route with the cleanup  and make the parties,

16  whoever they are responsible—may  not be that woman's

17  company she's representing—but whoever is ultimately

18  responsible should be responsible  for aggressive

19  cleanup of the site.  I think it's been put off way too

20  long now.  Thank you.

21            LESLIE McVICKAR:   Thank  you all for coming.

22  If you have any additional  guestions, feel free to

23  contact me.

24             (Whereupon the hearing was adjourned at 9:45

25  p.m.)

                      Shea & Sullivan
                      10 Lanyard Lane
                 Waterford, CT   06385-3208

-------
                     CERTIFICATE

STATE OF CONNECTICUT

COUNTY OF WINDHAM

          I, Jennifer Vernon, Professional Reporter and

Notary Public duly commissioned and qualified,  do

hereby certify that the foregoing is a true and

accurate transcript of the proceedings as taken

stenographically and which were audible by me at the

time and place aforementioned.

          IN WITNESS WHEREOF, I have hereunto set my

hand this 28th day of June, 1997, at Moosup,

Connecticut.


                     Shea & Sullivan
                     10 Lanyard Lane
                Waterford, CT  06385-3208

-------
                          APPENDIX E

                  ADMINISTRATIVE RECORD INDEX

                    ROD Signed: September 1997

                                   Prepared By
                                 EPA New England
                     Office of Site Remediation & Restoration
                       U.S. Environmental Protection Agency
                  ADMINISTRATIVE RECORD INDEX
                        GALLUP'S QUARRY
  09/25/97
Page     1
   SITE ASSESSMENT - PRELIMINARY ASSESSMENT

   Title:       Preliminary Assessment Package for Gallup's Quarry, Plainfield, Connecticut.
   Addressee:   DON SMITH - ENVIRONMENTAL PROTECTION AGENCY/REGION 1
   Authors:     KENNETH JONES - NUS CORPORATION/FIELD INVESTIGATION TEAM
   Date:       July 24,  1986
   Format:      MEMORANDUM                   No. Pgs:  12
   AR No.       01.02.1                      Document No.  000001

   Title:       Trip Report:  Gallup's Quarry, Plainfield,  Connecticut.
   Addressee:   DON SMITH - ENVIRONMENTAL PROTECTION AGENCY/REGION 1
   Authors:     KENNETH JONES - NUS CORPORATION/FIELD INVESTIGATION TEAM
   Date:       January 9,  1987
   Format:      MEMORANDUM                   No. Pgs:  2
   AR No.       01.02.2                      Document No.  000002

   Title:       Summary of Telephone Conversation between EPA Contractor and Plainfield Crystal Water
               Company Regarding Water Services in Plainfield, Connecticut.
   Addressee:   RANDY KEMPAIGN - PLAINFIELD/CRYSTAL WATER CO.
   Authors:     JANE CONNET - NUS CORPORATION/FIELD INVESTIGATION TEAM
   Date:       June 17,  1987
   Format:      TELEPHONE MEMO               No. Pgs:   1
   AR No.       01.02.3                      Document No.  000003

   Title:       Summary of a Telephone Conversation between EPA Contractor and Gallup Water Company
               Regarding Their service Area in Plainfield.
   Addressee:   GALLUP WATER CO.
   Authors:     JANE CONNET - NUS CORPORATION/FIELD INVESTIGATION TEAM
   Date:       June 18,  1987
   Format:      TELEPHONE MEMO               No. Pgs:   1
   AR No.       01.02.4                      Document No.  000004

        Title:       Removal Program,  Preliminary Assessment/Site Investigation for Gallup's Quarry Site,
                    Plainfield, Connecticut.
        Addressee:  ENVIRONMENTAL PROTECTION AGENCY/REGION 1
        Authors:     ROY F. WESTON/TECHNICAL ASSISTANCE TEAM
        Date:        August 1991
        Format:     REPORT, STUDY                No.  Pgs:   27
        AR No.       01.02.5                      Document No.  000005
02.02
        REMOVAL RESPONSE - REMOVAL RESPONSE REPORTS
        Title:       Gallup's Quarry Site, Drinking Water Sampling Survey, Plainfield, Connecticut.
        Addressee:   US EPA REGION I/LEXINGTON
        Authors:     ROY F. WESTON/TECHNICAL ASSISTANCE TEAM
        Date:         1993
        Format:      REPORT,  STUDY                No. Pgs:  78
        AR No.       02.02.1                      Document No.  000006

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02.03
        REMOVAL RESPONSE - SAMPLING & ANALYSIS DATA
        Title:       Evaluation of Soil Sample Taken from Gallup's Quarry Site Using Soil pH Method 9045.
        Addressee:  DOROTHY GIRTEN - ENVIRONMENTAL PROTECTION AGENCY/REGION 1
        Authors:     KATHLEEN M. POLGAR - US EPA REGION I/LEXINGTON
        Date:        January 14, 1993
        Format:      MEMORANDUM                   No. Pgs:   2
        AR No.       02.03.1                      Document No.  000007

        Title:       Evaluation of Soil Samples Taken from Gallup's Quarry Site Using Test Method 335.2.
        Addressee:  DOROTHY GIRTEN - ENVIRONMENTAL PROTECTION AGENCY/REGION 1
        Authors:     KATHLEEN M. POLGAR - US EPA REGION I/LEXINGTON
        Date:        January 28, 1993
        Format:      MEMORANDUM                   No. Pgs:   4
        AR No.       02.03.2                      Document No.  000008

   03.01  REMEDIAL INVESTIGATION - CORRESPONDENCE

          Title:        Addendum to Ground Water Monitoring Report, Former Pervel Industries Flocking
                       Plant,  August and December 1992 Sampling Events.
          Addressee:   ROBINSON & COLE
          Authors:     HRP ASSOCIATES, INC.
          Date:         April 20, 1993
          Format:       LETTER                       No. Pgs:  117
          AR No.        03.01.1                      Document No.   000009

          Title:        Addendum to Ground Water Monitoring Report, Former Pervel Industries Flocking
                       Plant,  March and June 1993 Sampling Events.
          Addressee:   FRANK WILSON - CT YANKEE COMMUNITY AVENUE PARTNERSHIP
          Authors:     HRP ASSOCIATES, INC.
          Date:         October 25, 1993
          Format:       REPORT, STUDY                No. Pgs:  28
          AR No.        03.01.2                      Document No.   000010

          Title:        Gallup's Quarry Superfund Site, Approval of Amended RI/FS Work Plan.
          Addressee:   THOMAS HARRISON - DAY, BERRY AND HOWARD
          Authors:     LESLIE MCVICKAR - ENVIRONMENTAL PROTECTION AGENCY/REGION 1
          Date:         August 19, 1994
          Format:       LETTER                       No. Pgs:  1
          AR No.        03.01.3                      Document No.   000011
          Title:        Gallup's Quarry Superfund Project, CT DEP File Review.
          Addressee:   LESLIE MCVICKAR - ENVIRONMENTAL PROTECTION AGENCY/REGION 1
          Authors:     JIM BANNON, RUTH KRUMHANSL - ENVIRONMENTAL SCIENCE & ENGINEERING,
          Date:         March 28, 1995
          Format:       LETTER                       No. Pgs:  4
          AR No.        03.01.4                      Document No.  000012
INC
          Title:       Gallup's Quarry Superfund Site:  Third Draft Phase IB Work Plan.
          Addressee:  THOMAS HARRISON - DAY, BERRY AND HOWARD
          Authors:    LESLIE MCVICKAR - ENVIRONMENTAL PROTECTION AGENCY/REGION 1
          Date:        October 6, 1995
          Format:      LETTER                       No. Pgs:  2
          AR No.       03.01.5                      Document No.  000013
   3.02
          REMEDIAL INVESTIGATION - SAMPLING & ANALYSIS DATA
          Title:       Data Validation Report, Case No. 23076, SDG AJH43.
          Addressee:  CHRISTINE CLARK - US EPA REGION I/LEXINGTON
          Authors:    EDWARD J. MACKINNON - TRC ENVIRONMENTAL CORPORATION
          Date:        April 17, 1995
          Format:      REPORT,  STUDY                No. Pgs:  53
          AR No.       03.02.1                      Document No.  000014

-------
Title:      Data Validation Report, Case No. 23076.
Addressee:  CHRISTINE CLARK - US EPA REGION I/LEXINGTON
Authors:    EDWARD J. MACKINNON - TRC ENVIRONMENTAL CORPORATION
Date:       April 17, 1995
Format:     REPORT, STUDY                No. Pgs:  31
AR No.      03.02.2                      Document No.  000015

Title:      Data Validation Report, Case No. 0008T SDG DAT070.
Addressee:  CHRISTINE CLARK - US EPA REGION I/LEXINGTON
Authors:    EDWARD J. MACKINNON - TRC ENVIRONMENTAL CORPORATION
Date:       April 17, 1995
Format:     REPORT, STUDY                No. Pgs:  33
AR No.      03.02.3                      Document No.  000016

Title:      Data Validation Report, Case No. 23127 SDG MAC249.
Addressee:  CHRISTINE CLARK - US EPA REGION I/LEXINGTON
Authors:    EDWARD J. MACKINNON - TRC ENVIRONMENTAL CORPORATION
Date:       April 17, 1995
Format:     REPORT, STUDY                No. Pgs:  36
AR No.      03.02.4                      Document No.  000017

Title:      Data Validation Report, Case No. 23127 SDG MAC238.
Addressee:  CHRISTINE CLARK - US EPA REGION I/LEXINGTON
Authors:    EDWARD J. MACKINNON - TRC ENVIRONMENTAL CORPORATION
Date:       April 17, 1995
Format:     REPORT, STUDY                No. Pgs:  33
AR No.      03.02.5                      Document No.  000018

Title:      Data Validation Report, Case No. 23127 SDG AJHM.
Addressee:  CHRISTINE CLARK - US EPA REGION I/LEXINGTON
Authors:    EDWARD J. MACKINNON - TRC ENVIRONMENTAL CORPORATION
Date:       April 17, 1995
Format:     REPORT, STUDY                No. Pgs:  58
AR No.      03.02.6                      Document No.  000019

Title:      Data Validation Report, Case No. 23127 SDG:AJH49  [Confidential].
Addressee:  CHRISTINE CLARK - US EPA REGION I/LEXINGTON
Authors:    EDWARD J. MACKINNON - TRC ENVIRONMENTAL CORPORATION
Date:       April 17, 1995
Format:     REPORT, STUDY                No. Pgs:  57
AR No.      03.02.7                      Document No.  000020
Title:      Data Validation Report, Case No. 23127 SDGMAC238  [Confidential].
Addressee:  CHRISTINE CLARK - US EPA REGION I/LEXINGTON
Authors:    EDWARD J. MACKINNON - TRC ENVIRONMENTAL CORPORATION
Date:       April 17, 1995
Format:     REPORT, STUDY                No. Pgs:  33
AR No.      03.02.8                      Document No.  000021

Title:      Data Validation Report, Case No. 23076 SDG: MAEP53  [Confidential]
Addressee:  CHRISTINE CLARK - US EPA REGION I/LEXINGTON
Authors:    EDWARD J. MACKINNON - TRC ENVIRONMENTAL CORPORATION
Date:       April 17, 1995
Format:     REPORT, STUDY                No. Pgs:  31
AR No.      03.02.9                      Document No.  000022
Title:      Data Validation Report, Case No. 23127 SDG:MAC249  [Confidential].
Addressee:  CHRISTINE CLARK - US EPA REGION I/LEXINGTON
Authors:    EDWARD J. MACKINNON - TRC ENVIRONMENTAL CORPORATION
Date:       April 17, 1995
Format:     REPORT, STUDY                No. Pgs:  36
AR No.      03.02.10                     Document No.  000023

-------
Title:      Data Validation Report, Case No. 0008T SDG:DAT070  [Confidential].
Addressee:  CHRISTINE CLARK - US EPA REGION I/LEXINGTON
Authors:    EDWARD J. MACKINNON - TRC ENVIRONMENTAL CORPORATION
Date:       April 17, 1995
Format:     REPORT, STUDY                No. Pgs:  34
AR No.      03.02.11                     Document No.  000024

Title:      Data Validation Report, Case No. 23076 SDG:AJH43  [Confidential].
Addressee:  CHRISTINE CLARK - US EPA REGION I/LEXINGTON
Authors:    EDWARD J. MACKINNON - TRC ENVIRONMENTAL CORPORATION
Date:       April 17, 1995
Format:     REPORT, STUDY                No. Pgs:  53
AR No.      03.02.12                     Document No.  000025

3.03  REMEDIAL INVESTIGATION - SCOPES OF WORK

      Title:       Statement of Work, Remedial Investigation and Feasibility Study, Gallup's  Quarry
                   Superfund  Site.
      Authors:     ENVIRONMENTAL PROTECTION AGENCY/REGION 1
      Date:        September 7, 1993
      Format:      WORK PLAN                    No. Pgs:  55
      AR No.       03.03.1                      Document No.   000026

3.04  REMEDIAL INVESTIGATION - INTERIM DELIVERABLES
      Title:       Well Survey Performed at the Gallup's Quarry Site on January  21,
      Addressee:   MIKE JASINSKI - ENVIRONMENTAL PROTECTION AGENCY/REGION  1
      Authors:     KRISTINE CAMPBELL - METCALF & EDDY
      Date:        January 27, 1993
      Format:      LETTER                       No. Pgs:  8
      AR No.       03.04.1                      Document No.  000027
1993
      Title:       Final Remedial Investigation/Feasibility Study, Work Plan -  Phase  1A, Volume  1
                   Work Plan.
      Addressee:   ENVIRONMENTAL PROTECTION AGENCY/REGION 1
      Authors:     ENVIRONMENTAL SCIENCE & ENGINEERING, INC
      Date:        August 29, 1994
      Format:      REPORT;  STUDY                No. Pgs: 185
      AR No.       03.04.2                      Document No.  000028

      Title:       Final Remedial Investigation/Feasibility Study, Work Plan -  Phase  1A, Volume  2
                   Appendices A and B.
      Addressee:   ENVIRONMENTAL PROTECTION AGENCY/REGION 1
      Authors:     ENVIRONMENTAL SCIENCE & ENGINEERING, INC
      Date:        August 29, 1994
      Format:      REPORT, STUDY                No. Pgs:  232
      AR No.       03.04.3                      Document No.  000029

Title:      Final Remedial Investigation/Feasibility Study, Work Plan - Phase 1A, Volume 3  -
            Appendices C, D and E.
Addressee:  GALLUP'S QUARRY PRP GROUP TECH COMMITTEE
Authors:    HALEY & ALDRICH
Date:       August 29, 1994
Format:     REPORT,  STUDY                No. Pgs:  582
AR No.      03.04.4                      Document No.  000030
Title:      Laboratory Comprehensive Quality Assurance Plan for Environmental Science  &  Engineering,
            Inc. Peoria Laboratory.
Addressee:  ENVIRONMENTAL PROTECTION AGENCY/REGION 1
Authors:    BARBARA BEARD, KIM JOHNSON, BARBARA RAYA-HASH, LETTIE SCHMITT - ESE/PEORIA,  IL LABORATORY
Date:       October 1994
Format:     REPORT, STUDY                No. Pgs:  288
AR No.      03.04.5                      Document No.  000031

-------
Title:      Phase IB Work Plan, Gallup's Quarry Superfund Project, Revision 3.
Addressee:  ENVIRONMENTAL PROTECTION AGENCY/REGION 1
Authors:    ENVIRONMENTAL SCIENCE & ENGINEERING, INC
Date:       November 1995
Format:     REPORT, STUDY                No. Pgs:  46
AR No.      03.04.6                      Document No. 000032

Title:      Review of Initial Site Characterization Report—Phase IA, Draft October  6,  1995.
Addressee:  LESLIE MCVICKAR - ENVIRONMENTAL PROTECTION AGENCY/REGION 1
Authors:    MARK LEWIS - CT DEP/BUREAU OF WATER MANAGEMENT
Date:       November 17, 1995
Format:     LETTER                       No. Pgs:  3
AR No.      03.04.7                      Document No.  000033

03.06  REMEDIAL INVESTIGATION - REMEDIAL INVESTIGATION REPORTS

       Title:       Gallup's Quarry Superfund Project, Remedial Investigation Report, Volumes  I-VII.
       Addressee:   ENVIRONMENTAL PROTECTION AGENCY/REGION 1
       Authors:     QST ENVIRONMENTAL
       Date:        June 1997
       Format:      REPORT,  STUDY
       AR No.       03.06.1                      Document No.  000034

3.09  REMEDIAL INVESTIGATION - HEALTH ASSESSMENTS

      Title:       Health Consultation:  Evaluation of Well Water Sampling, Gallup's Quarry,
                   Plainfield, Connecticut.
      Addressee:   ALEX SHERRIN - ENVIRONMENTAL PROTECTION AGENCY/REGION 1
      Authors:     LOUISE HOUSE - US EPA/ATSDR
      Date:        May 29, 1989
      Format:      MEMORANDUM                   No. Pgs:  2
      AR No.       03.09.1                      Document No.  000035
      Title:       Health Assessment for Gallup's Quarry Site, Plainfield, Connecticut.
                   CTD108960972.
      Authors:     US DEPT. OF HEALTH & HUMAN SVCS/ATSDR
      Date:        January 30, 1991
      Format:      REPORT, STUDY                No. Pgs:  15
      AR No.       03.09.2                      Document No.  000036
                 CERCLIS No.
      Title:       Reguest for Health Consultation, Gallup's Quarry Superfund Site, Plainfield,
      Addressee:   LOUISE HOUSE - US EPA/ATSDR
      Authors:     MIKE JASINSKI - ENVIRONMENTAL PROTECTION AGENCY/REGION 1
      Date:        February 19, 1993
      Format:      MEMORANDUM                   No. Pgs:  1
      AR No.       03.09.3                      Document No.  000037
                        CT.
Title:      ATSDR Record of Activity:  Review of Private Well Water Sampling Results for Eight
            Private Wells in the Vicinity of the Gallup's Quarry Site.
Addressee:  MIKE JASINSKI - ENVIRONMENTAL PROTECTION AGENCY/REGION 1
Authors:    LYNN C. WALDEN - AGENCY FOR TOX SUBS. & DISEASE REGISTRY
Date:       February 25, 1993
Format:     PRINTOUT                     No. Pgs:  2
AR No.      03.09.4                      Document No.  000038
Title:      Investigation of Cancer Occurrence in Canterbury, Griswold,
            Connecticut, 1971-1990.
Authors:    DIANE D. AYE - CT DEPARTMENT OF HEALTH SERVICES
Date:       March 24, 1993
Format:     MEMORANDUM                   No. Pgs:  10
AR No.      03.09.5                      Document No. 000039
Lisbon,  and Plainfield,

-------
    Title:      ATSDR Record of Activity:  Health Consultation for Additional Data Collected During
                Follow-up Site Visits, with Attached Analytical Data.
    Authors:    EDWARD BAZENAS - ENVIRONMENTAL PROTECTION AGENCY/REGION 1
    Date:       March 31, 1993
    Format:     PRINTOUT                     No. Pgs:   11
    AR No.      03.09.6                      Document No.  000040

    Title:      ATSDR Record of Activity:  Explanation of Soil Sampling Results for the Gallup's Quarry
                Site.
    Authors:    LYNN C. WALDEN - AGENCY FOR TOX SUBS.  & DISEASE REGISTRY
    Date:       March 31, 1993
    Format:     PRINTOUT                     No. Pgs:   2
    AR No.      03.09.7                      Document No.  000041

    Title:      Health Consultation, Gallup's Quarry,  Plainfield, Connecticut, CERCLIS No. CTD10896072.
    Date:       June 2, 1994
    Format:     REPORT, STUDY                No. Pgs:   4
    AR No.      03.09.8                      Document No.  000042

    Title:      Gallup's Quarry Superfund Site, Plainfield, CT, Reguest for Health Consultation.
    Addressee:  LOUISE HOUSE - US EPA/ATSDR
    Authors:    LESLIE MCVICKAR - ENVIRONMENTAL PROTECTION  AGENCY/REGION 1
    Date:       May 3, 1995
    Format:     MEMORANDUM                   No. Pgs:   1
    AR No.      03.09.9                      Document No.  000043

    Title:      ATSDR Record of Activity:  Review of Results of Soil Sample Analysis for PCBs.
    Authors:    ROBERT WILLIAMS - AGENCY FOR TOX SUBS. & DISEASE REGISTRY
    Date:       May 30, 1995
    Format:     PRINTOUT                     No. Pgs:   3
    AR No.      03.09.10                     Document No.  000044

    Title:      ATSDR Record of Activity:  Comments on PCB Levels Analyzed in Soil Samples Taken from the
                Gallup's Quarry site.
    Authors:    ROBERT WILLIAMS - AGENCY FOR TOX SUBS. & DISEASE REGISTRY
    Date:       July 12, 1995
    Format:     PRINTOUT                     No. Pgs:   2
    AR No.      03.09.11                     Document No.  000045

3.10   REMEDIAL INVESTIGATION - ENDANGERMENT/BASELINE RISK ASSESSMENTS

   Title:       Risk Assessments, Gallup's Quarry Project.
   Addressee:   LESLIE MCVICKAR - ENVIRONMENTAL PROTECTION  AGENCY/REGION 1
   Authors:     W. GARY WILSON - ENVIRONMENTAL SCIENCE & ENGINEERING, INC
   Date:        April 12, 1995
   Format:      LETTER                       No. Pgs:   2
   AR No.       03.10.1                      Document No.  000046

    Title:      Risk Assessment, Gallup's Quarry Superfund Site, Plainfield, Connecticut, Pathway
                Analysis Report, Revision 1.0.
    Addressee:  ENVIRONMENTAL PROTECTION AGENCY/REGION 1
    Date:       November 1995
    Format:     REPORT, STUDY                 No. Pgs:  88
    AR No.      03.10.2                       Document No.  000047
    Title:      Comments on a February 2, 1996 Letter from TRC Corporation.
    Addressee:  LESLIE MCVICKAR - ENVIRONMENTAL PROTECTION AGENCY/REGION 1
    Date:       February 22, 1996
    Format:     MEMORANDUM                   No. Pgs:  2
    AR No.      03.10.3                      Document No.  000048

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 Title:       Gallup's Quarry Risk Assessment, Draft Risk Assessment, Contract No.
             23-1LB7.
 Addressee:   LESLIE MCVICKAR - ENVIRONMENTAL PROTECTION AGENCY/REGION 1
 Authors:     PAUL HUGHES - TRC ENVIRONMENTAL CORPORATION
 Date:        May 10,  1996
 Format:      LETTER                       No. Pgs:   2
 AR No.       03.10.4                      Document No.  000049
         3-W9-0033, WA No.
 Title:       Review of Gallup's Quarry Draft Human Health Risk Assessment.
 Addressee:   LESLIE MCVICKAR - ENVIRONMENTAL PROTECTION AGENCY/REGION 1
 Authors:     SARAH LEVINSON - ENVIRONMENTAL PROTECTION
             AGENCY/REGION 1
 Date:        June 25,  1996
 Format:      MEMORANDUM                   No. Pgs:  3
 AR No.       03.10.5                      Document No.  000050
 Title:       Gallup's  Quarry Risk Assessment, Draft Risk Assessment  (Revision 1).
 Addressee:   LESLIE MCVICKAR - ENVIRONMENTAL PROTECTION AGENCY/REGION 1
 Authors:     PAUL HUGHES - TRC ENVIRONMENTAL CORPORATION
 Date:        July 19,  1996
 Format:      LETTER                       No. Pgs:  2
 AR No.       03.10.6                      Document No.  000051

       Title:      Comments on Draft Risk Assessment, Gallup's  Quarry Superfund Project, ESE Project
                   No. 7194138.
       Addressee:  LESLIE MCVICKAR - ENVIRONMENTAL PROTECTION AGENCY/REGION 1
       Authors:     W.  GARY WILSON - ENVIRONMENTAL SCIENCE & ENGINEERING, INC
       Date:        February 4,  1997
       Format:      LETTER                       No. Pgs:  4
       AR No.      03.10.7                      Document No.  000052

       Title:      Human Health Risk Assessment Addendum, Gallup's Quarry Superfund Site, Plainfield,
                   Connecticut.
       Addressee:  LESLIE MCVICKAR - ENVIRONMENTAL PROTECTION AGENCY/REGION 1
       Authors:     TRC COMPANIES
       Date:        May 1997
       Format:      REPORT, STUDY                No. Pgs:  416
       AR No.      03.10.8                      Document No.  000053

04.06  FEASIBILITY STUDY - FEASIBILITY STUDY REPORTS

       Title:       Gallup's Quarry Superfund Project Development and Initial Screening of
                    Alternatives Report.
       Addressee:   LESLIE MCVICKAR - ENVIRONMENTAL PROTECTION AGENCY/REGION 1
       Authors:      MARK LEWIS - CT DEP/BUREAU OF WATER MANAGEMENT
       Date:         August 1, 1986
       Format:       LETTER                       No. Pgs:  18
       AR No.       04.06.1                      Document No.  000054

       Title:       Gallup's Quarry Superfund Project, Draft Feasibility Study.
       Addressee:   LESLIE MCVICKAR - ENVIRONMENTAL PROTECTION AGENCY/REGION 1
        Authors:     MARK LEWIS - CT DEP/BUREAU OF WATER MANAGEMENT
        Date:       March 10, 1997
        Format:      LETTER                       No. Pgs:  13
        AR No.       04.06.2                      Document No.  000055
        Title:       Feasibility Study,  Volume 1 - Text, Figures, Tables &
        Addressee:  ENVIRONMENTAL PROTECTION AGENCY/REGION 1
        Authors:     QST ENVIRONMENTAL
        Date:        June 1997
        Format:      REPORT,  STUDY                No. Pgs:  353
        AR No.       04.06.3                       Document No.  000056
Plates.

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       Title:      Feasibility Study, Volume 2 - Appendices A, B, C, D & E.
       Addressee:  ENVIRONMENTAL PROTECTION AGENCY/REGION 1
       Authors:    QST ENVIRONMENTAL
       Date:        June 1997
       Format:     REPORT,  STUDY                No. Pgs:   219
       AR No.      04.06.4                       Document No.  000057

04.09  FEASIBILITY STUDY -  PROPOSED PLANS FOR SELECTED REMEDIAL ACTION

       Title:       Proposed Plan for the Gallup's Quarry Superfund Site.
       Authors:     ENVIRONMENTAL PROTECTION AGENCY/REGION 1
       Date:         June 1997
       Format:      REPORT,  STUDY                No. Pgs:  14
       AR No.       04.09.1                      Document No.  000058

5.03  RECORDS OF DECISION - RESPONSIVENESS SUMMARIES

      Title:        Comments on Proposed Plan for Gallup's Quarry Site.
      Addressee:   LESLIE MCVICKAR - ENVIRONMENTAL PROTECTION AGENCY/REGION 1
      Authors:     CAROL LYNN SHAGZDA
      Date:          1997
      Format:      FORM                         No. Pgs:   2
      AR No.        05.03.1                       Document No.  000059

       Title:      Comment  on the Eguipment, Trailers and Fencing Left Behind at the Gallup's Quarry
                   Site.
       Addressee:  LESLIE MCVICKAR - ENVIRONMENTAL PROTECTION AGENCY/REGION 1
       Authors:    JOHN BLARNEY, RUTH BLARNEY
       Date:        June 27,  1997
       Format:     MEMORANDUM                   No. Pgs:   1
       AR No.      05.03.2                       Document No.  000060

       Title:      Comments on the Proposed Plan for the Gallup's Quarry Superfund Site.
       Addressee:  LESLIE MCVICRAR - ENVIRONMENTAL PROTECTION AGENCY/REGION 1
       Authors:    W.  GARY WILSON
       Date:        July 15,  1997
       Format:     LETTER                       No. Pgs:   2
       AR No.      05.03.3                       Document No.  000061

       Title:      State Comments Regarding Proposed Plan for the Gallup's Quarry Superfund Site.
       Addressee:  LESLIE MCVICRAR - ENVIRONMENTAL PROTECTION AGENCY/REGION 1
       Authors:    MARR LEWIS - CT DEP/BUREAU OF WATER MANAGEMENT
       Date:        July 22,  1997
       Format:     LETTER                       No. Pgs:   2
       AR No.      05.03.4                       Document No.  000062
9.10
       STATE COORDINATION - STATE TECHNICAL AND HISTORICAL RECORDS
       Title:      Gallup's Quarry Federal National Priorities List Superfund Site, Plainfield,
                   Connecticut, Preliminary Ground Water Use and Value Determination.
       Authors:    SIDNEY HOLBROOR - CT DEPT. OF ENVIRONMENTAL PROTECTION
       Date:        March 18,  1996
       Format:     MEMORANDUM                   No. Pgs:  15
       AR No.      09.10.1                      Document No.  000063
       Title:      Draft Preliminary Ground Water Use & Value Determination, Gallup's Quarry
                   Superfund Project.
       Addressee:  MARR LEWIS - CT DEP/BUREAU OF WATER MANAGEMENT
       Authors:    W. GARY WILSON - ENVIRONMENTAL SCIENCE & ENGINEERING, INC
       Date:        October 28,  1996
       Format:     LETTER                       No. Pgs:  2
       AR No.      09.10.2                      Document No.  000064

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       Title:       Final Ground Water Use & Value Determination for the Gallup's Quarry Superfund
                   Site.
       Addressee:   ENVIRONMENTAL PROTECTION AGENCY/REGION 1
       Authors:     SIDNEY HOLBROOK - CT DEPT. OF ENVIRONMENTAL PROTECTION
       Date:        August 11,  1997
       Format:      REPORT,  STUDY                No. Pgs:   16
       AR No.       09.10.3                      Document No.  000065

10.07  ENFORCEMENT/NEGOTIATION - EPA ADMINISTRATIVE ORDERS

       Title:        Consent Order, Gallup's Quarry Superfund Site, Plainfield, Connecticut, CERCLA
                    Docket No. 1-93-1080.
       Authors:      ENVIRONMENTAL PROTECTION AGENCY/REGION 1
       Date:         August 1993
       Format:                                    No. Pgs:  129
       AR No.        10.07.1                      Document No.  000066

       Title:        Final Acceptance of Cost Recovery Settlement, Gallup's Quarry Superfund Site,
                    Plainfield, Connecticut.
       Addressee:    JOHN DEVILLARS - ENVIRONMENTAL PROTECTION AGENCY/REGION 1
       Authors:      MARGERY ADAMS, LESLIE MCVICKAR - ENVIRONMENTAL PROTECTION AGENCY/REGION 1
       Date:         February 16, 1994
       Format:       MEMORANDUM                   No. Pgs:  147
       AR No.        10.07.2                      Document No.  000067

13.02  COMMUNITY RELATIONS - COMMUNITY RELATIONS PLANS

       Title:       Community Relations Plan, Gallup's Quarry Superfund Site, Plainfield, Connecticut.
       Authors:     ENVIRONMENTAL PROTECTION AGENCY/REGION 1
       Date:        June 1994
       Format:      REPORT,  STUDY                 No. Pgs:  15
       AR No.       13.02.1                       Document No.  000068

13.03  COMMUNITY RELATIONS - NEWS CLIPPINGS/PRESS RELEASES

       Title:       Now What Do We Do With It?!.
       Authors:     MARK KESHGIAN
       Format:      NEWS CLIPPING                No. Pgs:   1
       AR No.       13.03.1                      Document No.  000069

       Title:       Plainfield Executive Charged in Chemical Wastes Burial.
       Authors:     GERALD DEMEUSY
       Format:      NEWS CLIPPING                No. Pgs:   1
       AR No.       13.03.2                      Document No.  000070

       Title:       EPA Targets Two Sites for Superfund Cleanup.
       Authors:     DON BOND
       Format:      NEWS CLIPPING                No. Pgs:   1
       AR No.       13.03.3                      Document No.  000071

       Title:       Gallup Demands Respect - Commands Great Power.
       Authors:     NORWICH BULLETIN
       Date:        1978
       Format:      NEWS CLIPPING                No. Pgs:   2
       AR No.       13.03.4                      Document No.  000072

       Title:       Trailer Truck Photograph May Identify Source of Gravel Pit Chemical Dumping.
       Authors:     MARION PROKOP - NORWICH BULLETIN
       Date:        January 17, 1978
       Format:      NEWS CLIPPING                No. Pgs:   1
       AR No.       13.03.5                      Document No.  000073
       Title:       Police Raid Five Businesses in Toxic Chemical Crime sweep.
       Authors:     ED MAHONY,  MARION PROKOP - NORWICH BULLETIN
       Date:        March 11,  1978
       Format:      NEWS CLIPPING                No. Pgs:  2
       AR No.       13.03.6                      Document No.  000074

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Title:      Barrels Impounded in Case Involving Toxic Chemicals.
Authors:    THEODORE DRISCOLL - HARTFORD COURANT
Date:       March 11, 1978
Format:     NEWS CLIPPING                No. Pgs:   1
AR No.      13.03.7                      Document No. 000075

Title:      Chemicals in Plainfield Pit Part of Illegal Interstate Venture.
Authors:    MARION PROKOP - NORWICH BULLETIN
Date:       March 11, 1978
Format:     NEWS CLIPPING                No. Pgs:   1
AR No.      13.03.8                      Document No.  000076

Title:      Toxic Chemicals Under Guard.
Authors:    THEODORE DRISCOLL - HARTFORD COURANT
Date:       March 12, 1978
Format:     NEWS CLIPPING                No. Pgs:   1
AR No.      13.03.9                      Document No.  000077

Title:      State Police Continue to Probe Disposal of Flammable Chemicals.
Authors:    BRIDGEPORT POST
Date:       March 16, 1978
Format:     NEWS CLIPPING                No. Pgs:   1
AR No.      13.03.10                     Document No.  000078

Title:      Latest Form of Recognition Taints Gallup's Reputation.
Authors:    PAUL FRISMAN
Date:       April 8, 1978
Format:     NEWS CLIPPING                No. Pgs:   2
AR No.      13.03.11                     Document No.  000079

Title:      Court Tells Gallup to Pay $790,000.
Authors:    ED MAHONY - NORWICH BULLETIN
Date:       May 13, 1978
Format:     NEWS CLIPPING                No. Pgs:   2
AR No.      13.03.12                     Document No.  000080

Title:      Region May Be Littered with Hazardous Dump Sites.
Authors:    DENIS MORIN - NORWICH BULLETIN
Date:       December 2, 1978
Format:     NEWS CLIPPING                No. Pgs:   1
AR No.      13.03.13                     Document No.  000081

Title:      Hazardous Waste Disposal Plan Needed to Retain Industries.
Authors:    ANSON SMITH - NORWICH BULLETIN
Date:       February 1, 1979
Format:     NEWS CLIPPING                No. Pgs:   1
AR No.      13.03.14                     Document No.  000082

Title:      A Case of Too Little Action Too Late - Toxic Waste Dumping Has Taken Its Toll.
Authors:    MARK KESTIGIAN
Date:       March 21, 1980
Format:     NEWS CLIPPING                No. Pgs:   1
AR No.      13.03.15                     Document No.  000083

Title:      EPA Wants Comments On Potential Superfund Sites.
Authors:    CLAIRE BESSETTE - NORWICH BULLETIN
Date:       September 9, 1988
Format:     NEWS CLIPPING                No. Pgs:   1
AR No.      13.03.16                     Document No.  000084
Title:      Gallup Quarry on Cleanup List.
Authors:    DON BOND - NORWICH BULLETIN
Date:       September 29, 1989
Format:     NEWS CLIPPING                No. Pgs:  1
AR No.      13.03.17                     Document No.  000085

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        Title:       Firms Agree to Pay for Toxic Waste Study at Gallup's Quarry.
        Authors:     CLAIRE BESSETTE - NORWICH BULLETIN
        Date:        September 15,  1993
        Format:      NEWS CLIPPING                No. Pgs:   1
        AR No.       13.03.18                     Document No.  000086

 13.04  COMMUNITY RELATIONS - PUBLIC MEETINGS/HEARINGS

        Title:       Gallup's Quarry Superfund Site - Plainfield,  Connecticut - Community Meeting and
                    Public Hearing on the Proposed Plan.
        Authors:     ENVIRONMENTAL PROTECTION AGENCY/REGION 1
        Date:        June 5,  1997
        Format:      PUBLIC MEETING RECORDS       No. Pgs:   1
        AR No.       13.04.1                      Document No.  000087

 13.05  COMMUNITY RELATIONS - FACT SHEETS/INFORMATION UPDATES

        Title:       23 Parties Sign Administrative Agreement with the EPA to Undertake Studies at the
                    Gallup's Quarry Superfund Site.
        Authors:     US EPA/OFFICE OF COMMUNITY RELATIONS
        Date:        August 1994
        Format:      FACT SHEET, PRESS RELEASE    No. Pgs:   3
        AR No.       13.05.1                      Document No.  000088

        Title:       EPA Announces the Start of the Remedial Investigation at the Gallup's Quarry Site.
        Authors:     US EPA/OFFICE OF COMMUNITY RELATIONS
        Date:        August 1994
        Format:      FACT SHEET, PRESS RELEASE    No. Pgs:   9
        AR No.       13.05.2                      Document No.  000089

        Title:       Announcement of Availability of the Gallup's Quarry Superfund Site Community
                    Relations Plan.
        Authors:     US EPA/OFFICE OF COMMUNITY RELATIONS
        Date:        August 3, 1994
        Format:      FACT SHEET, PRESS RELEASE    No. Pgs:   2
        AR No.       13.05.3                      Document No.  000090

       Title:       Site Investigations Complete at Gallup's Quarry Superfund Site.
       Authors:     US EPA/OFFICE OF COMMUNITY RELATIONS
       Date:        November 1996
       Format:      FACT SHEET, PRESS RELEASE    No. Pgs:  4
       AR No.       13.05.4                      Document No. 000091

       Title:       Remedial Investigation Activities Completed at the Gallup's Quarry Site.
       Authors:     US EPA/OFFICE OF COMMUNITY RELATIONS
       Date:        November 1996
       Format:      REPORT, STUDY                No. Pgs:  7
       AR No.       13.05.5                      Document No.  000092

16.01  NATURAL RESOURCE TRUSTEE - CORRESPONDENCE

       Title:        Analysis of Potential Offsite Migration of Hazardous Substances in the Watershed.
       Addressee:   LESLIE MCVICKAR - ENVIRONMENTAL PROTECTION AGENCY/REGION 1
       Authors:      KENNETH FINKELSTEIN - NATIONAL OCEANIC AND ATMOSPHERIC ADMIN.
       Format:       LETTER                       No. Pgs:   1
       AR No.        16.01.1                      Document No.  000093
       Title:        Notification of Impending RI/FS Negotiations with Gallup's Quarry Potentially
                    Responsible Parties.
       Addressee:    WILLIAM PATTERSON - US DEPARTMENT OF THE INTERIOR
       Authors:      LESLIE MCVICKAR - ENVIRONMENTAL PROTECTION AGENCY/REGION 1
       Date:         March 3,  1993
       Format:       LETTER                       No. Pgs:  1
       AR No.        16.01.2                      Document No.  000094

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16.05  NATURAL RESOURCE TRUSTEE - TECHNICAL ISSUE PAPERS

       Title:        Finalized Habitat Characterization Report for the Gallup's Quarry National
                    Priorities List Site, Plainfield, Connecticut.
       Addressee:   ENVIRONMENTAL PROTECTION AGENCY/REGION 1
       Authors:     US FISH AND WILDLIFE SERVICE/NEW ENGLAND
       Date:         March 1995
       Format:      REPORT,  STUDY                No. Pgs:  18
       AR No.        16.05.1                      Document No.  000095

17.08  SITE MANAGEMENT RECORDS - FEDERAL AND LOCAL TECHNICAL AND HISTORICAL

       Title:       Geohydrology of the Gallup's Quarry Area, Plainfield, Connecticut.
       Authors:    US GEOLOGICAL SURVEY
       Date:        1995
       Format:     REPORT,  STUDY                No. Pgs:   62
       AR No.       17.08.1                       Document No.  000096

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Guidance Documents

The EPA guidance documents listed below were considered during the process of selecting the response
action for the Gallup's Quarry site. These EPA guidance documents may be reviewed at the EPA Region I
Office of Site Remediation and Restoration Records Center, 90 Canal Street, Boston, MA 02114.

1. Additional Interim Guidance for Fiscal Year 1987 Records of Decision, J. Winston Porter, U.S.
Environmental Protection Agency, Office of Solid Waste and Emergency Response. (OSWER Directive No.
9355.0-21). July 24, 1987.

2. Alternate Concentration Limit Guidance Part 1 - ACL Policy and Information Reguirements, U.S.
Environmental Protection Agency, Office of Solid Waste/Waste Management Division. (OSWER 9481.00-6c).

July 1, 1987.

3. ARARs Q'a & A's. General Policy: RCRA CWA & SWDA. U.S. Environmental Protection Agency, Office of
Emergency and Remedial Response. (OERR 9234.2-01FS). May 1, 1989.

4. CERCLA Compliance With Other Laws Manual-CERCLA Compliance with the CWA and SDWA [Quick Reference
Fact Sheet]. U.S. Environmental Protection Agency, Office of Solid Waste and Emergency Response.
(OSWER 9234.2-06FS). February 1, 1990.

5. CERCLA Compliance With Other Laws Manual-Overview of ARARs-Focus on ARAR Waivers [Quick Reference
Fact Sheet]. U.S. Environmental Protection Agency, Office of Solid Waste and Emergency Response.
(OSWER 9234.2-03FS). December 1, 1989.

6. CERCLA Compliance With Other Laws Manual Part II: Clean Air Act and Other Environmental Statutes and
State Reguirements [Quick Reference Fact Sheet]. U.S. Environmental Protection Agency, Office of
Solid Waste and Emergency Response. (OSWER 9234.1-02). August 1, 1989.

7. Community Relations in Superfund: A Handbook (Interim Version). U.S. Environmental Protection
Agency, Office of Emergency and Remedial Response. (OERR 9230.0-038). June 1, 1988.

8. Comprehensive Environmental Response, Compensation, and Liability Act of 1980. U.S. Environmental
Protection Agency. October 17, 1980.

9. Considerations in Groundwater Remediation at Superfund Sites. U.S. Environmental Protection Agency.
(9355.3-11). October 18, 1989.

10. Determining Soil Response Action Levels Based on Potential Contaminant Mbaration to Ground Water: A
Compendium of Examples. U.S. Environmental Protection Agency, Office of Emergency and Remedial
Response. (EPA/540/2-89/057). October 1989.

11. Drinking Water Regulations Maximum Contaminant Level Goals and National Primary Drinking Water
Regulations for Lead and Copper Proposed Rule. U.S. Environmental Protection Agency. (Federal
Register, Volume 53, No. 160). August 18, 1988.

12. EPA Guide for Minimizing Adverse Environmental Effects of Cleanup of Uncontrolled Hazardous Waste
Sites. U.S. Environmental Protection Agency, Environmental Research Laboratory. (EPA/600/8-85/008).
June 1, 1985.

13. Estimated Soil Ingestion Rates for Use in Risk Assessment. Peter K. Lagoy. Taken from Risk Analysis,
Vol. 7, No. 3. January 8, 1987.

14. Estimating Potential for Occurrence of DNAPL at Superfund Sites. U.S. Environmental Protection
Agency, Office of Solid Waste and Emergency Response. (OSWER 9355.4-07FS). January 1, 1992.

15. Evaluating Cover Systems for Solid and Hazardous Waste. R.J. Lutton, U.S. Army Corps of Engineers.
(9476.00-1). September 1, 1982.
16. Evaluation of Ground-Water Extraction Remedies-Volume 1 Summary Report. U.S. Environmental
Protection Agency. (EPA/540/2-89/054). September 1, 1989.

17. Federal Manual for Identifying and Delineating Jurisdictional Wetlands. U.S. Department of Army,
U.S. Environmental Protection Agency, U.S. Fish and Wildlife Service, and U.S. Soil Conservation
Service. January 10, 1989.

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18. Final Guidance on Oversight of Potentially Responsible Party Remedial Investigations and Feasibility
Studies. Volumes 1 & 2. U.S. Environmental Protection Agency, Office of Research and Development.
July 1, 1991.

19. Final Ground Water Use and Value Determination Guidance. U.S. Environmental Protection Agency.
April 3, 1996.

20. Ground Water Protection Strategy. U.S. Environmental Protection Agency, Office of Ground-Water
Protection. (EPA/440/6-84/002). August 1, 1984.

21. Guidance on Remedial Actions for Superfund Sites with PCB Contamination. U.S. Environmental
Protection Agency. (9355.4-01). August 1, 1990.

22. Guide to Selecting Superfund Remedial Actions. U.S. Environmental Protection Agency. (9355.02FS-4).
April 1, 1990.

23. Interim Final Guidance for Conducting Remedial Investigations and Feasibility Studies Under CERCLA.
U.S. Environmental Protection Agency, Office of Solid Waste and Emergency Response/Office of
Emergency and Remedial Response. (OSWER/OERR 9355.3-01). October 1, 1988.

24. Interim Final Guidance on Preparing Superfund Decision Documents: Proposed Plan, Record of
Decision, ESDs, Record of Decision Amendment. U.S. Environmental Protection Agency, Office of
Emergency and Remedial Response. (OERR 9355.3-02). June 1, 1989.

25. Interim Guidance on Superfund Selection of Remedy. J.W. Porter, U.S. Environmental Protection
Agency, Office of Solid Waste and Emergency Response (OSWER 9355.0-19). December 24, 1986.

26. National Oil and Hazardous Substances Pollution Continency Plan. U.S. Environmental Protection
Agency. (CFR Title 40, Part 300). November 20, 1985.

27. National Primary and Secondary Drinking Water Regulations. U.S. Environmental Protection Agency.
(Federal Register, Vol. 54, No. 97). May 22, 1989.

28. National Primary Drinking Water. Regulations Volatile Synthetic Organic Chemicals. U.S.Environmental
Protection Agency. (Federal Register, Vol. 50, No. 219). November 13, 1985.

29. Protection of Wetlands: Executive Order 11990. President Jimmy Carter. (Federal Register Vol. 42,
No. 26961. May 24, 1977.

30. Risk Assessment Guidance for Superfund. Volume I, Human Health Evaluation Manual. U.S.
Environmental Protection Agency. (9285.7-Ola). September 29, 1989.

31. Risk Assessment Guidance for Superfund. Volume II, Environmental Evaluation Manual. U.S.
Environmental Protection Agency. (EPA/540/1-89/001). March 1, 1989.

32. Risk Assessment Guidance for Superfund. Volume 1. Human Health Evaluation Manual Supplemental
Guidance: Standard Default Exposure Factors. Interim Final. U.S. Environmental Protection Agency,
Office of Emergency and Remedial Response. (OERR 9285.6-03). March 25, 1991.

33. Risk-Based Concentration Table, Third Quarter 1994. Roy L. Smith, U.S. Environmental Protection
Agency, Region III. July 11, 1994.

34. Role of the Baseline Risk Assessment in Superfund Remedy Selection Decisions. U.S. Environmental
Protection Agency, Office of Solid Waste and Emergency Response (OSWER 9355.0-30). April 22,1991.

35. Superfund LDR Guide #5: Determining When Land Disposal Restrictions (LDRs) are Applicable to CERCLA
Response Actions. U.S. Environmental Protection Agency. (OSWER 9347.3-05FS). July 1, 1989.

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