Superfund Record of Decision Forest Glenn Mobile Home Subdivision OU2 Niagra Falls NY


                                    EPA/ROD/R02-98/005
                                    1998
EPA Superfund
     Record of Decision:
     FOREST GLEN MOBILE HOME SUBDIVISION
     EPA ID: NYD981560923
     OU02
     NIAGARA FALLS, NY
     03/31/1998

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EPA 541-R98-005

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION II

DATE: MAR 31 1998

SUBJECT: Record of Decision for the Forest Glen Subdivision Superfund Site

FROM: Richard L. Caspe, Director
Emergency and Remedial Response Division

TO: Jeanne M. Fox
Regional Administrator

Attached for your approval is the Record of Decision (ROD) for the Forest Glen Subdivision Superfund Site,
located in the City of Niagara Falls and the Town of Niagara, Niagara County, New York. The selected remedial
action addresses soils containing volatile organic, semi-volatile organic, PCBs, pesticides and inorganic
contaminants.

The selected remedy calls for the excavation of contaminated soils from the southern portion of the site and
consolidating these soils in the northern portion of the site, the construction of a hazardous-waste cap over
the consolidated soils and the implementation of an inspection and maintenance program to ensure cap
integrity

The Remedial Investigation and Feasibility Study reports and the Proposed Plan were released to the public
for comment on September 24, 1997. A public comment period on these documents was held from September 24,
1997 through December 8, 1997. Comments received during the public comment period are addressed in the
attached Responsiveness Summary.

The estimated present worth cost of the selected remedy (Alternative S-4) is $16,397,000. The remedy is the
same as the preferred alternatives presented in the Proposed Plan.

The ROD has been reviewed by the New York State Department of Environmental Conservation, and the appropriate
program offices within Region II. Their input and comments are reflected in this document. The New York State
Department of Environmental Conservation has concurred with the selected remedy for the Forest Glen
Subdivision Site, as indicated in the attached letter.

If you have questions or comments on this document, I would be happy to discuss them with you at your
convenience.

Attachments

bcc: C. Berns, ORC
S. Walker, EPA-HQ

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DECLARATION FOR THE RECORD OF DECISION

SITE NAME AND LOCATION

Forest Glen Superfund Site

City of Niagara Falls and Town of Niagara

Niagara County, New York

STATEMENT OF BASIS AND PURPOSE

This decision document presents the selected remedial action for the Forest Glen Subdivision Site, which was
chosen in accordance with the reguirements of the Comprehensive Environmental Response, Compensation, and
Liability Act of 1980, as amended (CERCLA), and to the extent practicable, the National Oil and Hazardous
Substances Pollution Contingency Plan. This decision document explains the factual and legal basis for
selecting the remedy for this site.

The New York State Department of Environmental Conservation (NYSDEC) concurs with the selected remedy. A
letter of concurrence from the NYSDEC is attached to this document (Appendix IV).

The information supporting this remedial action decision is contained in the administrative record for this
site. The index for the administrative record is attached to this document (Appendix III).

ASSESSMENT OF THE SITE

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

DESCRIPTION OF THE SELECTED REMEDY

This operable unit represents the second of three operable units planned for the site. It addresses the
principal threats posed by the site through controlling the source of contamination. The major component of
the first operable unit ROD, dated December 29, 1989, was the relocation of residents of the subdivision. The
third operable unit addresses groundwater contamination at the site which is the subject of an ongoing
Remedial Investigation/Feasibility study.

The major components of the selected remedy include the following:

• Excavation of contaminated soils from the southern portion of the site, and contaminated sediment from
East Gill Creek, and consolidation of these materials in the northern portion of the site followed by
grading in preparation for placement of the cap.

• Confirmatory sampling of the bottom and sidewalls of the excavation to ensure that cleanup goals have
been met followed by backfilling with clean fill overlain with a six-inch layer of clean topsoil and
grass cover.

• Construction of an 8.5-acre cap over the consolidated soils in the northern portion of the site in
conformance with the major elements described in 6 New York Code of Rules and Regulations Part 360 for
solid waste landfill caps. Conceptually, the cap will be comprised of: 18 inches of clay or a suitable
material to ensure a permeability of 10-7 cm/sec, six inches of porous material serving as a drainage
layer, 18 inches of backfill, and 6 inches of topsoil and grass cover.

• Implementation of a long-term inspection and maintenance program to ensure cap integrity.

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• Removal and off-site disposal of the vacant trailers and two permanent homes to facilitate the
excavation of soils.

• Capping the Wooded Wetland with six inches of clean sediment. If further studies conclude that the
addition of six inches of clean sediment would have an adverse impact on the wetland,
contamination in the Wooded Wetland would be excavated and the Wooded Wetland would be appropriately
restored.

• Performance of a wetlands assessment and mitigation plan during the remedial design phase in order to
minimize potential adverse impacts to the wetland and to replace any wetlands lost due to the
remediation.

• Compliance with all ARARs, including the location-specific ARARs identified in this ROD. This will
include the performance of a Stage IB cultural resources survey and a floodplain assessment.

• Taking measures to secure institutional controls to limit future activities in the Northern Aspect and
fencing to limit future access to the capped area.

DECLARATION OF STATUTORY DETERMINATIONS

The selected remedy meets the reguirements for remedial actions set forth in CERCLA ° 121, 42 U.S.C. ° 9621.
It is protective of human health and the environment, complies with Federal and State reguirements that are
legally applicable or relevant and appropriate to the remedial action, and is cost-effective. The selected
remedy utilizes permanent solutions and alternative treatment technologies to the maximum extent practicable,
given the scope of the action. However, the remedy does not satisfy the statutory preference for remedies
that employ treatment that reduces toxicity, mobility, or volume of contaminants as their principal
element.

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

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                      RECORD OF DECISION

                 Forest Glen Subdivision Site

            Town of Niagara and City  of  Niagara  Falls,
                     Niagara County,  New York


            United States Environmental  Protection Agency
                              Region  II
                          New York, New  York
                              March 1998

                         TABIiE OF CONTENTS

                                                             PAGE

SITE NAME, LOCATION AND DESCRIPTION 	  1

SITE HISTORY AND ENFORCEMENT ACTIVITIES  	  1

HIGHLIGHTS OF COMMUNITY PARTICIPATION 	  6

SCOPE AND ROLE OF RESPONSE ACTION	7

SUMMARY OF SITE CHARACTERISTICS  	  7

REMEDIAL ACTION OBJECTIVES  	  17

SUMMARY OF SITE RISKS	19

DESCRIPTION OF REMEDIAL ALTERNATIVES  	  24

SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES  	   29

SELECTED REMEDY 	   35

STATUTORY DETERMINATIONS 	  37

DOCUMENTATION OF SIGNIFICANT CHANGES  	  39

ATTACHMENTS

APPENDIX I.    FIGURES
APPENDIX II.   TABLES
APPENDIX III.  ADMINISTRATIVE RECORD  INDEX
APPENDIX IV.   STATE LETTER OF CONCURRENCE
APPENDIX V.    SUMMARY OF RISK ASSESSMENT
APPENDIX VI.   RESPONSIVENESS SUMMARY

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SITE NAME, LOCATION AND DESCRIPTION

The Forest Glen Subdivision Site is located in both the Town of Niagara and the City of Niagara Falls,
Niagara County, New York (see Figure 1). The site, approximately one-half mile north of Porter Road, is
accessed from Service Road. Expressway Village mobile home subdivision is adjacent to the site's southern
boundary; 1-190 is to the north and to the east; and the Conrail-Foote railroad yard is to the west.

The 39-acre site (see Figure 2) is divided by East Gill Creek, a narrow, low-flowing creek, into separate
parcels of land. South of Gill Creek is the now vacant 15-acre Forest Glen Subdivision, consisting of 51
mobile and two permanent residences. Access to the Subdivision is through Edgewood Drive. Edgewood Drive
formally was connected to an adjacent neighborhood, but the construction of 1-190 in the early 1960s bisected
the road. The southern portion of the site also includes the Edgewood Drive Wooded Lots, which are two 3-acre
undeveloped wooded lots located to the north and south of Edgewood Drive.

The northern portion of the site consists of the 18-acre Northern Aspect, which includes a 15-acre
undeveloped triangle of land which is bordered on the west by a berm, approximately 11 feet in height. A
1.5-acre Wooded Wetland is part of the southeast portion of the Northern Aspect.

The site is located in an area zoned for mixed residential, commercial and industrial use. The southern
portion of the site, including the Subdivision, is zoned for residential land use, while the northern portion
of the site is zoned for commercial use.

The population of the City of Niagara is 61,840. The population of Niagara County is 220,756. A total of 517
persons live within one-half mile of the site.

SITE HISTORY AND ENFORCEMENT ACTIVITIES

Prior to 1973, portions of the site were owned by Michigan-Mayne Realty, the New York Power Authority and
three individuals, Ernest Booth, James Strong, and Sanford Brownlee. In 1973, the land which now comprises
the site was purchased by Mr. Thomas G. Sottile, who, with his wife, Betty Sottile, formed the Niagara Falls
U.S.A. Campsite Corporation. Shortly thereafter, the property was subdivided. The development of the
property, which included clearing and the installation of roads and utilities, took place during the
mid-1970's. The sale of the properties in the Forest Glen Subdivision to individuals began in 1979.

Evidence of past waste disposal was apparent during the installation of utilities in the Subdivision which
took place as early as 1973. During the installation of sewer and water lines, workers encountered resinous
and powder-like waste, drums, and battery casing parts. There is also a history of reports indicating that
residents encountered waste on their properties. In June 1980, the Niagara County Health Department (NCHD)
responded to a complaint concerning the presence of drum tops and resinous material on the property of a
resident living on Lisa Lane. Samples collected by the NCHD indicated that this material was a phenolic
resin. Thomas Sottile was ordered by the NCHD in July 1980 to remove any wastes present at the site to an
approved landfill. It was subseguently reported to NCHD that approximately 10 truckloads of a yellow
resin-like material were excavated and transported to the CECOS Landfill in Niagara Falls.

EPA first became involved in Forest Glen in 1987 when both NYSDEC and NCHD brought it to the Agency's
attention. On August 6, 1987, as part of an initial site investigation, members of EPA's Field Investigation
Team collected four soil samples in the northern portion of the subdivision. Analytical results for these
samples indicated that volatile and semi-volatile organic chemicals and heavy metals were present at varying
concentrations. In addition, numerous tentatively identified and unknown compounds which were difficult to
analyze and quantify were noted at high concentrations. In an effort to determine if these compounds were
present at other locations within the Subdivision, an expanded site investigation was conducted in September
1988. A total of 63 soil, waste, and sediment samples were obtained at this time to a maximum depth of 3.0
feet. Analytical results for these samples concluded that high concentrations of unknown and Tentatively
Identified Compounds (TICs) were present at additional locations in the northern portion of the Subdivision.

In a March 9, 1989 Health Consultation, the Agency for Toxic Substances and Disease Registry (ATSDR)
classified the Forest Glen Subdivision site as posing a potential health threat to residents. ATSDR did not

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recommend that relocation was required at that time, but, instead, indicated that TICs should be positively
identified so that their health effects could be determined.

On March 25,  1989, EPA issued an Administrative Order, pursuant to Section 106(a) of the Comprehensive
Environmental Response, Compensation, and Liability Act  (CERCLA),  requiring that three potentially
responsible parties (PRPs),  Thomas Sottile, the Niaqara Falls USA Campsite Corporation, and Ernest Booth,
carry out actions to reduce the immediate threat posed by conditions at the site. Based on information
available at the time EPA issued the Order, these three parties were viable and potentially responsible for
contamination in the residential portion of the site addressed in the Administrative Order. EPA ordered the
PRPs to secure drums and containers at the site which were leakinq or in immediate danqer of    leakinq and
to submit a detailed Work Plan to EPA for construction and seedinq of a cover to prevent contact with
contaminated soil. The Order also directed that the Work Plan include fencinq of the undeveloped areas east
of the Subdivision on either side of Edqewood Drive and the off-site disposal of all drums and their contents
present at the site. The PRPs did not comply with this Order.

EPA executed interim measures to stabilize conditions and protect the public at the site, includinq
collection, staqinq, and securinq drums of waste that were located in the areas north and east of the
Subdivision.  EPA also installed temporary fencinq around areas of suspected contamination in the two wooded
areas north and south of Edqewood Drive. In addition, an area where contaminants were detected in hiqh
concentrations in surface soils was temporarily covered with concrete.

In April 1989, EPA resampled approximately fourteen of the locations that previously exhibited the hiqhest
concentrations of compounds. An air samplinq proqram was also implemented in April 1989 and included the
collection of samples of ambient air at locations throuqhout the Subdivision and beneath several mobile
homes and from the basement of one permanent residence. The air samplinq activities did not identify any of
the tarqet compounds,  however, several compounds were detected that appeared to be oriqinatinq from an upwind
source.

In June 1989, the analysis of the soil samples collected in April of the same year positively identified
aniline, phenothiazine,  mercaptobenzothiazole, and benzothiazole present in the soils at siqnificant
concentrations.

On June 22 and 23, 1989, the New York State Department of Health  (NYSDOH) conducted an exposure survey at the
Forest Glen Subdivision. In that survey, 39 people from 23 households reported havinq contact with chemical
wastes, and 45 people reported health problems that they believed were associated with chemicals on the site.

Based on the positive identification of aniline, phenothiazine, mercaptobenzothiazole, and benzothiazole,
toqether with the presence of semi-volatile polyaromatic hydrocarbons (PAHs), ATSDR issued a Preliminary
Health Assessment for the Forest Glen Subdivision on July 21, 1989, which stated that the site posed a
siqnificant threat to public health because of possible contact with contaminated soils and wastes and
advised that immediate action be taken to relocate residents of the entire Subdivision beqinninq with the
most contaminated areas.

On July 26, 1989, EPA, throuqh an interaqency aqreement with FEMA, beqan a proqram which provided for the
temporary relocation of residents from the Forest Glen Subdivision.

On July, 31,  1989, ATSDR issued a Public Health Advisory recommendinq that individuals be disassociated from
the site, that is, relocated, and that the site be placed on the National Priorities List  (NPL). The NPL is a
list of sites slated for EPA cleanup or enforcement action under CERCLA °105.

The National Continqency Plan (NCP),  which sets forth procedures and standards for the cleanup of hazardous
waste sites,  states in °300.425 (c),  Methods for determininq eliqibility for NPL, that a    release may be
included on the NPL if "(3)  the release satisfies the followinq criteria: (i) The Aqency for Toxic Substances
and Disease Reqistry has issued a health advisory that recommends dissociation of individuals from the
release; (ii) EPA determines that the release poses a siqnificant threat to public health; and (iii) EPA
anticipates that it will be more cost effective to use its remedial authority than to use its removal
authority to respond to the release."

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Therefore, due to ATSDR's Health Advisory, the site was listed on the NPL on November 29, 1989. Placement on
the NPL enabled EPA to take remedial action at the site. Previously, EPA had been utilizing its removal
authority to take interim actions at the site.

After completing a PRP search, EPA compiled a list of PRPs for the Forest Glen Subdivision site. This list
includes Goodyear Tire and Rubber Company, Thomas G. Sottile and the Niagara Falls USA Campsite Corporation.

On November 29, 1989, Special Notice was issued to the PRPs pursuant to Section 122 of the CERCLA. A
sixty-day moratorium on remedial action at the site, pending a good faith offer from the PRPs, was also
initiated on that day. The PRPs subseguently declined to participate in any remedial action, at the site.

EPA conducted a Focused Feasibility Study of Relocation Options  (FFS) to evaluate in detail three
alternatives for relocating residents from the site. The FFS evaluated a No-Action alternative, as reguired
by CERCLA, as well as temporary and permanent relocation alternatives.

On December 29, 1989, EPA issued a Record of Decision (ROD) selecting permanent relocation of the residents
of the Forest Glen Subdivision as the remedial action for the first operable unit  (OU1).  EPA, through the
Federal Emergency Management Agency (FEMA),  relocated the residents from June 1990, through December 1992.

Once EPA had relocated the residents from the site, a Remedial Investigation and Feasibility Study (RI/FS) to
be performed to determine the nature and extent of contamination at the site and the remedial alternatives
which, consistent with the NCP, may be implemented at the site. EPA had information concerning the surficial
contamination in the Subdivision, but it did not know the vertical and lateral extent of the soil
contamination and no data existed on the ground water.

On June 30, 1992, EPA issued Special Notice Letters to the PRPs. A sixty-day moratorium on EPA performing a
RI/FS at the site, pending a good faith offer from the PRPs, was also initiated on that day. However, the
PRPs subseguently declined to participate in any RI/FS at the site.

EPA conducted an RI/FS at the site from 1994 to 1997. Initial site investigations were conducted in order to
characterize the geologic and hydrogeologic conditions at the site. In addition, surface and    subsurface
soil, wetland sediments, creek sediments, surface water and ground water were sampled. EPA is currently
conducting a supplemental ground-water RI/FS which is expected to be completed in June 1998.

HIGHLIGHTS OF COMMUNITY PARTICIPATION

The RI report, FS report, and the Proposed Plan for the site were released to the public for comment on
September 24, 1997. These documents, as well as other documents in the administrative record were made
available to the public at two information repositories maintained at the EPA Docket Room in Region II, New
York and the U.S. EPA Public Information Office, located at 345 Third Street, Niagara Falls, New York. A
notice of availability for the above-referenced documents was published in the Niagrara Gazette on
September 24, 1997. The public comment period established in these documents was from September 24, 1997 to
October 23, 1997.

On October 15, 1997, EPA held a public meeting at the Niagara Fire Company Number One, located at 6010
Lockport Road, Niagara Falls, New York, to present the Proposed Plan to interested citizens and to answer any
guestions concerning the Plan and other details related to the RI and FS reports. Responses to the comments
and guestions received at the public meeting, along with other written comments received during the public
comment period, are included in the Responsiveness Summary  (see Appendix V) . In addition, EPA also met with
the Town of Niagara Supervisor and City of Niagara Falls Environmental Planer to present the Proposed Plan
and to answer any guestions concerning the Plan and other details related to the RI and FS reports.

At the Public Meeting, EPA announced that, in response to a reguest, the public comment period announced in
the Plan would be extended to November 24, 1997. A notice of the extension of the public comment period was
published in the Niagara Gazette on October 21, 1997. The public comment period was extended again    until
December 8, 1997.

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During this comment period, a member of the Office of the City Council of the City of Niagara Falls and the
Supervisor of the Town of Niagara commented that the preferred alternative (S-4) identified in the Proposed
Plan is based upon a presumed residential use of the site. These commenters stated that the most productive
use of this site would be commercial, not residential. Subsequent to receiving the aforementioned comments,
EPA met with the Mayor of Niagara Falls and his staff to determine if the City of Niagara Falls concurred
that the residential zoning of the Subdivision should be changed to commercial. The Mayor asserted that the
City had no intentions to change the residential zoning of the former Forest Glen Subdivision to commercial
zoning.

SCOPE AND ROLE OF RESPONSE ACTION

Site remediation activities are sometimes segregated into different phases, or operable units, so that
remediation of different environmental media can proceed separately, resulting in an expeditious cleanup of
the entire site. EPA has designated three operable units for this site. The first operable unit addressed the
permanent relocation of the residents of the Forest Glen Subdivision which was completed in 1992.

The remedy selected in this ROD addresses soil and sediment contamination at the site which EPA has
designated as the second operable unit (OU2) of site remediation.

The third and final operable unit will address ground-water contamination. While the ground water underlying
the southern portion of the site is contaminated, additional data are required to adequately characterize the
ground water in the northern portion of the site. A Supplemental RI/FS to obtain and analyze this information
is currently underway and expected to be completed by June 1998.
SUMMARY OF SITE CHARACTERISTICS

EPA detected high levels of contamination in site soils prior to the RI. Table 3 presents a summary of these
analytical data collected by EPA during previous sampling events. Two areas with the highest levels of
contamination were temporarily covered with concrete to prevent exposure to these contaminants. These covered
areas were not resampled during the RI.

As part of the RI, initial site investigations were conducted in order to characterize the geologic and
hydrogeologic conditions at the site. In addition, surface and subsurface soil, wetland sediments, creek
sediments, surface water and ground water were sampled.

A geophysical survey was conducted to investigate subsurface conditions and identify buried drums and waste.
This work included an electromagnetic survey in the Northern Aspect and a seismic refraction survey in the
Subdivision. Twelve test pits were excavated in the Northern Aspect at locations where anomalies were
detected during the geophysical survey. A total of 48 surface soil samples were collected in the Subdivision,
Northern Aspect and Edgewood Drive Wooded Lots. Ten sediment samples were gathered from the Wooded Wetland.
Two rounds of surface water and sediment samples were collected from East Gill Creek. Nine monitoring well
clusters were installed in the shallow and deep bedrock. An overburden monitoring well and a perched water
monitoring well were also installed at one location for a total of 20 wells. Two rounds of ground-water
samples were collected from these wells to evaluate the nature and extent of ground-water contamination.

Samples collected from the different media were analyzed for the Target Compound List/Target Analyte List
(TCL/TAL). The TCL consists of 130 compounds, including volatile organic compounds, semi-volatile organic
compounds, pesticides and polychlorinated biphenyls (PCBs) . The TAL inorganic analytes consist of 24 metals.
In addition, based on the pre-RI sampling results, EPA developed a site-specific list of rubber industry
chemicals associasted with Goodyear, designated as the Targeted Organic Compounds, (see Table 1) which were
not included in the TCL/TAL.

A summary of the analytical data collected for OU2, listed by areas of concern, can be found in Table 2 of
Appendix II.

Physical Site Conditions

The Forest Glen Subdivision Site is generally flat, with the ground elevation increasing toward the north.

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Local variations in topography occur along East Gill Creek, the berm and several soil mounds. Surface
elevations range from 591 feet above mean sea level (AMSL) in the Subdivision to 608 feet AMSL in the
Northern Aspect.

Geology and Hydrogeology

The geology of the region consists predominantly of compact and generally impermeable lodgement till and
glacial lacustrine clay common to the Niagara Escarpment. The lodgement till is a remnant of the receding
glaciers of the last ice age. The resulting topography is generally flat, due to the scouring effect of the
glacier and is poorly drained, due to the impermeability of the glacial lacustrine clay and glacial till.

The region surrounding the site exhibits this glacial geomorphology, although evidence of manmade
modification is apparent. The regional overburden consists of glaciolacustrine deposits (clay) and clay till
deposits overlying the Lockport Dolomite bedrock. The Lockport Dolomite is a karst formation, generally 150
feet of doledtone overlying 120 feet of limestones and shales, including the impermeable Rochester Shale,
below which is limestone and sandstone, overlying the Queenstone Shale. The bedrock beneath the site and
throughout the region dips gently to the south at 29 feet per mile.

The Lockport Dolomite is the major water-producing formation of the area. At the site, the hydrogeology is
defined by three hydrostratigraphic zones: perched overburden water, shallow bedrock and deep bedrock. The
overburden extends approximately from zero to 20 feet below ground surface (BGS). Due to the low permeability
of the overburden clay and till, perched ground-water conditions were encountered at the site. The shallow
bedrock zone extends from 16 to 28 feet BGS. Ground water in this zone flows both vertically and horizontally
through an interconnecting system of closely-spaced joints and bedding plane fractures. The deep bedrock zone
is encountered at depths of 40 to 45 feet BGS. It is probable that hydraulic communication occurs between the
shallow and deep bedrock zones.

Ecology

There are four broad habitat categories at the site: residential, wetland, aquatic and disturbed upland
successional habitat. Nearly all the non-residential areas of the site have been determined to be wetland
areas, including the following types: palustrine, forested, broad-leaved, deciduous wetland; palustrine
scrub-shrub, broad-leaved, deciduous wetland, and emergent wetland.

Numerous on-site wildlife observations have been made, including the direct observations of birds, mammals,
fish, amphibians, insects and arachnids. There were also observations of wildlife usage, such as scat, nests,
tracks, runways and browsed vegetation.

Areas of Concern

The site was divided into six areas of concern (AOC) (see Figure 2) based upon their unigue physical
characteristics, historical use and waste disposal practices. The following is a description of each AOC.

AOC 1 - Berm

The 1.8-acre berm is located within the Northern Aspect (AOC 2). Approximately 1,300 feet long, 50 feet wide
and 11 feet high, it is bordered on the west and north by the Conrail Foote Railroad yard and to the south
and east by the Northern Aspect. The berm was reportedly built in the 1970s to act as a sound barrier for the
planned Subdivision and is constructed of fill material and native soil excavated from the ground surface of
the Northern Aspect. Drums of waste material were discovered along the berm and were subsequently removed
during previous EPA investigations.

AOC 2 - Northern Aspect

The Northern Aspect consists of an 18-acre open field located north of East Gill Creek and the Subdivision.
According to historical records, the field was leveled and topsoil was used to create the earthen berm
that acts as much of the Northern Aspect's western boundary. This area is bounded to the south by East Gill

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Creek and Service Road, to the north by the Conrail Foote railroad yard and to the east by Interstate 190.
Anecdotal reports from area residents suggest illegal landfilling activities may have occurred in the
Northern Aspect.

AOC 3 - Wooded Wetland

The Wooded Wetland is a 1.5-acre low-lying area located in the southeastern part of the Northern Aspect. This
area is characterized as a palustrine forest, broad-leaved, deciduous wetland. It is bounded on the north and
west by the Northern aspect, on the south of east Gill Creek and to the east by Service Road. An
intermittent stream was noted in the area occasionally connecting the Wooded Wetland to East Gill Creek.

AOC 4 - East Gill Creek

East Gill Creek is a narrow, shallow, low-flowing creek that serves as the Subdivision's northern boundary.
Subdivision runoff is directed into the creek via two outfalls. Aerial photographs indicated that the creek
was rerouted in the late 1960s from its original location 400 feet south of its present location. The creek
flows onto the site from the east through a series of culverts that flow under 1-190.

AOC 5 - Edgewood Drive Wooded Lots

These are two wooded, undeveloped lots located north and south of Edgewood Drive. The lots are bisected by
Edgewood Drive and are both bounded by T. Mark Drive to the west and Service Road to the east. The north lot
is approximately 3 acres in size and is bounded to the north by East Gill Creek. The south lot is
approximately 3.3 acres in size and extends approximately 250 to the south of Edgewood rive. Aerial
photographs, together with stressed vegetation and topographical depressions, suggest illegal landfilling
occurred in the wooded areas over the years.

AOC 6 - Forest Glen Subdivision

This area of concern includes the abandoned residential Subdivision located in the southwest corner of the
site. The Subdivision is bounded by T. Mark Drive to the east, the Conrail Foote Railroad yard to the west,
Lisa Lane to the south and East Gill Creek to the north. The Subdivision is accessed via Edgewood Drive, off
Service Road. The former residents of the Subdivision were relocated to prevent their exposure to high
concentrations of surface-soil contaminants detected in sampling events performed by EPA prior to the RI.
Areas of high contamination were temporarily covered with concrete.

Soil, Sediment and Surface Water Contamination

EPA detected high levels of contamination in site soils prior to the RI (See Table3). Two areas with the
highest levels of contamination were temporarily covered with concrete to prevent exposure to these
contaminants. These covered areas were not resampled during the RI.

In order to characterize the contamination, levels of organic contaminants detected at the site were compared
to NYSDEC's recommended soil cleanup objectives identified in the Technical and Administrative Guidance
Memorandum (TAGM) (See Table 4, Appendix II). The inorganic compounds, with the exception of mercury, were
compared to soil background concentrations for these parameters. NYSDEC Technical Guidance for Screening
Contaminated Sediments was used to assess sediments. Ground-water contamination was assessed against National
Primary Drinking Water Standards (Maximum Contaminant Levels) and creek contamination was compared to New
York State Water Classification and Quality Standards.

Fill was encountered in soil borings and test pits in the northwest section of the Northern Aspect, in all
berm samples, in some borings in the Edgewood Drive Wooded Lots and in the northern and central section of
the Subdivision. This fill varies in composition and appearance in different parts of the site, but
generally includes black-stained material which is attributed to past dumping activities.

Soil Contamination: AOC 1 - Berm

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The highest levels of contamination in the Bern were associated with the heavily stained fill material. The
Targeted Organic Compounds were detected at the following concentrations in ppb: benzothiazole  (410-150,000);
diphenylamine  (400-11,000); 2-mercaptobenzothiazole  (270-1,100,000); 2-anilinobenzothiazole  (90-960,000);
N,N'-diphenyl-l,4-benzenediamine  (18,000-210,000); perylene  (1,400-3,800); phenothiazine  (60-4,600); and
phenyl isothiocyanate (1,100). The concentrations of these Targeted Organic Compounds in the Berm exceeded
the NYSDEC cleanup objective for these contaminants by up to one thousand times
(2-mercaptobenzothiazole). The semivolatile organic compounds were detected at the following range of
concentrations in ppb: benzo(a)pyrene  (210-3,800); benzo-(b)fluoranthene  (55-10,000); benzo(k)  fluoranthene
(55-11,000) ; benzo  (a)  anthracene  (200-6,600); phenol  (330-9,700); and 2-methylphenol  (120-980). The
concentrations of benzo(a)pyrene and phenol are 60 and 300 times the NYSDEC cleanup objective for these
contaminants, respectively. The inorganic compounds were detected at the following range of concentrations in
mg/kg or parts per million  (ppm): cobalt  (15.3-30.7) ; nickel  (29.6-47.9); arsenic  (2.3-15.8);  chromium
(21.4-120); mercury  (0.19-13.5); lead  (8.6- 73.6); copper  (25-185); and   vanadium  (28.1-38.7). These metal
concentrations are two to four times greater than their background concentrations, with the exception of the
mercury which was detected at up to 135 times the NYSDEC cleanup objective for the contaminant.  (See Table 4,
Appendix II.)

It is estimated that there are approximately 56,000 cubic yards  (cy) of subsurface soil in the  Berm that
contain contaminants above NYSDEC's cleanup objectives.

Soil Contamination: AOC 2 - Northern Aspect

The Targeted Organic Compounds were detected in surface soils in the Northern Aspect at the following
concentrations in ppb: perylene (50-100) and 2-anilinobenzothiazole  (80). The semivolatile organic compounds
were detected in surface soils at the following concentrations in ppb: benzo  (a) pyrene  (27-260) and
dibenzo(a,h)anthracene  (25-50). The inorganic compounds were detected in surface soils at the following
concentrations in ppm: barium  (114-278); beryllium  (0.26-1.5); mercury  (0.17-1.5); and nickel  (18.7 - 49.10).

The highest contaminant concentrations were associated with fill material in subsurface soils.  The Targeted
Organic Compounds were detected in subsurface soils at the following concentrations in ppb: perylene
(130-450); 2-anilinobenzothiazole (130-27,000); diphenylamine  (320-330); 2-mercaptobenzothiazole
(3,200-24,000); aniline  (260-280); phenothiazine  (270-470); and benzothiazole  (2,200-3,200). The
concentrations of these Targeted Organic Compounds in subsurface soils exceeded the MYSDEC cleanup objective
for these contaminants by up to 28 times  (2-mercaptobenzothiazole)- The semivolatile organic compounds were
detected in subsurface soils at the following concentrations: dibenzo(a,h)anthracene
(26-330); benzo(a)pyrene  (78-2,600); benzo(a)anthracene (91-7,700); phenol  (57-200); benzo(b)fluoranthene
(150-12,000); chrysene  (87-2,700); and benzo (k) fluoranthene  (75-12,000). The PAHs exceeded NYSDEC cleanup
objectives by more than 40 times. The inorganic compounds were detected in subsurface soils at  the following
concentrations in ppm: arsenic  (2-9.4); chromium  (6.2-34.7); nickel  (8.3-55.5); mercury  (0.07-2.8); vanadium
(10-70.4) and selenium  (1.4-2.6). The inorganics were detected at levels one to two times above background
levels, however, mercury was present at concentrations over 25 times the NYSDEC cleanup objective.  (See Table
4, Appendix II.)

It is estimated that there are approximately 105,000 cy of surface and subsurface soil in the Northern Aspect
that contain contaminants above NYSDEC cleanup objectives.

Sediment Contamination:  AOC 3 - Wooded Wetland

PAH, pesticide and PCE contamination was found in sediments throughout the Wooded Wetland. The  only Targeted
Organic Compound detected in sediments was perylene  (120-250 ppb). The semivolatile organic compounds  (PAHs)
were detected in sediments at the following concentrations in ppb: fluoranthene  (300-920); pyrene  (320-670);
benzo(a)anthracene (160-510);  chrysene  (310-680); benzo(b)fluoranthene  (570-1400); benzo(k)fluoranthene
(620-1400); indeno(1,2,3-CD)pyrene  (150-290); dibenzo(a,h)anthracene  (52-80); benzo(g,h,i)perylene  (160-390);
and benzo(a)pyrene (260-530).  Pesticides and PCBs were detected in sediments at the following concentrations:
alpha-BHC  (0.47-5.5); 4,4'-DDE  (1.2-12); arochlor 1254  (68-110) ; and beta-BHC  (2.1-8.1). The inorganic
compounds were detected in the sediment at the following concentrations in ppm: arsenic  (4.6-7.7); cadmium

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(1.1-1.5); chromium  (36.7-53.5); copper  (29.2-51.9); lead  (84.8-114); mercury  (0.55-1.5); nickel  (30.5-39.2);
silver (1.2-2); and zinc  (214-374). These inorganic compounds were detected at concentrations that are twice
the cleanup objectives for these contaminants.  (See Table 4, Appendix II.)

It is estimated that there are approximately 2400 cy of sediment that contain contaminants above NYSDEC
cleanup objectives.

Sediment Contamination: AOC 4 - East Gill Creek

East Gill Creek receives storm-water runoff from the site. Analytical results show that surface soil
contamination has been transported into East Gill Creek. The highest concentrations were seen in the
downstream samples. Therefore, it appears that the creek could act as a contaminant migration pathway during
times of high flow. Surface-water guality is characterized by pesticide concentrations at or exceeding NYSDEC
surface-water standards. Two pesticides which exceeded the NYSDEC surface-water standards, alpha-BHC and
beta-BHC  (up to 3,600 ppb),  were frequently detected in the Wooded Wetland. (See Table 4, Appendix II.)

It is estimated that there are approximately 190 cy of sediment that contain contaminants above NYSDEC
cleanup objectives.

Soil Contamination: AOC 5 - Edgewood Drive Wooded Lots

The highest concentrations generally were detected in the fill material in surface soils. The Targeted
Organic Compounds were detected in surface soils at the following concentrations in ppb: perylene  (5-12,000);
2-mercaptobenzothiazole  (570-1,800); 2-anilinobenzothiazole  (1,300-2,100); diphenylamine  (50);
N,N'-diphenyl-1,4-benzenediamine (2,800); and benzothiazole  (260). The concentrations of these Targeted
Organic Compounds exceeded the NYSDEC cleanup objective for these contaminants by up to two times
(2-mercaptobenzothiazole). The semivolatile organic compounds were detected in surface soils at the following
concentrations in ppb: chrysene (40-95,000); benzo(a)anthracene(54-100,000); benzo(b)fluoranthene
(100-130,000); benzo(k)fluoranthene (98-120,000); benzo(a)pyrene  (47-88,000);  dibenzo(a,h)anthracene
(68-16,000); indeno(1,2,3-cd)pyrene (240-25,000); and fluoranthene 56-130,000). The PAHs were found at
concentrations up to 1400 times the NYSDEC cleanup objectives for these contaminants. The inorganic compounds
were detected in surface soils at the following concentrations in ppm: nickel  (23.6-139); mercury  (0.07-2.5);
lead (8.7-157); arsenic  (4.6-21.3); beryllium (0.29 - 1.5); and vanadium    (32.3-125).

The only Targeted organic Compound detected in subsurface soils in the Edgewood Drive Wooded Lots was
perylene  (0.08-6,800 ppb). The semivolatile organic compounds were detected in subsurface soils at the
following concentrations in ppb: benzo(b)fluoranthene (87-98,000); benzo(k)fluoranthene  (85-79,000);
benzo(a)anthracene (53-56,000); chrysene (56-50,000); and benzo(a)pyrene(40-42,000). Although the PAH
concentrations generally decreased in the subsurface soils, these levels ranged from 70 to 680 times the
NYSDEC cleanup objectives. The inorganics were detected in subsurface soils at the following concentrations
in ppm: nickel  (8.5-69.4); mercury  (0.14-3.2); cobalt (4.3-16.8); chromium  (6-6-54.4);  beryllium  (0.44-1.7) ;
barium (34.7-182); and lead  (6.3-114).

Metals in the subsurface were found at levels up to twice background levels. (See Table 4, Appendix II.)

It is estimated that there are approximately 54,100 cy of surface and subsurface soil in the Edgewood Drive
Lots that contain contaminants above NYSDEC cleanup objectives.

Soil Contamination: AOC 6 - Subdivision

The highest concentrations of contaminants were found in the fill in surface soil in the northern end of the
Subdivision. The Targeted Organic Compounds were detected in surface soils at the following concentrations in
ppb: 2-anilinobenzothiazole  (90-330, 000);  2-mercaptobenzothiazole (120-47,000); benzothiazole (120-10,000);
perylene  (40-650); N,N'-diphenyl-1,4-benzenediamine  (110-13,000); diphenylamine (40-1,600); phenothiazine
(80-3,800); and phenyl isothiocyanate (100-130). The concentrations of these Targeted Organic Compounds in
the surface soils of the Subdivision exceeded the NYSDEC cleanup objective for these contaminants by up to 55
times  (2-mercaptobenzothiazole). The semivolatile organic compounds were detected in surface soils at the

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following concentrations in ppb: benzo(a)pyrene  (100-2,500); benzo(a)- anthracene  (130-2,900); chrysene
(25-2,400); benzo(b)fluoranthene     (220-7,200); benzo(k)fluoranthene  (220-6,900) dibenzo  (a, h) -
anthracene  (74-530); phenol  (85-7,800); and 2-methyl phenol  (60-360). These PAH and phenol concentrations are
up to 40 and 260 times greater that NYSDEC cleanup objectives for these contaminants, respectively. While
elevated levels of organic  compounds were detected in surface soils, concentrations are significantly less
than have been historically reported. The inorganics were detected in surface soils at the following
concentrations in ppm: copper  (4.3-387) cobalt  (1.1-193); mercury (0.11-5.7) and beryllium  (0.08-0.97).
Metals were detected at concentrations up to nine times the NYSDEC cleanup objectives for these contaminants.

The only volatile organic compounds detected in subsurface soils in the Subdivision were total xylenes
(2-10,000). The Targeted Organic Compounds were detected in surface soils at the following concentrations in
ppb: perylene  (60-8,000); N,N'-diphenyl-1,4 -benzenediamine  (40-25,000); benzothiazole (100-16,000);
diphenylamine  (800-8,000); 2-mercaptobenzothiazole (200-50,000); 2 -anilinobenzothiazole (1,000-170,000);
phenothiazine  (800); and aniline (400). The concentrations of these Targeted organic Compounds in the
subsurface soils of the Subdivision exceeded the NYSDEC cleanup objective for these contaminants by up to 58
times (2-mercaptobenzothiazole).

The semivolatile organic compounds were detected in subsurface soils at the following concentrations in ppb:
behzo(a)pyrene (320-170,000); benzo  (a) anthracene (460-250,000); chrysene  (530-160,000);
benzo(b)fluoranthene  (340-220,000); dibenzo(a,h)-anthracene  (8,600-8,700); and phenol (250-7,500). The PAH
concentrations exceeded NYSDEC cleanup objectives by more than 2,780 times. The inorganics were detected in
subsurface soils at the following concentrations in ppm: nickel  (0.02-132); chromium (0.02-46.6); vanadium
(0.03-147); arsenic (2.5-14.6); and mercury (0.13-25.6). The inorganics were detected in the subsurface at
levels between eight to nine times background Mercury, however, was present at concentrations 250 greater
than the NYSDEC cleanup objectives for this contaminant. (See Table 4, Appendix II.)

It is estimated that there are approximately 67,500 cy of surface and subsurface soil in the Subdivision,
including those under the temporary concrete cover, that contain contaminants above NYSDEC cleanup
objectives. Based on the results of several sampling events conducted to date at the site,  no contamination
was detected in the southern portion of the Subdivision. These data, together with a review of aerial
photographs taken at the site, suggest that the southern portion of the Subdivision has not been used for
industrial waste disposal.

In summary, the total volume of contaminated soil and sediments at the site that exceed soil cleanup
objectives is estimated at 285,200 cy.

REMEDIAL ACTION OBJECTIVES

Remedial Action Objectives (RAOs)  are specific goals to protect human health and the environment; they
specify the contaminants of concern, exposure routes, receptors and acceptable contaminant levels for each
exposure route.

The following RAOs were established for the site:

•       Prevent human contact with contaminated soils, sediments, and ground water;


•       Prevent  ecological contact with contaminated soils and sediments;

•       Mitigate the migration of contaminants  from soils/fill to ground water;

The RAOs which were developed for soil and sediment are designed, in part, to mitigate the health threat
posed by ingestion,  dermal contact or inhalation of particulates where these soils are contacted or
disturbed. Such objectives are also designed to prevent further leaching of contaminants from the soil to the
ground water.

Preliminary Remediation Goals are cleanup objectives based on the available information and standards, such

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as applicable or relevant and appropriate (ARARs) and risk-based levels established in the risk assessment.
The PRGs for soil are the NYSDEC recommended soil cleanup objectives identified in the TAGM (see Table 4,
Appendix II). The primary soil PRGs are benzo(a)pyrene at 61 Ig/kg or ppb, aniline at 100 Ig/kg or ppb,
phenol at 30 Ig/kg or ppb, and mercury at 0.1 mg/kg or ppm.

The PRGs for sediment are NYSDEC recommended cleanup objectives identified in NYSDEC's Technical Guidance for
Screening Contaminated Sediment, 1994. The primary sediment RAO for manganese is 460 ppm.

The RAOs and PRGs were based on the assumption of a residential land-use scenario. The current land-use
designation of the Subdivision is residential. If the zoning changes, EPA will consider how this change
affects the selected remedy.

SUMMARY OF SITE RISKS

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 a site based on several
factors such as toxicity, freguency of occurrence, and concentration. Exposure Assessment--etimates 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 site baseline risk assessment began with selecting contaminants of concern (COCs) for the various site
media: soils; ground water; surface water; and sediments. COCs are selected based on the freguency of
detection in RI samples, the magnitude of the concentrations detected and the relative toxicity of the
contaminants. COCs characterize the contaminants that are most representative of risks at the site.

The baseline risk assessment evaluated the health effects whichcould result from current and future site-use
conditions. Under current-use conditions, exposure pathways based on ingestion and dermal contact with
contaminants in soil and dermal contact with sediments and surface water at the site were evaluated for both
adult and children trespassers. Under future-use conditions, potential residents were evaluated for ingestion
and dermal contact with contaminants in surface soil and sediments, inhalation of particulates from surface
soil, ingestion of ground water, dermal contact with ground water, inhalation of VOCs in ground water while
showering and ingestion of chemicals present in sediment and surface water at the site. Future-use risks to
construction workers on site were evaluated through ingestion, dermal contact and inhalation of particulates
from surface and subsurface soil.

Current federal guidelines for acceptable exposures are an individual lifetime excess carcinogenic risk in
the 10 -4 to 10 -6 (i.e., a one-in-ten-thousand to one-in-a-million excess cancer risk or likelihood of an
additional instance of cancer developing) and a maximum health Hazard Index (HI), which reflects
noncarcinogenic effects for a human receptor, egual to 1.0. An HI greater than 1.0 indicates a potential of
noncarcinogenic health effects.

The results of the baseline human health risk assessment are contained in the Endangerment Assessment, Forest
Glen Site, Niagara Falls, New York, dated November 1996 which was prepared by COM Federal Programs
Corporation. Under current-use conditions, site exposure pathways were evaluated for teenage trespassers.
Receptors for future-use conditions at the site were adults and children.

The risk assessment concluded that teenage trespassers were not at risk from potential contact with
contamination in site media, based on an estimated risk of 3.1 x 10 -5. The noncancer HI for teenage
trespassers (HI=0.26) was well below the target level of 1.

However, the risk assessment concluded that potential future residents would be at risk from exposure to

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site-soil contamination and from ingestion of the organic compounds in the site ground water.

For future-use conditions, the greatest carcinogenic risks to potential residents resulted from the
incidental ingestion of surface soils from the Edgewood Drive Wooded Lots. These risks are 4.2 X 10 -4 for
adults and 9.6 X 10 -4 for children, which exceed the target risk range. The greatest singular contributor to
these risks is benzo(a)pyrene. The carcinogenic risk from the ingestion of site ground water for adults is
7.4 X 10 -4. This risk is primarily a result of the presence of vinyl chloride and n-nitroso-
di-n-propylamine.

Many of the Targeted organic Compounds, including 2-anilinobenzothiazole, benzothiazole and phenyl
isothiocyanate, do not have toxicity data available. Therefore, these compounds were not included in the risk
calculation. This may have underestimated the risks at the site. In addition, risks may have been
underestimated because EPA performed the risk assessment solely using data gathered during the RI. Areas with
high concentrations of contaminants which were covered during the removal action at the site were not
resampled during the RI and included in the risk assessment analysis. There are significant potential risks
associated with the concentrations of contaminants detected during sampling events prior to the RI. Aniline,
for example, poses a significant potential cancer risk on the order of 1x10 -4 based on the maximum
concentration detected (11,000,000 ppb). Based primarily on the presence of the Targeted Organic Compounds,
ATSDR, in the July 1989 Health Advisory, determined that there was a "significant risk to human health" at
the site.

The highest noncarcinogenic His for the future residential scenario for children by exposure via ingestion
and inhalation (primarily manganese) are as follows: Subdivision-4.9; Northern Aspect-3.3; Edgewood Drive
Wooded Lots-3.2. The HI for future residential exposure via ingestion of ground water is 8 for adults and 19
for children. The primary contributors to these risks are 1,2-dichloroethene, hexachlorobutadiene, arsenic
and manganese.

Based on the results of the baseline risk assessm ent, EPA has determined that actual or threatened releases
of hazardous substances from the 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.

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 the 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 contamination to effects on ecological receptors. Risk
Characterization—measurement or estimation of both current and future adverse effects.

The potential risk to ecologic receptors at the site was assessed by comparing the estimated exposure levels
with toxicity values. Aguatic, as well as terrestrial risks, were considered. Aguatic risks from East Gill
Creek sediment and surface water were evaluated using the muskrat as a receptor. Terrestrial risks were
evaluated using the shorttail shrew and the red-tail hawk.

Evaluation of the muskrat as an ecological receptor for chemicals from East Gill Creek sediment and surface
water indicates the potential for both acute and chronic adverse effects. Aluminum and iron are the major
contributors to these potential adverse effects.

Chemicals in site soils also present the potential for adverse effects. For the shorttail shrew, an
ecological receptor at the base of the food chain, the potential exists for both acute and chronic effects
from exposure to contaminated soils in the Northern Aspect, Subdivision, Wooded Wetland and Edgewood Drive
Wooded Lots. The primary contributor to this risk is lead, with chromium and copper as secondary
contributors. For the red-tailed hawk, an ecological receptor at the top of the food chain, no acute adverse

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effects are expected from exposure to site soils, either from individual AOCs or from the entire site.
However, the potential exists for chronic adverse effects for the red-tail hawk, primarily from copper.

It is possible that some ecological COCs detected in on-site sediment and surface water are not related to
site activities, but were transported from an upstream source. An example of this is water flowing onto the
site in East Gill Creek contains higher concentrations of compounds than water leaving the site. An
investigation of such potential upstream sources of contamination, which may be impacting the site, is
planned as part of the ongoing Supplemental RI/FS.

Discussion of Uncertainties in Risk Assessment

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

       •      environmental chemistry sampling and analysis;
       •      environmental parameter measurement;
       •      fate and transport modeling;
       •      exposure parameter estimation;  and,
       •      toxicological data.

Uncertainty in environmental sampling arises, in part, from the potentially uneven distribution of chemicals
in the media sampled. 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 exposure assessment are related to estimates of how often an individual would actually
come in contact with the contaminants of concern, the period of time over which such exposure would occur,
and in the models used to estimate the concentrations of the contaminants 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 baseline human health risk assessment provides upper-bound
estimates of the risks to populations near the site, and it 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 EPA's baseline human health risk
assessment report for OU2.

The greatest carcinogenic risks at the site revealed during OU2, assuming the future land use at the site
remains residential, are associated with the ingestion of surface soil by adults and children in the Edgewood
Drive Wooded Lots and the ingestion of ground water. The greatest noncarcinogenic risks at the site are
associated with the ingestion of surface soil by adults and children in the Subdivision, Northern Aspect and
the Edgewood Drive Wooded Lots and the ingestion of ground water.

In light of the above, EPA has determined that actual or threatened releases of hazardous substances from
this site, if not addressed by implementing the response actions selected in this ROD, may present a
potential threat to public health and welfare, or the environment.

DESCRIPTION OF REMEDIAL ALTERNATIVES

CERCLA reguires 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, alternative treatment
technologies and resource recovery alternatives to the maximum extent practicable. In addition, the statute
includes a preference for the use of treatment as a principal element for the reduction of toxicity,

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mobility, or volume of the hazardous substances.

Six soil remedial alternatives for addressing the contamination associated with the Forest Glen Subdivision
Site were evaluated in detail in the Proposed Plan and in the Record of Decision.

Construction time refers to the time required to physically construct the remedial alternative. This does not
include the time required to negotiate with the responsible parties for the remedial design and remedial
action, or design the remedy or to obtain institutional controls.

During the detailed evaluation of remedial alternatives, each alternative was assessed against nine
evaluation criteria, namely, overall protection of human health and the environment, compliance with ARARs,
long-term effectiveness and permanence, reduction of toxicity, mobility, or volume through treatment,
short-term effectiveness, implementability, cost, and state and community acceptance. (See Table 5, Appendix
II.)

Alternative S-l: No Further Action

Capital Cost $ 586,800
Annual O&M Cost $ 9,600
Present Worth Cost $ 643,500
Time to Construct None

CERCLA requires that the "No-Action" alternative be considered as a baseline for comparison with other
alternatives. The No-Further-Action alternative does not include institutional controls or active remedial
measures to address on-site contaminated soils. However, this response action does include the implementation
of a ground-water monitoring program to monitor contaminant migration from contaminated soils.

The No-Further-Action alternative also would include the development and implementation of a public awareness
and education program for the residents in the area surrounding the site. This program would include the
preparation and distribution of informational press releases and circulars and convening public meetings.
These activities would serve to enhance the public's knowledge of the conditions existing at the site.

This alternative, if selected, would result in contaminants remaining on-site in concentrations exceeding
health-based levels. Therefore, under CERCLA, the site would have to be reviewed at least every five years.

Alternative S-2: Limited Action

Capital Cost $ 1,173,800
Annual O&M Cost $ 35,100
Present Worth Cost $ 2,469,200
Time to Construct 6 months

This alternative includes the installation of a fence surrounding the site, the implementation of
institutional controls (the placement of restrictions of ground-water wells at the site and limitations on
the future use of the site) and a ground-water monitoring program to monitor contaminant migration from
contaminated soils.

This limited-action alternative would also include the development of public awareness and education programs
for the residents in the surrounding area (see Alternative S-l).

Alternative S-3: Capping (6 NYCRR Part 360 Cap)

Capital Cost $ 10,207,300
Annual O&M Cost $ 112,300

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Present Worth Cost $ 12,454,000
Time to Construct 12 months

The major feature of this alternative is the construction of a hazardous waste landfill cap to eliminate the
threat of exposure to contaminated soils. Contaminated soils would be consolidated and it is estimated that
the final size of the capped area would be approximately 17 acres. The cap would be built according to NYSDEC
regulations (6 NYCRR Part 360), with the exception of the Wooded Wetland which would be capped with six
inches of sediment. 1 No intrusive activities should be performed on the cap in order to preserve its
integrity. Therefore, this alternative would include taking steps to secure institutional controls to limit
future activities at the site and fencing to limit future access. The vacant trailers and two permanent homes
would be removed in order to prepare the site for capping. A ground-water monitoring program would be
implemented to assess the effectiveness of the remedy.

Alternative S-4: Excavation, Consolidation and on-site Disposal

Capital Cost $ 15,357,800
Annual O&M Cost $ 34,300
Present Worth Cost $ 16,397,000
Time to Construct 18 months

This alternative includes the excavation of approximately 190,200 cy contaminated soils from the AOCs 1,5 and
6, and 190 cy of sediment from East Gill Creek and the consolidation of these excavated soils in the Northern
Aspect. The contaminated soil and sediment would be compacted and covered with a cap approximately 8.5 acres
in size and approximately 30 feet in height in accordance with 6 NYCRR Part 360, with the exception of the
Wooded Wetland which would be covered with six inches of sediment. 1 The vacant
trailers and two permanent homes would be removed in order to prepare the site for excavation. Excavated
areas would be backfilled with clean fill and topsoil and seeded. Monitoring wells in the Northern Aspect
would be monitored to ensure the effectiveness of the remedy. This alternative would include taking steps to
secure institutional controls to limit future activities in the Northern Aspect and fencing to limit future
access to the capped area. This alternative would result in restricting future use in the Northern Aspect,
but would allow productive use of the remainder of the site.

Alternative S-5: Excavation and Off-site Disposal

Capital Cost $ 106,350,434
Annual O&M Cost $ 0
Present Worth Cost $ 106,350,434
Time to Construct 12 months

This alternative also includes the excavation of approximately 282,600 cy contaminated soils from AOCs 1,2,5
and 6, and 2,590 cy of sediments from East Gill Creek and the Wooded Wetland. Excavated areas would be
backfilled with clean fill, topsoil and seeded in the Northern Aspect, the Berm, the Wooded Lots and the
Subdivision. Sediments from the East Gill Creek would be replaced with material of a similar nature and the
Wooded Wetland would be appropriately restored. Waste characterization samples would be collected and
analyzed, and the contaminated soils disposed in a Resource Conservation and Recovery Act (RCRA) licensed and
approved off-site hazardous waste landfill. The vacant trailers and two permanent homes would be removed to
prepare the site for excavation.

1 If further studies conclude that the addition of six inches of clean sediment would have an
adverse impact on the wetland, contamination in the Wooded Wetland would be excavated and the
Wooded Wetland would be appropriately restored. It is extimated that this work could be

-------
          performed at a cost of approximately $50,000.


Once the excavation work has been completed, there would be no future O&M costs or ground-water monitoring
associated with this alternative because no contaminants would remain on-site exceeding health-based levels.

Alternative S-6: Excavation and On-site Low Temperature Desorption and Solidification/Stabilization

    Capital Cost             $ 81,986,000
    Annual O&M Cost          $          0
    Present Worth Cost       $ 81,986,000
    Time to Construct        18 months

This alternative also includes the excavation of approximately 282,600 cy contaminated soils from AOCs 1,2 5
and 6, and 2,590 cy of sediments from East Gill Creek and the Wooded Wetland. These soils and sediments would
then be treated on-site to remediate the organic contamination using low temperature thermal desorption
(LTTD).  The excavated soils and sediments would be fed to a mobile LTTD unit brought to the site, where hot
air injected at a temperature above the boiling points of the organic contaminants of concern would allow
them to be volatilized into gases and escape from the soil. The organic vapors extracted from the soil would
then either be condensed, transferred to another medium (such as activated carbon) or thermally treated in an
afterburner operated to ensure the complete destruction of the volatile organics. The off-gases would be
treated through a carbon vessel. Once the treated soil achieved the TAGM objectives, it would be tested in
accordance with the Toxicity Characteristic Leaching Procedure (TCLP) to determine whether it constitutes a
RCRA hazardous waste and, provided that it passes the test (i.e., it is determined to be a hazardous waste),
this treated soil would need to undergo on-site stabilization/ solidification to chemically fix the inorganic
contaminants to prevent leaching. The excavated areas would be backfilled with the treated soil and would be
restored as described under Alternative S-5. Treatability studies would have to be performed during the
remedial design phase to establish optimum operating conditions for the LTTD and
solidification/stabilization. The vacant trailers and two permanent would be removed to prepare the site for
excavation.

Similar to Alternative S-5, once the contaminated soils have been treated and stabilized, there would be no
future O&M costs or ground-water monitoring associated with this alternative because no contaminants would
remain on-site exceeding health-based levels.

SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES

During the detailed evaluation of remedial alternatives, each alternative was assessed utilizing nine
evaluation criteria as set forth in the NCP and OSWER Directive 9355.3-01. These criteria were developed to
address the reguirements of Section 121 of CERCLA to ensure all important considerations are factored into
remedy selection decisions.

The following "threshold" criteria are the most important, and must be satisfied by any alternative in order
to be eligible for selection:

    1.   Overall protection of human health and the environment addresses whether or not a remedy provides
         adeguate protection and describes how risks posed through each exposure pathway (based on a
         reasonable maximum exposure scenario)  are eliminated, reduced, or controlled through treatment,
         engineering controls, or institutional controls.

    2.   Compliance with ARARs addresses whether or not a remedy would meet all of the applicable, or
         relevant and appropriate reguirements of Federal and State environmental statutes and
         reguirements or provide grounds for invoking a waiver.

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

-------
3. Long-term effectiveness and permanence refers to the ability of a remedy to maintain reliable
protection of human health and the environment over time, once cleanup goals have been met. It
also addresses the magnitude and effectiveness of the measures that may be reguired to manage the
risk posed by treatment of residual and/or untreated wastes.

4. Reduction of toxicity, mobility, or volume through treatment is the anticipated performance of a
remedial technology, with respect to these parameters, that a remedy may employ.

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 is the technical and administrative feasibility of a remedy, including the
availability of materials and services needed.

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

The following "modifying" criteria are considered fully after the formal public comment period on the
Proposed Plan is complete:

8. State acceptance indicates whether, based on its review of the RI/FS 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.

A comparative analysis of the remedial alternatives based upon the evaluation criteria noted above follows.

Remedial Alternatives

Overall Protection of Human Health and the Environment

All of the remedial alternatives, with the exception of No Further Action and Limited Action (S-l and S-2),
would provide adeguate protection of human health by eliminating risks posed by exposure to contaminated
surface soils.

Alternative S-3, Capping, would provide engineering controls (capping) to reduce the risk of exposure to
contaminated surface soil and institutional controls (fencing, deed restrictions) to ensure cap integrity.
Ground-water monitoring would be performed to ensure the remedy is protective. This alternative would also
provide a source-control measure, since the impermeable cap would prevent rainwater from infiltrating through
the vadose zone,thereby preventing the formation of leachate and the migration of contaminants.

Alternative S-4, Excavation, Consolidation and On-site Disposal, would also provide engineering and
institutional controls. In addition, this alternative provides for the removal of contaminated soil through
excavation in the southern portion of the site, including the former Subdivision, thereby eliminating the
risk of exposure to the contaminated soil by its permanent removal from the southern portion of the site.
Alternative S-4 removes the source of contamination to the ground water in the southern portion of the site.
The impermeable cap in the Northern aspect would prevent rainwater from infiltrating through the ground,
thereby preventing the formation of leachate and the migration of contaminants.

Alternative S-5, Excavation and Off-site Disposal, would eliminate the risk of exposure to contaminated
soils, as well as being an effective source-control measure. This excavation alternative would provide a
greater degree of protection of human health and the environment than Alternatives S-3, S-4, and S-6, as the
contaminants would be removed permanently from the site. This alternative also provides the most effective
source-control measure.

-------
Alternative S-6, Excavation and On-site Low Temperature Desorption and Solidification/Stabilization, would
eliminate the risk of exposure to contaminated soils through treatment of these soils. This alternative is
also an effective source-control measure since the soils would be treated to remove the organic contaminants
and fix the inorganic compounds in the soil to prevent leachate formation and the migration of contaminants.

Compliance with ARARs

While there are no federal or New York State ARARs for organic compounds in soil, one of the remedial action
goals is to meet soil TAGM objectives. Action-specific ARARs for the site include Federal and State
regulations for treatment, temporary storage, and disposal of wastes (40 CFR Part 256-268 and 6 NYCRR Part
360). Location-specific ARARs include Executive Order 11990 on wetlands protection. "To be considered" are
the Executive Order 11988, Floodplain management and EPA's 1985 Statement of Policy on Floodplains and
Wetlands Assessments for CERCLA Actions, and the National Historic Preservation Act of 1966.

No action-specific ARARs correspond to Alternatives S-l and S-2, No Further Action and Limited Action, as no
remedial activities would be conducted at the site. TAGMs would not be reached under either
alternative.

Alternative S-3, Capping, would achieve ARARs through the capping of the site in accordance with 6 NYCRR Part
360. Alternative S-4, Excavation, Consolidation and On-site Disposal, would comply with ARARs through the
excavation of contaminated soils in the southern portion of the site, the consolidation of these excavated
soils in the Northern Aspect and the placement of a Part 360 cap over the consolidated soils.

Alternative S-5, Excavation and Off-site Disposal, would comply with ARARs through the excavation of
contaminated soils at the site. Excavated soils would be disposed of off-site at an EPA-approved licensed
facility. Any off-site transportation of hazardous wastes would be conducted in accordance with all
applicable hazardous-waste manifest and transportation reguirements. Alternative S-6 would meet ARARs through
the treatment and subseguent fixation of contaminated soils.

Long-Term Effectiveness and Permanence

Alternative S-l, No Further Action, would not provide for long-term effectiveness and permanence as
contaminants would remain in site soils with no institutional controls implemented to prevent human contact
with the wastes. Alternative S-2, Limited Action, provides marginal long-term effectiveness in that it deters
inadvertent access through the implementation of institutional controls and the placement of a fence around
the site, but does not eliminate the potential for trespassers, future residential exposure or preclude
further migration of contaminants. In addition, Alternatives S-l and S-2 do not provide for long-term
effectiveness and permanence because these alternatives leave the temporary concrete cover in place in the
Subdivision.

The degree of long-term effectiveness of Alternative S-3, Capping, and Alternative S-4, Excavation, Capping
and On-site Disposal, is dependent on the continued integrity and maintenance of the Part 360 cap. Deed
restrictions would limit the types of activities that may performed on the cap. Annual maintenance would be
performed on the cap. The cap eliminates the threat of direct contact and prevents infiltration of rainwater
through the vadose zone. Alternative S-4 will achieve long-term effectiveness and permanence in the southern
portion of the site because the contaminants, including those under the temporary concrete cover, would be
removed.

Alternative S-5, Excavation and Off-site Disposal, will achieve long-term effectiveness and permanence, since
the contaminated soil is excavated from the site and removed to an off-site facility. Alternative S-6,
Excavation and On-site Low Temperature Desorption and Solidification/Stabilization, would significantly
reduce or eliminate the leaching of contaminants to the ground water.

Long-term monitoring and maintenance would be reguired for all remedial alternatives, with the exception of
Alternative S-5, which would provide long-term effectiveness and permanence by removing the contaminants from
the site.

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Reduction in Toxicity, Mobility or Volume Through Treatment

Alternatives S-l and S-2, No Further Action and Limited Action, would not provide a reduction in the
toxicity, mobility, or volume of contaminants. These alternatives rely entirely upon biological processes.
Alternatives S-3, Capping, and S-4, Excavation, Consolidation and On-site Disposal, would reduce the mobility
of the contaminants by placing these soils under the cap, but would not reduce the toxicity or volume of the
contaminants. Alternative S-5, Excavation and Off-site Disposal, would provide for the physical removal of
the contaminated material and the maximum reduction in toxicity, mobility of contaminants, however, this
reduction is not achieved through treatment. Alternative S-6, Excavation and On-site Low Temperature
Desorption and Solidification/Stabilization, would reduce toxicity, mobility and volume of contaminants
through treatment since the organic contaminants would be eliminated through thermal destruction and the
inorganic contaminants would be chemically fixed to the soil to prevent the formation of leachate.

Short-Term Effectiveness

Alternatives S-l and S-2, No Further Action and Limited Action, would not result in any adverse short-term
impacts. Potential short-term impacts would be associated with the other alternatives due to the direct
contact with soils by workers and/or the generation of vapor and particulate air emissions. Such impacts
would be addressed through worker health and safety controls, air pollution controls such as water spraying,
dust suppressants, and tarps for covering waste during loading, transporting and waste feeding preparation.
Site and community air monitoring programs would be implemented when conducting such activities, to ensure
protection of workers and the nearby community. It is estimated that all the alternatives could be completed
as follows: Alternative S-l immediately; Alternative S-2 in 6 months; Alternative S-3 in 12 months;
Alternative S-4 in 18 months; Alternative S-5 in 12 months; and, Alternative S-6 in 18 months. These time
estimates do not include the time needed for remedial design.

Implementability

All of the alternatives are implementable from an engineering standpoint. Each alternative would utilize
commercially available products and accessible, proven technology. Each alternative is administratively
feasible. Alternatives S-3, Capping and S-4, Excavation, Consolidation and Onsite Disposal are both
implementable using proven technology. Alternative S-4 has complex administrative issues regarding
consolidation of the contaminated material on-site and the need to comply with air emission standards.
Alternative S-5, Excavation and Off-Site Disposal, is implementable. Administrative issues include the
verification of the current approved status of the off-site disposal facility. Alternative S-6, Excavation
and On-site Low Temperature Desorption and Solidification/Stabilization, is the most technically complex
alternative, however, the technologies which will be utilized have been demonstrated to be successful at
numerous other sites. This alternative would reguire a treatability study to obtain design parameters for the
full-scale system. A mobile LTTD unit needs to be brought on-site, which often has a long lead time (4-6
months).

Cost

The capital, present worth, and operation and maintenance (O&M) costs for the soil Alternatives S-l to S-5
are summarized in Table 5. Alternative S-3, Capping, has a present worth cost of $12,454,000 that includes an
annual O&M cost associated with maintenance of the cap. Alternative S-4, Excavation and On-site Disposal,
has a present worth cost of $16,397,000. Alternative S-5, Excavation and Off-site Disposal, is substantially
more expensive with a present worth cost of $106,350,400, due to the high capital cost of excavation and
off-site disposal. Alternative S-6, Excavation and On-site Low Temperature Desorption and
Solidification/Stabilization, is also substantially more expensive with a present worth cost of $81,986,000,
due to the high cost of treatment.

State Acceptance

After review of all available information the NYSDEC has indicated that it concurs with the selected
alternative for OU2. NYSDEC's letter of concurrence is presented in Appendix IV of this document.

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       Community Acceptance

Community acceptance of the preferred alternative for OU2 has been assessed in the Responsiveness Summary
portion of this ROD following review of the public comments received on the RI/FS report and Proposed Plan.
All comments submitted during the public comment period were evaluated and are addressed in the attached
Responsiveness Summary (Appendix VI).

SEIiECTED REMEDY

EPA has determined, upon consideration of the reguirements of CERCLA, the detailed analysis of the various
alternatives, and public comments, that Alternative S-4  (see Figure 3)  is the appropriate remedy for the
contaminated soil and sediment at the site.

The major components of the selected remedy are as follows:

•      Excavation of contaminated soils from the southern portion of the site,  and contaminated sediment from
       East Gill Creek,  and consolidation of these materials in the northern portion of the site,  followed by
       grading in preparation for placement of the cap.

•      Confirmatory sampling of the bottom and sidewalls of the excavation to ensure cleanup goals have been
       met,  followed by backfilling with clean fill overlain with a six-inch layer of clean topsoil and grass
       cover.

•      Construction of an approximately 8.5-acre cap over the consolidated soils in the northern portion of
       the site in conformance with the major elements described in 6 New York Code of Rules and Regualtions
       Part 360 for solid waste landfill caps. Conceptually, the cap will be comprised of:        18 inches of
       clay or a suitable material to  ensure a permeability of 10-7 cm/sec,  six inches of porous material
       serving as a drainage layer,  18 inches of backfill, and six inches of topsoil and grass cover.

•      Implementation of a long-term inspection and,  maintenance program to ensure cap integrity.

•      Removal and off-site disposal of the vacant trailers and two permanent homes to facilitate the
       excavation of soils.

•      Taking measures to secure institutional controls in the form of deed restrictions to limit future
       activities in the Northern Aspect and fencing to limit future access to the capped area.

•      Capping the Wooded Wetland with six inches of clean sediment. If further studies conclude that  the
       addition of six inches of clean sediment would have an adverse impact on the wetland, contamination in
       the Wooded Wetland would be excavated and it would be appropriately restored.

•      Performance of a wetlands assessment and mitigation plan during the remedial design phase in order to
       minimize potential adverse impacts to the wetland and to replace any wetlands lost due to the
       remediation.

•      Compliance with all ARARs, including the location-specific ARARs identified in this ROD. This will
       include the performance of a Stage IB cultural resources survey and a floodplain assessment.

The goal of the remedial action is to contain the source area and to prevent further migration of
contaminants to the ground water to the extent practicable. Based on information obtained during the
investigation, and the analysis of the alternatives,  the selected alternatives will provide the best balance
of trade-offs among alternatives with respect to the evaluating criteria. EPA and NYSDEC believe that  the
selected alternative will be protective of human health and the environment, will comply with ARARs, will be
cost-effective, and will reduce mobility of contaminants permanently by utilizing permanent solutions  and
alternative treatment technologies or resource recovery technologies to the maximum extent practicable.

Selected Alterative: Excavation, Consolidation & On-Site Disposal

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Capital Cost: $ 15,357,836

Annual O&M Costs: $ 34,334

Present Worth Cost: $ 16,397,000

STATUTORY DETERMINATIONS

Under its legal authorities, EPA's primary responsibility at Superfund sites is to undertake remedial actions
that are protective of human health and the environment. In addition, Section 121 of CERCLA establishes
several other statutory requirements and preferences. These specify that when complete the selected
remedial action for this site must comply with applicable, or relevant and appropriate environmental
standards established under Federal and State environmental laws unless a statutory waiver is justified. The
selected remedy also must be cost-effective and utilize permanent solutions and alternative treatment
technologies or resource-recovery technologies to the maximum extent practicable. Finally, the statute
includes a preference for remedies that employ treatment that permanently and significantly reduce the
volume, toxicity, or mobility of hazardous substances, as available. The following sections discuss how the
selected remedy meets these statutory requirements.

Protection of Human Health and the Environment

The selected remedy is protective of human health and the environment. The excavation of contaminated soils
in southern portion of the site and the consolidation of these soils in the Northern Aspect will provide
protection of both human health and the environment for these areas by preventing human contact with the
contaminated soils and leaching of contaminants to ground water.

Capping of the consolidated soils in the Northern Aspect is expected to be effective in preventing human
contact with the contaminated soils. Contaminants will remain in soils, however, the cap would eliminate or
reduce infiltration of precipitation, thereby minimizing the potential for migration of contaminants to
ground water. The institutional controls will help protect human health by preventing access to the
contamination and future exposure of individuals to it.

The long-term monitoring of the ground water will assess the effectiveness of the remedy, ensuring that the
cap remains protective of human health and the environment.

Compliance with ARARs

Action-specific ARARs for the site include Federal and State regulations for treatment, temporary storage,
and disposal of wastes (40 CFR Part 256-268 and 6 NYCRR Part 360). Location-specific ARARs for the site
include Executive Order 11990 on wetlands protection. "To be considered" are the Executive Order 11988,
"Floodplain Management" and EPA's 1985 Statement of "Policy on Floodplains and Wetlands Assessments for
CERCLA Actions" The selected remedy will comply with these standards through capping of the consolidated
contaminated soils in the Northern Aspect. A wetlands assessment will be performed during the remedial design
and a mitigation plan will be developed to address any adverse impacts on the wetlands that may be caused by
the remedial action.

Cost-Effectiveness

Each of the alternatives underwent a detailed cost analysis. In that analysis, capital costs and O&M costs
have been estimated and used to develop present worth costs. In the present-worth cost analysis, annual costs
were calculated for 30 years (estimated life of an alternative) using a five percent discount rate and based
on 1997 costs. The selected alternative has the lowest cost that will achieve the goals of the response
actions.

Alternatives S-l and S-2 are less expensive, but are not deemed to be protective. Alternative S-3, Capping,
is deemed to be protective of human health and the environment, however, this alternative is not suitable for

-------
a residential-use scenario because it effectively eliminates that use. The selected remedy,    Alternative
S-4, is cost-effective because it will provide the best overall effectiveness proportional to its cost.

Utilization of Permanent Solutions and Alternative Treatment Technologies to the Maximum Extent Practicable

By excavating the contaminated soils in the southern portion of the site, consolidating these soils in the
Northern Aspect, placing a cap over these consolidated soils and implementing a long-term groundwater
monitoring program,  the selected remedy utilizes permanent solutions and treatment technologies to the
maximum extent practicable.

Overall, the selected remedy  (Alternative S-4) is considered to include the most appropriate solutions to
contamination at the site because it provides the best balance of trade-offs among the alternatives with
respect to the nine evaluative criteria.

Preference for Treatment as a Principal Element

The statutory preference for remedies that employ treatment as a principal element is not satisfied by the
selected remedy. However, the selected remedy is nevertheless protective of human health and the environment.

DOCUMENTATION OF SIGNIFICANT CHANGES

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

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                                  APIENDIX I

                                   FIGURES

    Figure 1 - Site Location Map
    Figure 2 - Site Map
    Figure 3 - Extent of Cap - Alternative S-4

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                               APPENDIX II

                                 TABIiES

Table 1 -   Targeted Organic Compounds
Table 2 -   Contaminants of Concern
Table 3 -   Summary of Previous Analytical Data
Table 4 -   NYSDEC TAGMs - Soil Cleanup Objectives
Table 5 -   Cost Comparison of Soil Remedial Alternatives

See Appendix V,  Summary of Risk Assessment for the following:

Table 6 -   Summary Information on Chemicals of Concern
Table 7 -   Carcinogenic Toxicity Characteristics of Chemicals of Concern
Table 8 -   Non-Carcinogenic Information for Chemicals of Concern
Table 9 -   Summary of Carcinogenic Risk for Chemicals Triggering the Need for Cleanup
Table 10-   Risk Characterization Summary - Noncarcinogens
Table 11-   Summary of Total Risk Based on Exceedances of Risk Range

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          TABIiE 1
 TARGETED ORGANIC COMPOUNDS

          Aniline
   Phenyl Isothiocyanate
       Diphenylamine
   2-Mercaptobenzothiazole
   2-Anilinobenzothiazole
          Perylene
N,N-Diphenyl-l,4-Benzenediamine
       Phenothiazine
       Benzothiazole

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TABIiE 2 - CONTAMINANTS OF CONCERN
BERM - SUBSURFACE SOIL
 COGS
Range of Detection
                                                         Frequency
                                                         of Detection
Screening
Criteria
Frequency of
Exceedance
  AOC 1
Highest
Location
TARGETED ORGANIC
COMPOUNDS (Ig/kg)

Benzothiazole
Diphenylamine
2-Mercaptobenzothiazole
2-Anilinobenzothiazole
N,N'-Diphenyl-1,4-benzenediamine
Perylene
Phenothiazine
Phenyl Isothiocyanate

SEMIVOLATILE ORGANIC
COMPOUNDS (Ig/kg)

Benzo(a)pyrene
Benzo(b)fluoranthene
Benzo(k)fluoranthene
Benzo(a)anthracene
Phenol
2-Methyl phenol
410 - 150,000 D
400 - 11,000 J
270 J - 1,100,000 DJ
90 J - 960,000 D
18,000 JD - 210,000 D
1,400 J - 3,800 J
60 J - 4, 600 J
1,100 J
4/7
4/7
5/7
5/7
4/7
3/7
4/7
1/6
NS
NS
NS
NS
NS
NS
NS
NS
NA
NA
NA
NA
NA
NA
NA
NA
                                    TAGMs
210 J
55 JX
55 JX
200 -
330 J
120 J
- 3,800 J
- 10,000 J
- 11,000 J
6,600 J
- 9,700 J
- 980 J
4/7
5/7
5/7
4/7
5/7
2/7
61
1,100
1,100
224
30
100
4/4
3/5
3/5
3/4
5/5
1/2
                             2A
                             2A
                             2A
                             2A
                             2A
                             2A
                             2A
                             2A

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TABIiE 2 - CONTAMINANTS OF CONCERN
BERM - SUBSURFACE SOIL
 COGS
INORGANICS  (mg/kg)

Cobalt
Nickel
Arsenic
Chromium
Mercury
Lead
Copper
Vanadium
Range of Detection
15.3 - 30.7
29.6 - 47.9
2.3 B - 15.8
21.4 - 120
0.19 - 13.5
8.6 - 73.6
25 - 185
28.1 J - 38.7
Frequency
of Detection
7/7
7/7
7/7
7/7
4/7
7/7
7/7
7/7
Screening
Criteria*
14.84
28.36
05.52
27.6
00.1**
37.16
41.6
35.4
Frequency of
Exceedance
7/7
7/7
5/7
5/7
4/4
4/7
3/7
3/7
NS   No Standard
J    Estimated Value
B    
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TABIiE 2 - CONTAMINANTS OF CONCERN
NORTHERN ASPECT - SURFACE SOIL
COGS
                             AOC 2
Range of Detection   Frequency     Screening   Frequency of  Highest
                     of Detection  Criteria    Exceedance    Location
TARGETED ORGANIC
COMPOUNDS (Ig/kg)

Perylene
2-Anilinobenzothiazole
50 J - 100 J
80 J
2/18
1/18
                                                                       NS
                                                                       NS
NA
NA
SS01
DP029
                                    27 - 260 J
                                    25 J - 50 J
                     4/18
                     2/18
             61
             14
SEMIVOLATILE ORGANIC
COMPOUNDS  (Ig/kg)

Benzo(a)pyrene
Dibenzo(a,h)anthracene

INORGANICS  (mg/kg)

Barium
Beryllium
Mercury
Nickel
NS   No Standard
J    Estimated Value
B    
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TABIiE 2 - CONTAMINANTS OF CONCERN
NORTHERN ASPECT - SUBSURFACE SOIL
COGS

TARGETED ORGANIC
COMPOUNDS  (Ig/kg)

Perylene
2-Anilinobenzothiazole
Diphenylamine
2-Mercaptobenzothiazole
Aniline
Phenothiazine
Benzothiazole

SEMIVOLATILE ORGANIC
COMPOUNDS  (Ig/kg)

Dibenzo(a,h)anthracene
Benzo(a)pyrene
Benzo(a)anthracene
Phenol
Benzo(b)fluoranthene
Chrysene
Benzo(k)fluoranthene
 Range of Detection
130 J - 450 J
130 J - 27,000 D
320 - 330 J
3,200 J - 24,000 JD
260 J - 280
270 J - 470
2,200 - 3,200
26 J - 330 J
78 J - 2,600
91 J - 7,700 D
57 J - 200 J
150 J - 12,000 D
87 J - 2,700
75 J - 12,000 D

Freguency
of Detection
3/26
3/26
2/26
2/26
2/26
2/26
2/26

2/25
5/26
5/26
2/25
5/26
5/26
5/26

Screening
Criteria
NS
NS
NS
NS
NS
NS
NS
TAGMs
14
61
224
30
1,100
400
1,100

Freguency of
Exceedance
NA
NA
NA
NA
NA
NA
NA

2/2
5/5
2/5
2/2
1/5
1/5
1/5
AOC 2
Highest
Location
TPEXP
TP09
TPEXP
TP09
TP09
TP09
TPEXP

TPEXP
TPEXP
TPEXP
TP01
TPEXP
TPEXP
TPEXP
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TABIiE 2 - CONTAMINANTS OF CONCERN
NORTHERN ASPECT - SUBSURFACE SOIL

COGS

INORGANICS  (mg/kg)

Arsenic
Chromium
Nickel
Mercury
Vanadium
Selenium
Range of Detection
2 BJ - 9.4
6.2 - 34.7
8.3 B - 55.5
0.07 B - 2.8
10 B - 70.4
1.4 J - 2.6
Frequency
of Detection
25/26
15/15
26/26
4/26
26/26
11/26
Screening
Criteria*
5.2
27.6
28.36
0.1**
35.4
2**
Freqi
Excei
7/25
5/15
10/26
3/4**
8/26
5/11
NS   No Standard
J    Estimated Value
B    
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TABIiE 2 - CONTAMINANTS OF CONCERN
WOODED WETLAND - SEDIMENT

COGS
                               Range of Detection
                                                         Frequency
                                                         of Detection
                      AOC
              Screening
              Criteria
Frequency of
Exceedance
Background
Highest
Location
TARGETED ORGANIC
COMPOUNDS  (Ig/kg)

Perylene

SEMIVOLATILE, ORGANIC
COMPOUNDS  (Ig/kg)

Fluoranthene
Pyrene
Benzo(a)anthracene
Chrysene
Benzo(b)fluoranthene
Benzo(k)fluoranthene
Indeno(1,2,3-CD)pyrene
Dibenzo(a,h)anthracene
Benzo(g,h,i)perylene
Benzo(a)pyrene
S
J
B
D
X
*
                               120 J - 250 J
10/10
                                                                   NS
                                                                                NA
                                                                                                110  J
No Standard
Estimated Value
-------
TABIiE 2 - CONTAMINANTS OF CONCERN
WOODED WETLAND - SEDIMENT

COGS
 Range of Detection
                                                         Freq. of
                                                         Detection
Screening
Criteria*
Freg. of
Exceedance
Background
AOC 3
 High Loc.
PESTICIDES/PCBs  (Ig/kg)

Alpha-BHC
4,4'-DDE
Aroclorl254
Beta-BHC
0.47 NJ - 5.5 J
1.2 J - 12 J
68 J - 110 J
2.1 J - 8.1 NJ
10/10
8/9
5/7
2/4
NS
10
0.8
NS
6
5
60
5
NA
10
0.8
NA
6
5
60
5
ND
8.65
ND
ND
03
03
02,
03


06,08

INORGANICS  (mg/kg)

Arsenic
Cadmium
Chromium
Copper
Lead
Mercury
Nickel
Silver
Zinc
4.6 -
1.1 B
36.7 -
29.2 -
84.8 -
0.55 -
30.5 -
1.2 B
214 -
7.7
- 1.5 B
53.5
51.9 J
114
1.5
39.2
- 2 B
374 NJ
10/10
7/10
10/10
10/10
10/10
10/10
10/10
4/10
10/10
6
0.6
26
16
31
.15
16
1
3.1
                                          NS
Screening Criteria: DEC / Ontario
N    For organic - uncertainty in ID; for inorganic - spike sample recovery not w/in limits
12.5
1.16 B
349
75.6
155.6
1.42
61.4
ND
292
06
08
07
07
06
09
03
03
05
-------
TABLE 2 - CONTAMINANTS OF CONCERN
SUBDIVISION - SURFACE SOIL

COGS
 Range of Detection
                                                         Frequency
                                                         of Detection
Screening
Criteria
Frequency of
Exceedance
AOC 6
 Highest
 Location
TARGETED ORGANIC
COMPOUNDS (Ig/kg)

2-Anilinobenzothiazole
2-Mercaptobenzothiazole
Benzothiazole
Perylene
N,N'-Diphenyl-1,4-benzenediamine
Diphenylamine
Phenothiazine
Phenyl Isothiocyanate
90 J - 330,000
120 J - 47,000
120 J - 10,000 DJ
40 J - 650 J
110 J - 13,000 DJ
40 J - 1,600
80 J - 3,800 J
100 J - 130 J
D
DJ
DJ

DJ



16/18
14/18
13/18
13/18
12/18
9/18
7/18
2/18
NS
NS
NS
NS
NS
NS
NS
NS
NA
NA
NA
NA
NA
NA
NA
NA
                           SS05
                           SS10
                           SS10
                           SS17
                           SS18
                           SS05
                           SS05
                           SS05
SEMIVOLATILE ORGANIC
COMPOUNDS (Ig/kg)

Benzo(a)pyrene
Benzo(a)anthracene
Chrysene
Benzo(b)fluoranthene
Benzo(k)fluoranthene
Dibenzo(a,h)anthracene
100 J - 2,500
130 J - 2,900
25 J - 2,400
220 J - 7,200 D
220 - 6,900 D
74 J - 530
                                  TAGMs
15/18
15/18
16/18
15/18
15/18
5/18
61
224
400
1,100
1,000
14
15/15
12/18
9/16
5/15
4/15
5/5
SS17
SS17
SS17
SS17
SS17
DP013
-------
TABIiE 2 - CONTAMINANTS OF CONCERN
SUBDIVISION - SURFACE SOIL
                                                                                                    AOC 6
SEMIVOLATTLE ORGANIC
COMPOUNDS  (Ig/kg)
Phenol
2-Methyl phenol

SUBDIVISION- SURFACE SOIL

COGS

INORGANICS  (mg/kg)

Copper
Cobalt
Mercury
Beryllium
NS
J
B
D
N
*
**
                             85 J - 7,800 J
                             60 J - 360
                               Range of Detection
                               4.3* B - 387* B
                               1.1 B - 193
                               0.11 NJ - 5.7 J
                               0.08 B - 0.97 B
 9/18
 4/18
TAGMs
30
100
9/9
3/4
SS10
SS06
Freguency
of Detection
18/18
17/18
12/14
15/18
 Screening
 Criteria*
  40.26
  21.52
  0.58**
  10.68
 Freguency of
 Exceedance
 9/18
 6/17
 5/12**
 17/15
   AOC 6

  Highest
  Location
  SS06
  SS06
  DP033
  SS12
No Standard
Estimated Value
-------
TABIiE 2 - CONTAMINANTS OF CONCERN
SUBDIVISION - SUBSURFACE SOIL

COGS
Range of Detection
           AOC 6
Frequency     Screening
of Detection  Criteria
                                                                                     Frequency of
                                                                                     Exceedance
                           Highest Location
VOLATILE ORGANIC
COMPOUNDS  (Ig/kg)

Total Xylenes

TARGETED ORGANIC
COMPOUNDS  (Ig/kg)

Perylene,
N,N'-Diphenyl-1,4-benzenediamine
Benzothiazole
Diphenylamine
2-Mercaptobenzothiazole
2-Anilinobenzothiazole
Phenothiazine
Aniline

SEMIVOLATILE ORGANIC
COMPOUNDS  (Ig/kg)

Benzo(a)pyrene
Benzo(a)anthracene
Chrysene
Benzo(b)fluoranthene
2 J - 10,000 J
 3/18
60 J -
40 J -
100 J
800 -
200 J
1,000
800
400
320 J
460 -
530 -
340 J
8,000
25,000 D
- 16,000 D
8,000 DJ
- 50,000 DJ
- 170,000 D


- 170,000
250,000 J
160,000
- 220,000
6/26
5/26
3/26
2/26
2/26
2/26
2/26
1/26
4/26
4/26
4/26
4/26
1,200
                                  TAGMs

                                   61
                                   224
                                   400
                                   1,100
1/3
6/26
5/26
3/26
2/26
2/26
2/26
2/26
1/26
NS
NS
NS
NS
NS
NS
NS
NS
NA
NA
NA
NA
NA
NA
NA
NA
                           4/4
                           4/4
                           4/4
                           3/4
                                                                DP034B
                                                                DP013B
                                                                DP018B
                                                                DP018B
                                                                DP018B
                                                                DP018B
                                                                DP018B
                                                                DP018B+33
                                                                DP033
                            DP013B
                            DP013B
                            DP013B
                            DP013B
-------
TABIiE 2 - CONTAMINANTS OF CONCERN
SUBDIVISION - SUBSURFACE SOIL

Dibenzo(a,h)anthracene
Phenol

SUBDIVISION-SUBSURFACE SOIL

COGS
INORGANICS  (mg/kg)

Nickel
Chromium
Vanadium
Arsenic
Mercury
NS
J
B
D
N
*
**
                               8,600 D - 8,700 J    2/26
                               250 J - 7,500        2/26
             14
             30
                               Range of Detection
                               0.02 - 132
                               0.02 - 46.6
                               0.03 - 147
                               2.5 - 14.6
                               0.13 NJ - 25.6 NJ
Frequency     Screening
of Detection  Criteria*
2/2
2/2
                                                                                    Frequency of
                                                                                    Exceedance
No Standard
Estimated Value
-------
TABIiE 2 - CONTAMINANTS OF CONCERN
EDGEWOOD DRIVE LOTS - SURFACE SOIL
                                                                                                    AOC 5
COGS
Range of Detection
Frequency     Screening    Frequency of   Highest
of Detection  Criteria     Exceedance     Location
TARGETED ORGANIC
COMPOUNDS (Ig/kg)

Perylene
2-Mercaptobenzothiazole
2-Anilinobenzothiazole
Diphenylamine
N,N'-Diphenyl-1,4-benzenediamine
Benzothiazole
5 - 12,000
570 J - 1,800 J
1,300 J - 2,100
50 J
2,800 J
260 J
8/16
2/16
2/16
1/16
1/16
1/16
NS
NS
NS
NS
NS
NS
NA
NA
NA
NA
NA
NA
                                         SB14-SS
                                         SB04-SS
                                         SB14-SS
                                         SB07-SS
                                         SB07-SS
                                         SB07-SS
SEMIVOLATILE ORGANIC
COMPOUNDS (Ig/kg)

Chrysene
Benzo(a)anthracene
Benzo(b)fluoranthene
Benzo(k)fluoranthene
Benzo(a)pyrene
Dibenzo(a,h)anthracene
Indeno(1,2,3-cd)pyrene
Fluoranthene
                                   TAGMs
40 J - 95,000 DJ
54 J - 100,000 D
100 J - 130,000 DJ
98 J - 120,000 DJ
47 J - 88,000 DJ
68 J - 16,000 DJ
240 J - 25,000 DJ
56 J - 130,000 D
10/16
8/16
8/16
8/16
816
6/16
7/16
9/16
400
224
1,100
1,100
61
14
3,200
50,00
7/10
7/8
6/8
6/8
7/8
6/6
4/7
3/9
SB07-SS
SB07-SS
SB07-SS
SB07-SS
SB07-SS
SB07-SS
SB07-SS
SB07-SS
-------
TABIiE 2 - CONTAMINANTS OF CONCERN
EDGEWOOD DRIVE LOTS- SURFACE SOIL
COGS
INORGANICS  (mg/kg)

Nickel
Mercury
Lead
Arsenic
Beryllium
Vanadium
 Range of Detection
23.6 J - 139
0.07 B - 2.5
8.7 - 157 NJ
4.6 - 21.3
0.29 - 1.5 B
32.30 J - 125
AOC 5
Frequency
of Detection
16/16
9/16
16/16
16/16
16/16
16/16

Screening
Criteria*
27.68
0.58**
106.8
9.2
0.68
50.8

Frequency of
Exceedance
14/16
3/16**
5/16
6/16
6/16
6/16
NS   No Standard
J    Estimated Value
B    
-------
TABIiE 2 - CONTAMINANTS OF CONCERN
EDGEWOOD DRIVE LOTS - SUBSURFACE SOIL
COGS
                               Range of Detection
  AOC 5
 Frequency
 of Detection
Screening
Criteria
                                                                                    Frequency of
                                                                                    Exceedance
              Highest Location
TARGETED ORGANIC
COMPOUNDS (Ig/kg)

Perylene
                               0.08 J - 6,800 J
 3/14
                                                                   NS
                                                                                NA
                                                                                               SBCENTER
SEMIVOLATILE ORGANIC
COMPOUNDS (Ig/kg)

Benzo(b)fluoranthene
Benzo(K)fluoranthene
Benzo(a)anthracene
Chrysene
Benzo(a)pyrene
NS
J
B
D
N
*
                               87 XJ - 98,000 D
                               85 XJ - 79,000 D
                               53 J - 56,000 D
                               56 J - 50,000 D
                               40 J - 42,000 D
TAGMs

 6/14
 6/14
 5/14
 5/14
 5/14
1,100
1,100
224
400
61
2/6
2/6
2/5
2/5
3/5
SBCENTER
SBCENTER
SBCENTER
SBCENTER
SBCENTER
No Standard
Estimated Value
-------
TABIiE 2 - CONTAMINANTS OF CONCERN
EDGEWOOD DRIVE LOTS - SUBSURFACE SOIL
COGS
INORGANICS  (mg/kg)

Nickel
Mercury
Cobalt
Chromium
Beryllium
Barium
Lead
Range of Detection
8.5 B - 69.4
0.14 - 3.2
4.3 B - 16.8 J
6.6-54.4
0.44 B - 1.7
34.7 B 182
6.3 - 114 N*J
Freguency
of Detection
14/14
5/14
14/14
14/14
14/14
14/14
14/14
Screening
Criteria
28.36
0.1**
14.84
27.6
0.84
163.44
37.16
Freguency of
Exceedance
9/14
5/5**
5/14
4/14
5/14
4/14
2/14
                                                                                                           AOC  5
Highest Location
SBCENTER
SBCENTER
SB14A
SB14A
SB13
SB13
SBCENTER
NS   No Standard
J    Estimated Value
B    
-------
EAST GILL CREEK SEDIMENTS - ROUND 1
                                                                                                 AOC  4
COGS

TARGETED ORGANIC
COMPOUNDS  (Ig/kg)

2-Mercaptobenzothiazole
2-Anilinobenzothiazole
Perylene
N,N'-Diphenyl-l,4-
benzenediamine

Benzothiazole

SEMIVOLATILE ORGANIC
COMPOUNDS  (Ig/kg)

Anthracene
Dibenzo(a,h)anthracene
Phenanthrene
Benzo(a)anthracene
Range of Detection
2,000 J
800 J - 6,000 J
200J
300J
400
350J
62 J - 360 J
140 J - 1,200
140 J - 1,000
Freguency Screening
of Detection Criteria
1/3
2/3
1/3
1/3
1/3

1/3
3/3
3/3
3/3
NS
NS
NS
NS
NS
DEC.
NS
NS
NS
1300


ONT
220
60
560
320
Background     Freguency of   Highest
               Exceedance     Location
NS   No Standard
J    Estimated Value
B    
-------
TABIiE 2 - CONTAMINANTS OF CONCERN
EAST GILL CREEK SEDIMENTS - ROUND 1
COGS
INORGANICS  (mg/kg)

Arsenic
Cadmium
Chromium
Copper
Lead
Manganese
Mercury
Nickel
Zinc
Range of Detection
5.9 J - 6.3 J
3.6 - 4.4
40.3 J - 62.7 J
33.2 J - 35.3 J
52.9 - 61.7 J
375 EJ - 877 EJ
0.29 NJ - 0.4 NJ
25.9 J
379 - 497 J
Frequency
of Detection
3/3
3/3
3/3
3/3
3/3
3/3
3/3
1/1
3/3
Screening
Criteria*
6
0.6
26
16
31
460
.15 .2
16
120
Frequency of
Exceedance
2/3
3/3
3/3
3/3
3/3
2/3
3/3
1/1
3/3
Background

5.5 BJ
6.4 J
122 J
64.1 J
134 J
386 EJ
0.67 NJ
R
1240 J
Hi'
Lo
D4
D3
D2
D2
D2
D4
D2
D2
D2
NS   No Standard
J    Estimated Value
B    
-------
TABIiE 2 - CONTAMINANTS OF CONCERN

EAST GILL CREEK SEDIMENTS - ROUND 2

COGS
                                                                        AOC 4
 Range of Detection   Frequency     Screening    Frequency of  Background Highest
                      of Detection  Criteria*    Exceedance               Location
TARGETED ORGANIC
COMPOUNDS (Ig/kg)

Diphenylamine
2-Mercaptobenzotbiazole
2-Anilinobenzothiazole
Perylene
N,N'-Diphenyl-l, 4-
benzenediamine
Phenothiazine
Benzothiazole

SEMIVOLATILE ORGANIC
COMPOUNDS (Ig/kg)

Chrysene
Benzo(a)anthracene
Benzo(g,h,i)perylene
150 J - 3,000
3,600 J
90 J - 19,000 D
160 J - 850
1,000 J - 81,000 J

430
140 J - 1,500
260 J - 790
470 J - 500 J
30 J - 3,400 J
2/4
1/4
4/4
3/4
2/4
1/4
2/4
NS
NS
NS
NS
NS
NS
NS
4/4
2/4
4/4
                                   DEC
NS   No Standard
J    Estimated Value
B    
-------
TABIiE 2 - CONTAMINANTS OF CONCERN

EAST GILL CREEK SEDIMENTS - ROUND 2                                                                         AOC 4

COGS                                Range of Detection   Frequency     Screening    Frequency of  Background Highest
                                                         of Detection  Criteria*    Exceedance               Location

INORGANICS  (mg/kg)

Arsenic
Chromium
Copper
Lead
Manganese
Mercury
Nickel
Zinc

NS   No Standard
J    Estimated Value
B    
-------
TABIiE 2 - CONTAMINANTS OF CONCERN
EAST GILL SURFACE WATER - ROUND 1
                                                                                                              AOC  4
COGS
PESTICIDES/PCBs  (Ig/1)

Alpha-BHC
Beta-BHC

INORGANICS  (Ig/1)

Aluminum
Cobalt
Iron
Selenium
Vanadium
Zinc
Copper
Lead
Range of Detection
150 J - 3,000
3,600 J
4380 - 72,500
15.6 B - 44.5 B
4,810 EJ - 90,700 EJ
4.2 B
11.3 BE - 130 EJ
11.3 - 1,820
10.7 BE - 130 EJ
7.8 J - 190
Freguency
of Detection
3/3
3/3
3/3
2/3
3/2
1/3
3/3
3/3
3/3
3/3
Screening
Criteria*
0.01*
0.01*
100
5
300
1
14
30
54.1
30.6
Freguency of  Background Highest
Exceedance               Location
NS   No Standard
J    Estimated Value
B    
-------
TABIiE 2 - CONTAMINANTS OF CONCERN

EAST GILL SURFACE WATER - ROUND 2
                                                                                                  AOC 4
                         0.06 J - 0.11 J
4/4
                                                             0.01*
4/4
COGS                     Range of Detection   Frequency     Screening
                                              of Detection  Criteria

PESTICIDES/PCBs  (Ig/1)

Beta-BHC

INORGANICS  (Ig/1)

Aluminum

Iron

Selenium

Zinc

Cyanide

NS   No Standard
J    Estimated Value
B     instrument detection limit
D    Diluted Value
*    Inorganic Screening Criteria 2X background
**   TAGM used since ND in background
                                                                         Frequency of   Background   Highest
                                                                         Exceedance                  Location
                                                                                        ND
                                                                                                     GCSW2
205 -
347 -
8.1 -
42 -
12 -
1, 650
2,710
9.1
79
13.6
4/4
4/4
4/4
4/4
2/4
100
300
1
30
5.2
4/4
4/4
4/4
4/4
2/2
291
492
8.4
54
10.3
GCSW4
GCSW4
GCSW6
GCSW4
GCSW6
-------
           TAKLE 2 -- CONTAMINANTS OF CONCERN -- GROUND WATER -- ROUND 1
Targeted Organic
Compounds  (Ig/1)

Benzothiazole

Volatile Organic
Compounds  (Ig/1)

Vinyl Chloride

1,1-Dichloroethane

Trichloroethene

Xylenes

1,2-Dichloroethene  (total)

Benzene

Semivolatile Organic
Compounds  (Ig/1)

Pentachlorophenol

Hexachlorobutadiene

Phenol

2-Chlorophenol

4-Chloro-3-methylphenol

4-Nitrophenol

Pyrene

Inorganics (Ig/1)


Chromium

Iron

Lead

Managanese

Nickel
Range of
Detection
1 (J)

3 (J) - 16
3 (J) - 8 (J)
1 (J) - 8 (J)
3 (J) - 8 (J)
1 (J) - 130
1 (J) - 2 (J)
6 (J)
10 (J)
4 (J) - 8 (J)
10 (J)
10 (J)
10 (J)
6 (J)
4.3 (J)- 749 (J)
417 - 32,500
2.2 (BJ) - 105
17.5- 6,790 (J)
9.3 (B)- 725(J)
Freg. of MCLs
Detection
2/20

3/20
3/20
3/20
6/20
7/20
4/20
1/18
1/18
2/18
1/18
1/18
1/18
1/18
20/20
20/20
17/20
20/20
20/20
NS

2
NS
5
10,000
NS
5
1
NS
NS
NS
NS
NS
NS
100
NS
15
0
100
DEC
GW
NS

2
5
5
5
5
0.7
1
5
1
5
5
5
5
50
300*
25
300*
NS
DOH
DW
NS
2
5
5
5
5
5
5
1
5
NS
NS
NS
NS
NS
100
NS
50
NS
NS
HIGH
MW
4S

5S
5D
5S
9D
5S
3D,9D
6D
6D
6D
6D
6D
6D
6D
30B
4S
4S
3PW
30B
  NS = No Standard
  * Fe + Mg = 500
-------
              TABLE 2 -- CONTAMINANTS OF CONCERN — GROUND WATER  — ROUND  2
Volatile Organic
Compounds (Ig/1)
Vinyl Chloride
1, 1-Dichloroethane
Trichloroethene
1, 2-Dichloroethene (total)
1,1, 1-Trichloroethane
Semivolatile Organic
Compounds (Ig/1)
Benzo (a) pyrene
Di-n-octylph that ate
Inorganics (Ig/1)
Chromium
Iron
Lead
Managanese
Nickel
Range of
Detection
44 (J) - 220
2(J) - 70 (J)
2(J) - 76 (J)
1(J) - 130
12 (J) - 65 (J)

0.7(J)
0.7(J) - 10

11-488
182-19,300
3.1 - 37.5
35 - 1,330
59 - 125
Freg. of MCLs
Detection
3/20 2
3/20 NS
3/20 5
4/20 NS
2/20

1/20 0.2
5/20 NS

10/20 100
20/20 NS
11/20 15
18/20 0
3/20 100
DEC
GW
2
5
5
5


5
5

50
300*
25
300*
NS
DOH
DW
5
5
5
5


NS
NS

100
NS
50
NS
NS
HIGH
MW
5S
5S
5S
5S
5S

3PW
5S

4S
4S
4S
3PW
4D
NS = No Standard
* Fe + Mg = 500
-------
                                     Table 3
                     SUMMARY OF PREVIOUS EPA ANALYTICAL RESULTS
                           FOREST GLEN SUBDIVISION SITE
          COMPOUND
Benzothiazole

2(3H)Benzothiazole

2(3H)Benzothiazolethione

Aniline

Phenothiazine

Perylene

Diphenylamine

2-Mercaptobenzothiazole

Benzo(a)pyrene

Chrysene

Benzo(a)anthracene

Benzo(b)fluoranthene

Benzo(k)fluoranthene

Dibenzo(a,h)anthracene

Indeno(1,2,3-CD)pyrene

Phenol

2-Mmethylphenol
RANGE OF DETECTION
     (Ig/kg)

  8 - 44,000,000

  20 - 2,600,000

     4,600,000

 3.2 - 11,000,000

 700 - 5,550,000

  30 - 1,770

   5 - 8,300,000

  24 - 35,000,000

   30 - 88,000

   30 - 110,000

   28 - 110,000

   55 - 160,000

   42 - 60,000

   608 - 21,000

    28 - 54,000

    610 - 34,742

     84 - 3,026
     LOCATION OF HIGHEST
          DETECTION

SW1  S of Carrie Drive   5/89

S2   Carrie Dr.          8/87

S2

SW1

DR1  N. Aspect drum frag. 4/89

S90  E. End Carrie Dr.

SW1

SW1

S4   S Wooded Lot         8/87

S4

S4

S4

S31  S Wooded Lot         9/88

S4

S4

S20  N of Lisa Lane cul de sac

S20                       4/89
-------
                                        TABIiE 4
              NEW YORK STATE DEPARTMENT OF ENVIRONMENTAL CONSERVATION
                             TAGMs - SOIL CLEANUP OBJECTIVES

                               TARGETED ORGANIC COMPOUNDS

       Contaminants of Concern              NYSDEC TAGM 4046 Cleanup Goal  (ppm)

              Aniline                                     0.10

       2-Anilinobenzothiazole                              TBD

      2-Mercaptobenzothiazole                             0.85*

           Phenothiazine                                  0.85*

           Benzothiazole                                  0.85*

        Phenyl Isothiocyanate                              TBD

           Diphenylamine                                  0.85*

            Perylene                                       TBD

    N,N-Diphenyl-l,4-Benzenediamine                        TBD
TBD - To be determined
*Values computed using the methodology in TAGM 4046 and subseguently adjusted to the
Pratical Quantitaion limits of those compounds in soil.
-------
                                 TABLE 4 (continued)
              NEW YORK STATE DEPARTMENT OF ENVIRONMENTAL CONSERVATION
                           TAGMs - SOIL CLEANUP OBJECTIVES
    Contaminants of Concern

          Arsenic

          Barium

         Beryllium

          Cadmium

         Chromium

          Cobalt

          Copper

          Lead

        Manganese

         Mercury

         Nickel

        Selenium

         Silver

        Vanadium

          Zinc

SB - Site Background
INORGANIC COMPOUNDS

           NYSDEC TAGM 4046 Cleanup Goal (ppm)

                      7.5 or SB

                      300 or SB

                      0.16 or SB

                       10 or SB

                       50 or SB

                       30 or SB

                       25 or SB

                          SB

                          SB

                         0.1

                      13 or SB

                       2 or SB

                          SB

                      150 or SB

                       20 or SB
-------
                                  TABIiE 4  (continued)
              NEW YORK STATE DEPARTMENT OF ENVIRONMENTAL  CONSERVATION
                           TAGMs - SOIL CLEANUP OBJECTIVES

                           SEMI-VOLATILE ORGANIC  COMPOUNDS

       Contaminants of Concern           NYSDEC TAGM 4046 Cleanup Goal  (ppm)

             Anthracene                                 50

         Benzo(a)anthracene                         0.224  or  MDL

           Benzo(a)pyrene                           0.061  or  MDL

        Benzo(b)flouranthene                        0.224  or  MDL

        Benzo(g,h,i)perylene                            50

        Benzo(k)flouranthene                        0.224  or  MDL

             Chrysene                                   0.4

       Dibenzo(a,h)anthracene                      0.014 or MDL

           Flouranthene                                 50

       Ideno(1,2,3-cd)pyrene                            3.2

         2-methylphenol                               0.1  or  MDL

          Phenanthrene                                  50

            Phenol                                    0.03 or MDL

MDL - Method Detection Limit


                              PCBs & PESTICIDES

       Contaminants of Concern            NYSDEC  TAGM 4046 Cleanup Goal  (ppm)

           Aroclor 1254                      1.0  (surface)     10  (subsurface)

         Alpha - BHC 110                                  0.11

          Beta - BHC200                                   0.2

          4,4'- DDE210                                    2.1
-------
TABLE 5 - COST COMPARISON OF THE REMEDIAL ALTERNATIVES
                                  Capital Cost 1    Annual        Every 5-yr.   Total Present Worth Cost 3
                                                    O&M Costs 2   O&M Costs
                   Alternative


Alternative S-l    No Further Action

Alternative S-2    Limited Action

Alternative S-3    Capping  (6 NYCRR
                   Part 360 Cap)

Alternative S-4    Excavation, Consolidation and   $ 15,357,836
                   Onsite Disposal

Alternative S-5    Excavation and Offsite
                   Disposal

Alternative S-6    Excavation and Onsite Low
                   Temp. Desorption &
                   Solid./Stabilization

1 Capital Cost: includes costs associated with equipment, site preparation and treatment.
2 O&M means "operations and maintenance"
3 Total Present Worth Cost: The amount of money that EPA would have to invest now at 5% interest in order to have the
appropriate funds available at the actual time the remedial alternative is implemented.
$
$
$
$
$
$
0
1,
10
15

173,
,207
,357

820
,311
,836
106,350,434
81
,986
,045
$
$
$
$
$
$
0
35,128
112,281
34,334
0
0
$
$
$
$
$
$
0
60,334
111,130
50,780
0
0
$0
$
$
$
$
$

2,
12
16


469,200
,454,
,397,
106,350
81
,986,
000
000
,500
045
-------
                                       APPENDIX III
                                ADMINISTRATIVE RECORD INDEX

                                    FOREST GLEN SITE
                                    OPERABLE UNIT TWO
                            ADMINISTRATIVE RECORD INDEX FILE
                                   INDEX OF DOCUMENTS

3.0  REMEDIAL INVESTIGATION

3.4  Remedial Investigation Reports

P.    300001-   Report: Final Remedial Investigation Report,
     300339    Volume I,  Forest Glen Site, Niagara Falls, New
               York, prepared by COM Federal Programs
               Corporation, prepared for U.S. EPA, Region II,
               December 16, 1996.

P.    300340-   Report: Final Remedial Investigation Report,
     300860    Volume II,  Forest Glen Site, Niagara Falls, New
               York, prepared by COM Federal Programs
               Corporation, prepared for U.S. EPA, Region II,
               December 16, 1996.

P.    300861-   Report: Final Remedial Investigation Report,
     301401    Volume III,  Forest Glen Site, Niagara Falls, New
               York, prepared by COM Federal Programs
               Corporation, prepared for U.S. EPA, Region II,
               December 16, 1996.

P.    301402-   Report: Final Endangerment Assessment, Forest Glen
     301631    Site, Niagara Falls, New York, Volume I of IV
               prepared by COM Federal Programs Corporation,
               prepared for U.S. EPA, Region II, November 1, 1996.

P.    301632-   Report: Final Endangerment Assessment, Forest Glen
     301907    Site, Niagara Falls, New York. Volume II of IV
               prepared by COM Federal Programs Corporation,
               prepared for U.S. EPA, Region II, November 1, 1996.

P.    301908-   Report: Final Endangerment Assessment, Forest Glen
     302219    Site, Niagara Falls, New York, Volume III of IV,
               prepared by COM Federal Programs Corporation,
               prepared for U.S. EPA, Region II, November 1, 1996.

P.    302220-   Report: Final Endangerment Assessment, Forest Glen
     302400    Site, Niagara Falls, New York, Volume IV of IV,
               prepared by COM Federal Programs Corporation,
               prepared for U.S. EPA, Region II, November 1, 1996.

3.5  Correspondence
P.    302401-   Memorandum to various Regional Directors, from Mr.
     302411    Elliott P. Laws,  Assistant Administrator, U.S.
               EPA,  Washington,  D.C., re: OSWER Directive No.
               9355.7-04, Land Use in the CERCLA Remedy Selection
               Process,  May 25,  1995.
-------
4.0  FEASIBILITY STUDY

4.3  Feasibility Study Reports

P.    400001-   Report: Feasibility Study Report, Forest Glen
     400410    Site, Niagara Falls, New York, prepared by CDM
               Federal Programs Corporation, prepared for U.S.
               EPA, Region II, August 4, 1997.

10.0 PUBLIC PARTICIPATION

10.1 Comments and Responses

P.    10.00001- Letter to Ms. Gloria M. Sosa, Remedial Project
     10.00001  Manager,  U.S. EPA, Region II, from Mr. Clyde J.
               Johnston, resident of Niagara County, New York,
               re: Comments on the Proposed Plan, October 23, 1997.

P.    10.00002- Letter to Ms. Gloria M. Sosa, Remedial Project
     10.00002  Manager,  U.S. EPA, Region II, from Ms. Linda
               Abdullah, resident of Niagara County, New York,
               re: Comments on the Proposed Plan, October 23, 1997.

P.    10.00003- Letter to Ms. Gloria M. Sosa, Remedial Project
     10.00003  Manager,  U.S. EPA, Region II, from Mr. John
               Srijka, resident of Niagara County, New York, re:
               Comments on the Proposed Plan, October 23, 1997.

P.    10.00004- Letter to Ms. Gloria M. Sosa, Remedial Project
     10.00004  Manager,  U.S. EPA, Region II, from Mr. Mark S.
               Printop,  resident of Niagara County, New York, re:
               Comments on the Proposed Plan, October 23, 1997.

P.    10.00005- Letter to Ms. Gloria M. Sosa, Remedial Project
     10.00005  Manager,  U.S. EPA, Region II, from Mr. William
               Johnston, resident of Niagara County, New York,
               re: Comments on the Proposed Plan, October 23, 1997.

P.    10.00006- Letter to Ms. Gloria M. Sosa, Remedial Project
     10.00006  Manager,  U.S. EPA, Region II, from Mr. Fabian S.
               Rosati, Chairman, Town of Niagara Environmental
               Commission, re: Comments on the Proposed Plan,
               November 13, 1997.

P.    10.00007- Letter to Ms. Gloria M. Sosa, Remedial Project
     10.00009  Manager,  U.S. EPA, Region II, from Mr. Steven C.
               Richards, Town Supervisor, Town of Niagara, re:
               EPA Proposed Plan for the Forest Glen Subdivision
               Superfund Site, Niagara Falls, New York, December 8, 1997.

P.    10.00010- Letter to Ms. Gloria M. Sosa, Remedial Project
     10.00012  Manager,  U.S. EPA, Region II, from Connie M.
               Lozinsky, Esg., Councilmember, City of Niagara
               Falls, New York, Office of the City Council, re:
               EPA Proposed Plan for the Forest Glen Subdivision
               Superfund Site, Niagara Falls, New York, December 8, 1997.
-------
P.    10.00013- Letter to Ms. Gloria M. Sosa, Remedial Project
     10.00015  Manager,  U.S. EPA, Region II, from Mr. Guy T.
               Sottile,  and Mr. Jack A. Brundage, Niagara Falls
               USA Campsites, Inc., re: EPA Proposed Plan for the
               Forest Glen Subdivision Superfund Site, Niagara
               Falls, New York, December 8, 1997.

P.    10.00016- Letter to Ms. Gloria M. Sosa, Remedial Project
     10.00017  Manager,  U.S. EPA, Region II, from Mr. Joseph J.
               Certo, Vice President, Certo Brothers Distributing
               Company,  re: Comments on the EPA Proposed Plan
               for the Forest Glen Subdivision Superfund Site,
               Niagara Falls, December 8,  1997.

P.    10.00018- Letter to Ms. Gloria M. Sosa, Remedial Project
     10.00022  Manager,  U.S. EPA, Region II, from Mr. James C.
               Whiteley, Vice President, The Goodyear Tire &
               Rubber Company,  and Mr. Neal T. Rountree,
               Attorney, re: EPA Proposed Plan for The Forest
               Glen Subdivision Superfund Site, Niagara Falls,
               New York, December 8, 1997.

P.    10.00023- Letter to Ms. Gloria M. Sosa, Remedial Project
     10.00106  Manager,  U.S. EPA, Region II, from Mr. Robert M.
               Hallman,  Cahill Gordon & Reindel, re: EPA Proposed
               Plan for The Forest Glen Subdivision Superfund
               Site,  Niagara Falls, New York,  December 9, 1997.
               (Attachment: Report: Comments on U.S. EPA's
               September 1997 Propoped Plan for the Forest Glen
               Superfund Site,  The Goodyear Tire & Rubber
               Company,  prepared by O'Brien & Gere Engineers,
               Inc. for The Goodyear Tire & Rubber Company,
               December 8, 1997.

P.    10.00107- Letter to Mr. Kevin Lynch,  Section Chief, Western
     10.00107  New York Remediation Section, U.S. EPA, Region II,
               from Mr.  James C. Galie, Mayor, City of Niagara
               Falls, New York, Office of the Mayor, re: Forest
               Glen Remediation Preferences, February 20, 1998.

10.3 Public Notices

P.    10.00108- Public Notice: "The U.S. EPA and the NYSDEC want
     10.00108  your comments on the Proposed Plan for Cleanup of
               the Forest Glen Superfund Site", Niagara Falls,
               New York, Niagara Gazette,  Wednesday, September 24, 1997.

P.    10.00109  Public Notice: "The United States Environmental
     10.00109  Protection Agency Announces an Extension of the
               Public Comment Period on the Proposed Plan for the
               Forest Glen Superfund Site in Niagara Falls, New
               York", Niagara Gazette, Thursday, October 23, 1997.
-------
P.    10.00110- Public Notice: "The United States Environmental
     10.00110  Protection Agency Announces an Extension of the
               Public Comment Period on the Proposed Plan for the
               Forest Glen Superfund Site in Niagara Falls,  New
               York", Niagara Gazette,  Thursday, November 20, 1997.

10.4 Public Meeting Transcripts

P.    10.00111- Public Meeting Transcript: "Forest Glen
     10.00180  Subdivision Superfund Site", held on Wednesday,
               October 15, 1997, prepared by Th*r*se M. McGreevy
               Court Reporting Service, Inc., October 15,  1997.
-------
                                       APPENDIX IV

                               STATE IiETTER OF CONCURRENCE



                                       APPENDIX V

                                SUMMARY OF RISK ASSESSMENT

SUMMARY OF RISK ASSESSMENT

Based upon the results of the RI and the Remedial Investigation Report, 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 risks which could result from the contamination at the site if no
remedial action were taken.

Human Health Risk Assessment

A four-step process is utilized for assessing site-related human health risks for a reasonable maximum
exposure scenario. Hazard Identification identifies the contaminants of concern at the site based on several
factors such as toxicity, freguency of occurrence, and concentration. 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.

Hazard Identification and Toxicity Assessment. The baseline risk assessment began with selecting contaminants
of concern which would be representative of site risks  (see TABLE 6). These contaminants included several
semivolatile organic compounds  (benzo(a)pyrene, benzo(a)anthracene, etc.), targeted semivolatile organic
compounds (2-mercaptobenzothiazole and N,N-diphenyl-l, 4-benzenediamine) , polychlorinated biphenyls  (Aroclors
1254 and 1260), and inorganics; (arsenic, barium, beryllium cadmium, etc.) in surface and subsurface soils,
groundwater and sediment. Several of the contaminants are known to cause cancer in laboratory animals and are
suspected or known to be human carcinogens. A summary of toxicity data  (cancer slope factors and Reference
Doses)  for the chemicals of concern are provided in Tables 7 and 8).
-------
                                      NOTE:

                             TABIiES 1 THROUGH 5 ARE  IN

                                   APPENDIX II

                                  TABIiE 6 - Continued
Chemicals
     Concentration Detected
           (rag/kg)

                         Frequency
Minimum      Maximum     of Detection

    Surface Soil - NORTHERN ASPECT AOC-2
                             Exposure Point
                              Concentration
                                  (mg/kg)
                                  Statistical
                                    Measure
SVOCS

Benzo(a)pyrene
Benzo(b)fluoranthene
Dibenzo(a,h)anthracene

Pesticides/PCBs

Aroclor 1254

Inorganics

Antimony
Arsenic
Barium
Beryllium
Chromium
Manganese
Mercury
Thallium
Vanadium
0.027 J
0.036 J
0.025 J
0.047
0.260 J
0.520
0.050 J
             0.047
4/18
4/18
2/18
               1/18
5 . 9 BN J
3.4 J
114
0.38 B
13.1
427
0.17 NJ
1.2 B
21.2 J
5 . 9 BN J
8.5 J
278
1.5
803
2,800
1.50
2.4 B
63.3
1/18
18/18
18/18
11/18
16/16
18/18
4/18
6/18
18/18
                                            15
0.26
0.29
0.05
                                                0.024
                                   2.58
                                   6.74
                                    278
                                    0.88
                                 .2 (Chrome VI)
                                   1,080
                                   0.26
                                   1.38
                                   51.7
Maximum
95% UCL
Maximum
                                                                 95% UCL
                                    95% UCL
                                    95% UCL
                                    Maximum
                                    95% UCL
                                    95% UCL
                                    95% UCL
                                    95% UCL
                                    95% UCL
                                    95% UCL
-------
                                 TABLE 6 - Continued
Chemicals
SVOCS

Benzo(a)anthracene
Benzo(a)pyrene
Benzo(b)fluoranthene
Dibenzo(a,h)anthracene
Indeno(1,2,3-cd)pyrene
Pyrene

TSVOCs

N,N-Diphenyl-l,4-
benzenediamine

Inorganics

Arsenic
Barium
Chromium
Manganese
Mercury
Nickel
Thallium
Vanadium
                                Concentration Detected
                                       (mg/kg)
                        Freguency
                        of Detection
               Exposure Point
                Concentration
                   (mg/kg)
Minimum      Maximum

    Surface Soil - EDGEWOOD DRIVE WOODED LOTS  (AOC5)
0.54.0 J
0.047 J
0.100 XJ
0.068 J
0.240 J
0.044 J
100.0 D
88.0 DJ
130.0 DJ
16.0 DJ
25.0 DJ
130.0 D
8/16
8/16
8/16
6/16
7/16
10/16
1.46 J
            1.46 J
1/16
4.60
46.6 B
24.1
173
0.07 B
23.6 J
1.05 B
32.3 J
21.3
228
271
1,170
2.50
139
2.30 B
125
16/16
16/16
16/16
16/16
9/16
16/16
6/16
16/16
                                               1.46
                                               12.5
                                                228
                                          9.05 (Chrome VI)
                                                743
                                                2.50
                                                86.3
                                                1.24
                                                81.3
Statistical
  Measure
100
88.0
130
4.32
25.0
130
Maximum
Maximum
Maximum
95% UCL
Maximum
Maximum
                                                               Maximum
                                     95% UCL
                                     Maximum
                                     95% UCL
                                     95% UCL
                                     Maximum
                                     95% UCL
                                     95% UCL
                                     95% UCL
-------
                                  TABLE 6 - Continued
Chemicals
                                Concentration Detected
                                       (mg/kg)
                           Frequency
                           of Detection
                           Exposure Point
                            Concentration
                               (mg/kg)
Minimum      Maximum

    Subsurface Soil - SUBDIVISION Area of Concern 6
               Statistical
                 Measure
SVOCS
Benzo(a)anthracene
Benzo(a)pyrene
Benzo(b)fluorenthene
Dibenzo(a,h)anthracene
Fluoranthene
Indeno(1,2,3-cd)pyrene
Pyrene
1.158
1.508 J
2.558 J
4.405 D
1.508
1.708
1.358
250.0 J
170.0
220.0
8.7 J
250.0
84.0
200.0 J
3/17
3/17
3/17
2/17
3/17
3/17
3/17
28,
22,
27,
1.'
31,
10,
25,
.8
.6
.5
18
.2
.8
.3
95%
95%
95%
95%
95%
95%
95%
UCL
UCL
UCL
UCL
UCL
UCL
UCL
TSVOCs
N,N-diphenyl,1-4-
benzenediamine
 0.040 J
               12.53 JD
            4/17
                                                 0.86
                                                                 95% UCL
Inorganics

Arsenic
Manganese
Mercury
Nickel
Vanadium
 2.50 B
  135
0.13 NJ
 7.6 B
 9.2 B
14.6
 880
25.6 NJ
 87.4
 98.6
                           17/17
                           17/17
                            5/17
                           17/17
                           17/17
8.07
 686
1.93
87.4
49.6
95% UCL
95% UCL
95% UCL
Maximum
95% UCL
-------
                                  TABLE 6 - Continued
Chemicals



SVOCS

Dibenzo(a,h)anthracene
                                Concentration Detected
                                       (mg/kg)
                       Frequency
                       of Detection
            Exposure Point
             Concentration
                (mg/kg)
Minimum      Maximum

    Subsurface Soil - NORTHERN ASPECT Area of Concern 2
0.026 J
             0.026 J
1/13
                                                0.026
Statistical
  Measure
                                                                 Maximum
Inorganics

Arsenic
Barium
Beryllium
Chromium
Manganese
Nickel
Vanadium
Zinc
2. BJ
29.1 B
0.25 B
6.20
530
8.3 B
10.0 B
69.7
6.1 J
325
0.29 B
34.7
745
37.3
43.5
269
12/13
13/13
4/13
13/13
13/13
13/13
13/13
13/13
                                              5.76
                                               172
                                               0.21
                                          .96 (Chrome VI)
                                               652
                                              32.9
                                              38.9
                                               269
                                   95% UCL
                                   95% UCL
                                   95% UCL
                                   95% UCL
                                   95% UCL
                                   95% UCL
                                   95% UCL
                                   Maximum
-------
                                  TABIiE 6 - Continued
Chemicals
SVOCS

Benzo(a)anthracene
Benzo(a)pyrene
Benzo(b)fluoranthene
Benzo(k)fluoranthene
Dibenzo(a,h)anthracene
Fluoranthene
Indeno(1,2,3-cd)pyrene

Inorganics

Arsenic
Beryllium
Manganese
Mercury
Nickel
Vanadium
Thallium
                                Concentration Detected
                                       (mg/kg)
Freguency
of Detection
Exposure Point
 Concentration
    (mg/kg)
Minimum      Maximum

    Subsurface Soil - EDGEWOOD DRIVE WOODED LOTS  (AOC-5)
0,
0,
0,
0,
0,
0,
2,
.053
.040
.087
.085
.955
.050
.645
J
J
XJ
XJ

J
JD
56.0
42.0
98.0
79.0
2.4
66.
16
D
D
D
D
J
0 D
.0
4/13
4/13
5/13
5/13
2/13
5/13
2/13
2.0 B
0.44 B
420
0.16
8.50 B
10.1 B
1.3 B
8.80 J
1.70
1,320
3.20
69.4
59.1
1.8 B
13/13
13/13
13/13
4/13
13/13
13/13
3/13
                      5.85
                      1.10
                       763
                      0.72
                      69.4
                      40.6
                      1.07
Statistical
  Measure
36.5
24.3
98.0
55.1
0.65
66
3.42
95% UCL
95% UCL
Maximum
95% UCL
95% UCL
Maximum
95% UCL
                        95% UCL
                        95% UCL
                        95% UCL
                        95% UCL
                        Maximum
                        95% UCL
                        95% UCL
-------
Chemicals
                                  TABIiE 6 - Continued
                                 Concentration Detected
                                       (mg/kg)
Minimum
Maximum
Frequency
of Detection
Exposure Point
 Concentration
    (mg/kg)
Statistical
  Measure
SVOCS
                               Subsurface Soil - BERM  (AOC - 1)
Benzo(a)anthracene
Benzo(a)pyrene
Benzo(b)fluoranthene
Bis (2-ethythexyl)phthalate 0.060
Indeno(1,2,3-cd)pyrene
0.200 J
0.210 J
0.055 JX
0.060 J
0.100 J
4.1 J
2.55 J
6.3 J
61.0 DK
1.010 J
3/5
3/5
4/5
5/5
3/5
                                                4.10
                                                2.55
                                                6.30
                                                61.0
                                                1.01
                                                   Maximum
                                                   Maximum
                                                   Maximum
                                                   Maximum
                                                   Maximum
TSVOCs
2-Mercaptobenzene-
thiazole
                            1.70 J
                                       565.0 DJ
                            3/5
                                                                            565
                                                                                           Maximum
N,N-diphenyl-l, 4-
benzenediamine
 9.06 DJ    119.0 DJ
               3/5
                                                 119
                                                                Maximum
Inorganics
Antimony
Arsenic
Beryllium
Manganese
Mercury
Thallium
3.83 BNJ
4.90
0.45 B
377
0.19
1.20 B
3.83 BNJ
9.05 B
0.84 B
1,571
7.60
1.85 B
1/5
5/5
5/5
5/5
3/5
2/5
                                                 3.37
                                                 8.41
                                                 0.74
                                                 1,570
                                                 7.60
                                                 1.85
                                                    Maximum
                                                    Maximum
                                                    Maximum
                                                    Maximum
                                                    Maximum
                                                    Maximum
-------
TABIiE 6 - Summary Information on Chemicals of Concern
Chemicals
Semi Volatile Organic
Compounds  (SVOCS)

Benzo(a)anthracene
Benzo(a)pyrene
Benzo(b)fluoranthene
Dibenzo(a,h)anthracene
Indeno(1,2,3-cd)pyrene

Targeted Semivolatile
Organic Chemicals
(TSVOCs)

2-Mercaptobenzothiazole

N,N-Diphenyl-
1,4,Benzenediamine
                                Concentration Detected
                                       (mg/kg)
                         Freguency
                         of Detection
                             Exposure Point
                              Concentration
                                 (mg/kg)
Minimum      Maximum

    Surface Soil - SUBDIVISION Area of Concern  (AOC) - 6
0.130 J
0.100 J
0.240
0.074 J
0.210 J
2.9
2.5
7.2 D
0.53
1.20
15/17
15/17
15/17
5/17
7/17
 0.120 J    47.0 DJ

 0.110 J    13.0 DJ
              14/17

              12/17
                                                47.0

                                                13.0
               Statistical
                 Measure
1.89
1.91
2.95
0.53
1.08
95% UCL
95% UCL
95% UCL
Maximum
95% UCL
                 Maximum

                 Maximum
Pesticides/PCBs
Aroclor 1254
Aroclor 1260
0.048 NJ
0.080 NJ
0.31
0.080 NJ
                           3/17
                           1/17
0.07
0.03
95% UCL
95% UCL
-------
                                  TABIiE 6 - Continued
Chemicals
                                Concentration Detected
                                       (mg/kg)
Frequency
of Detection
Exposure Point
 Concentration
    (mg/kg)
Statistical
  Measure
Minimum      Maximum

    Surface Soils - SUBDIVISION Area of Concern  (AOC) - 6 - Continued
Inorganics
Arsenic
Barium
Beryllium
Cadmium
Chromium
Manganese
Mercury
Vanadium
Zinc
1.40 B
9.10 B
0.08 B
0.45 B
32.4
315
0.11 NJ
4.90 B
67.9
10.5
335
0.97 B
7.88
366
5,230
5.70 J
45.3
10,200 J
17/17
17/17
15/17
15/17
3/3
17/17
12/13
17/17
17/17
6.42
335
0.92
7.88
52.3 (Chrome VI)
1,220
5.70
45.3
9.01
95% UCL
95% UCL
95% UCL
Maximum
95% UCL
95% UCL
Maximum
Maximum
95% UCL
-------
Chemicals
VOCs
                                  TABIiE 6 - Continued

                                   On-Site Groundwater

                               Concentration Detected
                                      (mg/1)
       Minimum
 Maximum
                               On Site GROUNDWATER
Frequency
of Detection
  Exposure Point
   Concentration
      (mg/1)
Statistical
 Measure
1,2-Dichloroethene
Vinyl Chloride
(Total)   0.001  J      1.3
         0.015        0.220  J
                9/28
                5/28
                      1.30
                      0.02
                       Maximum
                       Maximum
SVOCs
Benzo(a)pyrene             0.0007 J    0.0007 J        1/26
Hexachlorobutadiene        0.0075 J    0.0075 J        1/26
N-nitroso-di-N-propylamine  0.003 J     0.003 J        1/26
                                                      0.0007
                                                      0.0045
                                                      0.003
                                                   Maximum
                                                   Maximum
                                                   Maximum
Inorganics

Arsenic
Chromium
Manganese
Mercury
Nickel
Silver
Vanadium
        0.0034  BJ
        0.00430 BJ
         0.0175
        0.00013 BJ
        0.0093  B
        0.0234  J
        0.0040  B
 0.0115
  0.749
 6.790 J
0.0011 NJ
  0.725 J
  0.0446
  0.0384 B
   5/28
   21/28
   26/28
   13/28
   17/28
   2/28
   8/28
      0.0054           95% UCL
0.0021 (Chrome VI)      95% UCL
       1.4             95% UCL
     0.0011            Maximum
       0.01            95% UCL
      0.0446           95% UCL
      0.0384           95% UCL
-------
Chemicals
VOCs
                                  TABIiE 6 - Continued

                                Surface Water - East Gill Creek AOC-4

                              Concentration Detected
                                       (mg/1)
                         Frequency
             Maximum     of Detection
                             Exposure Point
                              Concentration
                                 (mg/1)
Minimum

    Surface Water - EAST GILL CREEK AOC-4 - On Site
                      Statistical
                       Measure
1,1,2,2,-Tetrachloroethene  0.0022 J
(TIC)
                                         0.0022 J
                              1/4
                                                                          0.0022
                                                                                           Maximum
Inorganics
Antimony
Arsenic
Barium
Beryllium
Chromium
Manganese
Mercury
Nickel
Vanadium
Zinc
0.0157 BNJ
0.0075 B
 0.32 EJ
0.0014 BJ
 0.0085
 0.0360
0.00053
0.0469 B
0.0583 BEJ
 0.042
0.0157 BNJ
  0.0139
 0.599 EJ
0.0033 BJ
  0.289
  1.710
  0.001
  0.102 J
  0.133 EJ
   1.820
                              1/4
                              2/4
                              2/4
                              2/4
                              4/4
                              4/4
                              2/4
                              2/4
                              2/4
                              4/4
0.0413
0.0157
0.0139
 0.599
0.0033
(Chrome VI)
 1.71
 0.001
 0.102
 0.133
  1.82
Maximum
Maximum
Maximum
Maximum
Maximum
Maximum
Maximum
Maximum
Maximum
Maximum
-------
                                  TABIiE 6 - Continued

                             Sediment On Site - East Gill (AOC-4)

                                Concentration Detected
                                      (mg/kg)
                                                                     Exposure Point
                                                    Frequency         Concentration      Statistical
Chemicals                  Minimum      Maximum     of Detection         (mg/kg)           Measure

                               Sediment On Site - EAST GILL CREEK (AOC-4)

SVOCs


Benzo(a)pyrene            0.200 J       0.750 J         4/4            Not calculated
                                                                      based on lack of
                                                                      toxicity factor for
                                                                      dermal exposure

Benzo(b)fluoranthene      0.270 J       1.200 J         4/4            Not calculated
                                                                      based on lack of
                                                                      toxicity factor for
                                                                      dermal exposure

Dibenzo(a,h)anthracene    0.068 J       0.230 J         4/4            Not calculated
                                                                      based on lack of
                                                                      toxicity factor for
                                                                      dermal exposure
-------
Chemicals



Inorganics

Arsenic

Barium




Beryllium




Cadmium

Chromium
Manganese
Mercury
Nickel
                                  TABIiE 6 - Continued
                           Sediment On Site-East Gill (AOC-4)

                                Concentration Detected
                                      (mg/kg)
                           Freguency
                           of Detection
Minimum      Maximum

    Sediment On-Site - EAST GILL CREEK (AOC-4)
              Exposure Point
               Concentration
                  (mg/kg)
                    Statistical
                      Measure
  4.90

112 BEJ
  0.63




3.70 J

 43.0
                         851 EJ
                        0.27 NJ
                        25.9 J
              26.8 J

              169.0
              0.86




              4.15

              82.0
                                       0.57 J
                                       0.57 J
                                       32.0
4/4

4/4




3/4




2/4

4/4




4/4




4/4




3/3
 Not calculated
based on lack of
toxicity factor for
dermal exposure

 Not calculated
based on lack of
toxicity factor for
dermal exposure

       4.15

 Not calculated
based on lack of
toxicity factor for
dermal exposure

 Not calculated
based on lack of
toxicity factor for
dermal exposure

 Not calculated
based on lack of
toxicity factor for
dermal exposure

 Not calculated
based on lack of
toxicity factor for
dermal exposure
                                                                  Maximum
Maximum
-------
                      TABIiE 6 - Continued
                  Concentration Detected
                          (mg/kg)
Chemicals
Vanadium
Zinc
 Minimum
Maximum
Frequency
of Detection
  Sediment On-Site - EAST GILL CREEK (AOC-4)

26.7 BJ         40.5                   4/4
                   127
                                497 J
                                       4/4
Exposure Point
Concentration
   (mg/kg)
Statistical
  Measure
                                     Not calculated
                                   based on lack of
                                   toxicity factor for
                                   dermal exposure

                                     Not calculated
                                   based on lack of
                                   toxicity factor for
                                   dermal exposure
-------
                          TABLE 6 - Continued
                      Concentration Detected
                               (mg/kg)
Chemicals


SVOCS

Benzo(a)anthracene




Benzo(a)pyrene
 Minimum       Maximum

Sediment - WOODED WETLAND AOC-3
 Frequency
of Detection
 0.160 J
 0.260 J
Dibenzo(a,h)anthracene 0.052 J
Pesticides/PCBs
Aroclor 1254
               0.510 J
               0.530J
Benzo(b)fluoranthene   0.545 XJ      1.400 X
               0.080
                       0.068 J
                                     0.110 J
 10/10
 10/10
                               10/10
 12/10
                                5/7
Exposure Point
Concentration
   (mg/kg)
  Not calculated
based on lack of
toxicity factor for
dermal exposure

  Not calculated
based on lack of
toxicity factor for
dermal exposure

  Not calculated
based on lack of
toxicity factor for
dermal exposure

  Not calculated
based on lack of
toxicity factor for
dermal exposure

      0.11
Statistical
Measure
                                      Maximum
-------
                           TABIiE 6 - Continued
                      Concentration Detected
                              (mg/kg)
Chemicals



Inorganics

Arsenic

Barium




Beryllium




Cadmium
Chromium
Manganese
Mercury
 Minimum       Maximum

Sediment- WOODED WETLAND (AOC-3)
                Freguency
               of Detection
             Exposure Point
             Concentration
                (mg/kg)
                    Statistical
                        Measure
  4.6

  150
  0.74 B
                        1.10
                        36.7
                        215
                        0.55
7.7

192
               1.50 B
                                     1.50 B
                                     53.5
                                     616
                                     1.50
 10/10

 10/10




 10/10




 7/10




10/10




10/10




10/10
    6.67

  Not calculated
based on lack of
toxicity factor for
dermal exposure

  Not calculated
based on lack of
toxicity factor for
dermal exposure

  Not calculated
based on lack of
toxicity factor for
dermal exposure

  Not calculated
based on lack of
toxicity factor for
dermal exposure

  Not calculated
based on lack of
toxicity factor for
dermal exposure

  Not calculated
based on lack of
toxicity factor for
dermal exposure
                                                                      95% UCL
-------
Chemicals
                       TABIiE 6 - Continued

                      Concentration Detected
                              (mg/kg)
Minimum
Maximum
 Frequency
of Detection
                      Sediment - WOODED WETLAND AOC-3
Exposure Point
 Concentration
    (mg/kg)
Statistical
    Measure
Nickel
Thallium
Vanadium
Zinc
                       30.5
                       1.60
                       35.4 J
                       214
                                     39.2
                                     1.90 B
                                     47.2 J
                                     374 NJ
                                10/10         Not calculated
                                            based on lack of
                                            toxicity factor for
                                            dermal exposure

                                 2/10         Not calculated
                                            based on lack of
                                            toxicity factor for
                                            dermal exposure

                                10/10         Not calculated
                                            based on lack of
                                            toxicity factor for
                                            dermal exposure

                                10/10         Not calculated
                                            based on lack of
                                            toxicity factor for
                                            dermal exposure
-------
Footnotes to TABLE 6

     J     =    Reported concentration is estimated.

     B     =    Reported concentration is estimated since it was detected in both the sample and
                in the associated blank for organics; for inorganics, the B gualifier indicates that
                the reported value is less than the contract reguired detection limit but greater than
                the instrument detection limit.

     E     =    For inorganics indicates that the value is estimated due to matrix interferences.

     N     =    For organics indicates that there is only presumptive evidence for their
                presence; for inorganics the N gualifier indicates that the spiked sample recovery
                is not within control limits.

     D     =    For organics indicates that the chemicals was identified in an analysis at a
                secondary dilution factor.

     X     =    For organics indicates difficulty in chromatographic separation of compounds.

     U     =    Indicates that the chemical was not detected at the reported detection limit.

95% UCL = 95% upper confidence limit on the arithmetic mean soil concentration of a chemical at a
given site.

Max = Maximum concentration detected of a chemical at a given site. Used in place of a 95% UCL when
the 95% UCL exceeds the maximum concentration detected.
-------
TABIiE 7 - Carcinogenic Toxicity Characteristics of Chemicals  of Concern
Chemicals
VOCS

1,2-Dichloroethene  (Total)
Vinyl Chloride
1,1,2,2-Tetrachloroethene

SVOCS

Benzo(a)anthracene
Benzo(a)pyrene
Benzo(b)fluoranthene
Dibenzo(a,h)anthracene
Indeno(1,2,3-cd)pyrene
Pyrene
Fluorcanthene
Benzo(k)fluoranthene
Bis(2-ethyl-hexyl)
phthalate
Hexachlorobutadi ene
N-nitroso-di-N-propylamine   7.0 E+00
Oral
Slope
Factor
(mg/kg-day) -1
NA
1.9 E+00
2.0 E-01
7.3 E-01



7.3 E+00
7.3 E-01



7.3 E+00



7.3 E-01



NA
NA
7.3 E-02



1.4 E-02
7.8 E-02
7.0 E+00
Inhalation
Slope
Factor
(mg/kg-day) -1
NA
3.0 E-01
2.0 E-01
NA



NA
NA



NA



NA



NA
NA
NA



NA
7.8 E-02
-

Weight of
Evidence

NA
A
C
B2



B2
B2



B2



B2



D
D
B2



B2
C
B2

Source of
Data

IRIS/HEAST
HEAST
IRIS
USEPA
RELATIVE
POTENCY
GUIDANCE
IRIS
USEPA
RELATIVE
POTENCY
GUIDANCE
USEPA
RELATIVE
POTENCY
GUIDANCE
USEPA
RELATIVE
POTENCY
GUIDANCE
IRIS
IRIS
USEPA
RELATIVE
POTENCY
GUIDANCE
IRIS
IRIS
IRIS

Date of
Analysis

2/96
FY'95
2/96
1993



2/96
1993



1993



1993



2/96
2/96
1993



2/96
2/96
2/96
-------
Chemicals
TSVOCs
TABIiE 7 - Continued

     Oral
     Slope
     Factor
Inhalation
Slope
Factor
                             (mg/kg-day)-1    (mg/kg-day)-1
Weight of
Evidence
Source of
Data
 Date of
Analysis
2-Mercaptobenzothiazole      2.9 E-02       NA
N,N-Diphenyl-l,4-            NA             NA
Benzene-diamine
                                      C
                                      D
                                                        NCEA
                                                     2/96
Pesticides/PCBs
Aroclors 1254
Aroclors 1260
      7.7 E+00
      7.7 E+00
NA
NA
B2
B2
IRIS
IRIS
   2/96
   2/96
Inorganics

Antimony
Arsenic
Barium
Beryllium
Cadmium
Chromium VI
Manganese
Mercury (methyl)
Vanadium
Zinc
Thallium (chloride)
Nickel (soluble salt)
Silver
      NA
      1.5 E+00
      NA
      4.3 E+00
      NA
      NA
      NA
      NA
      NA
      NA
      NA
      NA
NA
1.5 E+01
NA
8.4 E+00
6.3 E+00
4.1 E+01
NA
NA
NA
NA
NA
NA
NA
A
NA
B2
Bl
A
D
C
NA
D
D
NA
IRIS
NA
IRIS
IRIS
IRIS
IRIS
IRIS
IRIS
IRIS
IRIS

IRIS
   2/96

   2/96
   2/96
   2/96
   2/96
   2/96
   2/96
   2/96
   2/96

   2/96
-------
    TABIiE 7 - Abbreviations
    Weight of Evidence Classifications = A, known human carcinogens; Bl and B2, probable human
    carcinogens; C,  possible human carcinogens; D, not classifiable as to human carcinogenicity; and E,
    evidence of non-carcinogenicity.
    IRIS - Integrated Risk Information System
    HEAST - Health Effects Assessment Summary Table - FY'95.
    NCEA - National Center for Environmental Assessment - source of provisional toxicity values.
    Manganese - The total intake of manganese is estimated to be 10 mg/day. Of the 10 mg/day, 5 mg/day is
             subtracted as the estimated daily dietary intake. This value was then divided by 70 kg  (adult
             body weight) and by a modifying factor of 3 (sensitive individuals).
    Polyaromatic Hydrocarbons - were assessed using Relative Toxicity Values as described in the U.S. EPA,
 1993 guidance document. U.S. EPA (1993)  Provisional Guidance for Quantitative Risk Assessment of
Polycyclic Aromatic Hydrocarbons. U.S. EPA, Environmental Criteria and Assessment Office (currently
    the National Center for Environmental Assessment), Cincinnati, Ohio. EPA/600/R-93/089.  July.
-------
                TABIiE 8 - Non-Carcinogenic Information for Chemicals of Concern
Chemicals
Oral
Reference
Dose
(mg/kg-day)
                                            Critical Effect/
                                            Uncertainty Factor
Inhalation
Reference    Source of  Date of
Dose         Data      Analysis
 (mg/kg-day)
VOCS
1,2-Dichloroethene  (Total)    9.0 E-03
Vinyl Chloride                NA
1,1,2,2-Tetrachloroethene     3.0 E-02
              Liver Lesions/1,000

              Liver & Kidney
              Lesions/3, 000
NA
NA
NA
HE AST
NA
HEAST
FY'95
 NA
FY'95
SVOCS
Benzo(a)anthracene            NA
Benzo(a)pyrene                NA
Benzo(b)fluoranthene          NA
Dibenzo(a,h)anthracene        NA
Indeno(1,2,3-cd)pyrene        NA
Pyrene                        3.0 E-02
Fluoroanthene                 4.0 E-02
Benzo(k)fluoranthene          NA
Bis(2-ethylhexyl)phthalate    2.0 E-02
Hexachlorobutadiene           2.0 E-04
N-nitroso-di-N-propylamine    NA
              Kidney Effects/3,000
              Kidney Effects/3,000

              Liver Effects/1,000
              Kidney Effects/1,000
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
IRIS
IRIS

IRIS
HEAST






2/96
2/96

2/96
FY'95

TSVOCs
2-Mercaptobenzothiazole       1.0 E-01
N,N-Diphenyl-l,4-             3.0 E-04
Benzenediamine
              Kidney Effects/100
              Reproductive
              Effects/1,000
NA
NA
NCEA
IRIS
 2/96
 2/96
-------
                         TABIiE 8 - Continued
Chemicals


Pesticides/PCBs

Aroclors 1254
Aroclors 1260

Inorganics

Antimony

Arsenic

Barium
Beryllium
Cadmium  (food)
         (water)
Chromium III
Chromium VI
Manganese  (water)
Mercury  (methyl)

Vanadium

Zinc
 Oral
 Reference
 Dose
(mg/kg-day)
 2.0  E-05
 NA
 4.0  E-04

 3.0  E-04

 7.0  E-02
                                            Critical Effect/
                                            Uncertainty Factor
Ocular Effects/300
Changes in cholesterol
levels/1.000
Hyperpigmentation and
keratosis/3
Increased blood
pressure/3

Inhalation: changes in
liver function/1,000
5.0 E-03
1.0 E-03
5.0 E-04
1.0 E+00
5.0 E-03
2.4 E-02
NOAEL/100
NOAEL-/ 1

NOAEL/100
NOAEL/500
CNS/1
 1.0  E-04       Kidney/1000

 7.0  E-03       Decreased hair
               cystine/100
 3.0  E-01       Decreased Erythrocyte
               Superoxide
               Dismutase/3
                           Inhalation
                           Reference
                           Dose
                           (mg/kg-day)
NA
NA
NA

NA

1.4 E-04
            Source of
            Data
IRIS
IRIS
IRIS

IRIS
         Date of
        Analysis
2/96
2/96
2/96

2/96
IRIS  2/96 (oral)
HEAST      FY'95
           (inh)
NA
NA
NA
NA
1.4 E-05






8.6 E-05
(elemental)
NA
NA
IRIS
IRIS
IRIS
IRIS
IRIS






IRIS

IRIS
IRIS
2/96
2/96
2/96
2/96
2/96 (with
modificati
on for
sensitive
indv. )
2/96
(inhalation)
2/96

2/96
2/96
-------
                          TABIiE 8 - Continued
Chemicals



Thallium  (chloride)

Nickel  (soluble salt)

Silver

Abbreviations

NOAEL = No Observed Adverse Effect Level.
Oral
Reference
Dose
(mg/kg-day)
8.0 E-05

2.0 E-02

5.0 E-03
Critical Effect/
Uncertainty Factor


Changes in blood
chemistries/3, 000
Decreased organ and
body weights/300
Discoloration of skin/3
Inhalation
Reference
Dose
(mg/kg-day)
NA

NA

NA
Source of   Date of
Data        Analysis
IRIS        2/96

IRIS        2/96

IRIS        2/96
-------
Exposure Assessment. Since residents currently live in the vicinity of the Forest Glen site, numerous
potential exposure scenarios and human receptors were selected for quantitative evaluation in this risk
assessment.

Surface Soil Current Exposure - For the risk assessment, the site was divided into 3 distinct areas of
concern for the evaluation of site surface soil: 1) the Subdivision (AOC 6), 2) the Northern Aspect (AOC 2),
and 3) the Edgewood Drive Wooded Lots  (AOC 5).

Area residents/trespassers may inadvertently ingest or dermally contact surface soil in the Subdivision, the
Northern Aspects, and the Edgewood Drive Wooded Lots during recreational (e.g., trespassing) activities.
Evidence of trespassing at the site was observed by EPA's contractor.  The following activities were not
selected as potential routes of exposure: inhalation of suspended particulates based on limited exposure time
and limited exposed ground surface; inhalation of VOCs pathways based on the negligible risk. The site is not
currently used for residential, commercial/industrial, or excavation so these pathways and receptors were not
selected.

Subsurface Soil Current Exposure - No construction work involving excavation activities is currently in
progress in any areas of concern at the site. The site is also not used for residential or
commercial/industrial purposes.

Groundwater Current Exposure - No present use of groundwater were selected since these pathways are
incomplete.

Surface Water Current Exposure - The East Gill Creek is too shallow to support recreational activities such
as swimming and wading. Area residents/trespassers may dermally contact surface water while on-site;
however, they are expected to ingest a negligible amount of surface water and to inhale a negligible amount
of VOCs released from surface water into the ambient air.

Sediment Current Exposure - the surface water in East Gill Creek and the Wooded Wetland are too shallow to
support formal recreational activities. Area residents/trespassers may dermally contact sediment in East Gill
Creek and Wooded Wetland while on-site; however, they are expected to ingest a negligible amount of sediment.
Since the creek and Wooded Wetland have not been observed to dry out,  the amount of sediment particulates
released into the ambient air and subsequently inhaled is assumed to be negligible.

The potential exists, in the future, for residential development of the Forest Glen site. A list of the
potential exposure scenarios under the future scenario are listed below.

Surface Soil Future Use - Based on the potential residential future land use the potential exists for
residents  (children and adults) to come into direct contact with surface soil. The potential for construction
workers to come into direct contact with surface soil during the source of a normal work day was also
evaluated. Worker/employee exposure was not evaluated based on the land use. Exposure from the inhalation of
VOCs is assumed to be negligible, as released would not be into the ambient air and no VOCs were selected as
chemicals of potential concern.

Subsurface Soil Future Use - Based on the potential residential future land use, construction workers would
be expected to come into direct contact with the surface soil during excavation activities as a result of
mechanical disturbances. Inhalation of VOCs were not selected since they were not selected as chemicals of
concern. Based on land use site worker/employee exposure is not expected to occur. During potential future
construction work involving excavation activities, residents and area residents/ trespassers are assumed to
come into direct contact with a negligible amount of subsurface soil as compared to construction workers.

Groundwater Future Use - Under the residential land-use scenario the potential exists for residential wells
to be installed into the chemically contaminated zones beneath the site since the public water supply is not
currently available and may not be available in the future. Residents may ingest the contaminated groundwater
as well as inhale VOCs during such routine daily activities as cooking and showering. Dermal contact with and
absorption of chemicals during showering is assumed to be negligible due to low permeabilities. Site
workers/employees are not expected to be exposed under the residential
-------
scenario. Construction workers are not expected to ingest groundwater while on-site, nor are they expected to
shower on-site.

Surface Water Future Use - The East Gill Creek and Wooded Wetland are too shallow to support formal
recreational activities such as swimming and wading and therefore are not considered in the evaluation.
Future site residents may dermally contact the surface water in the vicinity of their homes, but are not
assumed to ingest the surface water. Exposure from the inhalation of VOCs is assumed to be negligible as
limited receptor contact with the surface water is assumed to occur and VOC released would be into the
ambient air.

Sediment Future Use - The East Gill Creek and the Wooded Wetland will remain too shallow to support formal
recreational activities in the future. Future residents may dermally contact sediment in these area; however,
they are expected to ingest a negligible amount of sediment. Based on the low probability of the Creek and
Wetland drying out, the amount of sediment particulates released into the ambient air and subseguently
inhaled is negligible.

Risk Characterization. Current federal guidelines for acceptable exposures are an individual lifetime excess
carcinogenic risk in the range of 10 -04 to 10 -06 which can be interpreted to mean that an individual may
have a one in ten thousand to a one in a million increased chance of developing cancer as a result of
site-related exposure to a carcinogen over a 70 year lifetime under the specific exposure conditions at the
site.

For non-carcinogens the potential adverse health effects are evaluated by comparing the exposure level over a
specified period of time (i.e., 30 years) with a Reference Dose (or concentration)  derived for a similar
exposure period. The ratio of exposure to toxicity is referred to as a hazard guotient; the sums of the
individual hazard guotients is referred to as a hazard index. To assess the overall potential for
noncarcinogenic effects posed by more than one contaminant, EPA has developed a Hazard Index (HI).  The HI
measures the assumed simultaneous subthreshold exposures to several chemicals which could result in an
adverse health effect. When the HI exceeds 1.0, there may be concern for potential noncarcinogenic health
effects.

A summary of the results of the risk assessment for cancer risks and non-cancer hazards are summarized below
based on the media and potentially exposed populations. Tables 8A and 8B summarizes the specific results for
each media where the risk range was exceeded. A summary of the risks from multiple pathways is presented in
TABLE 8 for carcinogenic and non-carcinogenic health effects.

Surface Soil. The risks to the present area residents/trespassers in Subdivision (AOC-6), Northern Aspect
(AOC-2); and Edgewood Drive Wooded Lots  (AOC-5) through ingestion and dermal exposures are all within EPA's
acceptable risk range for carcinogens and non-carcinogens previously described.

AOC6. For future residents the potential future residential surface soil ingestion in the Subdivision  (AOC-6)
shows total carcinogenic risks for adults and children are within the acceptable risk range. The non-cancer
hazards for future adult and child surface soil ingestion are 2.9 E-01 and 2.7 E+00, respectively.  The hazard
index value for children exceeds the USEPA's target level of 1. For children, manganese and mercury show a
combined hazard guotient of 1.4 E+00 and contribute nearly 52% to the hazard index. No other chemicals show
hazard guotients in exceedence of 1. The toxicity endpoint for manganese and mercury is the central nervous
system.

The potential future residential dermal contact with surface soil in AOC-6 is within EPA's acceptable risk
range. The hazard index values for potential future adult and child dermal contact with surface soil are also
within EPA's acceptable range.

The potential future residential indoor and outdoor surface soil inhalation in the Subdivision, shows total
carcinogenic risks for adults and children within the EPA acceptable risk range for cancer. The Hazard Index
values for potential future adult and child indoor and outdoor surface soil inhalation in AOC-6 are 4.7 E-01
and 2.2 E+00, respectively. The Hazard Index value for children exceeds USEPA's target level of 1.  Manganese
shows a hazard guotient of 2.2 E+00 and is associated with a toxicity endpoint of the central nervous system.
-------
Northern Aspect. The potential future residential surface soil ingestion from the Northern Aspect shows total
carcinogenic risks for adults and children within the acceptable risk range. The Hazard Index for potential
future children and adults are 1.5 E-01 and 1.4 E+00, respectively. The Hazard Index value for children
exceeds the USEPA's target level of 1. Manganese shows a hazard guotient of 5.8E-01 and contributes 41% to
the hazard index and is associated with effects on the central nervous system. No other chemicals exceed the
Hazard Index of 1.

For the Northern Aspect (AOC-2)  residents the potential future residential dermal contact with surface soil
shows total carcinogenic risks and Hazard Indices for adults and children within the EPA acceptable risk
range.

For the Northern Aspect (AOC-2)  potential future residential indoor and outdoor surface soil inhalation in
the Northern Aspects, shows total carcinogenic risks for adults and children within the acceptable risk
range.  The Hazard Index values for potential future adult and child indoor and outdoor surface soil
inhalation in the Northern Aspect are acceptable for adults and 1.9 E+00 for children. The Hazard Index value
for children exceeds EPA's target level of 1 for manganese. The Hazard Index for manganese is 1.9 and the
toxicity endpoint is central nervous system effects.
Edgewood Drive Wooded Lots - AOC-5.  The carcinogenic risk and non-carcinogenic hazard indices for
residents/trespassers in the Edgewood Drive Wooded Lots under the current use for surface soil ingestion are
within EPA's acceptable risk range.  The hazard index for present area residents/trespassers surface soil
ingestion falls below EPA's non-cancer target level of 1. The resident/trespasser dermal contact with surface
soil is within EPA's acceptable risk range. The hazard index for resident/trespasser dermal contact with
surface soil falls well below EPA's target level of 1.

Subdivision AOC-6. The potential future residential surface soil ingestion in the Subdivision, shows total
cancer risks for adults and children within EPA's acceptable risk range. The hazard index for potential
future adult and child surface soil ingestion is within the acceptable range for adults and exceeds the
range for children (2.7) .  For children, manganese and mercury show a combined hazard guotient of 1.4 and
contribute nearly 52% to the hazard index. No other chemicals show hazard guotients in exceedance of 1. The
toxicity endpoint for manganese and mercury is the central nervous system.

The potential future residential dermal contact with surface soil in the Subdivision, shows total
carcinogenic risk for adults and children within the acceptable risk range. The hazard index values for
potential adult and child dermal contact with surface soil are below EPA's target level of 1.

The potential future residential indoor and outdoor surface soil inhalation in the Subdivision shows total
carcinogenic risks for adults of children within the acceptable risk range. The hazard index values for
potential future adult and child indoor and outdoor surface soil inhalation in the Subdivision is within the
acceptable risk range for adults but exceeds for children. The hazard index for children is 2.2 and manganese
that effects the central nervous system is responsible for the unacceptable hazard.

Northern Aspect AOC-2. The potential future residential surface soil ingestion in the Northern Aspects, shows
total carcinogenic risks for adults and children within the acceptable risk range. The hazard index values
for potential future adult and child surface soil ingestion are acceptable for adults and exceed for
children. The hazard index value for children exceeds the EPA's target level of 1. Manganese shows a hazard
guotient of 0.58 and contributes 41% to the hazard index. No other chemicals show hazard guotients in
exceedance of 1. The toxicity endpoint for manganese is the central nervous system.

Potential future residential dermal contact with surface soil in the Northern Aspect, shows total
carcinogenic risks for adults and children within the acceptable risk range. The hazard index for potential
future and adult and child dermal contact with surface soil is within the acceptable hazard range.

Potential future residential indoor and outdoor surface soil inhalation in the Northern Aspects is within the
acceptable risk range. The hazard index values for potential future adult and child indoor and outdoor
surface soil inhalation in the Northern Aspect are acceptable for adults and exceed the range for children.
The hazard index value for children shows manganese is responsible for the entire hazard index of 1.9. The
-------
toxicity endpoint for manganese is the central nervous system.

Edgewood Drive Wooded Lots - AOC-5 The potential future residential surface soil ingestion in the Edgewood
Drive Wooded Lots shows a total carcinogenic risk for adults and children of 4.1 E-04 and 9.6 E-04,
respectively. For adults, benzo(a)pyrene and benzo(b)fluoranthene show individual risks of 3 E-04 and
4.5 E-05, respectively. Combined these two chemicals contribute greater than 84% of the total risk.

For children, benzo(a)pyrene and benzo(b)fluoranthene show individual risks of 7.0 E-04 and 1.0 E-04,
respectively. Combined these two chemicals contribute greater than 83% of the total risks. The combined risks
for adults and children is 1.4 E-03 and exceeds the EPA's target risk range.

The hazard indices for potential future adult and child surface soil ingestion are acceptable for adults and
are 1.9 for children. Manganese and mercury show a hazard guotient of 0.72 and contribute 40% to the hazard
index. No other chemicals show hazard guotients in exceedance of 1. The toxicity endpoint for
manganese and mercury is the central nervous system.

The potential future residential dermal contact with surface soil is within the acceptable risk range. The
hazard index values for potential future adult and child dermal contact with surface soil is within the
acceptable hazard range.

The potential future residential inhalation of surface soil are within the acceptable risk range for adults
and children. The hazard index for potential future adult and child inhalation of surface soil in the area
are acceptable for adults and slightly exceed the hazard range  (1.3) for children. Manganese is responsible
for the entire hazard index and effects the central nervous system.

Subdivision AOC6. The potential future construction worker surface soil ingestion, dermal, and inhalation of
surface soil are within the acceptable risk range and non-cancer hazard range.
Northern Aspect AOC2. The carcinogenic and non-carcinogenic hazard indices for the construction workers for
ingestion, dermal and inhalation of surface soil are with EPA's acceptable risk range.

Edgewood Drive Wooded Lots AOC5.  The results of the carcinogenic risk and non-carcinogenic hazard index
calculations for potential future construction workers are within EPA's acceptable risk range and
non-carcinogenic hazard index.

Subsurface Soil. The potential future construction worker subsurface soil ingestion, dermal and inhalation
exposures in Subdivision AOC-6, Northern Aspect AOC-2, Edgewood Drive Wooded Lots AOC-5, and Berm AOC-12 are
within the acceptable risk range for cancer and non-cancer health effects.

Groundwater. The potential future residential groundwater ingestion, shows total carcinogenic risks for
adults and children of 6.8 E-04 and 4.0 E-04, respectively. For adults vinyl chloride and
n-nitroso-di-n-propylamine show risks of 3.6 E-04 and 2.0 E-04 and represent 82% of the risk. The combined
risk for adults and children is 1.1 E-03 and exceeds the target risk range.

The hazard index values for potential future adult and child groundwater ingestion are 8.0 and 19.0,
respectively. For adults 1,2-dichloroethene  (total and manganese show individual hazard guotients of 4.0 and
1.6, respectively and represent 83% of the hazard. For children, 1,2-dichloroethene  (total),
hexachlorobutadiene, arsenic and manganese show individual hazard guotients which range from 1.2 to 9.25. The
chemical combined contribute greater than 82% to the total hazard.

The future adult residential inhalation of VOCs in groundwater based on the shower model are within the
acceptable risk range. A hazard index could not be calculated based on the lack of chronic inhalation
Reference Doses for VOCs.

Surface Water. The risks for area residents/trespassers dermal contact with surface water in the East Gill
Creek  (AOC-4) are within the acceptable risk range for cancer and non-cancer. The risks to potential future
residential dermal contact with surface water in East Gill Creek for cancer and non-cancer are
within the acceptable risk range.
-------
Sediment. The risks for present area resident/trespasser from dermal contact with sediment in East Gill
Creek,  Wooded Wetland AOC-3 and Wooded Wetland AOC-3 are within the acceptable risk range. The potential
future residential dermal contact with sediment in the East Gill Creek are also within the acceptable risk
range for cancer and non-cancer health effects.
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TABIiE 9 Summary of Carcinogenic Risks for Chemicals Triggering the Need for Cleanup
Media
Surface Soil
Edgewood
Drive Wooded
Lots  (AOC-5)
Exposure
Scenarios
That Trigger
the Need for
Cleanup

Adults - Future
Use Scenario

Surface Soil
Ingestion,
Dermal
Contact and
Inhalation of
Particulates

Children - 0-6
yrs.  Future
Use Scenario

Surface Soil
Ingestion,
Dermal
Contact and
Inhalation of
Particulates
                       Chemicals
                             Ingestion   Inhalation
                                                                                              Dermal
Benzo(a)anthracene
Benzo(a)pyrene
Benzo(b)fluoranthene
Dibenzo(a,h)anthracene
Indeno(1,2,3-cd)pyrene
Arsenic
Chromium VI
                                       Benzo(a)anthracene
                                       Benzo(a)pyrene
                                       Benzo(b)fluoranthene
                                       Dibenzo(a,h)anthracene
                                       Indeno(1,2,3-cd)pyrene
                                       Arsenic
                                       Chromium VI

                                       Total
3,
3,
4,
1.
8,
8,
6,
4,
8,
7,
1.
3,
.4
.0
.5
.5
.6
.8
.8
.1
.0
.0
.0
.5
E-05
E-04
E-05
E-05
E-06
E-06
E-07
E-04
E-05
E-04
E-04
E-05
                             2.0 E-05
                             2.0 E-05
                                                                    9.6 E-04
                                                                                3.4 E-07
                                                                                3.4 E-07
                                         1.5 E-06
                                                                                1.5 E-06
                                                                                              5.1 E-06
                                                                                              5.1 E-06
                                                       4.0 E-07
                                                       8.0 E-07

                                                       1.2 E-06
                                                                                                          Exposure
                                                                                                          Routes Total
3.4 E-05
3.0 E-04
4.5 E-05
1.5 E-05
8.6 E-06
1.4 E-05
                                                                   4.2 E-04

                                                                   8.0 E-05
                                                                   7.0 E-04
                                                                   1.0 E-04
3.5 E-05
2.0 E-05
2.2 E-05
8.0 E-07
                                                                                                          9.6 E-04
                Combined
                Children and
                Adults
                                                    1.4 E-03
                                                                6.5 E-06
                                                                              2.2 E-06
                                                                                          1.4 E-03
-------
Media
Groundwater
(on-site)
Exposure
Scenarios
That Trigger
the Need for
Cleanup

Adult
Residents
Future Use
Scenario
                Child (0-6 yrs)
                Residents
                Future Use
                Scenario
                   TABIiE 9 - Continued.

                       Chemicals
                                      Vinyl Chloride
                                      Benzo(a)pyrene
                                      Hexachlorobutadiene
                                      N-nitroso-di-N-
                                      propylamine
                                      Arsenic

                                      Total
                      Vinyl Chloride
                      Benzo(a)pyrene
                      Hexachlorobutadiene
                      N-nitroso-di-N-
                      propylamine
                      Arsenic
Ingestion   Inhalation
                                                                                              Dermal

3.6
4.8
3.3
2.0
7.6
6.8

2.1
2.8
1.9
1.2
4.4

E-04
E-05
E-06
E-04
E-05
E-04

E-04
E-05
E-06
E-04
E-05
Showering
6.3 E-05




6.3 E-05
Showering
NA




                          NA
                          NA
                                                                                                          Exposure
                                                                                                          Routes Total
                                     4.2 E-04
                                     4.8 E-05
                                     3.3 E-06
                                     2.0 E-04

                                     7.6 E-05

                                     7.4 E-04
                                     2.1 E-04
                                     2.8 E-05
                                     1.9 E-06
                                     1.2 E-04
                                     4.4 E-05
                                      Total
                                                                    4.0 E-04
                                                                                                         4.0 E-04
                Adults and
                Children
                                                                    1.1 E-03
                                                                                6.3 E-05
                                                                                              NA
                                                                                                         1.2 E-03
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TABIiE 10 Risk Characterization Summary - Non-Carcinogens
Media
Surface Soil
Subdivision
(AOC6)
Exposure
Scenarios
That Trigger
the Need for
Cleanup

Children (0-6
yrs) - Future
Scenario

Ingestion of
Soil, Dermal
Contact with
Soil and
Inhalation of
Particulates
                       Chemicals
                             Ingestion   Inhalation
                                                                                              Dermal
2-Mercapto-benzothiazole
N,N-diphenyl-l,4 -
Benz enedi amine
Aroclor 1254
Arsenic
Barium
Beryllium
Cadmium
Chromium VI
Manganese
Mercury
Vanadium
Zinc
0.006
0.55

0.045
0.27
0.061
0.0024
0.10
0.13
0.65
0.73
0.083
0.038
                                                                                0.0064
                                                                                0.02
                                                                                              2.2
                                                                                              0.0015
                                                                                                          Exposure
                                                                                                          Routes Total
0.006
0.55

0.051
0.29
0.061
0.0024
0.10
0.13
2.85
0.73
0.083
0.038
                                       Total
                                                                                0.03
                                                                                                          4.9
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                                  TABLE 10 - Continued.
Media


Surface Soil
Subdivision
Northern
Aspect
(AOC2 )


Exposure
Scenarios
That Trigger
the Need for
Cleanup
Children (0-6
yrs) - Future
Scenario
Ingestion of
Soil,
Inhalation of
Particulates,
Dermal
Contact with
Soil
Chemicals


Aroclor 1254
Antimony
Arsenic
Barium
Beryllium
Chromium VI
Manganese
Mercury
Thallium
Vanadium
                                                                    Ingestion   Inhalation
                                                                              Dermal
                                                                    0.015
                                                                    0.082
                                                                    0.29
                                                                    0.051
                                                                    0.0023
                                                                    0.039
                                                                    0.58
                                                                    0.033
                                                                    0.22
                                                                    0.094
                                                                              0.0022

                                                                              0.021
                                                                1.9
                                                                0.000076
                                                                                          Exposure
                                                                                          Routes Total
                                                                   0.015
                                                                   0.082
                                                                   0.31
                                                                   0.051
                                                                   0.0023
                                                                   0.039
                                                                   2.48
                                                                   0.033
                                                                   0.22
                                                                   0.094
                                       Total
                                                                    1.4
                                                                                1.9
                                                                                              0.023
Surface Soil
Edgewood
Drive Wooded
Lots
(AOC 5)
Children (0-6
yrs)  - Future
Scenario
Ingestion of
Soil,
Inhalation of
Particulates,
Dermal
Contact with
Soil
Fluoranthene
Pyrene
N,N-Diphenyl-l,4-
Benz enedi amine
Arsenic
Barium
Chromium VI
Manganese
Mercury
Nickel
Thallium
0.042
0.055
0.062

0.53
0.042
0.023
0.40
0.32
0.055
0.02
0.038
                                                                                1.3
                                                                                0.00073
0.042
0.055
0.062

0.568
0.042
0.023
1.7
0.32
0.055
0.02
                                       Vanadium
                                       Total
                                                    0.15
                                                    1.9
                                                                                1.3
                                                                                              0.038
                                                                   0.15
                                                                   2.2
-------
Media
Groundwater
Site-Wide
Exposure
Scenarios
That Trigger
the Need for
Cleanup

Adults - Future
Scenario

Ingestion and
Inhalation
While
Showering
                  TABLE 10 - Continued.

                       Chemicals
1,2-Dichloroethene  (Total)
Hexachlorobutadiene
Trichloroethylene
arsenic
Chromium VI
Manganese
Mercury
Nickel
Silver
Vanadium
                              Ingestion   Inhalation
                                                                                              Dermal
4.0
0.62
0.35
0.49
0.12
1.6
0.3
0.14
0.24
0.15
No
Toxicity
Values
Available
for VOCs
                                                                                              NA
                                                                                                          Exposure
                                                                                                          Routes Total
4.0
0.62
0.35
0.49
0.12
1.6
0.3
0.14
0.24
0.15
                                      Total
Groundwater
Site-Wide
Children  (0-6
yrs)

Future
Scenario
Ingestion
1,2-Dichloroethene  (Total)    9.2
Hexachlorobutadiene           1.4
Trichloroethylene             0.81
arsenic                       1.2
Chromium VI                   0.27
Manganese                     3.7
Mercury                       0.7
Nickel                        0.32
Silver                        0.57
Vanadium                      3.5
                                                                                NA
                                                                                              NA
                                      9.2
                                      1.4
                                      0.81
                                      1.2
                                      0.27
                                      3.7
                                      0.7
                                      0.32
                                      0.57
                                      3.5
                                      Total
                                                                    19.0
                                                                                                          19.0
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Table 11 - Summary of Total Risk Based on Exceedance of Risk Range

                      Carcinogenic Risks

Area                                    Cancer Risks  (Adults and Children)

Surface Soil - Edgewood Drive           1.4 E-03
Wooded Lots - AOC-5

Groundwater                             1.2 E-03

  Total Risks                           2.6 E-03

                      Non-Cancer Hazards

                                        Children

Surface Soil - AOC 6                    4.9

Groundwater (Site-Wide)                 19.0

  Total Hazard                          23.9

Surface Soil - AOC-2                    2.2

Groundwater (Site-Wide)                 19.0

  Total Hazard                          21.2

Groundwater (Site-Wide) - Adults        8.0

Groundwater (Site-Wide) - Children      19.0

  Total Hazard - Groundwater            27.0
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Uncertainties

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

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

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

Uncertainty in the exposure assessment is 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.

Uncertainty in toxicological data occurs in extrapolating both from animals to humans and from high to low
doses of exposure, as well as from 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 baseline risk assessment provides upper bound estimates of the risks to future populations
at the site and is highly unlikely to underestimate actual risks related to the Site.
-------
                                APPENDIX VI

                           RESPONSIVENESS SUMMARY

                        FOREST GIiEN SUBDIVISION SITE

1.0  INTRODUCTION

A responsiveness summary is required by Superfund regulation. It provides a summary of public comments and
concerns received during the public comment period, and the United States Environmental Protection Agency
(EPA) and the New York State Department of Environmental Conservation's  (NYSDEC) responses to those comments
and concerns. All comments summarized in this document have been considered in EPA and NYSDEC's final
decision for the selected remedy for the Forest Glen Subdivision Site.

This Responsiveness Summary is organized into the following sections:

2.0  SUMMARY OF COMMUNITY RELATIONS ACTIVITIES

This section summarizes the involvement of EPA as the lead agency for community relations at the Site.

3.0  SUMMARY OF COMMENTS RECEIVED DURING PUBLIC MEETING AND EPA'S RESPONSES

This section summarizes verbal comments submitted to EPA by local residents at the public meeting and
provides EPA's responses to these comments.

4.0  SUMMARY OF WRITTEN COMMENTS AND EPA'S RESPONSES

This section summarizes written comments submitted to EPA during the public comment period and EPA's
responses to these comments.

5.0  APPENDICES

There are five appendices attached to this document. They are as follows:

         Appendix A -  Proposed Plan

         Appendix B -  Public Notices published in the Niagara Gazette

         Appendix C -  September 24, 1997 Public Meeting Attendance Sheets

         Appendix D -  September 24, 1997 Public Meeting Transcript

         Appendix E -  Letters Submitted During the Public Comment Period

2.0  SUMMARY OF COMMUNITY RELATIONS ACTIVITIES

Community involvement at the site has been relatively strong. EPA has served as the lead agency for community
relations and remedial activities at the site.

The Proposed Plan for the soil contamination at the site was released to the public for comment on September
24, 1997. This document, together with the Remedial Investigation report, the Feasibility Study, the
Endangerment Assessment (Human Health and Ecological Risk Assessment) and other reports, were made
available to the public in the Administrative Record file at the EPA Docket Room in Region II,  New York, and
at the EPA Public Information Office, 345 Third Street, Niagara Falls, New York.

The notice of availability for the above referenced documents was published in the Niagara Gazette on
-------
September 24, 1997. On October 1, 1997, a similar notice was sent to the addressees on the site mailing list
and copies of the Proposed Plan were hand delivered to the residents of Expressway Village. Another    notice
was placed in the Niagara Gazette on October 21, 1997, to extend the comment period through November 24,
1997. A final notice was placed in the Niagara Gazette on November 20,  1997, announcing another extension of
the public comment period to December 8, 1997.

On October 15, 1997, EPA conducted a public meeting at the Niagara Fire Company No. 1 at 6010 Lockport Road,
Niagara Falls, New York to discuss the Proposed Plan and to provide an opportunity for the interested parties
to present comments and guestions to EPA.

3.0  SUMMARY OF COMMENTS RECEIVED DURING PUBLIC MEETING AND EPA'S RESPONSES

Comments expressed at the September 24, 1997 public meeting and EPA's responses to these comments are
presented as follows:

Comment #1: A citizen asked who will pay for the costs of the remedial action at the site?

EPA's Response: It is EPA's intent to ask the potentially responsible parties (PRPs) for the site to perform
the remedial action. If the PRPs refuse, EPA can order the PRPs to implement the remedy, or use Superfund
monies for this purpose, and later recover these costs from the PRPs.

Comment #2: A citizen asked who placed the contaminated materials at the site?

EPA's Response: While it is not known exactly "who placed the contaminated materials at the site," under the
Superfund statute, those liable and potentially responsible for the contamination include waste generators,
haulers and site owners. Those who sent waste to the site include The Goodyear Tire and Rubber Company
(Goodyear). Those who hauled waste include Walter S. Kozdranski. EPA's PRP search is not    concluded.

Comment #3: A citizen asked if any investigation was performed at Veterans' Heights, a neighborhood to the
northeast of the site?

EPA's Response: Veterans' Heights is a neighborhood located northeast of the site, across the interstate
highway, 1-190, and on the west side of Military Road. Aerial photographs did not indicate that waste
disposal occurred in Veterans' Heights. Therefore, it was not included as part of the investigation at the
Forest Glen site.

Comment #4: A resident of the Expressway Village trailer park located south of the Forest Glen site asked if
there were plans to perform additional testing in this trailer park.

EPA's Response: Soil sampling performed during the RI/FS indicates that the area of the Forest Glen
Subdivision adjacent to Expressway Village is not contaminated. This is consistent with historical evidence,
including aerial photographs, which indicate that no dumping occurred at Expressway Village. EPA  has
performed two soil-sampling events at this trailer park and no indication of hazardous waste disposal was
found. As a result, EPA is not planning to perform additional testing at Expressway Village.

Comment #5: A citizen asked if there would be any reassessment of the health studies which were performed a
few years ago?

EPA's Response: The New York State Department of Health (NYSDOH) interviewed the residents of the Forest Glen
Subdivision during 1989 and 1990 to obtain information about their health concerns, medical conditions, and
potential exposures. The full-time residents who were interviewed were invited to take part in a medical
evaluation which was conducted in April 1990 at the Union Occupational Health Clinic in Buffalo. In addition,
11 former residents who lived at Forest Glen for 10 years or more participated in the evaluation. The
evaluation included: a medical history guestionnaire, physical examination, urinalysis, blood analysis, and
pulmonary function tests. The physical examination results and laboratory results were provided to the
residents and their personal physicians. In 1994 and early 1995, a follow-up health interview was conducted
that asked for information similar to that collected in the 1989-1990   interviews. NYSDOH is currently
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evaluating the information and compiling a report.

Comment #6: A citizen was concerned with the levels of mercury at the site.

EPA's Response: Mercury was detected as high as 25.6 mg/kg in site soils. Conseguently, potential exposures
from mercury for children, adults and trespassers were evaluated. It was determined that mercury is not a
major contributor to the human health risk, but does contribute somewhat to the noncarcinogenic risk at the
site. The selected remedy includes the consolidation of contaminated soils and the placement of a Part 360
cap over the consolidated soils, together with institutional controls to prohibit activities which may
compromise the integrity of the cap. As a result, future exposures to mercury and other site-related
contaminants will be prevented.

Comment #7: A citizen wanted to know how deep the waste is at the site and where the water table is in
relation to the waste.

EPA's Response: The waste is estimated to be as deep as 12 to 15 feet below the surface in some areas. The
waste is not in contact with the water table which is approximately 30 feet deep.

Comment #8: A citizen wanted to know if an impermeable liner would be placed under the waste?

EPA's Response: No. An impermeable cap will be placed on top of the contaminated soils to prevent the
infiltration of rain water into the soil, thereby preventing the formation of leachate caused by the
percolation of rain water through the contaminated soils.

Comment #9: A citizen was concerned that the impermeable cap would not be keyed into the native clay at the
site.

EPA's Response: The impermeable cap will be keyed into the native clay.

Comment #10: A citizen asked how long the cap will remain in place?

EPA's Response: The cap is designed to remain in place indefinitely. After construction, the cap will be
routinely inspected and repaired as necessary, to ensure its long-term effectiveness.

Comment #11: A citizen wanted to know what was meant by the "productive" use of the land.

EPA's Response: "Productive use" means that the land can be used in accordance with local zoning which is a
determination made by local government, not EPA. In developing remedies for sites, EPA, in accordance with
its Land Use Guidance, considers the historical and current land use and particularly, the  reasonably
anticipated future land use of a property.

4.0  SUMMARY OF WRITTEN COMMENTS AND EPA'S RESPONSES

Written comments received during the public comment period have been categorized as follows:

           I. Operable Unit Two (OU-2) Remedy Selection Issues

          II. Land-Use Decisions

         III. Risk Assessment

Many of the comments that follow were submitted by Goodyear, a PRP for the site. Additional comments were
submitted by the City of Niagara Falls, the Town of Niagara, as well as individual citizens.

I.   Operable Unit Two (OU-2) Remedy Selection Issues

Comment #12: The Chairman of the Town of Niagara Environmental Commission  (EC) commented that the preferred
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alternative  (Alternative S-4, Excavation, Consolidation and On-site Disposal) was not acceptable to the EC
because it only allows for partial reclamation of the land. In addition, the EC was not in favor of the
creation of a 30-foot mound associated with this alternative. The EC considered Alternative S-5,
Excavation and Off-site Disposal, to be a better choice, since it would involve the removal of all
contaminated materials and debris from the site and would not result in a 30-foot mound. Several commenters
presented this same view.

EPA's Response: Each remedial alternative was assessed by EPA utilizing the nine criteria set forth in the
National Continency Plan. Overall protection of human health and the environment and compliance with
"applicable and relevant and appropriate requirements"  (ARARs) are the two threshold criteria which must be
met. The five balancing criteria are long-term effectiveness and permanence, reduction of toxicity,
mobility or volume through treatment, short-term effectiveness, implementability and cost. The two modifying
criteria are state and community acceptance.

All of the action alternatives  (i.e., Alternatives S-3 through S-6) were considered to be protective of human
health and the environment and could meet ARARs. However, EPA believes that the selected remedy, Alternative
S-4, Excavation, Consolidation and On-site Disposal, provides the best balance of the   remaining criteria
with respect to its cost.

The cost of excavating all the contaminated material and disposing of it off-site, as included in Alternative
S-5, was estimated to be approximately $106 million. EPA has recognized that removal of large volumes of
waste such as contained in municipal landfills or other large disposal sites similar to Forest Glen, can be
excessively costly and not practical. As a result, in 1993, EPA issued the guidance document, Presumptive
Remedy for CERCLA Municipal Landfill Sites  (OSWER Directive No. 9855.0-49FS), which indicates that proper
closure and capping is an effective means of protecting public health and the environment for landfills and
other large disposal areas. The selection of Alternative S-4 as the appropriate remedy for the site is
consistent with this guidance. Upon completion of the construction of a cap, a long-term    maintenance
program will ensure that the cap does not fail. In addition, EPA will be reviewing the site at five-year
intervals to ensure that the remedy remains protective of public health and the environment.
The estimated 30-foot height of the mound of materials that will be consolidated on the Northern Aspect is
based on preliminary conceptual design calculations and is intended to restore the maximum amount of land to
productive use. While the cap will restrict the development of the northern portion of the site, the selected
remedy will allow the southern portion of the site to be returned to productive use.

Comment #13: Goodyear commented that it could support Alternative S-2, Limited Action, however, it was
reluctant to endorse a remedy that rendered the site permanently unusable.

EPA's Response: EPA agrees that the site should be restored to productive use in the future. The selected
remedy enables portions of the site to return to productive use.

Comment #14: Goodyear made several comments regarding groundwater contamination and believes that a
ground-water source control remedy is not appropriate for the site. Goodyear contends that the ground-water
contamination at the site is not associated with the contaminated fill, but rather is caused by another
source. In addition, Goodyear also commented that contaminant concentrations in the soil are too low to
produce the concentrations of contaminants in the ground water and the clay layer beneath the site should
prevent the contaminants from leaching into the ground water. Lastly,  Goodyear believes that the correlation
between the contaminants in the soil and those in the ground water is weak because the contamination in  the
ground water is different from that in the soil.

Goodyear proposed a remedy that would include covering approximately nine acres of the site with a permeable
geotextile and soil cover to eliminate the dermal contact exposure to site soils. In the future, if the site
were to be developed commercially (if the residential zoning is changed),  a hard cover, such as buildings and
parking areas would be placed on the geotextile/soil cover.

EPA's Response: The remedy proposed by Goodyear would not be protective of the ground-water resources. Site
data indicate that the ground-water contamination is directly related to the contaminated fill at the site.
Therefore, a primary objective of the soils remedy is to eliminate the contaminated soils as a source of
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contamination to the ground water. The supporting data are contained in the RI/FS and the administrative
record.

The ground water upgradient from the site is not contaminated. However, the ground water beneath the site is
above Maximum Contaminant Levels  (MCLs).  The highest contaminant concentration in the ground water was
detected at monitoring well MW-5, which is immediately downgradient of the highest levels of contamination in
the soil in the Subdivision. The ground-water contamination drops off downgradient of the site. This
information indicates that the ground water is being impacted by the site.

The clay layer which was observed throughout the site is at its thinnest in the area of monitoring well MW-5
where the greatest ground-water contamination exists. Clay does not completely prevent water moving through
it, but rather retards the movement of water. However slowly, water does travel through the clay. It is also
possible that the clay layer may be breached in an area where no samples were taken.

Contaminants found in site soils have been detected in the ground water. The soils at the site have been
characterized in the Remedial Investigation  (RI).  Due to the uneven distribution of chemicals at the site and
the limited number of samples taken during the RI,  a direct correlation between the concentrations in the
soil to that in the ground water would not be expected. In addition, hot spots were covered during an  EPA
removal action in 1989. The soil under these covered areas was not resampled as part of the RI sampling
effort. Nonetheless, these highly elevated contaminant areas remain on the site. Lastly, compounds degrade
during their residence time in the site soils resulting in the generation of new    contaminant break-down
products.

Contaminants identified in the ground water are very similar to those identified in the site soils,
especially the more soluble volatile organic compounds (VOCs) . The primary VOCs in the groundwater include
vinyl chloride, 1,2-dichloroethene, 1,1-dichloroethane, trichloroethene, and xylene. The very same  compounds
were identified in soil sampling performed by NUS Corporation in 1987 and 1988. Concentrations of these
compounds in onsite and downgradient monitoring wells have increased based on the 1995 and 1997 sampling
events. Further, these VOCs are not present in the "upgradient monitoring wells on the eastern site boundary.
Therefore, EPA concludes that the site soils are a source of contamination to the ground    water.

Comment #15: Goodyear commented that the New York State Technical and Administrative Guidance Memorandum
(TAGM)  values were used inappropriately in the Feasibility Study.

EPA's Response: EPA utilized TAGMs appropriately in the Feasibility Study and subseguently in the Proposed
Plan. TAGMs are recommended cleanup objectives devised by New York State that are protective of the ground
water.  Once EPA determined that an unacceptable risk existed at the site, TAGMs were used as cleanup
objectives for the soil.
Superfund remedial actions must meet any Federal standards, reguirements, criteria or limitations that are
determined to be legally "applicable or relevant and appropriate" (ARARs). TAGMs are not ARARs, but "to be
considered" (TBC)  guidance. There are no ARARs that specify cleanup levels in soils. However, EPA
consistently considers TAGM cleanup objectives in developing remedial actions at Superfund sites.

II. Land-Use

Comment #16: A member of the office of the City Council of the City of Niagara Falls and the Supervisor of
the Town of Niagara commented that the preferred alternative  (S-4)  identified in the Proposed Plan is based
upon a presumed residential use of the site. These commenters stated that the most productive use    of this
site would be commercial, not residential. The councilperson indicated her intent to initiate formal action
to rezone the site as commercial property. Goodyear also commented that the "most appropriate future use of
the site is commercial/industrial."

EPA's Response: EPA's land use guidance is summarized in OSWER Directive No. 9355.7-04. This guidance
reguires that EPA consider current and "reasonably anticipated" future land use designations, along with
community concerns. The guidance also refers to "productive" land use. The current land use designation of
the Subdivision is residential. The Subdivision area was used historically as a trailer park before the site
was placed on the National Priorities List. EPA contacted the City Planner for the City of Niagara Falls by
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telephone in April 1997 to determine if the City had any plans to change the zoning of the Subdivision.  The
City Planner responded to EPA that the City of Niagara Falls had no plans to change the    zoning of the
Subdivision area of the site.

The zoning of the Northern Aspect is designated as commercial/industrial. However,  plans are registered with
the City of Niagara Falls which state the intent of the owner, Niagara Falls USA Campsites,  Inc., to develop
the land in the future as a campground.

It is EPA's understanding that the surrounding land may be designated as commercial/industrial,  but no
actions have been taken at this time by any local authority to change the zoning for the Forest Glen
Subdivision to commercial/industrial. On the basis of the current land use,  discussions with local  planning
officials and the lack of any proposals to the local zoning commissions to change this designation, EPA
determined that the site should be assessed as a residential property in terms of risk and the appropriate
cleanup standards. In addition, the commercial/industrial classification is not the    sole determinative of
the actual land use,  as evidenced by the property where a commercially/ industrially-zoned area is being used
as a trailer park for residential use  (Expressway Village).  The actual zoning of Expressway Village may be
commercial, yet it is being used residentially. This information supports the determination that based on the
current land use, the historical activities at the site and expressed future plans, the residential land use
designation is appropriate. It is further noted that cleanup to residential standards would not be
inconsistent with subseguent usage as   commercial/industrial, if the zoning is changed.

Subseguent to receiving the comment from the city councilperson, EPA met with the Mayor of Niagara Falls and
his staff to determine if the City of Niagara Falls concurred that the residential zoning of the Subdivision
should be changed to commercial. The Mayor asserted that the City had no intentions to change the residential
zoning of the former Forest Glen Subdivision to commercial zoning.

III. Risk Assessment

Comment #17: Goodyear states in its comments that error was introduced into the risk assessment by the manner
in which the background levels of the inorganic compounds, notably arsenic,  manganese and beryllium were
addressed. Goodyear believes that these inorganic compounds are part of the naturally occurring soil at the
site.

EPA's Response: The risk assessment was performed in accordance with current policy and guidance, including
Risk Assessment Guidance for Superfund (RAGS-EPA/540/1-89/002).  Site-specific data are usually compared to
local background to ensure that there are no anomalies in the background at the site from    nonsite-related
chemicals. In the absence of regional geographic soil data,  the background concentrations at the site were
compared to background inorganic surface soil and subsurface soil results from the Eastern United States and
New York State. The lack of more geographic-specific background information may potentially underestimate
risks since the Forest Glen soil conditions may differ from conditions in the    Eastern U.S. or New York
State. The inorganic compounds included in the risk assessment were found to be present in site soil and
sediment at more than twice their background levels.

The selection of chemicals of potential concern for the site was based on a number of criteria as outlined on
page 22 of the Final Endangerment Assessment for the Forest Glen Site. These criteria were used for the
determination of the inclusion of arsenic, manganese and beryllium as chemicals of potential concern. As
indicated in Chapter 2 of the Final Endangerment Assessment for the Forest Glen Site, arsenic and beryllium
were retained as chemicals of concern based on the concentration-toxicity screening, freguency of detection
and toxicity. Review of the risk assessment results indicates that the risks and hazards from these chemicals
are within EPA's acceptable risk range and are not primary risk drivers. Arsenic is a  class A carcinogen,
and RAGS states that it should be retained in the risk assessment.

Manganese was evaluated based on the concentration-toxicity screening, freguency of detection and toxicity as
was developed for arsenic and beryllium.  For manganese, the hazard index was exceeded in the Subdivision for
children  (HI = 2.2),  for surface soil inhalation for Northern Aspect child residents (HI    = 1.9), surface
soil inhalation for future child residents at the Edgewood Drive Wooded Lots (HI = 1.3) and for adult
resident ingestion of groundwater (HI = 1.6) and children (HI = 3.7). These findings indicate a potential
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hazard to both adults and children through two different pathways from exposure to manganese.

On-site ground-water concentrations were compared to upgradient ground water as background. Based on the
concentration-toxicity screening, freguency of detection and toxicity, these chemicals were evaluated for
potential risks through ingestion of contaminated water. The primary risk drivers for ground-water
contamination, however, were vinyl chloride and n-nitroso-di-n-propylamine for adults and children based on
carcinogenic risks. For noncancer risks, the main contributors were 1,2-dichloroethene (total)  and manganese
for adults and 1,2-dichloroethene (total), hexachlorobutadiene, arsenic and manganese for children. Of those
chemicals exceeding the risk range,  the volatile organics contributed a higher percentage to the risks and
hazards than did the metals.

Comment #18: Goodyear guestioned the risk assessment and the subseguent use of the results of the risk
assessment in the Feasibility Study for each area of concern. Goodyear commented that the carcinogenic risk
in the Subdivision area was within EPA's target risk range. Goodyear indicated that the HI would be less than
one, and therefore acceptable, if a commercial/industrial scenario were utilized in the risk assessment.
Goodyear also commented that the value used in the risk assessment for benzo(a)pyrene, which was the 95%
Upper Confidence Limit (UCL),  was higher than most of the values reported for benzo(a)pyrene.

EPA's Response: The carcinogenic risk in the Subdivision is within EPA's target risk range. However, the HI
for a child for this area is 6.9, which is above EPA's acceptable level. When an HI is above 1.0, there may
be a concern for potential noncarcinogenic health effects. The risk assessment was performed using a
residential scenario, since the historical use of the Subdivision was residential, and so is its reasonably
anticipated future use. (See response to Comment #16). The concentration term in a risk assessment is used in
calculating what a receptor may have been exposed to  (exposure assessment).  The Supplemental Guidance to
RAGS: Calculating the Concentration Term  (Publication 9285.7-081), dated May    1992, states: "Because of the
uncertainty associated with estimating the true average concentration at a site, the 95 percent upper
confidence limit (UCL) of the arithmetic mean should be used for this variable." The 95% UCL was used in
accordance with the guidance in the Final Endangerment Assessment for the Forest Glen Site.

In addition to the risk from surface contact with the site soils, the ground-water contamination underlying
the site must be addressed. Source control measures are necessary to prevent further degradation of
ground-water guality from contaminated soils, as ground-water contaminant levels are above MCLs. The
contaminant levels in the soil exceed the concentrations identified in NYSDEC's recommended soil cleanup
objective (TAGM values) which are designed to protect the ground water.

Comment #19: Goodyear guestioned the risk assessment for the Northern Aspect and the subseguent use of the
results of the risk assessment in the Feasibility Study. Goodyear states that the carcinogenic risk for the
Northern Aspect was within EPA's target risk range. Goodyear stated that the residential future-use scenario
was inappropriate for this area of the site, since it is zoned commercial/industrial. Goodyear    indicates
the HI would be below one if a commercial/industrial future-use scenario had been used in the risk
assessment.  In addition,  Goodyear asserts that the calculated risk values are not indicative of a chemical
waste problem in the Northern Aspect.

EPA's Response: The carcinogenic risk for the Northern Aspect is within EPA's acceptable risk range, but the
noncarcinogenic HI for children is 5.4, which is above the level of 1 at which there may be a concern for
potential noncarcinogenic health effects. The risk assessment, as previously discussed in the response to
comment 16,  was performed utilizing a residential future-use scenario because plans are registered with the
City of Niagara Falls which state the intent of the owner, Niagara Falls USA Campsites, Inc., to develop the
land in the future as a campground.

However, even if the risk from surface contact with the site soils had not indicated the need to take an
action, the degradation of the ground-water guality underlying the site must be addressed. Organic compounds
were detected in the Northern Aspect fill at concentrations ranging up to 27,000 ppb
(2-anilinobenzothiazole),  while PAH concentrations exceeded TAGM cleanup goals by more than 40 times for
benzo(a)pyrene.

Comment #20: Goodyear commented that there was no need to remediate the Berm,  as both the carcinogenic and
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non-carcinogenic risks are within EPA's acceptable risk range.

EPA's Response: The carcinogenic and noncarcinogenic risks are within EPA's acceptable risk range. However,
organic compounds were detected in the soils in this area at concentrations up to 1,100,000 ppb
(2-mercaptobenzothiazole) and PAHs exceeded TAGM cleanup goals by more than 60 times for benzo(a)pyrene.
Phenol exceed TAGMs in the Berm by more than 300 times. Mercury concentrations ranged up to 135 times the
TAGM cleanup goal. A remedial action is necessary for the Berm in order to protect the underlying ground
water.

Comment #21: Goodyear guestioned the risk assessment for the Edgewood Drive Wooded Lots and the subseguent
use of the results of the risk assessment in the Feasibility Study. Goodyear commented that a single high
detection for benzo(a)pyrene of 88 mg/kg was used as a concentration term in the risk assessment.

EPA's Response: The risk assessment was performed according to EPA guidance. The Supplemental Guidance to
RAGS: Calculating the Concentration Term  (Publication 9285.7-081), dated May 1992, states that a maximum
value should be used as an exposure concentration in a risk assessment, if the 95% Upper Confidence Limit
(UCL) calculation exceeds the maximum reported value. For the surface soil of the Edgewood Drive Wooded Lots,
the UCL for benzo(a)pyrene was calculated to be 281 mg/kg, which exceeds the maximum value reported  (88
mg/kg).

Comment #22: Goodyear guestioned the risk assessment for the Wooded Wetland and the subseguent use of the
results of the risk assessment in the Feasibility Study.

EPA's Response: The human health risk assessment determined that the carcinogenic and noncarcinogenic risks
in the Wooded Wetland are within EPA's acceptable risk range. However, the ecological risk assessment
determined there were potential ecological risks present in the Wooded Wetland sediments. The    Wooded
Wetland may also be an intermittent source of contamination to East Gill Creek. For these reasons, the Record
of Decision (ROD) specifies that six inches of clean sediment will be placed over the Wooded Wetland which
will ensure the contaminated sediments are not bioavailable to the local wildlife receptors.

Comment #23: Goodyear guestioned the risk assessment for East Gill Creek and the subseguent use of the
results of the risk assessment in the Feasibility Study.

EPA's Response: The results of the risk assessment show that the risks, both carcinogenic and
noncarcinogenic, from ingestion, inhalation and dermal contact of East Gill Creek sediments are within EPA's
acceptable risk range. However, the ecological risk assessment determined there were potential    ecological
risks present in the East Gill Creek sediments. In addition, these sediments have concentrations of
contaminants above the cleanup objectives identified in the NYSDEC Technical Guidance for Screening
Contaminated Sediments. East Gill Creek may also serve as a contaminant migration pathway during times of
high flow.

Comment #24: Goodyear commented that EPA did not adeguately evaluate the data from the site in developing the
exposure concentration term in the risk assessment.

EPA's Response: In developing the exposure concentration, EPA used RAGS and appropriate supplemental
guidance. In the Supplemental Guidance to RAGS: Calculating the Concentration Term (EPA/9285.7-081), it is
stated:

        "Because of the uncertainty associated with estimating the true average concentration at a site,
        the 95% upper confidence limit (UCL) of the arithmetic mean should be used for the concentration
        term."

This guidance further states:

       "For exposure areas with a limited amount of data or extreme variability in measured or modeled
       data, the UCL can be greater than the highest measured or modeled concentration. In these cases, if
       additional data cannot practicably be obtained, the highest measured or modeled value could be used
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       as the concentration term."

The determination of the appropriate data for the calculation of the exposure point concentration was based
on the number of samples collected and the representativeness of the data. In those cases where there were a
small number of samples, the maximum concentration was used as outlined in the guidance.    Where there were
an adequate number of samples and the 95% UCL exceeded the maximum concentration, the maximum concentration
was used as outlined in the guidance. Where there were an adequate number of samples and the 95% UCL was less
than the maximum,  the 95% UCL was used as the exposure point concentration.

Comment #25: Goodyear commented that the potential exposures to the various portions of the site would not
have the same probability.

EPA's Response: As stated on page 11 of the Final Endangerment Assessment, the future-use scenario assumes
future development of the three areas (Northern Aspect, Edgewood Drive Wooded Lots and the Subdivision) at
the same time since they are in close proximity to each other. Based on the relatively small size of each
individual area, the number of samples,  and the probability of random exposure to these areas under the
current and future scenarios, the use of a 95% UCL for the exposure point concentration is appropriate.

Comment #26: Goodyear commented that the thallium value used in the Northern Aspect surface soil risk
assessment was lower than the background screening value.

EPA's Response: As indicated in RAGS (section 5.8), compounds positively detected in at least one Contract
Laboratory Program sample in a given medium should be considered in the risk assessment. Since a minimum of
one of the 18 thallium samples met this criterion, it was appropriate to calculate risks for    exposure to
thallium in the Northern Aspect.

Comment #27: Goodyear stated in its comments that the risks are potentially overestimated for various aspects
of the site.

EPA's Response: The risks were calculated following EPA guidance and procedures. In addition, many of the
Targeted Organic Compounds  (a site-specific list of compounds associated with the rubber industry),  including
2-anilinobenzothiazole,  benzothiazole and phenyl isothiocyanate, do not have toxicity data available.
Therefore, these compounds were not included in the risk calculation. This may have underestimated the risks
at the site. In addition, risks may have been underestimated because EPA performed the risk assessment solely
using data gathered during the RI. Areas with high concentrations of contaminants which were covered during
the removal action at the site were not resampled during the RI and  included in the risk assessment
analysis. There are significant potential risks associated with the concentrations of contaminants detected
during sampling events prior to the RI.  Aniline, for example, poses a significant potential cancer risk on
the order of 1x10 -4 (one in ten thousand), based on the    maximum concentration detected (11,000,000 ppb).
Based primarily on the presence of the Targeted Organic Compounds, ATSDR, in the July 1989 Health Advisory,
determined that there was a significant risk to human health" at the site based on the presence of these
compounds in high concentrations.

The procedures and inputs used to assess risks in this evaluation, as in all such assessments, are subject to
a wide variety of uncertainties. In general, the main sources of uncertainty include: environmental chemistry
sampling and analysis;  environmental parameter measurement; fate and transport modeling; exposure parameter
estimation; and, toxicological data.

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

Uncertainty in the exposure assessment is 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.
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Uncertainty in toxicological data occurs in extrapolating both from animals to humans and from high to low
doses of exposure, as well as from difficulties in assessing the toxicity of a mixture of chemicals.  These
uncertainties are addressed as a matter of policy by making conservative assumptions concerning risk and
exposure parameters throughout the assessment.
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SITE
                       ROD FACT SHEET
Site name:
Site location:

HRS score:
EPA Site ID
Forest Glen Subdivision Site
Town of Niagara and City of Niagara Falls,
Niagara County, New York
37.50  (Aug. 1989)
NYD981560923
ROD

Date Signed:
Operable Unit:
Selected Remedy:
March 31, 1998
OU-2
Excavation of contaminated soils above the
cleanup goals in the southern portion of the
site and the consolidation of these soils in
the northern portion of the site, the
construction of a hazardous-waste cap over
the consolidated soils and the implementation
of a maintenance and monitoring program to
ensure the integrity of the cap. In
addition, institutional controls to prevent
intrusive activities from being performed on
the cap.
Construction Completion:
Capital Cost:       $15,357,800
0 & M cost:         $34,334/year
Present-Worth Cost: $16,397,000  (5% discount rate, 30 years O&M)
LEAD
Remedial:
Primary Contact:
Secondary Contact:
Main PRPs:
U.S. Environmental Protection Agency
Gloria M. Sosa  (212)  637-4283
Kevin M. Lynch  (212)  637-4287
The Goodyear Tire and Rubber Co.
Thomas G. Sottile
WASTE
Waste type: Various volatiles, semi-volatiles, PCBs, PAHs and inorganics.
Waste origin: Suspected industrial waste

Est.guantity: 285,200 cubic yards total contaminated soil and sediment at the site
Contaminated media: Soil and sediment
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