EPA/ROD/R02-95/257
1995
EPA Superfund
Record of Decision:
SIDNEY LANDFILL
EPA ID: NYD980507677
OU01
SIDNEY, NY
09/28/1995
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DECLARATION FOR THE RECORD OF DECISION
SITE NAME AND LOCATION
Sidney Landfill, Town of Sidney, Delaware County, New York
STATEMENT OF BASIS AND PURPOSE
This Record of Decision (ROD) documents the U.S. Environmental Protection Agency's (EPA's) selection of a
remedial action for the Sidney Landfill site, which is chosen in accordance with the requirements of the
Comprehensive Environmental Response, Compensation and Liability Act of 1980, as amended (CERCLA), 42 U.S.C.
§9601 et seq. and to the extent practicable the National Oil and Hazardous Substances Pollution Continqency
Plan (NCP), 40 CFR Part 300. This decision document explains the factual and leqal basis for selectinq the
remedy for the site. The attached index (see Appendix III) identifies the items that comprise the
Administrative Record upon which the selection of the remedial action is based.
The New York State Department of Environmental Conservation (NYSDEC) has been consulted on the planned
remedial action in accordance with CERCLA §121(f), 42 U.S.C. §9621(f), and it concurs with the selected
remedy (see Appendix IV).
ASSESSMENT OF THE SITE
Actual or threatened releases of hazardous substances from the site, if not addressed by implementinq the
response action selected in this ROD, may present an imminent and substantial endanqerment to public health,
welfare, or the environment.
DESCRIPTION OF THE SELECTED REMEDY
The selected remedy (Alternative 2A) includes:
excavatinq and relocatinq the waste from the Can and Bottle Dump Area to the adjacent North Disposal Area;
• constructinq four independent closure caps which are consistent with the requirements of New York
State 6 NYCRR Part 360 over the North Disposal Area, the White Goods Disposal and Alleqed Liquid
Disposal Areas (capped toqether), the Southeast Disposal Area, and the Southwest Disposal Area, and
the construction of four individual chain-link fences;
• extractinq contaminated qroundwater from the bedrock aquifer in the vicinity of detected), followed by
air-strippinq or other appropriate treatment, and discharqe to surface water;
• takinq steps to secure institutional controls (the placement of restrictions on the installation and
use of qroundwater wells at the site and restrictions on the future use of the site in order to
protect the inteqrity of the caps); and
• lonq-term monitorinq of qroundwater, surface water, and sediments.
After the construction of the four caps, and the extraction and treatment of the contaminated qroundwater in
the vicinity of monitorinq well MW-2S for five years, the results of semi-annual bedrock qroundwater
monitorinq will be evaluated usinq trend analysis and possibly modelinq of the bedrock aquifer to determine
whether it appears that the qroundwater quality in the bedrock aquifer would be restored to acceptable levels
throuqh natural attenuation cost-effectively and within a reasonable time flame. Should the trend analysis
and/or modelinq show that qroundwater quality in the bedrock aquifer would likely not be restored within a
reasonable time frame by natural attenuation alone, then site-wide bedrock qroundwater extraction and
treatment (Alternative 3A) may be implemented.
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DECLARATION OF STATUTORY DETERMINATIONS
The selected remedy (Alternative 2A) and the contingent remedy (Alternative 3A) meet the requirements for
remedial actions set forth in CERCLA §121, 42 U.S.C. §9621 in that they: 1) are protective of human health
and the environment; 2) attain a level or standard of control of the hazardous substances, pollutants and
contaminants, which at least attains the legally applicable or relevant and appropriate requirements (ARARs)
under federal and state laws; 3) are cost-effective; and 4) utilize permanent solutions and alternative
treatment (or resource recovery) technologies to the maximum extent practicable. In keeping with the
statutory preference for treatment as a principal element of the remedy, under the selected remedy and the
contingency remedy, contaminated groundwater will be collected and treated. The landfill material, however,
cannot be excavated and treated effectively, because of the size of the landfill and because no on-site "hot
spots" were found that represent the major sources of contamination.
A review of the remedial action pursuant to CERCLA §121(c), 42 U.S.C. §9621 (c), will be conducted five years
after the commencement of the remedial action, and every five years thereafter, to ensure that the remedy
continues to provide adequate protection to human health and the environment, because this remedy will result
in hazardous substances remaining on-site above health-based levels.
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Jeanne M. Fox Date
Regional Administrator
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RECORD OF DECISION
DECISION SUSIMARY
Sidney Landfill
Town of Sidney, Delaware County, New York
United States Environmental Protection Agency
Region II
New York, New York
September 1995
TABIiE OF CONTENTS
page
SITE NAME, LOCATION AND DESCRIPTION 1
SITE HISTORY AND ENFORCEMENT ACTIVITIES 1
HIGHLIGHTS OF COMMUNITY PARTICIPATION 2
SCOPE AND ROLE OF OPERABLE UNIT 2
SUMMARY OF SITE CHARACTERISTICS 2
SUMMARY OF SITE RISKS 5
REMEDIAL ACTION OBJECTIVES 9
DESCRIPTION OF REMEDIAL ACTION ALTERNATIVES 10
SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES 14
SELECTED REMEDY 19
STAUTORY DETERMINATIONS 20
DOCUMENTATION OF SIGNIFICANT CHANGES 24
ATTACHMENTS
APPENDIX I. FIGURES
APPENDIX II. TABLES
APPENDIX III. ADMINISTRATIVE RECORD INDEX
APPENDIX IV. STATE LETTER OF CONCURRENCE
APPENDIX V. RESPONSIVENESS SUMMARY
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SITE NAME, LOCATION AND DESCRIPTION
The 74-acre Sidney Landfill site is situated in hilly terrain within the Susquehanna River basin, in the
Town of Sidney, Delaware County, New York (see Figure 1-1), approximately 2.5 miles southeast of Sidney
Center and 3.5 miles northeast of Trout Creek. The landfill is situated on the western slope of Richardson
Hill, which is on the east side of Richardson Hill Road (see Figure 1-2). West of the landfill, adjacent to
Richardson Hill Road, is North Pond; to the southwest is South Pond. The site is situated on a drainage
divide. To the north, wetlands which receive runoff from the vicinity of the site drain into an unnamed
tributary to Carrs Creek, which flows through Sidney Center on its way to the Susguehanna River. To the
south, wetlands, which receive runoff from the vicinity of the site, drain into an unnamed tributary to Trout
Creek, which flows into the Cannonsville Reservoir on the west branch of the Delaware River. The
Cannonsville Reservoir is part of the Delaware watershed system, supplying drinking water to the New York
City metropolitan area. There are numerous springs around the site, some of which eventually discharge into
the wetlands.
The elevation in the area ranges from 1,800 at the base of the landfill to 2,120 at the top of the hill; the
distance between the two being approximately 1,700 feet.
Although the area in which waste was deposited is not well documented, it appears that several discrete areas
in different parts of the site were filled. The following disposal areas show the presence of hazardous
constituents: the North Disposal Area (10.8 acres); the Southeast Disposal Area (6.4 acres); the Southwest
Disposal Area (1.9 acres); the Alleged Liguid Waste Disposal Area (3,125 ft2); the White Goods Disposal Area
(8,516 ft2); and the Can and Bottle Dump Area (19,032 ft2) (see Figure 1-3).
SITE HISTORY AND ENFORCEMENT ACTIVITIES
The land on which the Sidney Landfill is located was purchased by Devere Rosa in 1967 for the purpose of
operating a refuse disposal area. While operating the Sidney Landfill, Mr. Rosa also operated a disposal
area on the west side of Richardson Hill Road referred to as the Richardson Hill Road Landfill.l The Sidney
and Richardson Hill Road Landfills were allegedly used for the disposal of municipal waste from the Town of
Sidney and commercial wastes from Bendix Corporation. NYSDEC and New York State Department of Health (NYSDOH)
files indicate that the Sidney Landfill was poorly operated, with improper compaction of waste, poor daily
covering, no supervision, and uncontrolled access to the site.
The Sidney Landfill was operated by Mr. James Bartlett from 1971 until 1972, when the Town of Sidney began
sending its waste to a landfill in Chenango County. In 1978, ownership of the site changed to James
Bartlett. The current owner is Lou Mangione.
1 The Richardson Hill Road Landfill, also a National Priorities List site, is currently being
investigated separately.
Based upon the results of a New York State-performed Phase II investigation of the site, which was
performed from 1985 to 1987, the site was proposed for listing on the Superfund National Priorities
List on June 24, 1988. The site was listed on the National Priorities List on March 30, 1989.
HIGHLIGHTS OF COMMUNITY PARTICIPATION
The remedial investigation (RI) report, feasibility study (FS) report, and the Proposed Plan for the site
were released to the public for comment on July 27, 1995. These documents were made available to the public
in the administrative record file at the EPA Docket Room in Region II, New York and the information
repository at the Sidney Memorial Public Library ,Main Street, Sidney. The notice of availability for the
above-referenced documents was published in the Press and SHn Bidletin on July 29, 1995. The public comment
period related to these documents was held from July 27, 1995 to August 26, 1995.
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On August 2, 1995, EPA conducted a public meeting at the Sidney Civic Center to inform local officials and
interested citizens about the Superfund process, to review current and planned remedial activities at the
site, to discuss the Proposed Plan and to respond to guestions from area residents and other interested
parties.
Responses to the comments received at the public meeting and in writing during the public comment period are
included in the Responsiveness Summary (see Appendix V).
SCOPE AND ROLE OF OPERABLE UNIT
This response action applies a comprehensive approach, therefore only one operable unit is reguired to
remediate the site.
SUMMARY OF SITE CHARACTERISTICS
The purpose of the RI, conducted from 1991 to 1995, was to determine the nature and extent and
contamination at and emanating from the site. The results of the RI are summarized below.
Groundwater Quality and Residential Wells/Springs
Bedrock aguifer samples (there is no overburden aguifer present) were collected from site monitoring wells in
1991 (Round 1) and in 1994 (Round 2) (see Table 1). Round I groundwater sampling detected, predominantly,
trichloroethene (TCE), 1,1,1-trichloroethane (TCA) , and their breakdown products, along with the occasional
presence of other volatile organic compounds (VOCs), such as toluene, xylene, and carbon disulfide.
Bis(2-Ethylhexyl)phthalate (BEHP) was the only semi-volatile organic compound (SVOC) detected with any
regularity in the groundwater samples from Round 1.
The pesticides aldrin, DDT, and heptachlor epoxide were detected in the parts per trillion range.
During Round 1, floating product was detected in a monitoring well located just east of the North Disposal
Area (monitoring well MW-2S). Screening results of the sampling showed the presence of the PCB Aroclor 1242
(61,000,000 micrograms per liter (• g/1)), ethylbenzene (12,312 • g/1), 1,1,2,2-tetrachloroethane (TCA)
(16,871 *g/l), tetrachloroethene (PCE) (23,874 • g/1), TCE (101,557 • g/1), xylenes (44,264 • g/1), and
1,2,4-trimethylhenzene (197,830 •g/1).
The results from Round 2 indicated that, on a site-wide basis, concentrations of TCE, TCA, 1,2-
dichloroethene (DCE), dichloroethane, and vinyl chloride were generally the same or less than Round
1, with the exception of a well located downgradient of the North Disposal Area (monitoring well
MW-6D) and a well located downgradient of monitoring well MW-2S (monitoring well MW-15s), which showed
elevated levels. Subseguent sampling of the groundwater "hot spot" (monitoring well MW-2S) indicated that,
while the floating product and PCBs were not detected (they may have migrated downgradient or dispersed),
high concentrations of BETX (benzene, ethylbenzene, toluene, and xylene) and VOCs were present.
TCE and its breakdown products, 1,2-DCE and vinyl chloride, are the primary groundwater contaminants that
were detected over most of the site. Concentrations of TCE ranged from 6 • g/1 to 160 • g/1, exceeding EPA
and New York State standards of 5 *g/l. TCA and its breakdown products were detected throughout the site
at guantities roughly an order-of-magnitude less than TCE, DCE, and vinyl chloride. The concentrations of
TCA did not exceed the EPA or the New York State standards in any sample. The compounds that were detected
in the groundwater appear to be distributed both horizontally and vertically in the groundwater, having been
detected to depths of 130 feet, including wells which are to the east of the site and on the other side of a
surface-water and groundwater divide. There is, however, no discernible site-wide pattern of groundwater
contamination. The highest concentrations are generally near the waste disposal areas, with the exception of
two locations southeast of the landfill site. Notable among the Round 2 results when compared to Round 1 is
the presence of PCBs (other than at the hot spot) and the virtual disappearance of pesticides. Samples from
a well located downgradient of the North Disposal Area (monitoring well MW-6S) exceeded the EPA and New York
State standards of 5 • g/1 and. 1 • g/1 respectively for Aroclor 1248 at 9.3 *g/l. Only one groundwater
sample collected during Round 2 contained elevated pesticide concentrations. A sample collected downgradient
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of the Southeast Disposal Area (monitoring well MW-3D) during Round 2 contained 0.022 • g/1 DDE, which
exceeded the New York State standard of nondetectable.
Three private water supplies (springs) located adjacent to the site show chemical contamination. Two are
currently above drinking water standards. Both springs have whole-house treatment systems, which are
currently being maintained by potentially responsible parties associated with the Richardson Hill Road
Landfill site, pursuant to an Administrative Order on Consent. As a result of the treatment systems, the
water supplies show no contamination at the point of use.
Surface and Subsurface Soils
Organic contaminants detected in the surface soils (see Table 1) were predominantly pesticides and
polychlorinated biphenyls (PCBs), with the highest concentration of PCBs being found on the east side of the
Southeast Disposal Area. The maximum PCB concentration detected in the surface soil in this area was 158,000
micrograms per kilogram (• g/kg); the maximum PCB concentration detected in the subsurface soil was 180,000
• g/kg. Other areas where PCBs were detected include the Southwest Disposal Area; the North Disposal Area;
and east of and along the road immediately downhill from the North Disposal Area. Pesticides were distributed
over the site in approximately the same areas as PCBs. DDT and its breakdown products, ODD and DDE, were
most commonly detected. The highest concentration of DDT was 640 • g/kg.
Elevated inorganic contaminants were detected, primarily, in surface soil samples in the eastern portion of
the Southeast Disposal Area and northwest of the North Disposal Area. Cadmium and thallium, neither of which
were detected in background samples, were detected at 14.8 milligrams per kilogram (mg/kg) and 0.4 mg/kg,
respectively. Concentrations of copper (12,300 mg/kg) and lead (53,800 mg/kg) at the Southeast Disposal Area
were extremely high relative to all other on-site surface soil samples. At the other locations,
concentrations of these contaminants ranged from non- detect to 554 mg/kg for copper and 6.3 to 119 mg/kg for
lead. Many of the subsurface soil samples contained inorganic analyte concentrations which exceeded surface
soil background levels. Except for one extremely high iron concentration (295,000 mg/kg), the concentration
ranges for most analytes were generally within the range of 2 to 10 times site background levels.
The Southeast Disposal Area samples generally contained concentrations olinorganics well above background
levels. It should be noted that the highest concentrations of aluminum, cadmium, chromium, copper, lead,
nickel, and zinc were found in the part of the Southeast Disposal Area called the Eastern Stained Soil Area.
The highest concentrations of the inorganics arsenic, barium, manganese, and silver, were detected
to the north of the landfill. The concentrations of these inorganics were within site and New York
State background levels in all on-site samples (with the exception of one on-site sample having a
slightly elevated concentration of arsenic). Soil samples collected from the north of the landfill
contained the highest detected concentrations of iron.
Surface Water, Sediment, and Leachate Investigations
The objectives of the surface water, sediment, and leachate investigations were to determine if site-
generated contaminants have migrated to adjacent wetlands or open areas downslope of the site, and
to determine site-specific background contaminant concentrations. A total of 23 sediment, 19 surface
water, and 5 leachate samples were collected and analyzed for Target Compound List and Target Analyte List
analytes.
Surface water samples (see Table 2) collected from South Pond, North Pond, the tributary to Trout
Creek, and Carrs Creek indicate the presence of low levels of acetone (11 •/I), DCE (4 • g/1), TCE
(2 *g/l), chloromethane (12 • g/1), BEHP (2 • g/1), and PCBs (Aroclor 1248 (0.84 • g/1)) .
Sediment samples (see Table 5) collected from South Pond contained PCBs and a variety of pesticides,
including aldrin, heptaclor epoxide, DDT, DDE, ODD, endosuffan, endrin, and chlordane. The maximum
concentrations were 1,100 • g/kg alpha-chlordane (pesticides) and 44,000 • g/kg PCBs. (It should be noted
that, based upon the documented release of PCBs and solvent-containing waste oils to South Pond from a waste
oil pit located on the Richardson Hill Road Landfill site, it is believed that the contamination in South
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Pond is attributable to the Richardson Hill Road Landfill site, rather than the Sidney Landfill site.)
The maximum PCB sediment concentration in North Pond was 80 • g/kg. Only one sample in North Pond contained
pesticides (4.4 • g/kg DDE) . Sediment samples collected from Carts Creek contained only VOCs and SVOCs, with
a maximum concentration of 420 • g/kg of benzo[a]pyrene. Sediment samples from a tributary to Trout Creek
contained several pesticides and PCBs, with lesser amounts of volatile and semi-volatile organics. The
number of compounds detected in the samples and the total concentrations generally decreased in a southerly
direction from South Pond. These samples were the only samples to contain PCBs in the sampling location
outside the boundaries of the landfill, as was the case for surface water samples. PCBs ranged in
concentration from 120 to 3,200 • g/kg for Aroclor 1248. The EPA sediment guality criteria for Aroclor 1248
is 0.5 • g/kg, the NYSDEC standard is 0.1 • g/kg. Pesticides present in these samples include DDE, ODD, DDT,
dieldrin, methoxychlor, aldrin, and endosulfan II, ranging in concentrations from 4.5 • g/ for ODD to 180
• g/kg for aldrin. The only VOC detected in off-site sediment samples was acetone at a concentration of
140/* g/kg. The only SVOC detected during the sample analyses of the off-site sediment samples was
di-n-octylphthalate at a concentration of 810 • g/kg.
A leachate seep located near the road southwest of the North Disposal Area contained VOCs, with a total
concentration of 91 • g/1 (see Table 3). A leachate seep located on the west edge of the North Disposal Area
contained VOCs, SVOCs, and PCBs. Total BETX compounds were present at 490 •g/1 and PCBs at 3.6 •g/l. Of
the remaining compounds, only 1,4-DCB (24 /• g/1) and 4-methylphenol (29 •g/1) were present at levels above
20 •g/l.
SUMMARY OF SITE RISKS
Based upon the results of the RI, a baseline risk assessment was conducted to estimate the risks
associated with current and future site conditions. The baseline risk assessment estimates the human
health and ecological risk which could result from the contamination at the site, if no remedial action
were taken.
Human Health Risk Assessment
A four-step process is utilized for assessing site-related human health risks for a reasonable maximum
exposure scenario: Hazard Identification—identifies the contaminants of concern at the site based on
several factors such as toxicity, freguency of occurrence, and concentration (see Appendix II-c). Exposure
Assessment—estimates the magnitude of actual and/or potential human exposures, the freguency and duration of
these exposures, and the pathways (e.g., ingesting contaminated well-water) by which humans are potentially
exposed. Toxicit), Assessment—determines the types of adverse health effects associated with chemical
exposures, and the relationship between magnitude of exposure (dose) and severity of adverse effects
(response). Risk Characterization—summarizes and combines outputs of the exposure and toxicity assessments
to provide a guantitative assessment of site-related risks.
The baseline risk assessment began with selecting contaminants of concern that would be representative of
site risks. The contaminants included 18 volatile organic compounds, 21 SVOCs, 9 pesticides, PCBs, 17
metals, and cyanide. Several of the contaminants, including vinyl chloride, benzene, and arsenic, are known
to cause cancer in laboratory animals and are suspected to be human carcinogens.
The baseline risk assessment evaluated the health effects which could result in various potentially exposed
populations from hypothetical current- and future-use exposure to the chemicals of potential concern in the
absence of remedial action. In the current-use scenario, exposure to the chemicals of potential concern in
spring water during potable use by resident adults and children; exposure to the
chemicals of potential concern in on-site surface soil, on-site leachate, surface soil from the Alleged
Liguid Disposal Area, and off-site surface soil by adolescent trespassers; and exposure to the chemicals of
potential concern in surface water and sediment from North Pond and the small ponds and wetlands in the
vicinity of the site by adolescent recreationalists were evaluated. In the future-use scenario, exposure to
the chemicals of potential concern in subsurface soils on site, at the Alleged Liguid Disposal Area, at the
Eastern Stained Area (part of the Southeast Disposal Area), and off-site by utility/maintenance workers was
evaluated.
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Current federal guidelines for acceptable exposures are an individual lifetime excess carcinogenic risk
in the range of 10-4 to 10-6 (e.g.,a one-in-ten-thousand to a one-in-a-million excess cancer risk) and a
maximum health Hazard Index (which reflects noncarcinogenic effects for a human receptor) egual to 1.0. (A
Hazard Index greater than 1.0 indicates a potential of noncarcinogenic health effects.)
In the current-use scenario, exposure of resident adults and children to spring water (Hazard Indices of 20
for adults and 40 for children and an estimated cancer risk of 3x10-4 for children) and exposure of
adolescent trespassers to on-site surface soil and on-site leachate (a Hazard Index of 7) result in risks in
excess of EPA's acceptable risk range. The primary contributors to the risk estimates are tricholorethene
and manganese in spring water and PCBs in on-site surface soil and on-site leachate.
In the future-use scenario, exposure of resident adults and children to groundwater (Hazard Indices of 90 for
adults and 200 for children and an estimated cancer risks of 4x10-3 for adults and 2X10-3 for children) and
exposure of utility/maintenance workers to sub-surface soil at the Eastern Stained Area (a Hazard Index of 4)
result in risks in excess of the EPA Superfund acceptable risk range. Theprimary contributors to the risk
estimates are manganese, arsenic, antimony, barium, beryllium, vinyl chloride, and PCBs in groundwater and
PCBs in the Eastern Stained Area.
Ecological Risk Assessment
A four-step process is utilized for assessing site-related ecological risks for a reasonable maximum exposure
scenario: Problem Formulation--a gualitative evaluation of contaminant release, migration, and fate;
identification of contaminants of concern, receptors, exposure pathways, and known ecological effects of the
contaminants; and selection of endpoints for further study. Exposure Assessment—a quantitative evaluation
of contaminant release, migration, and fate; characterization of exposure pathways and receptors; and
measurement or estimation of exposure point concentrations. Ecological Effects Assessment—literature
reviews, field studies, and toxicity tests, linking contaminant concentrations to effects on ecological
receptors. Risk Characterization—measurement or estimation of both current and future adverse effects.
Habitats which presently exist in the vicinity of the Sidney Landfill include palustrine emergent marsh
wetlands, open water, shrubland and forested upland. Surface soils on the site may provide a source of
exposure to wildlife through direct contact, ingestion, and ingestion of vegetation growing in contaminated
soil. Surface runoff may transport contaminated soil particles into the various streams and wetland areas,
potentially contaminating surface water and sediments in these areas.
If contaminants are discharged into the wetland areas, fish and wildlife ingesting aquatic vegetation can be
exposed to contaminants which have become bioaccumulated into plant tissues. Also, direct contact with water
and sediments can occur during feeding and nesting activities of waterfowl and on a constant basis for fish
and other aquatic organisms inhabiting open water areas of the wetlands. Terrestrial wildlife may also be
exposed to contaminants via ingestion of water, aquatic vegetation, and organisms such as fish.
The risk assessment evaluated the potential risks of exposure to the contaminants of concern to several
indicator species. Largemouth bass was the only species of fish caught from North Pond and the control
location. Therefore, this species is used as an indicator of conditions in the ponder areas in the vicinity
of the site. For assessment of risks from exposure to surface soils, the cottontail rabbit, a common mammal
known to occur on the site, was used as an indicator. Mink and osprey were chosen as indicators for analysis
of risk through exposure to contaminants in fish tissue, since these species may inhabit the vicinity of the
landfill, and are known to consume fish as the bulk of their diet. A summary of the Environmental Assessment
of the Site is presented in Table 5.
The ratio of the estimate of chronic daily intake to the health-protective criterion (CDI/RfD) is called a
Hazard Quotient (HQ). The HQ assumes that there is a level of exposure (i.e., the RfD) below which it is
unlikely for even sensitive subpopulations to experience adverse health effects. If the HQ exceeds 1.0,
there may be concern for potential non-cancer effects. The greater the hazard quotient above 1.0, the
greater the level of concern.
Surface Water and Leachate Seeps
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In calculating the HQs for the 17 chemicals of concern, the lowest available criterion (either EPA or NYSDEC
Ambient Water Quality Criteria) was used to provide a conservative view of potential health risks. Based on
the HQs, it appears that aluminum, bis[2-ethylhexyl]phthalate, cadmium, chlorobenzene, 4-chloro-
3-methylphenol, cobalt, copper, 1,4-dichlorobenzene, 1,1-dichloroethane, iron, lead, manganese, PCBs, silver,
and 1,1,1-trichloroethane present a risk to aguatic biota in the site vicinity. Due to iron and manganese
exceeding site background and applicable criteria or toxicity data, they were included in this analysis. It
should be noted that elevated background concentrations of iron present a potential risk to aguatic biota
based on a calculated HQ of 9.5 (average detected concentration in background samples was 2,853 • g/1) .
Sediment
Based on the HQs calculated for the 15 chemicals of concern, it appears that aldrin, arsenic, cadmium,
chlordane, copper, DDT, DDE, ODD, endosulfan, endrin aidehyde, heptachlor epoxide, iron, manganese, nickel,
PCBs, and zinc present a potential risk to benthic organisms inhabiting the areas sampled. PCBs, DDT, DDE,
and ODD were detected in both North and South Ponds, but concentrations were significantly higher in South
Pond. Based on the average PCB concentrations for each of these areas (0.074 mg/kg for North Pond and 8.1
mg/kg for South Pond), there appears to be no potential ecological risk to benthic organisms in North Pond
(HQ = 0.96) and a potential risk in the South Pond (HQ = 105). Based on the average DDT, DDE, and ODD
concentrations (0.0044 mg/kg for North Pond and 0.136 mg/kg for the South Pond), there appears to be no
potential risk to benthic organisms in North Pond (HQ = 0.08) and a potential risk in the South Pond (HQ =
2.5) .
Surface Soil
Aluminum, arsenic, barium, copper, lead, manganese, nickel, and PCBs present a potential risk to wildlife
ingesting surface soil. The presence of DDT, ODD, and DDE in surface soil poses no potential risk to
wildlife in the site vicinity. Cadmium, chromium, copper, manganese, nickel, PCBs, silver, and zinc present
a possible risk.
Fish Tissue
In determining the effects of contaminants present in fish in the vicinity of the Sidney Landfill,
concentrations in fish tissue which are considered to be protective of fish-consuming wildlife were developed
for the chemicals of potential concern. The indicator species which were chosen for this assessment are
mink and osprey, with mink representing a fish-consuming mammal and osprey representing a bird species whose
diet consists entirely of fish.
Based on the HQs for these compounds, the presence of DDT, endrin, and nickel in fish tissue presents no
potential risk to wildlife consumers of fish from North Pond. For manganese, the concentration in fish
tissue from North Pond was only slightly higher than the acceptable level for mink (15.6 mg/kg in North Pond
fish versus acceptable concentration of 12.0 mg/kg). The background fish tissue concentration of manganese
was 4.6 mg/kg, within the same order of magnitude as North Pond fish tissue concentrations. This indicates
that the actual risk is likely to be lower than suggested by the HQ, especially since manganese is considered
to be a vital nutrient for both plants and animals.
Due to the site's location in a rural area and the presence of both upland and wetland habitats, the
potential for utilization by wildlife is high. The presence of pesticides, PCBs, and inorganic compounds in
environmental media, at concentrations which present a potential risk based on Hgs, are likely to have some
adverse effect on wildlife utilizing the site vicinity, even if those effects are not apparent on an
ecosystem level. If the site is unremediated, contaminants may continue to be released (e.g., via leachate,
surface runoff, groundwater discharge) into the environment. Effects of contaminants could be more
pronounced over time as a result of increasing concentrations in the media of concern and bio- accumulation
through the food chain. Remediation of the site would limit future contaminant releases, and may allow the
affected media to recover over time through such natural processes as dilution and sedimentation and, for
some organics, biodegradation.
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In summary, actual or threatened releases of hazardous substances from this site, if not addressed by the
preferred remedy or one of the other active measures considered, may present a current or potential threat to
public health, welfare and the environment.
REMEDIAL ACTION OBJECTIVES
Remedial action objectives are specific goals to protect human health and the environment. These
objectives are based on available information and standards such as applicable or relevant and appropriate
requirements and risk-based levels established in the risk assessment.
The following remedial action objectives have been established for the site:
• minimize infiltration and the resulting contaminant leaching to groundwater;
• control surface water runoff and erosion;
• mitigate the off-site migration of contaminated groundwater;
• restore groundwater quality to levels which do not exceed state or federal drinking-water standards;
• control generation and prevent migration of subsurface landfill gas; and
• prevent contact with contaminants in the groundwater.
DESCRIPTION OF REMEDIAL ACTION ALTERNATIVES
CERCIA §121(b)(1), 42 U.S.C. §9621(b)(1), mandates that a remedial action must be protective of human health
and the environment, cost-effective, and utilize permanent solutions and alternative treatment technologies
or resource recovery technologies to the maximum extent practicable. Section 121(b)(1) also establishes a
preference for remedial actions which employ, as a principal element, treatment to permanently and
significantly reduce the volume, toxicity, or mobility of the hazardous substances, pollutants and
contaminants at a site. CERCLA §121(d), 42 U.S.C. §9621(d), further specifies that a remedial action must
attain a level or standard of control of the hazardous substances, pollutants, and contaminants, which at
least attains ARARs under federal and state laws, unless a waiver can be justified pursuant to CERCLA §121
(d) (4) , 42 U.S.C. §9621 (d) (4) .
This ROD evaluates in detail, five remedial alternatives for addressing the contamination associated
with the Sidney Landfill site. Various processes are considered and are assembled into remedial
alternatives which can accomplish the remedial action objectives. Cost and construction time, among
other criteria, were evaluated for each remedial alternative. The time to implement a remedial
alternative reflects only the time required to construct or implement the remedy and does not include
the time required to design the remedy, negotiate with the responsible parties, procure contracts for
design and construction, or conduct operation and maintenance activities at the site.
The remedial alternatives are:
Alternative 1 - No Further Action
Capital Cost: $155,016
Annual Operation and Maintenance Cost: $134,400
Present Worth Cost: $2,190,000
Construction Time: 3 months
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The Superfund program requires that the "no-action" alternative be considered as a baseline for comparison
with the other alternatives. The no-action remedial alternative does not include any physical remedial
measures that address the problem of contamination at the site. However, this response action does include
the installation of a chain-link fence and gates, recommends the implementation of institutional controls
(the placement of restrictions on the installation and use of groundwater wells at the site and limitations
on the future use of the site), and implements a long-term groundwater monitoring program. Water quality
samples would be collected on a semi-annual basis from upgradient, on-site, and down gradient groundwater
monitoring welts.
The no-action response also includes the development and implementation of a public awareness and education
program for the residents in the area surrounding the site. This program would include the preparation and
distribution of informational press releases and circulars and convening public meetings. These activities
would serve to enhance the public's knowledge of the conditions existing at the site. This alternative would
also require the involvement of local government, various health departments, and environmental agencies.
Because this alternative would result in contaminants remaining on-site above health-based levels, CERCLA
requires that the site be reviewed every five years. If justified by the review, remedial actions may be
implemented to remove or treat the wastes.
Alternative 2A: Installation of Four Landfill Caps and "Hot-Spot" Groundwater Remediation in the Vicinity of
Monitoring Well MW-2S
Capital Cost: $4,624,041
Annual Operation and Maintenance Cost: $370,728
Present Worth Cost: $10,260,000
Construction Time: 10 - 12 months
The main features of this alternative include excavating and relocating the waste from the Can and Bottle
Dump Area to the adjacent North Disposal Area, constructing four independent closure caps, which are
consistent with the requirements of New York State 6 NYCRR Part 360, over the White Goods Disposal and
Alleged Liquid Disposal Areas (capped together), the North Disposal Area, the Southeast Disposal Area, and
the Southwest Disposal Area, and the construction of four individual chain- link fences. In addition, this
alternative would include the extraction of the contaminated groundwater (high concentrations of BETX and
VOCs) from the bedrock aquifer in the vicinity of monitoring well MW-2S to remove a continuing source of
contaminants to the groundwater, and air-stripping (or other appropriate treatment) of the extracted
groundwater, followed by discharge to surface water.
Prior to the construction of the caps, the landfill disposal areas would have to be regraded and compacted to
provide a stable foundation for the placement of the various layers of the cap and to promote runoff Landfill
gases would be vented to the atmosphere or controlled as needed.
This alternative would also include long-term monitoring of groundwater, surface water, and sediments, taking
steps to secure institutional controls (the placement of restrictions on the installation and use of
groundwater wells at the site and restrictions on the future use of the site in order to protect the
integrity of the caps), and implement a public awareness program to ensure that the nearby residents are
familiar with all aspects of this response action.
Because this alternative would result in contaminants remaining on-site above health-based levels, CERCLA
requires that the site be reviewed every five years. If justified by the review, further remedial actions
may be implemented to remove or treat the wastes.
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Alternative 2B: Installation of Four Resource Conservation and Recovery Act (RCRA)
Landfill Caps and "Hot-Spot" Groundwater Remediation in the Vicinity of Monitoring Well
MW-2S
Capital Cost: $6,103,191
Annual Operation and Maintenance Cost: $370,728
Present Worth Cost: $11,720,000
Construction Time: 12-14 months
This alternative is the same as Alternative 2A, with the only difference being the construction of RCRA
landfill caps in place of of caps which are consistent with the reguirements of New York State 6 NYCRR Part
360. The RCRA cap system differs from the 6 NYCRR Part 360 cap by reguiring a 24-inch thick soil barrier
layer and a 40-mil geomembrane, a 12-inch thick drainage layer and a 24-inch thick topsoil layer. A RCRA cap
is marginally more effective in reducing infiltration compared to a 6 NYCRR Part 360 cap. Prior to the
construction of the caps, the disposal areas would have to be regraded and compacted to provide a stable
foundation for the placement of the various layers of the caps and to promote runoff Landfill gases would be
vented to the atmosphere. Because this alternative would result in contaminants remaining on-site above
health-based levels, CERCLA reguires that the site be reviewed every five years. If justified by the review,
remedial actions may be implemented to remove or treat the wastes.
Alternative 3A: Installation of Four Landfill Caps, "Hot-Spot" Groundwater Remediation in the Vicinity of
Monitoring Well MW-2S, and Groundwater Extraction and Treatment
Capital Cost: $8,288,883
Annual Operation and Maintenance Cost: $419,016
Present Worth Cost: $14,630,000
Construction Time: 12-16 months
This alternative is identical to Alternative 2A, except that it also includes extraction of the
contaminated groundwater on a site-wide basis from the bedrock aguifer. This would be accomplished by the
installation of vertical extraction wells in blasted trenches or using hydro-fracing. In a blasted trench, a
linear fracture zone is created by controlled subsurface blasting with explosives in closely spaced
boreholes. The principal of this technology is to interconnect existing fractures and create new fractures
to substantially increase the hydraulic conductivity within the area of blasting (fracture zone). The
increased hydraulic conductivity in the fracture zone increases the area of influence created by pumping of
the fracture zone. This results in the formation of a hydraulic line sink (similar to a trench). In
hydro-fracing, water and other fluid mixtures are injected under sufficient pressure to open existing
fractures and induce new fractures along areas of bedrock weakness to increase the specific yield of the
well. Hydro-fracing will not shatter the bedrock, since significantly higher pressures than those attainable
during hydro-fracing are reguired. The hydro-fracing pressures are sufficient to part the rock matrix at
bedding planes, existing fractures or other weak points in the bedrock. The extracted groundwater would be
treated by air-stripping (or other appropriate treatment) and discharged to a nearby surface water.
Because this alternative would result in contaminants remaining on-site above health-based levels, CERCLA
reguires that the site be reviewed every five years. If justified by the review, further remedial actions
may be implemented to remove or treat the wastes.
Alternative 3B: Installation of Four RCRA Landfill Caps, "Hot-Spot" Groundwater Remediation in the Vicinity
of Monitoring Well MW-2S, and Groundwater Extraction and Treatment
Capital Cost: $9,355,833
Annual Operation and Maintenance Cost: $419,016
Present Worth Cost: $15,700,000
Construction Time: 12-16 months
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This alternative is identical to Alternative 2B, except that it would also include the extraction of
contaminated groundwater from the bedrock aquifer using vertical extraction wells followed by air- stripping
(or other appropriate treatment) and discharge to surface water. This would be accomplished by the
installation of vertical extraction wells in blasted trenches or using hydro-fracing.
Because this alternative would result in contaminants remaining on-site above health-based levels, CERCLA
requires that the site be reviewed every five years. If justified by the review, further remedial actions
may be implemented to remove or treat the wastes.
Alternatives involving the excavation and consolidation of the Southwest Disposal Area, the Alleged Liquid
Waste Disposal Area, the White Goods Disposal Area, and the Can and Bottle Dump Area into the North Disposal
Area and the Southeast Disposal Area, followed by the fencing of these two areas, were considered. These
alternatives were not, however, presented in the Proposed Plan, since the consolidation of the waste disposal
areas into two areas would cost approximately $1 million more than constructing four independent closure caps
and chain-link fences as presented in Alternatives 2A, 2B, 3A, and 3B, yet would not provide a significant
savings in operation and maintenance costs.
SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
In selecting a remedy, EPA considered the factors set out in CERCLA §121, 42 U.S.C. §9621, by conducting a
detailed analysis of the viable remedial alternatives pursuant to the NCP, 40 CFR §300.430(e)(9) and OSWER
Directive 9355.3-01. The detailed analysis consisted of an assessment of the individual alternatives against
each of nine evaluation criteria and a comparative analysis focusing upon the relative performance of each
alternative against those criteria.
The following "threshold" criteria are the most important and must be satisfied by any alternative in order
to be eligible for selection:
1. Overall protection of human health and the environmental addresses whether or not a remedy provides
adequate protection and describes how risks posed through each exposure pathway (based on a reasonable
maximum exposure scenario) are eliminated, reduced, or controlled through treatment, engineering
controls, or institutional controls.
2. Compliance with ARARs addresses whether or not a remedy would meet all of the applicable (legally
enforceable), or relevant and appropriate (pertaining to situations sufficiently similar to those
encountered at a Superfund site such that their use is well suited to the site) requirements of
federal and state environmental statutes and requirements or provide grounds for invoking a waiver.
The following "primary balancing" criteria are used to make comparisons and to identify the major
trade-offs between alternatives:
3. Long-term effectiveness and permanence refers to the ability of a remedy to maintain reliable
protection of human health and the environment over time, once cleanup goals have been met. It also
addresses the magnitude and effectiveness of the measures that may be required to manage the risk
posed by treatment residuals and/or untreated wastes.
4. Reduction of toxicity, mobility, or volume via treatment refers to a remedial technology's expected
ability to reduce the toxicity, mobility, or volume of hazardous substances, pollutants or
contaminants at the site.
5. Short-term effectiveness addresses the period of time needed to achieve protection and any adverse
impacts on human health and the environment that may be posed during the construction and
implementation periods until cleanup goals are achieved.
6. Implementability refers to the technical and administrative feasibility of a remedy, including the
availability of materials and services needed.
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7. Cost includes estimated capital and operation and maintenance costs, and the present-worth costs.
The following "modifying" criteria are considered fully after the formal public comment period on the
Proposed Plan is complete:
8. State acceptance indicates whether, based on its review of the RI/FS reports and the Proposed Plan,
the State supports, opposes, and/or has identified any reservations with the selected alternative.
9. Community acceptance refers to the public's general response to the alternatives described in the
Proposed Plan and the RI/FS reports. Factors of community acceptance to be discussed include support,
reservation, and opposition by the community.
A comparative analysis of the remedial alternatives based upon the evaluation criteria noted above follows.
• Overall Protection of Human Health and the Environment
Alternative 1, which would include installing fences around the waste disposal areas, would prevent
or reduce the likelihood of trespassers from entering the waste disposal areas. Institutional controls
would limit the intrusiveness of future activity that could occur on the site. This alternative would
not, however, prevent or reduce exposure to leachate seeps which are not all in the waste disposal
areas and do not fall within the fence line.
Alternatives 2A, 2B, 3A, and 3B would be significantly more protective than Alternative 1, in that the risk
of incidental contact with waste by humans and other ecological receptors would be reduced by the caps.
Collecting and treating the contaminated groundwater from the vicinity of monitoring well MW-2S under
Alternatives 2A, 2B, 3A, and 3B would reduce the possibility of additional groundwater contamination
originating from this area. Also, Alternatives 2A, 2B, 3A, and 3B would provide for overall protection of
human health and the environment in that the capping of the landfilled materials would reduce infiltration,
thereby reducing the migration of contaminants of concern from the landfill to the groundwater. However, it
is estimated that, while Alternatives 2A and 3A (caps consistent with the requirements of New York State 6
NYCRR Part 360) would provide a substantial reduction in leachate production, Alternatives 2B and 3B (RCRA
impermeable caps) would provide a slightly greater reduction in leachate production. Alternatives 2B and 3B
would, therefore, be marginally more protective than Alternatives 2A and 3A, respectively.
Alternatives 3A and 3B are identical to Alternatives 2A and 2B, respectively, except that they also include
bedrock groundwater extraction which would control off-site migration of contaminants. The effluent from the
treatment system would meet surface water discharge requirements. In terms of addressing the bedrock
groundwater contamination in the vicinity of monitoring well MW-2S, Alternatives 2A, 2B, 3A, and 3B, would be
equally protective. However, since Alternatives 3A and 3B would extract contaminated groundwater from the
bedrock aquifer at other locations in addition to the vicinity of monitoring well MW-2S, they would provide
marginally more protection to human health and the environment than Alternatives 2A and 2B, which would
primarily rely on natural attenuation to address the contamination in the bedrock aquifer at these other
locations.
• Compliance with ARARs
A cap consistent with the requirements of 6 NYCRR Part 360 is an action-specific ARAR for landfill closure.
Therefore, Alternatives 2A, 2B, 3A, and 3B each would satisfy this action-specific ARARs. Alternative 1 would
not meet this ARAR, since it does not include any provisions for landfill caps.
Alternative 1 does not provide for any direct remediation of groundwater and would, therefore, never meet the
chemical-specific ARARs. Alternatives 3A and 3B would be the most effective in reducing groundwater
contaminant concentrations below the maximum contaminant levels (MCLs) (chemical- specific ARARs) because the
lower precipitation infiltration rate associated with placing impermeable caps over the landfilled areas
would significantly reduce the generation of additional groundwater contamination, and because these
alternatives include the collection and treatment of contaminated groundwater in the vicinity of monitoring
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well MW-2S and elsewhere from the bedrock aquifer. Alternatives 2A and 2B would provide for the remediation
of groundwater only in the vicinity of monitoring well MW-2S. However, the extraction of the contaminated
groundwater at this location, combined with the capping of the waste disposal areas, should significantly
reduce or possibly eliminate the source of on-going bedrock groundwater contamination, particularly in that
the hydrogeological investigation performed at the site indicates that the groundwater elevation in all of
the waste disposal areas is below the wastes. Given the expected reduction or elimination of the source of
the bedrock groundwater contamination, and that the levels of contamination in the bedrock aquifer (other
than in the vicinity of monitoring well MW-2S) are less than 200 • g/L for any contaminant, it is anticipated
that collecting and treating contaminated groundwater from the vicinity of monitoring well MW-2S, in
conjunction with natural attenuation of the other contamination already present in the bedrock aquifer, will
reduce bedrock aquifer contaminant levels toward a goal of MCLs.
• Long-Term Effectiveness and Permanence
Alternatives 2A, 2B, 3A, and 3B would be equally effective over the long-term. Both the RCRA caps and the 6
NYCRR Part 360 caps (or caps consistent with those requirements) would substantially reduce the residual risk
ofuntreated waste on the site by essentially isolating it from contact with human and environmental receptors
and the mobility caused by infiltrating rainwater. The adequacy and reliability of these caps to provide
long-term protection from waste remaining at the site should be excellent.
Both the RCRA caps and the 6 NYCRR Part 360 caps (or caps consistent with those requirements) would require
routine inspection and maintenance to ensure long-term effectiveness and permanence. Routine maintenance of
the caps, as a reliable management control, would include mowing, fertilizing, reseeding and repairing any
potential erosion or burrowing rodent damage.
While a large volume of contaminated groundwater would be treated during remediation, Alternatives 3A and 3B
may not be completely effective in removing all the contamination, because some of the contamination may
remain in the fractured bedrock at the completion of remediation. The long-term effectiveness would also be
affected by any on-going migration of contaminants from the source areas. While groundwater extraction and
treatment in the vicinity of monitoring well MW-2S is expected to reduce the level of contamination in the
bedrock aquifer in this area, not all of the groundwater contamination will be removed.
• Reduction in Toxicity, Mobility, or Volume via Treatment
Alternative 1 would not actively reduce the toxicity, mobility, or volume of contaminants through treatment.
This alternative would rely on natural attenuation to reduce the levels of contaminants.
The caps that would be installed under Alternatives 2A, 2B, 3A, and 3B would nearly eliminate the
infiltration of rainwater into the waste disposal areas and the associated leaching of contaminants from
these areas. The results of soil borings su*gest that all of the waste disposal areas are located above the
groundwater table. Therefore, the reduction in mobility (without treatment) of contaminants by the caps
would be significant. Collecting and treating contaminated groundwater from the vicinity of monitoring well
MW-2S under Alternatives 2A, 2B, 3A, and 3B would reduce the toxicity, mobility, and volume of contaminants,
and it would also reduce the possibility of additional groundwater contamination originating from this area.
Alternatives 2A and 2B would also rely on natural attenuation to reduce the levels of contamination in areas
not in the vicinity of monitoring well MW-2S. Alternatives 3A and 3B would provide for additional
groundwater extraction and treatment and would further reduce the toxicity, mobility, and volume of
contaminants.
• Short-Term Effectiveness
Alternative 1 does not include any physical construction measures in any areas of contamination and,
therefore, does not present a risk to the community as a result of its implementation. Alternatives 2A,
2B, 3A, and 3B involve excavating, moving, placing, and regrading of waste prior to cap construction, and the
installation of extraction wells. All of the action alternatives present some risk to on-site workers
through derreal contact and inhalation from cap construction and groundwater sampling activities, which can
be minimized by utilizing proper protective equipment. The vehicle traffic associated with landfill cap
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construction could impact the local roadway system and nearby residents through increased noise level.
Disturbance of the land during construction could affect the surface water hydrology of the site. There is a
potential for increased stormwater runoff and erosion during construction that would be properly managed to
prevent excessive water and sediment loading.
• Implementability
Fencing the site and performing routine groundwater monitoring are actions that can be readily implemented.
These actions are technically and administratively feasible and reguire readily available
materials and services. Constructing caps over the waste disposal areas on the site (Alternatives 2A, 2B,
3A, and 3B), although more difficult to implement than the no-action alternative, can be accomplished using
technologies proven to be reliable and readily implementable. Eguipment, Services and materials for this
work are readily available. Each of the capping alternatives would also involve remediation of the
groundwater in the vicinity of the monitoring well MW-2S groundwater hot spot.
Air stripping is a process through which volatile contaminants are transferred from the agueous phase to an
air stream. Air stripping has been effectively used to remove over 99 percent of volatile organic compounds
from groundwater at numerous hazardous waste and spill sites.
The use of blasted trenches (Alternatives 3A and 3B) are technically feasible. Additionally, the use of an
experienced blasting firm would be reguired during the design and the implementation of the trenches.
Hydro-fracing (Alternatives 3A and 3B) is one method of opening existing fractures and increasing hydraulic
conductivity. The eguipment used for hydro-fracing is readily available throughout the drilling industry.
All of the components for the treatment system are readily available.
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Cost
The present-worth costs are calculated using a discount rate of 5 percent and a 30-year time interval. The
estimated capital, annual operation and maintenance (O&M), and present-worth costs for each of the
alternatives are presented below.
Alternative Capital Costs O&M Costs Present Worth
1 $155,106 $134,400 $2,190,000
2A $4,624,041 $370,728 $10,260,000
2B $6,103,191 $370,728 $11,720,000
3A $9,302,747 $411,726 $15,540,000
3B $10,369,697 $411,726 $16,610,000
As indicated from the cost estimates, there is a significant cost increase between Alternative 1 and the
other alternatives. There is also an approximately $1 million cost increase between Alternatives 2A and 2B
due to the incremental cost of the installation of RCRA landfill caps versus the caps consistent with the
reguirements of 6 NYCRR Part 360. The capital cost associated with collecting and treating contaminated
groundwater in the vicinity of monitoring MW-2S would be approximately $600,000; the annual O&M cost would be
approximately $180,000. The capital cost associated with collecting and treating contaminated groundwater
from the bedrock aguifer would be approximately $3 million; the annual O&M cost would be approximately
$40,000.
Furthermore, there is an approximately $5 million cost increase between Alternatives 2A and 3A and
Alternatives 2B and 3B. This cost increase is due to the addition of the bedrock groundwater extraction
system. The annual costs are for O&M and are similar, except for Alternative 1.
State Acceptance
NYSDEC concurs with the selected alternative. NYSDEC also concurs with the contingent remedy, should the
implementation of the bedrock groundwater extraction and treatment component of Alternative 3A be determined
to be necessary.
Community Acceptance
Comments received during the public comment period indicate that the public generally supports the selected
remedy. Comments received during the public comment period are summarized and addressed in the
Responsiveness Summary, which is attached as Appendix V to this document.
SEIiECTED REMEDY
Based upon consideration of the reguirements of CERCLA, the detailed analysis of the alternatives, and public
comments, EPA and NYSDEC have determined that Alternative 2A is the appropriate remedy, because it best
satisfies the reguirements of CERCLA §121, 42 U.S.C. §9621, and the NCP's nine evaluation criteria for
remedial alternatives, 40 CFR §300.430 (e) (9) . Alternative 3A is selected as a contingent remedy for the
site.
The selected remedy includes excavating and relocating the waste from the Can and Bottle Dump Area to the
adjacent North Disposal Area, installing landfill caps consistent with the reguirements of 6 NYCRR Part 360
in four areas, extracting the contaminated groundwater from the bedrock aguifer in the vicinity of monitoring
well MW-2S, air-stripping (or other appropriate treatment), and discharge to surface water, long-term
monitoring of groundwater, surface water, and sediments, and taking steps to secure institutional controls
(the placement of restrictions on the installation and use of groundwater wells at the site and restrictions
on the future use of the site in order to protect the integrity of the caps). In addition, the bedrock
groundwater extraction and treatment component of Alternative 3A has been selected as a contingent remedy.
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EPA intends to continue to address the two private water supplies with high levels of chemical contamination
as part of the remedial activities associated with the Richardson Hill Road Landfill site. The treatment
systems installed on these water supplies are currently being maintained by the potentially responsible
parties for the Richardson Hill Landfill site.
Under the selected remedy, the source of the bedrock groundwater contamination is expected to be
significantly reduced or possibly eliminated due to the reduction of infiltrating precipitation by the
capping of the waste disposal areas and the extraction of the contaminated groundwater from the bedrock
aguifer in the vicinity of monitoring well MW-2S. Because of this and the fact that the levels of
contamination in the bedrock aguifer are less than 200 • g/1 for any contaminant (other than in the vicinity
of monitoring well MW-2S), EPA anticipates that collecting and treating contaminated groundwater from the
vicinity of monitoring well MW-2S, in conjunction with natural attenuation of the other contamination present
in the bedrock aguifer, will result in the compliance with groundwater ARARs in a reasonable time frame and
at a significantly lower cost than Alternative 3A, After the construction of the four caps, and the
extraction and treatment of the contaminated groundwater in the vicinity of monitoring well MW-2S for five
years, the results of semi-annual bedrock groundwater monitoring will be evaluated using trend analysis and
possibly modeling of the bedrock aguifer to determine whether it appears that the groundwater guality in the
bedrock aguifer would be restored to acceptable levels through natural attenuation cost-effectively and
within a reasonable time frame. Should the trend analysis and/or modeling show that groundwater guality in
the bedrock aguifer would likely not be restored within a reasonable time frame by natural attenuation alone,
then the groundwater remediation component of Alternative 3A may be implemented.
The selected remedy and the contingent remedy are believed to be able to achieve the ARARs more guickly, or
as guickly, and at less cost than the other alternatives. Therefore, the selected remedy and the contingent
remedy will provide the best balance of trade-offs among alternatives with respect to the evaluating
criteria. EPA and the NYSDEC believe that the selected remedy and the contingent remedy will be protective
of human health and the environment, comply with ARARs, be cost-effective, and utilize permanent solutions
and alternative treatment technologies or resource recovery technologies to the maximum extent practicable.
The selected remedy and the contingent remedy also will meet the statutory preference for the use of
treatment as a principal element (for the groundwater), and are generally consistent with landfill closure
reguirements applied to municipal landfills in the State of New York. However, since the landfill's
contaminant source areas cannot be effectively excavated and treated due to their size and the absence of
identified hot spots representing major sources of contamination (other than the groundwater hot-spot in the
vicinity of monitoring well MW-2S), none of the alternatives considered satisfied the statutory preference
for treatment as a principal element of the remedy with respect to the sources of contamination.
STATUTORY DETERMINATIONS
As was previously noted, CERCLA §121 (b) (1), 42 U.S.C. §9621(b) (1), mandates that a remedial action must be
protective of human health and the environment, cost-effective, and utilize permanent solutions and
alternative treatment technologies or resource recovery technologies to the maximum extent practicable.
Section 121 (b)(1) also establishes a preference for remedial actions which employ treatment to permanently
and significantly reduce the volume, toxicity, or mobility of the hazardous substances, pollutants, or
contaminants at a site. CERCLA §121(d), 42 U.S.C. §9621(d), further specifies that a remedial action must
attain a degree of cleanup that satisfies ARARs under federal and state laws, unless a waiver can be
justified pursuant to CERCLA §121(d)(4), 42 U.S.C. §9621(d)(4).
For the reasons discussed below, EPA has determined that the selected remedy meets the reguirements of CERCLA
§121, 42 U.S.C. §9621.
Protection of Human Health and the Environment
The selected remedy would be significantly more protective than no-action, in that the risk of incidental
contact with waste by humans and other ecological receptors would be reduced by the caps. Collecting and
treating the contaminated groundwater from the vicinity of monitoring well MW-2S would reduce the possibility
of additional groundwater contamination originating from this area. Also, the selected remedy would provide
for overall protection of human health and the environment in that the capping of the landfilled materials
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would reduce infiltration, thereby reducing the migration of contaminants of concern from the landfill to the
groundwater. Alternative 3A, the contingent remedy, is identical to the selected remedy, except that it also
includes bedrock groundwater extraction and treatment which would control off-site migration of contaminants.
The effluent from the treatment system would meet surface water discharge requirements.
Compliance with ARARs
The selected remedy would be effective in reducing groundwater contaminant concentrations below MCLs
(chemical-specific ARARs) because the lower precipitation infiltration rate associated with placing low-
permeability caps over the landfilled areas would significantly reduce the generation of additional
groundwater contamination. Additionally, the selected remedy would provide for the remediation of ground-
water in the vicinity of monitoring well MW-2S. However, the extraction of the contaminated groundwater at
this location, combined with the capping of the waste disposal areas, should significantly reduce the source
of the bedrock groundwater contamination, particularly in that the hydrogeological investigation performed at
the site indicates that the groundwater elevation in all of the waste disposal areas is below the wastes.
Given the expected reduction of the source of the bedrock groundwater contamination, and that the levels of
contamination in the bedrock aguifer (other than in the vicinity of monitoring well MW-2S) are less than 200
• g/1 for any contaminant, it is anticipated that collecting and treating contaminated groundwater from the
vicinity of monitoring well MW-2S, in conjunction with natural attenuation of the other contamination already
present in the bedrock aguifer, will reduce bedrock aguifer contamination toward a goal of MCLs A summary of
action-specific, chemical-specific and location-specific ARARs which will be complied with during
implementation is presented below. A listing of the of the individual chemical-specific ARARs is presented
in Table 6.
Action-specific ARARs:
• National Emissions Standards for Hazardous Air Pollutants
6 NYCRR Part 257, Air Quality Standards
6 NYCRR Part 212, Air Emission Standards
6 NYCRR Part 373, Fugitive Dusts
40 CFR 50, Air Quality Standards
• State Permit Discharge Elimination System
• Resource Conservation and Recovery Act
Chemical-specific ARARs:
• Safe Drinking Water Act Maximum Contaminant Levels and Maximum Contaminant Level Goals(MCLs and MCLGs,
respectively, 40 CFR Part 141)
6 NYCRR Parts 700-705 Groundwater and Surface Water Quality Regulations
10 NYCRR Part 5 State Sanitary Code
Location-specific ARARs:
Clean Water Act Section 404, 33 U.S.C. 1344
Fish and Wildlife Coordination Act, 16 U.S.C. 661
National Historic Preservation Act, 16 U.S.C. 470
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New York State Freshwater Wetlands Law ECL, Article 24, 71 in Title 23
• New York State Freshwater Wetlands Permit Requirements and Classification, 6 NYCRR 663 and 664
• New York State Endangered and Threatened Species of Fish and Wildlife Requirements, 6 NYCRR 182
Other Criteria, Advisories, or Guidance To Be Considered:
Executive Order 11990 (Protection of Wetlands)
• Executive Order 11988 (Floodplain Management)
• EPA Statement of Policy on Floodplains and Wetlands Assessments for CERCLA Actions
• New York Guidelines for Soil Erosion and Sediment Control
New York State Sediment Criteria, December 1989
• New York State Air Cleanup Criteria, January 1990
SDWA Proposed MCLs and MCL Goals
NYSDEC Technical and Operational Guidance Series 1.1.1, November 1991
EPA Ambient Water Quality Criteria (Federal Register, Volume 57, No. 246, December 22, 1992)
• Technical Guidance for Screening Contaminated Sediments (November 1993, NYSDEC, Division of Fish and
Wildlife, Division of Marine Resources).
Cost-Effectiveness
The selected remedy and the contingent remedy provide effectiveness proportional to their cost. The total
capital and present-worth costs for the selected remedy are estimated to be $4,624,041 and $10,260,000,
respectively. For the contingent remedy, which includes remediation of the bedrock aquifer, the total
capital and present-worth costs are $9,302,747 and $15,540,000, respectively.
Utilization of Permanent Solutions and Alternative Treatment Technologies to the Maximum Extent Practicable
Given the size of the landfill and the absence of isolated hot spots, containment of the waste mass is the
only practical means to remediate the site. By constructing four caps over the discrete landfills which are
consistent with New York State's 6 NYCRR Part 360 for landfill closure, hazardous wastes will be isolated
from the environment and their mobility will be minimized. The closure cap is a permanent technology that
must be maintained at regular intervals to ensure its structural integrity and impermeability. Extracting
contaminated groundwater from the bedrock aquifer in the vicinity of monitoring well MW-2S is a means of
addressing the groundwater hot spot at this location. If determined to be necessary, groundwater will be
collected via bedrock extraction wells, and will be treated using a treatment system located permanently at
the site. Thus, the selected remedy and contingent remedy, which require the construction of caps consistent
with the requirements of 6 NYCRR Part 360, extraction of contaminated groundwater from the bedrock aquifer in
the vicinity of monitoring well MW-2S, and if needed, bedrock groundwater extraction and treatment, utilize
permanent solutions and alternative treatment technologies to the maximum extent practicable. The selected
remedy and the contingent remedy represent the best balance of trade-offs among the alternatives with respect
to the evaluation criteria.
Groundwater monitoring will be performed to demonstrate that the selected remedy meets all remedial action
objectives. If the monitoring results and modeling indicate that the selected remedy is not effective in
meeting remedial action objectives, then the contingent remedy may be implemented. The extraction and
subsequent treatment of groundwater from the bedrock aquifer, if implemented, will permanently and
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significantly reduce the toxicity, mobility, and volume of contaminants in the ground water.
The selected remedy will reguire construction of landfill caps. No technological problems should arise since
the technologies and materials needed for capping the landfill areas are readily available. With the
construction of the landfill caps, the direct contact risk to the landfill surface will be eliminated.
Preference for Treatment as a Principal Element
The statutory preference for remedies that employ treatment as a principal element cannot be satisfied for
the landfill itself, since treatment of the landfill material is not practicable. The size of the landfill
and the fact that there are no identified on-site hot spots that represent the major sources of contamina-
tion (other than in the vicinity of monitoring well MW-2S), preclude a remedy in which contaminants could be
excavated and treated effectively. The statutory preference for remedies that employ treatment as a
principal element is, however, satisfied by treating the contaminated groundwater in the vicinity of
monitoring well MW-2S.
DOCUMENTATION OF SIGNIFICANT CHANGES
There are no significant changes from the selected alternative presented in the Proposed Plan.
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APPENDIX V
RESPONSIVENESS SUMMARY
Sidney Landfill Superfund Site
INTRODUCTION
A responsiveness summary is required by Superfund regulation. It provides a summary of citizens' comments
and concerns received during the public comment period, and the United States Environmental Protection
Agency's (EPA's) and the New York State Department of Environmental Conservation's (NYSDEC's) responses to
those comments and concerns. All comments summarized in this document have been considered in EPA's and
NYSDEC's final decision for selection of a remedial alternative to address the contamination at the Sidney
Landfill site.
OVERVIEW
The public generally supports the preferred remedy, excavating and relocating the waste from the Can and
Bottle Dump Area to the adjacent North Disposal Area, installing a landfill cap consistent with 6 NYCRR Part
360 in four areas, extracting contaminated groundwater from the bedrock aguifer in the vicinity of monitoring
well MW-2S, followed by air-stripping and discharge to surface water, long-term monitoring of the
groundwater, surface water, and sediments, and recommending the implementation of institutional controls (the
placement of restrictions on the installation and use of groundwater wells at the site and restrictions on
the future use of the site in order to protect the integrity of the caps).
The primary concerns were related to the contamination that is present in South Pond and the threat that the
site poses to private water supplies. It was explained at the public meeting that, while sediment samples
collected from South Pond contained PCBs and a variety of pesticides, based upon the documented release of
PCBs and solvent-containing waste oils to South Pond from a waste oil pit located on the adjacent Richardson
Hill Road Landfill Superfund site, it is believed that the contamination in South Pond is attributable to the
Richardson Hill Road Landfill site, rather than the Sidney Landfill site It is anticipated that the remedial
investigation and feasibility study (RI/FS) for the Richardson Hill Road Landfill site will be completed in
the summer of 1996. The remedy that is ultimately selected for the Richardson Hill Road Landfill site will
address the contaminated sediments in South Pond. With regard to the private water supplies, two private
springs located adjacent to the site show chemical contamination above drinking water standards. Both
springs have whole-house treatment systems, which are currently being maintained by potentially responsible
parties associated with the Richardson Hill Road Landfill site As a result of the treatment systems, these
water supplies show no contamination at the point of use. Based upon the results of samples collected from
private wells located downgradient from the site, there is no indication that these wells have been or are
expected to be impacted by the site.
SUMMARY OF COMMUNITY RELATIONS ACTIVITIES
The RI report, FS report, and Proposed Plan for the site were released to the public for comment on July 27,
1995. These documents were made available to the public in the administrative record file at the EPA Docket
Room in Region II, New York and the information repository at the Sidney Memorial Library. The notice of
availability for the above-referenced documents was published in the Press and Sun Bulletin on July 27, 1995.
The public comment period related to these documents was held from July 27, 1995 to August 26, 1995.
On August 2, 1995, EPA conducted a public meeting at Sidney Civic Center to inform local officials and
interested citizens about the Superfund process, to review current and planned remedial activities at the
site, to discuss and receive comments on the Proposed Plan, and to respond to guestions from area residents
and other interested parties.
SUMMARY OF COMMENTS AND RESPONSES
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The following correspondence (see Appendix V-a) was received during the public comment period:
• Letter to Richard Ramon, P.E., dated August 22, 1995, from Samuel S. Waldo, Director, Environmental
Affairs, Amphenol Corporation, and Robert J. Ford, Director, Site Remediation, Allied Signal, Inc.
• Letter to Richard Ramon, P.E., dated August 25, 1995, from David Rider, P.E., Administrative Engineer,
New York City Department of Environmental Protection.
• Letter to Richard Ramon, P.E., undated, from Kate Wheeler, Neighbors United for Community Health.
A summary of the comments contained in the above letters and the comments provided by the public at the
August 2, 1995 public meeting, as well as EPA's and NYSDEC's response to those comments, follows.
Letters
Letter to Richard Ramon, P.E., dated August 22, 1995, from Samuel S. Waldo, Director, Environmental Affairs,
Amphenol Corporation, and Robert J. Ford, Director, Site Remediation, AlliedSignal, Inc.
Comment #1: The ecological risk assessment states that a potential risk exists in the South Pond as a result
of the levels of pesticide residues detected there. It is further stated that, because contamination in South
Pond likely originated from the Richardson Hill Road Landfill, any remedial activities to address the
contamination in South Pond would be undertaken in conjunction with the remediation of the Richardson Hill
Road Landfill site. The data from Richardson Hill Road Landfill site, however, does not support a conclusion
that the pesticide residues, if present at all, resulted from activities associated with the Richardson Hill
Road Landfill site.
Response #1: Sediment samples from South Pond collected during the Sidney Landfill site RI contained PCBs and
a variety of pesticides. Based upon the documented release of PCBs and solvent-containing waste oils to
South Pond from a waste oil pit located on the Richardson Hill Road Landfill site, it is believed that, with
the exception of the pesticides, the contamination in South Pond is attributable to the Richardson Hill Road
Landfill site, rather than the Sidney Landfill site While the RI data indicate that the Sidney Landfill site
is not the source of the pesticide contamination that was detected in South Pond, it does not appear that the
Richardson Hill Road Landfill site is the source either. It should be noted that even the control pond had
pesticides present.
Comment #2: The Proposed Plan calls for the installation of four independent 6 NYCRR Part 360 caps. While
there is no reason to believe that the 6 NYCRR Part 360 caps would not perform as anticipated, it is
su* gested that the remedy be modified slightly to call for the installation of caps "consistent with the
reguirements of 6 NYCRR Part 360." There have been recent improvements in cap technology and materials of
construction which could provide eguivalent or increased protection in a more cost-effective manner. The
recommended modification would allow design of caps utilizing the most current technology available, while
still meeting the performance reguirements of 6 NYCRR Part 360.
Response #2: As suggested, the cap designs will be consistent with the reguirements of 6 NYCRR Part 360.
Comment #2: The Proposed Plan calls for the installation of a "hot-spot" groundwater recovery and treatment
system in the vicinity of monitoring well MW-2S to address the light non-agueous phase liguid (LNAPL). Since
subseguent sampling of this monitoring well indicated only residual LNAPL, and since downgradient wells do
not indicate the presence of LNAPL, there does not appear to be recoverable contamination hot-spots.
Therefore, it is recommended that any effort to institute groundwater treatment be considered as a phased
task in conjunction with the site-wide trend analysis. In addition, a period of routine monitoring is
appropriate prior to determining the need for and the feasibility of a focused groundwater treatment system.
Even if the "hot-spot" groundwater treatment is implemented, there should be flexibility in selecting a
treatment technology (i.e., the treatment technology should not be limited to air-stripping).
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MW-2S. The LNAPL was monitored during each water-level monitoring event for thickness and the bottom of
monitoring well MW-2S was checked with an interface probe for the presence of DNAPL, which was not found.
Comment #6: What is the contaminant loading to surface water during storm and non- torm events?
Response #6: Although samples were collected during non-storm conditions during the RI, contaminant loading
to the adjacent water bodies was not calculated. Surface water sampling was not conducted during storm
events. Once the disposal areas are capped, the contaminant loading to neighboring water bodies during storm
and non-storm events will be significantly reduced or eliminated.
Comment #7: What is the extent of surficial soil contamination in areas other than those areas that are to
be capped?
Response #7: Contaminants detected in the surface soils outside the areas to be capped were predominately
pesticides and PCBs. Semi-volatile organic compounds (SVOCs) and volatile organic compounds (VOCs) were
detected in samples along the west side of the site. The contaminants found, and the respective ranges, are
summarized as follows: PCB Aroclor 1248 (43-890 • g/1); PCB Aroclor 1254 (240-670 • g/1); 4,4'-DDE (1.9- 8
•g/1); 4,4'-DDT (2.4 pg/1); 1,2-dichloroethene (23-98 pg/1); 1,1,1- trichloroethane (9-10 • g/1);
1,1-dichloroethane (9-21 • g/1); 1,4-dichlorobenzene (68 • g/1); 4-methylphenol (390 • g/1 ); bis (2-
Ethylhexyl)phthalate (150-5100 • g/1); Benzo (k) Fluorene (10-11 • g/1); Benzo (b) Fluorene (18-28 • g/1) ;
Butyl-benzyl-Phthalate (11 • g/1); Chrysene (21 • g/1); Flourantene (50 • g/1); Methylene Chloride (2 • g/1) ;
Phenanthrene (38 p.g/1); trichloroethene (11-23 •g/1); and Toluene (2 • g/1) . While surficial soil
contamination is present in areas beyond the limits of the areas that will be capped, the levels of
contamination in these areas do not pose an unacceptable human health or ecological risk.
Comment #8: What are the exposure scenarios used in the human health and ecological risk assessments?
Response #8: The baseline risk assessment estimates the human health and ecological risk which could result
from the contamination at the site, if no remedial action were taken.
The human health risk assessment began with selecting contaminants of concern that would be representative of
site risks. The contaminants included 18 volatile organic compounds, 21 semi-volatile organic compounds, 9
pesticides, PCBs, 17 metals, and cyanide. Several of the contaminants, including vinyl chloride, benzene,
and arsenic, are known to cause cancer in laboratory animals and are suspected to be human carcinogens.
In the current-use scenario, exposure to the chemicals of potential concern in spring water during
potable use by resident adults and children; exposure to the chemicals of potential concern in on-site
surface soil, on-site leachate, surface soil from the Alleged Liguid Disposal Area, and off-site
surface soil by adolescent trespassers; and exposure to the chemicals of potential concern in surface
water and sediment from North Pond and the small ponds and wetlands in the vicinity of the site by
adolescent recreationalists were evaluated. In the future-use scenario, exposures to the chemicals of
potential concern in subsurface soils on site, at the Alleged Liguid Disposal Area, at the Eastern
Stained Area (part of the Southeast Disposal Area), and off-site by utility/maintenance workers were
evaluated.
The ecological risk assessment evaluated the potential risks of exposure to the contaminants of
concern to several indicator species. Largemouth bass was the only species of fish caught from North
Pond and the control location. Therefore, this species was used as an indicator of conditions in the
ponded areas in the vicinity of the site. For assessment of risks from exposure to surface soils, the
cottontail rabbit, a common mammal known to occur on the site, was used as an indicator. Mink and
osprey were chosen as indicators for analysis of risk through exposure to contaminants in fish tissue,
since these species may inhabit the vicinity of the landfill, and are known to consume fish as the
bulk of their diet.
For the ecological risk assessment, if criteria or guideline values were exceeded, the chemicals were
chosen as chemicals of potential concern for this assessment. The list was refined by considering
freguency of detection and other properties of the chemicals which may affect exposure and toxicity.
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Comment #9: How many extraction wells will be necessary to remediate the contaminated groundwater?
Response #9: It was estimated in the FS report that 20 extraction wells would need to be installed to
remediate the contaminated groundwater in the vicinity of monitoring well MW-2S. The specific number of
extraction wells that will be installed will be determined during pre-remedial design studies.
Comment #10: How do Alternatives 2A and 3A differ in the protection of human health and the environment?
Response #10: In terms of addressing the bedrock groundwater contamination in the vicinity of monitoring well
MW-2S, Alternatives 2A and 3A would be egually protective. Under Alternatives 2A and 3A, the source of the
bedrock groundwater contamination is expected to be significantly reduced or possibly eliminated due to the
reduction of infiltrating precipitation by the capping of the waste disposal areas and the extraction of the
contaminated groundwater from the bedrock aguifer in the vicinity of monitoring well MW-2S.
Since Alternative 3A would extract contaminated groundwater from the bedrock aguifer at locations in addition
to the vicinity of monitoring well MW-2S, it would provide marginally more protection to human health and the
environment than Alternative 2A, which would primarily rely on natural attenuation to address the
contamination in the bedrock aguifer. However, since the levels of contamination in the bedrock aguifer are
less than 200 • g/1 for any contaminant (other than in the vicinity of monitoring well MW-2S), EPA
anticipates that collecting and treating contaminated groundwater from the vicinity of monitoring well MW-2S,
in conjunction with natural attenuation of the other contamination present in the bedrock aguifer, as called
for in Alternative 2A, the selected remedy, would result in remediating the groundwater in a reasonable time
frame and at a significantly lower cost than Alternative 3A.
Comment #11: What are the post-closure operation, maintenance, and monitoring activities proposed for the
site?
Response #11: The post-closure operation, maintenance, and monitoring activities that would be undertaken as
part of the selected remedy will include long-term monitoring of groundwater, surface water, and sediments,
and routine inspections and maintenance of the caps, consisting of mowing, fertilizing, reseeding, and
repairing any potential erosion or burrowing rodent damage. The specific details of the operation,
maintenance, and monitoring activities will be developed as part of the remedial design.
Comment #12: What is the status of current remedial activities at the Richardson Hill Road Landfill site?
Will there be a coordinated effort by EPA to ensure that the individual remedial actions for these two sites
will address all of the deleterious effects associated with each of these sites?
Response #12: It is anticipated that the RI/FS for the Richardson Hill Road Landfill site will be completed
in the summer of 1996. It is envisioned that the remedy that will be selected for the Richardson Hill Road
Landfill site will meet the remedial action objectives (the specific goals to protect human health and the
environment) that will be established for this site.
The selected remedy for the Sidney Landfill site, which includes, among other things, installing landfill
caps in four areas and extracting, treating, and discharging to surface water the contaminated groundwater
from the bedrock aguifer in the vicinity of monitoring well MW-2S, is expected to meet the remedial action
objectives that were established for the site, namely, to: minimize infiltration and the resulting
contaminant leaching to groundwater; control surface water runoff and erosion; mitigate the off-site
migration of contaminated groundwater; restore groundwater guality to levels which do not exceed state or
federal drinking-water standards; control generation and prevent migration of subsurface landfill gas; and
prevent contact with contaminants in the groundwater.
EPA will ensure that the individual remedial actions for the two sites will address all of the contamination
associated with each of the sites.
Comment #13: It is recommended that, after treatment, the extracted groundwater be discharged to surface
waters outside of the New York City water supply watershed.
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Response #13: The exact discharge location for the treated groundwater will be determined during the remedial
design. The conceptual design of the selected remedy included discharge of the treated groundwater to a
surface water which is part of the and is outside of the New York City water supply watershed. It is EPAs
intention to discharge to a surface water in the Susquehanna River basin.
Letter to Richard Ramon, P.E., undated, from Kate Wheeler, Neighbors United for Community Health.
Comment #1: The RI/FS report provides little detail on the historical usage of the landfill by the Town and
nearby industries. The historical usage of the landfill should be provided in greater detail so as to
provide guidance on the likelihood that pockets of waste are present on the site.
Response #1: While the Rl/FS report does not go into great detail on the historical usage of the landfill,
based on interviews with former landfill employees, the review of historical aerial historical photographs,
which were used to identify disturbed areas for the purpose of locating soil borings and monitoring wells,
and the results of an extensive RI, the likelihood of undetected areas of waste is low. Any pockets of waste
that are located in the waste disposal areas will be contained by capping.
Comment #2: It is not clear from the RI/FS report whether dense non-agueous phase liguids (DNAPLs) are
present on the site and whether they will be addressed by the remediation of the groundwater.
Response #2: During the RI, the sample results were reviewed to determine whether there were concentrations
of contaminants which approached approximately one percent of their solubility (EPA1 s guidance on determining
whether NAPL may be present). NAPL was not observed. Based on analytical results of samples and the visual
observation of floating product, it was determined that LNAPL was present in monitoring well MW-2S. The
LNAPL was monitored during each water-level monitoring event for thickness and the bottom of monitoring well
MW-2S was checked with an interface probe for the presence of DNAPL, which was not found. The RI/FS report
also identifies the presence of compounds with specific gravities greater than one, which if present at high
enough concentrations, would have the potential of forming DNAPL. These compounds, however, were not
detected at concentrations which are indicative of potential DNAPL formation.
Comment #3: No explanation is provided for the presence of 61,000,000 • g/1 of PCBs at monitoring well
MW-2S during the 1991 sampling round and the failure to detect it in a subsequent sampling round. Could the
PCBs be present from an acute release from a buried drum? Is the one-time presence of these PCBs
reflective of a "slug" of contamination passing though the site? Has the migratory pattern of this
contaminant plume been determined through additional testing (e.g., where is it going and when will it get
there)?
Response #3: During the first sampling round, floating product was detected in monitoring well MW-2S.
Screening results of the sampling showed the presence of the PCB Aroclor 1242 (61,000,000 •g/1) and other
compounds. The results from the second sampling round indicated that, while the floating product and PCBs
were not detected at monitoring well MW-2S, high concentrations of volatile organic compounds were present.
Since monitoring well MW-2S is located just east of the North Disposal Area, it is likely that this disposal
area was the source of the PCBs and other contaminants that were detected in this monitoring well. It is
unknown whether the PCBs were originally contained in a drum. While it ig not clear what happened to the
PCBs that were detected in the first sampling round, it is presumed that they have either migrated
downgradient or dispersed. The migratory pattern of the contaminant plume has not been determined.
Comment #4: How many groundwater sampling rounds exist for each well and what contaminants were found?
Response #4: Bedrock aguifer samples (there is no overburden aguifer present) were collected from site
monitoring wells in 1991 (Round 1) and in 1994 (Round 2).
Round 1 groundwater sampling detected, predominantly, TCE, 1,1,1-TCA, and their breakdown products, along
with the occasional presence of other volatile organic compounds, such as toluene, xylene, and carbon
disulfide. Bis(2-Ethylhexyl)phthalate was the only SVOC detected with any regularity in the groundwater
samples from Round 1. The pesticides aidtin, DDT, and heptachlor epoxide were also detected. During Round
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1, floating product was detected in a monitoring well (MW-2S). Screening results of the floating product
showed the presence of the following additional compounds: PCBs; ethylbenzene; 1, 1, 2, 2- tetrachloroethane
(TCA) ; tetrachloroethene (PCE); and 1,2,4-trimethylbenzene.
The results from Round 2 indicated the presence of TCE, TCA, 1,2-dichloroethene, dichloroethane, and vinyl
chloride. Only one groundwater sample contained elevated pesticide concentrations. Benzene, ethylbenzene,
toluene, and xylene were detected in monitoring well MW-2S.
Comment #5: The RI/FS report states that the sediment contamination in South Pond is the result of
contaminants from the adjacent Richardson Hill Road Landfill site. The assumption that no contribution to
South Pond occurred from the Sidney Landfill site does not appear to be justified, given the sediment data
upgradient of this water body.
Response #5: No sediment samples were collected upgradient of South Pond. While the sediment sample
collected farthest north in South Pond (closest to the Sidney Landfill) contained a maximum concentration of
PCBs of 110 microgram/kilogram (• g/kg), the sediment sample collected closest to the Richardson Hill Road
Landfill (located to the west of South Pond) had a concentration of PCBs in excess of 2,500 • g/kg. In
addition to these sediment sample results, it has been well documented that the Richardson Hill Road Landfill
had an oil pit which overflowed into South Pond.
Comment #6: The use of oils and other liguids to reduce dust at landfills was a common practice during the
time that this facility was operational. Could the presence of PCBs in surface soils on the site and in South
Pond sediments be a result of these activities?
Response #6: Since it was reported to EPA that oils were used for dust control on the roadways at the site,
during the RI, surface soil samples were collected at several locations along the landfill's roadways. The
results of this sampling indicate that PCBs were present in one location on a roadway, however, at levels
below the New York State Department of Environmental Conservation's recommend soil cleanup guidance of 1
milligram/kilogram for surface soils. It is likely that the majority of the PCBs found on-site are
attributable to disposal activities rather than dust control.
Comment #7: Are subsurface conditions sufficiently documented to install groundwater extraction wells at
this time?
Response #7: While subsurface conditions at the site are sufficiently defined to support the selection of
groundwater extraction in the vicinity of monitoring well MW-2S as a viable remedy, pre-remedial design
studies will need to be conducted to define design parameters such as the placement of the extraction wells,
pumping rates, etc.
Comment #8: Air stripping of groundwater is not an appropriate remedial action for groundwater containing
PCBs. What actions/monitoring will occur to ensure that any PCBs in the groundwater are properly treated?
Response #8: Although PCBs were detected in monitoring well MW-2S during the firstsampling round, they were
not detected in the second sampling round. Therefore, treatment of PCBs was assumed to be unnecessary. If,
however, during the pre-remedial design sampling or during long-term monitoring, PCBs are detected at levels
which would reguire treatment to comply with surface water discharge reguirements, an appropriate treatment
unit would be included.
Comment #9: The proposed discharge of the treated effluent to surface water will reguire careful
monitoring to ensure that aguatic life and downstream users (there are dairy farms just downstream) are
protected. What monitoring schedule will be implemented to document that discharges meet EPA standards?
What safeguards will be in place to ensure system shutdown in the event that unanticipated compounds (e.g.,
PCBs) are present in the effluent?
Response #9: The water treatment plants effluent will be monitored to ensure that it complies with federal
and state surface water discharge reguirements. A long-term monitoring plan, which will be developed during
the remedial design, will describe the sampling freguency, what parameters are to be sampled for, and
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corrective measures that would be implemented in the event of the treatment systems failure to properly treat
the extracted groundwater.
Comments from the Public Meeting
Comment #1: How far downstream from the site were the surface water and sedimentstested? What were the
levels of contaminants that were detected?
Response #1 As part of the RI, water guality and sediments were sampled as far downstream as a tributary to
Trout Creek, which is located less than one mile from the site. Sampling results at the farthest location
(SW/SD 12) indicated the presence of low levels of bis(2-ethylhexyl)phthalate (1 •/I) in the surface water
and low levels of acetone (29 • g/1) and di-n-butlyphthalate (68 • g/1) in the sediments.
Comment #2: Are the contaminated sediments that were present in South Pond 20 years ago now in the
Cannonsville Reservoir?
Response #2: The New York State Department of Health took water and sediment samples upstream and downstream
of Trout Creek and found that, although South Pond was heavily contaminated, only low levels of contaminants
were detected in sediments in the first downstream beaver pond. At the next downstream beaver pond (one-mile
downstream), the sediments had only trace amounts of contamination. Therefore, it is highly unlikely that
the Cannonsville Reservoir, which is located 17 miles downstream from South Pond would be impacted by
contaminated sediments located in South Pond.
Comment #3: Does the contamination from the site threaten downgradient drinking water supplies?
Response #3: Two private springs located adjacent to the site show chemical contamination above drinking
water standards. Both springs have whole-house treatment systems, which are currently being maintained by
potentially responsible parties associated with the Richardson Hill Road Landfill site. As a result of the
treatment systems, these water supplies show no contamination at the point of use. According to the New York
State Department of Health, based upon the results of its samples collected from private wells located down-
gradient from the site, there is no indication that these wells might be impacted by the site.
Comment #4: If someone's well is currently free of contaminants, but in the future, analyses indicate that
the well is contaminated, would the homeowner be responsible for protecting his own water supply?
Response #4: If it is determined that the site is the source of contamination to a private water supply,
protecting the water supply can be addressed under the Superfund program.
Comment #5: What kinds of contaminants were detected at the site and what are the potential impact of these
contaminants on human health? Is the long-term exposure to any of the contaminants that are present likely
to cause genetic damage? Are any of the contaminants carcinogens?
Response #5: Organic contaminants detected in the surface soils were predominantly pesticides and PCBs.
Elevated inorganic contaminants, including, aluminum, arsenic, barium, cadmium, chromium, copper, lead,
manganese, nickel, silver, thallium, and zinc were detected.
Trichloroethene and its breakdown products, 1,2-dichloroethene and vinyl chloride, are the primary
groundwater contaminants that were detected over most of the site. Bedrock aguifer samples also detected,
1,1,1-trichloroethane and tetrachloroethene, along with the occasional presence of other VOCs, such as
toluene, xylene, and carbon disulfide. PCBs and pesticides were also detected.
Some VOCs are considered to cause genetic damage and some do not. Xylene, toluene, and PCBs are nongenotoxic,
but trichloroethene is considered a weak mutagen, vinyl chloride is considered mutagenic, and benzene and/or
its metabolites seem to be genotoxic to humans, causing primarily chromosomal aberrations in the bone marrow
and lymphocytes. There is not enough scientific data to determine if 1,2-dichloroethene, carbon disulfide,
and 1,1,1-trichloroethene cause genetic effects in humans.
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The following metals are considered to cause genetic effects in humans: copper, nickel, silver, thallium,
beryllium, cadmium, chromium (hexavalent), arsenic, and aluminum. There is not enough scientific data to
determine if manganese, zinc, antimony, or barium cause genotoxic effects.
In regard to systemic (noncancer) effects, different chemicals act on different organs and body systems. The
neurological system is affected primarily by the following chemicals: lead, manganese, thallium, xylene,
carbon disulfide, vinyl chloride, toluene, aluminum, and 1,1,1-trichloroethane. Chromium (hexavalent),
antimony, beryllium, and nickel effect the respiratory tract. Zinc and copper act primarily on the
gastrointestinal tract. The cardiovascular system is affected by benzene, arsenic, and barium. Silver
affects the skin. Cadmium affects the kidneys. Trichloroethene causes effects on the liver.
With regard to carcinogens)benzene is a known carcinogen; PCBs, trichloroethene, tetrachlorethene, and vinyl
chloride are suspected carcinogens. Xylene, carbon disulfide, 1,2-dichloroethene, and 1,1,1-trichloroethane
are Class D carcinogens, which means that there is not enough scientific data to determine if the chemical
causes cancer in humans. All of the metals mentioned above, except arsenic, beryllium, cadmium, chromium,
lead, and nickel, are classified as Class D carcinogens. Of the remaining inorganics, arsenic and chromium
(hexavalent) are known human carcinogens and the rest are suspected.
In the current-use scenario, exposure of resident adults and children to spring water and exposure of
adolescent trespassers to on-site surface soil and on-site leachate result in risks in excess of EPA's
acceptable risk range. The primary contributors to the risk estimates are tricholorethene and manganese in
spring water and PCBs in on-site surface soil and on-site leachate.
In the future-use scenario, exposure of resident adults and children to groundwater and exposure of
utility/maintenance workers to sub-surface soil at the Eastern Stained Area result in risks in excess of
EPA's acceptable risk range. The primary contributors to the risk estimates are manganese, arsenic,
antimony, barium, beryllium, vinyl chloride, and PCBs in groundwater and PCBs in the Eastern Stained Area.
Comment #6: Are signs posted along South Pond and North Pond?
Response #6: There are warning signs posted on a construction fence that was installed along Richardson Hill
Road adjacent to South Pond. Since the levels of contamination in North Pond do not pose a threat, it has
not been fenced or posted.
Comment #7: To what extent has wildlife, such as deer, been impacted by the site?
Response #7: Due to the site's location in a rural area and the presence of both upland and wetland
habitats, the potential for utilization by wildlife is high. The presence of pesticides, PCBs, and inorganic
compounds in environmental media, at concentrations which present a potential risk, are likely to have some
adverse effect on wildlife utilizing the site vicinity, even if those effects are not apparent on an
ecosystem level. If the site is unremediated, contaminants may continue to be released (e.g., via leachate,
surface runoff, groundwater discharge) into the environment. Effects of contaminants could be more
pronounced over time as a result of increasing concentrations in the media of concern and bioaccumulation
through the food chain. Remediation of the site would limit future contaminant releases, and may allow the
affected media to recover over time through such natural processes as dilution, sedimentation, and, for some
organics, biodegradation.
Analytical data associated with the sites soil, surface water, and leachate was used to evaluate the
potential risk to animal populations. This evaluation focused on earthworms, animals that feed on
earthworms, moving up through the food chain or the food pyramid, because those are the things that are in
contact with the soil and surface water, to see if, for example, predatory birds or other animals could be
affected. The conclusion was that there were some potential risks, but the remedy will isolate the
contaminants. Since deer eat vegetation instead of other animals, and because they are farther roaming (so
they feed from a large area), it's unlikely that they would be affected from the landfill because they cover
a larger area.
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Comment #8: How is a landfill cap constructed and how will capping the disposal areas protect public health
and the environment?
Response #8: Prior to the construction of the caps, test pits will be excavated to determine the actual
limits of the waste disposal areas. Once the waste disposal areas are clearly defined they will be regraded
and compacted to provide a stable foundation for placement of the various layers of the caps and to provide
rapid runoff of rainwater. Since decomposing wastes produce methane gas which could cause bubbling under the
caps, a gas-venting layer is installed. A 40-mil plastic cap, which is thermally seamed so that it's a
continuous sheet, is then installed over the entire waste area. Vents are installed through the cap into the
gas-venting layer. On top of the cap, a drainage layer is installed so that precipitation that does not run
off the surface can drain off the cap. On top of this is placed six inches of topsoil to support the grass
or vegetation, which would be mowed and maintained. The grass prevents erosion of the surface of the cap and
draws moisture out of the cap. To prevent rainwater from seeping into the wastes at the bottom edge (toe) of
a landfill cap, it is standard practice for the cap's toe to extend beyond the waste disposal area that is
being covered.
Capping the wastes serves two purposes: First, capping will prevent direct contact with the wastes and
leachate seeps. Second, the caps that would be installed would nearly eliminate the infiltration of
rainwater into the waste disposal areas and the associated leaching of contaminants from these areas.
Since the results of soil borings suggest that all of the waste disposal areas are located above the
groundwater table, capping the wastes would effectively isolate the source of the contamination to the
groundwater. Eventually, whatever contamination has migrated out of the waste disposal areas will move
downgrade, dissipate, and/or biodegrade.
Comment #9: The RI/FS refers to a 30-year life for the cap. How long will operation and maintenance be
performed.?
Response #9: A 30-year time frame is used in RI/FSs as a means of comparing the costs of the various
alternatives that are evaluated. The cap is expected to last longer than 30 years with proper maintenance.
The maintenance of the cap, which will include mowing the grass, repairing settling or burrowing damage to
the cap, and the like, would continue indefinitely. Other operation and maintenance activities that would be
performed at the site include maintaining the fences and collecting samples from the monitoring of the wells.
Comment #10: Who will pay for the annual operation and maintenance costs?
Response #10: If the potentially responsible parties do not elect to either perform or pay for the remedial
action and the associated operation, maintenance, and monitoring, then EPA and NYSDEC would pay for the
remedial action (which would include the construction of the caps, the fences, and up to ten years of
groundwater extraction and treatment) and NYSDEC would pay for the post-remedial action operation,
maintenance, and monitoring.
Comment #11: Why isnt Alternative 3A being selected?
Response #11: Under the selected remedy, Alternative 2A, the source of the bedrock groundwater
contamination is expected to be significantly reduced or possibly eliminated due to the reduction of
infiltrating precipitation by the capping of the waste disposal areas and the extraction of the contaminated
groundwater from the bedrock aguifer in the vicinity of monitoring well MW-2S. Because of this and the fact
that the levels of contamination in the bedrock aguifer are less than 200 g/1 for any contaminant (other than
in the vicinity of monitoring well MW-2S), EPA anticipates that collecting and treating contaminated
groundwater from the vicinity of monitoring well MW-2S, in conjunction with natural attenuation of the other
contamination present in the bedrock aguifer, would result in remediating the groundwater in a reasonable
time frame and at a significantly lower cost than Alternative 3A.
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RECORD OF DECISION FACT SHEET
EPA REGION II
Site:
Site name: Sidney Landfill
Site location: Town of Sidney, Delaware County, New York
HRS score: 29.36 (June 1988)
EPA ID #: NYD980507677
Record of Decision:
Date signed: September 28, 1995
Selected remedy: Installation of Landfill Caps consistent with 6 NYCRR Part 360 in Four Areas
Capital cost: $4,624,041
Construction Completion - 10-12 months
Annual 0 & M cost - $370,728
Present-worth cost - $10,260,000 (5% discount rate for 30 years)
Lead:
Site is enforcement lead - EPA is the lead agency
Primary Contact: Richard Ramon (212) 637-4253
Secondary Contact: Joel Singerman (212) 637-4258
Main PRPs: Amphenol Corporation and AlliedSignal, Inc.
Waste:
Waste type: metals, volatile organics, semi-volatile organics and PCBs
Waste origin: Hazardous waste
Contaminated medium: soil, groundwater
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