Superfund Record of Decision Olean Well Field Site Cattaraugus County NY


                                    EPA/ROD/R02-96/281
                                    1996
EPA Superfund
     Record of Decision:
     OLEAN WELL FIELD
     EPA ID: NYD980528657
     OU02
     OLEAN, NY
     09/30/1996

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RECORD OF DECISION
DECISION SUMMARY

Olean Well Field

City of Olean, Cattaraugus County, New York

United States Environmental Protection Agency
Region II
New York, New York
September 1996

TABLE OF CONTENTS

                                                              page

SITE NAME, LOCATION AND DESCRIPTION  	  1

SITE HISTORY AND ENFORCEMENT ACTIVITIES  	  1

HIGHLIGHTS OF COMMUNITY PARTICIPATION  	  5

SCOPE AND ROLE OF OPERABLE UNIT	5

SUMMARY OF SITE CHARACTERISTICS	6

SUMMARY OF SITE RISKS	21

REMEDIAL ACTION OBJECTIVES  	   27

DESCRIPTION OF REMEDIAL ALTERNATIVES   	   29

SUMMARY OF COMPARATIVE ANALYSIS  OF ALTERNATIVES	38

SELECTED REMEDIES 	   72

STATUTORY DETERMINATIONS   	   77

DOCUMENTATION OF SIGNIFICANT CHANGES   	   87

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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RECORD OF DECISION

Olean Well Field

City of Olean, Cattaraugus County, New York

United States Environmental Protection Agency
Region II
New York, New York
September 1996

DECLARATION FOR THE RECORD OF DECISION

SITE NAME AND LOCATION

Olean Well Field

City of Olean, Cattaraugus county, New York

STATEMENT OF BASIS AND PURPOSE

This Record of Decision (ROD) presents the selected remedial actions for the Olean Well Field Site (Site),
which were chosen in accordance with the Comprehensive Environment Response, Compensation and Liability Act
of 1980, as ammended (CERCLA) , 42 U.S.C. §§ 9601-9675 and the National Oil and Hazardous Substances Pollution
Contingency Plan. This decision document explains the factual and legal basis for selecting the remedies for
the Site. The attached index (Appendix III) identifies the items that comprise the Administrative Record
upon which the selection of the remedial actions is based.

The State of New York concurs with the selected remedy per the attached letter (Appendix IV).

ASSESSMENT OF THE SITE

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

DESCRIPTION OF THE SELECTED REMEDY

This operable unit, which is the second of two operable units for the Site, addresses the violatile organic
compound (VOC) contamination at four properties, as described below. The first operable unit focused on
determining the nature and extent of volatile organic compound (VOC) contamination in the groundwater. The
first operable unit ROD, which was signed on September 24, 1985, specified the installation of two air
strippers, which are effectively removing VOC contaminants from the groundwater to concentrations, which are
below the maximum allowable concentrations that have been set by EPA and the New York State Department of
Health, for drinking water. Groundwater is a source of drinking water for the City and Town of Olean, New
York.

The major components of the selected remedy for the second operable unit for the Alcas property includes the
following:

! Vacuum Enhanced Recovery (VER) of VOCs from contaminated soil.
! Upgradient and downgradient groundwater monitoring.
! Implementation of groundwater use restrictions.

The major components of the selected remedy for the Loohn's Dry cleaners and Launderers property include the
following:

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! Vacuum Enhanced Recovery or Soil Vapor Extraction with air sparging (SVE/AS). Should design studies
indicate that VER and SVE/AS are impracticable due to the influence of the Allegheny River, the source
area will be excavated.
! Upgradient and downgradient groundwater monitoring.
! Implementation of groundwater treatment if VER and SVE/AS or excavation does not adequately improve
the quality of the City Aquifer, and if the property continues to affect the groundwater entering the
municipal wells.
! Implementation of groundwater use restrictions.

The major components of the selected remedy for the McGraw-Edison property include the following:

! Groundwater treatment
! Upgradient and downgradient groundwater monitoring.
! Implementation of groundwater use restrictions.

The major components of the selected remedy for the AVX property include the following:

! Excavation and removal of contaminated soil.
! Off-Site low temperature desorption of soil contaminants, if necessary.
! Upgradient and downgradient groundwater monitoring.
! Implementation of groundwater treatment, if excavation and removal of the contaminated soil does not
adequately improve the quality of the City Aquifer and if the property continues to affect the
groundwater entering the municipal wells.
! Implementation of groundwater use restrictions.

The Site Monitoring Plan, which is being implemented as part of the remedy selected for operable unit one,
will be modified to determine the effect of the remedies on the upper and lower aquifers and the influence
groundwater to Municipal Wells 18M and 37/38M.

DECLARATION OF STATUTORY DETERMINATIONS

The selected remedies meet the requirements for remedial actions set forth in CERCLA §121, 42 U.S.C. §9621:
(1) they are protective of human health and the environment; (2) they attain a level or standard of control
of the hazardous substances, pollutants and contaminants, which at least attain the legally applicable or
relevant and appropriate requirements (ARARs) under federal and state laws, (3) they are cost-effective; (4)
they utilize permanent solutions and alternative treatment (or resource recovery) technologies to the maximum
extent practicable; and (5) they satisfy the statutory preference for remedies that employ treatment to
reduce the toxicity, mobility, or volume of the hazardous substances, pollutants or contaminants at a site.

Pursuant to CERCLA §121(c), 42 U.S.C. §9621(c), a review of the remedial action will be conducted five years
after the commencement of the remedial action 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.

SITE NAME, LOCATION AND DESCRIPTION

The Clean Field Site is located in the eastern portion of the city of Clean and east and south of the City in
the Towns of Clean and Portville in Cattaraugus County, New York. The Well Field is roughly rectangular in
shape and encompasses approximately 800 acres (see Figure 1). The Site is approximately 65 miles southeast
of Buffalo, New York and 7 miles north of the New York/Pennsylvania border at 42° 05' latitude, 78° 25'
longitude. State Routes 16 and 417 provide access to the area.

SITE HISTORY AND ENFORCEMENT ACTIVITIES

Three municipal water supply wells (18M, 37M and 38M) were constructed in the mid- to late 1970s to provide

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water for the City of Clean, New York. The supply wells draw water from the lower aquifer also known as the
City Aquifer. Prior to the construction of these municipal wells, city water was supplied by a surface-water
treatment facility, which drew water from the Clean Creek. In January 1981, trichloroethene (TCE) and other
chlorinated orqanic solvents were detected in the Clean water supply. The municipal wells were shut down at
that time as TCE levels exceeded acceptable drinkinq water standards set by the New York State Department of
Health (NYSDOH). Surface-water treatment facility operations were reactivated.

On October 23, 1981, the EPA Reqion II Field Investiqation Team (FIT) evaluated the Site for inclusion on the
National Priorities List. as a result of this evaluation, the Site was included on the National Interim
Priorities List, published on October 23, 1981, and was included on the first official Superfund National
Priorities List (NPL), published on September 9, 1983.

In November 1981, an EPA consultant initiated a preliminary hydroqeoloqic investiqation at the Site (also
referred to as the "Remedial Action Master Plan" or "RAMP"). This investiqation, completed in October 1982,
included, amonq other thinqs, the installation of monitorinq wells and samplinq of those wells, and an
aquifer pump test utilizinq municipal wells 18M and 37M.

Followinq the discovery by the Cattarauqus County Department of Health and NYSDOH that a number of private
wells in the City and Town of Clean, all of which received qroundwater from the upper aquifer, were
contaminated with TCE, EPA performed an initial removal action in January 1982. This action involved the
installation of carbon adsorption filters on 16 contaminated private wells in the City and town of Clean and
periodic monitorinq of those wells. EPA ultimately conducted two additional removal actions at the Site.
The first of these commenced in June 1984 and included the replacement of one of the carbon filters installed
for the additional removal action, installation of carbon units on ten additional contaminated private wells,
and monitorinq. The second action, implemented in March 1985, involved the installation of two additional
carbon filter systems.

EPA conducted additional activities includinq a 1993 investiqation by the FIT, which involved installation of
two wells upqradient of the Cooper Industries/McGraw-Edison company facility (McGraw-Edison), a potentially
responsible party (PRP) for the Site, and a 1985 FIT action includinq an aquifer pump test and further
samplinq at the municipal wells.

A Remedial Investiqation and Feasibility Study (RI/FS) was funded throuqh an EPA Cooperative Aqreement and
performed in 1984-85 by a contractor to the New York State Department of Environmental Conservation (NYSDEC).
Durinq the course of the RI/FS, it became apparent that a plume of TCE was threateninq a number of private
wells in the city and Town of Clean before a permanent remedy for the Site could be implemented. A focused
feasibility study was performed and an Initial Remedial Measure (IRM) was conducted which included reqular
monitorinq of private wells and installation of carbon adsorption units, as necessary, until the permanent
remedy was in place.

In 1983-84, pursuant to an administrative order issued by EPA, McGraw-Edison performed an investiqation at
its facility. This and subsequent investiqations performed by McGraw-Edison revealed that soil and
qroundwater in both aquifers at the facility were contaminated with TCE, 1,1,1- trichloroethane (1,1,1-TCA),
1,1-dichloroethylene, 1,1-dichloroethane, trans-1,2-dichloroethane, tetrachloroethane (PCE) and methylene
chloride. The studies further indicated that a pathway exists for miqration of contaminants away from the
McGraw-Edison facility and toward the contaminated municipal wells.

AVX Corporation (AVX), another PRP at the Site, performed an investiqation of its facility in 1984-85
pursuant to an administrative order issued by EPA. this investiqation indicated that soils and qroundwater
were contaminated with TCE, 1,1,1-TCA, tetrachloroethylene and other VOCs. Data collected by AVX durinq this
and subsequent investiqations demonstrated that contamination miqrates downward from the surficial soils at
the AVX facility throuqh the till and into the lower aquifer.

Alcas Cutlery Corporation (Alcas), another PRP, conducted an investiqation at its facility pursuant to an
administrative order issued by EPA in 1984. The investiqation found that soil at the Alcas facility was
contaminated with VOCs. Upper and lower aquifer qround water was also determined to be contaminated with TCE
and trans-1,2-dichloroethylene. Subsequent EPA analyses showed elevated TCE concentrations of up to 12 parts

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per million (ppm) in monitoring well B-2, which is screened in the lower aquifer at the facility and located
approximately 100 yards from municipal well 18M.

EPA issued a Record of Decision (ROD) on September 24, 1985, which required the following: 1) installation of
an air stripper to treat the groundwater from municipal well 18M, which is located on the north side of the
Allegheny River, and a second air stripper to treat the groundwater from municipal wells 37M and M38M, which
are located south of the River. Because wells 37M and 38M are located next to one another, only one air
stripper was required.; 2) extension of the City of Clean's public water supply line into the town of Clean
to connect approximately 93 residences served by private wells, including those equipped with carbon filters
as part of EPA's Removal Actions conducted in 1982, 1984 and 1985; 3) inspection of an industrial sewer at
McGraw-Edison and performance of any necessary repairs on the sewer; 4) recommendation for institutional
controls to restrict the withdrawal of contaminated groundwater; 5) institution of a Site Monitoring Plan;
and, 6) initiation of a supplemental RI/FS (SRI/FS) to evaluate source control measures at facilities that
are contributing to the groundwater contamination.

On February 7, 1986, EPA issued a Unilateral Administrative Order, Index Number II CERCLA-60201, under
Section 106(a) of CERCLA, 42 U.S.C. §9606, (the 106 Order) to AVX, Alcas, McGraw-Edison, Cooper Industries,
Inc. (Cooper), Aluminum Company of America (ALCOA), and W.R. Case and Sons Cutlery Co. (Case), (the PRPs) .
The 106 order required the PRPs to carry out the remedial actions selected in the ROD. All of the PRPs, with
the exception of Case, performed the actions pursuant to the 106 Order. The trustee in bankruptcy for the
bankruptcy estate of Case subsequently entered into a consent decree with the United States which required
the bankruptcy estate to pay a portion of EPA's past costs and a penalty for Case's failure to comply with
the 1986 unilateral order. In exchange, Case was granted a covenant not to sue for all past and future
liability.

The extension of the City of Cleans's water line was completed in 1988. In 1989, the private well users were
connected to the water line extension. Also in 1989, the industrial sewer at the McGraw-Edison property was
inspected and repaired. In February 1990, physical construction of the air strippers was completed and the
municipal wells were put back on line. Current pumping rates for Municipal well 18M and the combined pumping
rates for Municipal Wells 37M and 38M are approximately 1.2 and 1.9 million gallons per day (MGD),
respectively. Since the system began operating, treated water from the air strippers has met State and
Federal drinking water standards.

On November 13, 1989, EPA issued an administrative order to Alcas. The order required the Alcas to excavate
approximately 10 cubic yards of contaminated soil from an area at the Alcas property where TCE had previously
been used as a weed killer. The work was completed in 1989.

On June 25, 1991, an Administrative Order on Consent, Index Number II CERCLA-10202 (the SRI/FS Order) was
entered into between EPA and Alcas, AVX, McGraw-Edison, Cooper Industries and ALCOA. The SRI/FS was a mixed
work project. the PRPs were required to undertake a study of their respective facilities and write the
SRI/FS. EPA conducted studies on 10 additional properties and gave the information to the PRPs for
incorporation into the SRI/FS. In 1994, EPA oversaw the completion of a removal action at the Clean Steel
property (see figure 1). Clean Steel, which was one the properties investigated as part of the supplemental
RI, is a scrap metal recycling operation. EPA ordered the owner of the property to remove approximately 500
pails and drums and 120 cubic yards of contaminated debris and soil from the property. The debris and soil
was contaminated with phenol, chromium, lead, bis(2-ethylhexyl)phthalate, copper and zinc. In 1994, a
groundwater sample was collected by EPA from an upper aquifer well, as a follow up to the Removal Action.
Analysis of the sample revealed arochlor-1254, a polychlorinated biphenyl compound, at a concentration of 5.4
ppb. However, because the groundwater at Clean Steel is not hydraulically connected to the Clean Well Field
Site, EPA is referring this matter to the NYSDEC for further action.

HIGHLIGHTS OF COMMUNITY PARTICIPATION

EPA's public meeting for the Record of Decision for the first operable unit was held on March 29, 1988. The
major concern of the community then was on the potential economic impact of EPA's selected remedies on the
companies which were held responsible for the for the Site. The local community feared the loss of jobs;
while the City feared the loss of tax revenue, which would result from job loss.

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The supplemental RI report, supplemental FS report, and the Proposed Plan for the second operable unit for
the sight were released to the public for comment during the period: July 9,1996, through August 26, 1996.
These documents were made available to the public in the administrative record file at the EPA Region II
Superfund Records Center, located on the 18th floor at 290 Broadway, New York, New York and the information
repository at the Clean Public Library, located at Second and Laurens Street in Clean, New York.  The notice
of availability for the above-referenced documents was published in the Clean Times Herald on July 9, 1996.
The public comment period on these documents was held from July 9, 1996 to August 26, 1996.

On July 16, 1996, EPA and NYSDEC conducted a public meeting at the Clean Municipal Building to inform local
officials and interested citizens about the Superfund process, discuss the Agency's preferred remedial
alternatives, review current and planned remedial activities at the Site, and respond to any guestions or
comments raised.

Responses to the comments received at the public meeting and in writing during the public comment period are
included in the Responsiveness Summary, attached hereto as Appendix V.

SCOPE AND ROLE OF OPERABLE UNIT TWO

The remedies discussed in this Record of Decision constitute the second and last of two operable units
planned for the Site.  The first operable unit focused on determining the extent and level of VOC
contamination in the groundwater.  Groundwater is a source of drinking water.  The Record of Decision for the
first operable unit, which was signed on September 24, 1985, specified the installation of two air strippers
on Municipal Wells 18M and 37/38M, which have been treating VOC contaminated groundwater since 1990.  The
treated groundwater is pumped into the City and Town of Clean public water supply system.

A SRI/FS, which was conducted pursuant to the 1985 ROD, identified four areas on-Site which are acting as
sources of VOC contamination to the groundwater.  VOC contaminated soil, itself, does not pose an
unacceptable risk, however, it is the source of contamination to the groundwater.  contaminated groundwater
is the principal threat posed by the Site.

This second operable ROD sets forth EPA's selected remedies for the four sources of VOC contamination to the
groundwater.  The goal of the second operable unit is to restore the aguifer to its beneficial use as a
drinking water supply.

SUMMARY OF SITE CHARACTERISTICS

GEOGRAPHY

Olean is located in the Allegheny River Valley near the border of the northwestern Appalachian plateau.  The
Allegheny River, a principal tributary of the Ohio River, flows west-northwest through the southern portion
of the Site.  Olean and Haskell Creeks, tributaries of the Allegheny, are located to the west and east of the
Site, respectively.  Surface runoff, direct precipitation, and groundwater inflow sustain the annual flow in
these river/stream systems.

Site Geology and Hhydrogeology

The Olean Well Field is underlain by approximately 300 feet of unconsolidated sediments.  Previous
groundwater investigations in the Olean Well Field have shown that the upper 100 feet of sediment can be
divided into five lithologic units based on color, texture, grain size, and mode of deposition.  These
lithographic units have geen grouped into four hydrogeologic units referred to as the upper aguifer, upper
aguartard, lower aguifer, and lower aguartard.

The upper aguifer is comprised of glaciofluvial coarse sands and sandy gravels, and recent fluvial deposits
of fine sands and silts with some clay.  The upper aguifer is not continuous across the Olean Well Field.
The thickest portion of the aguifer (approximately 41 feet) is found along the Allegheny River.  The aguifer
thins to the north, pinching out south of the AVX facility.

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The upper aquartard is located above the lower aquifer. This unit is a low permeability lodgment till
composed of greater than 50 percent silt and clay. The thickness of the upper aquartard in the study area
ranges from as little as 6 feet in the south to over 30 feet in the north. In the northern portion of the
Clean Well Field, this unit is present at the surface and consists of surficial till.

The lower aquifer, also referred to as the City Aquifer, consists of glacial outwash deposits of sand, silt,
and gravel. The lower aquifer is approximately 70 feet thick in the northern portion of the Clean Well Field
and thins to approximately 30 feet south of the Allegheny River. The lower aquifer is the main source of
water for the city and Town of Clean. In addition, several industrial facilities (Clean Steel,
McGraw-Edison, and AVX) utilize wells completed in the lower aquifer for process water.

The lower aquartard has been described as silt, clay, and fine to very fine sand deposited in a preglacial
environment.

The upper aquifer is recharged by the infiltration of precipitation. Recharge to the lower aquifer is via
leakage from the upper aquifer (or till where the upper aquifer is not present) through the upper aquartard.
The magnitude of leakage over the study area is variable and is dependent on the thickness and permeability
of the till (upper aquartard) and relative head differences between the upper aquifer (or till) and lower
aquifer.

SUPPLEMENTAL REMEDIAL INVESTIGATION SUMMARY

Pursuant to the June 25, 1991, SRI/FS Order, EPA and five PRPs for the Site collected soil gas, soil and
groundwater samples at 13 properties to determine if the properties are sources of contamination to the Clean
Well Field Site. The PRPs were responsible for sampling the AVX, Alcas and McGraw-Edison properties.
Ebasco, under contract to EPA, sampled 10 other properties, which are located throughout the Site. These
properties included: Olean Steel; Clean Wholesale; the immediate vicinity of Fay Avenue and Shaefer Street; a
Private Dump located at the end of Butler and Andrews Avenues; the "Borrow Pit," a common disposal area
located along Riverside Drive; Sandburg Oil; Mastel Ford; Griffith Oil; Loohn's Cleaners and Launderers, Inc.
(Loohn's); and Olean Tile. Figure 1 shows the locations of the 13 properties investigated.

With the exception of Olean Steel, soil gas surveys were conducted on 100-by-100 foot grid spacings across
each property during September and October 1991. A grid could not be established at the Olean Steel property
due to the presence of large amounts of scrap metal on the property. Two additional soil gas surveys were
conducted in February 1993 and February 1995 at finer grid spacings of 25 feet.

In 1991, using the results of the soil gas surveys to locate the soil borings, forty-six borings were located
and drilling at the suspected source areas. In February 1993 and February 1995, a total of 25 additional
soil borings were drilled to better determine the extent of contamination at the suspected source areas.
Each soil boring extended down to the water table to determine the verticle extent of contamination.

Sediment samples were taken at three locations in a wetlands area behind the AVX facility. The samples were
taken to determine the potential impact of the AVX property on the wetlands area.

Four upper and four lower aquifer groundwater monitoring wells were installed to collect data to determine
the extent of groundwater contamination in the upper and lower aquifers and the impact of the source areas on
the groundwater. The upper aquifer wells were installed at Clean's Wholesale, Olean Steel, McGraw-Edison,
and the Loohn's Dry Cleaners properties. The lower aquifer wells were installed at Olean Wholesale, Olean
Steel, Loohn's and Sandburg Oil.

In addition to the groundwater samples obtained from the 8 wells described above, samples were collected from
24 existing wells (13 upper aquifer; 11 lower aquifer wells), which were installed during previous studies of
the Site. In addition, groundwater grab samples were collected from the 25 soil borings, which were drilled
at the properties being investigated in 1993 and 1995.

A 72-hour pump test was conducted on the upper aquifer at the McGraw-Edison property in 1991. The results of
the test assisted in determining the feasibility of pumping contaminated groundwater from the aquifer for

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treatment.

Finally, pilot tests were preformed to determine whether vacuum enhanced recovery  (VER) or soil vapor
extraction with air sparging  (SVE/AS) would be an effective means of in-situ treatment of VOC contaminated
soils at areas of similar subsurface conditions in the study area.  SVE/AS and VER are two treatment
technologies possible under remedial Alternative 4 for the site.  See section below entitled "Description of
Remedial Alternatives" for an explanation of the two technologies.

A summary of the soil, sediment and groundwater samples, which were collected at the 13 properties which were
investigated during the SRI follows.

AVX

Soil gas, soil and groundwater samples were collected from the AVX properties in 1991 and 1993.

VOCs were detected at significant concentrations in the southern portion of the property at soil boring SB06
(see Figure 1).  The maximum concentrations detected were 1,1,1-TCA  (1,300,000 ppb), TCE  (500,000 ppb), PCE
(270,000 ppb), xylene (73,000 ppb), and cis-1,2 dichloroethene  (1,2-DCE) (45,000 ppb).  Lower levels of PCE
(610 ppb) and TCE (29 ppb) were detected in a sample from SB05.

Soil samples were collected from four other borings at the facility.  VOC contaminants were either not
detected in these samples or were detected at levels, which were below the numerical cleanup goals
established to meet the soil Remedial Action Objectives (RAOs) for the Site.  See the section on RAOs below.

Analysis of a groundwater grab sample taken from the bottom of soil boring SB06 revealed TCE (110,000 ppb),
1,1,1-TCA (360,000 ppb), 1,2-DCE (73,000 ppb), PCE (14,000 ppb), toluene (21,000 ppb), 1,1-DCE  (16,000 ppb),
1,1-DCA  (26,000 ppb), acetone (180,000 ppb), and xylene (3,900 ppb).  Each of these compounds exceeded its
State or federal Maximum Contaminant Level  (MCL) value  (i.e., drinking water standards).  See Table 1.

The soil and groundwater sample results confirmed that the AVX property is a source of VOC contamination to
the Clean Wellfield Superfund Site groundwater.

Alcas

Soil gas, soil and groundwater samples were collected from the Alcas property in 1991 and 1993.

Significant levels of VOCs were detected in the southern portion of the facility in soil samples from boring
SB07 (see Figure 1).  The following maximum soncentrations of VOCs were detected: TCE  (12,000 ppb) and PCE
(200 ppb).   In addition, 1,2-DCE (1,000 ppb), TCE (690 ppb), and vinyl chloride  (100 ppb) were detected in a
sample from boring SB04.

Soil samples were collected from five other borings at the facility.  VOC contaminants were either not
detected in samples from these borings or were detected at levels which were below the RAOs for the Site.

Analysis of a groundwater gab sample taken from the bottom of boring SB07 showed TCE  (8,800 ppb), 1,1,1-TCA
(500 ppb),  1,2-DCE  (640 ppb), and vinyl chloride (25 ppb).  Each of these compounds  exceeded its State or
federal MCL value.  See Table 1.

Chromium, copper and manganese were also detected in the soil from boring SB05 at 944,000 ppb,  93,600 ppb,
and 4,680,000 ppb, respectively.

The soil and groundwater sample results confirmed that the Alcas property is a source of VOC contamination to
the Clean Well Field Superfund Site groundwater.

McGRAW-EDISON

Soil gas, soil and groundwater samples were collected at the McGraw-Edison property in 1991 and 1993.

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Soil samples were collected from nine borings at the facility. VOCs were either not detected in soil samples
from those borings or were detected at low levels, which were below the RAOs for the Site.

TCE was detected at 860 ppb in a saturated (below the water-table) soil sample, which was collected from 24
to 26 feet below the ground surface. The sample was collected during the installation of the upper aguifer
well EW-3, which is located in the southeastern part of the property.

Analysis of the groundwater from well EW-3 showed 2,1000 ppb of TCE. A ground water grab sample from boring
SB08 revealed TCE and 1,2-DCE at 400 ppb and 51 ppb, respectively. Each compound exceeded its State or
federal MCL value. See Table 1.

Groundwater samples were also collected in December 1991 from upper aguifer monitoring wells A-l, C-l, and
EW-3. TCE was detected in samples from wells A-l, C-l, and EW-3 at concentrations of 40 ppb, 50 ppb, and
2,400 ppb, respectively, which exceeded the State and federal MCL of 5 ppb for this contaminant.

The saturated soil and groundwater sample results confirmed that the McGraw-Edison property is a source of
VOC contamination to the Clean Well Field Superfund Site groundwater.

LOOHN'S CLEANERS AND LAUNDERERS

Soil gas, soil and groundwater samples were collected from the Loohns property in 1991 and 1995.

Significant concentrations of VOCs were detected in the soil from borings SB09, SB12, SB47 and SB48. The
soil sampled from boring SB09 showed TCE (24,000 ppb), 1,2-DCE (59,000 ppb), PCE (91,000 ppb) and 2-butanone
(5,400 ppb). Soil samples from boring SB12 revealed PCE (38,000 ppb) and TCE (18,000 ppb). Samples from
boring SB47 revealed TCE (4,3000 ppb), PCE (370,000 ppb), 2-butoanone (2000,000 ppb) and TCE (400,000 ppb).
Finally, a soil sample from Boring SB48 showed 1,2-DCE (2,000 ppb), TCE (510 ppb) and PCE (18,000 ppb).

Soil samples were collected from two other borings at the facility. VOC contaminants were either not
detected in samples from these borings or were detected at levels which were below RAOs for the Site.

In January 1995, grab samples of groundwater from borings SB47 and SB48 revealed TCE (29 ppb) in the grab
boring SB48 and cis-l,2-DCE (23 ppb) in the grab sample from boring SB47.

In addition, a lower aguifer well was installed at boring SB47 and an upper aguifer well was installed at
boring SB48. Cis-1,2 DCE, TCE and PCE were detected at 6.3 ppb, 88 ppb and 1,800 ppb, respectively, in
groundwater from the upper aguifer well. PCE was detected at 11 ppb in the lower aguifer well. Each
compound exceeded its State or federal MCL value listed on Table 1.

The soil and groundwater sample results confirmed that the Loohn's property is a source of VOC contamination
to the Clean Well Field Superfund Site groundwater.

OLEAN STEEL

Soil gas, soil and groundwater samples were collected at Clean Steel in 1991, 1993, and 1995.

In 1991, four soil borings, an upper aguifer well, MW03, and a lower aguifer well, MW04, were drilled and
sampled at the locations shown in Figures 1 and 2. VOCs were not detected above the numerical cleanup goals
established to meet the RAOs for soil. Analysis of groundwater samples obtained from these wells in December
1991 did not reveal VOCs above the numerical cleanup goals established to meet the RAOs for groundwater.

In 1993, two additional soil borings were drilled at the locations shown on Figure 1. Low concentrations of
VOCs were detected.

In 1994, another groundwater sample was collected from MW04 by EPA as a follow up to the Removal Action which
was conducted in 1994 (See discussion of Site History on pages 4 and 5). Analysis of the sample revealed
arochlor-1245, a polychlorinated biphenyl compound, at a concentration of 5.4 ppb.

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In February 1995, one additional boring (SB44) was drilled down to the top of the upper aquifer. VOCs were
not detected above the numerical cleanup goals established to meet the RAOs for soil.

VOC contaminants were either not detected in the soil and groundwater samples from the Clean Steel property
or were detected at levels which were below the numerical cleanup goals established to meet the RAOs for the
Site. The soil and groundwater sample results indicate that the Clean Steel property is not a source of VOC
contamination.

In addition, after review of the groundwater flow data for the upper aguifer, EPA has also concluded that
Olean Steel is not hydraulically connected to the Olean Well Field Site. After discussion with NYSDEC, EPA
is however referring the PCB sample results to the NYSDEC for further action.

MASTEL FORD

Soil gas, soil and groundwater samples were collected at the Mastel Ford property in 1991, 1993, and 1995.

In 1991, three soil borings were drilled at the locations shown on Figure 1. Minimal concentrations of VOCs
were detected.

In 1993, two additional soil borings were drilled at the Mastel Ford facility. Minimal concentrations of
VOCs were detected.

In February 1995, a sixth soil boring SB45 was drilled down to the top of the upper aguifer. No significant
contamination was found.

Two groundwater grab samples were collected in 1993 from soil borings SB31 and SB32 and one grab sample was
collected in January 1995 from SB45. VOCs were not detected in the sample SB31. Minimal levels of VOCs were
detected in the grab samples from SB32 and SB45.

VOC contaminants were either not detected in the soil and groundwater samples from the property or were
detected at levels which were below the numerical cleanup goals established to meet the RAOs for the Site.
These results indicate that the Mastel Ford property is not a source of contamination to the Olean Well Field
Superfund Site groundwater.

SANDBURG OIL

Soil gas, soil and groundwater samples were collected at the Sandburg Oil property in 1991, 1993 and 1995.

In 1991, one soil boring (SB23) was drilled. Analysis of soil from the boring showed benzene (9 ppb) and
xylene (4,500 ppb). These VOCs are associated with petroleum and petroleum product derivatives.

In February 1995, a third soil boring (SB46) was advanced down to the top of the upper aguifer. A
groundwater grab sample collected from the boring revealed: ethylbenzene (540 ppb), xylene (157 ppb),
naphthalene (110 ppb) and 2-methylnapthalene (54 ppb). These VOCs are associated with petroleum and
petroleum product derivatives.

A lower aguifer monitoring well was installed in the borehold for SB46. Methylene chloride was the only VOC
detected (15 ppb) in the groundwater, which exceeded State and federal MCLs. However, the presence of the
compound in the groundwater was not attributed to Sandburg Oil, since it was not detected in the soil at
concentrations above the numerical cleanup goals established to meet the RAOs for the Site.

The soil and groundwater sample results confirmed Sandburg Oil as a source of petroleum-related contamination
to the Olean Well Field Superfund Site groundwater. Because CERCLA prevents EPA from using the Superfund to
clean up or oversee the cleanup of petroleum contamination, EPA is referring this property to the NTSDEC for
action under the State petroleum clean up program.

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GRIFFITH OIL

Soil gas, soil and groundwater samples were collected at the Griffith Oil property in 1991, 1993 and 1995.

During 1991, three soil borings were drilled and sampled at the locations shown on Figure 1. SVOCs were
detected from samples from soil boring SB24, namely, 2-methyl naphthalene (7,600 ppb) and phenanthrene (1,100
ppb) .

Two groundwater grab samples were collected at soil borings SB41 and SB42 during 1993. Minimal
concentrations of VOCs were detected.

In January 1995, soil boring SB49 was drilled down to the top of the upper aquifer. The location of SB-49 is
shown in Figure Gl-6 of the SRI/FS report. Analysis of the soil revealed elevated concentrations of benzene
(650 ppb), toluene (5,900 ppb) and xylene (23,000 ppb), which are associated with petroleum and petroleum
product derivatives.

Analysis of groundwater from an upper aguifer well DW6R-01, located on the Griffith Oil property, revealed
six VOCs, namely, methyl chloride (14 ppb), 1,1-DCA (6.1 ppb), cis-l,2-DCE (79 ppb), TCE (78 ppb), benzene
(220 ppb) and ethyl benzene (5.7 ppb).

Although nonpetroleum-related VOC contaminants were also detected (1,1-DCE, cis-l,2-DCE, and TCE) in the
groundwater, they were not attributed to Griffith Oil, since the VOCs, which were detected in the soil, were
below the numerical cleanup goals established to meet the soil RAOs for the Site. The sample results
therefore indicate that the Griffith Oil property is not a source of the VOC contamination.

The soil and groundwater sample results confirmed Griffith Oil as a source of petroleum-related contamination
to the Clean Well Field Superfund Site groundwater.

The NYSDEC is currently overseeing a spill response clean-up of fuel oil and gasoline spills at the Griffith
Oil facility.

FAY AVENUE/SCHAEFER STREET

Soil gas, soil and groundwater samples were collected in the immediate vicinity of Fay Avenue and Schaefer
Street in 1991 and 1993, in order to determine whether past alleged dumping activities may be a source of
contamination to the groundwater.

In 1991 and 1993, three soil boring were drilled and sampled at the locations shown on Figure 1. All VOC
concentrations were below the numerical cleanup goals established to meet the soil RAOs for the Site.

One groundwater grab sample was collected at soil boring SB40 during 1993. In this sample only, cis-l,2-DCE
was detected at 2 ppb.

The soil and groundwater sample results indicate that the Fay Avenue/Shaefer area is not a source of
contamination to the Clean Well Field Superfund Site groundwater. VOC contaminants were either not detected
in the soil and groundwater samples from the property or were detected at levels which were below the
numerical cleanup goals established to meet the RAOs for the Site.

OLEAN TILE

Soil gas, soil and groundwater samples were collected at the Clean Tile property in 1991 and 1993.

In 1991, four soil borings were drilled at the locations shown on Figure 1. VOCs were not detected with one
exception - acetone was detected (26 ppb) in sample SB13-0002.

In 1993, three additional soil borings were drilled at the locations shown on Figure 1. The following VOCs
were detected in soil samples from boring SB34: toluene (28,000 ppb); xylene (10 ppb), and 2-butanone (14

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ppb) .

Two groundwater grab samples were collected at soil borings SB35 and SB36 during the 1993 soil boring
program. VOCs were not detected in the samples.

EPA does not believe toluene is a source of contamination to the groundwater which reaches the municipal
wells. The compound was detected from 4 to 10 feet below the surface. No organic contaminants were detected
from 11 feet to 42 feet. The boring terminated at a depth of 42 feet; groundwater was not observed in the
borehole. Therefore, EPA believes that the toluene contamination is isolated and should not impact the
groundwater. However, because of the elevated level of toluene found, EPA will be evaluating this matter
further using its Site Assessment program.

In February 1995, a surface water sample was collected from the Allegheny River to determine if any
contamination emanating from the Clean Tile property was impacting the river. Results of the water sample
analysis indicated that no VOCs, including toluene, were detected.

The soil, groundwater and surface water sample results indicate that Clean Tile is not a source of
contamination to the Clean Well Field Superfund Site groundwater or the Allegheny River.

CLEAN WHOLESALE

Soil gas, soil and groundwater samples were collected from the Clean Wholesale property in 1991 and 1993.

In 1991, four soil borings were sampled at the locations shown on Figure 1. VOCs were detected at
concentrations, which were below the numerical cleanup goals established to meet the RAOs for the Site.

In 1993, soil samples were collected from one additional soil boring. No VOCs were detected.

Groundwater samples were collected in December 1991 from upper aguifer monitoring well MW02 and lower aguifer
monitoring well MW01. VOCs were not detected in the samples from either well.

One groundwater grab sample was collected at soil boring SB43 in 1993. TCE was detected at 7 ppb.

The soil and groundwater sample results indicate that Clean Wholesale is not a source of contamination to the
Olean Well Field Superfund Site groundwater. VOC contaminants were either not detected in soil samples from
the property or were detected at levels which were below the numerical cleanup goals established to meet the
RAOs for the Site.

PRIVATE DUMP

Soil gas and soil samples were collected from the Private Dump in 1991, in order to determine whether past
alleged uncontrolled dumping activities may be a source of contamination to the groundwater.

In 1991, two soil borings (SB25 and SB26) were drilled and sampled at the locations shown on Figure 1. Three
sediment samples (SD01, SD02, and SD03) were also collected from a swampy area. VOCs were not detected in
the soil with one exception - toluene (6 ppb) and 2-butanone (60 ppb) were detected at boring SB26. PCE was
detected in the sediment at 10 ppb.

No soil samples were collected in 1993.

The soil sample results indicate that the Private Dump is not a source of contamination to the Olean Well
Field Superfund Site groundwater.

BORROW PIT

Soil gas, soil and sediment samples were collected from the Borrow Pit in 1991 and 199, in order to determine
whether past alleged uncontrolled dumping activities may be a source of contamination to the groundwater.

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In 1991, one soil boring (SB28) was sampled at the location shown in Figure 1. VOCs were not detected.

Three sediment samples (SD4, SD5, and SD6) were also collected from a pounded area (see Figure 1) in 1991.
Minimal levels of VOCs were detected.
In 1993, one additional soil boring (SB39) was drilled at the location shown on Figure 1.
detected with one exception - methylene chloride (12 ppb).
VOCs were not
One groundwater grab sample was collected from soil boring SB39 in 1993.
ppb.
The only VOC detected was TCE at 13
The soil and groundwater sample results indicate that the Borrow Pit is not a source of contamination to the
Clean Well Field Superfund Site groundwater. VOC contaminants were either not detected in the soil samples
from the property or were detected at levels which were below the numerical cleanup goals established to meet
the RAOs for the Site.

BACKGROUND SOIL SAMPLES

In 1991, two soil borings (SB29 and SB30) were drilled and sampled off-Site at the intersection of King and
Seneca Streets, in the City of Clean. The samples were collected as background samples to establish a
baseline upon which the Site data could be compared. PCE and methylene chloride were detected at 8 ppb and
10 ppb, respectively, in a soil sample from boring SB29. Also, inorganic analysis of the samples indicated
metal concentrations were within background concentrations of metals for the soils in the eastern United
States.

SITE-WIDE GROUNDWATER SAMPLES

Groundwater samples were also collected from twenty-four existing monitoring wells on Site in December 1991,
November 1994, and March 1995. The wells included: A-l, C-l, CW-1B, CW-3B, CW-4, CW-4A, CW-5, CW-5A, CW-7A,
CW-9A, CW-10, CW-10A, CW-12, CW-12A, CW-13, CW-13A, CW-15A, CW-18, CW-18A, well located at S&S Car Cleaners,
DW6R-01, Alcas D-2, AVX-5D, and MEC-A-2. See Figure 2 for the well locations.

Maximum concentrations of VOCs detected between 1989 and 1995 in samples from several of the existing wells
were as follows:

Contaminant
TCE

1,1,1-TCA

Cis-1,2 DCE

PCE
Monitoring
Well
Alcas D2
AVX-5D
CW-7A
CW-10
MEC-A2
AVX-5D
CW-7A
AVX-5D
CW-18A
CW-18A
Concentration
Detected
6,500 ppb
2,000 ppb
590 ppb
340 ppb
170 ppb
7,200 ppb
7 ppb
15,000 ppb
41 ppb
3.1 ppb
Federal
MCL
5 ppb
C-l
CW-9A
CW-18A
S&S Cleaners
200 ppb
CW-18A
70 ppb

5 ppb
State
MCL
5 ppb
40 ppb
400 ppb
1,400 ppb
39 ppb
5 ppb
15 ppb
5 ppb

5 ppb
In addition, bis (2-Ethylhexyl) phthalate, an SVOC, was detected in CW-5 (190 ppb) and CW-12 (560 ppb).
State and federal MCLs, were exceeded for Chromium in samples from the existing wells CW-12 and CW-12A (1,720
ppb). Chromium was detected in CW-12 (22,500 ppg) and CW-12A (1,720 ppg). The federal and State MCL values
for chromium at 100 ppb and 50 ppb, respectively. However, analysis of the groundwater, before it is treated
at municipal wells 18M and 38M, has not revealed chromium or any other inorganic contaminants. Because of
the proximity of the monitoring wells to well 18M and the high concentration of chromium detected, EPA
believes that chromium also be added to the list of contaminants which are analyzed for as part of the Site

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Monitoring Plan, which was required as part of the remedy selected for the September 24, 1985 ROD.

UPPER AQUIFER PUMP TEST

A 72-hour constant rate pumping test was performed on well EW-3 in January 1992 at the McGraw-Edison facility
to determine the transmissivity and storativity of the upper aguifer in the Clean Well Field. Results from
this test will be used in designing a system for treating contaminated groundwater from the upper aguifer.

DIRECTION OF GROUNDWATER FLOW

Groundwater water level measurements were collected in selected upper aguifer and lower aguifer monitoring
wells located throughout the Site on February 13, 1992, February 27, 1992, and March 26, 1992.

Water-level measurements were also collected from existing monitoring wheels in the vicinity of Haskell Creek
and used in the preparation of potentiometric surface maps, which are included in the SRI report.

The potentiometric surface map for the upper aguifer indicates that lines of egual elevation for the upper
aguifer generally parallel the Allegheny River. This indicates that groundwater flow is towards the river
from both sides of the river valley. In general, the horizontal component of groundwater flow is consistent
with the flow pattern for the upper aguifer described in the RI/FS conducted in 1984.

Groundwater in the lower, or City Aguifer, flows from east to west. Flow conditions in the lower aguifer
have been altered since the 1985 RI in that during the RI, the municipal wells were inactive and the AVX
production well was pumping at approximately 200 gpm. Since 1990, the three municipal wells have been
pumping at a combined rate of 2,150 gpm and the AVX production well has been decreased to approximately 50
gpm due to decreased demand. The principle difference between the groundwater flow regime at the time of the
1985 RI report and the March 1992 SRI potentiometric maps, is the increased hydraulic gradient in the study
area which resulted from the pumping stress imposed by the now active municipal wells. A figure identifying
the capture zones is included in the SFS report.

CULTURAL RESOURCE SURVEY

In April 1992, an EPA contractor conducted a Stage 1A Cultural Resources Survey (CRS-1A) of the Site which
entailed a review of the historic maps and archival records on file at the New York State Office of Parks and
Recreation, Historic Division; the Cattaraugus County Historical Society; and the Assessor's and Engineer's
Office of the City of Clean. The contractor also reviewed previous cultural resource surveys of the region
and conducted on-Site reconnaissance. A copy of the CRS-1A report is included in the Administrative Record
for the Site, which is located in the public repositories listed on page 2.

After review of the CRS-1A report and pursuant to the National Historic Preservation Act, EPA has decided
that additional cultural investigations must be completed at the Alcas and Loohn's facilities. Specifically,
the Alcas and the Loohn's have been determined to be sensitively for the discovery of cultural resources. As
such, a Stage IB Cultural Resources Survey will be completed early in the remedial design. If, based on the
results of the CRS report, it is necessary to carry out additional CRS work at the site, it will be completed
during the remedial design to meet the reguirements of the National Historic Preservation Act.

SUMMARY OF SITE RISKS

Based upon the results of the SRI, 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 if no remedial actions 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. Exposure Assessment—estimates

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the magnitude of actual and/or potential human exposures, the frequency and duration of these exposures, and
the pathways (e.g., ingesting contaminated well-water) by which humans are potentially exposed. Toxicity
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
quantitative assessment of site-related risks.

EPA's baseline risk assessment addressed the potential risks to human health by identifying several potential
exposure pathways by which the public may be exposed to at the site under current and future land-use
conditions. The contaminants of concern which were detected in the groundwater and the soild at each of the
properties investigated are listed in Tables 2 and 3, respectively.

The baseline risk assessment evaluated the health effects which would result from exposure to groundwater
contamination through three pathways, namely, ingestion, dermal contact and inhalation of volatilized
contaminants during showering. The groundwater exposure scenarios are presented in Table 4.

Risks due to contaminants in the surface and subsurface soil were calculated for exposure as a result of
ingestion or inhalation of contaminants by construction workers. A residential exposure scenario was not
calculated because all of the properties studied during the SRI/FS are zoned and operated as either
industrial or commercial, and it is expected that such use would continue in the future.

Risk due to dermal contact with soils was assessed qualitatively due to the absence of dermal absorption
factors for all Site-related containments except cadmium. Cadmium was found at five of the 13 properties
investigated. However, of the five properties the highest concentration of cadmium detected was just above 4
ppm, which would not pose an unacceptable risk.

Under current EPA guidelines, the likelihood of carcinogenic (cancer-causing) and noncarcinogenic effects due
to exposure to site chemicals are considered separately. It was assumed that the toxic effects of the
site-related chemicals would be additive. Thus, carcinogenic and noncarcinogenic risks associated with
exposures to individual compounds of concern were summed to indicate the potential risks associated with
mixtures of potential carcinogens and noncarcinogens, respectively.

Noncarcinogenic risks were assessed using a hazard index (HI) approach, based on a comparison of expected
contaminant intakes and safe levels of intake (Reference Doses). Reference does (RfDs) have been developed
by EPA for indicating the potential for adverse health effects. the reference doses for the compounds of
concern at the site are presented in Tables 7 and 8. RfDs, which are expressed in units of
milligrams/kilogram-day (mg/kg-day), are estimates of daily exposure levels for humans which are thought to
be safe over a lifetime (including sensitive individuals). Estimated intakes of chemicals from environmental
media (e.g., the amount of a chemical ingested from contaminated drinking water) are compared to the RfD to
derive the hazard quotient for the contaminant in the particular medium. The HI is obtained by adding the
hazard quotients for all compounds across all media that impact a particular receptor population.

An HI greater than 1.0 indicates that the potential exists for noncarcinogenic health effects to occur as a
result of Site-related exposures. The HI provides a useful reference point for gauging the potential
significance of multiple contaminant exposures within a single medium or across media. A summary of the
noncarcinogenic risks associated with these chemicals across various exposure pathways is found in Tables 5
and 6.

Potential carcinogenic risks were evaluated using the cancer slope factors developed by EPA for the
contaminants of concern. Cancer slope factors (SFs) have ben developed by EPA's Carcinogenic Risk
Assessment Verification Endeavor for estimating excess lifetime cancer risks associated with exposure to
potentially carcinogenic chemicals. SFs, which are expressed in units of (mg/kg-day)-1, are multiplied by
the estimated intake of a potential carcinogen, in mg/kg-day, to generate an upper-bound estimate of the
excess lifetime cancer risk associated with exposure to the compound at that intake level. The term "upper
bound" reflects the conservative estimate of the risks calculated from the SF. Use of this approach makes
the underestimation of the risk highly unlikely. The SF for the compounds of concern are presented in Tables
7 and 8.

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For known or suspected carcinogens, EPA considers excess upper-bound individual lifetime cancer risks of
between 10-4 to 10-6 to be acceptable. This level indicates that an individual has no greater than a one in
ten thousand to one in a million chance of developing cancer as a result of site-related exposure to a
carcinogen over a 70-year period under specific exposure conditions at the site.

The results of the baseline risk assessment indicate that ingestion of and dermal contact with untreated
groundwater at the Site poses unacceptable risks to human health. Cancer risks due to ingestion of
groundwater were determined to be approximately one-in-one-hundred for adults and young children (1.49 x 10-2
and 1.3 x 10-2, respectively) and six-in-one-thousand (5.94 x 10-3) for older children. Noncarcinogenic His
for these exposure groups were 3.36 for adults, 14.7 for young children and 6.73 for older children. The
aforementioned cancer and non-cancer risks are referenced in Table 5.

Cancer risks due to dermal contact with groundwater contaminants were determined to be 2.35 x 10-3 for
adults, 9.21 x 10-4 for young children and 6.68 x 10-4 for older children. The HI for each group was less
than one.

Cancer and noncancer risks due to inhalation of contaminants from untreated groundwater during showering were
within EPA's acceptable risk range. Cancer risks for adults were determined to be 6.38 x 10-5 for adults and
5.98 x 10-5 young children, and 2.73 x 10-5 for older children. The HI for each group was less than one.

Risks were also calculated for ingestion and inhalation of surface and subsurface soil contaminants by
construction workers. The risks were calculated for a two year exposure period and are referenced in Table
6. Cancer risks were found to be acceptable for each of the thirteen properties investigated. Noncancer
risks were also found to be acceptable at twelve of the thirteen properties with the exception of
McGraw-Edison. A minimal non-cancer risk (HI of 1.14) due to soil ingestion was calculated for
McGraw-Edison. The elevated risk is due mainly to arsenic.

The cumulative upper-bound cancer risks for exposure to untreated groundwater at the Site are 1.73 x 10-2 for
adults, 1.39 x 10-2 and 6.64 x 10-3 for older children, which are greater than the acceptable risk range of
10-4 to 10-6. The estimated total risks are primarily due to trichloroethene, which contributed
significantly to the carcinogenic risk calculations and was attributable releases of the contaminant onto the
ground and eventually into the groundwater.

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.

EPA conducted an assessment of a wetlands area, which is located to the south of the AVX facility. The
assessment was conducted to determine if the wetlands area overlapped the area of contamination at the AVX
facility. Sediment samples were taken to determine if AVX was impacting the wetlands area.

The wetlands area, which encompasses approximately 18.5 acres, is bordered to the north by Seneca Avenue, he
south by a Conrail right-of-way and AVX, the east by Dugan Road and the west by AVX. Three sediment
samples were collected from the wetlands area south of the AVX property and north of the Conrail railroad
tracks. Analysis of the samples did not reveal any VOC contamination. Several semi-volatile organic
compounds (SVOCs) were detected, but were attributed to the Conrail railroad tracks. Also the SVOCs were not
determined to be impacting the groundwater.

No other studies were conducted to assess other ecological risks since the Site is located in an urban
commercial/industrialized area. The three other source areas, Alcas, McGraw-Edison and Loohn's, which are

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included as part of the Site, are developed properties with lawns, planting, and one or more buildings with
asphalt entry ways and parking areas. There are no significant habitats present at the Site which could
potentially support indigenous wildlife receptor species. These properties, however, may provide a habitat
for various non-native species which have adapted to highly urbanized areas (e.g., rats, starlings and
pigeons).

Uncertainties

The procedures and inputs used to assess risks in this evaluation, as in all such assessments, are subject to
a wide variety of uncertainties. In general, the main sources of uncertainty include:

! environmental chemistry sampling and analysis
! environmental parameter measurement
! fate and transport modeling
! exposure parameter estimation
! toxicological data.

Uncertainty in environmental sampling arises in part from the potentially uneven distribution of chemicals in
the media sampled. Conseguently, there is significant uncertainty as to the actual levels present.
Environmental chemistry-analysis error can stem from several sources including the errors inherent in the
analytical methods and characteristics of the matrix being sampled.

Uncertainties in the exposed assessment are related to estimates of how often an individual would actually
come in contact with the chemicals of concern, the period of time over which such exposure would occur, and
in the models used to estimate the concentrations of the chemicals of concern at the point of exposure.

Uncertainties in toxicological data occur in extrapolating both from animals to humans and from high to low
doses of exposure, as well as from the difficulties in assessing the toxicity of a mixture of chemicals.
These uncertainties are addressed by making conservative assumptions concerning risk and exposure parameters
throughout the assessment. As a result, the Risk Assessment provides upper-bound estimates of the risks to
populations near the site, and is highly unlikely to underestimate actual risks related to the site.

More specific information concerning public health risks, including a guantitative evaluation of the degree
of risk associated with various exposure pathways, is presented in the Risk Assessment Report. The report is
part of the Administrative Record for the Site, which may be found in the public repositories listed on page
2.

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

REMEDIAL ACTION OBJECTIVES

Remedial action objectives are specific goals to protect human health and the environment. These objectives
are based on available information and standards such as applicable or relevant and appropriate reguirements
(ARARs), To Be Considered (TBC) guidance values, and risk-based levels established by th risk assessment.

Remedial action objectives for the Site were developed for two contaminated media - groundwater and soil.
Both sets of objectives are designed to restore the upper and lower aguifers to their beneficial use a source
of drinking water.

Groundwater objectives include: 1) removal and/or control of the sources of contamination to the groundwater;
and, 2) removal of sources of contamination already in the groundwater.

Soil objectives include the elimination of leaching of contaminants of concern from the soil at each of the
source areas into the groundwater.

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In order to determine which source areas require remediation, EPA compared contaminants in the groundwater
and soil at all of the properties to various criteria. For soil, EPA used the NYSDEC's Technical and
Administrative Guidance Memorandum (TAGM) cleanup numbers, which represent concentrations of VOCs which will
not leach from the soil and dissolve into the groundwater at levels which are above federal or State MCL
concentrations. For groundwater, EPA used federal and State MCLs. Facilities where soil and groundwater
contamination levels exceeded these criteria were targeted for remediation. These criteria, which will also
be used as cleanup goals, are presented in Table 1.

As a result of this analysis, EPA has determined that the AVX, Alcas, Loohn's and McGraw-Edison properties
are sources of contamination to the groundwater and therefore require remediation.

For the AVX and Loohns source areas, the remediation will be phased. First, a soil cleanup will take place,
after which EPA will monitor the groundwater to determine if VOC concentrations are decreasing at a rate
sufficient to meet the goal of aquifer restoration in a reasonable time frame. If necessary, EPA will
install a groundwater pump and treat system at the two source areas to facilitate aquifer restoration.

Because of the close proximity of the Alcas source area to municipal well 18M, remediation of the
contamination will only consist of a soil remediation phase. Additional groundwater remediation is not
necessary since any groundwater which is contaminated by the property is captured and treated by an air
stripper, which is currently operating at the municipal well.

Remediation of the McGraw-Edison facility will only consist of a groundwater phase, since the soil was not
found to be contaminated. (The contamination in the saturated soil zone will be addressed by the groundwater
cleanup.)

The Sandburg Oil and Griffith Oil properties were also determined to be sources of groundwater contamination,
although the contamination was found to be petroleum-related. As such, CERCLA prohibits the use of Superfund
Trust Fund monies to clean up or to oversee the clean up of the petroleum contamination. EPA will therefore
refer the contamination at these properties to the NYSDEC for action under the State's petroleum cleanup
program.

DESCRIPTION OF REMEDIAL ALTERNATIVES

CERCLA §121(b)(1), 42 U.S.C. §9621(b)(1), mandates that a remedial action be among other things protective of
human health and the environment and cost-effective, and must 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).

Discussed below are the six remedial alternatives which were evaluated in detail for addressing the
contamination associated with the Clean Well Field Site. The time to implement a remedial alternatives
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 at the site.

Alternative 1 - No Action

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Because this alternative would result in contaminants being left on-Site above health based levels, CERCLA
Section 121(c),  42 U.S.C. §9621(c) requires that the Site be reviewed every 5 years.

There are no capital or operation and maintenance costs associated with this alternative.

Construction Time: Since this is a no action alternative, no time would be required for construction.

Alternative 2 - Institutional Controls and Access Control

This alternative includes educational programs, such as public meetings and presentations, designed to
increase public awareness about the hazards present in the identified source areas.  In addition, this
alternative includes the implementation of institutional controls, such as deed restrictions, and other
notices, contractual agreements,  local law or ordinances or other governmental actions for the purpose of
restricting installation and use of groundwater wells throughout the Site, ensuring that excavation of soils
in or near an identified soil source area is accompanied by implementation of a worker/local area health and
safety plan and appropriate off-Site treatment and/or disposal of contaminated soils, and ensuring that the
property remains for industrial use.  Institutional controls restricting groundwater use, land use and
excavation would be required until the groundwater has been demonstrated to meet RAOs as set forth in Table
1.

Because this alternative would result in contaminants being left on-Site above health-based levels, CERCLA
requires that the Site be reviewed every five years.

Capital, present worth, and operation and maintenance costs for this alternative are summarized in Table 9.
Costs were developed by source area.  Capital costs would include fencing and manpower to obtain land access
use and deed restrictions and to educate the public on the level and extent of contamination at the Site.
Operation and maintenance costs would include Site-wide sampling and analysis of the groundwater for thirty
years.

Construction Time: this alternative could be implemented within 3 to 6 months.

Alternative 3 - Capping and Groundwater Treatment

This alternative would involve the following major elements:

!       Capping of contaminated soil.
!       Implementation of land use/access restrictions to maintain integrity of the cap and groundwater use
       restrictions.
!       Monitoring programs at selected monitoring wells and at the Clean Well Field municipal wells.
!       Implementation of groundwater treatment if capping does not sufficiently remediate the groundwater.
!       Conducting a 5-year review.

Stage 1

Alternative 3 would require capping of impacted soils at the soil source areas with a clay and soil cap.
This would reduce further migration of the contamination from the soil to the groundwater. Land use and deed
restrictions and groundwater monitoring, as described for Alternative 2, would also be implemented.  Land use
restrictions would prevent any activities which would adversely affect performance of the cap.  Deed
restrictions would also be imposed to prevent the installation of private drinking water wells.

The soil source areas would be covered with a clay cap.  The surface area capped would be approximately 9,800
square feet at Alcas, approximately 3,200 square feet at AVX and approximately 6,000 square feet at Loohns.
Since no soil contamination was detected at the McGraw-Edison property, a cap would not be necessary.

Stage 2

After capping is completed at Alcas, AVX and Loohns, EPA will assess the effect on the groundwater after

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waiting the time for three pore volumes of groundwater to travel from all three source area properties to the
municipal wells. It is estimated that it will take four years for the three pore volumes of groundwater to
pass or flush from the source areas to the municipal wells. Therefore, groundwater monitoring will be
reguired. The effectiveness of the remediation will be evaluated at four year intervals. If it is
determined that the City Aguifer still contains contaminant concentrations above drinking water standards and
if it is determined that the remedial source are continues to effect the groundwater entering the City
Municipal wells 18M, 37M and 38M, a groundwater pump-and-treat system may be installed at either AVX or the
Loohns Dry Cleaners source areas. However, such treatment will not be necessary at the Alcas source area due
to the close proximity of the source area to municipal well 18M.

If groundwater treatment is determined to be necessary for the AVX source area, EPA will also evaluate the
impact of a groundwater pump and treat system on the wetlands area. This evaluation will weigh the need for
reducing contaminant concentrations in the groundwater with any potentially adverse affect on the wetlands
area.

Because this alternative would result in contaminants being left on-Site above health-based levels, CERCLA
reguires that the Site be reviewed every five years.

Capital, present worth and operation and maintenance costs for this alternative are summarized in Table 9.
Costs were developed by source area. Capital costs were developed for the construction of a cap at each
source area and construction of a groundwater collection and treatment systems at the Loohns and AVX source
areas. The capital cost for the Alcas source area does not include groundwater treatment, since contaminated
groundwater from the source area will be captured and treated by the air stripper at municipal well 18M. The
capital cost for the Alcas source area includes only construction of the cap. Operation and maintenance and
present worth costs for AVX and Loohn's were developed for maintenance of a cap and groundwater treatment
system for thirty years and Site-wide sampling and analysis of the groundwater for thirty years.

Construction Time: Capping of the source area properties could be implemented within 1 year. Groundwater
treatment, if determined to be necessary, could be implemented within 9 to 12 months after the design of the
groundwater extraction and treatment system has been completed.

Alternative 3A - Groundwater Pumping and Treating

This alternative would involve the following elements:

! Groundwater treatment at the source areas
! Implement groundwater use restrictions.

Under this alternative, groundwater recovery system would be installed. Contaminants in the recovered
groundwater would be removed by an air stripping system. The treated groundwater would be treated further,
if necessary, with granulated activated carbon (GAG) and discharged to the City of Clean sewer system and
ultimately to the Publicly Owned Treatment Plant. If necessary to meet New York state air emission limits,
the off-gas from the air stripping system would be treated with vapor phase GAG.

This alternative would also involve deed restrictions which would be imposed to prevent the installation of
private drinking water wells.

Capital, present worth and operation and maintenance costs for this alternative are summarized in Table 9.
Operation and maintenance and present worth costs are for Site-wide sampling and analysis of the groundwater
for thirty years.

Construction Time: Groundwater recovery/treatment systems, if determined to be necessary, could be
constructed at the AVX or Loohns properties within 9 to 12 months. Groundwater treatment at McGRAW-EDISON,
could be implemented within 3 to 6 months, since an air stripper with sufficient excess capacity already
exists on site. McGraw-Edison installed the air stripper in the early 1980's to treat groundwater for
industrial use on-Site.

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Alternative 4 - Soil Vapor Extraction (SVE/Vacuum Enhanced Recovery (VER) and Groundwater Treatment

This alternative consists of implementing the following:

! SVE/VER of contaminated soil.
! Monitoring programs at selected monitoring wells and at Clean Well Field municipal wells.
! Implementation of groundwater treatment if SVE does not result in sufficiently lower contaminant
concentrations in the ground water.
! Implement groundwater use restrictions

Stage 1

Two different types of in-situ treatment systems were considered for treating VOC contaminated soil: SVE
with Air Sparging (SVE/AS) and Vacuum Enhanced Recovery (VER)

Evaluations of the Alcas and AVX properties determined that a SVE/AS treatment system would not be effective.
However, pilot tests were conducted at the source areas in 1994 and the tests confirmed that vacuum enhanced
recovery (VER) could effectively desorb VOCs from the contaminated subsurface at both properties. Additional
data needs to be collected for the Loohns property in order to determine whether SVE/AS or VER would be the
more effective means of soil treatment. EPA intends to collect these data during a pilot test, which would
be conducted as part of a remedial design for the Loohn's source area.

This remedial alternative would also include the imposition of deed restrictions that would prevent the
installation of private drinking water wells.

Descriptions of VER and SVE/AS are provided as follows:

A VER system uses negative air pressure which is applied to a series of recovery wells. The negative
pressure, which is generated by a high vacuum pump, causes the movement of soil vapor and some groundwater
towards the wells for recovery. The vapor recovery causes desorption (removal of contaminants which are
adsorbed onto soil particles) and volatilization of VOCs by continuously removing contaminated vapors and
forcing clean air into the contaminated areas. An off-gas treatment system will use granulated activated
carbon (GAG) to remove contaminants which are above federal and New York State air emission levels. Any
groundwater which is recovered with the soil vapor, would also be treated with GAG prior to discharge to the
City sewer system.

The air bubbles, which are formed, traverse horizontally and vertically through the water column. Volatile
compounds, which are exposed to the sparged air, volatilize intot he gas phase and are carried into the
vadose zone where they are captured by the vapor recover system. An off-gas treatment system will use GAG to
remove contaminants which are above federal and New York State air emission levels. Any groundwater which is
recovered with the soil vapor, would also be treated with GAG prior to discharge to the City sewer system or
to the surface water with a New York State Pollution Discharge Elimination System permit.

Essentially, a VER system works by applying a higher vacuum to the subsurface than a SVE/AS system. The
higher vacuum allows VER to operate more effectively than SVE/AS in varied geological settings.

The SVE/VER system would be operated until contaminant levels in the soil vapor and water effluents cease to
decline and remain constant at a negligible rate. At which time, the system would be shut off. EPA expects
that the soil cleanup objectives in Table 1 will be met.

Stage 2

After soil remediation is completed at Alcas, AVX and Loohns, EPA will assess the affect on the groundwater

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after waiting four years to allow three pore volumes of groundwater to pass, or flush through, from the
source areas to the municipal wells. The groundwater guality will be monitored and the effectiveness of the
remediation will be evaluated at four-year intervals. If it is determined that the City Aguifer still
contains contaminant concentrations above drinking water standards and if it is determined that the
remediated source are continues to affect the groundwater entering the City Municipal wells 18M, 37M and 38M,
a groundwater pump-and-treat system may be installed at either the AVX or the Loohn's Dry Cleaners source
areas. However, additional groundwater treatment will not be necessary at the Alcas source area due to the
close proximity of the source area to municipal well 18M.

If groundwater treatment determined to be necessary for the AVX source area, EPA will also evaluate the
impact of a groundwater pump and treat system on the wetlands area. This evaluation will weigh the need for
reducing contaminant concentrations in the groundwater with any potentially adverse affect on the wetlands
area.

Capital, present worth, and operation and maintenance cost for this alternative are summarized in Table 9.
Costs were developed by source area. Capital costs were developed for the construction of SVE/VER systems at
the source areas and construction of groundwater collection and treatment systems at the Loohns and AVX
source areas. Because contaminated groundwater from the source area will be captured and treated by the air
stripper at municipal well 18M, the capital cost for the Alcas source area does not include groundwater
treatment. Operation and maintenance and present worth costs were developed for maintenance of an SVE/VER
system for five years and groundwater treatment system for thirty years for AVX and Loohn's and Site-wide
sampling and analysis of the groundwater for thirty years.

Constrruction Time: Installation of SVE/VER system at the source area properties could be implemented within
one year. Groundwater treatment, if determined to be necessary, could be contructed within 9 to 12 months
after the date the decision is made.

Alternative 5 - Soil Removal And Groundwater Treatment

Alternative 5 would consist of implementing the following:

! Excavation and removal of contaminated soil above and below the water table.
! Off-Site low temperature desorption of soil contaminants (if necessary).
! Monitoring programs at selected monitoring wells and at Clean Well Field municipal wells.
! Implementation of groundwater treatment if excavation and removal of the contaminated soil does not
sufficiently lower contaminant concentrations in the groundwater.
! Implement land use/access and groundwater use restrictions.

Stage 1

The soil source area(s) would be excavated and the soils tested to determine if the excavated soils are
classified as RCRA hazardous waste material. If hazardous, the soils would be transported off-Site to a
facility for low temperature desorption of soil contaminants. If not hazardous, the soils would be disposed
of at a local landfill. Clean fill material would be brought in to restore each of the areas to grade.
Confirmatory soil sampling and analyses would be conducted during soil excavation to ensure that all soils
with contaminant levels exceeding the RAQs as set forth in Table 1 are removed.

Until restoration of the excavated areas is complete, land use/access restrictions would be placed on the
source area restricting current and future use. These actions would also include the imposition of deed
restrictions that would be imposed to prevent the installation of private drinking water wells. During all
phases of the soil removal, it would be necessary to implement dust and volatile emission control measures,
soil erosion, and sediment control measures.

Stage 2

After soil remediation is completed at Alcas, AVX and Loohns, EPA will assess the affect on the groundwater
after waiting four years to allow three pore volumes of groundwater to pass, or flush through, from the

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sources areas to the municipal wells. The groundwater quality will be monitored and the effectiveness of the
remediation will be evaluated at four-year intervals. If it is determined that the City Aquifer still
contains contaminant concentrations above drinkinq water standards and if it is determined that the
remediated source area continues to affect the qroundwater enterinq the City Municipal wells 18M, 37M and
38M, a qroundwater pump-and-treat system may be installed at either the AVX or the Loohn's Dry Cleaners
source areas. However, additional qroundwater treatment will not be necessary at the Alcas source area due
to the close proximity of the source area to municipal well 18M.

If qroundwater treatment is determined to be necessary for the AVX source area, EPA will also evaluate the
impact of a qroundwater pump and treat system on the wetlands area. This evaluation will weiqh the need for
reducinq contaminant concentrations in the qroundwater with any potentially adverse effect on the wetlands
area.

Capital, present worth and operation and maintenance costs for this alternative are summarized in Table 9.
Costs were developed by source area. Capital costs were developed for the removal of contaminated soil at
each source area and construction of qroundwater collection and treatment systems at the Loohn's and AVX
source areas. Because contaminated qroundwater from the source area will be captured and treated by the air
stripper at municipal well 18M, the capital cost for the Alcas source area does not include qroundwater
treatment. Operation and maintenance and present worth costs were developed for maintenance of the
qroundwater treatment systems for thirty years for AVX and Loohn's and Site-wide samplinq and analysis of the
qroundwater for thirty years.

Construction Time: Removal of contaminated soil from Alcas, AVX and Loohns could be implemented within one
year. Groundwater treatment, if determined to be necessary, could be constructed within 1 year after the
date the decision is made.

SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES

In selectinq a remedy, EPA considers the factors set forth in CERCLA §121, 42 U.S.C. §9621, by conductinq a
detailed analysis of the viable remedial alternatives pursuant to the National Continqency Plan (NCP), 40 CFR
§ 300.430 (e) (9) (iii) and OSWER Directive 9355.3-01 entitled "Guidance for Conductinq Remedial Investiqations
and Feasibility Studies Under CERCLA." The detailed analysis consists of an assessment of the individual
alternatives aqainst each of nine evaluation criteria and a comparative analysis focusinq upon the relative
performance of each alternative aqainst those criteria.

The followinq "threshold" criteria must be satisfied by any alternative in order to be eliqible for
selection:

1. Overall protection of human health and the environment addresses whether or not a remedy provides
adequate short-and lonq-term protection and describes how risks posed throuqh each exposure pathway (based on
a reasonable maximum exposure scenario) are eliminated, reduced, or controlled throuqh treatment, enqineerinq
controls, or institutional controls.

2. Compliance with ARARs addresses whether or not a remedy would attain all of the applicable (legally
enforceable), or relevant and appropriate (requirements that pertain 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 invokinq a waiver.

The followinq "primary balancinq" criteria are used to make comparisons and to identify the major trade-offs
between alternatives:

3. Lonq-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 qoals have been met. It also
addresses the maqnitude and effectiveness of the measures that may be required to manaqe the risk posed by
treatment residuals and/or untreated wastes.

4. Reduction of toxicity, mobility, or volume via treatment refers to a remedial technoloqy's expected

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ability to reduce the toxicity, mobility, or volume of hazardous substances, pollutants or contaminants at
the site.

5. Short-term effectiveness addresses the period of time needed to achieve protection and any adverse
impacts on human health and the environment that may be posed during the construction and implementation
periods until cleanup goals are achieved.

6. Implementability refers to the technical and administrative feasibility of a remedy, including the
availability of materials and services needed.

7. Cost includes estimated capital and operation and maintenance costs, and the present-worth costs.

The following "modifying" criteria were considered fully after the formal public comment period on the
Proposed Plan was completed:

8. State acceptance indicates whether, based on its review of the RI/FS and the Proposed Plan, the State
supports, opposes, and/or has identified any reservations with the preferred 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.

The following is a comparative analysis of these alternatives by source area, which is based upon the
evaluation criteria noted above.

ALCAS SOURCE AREA

This subsection presents the comparative analysis of alternatives for the Alcas source area. Available data
for this source area indicate that the upper aguifer cannot effectively be pumped, and that the lower aguifer
is within the capture zone of the municipal wells. Therefore, groundwater treatment via pump-and-treat
(Alternative 3A and Stage 2 of Alternatives 3, 4 and 5) is not considered applicable for the Alcas source
area.

Alternative 4, as discussed in this subsection, does not include soil vapor extraction with air sparging
(SVE/AS). A field investigation conducted in July 1994 determined that a SVE/AS treatment system would not
be effective due to a non-homogenous subsurface geology. A pilot test conducted in November 1994 confirmed
that vacuum enhanced recovery (VER) could effectively desorb VOCs from the contaminated subsurface.
Effective mass removal of VOCs was observed during the test for both the vapor and the dissolved phases.

Overall Protection of Human Health and the Environment

Alternative 1 (No Action) is not protective of human health and the environment. Existing restrictions on
groundwater use would remain, but no further restrictions would be implemented. This Alternative would not
meet the remedial action objectives (RAOs) for the Site.

Alternative 2 (Institutional Controls) provides some level of protection of human health, since groundwater
and land use restrictions would be implemented to reduce exposures to contaminated soil and groundwater;
however, since no remediation of contamination takes place under this alternative, it is not protective of
the environment. This alternative would meet only some of the RAOs for the Site, since it prevents exposure
to contaminants, but does not provide treatment of the source area to expedite cleanup of the City Aguifer.

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probability that after implementation of this alternative, migration of contaminants from the source area
could continue as a result of groundwater flow beneath the cap, with the result that cleanup of the City
Aguifer is not expedited.

Alternatives 4 (Vacuum Enhanced Recovery) and 5 (Excavation, Treatment and Disposal), which both include
reduction or elimination of the source area by removal and treatment, would be protective of human health and
the environment. Alternative 4 would reduce the level of contaminants in the source area using vacuum
enhanced recovery (VER), while Alternative 5 would completely eliminate the identified source area by
excavation and off-Site treatment and disposal. Upon completion of either of these alternatives, the soil
RAOs for the Site would be achieved.

Compliance with ARARs

Chemical-, location- and action-specific ARARs were evaluated for the Alcas source area. The major ARARs
considered included: state and federal maximum contaminant levels (MCLs) for drinking water, and federal and
state air emission limits (chemical-specific ARARs); historic preservation reguirements (location-specific
ARARs); and, RCRA hazardous waste generator, transporter and treatment, storage and disposal reguirements
(action-specific ARARs).

Alternatives 1 and 2 would not comply with chemical-specific ARARs. Existing contaminant concentrations in
the groundwater, which already exceed chemical-specific ARARs, would continue to exceed these levels, with a
potential increase in contaminant levels, since the Alcas source area would continue to contribute
contamination to the aguifer. Alternative 1 involves no remedial activities, and therefore does not trigger
any location- or action-specific ARARs. Alternative 2 would be implemented in such a manner so as to comply
with location- and action -specific ARARs. Neither of these alternatives would comply with the soil RAOs,
which are TBCs (to be considered levels) for soil remediation.

Alternative 3 would not initially comply with chemical-specific ARARs for the groundwater, since the
contaminant concentrations would not be immediately reduced by implementation of this alternative. However,
by reducing the migration of contaminants from the soil it is expected that this alternative could result in
compliance with the chemical-specific ARARs. This alternative may not fully comply with groundwater RAOs
since it may not be adeguate in reducing the migration of contaminants from the soil. Compliance with
location- and action-specfic ARARs would be achieved through proper implementation of this alternative.

Alternative 5 would provide the most rapid compliance with chemical-specific ARARs, since the groundwater
contaminant concentrations would be rapidly reduced by implementation of this alternative. Contaminated
soil, including an extensive amount of soil in the saturated zone, that is acting as a source of
contamination to the groundwater would be removed in this alternative, thereby eliminating additional
contributions of contamination to the City Aguifer and resulting in compliance with chemical-specific ARARs.
Proper design and implementation of the excavation, transportation and disposal of the contaminated soil
would ensure that the implementation of this alternative would be in compliance with location- and
action-specific ARARs. The alternative would also be in compliance with the soil RAOs.

Short-term Effectiveness

Alternative 1 involves no remedial activities, and therefore results in no increase in short-term risks to
workers or the community. Implementation of this alternative would be immediate.

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Alternative 2 includes administrative actions and minimal construction activities (e.g., fence construction).
Workers and the nearby community would be subject to a slightly increased risk of exposure to contaminants
due to disturbance of contaminated soil during these activities. These risks would be minimized thought the
implementation of a site-specific health and safety plan and appropriate engineering controls (e.g., dust
suppression). Implementation of this alternative could be completed in approximately 6 months.

Alternative 4 includes construction activities; however, as this alternative involves in situ treatment, the
disturbance of contaminated soils during construction activities would be limited. Any increased risks due
to disturbance of contaminated soil would be mitigated through the implementation of a site-specific health
and safety plan and appropriate engineering controls (e.g., dust suppression). This alternative could be
constructed in approximately 1 year. Operation of the system should not result in any increased risk of
exposure.

Long-term Effectiveness

Alternative 1 does not remove or contain the source of contamination. Therefore, the current risks from
exposure to contaminated groundwater and soil would remain, and future risk may even be greater as the source
area continues to release contaminants to the groundwater. Long-term monitoring and assessment would
required under this alternative, and there is the potential that additional remedial activities might be
necessary in the future.

Alternative 2 also does not remove or contain the source of contamination, but does provide some reduction in
the risk of exposure to contaminated soil and groundwater vial access and use restrictions, provided these
restrictions are adequately maintained and enforced. Long-term monitoring would required under this
alternative, and there is the potential that additional remedial activities might be necessary in the future.
In addition, it could be difficult to maintain institutional controls in the long term.

Alternative 3 provides containment of the contaminated source area, which would reduce the risk of exposure
to contaminated soil and would reduce migration of contaminants from the source area to groundwater.
Long-term monitoring and maintenance would required under this alternative to ensure to integrity of the cap.
Due to lateral movement of groundwater, it is possible that the cap may not adequately prevent migration of
contamination from the source area to the groundwater, and that additional remedial activities could be
necessary in the future.

Alternative 5 provides removal of the source areas. This alternative provides a permanent remedy, in that

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contaminated soils removed from the Site would not pose any future risk would not be subject to any further
remedial action on the future. No long-term monitoring or maintenance would be reguired for the source area;
however, long-term monitoring would be reguired under this alternative to monitor improvements in the water
guality of the City Aguifer.

Reduction of Toxicity, Mobility or Volume Through Treatment

Alterative 1 and 2 provide no removal or treatment of contaminated soils or groundwater, and therefore
provide no reduction in toxicity, mobility or volume of contaminated materials.

Alternative 3, if properly maintained, should reduce the mobility of contaminants without treatment, thereby
minimizing additional contamination of the groundwater from this source area. This alternative does not
provide any reduction in toxicity or volume of contaminated material, and does not provide for treatment of
the soil which is preferred.

Alternative 4 provides treatment of contaminated soil and capture and treatment of contaminated groundwater.
A pilot test, which was conducted at Alcas in November 1994, confirmed that a VER system would reduce the
mobility of contaminants by capture, and upon completion of the remediation would significantly reduce the
volume of contaminated soil at this source area. Reduction of the contaminant levels in the groundwater
within the influence of a VER system should also be achieved under this alternative.

Alternative 5 provides a reduction in mobility and volume of contaminated soil by excavation and off-Site
treatment and disposal of contaminated media. Contaminated soil removed from the Site would no longer pose
any risk of further contamination of the groundwater.

Implementability

Alternative 1 would be easily implemented, as it does not include any remedial activities. Alternative 2 may
be difficult to implement, since it reguires cooperation from individual property owners, which would be
difficult to enforce. Minor construction activities (e.g., fence) included in this alternative would be easy
to implement, and would not reguire a significant administrative effort. Long-term maintenance would be
reguired for Alternative 2.

Capping (Alternative 3) is a readily available and well-developed technology that could be completed using
conventional construction technigues. Long-term maintenance of the cap would be reguired.

For Alternative 4, on-site construction activities would be minor, consisting of well installation and
construction or mobilization of a small treatment system. This would result in a minimal disruption of
facility operations and would also minimize any effects to the on-Site building, which may be situated close
to or over the subsurface contamination. In addition, a VER system may be modified, as necessary, to
remediate larger or inaccessible areas. However, in situ treatment technologies are still considered
innovative, and there are only a small number of vendors offering these services. In addition, effective
operation reguires intensive monitoring and assessment. Administratively, coordination with local
authorities and other agencies may be reguired for the discharge of treated water and vapor; however, this
alternative does not involve any off-Site transportation of hazardous materials.

Alternative 5 would reguire excavation to depths of approximately 16 feet with approximately 12 feet below
the water table. Dewatering and shoring would be reguired; however, this alternative could be implemented
using conventional construction technigues. Off-Site RCRA storage, treatment and disposal facilities are
available for treatment and disposal of VOC-contaminated soil. Administratively, this alternative would
reguire coordination with the local authorities and other agencies for transportation, treatment and disposal
of hazardous materials.

Cost

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NPWs of $0 and $152,295, respectively. Alternative 3 is slightly more expensive, with a NPW of $298,158.
Alternative 4 is significantly more expensive, with a NPW of $837,721. Alternative 5 is the most expensive,
with a NPW of $1,013,495. Cost estimates are summarized in Table 9.

AVX SOURCE AREA

This subsection presents the comparative analysis of alternatives for the AVX source area. Available data
indicate that groundwater and soil are contaminated and are amenable to remediation. Therefore, the
evaluation presented in this subsection considers all stages of each of the alternatives (i.e., no action for
Alternative 1; institutional controls for Alternative 2; groundwater remediation for Alternative 3A; and
stages 1 and 2 for Alternatives 3, 4 and 5).

Alternative 4, as discussed in this subsection, does not include soil vapor extraction with air sparging
(SVE/AS). An evaluation of the AVX property concluded that a SVE/AS treatment system would not be effective,
due to low soil permeability at the property. However, a pilot test conducted in August 1994 confirmed that
vacuum enhanced recovery (VER) could effectively desorb VOCs from the contaminated subsurface. Effective
mass removal of VOCs was observed during the test for both the vapor and the dissolved phases.

Overall Protection of Human Health and the Environment

Alternative 2 (Institutional Controls) provides some protection of human health, since groundwater and land
use restrictions would be implemented to reduce exposures to contaminated soil and groundwater; however,
since no remediation of contamination takes place under this alternative, it is not protective of the
environment. Because this alternative prevents exposure to contaminants, but does not provide treatment of
the source area to expedite cleanup of the City (lower) Aguifer, it would meet only some of the RAOs for the
Site.

Alternative 3 (Capping) would reduce the risk of exposure to contaminated soils and potentially reduce the
migration of contaminants from the source area to the groundwater. After implementation of the alternative,
the risk of exposure to contaminated soils would be reduced. Groundwater and land use restrictions would be
implemented to further reduce the risk of exposures and to ensure cap intergrity. This alternative would
meet the RAOs for soil by preventing exposure to contaminants, and should meet the RAOs for groundwater by
reducing migration of contaminants from the source area to the groundwater, thereby expediting cleanup of the
City Aguifer. The groundwater guality will be monitored and the effectiveness of the remediation reevaluated
at four-year intervals. If it is determined that stage 1 of this alternative has not adeguately improved the
guality of the City Aguifer and it is determined that this source area continues to affect the groundwater
entering the municipal wells, stage 2 may be implemented. Proper operation and maintenance of this system
would ensure that the RAOs for groundwater would be achieved and therefore would be protective.

Alternative 3A (Groundwater Pump-and-Treat) is identical to the pump-and-treat portion (i.e., stage 2) of
Alternative 3, the difference being that the groundwater treatment system would be installed immediately upon
selection of this alternative. The evaluation is identical to stage 2 of Alternative 3.

Alternative 4 (Vacuum Enhanced Recovery) and 5 (Excavation, Treatment and Disposal), which both include
reduction or elimination of the source area by removal and treatment, would be protective of human health and
the environment. Alternative 4 would reduce the level of contaminants in the source are using vacuum
enhanced recovery (VER), while Alternative 5 would completely eliminate the identified source area by
excavation and off-Site treatment and disposal. Upon completion of either Alternative 4 or 5, the RAOs for
the Site should be achieved. The groundwater guality will be monitored and the effectiveness of the
remediation reevaluated at four-year internals. If it is determined that stage 1 of this alternative has not
adeguately improved the guality of the City Aguifer and it is determined that this source area continues to
affect the groundwater entering the municipal wells, stage 2 may be implemented. Proper operation and
maintenance of this system would ensure that the RAOs for groundwater would be achieved.

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Compliance with ARARs

Chemical-, location- and action-specific ARARs were evaluated for the AVX source area. The major ARARs
considered included: state and federal maximum contaminant levels (MCLs) for drinking water and federal and
state air emission limits (chemical-specific ARARs); wetlands protection and historic preservation
requirements (location-specific ARARs); and, RCRA hazardous waste generator, transporter and treatment,
storage and disposal requirements (action-specific ARARs).

Alternatives 1 and 2 would not comply with chemical-specific ARARs. Existing contaminant concentrations in
the groundwater, which already exceed chemical-specific ARARs, would continue to exceed these levels, with a
potential increase in contaminant levels, since the AVX source area would continue to contribute
contamination to the aquifer. Alternative 1 involves no remedial activities, and therefore does not trigger
any location- or action-specific ARARs. Alternative 2 would be implemented in such a manner so as to comply
with location- and action-specific ARARs. Neither of these alternatives would comply with the soil RAOs.

Alternative 3 would not initially comply with chemical-specific ARARs for the groundwater, since the
contaminant concentrations would not be immediately reduced by implementation of this alternative. However,
by reducing the migration of contaminants from the soil it is expected that this alternative could result in
compliance with the chemical-specific ARARs. This alternative may not fully comply with groundwater RAOs
since it may not be adequate in reducing the migration of contaminants from the soil. Stage 2, if required,
would supplement stage 1 to bring this area into compliance with ARARs. Through proper implementation of
this alternative, compliance with location- and action-specific ARARs would be achieved. This alternative
would not comply with the soil RAOs, since it does not include removal or treatment of contaminated soil.

It would take longer to come into compliance with chemical-specific ARARs with Alternative 3A for groundwater
that those alternatives that include source area remediation of the soil (i.e., Alternatives 3, 4 and 5),
since contamination could continue to migrate from the contaminated soil source area, which is not remediated
under this alternative. Through proper implementation of this alternative, compliance with location-and
action-specific ARARs would be achieved. This alternative would not comply with the soil RAOs, since it does
not include treatment or removal of contaminated soil, which would eliminate the leaching VOCs into the
groundwater.

Alternative 4 would not initially comply with chemical-specific ARARs, since the groundwater contaminant
concentrations would not be immediately reduced by implementation of this alternative. However, significant
quantities of contaminants in both the soil and groundwater would be removed by VER, thereby eliminating
additional contributions of contamination to the City Aquifer and eventually resulting in compliance with
chemical-specific ARARs. It is expected that compliance with chemical-specific ARARs would be achieved over
time. If it is determined that stage 1 of this alternative has not adequately improved the quality of the
City Aquifer and it is determined that this source area continues to affect the groundwater entering the
municipal wells, stage 2 may be implemented. Proper design and implementation of the VER system and the
groundwater pump-and-treat system (if necessary) would ensure that the implementation of both stages of this
alternative would be in compliance with location- and action-specific ARARs. This alternative, upon
completion of VER treatment (stage 1), would also be in compliance with the soil RAOs.

Alternative 5 would provide the most rapid compliance with chemical-specific ARARs, since the groundwater
contaminant concentrations would be rapidly reduced by implementation of this alternative. Contaminated soil
that is acting as a source of contamination to the groundwater would be removed in this alternative, thereby
eliminating additional contributions of contamination to the City Aquifer and resulting in compliance with
chemical-specific ARARs. If it is determined that stage 1 of this alternative has not adequately improved
the quality of the City Aquifer and it is determined that this source area continues to affect the
groundwater entering the municipal wells, stage 2 may be implemented. Proper design and implementation of
the excavation, transportation and disposal of the contaminated soil and proper operation of the
pump-and-treat system (if necessary) would ensure that the implementation of both stages of this alternative
would be in compliance with location- and action-specific ARARs. This alternative, upon completion of soil
excavation and disposal (stage 1), would also be in compliance with the soil RAOs.

Short-Term Effectiveness

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Alternative 1 involves no remedial activities, and therefore results in no increase in short-term risks to
workers or the community. Implementation of this alternative would be immediate.

Alternative 2 includes administrative actions and minimal construction activities (e.g., fence construction).
Workers and the nearby community would be subject to a slightly increased risk of exposure to contaminants
due to disturbance of contaminated soul during these activities. These risks would be minimized through the
implementation of a Site-specific health and safety plan and appropriate engineering controls (e.g., dust
suppression). Implementation of this alternative could be completed in approximately 6 months.

Alternative 3 includes construction activities for placement of a cap over the source area. Workers and the
nearby community would be subject to an increased risk of exposure to contaminants due to disturbance of
contaminated soil (e.g., grading) during these activities. These risks would be minimized through the
implementation of a site-specific health and safety plan (e.g., use of personal protective equipment) and
appropriate engineering controls (e.g., dust suppression). Implementation of stage 1 of this alternative
could be completed in approximately 1 year. If it is determined that stage 2 of this alternative (i.e.,
groundwater pump-and-treat) is required, there would be additional Site disturbances during construction of
the system, resulting in additional risks of exposures to contaminated groundwater for workers. Workers may
also be exposed to excessive noise during construction activities. These risks would be minimized through
the implementation of a site-specific health and safety plan. There would be no increased risk to the public
during construction of the pump-and-treat system, since contaminated soil would be contained beneath the cap;
however, operation of the pump-and-treat system might pose slightly increased risk of exposures to the public
from fugitive air emissions. These risks would be mitigated by proper design and operation of the system and
compliance with any emissions control requirements. Implementation of stage 2 could be completed in
approximately 1 year; however, the pump-and-treat system would be operated for an extended period of time (up
to 30 years). The short-term effectiveness of Alternative 3A is identical to the short-term effectiveness of
stage 2 of Alternative 3.

Alternative 4 includes construction activities; however as this alternative involves in situ treatment, the
disturbance of contaminated soils during construction activities would be limited. Any increased risks due
to disturbance of contaminated soil would be mitigated through the implementation of a site- specific health
and safety plan and appropriate engineering controls (e.g., dust suppression). Operation of the system
should not result in any increased risk of exposure. It would take approximately 1 year to implement stage 1
of this alternative. There would be no increased risk to the public, since contaminated soil would have
already been remediated during stage 1 of this alternative. The construction of the groundwater
recovery/treatment system (stage 2) could be completed in approximately 1 year; however, the pump-and-treat
system would be operated for an extended period of time (e.g., 30 years).

Alternative 5 includes the most intensive construction activities, including excavation and off-Site
transportation of contaminated soil. Workers and the nearby community would be subject to an increase in the
risk of exposure to contaminants due to disturbance of contaminated soil during excavation and transporation
of contaminated materials for off-Site treatment (if necessary) and disposal. These risks would be mitigated
by implementation of a site-specific health and safety plan, a site-specific traffic control plan and
appropriate engineering controls (e.g., dust suppression). This alternative could be completed in
approximately 1 year. If it is determined that stage 2 of this alternative (i.e., groundwater
pump-and-treat) is required, there would be additional site disturbances during construction of this system,
resulting in additional risks of exposures to contaminated groundwater for workers; however, there would be
no increased risk to the public, since contaminated soil would have already been remediated during stage 1 of
this alternative. The groundwater pump-and-treat system might pose slightly increased risk of exposures to
the public from fugitive air emissions; these risks would be mitigated by proper design and operation of the
system and compliance with any emissions control requirements. The construction of the groundwater
recovery/treatment system (stage 2) could be completed in approximately 1 year; however, the pump-and-treat
system would be operated for an extended period of time (e.g., 30 years).

Long-term Effectiveness

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area continues to release contaminants to the groundwater. Long-term monitoring and assessment would be
reguired under this alternative, and there is the potential that additional remedial activities might be
necessary in the future.

Alternative 2 also does not remove or contain the source of contamination, but does provide some reduction in
the risk of exposure to contaminated soil and groundwater via access and use restrictions, provide these
restrictions are adeguately maintained and enforced. Long-term monitoring would be reguired under this
alternative, and there is the potential that additional remedial activities might be necessary in the future.
In addition, it could be very difficult to maintain institutional controls in the long term.

Alternative 3 provides containment of the contaminated source area, which would reduce the risk of exposure
to contaminated soil and reduce migration of contaminants from the source area to
groundwater. Long-term monitoring and maintenance would be reguired under this alternative to ensure the
integrity of the cap. Due to lateral movement of groundwater, it is possible that the cap may not adeguately
prevent migration of contamination from the source area to the groundwater, and that additional remedial
activities could be necessary in the future.

Implementation of the stage 2 pump-and-treat system would provide an additional reduction in the risk of
exposure to contaminated groundwater by preventing further migration of contamination from this source.

Alternative 3A provides some containment of the source area by preventing migration of contamination, but
would not be as protective as Alternative 3, which includes the cap and the pump-and-treat system (if
necessary). Long-term monitoring and maintenance would be reguired to ensure proper and effective operation
of the pump and treat system.

Alternative 4 provides treatment of both the source are and associated groundwater. This alternative
provides a permanent remedy for the contaminated source area, including source areas below the water table,
since contaminants are removed from the soil. During the operation of, and upon completion of, the VER
treatment, monitoring would be reguired to assess the completeness of the remediation and to monitor
improvements in the guality of the City Aguifer; however, no further remediation of the source area should be
reguired. If it is determined that stage 1 of this alternative has not adeguately improved the guality of
the City Aguifer and it is determined that this source area continues to affect the groundwater entering the
municipal wells stage 2 may be implemented. Implementation of the stage 2 pump-and-treat system would proved
and additional reduction in the risk of exposure to contaminated groundwater by preventing further migration
of contamination from this source. Long-term monitoring and maintenance would be reguired to ensure proper
and effective operation of the pump-and-treat system.

Alternative 5 provides removal of the source areas. This alternative provides a permanent remedy, in the
contaminated soils removed from the Site would not pose any future risk and would not be subject to any
further remedial action in the future. No long-term monitoring or maintenance would be reguired for the
source area; however, long-term monitoring would be reguired under this alternative to monitor improvements
in the guality of the City Aguifer. If it is determined that stage 1 of this alternative has not adeguately
improved the guality of the City Aguifer and it is determined that this source area continues to affect the
groundwater entering the municipal wells, stage 2 may be implemented. Implementation of the stage 2
pump-and-treat system would provide an additional reduction in the risk of exposure to contaminated
groundwater by preventing further migration of contamination from this source.

Reduction of Toxicity, Mobility or Volume through Treatment

Alternatives 1 and 2 provide no removal or treatment of contaminated soils or groundwater, and therefore
provide no reduction in toxicity, mobility or volume of contaminated materials.

The cap that would be installed in stage 1 of Alternative 3, if properly maintained, should reduce the
mobility of contaminants without treatment, thereby minimizing additional contamination of the groundwater
from this source area. If the stage 2 pump-and-treat system is implemented, this system would further reduce
the toxicity, mobility and volume of contamination by extracting toxicity, mobility and volume of
contamination by extraction contaminated groundwater, treating it and preventing off-Site migration. The

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reduction in toxicity, mobility and volume for Alternative 3A is identical to stage 2 of Alternative 3.

Stage 1 of Alternative 4 provides treatment of contaminated soil and capture and treatment of contaminated
groundwater using VER. This system would reduce the mobility of contaminants by capture, and upon completion
of the remediation, would significantly reduce the volume of contaminated soil at this source area.
Reduction of the contaminant levels in the groundwater within the influence of the system might also be
achieved under this alternative. If stage 1 does not adeguately meet the RAOs and stage 2 is implemented,
the groundwater pump-and-treat system would further reduce the toxicity, mobility and volume of remaining
contamination by extracting contaminated groundwater, treating it and preventing off-site migration.

Stage 1 of Alternative 5 provides a reduction in mobility and volume of contaminated soil by excavation and
off-Site treatment and disposal of contaminated media. Contaminated soil removed from the Site would no
longer pose any risk of further contamination of the groundwater. If stage 1 does not adeguately meet the
RAOs and stage 2 is implemented, the groundwater pump-and-treat system would further reduce the toxicity,
mobility and volume of remaining contamination by extracting contaminated groundwater and preventing off-Site
migration.

implement, since it reguires cooperation from individual property owners, which is difficult to enforce.
Minor construction activities (e.g., fence) included in this alternative would be easy to implement, and
would not reguire a significant administrative effort. Long-term maintenance would be reguired for
Alternative 2.

Alternative 3 would involve on-Site construction. However, capping is a readily available and well-developed
technology that could be completed using conventional construction technigues. Long-term maintenance of the
cap would be reguired. If stage 2 of this alternative is reguired, it would be relatively easy to implement
technically, since groundwater pump-and-treat systems consist of readily available technologies and are
routinely installed at sites with contaminated groundwater. Administratively, coordination with local
authorities may be reguired for the discharge of treated water and emissions from the treatment system. The
implementability of Alternative 3A is identical to the implementability of stage 2 of Alternative 3.

For Alternative 4, on-Site construction activities would be minor, consisting of well installation and
construction or mobilization of a small treatment system. However, in situ treatment technologies are still
considered innovative, and there are only a small number of vendors offering these services. In addition,
effective operation reguires intensive monitoring and assessment. Administratively, coordination with local
authorities and other agencies may be reguired for the discharge of treated water and vapor; however, this
alternative does not involve and off-Site transportation of hazardous materials. If stage 2 of this
alternative is reguired, it would be relatively easy to implement technically, since groundwater
pump-and-treat systems consist of readily available technologies and are routinely installed at sites with
contaminated groundwater. Administratively, the reguirements would be similar to the VER system
reguirements.

Alternative 5 would reguire excavation to depths of approximately 6 feet in close proximity to on-site
structures. Dewatering and shoring would be reguired; however, this alternative could be implemented using
conventional construction technigues. Given the shallow depth of contamination, technical implementation of
this alternative would not be difficult. Off-Site RCRA storage, treatment and disposal facilities are
available for treatment and disposal of VOC contaminated soil. Administratively, this alternative would be
moderately difficult to implement, since it would reguire coordination with the local authorities and other
agencies for transportation, treatment and disposal of hazardous materials. If stage 2 of this alternative
is reguired, it would be relatively easy to implement technically, since groundwater pump-and-treat systems
consist of readily available technologies and are routinely installed at sites with contaminated groundwater.
Administratively, coordination with local authorities may be reguired for the discharge of treated water and
emissions from the treatment system.

Cost

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NPWs of $0 and $165,295, respectively. Alternative 3 (stage 1) is slightly more expensive, with a NPW of
$187,113. If stage 2 of Alternative 3 is implemented, the overall cost of this alternative is approximately
$821,117, but treatment of contaminated groundwater is provided. Alternative 3A, which includes
pump-and-treat for longer period of time, but no capping, has a cost of $1,070,610. Alternative 4 (stage 1)
is significantly more expensive than Alternative 3 (stage 1), with a NPW of $2,223,529. If stage 2 of
Alternative 4 is implemented, the cost increases to $1,747,533, and additional groundwater treatment is
provided. Alternative 5 (stage 1) is significantly less costly than Alternative 4 (stage 1), with a NPW of
$376,295. If stage 2 of Alternative 5 is implemented, groundwater treatment is provided, and the NPW is
$1,010,299. Cost estimates are summarized in Table 9.

McGRAW-EDISON SOURCE AREA

This subsection presents the comparative analysis of alternatives for the McGraw-Edsion source area.
Available data indicate that there is no contaminated soil source in this area. Therefore, Alternatives 3, 4
and 5, which all specify some kind of soil remediation, are not applicable. Alternative 3A, which specifies
groundwater pump-and-treat, is applicable and was evaluated for this area.

Overall Protection of Human Health and the Environment

Alternative 2 (Institutional Controls) provides some level of protection of human health, since groundwater
use restrictions would be implemented to reduce exposures to contaminated groundwater. However, since no
remediation of contamination takes place under this alternative, it is not protective of the environment.
After implementation of the alternative, risks of exposure would be reduced as long as the administrative
restrictions were maintained. This alternative would meet only some of the RAOs for the Site, since it
prevents exposure to contaminants, but does not provide any treatment to expedite cleanup of the City
Aguifer.

Alternative 3A would be implemented immediately at the McGraw-Edison site, since there is no soil source area
to be remediated. Proper operation and maintenance of the groundwater pump-and-treat system would ensure
that the RAOs for groundwater would be achieved. Extraction of contaminated groundwater will protect human
health and the environment by removing contamination from the aguifer and preventing migration of
contaminants from this area to the municipal well field.

Compliance with ARARs

Chemical-, location- and action-specific ARARs were evaluated for the McGraw-Edison source area. The major
ARARs considered included: state and federal maximum contaminant levels (MCLs) for drinking water and
federal and state air emission limits (chemical-specific ARARs); historic preservation reguirements
(location-specific ARARs); and, RCRA hazardous waste generator, transporter and treatment, storage and
disposal reguirements (action-specific ARARs).

Alternatives 1 and 2 would not comply with chemical-specific ARARs. Existing contaminant concentrations in
the groundwater, which already exceed chemical-specific ARARs, would continue to exceed these levels for an
extended period of time. Alternative 1 involves no remedial activities, and therefore does not trigger any
location- or action-specific ARARs. Alternative 2 would be implemented in such a manner so as to comply with
location- and action-specific ARARs.

Alternative 3A would not initially comply with chemical-specific ARARs, since the groundwater contaminant
concentrations would not be immediately reduced by implementation of this alternative. However, by treating
the groundwater beneath the McGraw-Edison site, further contamination migration to the municipal supply wells
would be eliminated, eventually resulting in compliance with chemical-specific ARARs. Through proper
implementation of this alternative, compliance with location- and action-specific ARARs would be achieved.
The soil RAOs do no apply to the McGraw-Edison site, since there are no identified areas of soil

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contamination.

Short-term Effectiveness

Alternative 1 involves no remedial activities, and therefore results in no increase in short-term risks to
workers or the community. Implementation of this alternative would be immediate.

Alternative 2 includes only administrative actions, since no access restrictions are required at the
McGraw-Edison site. Therefore, there would be no change in the risks to workers or the nearby community
during implementation of this alternative. Implementation of this alternative could be completed in
approximately 3 months.

Alternative 3A includes installation of a groundwater pump-and-treat system. As there is already a well and
an air stripper on site, only minimal construction activities would be required to upgrade the treatment
system and install one or more wells in the shallow aquifer. Workers would be subject to a slightly
increased risk of exposure to contaminated groundwater and exposure to noise during these activities. These
risks would be minimized through the implementation of a site-specific health and safety plan (e.g., use of
personal protective equipment). Operation of the groundwater pump-and-treat system might pose slightly
increased risk of exposures to the public from fugitive air emissions; these risks would be mitigated by
proper design and operation of the system and compliance with any emissions control requirements.
Implementation of the groundwater pump and treat system could be complete in approximately 3 to 6 months;
however, the pump-and-treat system would be operated for an extended period of time (e.g., 30 years).

Long-term Effectiveness

Alternative 1 does not remove or contain the contaminated groundwater. Therefore, the current risks from
exposure to contaminated groundwater persist, and future rusk may even be greater as the contaminated
groundwater beneath the site continues to migrate. Long-term monitoring and assessment would be required
under this alternative, and there is the potential that additional remedial activities might be necessary in
the future.

Alternative 2 also does not remove or contain the contaminated groundwater but does provide some reduction in
the risk of exposure to contaminated groundwater via access and use restrictions, provided these restrictions
are adequately maintained and enforced. Long-term monitoring would be required under this alternative, and
there is the potential that additional remedial activities might be necessary in the future. In addition, it
could be difficult to maintain institutional controls in the long term.

Alternative 3A provides for removal and treatment of groundwater contaminants beneath the site, thereby
reducing the risk of exposure to contaminated groundwater and migration of contaminated groundwater off site.
Long-term monitoring would be required under this alternative to confirm the effectiveness of the system.
Aside from operation and maintenance of the groundwater pump-and-treat system, no further remedial actions
would be required in the future.

Reduction of Toxicity, Mobility or Volume through Treatment

Alternatives 1 and 2 provide no removal or treatment of contaminated soils or groundwater, and therefore
provide no reduction in toxicity, mobility or volume of contaminated materials.

Alternative 3A would reduce the mobility and volume of contaminants in the groundwater via extraction and
treatment of contaminated groundwater beneath the site.

Implementability

Alternative 1 would be easily implemented, as it does not include any remedial activities. Alternative 2 may
be difficult to implement, since ie deals with individual property rights and could be difficult to enforce.
There are minimal construction activities in this alternative as it applies to the McGraw-Edsion site.
Long-term maintenance of administrative actions would be required for Alternative 2.

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Alternative 3A would be easily implemented, since it would require only well installation and possibly
upgrades to an existing groundwater treatment system (i.e., air stripper). As mentioned previously,
McGraw-Edison installed the air stripper in the early 1980's to treat groundwater for industrial use on-site.
Administratively, coordination with local authorities may be required for the discharge of treated water and
emissions from the treatment system after these modifications are made.

Cost

The 30-year present worth (NEW) of the remedial alternatives for the McGraw-Edison site range from $0 to
$935,610 based on a discount rate of 7%. Alternative 1 and 2 are the least expensive to implement, with NPWs
of $0 and $138,295, respectively. Alternative 3A has a NPW of $935,610. The costs for implementation of
Alterantive 3A include the expenses for operation and maintenance of an existing air stripper system, which
is currently treating groundwater form the lower aquifer at McGraw-Edison, and the necessary upgrades to the
system to treat groundwater from the upper aquifer. Cost estimates are summarized in Table 9.

LOOHN'S DRY CLEANERS AND LAUNDERERS

This subsection presents the comparative analysis of alternatives for the Loohn's Dry Cleaners source area.
Available data indicate that both groundwater and soil are contaminated and are amenable to remediation.
Therefore, the evaluation presented in this subsection considers all stages of each of the alternatives.

Overall Protection of Human Health and the Environment

Alternative 2 (Institutional Controls) provides some level of protection of human health, since groundwater
and land use restrictions would be implemented to reduce exposures to contaminated soil and groundwater;
however, since no remediation of contamination takes place under this alternative, it is not protective of
the environment. After implementation of the alternative, risks would be slightly reduced as long as the
administrative and physical restrictions were maintained. This alternative would meet only some of the RAOs
for the Site, since it prevents exposure to contaminants, but does not provide treatment of the source area
to expedite cleanup of the City Aquifer.

Alternative 3 (Capping) would reduce the risk of exposure to contaminated soils and potentially reduce the
migration of contaminants from this source area to the groundwater. After implementation of the alternative,
the risk of exposure to contaminated soils would be reduced. Groundwater and land use restrictions would be
implemented to further reduce the risk of exposures and to ensure cap intergrity. This alternative would
prevent exposure to soil contaminants, and should meet the RAOs for groundwater by reducing migration of
contaminants from the source area to the groundwater, thereby expediting cleanup of the City Aquifer. The
groundwater will be monitored and the effectiveness of the remediation will be reevaluated at four-year
intervals. If it is determined that stage 1 of this alternative has not adequately improved the quality of
the City Aquifer and it is determined that this source area continues to affect the groundwater entering the
municipal wells, stage 2 may be implemented. Proper operation and maintenance of this system would ensure
that the RAOs for groundwater would be achieved.

Alternative 3A (Groundwater pump and treat) is identical to the pump-and-treat portion (i.e., stage 2) of
Alternative 3, the difference being that the groundwater treatment system would be installed immediately upon
selection of this alternative. The evaluation is identical to stage 2 of Alternative 3.

Alternatives 4 (Vacuum Enhanced Recovery (VER) or Soil Vapor Extraction with Air Sparging (SVE/AS)) and 5
(Excavation, Treatment and Disposal), all of which include reduction or elimination of the source area by
removal and treatment, would be protective of human health and the environment. Alternative 4 would reduce
the level of contaminants in the source area using VER or SVE/AS, while Alternative 5 would completely
eliminate the identified source area by excavation and off-Site treatment and disposal. Upon completion of
either of these alternatives, the RAOs for the Site should be achieved. The groundwater quality will be

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monitored and the effectiveness of the remediation reevaluated at four-year intervals. If it is determined
that stage 1 of this alternative has not adequately improved the quality of the City Aquifer and it is
determined that this source area continues to affect the groundwater entering the municipal wells, stage 2
may be implemented. Proper operation and maintenance of this system would ensure that the RAOs for
groundwater would be achieved.

Compliance with ARARs

Chemical-, location- and action-specific ARARs were evaluated for the Loohn's source area. The major ARARs
considered included: state and federal maximum contaminant levels (MCLs) for drinking water and federal and
state air emission limits (chemical-specific ARARs); historic preservation requirements (location-specific
ARARs); and, RCRA hazardous waste generator, transporter and treatment, storage and disposal requirements
(action-specific ARARs).

Alternatives 1 and 2 would not comply with chemical-specific ARARs. Existing contaminant concentrations in
the groundwater, which already exceed chemical-specific ARARs, would continue to exceed these levels, with a
potential increase in contaminant levels, since the Loohn's source area would continue to contribute
contamination to the aquifer. Alternative 1 involves no remedial activities, and therefore does not trigger
any location- or action-specific ARARs. Alternative 2 would be implemented in such a manner so as to comply
with location- and action-specific ARARs. Neither of these alternatives would comply with the soil RAOs.

Compliance with location- and action-specific ARARs would be achieved through proper implementation of this
alternative. Stage 2, if required, would supplement stage 1 of bring this area into compliance with ARARs.
Through proper implementation of this alternative, compliance with location- and action-specific ARARs would
be achieved.

It' would take longer to come into compliance with chemical-specific ARARs with Alternative 3A for
groundwater than those alternatives that include source area remediation (i.e., Alternatives 3, 4 and 5),
since contamination could continue to migrate from the contaminated soil source area, which is not remediated
under this alternative. Through proper implementation of this alternative, compliance with location- and
action-specific ARARs would be achieved. This alternative would not comply with the soil RAOs, since it does
not include removal or treatment of contaminated soil.

Alternative 4 would not initially comply with chemical-specific ARARs, since the groundwater contaminant
concentrations would not be immediately reduced by implementation of this alternative. However, significant
quantities of contaminants in both the soil and groundwater would be removed by VER or SVE/AS, thereby
eliminating additional contributions of contamination to the City Aquifer and eventually resulting in
compliance with chemical-specific ARARs. It is expected that compliance with chemical-specific ARARs would
be achieved over time. If it is determined that stage 1 of this alternative has not adequately improved the
quality of the City Aquifer and it is determined that this source area continues to affect the groundwater
entering the municipal wells, stage 2 may be implemented. Proper design and implementation of the VER or
SVE/AS system and the groundwater pump-and-treat system (if necessary) would ensure that the implementation
both stages of this alternative would be in compliance with location- and action-specific ARARs. This
alternative, upon completion of VER or SVE/AS treatment (stage 1), would also be in compliance with the soil
RAOs.

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the quality of the City Aquifer and it is determined that this source area continues to affect the
qroundwater enterinq the municipal wells, staqe 2 may be implemented. Proper desiqn and implementation of
the excavation, transportation and disposal of the contaminated soil and proper operation of the
pump-and-treat system (if necessary) would ensure that the implementation of both staqes of this alternative
would be in compliance with location- and action-specific ARARs. This alternative, upon completion of soil
excavation and disposal (staqe 1), would also be in compliance with the soil RAOs.

Short-term Effectiveness

Alternative 1 involves no remedial activities, and therefore results in no increase in short-term risks to
workers or the community. Implementation of this alternative would be immediate.

Alternative 2 includes administrative actions and minimal construction activities (e.g., fence construction).
Workers and the nearby community would be subject to a slightly increased risk of exposure to contaminants
due to disturbance of contaminated soil during these activities. These risks would be minimized throuqh the
implementation of a site-specific health and safety plan and appropriate enqineerinq controls (e.g., dust
suppression). Implementation of this alternative could be completed in approximately 6 months.

Alternative 3 includes construction activities for placement of a cap over the source area. Workers and the
nearby community would be subject to an increased risk of exposure to contaminants due to disturbance of
contaminated soil (e.g., qradinq) durinq these activities. These risks would be minimized throuqh the
implementation of a site-specific health and safety plan (e.g., use personal protective equipment) and
appropriate enqineerinq controls (e.g., dust suppression). Implantation of stage 1 of this alternative could
be completed in approximately 1 year. If it is determined that staqe 2 of this alternative (i.e.,
qroundwater pump-and-treat) is required, there would be additional Site disturbances durinq construction of
this system, resultinq in additional risks of exposures to contaminated qroundwater for workers. Workers may
also be exposed to excessive noise durinq construction activities. These risks would be minimized throuqh
the implementation of a site-specific health and safety plan. There would be no increased risk to the public
durinq construction of the pump-and-treat system, since contaminated soil would be contained beneath the cap;
however operation of the pump-and-treat system miqht pose slightly increased risk of exposures to the public
from fugitive air emissions. These risks would be mitiqated by proper desiqn and operation of the system and
compliance with any emissions control requirements. Implementation of staqe 2 could be completed in
approximately 1 year; however, the pump-and-treat system would be operated for an extended period of time
(e.g., 30 years). The short-term effectiveness of Alternative 3A is identical to the short-term
effectiveness of stage 2 of Alternative 3.

Alternative 4 includes construction activities; however, as this alternative involves in situ treatment, the
disturbance of contaminated soils durinq construction activities would be limited. Any increased risks due
to disturbance of contaminated soil would be mitiqated throuqh the implementation of a site- specific health
and safety plan and appropriate enqineerinq controls (e.g., dust suppression). It would take approximately 1
year to implement stage 1 of this alternative. Operation of the system should not result in any increased
risk of exposure. There would be no increased risk to the public, since contaminated soil would have already
been remediated durinq staqe 1 of this alternative. Implementation of staqe could be completed in
approximately 1 year; however, the pump-and-treat system would be operated for an extended period of time
(e.q., 30 years).

Alternative 5 includes the most intensive construction activities, includinq excavation and off-site
transportation of contaminated soil. Workers and the nearby community would be subject to an increase in the
risk of exposure to contaminants due to disturbance of contaminated soil durinq excavation and transportation
of contaminated materials for off-Site treatment (if necessary) and disposal. These risks would be mitiqated
by implementation of a site-specific health and safety plan, a site-specific traffic control plan appropriate
enqineerinq controls (e.g., dust suppression). This alternative could be completed in approximately 1 year.
If it is determined that stage 2 of this alternative (i.e., qroundwater pump-and-treat) is required, there
would be additional Site disturbances durinq construction of this system, resultinq in additional risks of
exposures to contaminated qroundwater for workers; however, there would be no increased risk to the public,
since contaminated soil would have already been remediated durinq staqe 1 of this alternative. The
qroundwater pump-and-treat system miqht pose slightly increased risk of exposures to the public from fugitive

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air emissions; these risks would be mitigated by proper design and operation of the system and compliance
with any emissions control reguirements. Implementation of stage 2 could be completed in approximately 1
year; however, the pump-and-treat system would be operated for an extended period of time (e.g., 30 years).

Long-term Effectiveness

Alternative 1 does not remove or contain the source of contamination. Therefore, the current risks from
exposure to contaminated groundwater and soil would remain, and future risk may even be greater as the source
area continues to release contaminants to the groundwater. Long-term monitoring and assessment would be
reguired under this alternative, and there is the potential that additional remedial activities might be
necessary in the future.

Alternative 2 also does not remove or contain the source of contamination, but does provide some reduction in
the risk of exposure to contaminated soil and groundwater via access and use restrictions, provided these
restrictions are adeguately maintained and enforced. Long-term monitoring would be reguired under this
alternative, and there is the potential that additional remedial activities might be necessary in the future.
In addition, it would be difficult to maintain institutional controls in the long term.

Alternative 3 provides containment of the contaminated source area which would reduce the risk of exposure to
contaminated soil and reduce migration of contaminants from the source area to groundwater. Long-term
monitoring and maintenance would be reguired under this alternative to ensure the intergrity of the cap. It
is possible that the cap may not prevent migration of contamination from the source area to the groundwater,
and that additional remedial activities could be necessary in the future.

Alternative 4 provides treatment of both the source area and associated groundwater. This alternative
provides a permanent remedy for the contaminated source area, including source areas below the water table,
since contaminants are removed from the soil. During the operation of, and upon completion, of the VER or
SVE/AS treatment, long-term monitoring would be reguired to assess the completeness of the remediation and to
monitor improvements in the guality of the City Aguifer; however, no further remediation of the source area
should be reguired. If it is determined that stage 1 of this alternative has not adeguately improved the
guality of the City Aguifer and it is determined that this source area continues to affect the groundwater
entering the municipal wells, stage 2 may be implemented. Implementation of the stage 2 pump-and-treat
system would provide an additional reduction in the risk of exposure to contaminated groundwater by
preventing further migration of contamination from this source.

Alternative 5 provides removal of the source areas. This alternative provides a permanent remedy, in that
contaminated soils removed from the Site would not pose and future risk and would not be subject to any
further remedial action in the future. No long-term monitoring or maintenance would be reguired for the
source area; however, long-term monitoring would be reguired under this alternative to monitor improvements
in the guality of the City Aguifer. If it is determined that stage 1 of this alternative has not adeguately
improved the guality of the City Aguifer and it is determined that this source area continues to affect the
groundwater entering the municipal wells, stage 2 may be implemented. Implementation of the stage 2
pump-and-treat system would provide an additional reduction in the risk of exposure to contaminated
groundwater by preventing further migration of contamination from this source.

Reduction of Toxicity, Mobility or Volume through Treatment

Alternatives 1 and 2 provide no removal or treatment of contaminated soils or groundwater, and therefore
provide no reduction in toxicity, mobility or volume of contaminated materials.

The cap that would be installed in stage 1 of Alternative 3, if properly maintained, should reduce the

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mobility of contaminants, without treatment, thereby minimizing additional contamination of the groundwater
from this source area. Stage 1 of this alternative does not provide any reduction in toxicity or volume of
contaminated material. If the stage 2 pump-and-treat system is implemented, this system would further reduce
the mobility of contamination by preventing off-Site migration. The reduction in toxicity, mobility and
volume for Alternative 3A is identical to stage of Alternative 3.

Stage 1 of Alternative 4 provides treatment of contaminated soil and capture and treatment of contaminated
groundwater using VER or SVE/AS. This system would reduce the mobility of contaminants by capture, and upon
completion of the remediation, would significantly reduce the volume of contaminated soil at this source
area. Reduction of the contaminant levels in the groundwater within the influence of the system might also
be achieved under this alternative. If stage 1 does not adequately meet the RAOs and stage 2 is implemented,
the groundwater pump-and-treat system would further reduce the mobility of remaining contamination by
preventing off-Site migration.

Stage 1 of Alternative 5 provides a reduction in mobility and volume of contaminated soil by excavation and
off-Site treatment and disposal of contaminated media. Contaminated soil removed from the Site would no
longer pose any risk of further contamination of the groundwater. If stage 1 does not adequately meet the
RAOs and stage 2 is implemented, the groundwater pump-and-treat system would further reduce the mobility of
remaining contamination by preventing off-Site migration.

Implementability

Alternative 1 would be easily implemented, as it does not include any remedial activities. Alternative 2 may
be difficult to implement, since it requires cooperation from individual property owners and difficult to
enforce. Minor construction activities (e.g., fence) included in this alternative would be easy to
implement, and would not require a significant administrative effort. Long-term maintenance would be
required for Alternative 2.

Alternative 3 would involve on-Site construction. However, capping is a readily available and well-developed
technology that could be completed using conventional construction techniques. Long-term maintenance of the
cap would be required. If stage 2 of this alternative is required, it would be relatively easy to implement
technically, since groundwater pump-and-treat system consist of readily available technologies and are
routinely installed at Sites with contaminated groundwater. Administratively, coordination with local
authorities may be required for the discharge of treated water and emissions from the treatment system. The
implementability of Alternative 3A is identical to the implementability of stage 2 of Alternative 3.

For Alternative 4, on-Site construction activities would be minor, consisting of well installation and
construction or mobilization of a small treatment system. A pilot test will be necessary at the Loohn's
source area in order to determine whether VER or SVE/AS would be the more effective means of treatment and to
design the treatment system. However, in situ treatment technologies are still considered innovative, and
there are only a small number of vendors offering these services. In addition, effective operation requires
intensive monitoring and assessment. Administratively, coordination with local authorities and other
agencies may be required for the discharge of treated water and vapor; however, this alternative does not
involve any off-Site transporation of hazardous materials. If stage 2 of this alternative were required, it
would be relatively easy to implement technically, since groundwater pump-and-treat systems consist of
readily available technologies and are routinely installed at sites with contaminated groundwater.
Administratively, the requirements would be similar to the requirements for a VER or SVE/AS system.

Alternative 5 would require excavation ot depths of approximately 22 feet with approximately 14 feet below
the water table. Dewatering and shoring would be required; however, this alternative could be implemented
using conventional construction techniques. Off-Site RCRA storage, treatment and disposal facilities are
available for treatment and disposal of VOC-contaminated soil. Administratively, this alternative would be
moderately difficult to implement, since it would require coordination with the local authorities and other
agencies for transportation, treatment and disposal of hazardous materials. If stage 2 of this alternative
is required, it would be relatively easy to implement technically, since groundwater pump-and-treat systems
consist of readily available to technologies and are routinely installed at Sites with contaminated
groundwater. Administratively, coordination with local authorities may be required for the discharge of

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treated water and emissions from the treatment system.

Cost

The 30-year net present worth  (NPW) of the remedial alternative for the Loohns source area range from $0 to
$4,186,299, based on a discount rate of 7%.  Alternatives 1 and 2 are the least expensive to implement, with
NPWs of $0 and $153,295, respectively.  Alternative 3  (stage 1) is slightly more expensive, with a NPW of
$256,340.  If stage 2 of Alternative 3 is implemented, the overall cost of this alternative is approximately
$890,344, but treatment of contaminated groundwater is provided.  Alternative 3A, which includes a
pump-and-treat for longer period of time, but no capping, has a NPW of $1,070,610. Alternative 4 (stage 1)  is
significantly more expensive than Alternative 3  (stage 1), with a NPW of $1,011,024.  If stage 2 of
Alternative 4 is implemented, the cost increases to $1,645,028, and additional groundwater treatment is
provided.  Alternative 5 (stage 1)  is significantly more expensive than Alternative 4 (stage 1), with a NPW
of $3,552,295.  If stage 2 of Alternative 5 is implemented, groundwater treatment is provided, and the NPW is
$4,186,299.  Cost estimates are summarized in Table 9.

STATE ACCEPTANCE

The State of New York concurs with the selected remedies for the identified source areas.  Their letter of
concurrence is attached as Appendix IV.

COMMUNITY ACCEPTANCE

Community acceptance of the preferred remedies has been assessed in the Responsiveness Summary portion of
this ROD, following review of all public comments received on the supplemental RI/FS report and the Proposed
Plan.  All comments received during the public comment period were evaluated and are addressed in the
attached Responsiveness Summary.

Comments on EPA's Proposed Plan were received from the public and the Potentially Responsible Parties.  No
specific objection were raised by the public on implementation of the remedies stated in the Proposed Plan.
EPA's specific responses to the comments received on the Proposed Plan and all other comments received during
the public comment period can be found in Appendix V.

SELECTED REMEDIES

The following is a discussion of the selected remedial alternatives for the four source areas.  The
alternatives best satisfy 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).

ALCAS

Based on the treatability tests, Vacuum Enhanced Recovery  (VER), Alternative 4, is selected for the Alcas
source area.  This alternative is the most effective in protecting human health and the environment, while
being the most cost-effective.  Approximately 28,800 cubic feet of contaminated soil needs to be remediated
at Alcas.

A VER system, which will be installed at Alcas, uses negative air pressure which is applied to a series of
recovery wells.  The negative pressure, which is generated by high vacuum pump, causes the movement of soil
vapor and groundwater towards the recovery wells.  The vapor recovery causes desorption  (removal of
contaminants, which are adsorbed onto soil particles) and volatilization of VOCs by continuously removing
contaminated vapors and forcing clean air into the contaminated areas.  An off-gas treatment system will
remove contaminants which are above federal and New York State air emission levels using granulated activated
carbon (GAG).  Groundwater, which will be recovered with the soil vapor, will also be treated with GAG prior
to discharge to the City sewer system.

The VER system will be operated until contaminant levels in the soil vapor and water effluents cease to
decline and remain constant at a negligible rate, at which time, the systems will be shut off.  After the VER

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system is shut off, soil samples will be collected to confirm the effectiveness of the alternative.

Finally, the remedy selected for the Alcas property will include deed restrictions which will prevent the
installation of drinking water wells on the property.

The present worth for Alternative 4 is $837,721 for the Alcas source area. Table 9 provides the costs for
each remedial alternative by source area.

LOOHN'S DRY CLEANERS AND LAUNDERERS

Alternative 4 is selected for the Loohn's Dry Cleaners source area. This Alterative is the most effective in
protecting human health and the environment, while being the most cost-effective. EPA is also selecting
Alternative 5 as a contingency for remediating the Loohns source area. Alternative 5 would be implemented
if the pilot testing, which is planned for the Loohn's property, indicates either that a VER or SVE/AS system
would be ineffective or, if running either system would be infeasible due to the effects of the Allegheny
River. While not guite as cost-effective as Alternative 4, Alternative 5 will be just as effective in
protecting human health and the environment. Approximately 132,000 cubic feet of contaminated soil needs to
be remediated at Loohn's Dry Cleaners.

Alternative 4 will involve using either one of two different types of in-situ treatment systems: SVE with
Air Sparging (SVE/AS) or Vacuum Enhanced Recovery (VER), based on the results of pilot tests which will be
conducted as part of the remedial design.

An SVE/AS system would use a soil vapor recovery process combined with air injection wells, which would
extend below the water table. Air, which is injected under pressure into the wells, would enter water below
the water table. The air bubbles, which are formed, traverse horizontally and vertically through the water
column. Volatile compounds, which are exposed to the sparged air, volatilize into the gas phase and are
carried into the vadose zone where they are captured by a vapor recover system. An off-gas treatment system
would use GAG to remove contaminants which are above federal and New York State air emission levels.
Groundwater, which is recovered with the soil vapor, would also be treated with GAG prior to discharge to the
City sewer system.

A VER system uses negative air pressure, which is applied to a series of recovery wells. The negative
pressure, which is generated by high vacuum pump, causes the movement of soil vapor and groundwater towards
the recovery wells. The vapor recovery causes desorption (removal of contaminants, which are adsorbed onto
soil particles) and volatilization of VOCs by continuously removing contaminated vapors and forcing clean air
into the contaminated areas. An off-gas treatment system would remove contaminants which are above federal
and New York State air emission levels using granulated activated carbon (GAG). Groundwater, which is
recovered with the soil vapor, would also be treated with GAG prior to discharge to the City sewer system.

The system will be operated until contaminant levels in the soil vapor and water effluents cease to decline
and remain constant at a negligible rate, at which time, the systems will be shut off. Thereafter, soil
samples will be collected to confirm the effectiveness of the alternative.

Any contamination which is not removed by implementation of a VER or SVE/AS system, will be addressed, if
necessary, by the installation of a groundwater pump-and-treat system. The need for groundwater treatment
will be assessed every four years and will be based on a review of sample data for the influences to the city
Municipal wells 18M and 37/38M and upgradient and downgradient groundwater samples from the Loohn's source
area.

Finally, the remedy selected for the Loohn's property will include deed restrictions, which will prevent the
installation of drinking water wells on the property.

The costs for implementing Alternative 4 and 5 is $1,654,028 and $4,186,299, respectively, for the Loohn's
source area. Table 9 provides the costs for each remedial alternative by source area.

AVX

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Alternative 5, excavation, is selected for the AVX source area. This alternative is the most effective in
protecting human health and the environment, while being cost-effective. The area of contaminated soil is
very shallow (approximately 6 feet below the surface), which can be easily excavated. The soil to be
excavated is located in and around soil borings SB04 and SB07 and is estimated to be 10,000 cubic feet.

Contaminated soil at AVX will be excavated and tested to determine if it is a RCRA hazardous waste material.
If hazardous, the soils will be transported to an off-Site facility for low temperature desorption of soil
contaminants. If not hazardous, the soils will be disposed of at a local landfill. Clean fill material will
be brought in to restore the excavated area to grade. Confirmatory soil sampling and analyses will be
conducted to ensure that all soils with contaminant levels higher that the levels provided in Table 1 of this
ROD are removed.

Until restoration of the excavated areas is complete, land use/access restrictions will be placed on the
source area to restrict its use. Deed restrictions will be imposed to prevent the installation of drinking
water wells on the property. Finally, during all phases of the soil removal, it will be necessary to
implement dust and volatile emission control, soil erosion and sediment control measures.

Alternative 5 proved to be more cost-effective than Alternative 4, which was also found to be protective of
human health and the environment. The estimated present worth for Alternative 5 was $1,010,299 verses
$1,747,533 for Alternative 4.

Any contamination which is not removed from the AVX source area, will be addressed, if necessary, by the
installation of a groundwater pump-and-treat system. The need for groundwater treatment will be assessed
every four years and will be based on a review of sample data for the influences to the city municipal wells
18M and 37/38M and upgradient and downgradient groundwater samples from the AVX source area.

Also, if groundwater treatment is determined to be necessary for the AVX source area, EPA will also evaluate
the impact of a groundwater pump-and-treat system on the wetlands area. This evaluation will weigh the need
for reducing contaminant concentrations in the groundwater with any potentially adverse affect on the
wetlands area.

McGRAW-EDISON

Alternative 3A is selected for the McGraw-Edison source area as the most effective in protecting human health
and the environment, while being the most cost-effective. An extensive investigation of the McGraw-Edison
property was conducted during the SRI, but no soil contamination was found, which could act as a source of
contamination to the groundwater. However, groundwater contamination was detected at the facility, which EPA
believes is the result of previous disposal activities. By capturing and treating the groundwater rather
than letting it be treated by the municipal wells, cleanup of the aguifer can be expedited. Contaminated
groundwater from the upper aguifer will be pumped and treated by an existing air stripping system, which is
currently treating groundwater from the lower aguifer. The existing air stripper has enough excess capacity
to treat additional groundwater from the upper aguifer. Groundwater monitoring will also be institued
upgradient and downgradient of the source area in order to determine the continued effectiveness of the
remedy.

The remedy selected for the McGraw-Edison property will also include deed restrictions which will prevent the
installation of drinking water wells on the property.

The present worth of Alternative 3A is $935,610.

SITE MONITORING

Based on information collected during the SRI/FS, EPA has also decided to expand the list of chemical
compounds, which are currently being tested for under the current groundwater Site monitoring plan (SMP).
The PRPs were reguired to develop and implement the plan, as a reguirement of the EPA Administrative Order
issued on February 7, 1986. The plan was reguired in order assess the condition of the groundwater in the
upper and lower aguifers as the remedies, which were specified in EPA's 1985 ROD, were implemented.

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Currently, the SMP specifies that 13 groundwater monitoring wells be sampled every three months for the
presence of trichloroethene, 1,1,1-trichloroethene, 1,1-dichlorethane, 1,1-dichloroethene, 1,2-
dichloroethene and tetrachloroethane.

During the supplemental RI/FS, other VOCs, which were not tested for as part of the SMP, and chromium were
detected in the groundwater. Chromium was also detected in recent samples taken from the influent
groundwater to Municipal wells 18M and 37/38M. Therefore, EPA is proposing that the SMP be revised to
include analyses for a full scan of volatile organic compounds and chromium.

EPA will use the expanded SMP data along with the groundwater monitoring data, which will be collected to
determine whether or not groundwater pump and treat is needed for the AVX and Loohn's source area properties,
to assess the overall improvement of the groundwater as the source control remedies are implemented.

The chromium sample data will be collected to determine if there are unacceptable concentrations of chromium
in the groundwater, which flow to the municipal wells.

STATUTORY DETERMINATIONS

As previously noted, CERCLA §121(b)(1), 42 SU.S.C. §0621(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 federal and state ARARs, unless a wavier 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 for each source area property
meet the reguirements of CERCLA §121, 42 U.S.C. §9621:

ALCAS

Protection of Human Health and the Environment

Alternative 4 (Vacuum Enhanced Recovery) will reduce or eliminate the Alcas source area by removal and
treatment. Elimination of soil and groundwater contamination is protective of human health and the
environment, since it will lead to restoration of the aguifer, which is a source of drinking water and
eliminate unacceptable risks due to ingestion and dermal contact with untreated groundwater.

Any short-term risks due to the construction of a VER system will be mitigated through a site-specific health
and safety plan appropriate engineering controls. Engineering controls would also address cross-media
impacts. This would involve air emissions from the operation of a VER system.

The remedy selected for the Alcas property will also include deed restrictions which will contribute to the
protection of human health by preventing the installation of drinking water wells on the property.

Compliance with ARARs

Significant guantities of contaminants in both the soil and groundwater would be removed by VER, thereby
eliminating additional contributions of contamination to the City Aguifer and eventually resulting in
compliance with chemical-specific ARARs.

Proper design and implementation of the VER or SVE/AS system and treatment of the extracted groundwater and
vapor will ensure that the implementation of this alternative will be in compliance with location- and
action-specific ARARs.

Specific ARARs include:

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1. Federal hazardous waste management requirements: Regulations for Organic Air Emission Standards, 40
CFR Part 26 Subparts AA and BB, and the monitoring and detection requirements for Solid Waste Management
Units under 40 CFR part 264 Subpart F, are applicable. Also, groundwater monitoring regulations under 40 CFR
Part 264, Subpart F standards are applicable to long-time monitoring of the site. These standards provide
guidance for well construction and placement, sample collection and analysis procedures applicable to the
remedial action.

2. NYSDEC's hazardous waste management requirements may be found at 6 NYCRR Parts 370-372.

3. NYSDEC's Technical and Administrative Guidance Memorandum (TAGM), number HWR-94-4046, for determining
soil cleanup objectives.

4. State and federal air requirements: 6 NYCRR Parts 200-257, 6 NYCRR Parts 360-373 and 40 CFR Parts 50
and 61 and the NYSDEC's Air Guide-1

5. State and federal water requirements: federal requirements at 40 CFR Part 141, Section 404 of the
Clean Water Act, and Executive Order 11988 (Floodplain Management); New York State requirements at 6 NYCRR
Parts 701-703 and the NYSDOH requirements at 10 NYCRR, Subpart 5-1; Water Supplies.

6. Applicable requirements of the National Historic Preservation Act of 1966, as amended.

This alternative, upon completion of VER treatment, should also be in compliance with the soil RAOs.

Cost-Effectiveness

Alternative 4 is the most cost-effective alterative for the Alcas source area which is protective of human
health and the environment and which complies with ARARs. Only Alternatives 4 and 5 met these criteria. The
present worth of Alternative 4 is $837,721, while the present worth for Alternative 5 is $1,013,495.

Utilize Permanent Solutions and Alternative Treatment Technologies or Resource Recovery Technologies to the
Maximum Extent Practicable

Alternative 4 will permanently remove contamination in the soil and groundwater and therefore will meet the
statutory requirement for utilization of treatment as a permanent solution for eliminating contamination.
The alternative is also the most balanced selection when considering all the NCP criteria.

Preference for Treatment as a Principal Element

Alternative 4 involves treatment of contaminated soil and groundwater and therefore satisfies the statutory
requirement for selecting an alternative which has treatment as its primary element.

LOOHN'S DRY CLEANERS AND LAUNDERERS

Protection of Human Health and the Environment Alternative 4 (Vacuum Enhanced Recover (VER) or Soil Vapor
Extraction with Air Sparging (SVE/AS)) or Alternative 5 (Excavation) will reduce or eliminate the Loohn's
source area by removal and treatment. Upon completion of the remediation of soil contamination at all of the
source areas, groundwater quality will be monitored and the effectiveness of the remediation reevaluated at
four-year intervals. If it is determined that the City Aquifer still contains contaminant concentrations
above drinking water standards and if it is determined that the remediated source area continues to affect
the groundwater entering the City Municipal wells 18M, 37M and 38M, a groundwater pump-and-treat system may
be installed.

Elimination of soil and groundwater contamination is protective of human health and the environment, since it
will lead to restoration of the aquifer, which is a source of drinking water. The risk assessment revealed
unacceptable risks due to ingestion and dermal contact with untreated groundwater.

Any short-term risks due to the construction of a VER of SVE/AS system or due to excavation will be mitigated

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through a site-specific health and safety plan and appropriate engineering controls. Engineering controls
would also address cross-media impacts. This would involve air emissions from operation of a soil treatment
system or a groundwater extraction and treatment system.

The remedy selected for the Loohn's property will also include deed restrictions which will contribute to the
protection of human health by preventing the installation of drinking water wells on the property.

Compliance with ARARs

Significant quantities of contaminants in both the soil and groundwater will be removed by VER or SVE/AS,
thereby eliminating additional contributions of contamination to the City Aguifer and eventually resulting in
compliance with chemical-specific ARARs. It is expected that compliance with chemical-specific ARARs would
be achieved over time. If selected as the contingency alternative, Alternative 5 would provide rapid
compliance with chemical-specific ARARs, since the groundwater contaminant concentrations would be rapidly
reduced by implementation of this alternative. Contaminated soil that is acting as a source of contamination
to the groundwater would be removed in this alternative, thereby eliminating additional contributions of
contamination to the City Aguifer and resulting in compliance with chemical-specific ARARs. If it is
determined that chemical-specific ARARs in the groundwater have not been achieved, a groundwater
pump-and-treat system may be installed to ensure compliance with groundwater ARARs.

Specific ARARs include:

1. Federal hazardous waste management requirements: Regulations for Organic Air Emission Standards, 40
CFR Subparts AA and BB, and the monitoring and detection requirements for Solid Waste Management Units under
40 CFR Subpart F, are applicable. Also, groundwater monitoring regulations under 40 CFR Part 264, Subpart F
standards are applicable to long-term monitoring of the site. These standards provide guidance for well
construction and placement, sample collection and analysis procedures applicable to the remedial action.

The following federal requirements may also apply if Alternative 5, is implemented: 40 CFR Part 262, as a
generator, and 40 CFR Part 263 as a transporter. In addition, the RCRA land disposal restrictions of 40 CFR
Part 268 are applicable. As with Alternative 4, 40 CFR 264 Subparts F, AA, and BB are applicable to the
groundwater treatment system.

2. NYSDEC's hazardous waste management requirements may be found at 6 NYCRR Parts 370-372.

3. NYSDEC's Technical and Administrative Guidance Memorandum (TAGM), number HWR-94-4046, for determining
soil clean up objectives.

4. State and federal air requirements: 6 NYCRR Parts 200-257, 6 NYCRR Parts 360-373 and 40 CFR Parts 50
and 61 and the NYSDEC's Air Guide-1

5. Applicable requirements of the National Historic Preservation Act of 1966, as amended.

6. State and federal water requirements: federal requirements at 40 CFR. Part 141, Section 404 of the
Clean Water Act, and Executive Order 11988 (Floodplain Management); New York State requirements at 6 NYCRR
Parts 701-703 and the NYSDOH requirements at 10 NYCRR, Subpart 5-1; Water Supplies.

Cost-Effectiveness

Of the alternatives evaluated for the Loohn's source area, Alternatives 3, 3A, 4 and 5 were protective of
human health and the environment and could achieve ARARs. Alternative 4 was less costly than Alternatives 3A
and 5, but slightly more costly (about 13.5%) than Alternative 3. This additional cost is justified since
Alternative 4 will permanently remove the contaminated soil while Alternative 3 will only contain it.

Utilize Permanent Solutions and Alternative Treatment Technologies or Resource Recovery Technologies to the
Maximum Extent Practicable

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Alternative 4 and contingency Alternative 5 will permanently remove contamination in the soil and groundwater
and therefore will meet the statutory reguirement for utilizing a permanent solution for eliminating
contamination. The alternative is also the most balanced selection when considering all the NCP criteria.

Preference for Treatment as a Principal Element

Alternative 4 is EPA's preferred alternative for Loohn's and involves treatment of contaminated soil and
groundwater. This selection satisfies the statutory reguirement for selecting an alternative which has
treatment as its primary element.

AVX

Protection of Human Health and the Environment

Alternative 5 will completely eliminate the identified source area by excavation and off-Site treatment and
disposal. Upon completion of the remediation of soil contamination at all of the source areas, the
groundwater guality will be monitored and the effectiveness of the remediation reevaluated at four-year
intervals. If it determined that the City Aguifer still contains contaminant concentrations above drinking
water standards and if it is determined that the remediated source area continues to affect the groundwater
entering the City Municipal wells 18M, 37M and 38M, a groundwater pump-and-treat system may be installed.

Elimination of soil and groundwater contamination is protective of human health and the environment, since it
will lead to restoration of the aguifer, which is a source of drinking water and will eliminate unacceptable
risks due to ingestion and dermal contact with untreated groundwater.

Any short-term risks due to excavation will be mitigated through a site-specific health and safety plan and
appropriate engineering controls. Engineering controls would also address cross-media impacts. This would
involve air emissions from operation of a groundwater extraction and treatment system.

The remedy selected for the AVX property will also include deed restrictions which will contribute to the
protection of human health by preventing the installation of drinking water wells on the property.

Compliance with ARARs

Alternative 5 will provide the most rapid compliance with chemical-specific ARARs, since the groundwater
contaminant concentrations will be rapidly reduced by implementation of this alternative. Contaminated soil
that is acting as a source of contamination to the groundwater will be removed in this alternative, thereby
eliminating additional contributions of contamination to the City Aguifer and resulting in compliance with
chemical-specific ARARs. If it is determined that chemical-specific ARARs in the groundwater are not
achieved, a groundwater pump-and-treat system may be installed to ensure compliance with groundwater ARARs.

Specific ARARs include:

1. Federal hazardous waste management reguirements: The following regulations may apply: 40 CFR Part
262, as a generator, and 40 CFR Part 263 as a transporter. In addition, the RCRA land disposal restrictions
of 40 CFR Part 268 are applicable. Also, 40 CFR 264 Subparts F, AA, and BB are applicable to the groundwater
treatment system.

2. NYSDEC's hazardous waste management reguirements may be found at 6 NYCRR Parts 370-372.

3. NYDEC's Technical and Administrative Guidance Memorandum (TAGM), number HWR-94-4046, for determining
soil clean up objectives.

4. State and federal air reguirements: 6 NYCRR Parts 200-257, 6 NYCRR Parts 360-373 and 40 CFR Parts 50
and 61 and the NYSDEC's Air Guide-1.

5. State and federal water reguirements: federal reguirements at 40 CFR. Part 141, Section 404 of the

-------
Clean Water Act, and Executive Order 11988 (Floodplain Management); New York State requirements at 6 NYCRR
Parts 701-703 and the NYSDOH requirements at 10 NYCRR, Subpart 5-1; Water Supplies.

6. Federal Management Practices, which can be found in the Federal Register at Vol. 51, No. 219, Part
330.6, will be followed in order to minimize the spread of contamination and habitat impacts to the wetlands
from the selected remedial activities. In addition, Executive Order 11990 on Protection of Wetlands and
EPA's Statement of Policy on Wetlands and Floodplain applies.

Cost-Effectiveness

Of the alternatives evaluated for the AVX source area, Alternatives 3, 3A, 4 and 5 are protective of human
health and the environment and could achieve ARARs. Alternative 5 is less costly than Alternatives 4 and 3A,
but slightly more costly (about 23%) than Alternative 3. This additional cost is justified since Alternative
5 will permanently remove the contaminated soil while Alternative 3 will only contain it.

Utilize Permanent Solutions and Alternative Treatment Technologies or Resource Recovery Technologies to the
Maximum Extent Practicable

Alternative 5, excavation, meets the statutory requirement for utilizing treatment as a permanent solution
for eliminating the contamination. The alternative is also the most balanced selection when considering all
the NCP criteria.

Preference for Treatment as a Principal Element

Although treatment is not a principal element of Alternative 5, the excavated soil will be treated, if
necessary, in order to dispose of it properly. Also, if excavation does not result in adequate improvement
of the groundwater, the groundwater will be treated, which will satisfy the statutory requirement for
selecting an alternative which has treatment as its primary element.

McGRAW-EDISON

Protection of Human Health and the Environment

Alternative 3A will be implemented immediately at the McGraw-Edison site, since there is no soil source area
to be remediated. Proper operation and maintenance of the groundwater pump-and-treat system will ensure that
the RAOs for groundwater will be achieved. Extraction of contaminated groundwater will protect human health
and the environment by removing contamination from the aquifer and preventing migration of contaminants from
this area to the municipal well field.

Elimination of groundwater contamination is protective of human health and the environment, since it will
lead to restoration of the aquifer, which is a source of drinking water. In addition, the risk assessment
revealed unacceptable risks due to ingestion and dermal contact with untreated groundwater.

Any short-term risks due to modification of the existing groundwater extraction and treatment system will be
mitigated through a site-specific health and safety plan. Engineering controls would also address
cross-media impacts. This would involve air emissions from operation of the groundwater extraction and
treatment system.

The remedy selected for the McGraw-Edison property will also include deed restrictions which will contribute
to the protection of human health by preventing the installation of drinking water wells on the property.

Compliance with ARARs

By treating the groundwater beneath McGraw-Edison site, further contamination migration to the municipal
supply wells will be eliminated, eventually resulting in compliance with chemical-specific ARARs.

Specific ARARs include:

-------
1. Federal hazardous waste management requirements: Regulations for Organic Air Emission Standards, 40
CFR Part 264 Subparts AA and BB, and the monitoring and detection requirements for Solid Waste Management
Units under 40 CFR Part 264 Subpart F, are applicable.

2. NYSDEC's hazardous waste management requirements may be found at 6 NYCRR Parts 370-372.

3. State and federal air requirements include: 6 NYCRR Parts 200-257, 6 NYCRR Parts 360-373 and 40 CFR
Parts 50 and 61 and the NYSDEC's Air Guide-1.

4. State and federal water requirements include: federal requirements at 40 CFR. Part 141, Section 404
of the Clean Water Act, and Executive Order 11988 (Floodplain Management); New York State requirements at 6
NYCRR Parts 701-703 and the NYSDOH requirements at 10 NYCRR, Subpart 5-1; Water Supplies.

Cost-Effectiveness

Alternative 3A is the most cost-effective alterative for the McGraw-Edison source area, is protective of
human health and the environment and complies with ARARs. Alternatives 1 and 2 were determined not to be
protective of human health and the environment. Alternatives 4 and 5 were not evaluated since there was no
soil contamination. The present worth of Alternative 3A is $935,610.

Utilize Permanent Solutions and Alternative Treatment Technologies or Resource Recovery Technologies to the
Maximum Extent Practicable

Alternative 3A meets the statutory requirement for selecting a remedy which utilizes treatment as a permanent
solution for eliminating the contamination. The alternative is also the most balanced selection when
considering all the NCP criteria.

Preference for Treatment as a Principal Element

Alternative 3A involves treatment of contaminated groundwater and therefore satisfies the statutory
requirement for selecting an alternative which has treatment as its primary element.

DOCUMENTATION OF SIGNIFICANT CHANGES

There are no significant changes from the preferred alternative presented in the Proposed Plan.

APPENDIX I

FIGURES

APPENDIX II

TABLES

-------
Table 1
Contaminant
Benzene
2-Butanone
Cis 1,2- Dicloro-
ethene
Ethylbenzene
Tetrachloro
ehtene
1,1, 1-Trichloro-
e thane
Trichloroethene
Toluene
Vinyl Chloride
Xylene

Soil Clean up Federal
Objective Ground
water MCL
60 ppb 5 ppb
300 ppb
300 ppb 70 ppb
5,500 ppb 700 ppb
1, 400 ppb 5 ppb
800 ppb 200 ppb

700 ppb 5 ppb
1,500 ppb 1, 000 ppb
200 ppb 2 ppb
1,200 ppb 10,000 ppb


New York State
Water Quality
Standard-1
0.
50
5
5
5
5

5
5
2
5
7 ppb
ppb
ppb
ppb
ppb
ppb

ppb
ppb
ppb
ppb
1  -  The values listed are the more stringent of New York States drinking water and groundwater standards.

-------
TABLE 2

CHEMICALS OF CONCERN
GROUNDWATER EXPOSURE PATHWAY
OLEAN WELLFIELD SITE
CHEMICAL NAME
                       INDICATOR
                                   CHEMICALS  OF  CONCERN
                                     REASON FOR  EXCLUSION
ORGANICS  (ug/L)
1,1,1-Trichloroethane      Y
1,1,2-Trichloroethane      Y
1,1-Dichloroethane          Y
1,1-Dichloroethene          Y
1,2-Dichlorobenzene         Y
1,2-Dichloroethane          Y
cis-1,2-Dichloroethene     Y
trans-1,2-Dichlorethene    Y
1,2-Dichloroethene  (total) Y
Acetone                     Y
Benzene                     Y
Butyl benzyl phthalate     Y
Carbon disulfide            Y
Chlorobenzene               Y
Chloroform                  Y
Ethylbenzene                Y
Methylene chloride          Y
Tetrachloroethene           Y
Toluene                     Y
Trichloroethene             Y
Vinyl chloride              Y
Xylenes (Total)             Y
                                                                                          DETECTED RANGE
                                                                                   MAXIMUM
                                                                                                             MINIMUM
                                                                                                                             95% UCL
3,
6,
2,
1.
2,
1.
3,
3,
7,
1.
6,
6,
5,
1.
1.
2,
5,
1.
9,
1.
2,
3,
.60E +
.OOE-01
.60E +
. 60E +
. 60E +
.OOE +
.20E +
.OOE +
.30E +
.80E +
.OOE +
.OOE-01
.OOE +
.OOE +
.OOE +
. 10E +
.50E +
.40E +
.60E +
. 10E +
.50E +
. 90E +
05

04
04
01
00
03
00
04
05
00

00
00
00
01
03
04
01
05
01
03
4.OOE + 00
6.OOE-01
9.OOE-01
9.OOE-01
2.60E + 01
l.OOE + 00
2.OOE + 00
l.OOE + 00
2.OOE + 00
3.70E + 03
4.OOE + 00
6.OOE-01
5.OOE-01
l.OOE + 00
6.OOE-01
2.10E + 01
7.30E + 02
7.OOE-01
7.OOE-01
5.OOE-01
l.OOE + 00
9.OOE-01
 8.12E + 02
     *
 3.90E + 01
 3.22E + 01
 1.20E + 00
 6.53E
 2.57E
 2.03E
 3.64E
 3.01E
 2.32E
01
00
03
04
00

00
 3.31E + 00
 2.27E + 02
 3.40E + 01
 8.21E + 00

 3.04E + 00
3.29E + 01

-------
INORGANICS
Aluminum
Arsenic
Barium
Beryllium
Cadmium
Chromium
Cobalt
Copper
Lead
Manganese
Nickel
Potassium
Selenium
Thallium
Vanadium
Zinc
(mg/L)
                Y
                Y
                Y
                Y
                Y
                Y
                Y
                N
                N
                Y
                Y
                N
                Y
                Y
                Y
                Y
1,3

1
3
1
2
7

7

2
6

2
1
3
4
87E +
. 10E -
.77E -
.70E -
.20E -
. 10E -

.51E -

.20E -
.80E -

. 10E -
.OOE -
.35E -
.40E -
04
h 01
h 02
h 00
h 00
h 01

h 01

h 03
h 01

h 00
h 00
h 01
h 01
1.
1.
3.
1.
2.
7.
3.
1.
4.
4.
6.
7.
2.
1.
2.
1.
,42E H
,30E H
,67E H
,40E H
,20E H
,80E H
, 94E H
,68E H
,39E H
,26E H
,70E H
, 05E H
, 10E H
,OOE H
, 89E H
,27E H
- 02
- 00
- 01
- 00
- 00
- 00
- 01
- 01
- 01
- 01
- 01
- 03
- 00
- 00
- 01
- 01
                                                                     7.90E + 00

                                                                     1.30E + 00


                                                                     1.55E + 03

-------
TABLE 2

CHEMICALS OF CONCERN
GROUNDWATER EXPOSURE PATHWAY
OLEAN WELLFIELD SITE

CHEMICAL NAME                      CHEMICALS  OF  CONCERN                            DETECTED RANGE              95% UCL
                       INDICATOR     REASON FOR  EXCLUSION                  MAXIMUM          MINIMUM

Note:
Y:  Yes
N:  NO

1:  No available SF and RfDs.
2:  It is not carcinogenic compound  and the  detection  frequency is lower then  5  %.
3:  Essential nutrient
*:  UCL greater than maximum concentration
-:  Sample number is less than 10.   No 95% UCL was calculated.

-------
TABLE 3
CHEMICAL OF CONCERN
SOIL EXPOSURE PATHWAY
OLEAN WELLFIELD SITE-ALCAS
CHEMICAL NAME
VOA(ug/kg)
Vinyl chloride
Methylene chloride
Acetone
Carbon disulfide
1,2-Dichloroethene
Chloroform
Butanone
Trichloroethene
Tetrachloroethene
Toluene
Xylene (Total)
                                          CHEMICAL OF CONCERN
                                     INDICATOR   REASON OF EXCLUSION
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
                                                     DETECTED RANGE
                                                 MAXIMUM            MINIMUM
                                                                                                                             95%  UCL
1.
6,
1.
3,
1.
1.
4,
1.
2,
9,
1.
.OOE -
.OOE -
.OOE -
.20E -
.OOE -
.60E -
.OOE -
.20E -
.OOE -
.70E -
.OOE -
h 02
h 00
h 04
h 01
h 03
h 02
h 00
h 04
h 02
h 01
h 02
1.
2.
1.
2.
1.
1.
2.
8.
2.
5.
1.
, OOE +
, OOE +
, 10E +
, 90E +
, OOE +
,60E +
, OOE +
, OOE +
, OOE +
.OOE-01
, OOE +
02
00
01
01
00
02
00
00
02

00
3.98E H
3.06E H
8.50E H
3.86E H
1.68E H
1.71E H
2.97E H
1.70E H
1.86E H
3.93E H
- 02
- 02
- 04
- 02
- 03
- 02
- 02
- 04
- 02
- 02
                                                                                     1.72E  + 02

-------
BNA  (ug/kg)
2-Methylphenol
4-Methylphenol
2,4-Dimethylphenol
1,2,4-Trichlorobenzene
Naphthalene
2-Methylnaphthalene
Acenaphthylene
Acenaphthene
Dibenzofuran
Fluorene
Phenanthrene
Anthracene
Carbazole
Fluoranthene
Pyrene
Benzo(a)anthracene
Chrysene
Benzo(b)fluoranthene
Benzo(k)fluoranthene
Benzo(a)pyrene
Indenol(1,2,3-cd)pyrene
Dibenz(a,h)anthracene
Benzo(g,h,i)perylene
INORGANIC  (mg/kg)
Aluminum
Antimony
Arsenic
Barium
Beryllium
Cadmium
Calcium
Chromium
Y
Y
Y
Y
Y
N
N
Y
N
Y
N
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
N
N
Y
Y
Y
Y
Y
N
Y
5,
1.
8,
3,
2,
1.
7,
2,
3,
5,
2,
6,
1.
2,
1.
1.
1.
5,
6,
8,
4,
7,
2,
3,
1.
1.
1.
4,
7,
1.
9,
. 90E +
. 90E +
.20E +
.OOE +
.50E +
.50E +
. 60E +
. 60E +
.OOE +
.OOE +
.20E +
.40E +
.50E +
.20E +
.80E +
.OOE +
.OOE +
.70E +
.80E +
.80E +
. 10E +
.20E +
.30E +
. 01E +
. 89E +
. 49E +
. 49E +
.80E +
. 90E-01
. 67E +
.44E +
01
02
01
01
03
03
02
03
03
03
04
03
03
04
04
04
04
03
03
03
03
02
03
04
01
01
03
00

05
02
5
1
8
2
3
9
5
7
6
8
7
1
7
9
8
2
3
3
1
5
1
7
3
4
1
7
8
.90E +
.90E +
.20E +
.80E +
.20E +
.OOE +
.OOE +
.OOE +
.OOE +
.OOE +
.20E +
.20E +
.OOE +
.70E +
.60E +
.80E +
.70E +
.60E +
.OOE +
.OOE +
.20E +
.20E +
.OOE +
.81E +
.89E +
.80E +
. 16E +
01
02
01
01
01
00
00
00
00
00
01
01
00
01
01
01
01
01
01
01
01
01
01
03
01
00
01
2.80E-01
4.
4
1
70E-01
.62E +
.24E +

02
01
1.62E + 04
6.28E + 00
4.38E + 01
5.16E + 02
1.66E + 00
6.99E-01
8.59E + 04
3.53E + 02

-------
TABLE 3
CHEMICAL OF CONCERN
SOIL EXPOSURE PATHWAY
OLEAN WELLFIELD SITE-ALCAS
CHEMICAL NAME
                                         CHEMICAL  OF  CONCERN
                                     INDICATOR   REASON OF EXCLUSION
                                                    DETECTED RANGE
                                                MAXIMUM            MINIMUM
                                                                                                                            95% UCL
Cobalt
Copper
Iron
Lead
Magnesium

Manganese
Mercury
Nickel
Potassium
Selenium
Silver
Sodium
Thallium
Vanadium
Zinc
N
N
N
N
N

Y
Y
Y
N
Y
Y
N
Y
Y
Y
1.
9,
3,
1.
2,
4,
3,
6,
2,
2,
1.
6,
9,
3,
1.
. 16E +
.36E +
. 05E +
. 07E +
.22E +
.68E +
. 60E-01
.31E +
. 09E +
. 09E +
.70E +
.70E +
. 60E-01
.HE +
.20E +
01
01
04
02
04
03

01
03
03
00
02

01
02
1.
1.
8.
1.
1.
2.
9.
4.
4.
4.
1.
6.
4.
1.
2.
, 90E +
,33E +
,04E +
, 17E +
,44E +
, 95E +
, OOE-02
00
01
03
01
03
02

, 60E +00
,82E +
,82E +
,70E +
,14E +
.20E-01
,08E +
, 94E +
02
02
00
01

01
01
1.24E + 01
6.31E + 01
3.10E + 04
8.98E + 01
6.34E + 03
1.73E
        03
  94E-01
  10E + 01
  71E + 03
  OOE + 00
  90E-01
  63E + 02
5.28E-01
2.31E
1.01E
01
02
Note:
Y:  Yes
N:  No
1:  No available SF and RfDs.
2:  It is not carcinogenic compounds and the detection freguency is  lower  then  5  %.
-:  Sample number is less than 10. No 95% UCL was calculated.

-------
TABLE 3
CHEMICAL OF CONCERN
SOIL EXPOSURE PATHWAY
OLEAN WELLSFIELD SITE-AVX
CHEMICAL NAME
VOA  (ug/kg)
Methylene chloride
Acetone
1,1-Dichloroethene
1,1-Dichloroethane
1,2-Dichloroethene  (total)
Chloroform
1,2-Dichloroethane
2-Butanone
1,1,1-Trichloroethane
Trichloroethene
1,1,2-Trichloroethane
Benzene
4-Methyl-2-pentanone
Tetrachloroethene
1,1,2,2-Tetrachloroethane
Toluene
Ethyl benzene
Xylene  (total)
                                         CHEMICAL  OF  CONCERN
                                     INDICATOR   REASON OF EXCLUSION
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
N
Y
Y
                                                     DETECTED RANGE
                                                 MAXIMUM            MINIMUM
                                                                                                                            95% UCL
1.
1.
3,
2,
4,
8,
4,
4,
1.
5,
5,
1.
8,
2,
1.
1.
4,
4,
.70E -
.70E -
.70E -
.20E -
.50E -
.20E -
.70E -
.70E -
.30E -
.OOE -
.50E -
.20E -
. 90E -
.70E -
.70E -
.60E -
.OOE -
.OOE -
h 04
h 04
h 03
h 03
h 04
h 01
h 01
h 01
h 06
h 05
h 02
h 01
h 02
h 05
h 01
h 04
h 03
h 03
2,
2,
3,
5,
1,
8,
2,
2,
5,
3,
3,
1,
4,
3,
1,
3,
1,
1,
.OOE H
.OOE H
.70E H
.OOE H
.OOE H
.20E H
.OOE H
.OOE H
.40E H
.OOE H
.40E H
.OOE H
.OOE H
.OOE H
.70E H
.OOE H
.20E H
.20E H
- 00
- 00
- 03
- 00
- 00
- 01
- 00
- 00
- 01
- 00
- 01
- 00
- 00
- 00
- 01
- 00
- 01
- 01
2.56E H
2.57E H
5.58E H
7.51E H
2.22E H
8.99E H
7.78E H
1.24E H
2.26E H
4.90E H
3.98E H
6.18E H
1.09E H
1.12E H
6. OOE H
1.06E H
8.57E H
4.86E H
- 03
- 08
- 01
- 02
- 05
- 00
- 00
- 01
- 10
- 08
- 01
- 00
- 02
- 08
- 00
- 04
- 02
- 06

-------
BNA  (ug/kg)
2-Chlorophenol
1,2,4-Trichlorobenzene
Naphthalene
2-Methylnaphthalene
Acenaphthylene
Acenaphthene
Dibenzofuran
Fluorene
Phenanthrene
Anthracene
Carbazole
Fluoranthene
Pyrene
Benzo(a)anthracene
Chrysene
Di-n-octylphthaiate
Benzo(b)fluoranthene
Benzo(k)fluoranthene
Benzo(a)pyrene
Indeno(1,2,3-cd)pyrene
Dibenza(a,h)anthracene
Benzo(g,h,i)perylene

INORGANIC  (mg/kg)
Aluminum
Arsenic
Barium
Beryllium
Cadmium
Y
Y
Y
N
N
Y
N
Y
N
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
N
N
Y
Y
Y
Y
1.
3,
8,
5,
4,
2,
1.
2,
2,
5,
3,
4,
4,
2,
2,
2,
2,
4,
1.
9,
1.
3,
1.
1.
1.
5,
7,
.OOE +
.70E +
. 10E +
.70E +
. 10E +
. 10E +
.20E +
.80E +
.70E +
.30E +
. 10E +
.OOE +
. 10E +
.30E +
.40E +
.OOE +
. 60E +
.OOE +
. 90E +
.30E +
.80E +
.60E +
.70E +
. 46E +
.28E +
.70E-01
.70E-01
01
01
01
01
01
02
02
02
03
02
02
03
03
03
03
00
03
02
03
02
02
02
04
01
03


1.
1.
2.
7.
5.
1.
1.
2.
8.
1.
8.
2.
1.
6.
8.
2.
7.
2.
6.
5.
1.
3.
1.
1.
9.
2.
5.
, OOE +
,20E +
,80E +
, OOE +
, OOE +
,40E +
,50E +
,70E +
,80E +
,30E +
, OOE +
, 10E +
,50E +
, OOE +
, OOE +
, OOE +
,50E +
, 60E +
,40E +
, OOE +
, 10E +
, OOE +
, 02E +
, 17E +
, 89E +
.70E-01
.50E-01
01
01
01
00
00
01
01
01
01
01
00
02
02
01
01
00
01
01
01
01
01
01
04
01
01

-------
TABLE 3
CHEMICAL OF CONCERN
SOIL EXPOSURE PATHWAY
OLEAN WELLFIELD SITE-AVX
CHEMICAL NAME
                                         CHEMICAL OF CONCERN
                                     INDICATOR   REASON OF EXCLUSION
                                                    DETECTED RANGE
                                                MAXIMUM            MINIMUM
                                                                                                                            95% UCL
Calcium
Chromium
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Mercury
Nickel
Potassium
Selenium
Silver
Sodium
Vanadium
Zinc
N
Y
N
N
N
N
N
Y
Y
Y
N
Y
Y
N
Y
Y
2,
2,
1.
2,
3,
3,
4,
1.
1.
2,
2,
5,
3,
1.
2,
9,
. 09E +
. 12E +
.44E +
. 77E +
. 33E +
.52E +
. 79E +
.30E +
. 10E-01
. 94E +
.88E +
. 10E-01
.20E +
. 16E +
. 86E +
.79E +
04
01
01
01
04
01
03
03

01
03

00
02
01
01
1.
1.
7.
1.
2.
1.
1.
5.
1.
1.
7.
5.
1.
7.
1.
6.
,21E +
, HE +
,80E +
,63E +
,27E +
,60E +
,55E +
,56E +
.10E-01
,32E +
, 91E +
.10E-01
, OOE +
,40E +
,51E +
, 19E +
03
01
00
01
04
01
03
02

01
02

00
01
01
01
Note:
Y:  Yes
N:  No
1:  No available SF and RfDs.
2:  It is not carcinogenic compounds and the detection freguency is lower then 5 %.
-:  Sample number is less than 10.  No 95% UCL was calculated.

-------
TABLE 3
CHEMICAL OF CONCERN
SOIL EXPOSURE PATHWAY
OLEAN WELLFIELD SITE-BORROW PIT
CHEMICAL NAME
                                         CHEMICAL OF  CONCERN
                                     INDICATOR   REASON OF EXCLUSION
                                                     DETECTED  RANGE
                                                MAXIMUM            MINIMUM
                                                                                                                            95% UCL
VOA  (ug/kg)
Methylene chloride
Tetrachloroethene

BNA  (ug/kg)
Bis(2-Ethlhexyl)phthalate

INORGANIC  (mg/kg)
Aluminum
Antimony
Arsenic
Barium
Beryllium
Cadmium
Calcium
Chromium
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Nickel
Potassium
Sodium
Vanadium
Zinc
Y
Y
N
Y
Y
Y
Y
Y
N
Y
N
N
N
N
N
Y
Y
N
N
Y
Y
1.20E + 01
l.OOE + 01
                                                 9.10E  +  01
9.00E + 00
l.OOE + 01
                                                               6.60E  +  01
9,
5,
1.
1.
5,
2,
7,
1.
1.
1.
4,
2,
2,
1.
1.
1.
7,
1.
5,
.26E +
.40E +
.56E +
.52E +
. OOE-01
.40E-01
.82E +
. 03E +
.59E +
.85E +
. 86E +
.70E +
. 17E +
.53E +
. 91E +
.08E +
. 13E +
.48E +
.32E +
03
00
01
02


02
01
01
01
04
01
03
03
01
03
01
01
01
6.
5.
1.
8.
2.
2.
5.
7.
8.
1.
2.
1.
1.
3.
1.
7.
3.
8.
4.
, 12E +
,40E +
, 02E +
,25E +
.30E-01
.40E-01
, 06E +
,50E +
,20E +
, 17E +
, 05E +
,08E +
,44E +
, 87E +
,48E +
, 12E +
,80E +
,50E +
,53E +
03
00
01
01


02
00
00
01
04
01
03
02
01
02
01
00
01
Note:
Y:  Yes
N:  NO
1:  No available SF and RfDs.
2:  It is not carcinogenic compounds and the detection freguency is lower then 5
-:  Sample number is less than 10.  No 95% UCL was calculated.

-------
TABLE 3
CHEMICAL OF CONCERN
SOIL EXPOSURE PATHWAY
OLEAN WELLFIELD SITE-Loohn's Dry Cleaners and Launderers
CHEMICAL NAME
                                         CHEMICAL  OF  CONCERN
                                     INDICATOR   REASON OF EXCLUSION
                                                    DETECTED RANGE
                                                MAXIMUM            MINIMUM
                                                                                                                            95% UCL
VOA  (ug/kg)
1,2-Dichloroethene  (total)
2-Butanone
Trichloroethene
Tetrachloroethene

BNA  (ug/kg)
Naphthalene
2-Methynaphthalene
Acenaphthylene
Acenaphthene
Dibenzofuran
Fluorene
Phenanthrene
Anthracene
Carbazole
Di-n-butylphthaiate
Fluoranthene
Pyrene
Benzo(a)anthracene
Chrysene
Bis(2-Ethylhexyl)phthalate
Benzo(b)fluoranthene
Benzo(k)fluoranthene
Benzo(a)pyrene
Indeno(1,2,3-cd)pyrene
Dibenz(a,h)anthracene
Benzo(g,h,i)perylene
Y
Y
Y
Y
Y
N
N
Y
N
Y
N
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
N
6,
3,
2,
2,
7,
7,
5,
1.
1.
1.
1.
2,
1.
3,
1.
1.
1.
1.
1.
1.
8,
9,
4,
1.
3,
. 90E -
.30E -
.40E -
.40E -
. 90E -
. 90E -
. 90E -
. 10E -
.30E -
.OOE -
.40E -
.OOE -
.40E -
.30E -
. 90E -
.80E -
.20E -
.OOE -
.OOE -
.80E -
.30E -
.OOE -
.OOE -
. 90E -
.OOE -
h 03
h 03
h 04
h 04
h 01
h 01
h 01
h 02
h 02
h 02
h 03
h 02
h 02
h 01
h 03
h 03
h 03
h 03
h 03
h 03
h 02
h 02
h 02
h 02
h 02
1.
8.
7.
7.
3.
3.
2.
8.
4.
9.
1.
1.
1.
3.
1.
1.
5.
6.
1.
7.
8.
3.
4.
1.
2.
,50E H
, OOE H
,OOE H
,OOE H
,30E H
, OOE H
,20E H
,50E H
, 10E H
,30E H
, 10E H
,50E H
, 10E H
,30E H
,30E H
,20E H
,90E H
,50E H
,OOE H
,90E H
,30E H
,80E H
, OOE H
, 90E H
,50E H
- 01
- 00
- 00
- 00
- 01
- 01
- 01
- 01
- 01
- 01
- 03
- 02
- 02
- 01
- 03
- 03
- 02
- 02
- 02
- 02
- 02
- 02
- 02
- 02
- 02
6.79E + 05
5.03E + 07
1.20E + 07
8.07E + 11

-------
INORGANIC  (mg/kg
Aluminum
Arsenic
Barium
Beryllium
Calcium
Chromium
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Mercury
Nickel
Potassium
Sodium
N
Y
Y
Y
N
Y
N
N
N
N
N
Y
Y
Y
N
N
1.
1.
1.
6,
7,
3,
1.
2,
7,
2,
5,
9,
1.
2,
2,
1.
. 43E +
. 68E +
.34E +
.70E-01
.45E +
. 09E +
.44E +
.51E +
. 12E +
. 10E +
.22E +
. 12E +
.20E-01
. 99E +
.HE +
. 86E +
04
01
02

03
01
01
01
04
02
03
02

01
03
02
3.
7.
8.
2.
2.
1.
9.
2.
2.
1.
6.
5.
1.
1.
3.
9.
,71E +
,50E +
,24E +
.20E-01
,55E +
,45E +
,70E +
, 06E +
,55E +
,26E +
, 49E +
,70E +
.20E-01
,64E +
, 02E +
,02e +
03
00
01

03
01
00
01
04
01
02
02

01
02
01

-------
TABLE 3
CHEMICAL OF CONCERN
SOIL EXPOSURE PATHWAY
OLEAN WELLFIELD SITE-Loohn's Dry Cleaners and Launderers
CHEMICAL NAME
                                         CHEMICAL OF CONCERN
                                     INDICATOR   REASON OF NO
                                                    DETECTED RANGE
                                                 MAXIMUM           MINIMUM
                                                                                                                            95% UCL
Thallium
Vanadium
Zinc
Y
Y
Y
3.20E-01
2.00E + 01
2.16E + 02
3.20E-01
1.55E + 01
6.37E + 01
Note:
Y:  Yes
N:  No
1:  No available SF and RfDs.
2:  It is not carcinogenic compounds and the detection frequency is lower then 5
-:  Sample number is less than 10.  No 95% UCL was calculated.

-------
TABLE 3
CHEMICAL OF CONCERN
SOIL EXPOSURE PATHWAY
OLEAN WELLFIELD SITE-PRIVATE DUMP
CHEMICAL NAME
                                          CHEMICAL  OF  CONCERN
                                     INDICATOR   REASON OF EXCLUSION
                                                    DETECTED RANGE
                                                MAXIMUM            MINIMUM
                                                                                                                            95% UCL
PRIVATE DUMP
VOA  (ug/kg)
2-Butanone
Toluene

BNA  (ug/kg)
2-Methylphenol
4-Methylphenol
Acenaphthene
Dibenzofuran
Diethylphthalate
Fluorene
Phenanthrene
Anthracene
Carbazole
Fluoranthene
Pyrene
Benzo(a)anthracene
Chrysene
Bis(2-Ethylehexyl)phthalate
Benzo(b)fluoranthene
Benzo(a)pyrene
Y
Y
Y
Y
Y
N
Y
Y
N
Y
Y
Y
Y
Y
Y
Y
Y
Y
6,
6,
2,
7,
6,
4,
2,
8,
9,
1.
1.
1.
1.
6,
5,
7,
1.
4,
.OOE -
.OOE -
.80E -
.30E -
.50E -
. 90E -
. 10E -
.70E -
.20E -
. 10E -
.40E -
. 10E -
. 10E -
.OOE -
. 90E -
.50E -
.40E -
.80E -
h 01
h 00
h 01
h 01
h 01
h 01
h 01
h 01
h 01
h 02
h 02
h 03
h 03
h 02
h 02
h 02
h 03
h 02
6.
6.
2.
7.
6.
4.
2.
8.
2.
1.
1.
2.
1.
6.
5.
4.
1.
4.
, OOE H
,OOE H
,80E H
,30E H
,50E H
, 90E H
, OOE H
,70E H
, 10E H
,10e H
,40E H
,60E H
, 10E H
, OOE H
, 90E H
,40E H
,40E H
,80E H
- 01
- 00
- 01
- 01
- 01
- 01
- 01
- 01
- 01
- 02
- 02
- 01
- 03
- 02
- 02
- 01
- 03
- 02

-------
INORGANIC  (Mg/kg)
Aluminum
Arsenic
Barium
Beryllium
Calcium
Chromium
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Mercury
Nickel
Potassium
Sodium
Vanadium
Zinc
N
Y
Y
Y
N
Y
N
N
N
N
N
Y
Y
Y
N
N
Y
Y
1.
1.
4,
8,
2,
1.
1.
1.
3,
6,
6,
6,
1.
2,
1.
1.
2,
1.
.58E +
.40E +
. 13E +
.70E-01
.76E +
.54E +
. 47E +
. 09E +
.28E +
. 60E +
.34E +
.22E +
.70E-01
. 86E +
. 61E +
. 07E +
. 19E +
.80E +
04
01
02

04
01
01
02
04
01
03
03

01
03
02
01
02
6
5
5
2.
2
7
5
1
1
1
1
1
1.
1
4
5
1
4
.90E +
. 10E +
.41E +
50E-01
.07E +
.70E +
.60E +
. 10E +
. 61E +
.54E +
.41E +
.82E +
20E-01
.02E +
.95E +
.93E +
.63E +
.88E +
03
00
01

02
00
00
01
04
01
03
02

01
02
01
01
01

-------
TABLE 3
CHEMICAL OF CONCERN
SOIL EXPOSURE PATHWAY
OLEAN WELLFIELD SITE-PRIVATE DUMP
CHEMICAL NAME
                                         CHEMICAL  OF  CONCERN
                                     INDICATOR   REASON OF EXCLUSION
    DETECTED RANGE            95%  UCL
MAXIMUM            MINIMUM
Note:
Y:  Yes
N:  No
1:  No available SF and RfDs.
2:  It is not carcinogenic compounds and the detection frequency  is  lower  then  5  %.
-:  Sample number is less than 10.  NO 95% UCL was calculated.

-------
TABLE 3
CHEMICAL OF CONCERN
SOIL EXPOSURE PATHWAY
OLEAN WELLFIELD SITE-McGRAW-EDISON
CHEMICAL NAME
                                         CHEMICAL  OF  CONCERN
                                     INDICATOR   REASON OF EXCLUSION
                                                    DETECTED RANGE
                                                MAXIMUM            MINIMUM
                                                                                                                            95% UCL
VOA  (ug/kg)
Methylene chloride
Acetone
1,2-Dichloroethene  (total)
Chloroform
2-Butanone
1,1, 1-Trichloroethane
Trichloroethene
Benzene
Tetrachloroethene
Toluene
Chlorobenzene
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
1.
1.
5,
2,
1.
7,
8,
8,
4,
8,
7,
.20E -
.30E -
.OOE -
.OOE -
.40E -
.OOE -
.60E -
.OOE -
.OOE -
.OOE -
.OOE -
h 02
h 04
h 00
h 00
h 01
h 00
h 02
h 00
h 00
h 00
h 00
2
1
3
2
2
4
2
2
1
.OOE H
.OOE H
.OOE H
.OOE H
.OOE H
.OOE H
.OOE H
.OOE H
.OOE H
- 00
- 01
- 00
- 00
- 00
- 00
- 00
- 00
- 00
4. OOE-01
6. OOE-01
7.
6.
5
5
5
5
2
5
5
5
5
29E +
38E +
.02E -
.75E -
.48E -
. 10E -
.59E -
.15E -
.15E -
.86E -
.42E -
00
03
t- 00
¥ 00
¥ 00
¥ 00
t- 01
t- 00
t- 00
t- 00
t- 00
BNA  (ug/kg)
Phenol
1,2, 4-Trichlorobenzene
Naphthalene
Phenanthrene
Fluoranthene
Pyrene
Bis (2-Ethylhexyl)phthalate
Y
Y
Y
N
Y
Y
Y
2.60E -
3.80E -
4. OOE -
2. OOE -
1.90E -
1.30E -
4.50E -
h 01
h 01
h 00
h 01
h 01
h 01
h 02
2.60E H
2.30E H
4. OOE H
l.OOE H
6. OOE H
4. OOE H
4.50E H
- 01
- 01
- 00
- 01
- 00
- 00
- 02

-------
INORGANIC  (mg/kg)
Aluminum                                N                     1                          1.46E + 04     1.15E + 04
Antimony                                Y                                                4.60E + 00     4.40E + 00
Arsenic                                 Y                                                6.38E + 01     1.46E + 01
Barium                                  Y                                                I. TIE + 02     8.64E + 01
Beryllium                               Y                                                3.70E-01      2.30E-01
Calcium                                 N                    1                           1.55E + 03     1.31E + 03
Chromium                                Y                                                1.74E + 01     1.38E + 01
Cobalt                                  N                    1                           1.30E + 01     1.09E + 01
Copper                                  N                    1                           3.52E + 01     2.30E + 01
Iron                                    N                    1                           3.51E + 04     2.75E + 04
Lead                                    N                    1                           3.57E + 01     1.89E + 01
Magnesium                               N                    1                           3.67E + 03     3.21E + 03
Manganese                               Y                                                1.23E + 03     7.60E + 02
Nickel                                  Y                                                2.36E + 01     1.94E + 01
Potassium                               N                    1                           1.68E + 03     1.48E + 03
Sodium                                  N                    1                           8.14E + 01     6.18E + 01
Vanadium                                Y                                                1.97E +01     1.46E + 01
Zinc                                    Y                                                8.29E + 01     5.96E + 01

None:
Y:  Yes

    No
    No available SF and RfDs.
    It is not carcinogenic compounds and the detection freguency is lower then 5 %.
    Sample number is less than 10.  NO 95% UCL was calculated.

-------
TABLE 3
CHEMICAL OF CONCERN
SOIL EXPOSURE PATHWAY
OLEAN WELLFIELD SITE-MASTELFORD
CHEMICAL NAME
                                         CHEMICAL  OF  CONCERN
                                     INDICATOR   REASON OF EXCLUSION
                                                    DETECTED RANGE
                                               MAXIMUM        MINIMUM
                                                                                                                                   95% UCL
VOA  (ug/kg)
Acetone
1,2-Dichloroethene  (total)
Chloroform
2-Butanone
Trichloroethene
Benzene
Tetrachloroethene
Toluene
Chlorobenzene
Ethyl benzene
Xylenes  (total)

BNA  (ug/kg)
Naphthalene
2-Methylnaphthalene
Acenaphthylene
Acenaphthene
Dibenzofuran
Fluorene
Phenanthrene
Anthracene
Carbazole
Fluoranthene
Pyrene
Benzo(a)anthracene
Chrysene
Bis(2-Ethylhexyl)phthalate
Benzo(b)fluoranthene
Benzo(k)fluoranthene
Benzo(a)pyrene
Indeno(1,2,3-cd)pyrene
Benzo(g,h,i)perylene
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
N
N
Y
N
Y
N
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
N
4,
1.
2,
8,
3,
2,
4,
1.
0,
8,
8,
. 10E -
. 10E -
.OOE -
.80E -
.OOE -
. 10E -
.OOE -
.30E -
.OOE -
.70E -
.40E -
h 02
h 01
h 00
h 01
h 00
h 01
h 00
h 02
h 00
h 01
h 02
2.
6.
2.
8.
3.
2.
2.
2.
2.
2.
2.
, OOE H
, OOE H
,OOE H
,80E H
,OOE H
, 10E H
, OOE H
,30E H
, OOE H
, OOE H
,20E H
- 01
- 00
- 00
- 01
- 00
- 01
- 00
- 01
- 00
- 00
- 01
9,
2,
1,
5,
3,
7,
6,
1,
6,
7,
2,
8,
1,
2,
6,
3,
3,
2,
1,
.OOE -
.OOE -
.60E -
.20E -
.70E -
. 90E -
.OOE -
.OOE -
.20E -
. 90E -
.OOE -
.20E -
.OOE -
. 10E -
.50E -
.OOE -
. 10E -
.OOE -
.80E -
h 01
h 01
h 01
h 01
h 01
h 01
h 02
h 02
h 01
h 02
h 03
h 01
h 03
h 04
h 02
h 02
h 02
h 02
h 02
9.
2.
1.
5.
3.
7.
3.
6.
6.
6.
4.
8.
2.
2.
6.
1.
6.
2.
1.
,OOE H
, OOE H
,60E H
,20E H
,70E H
,90E H
,OOE H
,OOE H
,20E H
,50E H
,30E H
,20E H
, OOE H
, 10E H
,50E H
,70E H
, 10E H
, OOE H
,80E H
- 01
- 01
- 01
- 01
- 01
- 01
- 01
- 00
- 01
- 01
- 01
- 01
- 01
- 04
- 02
- 02
- 01
- 02
- 02
1.64E + 02
5.80E + 00
4.89E + 00
1.18E + 01
4.70E + 00
6.58E + 00
4.95E + 00
2.38E + 01
4.89E + 00
2.21E + 01
3.79E + 02

-------
INORGANIC  (mg/kg)
Aluminum
Arsenic
Barium
Beryllium
Calcium
Chromium
Cobalt
Copper
Iron
Magnesium
Manganese
Mercury
Nickel
Potassium
Sodium
N
Y
Y
Y
N
Y
N
N
N
N
Y
Y
Y
N
N
1.
2,
2,
9,
9,
1.
2,
1.
3,
4,
6,
1.
3,
1.
8,
.50E +
.55E +
.27E +
.40E-01
. 56E +
. 79E +
.88E +
. 67E +
.32E +
. 03E +
.81E +
. 90E-01
. 01E +
. 05E +
.31E +
04
01
02

03
01
01
01
04
03
02

01
03
02
8.
8.
6.
9.
7.
9.
6.
8.
1.
1.
2.
1.
1.
4.
6.
, 61E + 03
, 90E + 00
,54E + 01
.20E-01
,27E + 02
,50E + 00
,80E + 00
,30E + 00
, 67E + 04
, 95E + 03
, 14E + 02
, 90E-01
,35E + 01
, 26E + 02
, 43E + 01

-------
TABLE 3
CHEMICAL OF CONCERN
SOIL EXPOSURE PATHWAY
OLEAN WELLFIELD SITE-MASTEL FORD
CHEMICAL NAME
                                          CHEMICAL  OF  CONCERN
                                     INDICATOR   REASON OF EXCLUSION
                                                    DETECTED RANGE
                                               MAXIMUM        MINIMUM
                                                                                                                                   95% UCL
Vanadium
Zinc
Y
Y
3.36E + 01
7.10E + 01
1.53E + 01
5.78E + 01
Note:
Y:  Yes
    No
    No available SF and RfDs.
    It is not carcinogenic compounds and the detection  frequency  is  lower  then 5
    Sample number is less than 10.  No 95 % UCL was  calculated.

-------
TABLE 3
CHEMICAL OF CONCERN
SOIL EXPOSURE PATHWAY
OLEAN WELLFIELD SITE-GRIFITH OIL
CHEMICAL NAME
                                          CHEMICAL  OF  CONCERN
                                     INDICATOR   REASON OF EXCLUSION
                                                    DETECTED RANGE
                                               MAXIMUM        MINIMUM
                                                                                                                                    95% UCL
VOA  (ug/kg)
Methylene chloride
Acetone
Carbon disulfide
2-Butanone
1,1,1-Trichloroethane
Trichloroethene
Benzene
Toluene
Xylenes  (total)

BNA  (ug/kg)
Naphthalene
2-Methylnaphthalene
Phenanthrene
Di-n-butylphthaiate
Fluoranthene
Pyrene
Benzo(a)anthracene
Chrysene
Benzo(b)fluoranthene
Benzo(a)pyrene
Indeno(1,2,3-cd)pyrene
Benzo(g,h,i)perylene
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
N
N
Y
Y
Y
Y
Y
Y
Y
Y
N
6,
6,
3,
6,
1.
3,
1.
4,
5,
4,
7,
1.
2,
1.
1.
7,
9,
1.
9,
1.
1.
.50E -
.30E -
.OOE -
.OOE -
.60E -
.OOE -
.20E -
.OOE -
.OOE -
. 10E -
.60E -
. 10E -
.70E -
.30E -
.50E -
.40E -
.OOE -
.80E -
.20E -
.30E -
.50E -
h 01
h 01
h 00
h 00
h 01
h 00
h 01
h 01
h 00
h 01
h 03
h 03
h 01
h 02
h 02
h 01
h 01
h 02
h 01
h 02
h 02
6.
6.
3.
6.
1.
3.
1.
2.
5.
4.
9.
9.
2.
5.
5.
2.
2.
8.
4.
1.
1.
,50E
, OOE
, OOE
, OOE
, 60E
, OOE
, OOE
, OOE
, OOE
, 10E
,70E
,40E
,70E
,50E
, OOE
, 60E
, 90E
,70E
, 60E
,30E
,50E
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
01
00
00
00
01
00
00
00
00
01
01
01
01
01
01
01
01
01
01
02
02
8.61E + 00
2.10E + 01
2.60E + 00
5.19E + 00
4.30E + 00
2.60E + 00
4.43E + 00
6.60E + 00
2.93E + 00

-------
INORGANIC  (mg/kg)
Aluminum                                N              1                                1.44E  +  04          6.55E + 03
Antimony                                Y                                               7.50E  +  00          5.90E + 00
Arsenic                                 Y                                               2.73E  +  01          7.80E + 00
Barium                                  Y                                               1.52E  +  02          6.86E + 01
Beryllium                               Y                                               5.80E-01           3.30E-01
Cadmium                                 Y                                               4.30E  +  00          7.50E-01
Calcium                                 N              1                                4.22E  +  03          1.19E + 03
Chromium                                Y                                               1.58E  +  01          1.58E + 01
Cobalt                                  N              1                                2.16E  +  01          5.40E + 00
Copper                                  N              1                                1.19E  +  03          1.97E + 01
Iron                                    N              1                                3.50E  +  04          1.87E + 04
Lead                                    N              1                                3.45E  +  01          3.45E + 01
Magnesium                               N              1                                3.38E  +  03          1.80E + 03
Manganese                               Y                                               8.64E  +  02          1.18E + 02
Nickel                                  Y                                               2.19E  +  01          9.40E + 00
Potassium                               N              1                                1.36E  +  03          1.36E + 03
Sodium                                  N              1                                9.27E  +  01          5.15E + 01
Thallium                                Y                                               3.80E-01           3.80E-01
Vanadium                                Y                                               2.32E  +  01          1.12E + 01
Zinc                                    Y                                               1.43E  +  03          4.60E + 01

Note:
Y:  Yes

N:  No
1:  No available SF and RfDs.
2:  It is not carcinogenic compounds and the detection freguency is lower then 5 %.
-:  Sample number is less than 10.  No 95% UCL was calculated.

A-8.XLS

-------
 TABLE 3
CHEMICAL OF CONCERN
SOIL EXPOSURE PATHWAY
OLEAN WELLFIELD SITE-FAV &
                           SCHAFFER
CHEMICAL NAME
VOA  (ug/kg)
Carbon disulfide
1,1,1-Trichloroethane
Trichloroethene
Benzene
Toluene
Xylenes  (total)

BNA  (ug/kg)
Naphthalene
Acenaphthylene
Acenaphthene
Dibenzofuran
Fluorene
Phenanthrene
Anthracene
Carbazole
Di-n-butylphthaiate
Fluoranthene
Pyrene
Benzo(a)anthracene
Chrysene
Bis(2-Ethyhexyl)phthalate
Benzo(b)fluoranthene
Benzo(a)pyrene
Indeno(1,2,3-cd)pyrene
                                          CHEMICAL  OF  CONCERN
                                     INDICATOR   REASON OF EXCLUSION
Y
Y
Y
Y
Y
Y
                                                    DETECTED RANGE
                                               MAXIMUM        MINIMUM
                                                                                                                                   95% UCL
Y
N
Y
N
Y
N
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
2,
1.
6,
5,
8,
1.
5,
4,
8,
1.
3,
4,
4,
5,
2,
6,
6,
4,
4,
7,
5,
3,
3,
.40E -
.OOE -
.OOE -
.OOE -
.OOE -
.OOE -
. 90E -
.40E -
.OOE -
.70E -
. 10E -
.50E -
.50E -
.40E -
.20E -
.30E -
.30E -
.40E -
.30E -
. 10E -
.70E -
.60E -
.50E -
h 01
h 01
h 00
h 00
h 00
h 00
h 01
h 02
h 01
h 02
h 02
h 03
h 02
h 02
h 03
h 03
h 03
h 03
h 03
h 03
h 03
h 03
h 02
2.
5.
3.
4.
4.
1.
5.
4.
8.
1.
3.
4.
4.
5.
2.
6.
6.
4.
4.
8.
5.
3.
3.
,40E H
, OOE H
,OOE H
,OOE H
,OOE H
,OOE H
, 90E H
,40E H
,OOE H
,70E H
, 10E H
,50E H
,50E H
,40E H
,20E H
,30E H
,30E H
,40E H
,30E H
,40E H
,70E H
,60E H
,50E H
- 01
- 00
- 00
- 00
- 00
- 00
- 01
- 02
- 01
- 02
- 02
- 03
- 02
- 02
- 03
- 03
- 03
- 03
- 03
- 01
- 03
- 03
- 02

-------
INORGANIC  (mg/kg)
Aluminum
Arsenic
Barium
Beryllium
Calcium
Chromium
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Mercury
Nickel
Potassium
Sodium
Thallium
Vanadium
Zinc
N
Y
Y
Y
N
Y
N
N
N
N
N
Y
Y
Y
N
N
Y
Y
Y
2,
1.
1.
2,
2,
1.
8,
3,
3,
3,
2,
2,
1.
1.
1.
1.
3,
2,
1.
.HE +
. 46E +
.74E +
. 90E-01
.59E +
. 87E +
.70E +
.40E +
.24E +
. 05E +
.82E +
. 49E +
. 90E-01
. 89E +
.56E +
.42E +
.10E-01
. 17E +
. 79E +
04
01
02

03
01
00
01
04
02
03
02

01
03
02

01
02
8.
5.
6.
2.
8.
1.
6.
1.
1.
1.
1.
1.
1.
1.
8.
7.
3.
1.
5.
, 43E + 03
, 10E + 00
,32E + 01
.70E-01
, 01E + 02
,31E + 01
, OOE + 00
, 19E + 01
,58E + 04
,29E + 01
, 83E + 03
, 06E + 02
.40E-01
,32E + 01
, 66E + 02
,72E + 01
.10E-01
,58E + 01
, 66E + 01

-------
TABLE 3
CHEMICAL OF CONCERN
SOIL EXPOSURE PATHWAY
OLEAN WELLFIELD SITE-FAV &
                           SCHAFFER
CHEMICAL NAME
                                         CHEMICAL  OF  CONCERN
                                     INDICATOR   REASON OF EXCLUSION
     DETECTED RANGE            95%  UCL
MAXIMUM        MINIMUM
Note:
Y:  Yes
N:  No
1:  No available SF and RfDs.
2:  It is not carcinogenic compounds and the detection frequency  is  lower  then  5  %.
-:  Sample number is less than 10.  No 95% UCL was calculated.

-------
TABLE 3
CHEMICAL OF CONCERN
SOIL EXPOSURE PATHWAY
OLEAN WELLFIELD SITE-SANDBURG OIL
CHEMICAL NAME
                                          CHEMICAL  OF CONCERN
                                     INDICATOR   REASON OF EXCLUSION
                                                    DETECTED RANGE
                                               MAXIMUM        MINIMUM
                                                                                                                                   95% UCL
VOA  (ug/kg)
Methylene chloride
Acetone
Benzene
Toluene
Chlorobenzene
Ethyl benzene
Xylenes  (total)

BNA  (ug/kg)
Naphthalene
2-Methlnaphthalene
Phenanthrene
Anthracene
Fluoranthene
Pyrene
Benzo(a)anthracene
Chrysene
Benzo(b)fluoranthene
Benzo(k)fluoranthene
Benzo(a)pyrene
Y
Y
Y
Y
Y
Y
Y
Y
N
N
Y
Y
Y
Y
Y
Y
Y
Y
6. OOE -
4. OOE -
9. OOE -
3. OOE -
4.80E -
2. OOE -
4.50E -
h 00
h 03
h 00
h 00
h 01
h 00
h 03
6. OOE H
3.30E H
9. OOE H
3. OOE H
4.80E H
2. OOE H
8.10E H
- 00
- 01
- 00
- 00
- 01
- 00
- 01
7,
2,
2,
3,
1,
2,
1,
1,
1,
1,
1,
.50E -
.20E -
.OOE -
. 90E -
.80E -
.30E -
.20E -
.40E -
.30E -
.20E -
.20E -
h 02
h 03
h 02
h 01
h 02
h 02
h 02
h 02
h 02
h 02
h 02
3
2
1
3
1
2
1
1
1
1.
1
. 90E •
.20E •
.70E •
. 90E •
.80E •
.30E •
.20E •
.40E •
.30E •
20E 4
.20E •
+ 02
+ 02
+ 02
+ 01
+ 02
+ 02
+ 02
+ 02
+ 02
- 02
+ 02

-------
INORGANIC  (mg/kg)
Aluminum                                N              1                                1.34E  + 04          6.66E + 03
Antimony                                Y                                               5.60E  + 00          5.60E + 00
Arsenic                                 Y                                               1.14E  + 01          4.00E + 00
Barium                                  Y                                               1.28E  + 02          9.78E + 01
Beryllium                               Y                                               8.50E-01           4.20E-01
Cadmium                                 Y                                               1.30E  + 00          2.60E-01
Calcium                                 N              1                                2.24E  + 03          9.19E + 02
Chromium                                Y                                               1.64E  + 01          1.64E + 01
Cobalt                                  N              1                                9.80E  + 00          7.40E + 00
Copper                                  N              1                                5.03E  + 01          1.20E + 01
Iron                                    N              1                                2.32E  + 04          1.26E + 04
Lead                                    N              1                                1.82E  + 01          1.82E + 01
Magnesium                               N              1                                2.83E  + 03          1.47E + 03
Manganese                               Y                                               5.76E  + 02          1.68E + 02
Nickel                                  N              1                                1.87E  + 01          1.02E + 01
Potassium                               N              1                                9.88E  + 02          6.63E + 02
Sodium                                  N              1                                9.80E  + 01          8.10E + 01
Vanadium                                Y                                               2.18E  + 01          1.24E + 01
Zinc                                    Y                                               2.20E  + 02          4.41E + 01

Note:
Y:  Yes

    No
    No available SF and RfDs.
    It is not carcinogenic compounds and the detection freguency is lower then 5 %.
    Sample number is less than 10.  No 95% UCL was calculated.

-------
TABLE 3
CHEMICAL OF CONCERN
SOIL EXPOSURE PATHWAY
OLEAN WELLFIELD SITE-OLEAN STEEL
CHEMICAL NAME
                                         CHEMICAL  OF  CONCERN
                                     INDICATOR   REASON OF EXCLUSION
                                                    DETECTED RANGE
                                               MAXIMUM        MINIMUM
                                                                                                                                    95% UCL
VOA  (ug/kg)
Methylene chloride
Acetone
1,2-Dichloroethene  (total)
2-Butanone
Trichloroethene
Benzene
Tetrachloroethene
Toluene
Chlorobenzene
Ethyl benzene
Styrene
Xylenes  (total)

BNA  (ug/kg)
Bis(2-Chloroethoxy) methane
Naphthalene
2-Methylnaphthalene
Dibenzofuran
Fluorene
Phenanthrene
Carbazole
Fluroanthene
Pyrene
Benzo(a)anthracene
Chrysene
Bis(2-Ethylhexyl)phthalate
Y
Y
N
Y
Y
Y
Y
Y
Y
Y
N
Y
N
Y
N
N
Y
N
Y
Y
Y
Y
Y
Y
1.
1.
9,
2,
7,
1.
1.
1.
2,
2,
2,
8,
.50E -
.30E -
.OOE -
.80E -
.OOE -
.20E -
.20E -
.60E -
.OOE -
.30E -
.OOE -
.30E -
h 01
h 02
h 00
h 01
h 00
h 01
h 01
h 01
h 01
h 01
h 00
h 01
2.
8.
9.
1.
1.
1.
1.
8.
2.
2.
2.
1.
, OOE H
, OOE H
,OOE H
,OOE H
,OOE H
,OOE H
, OOE H
, OOE H
, OOE H
, OOE H
,OOE H
,OOE H
- 00
- 00
- 00
- 00
- 00
- 00
- 00
- 00
- 01
- 00
- 00
- 00
7,
2,
6,
8,
1.
3,
4,
2,
1.
7,
7,
8,
.80E -
.40E -
.20E -
. 90E -
.60E -
.60E -
.30E -
.20E -
.60E -
.60E -
.OOE -
.30E -
h 02
h 02
h 01
h 01
h 02
h 02
h 01
h 02
h 02
h 01
h 01
h 02
2
2
6
8
1
3
4
3
2.
7
7
6
.OOE •
.40E •
.20E •
. 90E •
.60E •
.60E •
.30E •
.40E •
80E 4
.60E •
.OOE •
.60E •
+ 00
+ 02
+ 01
+ 01
+ 02
+ 02
+ 01
+ 01
- 01
+ 01
+ 01
+ 01
5. HE H
1.27E H
3.01E H
7.67E H
3.12E H
3.20E H
3.18E H
5.83E H
3.53E H
3.63E H
2.52E H
8.05E H
- 00
- 01
- 00
- 00
- 00
- 00
- 00
- 00
- 00
- 00
- 00
- 00

-------
INORGANIC  (mg/kg)
Aluminum
Antimony
Arsenic
Barium
Beryllium
Cadmium
Calcium
Chromium
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Mercury
Nickel
Potassium
Selenium
Silver
N
Y
Y
Y
Y
Y
N
Y
N
N
N
N
N
Y
Y
Y
N
Y
Y
9,
2,
1.
1.
6,
0,
1.
1.
1.
4,
3,
2,
3,
1.
1.
2,
1.
4,
0,
. 43E +
. 96E +
.48E +
.50E +
.30E-01
.OOE +
. 62E +
.36E +
.25E +
.70E +
. 47E +
.48E +
. 49E +
.42E +
.80E-01
.44E +
.54E +
.80E-01
.OOE +
03
01
01
02

00
03
01
01
01
04
01
03
03

01
03

00
9.
1.
5.
4.
3
0.
1.
9.
9.
2.
1.
2.
1.
4.
1.
1.
4.
4.
0.
28E + 03
46E + 01
20E + 00
51E + 01
.50E-01
OOE + 00
86E + 02
OOE + 00
30E + 00
39E + 01
58E + 04
40E + 00
43E + 03
66E + 02
OOE-01
14E + 01
70E + 02
80E-01
OOE + 00

-------
TABLE 3
CHEMICAL OF CONCERN
SOIL EXPOSURE PATHWAY
OLEAN WELLFIELD SITE-OLEAN STEEL
CHEMICAL NAME
                                         CHEMICAL  OF  CONCERN
                                     INDICATOR   REASON OF EXCLUSION
                                                     DETECTED RANGE
                                                MAXIMUM        MINIMUM
                                                                                                                                    95% UCL
Sodium
Thallium
Vanadium
Zinc
N
Y
Y
Y
5.90E + 01
2.50E-01
1.75E + 01
9.18E + 01
4.08E + 01
 2.10E-01
l.OOE + 01
4.36E + 01
Note:
Y:  Yes
    No
    No available SF and RfDs.
    It is not carcinogenic compounds and the detection frequency is  lower  then  5
    Sample number is less than 10.  No 95% UCL was calculated.

-------
TABLE 3
CHEMICAL OF CONCERN
SOIL EXPOSURE PATHWAY
OLEAN WELLFIELD SITE-OLEAN TILE
CHEMICAL NAME
                                         CHEMICAL OF CONCERN
                                     INDICATOR   REASON OF EXCLUSION
                                                    DETECTED RANGE
                                               MAXIMUM        MINIMUM
                                                                                                                                    95% UCL
VOA  (ug/kg)
Methylene chloride
Acetone
Butanone
Trichloroethene
Toluene
Ethyl benzene
Xylenes

BNA  (ug/kg)
2,4-Dinitrotluene
Diethylphthalate
Phenanthrene
Fluoranthene
Pyrene
Benzo(a)anthracene
Chrysene

INORGANIC  (mg/kg)
Aluminum
Arsenic
Barium
Beryllium
Calcium
Chromium
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Nickel
Potassium
Vanadium
Zinc
Y
Y
Y
Y
Y
Y
Y
N
Y
N
Y
Y
Y
Y
N
Y
Y
Y
N
Y
N
N
N
N
N
Y
Y
N
Y
Y
9,
9,
1.
1.
2,
3,
5,
3,
1.
5,
6,
4,
2,
3,
1.
1.
1.
5,
2,
1.
1.
1.
2,
1.
2,
6,
2,
9,
2,
5,
.OOE +
.OOE +
.40E +
.OOE +
.80E +
.OOE +
.50E +
. 90E +
.OOE +
.70E +
.OOE +
. 90E +
. 60E +
.OOE +
. 15E +
. 03E +
. 26E +
.OOE-01
.23E +
.38E +
.34E +
.22E +
.54E +
.78E +
.55E +
. 12E +
. 07E +
.14E +
.HE +
.44E +
00
00
01
00
04
00
01
01
02
01
01
01
01
01
04
01
02

03
01
01
01
04
01
03
02
01
02
01
01
6.
6.
6.
1.
1.
3.
1.
3.
1.
5.
6.
4.
2.
3.
9.
7.
5.
4
5.
1.
8.
6.
2.
1.
1.
2.
1.
5.
1.
4.
OOE +
OOE +
OOE +
OOE +
20E +
OOE +
OOE +
90E +
OOE +
70E +
OOE +
90E +
60E +
OOE +
04E +
50E +
87E +
00
00
00
00
01
00
00
01
02
01
01
01
01
01
03
00
01
.60E-01
98E +
14E +
70E +
80E +
09E +
789E
93E +
05E +
42E +
64E +
77E +
75E +
02
01
00
00
04
+ 01
03
02
01
02
01
01
5.82E + 00
7.20E + 00
5.90E + 00
5.92E + 00
1.87E + 03
4.62E + 00
1.10E + 01

-------
Note:
Y:  Yes

N:  No
1:  No available SF and RfDs.
2:  It is not carcinogenic compounds and the detection frequency is lower then 5 %.
-:  Sample number is less than 10.  No 95% UCL was calculated.

-------
TABLE 3
CHEMICAL OF CONCERN
SOIL EXPOSURE PATHWAY
OLEAN WELLFIELD SITE-OLEAN WHOLESALE
CHEMICAL NAME
                                          CHEMICAL  OF  CONCERN
                                     INDICATOR   REASON OF EXCLUSION
                                                    DETECTED RANGE
                                               MAXIMUM        MINIMUM
                                                                                                                                   95% UCL
VOA  (ug/kg)
Methylene chloride
Tetrachloroethene
Toluene
Xylenes

BNA  (ug/kg)
Bis(2-Chloroethoxy) methane
Naphthalene
2-Methylnaphthalene
Dibenzofuran
Fluorene
Phenanthrene
Carbazole
Fluoranthene
Pryene
Benzo(a)anthracene
Chrysene
Bis(2-Ethylhexyl)phthalate
Y
Y
N
N
N
Y
N
N
Y
N
Y
Y
Y
Y
Y
Y
1.
1.
1.
2,
7,
2,
6,
8,
1.
3,
4,
2,
1.
7,
7,
8,
.OOE -
.30E -
.OOE -
.OOE -
.80E -
.40E -
.20E -
. 90E -
.60E -
.60E -
.30E -
.20E -
.60E -
.60E -
.OOE -
.30E -
h 00
h 01
h 00
h 00
h 02
h 02
h 01
h 01
h 02
h 02
h 01
h 02
h 02
h 01
h 01
h 02
1
6.
1
2
2
2
6
8
1
3
4
2
1
7
7
4
.OOE •
OOE 4
.OOE •
.OOE •
.OOE •
.40E •
.20E •
. 90E •
.60E •
.60E •
.30E •
.20E •
.60E •
.60E •
.OOE •
.OOE •
+ 00
- 00
+ 00
+ 00
+ 00
+ 02
+ 01
+ 01
+ 02
+ 02
+ 01
+ 02
+ 02
+ 01
+ 01
+ 00
2.64E + 00
3.88E + 00
2.64E + 00
2.52E + 00
6.
1.
1.
1.
1.
1.
1.
1.
1.
1.
1.
57E
75E
77E
71E
65E
88E
84E
72E
65E
73E
75E
+
+
+
+
+
+
+
+
+
+
+
02
02
02
02
02
02
02
02
02
02
02
                                                                                            5.02E  +  02

-------
INORGANIC  (mg/kg)
Aluminum                                N              1                                1.22E  +  04          9.06E + 03
Antimony                                Y                                               3.05E  +  01          2.93E + 01
Arsenic                                 Y                                               7.03E  +  01          1.28E + 01
Barium                                                Y                                 2.45E  +  02          8.37E + 01
Beryllium                               Y                                               6.50E-01           4.30E-01
Calcium                                 N              1                                2.40E  +  03          1.42E + 03
Chromium                                Y                                               1.38E  +  01          1.22E + 01
Cobalt                                  N              1                                1.80E  +  01          1.19E + 01
Copper                                  N              1                                2.18E  +  01          1.46E + 01
Iron                                    N              1                                3.27E  +  04          2.59E + 04
Lead                                    N              1                                6.40E  +  01          1.60E + 01
Magnesium                               N              1                                3.70E  +  03          3.24E + 03
Maganese                                Y                                               1.34E  +  03          4.03E + 02
Mercury                                 Y                                               1.70E-01           1.62E-01
Nickel                                  Y                                               2.78E  +  01          2.22E  +  01
Potassium                               N              1                                1.37E  +  03          1.03E + 03
Sodium                                  N              1                                5.17E  +  01          4.36E + 01
Thallium                                Y                                               6.60E-01            2.10E-01
Vanadium                                Y                                               2.33E  +  01          1.33E + 01
Zinc                                    Y                                               1.37E  +  02          6.42E + 01

Note:
Y:  Yes

    No
    No available SF and RfDs.
    It is not carcinogenic compounds and the detection freguency is lower then 5 %.
    Sample number is less than 10.  No 95% UCL was calculated.

-------
TABLE 4

GROUNDWATER
EXPOSURE SCENARIOS
       EXPOSURE
       GROUP
                     EXPOSURE
                     PATHWAY
       Resident Adults
                     Inhalation
                     Ingestion
                     Dermal  Contact
       Resident Young Children
       Resident Older Children
TABLE 5
SUMMARY RISKS LEVELS AND HAZARD INDEX VALUES
DUE THE EXPOSURE TO UNTREATED GROUNDWATER
PRESENT AND FUTURE USE EXPOSURE SCENARIOS
                                                Inhalation
                                                Ingestion
                                                Dermal Contact
                                                Inhalation
                                                Ingestion
                                                Dermal Contact
       EXPOSURE GROUP/
       PATHWAY
CARCINOGENIC RISK LEVELS
       REASONABLE MAXIMUM
       EXPOSURE VALUES
NONCARCINOGENIC
       REASONABLE MAXIMUM
       EXPOSURE VALUES
       Resident Adults
       1.  Inhalation
       2.  Ingestion
       3.  Dermal Contact
       Cumulative Risk
       6.38 x 10-5
       1.49 x 10-2
       2.35 x 10-3
       1.73 x 10-2
       1.62 x 10-3
       3.36
       1.4 x 10-1
       3.5
       Resident Young Children
       1.  Inhalation              5.98 x  10-5
       2.  Ingestion               1.3 x 10-2
       3.  Dermal Contact          9.21 x  10-4
       Cumulative Risk            1.39 x  10-2
                                  7.55 x  10-3
                                  14.7
                                  2.73 x  10-1
                                  14.98
       Resident Older Children
       1.  Inhalation
       2.  Ingestion
       3.  Dermal Contact
       Cumulative Risk
       2.73 x 10-5
       5.94 x 10-3
       6.68 x 10-4
       6.64 x 10-3
       3.45 x 10-3
       6.73
       1.98 x 10-1
       6.93

-------
Table 6
SUMMARY OF THE NONCARCINOGENIC HAZARD INDEX CALCULATION RESULTS
TO CONSTRUCTION WORKERS IN FUTURE USE SCENARIO
OLEAN WELLFIELD SITE
Risk Location


ALCAS

AVX

BORROW PIT

OLEAN CLEAN ALL

PRIVATE DUMP

McGRAW-EDISON

MASTEL FORD

GRIFFITH OIL

FAY&SCHAFFER

SANDBURG OIL

OLEAN STEEL

OLEAN TILE

OLEAN WHOLESALE

EXHB-N-5.XLS
Noncarcinogenic Hazard Index from Ingestion
      Reasonable Maximum Exposure

            5.02E-01

            4.53E-01

            4.06E-01

            3.70E-01

            5.64E-01

            1.14E+00

            4.86E-01

            6.47E-01

            3.01E-01

            3.05E-01

            6.96E-01

            2.19E-01

            1.61E+00
Noncarcinogenic Hazard Index from Inhalation
        Reasonable Maximum Exposure
Combined Hazard Index
5.12E-03
3.85E-03
7.59E-06
2.70E-03
1.84E-02
3.64E-03
2.02E-03
2.56E-03
7.38E-04
1.70E-03
4.20E-03
1.81E-03
3.96E-03
5.07E-01
4.57E-01
4.06E-01
3.73E-01
5.82E-01
1.14E+00
4.88E-01
6.50E-01
3.02E-01
3.07E-01
7.00E-01
2.21E-01
1.61E+00

-------
Table 6
SUMMARY OF THE CARCINOGENIC RISK CALCULATION RESULTS
TO CONSTRUCTION WORKERS IN FUTURE USE SCENARIO
OLEAN WELLFIELD SITE

Risk Location         Carcinogenic Risk Levels from Ingestion       Carcinogenic Risk Levels  from Inhalation          Combined Risk
                            Reasonable Maximum Exposure                  Reasonable Maximum Exposure

ALCAS

AVX

BORROW PIT

OLEAN CLEAN ALL

PRIVATE DUMP

McGRAW-EDISON

MASTEL FORD

GRIFFITH OIL

FAY&SCHAFFER

SANDBURG OIL

OLEAN STEEL

OLEAN TILE

OLEAN WHOLESALE

EXHB-N-5.XLS
4.97E-05
1.76E-05
3.95E-06
1.07E-05
6.80E-06
1.52E-05
9.06E-06
7.30E-06
2.16E-05
3.78E-06
4.00E-06
2.76E-06
1.70E-05
2.32E-08
4.18E-09
3.00E-09
4.43E-09
3.30E-09
1.04E-08
5.08E-09
5.29E-09
3.59E-09
2.83E-09
3.10E-09
2.41E-09
1.12E-08
4.97E-05
1.76E-05
3.95E-06
1.07E-05
6.80E-06
1.52E-05
9.07E-06
7.31E-06
2.16E-05
3.78E-06
4.00E-06
2.76E-06
1.70E-05

-------
Table 7
CLEAN WELLFIELD SITE
TOXICITY DATA FOR NONCARCINOGENIC
AND POTENTIAL CARCINOGENIC  EFFECTS
DOSE RESPONSE EVALUATION
Chemical Name
Noncarcinogen Reference Dose           Subchronic Noncarcinogen Reference Dose  (1)                    Carcinogen Slope Factor
        RfD         RfC            RfD            RfD                 RfC                  RfD                     SF
      (oral)        (inhalation)   (inhalation)             (oral  sub)    (inhalation, sub  inhalation,  sub)       (Oral)
  (mg/Kg-day)      (mg/Cu.m)     (mg/Kg-day)      (mg/Kg-day)           (mg/Cu.m)           (mg/Kg-day)           (mg/Kg-day)-1
                    1,1-Dichloroethene
                    Cis-1,2-Dichloroethene
                    Trans-1,2-Dichloroethene
                    Methylene Chloride
                    Tetrachloroethene
                    Trichloroethene
                    Vinyl  Chloride
                    Carbon  Disulfide
                    Chlorobenzene
                    Chloroform
                    Acetone
                    Benzene
                    Ethylbenzene
                    Toluene
                    Total  Xylenes

                    Butyl  benzyl phthalate

                    Arsenic
                    Barium
                    Beryllium
                    Cadmium
                    Chromium III
                    Chromium VI
                    Cobalt
                    Copper
                    Lead
                    Manganese
                    Nickel
                    Nickel  (Refinery Dust)
                    Thallium
                    Vanadium
                    Zinc



3 .



1.




1.
4 .

ND
ND
ND
. OOE+00*
ND
UN
ND
.OOE-02*
UN
UN
ND
ND
. OOE+00
. OOE-01
UN
ND
ND
ND
8.57E-01
ND
UN
ND
2.86E-03*
UN
UN
ND
ND
2.86E-01
ND
UN
9. OOE-03
1. OOE-01
2. OOE-01
6. OOE-02
1. OOE-01
ND
ND
1. OOE-01
2. OOE-01
1. OOE-02
1. OOE + 00
ND
1. OOE + 00
ND
4. OOE + 00
ND
ND
ND
3. OOE+00
ND
ND
ND
1. OOE-02
ND
ND
ND
ND
1. OOE+00
ND
NA
ND
ND
ND
8.57E-
ND
ND
ND
2.86E-
ND
ND
ND
ND
2.86E-
ND
NA



01



03




01


3 .
7 .
5.
5 .
1.
5.



1.
2.

7 .
7.
2.
.OOE-04
.OOE-02
.OOE-03
.OOE-04
.OOE+00
.OOE-03
UN
ND
ND
.OOE-01
.OOE-02
ND
.OOE-05
.OOE-03*
.OOE-01*
ND
UN
ND
UN
UN
UN
ND
ND
ND
4 . OOE-04*
UN
ND
ND
ND
ND
ND
UN
ND
UN
UN
UN
ND
ND
ND
1.14E-04*
UN
ND
ND
ND
ND
3. OOE-04
7. OOE-02
5. OOE-02
NA
1. OOE + 00
2. OOE-02
ND
ND
ND
1. OOE-01*
2. OOE-02*
ND
7. OOE-05
7. OOE-03
2. OOE-01
ND
ND
ND
UN
UN
UN
ND
ND
ND
4 .OOE-04
ND
ND
ND
ND
ND
ND
ND
ND
UN
UN
UN
ND
ND
ND
1.40E-04
ND
ND
ND
ND
ND
6 .


7


I.


6 .

2.



.OOE-01
ND
ND
.50E-03
UN
NA
.90E+00*
ND
ND
.10E-03
ND
.90E-02
ND
ND
ND
C
ND
ND
B2
ND
ND
A
ND
ND
B2
ND
A
ND
ND
ND
5.00E-05
ND
ND
4 .70E-07
UN
ND
8.40E-05*
ND
ND
2.30E-05
ND
8.30E-06
ND
ND
ND
1.75E-01
ND
ND
1. 65E-03
ND
ND
2. 94E-01
ND
ND
8.05E-02
ND
ND
ND
ND
ND
1.75E+00
ND
4.30E+00
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
A
ND
B2
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
                                                                                                                                                                            ND

                                                                                                                                                                      1.50E+05
                                                                                                                                                                            ND
                                                                                                                                                                      8.40E+00
                                                                                                                                                                      6.30E+00
                                                                                                                                                                            ND
                                                                                                                                                                      4.20E+01
                                                                                                                                                                            ND
                                                                                                                                                                            ND
                                                                                                                                                                            ND
                                                                                                                                                                            ND
                                                                                                                                                                            ND
                                                                                                                                                                      8.40E-01
                                                                                                                                                                            ND
                                                                                                                                                                            ND
                                                                                                                                                                            ND
                                                                                                                                                                                               ND
                                                                                                                                                                                               ND
                                                                                                                                                                                               B2
                                                                                                                                                                                               ND
                                                                                                                                                                                               ND
                                                                                                                                                                                              A
                                                                                                                                                                                              A
                                                                                                                                                                                              ND
                                                                                                                                                                                              ND
                                                                                                                                                                                              ND

-------
Table 7
OLEAN WELLFIELD SITE
TOXICITY DATA FOR NONCARCINOGENIC
AND POTENTIAL CARCINOGENIC EFFECTS
DOSE RESPONSE EVALUATION

EPA Weight of Evidence classifications are as follows:

Group A:  Human Carcinogen.  Sufficient evidence from epidemiologic studies to support a casual association between exposure and cancer.
Group Bl:   Probable Human Carcinogen.  Limited evidence of carcinogenicity in human from epidemiological studies.
Group B2:   Probable Human Carcinogen.  Sufficient evidence of carcinogenicity in animals.  Inadeguate evidence of carcinogenicity in humans.
Group C:  Possible Human Carcinogen.  Limited evidence of carcinogenicity in animals.
Group D:  Not Classified.  Inadeguate evidence of carcinogenicity in animals

Note:
(1) All the Reference Dose for subcronic noncarcinogic compounds were derived from HEAST-FY 1992..
(2) The data was derived through personal contact with EPA Region II Risk Assessment group.
NA:  Not available
ND:  No data
UN:  Under review by EPA risk group
*:  The data was from Health Assessment Summary Tables (HEAST)-FY 1992.

OLSF&R.XLS

-------
Table 8
CLEAN WELLFIELD SITE
TOXICITY DATA FOR NONCARCINOGENIC
AND POTENTIAL CARCINOGENIC  EFFECTS
DOSE RESPONSE EVALUATION
Chemical Name
Subchronic Noncarcinogen Reference  Dose  (1)
          RfD            RfC                 RfD
       (oral sub)   (inhalation,  sub  (inhalation,  sub)
   (mg/Kg-day)     (mg/Cu.m)         (mg/Kg-day)
 Carcinogen  Slope  Factor
Weight     Unit Risk          SF
           (Inhalation)   (Inhalation)
                (ug/Cu.m)-1   (mg/Kg-day)-1
                                                                                                                                                      Weight
Volatiles:
   1,1-Dich1oroethane
   1, 1-Dichloroethene
   1,1,2,2-Tetrachloroethane
   1,1, 1-Trichloroethane
   1,1, 2-Trichloroethane
   1,2-Dichloroethane
   1, 2-Dichloroethene
   Chlorobenzene
   Chloroform
   Chloroethane
   Methylene Chloride
   Tetrachloroethene
   Trichloroethene
   Vinyl  Chloride
   2-Butanone
   Carbon Disulfide
   4-Methyl-2-Pentanone
   Acetone
   Benzene
   Ethylbenzene
   Styrene
   Toluene
   Total  Xylenes
1.
9.

9 .
4 .

9.
2.
1.

6 .
1.


5.
1.

1.

1.
2.
2 .
4.
.OOE+00
.OOE-03
ND
.OOE-01
.OOE-02
ND
.OOE-03
.OOE-01
.OOE-02
NA
.OOE-02
.OOE-01
ND
ND
.OOE-01
.OOE-01
ND
.OOE+00
ND
.OOE+00
.OOE+00
.OOE+00
.OOE+00
5. OOE+00
ND
ND
ND
ND
ND
ND
ND
ND
NA
3. OOE+00
ND
ND
ND
3. OOE+00
1. OOE-02
ND
ND
ND
1. OOE + 00
ND
2. OOE+00
NA
1.









8.



8.
2.



2.

5.

43E+00
ND
ND
ND
ND
ND
ND
ND
ND
NA
57E-01
ND
ND
ND
57E-01
86E-03
ND
ND
ND
86E-01
ND
71E-01
NA
ND
6. OOE-01
2. OOE-01
ND
5.70E-02
9.10E-02
ND
ND
6.10E-03
ND
7.50E-03
5.20E-02
1. 10E-02 (2)
1.90E+00*
ND
ND
ND
ND
2.90E-02
ND
ND
ND
ND
C
C
C
ND
C
B2
ND
ND
B2
ND
B2
B2
B2
A
ND
ND
ND
ND
A
ND
ND
ND
ND
ND
5.00E-05
5.80E-05
ND
1.60E-05
2.60E-05
ND
ND
2.30E-05
ND
4 .70E-07
5.70E-07
1.70E-06 (2)
8.40E-05*
ND
ND
ND
ND
8.30E-06
ND
ND
ND
ND
ND
1.75E-01
2.30E-01
ND
5. 60E-02
9. 10E-02
ND
ND
8.05E-02
ND
1. 65E-03
2. OOE-03
5.95E-03 (2)
2.94E-01
ND
ND
ND
ND
2. 91E-02
ND
ND
ND
ND

-------
Table 8
CLEAN WELLFIELD SITE
TOXICITY DATA FOR NONCARCINOGENIC
AND POTENTIAL CARCINOGENIC  EFFECTS
DOSE RESPONSE EVALUATION
Chemical Name
Subchronic Noncarcinogen Reference Dose  (1)
         RfD             RfC              RfD
     (oral sub)    (inhalation, sub (inhalation,  sub)
     (mg/Kg-day)     (mg/Cu.m)         (mg/Kg-day)
           Carcinogen Slope Factor
           Weight        Unit  Risk
                       (Inhalation)
                            (ug/Cu.m)-1
                                                                                                                                                                             Weight
Semi-Volatiles:
       2,4-Dimethylphenol               2.00E-01
       2-Methylnaphthalene                  ND
       Acenaphthene                      6.00E-01
       Acenaphthylene                       ND
       Anthracene                        3.00E+00
       Benzo(g,h,i)perylene                 ND
       Dibenzofuran                         ND
       Fluranthrene                      4.00E-01
       Fluorene                          4.00E-01
       Naphthalene                       4.00E-02
       Phenanthrene                         ND
       Pyrene                            3.00E-01
Carcinogenic PAHs
          Benzo(a)pyrene                    ND
          Benzo(a)anthracene                ND
          Benzo(b)fluoranthene              ND
          Benzo(k)fluoranthene              ND
          Chrysene                           ND
          Dibenz(a,h)anthracene             ND
          Indeno(l,2,3-cd)  pyrene           ND
       1,2,4-Trichlorobenzene            l.OOE-02
       Bis(2-ethylhexyl)phthalate        2 . OOE-02
       Di-n-butyl phthalate              l.OOE+00
       Diethylphthalate                  8.00E+00
       2-Methylphenol                    5.00E-01
       4-Methylphenol                    5.00E-01
       Carbazole                            ND
       2 , 4-Dinitrotoluene                   ND
       Bis(2-chloroethoxy)methane           ND
                           ND
                           ND
                           ND
                           ND
                           ND
                           ND
                           ND
                           ND
                           ND
                           ND
                           ND
                           ND

                           ND
                           ND
                           ND
                           ND
                           ND
                           ND
                           ND
                           ND
                           ND
                           ND
                           ND
                           ND
                           ND
                           ND
                           ND
                           ND
   ND
   ND
   ND
   ND
   ND
   ND
   ND
   ND
   ND
   ND
   ND
   ND

7.30E+00
   ND
   ND
   ND
   ND
   ND
   ND
   ND
1.40E-02
   ND
   ND
   ND
   ND
2. OOE-02
   ND
   ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND

B2
ND
ND
ND
ND
ND
ND
ND
B2
ND
ND
ND
ND
B2
ND
ND
     ND
     ND
     ND
     ND
     ND
     ND
     ND
     ND
     ND
     ND
     ND
     ND

1.70E-03
     ND
     ND
     ND
     ND
     ND
     ND
     ND
     ND
     ND
     ND
     ND
     ND
5.70E-07
     ND
     ND
  ND
  ND
  ND
  ND
  ND
  ND
  ND
  ND
  ND
  ND
  ND
  ND

.95E+00
  ND
  ND
  ND
  ND
  ND
  ND
  ND
  ND
  ND
  ND
  ND
  ND
.OOE-03
  ND
  ND

-------
Table 8
CLEAN WELLFIELD  SITE
TOXICITY DATA FOR NONCARCINOGENIC
AND POTENTIAL CARCINOGENIC EFFECTS
DOSE RESPONSE EVALUATION
Chemical Name
 Subchronic  Noncarcinogen Reference Dose  (1)
        RfD              RfC              RfD
      (oral  sub)    (inhalation, sub  (inhalation,  sub)
(mg/Kg-day)     (mg/Cu.m)         (mg/Kg-day)
Carcinogen Slope Factor
 Weight        Unit Risk
              (Inhalation)
                  (ug/Cu.m)-1
Inorganics :
Aluminum
Antimony
Arsenic
Barium
Beryllium
Cadmium
Calcium
Chromium III
Chromium VI
Cobalt
Copper
Cyanide
Iron
Lead
Magnesium
Manganese
Mercury
Nickel
Nickel (Refinery Dust)
Potassium
Selenium
Silver
Sodium
Thallium
Vanadium
Zinc

ND
4.00E-04
3. OOE-04
7.00E-02
5.00E-02
NA
ND
1. OOE + 00
2. OOE-02
ND
ND
2. OOE-02
ND
ND
ND
1. OOE-01
3. OOE-04*
2. OOE-02
ND
ND
5.00E-03
5. OOE-03
ND
7.00E-05
7. OOE-03
2. OOE-01

ND
ND
ND
ND
ND
UN
ND
UN
UN
ND
ND
ND
ND
ND
ND
4. OOE-04
3. OOE-04
ND
ND
ND
ND
ND
ND
ND
ND
ND

ND
ND
ND
ND
ND
UN
ND
UN
UN
ND
ND
ND
ND
ND
ND
1.40E-04
8.57E-05
ND
ND
ND
ND
ND
ND
ND
ND
ND

ND
ND
1.75E+00
ND
4.30E+00
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND

ND
ND
A
ND
B2
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND

ND
ND
4 .30E-03
ND
2.40E-03
1. 80E-03
ND
ND
1.20E-02
ND
ND
ND
ND
ND
ND
ND
ND
ND
2.40E-04
ND
ND
ND
ND
ND
ND
ND
                                                                                                                                                           ND
                                                                                                                                                           ND
                                                                                                                                                      1.51E+01
                                                                                                                                                           ND
                                                                                                                                                        8.40E+00
                                                                                                                                                      3.30E+00
                                                                                                                                                           ND
                                                                                                                                                           ND
                                                                                                                                                        4.20E+01
                                                                                                                                                           ND
                                                                                                                                                           ND
                                                                                                                                                           ND
                                                                                                                                                           ND
                                                                                                                                                           ND
                                                                                                                                                           ND
                                                                                                                                                           ND
                                                                                                                                                           ND
                                                                                                                                                           ND
                                                                                                                                                        8.40E-01
                                                                                                                                                           ND
                                                                                                                                                           ND
                                                                                                                                                           ND
                                                                                                                                                           ND
                                                                                                                                                           ND
                                                                                                                                                           ND
                                                                                                                                                           ND
                                                                                                                                                                     Weight

-------
Table 8
OLEAN WELLFIELD SITE
TOXICITY DATA FOR NONCARCINOGENIC
AND POTENTIAL CARCINOGENIC EFFECTS
DOSE RESPONSE EVALUATION

EPA Weight of Evidence classifications are as follows:
Group A              Human Carcinogen.   Sufficient evidence from epidemiologic studies to support a causal association between exposure.
Group Bl             Probable Human Carcinogen.   Limited evidence of carcinogenicity in human from epidemiological studies.
Group B2             Probable Human Carcinogen.   Sufficient evidence of carcinogenicity in animals.   Inadeguate evidence of  carcinogeni
Group C              Possible Human Carcinogen.   Limited evidence of carcinogenicity in animal.
Group D              Not  classified.   Inadeguate evidence of carcinogenicity in animals.


Note:                All  toxicity values unless  otherwise noted are from Integrated Risk Information System (IRIS).
                     (1)  All  the Reference Dose  for subcronic noncarcinogenic compounds were derived from HEAST-FY 1992.
                     (2)  The  data was  derived through personal contact with EPA region II Risk Assessment group.
                     NA:  Not  available
                     ND:  No data
                     UN:  Under review  by EPA risk group
                     *: The data was from Health Assessment Summary Tables (HEASYT)-FY 1992.

-------
PRESENT WORTH AND CAPITAL AND  OPERATION AND MAINTENANCE COSTS BY SOURCE AREA
                                                               Alternative 3     Alternative  3A        Alternative 4         Alternative  4                 Alternative  5           Alternative 5
                                                                           Capping  and   Groundwater            In-Situ Treatment          VER or SVE/AS            Soil  Excavation            Soil Excavation and
                                                                 Groundwater    Treatment               using VER or   and Groundwater     (Stage 1)                  Groundwater
                                                                  Treatment                              SVE/AS                      Treatment                                             Treatment
                                                                 (Stages 152)                            (Stage 1)                    (Stages  152)                                (Stage 152)
ALCAS1
Capital Cost
OSM2  (1-5 yrs)
05M  (6-30 yrs)
PW1 of 05M
Total PW
AVX
Capital Cost
OSM  (1-5 yrs)
OSM  (6-30 yrs)
PW of OSM
Total PW
McGraw-Edison4
Capital Cost
OSM  (1-5 yrs)
OSM  (6-30 yrs)
PW of OSM
Total PW
Loohns Dry
Cleaners
Capital cost
OSM  (1-5 yrs)
OSM  (6-30 yrs)
PW of OSM
Total PW
1 - Present Worth and  capital  and  operation and maintenance costs for groundwater  treatment  are not presented, since groundwater  remediation  will  not be necessary at the Alcas source area.
2 - PW - Present Worth based on  a  7  percent discount rate.
2 - OSM - Operation  and maintenance  costs.
4 - Capital, present worth  and operation and maintenance costs were not calculated for  Alternatives 3,  4 or 5, since soil remediation will  not  be  necessary at the McGraw-Edison source area.
See page 60 of ROD for an explanation of the expenses which were included in the cost  estimates for Alternative 3A.

-------
APPENDIX III

ADMINISTRATIVE RECORD INDEX

OLEAN WELL FIELD SITE
OPERABLE UNIT TWO
ADMINISTRATIVE RECORD FILE
INDEX OF DOCUMENTS

3.0 REMEDIAL INVESTIGATION

3.1 Sampling and Analysis Plans

P. 300001- Plan: Addendum to the June 1989 Field Operations
300272 Plan for the Olean Well Field Supplemental RI/FS Study, undated. (Attachment: Field
Operations Plan (FOP) for Supplemental Remedial Investigation/Feasibility Study, Olean Well Field Site,
Olean, New York, prepared for U.S. EPA, Region II, prepared by Ebasco Services Incorporated, June 1989).

3.3 Work Plans

P. 300723- Plan: Addendum to the May 1989 Supplemental RI/FS
300275 Workplan for the Olean Well Field Site, undated.

P. 300276- Plan: Final Supplemental Remedial
300377 Investigation/Feasibility Study Work Plan, Olean Well Field Site, Olean, New York, prepared
for U.S. EPA, Region II, prepared by Ebasco Services Incorporated, May 1989.

P. 300378- Plan: Supplemental Work Plan, Olean Well Field
300399 Site, Olean, New York, prepared for Olean Cooperating Industries, prepared by Geraghty &
Miller, Inc., December 1992.

3.4 Remedial Investigation Reports

P. 300400- Report: Preliminary Facilities Characterization
300494 Summary, Olean Well Field Supplemental RI/FS, Volume I, Text, Tables, Figures and Appendices,
prepared for Olean Cooperating Industries, prepared by Geraghty & Miller, Inc., May 1992.

P. 300495- Report: Preliminary Facilities Characterization
300886 Summary, Olean Well Field Supplemental RI/FS, Volume II, USEPA Region 2, Organic Data
Validation Checklists, prepared for Olean Cooperating Industries, prepared by Geraghty & Miller, Inc., May,
1992.

P. 300887- Report: Preliminary Facilities Characterization
301014 Summary, Olean Well Field Supplemental RI/FS, Volume III, USEPA Region 2, Inorganic Data
Validation Checklists, prepared for Olean Cooperating Industries, prepared by Geraghty & Miller, Inc., May
1992.

P. 301015- Report: Draft Stage 1A Cultural Resources Survey,
301100 Olean Well Field Site, Olean, New York, prepared for U.S. EPA, Region II, prepared by Ebasco
Services Incorporated, June 1992.

P. 301101- Report: Final Supplemental Risk Assessment, Olean
301199 Well Field Site, Olean, New York, prepared for U.S. EPA, Region II, prepared by Ebasco
Services Incorporated, December 1993.

P. 301199A- Report: Final Risk Assessment, Olean Well Field,
301370 Olean, New York, prepared for U.S. EPA, Region II, prepared by Ebasco Services Incorporated,

-------
December 1993.

P.   301371-   Letter to Mr. Mark Mcese, Ebasco Environmental,
     301379    from Mr. Adrian R. Tucker, Soil Gas Projects Manager, Ebasco Environmental, re: Attached
Report: 1994 Soil Gas Results - Olean Well Field, March 18, 1994.

P.   301380-   Report: Supplemental Remedial Investigation
     301989    Report, Olean Well Field, Olean, New York, prepared for Olean Cooperating Industries, prepared
by Geraghty & Miller, Inc., October 1994.

P.   301990-   Report: Final Addendum to the Olean Well Field
     302171    Supplemental Remedial Investigation Report, prepared for Mr. Thomas Taccone, Remedial Project
Manager, for U.S. EPA, Region II, prepared by Mr. Mark D. Moese, Ph.D., Ebasco Services Incorporated, May 30,
1995.

P.   302172-   Report: Final Wetland Delineation Report, Olean
     302202    Well Field, Olean, New York, prepared for U.S. EPA, Region II, prepared by Ebasco Services
Incorporated, August 1995.

3.5  Correspondence

P.   302203-   Letter to Mr. Thomas Taccone, Remedial Project
     302205    Manager, U.S. EPA, Region II, from Ms. Libby Ford, Senior Environmental Health Engineering,
Olean Cooperating Industries SRI/FS Project Coordinator, Nixon, Hargrave, Devans & Doyle, re: Olean SRI/FS
Notification of Tentative Schedule for Boring and Well Drilling Program - Olean Cooperating Industries,
November 7, 1991.  (Attachment:  Facsimile transmission to Ms. Libby Ford, Nixon, Hargrave, Devans & Doyle,
from Mr. William J. Gray, Senior Scientist, Geraghty & Miller, Inc., re: Tentative Drilling Schedule dates
for Olean Well Field Supplemental RI/FS, November 6, 1991.)

P.   302206-   Letter to Ms. Libby Ford, Nixon, Hargrave, Devans
     302207    & Doyle, from Mr. William J. Gray, Senior Scientist, Geraghty & Miller, Inc., re: December 4,
1991 Conference Call with USEPA Monitoring and Management Branch  (Project No. AY08813), December 13, 1991.

P.   302208-   Letter to Ms. Libby Ford, Senior Environmental
     302209    Health Engineer, Nixon, Hargrave, Devans & Doyle, from Ms. Carole Petersen, Chief,
NY/Caribbean Superfund Branch II, U.S. EPA, Region II, re:  Olean Wellfield Superfund Site; Geraghty &
Miller's letter of April 20, 1992; Submission Date for the Remaining Ebasco RI Data, May 21, 1992.

P.   302210-   Letter to Ms. Libby Ford, Senior Environmental
     302213    Health Engineer, Nixon, Hargrave, Devans & Doyle, from Ms. Carole Petersen, Chief,
NY/Caribbean Superfund Branch II, U.S. EPA, Region II, re:  Olean Wellfield Superfund Site; Preliminary
Facilities Characterization Summary, August 20, 1992.

P.   302214-   Letter to Ms. Libby Ford, Nixon, Hargrave, Devans
     302219    & Doyle, from Mr. William J. Gray, Senior Scientist, Geraghty & Miller, Inc., re: Response to
United States Environmental Protection Agency's August 20, 1992 Letter Regarding the Olean Well Field
Preliminary Facilities Characterization Summary  (Project No. AY08813), September 11, 1992.

P.   302220-   Letter to Ms. Libby Ford, Senior Environmental
     302222    Health Engineer, Nixon, Hargrave, Devans & Doyle, from Ms. Carole Petersen, Chief,
NY/Caribbean Superfund Branch II, U.S. EPA, Region II, re:  Comments on the Draft Supplement to the
Supplemental RI/FS Workplan for the Olean Wellfield Superfund Site, October 19, 1992.

P.   302223-   Letter to Ms. Libby Ford, Senior Environmental
     302228    Health Engineer, Nixon, Hargrave, Devans & Doyle, from Ms. Carole Petersen, Chief NY/Caribbean
Superfund Branch II,  U.S. EPA, Region II, re: Olean Wellfield Superfund Site; November 4, 1992 Supplemental
RI/FS Workplan and FOP Supplement, November 27, 1992.   (Attachment:  Letter to Ms. Carole Petersen, Chief,

-------
NY/Caribbean Superfund Branch II, U.S. EPA, Region II, from Ms.  Libby Ford, Nixon, Hargrave, Devans & Doyle,
re:  Olean Wellfield Superfund Site; Reguested Changed Pages to the November 4, 1992 Supplement to the SRI/FS
Workplan and FOP Supplement, December 2, 1992.)

P.   302229-   Letter to Ms. Libby Ford, Senior Environmental
     302230    Health Engineer, Nixon, Hargrave, Devans & Doyle, from Ms. Carole Petersen, Chief,
NY/Caribbean Superfund Branch II, U.S. EPA, Region II, re: Olean Wellfield Superfund Site; Supplemental
RI/FS, July 2, 1993.

P.   302231-   Letter to Mr. Thomas Taccone, Remedial Project
     302291    Manager, U.S. EPA, Region II, from Ms. Libby Ford, Senior Environmental Health Engineer, Olean
Cooperating Industries SRI/FS Coordinator, Nixon, Hargrave, Devans & Doyle, re:  Olean Wellfield Supplemental
RI/FS—Comments on Draft EBASCO Risk Assessment and Reguest For a Meeting, October 1, 1993.   (Attachments:
1. Letter with attached data to Mr. Richard H. Uber, Manager, Field Operations and Environmental Affairs,
Cooper Industries, from Ms. Carole Petersen, Chief, NY/Caribbean Superfund Branch II, U.S. EPA, Region II,
re:  Olean Well Field Superfund Site; Start-up of the Air Strippers, September 8, 1993, 2. Letter with
attached data to Ms. Libby Ford, Nixon, Hargrave, Devans & Doyle, from Mr. Peter Marcus, Department of Public
Works, City of Olean, re:  attached inorganic test results at Wells 18 and 37-38, September 21, 1993, 3.
Construction Permission and Right of Way Agreement, September 22, 1993, 4. Memorandum to AVX Olean SRI/FS
File, from Ms. Libby Ford, Nixon, Hargrave, Devans & Doyle, re: Institutional Safeguards In Place to Insure
that the Former Private Wells are not Reconnected, September 24, 1993.)

P.   302292-   Letter to Mr. Thomas Taccone, Remedial Project
     302295    Manager, U.S. EPA, Region II, from Ms. Lani Rafferty, Program Research Specialist II, Bureau
of Environmental Exposure Investigation, State of New York Department of Health, re: Olean Wellfield, Olean,
Cattaraugus County, Site ID #905014, October 27, 1993.  (Attachment: Olean Wellfield Site, Chemicals of
Potential Concern, ARARs and Levels of Detection in Groundwater, undated.)

P.   302296-   Letter to Ms. Carole Petersen, Chief, NY/Caribbean
     302298    Superfund Branch II, U.S. EPA, Region II, from Ms. Libby Ford, Senior Environmental Health
Engineer, Olean Cooperating Industries SRI/FS Coordinator, Nixon, Hargrave, Devans & Doyle, re: Olean
Supplemental RI/FS--Finalization of Risk Assessment, November 19, 1993.

P.   302299-   Letter to Ms. Lani Rafferty, Program Research
     302300    Specialist, Bureau of Environmental Exposure Investigation, New York Department of Health,
from Mr. Thomas Taccone, Remedial Project Manager, U.S. EPA, Region II, re: Olean Wellfield Superfund Site,
November 30, 1993.

P.   302301-   Letter to Mr. Thomas Taccone, Remedial Project
     302305    Manager, U.S. EPA, Region II, from Ms. Lani Rafferty, Program Research Specialist, Bureau of
Environmental Exposure Investigation, New York Department of Health, re: Olean Wellfield, Olean, Cattargaurus
County, Site ID #905014, December 6, 1993.   (Attachments:  Figure 1: Fay Ave./Shafer Rd., Figure 2: Mastel
Ford, Figure 3: Griffith Oil (North).)

P.   302306-   Letter to Mr. Thomas Taccone, Remedial Project
     302311    Manager, U.S. EPA, Region II, from Mr. Steven M. Scharf, P.E., Project Engineer, Bureau of
Western Remedial Action, Division of Hazardous Waste Remediation, New York State Department of Environmental
Conservation, re: Olean Wellfield Site  (C&T), Cattaraugus County Site No. 9-05-014, December 13, 1993.
(Attachment: Appendix A: Letter to Mr. Steven Scharf, Environmental Engineer, Bureau of Western Remedial
Action, NYS Dept. of Environmental Conservation, from Ms.  Lani Rafferty, Program Research Specialist II,
Bureau of Environmental Exposure Investigation, New York State Department of Health, re: Olean Well Field.
Olean, Cattaraugus County, Site ID #905014, November 26, 1993.)

P.   302312-   Letter to Ms. Libby Ford, Senior Environmental
     302313    Health Engineer, Nixon, Hargrave, Devans & Doyle, from Ms. Carole Petersen, Chief,
NY/Caribbean Superfund Branch II, U.S. EPA, Region II, re: Final Risk Assessment for the Olean Wellfield
Superfund Site, December 17, 1993.

-------
P.   302314-   Letter to Mr. Thomas Taccone, Remedial Project
     302315    Manager, U.S. EPA, Region II, from Mr. Steven M. Scharf, P.E., Project Engineer, Bureau of
Western Remedial Action, Division of Hazardous Waste Remediation, New York State of Department of
Environmental Conservation, re: Clean Wellfield Site, Clean City & Town, Cattaraugus County Site No.
9-05-014, December 27, 1993.

P.   302316-   Letter to Ms. Libby Ford, Senior Environmental
     302323    Health Engineer, Nixon, Hargrave, Devans & Doyle, from Ms. Carole Petersen, Chief,
NY/Caribbean Superfund Branch II, U.S. EPA, Region II, re: Clean Wellfield Superfund Site; Comments on the
Draft Supplemental Remedial Investigation Report, January 10, 1994.

P.   302324-   Letter to Mr. Steven M. Scharf, P.E., Project
     302325    Engineer, Bureau of Western Remedial Action, Division of Hazardous Waste Remediation, New York
State Department of Environmental Conservation, from Mr. Thomas Taccone, Remedial Project Manager, U.S. EPA,
Region II, re: Clean Wellfield Superfund Site; Letter of December 27, 1993, January 18, 1994.

P.   302326-   Letter to Mr. Thomas Taccone, Remedial Project
     302337    Manager, U.S. EPA, Region II, from Mr. illiam J. Gray, Senior Scientist/Project Manager,
Geraghty & Miller, Inc., re: Response to USEPA Comments on Draft Clean Well Field Supplemental Remedial
Investigation Report  (Project No. AY0167.001), February 11, 1994.

P.   302338-   Letter to Ms. Libby Ford, Senior Environmental
     302343    Health Engineer, Nixon, Hargrave, Devans & Doyle, from Ms. Carole Petersen, Chief,
NY/Caribbean Superfund Branch II, U.S. EPA, Region II, re:  Clean Wellfield Superfund Site; Proposed
Revisions to the Draft Supplemental Remedial Investigation Report, March 30, 1994.

P.   302344-   Letter to Mr. Thomas Taccone, Remedial Project
     302357    Manager, U.S. EPA, Region II, from Mr. Wayne Westbrook, Principal Scientist, Pacific
Environmental Services, Inc., re: Clean Wellfield Superfund Site; Soil Gas Data to Access Indoor Air Risks,
April 8, 1994.   (Attachments: Enclosure 1:  "Model Used to Estimate Indoor Air Concentrations", Enclosure 2:
"Indoor Air Risk Calculations", Report: Air/Superfund National Guidance Study Series, Assessing Potential
Indoor Air Impacts for Superfund Sites, September 1992.)

P.   302358-   Letter to Mr. Thomas Taccone, Remedial Project
     302371    Manager, U.S. EPA, Region II, from Mr. William J. Gray, Senior Scientist/Project Manager,
Geraghty & Miller, Inc., re: Response to USEPA Proposed Revisions to Draft Clean Well Field Supplemental
Remedial Investigation Report  (Project No.  AY0167.001), April 15, 1994.   (Attachment)

P.   302372-   Letter to Ms. Carole Petersen, Chief, NY/Caribbean
     302373    Superfund Branch II, U.S. EPA, Region II, from Mr. Allison C. Wakeman, Chief, Western/Niagara
Section, Bureau of Environmental Exposure Investigation, State of New York Department of     Health, re:
Clean Wellfield, Clean, Cattaraugus County, Site ID #905014, June 7, 1994.

P.   302374-   Letter to Ms. Libby Ford, Senior Environmental
     302377    Health Engineer, Nixon, Hargrave, Devans & Doyle, from Ms. Carole Petersen, Chief,
NY/Caribbean Superfund Branch II, U.S. EPA, Region II, re:  Clean Wellfield Superfund Site; Proposed
Revisions to the Supplemental Draft SRI Report, June 9, 1994.  (Attachment)

P.   302378-   Letter to Mr. Thomas Taccone, Remedial Project
     302390    Manager, U.S. EPA, Region II, from Messrs. William J. Gray, Senior Scientist/Project Manager
and Andrew J. Barber, Senior Associate/Project Officer, Geraghty & Miller, Inc., re: Attached response to
USEPA Comments on Draft Clean Well Field Supplemental Remedial Investigation Report  (Project No. AY0167.001),
July 7, 1994.

P.   302391-   Letter to Mr. Allison C. Wakeman, Chief
     302391    Western/Niagara Section, Bureau of Environmental Exposure Investigation, New York State

-------
Department of Health, from Mr. Kevin Lynch, Chief, Western New York Section II, U.S. EPA, Region II, re:
Second Round of Soil Gas Sampling at the Olean Wellfield Superfund Site, July 22, 1994.

P.   302392-   Letter to Ms. Libby Ford, Senior Environmental
     302393    Health Engineer, Nixon, Hargrave, Devans & Doyle, from Ms. Carole Petersen, Chief,
NY/Caribbean Superfund Branch II, U.S. EPA, Region II, re:  Olean Wellfield Superfund Site; Proposed
Revisions to the Supplemental Draft SRI Report, September 23, 1994.

P.   302394-   Letter to Ms. Lani Rafferty, Program Research
     302394    Specialist II, Bureau of Environmental Investigation, New York State Department of Health,
from Mr. Thomas Taccone, Remedial Project Manager, U.S. EPA, Region II, re: Olean Wellfield Superfund Site:
Second Round of Soil Gas Sample Data, December 2, 1994.

P.   302395-   Letter to Ms. Lani Rafferty, Environmental Health
     302397    Specialist II, Bureau of Environmental Exposure Investigation, New York Department of Health,
from Mr. Thomas Taccone, Remedial Project Manager, U.S. EPA, Region II, re: Olean Wellfield Superfund Site;
Indoor Air Risk Analysis, February 27, 1995.

P.   302398-   Letter to Ms. Libby Ford, Senior Environmental
     302399    Health Engineer, Nixon, Hargrave, Devans & Doyle, from Ms. Carole Petersen, Chief,
NY/Caribbean Superfund Branch II, U.S. EPA, Region II, re:  Olean Wellfield Superfund Site; SRI Addendum and
Deadline Extension for the Draft SFS, March 17, 1995.

P.   302400-   Letter to Mr. Thomas Taccone, Remedial Project
     302401    Manager, U.S. EPA, Region II, from Mr. William J. Gray, Senior Scientist/Project Manager,
Geraghty & Miller, Inc., re: Attached Addendum to Olean Well Field SRI Report, March 30, 1995.  (Attachment)

P.   302402-   Letter to Mr. Thomas Taccone, Remedial Project
     302404    Manager, U.S. EPA, Region II, from Ms. Lani Rafferty, Environmental Health Specialist II,
Bureau of Environmental Exposure Investigation, State of New York Department of Health, re: Olean Well Field,
Olean, Cattaraugus County, ID #905014, June 16, 1995.

P.   302405-   Letter to Mr. Thomas Taccone, Remedial Project
     302407    Manager, U.S. EPA, Region II, from Mr. Steven M. Scharf, P.E., Project Engineer, Bureau of
Western Remedial Action, Division of Hazardous Waste Remediation, New York State Department of Environmental
Conservation, re: Olean Wellfield Site, City and Town of Olean, Cattaraugus County NYSDEC Site No.  9-05-014,
June 27, 1995.

P.   302408-   Letter to Ms. Libby Ford, Senior Environmental
     302409    Health Engineer, Nixon, Hargrave, Devans and Doyle, from Ms. Carole Petersen, NY/Caribbean
Superfund Branch II, U.S. EPA, Region II, re:  Olean Wellfield Superfund Site; Addendum to the SRI  Report and
Approval of the SRI Report, June 30, 1995.

P.   302410-   Letter to Mr. Steven M. Scharf, P.E., Project
     302411    Engineer, Bureau of Western Remedial Investigation, Division of Hazardous Waste Remediation,
New York State Department of Environmental Conservation, from Mr. Thomas Taccone, Remedial Project  Manager,
U.S. EPA, Region II, re: Olean Wellfield Superfund Site; DEC Comments on EPA's Addendum to the SRI, July 13,
1995.

P.   302412-   Letter to Mr. Thomas Taccone, Remedial Project
     302414    Manager, U.S. EPA, Region II, from Messrs.  William J. Gray, Senior Scientist/Project Manager
and Andrew J. Barber, Senior Associate/Project Officer, Geraghty & Miller, Inc., re: Attached Addendum to
Olean SRI Report, July 20, 1995.

4.0  FEASIBILITY STUDY

4.3  Feasibility Study Reports

-------
P.   400001-   Letter to Mr. Thomas Taccone, U.S. EPA, Region
     400055    II, from Messrs. William J. Gray, Senior Scientist, and Andrew J. Barber, Senior Associate,
Geraghty & Miller, Inc., re: Attached report:  Preliminary Screening of Assembled Remedial Alternatives,
Clean Well Field Site, Clean, New York, prepared for Clean Cooperating Industries, prepared by GMCE of New
York, P.C., Engineering Services, March 28, 1994.

P.   400056-   Letter to Mr. Thomas Taccone, U.S. EPA, Region II,
     400146    from Messrs. William J. Gray, Senior Scientist/Project Manager, and Andrew J. Barber, Senior
Associate/Project Officer, re: Attached report: Vacuum Enhanced Recovery Pilot Test Report, Alcas Facility,
Clean, New York, prepared for Clean Cooperating Industries, prepared by Geraghty & Miller, Inc., May 30,
1995.

P.   400147-   Letter to Mr. Thomas Taccone, U.S. EPA, Region II,
     400278    from Messrs. William J. Gray, Senior Scientist/Project Manager, and Andrew J. Barber, Senior
Associate/Project Officer, re: Attached report: Vacuum Enhanced Recovery Pilot Test Report, AVX Facility,
Clean, New York, prepared for Olean Cooperating Industries, prepared by Geraghty & Miller, Inc., June 1,
1995.

4 . 6  Correspondence

P.   400279-   Letter to Ms. Libby Ford, Senior Environmental
     400294    Health Engineer, Nixon, Hargrave, Devans & Doyle, from Ms. Carole Petersen, Chief,
NY/Caribbean Superfund Branch II, U.S. EPA, Region II, re:  Olean Wellfield Superfund Site Supplemental
Feasibility Study, January 10, 1994.  (Attachments: 1. Memorandum to Regional Hazardous Waste Remediation
Engineers, Bureau Divisions & Section Chiefs, from Mr. Michael J. O'Toole, Jr., Division of Hazardous Waste
Remediation, re:  Division Technical and Administrative Guidance Memorandum: Determination of Soil Cleanup
Objectives and Cleanup Levels, November 16, 1992, 2. Appendix A, Tables 1-4, "Recommended Soil Cleanup
Objectives  (mg/kg or ppm)", 3.  "Conventional Sediment Variables, Total Organic Carbon  (TOG)", March 1986.)

P.   400295-   Letter to Mr. Thomas Taccone, Remedial Project
     400304    Manager, U.S. EPA, Region II, from Ms. Libby Ford, Senior Environmental Health Engineer, Olean
Cooperating Industries SRI/FS Coordinator, Nixon, Hargrave, Devans & Doyle, re: Notification Triggering
Dispute Resolution—Clean Supplemental Remedial Investigation/Feasibility Study Objectives and How These
Objectives Are To Be Incorporated Into the Supplemental Feasibility Study, January 14, 1994.

P.   400305-   Letter to Ms. Libby Ford, Senior Environmental
     400306    Health Engineer, Nixon, Hargrave, Devans & Doyle, from Mr. Thomas Taccone, Remedial Project
Manager, U.S. EPA, Region II, re: Olean Wellfield Superfund Site; January 14, 1994 Notification of Dispute
Resolution, January 24, 1994.

P.   400307-   Letter to Mr. Thomas Taccone, Remedial Project
     400312    Manager, U.S. EPA, Region II, from Ms. Libby Ford, Senior Environmental Health Engineer, Olean
Cooperating Industries SRI/FS Coordinator, Nixon Hargrave, Devans & Doyle, re: Administrative Order II
CERCLA-10202, Olean Wellfield Supplemental RI/FS - Memorandum on Remedial Action Objectives, January 31,
1994.   (Attachment: Memorandum on Remedial Action Objectives, undated.)

P.   400313-   Letter to Ms. Libby Ford, Senior Environmental
     400319    Health Engineer, Nixon, Hargrave, Devans & Doyle, from Mr. Thomas Taccone, Remedial Project
Manager, U.S. EPA, Region II, re: Olean Wellfield Superfund Site; January 14, 1994 Notification of Dispute
Resolution, February 25, 1994.

P.   400320-   Letter to Ms. Libby Ford, Senior Environmental
     400321    Health Engineer, Nixon, Hargrave, Devans & Doyle, from Ms. Carole Petersen, Chief,
NY/Caribbean Superfund Branch II, U.S. EPA, Region II, re:  Olean Wellfield Superfund Site; Comments on the
Memorandum on Remedial Action Objectives and Subseguent FS Submittals, March 18, 1994.

P.   400322-   Letter to Ms. Libby Ford, Senior Environmental

-------
     400322    Health Engineer, Nixon, Hargrave, Devans & Doyle, from Ms. Carole Petersen, Chief,
NY/Caribbean Superfund Branch II, U.S. EPA, Region II, re:  Olean Wellfield Superfund Site Supplemental
Feasibility Study, April 21, 1994.

P.   400323-   Letter to Mr. Thomas Taccone, Remedial Project
     400327    Manager, U.S. EPA, Region II, from Mr. Steven M. Scharf, P.E., Project Engineer, Bureau of
Waste Remedial Action, Division of Hazardous Waste Remediation, New York State Department of Environmental
Conservation, re: Olean Wellfield Site, Olean C&T, Cattaraugus County Site No. 9-05-014, April 28, 1994.
(Attachments: Attachment A:  Facsimile to Mr. Steven Sharf, Environmental Engineer 2, NYS Department of
Environmental Conservation, Bureau of Western Remedial Action, from Ms. Lani Rafferty, Environmental Health
Specialist II, Bureau of Environmental Exposure Investigation, re: Olean Wellfield, Olean, Cattaraugus
County, Site ID #905014, April 27, 1994, Attachment B: Site map, Olean Steel Corp., Tax No. 94.020-01-023.)

P.   400328-   Letter to Ms. Carole Petersen, Chief, NY/Caribbean
     400424    Superfund Branch II, U.S. EPA, Region II, from Ms. Libby Ford, Senior Environmental Health
Engineer, Olean Cooperating Industries SRI/FS Coordinator, Nixon, Hargrave, Devans & Doyle, re: Submittal of
various Olean SRI/FS documents, May 6, 1994.   (Attachments: 1) Letter to Ms. Libby Ford, Senior Environmental
Health Engineer, Nixon, Hargrave, Devans & Doyle, from Mr. William J. Gray, Senior Scientist/Project Manager,
Geraghty & Miller, Inc., re: Enclosed Memorandum of Remedial Action Objectives, Olean Well Field, Olean New
York, May 6, 1994, 2) Letter to Mr. Thomas Taccone, Remedial Project Manager, U.S. EPA, Region II, from
Messrs. William J. Gray, Senior Scientist/Project Manager and Andrew J. Barber, Senior Associate/Project
Officer, Geraghty & Miller, Inc., re: Olean Well Field Supplemental Feasibility Study, May 6, 1994,
(Attachment: "Proposed Schedule of Activities for the Supplemental Feasibility Study at the Olean Well Field,
Olean, New York"), 3) Report:  Comparative Analysis of Remedial Alternatives, Olean Well Field, Olean, New
York, prepared for Olean Cooperating Industries, prepared by GMCE of New York, P.C., Engineering Services,
May 1994.)

P.   400425-   Letter to Mr. Steven M Scharf, P.E., Project
     400425    Engineer, Bureau of Western Remedial Action, Division of Hazardous Waste Remediation, New York
State Department of Environmental Conservation, from Mr. Thomas Taccone, Remedial Project Manager, U.S. EPA,
Region II,  re: Olean Wellfield Superfund Site; Comparative Analysis of Remedial Alternatives, Treatability
Workplan, Other SRI/FS Submissions, May 12, 1994.

P.   400426-   Letter to Mr. Steven M. Scharf, P.E., Project
     400427    Engineer, Bureau of Western Remedial Action, Division of Hazardous Waste Remediation, New York
State Department of Environmental Conservation, from Mr. Thomas Taccone, Remedial Project Manager, U.S. EPA,
Region II,  re: Olean Wellfield Superfund Site; Letter of April 28, 1994, May 17, 1994.

P.   400428-   Letter to Mr. Thomas Taccone, Remedial Project
     400430    Manager, U.S. EPA, Region II, from Mr. Steven M. Scharf, P.E., Project Engineer, Bureau of
Western Remedial Action, Division of Hazardous Waste Remediation, New York State Department of Environmental
Conservation, re: Olean Wellfield Site; Olean C&T, Cattaraugus County Site No. 9-05-014, June 15, 1994.

P.   400431-   Letter to Ms. Libby Ford, Senior Environmental
     400439    Health Engineer, Nixon, Hargrave, Devans & Doyle, from Ms. Carole Petersen, Chief,
NY/Caribbean Superfund Branch II, U.S. EPA, Region II, re:  Olean Wellfield Superfund Site; Comments on the
Preliminary Screening and Comparative Analysis of Remedial Alternative SFS Submittals, July 1, 1994.

P.   400440-   Letter to Mr. Thomas Taccone, Remedial Project
     400447    Manager, U.S. EPA, Region II, from Messrs. William J. Gray, Senior Scientist and Andrew J.
Barber, Senior Associate, Geraghty & Miller, Inc., re: Response to USEPA Comments on the Preliminary
Screening of Remedial Alternatives and the Comparative Analysis of Remedial Alternatives, Olean Well Field
Supplemental Feasibility Study, Olean, New York, July 21, 1994.

P.   400448-   Letter to Ms. Libby Ford, Senior Environmental
     400448    Health Engineer, Nixon, Hargrave, Devans & Doyle, from Ms. Carole Petersen, Chief,
NY/Caribbean Superfund Branch II, U.S. EPA, Region II, re:  Olean Wellfield Superfund Site; Response to

-------
Comments on the Preliminary Screening and Comparative Analysis of Remedial Alternatives, August 25, 1994.

P.   400449-   Letter to Mr. Thomas Taccone, Remedial Project
     400455    Manager, U.S. EPA, Region II, from Mr. Steven M. Scharf, P.E., Project Engineer, Bureau of
Western Remedial Action, Division of Hazardous Waste Remediation, New York State, Department of Environmental
Conservation, re: Olean Wellfield Site, Olean C&T, Cattaraugus County, Site No. 9-05-014, October  19, 1994.

P.   400456-   Letter to Mr. Thomas Taccone, Remedial Project
     400457    Manager, U.S. EPA, Region II, from Ms. Libby Ford, Senior Environment Health Engineer, Olean
CI SRI/FS Coordinator, Nixon, Hargrave, Devans & Doyle, re: Olean Wellfield Supplement RI/FS Administrative
Consent Order No. II-CERCLA-10202 — Advance Reguest for Extension of the 14 Day Comment Period to Respond to
EPA's Comments on the Comparative Analysis of Remedial Alternatives Report, December 15, 1994.

P.   400458-   Letter to Ms. Libby Ford, Senior Environmental
     400468    Health Engineer, Nixon, Hargrave, Devans & Doyle, from Ms. Carole Petersen, Chief,
NY/Caribbean Superfund Branch II, U.S. EPA, Region II, re:  Olean Wellfield Superfund Site; Draft  Preliminary
Screening of Remedial Alternatives and Comparative Analysis of Remedial Alternatives, January 23,  1995.

P.   400469-   Letter to Ms. Carole Petersen, Chief, NY/Caribbean
     400485    Superfund Branch II, and Mr. Thomas Taccone, Remedial Project Manager, U.S. EPA, Region II,
from Ms. Libby Ford, Senior Environmental Health Engineer, Olean Cooperating Industries SRI/FS Coordinator,
Nixon, Hargrave, Devans & Doyle, re:  Olean Wellfield Supplemental RI/FS Working Draft Supplemental
Feasibility Study, Administrative Consent Order No. II-CERCLA-10202, March 24, 1995.  (Attachment:  Letter to
Ms. Libby Ford, Senior Environmental Health Engineer, Nixon, Hargrave, Devans & Doyle, from Ms. Carole
Petersen, NY/Caribbean Superfund Branch II, U.S. EPA, Region II, re: Olean Well Field Superfund Site; Draft
Preliminary Screening of Remedial Alternatives, January 23, 1995.)

P.   400486-   Letter to Mr. Thomas Taccone, Remedial Project
     400493    Manager, U.S. EPA, Region II, from Messrs. Brent C. O'Dell, P.E., Project Engineer/Project
Manager and Arnold S. Vernick, P.E., Associate/Project Advisor, re: Olean Well Field Draft Supplemental
Feasibility Study Insert To Appendix D.  Table 1 Table 2., March 31, 1995.   (Attachments: Table 1: "Hydraulic
Parameters Used in Capture Zone  Analysis Olean Well Field, Olean, New York", Table 2: "Capture Zone Analysis
Results, Olean Well Field, Olean, New York".)

P.   400494-   Letter to Mr. Thomas Taccone, Remedial Project
     400508    Manager, U.S. EPA, Region II, from Mr. Steven M. Scharf, P.E., Project Engineer, Bureau of
Western Remedial Action, Division of Hazardous Waste Remediation, New York State Department of Environmental
Conservation, re: Olean Wellfield Site, Olean C&T, Cattaraugus County, New York, Site No. 9-05-014, May 1,
1995. (Attachments: fact sheets, data, correspondence)

P.   400509-   Letter to Mr. Steven Scharf, P.E., Project
     400510    Engineer, New York State Department of Environmental Conservation, Bureau of Western Remedial
Action,  Division of Hazardous Waste Remediation, from Mr. Thomas Taccone, Remedial Project Manager, U.S. EPA,
Region II, re: Olean Wellfield Superfund Site; NYSDEC and NYSDOH Comments on the Draft Supplemental FS, May
11, 1995.

P.   400511-   Letter to Ms. Libby Ford, Senior Environmental
     400518    Health Engineer, Nixon, Hargrave, Devans & Doyle, from Ms. Carole Petersen, Chief,
NY/Caribbean Superfund Branch II, U.S. EPA, Region II, re:  Olean Wellfield Superfund Site; Draft  Supplement
FS Report and Pilot Test Reports for AVX and Alcas, May 12, 1995.

P.   400519-   Letter to Mr. Thomas Taccone, Remedial Project
     400535    Manager, U.S. EPA, Region II, from Messrs. Brent C. O'Dell, P.E., Engineering Task Manager and
Arnold S. Vernick, P.E., Project Advisor, Geraghty & Miller, Inc., re: Response to Comments, Olean Draft
Feasibility Study Review, May 30, 1995.

P.   400536-   Letter to Ms. Libby Ford, Senior Environmental

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     400540    Health Engineer, Nixon, Hargrave, Devans & Doyle, from Ms. Carole Petersen, Chief,
NY/Caribbean Superfund Branch II, U.S. EPA, Region II, re:  Olean Wellfield Superfund Site; Draft
Supplemental FS Report, June 29, 1995.   (Attachment: "Sample Text for the Comparative Analysis of
Alternatives by Source Area", undated)

P.   400541-   Letter to Mr. Thomas Taccone, Remedial Project
     400542    Manager, U.S. EPA, Region II, from Ms. Lani Rafferty, Environmental Health Specialist II,
Bureau of Environmental Exposure Investigation, State of New York Department of Health, re: Olean Well Field,
Olean, Cattaraugus County, Site ID #905014, July 19, 1995.

P.   400543-   Letter to Mr. Thomas Taccone, Remedial Project
     400579    Manager, U.S. EPA, Region II, from Messrs. Brent C. O'Dell, P.E., Engineering Task Manager and
Arnold S. Vernick, P.E., Project Advisor, re:  Attached Response to Comments, Olean Draft Feasibility Study
Review, July 19, 1995.

P.   400580-   Letter to Mr. Thomas Taccone, Remedial Project
     400613A   Manager, U.S. EPA, Region II, from Messrs. Brent C. O'Dell, P.E., Engineering Task Manager and
Arnold S. Vernick, Project Advisor, re:  Attached Response to Comments, Olean Draft Feasibility Study Review
- Second Submittal, July 31, 1995.

P.   400314-   Letter to  Mr. Thomas Taccone, Remedial Project
     400646    Manager, U.S. EPA, Region II, from Messrs. Brent C. O'Dell, P.E., Engineering Task Manager and
Arnold S. Vernick, P.E., Project Advisor, re:  Attached Response to Comments, Olean Draft Feasibility Study
Review - Third Submittal, August 2, 1995.

P.   400647-   Letter to Ms. Lani Rafferty, Environmental Health
     400648    Specialist II, Bureau of Environmental Exposure Investigation, State of New York Department of
Health, from Mr. Thomas Taccone, Remedial Project Manager, U.S. EPA, Region II, re: Olean Wellfield Superfund
Site; NYSDOH Comments on the PRP's SFS Comments Dated May 30, 1995, October 11, 1995.

P.   400649-   Letter to Mr. Thomas Taccone, Remedial Project
     400654    Manager, U.S. EPA, Region II, from Mr. Steven M. Scharf, P.E., Project Engineer, Bureau of
Western Remedial Action, Division of Hazardous Waste Remediation, New York State Department of Environmental
Conservation, re:  Olean Wellfield Site, Olean City  & Town, Cattaraugus County Site No. 9-05-014, October 17,
1995.  (Attachment:  1. Letter to Mr. Steven M. Scharf, Bureau of Western Remedial Action, Division of
Hazardous Waste Remediation, NYS Department of Environmental Conservation from Ms. Lani Rafferty,
Environmental Health Specialist II, Bureau of Environmental Exposure Investigation, State of New York
Department of Health re:  Olean Wellfield, Olean, Cattaraugus County, Site ID #905014, October 6, 1995, 2.
Facsimile transmission entitled "Trigger Level Discussion for Insertion", prepared by Geraghty & Miller,
Inc., September 22, 1995.)

P.   400655-   Letter to Ms. Libby Ford, Senior Environmental
     400661    Health Engineer, Nixon, Hargrave, Devans & Doyle, from Ms. Carole Petersen, Chief,
NY/Caribbean Superfund Branch II, U.S. EPA, Region II, re:  Olean Wellfield Superfund Site; Draft
Supplemental FS Report, October 19, 1995.  (Attachment: "Soil and Groundwater Treatment by Source Area",
undated.)

7.0   ENFORCEMENT

7.3  Administrative Orders

P.   700001-   Administrative Order on Consent for Supplement
     700301    Remedial Investigation/Feasibility Study, Operable Unit, No. 2, In the Matter of the Olean
Well Field Site, Alcas Cutlery Corporation, Aluminum Company of America, AVX Corporation, Cooper Industries
Inc., McGraw-Edison Company, Respondents, Index No.  II CERCLA-10202, June 25, 1991.   (Attachments:  Appendix
1. Report: Final Supplemental Remedial Investigation/Feasibility Study Work Plan, Olean Well Field Site,
Olean, New York, prepared for U.S. EPA, Region II, prepared by Ebasco Services       Incorporated, May 1989,

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Appendix 2. Report: Draft Field Operations plan (FOP) for Supplemental Remedial Investigation/Feasibility
Study, Clean Well Field Site, Clean New York, prepared for U.S. EPA, Region II, prepared by Ebasco Services
Incorporated, June 1989.)

7.7 Notice Letters and Responses - 104e's

P. 700302- Letter to Mr. Earl D. Coleman, President, Loohn's
700311 Cleaners & Launderers, Inc., from Ms. Kathleen C. Callahan, Director, Emergency and Remedial
Response Division, U.S.EPA, Region II, re: Supplemental Reguest for Information Pursuant to Section 104(e)
of CERCLA, 42 U.S.C. section 9604 (e), Clean Wellfield Superfund Site, Clean, New York, Notice of Potential
Liability under 42 U.S.C. sections 9601-9675, November 14, 1995. (Attachments: Reguest for Information
Instructions and Certification.)

8.0 HEALTH ASSESSMENTS

8.1 ATSDR Health Assessments

P. 800001- Letter to Ms. Nicki Di Forte, SCB, U.S. EPA,
800013 Region II, from Mr. William Nelson, and Ms. Denise Johnson, ATSDR Regional Representatives,
Department of Health & Human Services, re: Attached report: Health Assessment for Clean Well Field National
Priorities List (NPL) Site, Clean Cattaraugus County, New York, November 21, 1988, November 29, 1988.

P. 800014- Report: Revised Site Review and Update for Clean
800028 Well Field, Clean, Cattaraugus County, New York, Cerclis No. NYD980528657, prepared by New
York State Department of Health Under a Cooperative Agreement With U.S. Department of Health & Human
Services, Public Health Service, and Agency for Toxic Substances and Disease Registry, April 21, 1994.

P. 800029- Letter to Mr. Tom Taccone, Remedial Project
800041 Manager, U.S. EPA, Region II, from Mr. Arthur Block, Senior Regional Representative,
Department of Health and Human Services, re: Attached report: Site Review and Update (SRU) for Clean Well
Field, Clean, Cattaraugus County, NY, September 3, 1993, October 7, 1993.

8.3 Correspondence

P. 800042- Memorandum to Mr. Arthur Block, Senior Regional
800042 Representative, Department of Health and Human Services, from Ms. Carole Petersen, Chief,
NY/Caribbean Superfund Branch II, U.S. EPA, Region II, re: ATSDR Site Update for the Clean Well Field
Superfund Site, November 19, 1993.

P. 800043- Letter to Mr. Arthur Block, Senior Regional
800043 Representative, Department of Health and Human Services, from Mr. Steven M. Scharf, P.E.,
Project Engineer, New York State Department of Environmental Conservation, re: Clean Wellfield Site, Olean
C&T, Cattaraugus County, NYSDEC Site No. 9-05-014, December 29, 1993.

P. 800044- Memorandum to Mr. Arthur Block, Senior
800045 Representative, Department of Health and Human Services, from Mr. Thomas Taccone, Project
Manager, U.S. EPA, Region II, re: Olean Wellfield Superfund; Comments on ATSDR's Revised Site Update, March
23, 1994.

P. 800046- Letter to "Interested Party", from Ms. Meaghan
800046 Boice-Green, Health Liaison Program, New York State Department of Health, re: Site Review and
Update (SRU) dated April 21, 1994 for the Olean Wellfield Site, September 23, 1994.

P. 800047- Memorandum to Mr. Arthur Block, Senior
800048 Representative, Department of Health and Human Services, from Mr. Kevin Lynch, Chief,
Western/NY Section II, U.S. EPA. Region II, re: Agency Review Draft Health Consultation for the Olean
Wellfield Superfund Site, July 24, 1995.

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10.0 PUBLIC PARTICIPATION

10.3 Public Notices

P. 1000001- Public Notice announcing Public Meeting to discuss
1000013 U.S. EPA's plans to direct a Supplemental Remedial Investigation/Feasibility Study (RI/FS) at
the Olean Well Field Superfund Site, September 19, 1991. (Attachment: "Mailing List for Olean Public
Notices".)

10.6 Fact Sheets and Press Releases

P. 1000014- Fact Sheet for the Olean Well Field Site,
1000016 Cattaraugus County, New York, prepared by U.S. EPA, Region II, September 1991.

OLEAN WELLFIELD SITE
OPERABLE UNIT TWO
ADMINISTRATIVE RECORD FILE UPDATE
INDEX OF DOCUMENTS

4.0 FEASIBILITY STUDY

4.3 Feasibility Study Reports

P. 400661A- Report: Olean Well Field Superfund Site
400909 Feasibility Study Report, United States Environmental Protection Agency's Preface,
prepared by U.S. EPA, undated. NOTE: see section 4.6, letter dated July 3, 1996 for details. (Attachment:
Report: Draft - Final, Supplemental Feasibility Study, Olean Wellfield Site, Olean, New York, prepared for
Olean Cooperating Industries, prepared by Geraghty & Miller, Inc., and GM Consulting Engineers, P.C., June
1996.)

4 . 6 Correspondence

P. 400910- Letter to Ms. Libby ford, Senior Environmental
400918 Health Engineer, Nixon, Hargrave, Devans and Doyle, from Ms. Carole Petersen, Chief,
NY/Caribbean Superfund Branch II, U.S. EPA, Region II, re: Olean Well Field Superfund Site; Finalization of
the Supplemental FS, July 3, 1996. (Attachment: Olean Well Field Superfund Site Feasibility Study Report,
United States Environmental Protection Agency's Preface, prepared by U.S. EPA, undated.)

10.0 PUBLIC PARTICIPATION

10.9 Proposed Plan

P. 1000005- Superfund Proposed Plan, Olean Well Field, City of
1000038 Olean, Cattaraugus County, New York, prepared by U.S. EPA, Region II, July 3, 1996.

OLEAN WELL FIELD SITE
OPERABLE UNIT TWO
ADMINISTRATIVE RECORD FILE UPDATE TWO
INDEX OF DOCUMENTS

4.0 FEASIBILITY STUDY

4.6 Correspondence

P. 400919- Letter to Ms. Libby Ford, Senior Environmental
400920 Health Engineer, Nixon, Hargrave, Devans & Doyle, from Ms. Carole Petersen, Chief,
NY/Caribbean Superfund Branch II, U.S. EPA, Region II re: Olean Wellfield Superfund Site, Supplemental

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RI/FS; Progress Report for August 1993, October, 14, 1993.

P.   400921-   Letter to Mr. Thomas Taccone, Olean Wellfield Site
     400944    Project Coordinator, U.S. EPA, Region II, Emergency & Remedial Response Division, from Messrs.
Steven T. Devernoe, Engineer, William J. Grey, Senior/Scientist/Project Manager, and Andrew J. Barber, Senior
Associate/Project Officer, Geraghty & Miller, Inc., September 7, 1994.  (Attachments: Figures, Appendix A and
Appendix B)

P.   400945-   Letter to Ms. Libby Ford, Senior Environmental
     400966    Health Engineer, Nixon, Hargrave, Devans & Doyle, from Ms. Carole Petersen, Chief,
NY/Caribbean Superfund Branch II, U.S. EPA, Region II, re:  Olean Wellfield Superfund Site; Draft
Supplemental FS Report, May 9, 1996.   (Attachments: Attachments 1 and 2).

P.   400967-   Letter to Mr. Thomas Taccone, Olean Wellfield Site
     401001    Project Coordinator, U.S. EPA, Region II, Emergency & Remedial Response Division, from Ms.
Libby Ford, QEP, Senior Environmental Health Engineer, Olean CI SRI/FS Coordinator, Nixon, Hargrave, Devans &
Doyle, re: Olean Wellfield Supplemental RI/FS Administrative Consent Order No. II-CERCLA-10202 Comments on
EPA Imposed revisions to SFS and Notice of Issue Submitted for Dispute Resolution, July 18, 1996.
(Attachments:  Appendix A through Appendix F).

P.   401002-   Letter to Mr. Kevin Lynch, Chief, Western NY
     401005    Remediation Section, U.S. EPA, Region II, Emergency and Remedial Response Division, from Ms.
Libby Ford, QEP, Senior Environmental Health Engineer, Nixon, Hargrave, Devans & Doyle, re:  July 18, 1996
Dispute Resolution Letter - Resolution of Issue Number One, July 30, 1996.   (Attachment: Pages of Section 2.1
of the Supplemental Feasibility Study with revisions, undated.)

10.0 PUBLIC PARTICIPATION

10.1 Comments and Responses


P.   1000039-  Letter to Mr. Thomas Taccone, Olean Wellfield Site
     1000329   Project Coordinator, U.S. EPA, Region II, from Ms. Libby Ford, QEP, Olean CI Coordinator,
Senior Environmental Health Engineer, Nixon, Hargrave, Devans & Doyle, re: Comments on "Superfund Proposed
Plan - Olean Wellfield", August 5, 1996.   (Attachments: Appendix A, which contains 41 documents appended to
this letter, undated.)

P.   1000330-  Letter to Mr. Thomas Taccone, Olean Wellfield Site
     1000332   Project Coordinator, U.S. EPA, Region II, from Ms. Libby Ford, QEP, Senior Environmental
Health Engineer, Olean CI SRI/FS Coordinator, Nixon, Hargrave, Devans & Doyle, re: Additional Comments on
"Superfund Proposed Plan - Olean Wellfield", August 7, 1996.

P.   1000333-  Letter to Mr. Thomas Taccone, Remedial Project
     1000333   Manager, U.S. EPA, Region II, from Mr. John Mitchell, Supervisor, Town of Olean, re: Olean
Wellfield Superfund Site, August 23, 1996.

P.   1000334-  Letter to Mr. Thomas Taccone, Remedial Project
     1000335   Manager, U.S. EPA, Region II, from Mr. Stewart C. Hill, re: Olean Wellfield, August 23, 1996.

P.   1000336-  Letter to Mr. Thomas E. Taccone, Remedial Project
     1000337   Manager, Emergency & Remedial Response Division, U.S. EPA, Region II, from Mr. Wayne D.
Mizerak, Environmental Engineer I, Division of Environmental Remediation, New York State Department of
Environmental Conservation, re: NYDECs response to comments 9 and 10 of the August 5, 1996 letter from Ms.
Libby Ford, August 27, 1996.

10.4 Public Meeting Transcripts

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P.    1000338-  Transcripts: "Public Meeting Transcript for the
     1000389   Olean Well Field Site, Proposed Remedial Action Plan", Olean, New York, July 16, 1996.

10.10 Correspondence


P.    1000390-  List of Attendees at the Olean Well Field Public
     1000393   Meeting, Olean Municipal Building, Olean, New York, held on July 16, 1996.

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APPENDIX IV

STATE LETTER OF CONCURRENCE

NEW YORK STATE DEPARTMENT OF ENVIRONMENTAL CONSERVATION
50 Wolf Road, Albany, New York 12233-7010

Mr. Richard L. Caspe Sep 27 1996
Director
Emergency & Remedial Response Division
U.S. Environmental Protection Agency
Region II
290 Broadway - 19th floor
New York, New York 10007

Dear Mr. Caspe:

Re: Olean Wellfield Site, Olean C&T, Cattaraugus County, New York, Site No. 9-05-014

The Operable Unit 2 (OU2) Record of Decision (ROD) for the Olean Wellfield site has been reviewed by the New
York State Department of Environmental Conservation (NYSDEC) and the New York State Department of Health
(NYSDOH). The OU2 ROD concerns the Supplemental Source Study Remedial Investigation and Feasibility Study.
Four source areas will reguire remediation under the U.S. Environmental Protection Agency's (USEPA)
jurisdiction. These four areas are McGraw-Edison, Alcas Cutlery, AVX and Loohn's Dry Cleaners and
Launderers.

The NYSDEC and the NYSDOH concur with the selected remedies listed in the Olean Wellfield OU2 ROD. This
includes Vacuum Enhanced Recovery (VER) for Alcas Cutlery and Loohn's Dry Cleaners and Launderers, soil
excavation at AVX and groundwater pump-and-treat at McGraw-Edison. In addition, AVX and Loohn's Dry Cleaners
and Launderers contain a Stage 2 component for groundwater pump-and-treat if future evaluation proves this
necessary.

If you have any guestions, please contact Mr. Robert W. Schick, P.E., of my staff, at 518/457-4343.

Sincerely,

cc: Commissioner Zagata
K. Lynch (USEPA)
T. Taccone (USEPA)
A. Carlson/L. Rafferty (NYSDOH)

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APPENDIX V

RESPONSIVENESS SUMMARY

APPENDIX V
RESPONSIVENESS SUMMARY
OLEAN WELL FIELD 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 the
NYSDEC's final decision for selection of a remedial alternative for the Clean Well Field site.

SUMMARY OF COMMUNITY RELATIONS ACTIVITIES

EPA's public meeting for the Record of Decision for the first operable unit was held on March 29, 1988.  The
major concern of the community then was on the potential economic impact of EPA's selected remedies on the
companies, which were deemed responsible for the groundwater contamination at the Site.  The local community
were concerned that jobs could be lost; while the City was concerned with the loss of tax revenue, which
would result from job loss.

The supplemental RI/FS report and the Proposed Plan for the second operable unit were made available to the
public in the administrative record file at the EPA Docket Room in Region II, in New York City and the
information repository at the Clean Public Library, located in the City of Clean, New York.  The public
comment period for these documents was held from July 9, 1996 to August 26, 1996.

On July 16, 1996, EPA conducted a public meeting at the Clean municipal building in order to present its
Proposed Plan for the second operable unit for remediating four areas of Site contamination.  Most of th
guestions and comments raised during the meeting and in written comments received by EPA during the public
comment period focused on technical implementation of the remedy for the first operable unit and the remedies
described in EPA's Proposed Plan for the second operable Unit.  No objections were voiced at the meeting or
in any of the written comments on the proposed remedies.

Attached to the Responsiveness Summary are the following
Appendices:
Appendix A - Proposed Plan
Appendix B - Public Notices
Appendix C - July 16, 1996 Public Meeting Attendance Sheets
Appendix D - July 16, 1996 Public Meeting Transcript
Appendix E - Letters Submitted During the Public Comment Period

SUMMARY OF COMMENTS AND RESPONSES

Comments expressed during the July 16, 1996, public meeting and written comments received during the public
comment period, have been categorized as follows:

!       Proposed Plan
!       Other Potential Sources of Site Contamination
!       EPA's July 3,  1996,  Preface to the supplemental FS
!       Content of the Administrative Record File Index
!       Remedies Specified Under the September 24, 1985, Record of Decision

A summary of the comments and EPA's Responses to the comments is provided below.

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Many of the comments which follow were submitted by Ms. Libby Ford, who represented the owners and operators
of the AVX facility, Alcas Cutlery facility, and the McGraw Edison facility. This group of owners and
operators is collectively referred to below as the potentially responsible parties or PRPs.

A. The Proposed Plan

PRP Comment #1: Page 2 - There is no mention of the inspection and repair of the McGraw Edison Sewer, which
was an important part of the first operable unit remedy.

EPA's Response: Mention of repair and inspection of the McGraw Edison sewer which was an important part of
the remedies selected for the first operable unit can be found on page 3 of the Proposed Plan.

PRP Comment #2: Page 3 - There is no mention of an upper aguifer at AVX.

EPA's Response: EPA has made this correction in the Record of Decision.

PRP Comment #3: Page 5 - The discussion of soil gas and analytical results of soil and groundwater sampling
incorrectly indicated that 53 ppb of trichloroethene (TCE) was detected in the soil at soil boring 05. The
correct concentration is 29 ppb.

EPA's Response: EPA has made this correction in the ROD.

PRP Comment #4: Page 7 - The forth paragraph of the section entitled "Faye Avenue/Schaefer Street" contains
statements which relate to the investigatory work which was performed at the Griffith Oil property.

EPA's Response: EPA has removed these statements from the section on the Faye Avenue/Schaefer Street
discussion in the ROD.

PRP Comments #5: Pages 9 and 29 - The PRPs disagreed with EPA's decision to expand the list of contaminants
specified in the Site Monitoring Plan (SMP) to include a full volatile organic compound (VOC) scan and
chromium. The additional compounds which are being reguested for analysis were not detected at levels of
concern. These additional compounds also have not been tied to any of the four identified source areas.

EPA's Response: EPA disagrees that none of the additional contaminants, which the Proposed Plan specified
for inclusion in the SMP, were detected at levels which are above levels of concern. Other volatiles, which
are not currently being tested for under SMP, but which would be included in a full VOC scan, have been
detected in the soils at concentrations which are above the Site soil clean up objectives. At AVX, toluene,
ethylbenzene and xylenes, were detected in the soils at 16,000 ppb, 4,000 ppb and 73,000 ppb, respectively.
Xylene was also detected in the groundwater at 3,900 ppb. At Loohn's, 2-butanone was detected at 5,400 ppb
and 43,000 in two separate soil borings.

The remedies selected for AVX and Loohn's Dry Cleaners will reguire groundwater monitoring to determine
whether groundwater remediation will be necessary after the contamination soil has been remediated. It will
be necessary to test the groundwater for each of the VOC contaminants which are present in the soil above the
soil cleanup levels. Therefore, EPA believes that the SMP should be revised to specify a full VOC scan.

Chromium was detected in monitoring wells CW-12 and CW-12A at 22.5 ppm, and 1.75 ppm, respectively. These
concentrations are above the MCL of 50 ppb and were detected in wells which are close to municipal wells 18M.
Chromium at levels below MCLs has been detected in the recent samples of the influent groundwater to
Municipal wells 18M and 37/38M collected by the City of Olean. Therefore, EPA believes that the SMP should
be revised to include chromium.

PRP Comment #6: Page 9 - A Stage IB Cultural Resource Survey (CRS), which would involve field investigation,
is not necessary at the ALCAS property since the survey would have little substantial impact on the design of
a VER system at Alcas.

EPA's Response: EPA is retaining the reguirement for a Stage IB CRS for both the Loohn's Dry Cleaners and

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Alcas properties. EPA believes that further investigation is needed, since the properties are located close
to the Allegheny River. This proximity makes the potential for encountering cultural artifacts high.
Therefore, a Stage IB CRS will need to be performed.

PRP Comment #7: Page 10 - The proposed Plan should specifically state that there are two separate exposure
pathways. The section entitled "Human Health Risk Assessment" in the document did not recognize that safe
water from the City public water supply line is available to the on-Site residents, and that those who are
consuming untreated groundwater are doing so by their own free choice.

EPA's Response: EPA agrees that there are two separate exposure pathways. This clarification has been made
in the ROD's discussion of risks.

PRP Comment #8: Page 11 - The Remedial Action Objectives (RAOs), as stated in the document, were not the
final RAOs for the SRI/FS.

EPA's Response: In general, the RAOs in the Proposed Plan did reflect the RAOs as stated in the supplemental
RI/FS. The discussion of RAOs in the ROD has been written to be more consistent with the Supplemental FS.

PRP Comment #9: Page 12, Table 1 - There is no New York State Technical and Administrative Guidance
Memorandum (TAGM) soil cleanup number for cis-1,2 dichloroethene (1,2-DCE). The soil cleanup number, which
is in the table for 1,2-DCE, is actually the number for trans-1,2 DCE. The fourth column of Table 1 should
be corrected to indicate the values lists are State groundwater and drinking water standards. The basis and
need for including 2-butanone, benzene, ethyl benzene, toluene and vinyl chloride should be stated, since
they are not in included in Table 2-1 of the supplemental FS.

EPA's Response: The cleanup number for cis-l,2-DCE, which was provided in Table 1 of the Proposed Plan, is
incorrect, and there is no specific soil cleanup number for cis-1,2 DCE in the NYSDEC's TAGM guidance.
However, the guidance either provides a specific soil cleanup number or provides a method for calculating a
number. Using the method, a soil cleanup number of 250 ppb has been established for cis-l,2-DCE. The number
is referenced in Table 1 of the ROD.

Regarding the column heading for the fourth column of Table 1 in the Proposed Plan, EPA has clarified the
table as it appears in the ROD. the heading now reads "New York Water Quality Standards." The heading also
has a footnote, which states, "The values listed are the more stringent of New York State's drinking water
and groundwater standards."

The compounds: 2-butanone, ethyl benzene, toluene and vinyl chloride all have been found in the soil on-Site
at levels above the NYSDEC's soil cleanup objectives. These compounds are Site-related and therefore must be
removed from the soil to the extent they are above the Site cleanup numbers.

PRP Comment #10: Page 12, Table 1 - The NYSDEC MCL for benzene should be 5 ppb, not 0.7 ppb. The fourth
column of Table 1 should be re-titled, "New York State Groundwater Standards."

EPA's Response: The state MCL for benzene is 5 ppb. However, the New York State Groundwater standard for
benzene is 0.7 ppb. Regarding the fourth column heading of Table 1 of the Proposed Plan, EPA revised the
table, which was included in the ROD as Table 1. The revised heading now reads, "New York State Water
Quality Standards." The table has also been footnoted to indicate that values listed are the more stringent
of the State drinking water or groundwater standards.

PRP Comment #11: Page 13 - An evaluation of the effect of a groundwater pump and treat system on the
wetlands areas, which is located south of the AVX facility, is unnecessary. The groundwater at AVX has been
pumped for 40 years without any detrimental effects on the wetlands.

EPA's Response: While there have been no observable effects on the wetlands area, if a groundwater pump and
treat system were installed at AVX, the location and pumping rate of the system would most likely be
different than the location and pumping rate of the present system, which was designed to provide a source of
water for the AVX plant operations. Therefore, some assessment of the potential impact of a groundwater pump

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and treat system on the wetlands areas is necessary.

PRP Comment #12: Page 13 - The 4-year review for determining whether a groundwater pump and treat is
necessary at the AVX and Loohn's Dry Cleaners properties should be combined with the CERCLA 5-year review.

EPA's Response: Past EPA correspondence on this matter may be found in the EPA's Administrative Record for
this Record of Decision (See Appendix III). Essentially, EPA believes that the 4-year review for the
remedies and the CERCLA 5-year review should not be combined, since the objective of each review is
different. The 4-year review is to determine if a specific portion of the remedial action, i.e., the source
control action at AVX or Loohn's, has been effective and if there is a need for the groundwater
pump-and-treat stage of the remedy. The four year period represents the amount of time for three volumes of
groundwater to travel or flush from the properties to the municipal wells. On the other hand, the 5-year
review is required by Section 121(c) of CERCLA whenever a remedial action results in contamination being left
on site above health-based levels to determine whether all of the remedial actions implemented at the Site
continue to be protective.

PRP Comment #13: Pages 16-28 - A previous draft of the Comparative Analysis of Remedial Alternatives section
of the supplemental FS was adequate and the commentors objected to EPA's written comments on previous drafts
of the Supplemental FS, which indicated that the section required further revisions.

EPA's Response: EPA's position on this matter is stated in its written comments on drafts of the
supplemental FS. EPA's comments may be found in the Administrative Record (See Appendix III). In summary,
EPA believed that the information provided in the draft Supplemental FS was not correctly organized and
therefore could not be used to form a basis of decision for remedy selection.

PRP Comment #14: Page 14 - Granular activated carbon (GAG) may or may not be adequate to treat the VOC
emissions from a Vacuum Enhanced Recovery (VER) or Soil Vapor Extraction System (SVE). A thermal oxidation
system may be more appropriate for vapor streams which have VOC concentrations, which are too high to treat
economically with GAG. Also, the groundwater which will be discharged from VER system may also be treated
more economically with an air stripper than GAG.

EPA's Response: EPA agrees with these comments and has included these comments in the ROD's description of
Alternative 4.

PRP comment #15: Page 17, paragraph 5 - The PRPs disagreed with the Proposed Plan's statement that
Alternative 5 (excavation) can achieve ARARs faster that Alternative 4 (VER or SVE) for the Alcas source
area.

EPA's Response: The Proposed Plan and the supplemental FS indicate that it would take approximately the same
amount of time to completely excavate all of the contaminated soil as it would to construct a VER system.
After this time period, complete remediation (excavation) of the soil under Alternative 5 would be
accomplished and soil cleanup goals would be met. Alternative 4, however, would require another 3 to 5 years
before the VOC's were removed to levels that would meet cleanup goals.

PRP Comment #16: Table 2 - The footnotes to Table 2 did not include all of the information which was
included in the footnotes in Table 4-1 of the supplemental FS.

EPA's Response: EPA reviewed Table 2 and found that footnote 4 did not state that the cost for implementing
Alternative 3A at McGraw Edison included the costs for operating and maintaining the existing air stripper,
which is currently treating groundwater from the lower aquifer, and the additional costs necessary for
pumping and treating water from the upper aquifer. EPA has made this correction in the ROD.

Comment #17: What happens to the vapors which would be generated by a vacuum enhanced recovery (VER) system?

EPA's Response: The vapors which would be emitted from a VER system would be treated to meet air emission
standards before they are released to the ambient air. Treatment could consist of a thermal oxidation
system, or, for lower concentrations, adsorption using granulated activated carbon.

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Comment #18: Will the companies which signed the 1991 administrative consent order pay EPA's past and future
supplemental RI/FS costs?

EPA's Response: Pursuant to a 1989 Consent Decree, the companies which signed the 1991 order paid th United
States $1,175,000 (with a $145,000 credit) for past costs through August 1989. In a November 1992 settlement
with the bankruptcy estate of W.R. Case, another for the Site, EPA received $650,000.00 for pat and future
response costs and $50,000 as a civil penalty for noncompliance with a 1986 Administrative Order. The
parties who signed the 1991 Order paid approximately $127,000 to reimburse EPA for costs incurred by the
government to prepare the work plans for the supplemental RI/FS. Additionally, the parties who signed the
1991 Order agreed, in that Order, to pay EPA's costs in overseeing the supplemental RI/FS. EPA will prepare
a bill in the near future, reguesting payment of its oversight costs. EPA and the PRPs will negotiate the
issue of EPA's future costs for the Site during negotiations regarding performance of the OU2 remedial
design/remedial action (see also response to comment 20).

Comment #19: How much time it will take to implement the remedies at the source area properties.

EPA's Response: After the design work is completed, EPA expects that is will take approximately one
construction season to excavate all of the soil at AVX, and approximately five years to complete the soil
treatment at Alcas and Loohn's. EPA expects that it will take approximately four additional years for the
groundwater underlying these properties to be below drinking water standards. The four-year period
represents the amount of time for three volumes of groundwater to travel or flush from the properties to the
municipal wells.

Regarding the groundwater remedies, EPA does not have a precise estimate for the time it will take to
remediate groundwater from the upper aguifer. For cost-estimation purposes, EPA used an estimate of thirty
years.

Comment #20: What is the time frame for negotiations with the PRPs before implementing the remedy?

EPA's Response: After the ROD is issued, EPA will send a "special notice letter" to the PRPs offering them
the opportunity to either perform the remedy themselves or finance the remedy. EPA and the PRPs will have no
less than 120 days to negotiate an agreement. If the parties have not reached an agreement by the conclusion
of the 120 day period, EPA could either issue a unilateral administrative order reguiring the PRPs to perform
the work, or perform the work itself and seek reimbursement at a later date. Work on the remedial design
will not begin until after the expiration of the 120 day negotiation period.

B. Other Potential Sources of Contamination on-Site

Comment #21: Why was not the Clean Municipal Landfill, which is located south of Seneca Avenue and north of
the Conrail Railroad tracks, included in the supplemental RI/FS investigation.

EPA's Response: The Clean Municipal Landfill, also known as the Seneca Landfill, was not included in the
supplemental RI/FS since during the previous RI/FS several wells down gradient from the landfill did not
indicate the presence of contamination from the landfill.

Comment #22: Many of the private wells in the area had levels of TCE of approximately 2 ppb, which was
"half-way to the maximum concentration allowable of 5 ppb." Will the wells which are located in the area of
Seneca Avenue will be retested?

EPA's Response: EPA's September 24, 1985, Record of Decision for the Site stated that the private wells near
Seneca Avenue should be monitored and that carbon adsorption units be placed on the wells as needed.
Analyses of groundwater from selected private wells located in this area in 1994 and 1995 have not shown the
presence of organic contaminants at or above state or federal maximum contaminant levels (MCLs) for drinking
water. EPA has asked Cooper Industries, one of the PRPs, to continue to monitor three wells, which are
spaced as widely as possible. However, since the this area is upgradient from the sources of contamination
to the Clean Well Field, we would not expect to see Site contamination migrating to those wells.

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Comment #23: The Town Supervisor of the Town of Clean stated that "In January 1996, after a flooding
episode, "the basement walls of several homes near East River Road appeared to be "cleaned" by a "cleaning
solvent."

EPA's Response: EPA does not consider this incident related to the contamination which has been detected at
the Site. EPA contacted the Town Supervisor and was told that the subject homes were located on the south
side of the Allegheny River across from the Alcas facility. No samples were collected during the incident.
However, there were no solvent odors evident during the event. EPA has also reviewed the data collected for
the Site Monitoring Plan and the Supplemental RI report. EPA believes that any contamination from the Alcas
facility, which wold be the closest source to the subject homes would be captured by municipal well 18M and
therefore could not travel to these homes. In addition, the influent groundwater from the lower aguifer
to the municipal wells 37/38M, which are located close to the homes, did not indicate any increase in
the concentration of contaminants during December 1995 and February 1996.

C. EPA's July 3, 1996 Preface to the supplemental FS

The Supplemental FS report submitted by the PRPs on June 17, 1996 did not accurately reflect the comments RPA
made on previous drafts. Therefore, EPA amended the report with a Preface to provide the Agency's position
on a number of issues.

The PRPs for the Site raised five major issues regarding EPA's July 3, 1996, Preface which finalized the
supplemental FS (SFS). These issues and EPA's response to them are provided below. EPA agrees that some
revision of EPA's Preface are appropriate.

PRP Comment 24: The Preface should not modify the Remedial Action Objectives which are contained in Section
2.1 of the SFS.

EPA's Response: The Supplemental FS submitted by the PRPs had added additional conditions to the Remedial
Action Objectives to the 1989 Supplemental RI/FS workplan. EPA's SFS Preface deleted the last sentence and
the guote from the SRI/FS report. However, EPA now believes that the statement and guote should include the
following language which was originally included in the SRI/FS workplan.

The Amended SRI Work Plan (Ebasco Services, Inc. 1989) also sets forth the following decision criteria:

"Thus, the Supplemental RI/FS Report will recommend that source control be performed at one or more
locations if it is determine that an action, consistent with the National Contingency Plan (NCP), will
expedite treatment of the well field aguifer or mitigate unacceptable risks" (Ebasco Services, Inc.
1989).

The third bullet on page 2-2 and the first bullet on page 2-3, which state two Remedial Action Objectives of
the SFS, should be stated as follows:

! Page 2-2, third bullet - "Restore soils at one or more locations to meet New York State soil cleanup
guidelines (NYSDEC TAGM HWR-94-4046) for concentrations of TCE, 1,1,1-TCA, cis-l,2-DCE, and other
site-related contaminants if such restoration will expedite the treatment of the contaminated
aguifer."

! Page 2-3, first bullet - "Provide additional localized groundwater treatment for TCE, 1,1,1-TCA,
cis-l,2-DCE, and other site-related contaminants at one or more locations if it will expedite the
treatment of the aguifer.

PRP Comment #25: The SFS should include a factual discussion of the past performance of the groundwater
pumping well at the AVX property. A pumping well at AVX should be mentioned since it has, in effect, been
treating the aguifer for the past 40 years.

EPA's Response: The well is a production well that was not designed for the purpose of treating the aguifer.
Therefore, EPA believes the inclusion, in the supplemental FS, of a discussion regarding the success or

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failure of its ability to cleanup the aquifer can be confusing or misleading.

EPA is, however, agreeable to including the statements, which point out the uncertainties of achieving
aguifer restoration through a groundwater pump and treat system.  EPA does maintain its position that a pump
and treat system, if necessary, would be an effective means of contaminant at AVX and therefore restorative
of the groundwater which is downgradient from the system.  The following phrases, which were deleted from the
SFS by the Preface, should remain in the SFS:

!       Section 3.4.3.3,   Page 3-35,  at the end of the second full paragraph - "While groundwater pumping from
       the City aguifer would be possible at the AVX property,  the greater than 15 years of active pumping at
       the site in relatively close proximity to the identified source area has not caused significant
       concentration reduction in the groundwater.  These observations are consistent with the nature of the
       dense till found in the source area."

PRP Comment #26:  The criteria which will be used to determine whether or not groundwater pump-and-treat will
be necessary for remedial alternatives 3, 4 and 5 must be tied to the completion of stage 1  (soil
remediation) at the identified source areas.

EPA's Response:  This issue relates to the criteria which EPA will use for determining whether groundwater
pump and treat will be necessary at the Loohn's Dry Cleaners and AVX properties.  The PRP's felt the
statement in the preface could be interpreted differently than EPA intended, i.e., as stated in the Proposed
Plan.  EPA agrees that the following language should remain in the SFS:
!       Page 4-17, The fifth and sixth sentences of the first full paragraph on page 4-17 "Four years after
       the completion of the soil remediation (Stage 1) at all the source areas, influent groundwater to
       Municipal Wells 18M and 37/38M will be analyzed to determine if groundwater treatment (Stage 2)  will
       be necessary.  In deciding whether to initiate the Stage 2 remedy,  the general decision criteria set
       out in Section 3.4.1.3 would be applied."

!       The bottom of page 4-17 and the top of page 4-18 "Four years after the completion of the soil
       remediation  (Stage 1)  at all the source areas,  the first evaluation of the effectiveness of the Stage
       1 remedy and the need for initiating the Stage 2 remedy would be evaluated.  In deciding whether to
       initiate the Stage 2 remedy,  the general decision criteria set out in Section 3.4.1.3 would be
       applied."

!       Page 4-33, The fifth and sixth sentences of the first full paragraph on page 4-33 "Four years after
       the completion of the soil remediation (Stage 1) at all the source areas, influent groundwater to the
       Municipal Wells 18M and 37/38M will be analyzed to determine if groundwater treatment (Stage 2)  will
       be necessary.  In deciding whether to initiate the Stage 2 remedy,  the general decision criteria set
       out in  Section 3.4.1.3 would be applied."

!       The first three full sentences on top of page 4-34 "Upon completion of either of these alternatives,
       the RAOs for the Site should be achieved.  Four years after the completion of the soil remediation
       (Stage 1) at all the source areas, the evaluation of the effectiveness of the Stage 1 remedy and the
       need for initiating the Stage 2 remedy would be evaluated.  In deciding whether to initiate the Stage
       2 remedy, the general decision criteria set out in Section 3.4.1.3 would be applied."

PRP Comment 27:  The meaning of the term "influent" in the SFS Preface needs to be clarified.

EPA's Response:  This issue concerned EPA's interpretation of the term "influent groundwater" as it is used
in Sections 3.2.3, 3.2.4, 3.2.5, 3.4.1.3, 3.4.1.5, and 3.4.1.6.  These include sections of the SFS, which are
entitled, "Summary of Remedial Action Alternatives for Soils," "Detailed Analysis of the Remedial
Alternatives" and "Comparative Analysis of Remedial Alternatives."  The commentors were concerned that EPA
interpreted "influent groundwater" to mean some distance away from the municipal wells 18M and 37/38M.
However, EPA interprets "influent groundwater" to mean the groundwater at the municipal wells.

PRP Comment #28:  Correction of the total cost for implementing remedial alternative 3A as listed on Table
C-l in Appendix C of the SFS is necessary.

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EPA's Response: The SFS Preface revised the total cost for operation and maintenance for remedial
alternative 3A from $114,000 to $171,000. However, the SFS Preface did not also revise the grand total for
alternative 3A.

The modified figure of $171,000 includes the funding necessary for operation and maintenance of groundwater
pump and treat systems at AVX, Loohn's Dry Cleaners and McGraw-Edison. (The SFS assumed that $57,000 would
be reguired for each system.) The $114,000 did not include the costs for a system at McGraw Edison. If the
revised total O&M costs of $171,000 is added to the $42,000 for Site-wide monitoring, the grand total for
implementing remedial alternative 3A is $213,000.

Despite the failure of the SFS Preface to adjust the final cost for alternative 3A, EPA did not cit the costs
in Appendix C for its selection of Site remedies. Instead, EPA used Table 4-1 of the SFS. Table 4-1 was
more appropriate for remedy selection costing, since it provided the costs for implementing the remedies by
source area.

D. Content of the Administrative Record File Index

PRP Comment #29: In an August 5, 1996 letter, Ms. Libby reguested that 41 additional documents be added to
the Administrative Record for this ROD.

EPA's Response: Ms. Ford's letter has been included in Appendix E of this Responsiveness Summary. EPA has
reviewed each of the documents and has determined that the documents were either not used in selecting the
remedies, which are stated in this ROD, or were already included in the Administrative Record. EPA's
determinations for the documents, which are numbered below as they are in Appendix A of Ms. Ford's letter,
are as follows:

Documents Numbered 1-15, 17-21, 24, 25, 27-36 and 40: EPA did not rely on these documents in order to
select the remedies, which are stated in this Record of Decision.

Documents Numbered 16, 22, 23, 26, 37, 38, 39 and 41: All of these documents have already been
included in the Administrative Record.

E. Remedies Specified Under the September 24, 1985, Record of Decision

Comment #30: What effects have the air strippers, which were installed to treat the groundwater from the
municipal wells 18M and M37/38M, had on the groundwater guality?

EPA's Response: Since the air strippers began treating the groundwater, the concentration of TCE in the
untreated influent groundwater water to the municipal wells has declined from over 200 ppb to approximately
20 ppb. After treatment there has not been any TCE detected in the drinking water.

Comment #31: What is the average volume of water which is pumped from the municipal wells. Could the
municipal wells "dry out" other nearby wells by lowering the water column below the well screens, if the well
pumps were operated at their full potential?

EPA's Response: According to the supplemental RI report, the combined pumping rate for wells 18M and M37/38M
is approximately 2150 gallons per minute (gpm) or 3.096 million gallons per day. EPA recently contacted the
City of Clean Department of Works and was informed that the combined pumping rate for the wells is currently
2,900 g.p.m. or approximately 4.17 MGD.

The City of Clean's water supply consists of groundwater which is pumped from the municipal wells and surface
water from Haskell Creek. As indicated above, the City has increased the pumping rate of the municipal wells
almost 35 percent and has no evidence that this increase has had any effect on the nearby wells. The City
has also indicated that it would meet any increase in water demand by increasing the amount of water it gets
from Haskell Creek. EPA believes that it is highly unlikely that the nearby wells would "dry out" from the
pumping of the municipal wells.

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Comment #32:   Were there any on-Site private well users who refused to be hooked up into the City water
supply line and have there been any effects to encourage the users to hook up?

EPA's Response:  Approximately eight private well users have declined to hook up into the Clean public water
supply system.  The users made this decision despite being contacted by the New York State Department of
Health and several offers from the PRPs to finance the connection to the public water system.

Comment #33:   Have the private wells, which are operated by the users who refused to hook up to the City
water supply system, been tested to determine if there is any contamination?

EPA's Response:  The New York State Department of Health indicated at the public meeting on July 16,  1996,
that the wells were last tested in September 1995.

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APPENDIX V

RESPONSIVENESS SUMMARY

APPENDIX A

PROPOSED PLAN



PURPOSE OF PROPOSED PLAN

This Proposed Plan describes the remedial alternatives considered for addressing contaminated soil and
groundwater associated with the Clean Well Field Superfund Site and identifies the preferred remedial
alternatives with the rationale for this preference.  This Proposed Plan was developed by the U.S.
Environmental Protection Agency (EPA) with support from the New York State Department of Environmental
Conservation  (NYSDEC).   The EPA is issuing this Plan as part of its public participation responsibilities
under Section 117(a) of the Comprehensive Environmental Response, Compensation, and Liability Act  (CERCLA),
42 U.S.C §§ 9601 - 9675, as amended, and 40 CFR 300.430(f) of the National Contingency Plan  (NCP).  The
alternatives summarized here are described in the Supplemental Remedial Investigation and Feasibility Study
(SRI/FS) report, which should be consulted for a more detailed description of all the alternatives.  As part
of the Administrative Record for the Site, the SRI/FS Report can be found in the public repositories listed
on page 2.

This Proposed Plan is being provided as a supplement to the SRI/FS report to inform the public of EPA's and
the NYSDEC's preferred remedies and to solicit public comments pertaining to all the remedial alternatives
evaluated,  as well as the preferred alternatives.

The remedies described in this Proposed Plan are the preferred remedies for the Site.  Changes to the
preferred remedies or a change from the preferred remedies to other remedies may be made, if public comments
or additional data indicate that such a change will result in a more appropriate remedial action.  The final
decision regarding the selected remedies will be made after EPA has taken into consideration all public
comments.  We are soliciting public comment on all of the alternatives considered in the detailed analysis of
the SRI/FS because EPA and the NYSDEC may select one or more remedies which are different than the preferred
remedies.

COMMUNITY ROLE IN SELECTION PROCESS

EPA and the NYSDEC rely on public input to ensure that the concerns of the community are considered in
selecting an effective remedy for each Superfund site.  To this end, the SRI/FS report Proposed Plan, and
supporting documentation have been made available to the public comment period which begins on July 9, 1996
and concludes on August 8, 1996.

A public meeting will be held during the public comment period at the Clean Municipal Building on July 16,
1996 at 7:00 pm to present the conclusions of the SRI/FS, to elaborate further on the reasons for
recommending the preferred remedial alternative, and to receive public comments.

Comments received at the public meeting, as well as written comments, will be documented in the
Responsiveness Summary Section of the Record of Decision  (ROD), the document which formalizes the selection
of the remedy.

All written comments should be addressed to:

Thomas Taccone
Project Manager
Olean Well Field Superfund Site
NY/Caribbean Superfund Branch II

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20th Floor
290 Broadway
New York, New York 10007-1866

Copies of the SRI/FS report, Proposed Plan, and supporting documentation are available at the following
repositories:

Olean Public Library, located at Second and Laurens Streets, Olean, N.Y. 14760; telephone (716) 372-0200;
hours Mon.- Thurs. 9:00 am - 9:00 pm and Fri-Sat. 9:00 am - 5:00 pm.

-and-

U.S. Environmental Protection Agency, Superfund Records Center; located at 290 Broadway, New York, New York
10007-1866; telephone (212) 637-3261; hours: Mon. -Fri. 9:00 am-5:00 pm.

SCOPE AND ROLE OF ACTION

From 1991 to 1995, a supplemental remedial investigation/feasibility study (SRI/FS) of the Olean Well Field
Superfund Site (the "Site") was conducted to identify sources of volatile organic compounds (VOCs) in the
soil at 13 properties on Site and to determine the effect of the contamination on the groundwater.
Information collected on soil and groundwater contamination at the properties was used to select: and
recommend alternatives to clean up the identified sources of contamination.

The remedies discussed in this Proposed Plan will constitute the second of two operable units (or phases) for
the Site. The first operable unit involved the construction of two air strippers which are treating VOCs
contaminated groundwater and the extension of the City of Olean public water supply line into the Towns of
Olean and Portville. The contaminated groundwater is pumped from two municipal wells. The treated
groundwater is pumped into the City and Town of Olean public water supply system.

The second operable unit will address remediation of contaminant sources of VOCs in the soil and the
groundwater. Contaminated groundwater is the principal threat posed by the Site.

SITE BACKGROUND

The Olean Well Field is located in the eastern portion of the City of Olean and east and south of the City in
the Towns of Olean and Portville in Cattaraugus County, New York. The Site is roughly rectangular in shape
and encompasses approximately 800 acres (see Figure 1). The Site is approximately 65 miles southeast of
Buffalo, New York and 7 miles north of the New York/Pennsylvania border. State Routes 16 and 417 provide
access to the area.

Three municipal water supply wells (18M, 37M and 38M) were constructed in the mid-to late 1970s to provide
water for the City of Olean, New York. The supply wells draw water from the lower aquifer also known as the
City Aguifer. Prior to the construction of these municipal wells, city water was supplied by a surface-water
treatment facility, which draws water from the Olean Creek. In January 1981, trichloroethane (TCE) and other
chlorinated organic solvents were detected in the Olean water supply. The municipal wells were shut down at
this time as TCE levels exceeded acceptable drinking water standards set by the New York State Department of
Health (NYSDOH). Surface-water treatment facility operations were reactivated.

On October 23, 1981, the EPA Region II Field Investigator Team ("FIT") evaluated the Site for inclusion of
the Nations Priorities List. As a result of this evaluation, the Site was included in the National Interim
Priorities List, published on October 23, 1981, and was included on the first official Superfund National
Priorities List ("NPL"), published on September 9, 1983. In November 1981, an EPA consultant initiated a
preliminary hydrogeologic investigation at the Site (also referred to as the "Remedial Action Master Plan" or
"RAMP"). This investigation, completed in October 1982, included, among other things, the installation of
monitoring wells and sampling of those wells, and an aguifer pump test utilizing municipal wells 18M and 37M.

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Following the discovery by the Cattaraugus County Department of Health and the NYSDOH that a number of
private wells in the City and Town of Clean, all of which received groundwater from the upper aguifer, were
also contaminated with TCE, EPA performed an initial removal action in January 1982.  This action involved
the installation of carbon adsorption filters on 16 contaminated private wells in the City and Town of Clean
and periodic monitoring of those wells.  EPA ultimately conducted two additional removal actions at the Site.
The first of these commenced in June 1984 and included the replacement of one of the carbon filters installed
for the initial removal action, installation of carbon units on ten additional contaminated private wells,
and monitoring.  The second additional removal action was implemented in March 1985 and involved the
installation of two additional carbon filter systems.

EPA conducted additional studies including a 1983 FIT study, which involved installation of two wells
up-gradient of the McGraw-Edison facility, a potentially responsible party (PRP) for the Site, and a 1985 FIT
study including an aguifer pump test and further sampling at the municipal wells.

A Remedial Investigation/Feasibility Study  ("RI/FS") was performed in 1984-85 by a contractor to the New York
State Department of Environmental Conservation ("NYSDEC").  During the course of the RI/FS, it became
apparent that a plume of TCE was threatening a number of private wells in the City and Town of Clean before a
permanent remedy for the Site could be implemented.  A focused feasibility study was performed and an Initial
Remedial Measure ("IRM") was conducted which included regular monitoring of private wells and installation of
carbon adsorption units, as necessary, until the permanent remedy was in place.

In 1983-84, pursuant to an administrative order issued by EPA, McGraw Edison performed an investigation at
its facility.  This and subseguent investigations performed by the PRP revealed that soil and ground water in
both aguifers at the facility were contaminated with TCE, 1,1,1-trichloroethane  (1,1,1-TCA),
1,1-dichloroethylene, 1,1-dichloroethane, trans-1,2-dichloroethane, tetrachloroethane (PCE) and methylene
chloride.  The studies further indicated that a pathway exists for migration of contaminants away from the
McGraw Edison facility and toward the contaminated municipal wells.

AVX, another PRP at the Site, performed an investigation of its facility in 1984-85 pursuant to an
administrative order issued by EPA.  This investigation indicated that soils and groundwater in the upper,
and lower aguifers were contaminated with TCE, 1,1,1-TCA, tetrachloroethylene and other VOCs.  Data collected
by AVX during this and subseguent investigations demonstrated that contamination is traveling downward from
the surficial soils at the AVX facility through the till and then entering the lower aguifer.

Alcas Cutlery, another PRP, conducted an investigation at its facility pursuant to an administrative order
issued by EPA in 1984.  The investigation found that soil at the Alcas facility was contaminated with VOCs.
Upper and lower aguifer ground water was also determined to be contaminated with TCE and
trans-1,2-dichloroethylene.  Subseguent EPA analyses showed elevated TCE concentrations of up to 12 parts per
million  ("ppm") in monitoring well B-2, which is screened in the lower aguifer at the facility and located
approximately 100 yards away from municipal well 18M.

EPA issued a Record of Decision (ROD) on September 24,  1985, which reguired the following:  1) installation
of one air stripper to treat the groundwater from municipal well M18, which is located on the north side of
the Allegheny River, and a second air stripper to treat the groundwater from municipal wells M37 and M38,
which are located south of the River  (Because wells M37 and M38 are located next to one another, only one air
stripper was needed.); 2)  extension of the City of Clean public water supply line into the Town of Clean to
connect approximately 93 residences served by private wells, including the private well users who received
carbon filter installations pursuant to the EPA Removal Actions conducted in 1982, 1984 and 1985; 3)
inspection of an industrial sewer at McGraw-Edison and performance of any necessary repairs on the sewer; 4)
recommendation of any institutional controls to restrict the withdrawal of contaminated groundwater; 5)
institution of a Site Monitoring Plan; and, 6) initiation of a  supplemental RI/FS to evaluate source control
measures at facilities that are contributing to the groundwater contamination.

On February 7, 1986, EPA issued a Unilateral Administrative Order, Index Number II CERCLA-60201, under
Section 106(a) of CERCLA,  42 U.S.C. §9606,  (the "106 Order") to AVX Corp., Alcas Cutlery Corp., McGraw Edison
Co., Cooper Industries, Inc., Aluminum Company of America, and W.R. Case and Sons Cutlery Co.  (the "PRPs").
The order reguired the PRPs to carry out the remedial actions selected in the ROD.  All of the PRPs with the

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exception of W.R Case and Sons performed the actions pursuant to the 106 Order.

The extension of the City of Clean water line was completed in 1988. In 1989, the private well users were
connected to the water line extension. Also in 1989, the industrial sewer at the McGraw Edison property was
inspected and repaired. In February 1990, physical construction of the air strippers was completed and the
municipal wells were put back on-line. Current pumping rates for Municipal wells M18, M37 and M38 are
approximately 1.2 and 1.9 million gallons per day (MGD), respectively. Since the system began operating,
treated water from the air strippers has met State and Federal drinking water standards.

On June 25, 1991, EPA issued an Administrative Order on Consent, Index Number II CERCLA-10202 (the "SRI/FS
Order") to the Alcas, AVX, McGraw Edison and Cooper Industries PRPs which required that a supplemental RI/FS
be undertaken at the Site. A portion of the supplemental RI/FS was performed by EPA.

In 1994, EPA oversaw the completion of a removal action at the Clean Steel property (see figure 1). Olean
Steel, which was one the properties investigated as part of the supplemental RI, is a scrap metal recycling
operation. EPA ordered the owner of the property to remove approximately 500 pales and drums and 120 cubic
yards of contaminated debris and soil from the property. The debris and soil was contaminated with phenol,
chromium, lead, bis(2-ethylhexyl)phthalate, copper and zinc. Also in 1984, a groundwater sample was
collected from an upper aguifer well by EPA as a follow up to the Removal action. Analysis of the sample
revealed arochlor-1254, a polychlorinated biphenyl compound, at a concentration of 5.4 ppb. EPA is,
therefore, referring this matter to the NYSDEC for further action.

GEOGRAPHY

Olean is located in the Allegheny River Valley near the border of the maturely dissected northwestern
Appalachian plateau. The Allegheny River, a principal tributary of the Ohio River, flows west-northwest
through the southern portion of the Site. Olean and Haskell Creeks, tributaries of the Allegheny, are
located to the west and east of the Site, respectively. Surface runoff, direct precipitation, and
groundwater sustain the annual flow in these river/stream systems.

Site Geology and Hydrogeology

The Olean Well Field is underlaid by approximately 300 feet of unconsolidated sediments. Previous
groundwater investigations in the Olean Well Field have shown that the upper 100 feet of sediment can be
divided into five lithologic units based on color, texture, grain size, and mode of deposition. These
lithologic units have been grouped into four hydrogeologic units referred to as the upper aguifer, upper
aguitard, lower aguifer, and lower aguitard.

The upper aguifer is comprised of glaciofluvial coarse sands and sandy gravels, and recent fluvial deposits
of fine sands and silts with some clay. The upper aguifer is not continuous across the Olean Well Field.
The thickest portion of the aguifer (approximately 41 feet) is found along the Allegheny River. The aguifer
thins to the north, pinching out south of the AVX facility.

The upper aguitard is located above the lower aguifer. This units is a low permeability lodgment till
composed of greater than 50 percent silt and clay. The thickness of the upper aguitard in the study area
ranges from as little as 6 feet in the south to over 30 feet in the north. In the northern portion of the
Olean Well Field, this unit is present at the surface and consists of surficial till.

The lower aguifer, also referred to as the City Aguifer, consists of glacial outwash deposits of sand, silt,
and gravel. The lower aguifer is approximately 70 feet thick in the northern portion of the Olean Well Field
and thins to approximately 30 feet south of the Allegheny River. The lower aguifer is the main source of
water for the City and Town of Olean. In addition, several industrial facilities (Olean Steel,
McGraw-Edison, and AVX) utilize wells completed in the lower aguifer for process water.

The lower aguitard has been described as silt, clay, and fine to very fine sand deposited in a preglacial
environment.

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The upper aquifer is recharged by the infiltration of precipitation. Recharge to the lower aguifer is via
leakage from the upper aguifer (or till where the upper aguifer is not present) through the upper aguitard.
The magnitude of leakage over the study area is variable and is dependent on the thickness and permeability
of the till (upper aguitard) and relative head differences between the upper aguifer (or till) and lower
aguifer.

SUPPLEMENTAL REMEDIAL INVESTIGATION SUMMARY

Pursuant to the June 25, 1991, SRI/FS Order, EPA and five PRPs for the Site collected soil gas, soil and
groundwater samples at 13 properties to determine if the properties are sources of contamination to the Clean
Well Field Site. The PRPs were responsible for sampling the AVX, Alcas and McGraw-Edison properties.
Ebasco, under contract to EPA, sampled 10 other properties, which are located throughout the Site. These
properties included: Clean Steel; Clean Wholesale; the immediate vicinity of Fay Avenue and Shaefer Street;
a Private Dump located at the end of Butler and Andrews Avenues; the "Borrow Pit," a common disposal area,
located along Riverside Drive; Sandburg Oil; Mastel Ford; Griffith Oil; Loohns Cleaners and Launderers, Inc;
and Olean Tile. Figure 1 shows the locations of the 13 properties investigated.

With the exception of Olean Steel, soil gas surveys were conducted on 100- by- 100 foot grid spacings across
each property during September and October 1991. A grid could not be established at the Olean Steel property
due to the presence of large amounts of scrap metal on the property. Two additional soil gas surveys were
conducted in February 1993 and February 1995 at finer grid spacing of 25 feet. The results of the surveys
assisted in locating the soil borings at each property. Soil samples were collected from each boring.

Each soil boring extended down to the water table to determine the vertical extent of contamination. In
1991, forty-six soil borings were located and drilled at the suspected source areas using the results of the
soil gas surveys. In February 1993 and February 1995, a total of 25 additional soil borings were drilled to
better determine the extent of contamination at the suspected source areas.

Sediment samples were taken at three locations in a wetlands area being the AVX facility. The samples were
taken to determine the potential impact of the AVX property on the wetlands area.

Eight groundwater monitoring wells were installed to collect data on the extent of groundwater contamination
in the upper and lower aguifers and to determine the impact of the source areas on the groundwater. The
wells consisted of four upper and four lower aguifer wells. The upper aguifer wells were installed at Olean
Wholesale, Olean Steel, McGraw-Edison, and the Loohns Dry Cleaners properties. The lower aguifer wells were
installed at Olean Wholesale, Olean Steel, Loohns and Sandburg Oil.

Groundwater samples were collected from eight newly installed groundwater monitoring wells (4 upper aguifer
and 4 lower aguifer wells) and from 24 existing wells (13 upper aguifer, 11 lower aguifer wells), which were
installed during previous studies of the Site. In addition, groundwater grab samples were collected from the
25 soil borings, which were drilled at the properties being investigated, in 1993 and 1995.

A 72-hour pump test was conducted on the upper aguifer at McGraw-Edison in 1991. The results of the test
assisted in determining the feasibility of pumping contaminated groundwater from the aguifer for treatment.

Finally, pilot tests were performed to determine whether vacuum enhanced recovery (VER) or soil vapor
extraction with air sparging (SVE/AS) would be an effective means of in-situ treatment of VOCs contaminated
soils at the AVX and Alcas properties. SVE/AS and VER are two treatment technologies possible under remedial
Alternative 4 for the Site. See section below entitled "Summary of Remedial Alternative" for a description
of the two technologies.

A summary of the soil, sediment and groundwater samples, which were collected during the SRI follows:

AVX

Soil gas, soil and groundwater samples were collected from the AVX property in 1991 and 1993.

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VOCs were detected at significant concentrations in the southern portion of the property at soil boring SB06
 (see Figure 1).  Analysis of soil samples revealed 1,1,1-TCA  (1,300,000 ppb), TCE  (500,000 ppb); PCE  (270,000
ppb),  xylene  (73,000 ppb) and cis-1,2 dichloroethane 1,2 DCE  (45,000 ppb).  Lower levels of PCE  (610 ppb) and
TCE (53 ppb) were detected in a sample from SB05.

Soil samples were collected from four other borings at the facility.  VOCS contaminants were either not
detected in samples from these borings or were detected at levels, which were below the Remedial Action
Objectives  (RAOs) for the Site.  See the section on RAOs below.

Analysis of a groundwater grab sample taken from the bottom of SB06 revealed TCE  (110,000 ppb); 1,1,1-TCA
 (360,000 ppb); 1,2-DCE  (73,000 ppb); PCE (14,000 ppb); toluene (21,000 ppb); 1,1-DCE  (16,000 ppb); 1,1-DCA
 (26,000 ppb), acetone (180,000 ppb); and xylene (3,900 ppb).  Each compound exceeded a state or federal
Maximum Contaminant Level (MCL) value (see Table 1 below).

The soil and groundwater sample result confirmed AVX as a source of VOCS contamination to the Clean Well
Field Superfund Site groundwater.

ALCAS

Soil gas, soil and groundwater samples were collected from the Alcas property in 1991 and 1993.

Significant levels of VOCs were detected in the southern portion of the facility in soil samples from boring
SB07 (see Figure 1).  The following VOCs were detected:  TCE  (12,000 ppb) and PCE  (200 ppb).  1,2-DCE  (1,000
ppb),  TCE (690 ppb) and vinyl chloride (100 ppb) were detected in a sample from SB04.

Soil samples were collected from five other borings at the facility. VOCS contaminants were either not
detected in samples from these borings or were detected at levels, which were below the RAOs for the Site.

Analysis of a groundwater grab samples taken from the bottom of boring SB07 showed TCE (8,800 ppb); 1,1,1-TCA
 (500 ppb); 1,2-DCE  (640 ppb); and vinyl chloride (25 ppb).  Each compound exceeded a state or federal MCL
value (see Table 1 below).

Chromium, copper and manganese were detected in the soil from boring SB05 at 944 ppm, 93.6 ppm, and 4,680
ppm, respectively.  SB05 was located in the southern part of the facility.

The soil and groundwater sample results confirmed Alcas as a source of VOCS contamination to the Clean Well
Field Superfund Site groundwater.

McGRAW-EDISON

Soil gas, soil and groundwater samples were collected at the McGraw-Edison property in 1991 and 1993.

Soil samples were collected from nine borings at the facility.  VOCs were either not detected in soil samples
from these borings or were detected at low levels,  which were below the RAOs for the Site.

TCE was detected at 860 ppb in a saturated (below the water-table) soil sample, which was collected from 24
to 26 feet below the ground surface.  The sample was collected during the installation of the upper aguifer
well EW-3, which is located in the southeastern part of the property.

Analysis of the groundwater from EW-3 showed 2,100 ppb of TCE.  A groundwater grab sample from boring SB08
revealed TCE and 1,2-DCE at 400 ppb and 51 ppb, respectively.  Each compound exceeded a state or federal MCL
value (see Table 1 below).

Groundwater samples were also collected in December 1991 from upper aguifer monitoring wells A-l, C-l, and
EW-3.   TCE was detected in samples from A-l,  C-l,  and EW-3 at concentrations of 40 ppb, 50 ppb, and 2,400
ppb, respectively.

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The saturated soil and groundwater sample results confirmed McGraw-Edison as a source of VOCS contamination
to Clean Well Field Superfund Site groundwater.

LOOHNS CLEANERS AND LAUNDERERS

Soil gas, soil and groundwater samples were collected from the Loohns property in 1991 and 1995.

Significant concentrations of VOCs were detected in the soil from borings SB09,SB12, SB47 and SB48. All four
borings were located in the southern portion of the facility. The soil sampled from SB09 showed TCE (24,000
ppb), 1,2-DCE (59,000 ppb), PCE (91,000 ppb) and 2-butanone (5,400 ppb). Soil samples from SB12 revealed PCE
(38,000 ppb) and TCE (18,000 ppb). Samples from SB47 revealed TCE (4,300 ppb), PCE (370,000 ppb), 2-butanone
(200,000 ppb) and TCE (400, 000 ppb). Finally, a soil sample from SB48 showed 1,2-DCE (2,000 ppb), TCE (510
ppb) and PCE (18,000 ppb).

Soil samples were collected from two other borings at the facility. VOCS contaminants were either not
detected in samples from these borings or were detected at levels which were below the RAOs for the Site.

In January 1995, grab samples of groundwater from borings SB47 and SB48 revealed TCE (29 ppb) in the grab
from SB48 and cis-l,2-DCE (23 ppb) in the grab sample from SB47.

Two groundwater monitoring wells were also installed at soil borings SB47 and SB48. A lower aguifer well was
installed at SB47 and an upper aguifer well was installed at SB48. Cis-1,2 DCE, TCE and PCE were detected at
6.3 ppb, 88 ppb and 1,800 ppb, respectively, in groundwater from the upper aguifer well. Each compound
exceeded a state or federal MCL value (see Table 1 below).

The soil and groundwater sample results confirmed Loohns as a source of VOCS contamination to the Clean Well
Field Superfund Site groundwater.

CLEAN STEEL

Soil gas, soil and groundwater samples were collected at Clean Steel in 1991, 1993, and 1995.

In 1991, four soil borings and two monitoring wells (MW03 and MW04) were drilled and sampled at the locations
shown in Figures 1 and 2. VOCs were were not detected above RAOs concentrations for soil.

In 1993, two additional soil borings were drilled at the locations shown on Figure 1. Low concentrations of
VOCs were detected.

Groundwater samples were collected in December 1991 from upper aguifer monitoring well MW04 and lower aguifer
monitoring well MW03. Analysis of groundwater samples from these wells did not reveal VOCs above the
groundwater RAOs for the Site.

In February 1995, one additional boring (SB44) was drilled down to the top of the upper aguifer. VOCs were
were not detected above RAO concentrations for soil.

VOCS contaminants were either not detected in the soil and groundwater samples from the property or were
detected at levels which were below the RAOs for the site. The soil and groundwater sample results indicate
that Clean Steel is not a source of contamination to the Clean Well Field Superfund Site groundwater.

MASTEL FORD

Soil gas, soil and groundwater sample were collected at Mastel Ford in 1991, 1993 and 1995.

In 1991, three soil borings were drilled at the locations shown on Figure 1. Minimal concentrations of VOCs
were detected.

In 1993, two additional soil borings were drilled at the Mastel Ford facility. Minimal concentrations of

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VOCs were detected.

In February 1995, a sixth soil boring (SB45) was drilled down to the top of the upper aquifer. No
significant contamination was found.

Two groundwater grab samples were collected in 1993 from soil borings SB31 and SB32 and one grab sample was
collected in January 1995 from SB45. VOCs were not detected in the sample from SB31. Minimal levels of VOCs
were detected in the grab samples from SB32 and SB45.

VOCS contaminants were either not detected in the soil and groundwater samples from the property or were
detected at levels which were below the RAOs for the site. The soil and groundwater samples results indicate
that Mastel Ford is not a source of contamination to the Clean Well Field Superfund Site groundwater.

SANDBURG OIL

Soil gas, soil and groundwater samples were collected at the Sandburg Oil property in 1991, 1993 and 1995.

In February 1995, a third soil boring (SB46) was advanced down to the top of the upper aguifer. A
groundwater grab sample collected from the boring revealed: ethylbenzene (540 ppb), xylene (157 ppb),
naphthalene (110 ppb) and 2-methylnaphthalene (54 ppb). Again, these VOCs are associated with petroleum and
petroleum product derivatives.

A lower aguifer monitoring well was installed in the borehole for SB46. Methylene chloride was the only VOCS
detected (15 ppb) in the groundwater, which exceeded state and federal MCLs. However, the pressure of the
compound in the groundwater was not attributed to Sandburg Oil, since it was not detected in the soil at
concentrations above the RAOs for the Site.

The soil and groundwater sample results confirmed Sandburg Oil as a source of petroleum related contaminated
to the Clean Well Field Superfund Site groundwater.

GRIFFITH OIL

Soil gas, soil and groundwater samples were collected at Griffith Oil in 1991, 1993 and 1995.

During 1991, three soil borings were drilled and sampled at the locations shown on Figure 1. SVOCs were
detected from samples from soil boring SB24: 20-methyl naphthalene (7,600 ppd) and; phenanthrene (1,100
ppb) .

Two groundwater grab samples were collected at soil borings SB41 and SB42 during 1993. Minimal
concentrations of VOCs were detected.

In January 1995, soil boring SB49 was drilled down to the top of the upper aguifer. The location of SB-49 is
shown in figure GI-6 of the SRI/FS report. Analysis of the soil revealed benzene (650 ppb), toluene (5,900
ppb) and xylene (23,000 ppb).

Analysis of groundwater from an upper aguifer well DW6R-01, located on the Griffith Oil property, revealed
six VOCs: methyl chloride (14 ppb), 1,1-DCA (6.1 ppb), cis-l,2-DCE (79 ppb), TCE (78 ppb), benzene (220 ppb)
and ethyl benzene (5.7 ppb).

Although non-petroleum VOCS contaminants were also detected (1,1-DCE, cis-l,2-DCE and TCE), they were not
attributed to Griffith Oil, since the VOCs, which were detected in the soil, were below the soil RAOs for the
Site and therefore could not be a source of the VOCS contamination.

The soil and groundwater sample results confirmed Griffith Oil as a source of petroleum related contamination

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to the Clean Well Field Superfund Site groundwater.

The NYSDEC is currently overseeing a spill response clean-up of fuel oil and gasoline spills at the Griffith
Oil facility.

FAY AVENUE/SCHAEFER STREET

In 1991 and 1993, three soil borings were drilled and sampled at the locations shown on Figure 1. VOCs were
detected at minimal levels.

One groundwater grab sample was collected at soil boring SB40 during the 1993. Cis-l,2-DCE was detected at 2
ppb.

The soil and groundwater sample results indicate that the Fay Avenue/Shaefer area is not a source of
contamination to the Clean Well Field Superfund Site groundwater. Although non-petroleum VOC contaminants
were also detected (1,1-DCE, cis-l,2-DCE and TCE), they were not attributed to Griffith Oil, since the VOCs,
which were detected in the soil, were below the soil RAOs for the Site and therefore could not be a source of
the VOCS contamination. VOCS contaminants were either not detected in the soil and groundwater samples from
the property or were detected at levels which were below the RAOs for the Site.

OLEAN TILE

Soil gas, soil and groundwater samples were collected at the Clean Tile property in 1991 and 1993.

In 1991, four soil borings were drilled at the locations shown on Figure 1. VOCs were not detected with one
exception - acetone was detected (26 ppb) in sample SB13-0002. SVOCs were not detected.

Two groundwater grab samples were collected at soil borings SB35 and SB36 during the 1993 soil boring
program. VOCs were not detected in the samples.

Despite the significant concentration of toluene detected at SB34, EPA does not believe toluene is a source
of contamination to the groundwater. The compound was detected from 4 to 10 feet below the surface. No
organic contaminants were detected from 11 feet to 42 feet. The boring terminated at a depth of 42 feet with
no observable guantity of groundwater. Therefore, EPA believes that the toluene contaminations is isolated
and should not impact the groundwater.

In February 1995, a surface water sample was collected from the Allegheny River to determine if the Clean
Tile property was contaminating the River. Analysis of the water sample, however, did not indicate the
presence of VOCs, especially toluene.

The soil and groundwater and surface water sample results indicate that Olean Tile is not a source of
contamination to the Olean Well Field Superfund Site groundwater or the Allegheny River.

OLEAN WHOLESALE

Soil gas, soil and groundwater samples were collected from the Olean Wholesale property in 1991 and 1993.

In 1991, four soil borings were sampled at the locations shown on Figure 1. Minimal concentrations of VOCs
were detected.

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In 1993, soil samples were collected from one additional soil boring. No VOCs were detected.

Groundwater samples were collected in December 1991 from upper aquifer monitoring well MW02 and lower aguifer
monitoring well MW01. VOCs were not detected in the samples from either well.

One groundwater grab sample was collected at soil boring SB43 in 1993. TCE was detected at 7 ppb.

The soil and groundwater results indicate that Clean Wholesale is not a source of contamination to the Clean
Well Field Superfund Site groundwater. VOCS contaminants were either not detected in soil samples from the
property or were detected at levels which were below the RAOs for the Site.

PRIVATE DUMP

Soil gas soil samples were collected from the Private Dump in 1991, in order to determine whether past
alleged uncontrolled dumping activities may be a source of contamination to the groundwater.

In 1991, two soil borings (SB25 and SB26) were drilled and sampled at the locations shown on Figure 1. Three
sediment samples (SD01, SD02, and SD03) were also collected. VOCs were not detected in the soil with one
exception - toluene (6 ppb) and 2-butanone (60 ppb) were detected at boring SB26. PCE was detected in the
sediment at 10 ppb.

No soil samples were collected in 1993.

The soil sample results indicate that the Private Dump is not a source of contamination to the Clean Well
Field Superfund Site groundwater.

BORROW PIT.

In 1991, one soil boring (SB28) was sampled at the location shown in Figure 1. VOCs were not detected.

Three sediment samples (SD4, SD5 and SD6) were also collected (see Figure 1) in 1991. Minimal levels of VOCs
were detected.

In 1993, one additional soil boring (SB39) was drilled at the location shown on Figure 1. VOCs were not
detected with one exception - methylene chloride (12 ppb).

One groundwater grab sample was collected from soil boring SB39 in 1993. TCE was detected 13 ppb.

The soil and groundwater sample results indicated that the Borrow Pit is not a source of contamination to the
Clean Well Field Superfund Site groundwater VOCS contaminants were either not detected in the soil samples
from the property or were detected at level which were below the RAOs for the Site.

BACKGROUND SOIL SAMPLES

In 1991, two soil borings (SB29 and SB30) were drilled and sampled off-Site at the intersection of King and
Seneca Streets, in the City of Olean. The samples were collected as background samples to establish a
baseline upon which the Site data could be compared. The borings were located off the northwest corner of
Figure 1. PCE and methylene chloride were detected a 8 ppb and 10 ppb, respectively, in a soil sample from
boring SB29. No Semi-VOCs were detected. Also, inorganic analysis of the samples indicated metal
concentrations which were within background concentrations of metals for the soils in the eastern United
States.

No background samples were collected 1993 or 1995.

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SITE-WIDE GROUNDWATER SAMPLES

Groundwater samples were also collected from twenty-four existing monitoring wells on Site in December 1991,
November 1994 and March 1995. The wells included: A-l, C-l, CW-1B, CW-3B, CW-4, CW-4A, CW-5, CW-5A, CW-7A,
CW-9A, CW-10, CW-10A, CW-12, CW-12A, CW-13, CW-13A, CW-15A, CW-18, CW-18A, well located at S&S Car Cleaners,
DW6R-01, Aleas D-2, AVX-5D and MEC-A-2. See Figure 2 for the well locations.

Maximum concentrations of VOCs detected between 1989 and 1995 in samples from several of the existing wells
were as follows: Cl-TCE 40 ppb: CW-7A-TCE 590 ppb, 1,1,1-TCA 7 ppb; CW-9A-TCE 400 ppb; CW-10-340 ppb;
CW-13A-methylene chloride 28 ppb; CW-18A-TCE 1400 ppb, 1,1,1-TCA - 15 ppb, cis-l,2-DCE 41 ppb, PCE 3,1 ppb; a
well located at S&S Car Cleaners - TCE 39 ppb; AVX-5D - TCE 2,000 ppb, cis-l,2-DCE 15,000 1,1,1-TCA 7,200;
Alcas-D2 - TCE 6,500 ppb, MEC-A2 - TCE 170 ppb.

Bis 92-Ethylhexyl) phthalate, an SVOC, was detected in CW-5 (190 ppb) and CW-12 (560 ppb).

Four metals exceeded state and federal MCLs from samples from the existing monitoring wells. Chromium was
detected in CW-12 (22,500 ppb) and CW-12A (1,720 ppb). Iron was detected CW-12 (143,000 ppb) and CW-12A
(23,400 ppb). Lead was detected in CW-5 (23.5 ppb) and CW-13A (84.6 ppb). Manganese was detected in CW-12
(8,560 ppb) and CW-12A (5,950 ppb). However, analysis of the groundwater, before it is treated at municipal
wells M18 and M37, M38, has not revealed chromium or any other inorganic contaminants. Because of the
proximity of the monitoring wells to well M18 and the high concentration of chromium detected (the MCL is 50
ppb), EPA intends to add chromium to the list of contaminants which are analyzed for as part of the Site
Monitoring Plan. The monitoring plan was required EPA, as part of the remedial action for the first operable
unit to monitor the effectiveness of the air strippers, which were installed to treat the groundwater from
the municipal wells and will be updated as part of the second operable unit.

UPPER AQUIFER PUMP TEST

A 72-hour constant rate pumping test was performed on well EW-3 in January 1992 at the McGraw-Edison facility
to determine the transmissivity and storativity of the upper aguifer in the Clean Well field. These
hydraulic properties of the aguifer were obtained to order to determine the amount of contaminated
groundwater which could be pumped and treated in order to restore the aguifer.

DIRECTION OF GROUNDWATER FLOW

Water-level measurements were also collected from existing monitoring wells in the vicinity of Haskell Creek.
Though several of these wells are beyond the limits of Figure 2, the water-level elevation data from these
wells were evaluated in the preparation of potentiometric surface maps, which are included in the SRI report.

Groundwater in the lower, or City Aguifer, flows from east to west. Flow conditions in the lower aguifer
have been altered since the 1985 RI in the during the RI, the municipal wells were inactive and the AVX
production well was pumping at approximately 200 gpm. Since 1990, the three municipal wells have been
pumping at a combined rate of 2,150 gpm and the AVX production well has been decreased to approximately 50
gpm due to decreased demand. The principal difference between the groundwater flow regime at the time of the
1985 RI report and the March 1992 SRI potentiometric maps, is the increased hydraulic gradient in the study
area which resulted from the pumping stress imposed by the now active municipal wells. A figure identifying
the capture zones is included in the SFS report.

CULTURE RESOURCE ASSESSMENT

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In April 1992, an EPA contractor conducted a Stage 1A Cultural Resources Survey (CRS) of the Site which
entailed a review of the historic maps and archival records on file at the New York State Office of Parks and
Recreation, Historic Division; the Cattaraugus County Historical Society; and the Assessor's and Engineer's
Office of the City of Clean. The contractor also reviewed previous cultural resource surveys of the region
and conducted on-Site reconnaissance. A copy of the CRS report can be found in the public repositories,
which are listed on page 2.

After review of the CRS report and pursuant to the National Historic Preservation Act, EPA has decided that
additional cultural investigations should be completed at the Alcas Cutlery and Loohns Cleaners and and
Launderers source areas. EPA believes that these areas may have cultural resource artifacts, which may be
potentially disturbed by a selected remedial alternative. As such, a Stage 1 B, Cultural Resources Survery
(CRS) will be completed during the remedial design phase of the selected alternative. The Stage IB will
assess whether additional investigative field work is necessary. Any additional work will be completed
during remedial design.

SUMMARY OF SITE RISKS

Based upon the results of the SRI, a baseline risk assessment was conducted to estimate the risks associated
with current and future Site conditions. A baseline risk assessment was conducted to determine whether soil
and groundwater remediation were necessary in order to reduce unacceptable risks to human and ecological
receptors.

HUMAN HEALTH RISK ASSESSMENT

A four-step process is utilized for assessing site-related human health risks for a reasonable maximum
exposure scenario: Hazard Indentification-identifies the contaminants of concern at the site based on
several factors such as toxicity, freguency of occurrence, and concentration. 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. Toxicity
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 which would be representative of
Site risks. These contaminants included trichloroethene, 1,1-dichloroethane, 1,1-dichloroethane,
1,2-dichloroethane, tetrachloroethane, benzene and vinyl chloride. Several of the contaminants, including
trichloroethene, tetrachloroethene, 1,1-dichloroethene, and 1,2-dichloroethane are known to cause cancer in
laboratory animals and are suspected to be human carcinogens. Vinyl chloride and benzene are known human
carcinogens.

The baseline risk assessment evaluated the health effects which could result from exposure to contamination
as a result of ingestion, dermal contact and inhalation of untreated groundwater and soil contaminants.
Groundwater exposure was assessed using present and future residential land use scenarios. Groundwater was
also assumed to be the sole source of water. Risks were calculated for groundwater by way of ingestion,
dermal contact and inhalation of volatilized contaminants during showering. Risks due to contaminants in the
surface and subsurface soil were calculated for exposure as a result of ingestion or inhalation of
contaminants by construction workers. A residential exposure scenario was not calculated because all of the
properties are either industrial or commercial and are zone for industrial uses only.

Risks due to dermal contact with soil contaminants were assessed for the Site, but could not be calculated
because dermal contact risks can only be calculated for soil which contains polychlorinated biphenyls (PCBs),
dioxins or cadmium. No PCBs or dioxins were found at the Site. Cadmium was found at 5 of the 13 properties
investigated. However, of the five properties, the highest concentration of cadmium detected was just above
4 ppm, which does not present an unacceptable risk.

Current federal guidelines for acceptable exposures are an individual lifetime excess carcinogenic risk in

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the range of 10-4 to 10-6 (e.g., a one-in-tn-thousand to a one-in-a-million excess cancer risk) and a maximum
health Hazard Index (which reflects noncarcinogenic effects for human receptor) egual to 1.0 (A Hazard Index
(HI) greater 1.0 indicates a potential for noncarcinogenic health effects.)

The results of the baseline risk assessment indicate that untreated groundwater at the Site poses an
unacceptable risk to human health. Cancer risks due to ingestion of groundwater were determined to be
approximately one-in-hundred (Ix 10-2) for adults and young children and six-in-one-thousand (6x10-3) for
older children. Noncarcinogenic His for these exposure groups were 3.4 for adults, 14.7 for young children
and 6.7 for older children. The aforementioned cancer and non-cancer risks are referenced in Table C-5, C-6
and C-7 of the Risk Assessment. These tables include the cancer and noncancer effects of TCE and PCE. Also,
these tables did not include the potential health effects of acetone, since the presence of the compound in
the sample data was attributed to laboratory contamination. Acetone is not considered a Site contaminant.

Cancer risks due to dermal contact with groundwater contaminants were determined to be approximately
tow-in-one-thousand (2x10-3) for adults, nine-in-ten-thousand (9x10-1) for young children and
seven-in-ten-thousand (7x10-4) for older children. The HI for each group was less than one.

Cancer and non-cancer risks due to inhalation of contaminants from untreated groundwater during showering
were within EPA's acceptable risk range. Cancer risks for adults were determined to be approximately 6x10-5
for adults, 6x10-5 for young children and 3x10-5 for older children. The HI for each group was less than
one.

Risks were also calculated for ingestion and inhalation of surface and subsurface soil contaminants by
construction workers. The risks were calculated for a two year exposure period.

Cancer risks were found to be acceptable for each of the thirteen properties investigated. Noncancer risks
were also found to be acceptable at twelve of the thirteen properties with the exception of McGraw-Edison. A
minimum noncancer risk (HI of 1.14) due to soil ingestion was calculated for McGraw- Edison. The elevated
risk is due mainly to arsenic.

Remedial Action Objective (see below) were used to determine the extent of groundwater and soil remediation
at the identified source areas. Achieving these levels will reduce the risks associated with groundwater
ingestion and dermal contact.

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 know ecological effects of the
contaminants; and selection of endpoints for further study. Exposure Assessment -- a guantitative 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.

EPA conducted an assessment of a wetlands area, which is located to the south of the AVX facility. The
assessment was conducted to determine if the wetlands are overlapped the area of contamination at the AVX
facility. Sediment samples were taken to determine if AVX was impacting the wetlands area.

The wetlands area, which encompasses approximately 18.5 acres, is bordered to the north by Seneca Avenue, the
south by a Conrail righ-of-way and AVX, the east by Dugan Road and the west by AVX. Three sediment samples
were collected from the wetlands area south of the AVX property and north of the Conrail railroad tracts.
Analysis of the samples did not reveal and VOCS contamination. Several Semi-VOCs were detected, but were
attributed to the Conrail railroad tracks and were not determined to be affecting the groundwater.

The three other source (Alcas, McGraw Edison and Loohns) are developed properties with lawns, planting, and
one or more buildings with asphalt entry ways and parking areas.

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No other studies were conducted to assess other ecological risks since the Site is located in an urban
commercial/industrialized area. There are no significant habitats present at the Site which could
potentially support indigenous wildlife receptor species. The Site may however provide a habitat for various
non-native species which have adapted to highly urbanized area (e.g., rats, starlings and regions).

Actual or threatened releases of hazardous substances from this Site, if not addressed by the preferred
alternative or one of the other active measures considered, may present a current or potential threat to
public health, welfare or the environment.

REMEDIAL ACTION OBJECTIVES

Remedial action objectives are specific goals to protect human health and the environment. These objectives
are based on available information and standards such as applicable or relevant and appropriate reguirements
(ARASs) , To Be Considered (TBC) guidance values, and risk-based levels established by the risk assessment.

Groundwater objectives include: 1.) removal and/or control of the sources of contamination to the
groundwater; and 2.) removal of sources of contamination already in the groundwater.

Soil objectives include the elimination of leaching of contaminants of concern from the soil at each of the
source areas into the groundwater.

In order to determine which source areas reguire remediation, EPA compared contaminants in the groundwater
and soil at all of the properties to various criteria. For soil, EPA used the NYSDEC's Technical and
Administrative Guidance Memorandum (TAGM) cleanup numbers, which represent concentrations of VOCs which will
not leach from the soil and dissolve into the groundwater at levels which are above federal or state MCL
concentrations. For groundwater, EPA used federal and state MCLs. Facilities with contamination
concentrations which exceeded these criteria are targeted for remediation. These criteria will also be used
as remediation cleanup goals. The criteria can be found in Table 1.

As a result of this analysis, EPA has determined that the AVX Alcas, Loohns Dry Cleaners and McGraw Edison
properties are sources of contamination to the groundwater and therefore reguire remediation.

For the AVX and Loohns source areas, the remediation will be phased. First, a soil cleanup will take place,
after which EPA will monitor the groundwater to determine if VOCS concentrations are decreasing at a rate
sufficient to meet the goal of aguifer restoration in a reasonable amount of time. If necessary, EPA will
install a groundwater pump and treat system at the two source areas to facilitate aguifer restoration.

Because of close proximity of the Alcas source area to municipal well M18, remediation of the contamination
will only consist of a soil remediation phase. Groundwater remediation is not necessary since any
groundwater which is contaminated by the property is captured and treated by an air stripper, which currently
operating at the municipal well.

Remediation of the McGraw Edison facility will only consist of a groundwater phase, since the soil was not
found to be contaminated. (The contamination in the saturated soil zone will be addressed by the groundwater
cleanup.)

The Sandburg and Griffith Oil properties were also determined to be sources of groundwater contamination,
although the contamination was found to be petroleum related. As such, CERCLA prohibits the use of Superfund
Trust Fund monies to clean up or to oversee the clean up of petroleum contamination. EPA is therefore
referring the contamination at these properties to the NYSDEC for action under the State's petroleum cleanup
program.

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Table 1

Contaminant
Benzene
2-Butanone
Cis 1,2- Dicloro-
ethene
Ethylbenzene
Tetrachloro-
ethene
1,1,1-Trichloro-
ethene
Trichloroethane
Toluene

Vinyl Chlorid
Xylene
Soil
Clean up
Objective
60 ppb
300 ppb
300

5,500 ppb
1,400 ppb

800 ppb

700 ppb
1,500 ppb

200 ppb
1,200 ppb
Federal
Ground
water
MCLs
5 ppb

70 ppb

700 ppb
5 ppb

200 ppb

5 ppb
1,000
ppb
2 ppb
10,000
ppb
New York
State
Ground-
water
Standards

0.7 ppb
50 ppb
5 ppb

5 ppb
5 ppb

5 ppb

5 ppb
5 ppb

2 ppb
5 ppb
SUMMARY OF REMEDIAL ALTERNATIVES
CERCLA requires that each selected Site remedy be protective of human health and the environment, be cost
effective, comply with other statutory laws, and utilize permanent solutions and alternative treatment
technologies and resources recovery alternatives to the maximum extent practicable. In addition, the statute
includes a preference for the use of treatment as a principle element for the reduction of toxicity,
mobility, or volume of the hazardous substances.

The supplemental FS report evaluated in detail five remedial alternatives for addressing the source areas at
the Clean Well Field Superfund Site. Each source area differed with regard to the extent of contamination,
general physical characteristics and location within the Site boundaries. Because of these differences, EPA
is not recommending a Site-wide remedial alternative, but a specific remedy for each source area.

Also, the time periods referenced below for construction of the remedial alternatives reflect only the times
required to implement the various remedies and do not include the times required to negotiate with the
responsible parties, to procure any contracts which are necessary for implementation or to design the remedy.

The five remedial alternative areas follow:

Alternative 1 - No Action

The Superfund program requires that the "no-action" alternative be considered as a baseline for comparison of
other alternatives. No Action results in leaving the source area properties as they currently exist with no
additional work to be performed. At present, groundwater recovery and treatment with air strippers on the
municipal water supply wells and on a production well at the McGraw-Edison site are in operation. A
quarterly Site Monitoring Program is also being carried out. These operations would continue and are
considered part of the No Action alternative. Because this alternative would result in contaminants on-Site,
CERCLA requires that the Site be reviewed every 5 years. If justified by the review, remedial actions may be
implemented to remove or treat the wastes.

There are no capital or operation and maintenance costs associated with this alternative.

Construction Time: Since this is a no action alternative, no time would be required for construction.

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Alternative 2 - Institutional Controls

This alternative includes education programs, such as public meetings and presentations, designed to increase
public awareness about the hazards present in the identified source areas. In addition, deed restrictions or
other legally enforceable restrictions would be instituted at the source areas to limit on-Site excavation,
property use and installation of domestic or industrial groundwater wells for potable water purpose until
soil and groundwater clean-up objective concentrations identified in Table 1 are achieved. Excavation
restrictions would ensure that excavation in or near an identified soil source area is accompanied by
implementation of a worker/local area health and safety plan and appropriate off-Site treatment and/or
disposal of any contaminated excavated soils. Legal activities associated with instituting land use
restrictions could include incorporating necessary language into Site property deeds. Access restrictions
could include installation of a 6-foot high fence with lockable gates (to the extent such fencing is not
already in place) around each source area. The integrity of the Site fencing would be maintained
indefinitely. A health and safety plan would govern future access to, or work within, the identified source
areas.

Capital, present worth and operation and maintenance costs for this alternative are summarized in Table 2.
Costs were developed by source area. Capital costs would include fencing and manpower to obtained land
access use and deed restrictions and to educate the public on the level and extent of contamination at the
Site. Operation and maintenance costs would include Site-wide sampling and analysis of the groundwater for
thirty years.

Construction Time: This alternative could be implemented within 3 to 6 months.

Alternative 3 - Capping and Groundwater Treatment

This alternative would involve the following major elements:

! Capping of contaminated soil.
! Implementation of land use/access restrictions to maintain integrity of the cap.
! Monitoring programs at selected monitoring wells and at the Clean Well Field municipal wells.
! Implementation of groundwater treatment if capping does not sufficiently remediate the groundwater.
! Conducting a 5 year review of Site conditions.

Stage 1

Alternative 3 would reguire capping of impacted soils at the soil source areas with a clay and soil cap.
This would reduce further migration of the contamination from he soil to the groundwater. Land use
restrictions and groundwater monitoring, as described for Alternative 2, would also be implemented.

The soil source areas would be covered with a clay cap. The surface area capped would be approximately 9,800
sguare feet (approximately 0.25 areas) at Alcas, approximately 3,200 sguare feet (approximately 0.07 acres)
at AVX and approximately 6,000 sguare feet (approximately 0.14 acres) at Loohns. Note that a cap would not
be necessary at McGraw Edison, since no soil contamination was detected at the property.

Stage 2

After soil remediation is completed at Alcas, AVX and Loohns, EPA will assess the affect on the groundwater
after waiting the time for three pore volumes of groundwater to travel from all three source area properties
to the municipal wells. EPA has calculated that it will take four years for the three pore volumes of
groundwater to pass, or flush through, from the source areas to the municipal wells. Therefore, the
groundwater guality will be monitored. The effectiveness of the remediation will be evaluated at four year
intervals. If it is determined that the city aguifer still contains contaminant concentrations above
drinking water standards and if it is determined that the remediated source area continues to affect the
groundwater entering the City Municipal wells 18M, 37M, a groundwater pump-and-treat system may be installed
at either the AVX or the Loohns Dry Cleaners source areas. However, such treatment will not be necessary at
the ALCAS source area due to the close proximity of the source area to municipal well 18M.

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If groundwater treatment is determined to be necessary for the AVX source area, EPA will also evaluate the
impact of a groundwater pump and treat system on the wetlands area. This evaluation will weigh the need for
reducing contaminant concentrations in the groundwater with any potentially advers affect on the wetlands
area.

Capital, present worth and operation and maintenance costs for this alternative are summarized in Table 2.
Costs were developed by source area. Capital costs were developed for the construction of a cap at each
source area and construction of groundwater collection and treatment systems at the Loohns and AVX source
areas. The capital cost for the Alcas source area does not include groundwater treatment, since contaminated
groundwater from the source area will be captured and treated by the air stripper at municipal well M18. The
capital cost for the Alcas source area only includes construction of the cap Operation and maintenance and
present worth costs were developed for maintenance of a cap and groundwater treatment system for thirty years
and Site-wide sampling and analysis of the groundwater for thirty years.

Alternative 3A - Groundwater Treatment

This alternative would involve the following elements:

! Groundwater treatment of the source areas
! Implement land use/access restrictions (if necessary).

Under this alternative, a groundwater recovery system would be installed. Contaminants in the recovered
groundwater would be removed by an air stripping system. The treated groundwater would be treated further,
if necessary, with granulated activated carbon (GAG) and discharged to the City of Clean sewer system and
ultimately to the Publicly Owned Treatment Plant. If necessary to meet New York state air emission limits,
the off-gas from the air stripping system would be treated with vapor phase GAG.

Capital, present worth and operation and maintenance costs for this alternative are summarized in Table 2.
Operation and maintenance and present worth costs are for Site-wide sampling and analysis of the groundwater
for thirty years.

Construction Time: Groundwater treatment, if determined to be necessary, could be implemented at AVX or
Loohns within 9 to 12 months. Groundwater treatment at McGraw Edison, could be implemented within 3 to 6
months, since an air stripper with sufficient excess capacity already exists on site. McGraw Edison
installed the air stripper in the early 1980's treat groundwater for industrial use on-site.

Alternative 4 - Soil Vapor Extraction (SVE)/Vacuum Enhanced Recovery (VER) and Groundwater Treatment

This alternative consists of implementing the following:

! SVE/VER of contaminated soil.
! Monitoring programs at selected monitoring wells and at Clean Well Field Municipal wells.
! Implementation of groundwater treatment if SVE does not result in sufficiently lower contaminant
concentrations in the groundwater.
! Access restrictions (if necessary).

Stage 1

Two different types of in-situ treatment systems were considered for treating VOCS contaminated soil: SVE
with Air Sparging (SVE/AS) and Vacuum Enhanced Recovery (VER).

Evaluations of the Alcas and AVX properties determined that a SVE/AS treatment system would not be effective.
However, pilot tests were conducted at the sources areas in 1994 and the tests confirmed that vacuum enhanced

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recovery (VER) could effectively desorb VOCs from the contaminated subsurface at both properties. Additional
data needs to be collected for the Loohns property in order to determine whether SVE/AS or VER would be the
nore effective means of soil treatment. EPA intends to collect this data during a pilot test, which would be
conducted as part of a remedial design for the Loohns source area.

Descriptions of VER and SVE/AS are provided as follows:

An SVE/AS system would use a soil vapor recovery process, which is discussed above, combined with air
injection wells which would extend below the water table. Air, which is injected under pressure into the
wells, would enter water below the water table. The air bubbles, which are formed, traverse horizontally and
vertically through the water column. Volatile compounds, which are exposed to the sparged air, volatilize
into the gas phase and are carried into the vadose zone where they are captured by the vapor recover system.
An off-gas treatment system will use granulated activated carbon (GAG) to remove contaminants which are above
federal and New York State air emission levels. Any groundwater which is recovered with the soil vapor,
would also be treated GAG prior to discharge to the City sewer system or to the surface water with a New York
State Pollutions Discharge Elimination System permit.

Essentially, a VER system works by applying a higher vacuum to the subsurface than a SVE/AS system. The
higher vacuum allows VER to operate more effectively than SVE/AS in varied geological settings.

Stage 2

After soil remediation is completed at Alcas, AVX and Loohns, EPA will assess the affect on the groundwater
after waiting the time for three pore volumes of groundwater to travel from all three source area properties
to the municipal wells. EPA has calculated that it will take four years for three pore volumes of
groundwater to pass, or flush through, from the source areas to the municipal wells. Therefore, the
groundwater quality will be monitored. The effectiveness of the remediation will be evaluated at four year
intervals. If it is determined that the city aguifer still contains contaminant concentrations above
drinking water standards and if it is determined that the remediated source area continues to affect the
groundwater entering the City Municipal wells 18M, 37M and 38M, a groundwater pump-and-treat system may be
installed at either the AVX or the Loohns Dry Cleaners source areas. However, such treatment will not be
necessary at the ALCAS source area due to the close proximity of the source area to municipal well 18M.

Capital, present worth and operation and maintenance costs for this alternative are summarized in Table 2.
Costs were developed by source area. Capital costs were developed for the construction of SVE/ER systems at
the source areas and construction of groundwater collection and treatment systems at the Loohns and AVX
source areas. The capital costs for the Alcas source area does not include groundwater treatment, since
contaminated groundwater from the source area will be captured and treated by the air stripper at municipal
well M18. Operation and maintenance and present worth costs were developed for maintenance of an SVE/VER

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system for five years and groundwater treatment system for thirty years and Site-wide sampling and analysis
of the groundwater for thirty years.

Construction Time: Installation of SVE/ER system at the source area properties could be implemented within
one year. Groundwater treatment, if determine to be necessary, could be implemented within 9 to 12 months
after the date of the decision is made.

Alternative 5 - Soil Removal And Groundwater Treatment

Alternative 5 would consist of implementing the following:

Stage 1

The soil source area(s) would be excavated and the soils tested to determine if the excavated soils are
classified as RCRA hazardous waste material. If hazardous, the soils would be transported off-Site to a
facility for low temperature desorption of soil contaminants. If not hazardous, the soils would be disposed
of at a local landfill. Clean fill material would be brought in to restore each of the areas to grade.
Confirmatory soil sampling and analyses would be conducted during soil excavation to ensure that all soils
with contaminant levels higher than the levels indicated in Table 1 are removed.

Until restoration of the excavated areas is complete, land use/access restrictions (if necessary) would be
placed on the source area restricting current and future use. During all phases of the soil removal, it
would be necessary to implement dust and volatile emission control measures, soil erosion, and sediment
control measures.

Stage 2

After soil remediation is completed at Alcas, AVX and Loohns, EPA will assess the affect on the groundwater
after waiting the time for three pore volumes of groundwater to travel from all three source area properties
to the municipal wells. EPA has calculated that it will take four years for three pore volume of groundwater
to pass, or flush through, from the source areas to the municipal wells. Therefore, the groundwater guality
will be monitored. The effectiveness of the remediation will be evaluated at four year intervals. If it is
determined that the city aguifer still contains contaminant concentrations above drinking water standards and
if it is determined that the remediated source area continues to affect the groundwater entering the City
Municipal wells 18M, 37M and 38M, a groundwater pump-and-treat system may be installed at either the AVX or
the Loohns Dry Cleaners source areas. However, such treatment will not be necessary at the ALCAS source area
due to the close proximity of the source area to municipal well 18M.

If groundwater treatment is determined to be necessary for the AVX source area, EPA will also evaluated the
impact of a groundwater pump and treat system on the wetlands area. This evaluation will weigh the need for
reducing contaminant concentrations in the groundwater with any potentially adverse affect on the wetlands
area.

Capital, present worth and operation and maintenance costs for this alternative are summarized in Table 2.
Costs were developed by source area. Capital costs were developed for the construction of SVE/VER systems at
the source areas and construction of groundwater collection and treatment systems at the Loohns and AVX
source areas. The capital cost for the Alcas source area does not include groundwater treatment, since
contaminated groundwater from the source area will be captured and treated by the air stripper at municipal
well M18. Operation and maintenance and present worth costs were developed for maintenance of an SVE/VER
system for five years and groundwater treatment system for thirty years and Site-wide sampling and analysis

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of the groundwater for thirty years.

Construction Time: Installation of SVE/VER system at the source area properties could be implemented within
one year. Groundwater treatment, if determine to be necessary, could be implemented within 9 to 12 months
after the date of the decision is made.

Alternative 5 - Soil Removal And Groundwater Treatment

Alternative 5 would consist of implementing the following:

Stage 1

The soil source area(s) would be excavated and the soils tested to determine if the excavated soils are
classified as RCRA hazardous waste material. If hazardous, the soils would be transported off-Site to a
facility for low temperature desorption of soil contaminants. If not hazardous, the soils would be disposed
of at a local landfill. Clean fill material would be brought in to restore each of the areas to grade.
Confirmatory soil sampling and analyses would be conducted during soil excavation to ensure that all soils
with contaminant levels higher than the levels indicated in Table 1 are removed.

Stage 2

After soil remediation is completed at Alcas, AVX and Loohns, EPA will assess the affect on the groundwater
after waiting the time for three pore volumes of groundwater to travel from all three source area properties
to the municipal wells. EPA has calculated that it will take four years for three pore volume of groundwater
to pass, or flush through, from the source areas to the municipal wells. Therefore, the groundwater guality
will be monitored. the effectiveness of the remediation will be evaluated at four year intervals. If it is
determined that the city aguifer still contains contaminant concentrations above drinking water standards and
if it is determined that the remediated source area continues to affect the groundwater entering the City
Municipal wells 18M, 37M and 38M, a groundwater pump-and-treat system may be installed at either the AVX or
the Loohns Dry Cleaners source areas. However, such treatment will not be necessary at the ALCAS source area
due to the close proximity of the source area to municipal well 18M.

Capital, present worth and operation and maintenance costs for this alternative are summarized in Table 2.
Costs were developed by source area. Capital costs were developed for the removal of contaminated soil at
each source area and construction of groundwater collection and treatment systems at the Loohns and AVX
source areas. The capital costs for the Alcas source area does not include groundwater treatment, since
contaminated groundwater from the source area will be captured and treated by the air stripper at municipal
well M18. Operation and maintenance and present worth costs were developed for maintenance of the
groundwater treatment systems for thirty years and Site-wide sampling and analysis of the groundwater for
thirty years.

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Construction Time: Removal of contaminated soil from Alcas, AVX and Loohns could be implemented within one
year. Groundwater treatment, if determined to be necessary, could be implemented within 1 year after the date
of the decision is made.

EVALUATION OF ALTERNATIVES

During the detailed evaluation of remedial alternatives, each alternative is assessed against nine evaluation
criteria, specified in the National Contingency Plan at 40 CFR § 300.430 (e) (9) (iii), namely, overall
protection of human health and the environment, compliance with applicable or relevant and appropriate
reguirements, long-term effectiveness and permanence, reduction of toxicity, mobility, or volume, short-term
effectiveness, implementability, cost, and state and community acceptance.

The evaluation criteria are described below.

! Overall protection of human health and the environment addresses whether or not a remedy provides
adeguate protection and describes how risks posed through each pathway are eliminated, reduced,or
controlled through treatment, engineering controls,or institutional controls.

! Compliance with applicable or relevant and appropriate reguirements (ARARs) addressed whether or not a
remedy will meet all of the applicable or relevant and appropriate reguirements of other federal and
state environmental statutes and reguirements or provide grounds for invoking a waiver.

! 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.

! Reduction of toxicity, mobility, or volume through treatment is the anticipated performance of the
treatment technologies a remedy may employ.

! Short-term effectiveness addresses the period of time needed to achieve protection and any adverse
impacts on human health and the environment that may be posed during the construction and
implementation period until cleanup goals are achieved.

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

! Cost includes estimated capital and operation and maintenance costs, and net present worth costs.

! State acceptance indicates whether, based on its review of the RI/FS reports and Proposed Plan, the
state concurs, opposes, or has no comment on the preferred alternative at the present time.

! Community acceptance will be assessed in the Record of Decision (ROD) following a review of the public
comments received on the RI/FS reports and the Proposed Plan.

The following is a comparative analysis of these alternatives by source area, which is based upon the
evaluation criteria noted above:

ALCAS SOURCE AREA

This subsection presents the comparative analysis of alternatives for the Alcas source area. Available data
for this source area indicated that the upper aguifer cannot effectively be pumped, and that the lower
aguifer is within the capture zone of the municipal wells. Therefore, groundwater treatment via
pump-and-treat (Alternative 3A and Stage 2 of Alternative 3, 4 and 5) is not considered applicable for the
Alcas source area.

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that vacuum enhanced recovery (VER) could effectively desorb VOCs from the contaminated subsurface.
Effective mass removal of VOCs was observed during the test for both the vapor and the dissolved phases.

Overall Protection of Human Health and the Environment

Alternative 2 (Institutional Controls) provides a slightly higher level of protection of human health, since
groundwater and land use restrictions would be implemented to reduce exposures to contaminated soil and
groundwater; however, since no remediation of contamination takes place under this alternative, it is not
protective of the environment. This alternative would meet only some of the RAOs for the Site, since it
prevents exposure to contaminants, but does not provide treatment of the source area to expedite cleanup of
the city aguifer.

Alternative 3 (Capping) would reduce the risk of exposure to contaminated soils and potentially reduce the
migration of contaminants from this source area to the groundwater. After implementation of the alternative,
the risk of exposure to contaminated soils would be reduced. Groundwater and land use restrictions would be
implemented to further reduce the risk of exposures and to ensure cap integrity. This alternative should
meet the groundwater RAOs by preventing exposures to contaminants and reducing migration of contaminants from
the source area to the groundwater, thereby expediting cleanup of the city aguifer. However, there is a
probability that after implementation of this alternative, migration of contaminants from the source area
could continue as a result of groundwater flow beneath the cap, with the result that cleanup of the city
aguifer is not expedited.

Compliance with ARARs

Chemical-, location-and action-specific ARARs were evaluated for the Alcas source area. The major ARARs
considered included: state and federal maximum contaminant levels (MCLs) for drinking water
(chemical-specific ARARs); historic preservation reguirements (location-specific ARARs); and, RCRA hazardous
waste generator, transporter and treatment, storage and disposal reguirements (action-specific ARARs).

Alternatives 1 and 2 would not comply with chemical-specific ARARs. Existing contaminant concentrations in
the groundwater, which already exceed chemical-specific ARARs, would continue to exceed these levels, with a
potential increase in contaminant levels, since the Alcas source area would continue to contribute
contamination to the aguifer. Alternative 1 involves no remedial activities, and therefore does not trigger
any location-or action-specific ARARs. Alternative 2 would be implemented in such a manner so as to comply
with location-and action-specific ARARs, if any are triggered by these activities. Neither of these
alternatives would comply with the soil Remedial Action Objectives (RAOs), which are TBCs (to be considered
levels) for soil remediation.

Alternative 3 would not initially comply with chemical-specific ARARs for the groundwater, since the
contaminant concentrations would not be immediately reduced by implementation of this alternative. However,
by reducing the migration of contaminants from the soil it is expected that this alternative could result in
compliance with the chemical-specific ARARs. This alternative may not fully comply with soil RAOs since it
may not be 100% effective in reducing the migration of contaminants from the soil. Compliance with
location-and action-specific ARARs would be achieved through proper implementation of this alternative.

Alternative 4 would not initially comply with chemical-specific ARARs, since the groundwater contaminant

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concentrations would not be immediately reduced by implementation of this alternative. However, significant
quantities of contaminants in both the soil and groundwater would be removed by VER, thereby eliminating
additional contributions of contamination to the city aguifer and eventually resulting in compliance with
chemical-specific ARARs. Proper design and implementation of the VER system and treatment of the extracted
groundwater and vapor would ensure that the implementation of this alternative would be in compliance with
location-and action-specific ARARs. This alternative, upon completion of VER treatment, would also be in
compliance with the soil RAOs.

Alternative 5 would provide the most rapid compliance with chemical-specific ARARs, since the groundwater
contaminant concentrations would be rapidly reduced by implementation of this alternative. Contaminated
soil, including an extensive amounted of soil in the saturated zone, that is acting as a source of
contamination to the groundwater would be removed in this alternative, thereby eliminating additional
contributions of contamination to the city aguifer and resulting in compliance with chemical-specific ARARs.
Proper design and implementation of the excavation, transportation and disposal of the contaminated soil
would ensure that the implementation of this alternative would be in compliance with location-and
action-specific ARARs. This alternative would also be in compliance with the soil RAOs.

Short-term Effectiveness

Alternative 1 involves no remedial activities, and therefore results in no increase in short-term risks
to-workers or the community. Implementation of this alternative would be immediate.

Alternative 2 includes administrative actions and minimal construction activities (e.g., fence construction).
Workers and the nearby community would be subject to a slightly increased risk of exposure to contaminants
due to disturbance of contaminated soil during these activities. These risks would be minimized through the
implementation of a site-specific health and safety plan and appropriate engineering controls (e.g., dust
suppression). Implementation of this alternative could be completed in approximately 6 months.

Alternative 4 includes construction activities; however, as this alternative involves in situ treatment, the
disturbance of contaminated soils during construction activities would be limited. Any increased risks due
to disturbance of contaminated soil would be mitigated through the implementation of a site-specific health
and safety plan and appropriate engineering controls (e.g., dust suppression). Design and installation of
the VER system could be completed in approximately 1 year. Operation of the system should not result in any
increased risk of exposure.

Long-term Effectiveness

Alternative 1 does not remove or contain the source of contamination. Therefore, the current risks from
exposure to contaminated groundwater and soil would remain, and future risk may even be greater as the source
area continues to release contaminants to the groundwater. Long-term monitoring and assessment would be
required under this alternative, and there is the potential that additional remedial activities might be
necessary in the future.

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Alternative 2 also does not remove or contain the source of contamination, but does provide some reduction in
the risk of exposure to contaminated soil and groundwater via access and use restrictions, provide these
restrictions are adequately maintained and enforced. Long-term monitoring would be required under this
alternative, and there is the potential that additional remedial activities might be necessary in the future.
In addition, it would be very difficult to maintain institutional controls in the long term.

Alternative 3 provides containment of the contaminated source area, which would reduce the risk of exposure
to contaminated soil and would reduce migration of contaminants from the source area to groundwater.
Long-term monitoring and maintenance would be required under this alternative to ensure the integrity of the
cap. It is possible that the cap may not prevent migration of contamination from the source area to the
groundwater, and that additional remedial activities could be necessary in the future.

Reduction of Toxicity, Mobility or Volume Through Treatment

Alternatives 1 and 2 provide no removal or treatment of contaminated soils or groundwater, and therefore
provide no reduction in toxicity, mobility or volume of contaminated materials.

Alternative 3, if properly maintained, should reduce the mobility of contaminants without treatment, thereby
minimizing additional contamination of the groundwater form this source area. This alternative does not
provide any reduction in toxicity or volume of contaminated material.

Alternative 5 provides a reduction in toxicity, mobility and volume of contaminated soil by excavation and
off-Site treatment and disposal of contaminated media. Contaminated soil removed from the Site would no
longer pose any risk of further contamination of the groundwater.

Implementability

Alternative 1 would be easily implemented, as it does not include any remedial activities. Alternative 2 may
be difficult to implement, since it reguires cooperation from individual property owners, which would be
difficult to enforce. Minor construction activities (e.g., fence) included in this alternative would be easy
to implement, and would not require a significant administrative effort. Long-term maintenance would be
required for Alternative 2.

Capping (Alternative 3) is a readily available and well-developed technology that could be completed using
conventional construction techniques. Long-term maintenance of the cap would be required.

For Alternative 4, on-site construction activities would be minor, consisting of well installation and

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construction or mobilization of a small treatment system. This would result in a minimal disruption of
facility operations and would also minimize any effects to the on-site building, which may be situated close
to or over the subsurface contamination. In addition, a VER system may be modified, as necessary, to
remediate larger or inaccessible areas. However, in situ treatment technologies are still considered
innovative, and there are only a small number of vendors offering these services. In addition, effective
operation requires intensive monitoring and assessment. Administratively, coordination with local
authorities and other agencies may be required for the discharge of treated water and vapor; however, this
alternative does not involve any off-site transportation of hazardous materials.

Alternatives 5 would require excavation to depths of approximately 16 feet with approximately 12 feet below
the water table. Dewatering and shoring would be required; however, this alternative could be implemented
using conventional construction techniques. Off-Site RCRA storage, treatment and disposal facilities are
available for treatment and disposal of VOCS contaminated soil. Administratively, this alternative would
require coordination with the local authorities and other agencies for transportation, treatment and disposal
of hazardous materials.

Cost

The 30-year net present worth (NPW) of the remedial alternatives for the Alcas source area range from $0 to
$1,013,495 based on a discount rate of 7%. Alternatives 1 and 2 are the least expensive to implement, with
NPWs of $0 and $152,295, respectively. Alternative 3 is slightly more expensive, with a NPW of $298,158.
Alternative 4 is significantly more expensive, with a NPW of $837,721. Alternative 5 is the most expensive,
with a NPW of $1,013,495. Cost estimates are summarized in Table 2.

AVX SOURCE AREA

Overall Protection of Human Health and the Environment

Alternative 1 (No Action) is not protective of human health and the environment. Existing restrictions on
groundwater use would remain, but no further restrictions would be implemented. This alternative would not
meet the remedial action objectives (RAOs) for the Site.

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city aquifer. The groundwater quality will be monitored and the effectiveness of the remediation reevaluated
at four year intervals. If it is determined that the city aquifer still contains contaminant concentrations
above drinkinq water standards and if it is determined that the remediated source area continues to affect
the qroundwater enterinq the City Municipal wells M18, M37 and M38, a qroundwater pump-and-treat system may
be installed. Proper operation and maintenance of this system would ensure that the RAOs for qroundwater
would be achieved.

Alternative 3A (Groundwater Pump-and-Treat) is identical to the pump-and-treat portion (i.e., staqe 2) of
Alternative 3, the difference beinq that the qroundwater treatment system would be installed immediately upon
selection of this alternative. The evaluation is identical to staqe 2 of Alternative 3.

Alternative 4 (Vacuum Enhanced Recovery) and 5 (Excavation, Treatment and Disposal), which both include
reduction or elimination of the source area by removal and treatment, would be protective of human health and
the environment. Alternative 4 would reduce the level of contaminants in the source area usinq vacuum
enhanced recovery (VER), while Alternative 5 would completely eliminate the identified source area by
excavation and off-Site treatment and disposal. Upon completion of either Alternative 4 or 5, the RAOs for
the Site should be achieved. The qroundwater quality will be monitored and the effectiveness of the
remediation reevaluated at four year intervals. If it is determined that the city aquifer still contains
contaminant concentrations above drinkinq water standards and if it is determined that the remediated source
area continues to affect the qroundwater enterinq the City Municipal wells M18, M37 and M38, a qroundwater
pump-and-treat system may be installed. Proper operation and maintenance of this system would ensure that
the RAOs for qroundwater would be achieved.

Compliance with ARARs

Chemical, location and action-specific ARARs were evaluated for the AVX source area. The major ARARs
considered included: state and federal maximum contaminant levels (MCLs) for drinkinq water
(chemical-specific ARARs); wetlands protection and historic preservation requirements (location-specific
ARARs); and, RCRA hazardous waste qenerator, transporter and treatment, storaqe and disposal requirement
(action-specific ARARs).

Alternatives 1 and 2 would not comply with chemical-specific ARARs. Existinq contaminant concentrations in
the qroundwater, which already exceed chemical-specific ARARs, would continue to exceed theses level, with a
potential increase in contaminant levels, since the AVX source area would continue to contribute
contamination to the aquifer. Alternative 1 involves no remedial activities, and therefore does not triqqer
any location- or action-specific ARARs. Alternative 2 would be implemented in such a manner so as to comply
with location- and action-specific ARARs, if any are triqqered by these activities. Neither of these
alternatives would comply with the soil RAOs.

Alternative 3 would not initially comply with chemical-specific ARARs for the qroundwater, since the
contaminant concentrations would not be immediately reduced by implementation of this alternative. However,
by reducinq the miqration of contaminant from the soil it is expected that this alternative could result in
compliance with the chemical-specific ARARs. This alternative may not fully comply with soil RAOs since it
may not be 100% effective in reducinq the miqration of contaminants from the soil. Staqe 2, if required,
would supplement staqe 1 to brinq this area into compliance with ARARs. Throuqh proper implementation of
this alternative, compliance with location- and action-specific ARARs would be achieved. This alternative
would not comply with the soil RAOs, since it does not include removal of contaminated soil.

It would take lonqer to come into compliance with Alternative 3A, with chemical-specific ARARs for
qroundwater than those alternatives that include source area remediation of the soil (i.e., Alternative 3, 4
and 5), since contamination could continue to miqrate from the contaminated soil source area, which is not
remediated under this alternative. Throuqh proper implementation of this alternative, compliance with
location- and action-specific ARARs would be achieved. This alternative would not comply with the soil RAOs,
since it does not include removal of contaminated soil, which would eliminate the leachinq of VOCs into the
qroundwater.

Alternative 4 would not initially comply with chemical-specific ARARs, since the qroundwater contaminant

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concentrations would not be immediately reduced by implementation of this alternative. However, significant
quantities of contaminants in both the soil and groundwater would be removed by VER, thereby eliminating
additional contributions of contamination to the city aguifer and eventually resulting in compliance with
chemical-specific ARARs. It is expected that compliance with chemical-specific ARARs would be achieved over
time. However, if groundwater ARARs are not achieved, a groundwater pump-and-treat system may be installed
to ensure compliance with ARARs. Proper design and implementation of the VER system and the groundwater
pump-and-treat system (if necessary) would ensure that the implementation of both stages of this alternative
would be in compliance with location-and action-specific ARARs. This alternative, upon completion of VER
treatment (stage 1), would also be in compliance with the soil RAOs.

Alternative 5 would provide the most rapid compliance with chemical-specific ARARs, since the groundwater
contaminant concentrations would be rapidly reduced by implementation of this alternative. Contaminated soil
that is acting as a source of contamination to the groundwater would be removed in this alternative, thereby
eliminating additional contributions of contamination to the city aguifer and resulting in compliance with
chemical-specific ARARs. If it is determined that chemical-specific ARARs in the groundwater are not
achieved, a groundwater pump-and-treat system may be installed to ensure compliance with groundwater ARARs.
Proper design and implementation of the excavation, transportation and disposal of the contaminated soil and
proper operation of the pump-and-treat system (if necessary) would ensure that the implementation of both
stages of this alternative would be in compliance with location- and action-specific ARARs. This
alternative, upon completion of soil excavation and disposal (stage 1), would also be in compliance with the
soil RAOs.

Short-term Effectiveness

Alternative 1 involves no remedial activities, and therefore results in no increase short-term risks to
workers or the community. Implementation of this alternative would be immediate.

Alternative 2 includes administrative actions and minimal construction activities (e.g., fence construction).
Workers and the nearby community would be subject to a slightly increased risk of exposure to contaminants
due to disturbance of contaminated soil during these activities. These risks would be minimized through the
implementation of a Site-specific health and safety plan and appropriate engineering controls (e.g., dust
suppression). Implementation of this alternative could be completed in approximately 6 months.

Alternative 3 includes construction activities for placement of a cap over the source area. Workers and the
nearby community would be subject to an increased risk of exposure to contaminants due to disturbance of
contaminated soil (e.g., grading) during these activities. These risk would be minimized through the
implementation of a site-specific health and safety plan (e.g., use of personal protective equipment) and
appropriate engineering controls (e.g., dust suppression). Implementation of stage 1 of this alternative
could be completed in approximately 1 year. If it is determined that stage 2 of this alternative (i.e.,
groundwater pump-and-treat) is required, there would be additional Site disturbances during construction of
this system, resulting in additional risks of exposures to contaminated groundwater for workers. Workers may
also be exposed to excessive noise during construction activities. These risks would be minimized through
the implementation of a site-specific health and safety plan. There would be no increased risk to the public
during construction of the pump-and-treat system, since contaminated soil would be contained beneath the cap;
however, operation of the pump-and-treat system might pose slightly increased risk of exposures to the public
from fugitive air emissions. These risks would be mitigated by proper design and operation of the system and
compliance with any emissions control requirements. Implementation of stage 2 could be completed in
approximately 1 year; however, the pump-and-treat system would be operated for an extended period of time (up
to 30 years). The short-term effectiveness of Alternative 3A is identical to the short-term effectiveness of
stage 2 of Alternative 3.

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pump-and-treat) is required, there would be additional Site disturbances during construction of this system,
resulting in additional risks of exposures  to contaminated groundwater for workers; however, there would be
no increased risk to the public, since contaminated soil would have already been remediated during stage 1 of
this alternative.  Implementation of stage 2 could be completed in approximately 1 year; however, the
pump-and-treat system would be operated for an extended period of time  (e.g., 30 years).

Alternative 5 includes the most intensive construction activities, including excavation and off-Site
transportation of contaminated soil.  Workers and the nearby community would be subject to an increase in the
risk of exposure to contaminants due to disturbance of contaminated soil during excavation and transportation
of contaminated materials for off-Site treatment  (if necessary) and disposal.  These risks would be mitigated
by implementation of a site-specific health and safety plan, a site-specific traffic control plan and
appropriate engineering controls (e.g., dust suppression).  This alternative could be completed in
approximately 1 year.  If it is determined that stage 2 of this alternative  (i.e., groundwater
pump-and-treat) is required, there would be additional site disturbances during construction of this system,
resulting in additional risk of exposures to contaminated groundwater for workers; however, there would be no
increased risk to the public, since contaminated soil would have already been remediated during stage 1 of
this alternative.  The groundwater pump-and-treat system might pose slightly increased risk of exposures to
the public from fugitive air emissions these risks would be mitigated by proper design and operation of the
system and compliance with any emissions control requirements.  Implementation of stage 2 could be completed
in approximately 1 year; however, the pump-and-treat system would be operated for an extended period of time
(e.g., 30 years).

Long-term Effectiveness

Alternative 1 does not remove or contain the source of contamination.  Therefore, the current risks from
exposure to contaminated groundwater and soil would remain, and future risk may even be greater as the source
area continues to release contaminants to the groundwater.  Long-term monitoring and assessment would be
required under this alternative, and there is the potential that additional remedial activities might be
necessary in the future.

Alternative 2 also does not remove or contain the source of contamination, but does provide some reduction in
the risk of exposure to contaminated soil and groundwater via access and use restrictions, provided these
restrictions are adequately maintained and enforced.  Long-term monitoring would be required under this
alternative, and there is the potential that additional remedial activities might be necessary in the future.
In addition, it would be very difficult to maintain institutional controls in the long term.

Alternative 3 provides containment of the contaminated source area, which would reduce the risk of exposure
to contaminated soil and reduce migration of contaminants from the source area to groundwater.  Long-term
monitoring and maintenance would be required under this alternative to ensure the integrity of the cap.  It
is possible that the cap may not prevent migration of contamination from the source area to the groundwater,
and that additional remedial activities could be necessary in the future.  Implementation of the stage 2
pump-and-treat system would provide and additional reduction in the risk of exposure to contaminated
groundwater by preventing further migration of contamination from this source.

Alternative 3A provides some containment of the source area by preventing migration of contamination, but
would not be as protection as Alternative 3, which includes the cap and the pump-and-treat system (if
necessary).

Alternative 4 provides treatment of both the source area and associated groundwater.  This alternative
provides a permanent remedy for the contaminated source area, including source areas below the water table,
since contaminants are removed from the soil; however, as with any in situ treatment, it would be difficult
to assess the level of treatment achieved in the subsurface soils.  During the operation of, and upon
completion of, the VER treatment, long-term monitoring would be required to assess the completeness of the
remediation and to monitor improvements in the quality of the city aquifer, however, no further remediation
of the source area should be required.  If it is determined that stage 1 of this alternative has not
adequately addressed the source area, groundwater remediation, stage 2, may be implemented. Implementation of
the stage 2 pump-and-treat system would provide an additional reduction in the risk of exposure to

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contaminated groundwater by preventing further migration of contamination from this source.

Alternative 5 provides removal of the source areas. This alternative provides a permanent remedy, in that
contaminated soils removed from the Site would not pose any future risk and would not be subject to any
further remedial action in the future. No long-term monitoring or maintenance would be reguired for the
source area; however, long-term monitoring would be reguired under this alternative to monitor improvements
in the guality of the city aguifer. If it is determined that stage 1 of this alternative has not adeguately
improved the guality of the city aguifer, stage 2 may be implemented. Implementation of the stage 2
pump-and-treat system would provide an additional reduction in the risk of exposure to contaminated
groundwater be preventing further migration of contamination from this source.

Reduction of Toxicity, Mobility or Volume through Treatment

Alternatives 1 and 2 provide no removal or treatment of contaminated soils or groundwater, and therefore
provide no reduction in toxicity, mobility or volume of contaminated materials.

The cap that would be installed in stage 1 of Alternative 3, if properly maintained, should reduce the
mobility of contaminants, without treatment, thereby minimizing additional contamination of the groundwater
from this source area. If the stage 2 pump-and-treat system is implemented, this system would further reduce
the toxicity, mobility and volume of contamination by extracting contaminated groundwater and preventing
off-Site migration. The reduction in toxicity, mobility and volume for Alternative 3A is identical to stage
2 of Alternative 3.

Stage 1 of Alternative 5 provides a reduction in toxicity, mobility and volume of contaminated soil be
excavation and off-Site treatment and disposal of contaminated media. Contaminated soil removed from the
Site would no longer pose any risk of further contamination of the groundwater. If stage 1 does not
adeguately meet the RAOs and stage 2 is implemented, the groundwater pump-and-treat system would further
reduce the toxicity, mobility and volume of remaining contamination by extracting contaminated groundwater
and preventing off-Site migration.

Implementability

Alternative 1 would be easily implemented, as it does not include any remedial activities. Alternative 2 may
be difficult to implement, since it reguires cooperation from individual property owners, which is difficult
to enforce. Minor construction activities (e.g., fence) included in this alternative would be easy to
implement, and would not reguire a significant administrative effort. Long-term maintenance would be
reguired for Alternative 2.

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effective operation requires intensive monitoring and assessment. Administratively, coordination with local
authorities and other agencies may be required for the discharge of treated water and vapor; however, this
alternative does not involve any off-Site transportation of hazardous materials. If stage 2 of this
alternative is required, it would be relatively easy to implement technically, since groundwater
pump-and-treat systems consist of readily available technologies and are routinely installed at sites with
contaminated groundwater. Administratively, the requirements would be similar to the VER system
requirements.

Alternative 5 would require excavation to depths of approximately 6 feet in close proximity to on-site
structures. Dewatering and shoring would be required; however, this alternative could be implemented using
conventional construction techniques. Given the shallow depth of contamination, technical implementation of
this alternative would not be difficult. Off-Site RCRA storage, treatment and disposal facilities are
available for treatment and disposal of VOCS contaminated soil. Administratively, this alternative would be
moderately difficult to implement, since it would require coordination with the local authorities and other
agencies for transportation, treatment and disposal of hazardous materials. If stage 2 of this alternative
is required, it would be relatively easy to implement technically, since groundwater pump-and-treat systems
consist of readily available technologies and are routinely installed at sites with contaminated groundwater.
Administratively, coordination with local authorities may be required for the discharge of treated water and
emissions from the treatment system.

Cost

The 30-year net present worth (NPW) of the remedial alternatives for the AVX source area range from $0 to
$1,747,533 based on a discount rate of 7%. Alternatives 1 and 2 are the least expensive to implement, with
NPWs of $0 and $165,295, respectively, Alternative 3 (stage 1) is slightly more expensive, with a NPW of
$187,113. If stage 2 of Alternative 3 is implemented, the overall cost of this alternative is approximately
$821,117, but treatment of contaminated groundwater is provided. Alternative 3A, which includes
pump-and-treat for a longer period of time, but no capping, has a cost of $1,070,610. Alternative 4 (stage
1) is significantly more expensive than Alternative 3 (stage 1), with a NPW of $1,113,529. If stage 2 of
Alternative 4 is implemented, the cost increase to $1,747,533, and additional groundwater treatment is
provided. Alternative 5 (stage 1) is significantly less costly than Alternative 4 (stage 1), with a NPW of
$376,295. If stage 2 of Alternative 5 is implemented, groundwater treatment is provided, and the NPW is
$1,010,299. Cost estimates are summarized in Table 2.

McGRAW EDISON SOURCE AREA

This subsection presents the comparative analysis of alternatives for the McGraw Edison source area.
Available data indicate that there is no contaminated soil source in this area. Therefore, Alternatives 3, 4
and 5, which all specify some kind of soil remediation, are not applicable. Alternative 3A, which specifies
groundwater pump-and-treat, is applicable and was evaluated for this area.

Overall Protection of Human Health and the Environment

Alternative 1 (No Action) is not protective of human health and the environment. Existing restrictions on
groundwater use would remain, but no further restrictions would be implemented. This alternative would not
meet the remedial action objectives (RAOs) for the Site.

Alternative 2 (Institutional Controls) provides a slightly higher level of protection of human health, since
groundwater use restrictions would be implemented to reduce exposures to contaminated groundwater. However,
since no remediation of contamination takes place under this alternative, it is not protective of the
environment. After implementation of the alternative, risks of exposure would be reduced as long as the
administrative restrictions were maintained. This alternative would meet only some of the RAOs for the Site,
since it prevents exposure to contaminants, but does not provide any treatment to expedite cleanup of the
city aquifer.

Alternative 3A would be implemented immediately at the McGraw Edison site, since there is no soil source area
to be remediated. Proper operation and maintenance of the groundwater pump-and-treat system would ensure

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that the RAOs for groundwater would be achieved. Extraction of contaminated groundwater will protect human
health and the environment by removing contamination from the aguifer and preventing migration of
contaminants from this area to the municipal well field.

Compliance with ARARs

Chemical, location and action-specific ARARs were evaluated for the McGraw Edison source area. The major
ARARs considered included: state and federal maximum contaminant levels (MCLs) for drinking water
(chemical-specific ARARs); historic preservation reguirements (location-specific ARARs); and, RCRA hazardous
waste generator, transporter and treatment, storage and disposal reguirements (action-specific ARARs).

Alternatives 1 and 2 would not comply with chemical-specific ARARs. Existing contaminant concentrations in
the groundwater, which already exceed chemical-specific ARARs, would continue to exceed these levels for an
extended period of time. Alternative 1 involves no remedial activities, and therefore does not trigger any
location- or action-specific ARARs. Alternative 2 would be implemented in such a manner so as to comply with
location- and action-specific ARARs, if any are triggered by thee activities.

Alternative 3A would not initially comply with chemical-specific ARARs, since the groundwater contaminant
concentrations would not be immediately reduced by implementation of this alternative. However, by treating
the groundwater beneath the McGraw Edison site, further contamination migration to the municipal supply wells
would be eliminated, eventually resulting in compliance with chemical-specific ARARs. Through proper
implementation of this alternative, compliance with location- and action-specific ARARs would be achieved.
The soil RAOs do not apply to the McGraw Edison site, since there are no identified areas of soil
contamination.

Short-term Effectiveness

Alternative 1 involves no remedial activities, and therefore results in no increase in short-term risks to
workers or the community. Implementation of this alternative would be immediate.

Alternative 2 includes only administrative actions, since no access restrictions are reguired at the McGraw
Edison site. Therefore, there would be no change in the risks to workers or the nearby community during
implementation of this alternative. Implementation of this alternative could be completed in approximately 3
months.

Alternative 3A includes installation of a groundwater pump-and-treat system. As there is already a well and
an air stripper on site, only minimal construction activities would be reguired to upgrade the treatment
system and install one or more wells in the shallow aguifer. Workers would be subject to a slightly
increased risk of exposure to contaminated groundwater and exposure to noise during these activities. These
risks would be minimized through the implementation of a site-specific health and safety plan (e.g., use of
personal protective eguipment). Operation of the groundwater pump-and-treat system might pose slightly
increased risk of exposures to the public from fugitive air emissions; these risks would be mitigated by
proper design and operation of the system and compliance with any emissions control reguirements.
Implementation of the groundwater pump and treat system could be complete in approximately 3 to 6 months;
however, the pump-and-treat system would be operated for an extended period of time (e.g., 30 years).

Long-term Effectiveness

Alternative 1 does not remove or contain the contaminated groundwater. Therefore, the current risks from
exposure to contaminated groundwater persist, and future risk may even be greater as the contaminated
groundwater beneath the site continues to migrate. Long-term monitoring and assessment would be reguired
under this alternative, and there is the potential that additional remedial activities might be necessary in
the future.

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there is the potential that additional remedial activities might be necessary in the future. In addition, it
would be very difficult to maintain institutional controls in the long term.

Alternative 3A provides for removal and treatment of groundwater contaminants beneath the site, thereby
reducing the risk of exposure to contaminated groundwater and migration of contaminated groundwater off site.
Long-term monitoring would be reguired under this alternative to confirm the effectiveness of the system.
Aside from operation and maintenance of the groundwater pump-and-treat system, no further remedial actions
would be reguired in the future.

Reduction of Toxicity, Mobility or Volume through Treatment

Alternatives 1 and 2 provide no removal or treatment of contaminated soils or groundwater, and therefore
provide no reduction in toxicity, mobility or volume of contaminated materials.

Alternative 3A would reduce the toxicity, mobility and volume of contaminants in the groundwater via
extraction and treatment of contaminated groundwater beneath the site.

Implementability

Alternative 1 would be easily implemented, as it does not include any remedial activities. Alternative 2 may
be difficult to implement, since it deals with individual property rights. There are minimal construction
activities in this alternative as it applies to the McGraw Edison site. Long-term maintenance of
administrative actions would be reguired for Alternative 2.

Alternative 3A would be easily implemented, since it would reguire only well installation and possibly
upgrades to an existing groundwater treatment system (i.e., air stripper). As mentioned previously, McGraw
Edison installed the air stripper in the early 1980's to treat groundwater for industrial use on-site.
Administratively, coordination with local authorities may be reguired for the discharge of treated water and
emissions from the treatment system after these modifications are made.

Cost

The 30-year net present worth (NPW) of the remedial alternatives for the McGraw Edison site range from $0 to
$935,610 based on a discount rate of 7%. Alternatives 1 and 2 are the least expensive to implement, with
NPWs of $0 and $138,295, respectively. Alternative 3A has a NPW of $935,610. Cost estimates are summarized
in Table 2.

LOOHNS DRY CLEANERS AND LAUNDERERS

This subsection presents the comparative analysis of alternatives for the Loohns source area. Available date
indicated that both groundwater and soil are contaminated and are amenable to remediation. Therefore, the
evaluation presented in this subsection considers all stages of each of the alternatives.

Overall Protectional of Human Health and the Environment

Alternative 1 (No Action) is not protective of human health and the environment. Existing restrictions on
groundwater use would remain, but no further restrictions would be implemented. This alternative would not
meet the remedial action objectives (RAOs) for the Site.

Alternative 2 (Institutional Controls) provides a slightly higher level of protection of human health, since
groundwater and land use restrictions would be implemented to reduce exposures to contaminated soil and
groundwater; however, since no remediation of contamination takes place under this alternative, it is not
protective of the environment. After implementation of the alternative, risks would be slightly reduced as
long as the administrative and physical restrictions were maintained. This alternative would meet only some
of the RAOs for the Site, since it prevents exposure to contaminants, but does not provide treatment of the
source area to expedite cleanup of the city aguifer.

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Alternative 3 (Capping) would reduce the risk of exposure to contaminated soils and potentially reduce the
migration of contaminants from this source area to the groundwater. After implementation of the alternative,
the risk of exposure to contaminated soils would be reduced. Groundwater and land use restrictions would be
implemented to further reduce the risk of exposures and to ensure cap integrity. This alternative would
prevent exposure to soil contaminants, and should meet the RAOs for groundwater by reducing migration of
contaminants from the source area to the groundwater, thereby expediting cleanup of the city aguifer. The
groundwater will be monitored and the effectiveness of the remediation will be reevaluated at four year
intervals. If it is determined that the city aguifer still contains contaminant concentrations above
drinking water standards and if it is determined that the remediated source area continues to affect the
groundwater entering the City Municipal wells M18, M37 and M38, a groundwater pump-and-treat system may be
installed. Proper operation and maintenance of this system would ensure that the RAOs for groundwater would
be achieved.

Alternatives 4 (Vacuum Enhanced Recovery (VER) or Soil Vapor Extraction with Air Sparging (SVE/AS)) and 5
(Excavation. Treatment and Disposal), which both include reduction or elimination of the source area by
removal and treatment, would be protective of human health and the environment. Alternative 4 would reduce
the level of contaminants in the source area using VER or SVE/AS, while Alternative 5 would completely
eliminate the identified source area by excavation and off-Site treatment and disposal. Upon completion of
either of these alternatives, the RAOs for the Site should be achieved. The groundwater guality will be
monitored and the effectiveness of the remediation reevaluated at four year intervals. If it is determined
that the city aguifer still contains contaminant concentrations above drinking water standards and if it is
determined that the remediated source area continues to affect the groundwater entering the City Municipal
wells M18, M37 and M38, a groundwater pump-and-treat system may be installed. Proper operation and
maintenance of this system would ensure that the RAOs for groundwater would be achieved.

Compliance with ARARs

Chemical, location and action-specific ARARs were evaluated for the Loohns source area. The major ARARs
considered included: state and federal maximum contaminant levels (MCLs) for drinking water
(chemical-specific ARARs); historic preservation reguirements (location-specific ARARs); and, RCRA hazardous
waste generator, transporter and treatment, storage and disposal reguirements (action-specific ARARs).

Alternatives 1 and 2 would not comply with chemical-specific ARARs. Existing contaminant concentrations in
the groundwater, which already exceed chemical-specific ARARs, would continue to exceed these levels, with a
potential increase in contaminant levels, since the Loohns source area would continue to contribute
contamination to the aguifer. Alternative 1 involves no remedial activities, and therefore does not trigger
any location- or action-specific ARARs. Alternative 2 would be implemented in such a manner so as to comply
with location-and action-specific ARARs, if any are triggered by these activities. Neither of these
alternatives would comply with the soil RAOs.

Alternative 3 would not initially comply with chemical-specific ARARs for the groundwater, since the
contaminant concentrations would not be immediately reduced by implementation of this alternative. However,
by reducing the migration of contaminants from the soil it is expected that this alternative could result in
compliance with the chemical-specific ARARs. This alternative may not fully comply with soil RAOs since it
may not be 100% effective in reducing the migration of contaminants from the soil. Compliance with
location-and action-specific ARARs would be achieved through proper implementation of this alternative.
Stage 2, if reguired, would supplement stage 1 to bring this area into compliance with ARARs. Through proper
implementation of this alternative, compliance with location- and action-specific ARARs would be achieved.

It would take longer to come into compliance with chemical-specific ARARs with Alternative 3A for groundwater
than those alternatives that include source area remediation (i.e., Alternatives 3, 4 and 5), since
contamination could continue to migrate from the contaminated soil source area, which is not remediated under
this alternative. Through proper implementation of this alternative, compliance with location-and

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action-specific ARARs would be achieved. This alternative would not comply with the soil RAOs, since it does
not include removal of contaminated soil.

Alternative 4 would not initially comply with chemical-specific ARARs, since the groundwater contaminant
concentrations would not be immediately reduced by implementation of this alternative. However, significant
guantities of contaminants in both the soil and groundwater would be removed by VER or SVE/AS, thereby
eliminating additional contributions of contamination to the city aguifer and eventually resulting in
compliance with chemical-specific ARARs. It is expected that compliance with chemical-specifi ARARs would be
achieved over time. However, if groundwater ARARs are not achieved, a groundwater pump-and-treat system
would be installed to ensure compliance with ARARs. Proper design and implementation of the VER or SVE/AS
system and the groundwater pump-and-treat system (if necessary) would ensure that the implementation of both
stages of this alternative would be in compliance with location- and action-specific ARARs. This
alternative, upon completion of VER or SVE/AS treatment (stage 1), would also be in compliance with the soil
RAOs.

Alternative 5 would provide most rapid compliance with chemical-specific ARARs, since the groundwater
contaminant concentrations would be rapidly reduced by implementation of this alternative. Contaminated soil
that is acting as a source of contamination to the groundwater would be removed in this alternative, thereby
eliminating additional contributions of contamination to the city aguifer and resulting in compliance with
chemical-specific ARARs. If it is determined that chemical-specific ARARs in the groundwater have not been
achieved, a groundwater pump-and-treat system may be installed to ensure compliance with groundwater ARARs.
Proper design and implementation of the excavation, transportation and disposal of the contaminated soil and
proper operation of the pump-and-treat system (if necessary) would ensure that the implementation of both
stages of this alternative would be in compliance with location- and action-specific ARARs. This
alternative, upon completion of soil excavation and disposal (stage 1), would also be in compliance with the
soil RAOs.

Short-term Effectiveness

Alternative 1 involves no remedial activities, and therefore results in no increase in short-term risks to
workers or the community. Implementation of this alternative would be immediate.

Alternative 2 includes administrative actions and minimal construction activities (e.g., fence construction).
Workers and the nearby community would be subject to a slightly increased risk of exposure to contaminants
due to disturbance of contaminated soil during these activities. These risks would be minimized through the
implementation of a site-specific health and safety plan and appropriate engineering controls (e.g., dust
suppression). Implementation of this alternative could be completed in approximately 6 months.

Alternative 3 includes construction activities for placement of a cap over the source area. Workers and the
nearby community would be subject to an increased risk of exposure to contaminants due to disturbance of
contaminated soil (e.g., grading) during these activities. These risks would be minimized through the
implementation of a site-specific health and safety plan (e.g., use of personal protective eguipment) and
appropriate engineering controls (e.g., dust suppression). Implementation of stage 1 of this alternative
could be completed in approximately 1 year. If it is determined the stage 2 of this alternative (i.e.,
groundwater pump-and-treat) is reguired, there would be additional Site disturbances during construction of
this system, resulting in additional risks of exposures to contaminated groundwater for workers. Workers may
also be exposed to excessive noise during construction activities. These risks would be minimized through
the implementation of a site-specific health and safety plan. There would be no increased risk to the public
during construction of the pump-and-treat system, since contaminated soil would be contained beneath the cap;
however, operation of the pump-and-treat system might pose slightly increased risk of exposures to the public
from fugitive air emissions. These risks would be mitigated by proper design and operation of the system and
compliance with any emissions control reguirements. Implementation of stage 2 could be completed in
approximately 1 year; however, the pump-and-treat system would be operated for an extended period of time
(e.g., 30 years). The short-term effectiveness of Alternative 3A is identical to the short-term
effectiveness of stage 2 of Alternative 3.

restrictions, provided these restrictions are adeguately maintained and enforced. Long-term monitoring would

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be required under this alternative, and there is the potential that additional remedial activities might be
necessary in the future. In addition, it would be very difficult to maintain institutional controls in the
long term.

Alternative 3 provides containment of the contaminated source area which would reduce the risk of exposure to
contaminated soil and reduce migration of contaminants from the source area to groundwater. Long-term
monitoring and maintenance would be required under this alternative to ensure the integrity of the cap. It
is possible that the cap may not prevent migration of contamination from the source area to the groundwater,
and that additional remedial activities could be necessary in the future. Implementation of the stage 2
pump-and-treat system would provide an additional reduction in the risk of exposure to contaminated
groundwater by preventing further migration of contamination from this source.

Alternative 4 provides treatment of both the source area and associated groundwater. This alternative
provides a permanent remedy for the contaminated source area, including source areas below the water table,
since contaminants are removed from the soil; however, as with any in situ treatment, it would be difficult
to assess the level of treatment achieved in the subsurface soils. During the operation of, and upon
completion, of the VER or SVE/AS treatment, long-term monitoring would be required to assess the completeness
of the remediation and to monitor improvements in the quality of the city aquifer; however, no further
remediation of the source area should be required. If it is determined that stage 1 of this alternative has
not adequately addressed the source area and groundwater remediation, stage 2 may be implemented.
Implementation of the stage 2 pump-and-treat system would provide an additional reduction in the risk of
exposure to contaminated groundwater by preventing further migration of contamination from this source.

Alternative 5 provides removal of the source areas. This alternative provides a permanent remedy, in that
contaminated soils removed from the Site would not pose any future risk and would not be subject to any
further remedial action in the future. No long-term monitoring or maintenance would be required for the
source area; however, long-term monitoring would be required under this alternative to monitor improvements
in the quality of the city aquifer. If it is determined that stage 1 of this alternative has not adequately
improved the quality of the city aquifer, stage 2 may be implemented. Implementation of the stage 2
pump-and-treat system would provide an additional reduction in the risk of exposure to contaminated
groundwater by preventing further migration of contamination from this source.

Reduction of Toxicity, Mobility or Volume though Treatment

Alternatives 1 and 2 provide no removal or treatment of contaminated soils or groundwater, and therefore
provide no reduction in toxicity, mobility or volume of contaminated materials.

The cap that would be installed in stage 1 of Alternative 3, if property maintained, should reduce the
mobility of contaminants, without treatment, thereby minimizing additional contamination of the groundwater
from this source area. Stage 1 of this alternative does not provide any reduction in toxicity or volume of
contaminated material. If the stage 2 pump-and-treat system is implemented, this system would further reduce
the mobility of contamination by preventing off-Site migration. The reduction in toxicity, mobility and
volume for Alternative 3A is identical to stage 2 of Alternative 3.

Stage 1 of Alternative 5 provides a reduction in toxicity, mobility and volume of contaminated soil by
excavation and off-Site treatment and disposal of contaminated media. Contaminated soil removed from the

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Site would no longer pose any risk of further contamination of the groundwater. If stage 1 does not
adeguately meet the RAOs and stage 2 is implemented, the groundwater pump-and-treat system would further
reduce the mobility of remaining contamination by preventing off-Site migration.

Implementability

Alternative 1 would be easily implemented, as it does not include any remedial activities. Alternative 2 may
be difficult to implement, since it reguires cooperation from individual property owners, which is difficult
to enforce. Minor construction activities (e.g., fence) included in this alternative would be easy to
implement, and would not reguire a significant administrative effort. Long-term maintenance would be
reguired for Alternative 2.

Alternative 3 would involve on-Site construction. However, capping is a readily available and well-developed
technology that could be completed using conventional construction technigues. Long-term maintenance of the
cap would be reguired. If stage 2 of this alternative is reguired, it would be relatively easy to implement
technically, since groundwater pump-and-treat systems consist of readily available technologies and are
routinely installed at Sites with contaminated groundwater. Administratively, coordination with local
authorities may be reguired for the discharge of treated water and emissions from the treatment system. The
implementability of Alternative 3A is identical to the implementability of stage 2 of Alternative 3.

For Alternative 4, on-Site construction activities would be minor, consisting of well installation and
construction or mobilization of a small treatment system. A pilot test will be necessary at the Loohns
source area in order to determine whether VER or SVE/AS would be the more effective means of treatment and to
design the treatment system. However, in situ treatment technologies are still considered innovative, and
there are only a small number of vendors offering these services. In addition, effective operation reguires
intensive monitoring and assessment. Administratively, coordination with local authorities and other
agencies may be reguired for the discharge of treated water and vapor; however, this alternative does not
involve any off-Site transportation of hazardous materials. If stage 2 of this alternative is reguired, it
would be relatively easy to implement technically, since groundwater pump-and-treat systems consist of
readily available technologies and are routinely installed at Sites with contaminated groundwater.
Administratively, the reguirements would be similar to the reguirements for a VER or SVE/AS system.

Alternative 5 would reguire excavation to depths of approximately 22 feet with approximately 14 feet below
the water table. Dewatering and shoring would be reguired; however, this alternative could be implemented
using conventional construction technigues. Off-Site RCRA storage, treatment and disposal facilities are
available for treatment and disposal of VOC contaminated soil. Administratively, this alternative would be
moderately difficult to implement, since it would reguire coordination with the local authorities and other
agencies for transportation, treatment and disposal of hazardous materials. If stage 2 of this alternative
is reguired, it would be relatively easy to implement techincally, since groundwater pump-and-treat systems
consist of readily available technologies and are routinely installed at Sites with contaminated groundwater.
Administratively, coordination with local authorities may be reguired for the discharge of treated water and
emissions from the treatment system.

Cost

The 30-year net present worth (NPW) of the remedial alternatives for the Loohns source area range from $0 to
$4,186,299, based on a discount rate of 7%. Alternative 1 and 2 are the least expensive to implement, with
NPWs of $0 and $152,295, respectively. Alternative 3 (stage 1) is slightly more expensive, with a NPW of
$256,340. If stage 2 of Alternative 3 is implemented, the overall cost of this alternative is approximately
$890,344, but treatment of contaminated groundwater is provided. Alternative 3A, which includes
pump-and-treat for a longer period of time, but no capping, has a NPW of $1,070,610. Alternative 4 (stage 1)
is significantly more expensive than Alternative 3 (stage 1), with a NPW of $1,011,024. If stage 2 of
Alternative 4 is implemented the cost increases to $1,645,028, and additional groundwater treatment is
provided. Alternative 5 (stage 1) is significantly more expensive than Alternative 4 (stage 1), with a NPW
of $3,552,295. If stage 2 of Alternative 5 is implemented groundwater treatment is provided, and the NPW is
$4,186,299.

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Cost estimates are summarized in Table 2.

! State Acceptance

! Community Acceptance

Community acceptance of the preferred alternative will be assessed in the ROD following review of the public
comments received on the RI/FS report and the Proposed Plan.

PREFERRED ALTERNATIVES

Based upon an evaluation of the six alternatives, EPA recommends Alternative 4 for the Alcas and Loohns Dry
Cleaners and Launderers source areas; Alternative 5 for the AVX source area; and Alternative 3A for the
McGraw Edison source area.

ALCAS and Loohns Dry Cleaners and Launderers

After carefully weighing all of the alternatives, EPA believes that Alternative 4 would be most effective in
protecting human health and the environment, while being the most cost effective for the Alcas and Loohns
source areas.

EPA is also recommending that Alternative 5 be selected as a contingency for remediating the Loohns source
area. Alternative 5 would be implemented if the pilot testing, which is planned for the Loohns property,
indicates either that a VER or SVE/AS system would be ineffective or, if running either system would be
infeasible due to the effects of the Allegheny River. While not guite as cost effective as Alternative 5
would be just as effective in protecting human health and the environment.

Treatability pilot tests, which were conducted in November 1994, indicated that an VER system would be
effective in remediating the contaminated soils at the Alcas property. A pilot test will also be necessary
at the Loohns source area in order to determine whether VER or SVE/AS would the more effective means of
treatment.

Alternative 4 involves two different types of in-situ treatment systems: SVE with Air Sparging (SVE/AS) and
Vacuum Enhanced Recovery (VER). A VER system uses negative air pressure, which is applied to a series of
recovery wells. The negative pressure, which is generated by high vacuum pump, causes the movement of soil
vapor and groundwater towards the recovery wells. The vapor recovery causes desorption (removal of
contaminants, which are absorbed onto soil particles) and volatilization of VOCs by continuously removing
contaminated vapors and forcing clean air into the contaminated areas. An off-gas treatment system would
remove contaminants which are above federal and New York State air emission levels using granulated activated
carbon (GAG). Groundwater, which is recovered with the soil vapor, would also be treated with GAG prior to
discharge to the City sewer system.

An SVE/AS system would use a soil vapor recovery process combined with air injection wells, which would
extend below the water table. Air, which is injected under pressure into the wells, would enter water below
the water table. The air bubbles, which are formed, traverse horizontally and vertically through the water
column. Volatile compounds, which are exposed to the sparged air, volatilize into the gas phase and are
carried into the vadose zone where they are captured by a vapor recover system. An off- gas treatment system
would use GAG to remove contaminants which are above federal and New York State air emission levels.
Groundwater, which is recovered with the soil vapor, would also be treated with GAG prior to discharge to the
City sewer system.

The SVE/VER systems would be operated until contaminant levels in the soil vapor and water effluents cease to
decline and remain constant at a negligible rate. At which time, the systems will be shut off. After the
SVE/VER systems are shut off, soil samples would be collected to confirm the effectiveness of the
alternative.

Any contamination which can not be removed by implementation of a VER or SVE/AS system may be addressed by

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the installation of a groundwater pump and treat system. The need for groundwater treatment will be assessed
every four years and will be based on a review of sample data for the influences to the City Municipal wells
M18 and M37/38 and up and downgradient groundwater samples from Loohns and Alcas.

According to Table 2, the cost for implementing Alternative 4 is $837,721 for ALCAS. The costs for
implementing Alternatives 4 and 5 is $1,654,028 and $4,186,299, respectively, for Loohns. Alternative 4 is
the more cost effective alternative for both source areas.

AVX

After carefully weighing all of the alternatives, EPA believes that Alternative 5 would be most effective in
protecting human health and the environment, while being cost effective for the AVX source area. The area of
contaminated soil is very shallow (approximately 6 feet below the surface), which would be easily amenable to
excavation. The soil to be excavated is located in and around soil borings SB04 and SB07 and is estimated to
be 10,000 cubic feet.

Contaminated soil at AVX would be excavated and tested to determine if it is a RCRA hazardous waste material.
If hazardous, the soils would be transported to an off-Site facility for low temperature desorption of soil
contaminants. If not hazardous, the soils would be disposed of at a local landfill. Clean fill material
would be brought in to restore the excavated area to grade. Confirmatory soil sampling and analyses would be
conducted during soil excavation to ensure that all soils with contaminant levels higher than the levels
provided in Table 1 of this Proposed Plan are removed.

Until restoration of the excavated areas is complete, land use/access restrictions (if necessary) would be
placed on the source area to restrict its use. During all phases of the soil removal, it will be necessary
to implement dust and volatile emission control, soil erosion and sediment control measures.

Alternative 5 proved to be more cost effective than Alternative 4, which was also found to be protective of
human health and the environment. The estimated cost for Alternative 5 was $1,010,299 verses $1,747,533 for
Alternative 4.

Any contamination which is not be removed from AVX, will be addressed, if necessary, by the installation of
groundwater pump and treat system. The need for groundwater treatment will be assessed every four years and
will be based on a review of sample data for the influences to the City Municipal wells M18 and M37/38 and up
and downgradient groundwater samples from AVX.

McGraw-Edison

After carefully weighing all of the alternatives, EPA believes that Alternative 3A would be the most
effective in protecting human health and the environment, while being the most cost effective for the McGraw
Edison source area. An extensive investigation of the facility was conducted during the SRI, but no soil
contamination was found, which could act as a source of contamination to the groundwater. However,
groundwater contamination was detected at the facility, which EPA believes is the result of previous disposal
activities. By capturing and treating the groundwater rather than letting it be treated by the municipal
wells, cleanup of the aguifer can be expedited. Contaminated groundwater from the upper aguifer will be
pumped and treated by an existing air stripping system, which is currently treating groundwater from the
lower aguifer. The existing air stripper has enough excess capacity to treat additional groundwater from the
upper aguifer. Groundwater monitoring will also be instituted up and downground of the source area in order
to determine the continued effectiveness of the remedy.

Site Monitoring

EPA also proposes to expand the list of chemical compounds, which are currently being tested for under the
current groundwater Site monitoring plan (SMP). The PRPs were the EPA Administrative Order issued on
February 7, 1986. The plan was reguired in order assess the condition of the groundwater in the upper and
lower aguifers as the remedies, which were specified in EPA's 1985 ROD were implemented. Currently, the SMP
specifies that 13 groundwater monitoring wells be sampled every three months for the presence of

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trichloroethane, 1,1,1-trichloroethane, 1,1-dichloroethane, 1,1-dichoroethene, 1,2-dichloroethane and
tetracholoroethene.

During the supplemental RI/FS, other VOCs, which were not tested for as part of the SMP, and chromium were
detected in the groundwater.  Because of these other contaminants, EPA is proposing that the SMP be revised
to include analyses for a full scan of volatile organic compounds and chromium.  EPA will use the expanded
SMP data along with the groundwater monitoring data which will be collected to determine whether or not
groundwater pump and treat is needed for the AVX and Loohns's source area properties, and to access the
overall improvement of the groundwater was the source control remedies are implemented.

NEXT STEPS

After EPA presents the preferred alternatives at the public meeting on July 16, 1996 and receives comments
and questions during the public comment period.  EPA will evaluate and respond to these guestions and
comments in a Responsiveness Summary.  The Responsiveness Summary will become part of the Record of Decision
(ROD) for the Site.

The ROD will also include a description of the final alternatives selected by EPA, the rational for selecting
them, a discussion of the alternatives that were considered,  but rejected, and the reasons for rejecting
them.

EPA will place the ROD in the Administrative Record, which is located at Region 2's office at 290 Broadway,
NY, NY, and at the public repository listed on page 2.  The Administrative Record file includes all Site
findings, reports and other documents that were relied upon EPA in formulating its decision regarding remedy
selection.  If the final remedy selections differ significantly from those presented in this Proposed Plan,
EPA will include a discussion of the changes in the ROD.

Upon acceptance and final approval of the remedies, EPA will give the PRPs an opportunity to implement the
remedies described in the ROD.

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TABLE 2

PRESENT WORTH AND CAPITAL AND  OPERATION AND MAINTENANCE COSTS BY SOURCE AREA
                                                                                Capping and
                                                                                Groundwater
                                                                                 Treatment
Groundwater
 Treatment
                                                                                                                                          Alternative 4
                                                                                                                                                                      Alternative  4
                                                                                                                                                                         Treatment
             Alternative  5

Soil Excavation and

               Treatment

    (Stage 1  &  2)
McGraw Edison4
1 - Present Worth and  capital  and  operation and maintenance costs for groundwater  treatment  are not presented, since groundwater remediation  will  not be necessary at the Alcas source area.

2 - PW - Present Worth based on  a  7  percent discount rate.

3 - O&M - Operation  and maintenance  costs.

4 - Capital, present worth, and  operation  and maintenance costs were not calculated  for  Alternatives 3,  4 or 5, since soil remediation will not  be necessary at the McGraw-Edison source area.

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GLOSSARY

Of Terms Used In the Proposed Plan

This glossary defines the technical terms used in this Proposed Plan. The terms and abbreviations contained
in this glossary are often defined in the context of hazardous waste management, and apply specially to work
performed under the Superfund program. Therefore, these terms may have other meanings when used in a
different context.

Administrative Order on Consent: A legal and enforceable agreement between EPA and the potentially
responsible parties (RPRs). Under the terms of the Order, the PRPs agree to perform or pay for Site studies
or cleanup work. It also describes the oversight rules, responsibilities and enforcement options that the
government may exercise in the even of non-compliance by the PRPs. This Order is signed by the PRPs and the
government; it does not reguire approval by a judge.

Administrative Order: A legally binding document issued by EPA directing the potentially responsible parties
to perform Site cleanups or studies (generally, EPA does not issue unilateral orders for Site studies.)

Aeration: A process that promotes breakdown of contaminants in soil or water by exposing them to air.

Air stripping: A process whereby volatile organic chemicals are removed from contaminated material by
forcing a stream of air through it in a pressurized vessel. The contaminants are evaporated into the air
stream. The air may be further treated before it is released into the atmosphere.

Aguifer: An underground layer of rock, sand, or gravel capable of storing water within cracks and pore
spaces, or between grains. When water contained within an aguifer is of sufficient guantity and guality, it
can be tapped and used for drinking or other purposes. The water contained in the aguifer is called
groundwater.

Backfill: To refill an excavated area with removed earth; or the material itself that is used to refill an
excavation area.

Borehole: A hole drilled into the ground used to sample soil and groundwater.

Borrow pit: An excavated area where soil, sand, or gravel has been dug up for use elsewhere.

Cap: A layer of material, such as clay or a synthetic material, used to prevent rainwater from penetrating
and spreading contaminated materials. The surface of the cap is generally founded or sloped so small will
drain off.

Carbon adsorption/carbon treatment: A treatment system in which contaminants are removed from groundwater
and surface water by forcing water through tanks containing activated carbon, a specially traced material
that attracts and holds or retains contaminants.

Consent decree: A legal document, approved and issued by a judge, formalizing an agreement between EPA and
the potentially responsible parties (PRPs). The consent decree

describes cleanup actions that the PRPs are reguired to perform and/or the costs incurred and/or will be
incurred by the government that the PRPs will reimburse, as well as the roles, responsibilities, and
enforcement options that the government may exercise in the event of non-compliance by RPRs. If a settlement
between EPA and the PRPs includes cleanup actions, it must be in the form of a consent decree. A consent
decree is subject to a public comment period.

Consent Order: A legal and enforceable agreement between EPA and the potentially responsible parties (PRPs).
Under the terms of the Order, the PRPs agree to perform or pay for Site studies or cleanup work. It also
describes the oversight rules, responsibilities and enforcement options that the government may exercise in
the event of non-compliance by the RPRs. This Order is signed by the RPRs and the government; it does not

-------
require approval by a judge.

Containment: The process of enclosing or containing hazardous substances in a structure, typically in ponds
and lagoons, to prevent the migration of contaminants into the environment.

Cooperative agreement: A contract between EPA and a state wherein the State agrees to manage or monitor
certain Site investigation and/or cleanup responsibilities and other activities on a cost-sharing basis.

Downgradient/downslope: A downward hydrologic slope that causes groundwater to move toward lower elevations.
Therefore, wells downgradient of a contaminated groundwater sources are prone to receiving pollutants.

Effluent: Wastewater, treated or untreated, that flows out of a treatment plant, sewer, or industrial
outfall. Generally refers to wastes discharged into surface waters.

Generator: A facility that "generates" hazardous wastes.

Hot Spot: An area or vicinity of a Site containing exceptionally high levels of contamination.

Hydrogeology: The geology of groundwater, with particular emphasis on the chemistry and movement of water.

Influent: Water, wastewater, or other liguid flowing into a reservoir, basin, or treatment system.

Long-term remedial phase: Distinct, often incremental, steps that are taken to solve Site pollution
problems. Depending on the complexity, Site cleanup activities can be separated into a number of these
phases.

Maximum Contaminant Level (MCL): The maximum level, or concentration, of a contaminant that is allowable in
a public drinking water supply.

Migration: The movement of contaminants, water, or other liquids through porous and permeable rock.

Mitigation: Actions taken to improve Site conditions by limiting, reducing, or controlling toxicity and
contamination sources.

Outfall: the place where wastewater is discharged into receiving waters.

Potentially Responsibilities Parties (PRPs): Parties, including owners, who may have contributed to the
contamination at a Superfund Site and may be liable for costs of response actions. Parties are considered
PRPs until they admit liability or a court makes a determination of liability. This means that PRPs may sign
a consent decree or administrative order on consent (see consent decree and Administrative Order on Consent)
to participate in Site cleanup activity without admitting liability.

Remedial: A course of study combined without actions to correct Site contamination problems through
identifying the nature and extent of cleanup strategies under the Superfund program.

Runof: The discharge of water over land into surface water. It can carry pollutants from the air and land
into receiving waters.

Sediment: The layer of soil, and minerals at the bottom of surface waters, such as streams, lakes, and
rivers that absorb contaminants.

Stripping: A process used to remove volatile contaminants from a substance (see Air Stripping).

Trichloroethylene (TCE): A stable, colorless liquid with a low boiling point. TCE has many industrial
applications, including use as a solvent and as a metal degreasing agent. TCE may be toxic to people when
inhaled, ingested, or through skin contact and can damage vital organs, especially the liver [see also
Volatile Organic Compounds.]

-------
Unilateral Order:  A legally binding document issued by EPA directing the potentially responsible parties to
perform Site cleanups or studies  (generally, EPA does not issue unilateral orders for Site studies).

Upgradient/Upslope:  Upstream; an upward slope.  Demarks areas that are higher than contaminated areas and,
therefore, are not prone to contamination by the movement of polluted groundwater.

Volatile/Semi-Volatile Organic compounds Compounds  (VOCs/SVOCs):   VOCs vaporize easily; SVOCs vaporize less
easily.  Both include carbon-based compounds such as solvents and oils.  Organic chemicals have varying
degrees of solubility in water.  VOCs tend to be more soluble in water than SVOCs.

Vadose Zone:  A subsurface zone which is defined by the ground surface and the water table.

Wetland:  An area that is regularly saturated by surface or groundwater and, under normal circumstances,
capable of supporting vegetation typically adapted for life in saturated soil conditions.  Wetlands are
critical to sustaining many species of fish and wildlife.  Wetlands generally include swamps, marshes, and
bogs.  Wetlands may be either coastal or inland.  Coastal wetlands have salt or brackish  (a mixture of salt
and fresh) water, and most have tides, while inland wetlands are non-tidal and freshwater.  Coastal wetlands
are an integral component of estuaries.

-------
APPENDIX V

RESPONSIVENESS SUMMARY

APPENDIX B

PUBLIC NOTICES




APPENDIX V

RESPONSIVENESS SUMMARY

APPENDIX C

PUBLIC MEETING ATTENDANCE SHEETS






APPENDIX V

RESPONSIVENESS SUMMARY

APPENDIX D

PUBLIC MEETING TRANSCRIPT

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

PUBLIC MEETING

Olean Well Field Site
Proposed Remedial Action Plan

Public meeting held at the Olean Municipal Building, Olean, New York, on Tuesday, July 16, 1996, commencing
at 7:00 P.M., before Theresa M. McGreevy, R.P.R., Notary Public.

Theresa M. McGreevy
Registered Professional Reporter
202 Lehn Springs Drive
Williamsville, New York 14221
(716)631-8534

-------
1      PRESENT:

2      KEVIN LYNCH
       US Environmental Protection Agency
3
       TOM TACCONE
4      US Environmental Protection Agency

5

6             MR.  LYNCH:   I'd  like to  thank  everyone  for

7      coming tonight.   I'm Kevin Lynch.   I  am chief  of

8      the EPA's Western New York Superfund  Section.

9      Tonight we're presenting the proposed plan for the

10     source control section  at the Clean Superfund

11     site.   Copies of the proposed plan are - - hopefully

12     everybody picked them up on their  way in.   They are

13     available in the front  of the room if everyone

14     doesn't have one.   We also have a  mailing list that

15     I think most of you are on.  If you're not and

16     would like to be on it,  if you've  signed in this

17     morning,  you'll automatically be put  onto it - -

18     this evening, excuse me.

19            The purpose of this meeting tonight is  to

20     present the proposed remedy for the source control

21     action at the Clean Superfund site and to elicit

22     your comments on that plan.  Any comments or

23     guestions from today's  meeting  are being recorded

-------
1      by the court reporter and will be part of the





2      administrative record for the site.   The other way





3      to comment on the site is to comment in writing to





4      Tom Taccone,  the site manager.  The  address is in




5      the proposed plan.   And the public comment period





6      will be open until  August 8th.





7             After considering your comments,  the EPA will





8      then make a decision on the actions  to take at this




9      site.  This will be published in a document that we





10     call the Record of  Decision.   Responses to these





11     comments will be included in that Record of





12     Decision document.




13            Tonight there'll be two presentations.   I





14     will make the first one,  which I will describe the





15     process which we use in Superfund to address





16     sites.  Tom Taccone,  project manager,  manager for




17     the Clean site will be summarizing the remedial





18     investigation/feasibility study, then presented - -





19     presenting the recommended alternatives for the





20     site.  Then we will take guestions.




21            Also with us today is  Steve Scharf from the





22     New York State DEC, who is at the front desk,





23     Sharon Kivowitz from EPA,  the attorney for the

-------
1      site,  from Foster Wheeler the EPA consultant Bob





2      Chozick,  from the New York State Department of





3      Health,  Lani Rafferty,  and from the Cattaraugus





4      County Health Department,  Eric Wohlers.




5             In 1979 a  number of environmental  disasters





6      occurred, the best known of which was Love Canal,





7      where  people discovered that they were living on a





8      hazardous waste site.   The U.S.  Government at that




9      time did not have a way to respond except for the





10     way it would normally respond to natural  disasters





11     such as hurricanes.  The response of that,  in 1980





12     Congress passed the Comprehensive Environmental




13     Response Compensation and Liability Act known as





14     CERCLA,  where they created a one point six billion





15     dollar fund to address such sites.   The law simply





16     is usually known as a Superfund Law,  based on that




17     one point six billion dollar sites.





18            It allows  us to address sites  in two





19     different ways.  One,  it allows us to have a guick





20     action such as in an emergency or an action to




21     prevent an emergency situation from developing.





22     This is called a removal action.  A removal action





23     was taken at Clean when it was discovered that

-------
1      people's wells were contaminated with high levels





2      of Chemicals,  of a chemical solvent.   Individual





3      treatment systems were placed on those individual





4      wells to protect those people until a more




5      permanent solution could be reached.   The other way





6      to address a site is the normal way we would do it,





7      and that would be to take a what we call  response





8      act.




9             The law also allows  EPA to order parties





10     responsible for contributing to the problem to take





11     actions.  These parties didn't have to have done





12     anything illegal,  they just have to have




13     contributed to the problem.  These are the parties





14     that are liable,  the owners or operators  of the





15     site.  They could be generators of the hazardous





16     substances that ended up at the site or they could




17     be transporters of those substances to the site.





18     This is a strict liability law.  The idea is that





19     if you are part of the problem, you should be part





20     of the solution.   This is important,  because the




21     one point six billion dollars that was first





22     created in the fund and the over eight billion





23     dollars that was added when the law was

-------
1      reauthorized in 1986 is not enough to clean up all





2      of the problems.   The problems are much more





3      expensive to address than originally thought,  and





4      there are a lot more of the problems.  So having




5      the potentially responsible parties involved in the





6      cleanups allow us to address a lot more sites.   The





7      law also reguires that we address the worst sites





8      first.  We have developed a National Priorities




9      List in order to ensure that we do that.





10            This slide,  if you can read it,  shows how our





11     regulations reguire us to address the site.  When a





12     site is first discovered, the State will nominate




13     the site for the National Priorities List.   We will





14     then go out and do what is called a preliminary





15     assessment, which is gathering all the information





16     that is already known about the site, things like




17     what contamination - - contaminants are there at the





18     site,  what's the population around the site, where





19     is the nearest drinking water source.  More





20     information is needed.  We will do a site




21     investigation which is where you go out,  physically





22     look at the site, take some environmental samples





23     to gather some of this information.  This

-------
1      information then is put into numerical model in an





2      attempt to rank the site.   If it ranks above a





3      certain number,  it goes on the National Priorities





4      List and we can address the site with Superfund




5      money.   If not,  it goes back to the State for them





6      to address.





7             Once on the National Priorities List,  we then





8      perform a remedial investigation and feasibility




9      study.   The remedial investigation is a study to





10     determine the nature and the extent of the





11     problem.   Basically we want to know what is at the





12     site,  where is it going,  and what problems is it




13     creating.  We do this by going out into the





14     environment and taking samples such as soil





15     samples,  putting in monitoring wells to determine





16     which way the groundwater's flowing and what's in




17     the groundwater,  take that information and put it





18     into a risk assessment.  A risk assessment is an





19     attempt to guantify what are the risks to human





20     health that are out there on the site.  You need




21     both a contaminant and you need a pathway for that,





22     and it's a calculation to determine what are the





23     potential risks to the people in the area.

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1             A feasibility study is  then performed,  and





2      that is the study that identifies different





3      alternative solutions to the problems,  and then





4      evaluates those alternatives using nine criteria.




5      Criteria are the overall protectiveness of human





6      health and the environment,  the compliance with





7      other environmental laws and regulations,  the





8      long-term effectiveness and permanence  of the




9      alternative,  how does it reduce the toxicity,





10     mobility or volume through treatment, what are the





11     short-term effects, how easily can it be





12     implemented,  what is the cost,  and what is the




13     State acceptance and what is the community





14     acceptance of the remedy.





15            EPA then identifies the  alternative solution





16     that we think is the best way to address the




17     problem.  We then present that preferred





18     alternative to the public, which we're  doing





19     tonight, and we get the public's impute on it.  Then





20     we choose a remedy, publish it in what  we call a




21     Record of Decision.  This remedy is then designed





22     and implemented.





23            We have been through this process once  before

-------
1      at Clean,  where the result of was  to install  a





2      cleaning system at the public supply wells  and





3      extend the water line to areas affected by  the





4      contamination.   We are again going through  the




5      process to select a remedy,  this  time to stop those





6      sources of contamination to the aguifer.





7             The documents  we have produced can be  of  a





8      highly technical nature,  and the  EPA does have




9      availability a  grant  program where funds can  be





10     provided to citizens  groups to hire independent





11     contractors to  help them interpret and comment on





12     the sites.  If  anyone would like  information  on




13     that,  we can provide  it for them later,  and we can





14     also have people from our information office  in





15     Niagara Falls assist  them in putting together that





16     application.




17            Tom Taccone will now summarize the remedial





18     investigation/feasibility study and present the





19     EPA's preferred alternative.





20            MR. TACCONE:   Good evening.   My name is Tom




21     Taccone,  and I  am the project officer of the  Clean





22     Well Field Superfund  site.   And I'm going to





23     provide for you a brief summary of the history of

-------
1      the site,  present the results of a supplemental





2      remedial investigation/feasibility of the site,





3      which was  recently completed, and summarize EPA's





4      proposed plan for cleaning up four areas of




5      contaminated soil and groundwater.   Copies of the





6      plan as Kevin mentioned are available at the front





7      of the room.





8             Site  history:   Early in 1981 three municipal




9      water supply wells in the City on Clean were found





10     to be contaminated with trichloroethane,  a volatile





11     organic compound.  Trichloroethane, or TCE,  is a





12     solvent commonly used for degreasing.  The chemical




13     was detected in the municipal water,  well water





14     concentrations which are above safe concentrations





15     established  by the New York State Department of





16     Health.  Now,  this is a map of the site over here.




17     This is the  Allegheny River,  and this is State





18     Street that  runs along the site.   The wells I'm





19     referring to are located north and south of the





20     river.  There's one well designated well 18M,  as in




21     Mary,  north  of the river,  and two wells located





22     close to one another designated 37, 38M south of





23     the river.

-------
1             The  wells  were  closed down  and  an  old  surface





2      water treatment plant  was reactivated  to  provide





3      water to the city residents.  Additional  tests  by





4      the Cattaraugus Health Department  in 1982 revealed




5      that sixteen private wells in the  area were also





6      contaminated with high levels of TCE.   EPA





7      installed carbon adsorption filters on the wells.





8      And these filters are  devices which removed




9      contaminants such as TCE from the  water.   EPA also





10     established a well testing program so  that further





11     contamination could be detected.





12            In 1984 and 1985  results  from the  well




13     testing program prompted two additional EPA





14     responses,  and filters were placed on  thirteen





15     additional  wells.  also during 1984 and 1985,  the





16     New York State Department of Environmental




17     Conservation,  the DEC,  received funding from EPA to





18     conduct a remedial investigation/feasibility study,





19     also called the RI/FS,  of the site. The  purpose of





20     the study was to determine the nature  and extent of




21     contamination, identifying any potential  risks  to





22     human health and the environment and evaluate





23     alternatives for eliminating any risks.  The

-------
1      State - - the study essentially focused on





2      investigating for the presence of contaminants  in





3      the groundwater.





4             The City of Clean is  underlaid  by two




5      water - bearing zones,  or aguifers.  This is  a





6      generalized figure which will help describe what an





7      aguifer is.  This heavy line you see on the top is





8      the surface of the ground.   This dotted line  would




9      be the top of the upper water - bearing zone, or





10     aguifer.   And that is on average about ten feet





11     below the ground surface in  Clean.   Continuing





12     down,  one would then encounter a layer of lesser




13     permeability,  meaning water  cannot readily pass





14     through it, and then there would be the lower





15     aguifer,  or the lower water-bearing zone.  The





16     municipal wells collect water from this lower zone.




17     And this third,  this bottom  layer here doesn't





18     existing Clean.   This is just a generalized





19     diagram.




20            The RI/FS  sample date revealed  widespread




21     contamination of TCE in the  upper and  lower





22     aguifers.  In may 1985 the State DEC completed  the





23     RI/FS,  and after evaluating  the results of the

-------
1      study,  EPA decided in September of 1985  on the





2      following remedies:   First,  air strippers,  which





3      are treatment devices which remove volatile organic





4      compounds such as TCE from water were installed on




5      the wells,  18M and 37,  38M,  located north and south





6      of the  river.  Construction of the air strippers





7      was completed in 1990.   Both air strippers are





8      currently operating and effectively treating




9      contaminated water to below the safe drinking water





10     limits.





11            Second,  the City of Clean's water supply was





12     extended into the Town of Clean.   Ninety-three




13     private well users were hooked up.  Construction of





14     the extension was completed in 1989.





15            Third,  an industrial  sewer at McGraw Edison,





16     located in,  right over - - this diagram is, figure




17     one of  the proposed plan,  McGraw Edison, it was an





18     industrial sewer located at that part of the site





19     or at that property,  and the sewer was acting as a





20     conduit for contamination.  Groundwater  was




21     emptying one end of the sewer and exiting further





22     down.  That sewer was repaired in 1989.





23            And finally,  EPA decided that a supplemental

-------
1      RI/FS study should be conducted of the site.   The





2      objective of the supplemental RI/FS was to identify





3      sources of contamination to the groundwater and to





4      determine how to remove or prevent the sources from




5      contaminating the groundwater which flows toward





6      the municipal wells.





7             In June 1991 the Alcas Corporation,  the AVX





8      Corporation,  the Aluminum Company of America,




9      McGraw Edison and Cooper Industries signed an





10     administrative consent order with EPA.  The order





11     reguired the companies to determine the extent of





12     contamination at the  AVX,  located to the north, the




13     Alcas,  and the McGraw Edison properties.  The





14     companies were also reguired to draft the





15     supplemental RI/FS report.





16            In addition to the  field work at the three




17     properties,  EPA,  through a consultant, now called





18     Foster Wheeler,  investigated ten other properties.





19     And these were American Clean Tile, Clean Steel,





20     Loohns Dry Cleaners,  depicted on the map as Clean




21     Clean All.  The names have been changed since to





22     Loohns Dry Cleaners.   Mastel Ford,  a Ford





23     dealership,  two oil companies,  Griffith and

-------
1      Sandburg Oil,  a private dump and a borrow pit





2      located just south of the river.   That borrow pit's





3      a common disposal area.  American Clean Wholesale,





4      and finally Faye Avenue and Schaefer Road.




5             In 1991,  1993  and 1995,  soil samples  were





6      collected from sixty-nine separate locations of the





7      thirteen areas.   At each location discrete soil





8      samples were collected at regular intervals  from




9      the ground surface to the top of the upper aquifer,





10     or the top of the upper water-bearing zone.





11     Groundwater samples were also collected from





12     groundwater monitoring wells at Clean Wholesale,




13     Clean Steel,  Sandburg,  Griffith Oil,  Loohns  Dry





14     Cleaners, McGraw Edison,  and at other selected





15     wells throughout the site.





16            Groundwater grab samples were also collected




17     at many of the soil sample locations when the top





18     of the water table - - when the water table  at the





19     top of the upper aguifer was reached.  The grab





20     samples were collected to try to establish a link




21     between contamination in the soil and the





22     groundwater.





23            And finally sediment samples were taken of

-------
1      the wetlands area located just south of the AVX





2      property,  and these samples were taken to determine





3      if there was any impact of AVX on the wetlands





4      area.




5             In the next several slides I'll summarize  for





6      you the results of the supplemental remedial





7      investigation.  Before I do that, let me describe





8      to you how EPA determined whether or not properties




9      that were investigated were a source of





10     contamination to the groundwater.





11            We looked at the soil data,  soil samples were





12     taken  of each of the properties,  as I mentioned.




13     The soil concentrations, contaminants in the soil





14     were compared to a value called a soil cleanup





15     objective.   This is a value, it's different for





16     different contaminants.  It's been developed by the




17     DEC and adopted by EPA for the site.  Soil





18     contaminations above that level,  any water that's





19     entering the soil would contaminate the





20     groundwater.  The contamination would be high




21     enough to be a threat to the groundwater.   If the





22     soil contamination was below that,  it wouldn't





23     affect the groundwater.

-------
1             The ground was  tested at the site,  each of





2      the properties,  and was compared against a value





3      called an MCL,  this is the maximum contaminant





4      level,  and it represents a level that if it's





5      exceeded the water will be unsafe to drink.  Below





6      that MCL level  the water is safe to drink.  And the





7      second criteria EPA uses is whether or not the





8      groundwater flowing to and from an area that was





9      investigated could flow toward the municipal wells.





10            The Alcas property was sampled,  and because





11     of the contaminants we found in the soils,





12     considered to be a source.  1,1,1-TCA,  that's





13     trichloroethane.  These are abbreviations for the





14     contaminants found.  TCE, trichloroethane, as I





15     mentioned, and PCE, tetrachloroethane.   These are





16     solvents.   These are the concentrations detected in





17     the soil.   Ppb is parts per billion.  And these are





18     the soil cleanup objectives for each of those





19     compounds.





20            A VOICE:   Just  for a - - Alcas,  you mean AVX.





21            MR. TACCONE:  I'm sorry,  AVX.





22            Groundwater grab samples were collected when





23     the groundwater was reached at the soil borings.  A

-------
1      boring is when we drill down,  collect the discrete





2      soil samples.   The groundwater grab samples also





3      found TCA,  TCE and PCE in the groundwater,  above





4      MCL values.   Now, these are grab samples.  They're





5      not monitoring well samples.   Because of that the





6      sample results are approximate,  but these results





7      are fine enough - - I'm sorry.  Yes,  the groundwater





8      samples,  they're groundwater grab samples,  and





9      because of that they're approximate.   Groundwater





10     monitoring well samples give a more exact result.





11     And the contamination that was found at AVX is high





12     enough to show groundwater contamination.





13            The AVX property was also sampled, the soil





14     was evaluated.  TCE,DCE and vinyl chloride were





15     found in the soil.  TCE and DCE were above the soil





16     cleanup objectives.  Because of that we're





17     considering it a source area.   The groundwater was





18     tested at that property.  TCE, DCE, and vinyl





19     chloride were also found in the groundwater above





20     the MCL values.





21            A VOICE:  That's Alcas.





22            MR.  TACCONE:  Alcas.





23            Loohns  Dry Cleaner was  evaluated.   The soil

-------
1      was tested at this property.   TCE,  PCE,  2-butanone,





2      all called methylethylketone,  solvents,  dry





3      cleaning solvents, were found at high levels in the





4      soil.   This is considered a source  area.   These




5      three  contaminants were found above the  soil





6      cleanup up objectives.   Groundwater samples taken





7      at that property showed elevated levels  of DCE and





8      PCE in the groundwater.




9             McGraw Edison,  the soil was  also  sampled.





10     The soil was sampled at this  property, but we





11     didn't find any soil contamination  at that





12     property.   The groundwater was tested and found to




13     have contaminants.  TCE was found in both the upper





14     and lower aguifers.   Considered a source area,





15     above  the MCL levels.   And these are well samples,





16     these  are not grab samples, so the  results we have




17     are more accurate, representative of what's in the





18     groundwater.





19            Sandburg Oil  was found to be a source of





20     contamination to the groundwater.  Xylene was




21     found.  The contaminants in the soil were above the





22     soil cleanup objective.  Benzene, ethylbenzene and





23     xylene were found in the groundwater, in the

-------
1      groundwater grabs,  above the MCL levels.





2             Griffith Oil had benzene,  toluene,  xylene and





3      ethylbenzene in the soil,  all above soil  cleanup





4      objectives.  DCE,  TCE and benzene were also found




5      in the groundwater above MCL levels.





6             Now, the contamination that was found in





7      Sandburg and Griffith Oil are all petroleum





8      related.   Benzene,  xylene,  toluene, all are




9      components of gasoline.  And because of that, EPA





10     cannot spend fed resources,  Superfund money, for





11     the cleanup of petroleum contamination.  Because of





12     that,  we're referring these properties to the DEC




13     for action under the Oil Spill Cleanup Program, the





14     State  Oil Spill Cleanup Program.





15            The other properties  we investigated, we





16     didn't find soil above the cleanup objective, and




17     we didn't find groundwater that was above MCLs.





18     These  are the properties,  were American Clean Tile,





19     Clean  Steel, the private dump, the borrow pit,





20     Mastel Ford, and the area Schaefer Avenue and - -




21     Faye Avenue and Schaefer Street.





22            And again to summarize, the criteria we used





23     for determining whether or not an area was

-------
1      investigated as a source,  we looked at the





2      contaminants in the soil to see that they were





3      above the soil cleanup objective,  a value that's





4      been developed for the site.  If the soil




5      contaminants were above this level,  they could,





6      considered - - the soil was considered a threat  to





7      the groundwater.   We looked at the groundwater





8      sample results to see if it was above the MCL.  And




9      we looked at the groundwater movement,  to see if it





10     could flow toward the municipal well,  bringing in





11     any contamination in the groundwater and soil to





12     the municipal wells.




13            Now,  using these two criteria,  EPA identified





14     the source areas, Alcas AVX, Loohns Dry Cleaners,





15     McGraw Edison and the two oil companies,  Sandburg





16     and Griffith Oil.  But again we're referring the




17     other companies to the DEC for action under the  Oil





18     Spill Cleanup Program.





19            The soil and groundwater data were then





20     evaluated to determine if the contaminants which




21     were found could pose an unacceptable risk to human





22     health and the environment.  However,  before I





23     explain to you the risk assessment process,  let  me

-------
1      first say that the people in the Town and City of





2      Clean are drinking safe water.   The risks which





3      exist at the site are for someone who would drink





4      untreated water from the ground,  not from the city




5      water supply.





6             There's a four-step process involved for





7      assessing and evaluating human risks.  Hazard





8      identification,  exposure assessment,  toxicity




9      assessment and risk characterization.





10            First step,  hazard identification,  and this





11     involves identifying those chemicals or





12     contaminants at the site which could cause harm.




13     And you see here,  these are the contaminants of





14     concern that were identified in the hazard





15     identification step.





16            Exposure assessment.   This assessment - -  this




17     step is an assessment of the various pathways a





18     chemical can take to affect people,  contaminants  in





19     the soil or groundwater.





20            The third step is toxicity assessment,  and




21     this third step determines the types of adverse





22     health effects which may be associated with the





23     contaminants,  and the relationship between the

-------
1      amount of exposure and the severity of the effect.





2             The fourth step is  risk characterization of





3      the risk assessment,  and this last step combines





4      the results of the exposure assessment and the risk




5      assessment to produce a quantitative assessment of





6      risk.





7             The risks  that we found for the site,  this is





8      for groundwater ingestion, this is for drinking




9      water,  consuming.  This would be over a thirty year





10     period,  drinking of water - - untreated water for





11     thirty years.  Adults and young children had a risk





12     of cancer of one in one hundred.  Older children




13     would have risk of six in one thousand.  Noncancer





14     risks,  this would be toxic effects.  For the three





15     exposure groups,  adults, young children and older





16     children,  drinking of water for thirty years would




17     have a risk that would be greater than one.  For





18     noncancer risks we use the hazard index.  If it's





19     greater than one, it's a,  it's an unacceptable





20     risk.   If it's less than one, it's an acceptable





21     risk.




22            We  also found the risk of dermal contact,





23     skin contact, and again, this is a risk over a

-------
1      thirty year period,  untreated water.   Adults would





2      have a cancer risk of two in one thousand,  two





3      people in a population of one thousand.   Young





4      children would have a risk of nine in ten




5      thousand.   Older children,  seven in ten thousand





6      Noncancer or toxic risk were all less than one for





7      those exposure groups.





8             The soil was  also evaluated.   Ingestion or




9      consumption of soil or dermal contact with soil,





10     but the risks we found - - we didn't find any risks





11     associated with soil.  However,  the soil is





12     contaminated enough to affect the groundwater and




13     produce risk in the groundwater,  and that's what





14     the remedies that I'm going to be talking about





15     shortly are all about.





16            Because of the potential  risks,  EPA is




17     proposing to remediate or clean up the sources of





18     contamination.  The Federal Superfund Law requires





19     that selected remedies be evaluated against nine





20     criteria,  and these are protection of human health




21     and the environment.  This is the ability of a





22     remedy to reduce risk.   The second criteria is the





23     ability of a remedy to comply with other

-------
1      environmental laws.   However effective the remedy is in





2      the long-term.   Number four,  the way the remedy





3      would reduce toxicity,  mobility or volume of the





4      contaminants through treatment.   Short-term




5      effectiveness,  this  would involve the amount of





6      risks that could be  created in the short term.





7      Some remedies might  produce an elevated risk





8      because of the way the remedy would be conducted.




9      Implementation,  this is how easy or difficult the





10     remedy might be implemented,  technically or





11     administratively.   How costly a remedy would be





12     The eighth criteria  is State acceptance,  and




13     finally community acceptance.





14            There were  six potential  remedial





15     alternatives that were considered for the source





16     areas.   And they are, first,  the no action




17     alternative was looked at,  and a no action





18     alternative is always looked at.  It's used as  a





19     baseline fors cost and reduction of risk for the





20     other alternative.




21            Alternative two would involve institutional





22     controls,  and this would include educational





23     programs whereby the - -  and for this site the

-------
1      groundwater would be tested,  and people would be





2      informed of the results,  how contaminated the





3      groundwater is,  and in successive analyses of the





4      water,  and how toxic,  how harmful the water might




5      be to drink.   This alternative would also include





6      property,  deed restictions which would control use





7      of the property.   And finally,  a health a safety





8      plan could be developed for the properties with




9      contamination for safe use of the property.





10            The third  alternative  involves capping.





11     Capping is simply an impervious layer that would be





12     placed over the area of contaminated soil.  This is




13     a generalized figure.   And it would simply prevent





14     water from entering the contaminated soil, and if





15     it's above the cleanup objective,  then





16     contaminating or  adding contamination to the




17     groundwater.   Alternative three would also involve





18     access restrictions,  so that the integrity of the





19     cap would be maintained.





20            Also a groundwater monitoring program would




21     be instituted with this remedy,  whereby the





22     groundwater that  enter -  -  that enter and leaves the





23     source areas would be analyzed.   We would look at

-------
1      the groundwater quality over time,  and if over a





2      certain period of time the groundwater quality





3      improves sufficiently,  that would be the end of the





4      remedy.   However,  if it does not improve,  EPA may




5      require that the groundwater at the source areas be





6      pumped and treated,  and this would prevent the





7      contamination from getting toward municipal wells.





8             The fourth alternative is groundwater




9      treatment, and this  would simply involve putting





10     groundwater recovery wells at the source areas,





11     pumping that water and treating it.  No soil





12     treatment would be required or called for under




13     this alternative.





14            The fifth alternative,  alternative  five,





15     involves the application of two very similar





16     technologies,  soil vapor extraction and vacuum




17     enhanced recovery.  Both types of treatment





18     technologies involve drawing air through the





19     contaminated soil.  The contaminants for the site





20     evaporate, and by pulling the air through the




21     contaminated soil over time, you would slowly





22     evaporate the contaminants and the concentration in





23     the soil would be reduced.  We would then institute

-------
1      a groundwater monitoring program which would be a





2      gauge to see how well the BER or SVE system would





3      be removing the contaminations - - contaminant





4      source from he soil to the groundwater.   And after




5      looking at the groundwater guality over time,  if





6      the groundwater guality improves enough





7      sufficiently so that source is not a threat to





8      the municipal wells,  that would be the end of the




9      remedy.   However,  if the groundwater guality does





10     not improve,  we may institute groundwater treatment





11     or the groundwater would be pumped and treated so





12     that it could not get to the municipal wells.




13            The sixth and final alternative is





14     excavation.   This would simply involve removing the





15     contaminated soil,  excavation it until clean soil





16     would be encountered.  Contaminated soul would be




17     transported off site and treated and then disposed





18     of.   A monitoring program would be set up,  as with





19     the other alternatives I mentioned.   Groundwater





20     guality would be monitored,  coming to and from the




21     site.  It improves sufficiently over time,  that





22     would be the end of the remedy.   However, if there





23     is still contamination and still a threat to the

-------
1      municipal wells,  EPA may require  groundwater





2      treatment at the  source areas.





3             Those are  the six potential  alternatives,  and





4      for the source areas EPA is  proposing the




5      following:   At the dry cleaners we  are proposing





6      that vacuum enhanced recovery or  soil vapor





7      extraction be used to remediate the soil at that





8      property.  Because this property  is located so




9      close to the Allegheny River,  the river may cause a





10     problem with the  vapor recovery wells that  would be





11     used in SVE or VER.   And because  of that, we're





12     proposing excavation to use  as a  backup remedy.




13     There will be a pilot test that will be conducted





14     at the Loohns Dry Cleaning property.   We're





15     planning on doing it later this year to see whether





16     or not VER or SVE would be the better technology.




17     VER works better  in an environment  or lower





18     permeability because it uses a higher vacuum.  And





19     the river is a potential problem, and if it is,





20     we'll go with excavation.




21            For the Alca  property we're  proposing that





22     vacuum enhanced recovery be  used.   The pilot test





23     was conducted at  the Alcas property,  and the test

-------
1      has shown that the technology will  be effective  in





2      remediating the soil for that property.





3            At AVX  we're proposing excavation.





4            And at  McGraw Edison,  you will recall  that  no




5      groundwater -  - no soil  contamination was  found  at





6      McGraw Edison.  Groundwater contamination  was found





7      in the upper and lower aguifer.  The contamination





8      from the lower aguifer is currently being  pumped by




9      the facility and traced  as we speak today,  but the





10     upper aguifer  is not treated, and we're  proposing





11     that,  a groundwater pump in the  treatment





12     system be used to remediate the  upper aguifer




13     McGraw Edison.





14            The next steps:   EPA will evaluate  and





15     respond to any guestions and comments on the





16     proposed plan  which are  received tonight and  during




17     the public comment period which  began on July 9th





18     and will end on August 8th.  This will be  done in  a





19     responsiveness summary.   The summary will  become





20     part of the Record of Decision for  the site.   The




21     Record of Decision will  also include a description





22     of the final alternatives selected  by EPA,  and the





23     rationale for  selecting  it.  EPA will place the

-------
1      Record of Decision in - - will place the ROD,  or the





2      Record of Decision,  in the administrative record,





3      which is located in EPA' s office at 290 Broadway in





4      New York City and at the public library.





5             And that  concludes my remarks.   Any





6      questions?  Yes,  sir.





7             STEWART HILL:   More of a comment than a





8      question,  but in reqards to your map,  where it





9      shows a private  dump on the AVX property,  that,  I





10     live on Seneca Avenue,  and that is in my backyard,





11     and that is not  a true perspective of the site of





12     that dump.  First of all, it was not a private





13     dump.  It was the loean Municipal City Landfill,





14     the first landfill in this area.  It was in





15     operation for about five years.  It takes in most





16     of that forty acres in the back there.   And if you





17     tried to excavate that land, you're qoinq to be





18     knee deep in solid waste.





19            MR. TACCONE:   You're talkinq about - -





20            STEWART HILL:   That landfill was never





21     properly maintained,  it was never capped,  it was





22     never sealed and it was never drained.   There is a





23     whole lot of sump holes in that field where

-------
1      groundwater lays continuously.   There is,  the area





2      that's,  that's depicted there is not a true size of





3      that dump at all.   It takes in the,  most of that





4      whole field.  And to excavate that area,  if you go





5      down more than a foot,  you're going to be in solid





6      waste.





7            MR.  TACCONE:   The area that we're proposing





8      for AVX  is right around here.  The area that I





9      think you're referring to - -





10           STEWARD HILL:   I'm referring to what's - -





11           MR.  TACCONE:   -  - that I  think you're





12     referring to was called the Seneca Landfill.





13           STEWART HILL:   Right.





14           MR.  TACCONE:   And that's  located right over





15     here. This private dump is really separate from





16     that.





17           STEWART HILL:  Well -  -





18           MR.  TACCONE:   So the excavation that we're





19     going to be doing isn't really going to be in this





20     area. It's very sharply delineated,  and it's in





21     this part of the property.





22           STEWART HILL:   The private dump has nothing





23     to do with the landfill?

-------
1             MR.  TACCONE:   No,  sir.





2             STEVE  SCHARF:   That  was  just  an  area where





3      people disposed of household goods over the  last





4      maybe thirty,  forty years,  I'm not sure.





5             STEWART HILL:   Well,  that  private  dump was





6      used for household disposal at  that  time,  back





7      probably seventy years ago.   Nobody  been dumping





8      down there that I know of in the  last thirty years.





9             MR.  TACCONE:   I think that was considered





10     for this study,  but was eliminated as an area for





11     sampling because we didn't  think  that it had





12     contamination that was getting  to the,  anything -  -





13     any,  any source to the groundwater.   But I think it





14     was considered.





15            STEVE  SCHARF:   Steve Scharf from DEC.





16     There's also  cluster wells  put  in 1984  that  did





17     not show contamination,  downgraded from the  Seneca





18     Avenue Landfill.  And what  Tom Taccone  is trying to





19     tell you is what is called  a private dump is  just





20     an area that  was indiscriminate disposal,  maybe it





21     was earlier than forty years ago, we're not  sure,





22     but that's separate from the landfill that was





23     operated by the City of Clean I believe in the

-------
1      1930s,  is what you're referring to.





2             STEWART HILL:   I was  under  the  assumption





3      that that meant for the  landfill,  the  landfill  is





4      through the - - the landfill site  is to the west of





5      what is marked as a private  dump and takes  in that





6      whole area.





7             STEVE SCHARF:   That's correct.





8             MR.  LYNCH:   This area here.





9             STEWART HILL:   But  there's  none of that  area





10     that would be excavated?





11            STEVE SCHARF:   No.  The  other thing  Tom  is





12     referring to is directly behind the AVX building,





13     and it's a localized hot spot of soil  that's





14     contaminated above the cleanup  criteria for organic





15     volume - - organics.   And  the landfill was,  the city





16     ceased to use that probably  before World Was II, if





17     I'm - - I think the city sopped using  that  Seneca





18     Avenue Landfill - -





19            STEWART HILL:   No.  No.   They closed it  in





20     '53 or '54.





21            STEVE SCHARF:   '53, I stand corrected.





22            STEWART HILL:   It was open  for  about five





23     years,  I would say roughly from 1950 to 1954,

-------
1      something like that.





2             STEVE  SCHARF:   But  those  are  three  separate





3      areas.





4             STEWART HILL:   And  the  landfill  area is  not





5      suspect of any contamination at  all?





6             STEVE  SCHARF:   Not,  we  have not  determined





7      that to be contaminated.   We determined that wasn't





8      any contamination from the - - from  the original





9      investigation.





10            MR.  LYNCH:   Yes.





11            JOHN MITCHELL:   Can you comment  on  the





12     effects of the monitoring  wells  and  the wells that,





13     the changes in the city wells  and the other well





14     that are being pumped in terms of concentrations





15     since the strippers and, you know, since the





16     initial program was into effect?





17            MR.  TACCONE:   Well,  the,  you  mean the





18     concentrations in the inflow at  the  municipal





19     well?





20            JOHN MITCHELL:   Right.





21            MR.  TACCONE:   Oh, it's  -  - I,  I  guess early





22     in 1990 when the testing was first started, it  went





23     up to two to,  two hundred  and fifty  parts  per

-------
1      billion,  I think.   Now it's down around twenty.   It





2      seems to be hover  around twenty,  at both wells,  18





3      and the two wells  south.





4             Yes,  sir.




5             STEWART  HILL:   The wells  that are pumping up





6      that are being  air stripped or whatever, whatever





7      the process is,  what is the,  the average amount  of





8      water that they're pumping the same as they were




9      pumping when they  were in operation for the city,





10     was it more or  less?





11            MR.  TACCONE:   I don't  know the answer to





12     that guestion.




13            STEVE SCHARF:   I'd say it's about the same as





14     it was prior to turning it off.   In other words,





15     they turned - - they put the  wells in there in 1979,





16     three municipal wells.  At that  time they were




17     pumping I think around,  around two,  two and a half





18     million gallons a  day total,  and currently that's





19     the same amount of water they're pumping on those





20     three wells.




21            STEWART  HILL:   When they  turned those wells





22     on in '79,  we had,  oh, probably  twenty wells in





23     that vicinity,  East Clean, go dry, and there was

-------
1      some concern about whether the city wells  were  the





2      culprit,  taking the water.   At that time the





3      engineers explained that it was impossible until





4      they decided that they were taking the  TCE out  of




5      that area also.   And then they conceded that the,





6      the fact  that the water was coming from that





7      vicinity.  I'm somewhat concerned that  if  these





8      three wells start pumping at their full potential,




9      we're going to have well problems again.   But you





10     say they  are,  they are pumping at their full





11     potential now.





12            STEVE SCHARF:   Well,  they're pumping at  the




13     same rate that they were before they turned them





14     off,  is what I'm saying.  And Libby Ford - -





15            LIBBY FORD:   I'm Libby Ford,  and I  was the





16     coordinator of the RI/FS for the Clean  cooperating




17     indurates.   The wells,  the three municipal wells





18     today are pumping at approximately the  same rate





19     they were prior to the shutdown in 1981,  and have





20     been for  six years.  There was a concern that they




21     -- there  were guestions raised as to whether or





22     not they  been causing some private wells to go





23     dry back  just about the time they were  shut down.

-------
1      You know,  we were ordered to supply them with the





2      treatment  and to turn them back on.   We  turned them





3      back on,  and it has been six years  now.   So if your





4      wells haven't had a problem,  particularly back last





5      summer when it was so dry,  you're probably going to





6      be okay,  but there is no guarantee.   But they're





7      being pumped at the same rate they  were  before.





8             GARY ABRAHAM:        Gary Abraham.  When you do the





9      vapor extraction process,  where do  the vapors go?





10            MR.  TACCONE:   They would go  into  a carbon





11     adsorption type of a filter,  which  would capture





12     any contaminants in the vapor before being emitted





13     into the  air.  So the air would --  the vapor would





14     be -- the  contaminants would be removed  from the





15     air before it would be discharged.





16            STEVE SCHARF:   I'd like to add something,





17     something that you put together here, the





18     properties that were determined not to be -- oh,





19     I'm sorry.   Steve Scharf,  from DEC.   I'll just add,





20     be more specific on something you put together.





21     when you  said the properties that were investigated





22     but not determined to be a source of contamination





23     to the groundwater,  it should be stated  the

-------
1      municipal groundwater aquifer,  lower aquifer,  and





2      that Clean Steel is listed as the second property





3      investigated,  is being referred by the EPA to  the





4      DEC for investigation based on data that was





5      encountered by samples from EPA,  so just for the





6      record,  say that.





7             KATHY KELLOGG:   Kathy Kellogg,  Buffalo  News.





8      What type of cleanup is going to proceed at Clean





9      Steel?





10            STEVE SCHARF:   Currently,  the well that we





11     are talking about is at the front of the property,





12     and there was  some product that was found in there





13     based upon sampling that was done by the EPA,





14     Edison,  and it's covered under the stat section  in





15     the proposed plan,  and they found pcbs in the





16     well.   And so  the DEC spill response unit has  gone





17     out and resembled that well,  and there's also  been





18     a report,  Maurice,  maybe you could add some





19     information to this,  there's been a report of  a  pcb





20     spill on the property,  and it's being looked at,





21     currently being looked at by the DEC spill response





22     program.





23            KATHY KELLOGG:   It that  -  -

-------
1             MR.  LYNCH:   To  give  a  little  history  on  that





2      is EPA did go out  and  take  a  removal action  on  the





3      site.   Tom could comment on what was removed from





4      the site,  to remove an immediate problem,  but this





5      sample that Steve  referred  to we don't feel  has the





6      potential  to get into  the municipal  wells, so we





7      cannot address it  under the Superfund site and  the





8      Clean Well Field Site.   Therefore, we've referred





9      it to the  State,  and the State will  investigate





10     there.





11            STEVE SCHARF:  We are  taking  their





12     information and we are  taking it to  be a step





13     further.





14            KATHY KELLOGG:   Will that be  a State





15     Superfund,  or is that  --





16            STEVE SCHARF:  Currently it's not listed,  is





17     not listed as a class  two act of hazardous waste





18     site.   However,  we've  had this report of the pcb





19     spill, and so currently the spill response team is





20     out there,  has taken a  sample and we're waiting to





21     get the results back.   That's not to say it's not





22     possible that -- it is  possible that in the  future





23     the Clean  Steel property may  be listed as  a

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1      hazardous waste site by the State,  based upon





2      information that we are going to be gathering at





3      the site.





4             MR.  TACCONE:   Yes.





5             KATHY KELLOGG:   Are  there,  are  there  any





6      people whose wells,  whose private wells were





7      contaminated who refused to be hooked  up to  the





8      city's water supply?





9             MR.  TACCONE:   Yes,  there were a group of





10     people that did refuse that.





11            KATHY KELLOGG:   Have there been any attempts





12     to draw those people into the





13            MR.  TACCONE:    Water supply system?





14            KATHY KELLOGG:   Yes.





15            MR.  TACCONE:   Hookup.





16            KATHY KELLOGG:   Encourage them  or educate





17     them.





18            MR.  TACCONE:   I believe the Department of





19     Health did,  and Lani,  can you help me?





20            LANI  RAFERTY:   Lani  Raferty from the  State





21     Health Department.   We did send letters to some





22     homeowners who had private wells still within the





23     contaminant plume requesting that we sample  their,

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1      their wells or,  and/or that they connect to the





2      municipal water  system.   We have encouraged the





3      people to connect a few times,  and they still have





4      not been interested in doing so.  And that's





5      certainly an individual choice.   So that's





6      basically all that we can do.   We recommend that





7      people within the plume connect to the municipal





8      water system, but that's,  that's as far as we can





9      go.





10            KATHY KELLOGG:   Do you have any idea how many





11     have not been --





12            LANI RAFFERTY:   Well, there are three homes





13     that have contaminants in their wells.  They did





14     not connect to the water system, to the public





15     water supply.   There are other homes who have wells





16     still and did not connect to the water supply,  but





17     their wells have not been contaminated that we have





18     been able to determine.   So I would say there are





19     about six.   That's a rough figure, but somewhere





20     around there.





21            KATHY KELLOGG:   Thank you.





22            JOHN MITCHELL:   Could I  ask what time frame





23     they were last checked or,  these wells, any wells?

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1             LANI  RAFFERTY:    Samples,  you mean?





2             JOHN  MITCHELL:   Yes.





3             LANI  RAFFERTY:   Sampled?   We  sampled them





4      last September,  I believe.





5             STEWART HILL:   The wells  on Seneca Avenue,  in





6      that area, were  tested about the time that  this was





7      discovered.   They had never been retested  since,





8      best of my knowledge.   Do  you intend to resemble





9      those wells?





10            LANI  RAFFERTY:   We never  found any indication





11     that there was  contamination up  in that area,  and





12     so we didn't pursue sampling wells.





13            STEWART HILL:   All the wells  were





14     contaminated.





15            LANI  RAFERTY:   I'm not saying that —





16            STEWART HILL:   All the ones that I was  aware





17     of were contaminated,  but  the contamination level





18     was below what was considered a  hazard.





19            LANI  RAFFERTY :   Tom,  can you indicate  on the





20     map the extent  of the public water,  do you  have





21     that information handy?





22            MR. TACCONE:   You mean where  the water





23     supply was extended?

-------
1             LANI  RAFFERTY:   Yes.





2             MR. TACCONE:   Let's  see,  right around here,





3      and down,  and down Schaefer Road.





4             STEVE SCHART:   As  far as  Haskell Road,  which





5      is right where your hand is there.





6             MR. TACCONE:   Right  here?





7             STEVE SCHARF:   Little further,  further down.





8             MR. TACCONE:   Right  there?





9             STEVE SCHARF:   Yes.





10            MR. TACCONE:   Oh,  yeah,  right here,  right.





11            STEVE SCHARF:   And then up  to the road about





12     as far as the end of the McGraw Edison property.





13            MR. TACCONE:   And down Schaefer Road,





14     Schaefer Street,  yep.





15            LANI  RAFFERTY:   Okay.  So you're saying you





16     have information that indicates that there are some





17     wells —





18            STEWART HILL:   There, that's Seneca Avenue.





19            LANI  RAFFERTY:   Right,  the  one that runs





20     along —





21            STEWART HILL:   Yeah,  that's  Seneca Avenue.





22            LANI  RAFFERTY:    —   where AVE is,  right?





23            STEWART HILL:   Right, all those wells in

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1      there were contaminated,  but they were contaminated





2      with very low amount of TCE,  and it was never





3      considered to be a health hazard.   My question is,





4      are they going to be tested again?





5             LANI  RAFFERTY:   I'm not  aware of that





6      information.  If you could,  if  you could maybe talk





7      to me afterwards,  you can indicate to me.   If we





8      have an indication that there's wells contaminated





9      up there,  then we certainly would sample them.   So





10     if you have  information that indicates that there





11     are,  talk to me afterwards.





12            STEWART HILL:   Well,  in  some ways I  have to





13     report,  I have a report saying  that my well had so





14     many parts per billion of TCE,  but it was very low





15     amount.





16            STEVE SCHARF:   Is  it  possible for the  Health





17     Department to sample -- is it possible for  the





18     Health Department to take a sample from the homes





19     on Seneca Avenue if they request it?





20            LANI  RAFFERTY:   We can look at the





21     information and,  you know,  evaluate it.  That's,





22     that's the approach that we would take.  We don't





23     normally just randomly sample wells, but if we have

-------
1      information that indicates that there might be a





2      problem,  we certainly would be willing to sample.





3      So maybe  we could talk afterwards,  and you can





4      indicate  to me the area that you're concerned





5      about,  and evaluate that.





6             LIBBY FORD:   Lani,  I believe that data is a





7      1985 -- the evidence was collected in the 1985





8      RI/FS,  and it was collected in the 80- '81 time





9      frame,  as I recall.  And the gentleman is correct,





10     it did show, as I recall,  about zero to four parts





11     per billion.





12            LANI RAFFERTY:   Of?





13            LIBBY FORD:   Of the various  VOCS  —  I can't





14     recall the TCE —





15            LANL RAFFERTY:   Okay.   We'll certainly look





16     at that again,  and it sound like it might warrant





17     another trip out there,  sample some private wells.





18            MR.  TACCONE:  Yes?





19            KATHEY KELLOGG:   Kathy Kellogg again.   You





20     listed, I think there were five people who signed a





21     consent order,  five companies?





22            MR.  TACCONE:  Five  companies,  yes.





23            KATHY KELLOGG:   Would you list them again for

-------
1      me,  and were they making any -- paying any of the





2      costs of the phase one or phase two?





3             MR.  TACCONE:  Well,  the  --  let's  see,  it's





4      Alcas,  AVX,  Aluminum Company of America,  McGraw





5      Edison,  and Cooper Industries.   That was the 1991





6      consent order.   And there is a  provision in the





7      order for it,  to repay -- to pay EPA any costs that





8      it incurs for overseeing the cleanup of the site.





9             MR.  LYNCH:   They actually performed the





10     study,  the investigation/feasibility study that was





11     performed,  and the past costs for  the air stripper.





12            MR.  TACCONE:  That's already been resolved.





13     I mean --





14            MR.  LYNCH:   Right,  but they were  the ones who





15     paid for it.





16            MR.  TACCONE:  Yes.





17            MR.  LYNCH:   They did pay for the  work that





18     had been done previously.





19            KATHY KELLOGG:   Do you know how much that





20     was?





21            MR.  TACCONE:  Sharon,  would you be able





22     to —





23            SHARON KIVOWITZ:   Not offhand,  I'm sorry,  I

-------
1      don't.   I could get that information to you exactly





2      how much was paid.   I'm looking now to see if I've





3      got anything in my files.





4             KATHY KELLOGG:   Will  those  PRPs be





5      responsible for any future costs?





6             MR.  TACCONE  :   Yes.





7             KATHY KELLOGG:   What?





8             MR.  LYNCH:   What we will do after we sign





9      Record of Decision, we will  approach them and ask





10     them to perform the design and implement the remedy





11     we select.   And we will go into a  series of





12     negotiations with them, and  in an  attempt  to get





13     them to perform it.  This  would be,  on this now,





14     for only the action for each individual site,  but





15     they would be responsible  now for  the source





16     control for their particular site, as in AVX for





17     the action we would take at  AVX, et cetera.





18            SHARON KIVOWITZ:  If  you could give me  your





19     card after the meeting, I  can give you the





20     information of who, the entire enforcement





21     history.   I'm Sharon Kivowitz with the EPA.





22            MR.  TACCONE:  Yes,  sir.





23            JOHN HART:   I'm John  Hart,  from Olean.   Can

-------
1      you predict the length of time that the





2      implementation of the remedies that your,  your





3      preferred remedies will take? And is - - and the





4      second question is,  are there any other plans after




5      the implementation of this phase?





6             MR.  TACCONE:   Well,  the soil remediation at





7      the areas where the soil is contaminated should





8      take about,  approximately five years.   The




9      groundwater usually take a little longer than





10     that.   It would be on the order of a thirty year





11     time frame,  but that's, that's a very rough





12     approximation.   As far as the next phase,  there is




13     - - there isn't a next phase planned.   I mean,





14     this,  this is the second phase or a second operable





15     unit.   The first one took care of the groundwater





16     problem.   That was the air strippers that are




17     currently operating and treating the groundwater.





18     This second phase is the, is a source control.





19     We're going after, in this study, what's causing





20     the contamination, and those are the two component




21     parts of  the plan.





22            Yes,  sir.




23            STEWART  HILL:   Is there an estimated time

-------
1      when the city wells will  be put back in service?





2             MR.  TACCONE:   The  city wells  are back  in





3      service.





4             STEWART HILL:   They're using  the water?





5             MR.  TACCONE:   Yes.   The  water that's pumped





6      from the groundwater goes through these air





7      strippers,  which removes  the TCE to  below the





8      drinking water levels,  and then goes into the water





9      supply.  And it's tested  on a regular basis,  and





10     since the air strippers have been put up on  line,





11     they've been effectively  treating the groundwater.





12            STEWART HILL:   What's, there's no





13     contamination in the water going into the city -  -





14            MR.  TACCONE:   No.   It's  way below the  safe





15     drinking water levels.





16            SHARON KIVOWITZ:   What's coming out is below





17     the safe drinking water levels.





18            MR.  TACCONE:   Yes.





19            SHARON KIVOWITZ:   There  still is





20     contamination going in, which is why the source





21     areas are being,  which is the purpose of this - -





22     unit, but what's coming out and what's going  into





23     people's faucets is going through this treatment

-------
1      process.





2             MR.  TACCONE:   Safe  water.   Yes.





3             WAYNE  MIZERAK:  Wayne Mizerak,  from DEC,  New





4      York State DEC.   You gave  him a time frame for





5      implementing  the remedy.   Can you give a similar





6      time frame as to how long  negotiations can be





7      expected before  the  remedy can start being





8      implemented,  because that's part of the whole time





9      frame?  How,  how willing are  they to negotiate to





10     get into this?  Are  they willing to go ahead and





11     go,  or are they  going to take  a while to do this?





12     We had that in our program, that would be





13     something,  information they would need,  get an idea





14     of implementation.





15            MR.  LYNCH:  What  our time frame is,  after we





16     signed the ROD,  we will  send  out what is called





17     special notice to the companies.   And we then go





18     into a hundred twenty day  moratorium period





19     where we can't take  action while we negotiate.   And





20     what we aim for  is that  at the end of that hundred





21     and twenty day period, we  either have an agreement





22     or we don't.   And at that  point we can either pay





23     for the remedy ourselves,  to  implement it,  or we

-------
1      can order them to do it administratively.   If they





2      cooperate,  it starts then.   If not,  then our choices





3      is,  do we go into court to  require them to do the





4      action,  to follow that administrative order,  or do





5      we pay for it ourselves,  and then go after,  after





6      them later to pay for it.   So hopefully it should





7      be,  what we're aiming at is after a hundred and





8      twenty days we will then start the process.





9             If there are no more questions,  I would like





10     to thank everyone for coming out.  And if  you have





11     questions later,  you either write to us in the





12     address that is in the proposed plan or you can





13     call us,  I believe Tom's phone number is in there





14     too, and we'll be glad to discuss any aspects of





15     the site that you have.  Thank you.





16               (The meeting concluded at  8:09 P.M.)





17





18




-I Q                   *****






20





21





22





23

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APPENDIX V
RESPONSIVENESS SUMMARY
APPENDIX E
LETTERS SUBMITTED DURING THE PUBLIC COMMENT PERIOD
                                                   Nixon, Hargrave, Devans & Doyle LLP
                                                     Attorneys and Counselors at Law
                                                             CLINTON SQUARE
                                                          POST OFFICE BOX 1051

                                                     ROCHESTER, NEW YORK 14603-1051
                                                              (716) 263-1000
                                                            FAX  (716) 263-1600
        ONE KEYCORP PLAZA
  437 MADISON AVENUE
     ALBANY, NEW YORK 12207
NEW YORK, NEW YORK 10022
          (518)  427-2650
     (212) 940-3000

      1600 MAIN PLACE TOWER
        SUITE 700
     BUFFALO, NEW YORK 14202
   ONE THOMAS CIRCLE
          (716)  853-8100
   WASHINGTON D.C. 20005

     (202) 457-5300
       990 STEWART AVENUE
   GARDEN CITY, NEW YORK 11530
(716) 263-1606
          (516)  832-7500

July 18, 1996

VIA FAX AND CERTIFIED MAIL - RETURN RECEIPT REQUESTED

Chief, NY/Caribbean Superfund Branch II
U.S. Environmental Protection Agency Region II
Emergency & Remedial Response Division
290n Broadway - 20th Floor
New York, New York 10007-1866

Attention:    Thomas Taccone,  Clean Wellfield Site Project
             Coordinator

RE:   Olean Wellfield Supplemental RI/FS Administrative
      Consent Order No. II-CERCLA-10202 Comments on EPA
      Imposed revisions to SFS and Notice of Issue
      Submitted for Dispute Resolution

Dear Tom:

In accordance with Article XVII of the above referenced Administrative Order, this letter serves to not only
fully reply the issues raised in EPA's July 3, 1996 SFS Letter and the attached unilaterally imposed
"Preface" to the SFS Report, but also a notice on behalf of the Olean Cooperating Industries  ("CIs") to EPA
that we are triggering the Dispute Resolution provisions under that Order.  In keeping with paragraph 87 of
the Order, dispute resolution of these issues is expressly allowed under that Order because the July 3, 1996
letter constituted EPA's imposition of "reguired revisions to the Draft SFS" pursuant to paragraph 56(b) of
the Order.  While our offices were closed on July 5, 1996  (the earliest date the July 3, 1996 letter could

-------
have arrived), we are submitting this notice within 14 days of that date in order to avoid any question as to
whether we have given timely notice to the Agency.

Because we strongly disagree with many of the statements made in EPA's July 3, 1996 letter and its enclosure,
and because we believe that the bases for our disagreement are factual and key to the ultimate decisions
which EPA will be making with respect to supplemental remedial measures within the Clean Wellfield, we
request that this letter be included as an official part of the Administrative Record for the Clean Wellfield
SRI/FS.

While the Clean CI's have disagreement and/or concerns with most of the content of the July 3rd EPA Letter,
they wish to submit three specific issues for formal dispute resolution. Nevertheless, the remaining issues
are important and deserving of correction. The main text of this letter sets out the areas for dispute
resolution, while Appendix A addresses the other comments in response to EPA's July 3, 1996 letter and its
attached unilateral Preface. The Clean CI's continue to believe that the final SFS (including any Preface),
the final RAP and the ROD must address not only the three issues set forth in the main body of this letter
but those included in Appendix A.

The Clean CI's hereby invoke the Dispute Resolution provisions (Article XVII) of the above referenced
Administrative Order with regard to the following issues:

1. The Objectives of the SRI/FS

2. In order to be complete and to fully address the mandated NCP evaluation, the SFS must include a factual
discussion of past pumpage of the groundwater beneath the AVX property and its inability to significantly
remove VOC mass.

3. The Stage 2 (groundwater pump and treat) "triggers" must reflect the SRI/FS Objectives and be tied to
completion of the Stage 1 remedial measures at all four of the identified source areas.

Each of these issues is discussed below.

1. What are the Objectives of the SRI/FS?

From the initiation of the Clean Wellfield SRI/FS process, the Olean Cooperating Industries, with EPA
concurrence, have viewed the SRI/FS as a continuation of the overall investigation and cleanup of the
Volatile Organic Contaminants ("VOC") within the wellfield aquifer. The 1995 and 1996 SRI and SFS Reports
build upon, and are integral with, the investigations done pursuant to the initial listing of the Olean
Wellfield superfund site. Similarly the decisions on future remediation arising from the SRI/FS process have
also been envisioned as complementing and supplementing (specifically in the form of expediting) the remedies
ordered under the 1985 ROD. Thus the Objectives of the SRI/FS are interconnected to the original RI/FS and
subsequent ROD.

In accordance with the 1985 ROD, the Olean Cis undertook a number of remedial measures. The remedial measure
which, on a continuing basis is directly tied to the SRI/FS Objectives was the construction and operation of
municipal air strippers on three City of Olean pumping wells, wells 18M, 37M and 38M. While the intent of
the air stripping system on the three wells was to ensure a safe drinking water supply to City and Town
residents, it was recognized that pumping and treatment of the Wellfield aquifer would

also provide a level of groundwater rehabilitation. Prevention and treatment at the municipal wells
would prevent the further spread of groundwater contamination, and would eventually reduce the levels
of VOC contaminants in groundwater.

The 1985 RI/FS also evaluated "an enhanced groundwater rehabilitation alternative" involving the installation
of an additional recovery well and treatment system." (Id.) The RI/FS concluded that while "[plumping and
treatment at the recovery well, in conjunction with pumping and treatment at the municipal wells, would
achieve further cleanup of VOC contaminants . . . [i]t is uncertain whether the benefits of enhanced
groundwater rehabilitation justifies the additional response ... as neither level of groundwater

-------
rehabilitation can be expected to restore the quality of groundwater to a level for use without treatment in
the foreseeable future"  (Id.)

Subsequently, EPA issued its Record of Decision  ("ROD")  adopting the recommendations included in the RI/FS
and also calling for the SRI/FS to determine if source control elsewhere in the aquifer could "expedite the
treatment of the contaminated aquifer, and to identify if another possible source of contamination exists
which may necessitate further action."

In 1990 The National Contingency Plan  ("NCP") was modified to include a formal statement of the
"expectations" EPA would follow in "developing appropriate remedial alternatives."  One of the expectations
added to the NCP was "to return usable groundwaters to their beneficial uses wherever practicable, within a
timeframe that is reasonable given the particular circumstances of the site."  (40 CFR § 300.430
(a) (iii) (F) .)  While the Clean CI's have acknowledged this NCP requirement, we have insisted, from before the
above referenced Administrative Order was signed  (June 1991),  that application of this provision be done in
the context of the Clean Wellfield SRI/FS, which is a supplemental investigation and study.  The 1985 ROD
ordered remediation which, while not explicitly stated in terms of the above NCP criteria, certainly was in
keeping with the spirit of this NCP expectation which was not incorporated into the regulations until 5 years
after the ROD was issued.

The Olean CI's have done their best since 1985 to ensure that all parties understood and agreed to the
Objectives of the SRI/FS.  Before we signed the SRI/FS Administrative Order  (referenced in the caption), we
made sure that:

1.     The SRI/FS Workplan (which had been put together by an EPA contractor) was modified to clearly  state
the objectives as we understood them.

2.     That paragraph 56(b)  was included in the Administrative Order.   Paragraph 56 (b)  states

       EPA's comments on, modifications to and directions for changes  to deliverables under this Order will
       be consistent with the terms of this Order and the objectives of the Supplemental RI/FS as set forth
       in the Work Plan; will not require the performance of work inconsistent with the division of labor
       between Respondents and EPA described in paragraphs 36-39,  above; and will neither be inconsistent
       with the  NCP nor arbitrary and capricious.  (Emphasis added.)

Despite the above provisions, even before the SRI was finalized, EPA began to indicate that it did not feel
that its future decisions were bound by the 1985 ROD and the agreed upon SRI/FS Objectives  (as set out in the
EPA Approved Workplan amendments).   The Olean CI's repeatedly tried to seek clarification of this and a
written commitment from EPA on just what the Objectives of the SRI were.  Time after time, we received verbal
assurances from EPA that it was not seeking to expand the agreed upon SRI/FS scope.  On January 14, 1994 our
concerns were again heightened and we attempted to pin EPA down by triggering the Dispute Resolution process
following an EPA letter dated January 10, 1994.  EPA rejected our efforts to trigger dispute resolution
(saying that its January 10,  1994 letter did not constitute final action on either the SRI or SFS reports,
and hence it could not be the subject of dispute resolution).   As a consequence,  however, it did issue a
letter dated February 25, 1994 which finally addressed this issue.  That letter acknowledges that the
objectives of the SRI/FS includes those set forth in the 1985 ROD and in the SRI/FS Objective.   (See Appendix
B.)

After receiving this letter the Olean CI's were under the clear understanding that while EPA would continue
to examine the identified remedial measures in the context of their ability to protect and restore the
aquifer, this examination would be done within the overall framework of the SRI/FS objectives. After
receiving this letter we submitted revised "Remedial Action Objectives: ("RAOs")  EPA edited to conform with
the EPA letter.   (See Appendix C.)   As called for under the Administrative Order, those RAOs became the SFS
objectives.  They were also discussed in the introduction of the SRI Report, which EPA approved on June 30,
1995.  They also have been clearly stated in all SFS-related submittals.

When we have questioned EPA why its SFS comments on this issue  (which ultimately were "resolved" in the first
three bullets on the July 3,  1996 Unilateral Preface to the SFS Report) continued to be included in EPA

-------
comment letters subsequent to EPA's February 25, 1994 letter we were told that this was for "administrative
reasons". In addition, we were told by EPA (Kevin Lynch) that our continued inclusion of the language would
not jeopardize the approval of the SFS. At no time did EPA even hint that it was planning to unilaterally
remove this language from the SFS. Thus, we continued to believe the issue had been satisfactorily resolved.

As EPA clearly indicated in its February 25, 1994 letter, the beneficial use of the Clean Wellfield aguifer
is for drinking water. As such, the first two bullets of the stated RAOs ("Remedial Action Objectives") for
groundwater are clearly intended to support the continued beneficial use of the aguifer for drinking water.
The remaining groundwater RAO and the three soil RAOs are meant to support the first two groundwater RAOs.
The disputed phrase "if such restoration will expedite the current treatment of the aguifer [which is being
done] at the municipal wells" is included to provide the pertinent timeframe against which the "reasonable
timeframe" NCP criteria can be made. To facilitate applying this NCP criteria the following
summary/conclusion statements were included in the approved SRI:

! Overall, total VOC concentrations in groundwater influent to Municipal Wells 18M and
37/38M have declined approximately 75 to 82 percent since these wells went back into
full-time service in February 1990.

! The SRI data indicate that, in general, groundwater quality within the upper and lower
aguifer monitoring wells in the Clean Well Field is improving as a result of the
remedial measures already in place. However, despite the effectiveness of these
measures, VOC concentrations, in the identified soil source areas and the existence (or
former existence) of non-point VOC sources within the upper aguifer may be such that
operation of the air stripping systems on the three municipal wells may be needed
indefinitely. Remediation in the identified source areas is expected to lead to
guantifiable groundwater guality improvement.

! The SRI data indicate that the remedial measures in place have already resulted in
significant improvements in water guality within the aguifer. Despite the effectiveness
of these measures, background levels of VOCs in groundwater are such that operation of
the air stripping systems on the three municipal wells is likely to be needed
indefinitely.

As is widely acknowledged within the environmental technical profession including within both EPA and NYDEC,
aguifer rehabilitation/restoration by groundwater pump and treat is an extended progress that, at many
locations, is unable to "rehabilitate/restore" an aguifer. It is ironic that this issue has become such a
sticking point for EPA with respect to the Clean Wellfield SFS since, through its imposition of the Stage 2
remedies in the SFS, EPA has simply called for complementing the ongoing and effective groundwater pump and
treatment system (co-located at the three municipal wells) with possibly two other groundwater pump and
treatment systems. One at the AVX source area where EPA has acknowledged that such a system will not be
effective as treatment mechanism, but only as a containment mechanism, and one at Olean Clean All\Loohns
where the proximity of the Rivers also calls into guestion the effectiveness of such a system.

In the opinion of the Olean CI's, successful resolution of this matter can only be accomplished by allowing
the language at issue to remain in the SFS report. This will allow the SRI and SFS reports to be internally
consistent. As we have acknowledged all along, EPA can certainly clarify in its PRAP and ROD how the
supplemental RI/FS objectives and the selected Remedial alternatives are consistent with the expectation of
40 CFR § 40. (a) (iii) (F) "to return usable groundwaters to their beneficial uses wherever practicable, within
a timeframe that is reasonable given the particular circumstances of the site." The Olean CI's are even
willing to discuss mutually agreeable "Preface" language addressing this issue.

When EPA ordered the Olean CIs to expand each of the Remedial Alternatives 3, 4 and 5 discussed in the SFS
report to include a second stage groundwater pump and treat remedy, this issue became one of much more
importance than just semantics and internal consistency. Because decisions as to whether groundwater pump
and treat will be necessary at any of the identified source areas will not be made until after the turn of
the century, it is vitally important that the SRI/FS and the subseguent RAP and ROD clearly spell out what
the objectives of the study were that led to the derivation of the Stage 2 portions of the selected remedies.

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The importance of this is further underscored by the subsequent two issue submitted for dispute resolution.

2. In order to be complete and to fully address the mandated NCP orders evaluation, the SFS must
include a factual discussion of past pumpage of the groundwater beneath the AVX property and its inability to
significantly remove VOC mass.

Through a series of imposed deletions and additions, EPA has stripped from the SFS the factual statements
which indicate that over 40 years of groundwater pumping (carried out in close proximity to the identified
source area) at the AVX site has not led to significant removal of VOC mass from the downgradient
groundwater. This fact is extremely important in an objective evaluation as the effectiveness of a pump and
treatment groundwater remedy at this site. We have already modified the SFS to support EPA's stated
intention of requiring, if necessary at Stage 2 groundwater pump and treat remedy as a containment measure at
the AVX source area. There is no justification for EPA to expunge the factual statements.

The removal of this language may have far reaching implications when the Stage 2 evaluations are performed
and decisions made as to whether the Stage 2 remedy must be constructed and activated at the AVX site. We
have also already accommodated EPA's stated intention of including the Stage 2 remedy in the ROD by asserting
(at EPA's request) that the implementation of the Stage 2 remedy at the AVX source area "would provide an
additional reduction in the risk..." (bullet 43) even though this reduction in risk, in actuality, is already
in place because the groundwater is already being pumped. Appendix D contains Geraghty & Miller's July 19,
1995 response to EPA's June 29, 1995 comments on the SFS and where the factual basis for the SFS statements
at issue were initially brought to EPA's attention. Subsequent to this submittal EPA stopped saying that
groundwater pump and treatment would be an "effective treatment" mechanism and, instead began to discuss it
as a "containment" option.

The NCP clearly instructs the Clean CIs and EPA to include this discussion. The very first "expectation"
included in 40 CFR § 300.430 (a) (iii) (A) of the NCP is that:

EPA expects to use treatment to address the principal threats posed by a site, wherever practicable.
(Emphasis added.)

In fact, without an examination of whether pump and treat will be an effective treatment measure, and a
conclusion that it is not practical, any SFS discussion about the effectiveness of groundwater pump and treat
as a containment measure and inclusion of Stage 2 pump and treat for containment purposes in the RAP and ROD
is inconsistent with the NCP. (See 40 CFR § 300.430 (a) (iii) (B)) .

Once again, the inclusion of this language in the SFS is necesary to allow decision makers in the year 2000
and beyond, to place in proper context EPA's decision to include a stage 2 remedy in the 1996 preferred
remedial alternative. Only in this way can an appropriate decision be made as to whether Stage 2 is
necessary and, if it is, whether the ROD ordered remedy of groundwater pump and treat is the proper remedy to
meet the SRI/FS objectives, or whether a ROD amendment to allow some other type of groundwater
treatment/containment measure to be used is warranted.

3. The Stage 2 (groundwater pump and treat) triggers must reflect the SRI/FS Objectives and be tied to
completion of the Stage 1 remedial measures at all of the 4 identified source areas.

Through these unilateral deletions and modifications EPA has abandoned most of the agreements we have reached
with it over the last year as to what would trigger the Stage 2 remedy. First, it has backed away from its
agreement that its "Guidance For Evaluating the Technical Impracticability of Groundwater Restoration" ("TI
Guidance") would guide decisions on whether the Stage 2 Groundwater pump and treat remedial measures would be
imposed. (Bullets 4, 6, 11, 14, 17, 27, 31, 41 and 42). (See Appendix E.)

Second, EPA has also apparently changed the starting timeframe for the initial Stage 2 review from 4 years
after all the remedial measures have been put into place, to a source area by source area review. Kevin
Lynch (as well as Tom Taccone) agreed that this review cycle should commence only after all the Stage 1
remedies were in place during our September 21, 1995 the remedial measures have been put into place, to a
source area by source area review. Kevin Lynch (as well as Tom Taccone) agreed that this review cycle should

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commence only after all the Stage 1 remedies were in place during our September 21, 1995 conference call.
This language has been reflected in every submittal to EPA since then. EPA never commented upon, or objected
to, this approach. (See Appendix E.)

Third, the modification to the Stage 2 "trigger language" (bullets 31 41 and 42) implies that if the
remediated source areas continue to "affect the groundwater entering the City Municipal wells M18, M37 and
M38" then Stage 2 will be triggered. This has long been a matter of discussion with EPA a conceptual
agreement was reached with Mr. Lynch and Mr. Taccone on this issue in the September 21, 1995 conference call
on this topic. The SFS language reflects this agreement. EPA's unilateral language not only ignores the
agreement reached, it can be interpreted as establishing a lower threshold for Stage 2, i.e. if a remediated
source area continues to have any "effect" on the three municipal wells. (See Appendix F,.)

Conclusion

The Clean CI's have worked closely with EPA on the SRI/FS project since at least 1989. We are extremely
disappointed and disheartened by the approach EPA chose to take in its July 3, 1996 letter and its attached
Unilateral Preamble to the SFS. We believe that preface contradicts many of the agreements and discussions
that have taken place between the agency and the Clean CI's over the last five years. For the reasons set
forth above and those discussed below in Appendix A, we believe that the record must be corrected and the
Unilateral Preamble either withdrawn or significantly modified before a ROD can be issued.

We look forward to a prompt reply to the issues raised in this letter. As always, if you have any guestions,
please do not hesitate to call me.

Very truly yours,

cc: SRI/FS Consent Order Distribution List
Michael O'Brien
Larry Blue
Brent O'Dell
Dennis Oldland
Robert Horger
Jim Stitt
Greg Shkuda
Russ Huber

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Appendix A

Point by Point Response to EPA's July 3, 1996 letter and its "Preface" to the Olean Wellfield SFS

A. July 3, 1996 Letter

SFS Report

We continue to disagree strongly with EPA' s assertion that our final draft did not properly evaluate the NCP
criteria. Rather than repeat what we said with regard to this issue in the past, we again reference our
letters dated [to be completed]. Furthermore, a review of 40 CFR § 300.430 (e) (iii) (3) which sets out the
NCP evaluation criteria and Section 4.1.2 of EPA's Draft "guidance for Conducting Remedial Investigations and
Feasibility Studies under CERCLA (October 1988) clearly indicates that the analyses we had done in the prior
draft of the SFS was in full compliance with both the NCP and EPA's Guidance. The fact that our SFS was not
organized in guite the same way EPA would have liked in no way detracted from the analyses. Our version of
the report presented the same information in a similar but differently organized fashion and would have
supported a logical, defensible analysis. What it did not completely support (from an organizational
approach) was EPA's pre-drafted PRAP which we understand was prepared over six months ago, EPA's July 3, 1995
letter at least partially acknowledges this when it stated "it's true that EPA used the information which was
already in the report...".

We agree that Mr. Taccone did not approve the Olean Cl's final set of submitted SFS changes during the May
15, 1996 telephone call. However on June 4, 1996 when Mr. Taccone called Ms. Ford with the instructions that
we were to finalize the SFS, she asked him if the changes we had submitted were acceptable, because we did
not want to go to the expense of printing the SFS if additional changes were going to be necessary. During
that conversation Mr. Taccone indicated that, while EPA had not completed its review of the proposed changes,
it was comfortable that any open items could be addressed through the PRAP/ROD process.

Remaining Issues in July 3, 1996 Letter

These are addressed either in the main body of this letter, or in the following discussion of the Unilateral
"Preface."

B. Unilateral SFS "Preface"

In order to facilitate review of the following, we suggest that each bullet in the Preface be assigned a
separate number (beginning with 1 and following seguentially until the last bullet which is bullet 55).

2. Section 2.1

Bullets 1-3

See issue #1 submitted for dispute resolution in the main body of this letter.

3. Sections 3.2.3, 3.2.4, 3.2.5, 3.4.1, 3.4.1.5, 3.4.1.6

Bullets 5, 7, 9, 12, 13,15, 16 and 18

With these changes EPA has rejected our suggested compromise between the prior draft of the SFS and EPA's
position, i.e. that, subseguent to the first 4 year Stage 2 review, all subseguent reviews be done in
conjunction with the statutorily mandated 5 year CERCLA reviews. EPA's basis for this is set forth in its
July 3, 1996 letter in item 2 under "SFS Report."

With respect to the practical implications of this EPA imposed change, it is probably not major and was one
that we had expressed a willingness to have further discussions on with EPA. We did not make these changes
in our Draft Final SFS because EPA had not yet informed us of its decision at the time it ordered us to
finalize the document, even though we had submitted this revised language to EPA for its consideration.

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Because of the actions taken in bullets 10, 13 and 16 (discussed below), there is now uncertainty as to
whether EPA intends to keep the Stage 2 review separate from the CERCLA § 121(c) review or to require that
review also be done on a 4 year cycle. We suggest that in the PRAP and ROD, EPA recognize that subsequent to
the first four year Stage 2 review there may be merit to combining any future Stage 2 reviews with the
subsequent 5 year CERCLA § 121(c) review.

Bullets 10, 13 and 16

EPA appears to have mistakenly removed from the SFS's short description of Remedial Alternatives 3, 4 and 5
the reference to the CERCLA § 121 (c) review. It did not remove reference to these reviews elsewhere in the
text (for example on page 3-19, last paragraph). Also its July 3, 1996 cover letter clearly states that EPA
intends that the CERCLA § 121(c) reviews be done, but on a separate schedule. We recommend that these
bullets be deleted from the Preface.

Bullets 4, 6, 8, 11, 14, 17

See the discussion below in Section 5 below.

4. Sections 3.2.3, 3.2.4, 3.2.5, 3.4.3, 3.4.4, 3.4.6

Bullets 19-24

These are simply editorial comments and do not improve the clarity of these sections. EPA had not previously
asked for these changes, or we would have made them. These changes could be included in either a SFS Errata
sheet or a revised final "Preface".

5. Sections 3.4.3.4, 3.4.3.4, 3.4.3.5, 3.4.3.6

Bullets 25, 28, 29 and 32 (and bullet 38 in Section 7 below)

See issue #2 submitted for dispute resolution in the main body of this letter.

Bullets 27, 30 and 33

Once again EPA has expunged all reference to the fact that the investigation it carried out on the Clean
Clean All ("OCA")/Loohn's site was insufficient to allow either its consultant or G&M to make a
determination, with the same level of certainty as was done for the three CI source areas, as to the
potential effectiveness of the Stage 2 groundwater pump and treatment remedy at this source area. EPA has
provided no written basis for its determination of potential effectiveness. With these deletions, the
OCA/Loohn's source is the only area not explicitly discussed in these sections. At the same time, EPA and
its technical consultant have acknowledged that the proximity of this site to the Allegany River does raise
significant questions not only of the effectiveness of the Stage 2 remedy, but also of VER at this source
area. We understand that despite this lack of groundwater data, EPA is going to recommend VER at the Clean
Clean All/Loohns source area. For this reason, in the PRAP EPA has adopted our recommendation that pilot
tests be carried out at the OCA/Loohns site before a decision is made as to whether to do VER or excavation
at this source area.

Bullets 27, 31 (as well as bullets 4, 6, 8, 11, 14, 17, 41, and 42 in previous and subsequent sections)

See issue #3 submitted for dispute resolution in the main body of this letter.

6. Section 4.1.2

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Bullet 34

See the comment above in Section 4.

7. Section 4.2.1.1

Bullets 35, 36, (and bullets 39, 40, 44, 45, 46 and 47. in subsequent sections)

The word "additional" was placed in these sections to underscore the fact that this is a Supplemental RI/FS
and that unlike the typical "No Action" and "Institutional Controls" RI/FS remedial alternatives, these
remedial alternatives would not be starting from ground zero (i.e. providing no protection of human health or
the environment), but rather that adoption of these remedies would not provide any protection in addition to
that which has already been provided.

From a practical viewpoint, the deletion of this word does not have any significant conseguence since these
are not the recommended remedial alternatives for any of the source areas. The deletion of this word could
confuse a reviewer in that it's presence acknowledges the supplemental nature of the SFS. Therefore, we
believe our original wording is warranted and serves to better remind a reviewer of the SFS that the remedial
measures discussed in it are intended to supplement the remedial measures already in place.

Bullet 37

As we had explained to EPA during a conference call after we received EPA's May 1996 "final" comments on the
SFS, Geraghty & Miller did not feel comfortable with the word "probability" as it pertains to a general
conclusion that groundwater migration of contaminants could occur after capping. This conclusion is very
site specific and depends on such factors as the volume of contaminated soil that would be beneath the top of
the water table once a new groundwater equilibrium is established post-capping. Geraghty & Miller agreed
that there was a "possibility" of such continued migration, but indicated that they could not conclude it was
a "probability" for all four source areas without a source area by source area review. Given the lack of
available groundwater date for the Clean Clean All/Loohns sites, it is currently impossible to make such a
conclusion specific to that source area, even if a source area-specific review were done. I was under the
impression that EPA agreed with this analysis and was comfortable with the use of the word "possibility."

Once again, because capping is not a recommended alternative for any of the source areas, there are no
practical ramifications of this EPA imposed change. It should be deleted from any final "Preface".

8. Section 4.2.2

Bullet 38

See Section 4 above.

9, Section 4.2.2.1

Bullets 39 and 40

See Section 6 above.

Bullets 41 and 42

See Section 4 above.

10. Section 4.2.2.4

Bullet 43

See section 4 above.

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11. Section 4.2.3.1

Bullets 44 and 45

See section 6 above.

12. Section 4.2.4.1

Bullets 46 and 47

See section 6 above.

Bullets 48 and 49

See section 4 above.

13. Section 4.2.3.3

Bullet 50

The second sentence on page 4-30 of the SFS already indicated that implementation of this alternative would
"involve the use and/or upgrade of existing eguipment and the possible installation of additional, similar
eguipment thus making implementation relatively easy and guicker." (Emphasis added) EPA's addition, two
sentences later, of the sentence "Additional recovery wells will be added as necessary", is redundant. This
sentence should be deleted from any SFS Preface.

14. Table 1-1
Bullet 51

This was a typographical error and, as such should be addressed in either an errata sheet or a revised SFS
Preface.

Bullet 52

This was a typographical error and, as such should be addressed in either an errata sheet or a revised SFS
Preface.

15. Table 3-1
Bullet 53

Similar to the discussion under Section 6 above, the Cis have always taken the position that both the No
Action and Institutional Control remedial alternatives would be protective of human health and the
environment. The fact that EPA and NYDOH have allowed people to continue to drink untreated aguifer water
since at least 1992 indicates their conclusion that there is no unacceptable public (as opposed to
individually chosen) health risk.

In addition, we note that EPA, in its most recent set of comments on the SFS, did not ask for this change.
There is no practical conseguence that could arise from this EPA imposed change. This change should not be
included in any final "Preface" to the SFS.

16. Appendix C

Bullets 54 and 55

Geraghty & Miller assumes that the comment is in reference to the calculations provided on Page 7 of 14 not 8
of 14 as referenced in the USEPA comment letter dated July 3, 1996. The calculations provided in Appendix C,

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provide a basis for the cost assumptions that went into preparing Table 4-1.  Since this  estimate was
generated by the USEPA and was considered to be conservative, we did not feel that it was necessary to
include it in the computations provided in Appendix C.  However, at USEPA's reguest, we did revise Table 4-1
to include an operating cost for Alternative 3A for McGraw-Edison of $67,500 as a conservative assumption
(See also Note 2 at the bottom of Table 4-1).

As stated in Appendix C of the SFS, we had determined through evaluating current operating cost information
provided by Cooper Industries, that the O&M cost for the existing system will not substantially increase (as
is noted on the bottom of Page 7 of 14).  As a result, Geraghty & Miller did not provide any additional cost
calculations for the O&M associated with the McGraw-Edison source area.  Therefore, revising the note as
suggested by EPA would not be correct for the reasons stated above.

Although Appendix C was transmitted to Mr. Tom Taccone in its current form on May 24, 1996, and no comments
were provided on it prior to SFS finalization, such additions (if warranted) could be addressed by way of an
errata sheet documenting the referenced changes.



       "In accordance with the September 185 Record of Decision, the purpose and the primary objective of the
       Supplemental RI/FS is to identify whether additional remediation and performance of source control at
       one or more locations will result in expediting the timeframe,  consistent with the National
       Contingency Plan "NCP", within which the air stripping system on the three municipal wells will be
       operated.  The Supplemental RI/FS will  attempt to identify measures that would minimize contaminant
       releases from the soils and shallow groundwater to the underlying aguifer in a manner consistent with
       the NCP, thus accelerating the remediation of the lower aguifer.  In addition, the Supplemental RI/FS
       will assess the risks posed by contamination from potential source areas at the Site and evaluate
       remedial alternatives consistent the NCP to address such risks.   Thus,  the Supplemental RI/FS report
       will recommend that source control be performed at one or more locations if it is determined that such
       an action,  consistent with the NCP, will expedite treatment of the well field aguifer or mitigate
       unacceptable risks."

EPA has determined that certain of the Clean PRP properties and non-CI properties are source areas
contributing to the groundwater, thus the SRI needs to consistent with the Administrative Order and the
project objectives stated in the workplan, addendum, identify measures that would minimize contaminant
releases from the soils and shallow groundwater to the underlying aguifer.  At the November 16, 1993 meeting,
EPA asked what scientific analysis the Clean PRPs used to back up the claim that additional remediation at
the potential sources identified in the SRI (alone or in combination will not expedite treatment of the
contaminated aguifer.  Your consultant then admitted that this was only based on his opinion; however, his
opinion has not been substantiated with any facts.  EPA's decision on what remedial actions are necessary for
the Clean site will be made based on a defensible, scientific analysis of the data.  The FS must include this
analysis since it was not conducted during the  SRI.

Furthermore, the NCP states that "the goal of EPA's Superfund approach is to return usable ground waters to
their beneficial uses within a timeframe that is reasonable given the particular circumstances of the site.
The groundwater at the Clean site is used for drinking water, therefore its beneficial use is drinking water,
and thus the goal is to return the Clean aguifer to drinking water standards.   Therefore, the statement on
page 5 of your letter that EPA's direction to the Clean PRPs to evaluate groundwater remedies is consistent
with the project objectives is incorrect.  EPA has not yet determined that the current remedy will meet this
goal; addition extraction wells may be necesary.  This analysis must be done.

The possibility of further groundwater remediation has been under active consideration since the development
of the supplemental RI/FS workplan.  EPA's letter of April 10, 1989, which responded to Michael O'Brien's
letter of May 11,  1988, explained the that the purpose of the pump test at the McGraw Edison facility was to
determine the hydraulic characteristics of the upper aguifer "in order to evaluate the groundwater capture
and treatment alternatives for the upper aguifer."   Page 66 of the workplan also explains that the hydraulic
parameters determined by the pump test will be used to evaluate a pump and treat remedial alternative.  Given
the possibility of the presence of Dense Nonagueous Phase Liguids at AVX and Alcas, which was not known when

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the supplemental RI/FS workplan was developed, pump and treat and/or containment should be evaluated at or
near those facilities. Also, as discussed on page 6 of your letter, this evaluation should include the
pumping effects of city municipal wells M18 and M37/38.

The above discussion also relates to the first bullet of EPA's January 10, 1994 letter which instructed the
Clean PRPs to assess remedial alternatives for soil cleanup based upon the New York State Department of
Environmental Conservation (NYSDEC) TAGM guidance and to your assertion that the guidance is beyond the scope
of the objectives agreed upon for the SRI, EPA does not concur with this statement. One of the objectives of
the TAGM guidance is to establish a concentration of a contaminant in the soil which could not result in a
contravention of drinking water standards. Significant soil contamination exists in certain of the PRPs and
non-CIs properties. Evaluating the data in these areas against the TAGM guidance gives an indication of what
soils may need to be remediated in order to prevent continued degradation of the aguifer, thereby expediting
the aguifer remediation time frames.

Treatability Studies

The third bullet of EPA's January 10, 1994 letter instructed the Olean PRPs to submit "a treatability pilot
testing workplan for evaluating the performance of potential remedial technologies." EPA reviewed your
letter of august 4, 1993, which recommended that any treatability study work be deferred until the
comparative Analysis of Remedial Alternatives. However, data from the treatability studies may be needed in
order to properly screen the potential remedial alternatives under consideration. Performing the
studies/pilot tests will provide information on cost and potential operational difficulties which will be
needed in the screening process. However, EPA does agree that no pump and treat system treatability studies
will be needed since these systems are already in operation at the site. Please submit a treatability
testing workplan for the technologies discussed in your letter of August 7, 1993.

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May 6, 1994

Ms.  Libby Ford
Nixon, Hargrave, Devans & Doyle
Clinton Square
Post Office Box 1051
Rochester, New York 14603

Re:   Olean Well Field, Olean, New York.

Dear Ms. Ford:

Enclosed please find the revised Memorandum on Remedial Action Objectives.

If you have any questions or comments, please do not hesitate to contact me.

Sincerely,

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Memorandum on Remedial Action Objectives

The remedial action objectives were established based on the performance of a Supplemental Remedial
Investigation (SRI) for the Clean Well Field.  The performance of the SRI was part of the Selected Remedy set
forth in the September 24, 1985 "Record of Decision - Remedial Alternative Selection."

The Clean Cooperating Industries  (CIs) entered into a Consent Order to carry out the Supplemental Remedial
Investigation/Feasibility Study (SRI/FS) in a mixed work effort with the United States Environmental
Protection Agency  (USEPA).  In that Consent Order, the USEPA added another objective  (to those set forth in
the 1985 ROD): "to assess the risks posed by contamination from potential source areas..."  These objectives
were incorporated into the Amended SRI Work Plan  (1989 Ebasco as amended in 1991 SRI Work Plan) which also
set for the following decision criteria:

       "Thus,  the Supplemental RI/FS Report will recommend that source control be performed at one or more
       locations if it is determined that such an action,  consistent with the NCP,  will expedite treatment of
       the well  field aguifer or mitigate unacceptable risks" (1989 Ebasco as amended in 1991 SRI Work Plan
       Section 1.0).

The SRI was conducted to delineate and characterize potential source areas within the Clean Well Field. The
data collected during the SRI will be used to determine whether source control at one or more potential
source areas will expedite the treatment of the contaminated aguifer or to mitigate unacceptable risks due to
the constituents of interest.  In addition, the data collected will be used to evaluate remedial alternatives
in the Supplemental Feasibility Study (SFS) in accordance with the above criteria.

Therefore, the following remedial action objectives address the contaminants found in the aguifer supplying
the municipal wells and these same contaminants as they relate to potential soil source areas within the
Clean Well Field.  The only contaminants found in the influent to the municipal air strippers are
trichloroethene  (TCE) (the only compound detected above trace concentrations and its federal maximum
contaminant level  [MCL]  for drinking water [5 ug/L])  and trace concentrations of 1,1,1-trichloroethane
(1,1,1-TCA) and 1,2-cis dichloroethylene (cis 1,2-DCE) which ranged from non-detect to 8 ug/L and non-detect
to 9 ug/L respectively.   These trace concentrations are well below the federal MCLs for 1,1,1-TCA and cis
1,2-DCE of 200 ug/L and 70 ug/L, respectively, but occasionally slightly higher than the New York State
drinking water MCLs of 5 ug/L.  The City of Clean has indicated that the inorganics included in the Risk
Assessments have never been detected in the influent to the municipal air strippers. In addition, the data
collected at all the individual sites during the SRI indicates that the inorganic constituents are naturally
present in soils throughout the well field area.  Acetone and methylene chloride were also reported in the
SRI as being detected in some soils.  These detections however, may be due to sampling and/or laboratory
contamination.  Acetone has never been detected in the influent to the municipal strippers.  While methylene
chloride has been detected in the influent to the municipal strippers, the laboratory performing the analyses
indicates these detections are most likely due to laboratory contamination.  To the extent that acetone and
methylene chloride or any other VOCs are present at significant concentrations, the following remedial action
objectives for TCE, 1,1,1-TCA and cis 1,2-DCE will also address these constituents.

The remedial action objectives for the Clean Well Field will be as follows:

Objectives for Groundwater Remediation

              !       Prevent  ingestion of groundwater  having concentrations  of TCE  and other  site-related
                     contaminants  that would  pose  a potential  excess  cancer  risk greater than 10-6.
                     Groundwaters  will be assumed  to meet  this objective  if  the TCE concentration is  less
                     than  or  egual to  the federal  and  New  York drinking water standards.

              !       Prevent  ingestion of groundwater  having concentrations  of 1,1,1-TCA,  cis 1,2-DCE and
                     other site-related  contaminants that  would result in a  combined Hazard Index greater
                     than  1.   Groundwaters  will  be assumed to  meet  this objectives  if their concentrations
                     are less  than or  egual to the federal and New  York drinking water standards.
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                     Provide  additional  localized  groundwater  treatment  for  TCE,  1,1,1-TCA,  cis  1,2-DCE  and
                     other  site-related  contaminants  at  one  or more  locations  if  it will  expedite  the  current
                     treatment  of  the  aquifer  at the  municipal wells.
Objectives for Soil Remediation
                     Prevent  ingestion/direct  contact/inhalation  of  soil  having  concentrations  of  TCE  and
                     other  site-related  contaminants  that would pose a  potential excess  cancer  risk  greater
                     than 10-6.

                     Prevent  ingestion/direct  contact/inhalation  of  soil  having  concentrations  of  1,1,1   TCA,
                     cis 1,2-DCE  and  other  site  related  contaminants that would  result in a  combined Hazard
                     Index  greater  than  1.


                     Restore  soils  at one or more  locations  to appropriate  contaminant concentrations  of  TCE,
                     1,1,1-TCA, cis 1,2-DCE and  other site-related contaminants  if  such  restoration will
                     expedite the current treatment of the contaminated aquifer  at  the municipal wells.
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Mr. Thomas Taccone
Clean Well Field Project Coordinator
Chief, New York, Caribbean Superfund Branch II
Emergency and Response Division
United States Environmental Protection Agency - Region II
290 Broadway - 20th Floor
New York, New York 10007-1866

   Subject:   Response to Comments,  Clean Draft Feasibility Study Review

Dear Mr. Taccone:

The Clean Cooperating Industries  ("Clean CIs") have directed Geraghty & Miller, Inc. to submit the following
responses to the United States Environmental Protection Agency  (EPA) comment letter dated June 19, 1995
(received by the Clean CI coordinator on July 5, 1995) containing additional comments on the working draft of
the Clean Well Field Supplemental Feasibility Study (SFS) report that Geraghty & Miller had prepared and
submitted on their behalf.  The comments made on May 12, 1995 were responded to in Geraghty & Miller's letter
dated May 30, 1995.  Several USEPA comments from the May 12, 1995 letter were further discussed in the June
19, 1995 letter.  In this response to your June 19, 1995 correspondence, we have addressed those issues which
continue to reguire further clarification, but have not rediscussed issues satisfactorily addressed by our
May 30, 1995 letter or by phone.

Geraghty & Miller has retained the comment response format from the May 30, 1995 letter for those May 12,
1995 comment responses which were accepted by EPA, Appendix A to this letter contains the permanent "change"
pages to the working draft of the SFS.

Comment 1:  Geraghty & Miller's response still does not address EPA's comment.  A generic analysis would not,
as stated in Geraghty & miller's letter, provide any new or useful information.  A generic analysis is not
needed.  What is needed is an analysis of the seven evaluation criteria (as provided in 40 CFR 300.430 (a)
(iii)  (A) through  (G)) for each source area.  Attached is sample, partial comparative analysis of remedial
alternatives for the Alcas  source area.  The analysis should repeated for the other sources.

We feel that the drafts submitted to date contain all the reguired elements of a SFS comparative analysis.
Despite this, in the interest of bringing issue to closure, Geraghty & Miller will revise the SFS as
suggested.  The revisions will be made to Section 4.3 (Further Comparison of Remedial Alternatives by Source
Area).  The proposed revisions will be forwarded to USEP by July 31, 1995.

Comments 2, 23, 27, 38, 29, and 41:  the volume of soil and groundwater, which need to be remediated at
Loohns Dry Cleaners, was included in EPA's letter of may 12, 1995.  Please incorporate the volume into the
SFS.  At this time, EPA does not plan on drafting an SFS addendum.  A full SFS should be submitted, as
reguired by the Order on Consent  (Index No. II CERCLA-10202).

The Sandburg and Griffith oil source areas should be removed from the SFS.  These areas will be addressed by
the NYSDEC, under the New York State petroleum spill program since the soil and groundwater contamination at
those properties are related to releases of petroleum and/or petroleum derivatives.  As you may know,
petroleum contamination can not be addressed using federal Superfund authority.

Regarding Clean tile, EPA does not believe that the elevated levels of toluene, which were detected at soil
boring 34, are a threat to the aguifer.  The soil encountered at boring 34 was very tight so that little, if
any, groundwater can reach the contamination.  You'll note from the boring log for SB34 that the water table
was not reached.  Therefore, EPA does not consider Clean Tile a source of contamination to the Clean
Wellfield.

Shortly, EPA will mail to you an addendum to the supplemental remedial investigation report  (SRI).  The
report provides the results for the additional field samples at Clean Steel, Clean Tile, Loohns Dry Cleaners,
-------
Mastel Ford, Griffith Oil and Sandburg Oil.

After we submitted our May 30, 1995 response (which indicated that without the supporting data, we could not
incorporate into the SFS any conclusions with respect to the non-CI source area),  we have received the data
on the non-CI sites  (which has been incorporated by reference into the SRI report as Appendix G - Addendum to
that report).  As directed by EPA, the former non-CI source area Sandburg, Griffith Oil, and Clean tile are
not CERCLA-eligible source areas and will no longer be discussed in this SFS.  Because of this, Sections
4.1.5, 4.1.6, 4.2.5, and 4.2.6 should be deleted from the working draft of the SFS.  The data on the
remaining non-CI site (now Appendix G-Addendum to the SRI report) is being reviewed and evaluations for the
Loohns Dry Cleaners  (Clean Clean All)  will be added to the SFS.  We plan to forward the appropriate change
pages to EPA by July 31, 1995.

Comment 4:  EPA maintains its original comment.  The phrase "if it will expedite the current    treatment of
the aguifer at the municipal well," should be removed from the SFS report.

Based on our telephone conversation with you and Kevin Lynch on July 10, 1995, this phrase will remain in the
draft SFS document.

Comment 7:  The first paragraph of Geraghty & Miller's proposed language for Section 2.4.1.2 is inaccurate.
Extension of the city water main and installation of backflow prevention devices are active remedial
measures, not institutional controls.   The city's local ordinance which prevents a private well user from
connecting the well to the public water supply is an institutional control.  The second paragraph is
acceptable.

As discussed with EPA during our July 10, 1995 conference call, in Figure 4-5 of EPA's most recent SRI/FS
guidance  (October 1988), the extension of a city water main is considered an institutional control, even
though it involves physical work.  Similarly, the installation of a backflow prevention device, while
involving physical work, is also an institutional control and we have classified it as such.  This section of
the SFS will remain as proposed in our May 30,  1995 letter (see Appendix 1).

Comments 24, 28, and 32:  Upon further consideration, EPA is agreeable to allowing some period of time elapse
before assessing whether or not groundwater recovery and treatment is necessary.   However, instead of the 5
year period recommended in the draft SFS, specific time periods should be calculated for each source area.
Periods should be based on the distances from each source to the air strippers, the groundwater velocity in
the lower aguifer and enough time for 3 to 5 pore volumes of groundwater to flow from each source to the air
strippers.

As discussed during the July 10, 1995 telephone conversation, EPA and CIs are now in agreement that it is
appropriate under Alternative 3 or 5 for some period of time to elapse after a soil source area remediation
has been completed before assessing whether or not groundwater recovery and treatment is necessary.  As
discussed with EPA, if either of these remedial measures is selected for a source area, specific time periods
will be calculated for that source area.  The time periods will be based on the distance from the source area
to the municipal air stripper, the groundwater flow velocity in the low aguifer,  and providing enough time
for 3 to 5 pore volumes of groundwater to flow from the lower aguifer beneath each source area to the air
stripper.

Comment 25:  EPA will not agree to Alternative 3A, which specifies the possibility of groundwater treatment
with no other proposed remedial measure after five years.  This alternative should specify groundwater
treatment right away.  Please revise the alternative.

As discussed with you during the July 10, 1995 telephone call, this section has been revised to clarify that
groundwater treatment would begin right away in the lower aguifer beneath any source area where this is the
chosen alternative.

Comment 35:  EPA disagrees with Geraghty & Miller's response.  Treatment of groundwater at AVX is an
appropriate alternative and would serve as an effective source control measure.  Because of the proximity of
Alcas to municipal well M18, treatment of groundwater may not be necessary.
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We still feel that pumping in the lower aquifer will enhance migration into the lower aguifer, especially at
the AVX facility.  In addition, analysis of current data indicates that typical groundwater recovery has not
been an effective source remediation method at the AVX facility.

AVX has been pumping an on-site well  (for cooling purposes) for decades.  This production well is located
very close to the identified source area.  In the early 1980s this well was pumped at an approximate rate of
200 gpm (288,000 gpd).   Since that time, pumping rates have decreased to approximately 50 gpm  (72,000 gpd).
Despite these decades of extensive pumping of the lower aguifer in close proximity to the source area, that
source area still contains a significant VOC burden in the tight clayey soils.  There is no reason to expect
that source area related groundwater recovery, even at an increased rate, will lead to significant reductions
in the VOC levels in the soil source area in any time frame less than several decades In addition, as shown
on figure 74 of the 1992 SRI report, VOC concentrations in lower aguifer Monitoring Well AVX-5D, on the AVX
property,  were very low when the well was first sampled in 1985.  Since the start of guarterly monitoring in
October 1989, the VOC concentrations have shown an overall increase.  The increase in VOC concentrations in
Well AVX-5D since October 1989 may be due to the startup of the municipal well pumping, which has resulted in
the lowering of water levels in the lower aguifer beneath the till layer and thus has resulted in an
increased flux/leakage from the till layer into the lower aguifer.  Also, during this same time frame, the
pumping rate of the AVX production well  (lower aguifer) decreased from 200 gpm in 1984 to 105 gpm in 1988, to
approximately 50 gpm in 1990, which remains the current pumping rate.  The decrease in the AVX production
well pumping have decreased the hydraulic gradient in the vicinity of this well and reduced its influence on
groundwater flow.

Based upon the above information, we feel that pumping has not been effective in reducing the concentration
of VOCs in the source area at the AVX facility and has enhanced migration of VOCs into the lower aguifer.
This analysis will be added to the Evaluation of Alternative 3 for the AVX source area.

Comment 44:  Geraghty & Miller states that a low transmissivity (T) is considered to be conservative when
calculating capture zones.  This is a fundamental error in their analysis, because a high T is conservative
when calculating a capture zone.  An examination of the eguations used will show that T is on the bottom of
the eguation and is therefore inversely proportionate to the size of the capture zone.  Therefore, the low T
chosen for the calculations is not a conservative choice.

The capture zone should be recalculated using a conservative high T value.  EPA recommends the selection of a
conservative high T value in gpd/ft from Table D.4 of the February 1985 RI, Appendix D for the lower aguifer.
The upper aguifer capture zone should be calculated using the most conservative T from the EW-3 aguifer test
(1992) .

A conservative valve should typically be used for environmental calculations, however, for this case, a
conservative high T value is especially warranted because of the simplifications inherent in the capture zone
eguations used.  The lower aguifer capture calculations do not take into account possible leakage from the
upper aguifer to the lower aguifer and from the river.  The upper aguifer capture calculations do not take
into account possible river recharge.  These factors could serve to reduce the actual capture zone.  The use
of the most conservative T (highest value) would add a necessary measure of safety to the calculation.

With the information provided in Geraghty & Miller's response letter, EPA re-examined the captures zones
drawn on Figures 1 and 2 of the Draft FS, Appendix D.  The following capture distances were not measured
correctly:   (Xo, 18M) and (Wo, EW-3) .  After recalculating the new capture zones based on Comment 1, above,
please make all measurements as precisely as possible.

The w (upgradient Capture Width) should also be shown on the capture zone plots (Figure 1 and 2 of Appendix
D) .

Geraghty & Miller agrees that a conservative  (high) transmissivity  (T) value should be used in the capture
zone eguations due to the simplifications inherent in those eguations.  As recommended, by EPA, a T value of
8.66 x 10-5 gallons per day per foot  (gpd/ft) was selected from Appendix D, Table D-4, of the February 1985
RI and used to recalculate the capture zones for Municipal Wells 18M and 37/38M.
-------
A T value of 6,300 gpd/ft was used to calculate the capture zone of upper aquifer well EW-3 located on
McGraw-Edison property.  The T value selected was determined from a distance-drawdown analysis of the
hydraulic data collected during the pumping of EW-3 as discussed in Section 5.8 of the SRI report.  This T
value is the highest value determined during the drawdown phase of the aguifer test and is considered to be
conservative but representative of the transmissivity of the upper aguifer in the vicinity of the
McGraw-Edison property.

The revised capture zone analysis results are provided in Tables 1 and 2 included in Appendix B.  figures 1
and 2 (attached)n have also been revised to depict the recalculated capture zones.  Appendix B also contains
the proposed text revisions to SFS Appendix D.

The upgradient capture width (W)  is depicted on the revised Figures.  As the capture zone eguations do not
predict W at a specific distance upgradient of the pumping well, the upgradient width is interpretive.

Appendix A to this letter contains the following revised pages related to EPA's May 12, 1995 comments 3,
6-14, 16-18, 21, 22, 25, 26, 29 - 31.  Additional revised pages, including those showing our proposed text
changes which correspond to the phone responses will be provided by July 31, 1995, completing the revisions
to the draft SFS document.

If there are any guestions or comments regarding responses provided or the revised pages, please do not
hesitate to contact Ms. Libby Ford or the undersigned.

Sincerely,



cc:    Olean SRI/FS Distribution List
       B. Gray - Geraghty & Miller,  Albany
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APPENDIX A
Revised Pages To The SFS Document

GERAGHTY & MILLER, INC.
-------
                                       DRAFT

                             Nature and  Extent  of the  Contaminants and Approximate Volumes, Olean Well  Field Site,  Olean,  New York.
                                                                                                                                                                                SRI at 5.3.2
                                                                                                                                                                                SRI at 5.5.2
                                                                                                                                                                                and Alcas Pilot
                                                                                                                                                                                Test Report

                                                                                                                                                                                SRI at 5.3.1
                                                                                                                                                                                SRI at 5.5.1
                                                                                                                                                                                and Pilot Test Report
                                                                                                                                                                                Section 3.0

          McGraw Edison (1)                                   2,400                          —                         300,000                         None                      SRI at 5.3.3
          EW3                                                                                                   (Volume  of Groundwater)                                           SRI at 5.5.3

          Olean Clean All                                      —                          121,900                     Not enough                        —                      SRI at 5.4.1
          SB09                                                                                                     data  available                                               SRI at 5.6.8

          Olean Tile                                           —                           28,014                     Not enough                        —                      SRI at 5.4.7
          SB34                                                                                                     data  available                                               SRI at 5.6.4

                                                                                            4,500                     Not enough                        —                      SRI at 5.4.4
                                                                                                                   data  available                                               SRI at 5.6.9

                                       Volatile organic compounds.
                                       Micrograms per liter.
                                       Micrograms per kilogram.
                                       Supplemental Remedial  Investigation.

(1)   Groundwater Volume is based  on  a surface area estimated from Pumping Well  (EW-3)  and  Observation Wells A-l and C-l.  A 20 foot saturated  thickness with an average porosity of 30 percent is assumed.

Source:   Geraghty & Miller,  Inc.  1994b.

GERAGHTY & MILLER,  INC.
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DRAFT

              !       No action.

              !       Institutional  controls.

              !       Containment.

              !       In-situ treatment

              !       Removal/treatment/disposal.

              !       Removal/disposal.

2.4    IDENTIFICATION AND INITIAL SCREENING OF REMEDIAL TECHNOLOGIES

The term "remedial technologies" refers to categories of remedial action which comprise subsets of the
general response actions, such as capping or thermal destruction.  Process options, on the other hand, refer
to specific processes within each technology type  (e.g., clay cap or rotary kiln incineration).  The purpose
of this section is to evaluate and selectively reduce the universe of general response actions, remedial
technologies, and process options which are potentially applicable at the identified source areas.  This
involves a screening process in which the technologies and options are evaluated on the basis of technical
Implementability in accordance with "Guidance for conducting Remedial Investigations and Feasibility Studies
under CERCLA" (USEPA 1988).

The technologies that have been retained following this initial screening process are further evaluated based
on effectiveness, implementability, and cost, in order to select one representative process option for each
technology.  These process options are use to develop remedial alternatives in each of the contaminated media
categories.  These alternatives are then subjected to a second step screening process based primarily on
effectiveness, implementability, and cost.

Alternatives that remain after the second step screening process are then subject to a detailed guantitative
evaluation.  The detailed analysis of each alternative involves evaluation on the basis of overall protection
of human health and the environment; compliance with
-------


DRAFT

2.4.1.2   Institutional Controls

Institutional controls guard against the exposure or access to areas that have been impacted by site related
COCs.  Certain institutional controls are already in place in the Clean Well Field which guard against the
ingestion of impacted groundwater.  These include the extension of the public water supply line to areas
where it was known that COCs were in excess of State and federal drinking water standards.  Once the public
water supply lines were extended, hookups were offered to every property.  Most property owners chose to
hookup.  At the time of the hookup they signed a commitment to not reconnect their private wells to the
property's water distribution system until such time that they have been notified by the USEPA in writing
that the groundwater is no longer impacted.  For the purposes of this SFS deed restrictions,  restrictions on
groundwater use, provisions for a alternative water supply, groundwater monitoring, and public education
programs will be evaluated.

Deed Restrictions - An institutional control to prevent ingestion of impacted groundwater that could be
implemented is the imposition of deed restrictions on the properties that contain the identified source
areas.  The deed restrictions on those properties would prevent the installation or the use of groundwater
wells for potable purposes unless the groundwater was treated to consistently meet State and federal drinking
water standards.  Deed restrictions would be enforced by local and municipal planning,  zoning and local
health department officials.  Deed restrictions could also be implemented if the remedial action objectives
are not met for any property where a source are has been identified.  A deed restriction could be used on
that respective property to prevent the sale of the source area property for residential use.  This
technology has proven effective in minimizing contact with COCs in the groundwater, and therefore will be
retained for further evaluation.

Restrictions on Groundwater Usage - Institutional measures to prevent ingestion of contaminated groundwater
can include imposing deed restrictions or local zoning restrictions, prohibiting installation of new
production wells in the vicinity of the site, implementing
-------


DRAFT

Restrictions on Groundwater Usage - Institutional measures to prevent ingestion of contaminated groundwater
can include imposing deed restrictions or local zoning restrictions,  prohibiting installation of new
production wells in the vicinity of the site, implementing restrictions on the use of existing production
wells for drinking water, or reguiring point-of use treatment units in domestic water supply lines.

It is written in the policy of the New York State Health Department (NYSDH)  that the public water supply
districts (in the case of the Town of Clean)  develop a backflow prevention physical inspections program
designed to insure that any individual who also had a private well (for such non-consumptive uses as lawn
watering) had installed and was maintaining a suitable backflow prevention device.  This insures that
groundwater from private wells can not enter into the drinking water distribution system; where it could be
distributed to other public water supply users.  The Town of Clean carried out the first physical inspection
in 1992 and found no cross connections.  These inspections will continue to be carried out on an annual
(perhaps going to tri-annual) basis functioning as an additional institutional control.   In addition, 10
NYCRR Part 5 prohibits the use of any water in the State, including groundwater, as a source for public water
supply without adeguate treatment that insures State and federal drinking water standards are consistently
met.

This technology has been proven effective in minimizing contact with contaminants in groundwater, and,
therefore, will be retained for further evaluation.  Within the Clean Well Field this technology has already
been implemented at most former private wells with contaminant concentrations above drinking water standards.
Because the groundwater contains COCs above drinking water standards within a recognized public water supply
district, new private potable water supply wells are prohibited.

Provision of Alternative Water Supply - This alternative has been implemented in accordance with the 1985
ROD.  The existing treatment system at the facility is successfully treating the water.


-------
DRAFT

Groundwater Monitoring - Monitoring wells are used to collect groundwater samples to document contamination
levels in the groundwater and to track contaminant migration.  Groundwater monitoring can be used alone or in
conjunction with other remedial technologies.  This technology has already been implemented in the Clean Well
Field in accordance with the 1985 ROD.

Public Education Programs - This alternative includes education programs, such as public meetings and
presentations,  designed to increase public awareness about the hazards present in the identified source
areas.  The public education programs would involve public meetings where a fact sheet would be distributed
and maintenance of an information repository with the results of the Site Monitoring Programs (SMPs)  and the
results of the analyses of the water guality from the municipal wells after treatment.

2.4.1.3    Containment

Containment technologies restrict or impede the migration of contaminants by controlling groundwater flow.
Containment technologies include capping, vertical barriers, and horizontal barriers.

2.4.1.3.1.   Capping

Capping involves the placement of an engineered cover over contaminated soil or waste areas.  Capping would
prevent migration of contaminants by physically isolating them from driving forces,  such a precipitation
percolation, surface-water runoff,  and wind.  Capping can be completed relatively guickly using readily
available materials.  The eguipment needed for implementing this technology is standard construction
eguipment.  The main disadvantages of capping are the need for long-term maintenance, uncertain design life,
and the fact that it does not address source areas beneath the water table.  However, with slurry walls
involves the excavation of a vertical trench and the injection of slurry into the void space.  Slurry walls
can be installed to depths from 20 to 80 feet with widths of 2 to 3 feet. SB slurry walls are the most
popular since they have a lower permeability than CB walls, and are less costly.
-------


Trenches are generally dug with an ordinary small back hoe when depths are less that 25 feet (bis) below land
surface.  When depths exceed 25 (bis), track mounted back hoes and or clam shell excavators attached to Kelly
bar cranes are reguired.  When depths exceed 40 feet bis the cost of specialized and construction methods
makes slurry wall installation extremely expensive.

In order to contain contaminated groundwater at the identified source area, enclosed slurry wall systems
would be needed and would have to be combined with other systems such as capping and stormwater controls to
manage the increased hydraulic head in each area that reguires remediation.  This remedial technology only
contains the impacted areas at each site, and does not address the remediation of impacted groundwater or
soils.  The considerable depth at which the confining layer below the lower aguifer is found (170 feet)  also
makes this technology expensive to implement.  As there are other more effective and less costly remedies
being considered, slurry walls will not be retained for further consideration.

2.4.1.3.3.  Horizontal Barriers

Horizontal barriers such as grouting can be used to impede the vertical flow of contaminated groundwater.

Grouting - Grouting employs high pressure injection of a low-permeability substance into fractured or
unconsolidated geologic material where it is set in place to reduce groundwater flow and strengthen the
formation.  Grouted barriers are seldom used for

2.4.1.5.2.  Treatment

Treatment technologies for pumped groundwater can be grouped into two broad categories:  physical and
biological.  Physical treatment methods include carbon adsorption, reverse osmosis, and air stripping.
Precipitation, chemical oxidation/reduction, ion exchange, and neutralization are commonly used chemical
treatment methods.  Biological treatment methods include activated sludge, trickling filters,  and rotating
biological contractors.
-------



There are several groundwater treatment systems operating in the Clean Well Field site, the existing
McGraw-Edison groundwater treatment system and the City of Clean municipal well treatment systems.  Based on
the information we have on these systems,  treatment for inorganic parameters has not been implemented and is
not reguired.  Therefore, it is anticipated that no inorganic treatment technologies (e.g. precipitation,
reverse osmosis or ion exchange) will be reguired for a groundwater treatment system implemented as part of a
remedial action.

Carbon Adsorption - The use of activated carbon to purify water is well established.  Activated carbon has
the ability to remove relatively non-polar organic compounds.  Contaminated water is generally contacted with
the carbon in a series of downflow-packed bed columns.  When the carbon becomes saturated with chemicals, it
can either be thermally regenerated for reuse of discarded.  Activated carbon can adsorb a wide range of
organic compounds, but is more effective in the removal of compounds of moderate molecular weight.  This
includes the compounds targeted for remediation within the Clean Well Field.  Removal of contaminants to
non-detectable levels can generally be achieved.  Activated carbon adsorption will be retained for further
evaluation because of its technical feasibility.

Reverse Osmosis - Reverse osmosis employs a membrane and reguires the application of sufficient pressure to a
concentrated solution to overcome the osmotic pressure and force
-------
IMG SRC 096281D7>

DRAFT

Important considerations include the permeability of the materials in which the upgradient injection wells
are installed,  and the quality of the treated groundwater.  This option will be retained for further
evaluation.

2.4.2   Soil Remediation Technologies

The contaminant levels in the soils at the identified source areas and their localized nature indicate that
surface and subsurface soil remediation strategies may reduce or eliminate migration of contaminants to the
underlying aquifers,  reducing risk and potentially expediting the treatment of municipal wells.   The
following soil remediation technologies have been initially considered for the identified source areas.

2.4.2.1   No Action

The no-action technology, which is required by the National contingency Plan (NCP),  provides a baseline
against which other technologies may be compared.  Under no-action,  no additional cleanup would be
undertaken, and the contaminated surface and subsurface soils in the identified source areas would be left as
it now exists.

2.4.2.2   Institutional Controls

Institutional actions involve imposing access and/or deed restrictions on future land use of the site of the
contaminated soil area.  Institutional actions could also include fencing of the source areas.  Institutional
actions might temporarily limit public access to on-site contaminants, but cannot prevent exposure during
unauthorized access.   As such, they may be applicable in conjunction with other containment or treatment
technologies and therefore will be retained for further evaluation.

2.4.2.3  Containment
-------


DRAFT

2.4.2.4.1  Thermal Treatment

In-situ vitrification (ISV) - ISV involves placing an array of electrodes in the soil to be vitrified and
applying electric power to heat and melt the soil.  A high current is passed through these electrodes,
heating the adjacent soil to approximately 2,900 to 3,600 degrees Fahrenheit (F) and causing the soil to
melt.  As the soil melting spreads downward and outward, it thermally destroys organic contaminants by
pyrolysis.  Off-gases migrate to the surface where they are treated prior to atmospheric release.   When the
electric current ceases, the mass cools and solidifies into a glassy, solid matrix similar in form and
durability to the igneous rock obsidian.  This technology is primarily used to encapsulate non-volatile
organic element.  Although this technology can be applied to soils impacted by VOCs; VOCs would volatilize
and be released during implementation,  making off gas controls and treatment necessary.   Additionally there
is the potential for soils with a high moisture content to reguire remediation at the Clean Well Field site.
The cost to implement ISV becomes higher with increasing soil moisture content.

As this process is more appropriately implemented for inorganic constituent impacts, and would be costly to
implement due to the nature of the soils that would reguire remediation,  ISV will not be retained for further
evaluation.

In-Situ Steam Injection - In-situ steam injection removes volatile and semivolatile organics from soil
without excavation of the waste.  Steam is injected into the ground to raise the soil temperature and drive
off volatile contaminants.  Steam extraction systems may be mobile or stationary.  A mobile system injects
steam through rotating cutter blades that pass through the contaminated medium.  In a stationary system,
steam flows through individual valves from the manifold to injection wells.  Recovery wells remove gases and
liguids from the soil.
-------


DRAFT

and clay, in turn, are attached to sand and gravel particles by physical processes, primarily compaction and
adhesion.  Washing processes that separate the fine  (small) clay and silt particles from the coarser sand and
gravel soil particles, effectively separate and concentrate the contaminants into a smaller volume of soil
that can be further treated or disposed.  The clean, larger fraction can then be returned to the site for
continued use.  This set of assumptions forms the basis for the volume-reduction concept upon which most soil
washing technology applications are being developed.  At the present time, soil washing is used extensively
in Europe and has had limited use in the United States.

A wide variety of chemical contaminants can be removed from soils through soil washing applications.  Removal
efficiencies depend on the type of contaminants as well as the type of soil.  Volatile organic contaminants
after are easily removed from soil by washing; experience shows that volatiles can be removed with 90 to 99
percent efficiency or more.

However, where soils have a high silt or clay content, soil washing becomes much more costly and less
effective as the clean larger fraction is smaller and can not be re-used.  The soils at the Clean Well Field
site in general have a high silt and clay content, making soil washing less effective and more costly than
other technologies to implement.  Soil washing generally is not cost effective where soil volumes are below
10,000  (cy) cubic yards of soil volume.  The volume of soils reguiring remediation at the Clean Well Field
Site are significantly less than 10,000 cy.  Soil washing will not be retained for further consideration.

       !      Dehalogenation - An alkaline polyethylene glycolate (APEG)  reagent is used to dehalogenate
              aromatic compounds in a batch reactor.   In the APEG process,  the reaction causes the
              polyethylene glycol to replace halogen molecules and

GERAGHTY & MILLER, INC.
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DRAFT
Remedial Alternative 4:
VER.
In-Situ Treatment of Soil and Groundwater Using Air Sparging and SVE or
Remedial Alternative 5:
Soil Excavation and Off-Site Thermal Treatment and
Disposal and On-Site Treatment of Groundwater Using
Air Stripping, Carbon Polishing, and Discharge to
POTW.
Remedial Alternative 6:
Soil Excavation and Off-Site Thermal Treatment (if necessary)
and Disposal.
3.4
       DETAILED ANALYSIS OF REMEDIAL ALTERNATIVES
In this section a description of the combined remedial alternatives is provided and the results of its
subseguent evaluation is summarized.

3.4.1   Description of Combined Remedial Alternatives

This section presents a description of the combined remedial alternatives, outlined in Section 3.3, which are
considered for detailed analysis.
3.4.1.1
           Alternative 1:  No action
Implementation of Alternative 1: No Action results in leaving the source areas as they currently exist with
no additional work to be performed within or outside of the source area boundaries.  At present, groundwater
recovery and treatment with air strippers on the municipal water supply wells and the production well at the
McGraw-Edison site is in operation and a guarterly site Monitoring Program is carried out.  Every 5 years,  a
review of site conditions will be conducted to determine if the remedial action reguires modification.  These
operations would continue and are considered part of the No Action alternative.

GERAGHTY & MILLER, INC.
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DRAFT

3.4.1.2    Alternative 2:  Institutional Controls

Instituting Alternative 2 would involve implementing the following:

       !       Public education programs.

       !       Site monitoring program of selected monitoring wells and Clean Well  Field municipal  wells  (this
              may involve an expansion or modification of the current SMP)

       !       Prohibit the use of area groundwater for potable purposes.

       !       Place deed restrictions on the sale of source area properties for residential use.

       !       Access restrictions to the identified source areas.

       !       Conduct a 5 year review of site conditions.

This alternative includes education programs such as public meetings and presentations, designed to increase
public awareness about the hazards present in the identified source areas.   The public education programs
would involve a public meeting where a fact sheet would be distributed and maintenance of an information
repository with the results of the SMPs and the results of the analyses of the effluent water guality from
the municipal wells after treatment.

This alternative also involves implementation, relative to the identified source areas, of land use,  deed
restriction or other legally enforceable restrictions to limit on-site excavation, and to prevent
installation of domestic or industrial groundwater wells for potable water purposes until soil and
groundwater clean-up levels identified in Table 2-1 are achieved.  Excavation restrictions would ensure that
excavation in or near an identified soil source area is accompanied by implementation of a worker/local area
health and safely plan and appropriate off-site treatment and/or disposal of any contaminated excavated
soils.  Legal activities associated with instituting land use restrictions could include incorporating
necesary language into site property deeds.  Access restrictions could include installation of a 6-foot high
fence

GERAGHTY & MILLER, INC.
-------


DRAFT

Impacted groundwater will be pumped to the central air stripper for treatment and disposal.

Groundwater Recovery from the deep aquifer at any of the soil source areas could create a migration of COCs
from the shallow aguifer to the less contaminated deep aguifer.  Groundwater pumping related to this
alternative will be concentrate on shallow groundwater collection.  Groundwater collection in the shallow
aguifer could be more effective at containing the source areas a the impacted soils are above the shallow
aguitard.  (spelling)

As stipulated by Comprehensive Environmental Response, compensation and Liability Act  (CERCLA)  121(c),  a
5-year review is reguired under this alternative.  It is also necessary to periodically monitor the
effectiveness of the remedial system on the prevention of contaminant migration.  This would be done as part
of or as a modification to the SMP.

3.4.1.4   Alternative 3A:  On-Site Treatment of Groundwater Using Air Stripping and Carbon Polishing and
discharge to POTW

This alternative is similar to Alternative 3, except soil related activities would not be done, and the
groundwater remedy would be implemented immediately.

3.4.1.5   Alternative 4:  In-Situ Treatment of Soil Using Air Sparging and Soil Vapor Extraction or Vacuum
Enhanced Recovery

This alternative consists of implementing the following:


              !       Installation of  an air  sparging/soil vapor extraction (SVE)  system and/or
                     vacuum-enhanced  recovery (VER)  system.

              !       Access  restrictions (if necessary).

              !       Monitoring.

GERAGHTY & MILLER, INC.
-------


DRAFT

This alternative provides integrated soil and groundwater treatment.   For source areas where the geology is
suitable, groundwater within the areas would be treated through an air sparging system which is comprised of
a system of injection wells through which air is forced.  As the air rises towards the vadose zone it carries
VOCs with it.  Soil treatment would be accomplished by installing and operating a SVE system.  If source area
conditions are not appropriate  (primarily due to the presence of less permeable soils) variations of the SVE
technigue would be applied using either a VER system or a dual extraction SVE system.  If necessary to meet
ARARs and TCBs (primarily SGCs and AGCs included in NYDEC's Air Guide 1), an off-gas treatment system would
be installed to remove contaminants from the air stream of the SVE or VER system prior to discharge.

There is no soil contamination noted at the McGraw-Edison site and the groundwater can be pumped by
conventional methods and treated through the existing air stripper; VER is less directly applicable to the
site.

Based on the data collected for Clean Clean All it appears that air sparging and SVE or VER could be applied.
The soil data collected in the vicinity of the source area indicates a heterogeneous and silty clay formaties
that would seem to indicate that VER is more directly applicable than SVE and air sparging.

Deed restrictions and/or access restrictions and periodic monitoring similar to that described in
Alternative 2 could also be reguired.

3.4.1.6   Alternative 5:  Soil Excavation And Off-Site Thermal Treatment And Disposal, On-Site Treatment of
Groundwater Using Air Stripping And Carbon Polishing And Discharge To POTW

Alternative 5 would consist of implementing the following:

              !       Excavation and removal  of soil  at  the  identified soil  source  area(s).

GERAGHTY & MILLER, INC.
-------


DRAFT

Objectives and Cleanup Levels, NYSDEC TAGM #4046 - 1/94) a chemical-specific TBC would be used to establish
soil CGs in the soil source areas  (please refer to Appendix B).

According to the requirements set forth by the NCP, if an alternative does not meet the ARARs and a waiver of
the ARARs is not appropriate or justifiable, such an alternative should not be further considered.

3.4.2.1.3 Long-Term Effectiveness and Permanence

This evaluation criterion addresses the results of a remedial action in terms of its permanence and the
quantity/nature of waste or residual levels of contamination remaining at the site after response objectives
have been met.  The primary focus of this evaluation is the extent and effectiveness of the controls that may
be required to both manage the residual levels of target contaminants remaining at the site and to operate
the remedial system as necessary for the remedy to remain effective.  The following components of the
criterion are addressed:

              !       Permanence  of  the  remedial alternative;

              !       Magnitude of remaining risk;

              !       Adequacy of controls;  and

              !       Reliability of controls.


3.4.2.1.4 Reduction of Toxicity, Mobility,  or Volume Through Treatment

This evaluation criterion assesses the remedial alternative's use of recycling or treatment technologies that
permanently and significantly reduce toxicity, mobility, or volume of the hazardous wastes as their main
element.  CERCLA requires EPA to select remedies that use treatment to eliminate any significant  threats at
a site through destruction of toxic

GERAGHTY & MILLER, INC.
-------


DRAFT

This allows the cost of remedial action alternatives to be compared on the basis of a single figure
representing the amount of money that, if invested in the base year and disbursed as needed, would be
sufficient to cover all costs associated with the remedial action over its planned life.  For this evaluation
a discount interest rate of 7 percent has been assumed.

3.4.3    Analysis of Remedial Alternatives

In the sections which follow, each alternative is analyzed in reference to the evaluation criteria described
in Section 3.4.2.1.  A summary of the results of this analysis is provided in Table 3-1.

3.4.3.1   Alternative 1:  No Action

The No-Action alternative would reguire no additional action be undertaken to reduce and/or remove the
contaminants from the source area soils or groundwater beyond those already in place.

At this time, this alternative is not in compliance with the ARARs and does not offer any increased overall
protection of human health and the environment.  No remedial action is associated with this alternative;
therefore, implementation poses no risks to workers or the community and environmental impacts will remain as
they are presently.  This alternative offers no reduction of toxicity, mobility, or volume through treatment;
however, it is easy to implement as there is nothing to be done.  There are no  capital or operation and
maintenance cost involved with this alternative.

If implemented, this alternative would reguire a 5-year environmental review, at which time the need for
further remedial action will be decided.

GERAGHTY & MILLER, INC.
-------


DRAFT

Costs for this Alternative would consist of administrative expenses related to implementing land use/deed
and/or access restrictions, some enhancement of the current SMP,  instituting public education programs,
engineering, material, and construction costs.  The estimated costs for implementing Alternative 2 is given
in Table 3-2.  A cost breakdown for Alternative 2 is provided in Appendix C.

3.4.3.3   Alternative 3:  Capping,  On-Site Treatment Using Air Stripping and Carbon Polishing and Discharge
to POTW

This alternative should be protective of human health and the environment.  Capping would reduce the downward
migration or leaching of contaminants to the groundwater and subseguently to off-site receptors.  Capping
will also reduce the potential for contaminants to come in contact with human and animals and reduce erosion.
Capping will reguire periodic maintenance and annual inspection to check integrity.

Groundwater at the McGraw-Edison site would be treated as a source area and would involve activation of the
existing recovery well  (EW-3)  and treatment of the groundwater by the existing on-site air stripper at
McGraw-Edison.  This groundwater treatment program would reduce the potential for off-site migration of
contaminated groundwater, and be protective of human health and the environment.

This option has the potential of being in compliance with location, action specific ARARs and TBCs.  Chemical
specific ARARs related to soils would continue to be exceeded.  Groundwater chemical-specific ARARs could be
achieved under this alternative.  Location-specific and action-specific ARARs are expected to be met through
proper remedial design.

If during the first 5-year review data indicates that even after the underlying soil and groundwater have
established a new eguilibrium and natural groundwater attenuation and biodegradation have been given an
opportunity to remove COCs from the source, the

GERAGHTY & MILLER, INC.
-------


DRAFT

groundwater downgradient of the capped soil areas has not achieved the CGs identified in Table 2-1,  a
groundwater treatment program would be implemented.  The groundwater would be treated by installing a
recovery well system and by removing contaminants using air stripping and polishing the treated water using a
GAG adsorption system (if necessary).   The treated groundwater would then be discharged to the publicly owned
treatment works system  (POTW)  or to a surface water.  If necessary to meet the reguirements of the NYS Air
Guide 1, the off-gas from the air stripping system would be treated with activated carbon  (or other
appropriate methods).

This alternative will not reduce the toxicity or volume of soil contamination at the capped source areas,  as
no soil treatment or removal is proposed.  Mobility of contaminants in these areas would be reduced.  If the
establishment of a new soil/groundwater eguilibrium does not sufficiently reduce groundwater toxicity,
mobility, and volume at groundwater source areas, those items can be effectively reduced through groundwater
pumping, and treatment through on-site treatment systems(s) (McGraw-Edison)  which would consist of an air
stripper and (possibly)  GAG polishing.

Moderate short-term impacts, such as fugitive emissions and erosion may be associated with cap installation.
Air monitoring would be performed to identify harmful emissions during installation of the caps.  Standard
health and safety precautions would be maintained to mitigate any risks from construction operations.
Standard dust control measures would control exposure to workers during construction.  A health and safety
plan would be reguired.

This alternative is implementable.  Construction of the caps and on-site groundwater treatment systems is not
expected to involve any implementation problems.  Capping is an easily implementable technology and involves
little or no implementation problems.   Discharge to the POTW or a surface-water body for the groundwater
treatment system will reguire either a permit from the POTW or a SPDES permit from the state.  Modification
to the

GERAGHTY & MILLER, INC.
-------
APPENDIX B
Capture Zone Analysis Revised Pages

GERAGHTY & MILLER, INC.

DRAFT

PRELIMINARY CAPTURE ZONE ANALYSIS

Preliminary capture zone analyses were completed for lower aquifer Municipal Wells 18M and 37/38M, and upper
aquifer recovery well EW-3.  These analyses were performed in response to a request by the USEPA to determine
the approximate capture zones for the municipal pumping centers and the predicted capture zone for well EW-3
located on the McGraw-Edison property.

Generally, the capture zone may be described with three discreet dimensional parameters  (Javandel & Tsang
1986).

Xo -   the distance from the pumped well to the downgradient extent of the capture zone  (stagnation point).
Wo -          the width of the capture zone in the vicinity adjacent to the pumped well.
W  -   the maximum width of the capture zone for upgradient.

These parameters are calculated using the following equations:

              X =	               W =	                      W =	
               0  2nTI                       TI                     °        2TI
This analytical approach assumes the following:

              !       the  aquifer is  infinite,  isotropic,  and homogeneous  with a  horizontal base.

              !       steady-state conditions

              !       negligible vertical flow

              !       uniform saturated thickness


GERAGHTY & MILLER, INC.
-------
DRAFT

Lower Aquifer

A preliminary, conservative, capture zone analysis was performed for Municipal Wells 18M and 37/38M using
lower aquifer hydraulic data generated during the 1984 remedial investigation  (RI)  (Engineering Science
1985).  Specifically, conservative estimates of aquifer transmissivity  (T),  and horizontal gradient  (I)
derived under non-pumping conditions were input into equations to determine the capture zone of these pumping
centers.  These hydraulic parameters are shown in Table 1.

Results of a conservative capture zone analyses for the municipal pumping centers indicate downgradient
capture of 909 feet  (18M) and 1,440 feet (37/38M).  Capture zone widths in the vicinity adjacent to wells 18M
and 37/38M are approximately 2,857 feet and 4,524 feet, respectively  (see Table 2).

The lower aquifer is a semi-confined river valley aquifer.  Under non-pumping conditions the hydraulic
gradient of this aquifer is very flat as was indicated during the 1984 RI (Engineering-Science 1985).
Pumping of the municipal wells in the lower aquifer has created a large capture zone between the bedrock
boundaries north and south of the river valley, Figure 1.  Under continuous pumping it is anticipated that
flow is induced from the upper aquifer and the Allegheny River upgradient from the pumping centers.

Limitations of the Capture Zone Analysis for 18M and 37/38M

The results of the preliminary capture zone analysis presented are intended to provide a conservative general
picture of the extent of the capture zone for municipal well pumping centers 18M and 37/38M in the Clean Well
Field.  The analysis performed has technical limitations which can not be accounted for in this type of
model.  The principal limitations of this capture zone analysis are as follows:

GERAGHTY & MILLER, INC.
-------
DRAFT

1.     The effect of impermeable boundaries along the northern and southern portions of the river valley are
not considered in the equations.

2.     The contributions of water from the upper aquifer and the Allegheny River to the capture zone can not
be determined using this model.

3.     The extent and permeability of the upper aquitard is not accounted for in this model.

UPPER AQUIFER

A conservative preliminary capture zone analysis was performed for Well EW-3 on the McGraw-Edison site using
the upper aquifer hydraulic data generated during an aquifer test performed in January 1992.   These hydraulic
parameters are shown in Table 1.  Capture zone parameters were calculated using the equations specified
previously (Javandel & Tsang 1986).   The results of the conservative capture zone analysis for Well EW-3
presented in Table 2.  These results predict a downgradient capture of approximately 40 feet and a capture
zone width of approximately 250 feet.

The upper aquifer is an unconfined river valley aquifer.  Under pumping conditions, it is anticipated that
the capture zone for Well EW-3 will approximate the area shown on Figure 2.

Limitations of the Capture Zone Analysis for EW-3

The results of the preliminary conservative capture zone analysis is intended to provide a prediction of the
extent of the capture zone for well EW-3 at the McGraw-Edison facility.

GERAGHTY & MILLER INC.
-------
DRAFT





The principal limitations of this capture zone analysis are as follows:





1.     The effect of pumping the on-site lower aquifer productions well  is not considered in the equation.





2.     The permeability of the upper aquitard is not considered.





3.     The potential for recharqe to the upper aquifer from the river is not considered in the equation.





GERAGHTY & MILLER INC.
-------
DRAFT

Table 1.  Hydraulic Parameters Used in Capture Zone Analysis Clean Well Field, Clean, New York
Well   Tranmissivity (gpd/ft)

18M           8.66 x 105

37/38M        8.66 x 105

EW-3          6,300

T      Transmissivity
I      Hydraulic Gradient
Q      Pumping Rate

GERAGHTY & MILLER INC.
Gradient (ft/ft)

   0.00025

   0.00025

    0.011
Rate (gpd)

1.2 x 106

1.9 x 106

17,280
DRAFT

Table 2.  Capture Zone Analysis Results, Clean Well Field, Clean, New York.
                                                       Upgradient Capture
                                                           Width  (ft)

Well
18M
37/38M
EW-3
Xo
Downgradient Extent
of Capture (ft)
909
1,440
40
Wo
Capture
Width (ft)
2,857
4,524
125
W
Upgr,
1
5,714
9,048
250
GERAGHTY & MILLER INC.



-------
APPENDIX E

Nixon, Hargrave, Devans & Doyle LLP
Attorneys and Counselors at Law

ONE KEYCORP PLAZA           CLINTON SQUARE                         437 MADISON AVENUE
ALBANY, NEW YORK 12207      POST  OFFICE BOX 1051                   NEW YORK, NEW YORK 10022
(518) 427-2650              ROCHESTER,  NEW YORK 14603-1051           (212) 940-3000
                            (716)  263-1000
 1600 MAIN PLACE TOWER                                          SUITE 700
BUFFALO, NEW YORK 14202          FAX:  (716)  263-1600         ONE THOMAS CIRCLE
(716) 853-8100                                             WASHINGTON D.C. 20005
                                                               (202) 457-5300

990 STEWART AVENUE
GARDEN CITY NEW YORK 11530                              (716) 263-1606)
(516) 832-7500

November 14, 1995

VIA CERTIFIED MAIL - RETURN RECEIPT REQUESTED

Chief, NY/Caribbean Superfund Branch II
U.S. Environmental Protection Agency
Region II
Emergency & Remedial Response Division
290 Broadway - 20th Floor
New York, New York 10007-1866

Attention:    Thomas Taccone,  Clean Wellfield Site Project
              Coordinator

RE:    Olean Wellfield Supplemental RI/FS October 1995
       Monthly Progress Report Administrative Consent
       Order No. II-CERCLA-10202

Dear Tom:

As reguired under paragraph 62 of the above-referenced Consent Order, this letter will update you on the
progress made by the Cooperating Industries  ("CIs") on the various reguirements included in that Consent
Order during October 1995.  Because my October 11, 1995 letter to you, containing the September monthly
report, discussed activities through October 11, 1995, this letter will pick up from that date until November
14, 1995.  To facilitate your review, items reguiring feedback from you are  printed in bold print.

Reporting Period

SRI Report

As you know, the SRI Report has been finalized  (July 20,  1995) and approved  (June 30, 1995) by EPA  (subject
to the changes which EPA reguested and we  submitted on July 20,
-------
Nixon, Hargrave, Devans & Doyle LLP

Thomas Taccone
November 14, 1995

SFS Report

On October 25, 1995 we received the official version of EPA's October 19, 1995 comment letter on the draft
SFS report.  To expedite our review and response to that letter, EPA had earlier provided us with a faxed
copy of the letter.

Subsequent to receiving that letter a series of conference calls was made between yourself, Foster Wheeler
(Radian) and Geraghty and Miller and/or myself.  In addition, draft revisions to various portions of the
draft SFS report which were responsive to EPA's comments were forwarded to you by fax.  Copies of these are
attached for all parties except EPA and NYDEC  (as discussed below, we are providing complete copies of the
text and tables to those two organizations).  One of the main focuses of these discussions was the new
"Attachment 1" included in the October 19, 1995 letter which was EPA's proposed revisions to our SFS
description of when the various Stage 1 remedial actions would be deemed complete, and how the subsequent
evaluations of the groundwater quality would be done to determine if the Stage 2  (groundwater
remedy/containment) remedial actions would be needed at any source area.  The draft Attachment 1 also
addressed the factors which would be considered if the groundwater remedy appeared to have achieved its
reasonable maximum effectiveness but the groundwater clean up goals still had not been entirely met.  The
CI's requested some wording changes in this Attachment to reflect past discussions with EPA and an
acknowledgement that, in keeping with the stated SRI/FS objectives, one of the factors which would be
evaluated when deciding whether additional (Stage 2) groundwater treatment/containment would be required was
whether such treatment would result in improvement in the groundwater, which would materially affect the
groundwater quality at the influent to the municipal wells.  Revised section 3.2 of the SFS Report  (attached)
includes the SFS version of this language.

Another major topic of discussion during this time was how, if a Stage 2 groundwater remedy was found to be
necessary as a result of the above evaluation, but a remedial technology other then pump and treat  (which we
understand will be the technology which EPA will include in its Proposed Remedial Action Plan ("PRAP"))
appeared to be more effective, approval to install the alternative technology could be obtained.  I
understand that you informed Andy Barber that the mechanism would be a ROD amendment.  Such an amendment
would be triggered by the Source Area PRP sending a letter to EPA requesting and justifying such a change. If
EPA concurs, it would then issue a ROD amendment.

On October 13, 1995 Brent O'Dell and I consulted with you  (via telephone) to confirm our understanding that
we had supplied EPA with all the requested changes to the SFS.  During that conversation we agreed that the
revised SFS cost table still had to be submitted, and a copy was faxed to you after the call.  Unless we hear
otherwise, we assume that EPA now has copies of all the revisions to the SFS that it requested and will
shortly approve that Report.  To facilitate EPA's and NYDEC's final review of the SFS Report, complete copies
of the revised text and tables are being forwarded to you and Mr. Scarf.  Once EPA approves the SFS, complete
copies of it will be distributed to everyone on the distribution list.

Work during the Next Two Months

We believe that the draft SFS is essentially 100% complete.  We continue to be hopeful that the draft SFS
report will receive EPA's approval so that the final SFS Report, the PRAP, the public notice (with a
subsequent public meeting, if necessary)  and the ROD can all be completed by the end of 1995.

Looking forward to the remedial phase, one suggestion that the Clean CI's have made to EPA to expedite that
process while insuring that the work done is effective and efficient is that EPA's Order outlining the
remedial design process recognize that the Stage 1 remedial alternatives are straight forward and easily
implementable.  Because of this, the pre-approval reporting  (during the final "design" process)  should be
able to be streamlined.
-------
Unexpected Problems

No unexpected problems arose during the reporting period.

Percentage Completion

The SRI portion of the project is 100% complete.  As indicated above, we believe the SFS portion of the
project is  also 100% complete.

As always, if you have any guestions, please do not  hesitate to call me.



cc:    SRI/FS Consent Order Distribution List
       Michael O'Brien
       Robert Horger
       Andrew Barber
       Jim Stitt
       Joan Prager
       Brent O'Dell
-------
APPENDIX F

Nixon, Hargrave, Devans & Doyle LLP
Attorneys and Counselors at Law

ONE KEYCORP PLAZA             CLINTON SQUARE                       437 MADISON AVENUE
ALBANY, NEW YORK 12207        POST  OFFICE BOX 1051                 NEW YORK, NEW YORK 10022
(518) 427-2650                ROCHESTER,  NEW YORK 14603-1051         (212) 940-3000
                              (716)  263-1000
1600 MAIN PLACE TOWER                                         SUITE 700
BUFFALO, NEW YORK 14202          FAX:  (716)  263-1600           ONE THOMAS CIRCLE
(716) 853-8100                                                WASHINGTON D.C. 20005
                                                               (202) 457-5300

990 STEWART AVENUE
GARDEN CITY NEW YORK 11530                              (716) 263-1606)
(516) 832-7500

October 11, 1995

VIA CERTIFIED MAIL - RETURN RECEIPT REQUESTED

Chief, NY/Caribbean Superfund Branch II
U.S. Environmental Protection Agency Region  II
Emergency & Remedial Response Division
290 Broadway - 20th Floor
New York, New York 10007-1866

Attention:    Thomas Taccone,  Clean Wellfield Site Project
              Coordinator

RE:    Olean Wellfield Supplemental RI/FS September 1995
       Monthly Progress Report Administrative Consent
       Order No. II-CERCLA-10202

Dear Tom:

As reguired under paragraph 62 of the above-referenced Consent Order, this letter will update you on the
progress made by the Cooperating Industries  ("CIs") on the various reguirements included in that Consent
Order during September 1995.  Because my September 15, 1995 letter to you, containing the August monthly
report, discussed activities through September 15, 1995, this letter will pick up from that date until
October 11, 1995.  To facilitate your review, items reguiring feedback from you are printed in bold print.

Reporting Period

SRI Report

As you know, the SRI Report has been finalized (July 20, 1995) and approved  (June 30, 1995) by EPA  (subject
to the changes which EPA reguested and we submitted on July 20, 1995).

SFS Report

On September 21, 1995 a conference call was  held between yourself, Kevin Lynch, Linda Ross, Brent Miller,
Andy Barber and myself to talk about the "triggers" that would cause a source area which had been remediated
under Alternatives 3, 4 or 5 to move from Phase 1  (soil source area remediation) to Phase 2  (groundwater
containment and/or remediation).  While no final decisions were made during that call, the following concepts
were agreed to:
-------
1.  No Phase 2 will be necessary if the influent to the municipal wells is meeting the established
groundwater cleanup goals  ("CGs").

2.  Phase 2 would not be triggered at one source area until the remediation had been completed at all source
areas.

3.  Phase 2 will not be triggered just because the groundwater immediately downgradient of a source area does
not meet MCLs  (the CGs).

4.  EPA would like the Alternative 4  (SVE/VER) description of the two phases of the alternative to read the
same as the description of Alternative 3 (Capping).

5.  EPA believes that the ROD should specify an actual groundwater containment technology, namely groundwater
pump and treat.  The CIs want sufficient flexibility incorporated into the ROD with respect to Phase 2 that
if another equally or more effective containment/remedial technology is available by the time Phase 2 is
triggered, it can be implemented without having to go through a formal ROD amendment.

On September 22, 1995 Andy Barber faxed to you suggested language changes to the draft SFS which would
address items 1 through 3 above.  During the September 21 telephone call we all agreed that we understood the
concerns underlying Item 4 above.  It was also agreed that EPA would take the lead (As it drafted the ROD)  on
item number 5.  If the Clean CIs are not happy with the ROD language, we will be free to comment upon it
during the ROD public comment period.

Once EPA approves the SFS, complete copies of it, including the final edited changes included in the August 9
electronic version, will be distributed to everyone on the distribution list.

Work during the Next Two Months

We believe that the draft SFS is essentially 100% complete.  We are awaiting EPA's comments on the most
recent submittals.  We continue to be hopeful that the draft SFS report will receive EPA"s approval so that
the final SFS report and the ROD can be issued by the end of 1995.

Unexpected Problems

No unexpected problems arose during the reporting period.

Percentage Completion

The SRI portion of the project is 100% complete.  A SFS schedule has never been approved.  As indicated
above, we believe the SFS portion of the project is approaching 100% completion.

As always, if you have any guestions, please do not hesitate to call me.



cc:    SRI/FS Consent Order Distribution List
       Michael O'Brien
       Robert Horger
       Andrew Barber
       Jim Stitt
       Joan Prager
       Brent O'Dell
-------
Nixon, Hargrave, Devans & Doyle LLP
Attorneys and Counselors at Law

ONE KEYCORP PLAZA             CLINTON SQUARE                      437 MADISON AVENUE
ALBANY, NEW YORK 12207        POST  OFFICE  BOX 1051                 NEW YORK, NEW YORK 10022
(518) 427-2650               ROCHESTER,  NEW YORK 14603-1051        (212)  940-3000
                            (716)  263-1000
1600 MAIN PLACE TOWER                                       SUITE 700
BUFFALO, NEW YORK 14202          FAX:  (716)  263-1600         ONE THOMAS CIRCLE
(716) 853-8100                                              WASHINGTON D.C. 20005
                                                           (202)  457-5300

990 STEWART AVENUE
GARDEN CITY NEW YORK 11530                              (716) 263-1606)
(516) 832-7500

August 5, 1996

VIA CERTIFIED MAIL - RETURN RECEIPT REQUESTED

Chief, NY/Caribbean Superfund Branch II
U.S. Environmental Protection Agency Region  II
Emergency & Remedial Response Division
290 Broadway - 20th Floor
New York, New York 10007-1866

Attention:    Thomas Taccone,  Clean Wellfield Site Project
              Coordinator

RE:    Additional Comments on "Superfund Proposed Plan - Clean Wellfield"

Dear Tom:

On behalf of the Clean Cooperating Industriesl  ("Cis") this letter contains the CIs comments on the
above-referenced Superfund Proposed Plan  ("SPP").  As you know, on July 18, 1996, I submitted, on behalf of
the Clean CIs, a letter commenting on EPA's  July 3, 1996 letter to myself containing final comments on the
Clean Wellfield SFS and unilaterally imposing a "Preface" to that report.  To the extent that the issues
raised in that dispute have not been fully resolved by the close of the comment period on the Clean Wellfield
SPP, we reguest that the final resolution of those issues also be reflected in EPA's eventual "Record of
Decision" ("ROD") on this matter.  We also reguest that our July 18, 1996 letter, as well as this one, be
included as a part of the Administrative Record for this project.

For ease of reference, the following comments are presented on a page-by-page basis.  The order they are
presented is not meant to infer anything with respect to the importance the Clean CIs attach to any
particular issue.

1.   (Page 2)  The SPP neglects to mention an important part of the "first operable unit" for the Site,  that
is the inspection and repair of the McGraw-Edison industrial sewer.  That inspection found numerous illegal
connections to the industrial sewer.  While  those connections were allowed to remain, they were repaired so
that the sewer itself would not act as a migration pathway for any groundwater contaminants encountered along
its route.

2.   (Page 3)  There is no upper aguifer at the AVX site.  See SRI Section 3.3.2.

3.   (Page 5)  The TCE concentration detected in SB05  as stated in the SPP (53 ppb)  is incorrect.   As Table 5
of  the SRI report indicates, an estimated value of 29 ppb of TCE was reported for this sample.
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4.   (Page 7)  While not dealing with any of the CI sites,  we noticed that the text on the site in the section
discussing Fay Avenue/Schaefer Street refers to Griffith Oil.

5.   (Page 9)  (See the discussion below on comment number 19).

6.   (Page 9)  On this page EPA indicates that it believes the Alcas site may have cultural resource artifacts
that "may be potentially disturbed by a remedial alternative."   Considering that the Alcas site is an active
industrial facility and that the preferred remedy is relatively non-intrusive, Alcas and Alcoa believe that
the proposed Stage IB Cultural Resources Survey and possible subseguent investigations will have little
influence on the design and construction of the remedy other than to further delay implementation and
increase costs with little or no benefit.  Therefore, on behalf of Alcas and Alcoa we recommend that this
proposed survey be deleted before the issuance of the ROD.

7.   (Page 10)        In the discussion on the Human Health Risk Assessment  ("HHRA"),  the  SPP  fails  to
adeguately differentiate between the two different groundwater exposure pathways through which residents and
others may ingest groundwater from the Clean Wellfield aguifer.  First and foremost are those people who
drink municipal water which is withdrawn from the Wellfield aguifer and treated to remove VOCs before it
enters the municipal distribution system.  The December 1993 Final Risk Assessment, prepared by an EPA
contractor, examined this scenario, but assumed that the water pumped from the municipal wells was not
treated.  Even under this invalid assumption, the Risk Assessment states that "[b]ased upon this assessment
all potential carcinogenic risks fall within the USEPA acceptable risk range 10-4 to 10-6 and all His are
below 1.0."   (HHRA at 36).  The Risk Assessment concludes with an acknowledgment that the water from these
wells is being treated to federal drinking water standards and states that "[r]isk calculations were included
in this report to demonstrate that the treated groundwater is safe to use."   (Id. at 42.)  The failure to
mention the above analyses and conclusions in the SPP skews the summary of potential human health risks and
may lead to a serious misunderstanding of the health risks to those who rely on the City's municipal water
supply.

Instead, the SPP selectively discusses only those portions of the HHRA which conservatively attempt to
guantify the risks to those individuals who rely on water withdrawn through private wells within the aguifer.
For more than six years the Clean CIs, as well as the State and local Health Departments have been urging the
owners of these properties to discontinue the use of their private wells and to connect their properties to
the municipal drinking water system.  Most of the property owners have chosen to do so, but a few have not.
These owners have their own reasons for not connecting with the municipal water supply.  As was demonstrated
in § 6.1 of the SRI Report, there are many diffuse sources of VOCs to the Clean Wellfield aguifer,  just as
have been found in aguifers throughout the United States.  No matter how effective the SRI/FS recommended
source area remedial measures are, there will always remain the likelihood that water at various locations
within the Wellfield aguifer will continue to contain VOC levels above the drinking water standards.
Therefore, we agree with EPA and the Health Department that, ideally, people living in these areas should
switch to a treated water supply.  They are American citizens,  however, with a freedom of choice.  Apparently
the Health Departments have concluded that this situation is not one which constitutes either a public health
threat or a "guestion of security of life and health", thereby preventing them from ordering these property
owners to connect their properties to the public water supply system.   (§ 1301 New York Public Health Law).
The Clean CI's believe that it is very important for the final  Clean Supplemental Superfund Plan and the ROD
to clearly differentiate between public health risks and individually chosen risks (as reflected by
individual decisions not to connect with the treated water supply).

8.   (Page 11)        The Remedial Action Objectives ("RAOs")  included in the  SPP are  not  the  agreed upon RAOs
for this project.  These are set forth in § 2.1 of the SFS Report.  On July 30, 1996 we informed EPA of our
agreement to minor revisions of the SFS § 2.1 RAOs.  The final  version of these RAOs must be the ones
included in the final Superfund Plan and in the ROD.

9.   (Page 12, Table 1).

As indicated on page 11 of the SPP, the agreed upon soil cleanup objectives are NYSDEC's Technical and
Administrative Guidance Memorandum Cleanup Numbers.  However, Table 1 includes a number for cis
1,2-Dichlorethene  ("cis 1,2-DCE") while New York TAGM 4046  (dated January 24, 1994 contains no cleanup number
-------
for 1,2-DCE.  The number contained in the Table 1 for cis 1,2-DCE is for trans cis 1,2-DCE, which is a
different chemical with a different property.  There should be no cleanup number established for cis 1,2-DCE
since there is no established TAGM Remedial Number for this parameter.  Similarly, Table 1 contains a number
of substances (i.e., 2-Butanone, benzene, ethyl benzene, toulene, and vinyl chloride) for which the basis for
needing remedial goals for these substances had not been established.  To the extent that EPA is imposing
remedial goals beyond those included in Table 2-1 of the SFS, it must identify the need and basis for each of
them.

10.   (Page 12)       Table  1  of the  PRAP lists  the groundwater cleanup standards  which are,  according to the
text on page 11, based on federal and state MCLs.  However, the fourth column in Table 1 is entitled "New
York State Groundwater Standards".  After comparing the values in this column with New York State's Drinking
Water Standards  (10 NYCRR § 5-1.52 Table 3), we note that, except for benzene, the values listed in the
columns are, in fact, New York MCLs.  However,  the New York MCL for benzene is 5 ppb, not 0.7.  The title of
Table 1 and the benzene groundwater clean up goal should be corrected before the ROD is issued.

11.   (Page 13)       In its discussion of the Stage 2  remedial measure at AVX,  the SPP indicates "[i]f
groundwater treatment is determined to be necessary for the AVX source area, EPA will also evaluate the
impact of a groundwater pump and treat system on the wetlands area.  As we have previously pointed out to
EPA, groundwater pumpage has occurred at AVX for over 40 years without any detrimental effect on the wetland.
Therefore, if Stage 2 groundwater pump and treat is ever necessary at the AVX site, no evaluation of its
potential effect on the wetland should be necessary.  This statement should not be included in the final
Superfund Plan or in the ROD.   (See also our letter to yourself dated July 18, 1996).

12.   (Page 13)       As we  discussed with EPA representatives on July 29,  1996,  the Olean CI's urge  EPA to
consider the data needs for its 5 year statutory review as it works with AVX and Olean Clean All/Loohns
representatives to develop the scope of the 4 year Stage 2 groundwater reviews so that additional data is not
necessary for the 5 year CERCLA review.

13.   (Pages 16-28)

For the record we point out that the SFS section 4.2,  which USEPA largely wrote based upon information in our
prior drafts and information which was elsewhere in the draft SFS, is virtually verbatim from this section of
the SPP.  We continue to disagree strongly with EPA's assertion that our final draft SFS did not properly
evaluate the NCP criteria.   Rather than repeat what we said with regard to this issue in the past, we again
reference our letters dated May 30,  1995, July 19, 1995 and July 18, 1996.  Furthermore, a review of 40 CFR §
300.430 (e) (iii) (3) which sets out the NCP evaluation criteria and Section 4.1.2 of EPA's Draft "Guidance for
Conducting Remedial Investigations and Feasibility Studies under CERCLA (October 1988) clearly indicates that
the analyses we had done in the prior draft of the SFS was in full compliance with both the NCP and EPA's
Guidance.   The fact that our SFS was not organized in guite the same way EPA would have liked in no way
detracted from the analyses.   Our version of the Report presented the same information in a similar but
differently organized fashion and would have supported a logical, defensible analysis.  What it did not
completely support  (from an organizational approach) was EPA's pre-drafted SPP which we understand was
prepared over six months age.  EPA's July 3, 1996 letter at least partially acknowledges this when it stated
"it's true that EPA used the information which was already in the report...".  While we do not object to
EPA's use of language in its SPP, we strongly disagree with any implications that our draft SFS was not
consistent with the NCP and/or with EPA RI/FS guidance.

14.   (Page 29,  See also page 9)

The Olean Cis object strongly to an expansion of a Site Monitoring Plan ("SMP") to include a full scan of
volatile organic compounds and chromium.  As the SPP correctly notes, these parameters were analyzed for
during the SRI.   They were not found to be at levels of concern and, hence, are not included as remedial
goals in either the 1985 ROD or in the SPP for this Supplemental RI/FS.  Monitoring and analysis is
expensive.  EPA, as well as the current Administration, has publicly committed itself to not imposing
unnecessary administrative or financial burdens on taxpayers.  In fact, one of the mechanisms EPA has
identified to meet its stated goal of reducing administrative and reporting burdens by 25%, is to reduce
environmental monitoring where it does not yield needed information.  Therefore,  as these parameters are not
-------
of concern and have not been tied to any of the four identified source areas which will be the focus of the
ROD, there is no reasonable basis for ordering the Clean CIs to include monitoring for these parameters in
its SMP.  This is particularly true in the case of chromium, which has not been found to be a contaminant of
concern at any of the source areas.  In addition to the extent SRI monitoring detected chromium levels of
concern in groundwater, it was not in wells downgradient of any of the identified  source areas.

While the Clean CIs feel very strongly that the guarterly SMP monitoring should not include a full scan for
the volatiles but rather that it include only those VOCs targeted for remediation in the 1985 or 1996 RODs,
if EPA insist that such a scan be done, we recommend that it be limited to once a  year and, unless any of
them are found at or above the MCLs, that this annual reguirement expire at the end of three years.

15.           We have reviewed EPA's listing of documents that it believes comprises  the Administrative
Record for this project.  In addition to those listed by EPA, we believe the documents listed in Appendix A,
copies of which are appended to this letter, must also be included in the record.  These documents contain
information that the CIs believe may be necessary in the future if either a judicial challenge is brought
subseguent to an EPA Order, or even more importantly, so that future decision makers can fully understand the
issues that are involved as decisions regarding the need for a Stage 2 remedy on either the AVX or the Clean
Clean All/Loohns site are made.

As always, if you have any guestions, please do not hesitate to call me.



Enclosure

cc:  Clean Cooperating Industries  (w/o enclosures)
-------
Nixon, Hargrave, Devans & Doyle LLP
Attorneys and Counselors at Law

ONE KEYCORP PLAZA               CLINTON SQUARE                            437 MADISON AVENUE
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(518) 427-2650                  ROCHESTER, NEW  YORK 14603-1051            (212)  940-3000
                                (716)  263-1000
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(716) 853-8100                                                        WASHINGTON D.C. 20005
                                                                     (202)  457-5300

990 STEWART AVENUE
GARDEN CITY NEW YORK 11530                              (716) 263-1606)
(516) 832-7500

August 7, 1996

VIA CERTIFIED MAIL - RETURN RECEIPT REQUESTED

Chief, NY/Caribbean Superfund Branch II
U.S. Environmental Protection Agency Region II
Emergency & Remedial Response Division
290 Broadway - 20th Floor
New York, New York 10007-1866

Attention:    Thomas Taccone,  Clean Wellfield Site Project
              Coordinator

RE:    Additional Comments on "Superfund Proposed Plan - Clean Wellfield"

Dear Tom:

Since the submission of my August 5, 1996 letter, I have received the following additional comments from
Geraghty & Miller:

Page 14:  Under description of Alternative 4 - Stage 1, third full paragraph:

The SPP indicates that Granular Activated Carbon  ("GAG") would be used  to  treat the  extracted vapors from the
proposed In-situ Vacuum Enhanced Recovery ("VER") or soil Vapor Extraction ("SVE") system(s).  This may or
may not be the case depending on the final designs of the Interim Remedial Measures  ("IRMs").

The SFS text does not exclusively recommend the use of GAG as a treatment  technology for vapor emissions; in
fact Table C-l indicates that it is assumed  (for cost purposes) AVX would  utilize a  thermal  oxidation system
during the initial 6-months of operation  (please refer to footnotes provided at the  bottom of page 10 of 14
Table C-l).  Volatile Organic Compound  ("VOC")  concentrations in the vapor stream may be too high at several
of the source areas  (AVX at least) to cost effectively treat with GAG in the initial  states  of remediation.

A similar comment is made regarding the assumption of the use of GAG to treat  the extracted  groundwater prior
to discharge.  Air stripping can and more than likely will be used to treat the extracted groundwater
resulting from VER.

We recommend that corrections be made in the SPP to include the potential  use  of a thermal oxidizer or
similar treatment system for vapor emissions and air stripping for groundwater extraction.

Page 17:  Paragraph 5
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Geraghty & Miller disagrees with the USEPA' s assessment that Alternative 5 (Excavation) would provide the
most rapid compliance with chemical-specific ARARs.   Attenuation of constituents in groundwater, after
implementation of either Alternatives 4  (In-situ treatment) or Alternative 5 (Excavation),  will occur at
similar rates.  It is inaccurate to indicate that Alternative 5 (Excavation)  will result in a more rapid
compliance.

We recommend that corrections be made in the SPP to reflect this (Note:  the correct language was provided in
the SFS in Section 4.2).

Table 2 - Estimated Costs of Remedial Alternatives:

The estimated costs have not been changed from those included in the SFS - Table 4-1, however, footnotes that
were included on Table 4-1 in the SFS were not incorporated in SPP - Table 2.  These footnotes are important
to explain some of the major assumptions made in estimating the costs of several remedial alternatives.

We recommend that all footnotes from Table 4-1 in the SFS be added to Table 2 of the SPP.

As always, please do not hesitate to call me if you have any guestions.



cc:    Brent O'Dell
       Clean Cooperating Industries
       G.  Robert Witmer, Jr.
-------
                                                  HIGHWAY SUPERINTENDENT
                                                  TOWN GARAGE
                                                  GODFREY ROAD
                                                  OLEAN, N.Y. 14760
                                                  372-1060
Town of Clean

TOWN OFFICIALS
TOWN HALL
R.D. 1 - RT. 16 NORTH
OLEAN, N.Y. 14760
373-0582

August 23, 1996

Mr. Thomas Taccone
U.S. EPA, Region II
290 Broadway, 20th Floor
New York, NY  10007-1866

Subject:  Clean Wellfield Superfund Site

Dear Mr. Taccone:

I hope this note may be timely received as a comment regarding the proposed remedial action plan.

At the Public Hearing on July 16th, a town resident, Mr. Stewart Hill advised that his water had been tested
twice early in the investigation regarding this contamination and that both times he was told there was some
indicated presence but below action levels to reguire protective measures, (i.e.- carbon filtration).  The
address is on Seneca Ave. which was not included in the East State St. Water District.

I have no great concern but would like to clarify as to whether or not there were positive contaminant levels
found even at trace levels.
During our local flooding episode in Jan. of this year several basements were flooded in the East River Road
area which was also excluded from the original action area.  Due to apparent water well flooding and
subseguent bacterial contamination at least one additional residence is being added to the East State
district in that area.  My attention was called after the flooding to a condition of the flooded basement
walls being "cleaned" as if done with a cleaning solution.  Mortar deterioration between concrete blocks also
seems accelerated.  Both conditions seem unusual as compared with a number of previous "flooded basement"
episodes.

I'm simply reporting that seen and heard and wondering if there is any record of earlier trace contamination
which should perhaps be revisited.  The basement conditions I have observed. The residences in guestion are
guite near the City Water Well.


-------
August 23, 1996

Thomas Taccone
US EPA, Region II
290 Broadway, 20th Fl.
New York, NY 10007-1866

RE:  Olean Well Field

Dear Mr. Toccone:

After reviewing the proposed superfund plan for the Olean Well Field, I find it's somewhat ironic that the
area that was the prime suspect originally, as a source of the contaminants, is not even mentioned in the
report or identified on the maps.  The area to which I'm referring is the Olean Municipal land-fill located
South of Seneca Ave. and North of Conrail tracks.  This land-fill was in operation during the early and
middle fifties.  It is approximately forty acres of unburied waste, pits of stagnant water and across which
the McGraw-Edison line traverses to meet the city sewer line.  I found no evidence of even one test well that
was drilled in this area.  If that area has been declared to be free of any contaminants I was also unable to
find that information within the report.

Almost every private water well that was tested in the Seneca Ave. area tested positive for TCE.  At that
time the safe level was considered to be SOppb, I now understand that the safe level has been lower-to 5ppb.
We were told that 2ppb were levels that we should not be concerned about.  That level is now half-way to the
maximum allowed.  There has not been any further testing in this area since early eighties.

I am, however, relieved to know that there is no clean up scheduled for that area.  The jungle-like
vegetation that now covers that area has somewhat concealed the sins of the fifties.  It would not be
desirable to have that area stripped of what nature has done over the past forty years.

Another area that is mentioned in the report is that area directly South of AVX.  This area is designated for
clean-up, and rightfully so.  The conditions that existed there were brought to the attention of the
Cattaraugas Co. Health Dept. in the early seventies.  They apparently failed to see any potential problem.
Perhaps the many hues that spewed across the ground from the plant were considered natural.

The area designated as a private dump between Butler Ave. and Andrews Ave. seems to be a minor problem by
comparison.  I don't re-call any dumping in that area since the forties or fifties.  I wonder about the
expenditure of superfund monies on that area.

Thank you for giving me the opportunity to express my thoughts and concerns.  I have lived in this area all
of my life and only want what is best for all the residents.  The guality of the well water in this area has
always been excellent and of course we all want to preserve it for future generations.




Below is the Department's response to your guestions concerning comments 9 and 10 of the August 5, 1996
letter from Ms. Libby Ford.

Comment 9:  Though TAGM 4046 does not specify a value for (CIS)1,2-dichloroethene, it does not specify the
method to be used for calculating cleanup goals for compounds not specified.  Using the formulas stated in
the TAGM and looking up the appropriate values to substitute into the formula, the cleanup goal for
(CIS)1,2-dichloroethene is .245 ppm.  It would be acceptable to round this off to .25 ppm.  The values used
for this calculation were:

       !      (Organic Content):   f=.01

       !      (Appropriate water guality standard):   C3=.005 ppm
-------
       !       (Partition coefficient):   Koc=49

       !       (Correction Factor):   CF=100

Therefore:

       Soil  Cleanup Objective=(F)x(C3)x(Koc)x(CF)

              =(.01)x(.005 ppm)x(49)x(100)

                     =.245ppm

Comment 10:  The fourth column of Table 1 is a combination of two sets of regulations:

       !       Surface water and Groundwater Classifications and Standards from the New York State Codes,
              Rules and Regulations (NYCRR)  Title 6,  Chapter X,  Part 703.5:   This portion of the regulations
              covers several categories  of surface  water and groundwater.  Only the standards for Class GA
              fresh groundwaters  were used in this  table.

       !       Public Health Law,  Section 225,  Chapter I of the State Sanitary Code, Subpart 5-1, Public Water
              Systems:  All but one of the compounds  listed are principal organic chemicals (POC).   The one
              exception is Vinyl  Chloride which is  a  specific organic chemical (SOC).

The title of that column should be changed to "New York State Groundwater and/or Drinking Water Standards".
This title should be footnoted with the following:   "If the compound was regulated in both standards, then
the more stringent of the two was listed."

An *s' should be added to the Xylene at the end of the first column.



bcc:   L.  Rafferty
       R.  Schick
       M.  J.  Peachey
-------
Appendix A

1.     Office memorandum from Mary E. Ford regarding:  "Summary of Meeting Between Cooperating Industries,
Geraghty & Miller, EPA and EBASCO Placement of Soil Borings During Upcoming Boring Field Program and Other
Field-Related Activities.

2.     Letter to Libby Ford,  dated 10/18/91, from Carole Petersen, EPA, regarding:  Soil Gas Measurements and
FOP for the Olean Well Field.

3.     Letter to Libby Ford,  dated 11/22/91, from Carole Petersen, EPA, regarding:  Letters Dated October 15
and 23, 1991.

4.     Letter to Thomas Taccone, EPA, dated 2/14/92, from Libby Ford, NHDD, regarding:  Olean Wellfield
Supplemental RI/FS, January 1992 Monthly Progress Report Administrative Consent Order No. II-CERCLA-10202.

5.     Letter to Thomas Taccone, EPA, dated 4/14/92, from Libby Ford, NHDD, regarding:  Olean Wellfield
Supplemental RI/FS March 1992 Monthly Progress Report Administrative Consent Order No. II-CERCLA-10202.

6.     Letter to Thomas Taccone, EPA, dated 5/18/92, from Libby Ford, NHDD, regarding:  Olean Wellfield
Supplemental RI/FS April 1992 Monthly Progress Report Administrative Consent Order No. II-CERCLA-10202.

7.     Letter to Thomas Taccone, EPA, dated 6/12/92, from Libby Ford, NHDD, regarding:  Olean Wellfield
Supplemental RI/FS May 1992 Monthly Progress Report Administrative Consent Order No. II-CERCLA-10202.

8.     Letter to Thomas Taccone, EPA, dated 7/15/92, from Libby Ford, NHDD, regarding:  Olean Wellfield
Supplemental RI/FS June 1992 Monthly Progress Report Administrative Consent Order No. II-CERCLA-10202.

9.     Letter to Thomas Taccone, EPA, dated 9/11/92, from Libby Ford, NHDD, regarding:  Olean Wellfield
Supplemental RI/FS August 1992 Monthly Progress Report Administrative Consent Order No. II-CERCLA-10202.

10.    Letter to Carole Petersen, dated 11/4/92,  from Libby Ford, NHDD, regarding:  Revised Supplement to the
Supplemental RI/FS Workplan for the Olean Wellfield Superfund Site.

11.    Letter to Libby Ford,  from Carole Petersen, EPA, dated 4/20/92,  regarding:  Olean Wellfield Superfund
Site; Response to your Letter of March 16, 1992.

12.    Letter to Libby Ford,  dated 12/14/92, from Carole Petersen, EPA, regarding:  Approval of the
Supplement to the Supplemental RI/FS Workplan and FOP; Olean Wellfield Superfund Site.

13.    Letter to Thomas Taccone, EPA, dated 2/12/93, from Libby Ford, NHDD, regarding:  Olean Wellfield
Supplemental RI/FS January 1993 Monthly Progress Report Administrative Consent Order No. II-CERCLA-10202.

14.    Letter to Thomas Taccone, EPA, dated 4/12/93, from Libby Ford, NHDD, regarding:  Olean Wellfield
Supplemental RI/FS March 1993 Monthly Progress Report Administrative Consent Order No. II-CERCLA-10202.

15.    Letter to Thomas Taccone, EPA, dated 9/17/93, from Libby Ford, NHDD, regarding:  Olean Wellfield
Supplemental RI/FS August 1993 Monthly Progress Report Administrative Consent Order No. II-CERCLA-10202.

16.    Letter to Thomas Taccone, EPA, dated 10/1/93, from Libby Ford, NHDD, regarding:  Olean Wellfield
Supplemental RI/FS--Comments on Draft EBASCO Risk Assessment and Reguest For a Meeting.

17.    Letter to Libby Ford,  dated 10/14/93, from Libby Ford NHDD, regarding:   Olean Wellfield Superfund Site
Supplemental RI/FS, Your Progress Report for August 1993.

18.    Letter to Thomas Taccone, EPA, dated October 18, 1993,  from Libby Ford,  NHDD, regarding:  Olean
Wellfield Supplemental RI/FS January 1993 Monthly Progress Report Administrative Consent Order No.
II-CERCLA-10202.
-------
19.    Letter to Thomas Taccone, EPA,  dated 11/15/93, from Libby Ford, NHDD, regarding:  Olean Wellfield
Supplemental RI/FS October 1993 Monthly Progress Report Administrative Consent Order No. II-CERCLA-10202.

20.    Letter to Carole Petersen,  EPA,  dated 11/19/93, from Libby Ford, NHDD, regarding:  Olean Supplemental
RI/FS — Finalization of Risk Assessment.

21.    Letter to Thomas Taccone, EPA,  dated 12/15/93, from Libby Ford, NHDD, regarding:  Olean Wellfield
Supplemental RI/FS November 1993 Monthly Progress Report Administrative Consent Order No.  II-CERCLA-10202.

22.    Letter to Thomas Taccone, EPA,  dated 1/14/94, from Libby Ford, NHDD, regarding:  Notification
Triggering Dispute Resolution -- Olean Supplemental Remedial Investigation/Feasibility Study Objectives and
How These Objectives Are To Be Incorporated Into the Supplemental Feasibility Study.

23.    Letter to Libby Ford,  dated 1/24/94, from Thomas Taccone, EPA, regarding:  Olean Wellfield Superfund
Site; January 14, 1994 Notification of Dispute Resolution.

24.    Letter to Thomas Taccone, EPA,  dated 1/31/94, from Libby Ford, NHDD, regarding:  Administrative Order
II CERCLA-10202, Olean Wellfield Supplemental RI/FS - Memorandum on Remedial Action Objectives.

25.    Letter to Thomas Taccone, EPA,  dated 2/9/94,  from Libby Ford, NHDD, regarding:   Olean Wellfield
Supplemental RI/FS January 1994 Monthly Progress Report Administrative Consent Order No.  II-CERCLA-10202.

26.    Letter from Geraghty & Miller to Thomas Taccone, EPA dated 2/11/94, regarding:   Response to USEPA
Comments on Draft Olean Well Field Supplemental Remedial Investigation Report (Project No. AY0167.001).

27.    Letter to Thomas Taccone, EPA,  dated 3/14/94, from Libby Ford, NHDD, regarding:  Olean Wellfield
Supplemental RI/FS February 1994 Monthly Progress Report Administrative Consent Order No. II-CERCLA-10202.

28.    Letter to Thomas Taccone, EPA,  dated 4/18/94, from Libby Ford, NHDD, regarding:  Olean Wellfield
Supplemental RI/FS February 1994 Monthly Progress Report Administrative Consent Order No. II-CERCLA-10202.

29.    Letter to Libby Ford from Carole Petersen,  EPA, dated 4/21/94, regarding:  Olean Wellfield Superfund
Site Supplemental Feasibility Study.

30.    Letter to Thomas Taccone, EPA,  dated 5/31/94, from Libby Ford, NHDD, regarding:  Olean Wellfield
Supplemental RI/FS April 1994 Monthly Progress Report Administrative Consent Order No.  II-CERCLA-10202.

31.    Letter to Thomas Taccone, EPA,  dated 7/15/94, from Libby Ford, NHDD, regarding:  Olean Wellfield
Supplemental RI/FS June 1994 Monthly Progress Report Administrative Consent Order No.   II-CERCLA-10202.

32.    Letter to Thomas Taccone, EPA,  dated 8/15/94, from Libby Ford, NHDD, regarding:  Olean Wellfield
Supplemental RI/FS July 1994 Monthly Progress Report Administrative Consent Order No.   II-CERCLA-10202.

33.    Letter to Thomas Taccone, EPA,  dated 9/13/94, from Libby Ford, NHDD, regarding:  Submittal of Revised
Preliminary Screening of Assembled Remedial Alternatives - Olean Wellfield Site.

34.    Letter to Thomas Taccone, EPA,  dated 9/15/94, from Libby Ford, NHDD, regarding:  Olean Wellfield
Supplemental RI/FS August 1994 Monthly Progress Report Administrative Consent Order No.  II-CERCLA-10202.

35.    Letter to Thomas Taccone, EPA,  dated 9/20/94, from Libby Ford, NHDD, regarding:  Revised Comparative
Analysis of Remedial Alternatives SFS Submittal.

36.    Letter to Carole Petersen,  EPA,  dated 3/24/95, from Libby Ford, NHDD, regarding:  Olean Wellfield
Supplemental RI/FS Working Draft Supplemental Feasibility Study, Administrative Consent Order No.
II-CERCLA-10202.

37.    Letter to Thomas Taccone, EPA,  from Geraghty & Miller, dated 5/30/95, regarding:  Response to
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Comments,  Clean Draft Feasibility Study Review.

38.    Letter to Thomas Taccone,  EPA,  from Geraghty & Miller,  dated 7/20/95,  regarding:   Addendum to Clean
SRI Report.

39.    Letter to Thomas Taccone,  EPA,  from Geraghty & Miller,  dated 7/19/95,  regarding:   Response to
Comments,  Clean Draft Feasibility Study Review.

40.    Page 2 of a letter to Thomas Taccone,  EPA,  dated 10/11/95,  from Libby Ford,  NHDD.

41.    Letter to Thomas Taccone,  EPA,  dated 7/18/96,  from Libby Ford,  NHDD,  regarding:   Clean Wellfield
Supplemental RI/FS Administrative Consent Order No. II-CERCLA-10202 Comments on EPA Imposed Revisions to SFS
and Notice of Issue Submitted for Dispute Resolution.


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