Superfund Record of Decision Rosen Brothers Scrap Yard Dump Cortland NY


                                    EPA/ROD/R02-98/006
                                    1998
EPA Superfund
     Record of Decision:
     ROSEN BROTHERS SCRAP YARD/DUMP
     EPA ID: NYD982272734
     OU01
     CORTLAND, NY
     03/23/1998

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EPA 541-R98-006

                          RECORD OF DECISION

                          Rosen Brothers Site
                          Cortland, New York
                  U.S. Environmental Protection Agency
                                Region II
                            New York, New York
                                March 1998

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DECLARATION FOR RECORD OF DECISION

SITE NAME AND LOCATION

Rosen Brothers Site, Cortland, New York

STATEMENT OF BASIS AND PURPOSE

This Record of Decision (ROD) documents the U.S. Environmental Protection Agency's (EPA's) selection of a
remedy for the Rosen Brothers Superfund Site (the "Site") in accordance with the requirements of the
Comprehensive Environmental Response, Compensation and Liability Act of 1980, as amended (CERCLA), 42
U.S.C. °9601-9675, and to the extent practicable, the National Oil and Hazardous Substances Pollution
Contingency Plan, 40 CFR Part 300. This decision document explains the factual and legal basis for
selecting the remedy for the Site. The attached index (Appendix III) identifies the items that comprise
the Administrative Record upon which the selection of the remedial action is based.

The New York State Department of Environmental Conservation (NYSDEC) was consulted on the proposed
remedial action in accordance with CERCLA °121(f), 42 U.S.C. °9621(f), and it concurs with the selected
remedy (see Appendix IV).

ASSESSMENT OF THE SITE

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

DESCRIPTION OF THE SELECTED REMEDY

The major components of the selected remedy include the following:

• Excavation of all 1,1,1-trichloroethane (TCA)-contaminated soils above 1 milligram per
kilogram (mg/kg) in two hot spot areas (one immediately downgradient of the former cooling
pond in the monitoring well W-06 area and the other corresponding with test pit T-02) and
PCB-contaminated soils above 10 mg/kg in two hot spot areas (the northeast portion of the
Site and the area of the gantry crane in the central portion) 1. The actual extent of the
excavations and the volume of the excavated material will be based on post-excavation
confirmatory sampling. Clean or treated material will be used as backfill in the excavated
areas.

• Consolidation of all excavated soils with PCB concentrations less than 50 mg/kg onto the
former cooling pond. Those soils with PCB concentrations above 50 mg/kg will be sent
off-site for treatment/disposal at a Toxic Substances Control Act (TSCA)-compliant facility.
All excavated TCA-contaminated soils will either be sent off-site for treatment/disposal or
treated on-site to 1 mg/kg for TCA and used as backfill in the excavations.

• Removal and consolidation onto the former cooling pond of non-hazardous debris located on
surface areas where the site-wide surface cover will be installed and/or is commingled with
the excavated soil.

• Placement of a cap meeting the requirements of New York State 6 NYCRR Part 360 regulations
over the three-acre former cooling pond. Prior to the construction of the cap, the
consolidated soils, non-hazardous debris, and existing fill materials will be regraded and
compacted to provide a stable foundation and to promote runoff.

• Construction of a chain-link fence around the former cooling pond after it is capped.

• Placement of a surface cover over the remaining areas of the Site to prevent direct contact
with residual levels of contaminants in Site soils. The nature of the surface cover will be
determined during the remedial design phase.
1 See Figure 3 for locations of the areas to be remediated.

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       •       Monitored natural attenuation to address the residual groundwater contamination in
              downgradient areas.  As part of a long-term groundwater monitoring program,  sampling will be
              conducted in order to verify that the level and extent of groundwater contaminants are
              declining from baseline conditions and that conditions are protective of human health and
              the environment.

       •       Implementation of regrading and storm-water management improvements to protect the integrity
              of the cap/surface cover.

       •       Employment of dust and VOC control/suppression measures during all construction and
              excavation activities, as  necessary,  pursuant to state and federal guidance.

       •       Long-term monitoring to evaluate the  remedy's effectiveness.  The exact freguency,  location,
              and parameters of groundwater monitoring will be determined during remedial design.
              Monitoring will include a  network of  groundwater monitoring wells, including the
              installation of new monitoring wells  (as necessary).  Monitoring will also include  several
              sediment sampling stations.

       •       Taking steps to secure institutional  controls,  such as deed restrictions and contractual
              agreements, as well as local ordinances, laws,  or other government action,  for the purpose
              of,  among other things,  restricting the installation and use of groundwater wells  at and
              downgradient of the Site,  restricting excavation or other activities which could affect the
              integrity of the cap/site-wide surface cover, and restricting residential use of the
              property in order to reduce potential exposure to site-related contaminants.

       •       Reevaluation of Site conditions at least once every five years to determine if a
              modification to the selected alternative is necessary.

It is anticipated that excavation of the two PCB hot  spot areas and the installation of the site-wide
surface cover on a portion of the Site will be performed pursuant to a Unilateral Administrative Order
issued by EPA in early March 1998.

Data indicate that the groundwater  contamination in the monitoring well W-06 area is of an intermittent
nature and that TCA levels in groundwater along the Site's downgradient perimeter are present at
relatively low levels. These conditions, combined with the removal of the TCA source areas, extremely
high groundwater flow, and the presence of intrinsic  conditions favorable to contaminant degradation, is
expected to lead to the timely groundwater restoration via monitored natural attenuation (in
approximately 10 years) without relying on a costly groundwater extraction and treatment system.

If, however, monitored natural attenuation does not appear to be successful in remediating the
groundwater, then more active remedial measures would be considered. EPA may also invoke a waiver of
groundwater Applicable or Relevant  and Appropriate Reguirements  (ARARs) if the remediation program and
further monitoring data indicate that reaching Maximum Contaminant Levels  (MCLs) in the aguifer is
technically impracticable.

The selected alternative 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 utilize permanent
solutions to the maximum extent practicable.

DECLARATION OF STATUTORY DETERMINATIONS

The selected remedy meets the reguirements for remedial actions set forth in CERCLA °121, 42 U.S.C. °9621
in that it: (1)  is protective of human health and the environment;  (2) attains a level or standard of
control of the hazardous substances, pollutants and contaminants, which at least attains the legally
applicable or relevant and appropriate reguirements under federal and state laws;  (3) is cost-effective;
(4) utilizes alternative treatment  (or resource recovery) technologies to the maximum extent practicable;
and (5) satisfies the statutory preference for remedies that employ treatment to reduce the toxicity,
mobility, or volume of the hazardous substances, pollutants or contaminants at a site.

Because this remedy will result in  contaminants remaining on the Site above health-based limits until the
contaminant levels in the aguifer are reduced below MCLs, a review of the remedial action,  pursuant to
CERCLA °121(c),  42 U.S.C. °9621(c), will be conducted five years after the commencement of the remedial
action and every five years thereafter,  to ensure that the remedy continues to provide adeguate
protection to human health and the  environment.

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         DECISION SUMMARY

        Rosen Brothers Site
        Cortland, New York
U.S. Environmental Protection Agency
             Region II
        New York, New York

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                             TABIiE OF  CONTENTS
                                                                         page

SITE LOCATION AND DESCRIPTION  	  1

SITE HISTORY AND ENFORCEMENT ACTIVITIES  	  2

HIGHLIGHTS OF COMMUNITY PARTICIPATION  	  4

SCOPE AND ROLE OF OPERABLE UNIT OR RESPONSE  ACTION 	  4

SUMMARY OF SITE CHARACTERISTICS  	  4

SUMMARY OF SITE RISKS  	  9

REMEDIAL ACTION OBJECTIVES  	 13

SUMMARY OF REMEDIAL ALTERNATIVES  	 14

COMPARATIVE ANALYSIS OF ALTERNATIVES  	 18

DESCRIPTION OF THE SELECTED REMEDY  	 25

STATUTORY DETERMINATIONS  	 28

DOCUMENTATION OF SIGNIFICANT CHANGES  	 30


     ATTACHMENTS

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

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SITE LOCATION AND DESCRIPTION

The Rosen Brothers Site (the Site), located on relatively flat terrain, is an abandoned scrap-metal
processing facility which occupies approximately 20 acres on the southern side of the City of Cortland,
New York (see Figure 1). Access to the Site is restricted from the surrounding environs by a
seven-foot-high fence with two locked gates. To the east of the Site is the building and parking lot of
the former Kirby Company, Pendleton Street, a vacant lot, a small residential area consisting of
approximately 13 apartment buildings, and GT Auto Finishers. To the north is Perplexity Creek (an
eastward flowing, seasonally intermittent stream), railroad tracks associated with the New York,
Susguehanna & Western Railroad, several industries (Acorn Products, Tuscarora Plastics, and Marietta
Packaging), Huntington Street, a small residential area consisting of approximately 20 houses, and the
Randall Elementary School. To the west is a vacant lot, several industries (GS Heavy Duty Electric, JTS
Lumber, and Cortland Wholesale Lumber and Plywood), and South Main Street. To the south is Perplexity
Creek Tributary, a former City of Cortland dump site, Valley View Drive, and the Cortland City Junior and
Senior High Schools (see Figure 2).

Perplexity Creek Tributary, which flows northeast, converges with Perplexity Creek at the northeast
corner of the Site. Both are seasonally intermittent streams. At this point, Perplexity Creek continues
through a culvert for approximately 2,000 feet, then flows freely for approximately a one-half mile
interval before emptying into the Tioughnioga River. Surficial geology at the Site (hereinafter referred
to as overburden) is comprised of glacial sand and gravel overlain by a silt unit and a fill unit. The
silt unit appears to overlay the sand and gravel unit across most of the Site, ranging from two to six
feet in thickness. For most of the Site, the fill ranges in thickness from one to six feet, typically
consisting of gravels, sands, and silts mixed with various materials such as slag, cinders, and ash.
Other materials observed in the fill consist of metal, wire, brick, wood, glass, railroad ties, pipes,
tar, plastics, and concrete. Construction and, to a lesser extent, municipal wastes, ranging from four
to twenty-five feet in thickness, are present in a three-acre former cooling pond. The eastern portion of
the cooling pond has been filled in to an estimated fifteen feet above grade.

The Site overlies the Cortland-Homer-Preble aguifer, a sole source aguifer used as a supply of potable
water for the City of Cortland. The potable water supply well for the entire City is located
approximately two miles upgradient of the Site. Officials from both the City of Cortland and Cortland
County have indicated that there are no known users of groundwater in areas downgradient of the Site.

SITE HISTORY AND ENFORCEMENT ACTIVITIES

The area currently occupied by the Site is the eastern half of a forty-acre parcel of land which was
originally referred to as "Randall's Vacant Fields." In the late 1800's, the forty-acre parcel was
developed by Wickwire Brothers, Inc. (Wickwire) as an industrial facility for the manufacture of wire,
wire products, insect screens, poultry netting, and nails. The eastern half of the property was used,
primarily, as a scrap yard by Wickwire, supplying scrap metal for the steel mill. An on-site pond was
dammed and used as a cooling pond in the manufacture of raw steel. This pond was approximately three
acres in size and had an estimated capacity of one million gallons. The entire facility was sold to
Keystone Consolidated Industries, Inc. (Keystone) in 1968. Keystone closed the facility in 1971. Shortly
thereafter, the facility was destroyed by fire.

In the early 1970's, Phillip and Harvey Rosen (Rosen Brothers) transferred their existing scrap-metal
processing operation to the eastern portion of the property. At this time, Rosen Brothers began the
demolition of the Wickwire buildings on the western portion of the property. The demolition debris
(allegedly over a million and a half sguare feet of buildings) was used to fill in most of the cooling
pond to or above grade, hence the cooling pond is hereinafter referred to as "the former cooling pond".
In exchange for this work, Rosen Brothers was granted title to the eastern portion of the property. The
western portion of the Wickwire property was cleared for the development of new industry in 1979, and has
since been known as the Noss Industrial Park.

Rosen Brothers' scrap metal operations included scrap metal processing and automobile crushing. The Site
was used to stage large guantities of abandoned vehicles, appliances, steel tanks, drums, truck bodies,
and other scrap materials. Municipal waste, industrial waste, and construction waste were allegedly
intermittently disposed of in or on the former cooling pond. Drums were routinely crushed on-site, the
contents spilling onto the ground surface. Philip Rosen and Rosen Brothers were cited for various
violations throughout this period, including illegally dumping into Perplexity Creek Tributary,
improperly disposing of waste materials, and operating a refuse disposal area without a permit.
Operations on the Site ceased in 1985 and the Site was abandoned.

In 1986, NYSDEC conducted a Phase II investigation, which included a site inspection, geophysical
studies, installation of soil borings and monitoring wells, and sampling and analysis of groundwater,

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soils, sediments, and waste materials. The site inspection concluded that hazardous materials were
present on the Site, including several hundred full and/or leaking drums, transformers filled with
polychlorinated biphenyls  (PCBs),  and pressurized cylinders of unknown content. The results of sampling
efforts indicated elevated levels of trichloroethane  (TCA) , PCBs, anthracene, pyrene, lead, and chromium,
in Site soil, sediment, and groundwater.

EPA performed a removal action at the Site in 1987 to address immediate threats to the public health and
the environment. This removal action included fencing the Site, sampling, excavating visibly-contaminated
soil, and securing and temporary staging of drums, tanks, cylinders, transformers, and the excavated
soil.

Based on materials observed on the Site and other evidence, EPA issued Administrative Orders to Keystone
and several additional potentially responsible parties in 1988 and 1989, namely Monarch Machine Tool
Company (Monarch), Niagara Mohawk Power Corporation (Niagara Mohawk), and the Dallas Corporation  (later
called Overhead Door Corporation and hereinafter referred to as Overhead Door) , reguiring them to remove
the materials previously staged by EPA. This work was completed in April 1990.

On March 30, 1989, the Site was added to the Superfund National Priorities List. Overhead Door, Monarch,
and Niagara Mohawk agreed to conduct a remedial investigation/feasibility study (RI/FS) in accordance
with an Administrative Order on Consent (Index Number II CERCLA 00204) with EPA in January 1990.
Keystone,  Cooper Industries, Inc., and Potter Paint Co., Inc. assisted in the performance or funding of
the RI/FS pursuant to the terms of a Unilateral Administrative Order  (index Number II CERCLA-00205)
issued in February 1990. The companies completed the RI/FS in 1997. On March 6, 1998, EPA issued a
Unilateral Administrative Order to the companies noted above and several other entities to perform a
removal action in anticipation of planned on-site redevelopment activities.

These companies voluntarily undertook the demolition and removal of structurally unsound buildings and a
150-foot high smoke stack in December 1992. They also removed and recycled 200 tons of scrap materials in
December 1993. In November 1994,  the companies emptied and disposed of the contents of an abandoned
underground storage tank and removed a small concrete oil pit. In August 1997, EPA removed and recycled
over 500 tons of scrap metal and more than 20 tons of tires from the Site.

HIGHLIGHTS OF COMMUNITY PARTICIPATION

The RI report, dated May 1994, which describes the nature and extent of the contamination at and
emanating from the Site, the Risk Assessment, dated January 1995, which discusses the risks associated
with the Site, the FS report, dated April 1997, which identifies and evaluates various remedial
alternatives, and the November 1997 Proposed Plan were made available to the public in both the
Administrative Record and information repositories maintained at the EPA Docket Room in the Region II New
York City office and at the City of Cortland Public Library located at 32 Church Street, Cortland, New
York. The notice of availability for these documents was published in the Cortland Standard on November
17, 1997.  A public comment period was held from November 17 through January 16, 1998 1. A public meeting
was held on December 9, 1997 at the New York State Grange Building in Cortland, New York. At this
meeting, representatives from EPA presented the findings of the RI/FS and answered guestions from the
public about the Site and the remedial alternatives under consideration.

Responses to the comments received at the public meeting and in writing during the public comment period
are included in the Responsiveness Summary (see Appendix V).

SCOPE AND ROLE OF OPERABLE UNIT OR RESPONSE ACTION

The primary objectives of this action, the first and only remedial action planned for the Site, are to
address contaminated soils and groundwater and to minimize any potential future health and environmental
impacts.

SUMMARY OF SITE CHARACTERISTICS

During the RI, air, surface water, sediments, surface soils, subsurface soils, and groundwater were
sampled. The results from these samples are summarized below.
   1  A thirty-day extension of the comment period was granted.

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Air

Five air samples were collected downwind of the Site and analyzed for VOCs. In addition, potential
concentrations of constituents on dust particulates were evaluated. The results did not indicate any
significant site-related impacts to air quality.

Surface Water

Contaminant levels in the surface water were found to be generally insignificant.

Sediments

Although semi-volatile organic compounds (SVOCs), PCBs, and metals were detected in sediments, they were
present at levels that do not represent a significant impact.

Surface Soil

Surface soils were sampled for SVOCs and metals at forty-three locations. PCB samples were collected at
thirty-one locations. SVOCs were generally detected at low to moderate levels at almost every location
sampled. Surface soil sampling data are included in Table 1. The SVOCs that were detected were
predominantly polyaromatic hydrocarbons (PAHs) and phthalates. The highest concentrations (up to 2,300
milligram/kilogram (mg/kg) of total SVOCs) were detected in surface soil samples in the vicinity of the
former cooling pond. Four PAHs, benzo(a)anthracene, benzo(b)fluoranthene, benzo(k)fluoranthene, and
benzo(a)pyrene, were detected wherever SVOCs were present. The PAH compounds are believed to be
associated with petroleum products, coal, and combustion byproducts from both Wickwire and Rosen Brothers
operations. The phthalates are typically associated with plastic materials.

Elevated concentrations of metals were detected in multiple locations across the Site, including cadmium,
chromium, lead, manganese, mercury, and zinc. Elevated metal concentrations include manganese at
approximately 19,100 mg/kg and lead at approximately 3,000 mg/kg.

Surface-soil samples collected in the northeast portion of the Site contained PCBs with concentrations
exceeding 25 mg/kg. PCB sampling data from this event are included in Table 2. PCBs were detected
sporadically and at low levels (generally less than 1 mg/kg) in other areas of the Site, including an
area where an overhead Gantry crane operated to load and unload scrap during both Wickwire and Rosen
Brothers operations.

Subsurface Soil

Samples from twenty-one subsurface-soil locations were collected from test pits and borings. These
samples were analyzed for volatile organic compounds (VOCs), SVOCs, PCBs/pesticides, and metals.
Subsurface soil sampling data are included in Table 3. VOCs were generally detected at relatively low
concentrations (i.e., below 1 mg/kg), with the exception of TCA at 44 mg/kg in a single location, two to
three feet below the surface in the south-central portion of the Site (i.e., sample collected from test
pit T-02). Most of the SVOCs detected in subsurface soil samples collected at the Site were PAHs. Total
SVOC concentrations were generally low across the Site (i.e., below 1 mg/kg). The highest concentration
detected was approximately 330 mg/kg in the northeastern portion of the Site. Consistent with surface
soil sampling data, PCBs in subsurface soil samples were generally confined to the northeastern area
of the Site, at concentrations exceeding 25 mg/kg. Pesticides were either not detected or present at
extremely low levels. Metals in subsurface soils were generally detected at levels well below those
detected in surface soils. The maximum concentrations of manganese and lead were detected at
approximately 8,000 mg/kg and 1,100 mg/kg, respectively.

A suspected area of subsurface drum disposal in the southwestern portion of the Site was investigated by
test pitting during the RI in 1993. No drums were located during this effort. In addition, a geophysical
testing program was conducted in 1996 to explore discrete subsurface areas of the Site where drum
disposal was suspected. Using several remote sensing technologies, suspected areas were defined,
including three locations within the former cooling pond. A test-pitting program did not locate any
drums.

Groundwater

There are two primary hydrogeologic units beneath the Site -- the upper outwash unit and the lower sand
and gravel unit. In the southern portion of the Site, the upper unit directly overlies the lower unit and
they tend to act as one unit. In the northern portion of the Site, the upper outwash and lower sand and
gravel units become separated by a lower permeability lacustrine unit, forming two distinct hydrogeologic
units. The lacustrine unit also restricts the downward migration of contaminants from the upper outwash

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unit to the lower sand and gravel unit. The upper outwash unit is about 40 feet thick and the general
direction of groundwater flow is toward the northeast (see Figure 3).

During the RI, several groundwater sampling events were conducted using twenty-four monitoring wells.
Samples were analyzed for VOCs, SVOCs, PCBs/pesticides, and metals. Groundwater sampling data are
included in Table 4. The results of these RI sampling activities indicated the presence of elevated
levels of VOCs in the groundwater beneath the Site. The primary groundwater contaminants were determined
to be TCA and its degradation products, 1,1-dichloroethane (1,1-DCA) and 1,1-dichloroethene (1,1-DCE).
The highest concentrations of contaminants were detected in the south-central portion of the Site, in
monitoring well W-06, located immediately downgradient of the former cooling pond. A concentration of
3,400 micrograms per liter (Ig/1) of TCA was detected in this well. Subseguent groundwater monitoring
over the next several years showed a significant decline of TCA concentrations. Much lower concentrations
of these and other VOCs were detected at wells throughout the Site, downgradient of the Site, and to a
lesser extent, upgradient of the Site. The data indicate that there is a general decline in groundwater
contaminant levels in seven upper outwash wells along the northern (downgradient) perimeter of the Site.
The highest concentrations were detected in the central portion of the northern perimeter, located
hydraulically downgradient of monitoring well W-06 and test pit T-02, with a high concentration of 390
Ig/1 detected in February 1992. By March 1996, the last full round of groundwater sampling conducted, the
high concentration had declined to 88 Ig/1. Consistent with the northern-perimeter wells, the data
indicate that there is a general decline in groundwater contaminant levels in four off-site,
upper-outwash wells located downgradient of the northern-perimeter wells. Average TCA concentrations
ranged from 8 Ig/1 to 135 Ig/1. The highest concentrations were detected hydraulically downgradient of
monitoring well W-ll (see Figure 2), with a high concentration of 260 Ig/1, detected in February 1992,
which declined to 83 Ig/1 by March 1996.

Post-RI guarterly groundwater samples were collected from April 1995 through August 1996 to assess the
nature and degree of decline in the levels of TCA immediately downgradient of the former cooling pond. A
summary of all groundwater sampling data for TCA is included in Table 5. Levels of TCA continued to
decline until December 1995, when an elevated level of 5,000 Ig/1 was observed. The conclusion drawn from
these data was that there was an intermittent source of TCA present in the soils/fill in the vicinity of
or upgradient from monitoring well W-06 (See Figure 4).

In response, EPA conducted an investigation in the vicinity of monitoring well W-06 and the former
cooling pond. Groundwater, soil, and soil gas samples were collected and test pits were excavated into
the former cooling pond and in the monitoring well W-06 area in an attempt to identify the source of the
intermittent TCA contamination. The data collected led to the conclusion that there was a localized
source of TCA in the soils/fill in the monitoring well W-06 area and that the former cooling pond was not
a source of TCA. The estimated volume of contaminated soil in the monitoring well W-06 area is 500 to
1,000 cubic yards, based on elevated soil concentrations from four to eight feet deep overlying the silt
unit. A similar volume is assumed to be present in the test pit T-02 area.

PCBs were detected in groundwater in a single well in the northeastern portion of the Site. The highest
concentration reported was 11 Ig/1. The PCBs at this location can be correlated directly with the PCBs
detected in the soil in the vicinity of this well. No PCBs were detected in nearby downgradient
monitoring wells. Pesticides were not detected in the groundwater.

The data indicate that elevated levels of metals are present in the groundwater. Metals with elevated
concentrations include antimony, arsenic, cadmium, lead, chromium, and manganese. Manganese was often
detected above 5,000 Ig/1 in unfiltered samples and above 1,000 Ig/1 in filtered samples. While it is
difficult to correlate these groundwater contaminants solely with the Site, it appears that the Site
does contribute to the presence of metals in groundwater.

Overall, data from on- and off-site monitoring wells indicate a narrow, relatively low-level and stable
groundwater-contaminant plume migrating from the Site to the northeast and extending almost to the
Tioughnioga River. The groundwater data indicate that contaminants are confined to the upper outwash unit
and have not migrated to the lower sand and gravel unit. This is likely due to both the extremely high
horizontal groundwater flow velocity in the Cortland aguifer as well as to the presence of the
less-permeable lacustrine unit between the upper outwash and lower sand and gravel units across the
northern portion of the Site. The data collected, including the collection of data confirming the
presence of conditions favorable for natural attenuation, indicate that there continues to be a general
decline in the levels of contaminants over time downgradient of the source areas (i.e., at the northern
perimeter and areas downgradient of the Site).

Pump testing conducted after the RI concluded that a flow rate of 1,000 to 1,500 gallons per minute would
be necessary to create a hydraulic barrier along the downgradient edge of the Site in order to prevent
contaminated groundwater from leaving the Site.

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SUMMARY OF SITE RISKS

Based upon the results of the RI, a baseline risk assessment was conducted to estimate the risks
associated with current and future Site conditions. The baseline risk assessment estimates the human
health and ecological risk which could result from the contamination at the Site, if no remedial action
were taken.

Human Health Risk Assessment

A four-step process is utilized for assessing site-related human health risks for a reasonable maximum
exposure scenario:

Hazard Identification—identifies the contaminants of concern at the Site based on several factors such
as toxicity, freguency of occurrence, and concentration.

Exposure Assessment—estimates the magnitude of actual and/or potential human exposures, the freguency
and duration of these exposures, and the pathways (e.g., ingesting contaminated well-water) by which
humans are potentially exposed.

Toxicity Assessment—determines the types of adverse health effects associated with chemical exposures,
and the relationship between magnitude of exposure (dose) and severity of adverse effects (response).

Risk Characterization—summarizes and combines outputs of the exposure and toxicity assessments to
provide a guantitative assessment of site-related risks.

The baseline risk assessment began with selecting contaminants of concern which would be representative
of Site risks. Contaminants were identified based on factors such as potential for exposure to receptors,
toxicity, concentration, and freguency of occurrence. Contaminants of concern are presented in Table 6.
Several of the SVOCs (particularly the PAHs), as well as the PCBs, are known to cause cancer in
laboratory animals and are suspected or known to be human carcinogens. Many of the metals, particularly
manganese, are noncarcinogenic compounds with strong potential for adverse health effects.

The baseline risk assessment evaluated the health effects which could result from exposure to
contaminated Site media (i.e., soil, groundwater, etc.) through ingestion, dermal contact, or inhalation.
The assessment evaluated risks to potential trespassers, potential future off-site residents, potential
future excavation workers, and potential future industrial workers. Exposure routes are presented in
Table 7.

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

Potential carcinogenic risks were evaluated using the cancer slope factors developed by EPA for the
contaminants of concern. Cancer slope factors (SFs) have been developed by EPA's Carcinogenic Risk
Assessment Verification Endeavor for estimating excess lifetime cancer risks associated with exposure to
potentially carcinogenic chemicals. SFs, which are expressed in units of (mg/kg-day) -1, are multiplied
by the estimated intake of a potential carcinogen, in mg/kg-day, to generate an upper-bound estimate of
the excess lifetime cancer risk associated with exposure to the compound at that intake level. The term
"upper bound" reflects the conservative estimate of the risks calculated from the SF. Use of this
approach makes the underestimation of the risk highly unlikely. The SFs for the compounds of concern are
presented in Table 9.

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

The results of the baseline risk assessment indicate that the contaminated surface soils and groundwater
at the Site pose an unacceptable risk to human health due, primarily, to the presence of VOCs, SVOCs,
PCBs, and metals. HI data are summarized in Table 10. Cancer risk data are summarized in Table 11.

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Potential trespassers and potential future excavation workers were not found to be at risk from exposure
to contaminated Site media, primarily due to the assumed short duration of potential exposure. In
addition, the risk assessment concluded that there was no significant risk attributable to the Site when
evaluating current scenarios. The noncarcinogenic HI for exposure to groundwater and wind-borne soil
contaminants by potential future off-site residents is 69, attributable primarily to groundwater
ingestion, which is well above the acceptable level of 1. As was noted previously, the water supply for
the City of Cortland is located two miles upgradient of the Site and there are no known users of
groundwater downgradient of the Site. The carcinogenic risks related to ingestion, dermal contact, and/or
inhalation of vapors from groundwater and surface soils at the Site are outside the acceptable range at 9
x 10 -4 (i.e., a nine-in-ten-thousand excess cancer risk) for potential future industrial workers. For
potable groundwater ingestion by potential future off-site residents, the risk was 2 x 10 -3 (i.e., a
two-in-one-thousand excess cancer risk), which is outside the acceptable risk range.

For potential future industrial workers, the noncarcinogenic His for ingestion of groundwater and
ingestion and inhalation of surface soils (dust) are above the acceptable level of 1. The HI for
ingestion of groundwater by future industrial workers is 9 and the HI for ingestion and inhalation of
surface soils by future industrial workers is 2.

Ecological Risk Assessment

A four-step process is utilized for assessing Site-related ecological risks for a reasonable maximum
exposure scenario:

Problem Formulation - a qualitative evaluation of contaminant release, migration, and fate;
identification of contaminants of concern, receptors, exposure pathways, and known ecological effects of
the contaminants; and selection of endpoints for further study.

Exposure Assessment—a quantitative evaluation of contaminant release, migration, and fate;
characterization of exposure pathways and receptors; and measurement or estimation of exposure point
concentrations.

Ecological Effects Assessment-literature reviews, field studies, and toxicity tests, linking contaminant
concentrations to effects on ecological receptors.

Risk Characterization— measurement or estimation of both current and future adverse effects.

The ecological risk assessment began with evaluating the contaminants associated with the Site in
conjunction with the site-specific biological species/habitat information. The baseline risk assessment
concluded that the Site has low value as a wildlife habitat, while surrounding areas provide some limited
alternative, preferred habitats. The degree of physical disturbance at the Site and lack of continuous
quality habitat in the area are conditions which restrict the extent of use by wildlife. Perplexity Creek
and its tributary generally provide low habitat value for aquatic biota due to the intermittent nature of
the stream flow.

Raccoons and deer mice were chosen to represent terrestrial receptors potentially exposed to site-related
contaminants of concern. For raccoons, estimated doses of cadmium, mercury, and lead exceed the available
Lowest-Observed-Adverse-Effect Levels (LOAELs) and No-Observed-Adverse-Effect-Levels (NOAELs). For deer
mice, the estimated dose for PCBs exceeds both NOAELs and LOAELs. Estimated doses for mercury, nickel,
lead, and barium exceed their respective NOAELs, but not their LOAELs. The primary route of exposure was
bioaccumulation of contaminants through the food chain.

Summary of Human Health and Ecological Risks

Based on the results of the baseline risk assessment, EPA has determined that actual or threatened
releases of hazardous substances from the Site, if not addressed by the selected alternative or one of
the other active measures considered, may present a current or potential threat to public health,
welfare, or the environment.

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

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       •      toxicological data

Uncertainty in environmental sampling arises in part from the potentially uneven distribution of
chemicals in the media sampled. Consequently, there is significant uncertainty as to the actual levels
present. Environmental chemistry analysis uncertainty 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 will
actually come in contact with the chemicals of concern, the period of time over which such exposure will
occur, and in the models used to estimate the concentrations of the chemicals of concern at the point of
exposure.

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

REMEDIAL ACTION OBJECTIVES

Remedial action objectives are specific goals to protect human health and the environment. These
objectives are based on available information and standards, such as applicable or relevant and
appropriate requirements  (ARARs), to-be-considered guidance (TBCs),  and site-specific risk-based levels.

The following remedial action objectives were established for the Site:

       •      Prevent human contact with contaminated soils,  sediments,  and groundwater;

       •      Prevent ecological contact with contaminated soils and sediments;

       •      Mitigate the migration of contaminants from soils/fill to groundwater:

       •      Mitigate the off-site migration of contaminated  groundwater;

       •      Restore groundwater quality to levels which meet federal and state drinking-water standards
              (see Tables 12 and 13);  and

       •      Control surface water runoff and erosion.

SUMMARY OF REMEDIAL ALTERNATIVES

CERCLA requires that each selected Site remedy be protective of human health and the environment, be
cost-effective, comply with other statutory laws, and utilize permanent solutions and alternative
treatment technologies and 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, mobility, or volume of the hazardous substances.

This ROD evaluates, in detail, four remedial alternatives for addressing the contamination associated
with the Site. The four alternatives for the Site are discussed below in detail.

The construction time for each alternative reflects only the time required to construct or implement the
remedy and does not include the time required to design the remedy,  negotiate the performance of the
remedy with the responsible parties, or procure contracts for design and construction.

The alternatives are:

Alternative 1: No Action

  Capital Cost:                                             $0
  Annual Operation and Maintenance Cost:               $60,000
  Present-Worth Cost:                                 $440,000
  Construction Time:                                   1 Month

The Superfund program requires that the "no-action" alternative be considered as a baseline for
comparison with the other alternatives. The no-action remedial alternative does not include any physical

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measures to address the problem of contamination at the Site.

This alternative would, however, include a long-term groundwater monitoring program. Under the monitoring
program, water guality samples would be collected semi-annually from upgradient, on-site, and
downgradient groundwater monitoring wells. The specifics of monitoring locations, freguency, and
parameters would be determined during the remedial design.

The no-action response also includes the development and implementation of a public awareness and
education program for the residents in the area surrounding the Site. This program would include the
preparation and distribution of informational press releases and circulars and convening public meetings.
These activities would serve to enhance the public's knowledge of the conditions existing at the Site.
This alternative would also reguire the involvement of local government, various health departments, and
environmental agencies.

Because this alternative would result in contaminants remaining on-site above health-based levels, CERCLA
reguires that the Site be reviewed every five years. If justified by the review, remedial actions may be
implemented to remove or treat the wastes.

Alternative 2: Institutional Controls

Capital Cost: $0
Annual Operation and Maintenance Cost: $60,000
Present-Worth Cost: $440,000
Construction Time: 2 Months

This alternative is identical to Alternative 1, but would also include taking steps to secure
institutional controls, including, but not limited to, the placement of restrictions on the installation
and use of groundwater wells at and downgradient of the Site, restrictions on excavation, and
restrictions on residential use of the property.

It was assumed that the implementation of institutional controls included under this alternative would
not add to the overall costs as outlined in Alternative 1.

Alternative 3: Contaminated Soil Hot Spots Excavation and Disposal, Installation of Cap on Former Cooling
Pond, Site-Wide Surface Cover, and Monitored Natural Attenuation of Residual Groundwater Contamination

Capital Cost: $2,720,000
Annual Operation and Maintenance Cost: $60,000
Present-Worth Cost: $3,140,000
Construction Time: 1 Year

This alternative includes excavating all TCA-contaminated soils above the NYSDEC recommended soil cleanup
objective of 1 mg/kg identified in the Technical and Administrative Guidance Memorandum (TAGM) in two hot
spot areas (one immediately downgradient of the former cooling pond in the area around monitoring well
W-06 and the other corresponding with test pit T-02) and PCB-contaminated soils above the TAGM objective
of 10 mg/kg in two hot spot areas (the northeast portion of the Site and the area of the gantry crane in
the central portion). All of these areas are shown on Figure 3. TAGM objectives may be found on Table 14.
It is estimated that 2,000 cubic yards of TCA-contaminated soil and 3,000 cubic yards of PCB-contaminated
soil would be excavated.

All excavated soils with PCB concentrations less than 50 mg/kg would be consolidated onto the former
cooling pond. Those soils with PCB concentrations above 50 mg/kg would be sent off-site for
treatment/disposal at a Toxic Substances Control Act (TSCA)-compliant facility. All excavated
TCA-contaminated soils would either be sent off-site for treatment/disposal or treated on-site to 1 mg/kg
for TCA and used as backfill in the excavations. For cost-estimating purposes, it was assumed that the
TCA-contaminated soils would be treated/disposed of off-site.

Nonhazardous debris that is located on the surface of the areas where the site-wide surface cover would
be installed and/or is commingled with excavated soil would be removed and consolidated onto the former
cooling pond.

A cap meeting the reguirements of New York State 6 NYCRR Part 360 regulations would be placed over the
3-acre former cooling pond. Prior to the construction of the cap, the consolidated soils, nonhazardous
debris, and existing fill materials would be regraded and compacted to provide a stable foundation and to
promote runoff.

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As potential risks remain even after excavation of the contaminant hot spots, a surface cover  (e.g.,
asphalt, soil, crushed stone, etc.) would be placed over the remaining areas of the Site to prevent
exposure to residual levels of contaminants in Site soils. The nature of the surface cover would be
determined during the remedial design phase.

Under this alternative, monitored natural attenuation would be allowed to address the residual
groundwater contamination at and downgradient of the excavated source areas. Natural attenuation of
organic contaminants includes dispersion, volatilization, sorption, biodegradation, and biological and
chemical stabilization, transformation, or destruction. Natural attenuation of inorganic contaminants is
similar to that of organic contaminants, except that there is not a volatilization or biological
component. It is estimated that it would take approximately ten years to meet drinking water standards by
monitored natural attenuation. As part of a long-term groundwater monitoring program, samples from
upgradient, on-site, and downgradient groundwater monitoring wells would be collected and analyzed
semi-annually in order to verify that the level and extent of groundwater contaminants are declining from
baseline conditions and that conditions are protective of human health and the environment. The specifics
of monitoring locations, frequency, and parameters would be determined during the design of the selected
remedy. If monitored natural attenuation does not appear to be successfully remediating the groundwater,
then more active remedial measures would be considered.

This alternative would also include taking steps to secure institutional controls, including, but not
limited to, the placement of restrictions on the installation and use of groundwater wells at and
downgradient of the Site, restrictions on excavation or other activities which could affect the integrity
of the cap/site-wide surface cover, and restrictions on residential use of the property.

Because this alternative would result in contaminants remaining on-site above health-based levels, CERCLA
requires that the Site be reviewed every five years. If justified by the review, remedial actions may be
implemented to remove or treat the wastes.

Alternative 4: Contaminated Soil Hot Spots Excavation and Disposal, Installation of Cap on Former Cooling
Pond, Site-Wide Surface Cover, and Groundwater Extraction and Treatment

  Capital Cost:                                    $11,755,000
  Annual Operation and Maintenance Cost:            $1,970,000
  Present-Worth Cost:                              $19,830,000
  Construction Time:                                   2 Years

This alternative is identical to Alternative 3, except that it would address site-wide groundwater
contamination through the installation of a groundwater extraction and treatment system in order to
provide a hydraulic barrier between the Site and downgradient areas. It is assumed that groundwater
recovery would be achieved through the installation of six recovery wells (pumping 1,200 to 1,500 gpm)
located along the northern, hydraulically downgradient, boundary of the Site (just south of Perplexity
Creek) . The scope of the extraction system would be determined during remedial design. Following
pretreatment for solids and inorganic contaminant removal (as necessary), the extracted groundwater would
be treated by air-stripping  (or other appropriate treatment) to address organic contamination and then be
discharged to the Tioughnioga River. Monitored natural attenuation would be allowed to address the
low-level contamination in groundwater that has migrated to downgradient areas. It is estimated that it
would take approximately five years of groundwater extraction and treatment to meet drinking water
standards.

Because this alternative would result in contaminants remaining on-site above health-based levels, CERCLA
requires that the Site be reviewed every five years. If justified by the review, remedial actions may be
implemented to remove or treat the wastes.

COMPARATIVE ANALYSIS OF ALTERNATIVES

During the detailed evaluation of remedial alternatives, each alternative is assessed against nine
evaluation criteria, namely, overall protection of human health and the environment, compliance with
applicable or relevant and appropriate requirements, long-term effectiveness and permanence, reduction of
toxicity, mobility, or volume through treatment, short-term effectiveness, implementability, cost, and
state and community acceptance.

The evaluation criteria are described below.

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

       •      Compliance with ARARs addresses whether or not a remedy would meet all of the applicable or
              relevant and appropriate requirements of other federal and state environmental statutes and
              requirements or provide grounds for invoking a waiver.

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

       •      Reduction of toxicity, mobility,  or volume through treatment is the anticipated performance
              of the treatment technologies,  with respect to these parameters, a remedy may employ.

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

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

       •      Cost includes estimated capital and operation and maintenance costs,  and net present-worth
              costs.

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

       •      Community acceptance refers to the public's general response to the alternatives described
              in the Proposed Plan. Factors of community acceptance to be discussed include support,
              reservation, and opposition by the community.

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

Overall Protection  of Human Health  and the Environment

Since Alternative 1  (no action) would not address the risks posed through each exposure pathway, it would
not be protective of human health and the environment. Alternative  2  (institutional controls) would be
marginally more protective than the no-action alternative.

Alternative 3 (soil hot spots excavation, former cooling pond cap,  site-wide surface cover, and monitored
natural attenuation of residual groundwater contamination) and Alternative 4  (soil hot spots excavation,
former cooling pond cap,  site-wide  surface cover, and groundwater extraction and treatment) would be
significantly more protective than Alternative  1, in that the risk  of incidental contact with waste by
humans and ecological receptors would be reduced by excavation and  disposal of the contaminated soils in
the four hot spot areas,  installing a cap on the former cooling pond, and installing a site-wide surface
cover.

As part of Alternatives 2, 3, and 4, institutional controls would limit the intrusiveness  of future
activity that could occur on the Site.

Alternatives 1 and  2 would rely upon monitored natural attenuation  alone to restore groundwater quality.
Alternative 3 would include the removal of source areas  (hot spots) in conjunction with monitored natural
attenuation. This would result in the restoration of water quality  in the aquifer more quickly than
monitored natural attenuation alone, but not as expeditiously as Alternative 4, which would include
site-wide extraction and  treatment  of contaminated groundwater. Alternative 4 would mitigate the off-site
migration of low-level TCA-contaminated groundwater and would likely lead to a more expeditious
groundwater cleanup than  the other  alternatives, which employ monitored natural attenuation.

Compliance with ARARs

A 6 NYCRR cap is an action-specific ARAR for landfill closure. Therefore, Alternative 3  (soil hot spots
excavation, former  cooling pond cap, site-wide  surface cover, and monitored natural attenuation of

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residual groundwater contamination) and Alternative 4  (soil hot spots excavation, former cooling pond
cap, site-wide surface cover, and groundwater extraction and treatment) would satisfy this
action-specific ARAR. Alternatives 1 and 2 would not meet this ARAR, since they do not include any
provisions for a cap on the former cooling pond.

Since Alternatives 3 and 4 would involve the excavation of PCB-contaminated soils, their disposition
would be governed by the reguirements of TSCA. Under these alternatives, those excavated soils which
egual or exceed 50 mg/kg PCB would be sent off-site for treatment/disposal at a TSCA-compliant facility.

Alternatives 1 and 2 do not provide for any direct remediation of groundwater or source removal and,
therefore, would not comply with chemical-specific ARARs.  Although Alternative 3 does not include any
active groundwater remediation, the excavation of contaminated soils would significantly reduce the
migration of contaminants to the groundwater, thereby enabling Maximum Contaminant Levels (MCLs) and New
York State drinking-water standards (chemical-specific ARARs) to be met in the groundwater in a faster
time frame than Alternatives 1 and 2.  Alternative 4, which includes active groundwater treatment, would
be the most effective alternative in reducing groundwater contaminant concentrations.

Long-Term Effectiveness and Permanence

Alternatives 1 (no action) and 2 (institutional controls)  would not provide reliable protection of human
health and the environment over time.  Alternative 3 (soil hot spots excavation, former cooling pond cap,
site wide surface cover, and monitored natural attenuation of residual groundwater contamination) and
Alternative 4  (soil hot spots excavation, former cooling pond cap, site-wide surface cover,  and
groundwater extraction and treatment)  would be more effective over the long-term than Alternatives 1 and
2, because they would remove the hot-spot areas of contamination. Alternative 4 would have the greatest
effectiveness in restoring groundwater guality. Alternative 3, which includes a hot-spot excavation
component, is expected to restore the aguifer to drinking water guality in approximately ten years.
Alternative 4, with both hot-spot excavation and groundwater extraction and treatment components, is
expected to restore the aguifer to drinking water guality in approximately five years.

The institutional controls associated with Alternatives 2 through 4 would provide an additional element
of effectiveness in preventing exposure of on-site and downgradient receptors to contaminated
groundwater.

Under Alternatives 3 and 4, excavating the contaminated soil hot spots, the installation of a cap over
the former cooling pond, and the installation of a site-wide surface cover would substantially reduce the
residual risk of untreated waste on the Site by essentially isolating it from contact with human and
environmental receptors. The adeguacy and reliability of the cap and site-wide surface cover to provide
long-term protection from waste remaining at the Site should be excellent.

The 6 NYCRR Part 360 cap and site-wide surface cover would reguire routine inspection and maintenance to
ensure long-term effectiveness and permanence. Routine maintenance, as a reliable management control,
would include mowing, fertilizing,  reseeding and repairing any potential erosion or burrowing rodent
damage.

Reduction of Toxicitv, Mobility, or Volume through Treatment

Alternatives 1 (no action) and 2 (institutional controls)  would rely solely on monitored natural
attenuation to reduce the levels of groundwater contamination. Alternative 3 (soil hot spots excavation,
former cooling pond cap, site-wide surface cover, and monitored natural attenuation of residual
groundwater contamination) would rely on monitored natural attenuation after excavation of the hot-spot
areas of contamination to reduce the levels of groundwater contamination. Therefore, these alternatives
would not actively reduce the toxicity, mobility, or volume of groundwater contaminants through
treatment. Treating contaminated groundwater under Alternative 4  (soil hot spots excavation, former
cooling pond cap, site-wide surface cover, and groundwater extraction and treatment) would reduce the
toxicity, mobility, and volume of contaminants through treatment.

Excavation and disposal of the contaminated soil hot spots, the installation of a cap on the former
cooling pond, and a site-wide surface cover under Alternatives 3 and 4 would prevent further migration of
and potential exposure to these materials. In addition, under these alternatives, all excavated
TCA-contaminated soils would either be sent off-site for treatment/disposal or treated on-site to 1 mg/kg
for TCA and used as backfill in the excavations.

Short-Term Effectiveness

Alternatives 1 (no action) and 2 (institutional controls)  do not include any physical construction
measures in any areas of contamination and, therefore, do not present a risk to the community as a result

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of their implementation. Alternatives 3 (soil hot spots excavation, former cooling pond cap, site-wide
surface cover, and monitored natural attenuation of residual groundwater contamination) and 4 (soil hot
spots excavation, former cooling pond cap, site-wide surface cover, and groundwater extraction and
treatment) involve excavating, moving, placing, and regrading contaminated soils. Since Alternative 4
includes ex-situ treatment of the extracted groundwater, it would generate guantities of treatment
byproducts that would have to be handled by on-site workers and removed off-site for treatment/disposal.
Alternative 4 also includes the installation of extraction wells through potentially contaminated soils
and groundwater. While both of the action alternatives present some risk to on-site workers through
dermal contact and inhalation, these exposures can be minimized by utilizing proper protective eguipment.
The vehicle traffic associated with the cap and surface cover construction, and the off-site transport of
contaminated soils could impact the local roadway system and nearby residents through increased noise
level. Under Alternatives 3 and 4, disturbance of the land during construction could affect the surface
water hydrology of the Site. There is a potential for increased stormwater runoff and erosion during
excavation and construction activities that would be properly managed to prevent excessive water and
sediment loading.

It is estimated that Alternative 1 would reguire one month to implement, since developing a long-term
groundwater monitoring program would be the only activity reguired. It is estimated that the
implementation of institutional controls under Alternative 2 would take an additional month to implement.
Alternative 3 could be implemented in about one year. Alternative 4 would take an estimated two years to
implement.

Implementability

Performing routine groundwater monitoring and effecting institutional controls are all actions that can
be readily implemented. These actions are technically and administratively feasible and reguire readily
available materials and services. Excavating and relocating the contaminated soil, transporting materials
to an off-site treatment/disposal facility, installing a cap and site-wide surface cover (Alternatives 3
and 4), and installing extraction wells (Alternative 4), although more difficult to implement than the
no-action alternative, can be accomplished using technologies known to be reliable and can be readily
implemented. Eguipment, services and materials for this work are readily available. These actions would
also be administratively feasible.

Air stripping (Alternative 4) is a process through which VOCs are transferred from the agueous phase to
an air stream. Air stripping has been effectively used to remove over 99 percent of VOCs from groundwater
at numerous hazardous waste and spill sites.

Alternative 4 involves the extraction of over one million gallons per day and, in order to handle this
volume of water, installation of a pipeline to the Tioughnioga River. Alternative 4 also would involve
the generation of sludge reguiring off-site disposal. These considerations make Alternative 4 more
difficult to implement in comparison to the other alternatives.

Cost

The present-worth costs for Alternatives 1 through 3 are calculated using a discount rate of 7 percent
and a ten-year time interval. The results of modeling indicate that groundwater could be reasonably
expected to be restored to drinking water standards via monitored natural attenuation in ten years. The
present-worth cost for Alternative 4 is calculated using a discount rate of 7 percent and a five-year
time interval. It is estimated that groundwater could be reasonably expected to be restored to drinking
water standards via extraction and treatment in five years. The estimated capital, annual O&M, and
present-worth costs for each of the alternatives are presented below.

Alternative Capital Operation and Present-Worth
No. Cost Maintenance Cost Cost

1 $0 $60,000 $440,000
2 $0 $60,000 $440,000
3 $2,720,000 $60,000 $3,140,000
4 $11,755,000 $2,000,000 $19,830,000

As can be seen by the cost estimates, Alternatives 1 and 2 (No Action and Institutional Controls,
respectively) are the least costly remedies at $440,000. Alternative 4 (Downgradient Perimeter
Groundwater Recovery and Treatment) is the most costly remedy at $19,830,000.

State Acceptance

NYSDEC concurs with the selected remedy.

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Community Acceptance

Comments received during the public comment period indicate that the public generally supports the
selected remedy. Comments received during the public comment period are summarized and addressed in the
Responsiveness Summary, which is attached as Appendix V to this document.

DESCRIPTION OF THE SEIiECTED REMEDY

Based upon an evaluation of the various alternatives, EPA and NYSDEC have determined that Alternative 3
(contaminated soil hot spot excavation and disposal, installation of a cap on the former cooling pond, a
site-wide surface cover, and groundwater monitored natural attenuation) is an appropriate remedy for the
Site. Specifically, this would involve the following:

• Excavation of all 1,1,1-trichloroethane (TCA)-contaminated soils above 1 milligram per
kilogram (mg/kg) in two hot spot areas (one immediately downgradient of the former cooling
pond in the monitoring well W-06 area and the other corresponding with test pit T-02) and
PCB-contaminated soils above 10 mg/kg in two hot spot areas (the northeast portion of the
Site and the area of the gantry crane in the central portion) 2 . The actual extent of the
excavations and the volume of the excavated material will be based on post excavation
confirmatory sampling. Clean or treated material will be used as backfill in the excavated
areas.

• Removal and consolidated onto the former cooling pond of non-hazardous debris located on
surface areas where the site-wide surface cover will be installed and/or is commingled with
the excavated soil.

• Placement of a cap meeting the reguirements of New York State 6 NYCRR Part 360 regulations
over the three-acre former cooling pond. Prior to the construction of the cap, the
consolidated soils, non-hazardous debris, and existing fill materials will be regraded and
compacted to provide a stable foundation and to promote runoff.

• Construction of a chain-link fence around the former cooling pond after it is capped.

• Monitored natural attenuation to address the residual groundwater contamination in
downgradient areas. As part of a long-term groundwater monitoring program, sampling will be
conducted in order to verify that the level and extent of groundwater contaminants are
declining from baseline conditions and that conditions are protective of human health and
the environment.

• Implementation of regrading and storm-water management improvements to protect the integrity
of the cap/surface cover.

• Employment of dust and VOC control/suppression measures during all construction and
excavation activities, as necessary, pursuant to state and federal guidance.

• Long-term monitoring will evaluate the remedy's effectiveness. The exact freguency,
location, and parameters of groundwater monitoring will be determined during remedial
design. Monitoring will include a network of groundwater monitoring wells, including the
installation of new monitoring wells (as necessary). Monitoring will also include several
sediment sampling stations.
See Figure 3 for locations of the areas to be remediated.

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• Taking steps to secure institutional controls, such as deed restrictions and contractual
agreements, as well as local ordinances, laws, or other government action, for the purpose
of, among other things, restricting the installation and use of groundwater wells at and
downgradient of the Site, restricting excavation or other activities which could affect the
integrity of the cap/site-wide surface cover, and restricting residential use of the
property in order to reduce potential exposure to site-related contaminants.

• Reevaluation of Site conditions at least once every five years to determine if a
modification to the selected alternative is necessary.

It is anticipated that excavation of the two PCB hot spot areas and the installation of the site-wide
surface cover on a portion of the Site will be performed pursuant to a Unilateral Administrative Order
issued by EPA in early March 1998.

Data indicate that the groundwater contamination in the monitoring well W-06 area is of an intermittent
nature and that TCA levels in groundwater along the Site's downgradient perimeter are present at
relatively low levels. These conditions, combined with the removal of the TCA source areas, extremely
high groundwater flow, and the presence of intrinsic conditions favorable to contaminant degradation, is
expected to lead to the timely groundwater restoration via monitored natural attenuation (in
approximately 10 years) , without relying on a costly groundwater extraction and treatment system.

If, however, monitored natural attenuation does not appear to be successful in remediating the
groundwater, then more active remedial measures would be considered. EPA may also invoke a waiver of
groundwater Applicable or Relevant and Appropriate Reguirements (ARARs) if the remediation program and
further monitoring data indicate that reaching Maximum Contaminant Levels (MCLs) in the aguifer is
technically impracticable.

The selected alternative 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 utilize permanent
solutions to the maximum extent practicable.

STATUTORY DETERMINATIONS

As was previously noted, CERCLA °121(b)(1), 42 U.S.C. °9621(b)(1), mandates that a remedial action must
be protective of human health and the environment, cost-effective, and utilize permanent solutions and
alternative treatment technologies or resource recovery technologies to the maximum extent practicable.
Section 121(b)(1) also establishes a preference for remedial actions which employ treatment to
permanently and significantly reduce the volume, toxicity, or mobility of the hazardous substances,
pollutants, or contaminants at a site. CERCLA °121(d), 42 U.S.C. °9621(d), further specifies that a
remedial action must attain a degree of cleanup that satisfies ARARs under federal and state laws,
unless a waiver can be justified pursuant to CERCLA °121(d)(4), 42 U.S.C. °9621(d)(4).

For the reasons discussed below, EPA has determined that the selected remedy meets the reguirements of
CERCLA °121, 42 U.S.C. °9621.

Protection of Human Health and the Environment

The selected remedy protects human health and the environment by reducing levels of contaminants in the
groundwater and soil through extraction and treatment, respectively, as well as through the
implementation of institutional controls. The selected remedy will provide overall protection by reducing
the toxicity, mobility, and volume of contamination and by meeting federal and state MCLs.

Compliance with Applicable or Relevant and Appropriate Requirements of Environmental Laws

While there are no federal or New York State soil ARARs for VOCs, one of the remedial action goals is to
meet TAGM objectives. The selected remedy will meet soil TAGM objectives in the soil source areas.

As the aguifer is usable, federal MCLs and state drinking water standards are ARARs. The selected remedy
will be effective in meeting these ARARs, since it includes excavation of the source areas in combination
with monitored natural attenuation of the groundwater 3.
Because data indicate that TCA contamination in the groundwater is intermittent, the removal of TCA
source areas, extremely high groundwater flow, and the presence of intrinsic conditions favorable
to contaminant degradation, is expected to lead to timely groundwater restoration via monitored
natural attenuation.

-------
A summary of action-specific, chemical-specific, and location-specific ARARs which will be complied with
during implementation is presented below. A listing of the individual chemical-specific ARARs is
presented in Tables 11 and 12.

Action-specific ARARs:

              6 NYCRR Part 257,  Air Quality Standards

              6 NYCRR Part 373,  Fugitive Dusts

              40 CFR 50,  Air Quality Standards

       •      Resource Conservation and Recovery Act

Chemical-specific ARARs:

              Safe Drinking Water Act (SDWA)  MCLs and  MCL Goals (MCLGs)  40 CFR Part 141

              6 NYCRR Parts 700-705 Groundwater and Surface Water Quality Regulations

              10 NYCRR Part 5 State Sanitary Code

Location-specific ARARs:

              Clean Water Act Section 404,  33 U.S.C. 1344

       •      National Historic Preservation Act

Other Criteria, Advisories, or Guidance To Be Considered:

       •      New York Guidelines for Soil  Erosion and Sediment Control

       •      New York State Air Cleanup Criteria,  January 1990

       •      New York State Technical and  Administrative Guidance Memorandum (TAGM)

              New York State Air Guide-1

Cost-Effectiveness

The selected remedy provides for overall effectiveness in proportion to its cost and in mitigating the
principal risks posed by contaminated soil and groundwater. The estimated cost for the selected remedy
has a capital cost of $2,720,000, annual operation and maintenance of $60,000, and a 10-year
present-worth cost of $3,140,000.

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

The selected remedy utilizes permanent solutions and alternative treatment technologies to the maximum
extent practicable by the excavation and disposal of source area soils.

Preference for Treatment as a Principal Element

The selected remedy's utilization of on- or off-site treatment/disposal of the TCA-contaminated source
area soils and off-site treatment/disposal of source area soils exceeding 50 mg/kg PCBs satisfies the
statutory preference for remedies employing treatment that permanently and significantly reduces the
toxicity, mobility, or volume of hazardous substances.

DOCUMENTATION OF SIGNIFICANT CHANGES

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

-------
                                APPENDIX I

                                 FIGURES

FIGURE 1 SITE LOCATION MAP
FIGURE 2 SITE LAYOUT MAP WITH MONITORING WELL LOCATIONS
FIGURE 3 AREAS OF CONCERN
FIGURE4 DISTRIBUTION OF 1,1,1-TCA IN GROUNDWATER

-------
                              APPENDIX II

                                TABLES

TABLE 1       SURFACE SOIL SAMPLING DATA
TABLE 2       PCB SOIL SAMPLING DATA (NORTHEAST PORTION OF SITE)
TABLE 3       SUBSURFACE SOIL SAMPLING DATA
TABLE 4       GROUNDWATER SAMPLING DATA
TABLE 5       SUMMARY OF ALL GROUNDWATER SAMPLING DATE FOR TCA
TABLE 6       CONTAMINANTS OF CONCERN
TABLE 7       SUMMARY OF EXPOSURE ROUTES
TABLE 8       REFERENCE DOSES FOR COMPOUNDS OF CONCERN
TABLE 9       SLOPE FACTORS FOR COMPOUNDS OF CONCERN
TABLE 10      SUMMARY OF NON-CARCINOGENIC RISKS (HI DATA)
TABLE 11      SUMMARY OF CARCINOGENIC RISKS
TABLE 12      FEDERAL MAXIMUM CONTAMINANT LEVELS FOR DRINKING WATER
TABLE 13      STATE MAXIMUM CONTAMINANT LEVELS FOR DRINKING WATER
TABLE 14      NYSDEC TAGM OBJECTIVES FOR VOLATILE ORGANICS IN SOIL

-------
                                 TABLE  2

        SUPPLEMENTAL SOIL CHARACTERIZATION  OF POTENTIAL PCB AREA
                         NOVEMBER/DECEMBER  1993
                               ROSEN  SITE
                           CORTLAND,  NEW YORK

                      PCB FIELD SCREENING RESULTS
    Boring
Identification
Total Depth
Drilled  (ft)
                            P-l
                             P-2
                                                             P-3
                                                                                                P-4
                                                                                                                              P-5
                Interval  (ft) Result  (ppm)   Interval (ft)  Result (ppm)    Interval  (ft) Result  (ppm)
                                                                              Interval (ft) Result  (ppm)   Interval  (ft)  Result  (ppm)
                     0-1
                  1-2
                  2-3
                  3-4
                  4-5
              <25
              <25
              >25
0-1
1-2
2-3
                            5.0
                                                          3.0
                                                                         <25
 0-1
1-2
2-3
                                                                                        3.0
                                                                                                   <25
0-1
1-2
2-3
                                                                                                                               <25
                                                                                                                      3.0
                                                                                                                      0-1
                                                                                                                      0-1
                                                                                                                      1-2
                                                                                                                      2-3
                                                                                                                      3-4
                                                                                                                      4-5
                                                                                                                      5-6
                                                                                                                      6-7
                                                                                                                      7-8
                                                                                                         (Dup)
  >1, >25
   >1,  >25
  >1, >25
  >1, >25
No Recovery
No Recovery
   >1,  >25
  >1, <25
  >1, <25
   10.0
    Boring
Identification
Total Depth
Drilled  (ft)
                               P-6
                                                                P-7
                                                                                             P-E
                Interval  (ft) Result  (ppm)   Interval (ft)  Result (ppm)    Interval  (ft) Result  (ppm)
                                                                                                 P-9                           P-10
                                                                              Interval (ft) Result  (ppm)   Interval  (ft)   Result  (ppm)
   0-1
   1-2
   2-3
   3-4
   4-5
   5-6
   6-7
6-7 (Dup)
>25
>25
<25
                                NR
10.0
                   0-1
                   1-2
                   2-3
                   3-4
                   4-5
                   4-5
                                                              NR
                                                  (Dup)
                          0-1
                          1-2
                          2-3
                          3-4
                          4-5
                                                                                             >25
                                                                                             >25
                     0-1
                     1-2
                     2-3
                            0-1
                            1-2
                                                           10.0
                                                                                          10.0
                                                                                                                         10.0
(See Notes on Page 2)

0294840LOF
                                                                1 of 2
                                                                                                                                         21-Apr-94

-------
                                 TABLE 2

       SUPPLEMENTAL SOIL CHARACTERIZATION OF POTENTIAL PCB AREA
                         NOVEMBER/DECEMBER 1993
                              ROSEN SITE
                          CORTLAND, NEW YORK

                     PCB FIELD SCREENING RESULTS


                                                          P-12                          P-13
                                              Interval  (ft)  Result  (ppm)   Interval  (ft)   Result (ppm)
                                                      0-1        >1,  <25          0-1              <1
                                                      1-2          <1            1-2              <1
                                                      2-3          <1            2-3              <1
                                                      3-4          <1
                                                      4-5        >1,  <25
                                                      5-6          <1
                                                      6-7          <1
                                                      6-7  (Dup)    <1
                                                      7-8          <1

                                                       9.0                         10.0

Notes:
ppm = Parts per million.
Dup = Duplicate sample.
>1  = Greater than 1 ppm.
<25 = Less than 25 ppm.
NR  = No recovery of soil in the split barrel sampler.

0294840LOF                                                 2 of 2                            21-Apr-94
Boring
Identification










Total Depth
Drilled (ft)

P-ll
Interval (ft) Result
0-1 :
1-2 :
1-2 (Dup) :
2-3
3-4
3-4 (Dup)
4-5
4-5 (Dup)
5-6

10.0


(ppm)
>1, <25
>1, <25
>1, <25
<1
<1
<1
<1
<1
<1

-------

-------
                                        TABIiE 4
                             GROUND-lflATER ANALYTICAL RESULTS
                                        EVENT 1
                            GENERAL TSATER QUALITY PARAMETERS
                                        MAY 1991

                                       ROSEN SITE
                                   CORTLAND, NEW YORK

     Compound                         W01     W02    W02 Dup.     W03      W10     Wll

     Total Alkalinity                 89     223     222        137      134     206
     Biochemical Oxygen Demand       <2.0    <2.0    <2.0       <2.0     <2.0    <2.0
     Total Organic Carbon            <1.0     1.8     2.1       <1.0      1.8     2.0
     Chemical Oxygen Demand           10      22      19         11       52      29
     Total Hardness                  143     502     473        235      786    1,320
     Filterables Residue (1805C)     181     491     510        275      312    1,390
     Non-Filterable Residue (1035C)  298    1,350    786        158     5,000   1,490
     Sulfate                          76     284     320         65      688     882
     Silicon Dioxide                 8.8      17     8.6        5.1      110      36

    Notes:


    All concentrations and detection levels are reported as mg/L eguivalent to parts per million  (ppm)
    Dup. - indicates field duplicate.
    The < sign indicates the compound was analyzed for but not detected.


4/23/94

-------
                                                   TABLE 4
                                    GROUND-WATER ANALYTICAL RESULTS - EVENT 2
                                            SEMIVOLATILE ORGANICS
                                                FEBRUARY 1992
                                                  ROSEN SITE
                                              CORTLAND, NEW YORK
       Compound
                             W-15
                                      W-16
                                               W-17
                                                        W-18
W-18
Dup.
                                                                          W-19
                                                                                   W-20
                                                                                            W-21
                                                                                                     W-22
                                                                                                             New  York  State
                                                                                                             Standards/Guiddan      MCLs/
                                                                                                                co Values           MCLGs
Phenol
Bis (2-Chloroethyl)Ether
2-Chlorophenol
1,3-Dichlorobenzene
1,4-Dichlorobenzene
Benzyl Alcohol
1,2-Dichlorobenzene
2-Methylphenol
Bis (2-Chlorolsopropyl)Ether
4-Methylphenol
N-Nitroso-di-n-Propylamine
Hexachloroethane
Nitrobenzene
Isophorone
2-Nitrophenol
2,4 Dimethylphenol
Benzoic Acid                  <62
Bis (2-Choloroethoxy)Methane
2,4-Dichlorohpenol
1,2,4-Trichlorobenzene
Naphthalene
4-Chloroanitine
Hexachlorobutadlene
4-Chloro-3-Methylphenol
2-Methylnaphthalene
Hexachlorocyclopentadlene
2,4,6-Trichlorophenol
                                      <59
                                               <62
                                                        <62
                                                                 <62
                                                                          <62
                                                                                   <56
                                                                                                     <62
                                                 1 a
                                                 1.0
                                                 1 a
                                                 5
                                                 4.7

                                                 4.7
                                                 1 a
                                                 5
                                                 1 a

                                                 5
                                                 5
                                                 50  (G)
                                                 1 a
                                                 1 a

                                                 5
                                                 1 a
                                                 5
                                                 10  (G)
                                                 5
                                                 5
                                                 1 a

                                                 5
                                                 1 a
                                                                                                                                 750/750  (G)

                                                                                                                                 600/600  (G)
                                                                                                                                  70/70  (G)
                                                                                                                                  50/50  (G)
Notes on Page 3 of 3
4/20/94
 1 of 3

-------
                                               TABIiE 4  (Cont.)
                                    GROUND-WATER ANALYTICAL RESULTS - EVENT 2
                                            SEMIVOLATILE ORGANICS
                                                FEBRUARY 1992
                                                  ROSEN SITE
                                              CORTLAND, NEW YORK
       Compound

2,4, 5-Trichlorophenol
2-Chloronaphthalene
2-Nitroaniline
Dimethyl Phthalate
Acenaphthylene
2,6-Dinitrotoluene
3-Nitroaniline
Acenaphthene
2, 4-Dinitrophenol
4-Nitrophenol
Dibenzofuran
2, 4-Dinitrotoluene
Diethylphthalate
4-Chlorophenyl-phenylether
Fluorene
4-Nitroaniline
4, 6-Dinitro-2-Methylphenol
N-Nitrosodiphenylamine  (1)
4-Bromophenyl-phenylether
Hexachlorobenzene
Pentachlorophenol
Phenanthrene
Anthracene
Di-n-Butylphthalate
Fluoranthene
Pyrene
                             W-15
<62
                                      W-16
         <59
<62
         <59
         W-17

         <62

         <62
         W-18

         <62

         <62
         W-18
         Dup.

         <62

         <62
         W-19

         <62

         <62
         W-20

         <56

         <56
                                                                                            W-21
                  W-22

                  <62

                  <62
<62
         <59
                  <62
                           <62
                                    <62
                                             <62
                                                      <56
                                                                        <62
<62
<62
<59
<59
<62
<62
<62
<62
<62
<62
<62
<62
<56
<56
<62
<62
<62
<62
<59
<59
<62
<62
<62
<62
<62
<62
<62
<62
<56
<56
<62
<62
<62
         <59
                  <62
                           <62
                                    <62
                                             <62
                                                      <56
                                                                        <62
 New York State
Standards/Guiddan      MCLs/
    co Values          MCLGs

       1 a
      10 (G)
       5
      50 (G)

       5
       5
      20 (G)
       1 a
       1 a

       5
      50 (G)

      50 (G)
       5
       1 a
      50 (G)

       0.35            1/0  (G)
       1 a             1/0  (G)
      50 (G)
      50 (G)             50
      50
      50 (G)
      50 (G)
Notes on Page 3 of 3
4/20/94
                                     2 of 3

-------
                                                TABIiE 4  (Cont.)
                                    GROUND-WATER ANALYTICAL RESULTS  - EVENT  2
                                            SEMIVOLATILE ORGANICS
                                                FEBRUARY 1992
       Compound

Butylbenzylphthalate
3,3 a -Dichlorobenzidine
Benzo(a)Anthracene
Chrysene
Bis(2-Ethylhexyl)Phthalate
Di-n-Octyl Phthalate
Benzo(b)Fluoranthene
Benzo(k)Fluoranthene
Benzo(a)Pyrene
Indeno(1,2,3-cd)Pyrene
Dibenz(a,h)Anthracene
Benzo(g,h,i)Perylene

TOTAL TIC
                             W-15
                                      W-16
                     ROSEN SITE
                 CORTLAND, NEW YORK

                                    W-18
                  W-17     W-18     Dup.
                                                                          W-19
                                                                                   W-20
<25
         <24      <25      <25      <25
                                             <25
                                                      <22
                                                                                            W-21
                                                               <36
                                                                                                     W-22
                                                                        <25
                                                                                                                     New York State
                                                                                                             Standards/Guidan       MCLs/
                                                                                                                 co Values          MCLGs
100/0 (G)

0.1/0 (G)
0.2/0 (G)
6/0.0 (G)


0.
0.


0.
0.

0.
50
5
,002
,002
50
50
,002
,002
ND
,002
(G)

(G)
(G)

(G)
(G)
(G)

(G)
                                                                                                      0.2/0
                                                                                                      0.2/0
                                                                                                      0.2/0
                                                                                                      0.4/0
                                                                                                      0.3/0
      (G)
      (G)
      (G)
      (G)
      (G)
                                                       535J     778J
                                                                           17J
Notes:

All concentrations, detection levels, standard values, guidance values,  and MCLs/MCLGs  are  reportedd as  Ig/L
eguivallent to parts per billion  (ppb).
Dup. - Indicates field duplicate.
The < sign indicates the compound was analyzed for but not detected.
(1) - This compound cannot be separated from Diphenylamine.
a The standard value of Ig/L applies to the maximum limit for the  sum of all  Phenolic compound concentrations.
TIC - Tentatively Identified Compounds.
ND - Non-detectable.
J - Indicates an estimated value.

References:

Standard and guidance values are according to New York State Department  of Environmental  Conservation (NYSDEC),
Division of Water Technical and Operation Guidance Series  (1.1.1),
Ambient Water Quality Standards and Guidance Values {designated by (G) ] ,  October  1993.

MCLs  [Maximum Contaminant Levels] and MCLGs  [Maximum contaminant Level Goals,  designated  by (G)]  according to the
Code of Federal Regulations, Protection of Environment 40,
Part 141, July 1, 1991, and the Drinking Water Regulations and Health Advisories,  Office  of Water,  U.S.
Environmental Protection Agency, December 1993.
4/20/94
                       3 of 3

-------
Compound
                                                  TABLE  4
                                 GROUND-WATER ANALYTICAL  RESULTS - EVENT 2
                                              PESTICIDES/PCBs
                                              FEBRUARY  1992

                                                ROSEN SITE
                                            CORTLAND,  NEW  YORK
W-01   W-02   W-02 Dup.   W-03   W-04   W-05
                                                                   W-06
                                                                                 New York State
                                                                               Standards/Guidance
                                                                                     Values
                                  MCLs/MCLGs
Aroclor-1016
Aroclor-1221
Aroclor-1232
Aroclor-1242
Aroclor-1248
Aroclor-1254
Aroclor-1260
Notes on Page 7
4/21/94

<0.62
<0.62
<0.62
<0.62
<0.62
<1.2
<1.2
of 7


<0.62
<0.62
<0.62
<0.62
<0.62
<1.2
<1.2



<0.
<0.
<0.
<0.
<0.
<1.
<1.



62 <(
62 <(
62 <(
62 <(
62 <(
2 <:
2 <:


1 of 7
3.56
3.56
3.56
3.56
3.56
L.I
L.I



<0.54
<0.54
<0.54
<0.54
<0.54
<1.1
<1.1



<0.62 <
<0.62 <
<0.62 <
<0.62 <
<0.62 <
<1.2
<1.2 <



CO. 58
CO. 58
CO. 58
CO. 58
CO. 58
cl.2
cl.2



0.
0.
0.
0.
0.
0.
0.



1
1
1
1
1
1
1



a
a
a
a
a
a
a



0.5/0
0.5/0
0.5/0
0.5/0
0.5/0
0.5/0
0.5/0



(G)
(G)
(G)
(G)
(G)
(G)
(G)



a
a
a
a
a
a
a



                                              TABLE  4  (Cont.)
                                 GROUND-WATER ANALYTICAL RESULTS - EVENT 2
                                              PESTICIDES/PCBs
                                              FEBRUARY 1992
Compound
                   W-07   W-C
                                                ROSEN SITE
                                            CORTLAND,  NEW YORK
              W-09   W-10   W-ll   W-ll  Dup.
Aroclor-1016
Aroclor-1221
Aroclor-1232
Aroclor-1242
Aroclor-1248
Aroclor-1254
Aroclor-1260
<0. 62
<0.62
<0. 62
<0.62
<0. 62
4.3
<1.2
<0
<0
<0
<0
<0
<1
<1
.62J <
.62J <
.62J <
.62J <
.62J <
.2J <
.2J <
0.62
0.62
0.62
0.62
0.62
1.2
1.2
<0
<0
<0
<0
<0
<1
<1
.56 <
.56 <
.56 <
.56 <
.56 <
.1
.1
CO. 62
CO. 62
CO. 62
CO. 62
CO. 62
cl.2
cl.2
<0.
<0.
<0.
<0.
<0.
<1.
<1.
62
62
62
62
62
2
2
  New York State
Standards/Guidance
      Values

       0.1 a
       0.1 a
       0.1 a
       0.1 a
       0.1 a
       0.1 a
       0.1 a
MCLs/MCLGs
                                                                                       0.5/0
                                                                                       0.5/0
                                                                                       0.5/0
                                                                                       0.5/0
                                                                                       0.5/0
                                                                                       0.5/0
                                                                                       0.5/0
                                                                          (G)
                                                                          (G)
                                                                          (G)
                                                                          (G)
                                                                          (G)
                                                                          (G)
                                                                          (G)
Notes on Page 7 of 7
4/21/94
                                        2  of  7

-------
                                              TABIiE 4 (Cont.)
                                 GROUND-WATER ANALYTICAL RESULTS - EVENT 2
                                              PESTICIDES/PCBs
                                              FEBRUARY 1992

                                                ROSEN SITE
                                            CORTLAND,  NEW YORK
Compound
                   W-12   W-13
                                 W-14
                                        W-15    W-16
                                                       W-17
                                                               New York State
                                                             Standards/Guidance
                                                                   Values
                                                               MCLs/MCLGs
Aroclor-1016
Aroclor-1221
Aroclor-1232
Aroclor-1242
Aroclor-1248
Aroclor-1254
Aroclor-1260
Notes on Page 7
4/21/94
<0.62
<0.62
<0.62
<0.62
<0.62
<1.2
<1.2
of 7

<0.62
<0.62
<0.62
<0.62
<0.62
<1.2
<1.2


<0.
<0.
<0.
<0.
<0.
<1.
<1.


,62
,62
,62
,62
,62
,2
,2

3
<0.56 <
<0.56 <
<0.56 <
<0.56 <
<0.56 <
^1.1 <
^1.1 "~

of 7
CO. 56
CO. 56
CO. 56
CO. 56
CO. 56
cl.l
cl.l


<0.56
<0.56
<0.56
<0.56
<0.56
<1. 1
<1 . 1


0.
0.
0.
0.
0.
0.
0.


,1
,1
,1
,1
,1
,1
,1


a
a
a
a
a
a
a


0,
0,
0,
0,
0,
0,
0,


.5/0
.5/0
.5/0
.5/0
.5/0
.5/0
.5/0


(G)
(G)
(G)
(G)
(G)
(G)
(G)


a
a
a
a
a
a
a


                                              TABLE 4 (Cont.)
                                 GROUND-WATER ANALYTICAL RESULTS - EVENT 2
                                              PESTICIDES/PCBs
                                              FEBRUARY 1992

                                                ROSEN SITE
                                            CORTLAND,  NEW YORK
Compound
W-18   W-18 Dup.  W-19   W-20
                                                    W-21
                                                           W-22
Aroclor-1016
Aroclor-1221
Aroclor-1232
Aroclor-1242
Aroclor-1248
Aroclor-1254
Aroclor-1260
<0.56
<0.56
<0.56
<0.56
<0.56
<1. 1
<1. 1
<0.56
<0.56
<0.56
<0.56
<0.56
<1. 1
<1. 1
<0.56 <
<0.56 <
<0.56 <
<0.56 <
<0.56 <
<1 . 1 <
<1 . 1 <
CO. 62
CO. 62
CO. 62
CO. 62
CO. 62
cl.2
cl.2
<1.1
<1. 1
<1.1
<1. 1
<1.1
<2.2
<2.2
<0.56
<0.56
<0.56
<0.56
<0.56
<1.1
<1.1
  New York State
Standards/Guidance
      Values

       0.1 a
       0.1 a
       0.1 a
       0.1 a
       0.1 a
       0.1 a
       0.1 a
MCLs/MCLGs
                                                                                       0.5/0
                                                                                       0.5/0
                                                                                       0.5/0
                                                                                       0.5/0
                                                                                       0.5/0
                                                                                       0.5/0
                                                                                       0.5/0
                                                                           (G)
                                                                           (G)
                                                                           (G)
                                                                           (G)
                                                                           (G)
                                                                           (G)
                                                                           (G)
Notes on Page 7 of 7

4/21/94
                   4 of 7

-------
                                             TABIiE  4  (Cont.)
                                 GROUND-WATER ANALYTICAL RESULTS  -  EVENT 2
                                             PESTICIDES/PCBs
                                              FEBRUARY  1992
Compound

alpha-BHC
beta-BHC
delta-BHC
gamma-BHC(Lindane)
Heptachlor
Aldrin
Heptachlor epoxide
Endosulfan I
Dieldrin
4,4'-DDE
Endrin
Endosulfan II
4,4'-ODD
Endosulfan sulfate
4,4' -DDT
Methoxychlor
Endrin ketone
alpha-chlordane
gamma-chlordane
Toxaphene

Notes on Page 7 of 7

4/21/94
                       W-15
                                     W-16
                                               ROSEN  SITE
                                           CORTLAND,  NEW YORK
                                                   W-17
<0.056
<0.056
<0.056
<0.056
<0.056
<0.056
<0.056
<0.056
<0.11
<0.11
<0.11
<0.11
<0.11
<0.11
<0.11
<0.56
<0.11
<0.56
<0.56
<1.1
<0
<0
<0
<0
<0
<0
<0
<0
<0
<0
<0
<0
<0
<0
<0
<0
<0
<0
<0
<1
.056
.056
.056
.056
.056
.056
.056
.056
.11
.11
.11
.11
.11
.11
.11
.56
.11
.56
.56
.1
<0.056
<0.056
<0.056
<0.056
<0.056
<0.056
<0.056
<0.056
<0.11
<0.11
<0.11
<0.11
<0.11
<0.11
<0.11
<0.56
<0.11
<0.56
<0.56
<1.1
                       New York State
                     Standards/Guidance
                           Values

                              ND
                              ND
                              ND
                              ND
                              ND
                              ND
                              ND

                              ND
                              ND
                              ND

                              ND
MCLs/MCLGs
0.2/0.2  (G)
 0.4/0  (G)

 0.2/0  (G)
   2/2(G)
ND
35
5
0.1 b
0.1 b
ND

40/40 (G)

2/0 (G) b
2/0 (G) b
3/0 (G)
5 of 7

-------
                                             TABIiE 4  (Cont.)
                                 GROUND-WATER ANALYTICAL RESULTS  - EVENT  2
                                             PESTICIDES/PCBs
                                              FEBRUARY 1992
Compound           W-18
alpha-BHC
beta-BHC
delta-BHC
gamma-BHC(Lindane)
Heptachlor
Aldrin
Heptachlor epoxide
Endosulfan I
Dieldrin
4,4'-DDE
Endrin
Endosulfan II
4,4'-ODD
Endosulfan sulfate
4,4' -DDT
Methoxychlor
Endrin ketone
alpha-chlordone
gamma-chlordane
Toxaphene
Notes on Page 7 of 7
4/21/94
                                               ROSEN SITE
                                           CORTLAND, NEW YORK
W-18 Dup.   W-19
                                               W-20
                                                       W-21
                                                               W-22
                                                                         New York  State
                                                                       Standards/Guidance
                                                                             Values
MCLs/MCLGs
<0.056
<0.056
<0.056
<0.056
<0.056
<0.056
<0.056
<0.056
<0. 11
<0.11
<0. 11
<0. 11
<0. 11
<0.11
<0. 11
<0.56
<0.11
<0.56
<0.56
<1.1
<0. 056
<0.056
<0. 056
<0. 056
<0.056
<0. 056
<0.056
<0. 056
<0.11
<0. 11
<0.11
<0.11
<0.11
<0. 11
<0.11
<0.56
<0.11
<0.56
<0.56
<1. 1
<0
<0
<0
<0
<0
<0
<0
<0
<0
<0
<0
<0
<0
<0
<0
<0
<0
<0
<0
<1
.056
.056
.056
.056
.056
.056
.056
.056
.11
.11
.11
.11
.11
.11
.11
.56
.11
.56
.56
.1
<0.
<0.
<0.
<0.
<0.
<0.
<0.
<0.
<0.
<0.
<0.
<0.
<0.
<0.
<0.
<0.
<0.
<0.
<0.
<1.
,062
,062
,062
,062
,062
,062
,062
,062
,12
,12
,12
,12
,12
,12
,12
,62
,12
,62
,62
,2
<0
<0
<0
<0
<0
<0
<0
<0
<0
<0
<0
<0
<0
<0
<1
<0
<1
<1
<2
ill
.11
.11
.11
.11
.11
.11
.22
.22
.22
.22
.22
.22
.22
.1
.22
.1
.1
.2
<0.056
<0.056
<0.056
<0.056
<0.056
<0.056
<0.056
<0.056
<0.11
<0.11
<0.11
<0.11
<0.11
<0.11
<0.11
<0.56
<0.11
<0.56
<0.56
<1.1
ND
ND
ND
ND
ND
ND
ND

ND
ND
ND

ND

ND
35
5
0.1 b
0.1 b
ND


0.2/0.
0.4/0

0.2/0



2/2




40/40



2 (G)
(G)

(G)



(G)




(G)

2/0 (G) b
2/0 (G) b
3/0
(G)
                  6 of 7

-------
TABIiE 4 (Cont.)
GROUND-WATER ANALYTICAL RESULTS - EVENT 2
PESTICIDES/PCBs
FEBRUARY 1992

ROSEN SITE
CORTLAND, NEW YORK
Notes:
All concentrations, detection levels, standard values, guidance values, MCLs, and MCLGs are reported as ug/L eguivalent to parts per
billion (ppb).
Dup. - indicates field duplicate.
The < sign Indicates the compound was analyzed for but not detected.
a The standard value and MCLs/MCLGs apply to the maximum limit for the sum of all Aroclor concentrations.
b The standard value and MCLs/MCLGs apply to chlordane.
J - Indicates and estimated value.
ND - Non-detectable concentration by the approved analytical methods referenced in section 700.3 of 6 NYCRA Parts 700-705, Water Quality
Regulations.
- Did not analyze for this parameter.
Bold Indicates NYSDEC standard exceeded; shading indicates federal MCL exceeded.

References:

Standard and guidance values are according to New York State Department of Environmental Conservation (NYSDEC) , Division of Water Technical
and Operation Guidance Series (1.1.1) Ambient Water Quality Standards and Guidance Values [designated by (G)], October 1993.

MCLs [Maximum Contaminant Levels] and MCLGs [Maximum contaminant Level Goals, designated by (G)] according to the Code of Federal
Regulations, Protection of Environment 40, Part 141, July 1, 1991, and the Drinking Water Regulations and Health Advisories, Office of
Water, U.S. Environmental Protection Agency, December 1993.

4/21/94
29941013G 7 of 7

-------
                                                  TABIiE 4

                                 GROUND-WATER ANALYTICAL RESULTS - EVENT 5
                                                INORGANICS
                                                 JUNE 1993

                                                ROSEN SITE
                                            CORTLAND, NEW YORK

Notes:

All concentrations, detection levels, standard values, guidance values, and MCLs/MCLGs/SMCLs are reported
as ug/L eguivalent to parts   per billion  (ppb).
The < sign Indicates the compound was analyzed for but not detected.
B - Indicates a value greater than or egual to the Instrument detection limit but less than the contract
reguired detection limit.
E - Indicates a value estimated or not reported due to the presence of Interference.
S - Indicates value determined by Method of Standard Addition.
J - Indicates an estimated value.
R - Indicates the associated value Is unusable.
a - Applies to the sum of Iron  (maximum 300 ug/L)  and manganese.
Bold Indicates NYSDEC standards or guidance value exceeded; shading Indicates federal MCLs/SMCLs
exceeded.

References:

Standard and Guidance values are according the New York State Department of Environmental Conservation,
Division of Water Technical and Operation Guidance Series Ambient Water Quality Standards and Guidance
Values [designated by (G)], October 1993.

MCLs  [Maximum Contaminant Levels], MCLGs [Maximum Contaminant Level Goals, designated by  (G)] , and SMCLs
[Secondary Maximum Contaminant Levels, designated by  (S)] according to the Code of Federal Regulations,
Protection of Environment 40, Part 141, July 1, 1991,and the Drinking Water Regulations and Health
Advisories, Office of Water, U.S. Environmental Protection Agency. December 1993.	
                                          Table 5
         Summary of Analytical Data  (Detects only) for TCA Concentration in Groundwater
                                         Rosen Site
                                     Cortland, New York
Sampling
  Date
Onsite Wells

W-05    W-06
                                W-01
Downgradient Wells

W-02    W-03    W-10
                                                                W-ll
  Offsite Wells

W-16    W-17    W-18
                                                                                                W-19
 5/91
 2/92
12/93
 3/95
 8/95
12/95
 3/96
 8/96
(4)
7
NA
24 DJ
(2)
NA
NA
NA
3400
1100
100
110
15
5000
1000
240
D
D

DJ

D
D

19
40 D
NA
41 DJ
68
(3.7)
7.4
NA
120 D
190 D
NA
120 J
26
16
22 D
30 D
(4)
8
NA
ND
(0.78 J)
9.4
8.5
NA
73
190
NA
110
100
46
88
NA

D

D
D



270
390
NA
160
84
65
45
41
D
D

J
D

D

NA
36
NA
23
38 D
23
22
NA
NA
16 J
NA
(4)
11
(2.3)
5.2
NA
NA
28
NA
68 DJ
38
(3.6)
25
30 D
NA
260 D
NA
210 D
140
54
62
83
Notes:
Concentrations reported in ug/L  (eguivalent to ppb).
()   Concentration detected, but not above state or federal standards.
J    Indicates estimated value.
D    Indicates sample dilution occurred during analysis.
NA   Not analyzed.
ND   Not detected above method detection limit.

-------
                                             TABIiE  6

                         CHEMICAL OF INTEREST  IN ON-SITE  GROUND WATER
                                        UPPER  OUTWASH

                                          ROSEN SITE
                                      CORTLAND, NEW YORK
Chemical(a)

Organics

1,1-DICHLOROETHANE
1,1-DICHLOROETHENE
1,1,1-TRICHLOROETHANE
1,2-DICHLOROETHANE
1,2-DICHLOROETHENE  (total)
ACETONE
AROCLOR 1254
BROMOFORM
CHLOROMETHANE
CHLOROETHANE
CHLOROFORM
ETHYLBENZENE
METHYLENE CHLORIDE
TETRACHLOROETHENE
TOLUENE
TRICHLOROETHENE
XYLENES

Inorganics

ALUMINUM
ANTIMONY
ARSENIC
BARIUM
CADMIUM
CHROMIUM
COBALT
COPPER
LEAD
MANGANESE
MERCURY
NICKEL
VANADIUM
ZINC
Freguency
    of
Detection
 22/  28
 14/  28
 26/  28
  5/  28
  5/  28
  2/  28
  2/  24
  2/  28
  4/  28
  3/  28
  2/  28
  4/  28
  4/  28
  8/  28
  4/  28
 22/  28
  5/  28
 24/  24
  4/  24
  5/  11
 23/  24
 ll/  24
 21/  24
  7/  24
 21/  24
Range of Sample
Concentrations
 22/  22
 24/  24
  8/  24
 17/  24
  9/  24
 24/  24

















0






0
0
0
0


0
ND -
ND -
ND -
ND -
ND -
ND -
ND -
ND -
ND -
ND -
ND -
ND -
ND -
ND -
ND -
ND -
ND -
.0511 -
ND -
ND -
ND -
ND -
ND -
0.01 -
.0025 -
.0015 -
.0025 -
.0001 -
0.01 -
0.015 -
.0104 -
0.425
0.013
3.1
0.029
0.056
0.017
0.011
0.0002
0.014
0.023
0.0003
0.071
0.096
0.079
1.5
0.15
0.71
67
0.1045
0.116
0.614
0.0898
0.2
0.102
0.571
2.7
7.58
0.0023
0.23
0.278
1.13
Arithmetic
Mean
Concentration (b)
4,
2,
2,
1,
4,
2,
1,
2,
4,
2,
1,
3,
7,
5,
5,
8,
2,
1,
1,
1,
2,
1,
5,
2,
1,
1,
2,
3,
7,
4,
2,
.30E-02
.27E-03
. OOE-01
. OOE-03
. 60E-03
. OOE-02
.28E-03
. 47E-03
.OOE-03
. 40E-03
.OOE-03
.30E-03
.OOE-03
. 10E-03
. 10E-02
.OOE-03
.50E-02
. 87E+01
. 80E-02
. 60E-02
.20E-01
. 60E-02
. 02E-02
. 03E-02
.04E-01
. 67E-01
.20E+00
. OOE-04
.50E-02
. 80E-02
.80E-01
Standard
Deviation
1.01E-01
3.42E-03
5.99E-01
1. OOE-03
1.40E-02
2.90E-02
2.27E-03
9. OOE-03
9. OOE-03
4. OOE-03
1. OOE-03
1.26E-02
1.90E-02
1.63E-02
2.69E-01
2.77E-02
1.27E-01
2.20E+01
2.70E-02
3.20E-02
1.81E-01
2.30E-02
6.30E-02
2.10E-02
1.40E-01
5.40E-01
2.00E+00
5.20E-04
7.40E-02
6.20E-02
3.30E-01
95% Upper
Bound
Concentration (c)
7.80E-02
3. OOE-03
4.08E-01
1. OOE-03
1. OOE-02
2.80E-02
2.20E-02
6. OOE-03
7. OOE-03
4. OOE-03
1. OOE-03
8. OOE-03
1.50E-02
1. OOE-02
1.51E-01
1.80E-02
7.20E-02
2.80E+01
2.90E-02
3.70E-02
3. OOE-01
2.50E-02
8. OOE-02
3. OOE-02
1.70E-01
4.10E-01
3.00E+00
5.50E-04
1.06E-04
7.40E-02
4.20E-01

RME
Concentration
7.80E-02
3. OOE-03
4.08E-01
1. OOE-03
1. OOE-02
1.70E-02
1.10E-02
2. OOE-04
7. OOE-03
4. OOE-03
3. OOE-04
8. OOE-03
1.50E-02
1. OOE-02
1.51E-01
1.80E-02
7.20E-02
2.80E+01
2.90E-02
3.70E-02
3. OOE-01
2.50E-02
8. OOE-02
3. OOE-02
1.70E-01
4.10E-01
3.00E+00
5.50E-04
1.06E-01
7.40E-02
4.20E-01
                                                                                                          (d)

-------
Notes:

(a) All concentrations reported in mg/L. Concentrations reflect analytical results of unfiltered samples from
    all on-site monitoring wells screened in the upper outwash. A sample size less than 24 for inorganics
    indicates rejection of sample results by QA/QC review. Data shown here are for MW-1 through MW-3,
    MW-5 through MW-8, and MW-10 through MW-14.
(b) One-half the detection limit is used as a proxy concentration for non-detects per USEPA guidance.
(c) Based on student's T-distribution with n-1 degrees of freedom, alpha=0.025 in each tail.
(d) The lesser of the 95% upper bound concentration and the maximum detected concentration.

-------
                                            TABIiE 6

                         CHEMICAL OF INTEREST IN ON-SITE GROUND WATER
                                     LOWER SAND AND GRAVEL
Chemical(a)
Frequency
    of
Detection
                                          ROSEN SITE
                                      CORTLAND, NEW YORK
Range of Sample
Concentrations
  Arithmetic
     Mean
Concentration  (b)
Standard
Deviation
   95% Upper
     Bound
Concentration (c)
     RME
Concentration  (d)
Organics
BROMOFORM
  I/   3
                                            ND -   0.0001
                                                                   0.00037
                                                                                     0.00023
                                                                                                       0.00079
                                                                                                                            0.0001
Inorganics
BARIUM
CADMIUM
COPPER
MERCURY
3/
I/
2/
I/
3
3
3
3
0.0521 -
ND -
ND -
ND -
0.364
0.0012
0.0261
0.00028
                                         0.252
                                        0.0014
                                         0.012
                                       0.00016
                                             0.174
                                            0.0010
                                             0.012
                                           0.00010
                                           0.57
                                          0.003
                                          0.034
                                        0.00035
                                         0.364
                                        0.0012
                                        0.0261
                                       0.00028
Notes:

(a) All concentrations reported in mg/L. Concentrations reflect analytical  results  of unfiltered  samples  from all  on-site
    monitoring wells screened in the lower outwash.  (MW-9 AND MW-15).
(b) One-half the detection limit is used as a proxy  concentration for non-detects per USEPA guidance.
(c) Based on students T-distribution with n-1 degrees of freedom, alpha=0.025  in each tail.
(d) The lesser of the 95% upper bound concentration  and the maximum  detected concentration.
249480LOH
                                                                   1  of  1

-------
                                            TABIiE  6

                         CHEMICAL OF INTEREST  IN ON-SITE  GROUND WATER
                                        UPPER  OUTWASH

                                          ROSEN SITE
                                      CORTLAND, NEW YORK
Chemical(a)

Organics

1,1-DICHLOROETHANE
1,1-DICHLOROETHENE
1,1,1-TRICHLOROETHANE
1,2-DICHLOROETHANE
1,2-DICHLOROETHANE  (total)
TETRACHLOROETHENE
TRICHLOROETHENE

Inorganics

ALUMINUM
ANTIMONY
ARSENIC
BARIUM
CADMIUM
COBALT
COPPER
LEAD
MANGANESE
NICKEL
VANADIUM
ZINC
Freguency
of

Detection
4/
2/
4/
I/
3/
2/
4/
4/
3/
3/
4/
3/
3/
4/
4/
4/
3/
3/
4/
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
Range of Sample
Concentrations
0.0015 -
ND -
0.016 -
ND -
ND -
ND -
ND -
0.368 -
ND -
ND -
0.0575 -
ND -
ND -
0.0302 -
0.003 -
0.066 -
ND -
ND -
0.0378 -
0.093
0.011
0.3
0.0008
0.029
0.002
0.019
105.15
0.179
0.03185
0.867
0.0014
0.06955
0.2285
0.130
6.24
0.235
0.1475
0.834
Arithmetic
Mean
Concentration (b)
0.031
0.0033
0.095
0.00058
0.0077
0.00088
0.010
49.7
0.11
0.019
0.41
0.00080
0.037
0.12
0.28
3.4
0.13
0.057
0.44
Standard
Deviation
0.043
0.0052
0.14
0.00015
0.014
0.00075
0.010
44.5
0.063
0.014
0.35
0.00061
0.025
0.086
0.44
3.0
0.093
0.063
0.37
95% Upper
Bound
Concentration (c)
0.10
0.011
0.31
0.0008
0.030
0.0021
0.026
120.5
0.21
0.04
0.97
0.0018
0.077
0.26
0.98
8.17
0.27
0.16
1.03

RME
Concentration
0.093
0.011
0.3
0.0008
0.029
0.002
0.019
105.15
0.18
0.032
0.87
0.0014
0.07
0.23
0.130
6.2
0.23
0.15
0.83
                                                                                            (d)
Notes:

(a) All concentrations reported in mg/L.  Concentrations  reflect  analytical  results of unfiltered samples from all off-site downgradient
    monitoring wells screened in the upper  outwash.  Data  shown  here  are  for  MW - 16 through MW - 19.
(b) One-half the detection limit is used as  a proxy  concentration for non-detects per USEPA guidance.
(c) Based on student's T-distribution with  n-1 degrees  of freedom, alpha = 0.025 in each tail.
(d) The lesser of the 95% upper bound concentration  and the  maximum  detected concentration.
2594840LOH

                                                                    1  of 1

-------
                                                    TAKLE 6

                              CHEMICALS  OF INTEREST IN ON-SITE GROUND WATER
                                                  UPPER OUTWASH

                                                    ROSEN SITE
                                                CORTLAND,  NEW YORK
Chemical(a)

1,1-DICHLOROETHANE
1,1-DICHLOROETHENE
1,1,1-TRICHLOROETHANE
1,4-DICHLOROBENZENE
2-BUTANONE
2-METHYLNAPHTHALENE
2-METHYLPHENOL
2-NITROPHENOL
4,4'-DDE
ACENAPHTHENE
ACENAPHTHALENE
ACETONE
ANTHRACENE
AROCLOR 1254
AROCLOR 1260
BENZENE
BENZOIC ACID
BENZO(a)ANTHRACENE
BENZO(a)PYRENE
BENZO(b)FLUORANTHENE
BENZO(g,h,i)PERYLENE
BENZO(k)FLUORANTHENE
BIS(2-ETHYLHEXYL)PHTHALATE
BUTYLBENZYLPHTHALATE
CHRYSENE
DIBENZOFURAN
DIBENZO(a,h)ANTHRACENE
DI-n-BUTYLPHTHALATE
ETHYLBENZENE
FLUORANTHENE
FLUORENE
INDENO(1,2,3-cd)PYRENE
METHOXYCHLOR
METHYLENE CHLORIDE
NAPHTHALENE
N-NITROSODIPHENYLAMINE
PHENANTHRENE
PHENOL
PYRENE
Frequency
of

Detection
5/
I/
10/
I/
3/
2/
I/
I/
I/
I/
I/
ll/
I/
3/
I/
2/
3/
3/
4/
6/
I/
5/
ll/
6/
8/
I/
I/
6/
3/
6/
2/
2/
I/
2/
2/
I/
5/
I/
7/
18
18
18
19
17
19
18
19
19
19
19
18
19
19
19
18
19
19
18
18
18
18
19
19
19
19
18
19
18
19
19
18
19
18
19
19
19
19
19
Range of Sample
Concentrations
    ND
    ND
    ND
    ND
    ND
    ND
    ND
    ND
    ND
    ND
    ND
    ND
    ND
    ND
    ND
    ND
    ND
    ND
    ND
    ND
    ND
    ND
    ND
    ND
    ND
    ND
    ND
    ND
    ND
    ND
    ND
    ND
    ND
    ND
    ND
    ND
    ND
    ND
    ND
 0.550
  0.01
    44
0.0515
 0.083
    32
 0.305
 0.071
 0.016
  20.7
  3.23
 0.253
    16
   5.8
  0.61
 0.003
   0.1
  17.3
   9.7
   9.1
   3.1
   7.1
  16.7
    14
  14.7
    20
  0.55
  24.7
  1.90
    43
    24
   1.2
 0.066
 0.008
   110
 0.585
    97
  0.14
  41.7
Arithmetic
Mean
Concentration (b)
0.054
0.027
2.6
0.96
0.053
2.6
0.98
0.97
0.025
2
1.1
0.072
1.8
0.49
0.28
0.02
1.8
1.9
1.5
1.5
1.1
1.3
2.4
1.8
1.8
2
1
2.2
0.14
3.2
2.2
1.0
0.13
0.021
6.7
0.99
6.2
0.97
3.3

Standard
Deviation
0.14
0.066
10.4
2.4
0.13
7.5
2.4
2.4
0.025
5.1
2.5
0.13
4.2
1.3
0.27
0.06
2.5
4.5
3.2
3.2
2.5
2.9
4.8
3.8
4.0
5
2.5
6.0
0.44
9.9
5.8
2.5
0.13
0.062
25.1
2.4
22.1
2.4
9.6
95% Upper
Bound
Concentration (c)
0.12
0.06
7.7
2.1
0.12
6.3
2.1
2.1
0.038
4.5
2.3
0.14
3.8
1.1
0.41
0.05
3.0
4.1
3.1
3.1
2.4
2.8
4.7
3.7
3.8
4.4
2.2
5.1
0.36
8.0
5.0
2.3
0.19
0.052
18.8
2.2
16.9
2.1
8.0

RME
Concentration
0.12
0.01
7.7
0.00515
0.083
6.3
0.305
0.071
0.016
4.5
2.3
0.14
3.8
1.1
0.41
0.003
0.1
4.1
3.1
3.1
2.4
2.8
4.7
3.7
3.8
4.4
0.55
5.1
0.36
8.0
5.0
1.2
0.066
0.008
18.8
0.585
16.9
0.14
8.0
                                                                                             (d)

-------
TETRACHLOROETHENE
TOLUENE
TRICHLOROETHENE
XYLENES
2/
6/
7/
4/
18
18
18
18
ND -
ND -
ND -
ND -
1.69
27
0.012
33
0.11
1.8
0.02
2.2
0.40
 6.4
0.06
 7.8
0.31
 5.0
0.05
 6.0
 0.31
  5.0
0.012
  6.0
Inorganics

ALUMINUM
ANTIMONY
ARSENIC
BARIUM
BERYLLIUM
CADMIUM
CHROMIUM
COBALT
COPPER
LEAD
MANGANESE
MERCURY
NICKEL
SILVER
VANADIUM
ZINC
CYANIDE
19/
6/
18/
19/
3/
6/
19/
18/
18/
19/
19/
7/
19/
I/
18/
19/
5/
19
19
18
19
19
19
19
19
19
19
19
19
19
19
18
19
19
4070 -
ND -
1.9 -
19.4 -
ND -
ND -
6.5 -
ND -
10.6 -
8.4 -
53.1 -
ND -
6.5 -
ND -
9 -
32.2 -
ND -
18900
15.2
51.4
291
1.1
10.8
169
15.7
272
1150
8020
0.35
361
1.10
318
1020
2.1
10009.2
1.5
10.2
101.5
0.44
1.5
40.3
9.5
51.6
103.8
1552.6
0.10
59.0
0.4
52.4
374.0
0.79
4220.9
3.5
11.5
76.6
0.23
2.6
45.9
3.4
64.0
260.4
1888.8
0.11
78.1
0.21
91.3
594.2
0.40
12043.7
3.2
15.9
138.4
0.55
2.7
62.5
11.1
83.3
229.3
2463.0
0.15
96.6
0.50
97.6
660.5
0.98
12043.7
3.2
15.9
138.4
0.55
2.7
62.5
11.1
83.3
229.3
2453.0
0.15
96.6
0.50
97.6
660.5
0.98
Notes:

(a) All concentrations reported in mg/kg.
    A sample size less than 19 indicates rejection of sample results by QA/QC review.
(b) One-half the detection limit is used as a proxy concentration for non-detects per USEPA  guidance.
(c) Based on Student's T-distribution with n-1 degrees of freedom, alpha=0.025 in each tail.
(d) The lesser of the 95% upper bound concentration and the maximum detected concentration.
2894840LOH
                                                         1 of 1

-------
                                                            TABIiE 7

                                                  POTENTIAL EXPOSURE PATHWAYS

                                                           ROSEN SITE
                                                       CORTLAND,  NEW YORK
Potentially Exposed
    Population

Current Workers
Potential Trespassers
 Exposure
  Medium

Surface Soil
                             Air
Surface Water/
Sediments

Surface Soils
   Exposure
    Route
Exposure
 Point
Dermal contact;       On Site
Incidental Ingestion

Inhalation of dusts   On Site
and vapors
  Pathway
Selected for
 Evaluation?

     Yes
                                                                                           Yes
                                               Dermal Contact
                      Perplexity Creek
                      and Tributary
Dermal contact;       On Site
Incidental Ingestion
                                                                                            No
                                                               Yes
Reason for Selection or Exclusion

Work efforts currently occurring at the
site reguire the occasional presence of personnel.

Low concentrations of VOCs were detected in air monitoring,
and the lack of complete site cover allows for potential
generation of dusts especially during dry conditions.

Workers do not wade in the Creek of Tributary.
                                  Fencing surrounding the site does not
                                  completely eliminate access; hence,  trespassers
                                  may potentially enter the site and contact
                                  chemicals observed in surface soils.
                             Surface Water
                             Sediments
                             Air
                                               Dermal contact
                                               Dermal contact
                                        Perplexity Creek
                                        and Tributary

                                        Perplexity Creek
                                        and Tributary
                  Inhalation of dusts   On Site
                  and vapors
                                                                                            Yes
                                                                                            Yes
                                                                                            Yes
                                                          Trespassers potentially entering the site
                                                          may be attracted to Perplexity Creek or its tributary.

                                                          Trespassers potentially entering the site
                                                          may be attracted to Perplexity Creek or its tributary.

                                                          Low concentrations of VOCs were detected in air monitoring,
                                                          and the lack of complete site cover allows for potential
                                                          generation of dusts especially during dry conditions.
Hypothetical Future
Excavation Workers
Subsurface Soil   Dermal contact;        On Site
                  Incidental Ingestion
                                             Yes
                                  Future uses of the site may reguire
                                  construction/excavation activities.
                             Air
                  Inhalation of dusts   On Site
                  and vapors
                                                                                            Yes
                                                          Low concentrations of VOCs have been observed in air
                                                          monitoring,  and dry conditions, exposure of subsurface soils
                                                          via excavation,  and use of heavy eguipment may generate
                                                          significant amounts of dusts or increase volatilization.
0394840LOJ
                                                                                       1 of 2
                                                                                                                                                      20-Jan-95

-------
                                                                         TABLE 7

                                                               POTENTIAL EXPOSURE PATHWAYS
Potentially Exposed
    Population

Hypothetical Future
Off-Site Residents
Hypothetical Future
On-Site Residents
 Exposure
  Medium

Ground Water
                             Air
Ground Water
                                                                        ROSEN SITE
                                                                    CORTLAND, NEW YORK
   Exposure
    Route

Ingestion; dermal
contact; Inhalation of
volatiles

Inhalation of dusts
and vapors
Ingestion; dermal
contact, inhalation
of volatiles
  Exposure
   Point
  Pathway
Selected for
 Evaluation?

     Yes
Off-Site Wells
                                           Off-Site Residence  Yes
                                           On-Site Wells
                                                               Yes
Reason for Selection or Exclusion

Downgradent most nearby residents are supplied with
public water. However,  constituents of interest have been
detected in off-site groundwater.

Low concentrations of VOCs have been observed during
air monitoring; and dusts may be transported offsite by
prevailing winds.

Potential future use of the site may be residential.
                             Surface Soil
                             Air
                             Surface Water/
                             Sediment

Hypothetical Future          Ground Water
Commercial/Industrial Worker

                             Surface Soil
                             Air
                  Dermal contact;
                  Incidental Ingestion

                  Inhalation of dusts
                  and vapors
                  Dermal contact
                  Dermal contact
                  Ingestion

                  Dermal contact;
                  incidental ingestion

                  Inhalation of dusts
                  and vapors
                                           On Site
                         On Site
                             Surface Water/    Dermal contact
                             Sediment
                         Perlicity Creek
                         and Tributary

                         On-Site Wells
                         On Site
                         On Site
                                           Perlicity Creek
                                           and Tributary
                                                                                            Yes
                                                                                            Yes
                                                                No
                                                               Yes
                                                                                            Yes
                                                                                            Yes
                                              No
                                                          Potential future use of the site may be residential.
                                 Low concentrations of VOCs have been observed in air
                                 monitoring,  and the site may not be completely covered
                                 in the future.  Hence, continued volatilization and
                                 generation of dusts,  especially during dry conditions,
                                 may potentially occur.

                                 Exposure is possible, but as shown for trespassers,  risks
                                 are negligible, and hence not calculated.

                                 Potential future use of the site may be industrial/commercial.
                                 Potential future use of the site may be industrial/commercial.
                                 VOCs have been observed in air monitoring,  and the site
                                 may not be completely covered in the future.  Hence,
                                 continued volatilization and generation of dusts,  especially
                                 during dry concentrations, may potentially occur.

                                 Workers are unlikely to wade in the Creek.
0394840LOJ
                                                                                 2 of 2
                                                                                                                                                            20-Jan-95

-------
                                                                    Table 8

                             Available Toxicity Criteria for Non-Carcinogenic Health Effects of the Chemicals of Interest  (a)

                                                                   Rosen Site
                                                               Cortland,  New York
CHEMICAL

1, 1-DICHLOROETHANE
1, 1-DICHLOROETHENE
1, 2-DICHLOROETHANE
1,1, 1-TRICHLOROETHANE
1,2-DICHLOROETHENE  (cis-)
1,2-DICHLOROETHENE  (trans-)
1, 4-DICHLOROBENZENE
2-BUTANONE
2-METHYLPHENOL
2-METHYLNAPHTHALENE
2-NITROPHENOL
4-CHLORO-3-METHYL PHENOL
ACENAPTHENE
ACENAPHTHALENE
ACETONE
ALUMINUM
ANTHRACENE
ANTIMONY
ARSENIC
BARIUM
BENZOIC ACID
BERYLLIUM
BIS)2-ETHYLHEXYL)PHTHALATE
BROMOFORM
BUTYLBENZYLPHTHALATE
CADMIUM

CHLOROETHANE
CHLOROFORM
CHROMIUM  (III)
CHROMIUM  (IV)
COBALT
CYANIDE  (free)

COPPER
DIBENZOFURAN
DIMETHYLPHTHALATE
Di-n-BUTYLPHTHALATE
Di-n-OCTYLPHTHALATE
ETHYLBENZENE
ORAL
RfD
(mg/kg-day)
l.OE-01
9.0E-03
ND
ND
l.OE-02
2.0E-02
ND
6.0E-01
5.0E-02
ND
ND
ND
6.0E-02
ND
l.OE-01
ND
3.0E-01
4.0E-04
3.0E-04
7.0E-02
4.0
5.0E-03
2.0E-03
2.0E-02
2.0E-01
5.0E-04 Water
l.OE-03 Food
ND
l.OE-02
1.0
5.0E-03
UR
2.0E-02

ND
ND
10
l.OE-01
0.02
l.OE-01


Effect of Concern Source
NONE
liver lesions b


decreased hematocrit and hemoglobin b
increased alkaline phosphatase

NONE
decreased body weight; neurotoxicity


ND
hepatotoxicity

increased liver weight; nephrotoxicity

NONE
increased mortality, altered blood chemistry
keratosis; hyperpigmentation
increased blood pressure
NONE
NONE
increased relative liver weight
liver effects
altered liver weight
renal damage
renal damage

liver/fatty cysts
NONE
NONE

decreased body weight; thyroid effects; myelin
degeneration


liver, kidney, and testes effects b
increased mortality
liver, kidney, and testes effects b
hepatotoxicity; nephrotoxicity
INHALATION
RfC
(mg/m 3)
5E-01
UR
ND
ND
ND
ND
8E-1
1.0
NV
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
5E-04
ND
ND
ND
ND
ND
UR

10
UR
UR
UR
ND
ND

ND
ND
ND
NV
ND
1.0
 Effect of Concern

kidney damage
Source

  b
liver, kidney effects
decreased birth weight
ND
  b
  b
fetotoxicity
delayed fetal ossification
developmental toxicity

-------
FLUORANTHENE

FLUORENE
LEAD
MANGANESE  (food)
MANGANESE  (water)

See notes an Page 2.

0794840LOJ
4.0E-02

4.0E-02
     ND
l.OE-01
  5E-03
hematological changes; nephropathy;
increased liver weight
decreased erythrocytes

CNS effects
   ND

   ND
   ND
5E-05
5E-05
respiratory effects
psychomotor disturbances
                                                                            1 of 2
                                                                                                    b
                                                                                                    b
                                                                                                                                         20-Jan-95

-------
                                             Table 8

       Available Toxicity Criteria for Non-Carcinogenic Health Effects of the Chemicals of Interest  (a)

                                                Rosen Site
                                              Cortland, New York
       CHEMICAL
       MERCURY
       METHOXYCHLOR
       METHYLENE CHLORIDE
       NAPHTHALENE
       NICKEL
       PHENANTHRENE
       PHENOL
       PYRENE
       SELENIUM
       SILVER
       TETRACHLOROETHENE
       TRICHLOROETHENE
       THALLIUM
       TOLUENE
       VANADIUM
       XYLENES
       ZINC
       Notes:

       ND = No Data
       NV = Not Verifiable.
       UR = Under Review.
       RID = Reference Dose.
       RIG = Reference Concentration.
       CNS = Central Nervous System.
ORAL
RfD
(mg/kg-day)
3.
5.
6.

2.

6.
3.
5.
5.
1.


2.
7.

3.
, OE-04
, OE-03
, OE-02
ND
, OE-02
ND
. OE-01
, OE-02
, OE-03
, OE-03
, OE-02
ND
8E-05
, OE-01
, OE-03
2.0
, OE-01
         Effect of Concern
      kidney effects
      excessive loss of litters
      liver toxicity

      decreased weight (body; major organs)

      decreased fetal weight
      kidney effects
      clinical selenosis
      argyria
      hepatotoxicity

      Increased SCOT and LDH
      altered weight (liver, kidneys)
      NONE
      decressed body weight
Sources;

(a)  IRIS,  1994,  unless otherwise noted.
(b)  USEPA 1994a HEAST.
Source
   b
   b

   b
INHALATION
   RIG
  (mg/m 3)
    3E-04
       NV
      3.0
       ND
       UR
       ND
       NV
       ND
       ND
       ND
       ND
       ND
       ND
    4E-01
       ND
       ND
       ND
Effect of Concern
neurotoxicity

hepatotoxicity
Source
  b
                                 CN3 effects; eye irritation
0794640LOJ
                                                2 of 2
                                                                            20-Jan-95

-------
                                               Table 9

                 Available Toxicity Criteria for Carcinogenic Health Effects  of  the  Chemicals  of  Interest  (a)

                                              Rosen Site
                                           Cortland, New York
CHEMICAL
          Source
1, 1-DICHLOROETHENE
             b
1, 1-DICHLOROETHANE
1, 2-DICHLOROETHANE
1, 4-DICHLOROBENZENE
2-METHYLPHENOL
ARSENIC
BENZENE
BENZO(a)PYRENE
BENZO(b)FLUORANTHENE
BENZO(k)FLUORANTHENE
BENZO(a)ANTHRACENE
BERYLLIUM
BIS(2-ETHYLEHXYL)PHTHALATE
BROMOFORM
polyps;
CADMIUM
CARBAZOLE
CHLOROFORM
CHLOROMETHANE
CHROMIUM (VI)
CHRYSENE
4,4-DDE
DIBENZ(a,h)ANTHRACENE
INDENO(1,2,3-cd)PYRENE
METHYLENE CHLORIDE  (a)
NICKEL (REFINERY DUST)
N-NITROSODIPHENYLAMINE
POLYCHLORINATED BIPHENYLS  (PCBs)

TETRACHLOROETHENE
             d

TRICHLOROETHENE
             d
     ORAL
      BF
I/(mg/kg-day)

      6.0E-01
                                               HHEG
                                               CLASS

9.
2.


2.
7.
7.
7.
7.

1.
7.

2.
6.
1.

7.
3,


7.

4.

ND
1E-02
4E-02
ND
1.75
9E-02
3E+00
3E-01
3E-02
3E-01
4.3
4E-02
9E-03
ND
OE-02
1E-03
3E-02
ND
3E-03
4E-01
7.3
0.73
5E-03
ND
9E-03
7.7
C
B2
B2
C
A
A
B2
B2
B2
B2
B2
B2
B2
ND
B2
B2
C
ND
B2
B2
B2
B2
B2
ND
B2
B2
      5.2E-02
      1.1E-02
                    C-B2
                    C-B2
Tumor Type

 adrenal tumors
                                  liver tumors
                                  skin poplllornas
                                  skin cancer
                                  leukemia
                                  forestomach tumors
                                  total tumors
                                  liver tumors
                                  large intestine: adenomatous polyps;
                                       INHALATION
                                           URF
                                       Source
                                                                           adenocarcinoma
                                  liver tumors
                                  kidney turmors
                                  liver toxicity
                                  liver and thyroid tumors
                                  liver tumors

                                  bladder tumors
                                  liver tumors

                                  liver tumors
                                  liver tumors
 HHEG
1/Ih/m)

 5.0E-05
                                                                                                                                       CLASS
ND
2.6E-05
b ND
ND
4.3E-03
8.3E-06
ND
c ND
c ND
c ND
2.4E-03
ND
1.1E-06
1.8E-03
ND
2.3E-05
1.8E-06
1.2E-02
c ND
c ND
c ND
c
4.7E-07**
2.4E-04
ND
ND




A
A

B2
B2
B2
B2
B2

Bl

B2

A
B2

B2
B2
B2
A


                                                                                        5.8E-07
                                                                                        1.7E-06
                                                                                                          C-B2
                                                                                                          C-B2
Tumor Type

kidney: adenacarcinoma
                                                                                         respiratory  system tumors
                                                                                         leukemia
                                                                                         lung  tumors
                                                                                         lung  tumors
                                                                                         large Intestine:  adenarnatcus

                                                                                         adenocarcinoma
                                                                                         respiratory  system tumors

                                                                                         liver carcinomas

                                                                                         lung  tumors
                                                                                          lung;  liver  tumors
                                                                                          respiratory  system  tumors
                                                                                          lung  tumors


                                                                                          lung  tumors

-------
Notes;

ND = No Data.
SF = Slope Factor.
HHEQ Class - Human Health Evaluation Group Classification.
A - Known human carcinogen.
B1,B2 - Probable human carcinogen.
C - Limited evidence of human carcinogen.
D- Not classified.
E - Negative evidence of human carcinogencity.
URF = Unit Risk Factor.
** URF is derived from a metabolized dose: conversion to SF  is inappropriate.

Sources;

(a) IRS, 1094, unless otherwise noted.
(b) USEPA, 1994a HEAST.
(c) Toxicity values relative to benzo(a)pyrene:
    1.0 for benzo(a)pyrene and dibenz  (a,h) anthracene, 0.1  for benzo(a)anthracene  benzo(b)fluoranthene  and indeno[1,2,3-od]pyrene,
    0.01 for benzo  (k) fluoranthene, and 0.001 for Chrysene.
(d) ECAO, 1992

0794640LOJ                                                                          20-Jan-95

-------
                                   TAKLE 10

                            SUMMARY OF HAZARD INDICES  (His)
      Exposure
      Pathway
                                     ROSEN SITE
                                 CORTLAND, NEW YORK
CURRENT RECEPTORS
                           TRESPASSERS
                                             WORKERS
                                                            EXCAVATION
                                                              WORKERS
                                             HYPOTHETICAL
                                            FUTURE RECEPTORS
                                                      ON-SITE
                                                     RESIDENTS
 OFF-SITE
RESIDENTS
COMMERCIAL/
INDUSTRIAL
  WORKERS
Surface Soil
Incidental Ingestion
Dermal Contact
Inhalation (c)

Subsurface Soil
Incidental Ingestion
Dermal Contact
Inhalation

Ground Water - Upper Outwash
Ingestion
Dermal Contact
Inhalation

Ground Water - Lower Sand and Gravel
Ingestion
Dermal Contact
Inhalation
0.07
5E-04
0.6
NE
NE
NE
NE
NE
NE
.vel
NE
NE
NE
0.0008
1E-04
0.1
NE
NE
NE
NE
NE
NE
NE
NE
NE
(a)NE
NE
NE
0.01
2E-04
0.004
NE
NE
NE
NE
NE
NE
1
0.004
3
NE
NE
NE
31
0.02
1
0.3
IE-05
NQ
NE
NE
3
NE
NE
NE
66
0.02
0.4
NE
NE
NE
0.2
1E-04
2
NE
NE
NE
9
0.005
NE
0.08
IE-06
NE
Surface Water
Dermal Contact
                                 6E-09
                                                   NE
                                                                 NE
                                                                                          NE
                                                                                                            NE
                                                                                                                               NE
Sediments
Dermal Contact
                                NQ  (b)
                                                   NE
                                                                 NE
                                                                                          NE
                                                                                                            NE
                                                                                                                               NE
Total Site HI
                                  0.7
                                                  0.1
                                                               0.01
                                                                                        36(d)
                                                                                                            69
                                                                                                                               12
Notes:
(a) NE = Exposure pathway not evaluated for this receptor.
(b) NQ = Not guantifiable.
(c) Based on predicted maximum annual fenceline concentrations.
(d) Assumes ingestion of upper outwash groundwater. A HI of 4 can be derived assuming  ingestion  of  lower  sand and gravel  groundwater.
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                                    TABLE 11
                               SUMMARY OF CANCER RISKS

                                     ROSEN SITE
                                 CORTLAND, NEW YORK
         Exposure
         Pathway
CURRENT RECEPTORS
                                                              HYPOTHETICAL
                                                            FUTURE RECEPTORS
                        TRESPASSERS

Subsurface Soil
Incidental Ingestion
Dermal Contact
Inhalation (c)

Subsurface Soil
Incidental Ingestion
Dermal Contact
Inhalation

Ground Water - Upper Outwash
Ingestion
Dermal Contact
Inhalation

Ground Water - Lower Sand and Gravel
Ingestion
Dermal Contact
Inhalation
                                           WORKERS
                                                    EXCAVATION
                                                     WORKERS
2E-05
IE-OS
6E-06
NE
NE
NE
NE
NE
NE
Gravel
NE
NE
NE
IE-06
2E-06
IE-06
NE
NE
NE
NE
NE
NE

NE
NE
NE
(a) NE
NE
NE
3E-07
2E-07
2E-07
NE
NE
NE

NE
NE
NE

ON- SITE
RESIDENTS
3E-04
1E-04
4E-05
NE
NE
NE
2E-03
2E-03
2E-04
1E-08
7E-10
7E-08

OFF-SITE
RESIDENTS
NE
NE
4E-05
NE
NE
NE
9E-04
IE-OS
6E-04
NE
NE
NE
COMMERCIAL/
INDUSTRIAL
WORKERS
3E-05
5E-05
2E-05
NE
NE
NE
5E-04
3E-04
NE
3E-09
5E-11
NE
Surface Water
Dermal Contact

Sediments
Dermal contact
      NQ(b)
                             2E-07
                        NE
                                                NE
                                    NE
                                                            NE
                                                            NE
                                                                                    NE
                                                                            NE
                                                                                                    NE
                                                                                         NE
                                                                                                                 NE
Total
                             4E-05
                                             3E-06
                                                         7E-07
                                                                                 5E-03
                                                                                                     2E-03
                                                                                                                   9E-04
Notes:
(a) NE = Exposure Pathway not evaluated for this receptor.
(b) NQ = Not Quantifiable
(c) Based on maximum predicted annual fenceline concentrations.
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APPENDIX III

ROSEN BROTHERS SCRAP YARD SITE
ADMINISTRATIVE RECORD FIIiE
INDEX OF DOCUMENTS

1.0 SITE IDENTIFICATION

1.1 Background - RCRA and other Information

P. 100001- Report: Engineering Investigation at Inactive Hazardous Waste Sites in the State
100315 of New York Phase II Investigations, Rosen Site, City of Cortland, Cortland County, N.Y.,
prepared by Wehran Engineering, P.C., prepared for New York State Department of
Environmental Conservation (NYSDEC), Division of Solid and Hazardous Waste, April 1987.

P. 100316- Report: Engineering Investigation at Inactive Hazardous Waste Sites in the State
100559 of New York, Phase II Investigations, Appendix A-D, Rosen Site, City of Cortland, Cortland
County, N.Y., prepared by Wehran Engineering, P.C., prepared for NYSDEC, Division of
Solid and Hazardous Waste, April 1987.

3.0 REMEDIAL INVESTIGATION

3.1 Sampling and Analysis Plans

P. 300001- Plan: Sampling and Analysis Plan, Volume 1, Quality Assurance Project Plan,
300065 Remedial Investigation/Feasibility Study, Rosen Site, Cortland, N.Y., Participating
Potentially Responsible Parties, prepared by Blasland & Bouck Engineers, P.C., Final
Revision December 1990.

P. 300066- Plan: Sampling and Analysis Plan, Volume 2, Field Sampling Plan, Remedial Investigation/
300305 Feasibility Study, Rosen Site, Cortland, N.Y., Participating Potentially Responsible
Parties, prepared by Blasland & Bouck Engineers, P.C., Final Revision December 1990.

3.2 Sampling and Analysis Data/ Chain of Custody Forms

P. 300306- Rosen Data Summary, Soil Split Sample Results and Rinsate, undated.
300306

P. 300307- Inorganic Chemical Constituents and Physical Characteristics Sampling, undated.
300343

P. 300344- Bromofluorobenzene and Decafluorotriphenylphosphine data package, December 10, 1987.
300725 (Attachment: Analytical Report, Incineration Disposal (Sample FOC01), prepared by
ETC-Findlay Laboratory, prepared for U.S. EPA, Region II, December 8. 1987.)

P. 300726- Data Summary Table for Rosen Scrap Yard Remedial Investigation, prepared by Versar, Inc.,
300737 prepared for U.S. Environmental Protection Agency, Headguarters, Office of Waste Programs
Enforcement, December 11, 1992.

P. 300738- Sampling Data for trial run of treatment of Pump Test effluent with DEC discharge
300739 standards, prepared by Buck Environmental Laboratories, Inc., prepared for Blasland, Bouck
& Lee, Inc., January 18, 1995.

3.3 Work Plans

P. 300740- Plan: Work Plan for Remedial Investigation/Feasibility Study, Rosen Site,
300832 Cortland, N.Y., Participating Potentially Responsible Parties, prepared by Blasland &
Bouck Engineers, P.C., December 1990.

P. 300833- January 1992 Addendum to the Work Plan, Remedial Investigation/Feasibility Study, Rosen
300841 Site, Cortland, N.Y., Final Revision December 1990.

3.4 Remedial Investigation Reports

P. 300842- Chapter 7, "Redox Reactions" from Environmental Chemistry of Soils, written
300849 by Mr. Murray B. McBride, undated.

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P.   300850-     Chapter (w/ attachments)  from the U.S.  Geological Survey Professional Paper #820,
    300865      United States Mineral Resources,  Manganese,  prepared by Mr.  John Van N.  Dorr,  II,  Mr. Max
                D. Crittenden, Jr., and Mr. Ronald G. Worl,  undated.  (Attachment: Study and
                Interpretation of the Chemical Characteristics of Natural Water, Third Edition, prepared
                by the U.S. Geological Survey, Water-Supply Paper 2254, undated.)

P.   300866-     Report:  U.S.  Geological Survey,  Water-Resources Investigations 78-3,  Open-File Report,
    300938      Quality and Movement of Ground Water in Otter Creek- Dry Creek Basin, Cortland County,
                N.Y., prepared in cooperation with Cortland County, N.Y., undated.

P.   300939-     Report:  U.S.  Geological Survey,  Water-Resources Investigations,  Report 85-4090,
    300989      Hydrogeology of the Surficial Outwash Aguifer at Cortland, Cortland  County, N.Y.,
                prepared in cooperation with Susguehanna River Basin Commission, undated.

P.   300990-     Report:  U.S.  Geological Survey,  Water Resources Investigations 78-71, Open File Report,
    301026      Digital Model Simulation of the Glacial-Outwash Aguifer,  Otter Creek-Dry Creek Basin,
                Cortland County,  N.Y., prepared in cooperation with Cortland County, N.Y., undated.

P.   301027-     Report:  Summary Report,  Final Summary Report for Soil and Drum Sampling,  Rosen Brothers
    301249      Scrap Yard Site,  Cortland,  N.Y.,  prepared by Versar,  prepared for the Office of Waste
                Programs Enforcement, U.S.  EPA, Headguarters, June 6, 1991.

P.   301250-     Report:  Remedial  Investigation Report,  Rosen Site,  Cortland,  N.Y.,  Volume 1 of 3,
    301581      Contributing Potentially Responsible Parties,  prepared by Blasland,  Bouck & Lee, Inc.,
                Revised May 1994.

P.   301582-     Report:  Remedial  Investigation Report,  Rosen Site,  Cortland,  N.Y.,  Volume 2 of 3,
    301897      Continuing Potentially Responsible Parties,  prepared by Blasland, Bouck & Lee, Inc.,
                Revised May 1994.

P.   301898-     Report:  Remedial  Investigation Report,  Rosen Site,  Cortland,  N.Y.,  Volume 3 of 3,
    302543      Contributing Potentially Responsible Parties,  prepared by Blasland,  Bouck & Lee, Inc.,
                Revised May 1994.

P.   302544-     Report:  Baseline  Risk Assessment,  Rogan Site,  Cortland,  N.Y.,  Contributing Potentially
    302739      Responsible Parties,  prepared by Blasland,  Bouck Lee,  Inc.,  January 1995.

P.   302740-    Report: Report of Off-Site Soil Gas Modeling for the Remedial Investigation/Feasibility
    302755     Study Oversight at the Rosen Brothers Scrap Yard Site,  Cortland,  Cortland County, N.Y.,
               prepared by ICF Kaiser Environment & Energy Group, prepared for U.S.  EPA, Region II,
               August 1995.  (Attachments:  (1) Letter to Mr.  Mark Granger, Remedial Project Manager,  U.S.
               EPA, Region II, from Ms. Claudine Jones Rafferty, Public Health Specialist II
                (Environment), Bureau of Environmental Exposure Investigation, New York State Department
               of Health  (NYSDOH), re: Rosen Brothers Site,  Report of Off-Site Soil  Gas Monitoring,
               Cortland, Cortland  County,  January 3, 1996,  and  (2) Letter to Mr. Mark Granger, Work
               Assignment Manager, U.S. EPA, Region II, from Mr. Curtis A. Kraemer,  Site Manager, ICF
               Technology, Inc.,  re: Rosen Brothers Scrap Yard Site RI/FS Oversight, Response  to
               Comments on Off-Site Soil Gas Modeling,  March 21, 1996.)

3.5  Correspondence

P.   302756-     Letter to Mr.  Mark Granger,  Remedial Project Manager,  U.S. EPA,  Region II,  from Ms.  Nancy
    302758      E.  Gensky,  Manager,  Geology,  Blasland & Bouck Engineers,  P.C.,  re:  November 1992 Addendum,
                Rosen Site, November 20, 1992. (Attachment:  November 1992 Addendum to the Work Plan,
                Remedial Investigation/Feasibility Study, Final Revision December 1990, Rosen  Site,
                Cortland N.Y., November 20, 1992.)

P.   302759-     Letter to Mr.  Mark Granger,  Remedial Project Manager,  U.S. EPA,  Region II,  from Ms.  Nancy
    302785      E.  Gensky,  Associate,  Blasland &  Bouck  Engineers,  P.C.,  re:  October 1993 Addendum,  Rosen
                Site, October 18, 1993.  (Attachment: October 1993 Addendum to the Work Plan,,  Remedial
                Investigation/Feasibility Study,  Final  Revision December 1990,  Rosen Site,  Cortland,  N.Y.,
                October 18, 1993.)

-------
P.   302786-     Letter to Mr.  Mark Granger,  Remedial Project Manager,  U.S. EPA, Region II, from Ms. Nancy
    302797      E.  Gensky,  Associate,  Blasland,  Bouck & Lee, Inc.,  re: Rosen Site, Aguifer Performance
                Test, February 24, 1994.  (Attachments:  (1)  Table 1 - Ground-Water Analytical Results,
                Rosen Site Aguifer Test Program, Cortland,  N.Y., January  19, 1995,  (2) Table 2 - Summary
                of Transmissivity and Hydraulic conductivity Pumping Test at Well W-25, Rosen Site,
                Cortland, N.Y., January 19,  1995,  (3) Aguifer Test Program, Draft, Well No. W-25,
                prepared by Blasland,,  Bouck & Lee, Inc.,  February 27, 1995, and  (4)  Aguifer Test Program,
                Draft, Well No. W-26,  prepared by Blasland, Bouck & Lee,  Inc., February 27, 1995.)

P.   302798-     Letter to Mr.  Mark Granger,  Remedial Project Manager,  U.S. EPA, Region II, from Ms. Nancy
    302817      E.  Gensky,  Associate,  Blasland,  Bouck & Lee, Inc.,  re: October 1994 Addendum,  Rosen Site,
                November 7, 1994  (Attachment: Addendum to the Work Plan,  Remedial Investigation/
                Feasibility Study, Rosen Site, Cortland, N.Y., prepared by  Blasland, Bouck & Lee,  Inc.,
                October 1994.)

P.   302818-     Memorandum to  Mr.  Augus Eaton, Division of Water,  NYSDEC,  from Mr. David Camp,
    302819      Division of Hazardous  Waste  Remediation (DHWR),  NYSDEC, re:  Reguest for permission to
                discharge groundwater generated from a pump test at the Rosen  Site, January 5, 1995.
                (Attachment: Table listing constituents and concentrations  detected in the groundwater,
                May 1991.)

P.   302820-     Memorandum to  Mr.  David Camp,, DHWR, NYSDEC, from Mr.  Shayne Mitchell,  BWFD,  NYSDEC,
    302821      re:  Rosen Site, Proposed Short Term Wastewater Discharge,  January 11,  1995. (Attachment:
                Effluent Limitations and Monitoring Reguirements, Rosen Site,  Cortland, Cortland County,
                January 11, 1995.)

P.   302822      Letter to Mr.  Mark Granger,  Remedial Project Manager,  U.S. EPA, Region II, from Ms. Nancy
    302824      E.  Gensky, Associate,  Blasland, Bouck & Lee, Inc., re: Aguifer Performance Test, Rosen
                Site, Cortland, N.Y.,  January 18, 1995. (Attachment: Attachment 1 - Effluent Limitations
                and Monitoring Reguirements, Rosen Site, Cortland, Cortland County, January 11, 1995.)

P.   302825-     Letter to the  Director of various divisions and regions, from Mr.  Elliott P.  Laws,
    302835      Assistant Administrator,  U.S.  EPA,  Headguarters,  re:  Land Use in the CERCLA Remedy
                Selection Process, May 25, 1995.

P.   302836-     Letter to Mr.  Mark Granger,  Remedial Project Manager,  U.S. EPA, Region II, from Mr. David
    302872      W.  Hale, P.E., Associate, Blasland, Bouck & Lee Inc.,  re: Additional Preliminary
                Engineering Cost  Estimates, Rosen Site - Cortland, N.Y., June 21, 1995.  (Attachment:
                Additional Preliminary Engineering Cost Estimates,, Rosen Site - Cortland, N.Y., June 21,
                1995.)

P.   302873-     Letter (w/ attachments)  to Mr. Mark Granger, Remedial Project Manager,  U.S. EPA,
    302908      Region II,  from Ms.  Nancy E.  Gensky, Associate,  Blasland,  Bouck & Lee,  Inc.,  re:  Rosen
                Site, August 1995 Ground-Water Sampling and Analysis Event, December 5, 1995.

P.   302909-     Letter (w/ attachments)  Mr.  Mark Granger,  Remedial Project Manager,  U.S.  EPA,  Region II,
    302951      from Ms.  Nancy E.  Gensky,  Associate, Blasland,  Bouck & Lee,  Inc.,  re:  Rosen Site,  December
                1995 Ground-Water Sampling and Analysis Event, March 8, 1996.

P.   302952-     Letter to Mr.  Mark Granger,  Remedial Project Manager,  U.S. EPA, Region II, from Mr.
    302953      David A.  Camp,  P.E.,  Project Engineer,  NYSDEC,  re:  Rosen Site,  Cortland County,  N.Y.,
                April 4, 1996.

P.   302954-     Letter to Mr.  Mark E.  Granger, Remedial Project Manager, U.S.  EPA, Region II,
    302956     from Ms. Nancy E. Gensky, Associate, Blasland, Bouck &  Lee,  Inc., re: Schedule for
               Geophysical Investigation Program, Rosen Site - Cortland, N.Y., April 15,  1996.
                (Attachment: Figure 1 - Proposed Geophysical Survey Area Location Map, Rosen Site,
               Cortland, N.Y., prepared by Blasland, Bouck  & Lee, Inc., undated.)

4.0 FEASIBILITY STUDY
4.6 Correspondence

-------
P.   400001-     Letter to Mr.  Mark E.  Granger,  Remedial Project Manager,  U.S.  EPA,  Region II,
    400090     from Mr. David W. Hale, P.E., Associate, Blasland, Bouck & Lee, Inc., re: Rosen Site -
               Cortland, N.Y., Transmittal of the Sanitary Code, City of Cortland, March 4, 1997.
                (Attachment: The Sanitary Code of the Cortland County Health District, with amendments,
                prepared by the Cortland County Board of Health, undated.)

7.0 ENFORCEMENT

7.3 Administrative Orders
P.   700001-
    700013
P.   700014-
    700026

P.   700027-
    700051
P.   700052-
    700069
U.S. EPA, Region II, Administrative Order, Index No.,  II-CERCLA-80215,  In  the Matter
of Dallas Corporation,, Keystone Consolidated Industries, Inc., Monarch Machine Tool
Company, Respondents,  September 15, 1988.
  U.S.  EPA,  Region II, Administrative Order, Index No., II-CERCLA-90210,
  Niagara Mohawk Power Corporation, Respondent, April 4, 1989.
                                                                                       In the Matter of
  U.S.  EPA,  Region II, Administrative Order on Consent, Index No. II-CERCLA-00204,
  In the Matter of Dallas Corporation, Monarch Machine Tool Company, Niagara Mohawk Power
  Corporation, Respondents, December  28, 1989.

  U.S.  EPA,  Region II, Administrative Order, Index No., II-CERCLA-00205, In the
  Matter of Agway, Inc., Cooper Industries, Inc., Keystone Consolidated Industries, Inc.,
  Potter Paint Company, Inc., Harvey  M. Rosen, Smith Corona Corporation, Respondents,
  February 7, 1990.
7.5 Affidavits

P.   700070-     U.S.  District Court,  Northern District of N.Y.,  Cooper Industries,  Inc.,  et al.,
    700231      Plaintiffs,  vs.  Agway,  Inc.,  at al.,  Defendants,  Deposition of Mr.  R. Michael Scott,
                Volumes 1-4, prepared by Precision Reporters, Inc., October 12, 1992.  (Note: This
                document is CONFIDENTIAL. It is located at the U.S. EPA Superfund Records Center,
                290 Broadway, 18th Floor, N.Y., N.Y. 10007-1866).

P.   700232-     U.S.  District Court,  Northern District of N.Y.,  Cooper Industries,  Inc.,  et al.,
    700446      Plaintiffs,  vs.  Agway,  Inc.,  at al.,  Defendants,  Deposition of Mr.  Carl Edward Kimbrough,
                Volumes 1-2., prepared by Precision Reporters, Inc., October 21, 1992. (Note: This
                document is CONFIDENTIAL. It is located at the U.S. EPA Superfund Records Center,
                290 Broadway, 18th Floor, N.Y., N.Y. 10007-1866).

P.   700447-     U.S.  District Court,  Northern District of N.Y.,  Cooper Industries,  Inc.,  et al.,
    700514      Plaintiffs,  vs.  Agway,  Inc.,  et al.,  Defendants,  Deposition of Mr.  Dennis M. Hollenbeck,
                Volumes 1-2, prepared by Precision Reporters, Inc., November 17, 1992. (Note: This
                document is CONFIDENTIAL. It is located at the U.S. EPA Superfund Records Center,
                290 Broadway, 18th Floor, N.Y., N.Y. 10007-1866).

P.   700515-     U.S.  District Court,  Northern District of N.Y.,  Cooper Industries,  Inc.,  et al.,
    701202     Plaintiffs,  vs. Agway, Inc., et al.,  Defendants,  Deposition of Mr. Deri Ross, Volumes 1-3,
               prepared by Precision Reporters, Inc., March 23,  1993.  (Note: This document  is
               CONFIDENTIAL. It is located at the U.S. EPA Superfund Records Center, 290 Broadway,
              18th Floor,  N.Y.,  N.Y.  10007-1866).

P.   701203-   U.S. District Court, Northern District of N.Y., Cooper Industries, Inc., Plaintiffs,
    701234     vs. Agway,  Inc.,  Defendants,  Deposition of Mr.  William E.  Bondarenko, prepared by Precision
              Reporters, Inc., May 5, 1994.  (Note: This document is CONFIDENTIAL. It is located at  the
              U.S. EPA Superfund Records Center, 290 Broadway, 18th Floor, N.Y., N.Y. 10007-1866).

P.   701235-     U.S.  District Court,  Northern District of N.Y.,  Cooper Industries,  Inc.,  et al.,
    701494      Plaintiffs,  vs.  Agway,  Inc.,  et al.,  Defendants,  Deposition of Mr.  Philip Rosen,  Volumes
                1-5,  prepared by Precision Reporters, Inc., May 23, 1994.  (Note: This document is
                CONFIDENTIAL. It is located at the U.S. EPA Superfund Records Center, 290 Broadway,
                18th Floor,  N.Y., N.Y.  10007-1866).

-------
P.   701495-     U.S.  District Court,  Northern District of N.Y.,  Cooper Industries,  Inc.,  et al. ,
    701546      Plaintiffs,  vs.  Agway,  Inc.,  et al.,  Defendants,  Deposition of Mr.  Glenn E. Matoon,
                prepared by Precision Reporters,  Inc., December 12, 1994.  (Note: This document is
                CONFIDENTIAL. It is located at the U.S. EPA Superfund Records Center, 290 Broadway, 18th
                Floor,  N.Y., N.Y. 10007-1866).

9.0 NATURAL RESOURCE TRUSTEES

9. 4 Correspondence

P.   900001-     Letter  to Mr.  Mark Granger,  Remedial  Project Manager,  U.S. EPA,  Region II,  from Mr.  Todd
    900002      S.  Miller,  U.S.  Department of the Interior,  re:  Request for Information regarding the
                extent of the glaciolacustrine confining layer in the Cortland aguifer at the Rosen
                Superfund site,  January 13, 1994. (Attachment: Figure 2 - Site Map, Rosen Site,  Cortland,
                N.Y., prepared by Blasland & Bouck Engineers, P.C., undated.)

P.   900003-     Letter  to Mr.  Mark Granger,  Remedial  Project Manager,  U.S. EPA,  Region II,  from Mr.  Todd
    900044      S.  Miller,  U.S.  Department of the Interior,  re:  Results of a particle-tracking analyses
                for the Rosen Superfund site, February 24, 1994. (Attachment: Groundwater Path Lines from
                the Rosen Superfund Site,  Cortland,  N.Y., prepared by Mr. Todd S. Miller, undated.)

10.0 PUBLIC PARTICIPATION

10.2 Community Relations Plans

P.   1000001-  Plan: Revised Community Relations Plan, Rosen Brothers Site. Cortland, N.Y.,  prepared by
    1000038    Booz,  Allen & Hamilton,  prepared for  the Office of Waste Programs Enforcement,  U.S.  EPA,
              Headquarters, May 24, 1991.

10.6 Facts Sheets and Press Releases

P.   1000039-  Quick Reference Fact Sheet:  Presumptive Remedy for CERCLA Municipal Landfill Sites,
    1000053   prepared by U.S. EPA, Region II, September 1993.

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                               APPENDIX IV
                             STATE IiETTER OF
                               CONCURRENCE

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

-------
                               APPENDIX V

                         RESPONSIVENESS SUMMARY
                                 FOR THE
                     ROSEN BROTHERS SUPERFUND SITE
              CITY OF CORTLAND, CORTLAND COUNTY, NEW YORK

INTRODUCTION

This Responsiveness Summary provides a summary of citizens' comments and concerns received during the
public comment period related to the remedial investigation and feasibility study (RI/FS) and Proposed
Plan for the Rosen Brothers Site (the "Site") and the U.S. Environmental Protection Agency's  (EPA's) and
the New York State Department of Environmental Conservation's  (NYSDEC's) responses to those comments and
concerns. All comments summarized in this document have been considered in EPA's and NYSDEC's final
decision in the selection of a remedial alternative to address the contamination at the Site.

SUMMARY OF COMMUNITY RELATIONS ACTIVITIES

The RI/FS, which describes the nature and extent of the contamination at and emanating from the Site and
evaluates remedial alternatives to address this contamination, and the Proposed Plan, which identified
EPA's and NYSDEC's preferred remedy and the basis for that preference, were made available to the public
in both the Administrative Record and information repositories maintained at the EPA Docket Room in the
Region II New York City office and at the City of Cortland Free Library located at 32 Church Street,
Cortland, New York. Notices of availability of these documents were published in the Cortland Standard on
November 17, 1997. A public comment period was held from November 17, 1997 through January 16, 1998 1 to
provide interested parties with the opportunity to comment on the RI/FS and Proposed Plan. A public
meeting was held on December 9, 1997 at the New York State Grange Building in Cortland, New York to
inform local officials and interested citizens about the Superfund process, to review planned remedial
activities at the Site, to discuss and receive comments on the Proposed Plan, and to respond to guestions
from area residents and other interested parties. Approximately 25 people, consisting of local
businessmen, residents, representatives of the media, and state and local government officials, attended
the public meeting.

The public comment period originally ran from November 17, 1997 through December 17, 1997. In response to
a reguest for an extension of the comment period, it was extended thirty days to January 16, 1998.

OVERVIEW

The public, generally, supports the preferred remedy, which includes the excavation, treatment, and
disposal of the contaminated soils in four hot-spot areas of the Site, installation of a cap on the
former cooling pond, installation of a site-wide surface cover, and natural attenuation of residual
groundwater contamination.

The public's concerns, which relate to the groundwater contamination, treatment alternatives, community
acceptance, flexibility of the remedy, nature of the site-wide surface cover, groundwater monitoring
program, and institutional controls, are summarized below.

SUMMARY OF WRITTEN AND ORAL COMMENTS AND RESPONSES CONCERNING THE ROSEN BROTHERS SUPERFUND SITE

The following summarizes the oral and written comments received by EPA during the public comment period
and EPA's responses.

Groundwater Contamination

Comment #1: A commenter asked whether the contamination in the groundwater threatens downgradient private
wells. The commenter also asked whether the contaminated groundwater leaves toxic elements behind in its
path and what effect the contaminated groundwater has on the downgradient Tioghnioga River.

Response #1: No private wells are located downgradient of the Site; all residences within the City of
Cortland, including downgradient residences, utilize city water. By the time the groundwater reaches the
river, the contaminants have either been diluted, dispersed, or degraded; the contaminated groundwater
does not leave substantial toxic residues along its path. Removal of the source of contamination, in
combination with continued dilution, dispersion, and degradation of the contaminants, will eventually
eliminate the groundwater contamination.

-------
Comment #2: A commenter asked if there was any possibility that hazardous chemicals would be carried
off-site when there are fluctuations in the groundwater, especially in the vicinity of the former cooling
pond.

Response #2: A thorough investigation of the former cooling pond itself did not locate any hazardous
substances contributing to groundwater contamination (the wastes disposed of in the former cooling pond
consist of, primarily, construction debris and, to a lesser extent, municipal wastes). Contaminated
groundwater was, however, detected immediately downgradient of the former cooling pond; the source of
this groundwater contamination is attributable to a contaminated soil hot spot located outside of the
cooling pond. The selected remedy will remove the source of this contaminant hot spot (as well as another
one located in a different portion of the site). Once the two contaminant hot spots are removed, they
will no longer be a source of groundwater contamination. Further, as is noted in Response #1 above,
dilution, dispersion, and degradation of the contaminants will eventually eliminate the groundwater
contamination.

Comment #3: A commenter asked if EPA would set goals for the reduction of levels of contamination in the
groundwater if natural attenuation was part of the selected remedy.

Response #3: Whether the contaminated groundwater is extracted and treated or natural attenuation is
utilized, the cleanup goals for the groundwater are the same-state and federal groundwater standards. As
part of a long-term groundwater monitoring program, sampling will be conducted in order to verify that
the level and extent of groundwater contaminants are declining from baseline conditions and that
conditions are protective of human health and the environment.

Comment #4: Experience at other sites has shown that natural attenuation of chlorinated organics can take
several decades, even under favorable conditions. If additional source areas remain and/or unfavorable
conditions exist in the groundwater, then natural attenuation may be unacceptably slow. To reduce the
uncertainty in the long-term effectiveness of the remedy, there must be an ongoing evaluation of the
trends in contaminant concentrations and plume geometry from a robust groundwater monitoring network. It
is proposed that EPA install additional monitoring wells during the design phase to strengthen the
groundwater monitoring network. This will help identify any areas which are not degrading in a timely
fashion, and, perhaps, identify any remaining source areas. In addition, during and after the
implementation of the hot spot soil removal, EPA should conduct groundwater monitoring at sufficiently
freguent intervals.

Response #4: The removal of the contaminated soil source areas, extremely high groundwater flow, and the
presence of conditions favorable to contaminant degradation, should lead to timely groundwater
restoration via natural attenuation in about 10 years. Long-term monitoring of the groundwater will
evaluate the remedy's effectiveness. The exact freguency, location, and parameters of the groundwater
monitoring will be determined during the remedial design. Monitoring will include a network of
groundwater monitoring wells; new monitoring wells will be installed, if necessary. Sampling will be
conducted in order to verify that the level and extent of groundwater contaminants are declining from
baseline conditions and that conditions are protective of human health and the environment.

Preferred Remedy

Comment #5: A commenter stated that the Proposed Plan lacks specific details related to the nature of the
surface cover for the Site and the groundwater monitoring program.

Response #5: As potential risks remain even after the excavation of the soil contaminant hot spots, a
surface cover (e.g., asphalt, soil, crushed stone, etc.) will be placed over a large portion of the Site
to prevent exposure to residual levels of contaminants in site soils. All of the cover materials that are
being considered provide the same level of protection. It is our understanding there is local interest in
developing the Site and that a decision may be made within the next few months. Deferring the selection
of the nature of the cover material until the design phase will ensure that it will be compatible with
the future use of the property

Long-term monitoring will be utilized to evaluate the selected remedy's effectiveness. At this time, EPA
has developed only a conceptual plan for the groundwater monitoring program. Additional data and
information need to be collected during the design phase to optimally identify the freguency and
parameters of the groundwater monitoring.

Surface Cover

Comment #6: A commenter indicated that not all of the possible surface cover materials are egually
desirable from the community's point of view. An asphalt cover, for example, might limit many of the
possibilities for the property in the future. To facilitate site redevelopment, the site-wide surface

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cover should not be designed for any specific use. Instead, the design should be flexible enough to
accommodate a variety of uses or tenants. A flexible cover approach would allow, for example, paving some
areas and utilizing other materials for other areas. If clean fill is used, it should be a minimum of two
feet thick (a thicker cover would have greater durability, would be less likely to erode or be
accidentally breached, and would better support multiple uses). A geotextile marker layer at the base of
the cover appears to be an excellent way to ensure that future users of the Site know when they have
reached the base of the cover. Further, a cover maintenance manual should be developed during the design
phase. At a minimum, the manual should address cover maintenance and repairs, minimum health and safety
measures reguired of all contractors building on and/or modifying the cover (i.e., foundation work,
underground utilities, paving, landscaping, etc.), and disposal options for any excavated soils. Ideally,
it should also provide a description of the institutional controls that will be in place to protect the
integrity of the cover. The manual should be made available to prospective tenants, local governments,
and anyone who plans to do construction work at the Site.

The commenter also expressed a desire that the community be involved in the cover material selection
process.

Response #6: EPA agrees that the cover configuration needs to remain flexible to ensure it is appropriate
and compatible with the redevelopment of the property. A marker layer is envisioned as being a component
of every cover configuration. A cover maintenance manual will be formulated during the remedial design
phase and will be available to the community through the Site information repository.

The community's concerns are important to EPA. As part of EPA's ongoing community relations program,
during the remedial design , when a preferred cover material is identified, EPA will seek input from the
community.

Alternatives Evaluation

Comment #7: Several commenters wanted to know why only four alternatives were evaluated in the Proposed
Plan in light of the fact that two of the alternatives-no action and institutional controls-are not
viable and the "groundwater extraction and treatment" alternative appears to be unreasonable given its
cost.

Response #7: The Superfund program reguires that the "no-action" alternative be considered as a baseline
for comparison with the other alternatives. While the "institutional controls" alternative does not
include any physical remedial measures that address the problem of contamination at the Site and the
"groundwater extraction and treatment alternative" is more costly than the alternative that was selected,
EPA considered these three "action" alternatives to be viable and appropriate for consideration. Other
alternatives were considered in the FS but were eliminated because they were either not effective or
their cost was significantly greater than alternatives that could provide the same level of protection
for considerably less cost. The selected alternative (contaminated soil hot spot excavation and disposal,
installation of a cap on the former cooling pond, a site-wide surface cover, and groundwater natural
attenuation) will provide the best balance of trade offs among the alternatives with respect to the
evaluating criteria.

Comment #8: A commenter expressed concern about the acceptability of Alternative 3 (soil hot spot
excavation, former cooling pond cap, site-wide surface cover, and natural attenuation of residual
groundwater contamination) because in order to remove the contaminant hot spots, the excavation areas
would have to be secured 24 hours a day to prevent exposure to wildlife and trespassers. The commenter
also stated that, for the groundwater monitoring program to be efficient, an annual review of the Site
would be more sufficient than every 5 years.

Response #8: Under Alternative 3, to prevent exposure of wildlife and trespassers to hazardous substances
during the remediation of the Site, security measures will be employed at the Site, as necessary, such as
fencing and security guards.

As part of a long-term groundwater monitoring program, samples from upgradient, on-site, and downgradient
groundwater monitoring wells will be collected and analyzed semi-annually in order to verify that the
level and extent of groundwater contaminants are declining from baseline conditions and that conditions
are protective of human health and the environment. The effectiveness of the selected remedy will be
assessed on an ongoing basis as data are collected. In addition, to comply with the reguirements of the
Superfund statute and regulations, the remedy for the Site will be formally reviewed at least once every
five years to assess whether it is being adeguately protective of public health and the environment. If
justified by the ongoing assessments or the 5-year reviews, additional remedial actions may be
implemented to remove or treat the remaining contaminants.

-------
Comment #9: A commenter suggested that it would have been useful to include excavation of the entire
residually-contaminated soils as another alternative.

Response #9: The excavation of all of the residually-contaminated soils, which would involve excavating
to a depth of six feet across 17 acres of the Site, was evaluated in the FS. This alternative was,
however, screened out on the basis of cost--a site-wide surface cover would be similarly protective as
excavating all of the residually-contaminated soils, but would be significantly less expensive.

Former Cooling Pond

Comment #10: A commenter asked why the former cooling pond needs to be capped.

Response #10: While an investigation of the 3-acre former cooling pond did not locate any hazardous
substances, since it was used for the disposal of construction and demolition debris and municipal
refuse, it must be closed in accordance with New York State landfill closure reguirements.

Comment #11: A commenter wanted to know what would be disposed of in the former cooling pond prior to
capping.

Response #11: Only excavated soils characterized as nonhazardous and nonhazardous debris that is located
on the surface of the areas where the Site-wide surface cover will be installed will be consolidated onto
the former cooling pond prior to capping.

Comment #12: A commenter wanted to know what is the nature of the cap proposed for the former cooling
pond.

Response #12: The cap over the former cooling pond must meet the reguirements of New York State 6 NYCRR
Part 360 regulations. Prior to construction of the cap, the consolidated soils, nonhazardous debris, and
existing fill materials will be regraded and compacted to provide a stable foundation and to promote
runoff. The first layer of the cap will be an impermeable layer, made of high-density polyethylene or
clay. A 2-foot soil barrier protection layer will be installed on top of the impermeable layer. Six
inches of top soil and vegetation will be installed on top of the barrier protection layer.

Institutional Controls

Comment #13: A commenter asked whether there would be any mechanisms in place to preclude the drilling of
wells at or downgradient of the Site.

Response #13: The remedy includes taking steps to secure institutional controls, such as deed
restrictions and contractual agreements, as well as local ordinances, laws, or other government action,
for the purpose of, among other things, restricting the installation and use of groundwater wells at and
downgradient of the Site.

Comment #14: A commenter asked at what point in process would the institutional controls be implemented
and who would take the lead in implementing the institutional controls.

Response #14: Institutional controls are usually put into place following the completion of the
construction of the remedy. While it is EPA's responsibility to ensure that institutional controls are
put into place, if the potentially responsible parties (PRPs) agree to perform the design and
construction of the selected remedy, they, most likely, would take an active role in securing the
necessary institutional controls.

Comment #15: A commenter asked if Alternative 3 (contaminated soil hot spot excavation and disposal,
installation of a cap on the former cooling pond, a site-wide surface cover, and groundwater natural
attenuation) is selected, does it preclude the possibility of the excavation of soils underlying the
surface cover, as long as they are treated as hazardous substances.

Response #15: The institutional controls component of the remedy is designed to restrict, though not
necessarily preclude, the excavation of soils underlying the site-wide surface cover. For example, in the
event of the construction of structures on-site, any excavated soils would be tested for hazardous
substances (or may be simply assumed to be hazardous) and disposed of appropriately. A geotextile marker
layer at the base of the cover will ensure that future users of the Site know when they have reached the
base of the cover.

Comment #16: Because this is a site for which redevelopment is expected, the arrangements that will
govern what happens at the Site after the remedy has been implemented are more crucial than at most other
Superfund sites. Accordingly, the necessary institutional controls and regulatory arrangements need to be

-------
explicitly spelled out at the earliest possible date, and the community should be involved in the
process. Experience shows that over the long run, institutional controls are not always honored,
therefore, efforts need to be made to preserve the knowledge about the controls. Important areas that
need to be addressed include: permit restrictions related to the installation of groundwater wells; deed
restrictions for property(ies) above the cover, identification of the various governmental, regulatory,
and private entities which will be involved with the Site and their respective roles and
responsibilities; development and maintenance of a "cover integrity map" which will identify all the
areas in which the site-wide cover has been removed, modified, built over, repaired, etc. and which would
serve as a permanent reference for regulators and contractors intending to do work at the Site. The cover
maintenance manual should be placed in local libraries, attached to the land title records, and
distributed to local governmental agencies.

Response #16: Deed restrictions and contractual agreements and/or local ordinances and laws will be
employed to restrict the installation and use of groundwater wells at and downgradient of the Site,
restrict excavation or other activities which could affect the integrity of the cap/site-wide surface
cover, and restrict residential use of the property in order to reduce potential exposure to site-related
contaminants. While it is EPA's responsibility to ensure that institutional controls are put into place,
if the PRPs agree to perform the design and construction of the selected remedy, they, most likely, will
take an active role in securing the necessary institutional controls. Nevertheless, EPA will ensure that
the necessary institutional controls are scoped out as early as possible and that the controls that are
put into place are properly maintained. EPA will consider the suggestions related to the development and
maintenance of a "cover integrity map" and will make sure that the cover maintenance manual is placed
into the local repository and is made available to all that need access to it.

Potentially Responsible Parties

Comment #17: A commenter wanted to know if the PRPs would be responsible for any additional cleanup costs
should additional soil hot spots be identified in the future.

Response #17: Yes, the PRPs are responsible for financing or performing all remediation deemed necessary
for the Site, even after the Site is deleted from the Superfund National Priorities List.

Fencing Around the Site

Comment #18: A commenter asked whether or not the property will be fenced once the remediation is
completed.

Response #18: The property is currently fenced and will remain fenced until the site-wide cover is in
place. In addition, to protect the integrity of the cap, it is anticipated that a fence will be
constructed around the former cooling pond.

Additional Hot Spots

Comment #19: A commenter asked if EPA was confident that there are no other possible hot spots on the
Site.

Response #19: As part of the RI, over 60 soil samples were collected and analyzed. Conseguently, EPA
believes that the Site has been adeguately characterized. The possibility of the existence of additional
hot spots is unlikely. However, if additional sources of contamination are detected in the future, they
will be considered for remediation, as appropriate.

Perplexity Creek

Comment #20: A commenter asked how the former cooling pond was going to be remediated to ensure that it
does not negatively impact the adjacent Perplexity Creek tributary (i.e., erosion).

Response #20: Appropriate erosion control measures, such as rip rap, will be used to protect the
integrity of the cap on the former cooling pond and minimize impacts to Perplexity Creek.

Superfund Process

Comment #21: A commenter wanted to know if EPA intends to gather any additional information prior to
making a final decision in the ROD.

Response #21: Other than the public comments on the RI/FS reports and the Proposed Plan, EPA did not
intend to obtain any additional information prior to remedy selection.

-------
Comment #22: A commenter expressed concern that the public comment period was being conducted prior to
the signing of the ROD,  since the public might have post-ROD concerns or comments.

Response #22: The purpose of the public comment period prior to the selection of a remedy for this Site
is to solicit public comment on the proposed remedy. After considering the public's comments on the RI/FS
reports and the Proposed Plan,  EPA will select a remedy for the Site. Public participation will not,
however, end at this point. Throughout the design and construction of the selected remedy and during
long-term monitoring, EPA will continue to keep the public informed about site activities and encourage
future comments and inguiries.

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                   APPENDIX V-a

              RESPONSIVENESS SUMMARY
IiETTERS SUBMITTED DURING THE PUBLIC COMMENT PERIOD

-------
Disposal
Safety
Incorporated

To:   Mark Granger, USEPA RPM
From: Steven Amter

Date: January 15, 1998

Subject: Comments on USEPA's Proposed Plan

       Jamie Dangler and Larry Ashley of CURB have asked me to forward to you these comments on EPA's
Proposed Plan.

Natural Attenuation of Ground Water

       The proposed remedy relies on excavation of a few identified contaminant source areas followed by
natural attenuation of the ground water. This is a long term process that relies upon in situ mechanisms
of biodegradation, chemical degradation, volatilization, and other natural mechanisms to reduce
contaminant concentrations to applicable standards.

       Experience at other sites has shown that for chlorinated hydrocarbon contaminants,  this process
can take several decades even under favorable circumstances. If unaddressed source areas remain after the
planned excavation, or unfavorable chemical conditions exist in the ground water, then natural
attenuation will be unacceptably slow and the remedy will fail. Although there is a low probability of
significant source areas remaining within the shallow soil, given the high density of shallow soil
samples, the same confidence is not justified at greater depths where monitoring wells and other data
points are widely spaced.

       To reduce the uncertainty in the long-term effectiveness of the remedy, there must be an on-going
evaluation of the trends in contaminant concentrations and plume geometry from a robust ground-water
monitoring network. We suggest the following measures:

       •      The ground-water monitoring network should be strengthened by additional wells installed
              during the design phase.  This will help identify those areas which are and those which are
              not degrading in a timely fashion, 1 and better identify possible remaining source areas.  At
              a minimum,  there needs to be an additional well cluster along Huntington Street east of the
              W-18/19/20 cluster.

       •      During and after implementation of the remedy,  there needs to be ground-water monitoring at
              sufficiently freguent intervals.  On page 4-8,  the Feasibility Study Report (but not the
              Proposed Plan)  proposed the following schedule,  which seems acceptable:

                Sampling, followed by an evaluation to determine the effectiveness of natural
                attenuation, would be performed on a semi-annual basis for a period of up to ten
                years. Assuming successful natural attenuation with levels approaching  [remedial
                goals] for the Site, the freguency of monitoring the natural attenuation would be
                reduced to an annual basis for the next five years, and then every five years from
                year 16 through year 30.

       Of course, if the PRPs perform these evaluations, the results need to be submitted to the EPA.

Surface Cover

       Since the Proposed Plan does not provide design details, at this time we can only make general
comments about the site-wide cover. We reserve the right to make comments on the specific design as
details become available. To facilitate site redevelopment, we feel that the following elements are
crucial for any final cover design:
1   A review of TCE/DCE and TCA/DCA ratios and available dissolved oxygen data suggest that degradation
of chlorinated contaminants (by anaerobic dechlorination) is occurring most efficiently in area of the
plume that are downgradient of the anoxic water sources  (e.g., the cooling pond and/or the former city
disposal area).
1660 L Street NW, Suite 510
Washington, DC 20036
(202) 293-3993

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CURB, January 15, 1998 page 2

• It should not be designed for any specific use or tenant; instead, the design should be
flexible enough to accommodate a variety of uses or tenants by subsequent modification.

• A site-wide cover consisting totally of asphalt is unacceptable. However, a flexible cover
approach would allow paving over sub-areas.

• With respect to cover design, thicker is better. We believe that a minimum of two feet of
clean soil or equivalent is required. Although we understand that a thicker cover may not
provide additional reductions in risk per se (theoretically, a one-inch soil cover,
unbreached, provides the same level of protection as a five-foot cover), on a practical
basis a thicker cover has greater durability, is less likely to erode or be accidentally
breached, and better supports multiple uses.

• A geotextile marker layer at the base of the cover appears to be an excellent way to ensure
that future users of the site know when they have reached the base of the cover.

• A guide for cover modification and maintenance should be written during the design phase
with input from the cover designers. The guide should be made available to prospective
tenants, local governments, and anyone who plans to do construction work at the site. At a
minimum, it should address cover maintenance and repairs, minimum health and safety
measures required of all contractors building on and/or modifying the cover (i.e.,
foundation work, underground utilities, paving over, landscaping, etc.), and disposal
options for excavated soils. Ideally, it should also provide a useful description of the
institutional requirements that must be navigated by anyone doing work at the site that
could compromise the integrity of the cover.

Institutional Controls and Arrangements

Because this is a site for which redevelopment is planned, the arrangements that will govern what
happens at the site after the remedy has been implemented are more crucial than at many other Superfund
sites. Accordingly, the necessary institutional controls and regulatory arrangements need to be
explicitly spelled out at the earliest possible date, and the community should be involved in the
process. Experience shows that over the long run institutional controls are not always honored, therefore
efforts need to be made to preserve the knowledge about the controls. Important areas that need to be
addressed include:

• Permit restrictions for ground-water wells in the plume area.

• Deed restrictions for property(ies) above the cover.

• Identification of the various governmental, regulatory, and private entities which will be
involved with the site, their respective roles, and the institutional arrangements among
them. It will be particularly important to spell out who will maintain the site-wide cover
and which regulatory agency will provide the oversight to ensure the continued integrity of
the cover, particularly during and after construction or modification by tenants.

• The development and upkeep of a "cover integrity map." This map should be continuously
upgraded to identify all the areas in which the site-wide cover has been removed, modified,
built over, repaired, etc. It would serve as a permanent reference for regulators and
contractors intending to do work at the site.

• A non-technical version of the "Modification and Maintenance Guide" should be placed in
local libraries, attached to the land title records, and distributed to local governmental
agencies.

Notice

This document has been prepared solely for the guidance of CURB Pollution in interpreting
information available to them. Other users should satisfy themselves independently as to fact and
conclusions contained herein. In particular, such users should refer to original sources of information
rather than this memo. This document is not intended for use in any real estate or other transactions,
nor as a public health recommendation, and should not be used or relied upon for such purposes.

-------
                            SUSAN HAJDA BROCK
                             Attorney at Law
306 East State Street, Suite 230
Ithaca, New York 14850
Telephone: (607)  277-3995
                 Fax:  (607)  277-8042
         E-mail: brock@clarityconnect.com
http://www.brock.clarityconnect.com
BY FACSIMILE AND MAIL
                           December 17,1997
Mark Granger, Project Manager
Central NY Remediation Section
ERRD, 20th Floor
U.S. Environmental Protection Agency
290 Broadway
New York, NY 10007-1866

      Re: Rosen Site Proposed Plan

Dear Mark:
       At the December 9 public meeting on the Rosen Site's Proposed Plan,  members of CURB reguested that
the public have the opportunity to comment during the Remedial Design phase. They have particular
concerns about the nature of the site-wide surface cover and groundwater monitoring program.

       The City of Cortland supports CURB'S reguest.  The City agrees with EPA that the details of the
cover and monitoring should be specified during the Remedial Design phases to maintain flexibility.
However, there should be a formal mechanism for public input on these significant issues before EPA makes
its decisions. The City urges EPA to make a commitment to solicit and receive public comment during the
Remedial Design phase.

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      APPENDIX V-b





 RESPONSIVENESS SUMMARY








PUBLIC MEETING TRANSCRIPT

-------
 1    UNITED STATES

 2    ENVIRONMENTAL PROTECTION AGENCY

 3    	

 4                   ROSEN BROTHERS SUPERFUND SITE

 5                          PUBLIC MEETING

 6                                ON

 7                 ENVIRONMENTAL PROTECTION AGENCY'S

 8                         PROPOSED CLEANUP

 9    	

10

12

13          Held at the New York State Grange Building,

14          100 Grange Place, Cortland, New York,

15          on the 9th day of December, 1997,

16          commencing at 7:00 PH.

17

18

19

20

21

22                     PDQ COURT REPORTERS
                         MICHELE L. RICE
23               Shorthand Reporter, Notary Public
                      4815 Barry Hollow Road
24                  Marathon,   New York 13803
                   (607)  849-68847(800) 528-9013

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 1                    APPEARANCES





 2





 3               ABN RYCHLENSKI; Community Relations





 4   Coordinator, US Environmental Protection Agency.





 5





 6               JOEL SINGERMAN; Chief, Central New York





 7   Superfund Section,  US Environmental Protection Agency.





 8





 9               MARK GRANGER; Project Manager, US





10   Environmental Protection Agency.





11
13





14





15




16





17





18





19




20





21





22





23





24

-------
Public Meeting





  1                      MS.  RYCHLENSKI:  Good evening.





  2               Thanks for coming out tonight.  My name is





  3               Ann Rychlenski.  I'm community — I'm a





  4               Community Relations Coordinator with the





  5               US Environmental Protection Agency.  And I'm





  6               sure,  as most of you know,  this meeting here





  7               tonight is to discuss EPA' s Proposed Plan





  8               for the cleanup of the Rosen Brothers site





  9               here in Cortland.





 10                      Before I move onto a couple little





 11               matters of business, I just want to





 12               introduce my colleagues that are here with





 13               me this evening who will be doing the





 14               presentations.





 15                      All the way over to my left is Joel





 16               Singerman (indicating). And Joel's a Chief





 17               of the Central New York Superfund branch at





 18               EPA. He's going to be talking to you about





 19               how the Superfund process works, what it's





 20               all about.





 21                      And right here to my immediate left





 22               is Mark Granger  (indicating).  I think a lot





 23               of you here know Mark.  He's been around a





 24               long time with this site. Mark's the





                  PDQ COURT REPORTERS

-------
Public Meeting





  1               Project Manager of the Rosen site.  He's





  2               going to be talking about what we found in





  3               our site investigations,  basically what we





  4               found,  how much of it's there, where it's at





  5               and what we propose to do with it.





  6                      So,  that's basically what the line of





  7               business is here tonight.





  8                      I want to acknowledge one person





  9               who's here tonight from DEC, David Camp.





 10               Just say hi. New York State DEC. In case





 11               there are any State-related guestions that





 12               come up, I'm sure Dave would be happy to





 13               answer them.





 14                      We have a few things that we do here





 15               at meetings that deal with Proposed Plans.





 16               As you can see we have a stenographer here





 17               tonight, and that's not usual at most public





 18               meetings. And the reason for the





 19               stenographer is because this is, indeed, a





 20               legal record that is being taken, because





 21               public comment is being taken tonight, and





 22               public comment is very, very important in





 23               the Superfund process, because, as Mark will





 24               talk about a little later on, community





                  PDQ COURT REPORTERS

-------
Public Meeting





  1               acceptance of our Proposed Plan is one of





  2               the criteria by which we make a decision on





  3               what we're going to do about the site.





  4                      So, your comments here tonight are





  5               very important. And you will see answers to





  6               your guestions and comments reflected in the





  7               document that we call a Responsiveness





  8               Summary that we put out after we're all done





  9               with this. After we get all of our written





 10               comments in, EPA responds to the public.





 11               So. what you say here tonight is important,





 12               it goes on the record, it will be responded





 13               to in person here,  but it will also be part





 14               of our Responsiveness Summary.





 15                      What I also want to talk about a





 16               little bit is the public comment period for





 17               written comments too. We're in the middle





 18               of a public comment period now. It will end





 19               on December 17th. So, if you don't get in





 20               everything you want to say or ask about





 21               tonight, you want to write it down, send a





 22               guestion or comment on to Mark Granger, his





 23               address is in the Proposed Plan that you





 24               have,  and just make sure that you get it to





                  PDQ COURT REPORTERS

-------
Public Meeting





  1               Mark by close of business December 17th,  so





  2               that those comments and questions are also





  3               included in the public record for the





  4               decision on this site.





  5                      I just want to remind you all to sign





  6               in,  if you haven't already,  so that I can





  7               put you on the mailing list,  keep you there,





  8               make sure I have the right address for you.





  9                      You all have a copy of the Proposed





 10               Plan and you also have copies of the slides





 11               that Mark will be showing tonight that you





 12               can follow along with them.  If you have any





 13               guestions or things that kind of come into





 14               your head, you can jot it right down there,





 15               so feel free to just follow along with that.





 16                      If you want to really look at the





 17               documents involved with this site in depth,





 18               over at the Cortland Free Library we have an





 19               information repository that has all of the





 20               documents pertaining to this site. So, if





 21               you want to do any further exploration





 22               before the end of the comment period for a





 23               written comment, you want to go take a look,





 24               everything is over at the Cortland Free





                  PDQ COURT REPORTERS

-------
Public Meeting





  1               Library.





  2                      I'm going ask you to please keep your





  3               guestions and comments until the end so that





  4               our stenographer can get a clear record of





  5               what happens here tonight. If you do have a





  6               guestion or comment, please stand, give your





  7               name,  if you choose to, if you don't want





  8               to, that's okay, and speak clearly so that





  9               she can get the record down as accurately as





 10               possible.





 11                      I think that's about it. I'm going





 12               to turn it over to Joel, talk about the





 13               Superfund process. Thank you.





 14                      MR. SINGERMAN: Can you all see





 15               that?  Can everyone see this or is it too





 16               light?





 17                      Several well-publicized toxic waste





 is               disposal disasters in the late 1970's,  among





 19               them Love Canal, shocked the nation and





 20               highlighted the fact that past waste





 21               disposal practices were not effective.  In





 22               1980 Congress responded with the creation of





 23               the Comprehensive Environmental Response,





 24               Compensation & Liability Act, more commonly





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  1               known as Superfund.





  2                      The Superfund law provided Federal





  3               funds to be used for the cleanup of





  4               uncontrolled and abandoned hazardous waste





  5               sites and for responding to emergencies





  6               involving hazardous  wastes. In addition,





  7               EPA was empowered to compel those





  8               responsible for these sites to pay for or to





  9               conduct the necessary response actions.





 10                      The work to remediate a site is very





 11               complex and takes place in many stages.





 12               Once a site is discovered,  an inspection





 13               further identifies the hazards and





 14               contaminants. A determination is then made





 is               whether to include the site on the Superfund





 16               National Priorities  List,  a list of the





 17               nation's worst hazardous waste sites.  Sites





 18               are placed on the National Priorities List





 19               primarily on the basis of their scores





 20               obtained on the hazard ranking system, which





 21               evaluates the risk posed by the site.  Only





 22               sites in the National Priorities List are





 23               eligible for work by Superfund.





 24                      The selection of a remedy for a





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  1               Superfund site is based upon two studies:  A





  2               Remedial Investigation and a Feasibility





  3               Study.  The purpose of the Remedial





  4               Investigation is to determine the nature and





  5               extent  of the contamination at and emanating





  6               from the site and the associated risk to





  7               public  health and the environment. The





  8               purpose of the Feasibility Study is to





  9               identify and evaluate remedial alternatives





 10               to address that contamination.





 11                      Public participation is a key feature





 12               in a Superfund process. The public is





 13               invited to participate in all decisions that





 14               will be made at the site. Through the





 15               Community Relations Coordinator meetings





 16               such as this one are held as necessary to





 17               keep the public informed about what is





 18               happening at the site and what is planned.





 19               The public is also given the opportunity to





 20               comment on the results of the investigation





 21               and studies conducted at the site and the





 22               proposed remedy.





 23                      After considering public comments and





 24               the proposed remedy, a Record of Decision is





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  1               signed.  A Record of Decision documents why





  2               a particular remedy was selected.  The site





  3               then enters the remedial design phrase,





  4               where the plans and specifications





  5               associated with the selected remedy are





  6               developed. The remedial action,  which





  7               begins after design work is completed, is





  8               the actual hands on-work associated with





  9               cleaning up the site.





 10                      Following the completion of the





 11               remedial action the site is monitored, if





 12               necessary. Once the site no longer poses a





 13               threat to public health or the environment





 14               it can be deleted from the Superfund





 15               National Priorities List.





 16                      MR. GRANGER: Hi. My name is Mark





 17               Granger. I've been EPA's Remedial  Project





 18               Manager for the Rosen site for the past





 19               seven years. Tonight I'll be discussing





 20               site background, the Remedial Investigation,





 21               Feasibility Study,  the risk assessment and





 22               presenting EPA's preferred alternative.





 23                      The Rosen site is located on





 24               Pendleton Street here in the City  of





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  1               Cortland.  From the 1890's through the early





  2               '70s the Wickwire Facility operated on forty





  3               acres between South Main Street and





  4               Pendleton Street, smelting scrap metal and





  5               using that smelted metal in the manufacture





  6               of nails,  wire,  wire mesh,  screening and





  7               wire products. After the plant closed in





  8               the early '70s,  Philip Rosen was contracted





  9               to demolish the western twenty acres and in





 10               exchange was granted title to the eastern





 11               twenty acres. Rosen operated on the site





 12               from 1975 to 1985.





 13                       Ann, can we see figure 2?





 14                       MS.  RYCHLENSKI: Sure.





 15                       MR.  GRANGER: Here's South Main





 16               Street,  Pendleton Street to the right, you





 17               can see the site outlined,  and Philip Rosen





 18               was contracted to demolish this twenty acres





 19               and in exchange was granted the eastern





 20               twenty acres of the site (indicating).





 21                       We go to the next slide. Rosen





 22               activities at the site included scrap





 23               processing and garbage hauling. The site





 24               has been unoccupied since Rosen declared








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  1               bankruptcy in 1985.





  2                      A New York State Department of





  3               Environmental Conservation investigation of





  4               the site in 1986 found significant levels of





  5               contamination in groundwater and soil.  As a





  6               result of this investigation,  the site  was





  7               added to Superfund's National  Priority  List





  8               in March of 1989.





  9                      In January of 1990 a group of parties





 10               potentially liable for cleanup agreed to





 11               conduct the RI/FS for the site,  and these





 12               parties are known as potentially-responsible





 13               parties or PRP's.





 14                      Next slide. EPA conducted a removal





 15               action at the site from 1987 to 1989, where





 16               drums of hazardous materials were removed,





 17               along with severely-contaminated soils,





 is               transformers filled with PCBs.  And,  in





 19               addition, the site was fenced.





 20                      The RI was performed from 1990 to





 21               1995, with additional studies  being





 22               conducted from 1995  to 1997. I'll be





 23               discussing the results of these studies in a





 24               little while.





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  1                      The potentially-responsible parties





  2               performed the investigation of the site with





  3               EPA oversight,  and studies included





  4               groundwater sampling,  soil sampling,  both





  5               subsurface and surface soil,  sediment,





  6               surface water and air sampling,  along with





  7               test hitting and pump testing of the





  8               aguifer.





  9                      The results of the Remedial





 10               Investigation:  There are two groundwater





 11               units beneath the site,  an upper outwash





 12               unit and a lower sand and gravel unit.  The





 13               groundwater flow direction is to the





 14               northeast. The City of Cortland being





 15               situated at the confluence of several





 16               valleys has massive groundwater flow moving





 17               beneath the site, far more that you would





 18               find in most other areas of New York State,





 19               and probably a lot of other places,  as well.





 20                      The RI found that groundwater





 21               contamination is confined to the upper





 22               outwash unit.





 23                      The Cortland County -- I'm sorry.





 24               The City of Cortland water supply is located





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  1               far upgrading of the site.  Most soil





  2               samples were found to contain contaminants





  3               above State guidance levels.  And the RI





  4               further found that surface  water,  sediment





  5               and air have not been significantly impacted





  6               by the site.





  7                      During the RI, groundwater and soils





  8               were sampled for VOCs,  SVOCs, PCBs and





  9               metals. There were seven full rounds of





 10               groundwater sampling. And based on the





 11               groundwater and soil sampling efforts, it





 12               was concluded that there was  an intermittent





 13               source of contamination in  soils in the area





 14               of well 6.  I'll show you the  figure in a





 15               moment.





 16                      In addition,  the RI  concluded that





 17               VOC levels  in groundwater leaving the site





 18               were relatively low and have  undergone





 19               significant decline over time.





 20                      Results of an investigation of the





 21               cooling pond area, which I  will show you in





 22               a moment,  concluded that the  cooling pond





 23               area of the site was not a  significant





 24               source of contamination to  the aguifer.





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  1                      However,  several areas of significant





  2               PCB and TCA contamination were found,  as





  3               well as low to moderate levels of





  4               contaminants elsewhere in soils on the site.





  5                      Results of a drum investigation





  6               concluded that there were no buried drums





  7               able to be located at the site.





  8                      Can we see figure 2?





  9                      MS. RYCHLENSKI: Figure 2, sure.





 10                      MR. GRANGER: Groundwater flow is to





 11               the northeast. This being north, northeast,





 12               groundwater moves this way, northeast and





 13               out past Pendleton Street and then moves





 14               into an easterly direction as it goes out





 is               into the aguifer at large  (indicating).





 16                      And then figure 1, Ann.





 17                      MS. RYCHLENSKI: Mm-hm.





 18                      MR. GRANGER: There's valleys coming





 19               in from the west and from the north. The





 20               City of Cortland is situated at the





 21               confluence of these valleys and groundwater





 22               tends to move in the vicinity of the site to





 23               the northeast, to a westerly direction and





 24               then out down the Tioughnioga River Valley





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  1               (indicating).





  2                      And the Cortland water supply, as you





  3               can see,  the groundwater flow moves in this





  4               direction and down Cortland County





  5               (indicating).  The City of Cortland water





  6               supply is in this vicinity, far upgrading of





  7               groundwater associated with the Rosen site





  8               (indicating).





  9                      Okay,  Ann, figure 3.





 10                      MS. RYCHLENSKI: Mm-hm.





 11                      MR. GRANGER: The RI found a





 12               significant area of contamination in the





 13               well 6 area,  as well in the T-02 areas





 14               (indicating).  Those are areas where there's





 15               TCA-contaminated soils and PCB-contaminated





 16               soils in the northeastern portion of the





 17               site and in the Gantry Crane portion of the





 18               site.





 19                      The cooling pond, located at the





 20               southern portion of the site, comprises





 21               about three acres,  with the remaining area





 22               of the site being about seventeen acres





 23               (indicating).





 24                      Okay,  next slide.





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  1                       MS.  RYCHLENSKI:  Mm-hm.





  2                       MR.  GRANGER:  Sampling results from





  3               the I — the RI were  compiled and analyzed





  4               in the risk assessment.  The purpose of the





  5               risk assessment is to determine whether the





  6               sites poses a threat  to the human health and





  7               the environment should nothing be done.





  8                      EPA' s acceptable risk range for





  9               non-carcinogenic compounds is a hazard index





 10               less than or equal to 1,  and for





 11               carcinogenic compounds a 10 to the minus 4,





 12               to 10 to the minus 6  risk, which basically





 13               translates to an increased cancer rate from





 14               1 in 10,000 to 1 in 1,000,000.





 15                      Results for groundwater found that





 16               risks fell outside EPA's acceptable risk





 17               range, with non-carcinogenic risk coming in





 18               at -- with a hazard index of 66 and





 19               carcinogenic risks 1.5 times 10 to the minus





 20               3.





 21                      Results for soil also fell outside





 22               EPA' s accepted risk range only for





 23               non-carcinogenic risks,  with a hazard index





 24               64. All other risks were in or below EPA's





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  1                acceptable risk range.





  2                       Next slide.





  3                       MS. RYCHLENSKI: Mm-hm.





  4                       MR. GRANGER: EPA's evaluated four





  5               alternatives in the Proposed Plan to address





  6               these risks.





  7                      Alternative 1: No action,  is





  8               reguired as a baseline in comparison and





  9               assumes only monitoring over time,  which is





 10               the — $440,000 is the cost associated with





 11               monitoring over a ten-year period.





 12                      Institutional controls alternative





 13               assumes that the only action taken, aside





 14               from monitoring, is administrative action in





 15               the form of deed restrictions or





 16               restrictions on groundwater extraction for





 17               potable use, restrictions on excavating





 18               soils, et cetera, things of that nature.





 19               The cost was carried over, because the





 20               administrative actions were assumed to be in





 21               addition to monitoring over a ten-year





 22               period.





 23                      Alternative 3 includes hot spot





 24               excavation of the TCA and PCB areas, a cap





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  1               over the cooling pond,  with a cover over the





  2               remaining portion of the site and natural





  3               attenuation of residual groundwater.  The





  4               total cost over a ten-year period was





  5               collated to be $3.1 Million.





  6                       Can we go to figure 3,  Ann?





  7                       MS. RYCHLENSKI: Mm-hm.





  8                       MR. GRANGER: Basically alternative





  9               3 would provide for excavation of the two





 10               TCA areas and two PCB areas,  with a cap





 11               placed over the cooling pond, which we call





 12               a cooling pond. It was  formerly a cooling





 13               pond but was used as a  landfill,  we call it





 14               the cooling pond area.  It was a landfill





 15               that accepted construction and demolition





 16               debris. The most appropriate approach





 17               toward final closure of that would be





 18               placing a cap over the  top of it and a





 19               permeable cover placed  across the remaining





 20               portions of the site. And groundwater would





 21               be naturally attenuated over time.





 22                       We'll go to --





 23                       MS. RYCHLENSKI: Want to go back to





 24               the —





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  1                      MR.  GRANGER:  Yes.





  2                      Alternative 4 includes the same first





  3               three components of alternative 3,  which is





  4               hot spot excavation, cooling pond cap, and a





  5               cover over the remaining portion of the





  6               site, and in addition provides for





  7               groundwater extraction and treatment.





  8                      Can we go to the figure?





  9                      MS.  RYCHLENSKI: Mm-hm.





 10                      MR.  GRANGER:  So, in addition to





 11               excavation of the TCA and PCB areas with a





 12               cap over the cooling pond portion of the





 13               site and a permeable cover placed across the





 14               remaining portions of the site, a series of





 15               extraction wells would be placed across the





 16               northern perimeter of the site that would





 17               effectively create a hydraulic barrier or





 18               wall, if you will, which would extract





 19               groundwater and provide for a line to be





 20               constructed out to the Tioughnioga River





 21               where it would be discharged. And the total





 22               cost for that — can you go back to the





 23               other slide?





 24                      MS.  RYCHLENSKI: Sure.





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  1                      MR.  GRANGER:  — which was





  2              calculated over a five-year period was $19.8





  3              Million.





  4                      In evaluating the relative merits of





  5              each of the alternatives, EPA weighs each of





  6              them against nine evaluation criteria or





  7              what we call insure EPA's nine criteria, the





  8              threshold criteria being overall protection





  9              of human health and the environment and





 10              compliance with environmental regulations.





 11              Those are the primary criteria we look at,





 12              and then we move to the balance: Long-term





 13              effectiveness and permanence, reduction of





 14              toxicity, mobility or volume through





 is              treatment, short-term effectiveness,





 16              implementability and cost-modifying





 17              criteria, State and community acceptance,





 is              which Ann had mentioned earlier.





 19                      After careful consideration, EPA's





 20              preferred alternative is alternative 3,





 21              contaminated soil hot spots excavation and





 22              disposal, installation of cap on former





 23              cooling pond, site-wide surface cover and





 24              natural attenuation of residual groundwater





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  1               contamination.





  2                      EPA' s rationale was this alternative





  3               provides the best balance among the nine





  4               criteria.  It's  protective of human health





  5               and the environment,  reduces toxicity,





  6               mobility and volume through permanent





  7               solution,  it involves a simple





  8               implementation  with simple maintenance and





  9               uses known effective technologies and is





 10               cost effective.





 11                      Thank you for your time. I'll turn





 12               the meeting back over to Ann.





 13                      MR. SINGERMAN: The preferred remedy





 14               that was just described is just that, it's





 15               EPA' s preferred remedy, and EPA is not going





 16               to make a final selection until we've





 17               considered all  public comments and after the





 18               completion of the comment period.





 19                      MS. RYCHLENSKI: Okay, thank you,





 20               Joel.





 21                      Okay. Mark is going to — you've got





 22               the lights.  That's what we take EPA's





 23               engineers with  us for, these guys can do





 24               lights.





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  1                      Okay.  All right,  we'll take





  2               guestions.  As I asked before, just speak





  3               clearly,  stand and give your name if you





  4               feel comfortable with that,  so our





  5               stenographer can get a good record.





  6                      Any guestions or comments?





  7                      (Whereupon there was no verbal





  8               response)





  9                      MS.  RYCHLENSKI: No guestions or





 10               comments?





 11                      MS.  KATHLEEN HENNESSY: I have a





 12               guestion.





 13                      MS.  RYCHLENSKI: Okay.





 14                      MS.  KATHLEEN HENNESSY: My name is





 15               Kathleen Hennessy. And I'm just wondering





 16               about the groundwater, because even though





 17               it doesn't go into the City's water supply,





 18               what effect does it have on people with





 19               wells who-are within the path of the





 20               groundwater? I mean, I know you said it





 21               goes into the Tioghnioga River, but --





 22                      MR.  GRANGER: Right. We've done





 23               some investigations in terms of when there





 24               is any wells and we're unable to find anyone








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  1              with a well.  Basically the plume is





  2              confined within the City of Cortland,  and





  3              it's my understanding that everyone within





  4              the confines  of the City limits is on City





  5              water.





  6                      MS.  KATHLEEN HENNESSY:  Until it





  7              goes into the river.





  8                      MR.  GRANGER: Well, by the time it





  9              gets to the  river,  to tell you the truth,





 10              basically it's petered out.





 11                      MS.  KATHLEEN HENNESSY:  And it





 12              doesn't -- but doesn't it leave toxic





 13              elements behind on the path?





 14                      MR.  GRANGER: Contaminants can be





 15              absorbed to  soil,  but in general the type of





 16              contamination that's leaving the site is





 17              basically swept along and disbursed over





 18              distance and over time,  which is -- that's





 19              not something that's exclusive to this site,





 20              that's something that basically occurs at





 21              all sites. And if you're removing sources,





 22              as we are here, you would expect that





 23              petering out  period to be shorter and





 24              shorter.





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  1                       MS.  RYCHLENSKI:  Yes,  sir?





  2                       MR.  LARRY ASHLEY:  My name is Larry





  3              Ashley.  I wanted to start with a comment.





  4              We've handed to Mark a number of questions





  5              that have arisen from a Curb meeting which





  6              considered the Proposed Plan as you gave it





  7              to us,  and we sort of like to present those





  8              publicly, sort of get some reaction now and





  9              get them on the record.





 10                      The first thing that I would like to





 11              say is that in terms of Ann's statement that





 12              community acceptance of the plan is part of





 13              what you aim at, Curb at least finds it





 14              difficult to simply accept the plan since





 15              some crucial elements of the plan are





 16              postponed to the design phase, in particular





 17              the nature of the cap that's going to be on





 18              the site and details about the groundwater





 19              monitoring, both of which-are elements for





 20              the nine years of the development of this





 21              that Curb has been fairly involved in and





 22              considers to be fairly crucial from the





 23              point of view of the welfare of the





 24              community.





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  1                      So,  we just wanted to report to you





  2               that we were finding it hard to just sort of





  3               selectively say yes,  this looks like a good





  4               thing for the community and/or no,  this





  5               looks like something that we would not like





  6               in the long run,  because - because of the





  7               absence of specificity for a few details,  in





  8               particular the cap and the details about





  9               groundwater monitoring,  both of which are





 10               postponed until the design phase is





 11               completed.





 12                      Is that clear?





 13                      MR.  GRANGER: Yes,  that's perfectly





 14               clear.





 15                      And let me say that I think that one





 16               of the strong points of this Proposed Plan





 17               is that it does not specify the cap





 18               configuration nor the specifics of the





 19               groundwater monitoring plan. EPA is





 20               definitely looking for a protective cap and





 21               it's definitely looking for a comprehensive





 22               monitoring program. If you specify both of





 23               those — but let me just start with the cap.





 24               If you specify what the cap is, you're





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  1               basically closing off the possibilities for





  2               what you may want to do with the cap in the





  3               future.





  4                      So,  what our cap -- ultimately what





  5               our cap components are going to be could be





  6               a number of things, all of which would have





  7               an eguivalent protection, such as you could





  8               have an impermeable, geotextile layer with a





  9               foot of soil with grass on top. If we





 10               specified that, then it could be difficult





 11               to say okay, now we're going to build a road





 12               across the cap, which that would be a part





 13               of the cap too, but that would be asphalt





 14               with gravel. Or if you wanted to put gravel





 15               and put something else across the top,  or if





 16               you wanted to build a building, there's a





 17               lot of ways -- there's a lot of directions





 18               that this site could go in terms of the





 19               future.





 20                      At a site where the site was not





 21               going to do anything, nothing was going to





 22               happen with the site, you could specify,  you





 23               could say,  all right, we're going to put,





 24               you know, we're going to asphalt the entire





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  1               site and that's going to be the end of that.





  2                      I think that we're trying to allow





  3               the maximum flexibility in terms -- and





  4               provide that benefit to the community.





  5                      Similarly,  with the monitoring





  6               program, we could specify now what that





  7               monitoring program is,  but then you lock it





  8               in, and it is possible that EPA would want





  9               to reguire additional monitoring points,





 10               would want to go out further into the





 11               aguifer or reguire the installation of





 12               monitoring wells,  and if we went down on





 13               record as saying that this is going to be





 14               the monitoring program when we forge a legal





 15               agreement with whoever's going to implement





 16               the remedy, that's locked in in the Record





 17               of Decision, so -- okay, did I answer your





 18               guestion?





 19                      MR. LARRY ASHLEY: You did,  although





 20               it postpones rather than answers some of our





 21               difficulties. Because amongst those





 22               proposed remedies, they may all be egually





 23               protective, but they're not egually





 24               desirable from the point of view,  in our





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  1                judgment,  of the community and what the





  2                community will live with for the term after





  3                that.  So,  that's a crucial item which





  4                remains for us crucial,  and which we're





  5                going to,  I guess, continue to be asking or





  6                trying to make sure that what eventually is





  7                decided is not anything that the community





  8               is going to find hard to live with in the





  9               long run.  Such, in my judgment, would be an





 10               asphalt cover.





 11                      Putting an asphalt barrier, right





 12               there limiting, I think,  a lot of the





 13               possibilities for -- for the community in





 14               the future. This is a crucial issue for us.





 15               That's all I'm saying.





 16                      MR.  GRANGER: Are you worried about





 17               an asphalt cover?





 18                      MR.  LARRY ASHLEY:  Am I worried





 19               about it?





 20                      MR.  GRANGER: Are you worried that's





 21               going to be what's going to happen?





 22                      MR.  LARRY ASHLEY:  That's one





 23               possibility, yes.





 24                      MR.  GRANGER: Well, without going





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  1               down completely,  you know,  staking my





  2               reputation on it,  we're not really looking





  3               to place an asphalt cover over the site. I





  4               know that's not necessarily reassurance for





  5               you.





  6                      MR. LARRY ASHLEY: That's a relief,





  7               because in the document that you sent to us,





  8               in parentheses there was always the soil,





  9               gravel, asphalt trilogy, and one of those --





 10               one item in that trilogy is importantly, I





 11               think,  undesirable for the community, so --





 12                      MR. GRANGER: Right.





 13                      MR. LARRY ASHLEY: — if EPA was,





 14               you know,  still envisioning doing that, then





 15               that would be crucial for us.





 16                      MR. GRANGER: I think the only





 17               asphalt that we would envision on the Rosen





 18               site would be a road, in terms of like





 19               developing the property for-some other





 20               purpose.





 21                      MR. LARRY ASHLEY: Well, we look





 22               forward to that.





 23                      MR. SINGERMAN: How about the other





 24               items within parentheses, do you object to





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 1                any of the other ones or just the asphalt?





 2                       MR. LARRY ASHLEY: The crushed --





 3                what was it -- crushed gravel or crushed





 4                stone or whatever it was,  I don't guite know





 5                what that amounts to, and I guess I don't





 6                remember that that ever arose in your





 7                discussion with us as the basic cover, but





 8                that covered by soil seems plausible, but





 9                crushed stone by itself, I mean, I would





10                want to know what the ramifications are for





11                that remedy too.





12                       MR. GRANGER: Okay.





13                       MS. RYCHLENSKI: I think too — I





14                just want to interject for a moment: that





15                as we go into remedial design, we'll





16                continue to work with Curb and with the rest





17                of the community on that design. We don't





18                just come out and spring a remedial design





19                on people and say, hey, here, this is what





20                it is. We come out, we'll talk about it,





21                we'll have a meeting similar to this one,





22                maybe a meeting before that, maybe one after





23                that, depending on what the community's





24                reguirements are and the community's





                  PDQ COURT REPORTERS

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  1               concerns are.  But here it is written in





  2               stone and we're never going to talk to you





  3               again,  we'll never do that. We've been in





  4               touch and we'll stay in touch. You guys





  5               have been very important in this process.





  6                      MR. SINGERMAN: Plus if you have any





  7               ideas now or any recommendations in writing,





  8               we consider that --





  9                      MS. RYCHLENSKI: Absolutely.





 10                      MR. SINGERMAN: — for the future.





 11                      MS. RYCHLENSKI: Absolutely.





 12                      Yes, sir?





 13                      MR. SAM FARRELL: I'm Sam Farrell.





 14               You mentioned the groundwater extraction and





 15               treatment. Could you go into more detail on





 16               that?  If that happened, would that





 17               eliminate a cap if that was done in this





 18               particular area?





 19                      MR. GRANGER: No, it would not.





 20                      MR. SAM FARRELL: It would not.





 21                      MR. GRANGER: The purpose of the cap





 22               is to eliminate exposure to surface soils.





 23               Are you talking about the cap over the





 24               cooling pond or the surface cover?





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  1                      MR.  SAM FARRELL:  Yes,  well --





  2                      MR.  GRANGER:  Or both?





  3                      MR.  SAM FARRELL:  About the





  4               groundwater extraction,  would that also --





  5                      MR.  GRANGER:  Right.





  6                      MR.  SAM FARRELL:  —  would you be on





  7               the Rosen site? of course would that.





  8                      MR.  GRANGER:  Okay.





  9                      MR.  SAM FARRELL:  Would you also be





 10               drying out  the pond?





 11                      MR.  GRANGER:  Okay. The pond is not





 12               necessarily -- the pond is  not any different





 13               from the remainder of the site in terms of





 14               the aguifer.  It's not a pond. It's





 15               basically a landfill. It's  been covered and





 16               it's flat on -- it's at ground level on one





 17               end and it's mounded up fifteen feet high on





 18               the other end, so there's no  pond, per se.





 19               Basically when we say pond, we mean





 20               landfill. And there's construction debris,





 21               actually most of the Wickwire buildings were





 22               dumped into the cooling pond.





 23                      So,  as we were digging down doing our





 24               investigation, what you tended to see was





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  1               twenty feet deep of bricks mixed in with





  2               timbers and metal rods and things of that





  3               nature. So, the groundwater extraction and





  4               treatment actually -- just backing up — and





  5               one of the things I had mentioned in my talk





  6               was that there's a massive groundwater flow





  7               that's moving beneath the Rosen site and





  8               beneath the Cortland area in general.





  9                      As you extract groundwater, you





 10               wouldn't tend to dry out anything. You'd





 11               tend to extract the groundwater, you'd





 12               extract a lot,  probably a million to a





 13               million and a half gallons a day, but you





 14               wouldn't be drying anything out. So, that





 15               would not influence the cap at all. The





 16               purpose of the cap doesn't have anything to





 17               do with the groundwater, per se.





 18                      Is that clear?





 19                      MR. SAM FARRELL: Yes.





 20                      MR. GRANGER: Did I address your





 21               guestion?





 22                      MR. SAM FARRELL: (Nods head)





 23                      MR. GRANGER: Okay.





 24                      MS. RYCHLENSKI: Yes?





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  1                      MS.  JAMIE DAGLER: Jamie Dagler





  2               (phonetic)  from Curb. Our second question,





  3               Mark,  is kind of related to the first





  4               question that Larry asked. We're just





  5               pressing you a little bit more on this. In





  6               general we just want to know why more





  7               options weren't costed out in the Proposed





  8               Plan?





  9                      For example, you know, the fact that





 10               the Proposed Plan,  there are four





 11               alternatives; however, alternative 1 and





 12               alternative 2 are out of the question, I





 13               think,  right?





 14                      MS.  RYCHLENSKI: Well, I think





 15               alternative 2 is a viable alternative, but





 16               that's a subjective statement.





 17                      MS.  JAMIE DAGLER: Okay. I think I





 18               can,  at least speaking for Curb, it would





 19               certainly not be acceptable to Curb, but --





 20               so, alternatives 3 and 4 are what we agreed





 21               is really the only real alternatives for any





 22               kind of significant cleanup of the site, and





 23               alternative 4, certainly based on the





 24               informal discussions that we've had with you





                  PDQ COURT REPORTERS

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  1               all along,  appears to be a bit unreasonable





  2               perhaps,  given the cost in relation to the





  3               likely benefit of groundwater treatment,





  4               which leaves us then with only one





  5               alternative.





  6                       Our guestion or our comment is this:





  7               Now,  again, I am kind of echoing what Larry





  8               already said, given the lack of detail about





  9               groundwater monitoring, about the surface





 10               cover and alternative 3 as it has been





 11               presented in the plan,  we're wondering if --





 12               if what the Proposed Plan actually





 13               incorporates is an alternative which





 14               actually encompasses many possible





 15               alternatives?





 16                       In other words, why, perhaps,





 17               wouldn't you have costed out the difference





 18               between an asphalt cover as opposed to a





 19               one-foot soil cover with a geothermal —





 20               what's it called -- a geotextile cover as





 21               opposed to a two-foot soil cover, et cetera?





 22                       In other words, are there significant





 23               differences in cost to doing these kinds of





 24               options or doing some combination of those





                  PDQ COURT REPORTERS

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  1               things?





  2                        And,  you know,  as you know,  we





  3               certainly raised the issue of a soil





  4               scrapedown with you informally earlier in





  5               the process,  and I guess we want to,  for the





  6               record, ask that again.  Wouldn't it have





  7               been useful to cost out, as another





  8               alternative,  a soil scrapedown?





  9                       For example, it seems to us as a soil





 10               scrapedown would have been a more permanent





 11               remedy. And if that's the case, would it





 12               have been cost effective in terms of





 13               reducing long-term maintenance costs? For





 14               example, as opposed to blacktop, asphalt or





 15               other alternatives?





 16                       So, again, we're a little bit





 17               perplexed about what we see as a narrow --





 18               really literally just one realistic option





 19               which seems to have within it the





 20               possibility of a number of options which are





 21               not costed out as separate options.





 22                       Does  that make sense to you?





 23                       MR. GRANGER: Yes. As I had





 24               mentioned as  we were talking to Larry, I





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  1               can't emphasize enough that the flexibility





  2               that's built into the site-wide cover system





  3               is a strong point in the Proposed Plan,  not





  4               a weakness.





  5                      In fact, most likely the cost





  6               difference between an asphalt cap,  a gravel





  7               cap, a dirt cap is probably not all that





  8               much. What we were looking to get was the





  9               reduction of risk by ensuring that the site





 10               was covered from one end to the other. The





 11               flexibility comes in whereby if I specify --





 12               or I shouldn't say I -- but if EPA specifies





 13               in a Record of Decision some cap





 14               configuration and then locks it in, it





 15               eliminates the possibility of anything else





 16               being done on those portions of the site,





 17               which is significant. That's seventeen





 18               acres of property, seventeen acres of





 19               undeveloped property in the City of





 20               Cortland.





 21                      Again, for example,  if I specify --





 22               if EPA specifies a grass -- a dirt cover





 23               covered with soil and grass from one end to





 24               the other, it doesn't allow the possibility





                  PDQ COURT REPORTERS

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Public Meeting                                              39





      1     for then going in and putting a road and





      2     developing some sort of — performing some





      3     kind of development on the property in the





      4     future. Is that clear?





      5          MS. JAMIE DAGLER: Yeah,  although I





      6     guess I'm kind of confused, maybe,  about the





      7     process and the significance of the ROD.





      8     For example,  I guess I just envision this as





      9     proceeding such that at some point there is





     10     a definite decision made about all aspects





     11     of the cleanup, because, I mean,  we've been





     12     under the impression that eventually EPA





     13     turns the site over to the DEC, for example,





     14     and at that point obviously you're no longer





     15     involved.





     16          So, I'm not clear on -- I understand





     17     your point about flexibility, and certainly





     18     makes perfect sense, but at what point does





     19     the final configuration of what's going to





     20     be done there become decided?





     21          And certainly Curb has been





     22     interested in making sure that public





     23     comment — official public comment





     24     certainly, as well as the kind of informal





                               PDQ COURT REPORTERS

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      1     interchange will continue to be allowed





      2     through all of those.  Maybe we're just not





      3     clear about how the process will actually





      4     unfold after the ROD.





      5          MR.  GRANGER: Well,  we'll be looking





      6     for a design document, whether we're





      7     performing it or whether the PRPs are





      8     performing it, within -- let me see --





      9     probably 1999, and at that point you'll be





     10     finalizing all your cover configurations and





     11     your monitoring programs and your cap





     12     configuration.





     13          MS.  JAMIE DAGLER: So, the





     14     flexibility you're talking about, you're





     15     conceiving about the desirability of that





     16     flexibility for that now two- or three-year





     17     period?





     18          MR.  GRANGER: That's the way I





     19     envision it at present,  yes, although





     20     depending on what the City of Cortland





     21     you know, as you know, EPA's not in the land





     22     development, we're just allowing for it.





     23     Depending on how creative the City of





     24     Cortland is or Cortland County or whoever's








                         PDQ COURT REPORTERS

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Public Meeting                                              41





      1     approaching the City in the meantime would





      2     dictate somewhat how that flexibility is





      3     going to fall out.





      4          I don't think I was done with the





      5     second part of Jamie's guestion. Before we





      6     move on





      7          MS.  RYCHLENSKI: I think Larry had





      8     another guestion.





      9          MR.  LARRY ASHLEY:  No, it was really





     10     a follow to Jamie's.





     11          MR.  GRANGER: Okay, jump in.





     12          MR.  LARRY ASHLEY: The flexibility





     13     might seem important if you were going to





     14     gather some new information meanwhile, that





     15     is if we're keeping flexible for a couple of





     16     years, and that's an advantage. Presumably





     17     you're going to get some information that





     18     will come down solidly on the side of one





     19     form of capping rather than another or one





     20     display of monitoring rather than another.





     21     Are we planning to gather information during





     22     the intervening couple of years so that we





     23     gather information we don't presently have





     24     in making that decision?





                       PDQ COURT REPORTERS

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      1          MR.  GRANGER: Absolutely.





      2          MR.  LARRY ASHLEY:   Absolutely,  okay.





      3          MR.  GRANGER:  The information is





      4     going to be is anyone interested in putting





      5     some kind of enterprise on the site?





      6          MR.  LARRY ASHLEY:   That's the





      7     information that we're --





      8          MR.  GRANGER:  Yes.





      9          MR.  LARRY ASHLEY:   Not testing or





     10     anything like that?





     11          MR.  GRANGER:  No,  absolutely.





     12          MR.  LARRY ASHLEY:   Okay.





     13          MR.  GRANGER:  No,  there's no testing





     14     necessary for implementation of a cover on





     15     the site.





     16          And getting to a second part of





     17     Jamie's — is that clear, Larry?





     18          MR.  LARRY ASHLEY:   Yeah.





     19          MR.  GRANGER:  Getting to the second





     20     part, Jamie, we have four options in the





     21     Proposed Plan. There were several other





     22     options that were evaluated in the





     23     Feasibility Study. Obviously we can't put





     24     all of  the information that's included in








                       PDQ COURT REPORTERS

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      1     the Feasibility Study into the Proposed





      2     Plan.





      3          One of the sections of the





      4     Feasibility Study screens out alternatives





      5     that don't really appear to be realistic





      6     from a number of standpoints. And one of





      7     those addressed excavation of the entire





      8     contaminated soils from one end of the site





      9     to the other, which basically entails a





     10     massive undertaking of digging down six feet





     11     across the entire site,  which is what we





     12     found after going through several test pits,





     13     that the soils look like they've been





     14     impacted in some way down to six feet, and





     15     without, like, testing,  which is another





     16     probably tens of thousands of dollars more,





     17     that we would -- that that was not really a





     18     realistic approach.





     19          And that covering the site meets the





     20     goal of reducing the risk, which is





     21     basically the entire thrust of the program





     22     is to -- in balancing the nine criteria





     23     coming up with approaches that address site





     24     risks, not necessarily ease of maintenance








                       PDQ COURT REPORTERS

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      1     over the long term,  which is a





      2     consideration,  but granted,  doing that





      3     massive undertaking would make things very





      4     simple, because you're just removing





      5     everything,  you don't have anything else to





      6     worry about.  But when you start putting





      7     that into --  weighing that against what your





      8     other options are, it doesn't appear to be





      9     realistic.





     10          MS. RYCHLENSKI:  This gentleman here





     11     has been waiting  (indicating).





     12          MR. ERIC DUMOND:  Yeah, my name is





     13     Eric DuMond from Curb.  And this right now





     14     we're in the  middle of the public comment





     15     period. What  happens if, say, a





     16     year-and-a-half from now after the Record of





     17     Decision is made you're talking about maybe





     18     new technologies possibly arising to -- that





     19     may alter,  you know, the cap, will there be





     20     any future public comment period before the





     21     Record of Decision is implemented, before





     22     action is taken?





     23          MR. GRANGER:  The Record of Decision





     24     being implemented as is, there would not be











                       PDQ COURT REPORTERS

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      1     any further comment period unless there's a





      2     comment period associated with closeout.





      3          MR. SINGERMAN:  Well, there are





      4     mechanisms in the law that allow for changes





      5     to remedies. There's ROD amendments,





      6     there's an explanation of significant





      7     differences, and really it's a function of





      8     what type of changes are necessary.





      9          Quite freguently during design we may





     10     find something in the site that changes our





     11     opinion about the remedy, a new technology





     12     may come about,  so we have the ability and





     13     flexibility to change remedies.





     14          So, depending upon which mechanism we





     15     would use to change a remedy, we would seek





     16     public comment to make sure that -- that





     17     whatever we changed would be, you know,





     18     acceptable to the public, and in the same





     19     way we're reguesting public comment now.





     20          MR. ERIC DUMOND:  But the only





     21     the problem that I see is that, you know,





     22     we're in the Record of Decision, you know,





     23     public comment comes before the Record of





     24     Decision. We don't have any definite





                       PDQ COURT REPORTERS

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      1     really any definite answer as -- as far as





      2     specifics on the site.  How can we, as a





      3     community, or as an individual really,





      4     decide whether this proposal is acceptable





      5     to us?





      6          That's, you know, we had a meeting





      7     the other night — last night, and I was --





      8     I'm guite -- I'm very adamant about





      9     imposing, you know, the proposal number 3.





     10     because without any specifics, how can this





     11     community accept this proposal as is?





     12          And if after the record of, you know,





     13     or after this time period is over we're not





     14     allowed — our comments aren't going to





     15     influence the EPA' s decision on this until





     16     extremely late in the process, I don't think





     17     that's doing this community any justice.





     18          MR. SINGERMAN:  The Record of





     19     Decision comment period is just a comment on





     20     the remedy. EPA will accept comments all





     21     throughout the process, through the





     22     deletions of the site from the National





     23     Priorities List, at any time. We're always





     24     willing to hear what people have to say








                       PDQ COURT REPORTERS

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      1     about what we're doing.





      2          We have meetings all the time,  you





      3     know.  We can have -- like say,  for example,





      4     in various, you know, through the design, I





      5     mean, really what we feel is necessary, what





      6     the public feels is necessary as far as





      7     keeping them informed and trying to make





      8     sure the public's happy with what's going on





      9     with the site.





     10          We're not trying to ram this down





     11     anyone's throat. Basically we're here,





     12     there's some basic principles of the remedy





     13     that are being identified and we're





     14     excavating four known hot spot areas that we





     15     believe are the significant sources of





     16     contamination. We're covering over the





     17     former cooling pond. And I mean, we





     18     specifically identified, you know, those, I





     19     mean, those are the major part of the





     2 0     remedy.





     21          And the other part covering over





     22     is we're not exactly sure what we'll be





     23     covering with, but, I mean, whatever we do,





     24     we'll be protective of public health and the








                       PDQ COURT REPORTERS

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      1     environment.





      2          MR. ERIC DUMOND:  So, basically in





      3     all actually the official public comment





      4     period doesn't end the 17th, in other words,





      5     is what you're saying?





      6          MR. SINGERMAN:  The comment on the





      7     actual remedy, once we consider public





      8     comment, then we'll make a decision on the





      9     remedy, but we're always open to concerns or





     10     comments from the public.





     11          I mean, we — just as we presume





     12     comments were provided, you know, from the





     13     beginning,  you know, when the site was





     14     listed up until now we have -- people have





     15     commented on various things and Curb has





     16     presented concerns to our agency and, you





     17     know, Mark has met with the group and, you





     18     know, various other parties, I mean, you





     19     know, have expressed concern, so EPA has





     20     considered those.





     21          So, throughout the whole process from





     22     listing the site on the National Priorities





     23     List to deletion, EPA will always consider





     24     anybody's concerns, whether it be the





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      1     public's,  potentially-responsible parties,





      2     you know,  local officials,  elected





      3     officials,  whatever.





      4          MS. RYCHLENSKI:  And just to add to





      5     what Joel has said,  I've been doing





      6     community relations for the agency for a





      7     very long time.  And this is --





      8          A VOICE:  You need to speak up.





      9          MS. RYCHLENSKI:  I'm sorry, I've





     10     been doing community relations for the





     11     agency for a very long time and I have seen





     12     RODs reopened and changed,  and what we call





     13     an Explanation of Significant Differences





     14     done, because communities are vocal and





     15     because they are concerned.





     16          So, this is an official public





     17     comment period, as Joel mentioned, to this





     18     proposed remedy, but the public activity and





     19     especially, a group like yours in a





     20     community like this, does not end until the





     21     site is deleted.  It continues.





     22          We have some sites that are extremely





     23     active. This is one where the community's





     24     very active. We have some where the





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      1     communities don't become active at all,  but





      2     especially on sites like this it's a





      3     continuing process. Especially you have a





      4     TAG,  it's a continuing process.





      5          Yeah,  Larry?





      6          MR.  LARRY ASHLEY:  I think I can cut





      7     through this pit. Is it possible within





      8     Mark's guidelines or EPA's guidelines that





      9     you return to this community before the





     10     decision is already made?





     11          Because I'm a person who does not





     12     believe that once a decision has been made





     13     you're in the same position as just before





     14     it is made. I think what would be best from





     15     the point of view of -- of bringing this





     16     community into the decision,  would be if





     17     just prior or just at that moment when





     18     you're trying to decide what the nature of





     19     that cap is, you would return to this





     20     community and say here are the realistic





     21     alternatives as we're now looking at them,





     22     we're about to decide, give us some input,





     23     because we know you're going to live with





     24     what we decide.





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      1          If it's decided independently of us,





      2     I think it will leave residually.  There





      3     will always be people who think they have





      4     been kept out of the process and would --





      5     may move to opposition just on that. I





      6     think in the point of community relations





      7     and procedure I think it would be -- not





      8     give a -- a fet a compli (phonetic), but a





      9     genuine chance of contribution from -- not





     10     that you have to follow what we do,  but we'd





     11     like the language of being part of the





     12     process to have some real meaning, and





     13     something like that would do it.





     14          Now, that may not be standard,  but I





     15     guess I would like to request it,  if it's





     16     possible within the framework of what you





     17     do.





     18          MS. RYCHLENSKI:  It's not unusual.





     19     We can do it.





     20          MR. GRANGER:  I just want to make





     21     sure exactly what you're talking about.





     22     You're saying before the decision's final.





     23     We're anticipating finalizing our decision





     24     within the next month or so.





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      1          Now,  but what you're talking about





      2     especially is a final decision as to what





      3     the final cap configuration's going to be,





      4     which is presumably at the stage of





      5     completion of the remedial design,  is that





      6     correct?





      7          MR. LARRY ASHLEY:  What you're





      8     talking about for desirable purposes from





      9     your point of view leaving open and flexible





     10     for up to two years.





     11          MR. GRANGER: It's not from my point





     12     of view. It's from EPA's point of view and





     13     from the community point of view.





     14          MR. LARRY ASHLEY:  Okay, stand





     15     corrected. But in any case, if that's still





     16     going to remain open, we'll still be here





     17     and we will be interested in knowing what





     18     you are considering doing to that twenty





     19     acres, which is our twenty acres, you know.





     20          We don't want to see it -- we don't





     21     want to see it become either an eyesore or





     22     unuseable. Or actually I would say I trust





     23     that whatever cover you put on will be





     24     health protective. I mean, I just -- I have





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      1     to believe that you're going to do a good





      2     job of insulating whatever residual health





      3     dangers remain on the site from the





      4     community, but there's much more that





      5     remains at stake, because I think I could do





      6     that along the whole spectrum of things,





      7     some of which could be a disaster from our





      8     community.





      9              And economics aside,  if you won't





     10     tell us what the costs of these various





     11     things are,  we would certainly like to tell





     12     you which various alternatives we would





     13     prefer as a community to end up with for





     14     that site, and I think that's really where





     15     Eric was going with his question.





     16             MR.  GRANGER:  Let me just state for





     17     the record and make sure that I paraphrase





     18     for the record, you're not worried about





     19     acceptable cap configurations. What you're





     20     worried about, is it an unacceptable cap





     21     configuration from the community standpoint?





     22     For example, one example of which would be a





     23     complete asphalt paving of the property.





     24              MR. LARRY ASHLEY:  Exactly.








                       PDQ COURT REPORTERS

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      1          MR. GRANGER: And you would like to





      2     be kept informed and the opportunity to have





      3     input at the point where those decisions are





      4     being made?





      5          MR. LARRY ASHLEY: Yes.





      6          MR. GRANGER: Okay. That's my





      7     paraphrase and I'll defer to my supervisor.





      8          MR. SINGERMAN: But also is there





      9     anything else in the list of your,  you know,





     10     dislikes,  as far as, I mean, we'd be more





     11     than happy to consider if you want to just





     12     identify other, you know, other caps that





     13     you don't think are appropriate,  asphalt and





     14     anything else?





     15          One of the reasons we're here is to





     16     hear your concerns. I mean, you don't have





     17     to identify them right now. It's an ongoing





     18     process. One of the reasons we have TAG is





     19     that your advisor, you know, we can interact





     20     with the advisor and the group to make sure





     21     that the group is and the community at large





     22     in happy with what were selecting,  what





     23     we're ultimately selecting for the site.





     24          So, if you can identify now or at





                       PDQ COURT REPORTERS

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Public Meeting                                               55





      1     some time in the future,  we'd be more than





      2     happy to take that request.





      3          MR. LARRY ASHLEY: Yes. Would just





      4     like to say, although I don't know if you





      5     would like to be pressed on this too hard,





      6     that we were sort of surprised when the





      7     possibility was mooted of one-foot cover,





      8     because we had thought that two feet, in





      9     fact someone asserted three feet, but it's





     10     controversial for us what the depth of that





     11     cover is expected to be,  so we'd like to





     12     think that through,  and if a soil cover for





     13     the site is the selected capping surface,





     14     capping method.





     15          MR. GRANGER:  So, I mean,  I





     16     anticipate an ongoing relationship with Curb





     17     and individual members of Curb, although





     18     there's always the hit by a bus syndrome





     19     whereby, you know --





     20          MR. LARRY ASHLEY: Right, something





     21     doesn't —





     22          A VOICE: You or us?





     23          MR. GRANGER: Yeah, could be either





     24     way.  So —





                       PDQ COURT REPORTERS

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      1          MR. LARRY ASHLEY: We've dodged a





      2     few buses.





      3          MR. GRANGER: So,  let's put down for





      4     the record that we need to address the





      5     possibility of formalizing an agreement to





      6     maintain communication with the community





      7     regarding the cap configuration.





      8          MR. LARRY ASHLEY:  Thank you.





      9          MR. SINGERMAN: Because also we





     10     don't want to preclude the appropriate





     11     development of the property, so we don't





     12     want to put something down there, therefore





     13     it can't be developed, so, I mean,





     14     ultimately we see it as being -- developing





     15     the piece of property.





     16          MS. RYCHLENSKI:  Jamie?





     17          MS. JAMIE DAGLER: Yeah. Could I





     18     also just kind of state for the record that





     19     I think one reason why we're concerned





     20     about -- this is not the main reason, I





     21     think Larry's discussed the main reason —





     22     in that, you know, I guess we would like to





     23     see, you know, that kind of more official





     24     commitment that there will be a public





                       PDQ COURT REPORTERS

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      1     comment at this stage,  et cetera. Because





      2     we have had a really good relationship as a





      3     result of the TAG process,  et cetera. It's





      4     not clear that we will have that TAG for





      5     very much longer.





      6          I mean,  Mark, you know our situation,





      7     we're basically out of money. We need to





      8     decide whether we want to reapply for an





      9     additional TAG. And the fact of the matter





     10     is administering this TAG has been a





     11     nightmare for us and I'm not really sure





     12     that we can do it. And so if that happens,





     13     Curb is not going to dissolve. I can say





     14     that we are in it for the long run, but the





     15     nature of our relationship with you may





     16     change, you know, if we don't have the





     17     technical advisor.





     18          And we want to make sure that, you





     19     know, if that happens,  you know, if Curb





     20     kind of officially dissolves as a TAG group,





     21     that there are mechanisms in place to allow





     22     for us as individuals,  or collectively





     23     without TAG and the technical advisor --





     24          MR. GRANGER: Well, the technical





                       PDQ COURT REPORTERS

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Public Meeting                                                58





      1     advisor works for you.  Any relationship





      2     that you have established with EPA through





      3     my position or any other relationships that





      4     you might have is very straightforward.





      5          MS. JAMIE DAGLER:  Yeah.





      6          MR. GRANGER: The TAG is  ancillary





      7     to any relationship that's been established.





      8          MS. JAMIE DAGLER:  Well,  Mark,





      9     again, I firmly believe that  that is what





     10     will happen if you remain Project Manager,





     11     but if you don't -- and you really stuck





     12     with us over the long -- we went through two





     13     Project Managers in a short period of time





     14     and you've been with us for a long time and





     15     we really appreciate that. But again, we're





     16     talking about years really into the future,





     17     and so we're a little bit nervous about our





     18     ability to sustain that relationship with





     19     EPA, because we may not have  a TAG.





     20          And also if you end up not being in





     21     this position we'd be having  to forge around





     22     with a new Project Manager without a TAG,





     23     which I assume would be a bit more difficult





     24     to do, maybe depending on that individual





                       PDQ COURT REPORTERS

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      1     and his or her experience with community





      2     groups.  That's kind of where we're at.





      3          MR. GRANGER:   Okay.





      4          MR. SINGERMAN: Mark will look both





      5     ways twice before crossing now.





      6          MS. RYCHLENSKI:  So, basically what





      7     we're doing is we're chaining Mark to the





      8     Rosen site for the rest of his professional





      9     life.





     10          I saw a hand go up here (indicating).





     11          MR. TODD MILLER: Todd Miller. I've





     12     got my public hat on tonight. My guestion's





     13     two parts, hypothetical. Maybe one, Mark,





     14     you can answer and maybe the second part





     15     Dave here.





     16          One: Option 3 will allow a plume to





     17     go beyond the extent of the site underneath





     18     the residences. Is there a plan for





     19     surveys, such that in the future someone





     20     doesn't come in the neighborhood and drill  a





     21     well?





     22          And two: If someone wanted to drill





     23     a well anyway over the plume, what are their





     24     water rights situation? Can they go ahead,








                       PDQ COURT REPORTERS

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      1     drill it and say,  yeah,  my water's





      2     contaminated,  I'm going to sue or something





      3     like that?





      4          MR. GRANGER:   My understanding is





      5     that there are restrictions on installing





      6     potable drinking water wells within the City





      7     of Cortland, or at a minimum you need to





      8     obtain a permit first. I would say that as





      9     part -- typically as part of EPA's remedy





     10     and as part of the consent decree that would





     11     be entered into with the





     12     potentially-responsible parties,  or as part





     13     of EPA' s implementation of the remedies





     14     should the potentially-responsible parties





     15     not desire to proceed with implementation of





     16     the remedy, a part of whatever remedy that





     17     gets selected is the formalization of





     18     institutional controls,  such as deed





     19     restrictions and restrictions on





     20     installation of wells for potable purposes,





     21     sometimes even for nonpotable purposes.





     22          I don't see,  personally at this





     23     point, just speaking from my own opinion, I





     24     don't see the need to restrict groundwater





                       PDQ COURT REPORTERS

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      1     withdrawals for industrial purposes at this





      2     point in time,  but I do see the wisdom of





      3     restricting potable withdrawal of water





      4     downgrading of the Rosen site, and that





      5     would be formalized in the future.





      6          MR. TODD MILLER:   I guess it comes





      7     down to a guestion of water rights of the





      8     property owner. Can you prevent a property





      9     owner from using their water underneath





     10     their property?





     11          MR. GRANGER: That's a good





     12     guestion. I don't know if that would be





     13     enforceable,  but it certainly would be --





     14     I'm going to have to look into that one,





     15     Todd.





     16          MR. SINGERMAN:  Well, if





     17     institutional controls is part of the





     18     remedy, then EPA could effectively prohibit





     19     people from using the water underneath the





     20     property. I mean, if we select, you know,





     21     part of the remedy that we're proposing





     22     includes institutional controls, such as





     23     dead restrictions or other mechanisms to





     24     prevent any installation of potable water





                       PDQ COURT REPORTERS

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Public Meeting                                              62





      1     wells within the extent of the plume,  so





      2     basically that's,  you know,  that would be





      3     part of the remedy.





      4          So,  it would be up to some local





      5     authority to implement that aspect of it.





      6     Like, for example,  whoever controls the





      7     issuance of permits for installation of





      8     wells would know that they cannot issue





      9     permits for X number of years until EPA says





     10     that, you know,  the water is now safe. So,





     11     therefore,  you cannot install a well,  so





     12     that would be controlled as part of the





     13     remedy.





     14          But EPA itself cannot -- you can't go





     15     out and say -- we're not the authority that





     16     issues the permits, so we're not the one





     17     that can say you can't issue a permit. We





     18     would just tell the party, whether it's the





     19     County or City.  I guess it's the City.





     20          MR.  TODD MILLER:  Does the County





     21     have a right to refuse a permit on the basis





     22     that water is contaminated beneath them?





     23     That's my guestion.





     24          MR.  SINGERMAN: Yes, because one of





                       PDQ COURT REPORTERS

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      1     the purposes of issuing a permit is that you





      2     don't want to install a well that's not a





      3     potable supply, so they're not going to





      4     approve a permit if it's not going to have





      5     usable water, and if it's contaminated it's





      6     not usable unless you treat it,  so there's





      7     also some interrelationship between the fact





      8     that there's already public water supply.





      9          So,  sometimes there's -- there are





     10     local ordinances that preclude installation





     11     of private wells in the area that's





     12     controlled by a public water supply, so I





     13     don't know the specific — specifically what





     14     the law is here, but that, I mean, it's





     15     likely to be the case.





     16          MR.  TODD MILLER:  Actually that





     17     would work in Cortland, because actually





     18     Cortland is only one of the few places that





     19     has a permitting system.   Most counties





     20     don't in New York, but fortunately Cortland





     21     does.





     22          MS.  RYCHLENSKI: Okay. This lady





     23     here (indicating).





     24          MS.  AUDREY LEWIS: My name is Audrey





                       PDQ COURT REPORTERS

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      1     Lewis.  I am from the Health Department,  the





      2     agency that would be issuing permits,  and I





      3     think that the issue may soon be a moot





      4     point,  because for other reasons they're





      5     looking into restricting any wells drilled





      6     within the City public water supply,  water





      7     district to cross-contamination,





      8     cross-connection problems.  So,  it may not





      9     be allowed anywhere within the water





     10     district to drill potable waters. As well





     11     as the plume doesn't go outside City limits





     12     and once it reaches Cortlandville that's no





     13     longer in that.





     14          MR. GRANGER: Do you have a time





     15     frame for that, Audrey, of when you expect





     16     that decision to be finalized?





     17          MS. AUDREY LEWIS: Probably we talk





     18     to the Water Board.  Doug,  you would have a





     19     better estimate.





     20          MS. RYCHLENSKI: Okay.





     21          Yes, sir?





     22          A VOICE: What you just said, are





     23     you saying that the EPA' s proposing to





     24     monitor the plume from the plume broke --





                       PDQ COURT REPORTERS

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Public Meeting                                           65





 1            MR.  SINGERMAN:  Part of the remedy





 2     is to include monitoring of the plume to





 3     make sure that it is attenuating. We're





 4     just not going to just ignore it and walk





 5     away from it. Part of the long-term





 6     monitoring is to make sure that natural





 7     attenuation is occurring ss part of the





 8     remedy.





 9          A VOICE: So, does that mean that





10     you're going to be proposing more wells





11     downgradient of the site?





12          MR. SINGERMAN:  Well, it depends.  I





13     mean, we may be able to use existing wells,





14     we may have to install additional wells.





15     These are some of the decisions we have to





16     make during design, but we basically want to





17     el -- find out what's happens with the plume





18     over some time, so if we need more wells we





19     would install them.





20          A VOICE:  That's — once again, that





21     is one of my big concerns is once this





22     Record of Decision is made and this decision





23     is implemented, what happens if the EPA, god





24     forbid,  they fix a hot spot and a hot spot








                  PDQ COURT REPORTERS

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      1     develops,  what happens then? Are the PRPs





      2     still responsible for any additional cleanup





      3     costs?





      4          MR. SINGERMAN: PRPs are responsible





      5     for -- for anything at the site, even if we





      6     delete the site from the National Priorities





      7     List and find contamination after that,  so





      8     they're always on the hook. That's why it's





      9     in their best interest for them to implement





     10     a remedy at the site and do it the best





     11     possible way, because if they don't do it to





     12     our satisfaction, they may have to do it





     13     over again. Or EPA may have to go in and





     14     spend additional funds.





     15          So, the thing is, is that, as I





     16     mentioned earlier, the ROD amendments, ESDs,





     17     we have mechanisms for changing remedies, if





     18     necessary. So, if we find some additional





     19     hot spot in the future, you know, if we





     20     can't address it under the current ROD,  we





     21     can perhaps modify the ROD as, you know, as





     22     necessary to encompass other contaminant





     23     sources or problems we find in the future.





     24          MR. GRANGER: And just to add one





                       PDQ COURT REPORTERS

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      1     more thing to that,  you'll notice in the





      2     Proposed Plan as one of the bullet items





      3     under the preferred alternative,  the





      4     provision for a five-year review, so that





      5     such -- such that the Superfund program





      6     reguires that the site be reviewed and all





      7     the data that's been received reviewed every





      8     fire years to ensure that the remedy that's





      9     used remains protective.





     10          MS. RYCHLENSKI:  Larry?





     11          MR. LARRY ASHLEY: I'd like to ask





     12     some really just basically informational





     13     guestions I'm sure will be no problem. They





     14     mostly surround the 360 cap.





     15          MR. GRANGER: I'm sorry?





     16          MR. LARRY ASHLEY: The 360 cap over





     17     the cool pond.





     18          MR. GRANGER: Yes.





     19          MR. LARRY ASHLEY:  Several guestions





     20     about it.





     21          MR. GRANGER:  Okay.





     22          MR. LARRY ASHLEY: One: Could you





     23     tell us in other terms other than 360 cap





     24     what the nature of that barrier is like?








                       PDQ COURT REPORTERS

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Public Meeting





      1          Two: Is it in the end covered with





      2     this same sort of cover as is being





      3     committed for the other seventeen acres? Is





      4     it set aside in some way,  is it visually





      5     differentiable from the other areas of the





      6     site?





      7          I gather that the cooling pond gets





      8     treated differently because it deserves this





      9     cap. And what way does that translate to





     10     any difference that you can see once the





     11     remediation is completed?





     12          And finally, there's  language in





     13     those bullet items on page 15 that says that





     14     the nonhazardous wastes from the cooling





     15     pond are going to be removed, compacted and





     16     replaced or something for  fill, and it





     17     struck us as curious, how  do you separate





     18     the hazardous from the nonhazardous material





     19     that's in the cooling pond? I assume that





     20     there's hazardous material there.





     21          So, that's a battery  of guestions,





     22     basically information guestions.





     23          MR. GRANGER:  Let's break that into





     24     two parts.  The part about  compaction and








                       PDQ COURT REPORTERS

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      1     consolidation,  I'll answer that. The first





      2     part about the 360 cap is, yes,  it varies





      3     dramatically from the site-wide cover.  I





      4     could try to tackle it,  but we have an





      5     expert here on 360 caps,  so did you want to





      6     tell them?





      7          MR. DAVID CAMP:  Yeah, I mean, a 360





      8     cap, basically you would just contour the





      9     area a little bit to shape it into the shape





     10     you want. And then it's  the capping is just





     11     impermeable layer first,  like something like





     12     a plastic, high-density  polyethylene liner,





     13     or it could be a clay layer, something that





     14     meets the permeability reguirements of Part





     15     360. And then on top of  that is — it's a





     16     guess, a couple feet of  what they call





     17     barrier protection layer,  which is just this





     18     type soil. And then on top of that you put





     19     a topsoil layer. And then you seed it so





     20     that the topsoil is stable.





     21          And in this case that's basically





     22     what we're talking about for a 360 cap.





     23          MR. LARRY ASHKEY: The plastic part





     24     remains after a couple of decades still





                       PDQ COURT REPORTERS

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Public Meeting                                              70





      1     intimal? I mean,  it's -





      2               MR.  DAVID CAMP: Yeah,  as long as





      3     I -- yeah, it lasts a long time,  as long as





      4     it's not exposed to sunlight,  which it won't





      5     be.





      6               MR.  LARRY ASHLEY:  Right. Mark,





      7     you're looking up the section I  was talking





      8     about?





      9               MR.  GRANGER: Yeah,  I'll read it out





     10     loud for the record. "Nonhazardous debris





     11     that is located on the surface of the areas





     12     where the site-wide surface cover would be





     13     installed and/or is commingled with the





     14     excavated soil would be removed and





     15     consolidated onto the former cooling pond."





     16               What that's referring to is as we do





     17     the excavations,  you know, assuming this





     18     remedy moves forward, as the excavations





     19     would be performed you'd be digging up soils





     20     that are contaminated with PCBs  and TCA,





     21     there's going to be like large boulders,





     22     let's say, that in not necessarily PCB- or





     23     TCA-related whatsoever, and you could





     24     decontaminate it guite simply by rinsing it





                       PDQ COURT REPORTERS

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      1     off.  Or a pipe or a car body,  that is





      2     something that's not the kind of thing you'd





      3     want to send to a hazardous waste landfill





      4     in a rolloff or treat in some way.





      5          In addition, that's excavated-related





      6     materials. Then there's material on top of





      7     the site, like bricks and,  you know,  a pile





      8     of fishing wire, you know,  from — you know





      9     what I mean? There's, like, a big mass of





     10     spaghetti of old fishing line, things of





     11     that nature, that's what that's referring to





     12     in terms of, okay,  we're putting -- we have





     13     a landfill, we're going to be capping a





     14     landfill, these are the type of materials





     15     that are already in the landfill, let's





     16     consolidate those materials and focus our





     17     attentions on the hazardous materials in





     18     terms of treatment and sending off site, and





     19     we'll put the cap over the top of the





     20     cooling pond and other nonhazardous debris.





     21          MR. LARRY ASHLEY: So,  that bullet





     22     item began with a description of the cooling





     23     pond, but actually the materials that are





     24     going to go in is from the rest of the site?








                       PDQ COURT REPORTERS

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      1          MR. GRANGER: Well,  what it says is





      2     nonhazardous debris that is located on the





      3     surface of the areas where the site-wide





      4     surface cover would be installed,  meaning





      5     the seventeen acres on the surface, so you





      6     have structural steel, fishing line, et





      7     cetera, bricks.





      8          MR. LARRY ASHLEY: I don't know if





      9     we are talking about the same part. The





     10     bullet item that begins a cap -- a cap





     11     meeting the reguirements --





     12          MR. GRANGER: Oh, I'm sorry.





     13          MR. SINGERMAN: Prior to the





     14     construction of the cap, the consolidated





     15     soils --





     16          MR. LARRY ASHLEY: Nonhazardous





     17     debris --





     18          MR. GRANGER:  -- debris, and





     19     existing fill materials would be regraded





     20     and compacted to provide a stable





     21     foundation.





     22          Okay. That's building on the





     23     previous bullet, so what that's saying is





     24     that all those materials, and with the





                       PDQ COURT REPORTERS

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      1     addition of these other materials, would





      2     then go through what Dave said in terms of





      3     contouring. You have to have, like,





      4     specific grades in order to meet the





      5     specifications of the State standard,





      6     Part 360.





      7          MR. LARRY ASHLEY: Okay.





      8          MR. GRANGER: When they say





      9     compacted,  you have to -- in order to





     10     maintain that slope you have to send the





     11     eguivalent of a steam roller over the top





     12     and it has to meet -- it's a very technical





     13     specification and they have machines that





     14     measure compaction. You have to have





     15     ninety-nine percent, et cetera.





     16          MR. SINGERMAN: It's all so it





     17     doesn't start settling too, so the cap





     18     doesn't collapse.





     19          MS. RYCHLENSKI:  Okay. Any more





     20     questions or comments?





     21          Jamie?





     22          MS. JAMIE DAGLER: Yeah. Just





     23     wanted to ask a question about the





     24     institutional controls.  Can you give us an





                       PDQ COURT REPORTERS

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Public Meeting                                              74





      1     idea,  Mark,  of at what point in the process





      2     that's going to unfold? Would EPA begin the





      3     process of developing those institutional





      4     controls with the community?





      5          We're assuming that EPA takes the





      6     lead in bringing together,  if it be City,





      7     County, whomever, or the DEC, obviously,  to





      8     sit down and actually establish what those





      9     controls would be. For example, under what





     10     conditions could there be excavation on the





     11     site?





     12          And actually that's a guestion is





     13     would this remedy, if selected, still allow





     14     the possibility of excavation on the site as





     15     long as the soils underneath the surface





     16     cover were treated as hazardous waste, is





     17     that —





     18          MR. GRANGER: That's how I envision





     19     the institutional controls for soils related





     20     to the site proceeding.





     21          Very briefly, institutional controls





     22     could be begun to be instituted concurrently





     23     with design of the remedy or after. My





     24     experience has been that institutional





                       PDQ COURT REPORTERS

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Public Meeting                                             75





      1     controls are usually addressed kind of like





      2     as the period on the end of the sentence,





      3     where you're done with your remediation or





      4     you're done constructing your remedy,





      5     assuming that you don't have any thirty-year





      6     remedy going on, but in terms of just





      7     constructing the remedy, design and





      8     construction, and then you move into your





      9     institutional controls, fails that could be





     10     moved up.





     11          But I'm assuming perhaps, Joel, did





     12     you have any further insights on that?





     13          MR. SINGERMAN:  There's really no





     14     reguirement as to when it has to be done.





     15     If you definitely want to have the





     16     institutional controls in place before the





     17     remedy is basically completed, because at





     18     that time,  you know, you don't want to have





     19     people be able to do something to the





     20     covered area or cap that, you know, would





     21     adversely impact it, so we probably want to





     22     start early enough in the process that by





     23     the time the remedial action is completed,





     24     that we would have those protections in





                       PDQ COURT REPORTERS

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Public Meeting                                             76





      1     place.





      2          But there's really no specific time





      3     when we're required to start doing it,  but,





      4     you know,  I guess the sooner,  the better.





      5          MS. JAMIE DAGLER: So, that is the





      6     EPA' s responsibility, to make sure that





      7     these are implemented?





      8          MR. SINGERMAN: Well, everything at





      9     the site is EPA's responsibility depending





     10     if we -- we intend to negotiate with





     11     potentially-responsible parties to undertake





     12     the remedy, so,  you know, certain aspects





     13     may ultimately be their responsibility, but





     14     ultimately everything is EPA' s





     15     responsibility.





     16          If they do something on behalf of EPA





     17     we would want to make sure that it's done  as





     18     we would do it.





     19          MS. RYCHLENSKI: Mark?





     20          MR. LARRY ASHLEY: Sorry to jump in





     21     again.  Once the remediation in complete,





     22     will need there be a fence around the





     23     property or will it again be open to





     24     children who use it guite naturally as means








                       PDQ COURT REPORTERS

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Public Meeting                                               77





      1     of cutting down distances to and from their





      2     house and school,  et cetera, which remains a





      3     problem for any fencing that remains in





      4     place?





      5          As you know,  people have used,  over





      6     the years, that land as a thruway. Does any





      7     remediation,  absent someone on the site who





      8     fences it for purposes of security for





      9     whatever is going on there, does the type of





     10     cleanup we're talking about here end up with





     11     no fence around it or is a fence kept around





     12     it sort of perpetually in recognition of the





     13     fact that it's a site that needs to be





     14     treated carefully?





     15          MR. GRANGER:  I would say that the





     16     basic policy of EPA is to err on the side of





     17     conservative, such that any portions of the





     18     site that had not been remediated to





     19     eliminating health risks would be fenced,





     20     would remain fenced.





     21          MR. LARRY ASHLEY: But that would





     22     not be true for the huge majority of the





     23     site, is that right?





     24          MR. GRANGER:   I would say








                       PDQ COURT REPORTERS

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Public Meeting                                              78








      1     ultimately -- let's say that hypothetically





      2     half of the site was remediated and had some





      3     kind of cover configuration placed over the





      4     site,  over that portion of the site,  that





      5     the fence line could then be moved back to





      6     the unremediated portion of the site.





      7          In addition, I envision that the





      8     cooling pond portion of the site will be





      9     fenced in perpetuity,  typically to protect





     10     the integrity of the cover that's done.





     11          MR. SINGERMAN: That's currently





     12     fenced now.





     13          MR. GRANGER: The whole site is





     14     fenced now and that fence will stay up as





     15     long as there's remediation work going on.





     16          MR. SINGERMAN: We have no intention





     17     of taking the fence down, though. I -- I





     18     mean,  basically it's private property, so





     19     it's not -- so if the property owner will





     20     maintain the fence, then the fence will





     21     stay.





     22          MR. ERIC DUMOND:  I'm going to speak





     23     from a little bit of the ignorant side of my





     24     education. My understanding is groundwater








                       PDQ COURT REPORTERS

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Public Meeting                                                79








      1     rises,  it fluctuates,  right? It goes up and





      2     down.  This 360 cap is going to be on top of





      3     basically the cooling pond?





      4          MR. GRANGER: (Nods head)





      5          MR. ERIC DUMOND:  Is there any





      6     possibility of when the water rises it





      7     carrying away any hazardous chemicals when





      8     it rises?





      9          MR. GRANGER: Eric, that's the total





     10     point of this remedy is, first of all, to





     11     remove sources of contamination to the





     12     aguifer, so that when the groundwater does





     13     rise it doesn't carry away these chemicals.





     14          There's four areas of the site that





     15     are going to be excavated, two of which have





     16     a direct impact on groundwater. That's the





     17     first thing.





     18          The second part is the cap over the





     19     cooling pond is one thing, but we did an





     20     investigation of the cooling pond and did





     21     not find hazardous materials contributing to





     22     aguifer contamination.





     23          MR. ERIC DUMOND:  Okay.





     24          MR. GRANGER: So,  we're going to be








                       PDQ COURT REPORTERS

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Public Meeting                                              80





      1     excavating the materials outside of the





      2     cooling pond that have been determined to be





      3     a source to the aguifer, we're covering the





      4     cooling pond simply because it was a





      5     construction and demolition debris landfill





      6     and that's what you do with old landfills,





      7     not because it's hazardous.





      8          MR. ERIC DUMOND: Now,  you're guite





      9     positive that there are no other -- and I'm,





     10     you know, talking to you, we've dealt for a





     11     long time, and I, you know, I respect your





     12     opinion — are you guite confident that





     13     there are no other possible hot spots on the





     14     site?





     15          MR. GRANGER: I'm guite confident,





     16     yes, I would use that phrase.





     17          I think that we have an impressive





     18     data set, database for the site. There's





     19     just sampling points from one end of the





     20     site to the other. The nature of the site





     21     is such that it is not out of the guestion,





     22     I think it's remote, but it does remain a





     23     possibility. And if a source was determined





     24     to be present on the site,  then we would








                       PDQ COURT REPORTERS

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Public Meeting                                            81





      1     evaluate the need to address that in





      2     addition to what else we have.





      3          That builds on something that Joel





      4     had mentioned earlier,  that if information





      5     comes to EPA in the future, we do have





      6     mechanisms for reopening our decision, for





      7     reevaluating our decision and formalizing





      8     that in a post Record of Decision document.





      9          MS. RYCHLENSKI: Jamie, just let me





     10     get this gentleman in front of you.





     11          Yes, sir?





     12          MR. RICHARD PARKER: I'm Dick Parker





     13     with Curb. I've lived at that end of town





     14     most of my life, especially since '65.





     15          This Perplexity Creek and Owego Creek





     16     freguently go wild in the spring. Now, when





     17     you're going to cover that area of the





     18     cooling pond over there, which I'm really





     19     familiar with, you will have the Perplexity





     20     Creek to deal with, it goes right through





     21     it.





     22          And having had -- brought up a





     23     granddaughter that I confronted that





     24     Perplexity Creek commonly going under the





                       PDQ COURT REPORTERS

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Public Meeting                                                 82





      1     fence along with her friends. I don't think





      2     it's going to get remedied that easily. I





      3     just brought her home from LeMoyne this





      4     afternoon, so she's not one of your worries





      5     anymore.





      6          That would be a concern of mine, as





      7     to how you're going to get that thing so it





      8     doesn't run out of there,  out of this





      9     creekbed. Some parts of it are underground.





     10          MR.  GRANGER: Right. The creek is





     11     definitely a consideration in remedial





     12     design.





     13          MR.  RICHARD PARKER: Yeah.





     14          MR.  GRANGER: Absolutely.





     15          MR.  RICHARD PARKER: That's





     16     something you want to keep in your





     17     monitoring.





     18          MR.  GRANGER: You mean just during





     19     the construction of the cap or just long





     20     term?





     21          MR.  RICHARD PARKER: They'll tear it





     22     apart for you. If that thing wants to run





     23     wild up there it goes.





     24          MR.  GRANGER: We're going to have to





                       PDQ COURT REPORTERS

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Public Meeting                                             83





      1     design for that and they're going to put





      2     proper surface water drainage around the





      3     cap,  you know. They might have to beef that





      4     up and put riprap or something,  you know,





      5     different measures to prevent erosion and





      6     whatnot,  but,  yeah, that's definitely





      7     something that we're going to have to





      8     address.





      9          MR.  RICHARD PARKER: There will be





     10     considerable pressure from underneath there,





     11     because you may not be aware of the





     12     elevation of the subterrainian land, there





     13     are two aguifers there,  an upper one and a





     14     lower one. I don't know if you drove





     15     through both of them or not.  Did you not?





     16     Both of the aguifers?





     17          MR.  GRANGER: I'm familiar with





     18     them.





     19          MR.  RICHARD PARKER:  You were?





     20          MR.  GRANGER: I'm familiar with the





     21     aguifers beneath the Rosen site.





     22          MR.  RICHARD PARKER:  The two of





     23     them?





     24          MR.  GRANGER:  Right, exactly.





                       PDQ COURT REPORTERS

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Public Meeting                                            84





      1          MR.  RICHARD PARKER:  The upper and





      2     the lower?





      3          MR.  GRANGER: Yeah.





      4          MR.  RICHARD PARKER:   And I don't





      5     know if the lower one puts the pressure on





      6     or the upper one.





      7          MR.  GRANGER: Well,  that's one of





      8     the reasons that the site-wide cover system





      9     is being designed to be permeable, because





     10     the groundwater tends to rise so high,  I





     11     mean, I've been out at the site where you





     12     could literally dig to groundwater with a





     13     teaspoon,  so it really would be





     14     counterproductive to put a permeable cover





     15     across the site when the groundwater comes





     16     up so high, and it could actually compromise





     17     the cover system. So, I think the permeable





     18     specification is important for the site-wide





     19     cover.





     20          MR.  RICHARD PARKER:  I don't think





     21     they'll do it,  but they were considering





     22     putting a bypass highway just above that in





     23     Polkville. It had all been surveyed and





     24     staked off. I don't think they can get





                       PDQ COURT REPORTERS

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Public Meeting                                               85





      1     through there anymore, but they put that





      2     water tank up there, they might go around





      3     it,  and that's a State project from Route 13





      4     across Route 11 — or Route 81.





      5          MS. RYCHLENSKI:  Okay. Lot of stuff





      6     going on out near that site,  that's for





      7     sure.  Thank you.





      8          MR. RICHARD PARKER: Been there a





      9     long time.





     10          MS. RYCHLENSKI: Been here a long





     11     time, know it inside out, better than him, I





     12     guess.





     13          No offense.





     14          Jamie?





     15          MS. JAMIE DAGLER: Mark,  with regard





     16     to natural attenuation, if that's the remedy





     17     selected for groundwater, would you actually





     18     set goals for reduction of contaminants? In





     19     other words, I'm trying to project ahead.





     20     Say natural attenuation doesn't work, you





     21     know, in the long run you need to come back





     22     and revisit, at what point will you make





     23     that determination that this is not working,





     24     we need to go back and figure out why it's








                       PDQ COURT REPORTERS

-------
Public Meeting





      1     not working?





      2          Will you set goals based on the





      3     levels of contamination you know are there,





      4     they should be reduced to a certain level by





      5     a certain time or something like that?





      6          MR. GRANGER: There's already goals





      7     in terms of State and Federal groundwater





      8     standards for drinking waters,  so those are





      9     ultimately the goals. That's the rods, the





     10     yardstick that we're measuring it against.





     11          In terms of those goals being met





     12     over time, there's the stipulation, which is





     13     part of the Superfund program,  for a





     14     five-year review. Every five years that





     15     this site is reviewed to ensure that the





     16     remedy remains protective.  So,  we're saying





     17     right now that we believe natural





     18     attenuation will meet those drinking water





     19     standards within ten years.  That's an





     20     estimate. If it turns out to be fifteen





     21     years, at the second five-year review we





     22     would evaluate whether that remedy has





     23     remained protective and make a decision





     24     based on that.





                       PDQ COURT REPORTERS

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Public Meeting                                               87





      1          I would say that in the unlikely





      2     instance where the City of Cortland wanted





      3     or absolutely had to place their groundwater





      4     extraction well for drinking purposes





      5     downgradient of the Rosen site,  that would





      6     be -- that would change the eguation





      7     dramatically and that would be the kind of





      8     scenario where we would say, well, okay,





      9     this remedy's no longer protective, you





     10     know. If that's the circumstance we'd have





     11     to evaluate that, okay?





     12          MS. RYCHLENSKI: Okay. Any other





     13     questions or comments?





     14          (Whereupon there was no verbal





     15     response)





     16          MS. RYCHLENSKI: Okay, then we'll





     17     close for the evening. I thank you all very





     18     much. And just remember, written comments,





     19     get them to Mark by close of business





     20     December 17th. And I'm sure we'll see you





     21     soon.





     22          (Whereupon the meeting adjourned at





     23     8:30 PM)




     24                        * * * *





                       PDQ COURT REPORTERS

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 1     STATE OF NEW YORK  :





 2     COUNTY OF BROOME   :





 3





 4





 5                    I, MICHELE L. RICE,  Shorthand Reporter,





 6     do hereby certify that the foregoing is a true and





 7     accurate transcription of the proceedings in the Matter





 8     of a PUBLIC MEETING,  held in Cortland,  New York, on the





 9     9th day of December,  1997.





10





11





12





13     





14





15





16





17





18





19





20





21





22





23





24

-------
                         RECORD OF DECISION FACT SHEET
                                 EPA REGION II
Site
Site name:
Site location:
HRS score:
Listed on the NPL:
EPA Site ID#:
 Rosen Brothers Scrap Yard Site
 Cortland,  New York
 51.35
 3/30/89
 NYD982272734
Record of Decision
Date signed:
Selected remedy:
Capital cost:
Construction Completion:
0 & M cost:
Present-worth cost:

Lead
agency
Primary Contact:

Secondary Contact:
Main PRPs:
 3/23/98
 Hot spot soil excavation (TCA and PCBs);
 3-acre NYSDEC Part 360 cap; 17-acre site
 wide surface cover; monitored natural
 attenuation of groundwater.
 $2.7 million
 2000
 $60,000
 $3.1 million (10 years,  7% disc, rate)

 Site is PRP lead - EPA is the lead

 Mark Granger, Remedial Project Manager,
 (212)  637- 3955
 Joel Singerman, Chief, Central New York
 Remediation Section,  (212)  637-4258

BMC  Industries,  Inc.,  Cooper  Industries,  Inc.,  Elf
Atochem North America, Inc.,  Keystone Consolidated
Industries,  Inc., Mack Trucks,  Inc., Monarch Machine
Tool Co., Motor Transportation  Services,  Inc.,  New  York
State Electric  and  Gas Corp., Niagara Mohawk Power
Corp.,  Overhead Door Corp., Pall Trinity  Micro  Corp.,
Potter  Paint  Company,  Raymond,  Inc., Redding-Hunter,
Inc., Harvey  M.  Rosen, Wilson Sporting Goods, Inc.
Waste
Waste type:
Waste origin:
Contaminated medium:
VOCs, SVOCs, PCBs,  Inorganics
Hazardous waste;  scrap processing;  steel manufacturing
Soil and groundwater

-------