Superfund Record of Decision Goldisc Recordings Inc OU 2 Holbrook NY


                                    EPA/ROD/R02-98/139
                                    1998
EPA Superfund
     Record of Decision:
     GOLDISC RECORDINGS, INC.
     EPA ID: NYD980768717
     OU02
     HOLBROOK, NY
     09/30/1998

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EPA541-R98-139


                                  RECORD OF DECISION

                                   Operable Unit 2

                                Goldisc Recordings, Inc.

               Village of Holbrook, Town of Islip, Suffolk County, New York


                                    September 1998



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

                                     September 1998

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DECLARATION FOR THE RECORD OF DECISION

SITE NAME AND LOCATION

Goldisc Recordings, Inc.
Village of Holbrook, Town of Islip, Suffolk County, New York

STATEMENT OF BASIS AND PURPOSE

This Record of Decision (ROD) presents the selected remedy for the second operable unit (OU-2) for the
Goldisc Recordings Superfund site (Site), located in the Village of Holbrook, Town of Islip, Suffolk County,
New York, which was chosen in accordance with the requirements of the, Comprehensive Environmental Response,
Compensation and Liability Act (CERCIA), as amended, 42 U.S.C. °° 9601-9675, and, to the extent
practicable, the National Oil and Hazardous Substances Pollution Contingency Plan (NCP), 40 CFR Part 300. The
information supporting this remedial action decision is contained in the Administrative Record for the Site.
The Administrative Record index is attached (Appendix III).

The New York State Department of Environmental Conservation (NYSDEC) concurs with the selected remedy
(Appendix IV).

DESCRIPTION OF THE SELECTED REMEDY - MONITORED NATURAL ATTENUATION

This operable unit represents the second of two planned operable units for the Site. It addresses the fate
and transport of the nickel contamination in the groundwater emanating from the Site. The U.S. Environmental
Protection Agency (EPA) , in consultation with the State of New York, has determined that Monitored Natural
Attenuation is an appropriate remedy for the Site because groundwater contamination has declined
significantly in recent years and does not pose a significant threat to human health or the environment.
Monitored Natural Attenuation would use natural physical processes to restore groundwater at the Site.

A monitoring program will be developed subsequent to the issuance of this ROD in order to provide a profile
of future levels of the nickel contamination at the Site.

DECLARATION

In accordance with the requirements of CERCLA, as amended, and the NCP, it has been determined that the
selected remedy, Monitored Natural Attenuation, is protective of human health and the environment, complies
with Federal and State requirements that are legally applicable or relevant and appropriate to the remedial
action and is cost-effective. The principal threats at the Site have been addressed by the source control
OU-1 remedial action.

This ROD documents that all construction activities at the Site have been completed in accordance with Close
Out Procedures for National Priorities List Sites - August 1995 (OSWER Directive 9320.2-09).

There is no construction associated with the groundwater remedy. The groundwater monitoring performed to date
provides a valid representation of past and present groundwater conditions at the Site and demonstrates that
cleanup goals should be achieved within the time period of the selected remedy monitoring program. The scope
of this monitoring program is expected to be similar to that of the previous monitoring.

The contaminated surface soils and dry well sediments were cleaned up through a remedial action, identified
in the 1995 ROD, Information on that remedial action can be found in the January 1998 Remedial Action Report,
contained in the Administrative Record for the Site. Since the implementation of a contingency remedy is
unlikely, no further remedial action response is anticipated at the Site. Therefore, the Site now qualifies
for inclusion on the Construction Completion List.

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                                  RECORD OF DECISION
                                   DECISION SUMMARY

                               Goldisc Recordings,  Inc.

                      Village of Holbrook, Suffolk  County,  New York

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

                                      September 1998

                                  TABLE OF CONTENTS

Section                                                                       Page

SITE NAME, LOCATION AND DESCRIPTION  	  1

SITE HISTORY AND ENFORCEMENT ACTIVITIES  	  2

HIGHLIGHTS OF COMMUNITY PARTICIPATION 	  4

SCOPE AND ROLE OF OPERABLE UNIT  	  4

SUMMARY OF SITE CHARACTERISTICS  	  4

SUMMARY OF SITE RISKS  	  9

REMEDIAL ACTION OBJECTIVES 	  12

DESCRIPTION OF REMEDIAL ALTERNATIVES  	  13

SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES 	  15

DESCRIPTION OF THE SELECTED REMEDY  	  19

STATUTORY DETERMINATIONS  	  20

SITE CONSTRUCTION COMPLETION 	  21

DOCUMENTATION OF SIGNIFICANT CHANGES  	  22

ATTACHMENTS

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

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SITE NAME, LOCATION AND DESCRIPTION

The Goldisc Recordings Superfund site (Site) is located at the northeast corner of Veterans Memorial Highway
and Broadway Avenue in the Village of Holbrook, Town of Islip, New York. The 34-acre Site consists of two
one-story buildings that occupy six acres, three acres of pavement surrounding the buildings, and twenty five
acres of undeveloped land (see Figure 1).

Current zoning at the Site is commercial/industrial. The area surrounding the Site is primarily residential
and mixed forest, with some commercial and light industrial development. The Village of Holbrook has an
estimated population of 20,525. The Site is bordered to the north and east by mixed forest, to the south by
Veterans Memorial Highway, and to the west by Broadway Avenue (see Figure 2).

A municipal water supply wellfield, which provides drinking water for the Suffolk County Water Authority
(SCWA) , is located approximately 1,200 feet south of the Site on Church Street. SCWA monitors these wells on
a freguent basis. All residents of the Town of Islip depend on groundwater as their potable water supply. The
closest dwellings are located about 700 feet north of the Site. A New York State (NYS) and federally
regulated wetland is located approximately one-half mile south of the Site. A Sunoco gasoline station is
located on the southeast corner of Veterans Memorial Highway and Broadway Avenue, just south of the Site. A
groundwater remediation system is currently in operation at the station which addresses a release of
petroleum product to the groundwater.

Three distinct aguifers underlie the Site. At the base of the system is the Lloyd Aguifer, which exists under
highly confined conditions between the relatively impervious bedrock below and the Raritan Confining Unit
above. The Lloyd is not utilized for water supply in the Holbrook area because of its extreme depth
(>1000 feet) and its susceptibility to salt-water intrusion from the Great South Bay.

The second unit or Magothy Aguifer lies atop the Raritan Confining Unit and is widely used for water supply
purposes. The third unit and most shallow of the aguifers is the Upper Glacial Aguifer, which is an
unconfined aguifer and is highly susceptible to contamination from domestic septic systems and other manmade
pollution sources. This unit is the most permeable of the aguifer units underlying the Site. The thickness of
the Upper Glacial aguifer underlying the Site varies widely but is approximately 135 feet. Depth from the
surface to the water table ranges from 18 to 32 feet across the Site. Figure 3 shows a hydrogeologic cross
section of the study area.

The three Church Street (CS) Public Water Supply Wells (CS-1, CS 2 and CS-3) are located in a cluster
approximately 1200 feet south of the Site. CS-1 and CS-2 are both screened in the deeper portion of the Upper
Glacial Aguifer. CS-3 is screened in the mid-Magothy Aguifer.

The groundwater flow direction in the northern portion of the Site is generally south to southeast. However,
the southeast portion of the Site shows a shift in flow direction to the southwest in response to the radial
drawdown resulting from the pumping operations of the CS wellfield. The groundwater flow velocity ranges from
1.3 to 2.9 feet/day, depending on the pumping operations at the wellfield.

The natural hydrologic system in the Holbrook area may be considered to be in a general state of eguilibrium
with precipitation egual to the sum of surface water runoff, groundwater recharge and evapotranspiration.
Precipitation in the Holbrook area averages 46 inches a year. Since the study area is not heavily urbanized,
it may be assumed that surface run-off at the Site approximates natural conditions.

SITE HISTORY AND ENFORCEMENT ACTIVITIES

From 1968 to 1990, the two buildings were occupied by several different companies that generated and stored
hazardous substances on the Site. These companies included Goldisc Recordings, Inc. (Goldisc), which produced
phonographic records; ElectroSound Group, Inc. (ElectroSound), a company that manufactured audio visual and
optical devices; and Genco Auto Electric, Inc. (Genco), which rebuilt automotive engine parts. The First
Holbrook Company (First Holbrook) owned the property from 1973 to 1985. In 1985, the Red Ground Corporation
became the owner of the property. In 1989, Red Ground Corporation sold the property to a partnership named
Red Ground Company. In February 1997, Red Ground Company transferred its interest in 717 and 725 Broadway

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Avenue, Islip, New York to First Industrial, L.P., a limited partnership. The current occupants of the Site
buildings are dry goods merchants and do not perform any manufacturing on-site.

The substances known to have been disposed of on the Site between 1968 and 1990 include wastewater from the
various production processes, waste oils, metals, solutions containing high concentrations of xylene and
trichloroethylene and other degreasing agents. These substances were reportedly discharged to the environment
through dry wells, leaching pools, storm drains and leaking storage containers located around the buildings.

Since the late 1970s, the Suffolk County Department of Health Services (SCDHS), the New York State Department
of Environmental Conservation  (NYSDEC) and EPA have conducted various inspections and environmental
protection enforcement activities at the Site. In 1978, a representative from the SCDHS inspected the Site
and noted stains, puddles, and leaking drums suspected to be related to industrial wastes. In the early
1980s, the SCDHS collected samples from leaching pools, storm drains and cesspools located on the Site.
Laboratory analyses of the samples revealed violations of NYS Groundwater Effluent Guidelines. Between 1981
and 1983, laboratory analyses of groundwater samples collected from on-site monitoring wells revealed
elevated levels of solvents and metals, including: trichloroethane, trichloroethylene, tetrachloroethylene,
lead, nickel, chromium and silver. Analyses of samples obtained from the CS wellfield showed concentrations
of tetrachloroethylene slightly exceeding the Federal and State Maximum Contaminant Level  (MCL) of 5
micrograms/liter  (Ig/1) for public drinking water. Based on
these findings, the Site was proposed for inclusion on the National Priorities List (NPL) in October 1984 and
was added to the NPL in June 1986.

In 1988, DEC entered into an Administrative Order on Consent (AOC) with two of the potentially responsible
parties  (PRPs), namely, First Holbrook and ElectroSound. The AOC reguired the two PRPs to conduct an RI
(Phase I) at the Site. The Phase I RI was conducted in 1988 and included the investigation of nineteen
areas of potential contamination. Groundwater and soil samples were collected and analyzed to determine the
nature and extent of contamination in these areas. Elevated levels of lead and tetrachloroethylene were found
in groundwater samples. Soil samples were found to contain elevated levels of several metals,
volatile organic compounds (VOCs) and semi-volatile organic compounds.

Based on a review of the results, EPA and DEC determined that additional information was necessary in order
to better define the extent of contamination at the Site. In late 1990, DEC reguested that EPA take over as
lead agency for the Site. EPA notified First Holbrook, ElectroSound, Genco, and Red Ground of
their potential liability at the Site and reguested they finance or undertake the continuing RI/FS.
Subseguently, in 1991, EPA entered into an AOC with First Holbrook and ElectroSound. This AOC specifically
reguired the PRPs to conduct a supplemental RI/FS (or Phase II RI/FS). A subseguent notification of potential
liability was issued on August 17, 1995 to an additional seven individuals who are partners of First
Holbrook.

HIGHLIGHTS OF COMMUNITY PARTICIPATION

The Proposed Plan for OU-2 was released to the public for comment on August 29, 1998.  This Proposed Plan and
other site-related documents, including the RI/FS reports, were made available to the public at information
repositories located at the Town of Islip Town Hall and the Sachem Public Library. The notice of availability
for the above-referenced documents was published in Newsday, Suffolk County edition, on August 29, 1998, and
a press release was issued on August 27, 1998. The public comment period on these documents was held from
August 29, 1998 to September 23, 1995.

On September 17, 1998, EPA conducted a public meeting at the Bohemia Recreation Center to inform local
officials and interested citizens about the Superfund process,  to review current and planned remedial
activities at the Site and to respond to any guestions from area residents and other attendees.

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

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EPA divided the remedial work necessary to mitigate contamination stemming from the Site into two operable
units. OU-1 addressed the source of contamination at the Site and included the removal of surface soils,
removal of soils and sediments from seven dry wells and removal of soils and sediments from a production well
vault. The remedy was implemented when approximately 300 cubic yards of contaminated soils were excavated and
disposed of off-site during May-July 1997 (see Figure 4).

OU-2 is the subject of this Record of Decision and addresses the remediation of nickel contamination in the
groundwater.

SUMMARY OF SITE CHARACTERISTICS

In 1988, groundwater remedial investigation field work began at the Site with the Phase I RI, conducted by
the PRPs pursuant to an AOC with NYSDEC. The results of this investigation, as well as the results of the
Phase II RI, conducted by the PRPs pursuant to an AOC with EPA, are summarized in the August 1995 RI report.

Groundwater investigation field work at the Site has included the collection of groundwater samples from 17
on-site monitoring wells, four off-site monitoring wells, one on-site production well and the three CS public
water supply wells. Of the 17 on site monitoring wells, 15 are shallow (less than 50 feet below
ground surface (bgs)), one is intermediate (75 to 90 feet bgs) and one is deep (over 100 foot bgs). Of the
five off-site monitoring wells, three are shallow, one is intermediate and one is deep. Two of these off-site
monitoring wells are installed upgradient of the Site. All on-site monitoring wells are installed in the
Upper Glacial Aguifer. As discussed above, CS-1 and CS-2 are both shallow wells, installed, at similar depths
of approximately 160 feet, in the Upper Glacial aguifer. CS-3 is screened at approximately 500 feet in the
lower Magothy Aguifer.

Monitoring Well Data

In July and August 1988, the Phase I RI groundwater sampling was conducted for metals and VOCs. For the
metals, findings showed somewhat elevated levels of nickel, chromium and lead (see Tables la-lc). Only one
Site-related VOC, 1,1,1-trichloroethane, was detected above Federal and State drinking and groundwater
standards; 1,1,1-trichloroethane was detected in three wells, with the highest concentration of 9.8 Ig/1
found in monitoring well 171 (see.Tables la-lc).

Two rounds (April 1993 and September 1994) of groundwater samples were collected during the Phase II RI. The
groundwater samples were analyzed for Target Analyte List (TAL) metals and Target Compound List (TCL) VOCs.
This sampling was intended to complement groundwater sampling conducted during the Phase I RI.

The April 1993 Phase II groundwater sampling effort included collection of samples from eight on-site
monitoring wells. The metals analysis showed no levels above Federal or State drinking water standards (see
Table 2). Wells impacted by nickel contamination in the Phase I RI were not sampled during the first
round Phase II sampling. The only VOC detected at a concentration above a drinking water standard was carbon
disulfide in monitoring well 17D (MW-17D) (see Table 3). Analytical results for the split sample from MW-17D
did not indicate the presence of carbon disulfide above the drinking water standard. Carbon disulfide has
been determined to be a laboratory artifact and not a Site-related contaminant of concern.

The September 1994 Phase II sampling was initiated to investigate further the presence of heavy metals,
particularly nickel, in the groundwater at the Site (see Tables 4a and 4b). Samples were collected samples
from 15 on-site monitoring wells and analyzed for nickel, chromium, iron and manganese. All 15 samples were
split and analyzed by EPA for all TAL metals. The second round of Phase II metals sampling detected nickel at
three wells above the federal MCL, which, at the time, was 100 Ig/1. 1 Of the 15 wells sampled during Phase
II (second round), only three had levels of nickel above 100 Ig/1, namely, MW-11 (140 Ig/1), MW-12 (959 Ig/1)
and MW-16 (278 Ig/1). Table 5 provides results of all nickel analyses performed on samples collected from the
monitoring wells since 1994.

The Phase II second round of metals analysis also detected the presence of both iron and manganese above
their respective secondary drinking water standards (see Tables 4a and 4b). The Federal and State secondary
MCLs for iron and manganese are both based on aesthetic properties and are intended to prevent

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potential problems, such as poor taste, odor, and staining of plumbing fixtures, and do not specifically
present a health risk. The highest concentrations of iron (34,900 Ig/1) and manganese (2,840 Ig/1) were
present in the unfiltered sample collected from MW-11R. A filtered sample collected from MW-11R detected iron
and manganese at reduced levels of 189 Ig/1 and 459 Ig/1, respectively. In the filtered sample, manganese was
still detected in excess of the secondary standard. However, the manganese levels detected represent
background conditions in the area. Chromium was not detected above Federal and State drinking
water standards.

Comparison of the Phase I and Phase II groundwater sampling results indicated that, in general, VOC
concentrations had decreased, such that no Site-related VOCs were above Federal and State drinking water
standards. Based on its continued freguent detection at elevated concentrations at the Site and the
potential impact to the CS wellfield, nickel was deemed to be the only contaminant of concern in the
groundwater at the Site.

Following the completion of the remedial action for OU-1 and in order to evaluate the groundwater further,
the PRPs' contractor,

1 In 1995, EPA remanded the MCL for nickel. Subseguently, EPA issued a Health Advisory (HA) of 100
Ig/1 for nickel; this HA is intended to serve as informal technical guidance only. The HA
incorporates additional conservative assumptions related to potential nickel exposure from media
other than drinking water. For the Site, a health-based action level for nickel was also
developed, utilizing superfund risk assessment methodologies. This health-based action level,
detailed further in the risk discussion, was calculated to be 730 Ig/1.

under the direction of EPA, performed supplemental groundwater sampling before (May 1997) and after (December
1997) the source control remedial action was implemented during May-July 1997. The intent of this
supplemental groundwater investigation was to obtain additional information regarding the fate of nickel in
the groundwater at the Site after the removal of the nickel-contaminated surface soils and dry well
sediments.

In May 1997, 10 monitoring wells were sampled in order to establish nickel levels prior to the remedial
action for OU-1. The May 1997 results showed that only one well, MW-12, contained nickel levels above EPA's
Health Advisory level and NYS Class GA standard of 100 Ig/1 (see Table 5). Nickel was present at a
concentration of 394 Ig/1 in this well, significantly below the 959 Ig/1 detected in 1994. Similarly, nickel
concentrations in the other wells which had also been above 100 Ig/1 in 1994 decreased significantly; the
nickel concentration in MW-16 decreased from 278 ug/1 to 95 Ig/1, while the concentration in MW-11 decreased
from 140 Ig/1 to below-the detection limit of 14 Ig/1. Nickel was also not detected in five of the remaining
seven wells sampled.

In December 1997, 13 wells were sampled for nickel in order to assess the post-remediation nickel
concentration. The December 1997 results also showed a general decline in nickel concentrations (see Table
5). In particular, MW-12 results showed a reduction from 394 Ig/1 (May 1997) to 300 Ig/1 and was for nickel.
Nickel was not detected in 10 of the remaining 13 wells sampled.

Church Street Wellfield

As discussed above, the CS wellfield is located approximately 1200 feet south of the Site. CS-1 is screened
from approximately 112 feet to 160 feet in the lower Upper Glacial with a specific capacity of 34.5
gallons/minute/foot(gpm/ft). CS-2 is screened from approximately 126 feet to 157 feet in the lower Upper
Glacial with a specific capacity of 43.2 gpm/ft. CS-3 is screened from approximately 444 feet to 505 feet in
the mid-Magothy with a specific capacity of 35.1 gpm/ft. Historically, the wellfield production has ranged
from three million gallons per day (MGD) (summer) to 60,000 gallons/day (winter). The CS-2
and CS-3 wells may be blended during peak demand periods.

In late 1993, routine monitoring performed by SCWA on the CS wellfield detected the presence of nickel in
CS-2 in excess of the former MCL (100 Ig/1) for nickel. This prompted SCWA to remove CS-2 from service and
conduct testing to evaluate a suitable method of reducing the concentration of nickel in that supply well.

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The monitoring of CS-1 and CS-3 have shown that these wells have not been significantly impacted by
contamination from the Site. Since January 1995, the highest level of nickel detected at CS-2 was 112 Ig/1 in
January 1996. CS-2 was subsequently returned to service. Overall results of the SCWA sampling of the CS wells
has shown a general decrease in the nickel levels. SCWA has closely monitored the quality of water
in CS-2, in addition to its other wells, to ensure that the water distributed from its wellfield meets all
Federal and State drinking water standards.

From June 1997 until March 1998, CS-2 was sampled weekly; the highest nickel level of 99.7 Ig/1 was found in
July 1997. The levels since that time have decreased steadily, and, for the period from January 1998 through
June 1998, the average concentration in the influent to CS-2 was 55 Ig/1.

This decreasing trend of nickel concentrations to levels well below 100 Ig/1 is consistent with the solute
transport modeling results, which were provided in the August 1995 FS. The model incorporated very
conservative assumptions intended to overestimate the concentrations of nickel which might reach CS-2. The
model, which utilized the maximum concentration that had been found at the Site (959.Ig/1 rounded up to 1000
Ig/1) (see Figure 5), predicted that nickel concentrations reaching CS-2 would peak at 325 ug/1 in 1996,
prior to decreasing to levels below 100 Ig/1 in 1997. In fact, CS-2 sampling data available to EPA affirm
that the model assumptions were very conservative, since the nickel concentrations entering CS-2 reached a
peak of 112 ug/1 in January 1996 and have not been above 100 Ig/1 since then. It should be noted that, while
the sample results since January 1996 have generally indicated concentrations in the 50-70 Ig/1 range,
concentrations did approach 100 Ig/1 in late June 1997, only to decline shortly thereafter.

Given these results, coupled with the source removal and the significant decline of nickel on-site, it is
anticipated that nickel concentrations will continue to decrease on-site to levels below the NYS Class GA
standard within three years and that levels of nickel at CS-2 will continue to decrease and remain below 100
ug/1.

In order to monitor further the nickel concentration both upgradient of the CS wellfield and downgradient of
the Site, a cluster of two additional monitoring wells, identified as MW-19I and MW-19D, are currently being
installed just northeast of the existing CS wellfield. These wells will be sampled as part of the monitoring
program portion of the preferred remedy.

SUMMARY OF SITE RISKS

The 1995 RI included a baseline risk assessment which estimated the risks associated with current and future
uses of the Site. 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, frequency of occurrence, and concentration. Exposure Assessment—estimates the
magnitude of actual and/or potential human exposures, the frequency and duration of these exposures, and the
pathway (e.g, ingesting contaminated well-water) by which humans are potentially exposed. Toxicity
Assessment—determines the types of adverse health effects associated with chemical exposures, and the
relationship between magnitude of exposure (dose) and severity of adverse effects (response). Risk
Characterization— summarizes and combines outputs of the exposure and toxicity
assessments to provide a quantitative (e.g., one-in-a-million excess cancer risk) assessment of site-related
risks.

EPA conducted the baseline risk assessment to evaluate the potential risks to human health and the
environment associated with the Site in its current state. The risk assessment began with selecting
contaminants of concern which would likely pose significant risks to human health and the environment. These
contaminants included tetrachloroethylene, 1,1-dichloroethane, 1,1,1-trichloroethane, vinyl chloride,
benzo(a)anthracene, chrysene, cadmium, copper, lead, nickel and zinc.

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Exposure pathways were evaluated under possible on-site present and future land use conditions. The Site was
assumed to retain its current zoning status of commercial/industrial. The exposure pathway considered for
groundwater was domestic use of groundwater (including ingestion and inhalation of volatiles by nearby
residents using the CS wellfield as the exposure point).

EPA's acceptable cancer risk range is 10 -4 to 10 -6 under a reasonable maximum exposure (RME) scenario. This
can be interpreted to mean that an individual may have a one in ten thousand to a one in a million increased
chance of developing cancer as a result of exposure to a site-related carcinogen over a 70-year lifetime
under the specific exposure conditions at a site. The results of the baseline risk assessment indicated that
the groundwater at the Site does not pose an unacceptable risk to human health. The overall carcinogenic risk
for domestic use of groundwater, through ingestion and inhalation, is estimated to be
9.5 x 10 -6 (risk of 9.5 in a million) under RME assumptions. Much of this risk is attributable to vinyl
chloride which was detected at low levels in Site soils but was not detected in the groundwater. Because of
its presence in Site soils, vinyl chloride was conservatively assumed to be present in the groundwater at a
concentration one-half its detection limit.

To assess the overall potential for noncarcinogenic effects posed by the contaminants at a site, EPA has
developed the hazard index (HI). The HI measures the assumed simultaneous subthreshold exposures to several
chemicals which could result in an adverse health effect. When the HI exceeds 1.0, there may be concern for
potential noncarcinogenic health effects. The calculated HI values for the dermal absorption and direct
contact pathways were all calculated to be less than 1. Domestic use of groundwater contributed to an HI
value of 0.26; nickel was the major contributor to this HI.

Since significant nickel contamination exists in the Upper Glacial Aquifer, potential risks related to this
contamination were closely evaluated. An acceptable health-based action level was developed for nickel in
groundwater at the Site. Assuming that the groundwater would be used for domestic purposes, it was determined
that groundwater concentrations of nickel below 730 Ig/1 would result in an acceptable HI for the Site, i.e.,
an HI less than or equal to 1.0; conversely, levels above 730 Ig/1 could present an unacceptable
noncarcinogenic risk for the Site.

Consistent with EPA guidance for conducting Superfund risk assessments, this calculated value assumes that
there are no other significant sources of nickel exposure from other environmental media (e.g., air, soil,
diet, etc.). As a point of reference, the 95% Upper Confidence Level of the arithmetic mean, calculated
utilizing the nickel data from all monitoring wells sampled during all phases of the investigation is 66.5
Ig/1, well below the 730 Ig/1 action level.

As noted previously, EPA has issued a Health Advisory for nickel of 100 Ig/1 which is the same level as the
former Federal MCL. The Health Advisory incorporates additional conservative safety factors to account for
potential nickel exposure from media other than drinking water; this very conservative level of safety
assumes that drinking water only contributes 20% of the expected nickel exposure.

A solute transport model, performed during the 1995 FS to show the potential future concentrations of nickel
at the CS wellfield, determined that, under existing conditions, concentrations of nickel in CS-2 are
unlikely to ever approach the 730 Ig/1 site-specific EPA risk-based level. The modeling, using very
conservative assumptions, indicated that levels of nickel on-site would need to increase to greater than 2200
Ig/1 in order to exceed the 730 Ig/1 risk-based value at the CS wellfield. As discussed above, levels of
nickel on-site have decreased from a high of 959 Ig/1 1994 to 300 Ig/1 in 1998, and levels of nickel at the
CS Wellfield have steadily declined since 1996 and have not been 100 Ig/1 or above since January 1996. Since
the source of nickel contamination has been removed, the concentrations of nickel in the Site groundwater are
expected to decrease significantly.

Ecological Assessment

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groundwater into surface waters, particularly the state wetland located one-half mile south of the Site.
Phase II sampling shows that the wetlands have not been impacted by Site contaminants. Therefore, it was
determined that no significant effects on aguatic organisms in the wetlands near the Site could be attributed
to groundwater discharge from the Site.

The Site poses no unacceptable carcinogenic or noncarcinogenic risk to human health and 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
• toxicological data.

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

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

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

REMEDIAL ACTION OBJECTIVES

Remedial action objectives are specific goals to protect human health and the environment. These objectives
are based on available information and standards such as applicable or relevant and appropriate reguirements
(ARARs) and risk-based levels established in the risk assessment.

The remedial action objective for OU-2 is to prevent the ingestion of drinking water containing
concentrations of nickel above the 100 Ig/1 NYS Class GA standard, which is an ARAR at the Site.

DESCRIPTION OF REMEDIAL ALTERNATIVES

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, as a principal element, treatment to permanently and
significantly reduce the volume, toxicity or mobility of the hazardous substances, pollutants and
contaminants at a site. CERCLA °121(d), 42 U.S.C. °9621(d), further specifies that a
remedial action must attain a level or standard of control of the hazardous substances, pollutants and
contaminants, which at least attains ARARs under Federal and State laws, unless a waiver can be justified
pursuant to CERCLA °121(d)(4), 42 U.S.C. °9621(d)(4).

This ROD evaluates, in detail, four remedial alternatives for addressing contaminated groundwater associated
with the Site. Each alternative includes capital costs and operation and maintenance (O&M) costs.

-------
The construction time is defined as the period of time needed to construct or implement the remedy and does
not include the time required to design the remedy, procure contracts for design and construction or to
negotiate with responsible parties for implementation of the remedy.

The remedial alternatives for groundwater  (GWR) are as follows:

              GWR-I:     No Action
              GWR-II:    Water Supply - Wellhead Treatment
       •      GWR-III:   Recovery Well - Groundwater Remediation
              GWR-IV:    Monitored Natural Attenuation

Alternative GWR-I: No Action

   Capital Cost:  $0
   0 & M/yr Cost: $0
   Present Worth: $0

   Construction Time: N/A

The Superfund program requires that the no action alternative be considered as a baseline for comparison with
other alternatives. Under this no action alternative, no active or passive remediation nor monitoring would
occur.

Alternative GWR-II: Water Supply - Well Head Treatment

  Capital Cost: $3,319,920
  0 & M/yr Cost: $195,307
  Present Worth: $4,120,679  (over five years)

   Construction Time: 2 years

This alternative would include the installation and operation of a groundwater treatment system at the well
head for CS-2 for nickel removal, followed by discharge of the treated groundwater to the existing public
water supply distribution system.

At an estimated flow of 200 gpm, the groundwater would be pumped from a holding tank through a particulate
filter and through a multi-vessel ion exchange system. The ion exchange process would remove the metal ions,
primarily nickel, from solution, using e.g., hydrous aluminum silicates or organic resins. It is
estimated that 8,000 gallons of the concentrated nickel waste stream per month would be generated, requiring
off-site disposal in a RCRA Subtitle C facility in accordance with land disposal restrictions. Following
treatment, the groundwater would be pumped into the existing water supply storage tank and/or into the water
distribution system. Use restrictions would be imposed on the development of potable water supply wells at
the Site.

Alternative GWR-III: Recovery Well - Groundwater Remediation

  Capital Cost: $1,694,585
  0 & M/yr. Cost: $135,583
  Present Worth: $2,250,475  (over five years)

   Construction Time: 2 years

This alternative would include the installation of a groundwater recovery well and treatment system for
nickel removal and the discharge of treated groundwater to an existing recharge basin.

A groundwater recovery well, operating at 100 gpm, would be installed immediately downgradient of the Site on
the south of Veteran's Highway. The groundwater would be pumped through a particulate filter and a

-------
multi-vessel ion exchange system; this ion exchange process is similar to that of Alternative GWR-II.
It is estimated that 4,500 gallons of the concentrated nickel waste stream per month would be generated,
reguiring off-site disposal in a RCRA Subtitle C facility, in accordance with EPA land disposal restrictions.
The groundwater would be treated to meet Federal and State groundwater and drinking water standards prior to
discharge to an existing storm water recharge basin. Use restrictions, as described in GWR-II, would also be
implemented.

Alternative GWR-IV: Monitored Natural Attenuation

Capital Cost: $0
0 & M/yr Cost: $2,300
Present Worth: $9,430 (over five years)

Construction Time: 6 months

This alternative would use natural physical processes to restore groundwater to ARARs. Use restrictions, as
described in Alternative GWR-II, would also be implemented. EPA expects that final cleanup levels would be
met throughout the entire area of nickel contamination within a three-year time frame. Groundwater
monitoring would include sampling of existing on-site and off-site monitoring wells, both outside and within
the area of nickel contamination, including the CS wellfield. Sampling of the wells, i.e., those identified
in the proposed monitoring program, would be conducted on a guarterly basis. For cost-estimation purposes,
guarterly sampling was assumed; however, the actual freguency of sampling will be determined pursuant to a
final sampling plan.

Furthermore, in order to ensure that the CS wellfield is able to continue to supply water that meets all
Federal and State groundwater and drinking water standards, an additional monitoring well cluster is
currently being installed. This well cluster would also be included in the proposed monitoring-program
in order to monitor more closely the guality of the groundwater just upgradient of the CS wellfield,
particularly CS-2. The monitoring of this well cluster would occur on a more freguent basis. If, at any time
during the three-year monitoring period, this well cluster revealed nickel levels above 300 Ig/1; then, the
appropriateness of the natural attenuation remedy would be reconsidered and contingency measures would be
evaluated to ensure that the CS wellfield continues to distribute safe drinking water to its customers. These
contingency measures could include well-head treatment, installation of a new supply well and/or the
installation of a groundwater extraction and treatment system.

SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES

In selecting a remedy, EPA considered the factors set out in CERCLA °121, 42 U.S.C. °9621, by conducting a
detailed analysis of the viable remedial alternatives pursuant to the NCP, 40 CFR °300.430(e)(9) and OSWER
Directive 9355.3-01. The detailed analysis consisted of an assessment of the individual alternatives against
each of nine evaluation criteria and a comparative analysis focusing upon the relative performance of each
alternative against those criteria. During the detailed evaluation of remedial alternatives, each alternative
is assessed against nine evaluation criteria.

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

• Overall protection of human health and the environment addresses whether or not a remedy provides
adeguate protection and describes how risks are eliminated, reduced or controlled through treatment,
engineering controls or institutional controls.

• Compliance with ARARs addresses whether or not a remedy will meet all of the applicable or relevant
and appropriate reguirements and/or provide grounds for invoking a waiver.

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

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

• Reduction of toxicity-mobility or volume through treatment is the anticipated performance of the
treatment technologies a remedy may employ.

• Short-term effectivenees addresses the period of time needed to achieve protection from 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 both estimated capital and operation and maintenance costs and net present worth costs.

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

• State acceptance indicates whether, based on its review of the RI/FS reports and Proposed Plan, the
State concurs with, opposes or has no comment on the preferred alternative.

• Community acceptance will be assessed in the ROD and refers to the public's general response to the
alternatives described in the RI/FS reports and the Proposed Plan.

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

• Overall Protection of Human Health and the Environment

Alternatives GWR-II, GWR-III and GWR IV are fully protective of human health and the environment.
Alternative GWR-III would be most protective, since it would extract and treat the most highly
contaminated groundwater, followed by Alternative GWR-II which would extract and treat nickel
concentrations which are already deemed safe for drinking. Since Alternative GWR-I does not include any
active remediation or controls, it is less protective than the other alternatives.

• Compliance with ARARs

Alternative GWR-I would not comply with ARARs, since it would not address localized levels of nickel
above the NYS Class GA standard in the on-site groundwater. The other three alternatives would achieve
the NYS Class GA standard for on site groundwater in approximately the same time frame.

• Compliance with ARARs would be demonstrated through monitoring.

The treated effluent from Alternatives GWR-II and GWR-III would also comply with Federal and State
drinking water standards and standards for the transport and disposal of the concentrated nickel waste
stream from the ion exchange system.

• Long-Term Effectiveness and Permanence

Alternatives GWR-II, GWR-III and GWR-IV would all reduce the potential risk associated with groundwater
ingestion by implementing controls or treatment to prevent exposure to localized concentrations of
nickel in the on-site groundwater, which exceed the NYS Class GA standard. These alternatives all
provide the same relative degree of permanence.

-------
Each of these alternatives, as well as Alternative GWR-I, is expected to result in cleanup levels being
achieved within the aquifer within three years.

• Reduction in Toxicity, Mobility or Volume Through Treatment

Alternatives GWR-II and GWR-III would provide the greatest degree of reduction in toxicity and volume
of affected groundwater through treatment. Alternative GWR-III would control mobility of nickel in the
groundwater through the operation of the groundwater recovery system. Alternative GWR-II would control
the mobility of nickel in the groundwater through continued normal operation of the CS wellfield.
Alternatives GWR-I and GWR-IV would not actively reduce the toxicity, mobility or volume of the nickel
in the groundwater.

• Short-term Effectiveness

Alternative GWR-III would include excavation activities, installation of collection and discharge
systems and construction of the treatment plant; any potential impacts to residents and workers from
the construction activities would be minimized though the use of proper protective equipment.
Similarly, Alternative GWR-II would require some construction activities. Residuals from the treatment
process could pose a minor impart to workers handling and transporting these materials; safe handling
and transport procedures would be easily implemented to mitigate these minor impacts.

The implementation of Alternatives GWR-I and GWR-IV would result in no additional risk to the community
or on-site workers during remedial activities, since no major construction activities would be
conducted.

• Implementability

All services, materials and technologies required to implement Alternatives GWR-II and GWR-III are
readily available. Alternative GWR-III, however, would require approval and coordination of the SCWA to
install the water treatment system at the CS wellfield. Treatability study testing may need to be
conducted to design the treatment systems for Alternatives GWR-II and GWR-III.

There are no actions to implement under Alternative GWR-I. The groundwater monitoring program under
Alternative GWR-IV would be easily implemented.

Cost

Alternative GWR-II ($4,120,679) would be the most costly alternative to implement, followed by
Alternatives GWR-III ($2,250,475) and GWR-IV ($9,430). There are no implementation costs associated
with Alternative GWR-I.

• State Acceptance

NYSDEC concurs with the preferred alternative, Monitored Natural Attenuation (GWR-IV).

• Community Acceptance

The community concurs with the preferred alternative, Monitored Natural Attenuation (Alternative
GWR-IV).

DESCRIPTION OF THE SEIiECTED REMEDY

The selected remedy for the groundwater at the Site is Monitored Natural Attenuation. The selected remedy is
protective of human health and the environment, complies with Federal and State requirements that are legally
applicable or relevant and appropriate to the remedial action and is cost-effective.

A monitoring program will be developed subsequent to the issuance of this ROD in order to provide a profile

-------
of future levels of the nickel contamination at the Site and its effect on the Church Street wellfield. The
scope of this monitoring program is expected to be similar to that of the previous monitoring.

EPA and NYSDEC have determined that site-related groundwater contamination is limited and does not pose a
significant threat to human health or the environment; therefore, a more active remediation strategy is not
appropriate. This determination is based on the latest groundwater sampling data and the implementation of
the Operable Unit One (OU-1) source control remedy, i.e., the excavation and disposal of contaminated soils
and dry well sediments. Since the existing levels of contamination are limited, monitored natural attenuation
would use natural physical processes to restore groundwater at the Site.

STATUTORY DETERMINATIONS

As 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 is considered to be fully responsive to this criterion and to the identified remedial
action objective.

Compliance with ARARs

The selected remedy compliance with ARARs would be demonstrated through monitoring.

Action-Specific ARARs:

• None applicable.

Chemical-Specific ARARs:

NYSDEC Title 6, Chapter X, Parts 700-706, 1998, Final Combined Regulatory Impact and Environmental
Impact Statement, Division of Water.

Location-Specific ARARs:

• None applicable.

Cost-Effectiveness

The selected remedy is cost-effective in that it provides overall effectiveness proportional to its cost. The
total present worth cost of the remedy is $9,430; low long-term operation and maintenance costs are expected.

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

The selected remedy utilizes permanent solutions and treatment technologies to the Maximum Extent
Practicable.

Preference for Treatment as a Principal Element

-------
Although the selected remedy does not require treatment, it is anticipated that through natural attenuation
contamination levels will decrease.

SITE CONSTRUCTION COMPIiETION

This ROD documents that all construction activities at the Site have been completed in accordance with Close
Out Procedures for National Priorities List Sites - August 1995  (OSWER Directive 9320.2-09).

There is no construction associated with the groundwater remedy. The groundwater monitoring performed to date
provides a valid representation of past and present groundwater conditions at the Site and demonstrates that
cleanup goals should be achieved within the time period of the selected remedy monitoring program.

A monitoring program will be developed subsequent to the issuance of this ROD in order to provide a profile
of future levels of the nickel contamination at the Site and its effect on the CS wellfield. The scope of
this monitoring program is expected to be similar to that of the previous monitoring.

Contaminated soils and dry well sediments were excavated and disposed of off-site, in accordance with the
September 1995 ROD. Information on that remedial action can be found in the January 1998 Remedial Action
Report, contained in the Administrative Record for the Site. Since the implementation of a contingency
remedy is unlikely, no further remedial action response is anticipated at the Site. Therefore, the Site now
qualifies for inclusion on the Construction Completion List.

Activities and Schedule for Site Completion

The remedial action activities that remain to be completed for the Site include the following: 1) the
five-year monitoring program, 2) the placement of a deed restriction on the Site upon EPA's request, 3) the
five-year review and 4) the preparation of the Final Close Out Report. These activities will be completed
according to the following schedule:

          Task                 Estimated                  Responsible
                              Completion                 Organization

Monitor Groundwater           10/30/03                   PRPs/EPA/SCWA

Implement Deed                01/01/03 [upon                  PRPs
Restriction                   EPA' s request]

Final Close Out               01/01/03                        EPA
Report

Five-year Review              06/30/03                        EPA

Deletion From NPL             06/30/03                        EPA

DOCUMENTATION OF SIGNIFICANT CHANGES

The Proposed Plan for the Site groundwater, identifying the selected remedy as Alternative GWR-III, was
released to the public on August 29, 1998. There are no significant changes from the preferred alternative,
as presented in the OU-2 Proposed Plan.

The present worth costs of the selected remedy was modified from the preferred alternative in the OU-2
Proposed Plan to reflect EPA's current time frame for aquifer restoration (three years) and groundwater
monitoring (five years).

-------
                                    APPENDIX I

                                     FIGURES

-------
                                  APPENDIX II
                                     TABIiES
                                    TABIiE la
                      PHASE I ANALYTICAL RESULTS FOR GROUND WATER SANPLES
                                     FORMER GOLDISC SITE
                                     HOLBROOK, NEW YORK
                                        Page 1 of 3
Date Sampled
Volatile Organics
Methylene Chloride
Acetone
Chloroform
1,1 Dichloroethane
1,1,1 Trichloroethane
Te trachl or oe thane
TOTAL VOCs
Total VOC TICs
Total Metals
Aluminum
Calcium
Total Chromium
Hexavalent Chromium
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Mercury
Nickel
Potassium
Sodium
Vanadium
Zinc
Dissolved Metals
Aluminum
Calcium
Chromium
Copper
Iron
Lead
Magnesium
Manganese
Mercury
Nickel
Potassium
Sodium
Zinc
STD

5
50
100
5
5
5
-
-

-
-

100
-
-
300
15
-
300
2
100
-
-
-
5000

-
-
100
-
30
50
-
300
2
100
-
-
5000
MW-2
7/26/88

<5
<50
<5
<5
1.4 J
<5
1.4
U

2120
9730
13
<10
<50
<25
3259
<6.0
<5000
532
<0.2
<40
5620
31180
<50
67

<100
12060
11
<25
<100
<5.0
<5000
17
<0.2
<40
5450
37170
37 B
MW-3
7/26/88

<5
<50
<5
<5
2.5 J
<5
2.5
U

3720
15320
11
<10
<50
<25
4490
<20
<5000
647
<0.2
<40
<5000
15790
<50
36 B

326
15640
<10
<25
<100
<5.0
<5000
44
<0.2
<40
<5000
15640
83
MW-4R
7/27/88

4.4 B
2.8 B
<5
12
9.7
<5
28.9
4.0

224
15030
<10
<10
<50
<25
178
<5.0
<5000
37
<0.2
<40
<5000
19340
<50
33 B

<100
14730
<10
<25
<100
<5.0
<5000
<15
<0.2
<40
<5000
19980
76
MW-7B MW-7C
7/27/88 7/28/88

<5
<50
<5
<5
1.3 J
<5
1.3
U

179
10210
<10
<10
<50
<25
158
<5.0
<5000
154
<0.2
<40
<5000
12570
<50
33 B

<100
10290
<10
<25
<100
<5.0
<5000
143
<0.2
<40
<5000
12800
<20

<5
<50
<5
<5
<5
<5
U
U

233 J
14830 J
<10
<10
<50
<25
<100
<5.0
<5000
91 J
<0.2
<40
<5000
8410 J
<50
<20

<100
7670
<10
<25
<100
<5.0
<5000
<0.2
<0.2
<40
<5000
8320
<20
MW-8 MW-9R MW-10
7/27/88 7/26/88 7/26/88

<5
<50
<5
<5
<5
<5
U
U

9990
12780
<10
26
65
37
9272
88
<5000
1740
<0.2
145
<5000
<5000
<50
617

148
J 12290
<10
<25
<100
<5.0
<5000
527
<0.2
140
<5000
J <5000
465

<5
<50
<5
<5
<5
<5
U
117

1130
10120
<10
<10
<50
<25
1760
<5.0
<5000
202
0.3
<40
<5000
<5000
<50
37 B

<100
10120
<10
<25
<100
<5.0
<5000
<15
<0.2
<40
<5000
<5000
44 B

<5
<50
<5
<5
5.5 J
1.6 J
7J
U

4250
32930
73
<10
<50
<25
39230
<5.0
9770
535
<0.2
<40
<5000
8760
50
79

212
32990
11
25
161
<5.0
9990
17
<0.2
<40
<5000
8700
40 B
NOTES:     Units are micrograms per liter. Only detected VOCs  are  reported.
           TICs: Tentatively Identified Compounds.                          U:  Undetected.
           B: Compound also detected in blank.                              J:  Estimated concentration.
           PW-I was also analyzed for base/neutral/acid extractables,  pesticides,  and PCBs.  All
                concentrations were below detection  limits.

-------
                                                 TABLE Ib
                           PHASE  I ANALYTICAL RESULTS FOR GROUND WATER SAMPLES
                                            FORMER GOLDISC SITE
                                            HOLBROOK,  NEW YORK
                                                Page 2 of 3
                    STD
  Date Sampled
 Volatile Organics
Methylene Chloride    5
Acetone               50
Chloroform            5
1, 1 Dichloroethane    5
1,1,1 Trichloroethane 5
Tetrachloroethene     5
TOTAL VOCs
Total VOC TICs
     Total Metals
Aluminum
Calcium
Total Chromium       100
Hexavalent Chromium  100
Cobalt
Copper
Iron                 300
Lead                  15
Magnesium
Manganese            300
Mercury                2
Nickel               100
Potassium
Sodium
Vanadium
Zinc                5000
  Dissolved Metals
Aluminum
Calcium
Chromium             100
Copper
Iron                 300
Lead                  50
Magnesium
Manganese            300
Mercury                2
Nickel               100
Potassium
Sodium
Zinc                5000
                                                                              U: Undetected.
                                                                              J: Estimated  concentration.

-------
                                             TABIiE Ic
                          PHASE I ANALYTICAL RESULTS FOR GROUND WATER SAMPLES
                                        FORMER GOLDISC SITE
                                        HOLBROOK, NEW YORK
                                            Page 3 of 3
STD
Date Sampled
Volatile Organics
Methylene Chloride
Acetone
Chloroform
1,1 Dichloroethane
1,1,1 Trichloroethane
Tetrachloroethene
TOTAL VOCs
Total VOC TICs
Total Metals
Aluminum
Calcium
<5000
Total Chromium
Hexavalent Chromium
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Mercury
Nickel
Potassium
Sodium
Vanadium
Zinc
J
Dissolved Metals
Aluminum
Calcium
Chromium
Copper
Iron
Lead
Magnesium
Maganese
Mercury
Nickel
Potassium
Sodium
Zinc
J
MW-17D
8/5/88

5
50
5
5
5
5
-
-

-
-

100
100
-
-
300
15
-
300
2
100
-
-
-
5000


-
-
100
-
300
50
-
300
2
100
-
-
5000

MW-18
8/11/88

<5
<50
<5
<5
<5
<5
U
U

<100
<5000

<10
30 J
<50
<25
286
8.0
<5000
39
<0.2
<40
<5000
24920
<50
112 J


<100
<5000
<10
<25
<100
5.0
<5000
28
<0.2
<40
<5000
23830
47 J

PW-1
8/11/88

<5
7.0 B
<5
<5
<5
<5
7
U

2890
16310

11
10
<50
<25
2570 J
<5.0
<5000
783
<0.2
<40
<5000
<5000
<50
215 B


153
16100
<10
<25
345 J
<5.0
<5000
76
0.2
<40
<5000
<5000
76 B

EG-1
7/28/98

<5
<50
<5
<5
<5
<5
U
U

<100
<5000

<10
<10
<50
169
2305 J
<5.0
<5000
77
<0.2
<40
<5000
<5000
<50
80 B


132
<5000
<10
<25
1214 J
<5.0
<5000
74
<0.2
<40
<5000
<5000
113 B

CS-1
7/27/98

3.3 B
<50
<5
<5
<5
<5
3.3
U

456
26810

<10
21
<50
<25
17,500 J
<5.0
<5000
123
<0.2
<40
11200
32930
<50
196


196
28930
<10
<25
24,800 J
<5.0
<5000
402
<0.2
<40
10080
34420
82 B

CS-2
7/27/88

4.4 B
<50
<5
<5
<5
<5
4.4
U

113
8650

<10
<10
<50
101
<100
<5.0
<5000
47
<0.2
<40
<5000
14520
<30
115 J


<100
6750
<10
146
<100
9.0
<5000
34
<0.2
<40
<5000
13690
41




4.9 B
<50
<5
<5
CS-3
8/5/88

<5
<50
<5
<5
2.3 J <5
<5
7.2
U

<100
8760

<10
<10
<50
<25
<100
<5.0
<5000
68
0.3
67
<5000
15220
<50
38


<100
8880
<10
<25
<100
<5.0
<5000
56
<0.2
<40
<5000
15700
49

<5
U
U

<100


<10
<10
<50
<25
164
<5.0
<5000
<15
<0.2
<40
<5000
<5000
<50
J 24


<100
<500
<10
<25
168
<5.0
<5000
<15
<0.2
<40
<5000
<5000
J 76

NOTES:     Units are micrograms per liter. Only detected VOCs are reported.
           TICs: Tentatively Identified Compounds.                         U: Undetected.
           B: Compound also detected in blank.                             J: Estimated  concentration.
           PW-1 was also analyzed for base/neutral/acid extractables, pesticides,  and  PCBs. All
                    concentrations were below detection limits.

-------
                                                TABIiE  2
                          PHASE II ANALYTICAL RESULTS FOR 1993  GROUND WATER SAMPLES-METALS
                                          FORMER GOLDISC  SITE
                                          HOLBROOK, NEW YORK
                       STD.
Date Collected
Aluminum
Antimony
Arsenic
Barium
Beryllium
Cadmium
Calcium
Chromium
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Mercury
Nickel
Potassium
Selenium
Silver
Sodium
Thallium
Vanadium
Zinc

-
6 M
50
2000
1 M
5
-
100
-
300
15M
300
2
100
-
10
50
-
2 M
-
5000
MW-2
4/22/93
NA
NA
NA
NA
NA
NA
NA
<9.7
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
MW-4R
4/21/93
NA
NA
NA
NA
NA
NA
NA
<9.7
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
MW-8R
4/21/93
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
1.5 J
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
MW-9
4/22/93
NA
NA
NA
NA
NA
NA
NA
<9.7
NA
NA
NA
NA
NA
NA
NA
31.0
NA
NA
NA
NA
NA
NA
NA
MW-10R
4/21/93
NA
NA
NA
NA
NA
NA
NA
<9.7
NA
NA
NA
NA
NA
NA
NA
<13.6
NA
NA
NA
NA
NA
NA
NA
MW-17S

4/21/93
166
<2.4
2.2
12.9
<0.8
<3.3
8090
<9.7
<12.6
3.1
186
1.6
2060
6.5
<0.2
<13.6
1460
1.4
<0.2
18,500
<0.4
5.6
33.8


J
J






J
J




J
J
J

J


MW-17I
4/21/93
197
<2.4
2.6
17.8 J
<0.8
<3.3
10,100
<9.7
<12.6
5.0
65.0
3.0 J
3980
55.6
<0.2
<13.6
2150 J
<1.2 J
<2.0 J
15,900
<0.4 J
7.7
32.4
MW-17D
4/21/93
18.7
<2.4
2.9 J
10.6 J
<0.8
<3.3
9990
<9.7
<12.6
5.1
101 J
2.9 J
2230
54.1
<0.2
<13.6
872 J
<1.2 J
<2.0 J
9840
<0.79 J
8.6
30.9
NOTES:     Units are micrograms per liter.                    U:  Undetected
           NA: Not Analyzed.                                  J.  Estimated concentration.
           STD: New York State drinking water  standard,  except  those followed by M,  which are USEPA MCLs.

-------
                                              TABIiE 3
                      PHASE II ANALYTICAL RESULTS FOR 1993 GROUND WATER SAMPLES- VOLATILE ORGANIC COMPOUNDS
                                         FORMER GOLDISC SITE
                                         HOLBROOK, NEW YORK
Date Collected
Chioromethane
Bromomethane
Vinyl Chloride
Chloroethane
Methylene Chloride
Acetone
Carbon Bisulfide
1,1-Dichloroethene
1,1-Dichloroethane
Total 1,2-Dichloroethene
Chloroform
1,2-Dichloroethane
2-Butanone
1,1,1-Trichloroethane
Carbon Tetrachloride
Bromodichloromethane
1,2-Dichloropropane
cis-1,3-Dichloropropene
Trichloroethene
Bromochloromethane
1,1,2-Trichloroethane
Benzene
trans-1,3-Dichloropropene
Bromoform
4-Methyl-2-Pentanone
2-Hexanone
Tetrachloroethene
1,1,2,2-Tetrachloroethane
Toluene
Chlorobenzene
Ethylbenzene
Styrene
Total Xylenes
TOTAL VOCs
Total VOC TICs
STD. MW-2
4/22/93
5 10
5 10
2 <10
5 <10
5 <10
50 U R
50 <10
5 <10
5 <10
5 + <10
100 * <10
5 <10
50 UJ
5 1 J
5 <10
100 * <10
5 <10
5 <10
5 <10
100 * <10
5 <10
5 <10
5 <10
100 * <10
50 <10
50 <10
5 <10
5 <10
5 <10
5 <10
5 <10
5 <10
5+ <10
100 * 1
U
MW-4R MW-8R
4/21/93 4/21/93
<10 NA
<10 NA
<10 NA
<10 NA
<10 NA
U R NA
<10 NA
<10 NA
1 J NA
<10 NA
<10 NA
<10 NA
<10 NA
<10 NA
<10 NA
<10 NA
<10 NA
<10 NA
<10 NA
<10 NA
<10 NA
<10 NA
<10 NA
<10 NA
<10 NA
<10 NA
<10 NA
<10 NA
<10 NA
<10 NA
<10 NA
<10 NA
<10 NA
1 NA
U NA
MW-9 MW-10R MW-17S MW-17I
4/22/93 4/21/93 4/21/93 4/21/93
NA <10 <10 <10
NA <10 <10 <10
NA <10 <10 <10
NA <10 <10 <10
NA <10 <10 <10
NA U R U R U R
NA <10 2 J <10
NA <10 <10 <10
NA <10 <10 21
NA <10 <10 <10
NA <10 <10 <10
NA <10 <10 <10
NA <10 <10 <10
NA <10 <10 5 J
NA <10 <10 <10
NA <10 <10 <10
NA <10 <10 <10
NA <10 <10 <10
NA <10 <10 <10
NA <10 <10 <10
NA <10 <10 <10
NA <10 <10 <10
NA <10 <10 <10
NA <10 <10 <10
NA <10 <10 <10
NA <10 <10 <10
NA 1 J <10 <10
NA <10 <10 <10
NA <10 <10 <10
NA <10 <10 <10
NA <10 <10 <10
NA <10 <10 <10
NA <10 <10 <10
NA 1 2 7
NA U U U
MW-17D
4/21/93
<10
<10
<10
<10
<10
U R
140
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
140
U

-------
                                    NOTES:

                           Units are micrograms per liter.
                     STD:  New York State drinking water standard.
                    *Total of these compounds not to exceed 100 ug/1.
                            +: Standard is  for each isomer.
                     R:  Value rejected by data validation review.
                       TICs: Tentatively Identified Compounds.
                                 U: Undetected.
                           J: Estimated concentration.
                                 NA: Not Analyzed.

-------
                                     TABIiE #5

                           GOLDISC RECORDINGS, INC. SITE

                    MONITORING WELL SUMMARY FOR NICKEL IN GROUNDWATER

MONITORING          SCREENEDINTERVAL     MONITORING WELL SAMPLING DATES
WELL NO.             (IN FEET)                 (CONCENTRATIONS  IN  Ig/1)

                                            8/94     9/94     5/97      12/97
MW-7A               22.7 to 32.7            ND       ND       ND        ND
MW-7B               69.3 to 79.3            ND       ND       ND        ND
MW-7C               102 to 122              ND       ND       ND        ND
MW-8                20 to 30                40.8J    42       42.8      ND
MW-9                18.6 to 28.6            ND       ND       ND        ND
MW-10               22.5 to 32.5            ND       ND       ND        ND
MW-11               23 to 33                140J     127      ND        ND
MW-12               24.5 to 34.5            959      980      394       300
MW-14               23 to 33                NS       NS       24.3      ND
MW-16               30.7 to 40.7            278      277      94.6      81.1
MW-17S              18 to 38                13.3BJ   ND       ND        23.5
MW-17I              69 to 89                16.2BJ   ND       ND        ND
MW-17D              137 to 157              ND       ND       ND        ND

* Monitoring wells have been screened in the Upper Glacial Aquifer.

Ig/1- Micrograms per liter
NS  - Not sampled
ND  - Non-detect
J   - Estimated
B   - Detected in blank

-------
                                 APPENDIX III

                          ADMINISTRATIVE RECORD INDEX

                            GOLDISC RECORDINGS SITE
                               OPERABIiE UNIT TWO
                           ADMINISTRATIVE RECORD FIIiE
                               INDEX OF DOCUMENTS
1.0
      SITE IDENTIFICATION
1.5    Previous Operable Unit Information

P.    100001-   Record of Decision, Operable Unit 1, Goldisc
      100087    Recordings, Holbrook, Suffolk County, New York,
                prepared by the U.S. EPA, Region II, September 29, 1995.

P.    100088-   Letter to addressees, from Ms. Kathleen C.
      100093    Callahan, Director, Emergency and Remedial
                Response Division, U.S. EPA, Region II, re:
                Special Notice Pursuant to Section 122 (e) of
                CERCLA 42 U.S.C. 9622 (e), First Operable Unit,
                Goldisc Recordings Superfund Site, Town of Islip,
                Suffolk County, N.Y., March 22, 1996.

P.    100094-   Report:     Final  Remedial Activity Work Plan,
      100369    Former Goldisc Recordings Facility,  Village of
                Holbrook, Town of Islip, Suffolk County, New York,
                prepared by ERM-Northeast, prepared for The
                ElectroSound Group, Inc., September 26, 1996.

P.    100370-   Report:     Remedial Action  Report for  the  Soil
      100556    Remedy at the Former Goldisc Recordings Facility,
                Village of Holbrook, Town of Islip,  Suffolk
                County, New York,  prepared by ERM-Northeast,
                prepared for The ElectroSound Group, Inc., January 19, 1998.

3.0   REMEDIAL INVESTIGATION

-------
3.3   Sampling and Analysis Data/Chain of Custody Forms

P.     300001-   Letter to Mr. Damian J. Duda, Remedial Project
      300010    Manager,  Eastern New York Remedial Section
                (ENYRS),  U. S. EPA, Region II, from Mr. Michael B.
                Teetsel,  C.P.G., Senior Associate, ERM-Northeast,
                and Mr. John lannone, P.E., Project Director, ERM-
                Northeast, re: Ground Water Sampling Results,
                Former Goldisc Recordings Site, Holbrook, NY, July
                30, 1997.  (Attachment: (1) Table 1 - Water
                Chemistry Parameters Monitored in the Field,
                Former Goldisc Recordings Site - Holbrook, N.Y.,
                August 25, 1997; (2) Table 2 - Summary of Nickel
                Analytical Results, Ground Water Samples, Former
                Goldisc Site, Holbrook, N.Y., July 27, 1997;  (3)
                Figure 1 - Nickel Distribution in Ground Water
                Sampling date: May 1997,  prepared by ERM-
                Northeast, prepared for ElectroSound Group, Inc.,
                July 14,  1997; and  (4) Attachment 1 - Data
                Validation Review,  Ground Water Analyses, Former
                Goldisc Recordings Site,  Holbrook, NY, July 28, 1997.

P.     300011-   Letter to Mr. Damian J. Duda, Remedial Project
      300016    Manager,  ENYRS, U.S. EPA, Region II, from Mr.
                Michael B. Teetsel, C.P.G., Senior Associate, ERM-
                Northeast, re: December 1997 Ground Water Sampling
                Results,  Former Goldisc Recordings Site, Holbrook,
                NY, March 16, 1998.  (Attachments: (1) Table 1 -
                Water Chemistry Parameters Monitored in the Field,
                December 1997, Former Goldisc Recordings Site -
                Holbrook, N.Y., February 9, 1998; and  (2) Table 2
                - Summary of Nickel Analytical Results, Ground
                Water Samples, Former Goldisc Recordings Site,
                Holbrook, N.Y., March 16, 1998.)

P.     300017-   Suffolk County Water Authority, Church Street
      300059    Wellfield - Data for wells #1, #2, and #3, January
                1995 to June 1998,  July 15, 1998.

3.5   Correspondence

P.     300060-   Letter to Mr. John J. lannone, P.E., ERM-
      300060    Northeast, from Mr. Doug Garbarini,  Chief, ENYRS,
                U.S. EPA, Region II, re:  Remedial Activity Work
                Plan (RAWP) Approval, Goldisc Recordings Superfund
                Site, September 27, 1996.
      300061-   Letter to Mr. John J. lannone, P.E., ERM-
      300061    Northeast, from Mr. Doug Garbarini, Chief, ENYRS,
                U.S. EPA, Region II, re: Remedial Activity Work
                Plan (RAWP),  Administrative Order on Consent
                (RI/FS),  No.  II-CERCLA-10128, Goldisc Recordings
                Superfund Site, April 7, 1997

-------
P.     300062-   Letter to Mr. Leslie J. Levine, Ackerman, Levine &
      300062    Cullen,  LLP, from Mr. Doug Garbarini, Chief,
                ENYRS, U.S. EPA, Region II, re: Goldisc Recordings
                Superfund Site, Administrative Order on Consent -
                No. II-CERCLA-10218, Village of Holbrook, Suffolk
                County,  N.Y., October 9, 1997.

P.     300063-   Letter to Mr. Doug Garbarini, Chief, ENYRS, U.S.
      300063    EPA, Region II, from Mr. Marsden Chen, Federal
                Projects Section,  Bureau of Eastern Remedial
                Action,  Division of Environmental Remediation, New
                York State Department of Environmental
                Conservation (NYSDEC),  re: Goldisc Recordings Site
                #152022, Proposed Remedial Action Plan, July 27, 1998.

P.     300064-   Memorandum to File, from Mr. Damian Duda, Remedial
      300065    Project Manager, ENYRS, U.S. EPA, Region II, re:
                Goldisc Recordings Site Meeting with State and
                County Agencies Regarding the Groundwater
                Contamination at the Goldisc Site, August 14, 1998.

4.0   FEASIBILITY STUDY

4.3   Feasibility Study Reports

P.     400001-   Appendix D to August 1995 Feasibility Study -
      400016    Ground Water Modeling,  prepared by ERM-Northeast.

7.0   ENFORCEMENT

7.4   Consent Decrees

P.     700001    Consent Decree, United States of America,
      700086    Plaintiff, v. ElectroSound Group, Inc., First
                Holbrook Company,  Genco Auto Electric, Inc., Red
                Ground Company, Red Ground Corporation,
                Defendants, September 26, 1996.

7.8   Correspondence

P.     700087-   Letter to Mr. John J. lannone, P.E., ERM-
      700087    Northeast, from Mr. Doug Garbarini, Chief, ENYRS,
                U.S. EPA, Region II, re: Consent Decree - Civil
                Action #CV-97/728, Section XIV.  (c) - Remedial
                Action Report Approval, Goldisc Recordings
                Superfund Site, June 23, 1998.

8.0   HEALTH ASSESSMENTS

-------
8.1   ATSDR Health Assessments

P.     800001-   Final Combined Regulatory Impact and Environmental
      800011    Impact Statement,  Title 6, Chapter X, Parts 700-
                 706,  1998,  prepared by the Division of Water,
                NYSDEC,  February 10, 1998. (Attachments: (1)
                Combined Regulatory Impact and Draft Environmental
                Impact Statement,  Title 6, Chapter X, Parts 700-
                706,  Volume 2 of 3, Appendix II, In Part: Health
                (Water Source) Fact Sheets, 1997, prepared by the
                Division of Water,  NYSDEC, undated, and  (2)
                Exhibit 1: Oral Reference Dose Summary for Nickel
                Taken from the On-Line Integrated Risk Information
                System (IRIS) of the U.S. Environmental Protection
                Agency (as of June 1, 1995),  undated.)

10.0  PUBLIC PARTICIPATION

10.3  Public Notices

P.     10.00001- Notice:  "Notice of Lodging of Consent Decree
      10.00001  Pursuant to the Comprehensive Environmental
                Response,  Compensation, and Liability Act of 1980,
                as Amended", Federal Register, Vol. 62, No. 39,
                February 27, 1997.

10.6  Fact Sheets and Press Releases

P.     10.00002- For Release: "ElectroSound Agrees to Clean Up
      10.00003  Federal Superfund Site in Islip, New York;  Joins
                Others in Paying EPA for Past Costs", prepared by
                the U.S.  EPA, Region II, September 26, 1996.

P.     10.00004- Press Release: "Lazio Applauds Clean Up of
      10.00004  Superfund Site in Islip - Federal Oversight Role
                Praised",  February 19, 1997.

P.     10.00005- Press Release: "Zachary W. Carter, United States
      10.00006  Attorney for the Eastern District of New York,
                announced the filing of a Complaint and lodging of
                a Consent Decree in the civil environmental case
                against ElectroSound Group, Inc., First Holbrook
                Company,  Genco Auto Electric, Red Ground
                Corporation and Red Ground Company", prepared by
                the U.S.  Department of Justice, February 20, 1997.

P.     10.00007- Press Release: "ElectroSound Begins Remedial
      10.00008  Action at Federal Superfund Site in Islip,  N.Y.",
                prepared by the U.S. EPA, Region II, May 5, 1997.

-------
APPENDIX IV

STATE IiETTER OF CONCURRENCE

Damian J. Duda
September 2, 1998
Page 2

designated as Section 217, Block 2, Lots 8.001 and 8.002. The southern border
of the Site lies 160 linear feet to the south of dry well DW-2, except that where
Lot 8.002 abuts Lot 8.003, the southern border of the Site is coterminous with
the northern border of Lot 8.003.

Consent Decree in United States v. ElectroSound Group, Inc., et al., Civ. No. 97-728, p.10.
(Enclosed herein is a copy of the map depicting the above-described Site, provided to the
USEPA at the time the Consent Decree negotiations were completed.) If the description of the
Site in the Proposed Plan were accurate, the Site would include Lot 8.003, which in fact is
specifically excluded in its entirety, along with the southern edge of Lots 8.001 and 8.002, by
the Consent Decree definition.

2. Red Ground Has Appropriately Cooperated with the USEPA in the RI/FS Process

Also in the Site Background section of the Proposed Plan, the USEPA states
that in 1990, when First Holbrook, ESG and Red Ground were noticed of their potential
liability at the Site: "Red Ground refused to enter into negotiations with EPA to conduct
additional RI/FS activities. Subseguently, in 1991, EPA entered into an AOC with First
Holbrook and ElectroSound." Proposed Plan, p. 3. This characterization of the events that
transpired in 1991 is totally incorrect.

In fact, in early May 1991, the USEPA transmitted to Red Ground a draft
AOC, with an attached draft Statement of Work in connection with the Goldisc Site. Shortly
thereafter, counsel for ESG advocated to the USEPA that Red Ground Corporation be included
as a party to the AOC. In response, by letter dated May 28, 1991, Red Ground explained to
the USEPA that pursuant to the Contract of Sale between Red Ground and First Holbrook for
the Goldisc property, First Holbrook and ESG were legally obligated to undertake all
necessary measures to remediate the Goldisc property, and Red Ground would rely on that
Contract. The May 28, 1991 letter further noted that ESG and First Holbrook had already
submitted to the Agency a good faith offer to conduct the supplemental RI/FS activities.
Finally, while not stated in the letter, Red Ground would have been in breach of its Contract
of Sale with First Holbrook if it signed the AOC, and thus would have risked losing the
benefits of the Contract.

In response to this letter, the USEPA continued negotiations with ESG and First
Holbrook, eventually reaching final agreement in an AOC that became effective on July 3,
1991. Red Ground, as appropriate, was not a party to that AOC. However, as owner of the
property and pursuant to the contract of sale with First Holbrook, Red Ground fully
cooperated with the USEPA and participated through its counsel in the remedial investigation
process. As the USEPA is aware, Red Ground made great efforts to persuade ESG and First
Holbrook to fulfill their commitments to Red Ground, including by commencing a civil action

-------
D. Garbarini
Aug. 21, 1998
page 2

If you wish to discuss this matter further, please contact me at  (516) 853-3092.

Very truly yours,

-------
09/28/1998  15:55     516-589-5277                 SCWA ENGINEERING                  PAGE 03

         EPA/Goldisc Recording Plan

          (Site No. 1502022)                          September 25,1998              Page 2


                Additionally, the SCWA reguests the reimbursement of past water guality
         monitoring expenses, engineering, and plant operation costs associated with the
         loss of production from the Church Street well site.

                We trust these comments will be taken into account in the final document.
         However, if you wish to discuss these comments further,  please contact me at
          (516) 563-0202.

                                                    Very truly yours,

-------
                                APPENDIX V

                          RESPONSIVENESS SUMMARY

                         Goldisc Recordings Site
                     Operable Unit Two - Groundwater
                 Town of Islip, Suffolk County, New York
INTRODUCTION
A responsiveness summary is required by Superfund regulation. It provides a summary of citizens' comments and
concerns received during the public comment period, and the United States Environmental Protection Agency's
(EPA's) responses to those comments and concerns. All comments summarized in this document have been
considered in EPA's final decision for selection of a remedial alternative for the Goldisc Recordings site
(Site).

SUMMARY OF COMMUNITY RELATIONS ACTIVITIES

Community involvement at the Site has been low. In 1991, EPA took over as the lead agency for community
relations and remedial activities at the Site. On March 10, 1991, EPA initiated its community relations
activities with in-person interviews with local officials and residents of the Village of Holbrook and the
Town of Islip. Based on these interviews, the key issue of concern centered around the impacts which
Site-related contamination could have on the Suffolk County Water Authority (SCWA) Church Street Wellfield
(CSW) , particularly Church Street Well No. 2  (CS-2), which is located approximately 1200 feet downgradient of
the Site.

The Proposed Plan for the Second Operable Unit (OU-2), which addressed the remediation of contaminated
groundwater at the Site, was released to the public for comment on August 29,  1998. The Proposed Plan, the
Remedial Investigation  (RI) report and the Feasibility Study (FS) and all other documents are available to
the public in the Administrative Record file at the EPA Docket Room in Region II, New York and the
information repositories at the Islip Town Hall and the Sachem Public Library. A press release announcing the
preferred alternative was issued on August 29, 1998 to local media outlets. The notice of availability for
the above-referenced documents was published in Newsday [Suffolk County edition) on August 29, 1998. The
public comment period on these documents was held from August 29, 1998 to September 27, 1998.

On September 17, 1998, EPA conducted a public meeting at the Hamlet of Bohemia Recreation Center to inform
local officials and interested citizens about the Superfund process, the remedial alternatives for the Site
and EPA's preferred alternative, and to provide an opportunity for the interested parties to present oral
comments and guestions on the preferred alternative to EPA.

Attached to the Responsiveness Summary are the following Appendices:

  Appendix A -  Proposed Plan
  Appendix B -  Public Notice
  Appendix C -  September 17, 1998 Public Meeting Attendance Sheet
  Appendix D -  Letters Submitted During the Public Comment Period

SUMMARY OF COMMENTS AND RESPONSES

Comments were expressed at the public meeting and written comments were received during the public comment
period from Counsel, representing Red Ground Corporation and Red Ground Company  (RG Companies) and the
Holbrook Triangle Civic Association, Inc.

The comments have been categorized as follows:

  A.  General Site Issues

-------
  B.  Selected Remedy Issues
  C.  General Enforcement Issues

A summary of the comments and EPA's responses to the comments is provided below:

A. General Site Issues

Comment #1: One commenter asked how the Site came to be listed on the National Priorities List (NPL).

Response #1: During the preliminary investigation/site inspection, the Site was ranked using EPA's Hazard
Ranking System (HRS).  The Site scored 33.39 which is above the pre-determined benchmark score of 28.5  for
ranking Superfund sites. The potential impact of Site contamination on the sole source aguifers underlying
the Site and the downgradient public water supply CSW figured strongly in the HRS score for the Site.

Comment #2: The RG Companies' Counsel indicated that the size of the Site should be reduced as per the August
1996 Consent Decree (CD).

Response #2: As part of the CD, the "Site" was defined as 17.34 acres, relating directly to the remedial
action. However,  the Site includes the full 34-acre property that was the subject of the RI/FS, as well as
the contaminated groundwater. There has been no partial deletion of the Site from the NPL.

Comment #3: One commenter wanted to know when the Site will be deleted from the NPL.

Response #3: The time frame for deletion of the Site from the NPL is dependent upon the results of the
groundwater monitoring program. As noted in the OU-2 Proposed Plan, EPA expects that the nickel levels at the
Site will decrease to levels below the New York State Class GA standard of 100 Ig/1 within 3 years and, that
the concentrations of nickel at the CSW, which are currently below this standard, will continue to decrease.
[As noted at the September public meeting, unvalidated data for samples collected from on-site wells in
August 1998 indicate that nickel concentrations have already declined to levels below the
standard.)  EPA would continue to monitor the nickel contamination for one to two years after the nickel
concentrations at the Site decline to levels below the standard to ensure that levels will remain below the
standard. If EPA's expectations are correct, then the Site would likely be deleted from the NPL within three
to five years. If the time frame for reach the standards is longer or shorter, the time frame for
deletion would be adjusted accordingly.

Comment #4: One commenter asked if Federal funds were expended to pay for the cleanup at the Site.



drinking water. SCDHS indicated at the September public meeting, and in previous meetings with EPA, that it
and SCWA will follow up on the private well usage in the area of the Site.

Comment #6: A representative of SCDHS asked what actions EPA could take if a private residential well  reveals
high levels of nickel contamination after EPA signs a ROD selecting the preferred alternative.

Response #6: EPA has a process whereby it can amend a ROD if the remedy is no longer deemed to be protective
of human health and the environment. If nickel contamination attributable to the Site were detected in a
private well that is used for drinking water, EPA could amend the ROD to ensure that the residence has a safe
supply of water,  e.g., if the residence was not already connected to the public water supply, EPA could
either maKe this connection or a treatment unit could be provided to remove the
nickel prior to consumption. If the nickel concentration were above 500 Ig/1, EPA could utilize its removal
action authority to implement similar actions.

Comment #7: SCWA submitted written comments supporting concerns raised in SCDHS's August 21, 1998 letter to
EPA, which was submitted prior to the release of the OU-2 Proposed Plan. SCWA also reguested that it be
reimbursed for costs which it would not have incurred if nickel contamination from, the Site had not
impacted the CSW.

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Response #7: EPA responded to concerns raised in SCDHS's August 21, 1998 letter prior to the release of the
Proposed Plan and the start of the public comment period. EPA coordinated with SCDHS on the subject of the
sentinel well cluster location, residential well surveys and contingency measures for the preferred
alternative, as well as on other matters prior to the release of the OU-2 Proposed Plan to ensure that
SCDHS's concerns were adeguately addressed.

With regard to costs that would be incurred by SCWA for future monitoring, the selected remedy calls for
additional monitoring of the CSW. Therefore, expenditures associated with the monitoring of the CSW, as
provided for in EPA's Site monitoring plan pursuant to this ROD, would be reimbursable. In order for EPA to
reimburse SCWA, EPA and the New York State Department of Environmental Conservation (NYSDEC) would have to
modify their existing cooperative agreement for the Site to include such expenditures. NYSDEC would then have
to transfer the funds via a separate cooperative agreement with SCWA or other appropriate Suffolk County
authority. Since the costs to SCWA to perform this sampling and analysis are relatively small ($5 per sample
analysis plus staff time to collect the sample), it is possible that the PRPs may be willing to reimburse
SCWA for such costs. EPA will explore this alternative with the PRPs when discussing
the implementation of the future groundwater monitoring program for the Site.

Unfortunately, EPA cannot reimburse SCWA for past costs associated with sampling, engineering and production,
because past costs are not reimbursable under the Superfund Statute. However, SCWA may want to contact the
PRPs directly about such reimbursement.

B. Selected Remedy Issues

Comment #8: One commenter from SCWA asked how EPA decided upon the action level of 300 Ig/1 of nickel for the
sentinel well cluster.

Response #8: SCWA, SCDHS, EPA and NYSDEC agreed that it would be appropriate to install an additional cluster
of wells that could serve as an early warning or sentinel for nickel contamination which could disrupt the
distribution of drinking water from the CSW. SCWA, SCDHS, EPA and NYSDEC conferred on what an
appropriate action level would be for the sentinel well cluster, taking into consideration: 1) the levels of
nickel that had been detected in the Site groundwater; 2) the distance of the sentinel wells from the CSW; 3)
the fact that the sentinel wells would be designed to monitor selectively small intervals in the
groundwater table anticipated to have the highest concentrations of nickel; and, 4) the fact that the CSW,
with its significant pumping rate, would draw water from a much larger screened interval and would, thus,
draw in "clean" groundwater along with the contaminated groundwater, migrating from the Site. As a
result, it was determined that nickel levels below 300 Ig/1 at the sentinel wells would not likely cause the
100 Ig/1 GA standard to be contravened in water pumped from the CSW. All parties agreed that levels above 300
Ig/1 of nickel would warrant the governmental authorities to convene and to discuss whether it
would be necessary to take any additional actions to ensure that SCWA is able to continue to provide a safe
drinking water supply to its customers.

Conment #9: One commenter asked about the costs of the preferred alternative.

Response #9: The present worth costs for monitored natural attenuation over a five-year period is $9,430.

Comment #10: The RG Companies' Counsel expressed concern about the inconsistencies in the long-term
monitoring program's time frame versus costs.

Response #10: EPA has revised the costs for the preferred alternative which were presented in the OU-2
Proposed Plan. Since EPA currently anticipates that the nickel standard in the groundwater at the Site will
be achieved through monitored natural attenuation within a three-year time frame, the anticipated duration of
the monitoring program has been changed to five years, which results in a present-worth cost of $9,430.
Accordingly, EPA also modified the present-worth costs of Alternatives GWR-II and GWR-III to reflect the
anticipated time frame for achieving the nickel standard in the Site groundwater.

Comment #11: One commenter wanted to know when the source removal occurred.

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Response #11: The source removal, which included the removal of surface soils, soils and sediments from seven
dry wells and the removal of soils and sediments from a production well vault with subsequent off-site
disposal of these materials, was implemented by the PRPs between May 1997 and July 1997.

Comment #12: One commenter from a local organization expressed concern that the adjoining property north and
upgradient of the Site was exposed to Site contamination and that it should not be developed for residential
use.

Response #12: During the Site investigation in the Phase I and Phase II RIs, soils north of the Site property
boundary were investigated. As per the August 1995 ROD, the 1996 Remedial Activity Work Plan and 1996 CD, a
source control remedial action was performed in this area, identified as Area #8, where
approximately 215 cubic yards of contaminated soil were excavated and disposed of off-site. Therefore, EPA
believes that the adjoining property north of the Site can be developed without any restrictions.

Comment #13: RG Companies' Counsel asked that the ROD include a discussion on the criteria used to determine
when the groundwater monitoring program would cease.

Response #13: EPA has previously indicated that it anticipates that the downward trend in the nickel
concentrations both in monitoring wells and the CSW will continue. This expectation is based upon the
conservative predictions of the solute transport modeling performed for the August 1995 FS, the existing data
trends (downward) for both the Site monitoring wells and the CSW and the fact that a remedial action,
implemented at the Site, has removed the remaining source of nickel contamination to the groundwater.

It is anticipated that the nickel standard of 100 Ig/1 will be achieved within a three-year time frame (as
mentioned previously, unvalidated data for samples collected from on-site wells in August 1998 indicate that
nickel concentrations have already declined to levels below the standard). It is anticipated that
one to two years of monitoring will be required, subsequent to the nickel concentrations decreasing below the
standard, in order to deem that the concentrations will remain below the standard.

Comment #14: One commenter asked about the time frame for the contamination to travel to the CSW.

Response #14: The modeling performed for the August 1995 FS utilized a conservative flow rate of 1.5 feet day
for the groundwater at the Site. Given the fact that the CSW is 1200 feet south of the Site, groundwater at
the Site would take approximately 800 days to reach the CSW.

Comment #15: One commenter asked if EPA expects a downward trend of nickel levels in the study area during
two years of monitoring.

Response #15: A decreasing trend of nickel concentrations to levels well below 100 Ig/1 is consistent with
the solute transport modeling results performed for the August 1995 FS. The model incorporated very
conservative assumptions intended to overestimate the concentrations of nickel which might reach CS-2.
The model, which utilized the maximum concentration that had been found at the Site (959 Ig/1 rounded up to
1000 Ig/1), predicted that nickel concentrations reaching CS-2 would peak at 325 Ig/1 in 1996, prior to
decreasing to levels below 100 Ig/1 in 1997.

In fact, CS-2 sampling data available to EPA confirm that the model assumptions were very conservative, since
the nickel concentrations entering CS-2 reached a peak of 112 Ig/1 in January 1996 and have not been above
100 Ig/1 since then. It should be noted that, while the sample results since January 1996 have generally
indicated concentrations in the 50 to 70 Ig/1 range, concentrations did approach 100 Ig/1 in late June 1997,
only to decline shortly thereafter.

Given these results, it is anticipated that nickel concentrations will continue to decrease on-site and that
levels of nickel at CS-2 will continue to decrease and remain below 100 Ig/1. As noted at the public meeting,
unvalidated data for samples collected from on-site wells in August/September 1998 indicate
that nickel concentrations have already declined to levels below the standard.

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C. General Enforcement Issues

Comment #16: One commenter wanted to know which PRPs have performed response actions at the Site.

Response #16: The PRPs performed the RI/FS and remedial action as a group. The PRPs performed the RI/FS under
a 1991 Administrative Order on Consent (AOC)  and performed the remedial action for OU-1 under the CD. EPA
does not have any specific knowledge of exactly how the PRPs apportioned their responsibilities among
themselves.

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                                APPENDIX A

                              PROPOSED PLAN

Superfund Proposed Plan
                                          GOLDISC RECORDINGS SITE

               Town of Islip, Village of Holbrook
                                         Suffolk County, New York
          EPA
        Region 2                                      August 1998

PURPOSE OF PROPOSED PLAN

This Proposed Plan identifies a Monitored Natural Attenuation remedy for the second Operable Unit  (OU-2)
considered for the Goldisc Recordings Superfund site  (Site), located in the Town of Islip, Suffolk County,
New York. The Proposed Plan was developed by the U.S. Environmental Protection Agency  (EPA), as lead agency,
with support from the New York State Department of Environmental Conservation  (NYSDEC). EPA is issuing this
Proposed Plan as part of its public participation responsibilities under Section 117 (a) of the Comprehensive
Environmental Response, Compensation, and Liability Act  (CERCLA) of 1980, 42 U.S.C. °° 9601-9675 and the
National Contingency Plan, 40 C.F.R. ° 300.430(f).

This Proposed Plan for OU-2 is being provided to supplement the first Operable Unit (OU-1) August 1995
remedial investigation and feasibility study (RI/FS) reports, to inform the public of EPA's and NYSDEC's
preferred remedy for the groundwater and to solicit public comments pertaining to all the remedial
alternatives, as well as the preferred alternative on this action.

The remedy, as described in this Proposed Plan, is the preferred remedy for OU-2. Changes to the preferred
remedy or a change from the preferred remedy to another remedy may be made, if public comments or additional
data indicate that such a change will result in a more appropriate remedial action. The final decision
regarding the selected remedy will be made after EPA has taken into consideration all public comments.
Therefore, EPA is encouraging public comment on this Proposed Plan.

COMMUNITY ROLE IN SELECTION PROCESS

EPA and NYSDEC rely on public input to ensure that the concerns of the community are considered in

selecting an effective remedy for each Superfund site. To this end, the RI/FS reports. Proposed Plan and all
supporting documentation have been made available to the public for a public comment period which begins on
August 29, 1998 and concludes on September 27,  1998.

Copies of the RI/FS reports, the Proposed Plan, the supplemental groundwater monitoring well data, the
public water supply well data and other supporting documentation are available for review at the following
locations:

Islip Town Hall
655 Main Street
Islip, New York 11751
Tel.  (516) 224-5490
Hours: Mon-Fri: 8:30 AM to 5:00 PM

Sachem Public Library
150 Holbrook Road
Holbrook, New York 11741
Tel.  (516) 588-5024
Hours: Mon-Thurs: 9:30 AM to 9:00 PM
       Fri: 9:30 AM to 6:00 PM

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       Sat: 9.30 AM to 5:00 PM
       Sun: 12:00 PM to 4:00 PM  (9/13 and after)

Environmental Protection Agency
Superfund File Room - 18 th Floor
290 Broadway
New York, New York 10007-1866
Tel.  (212) 637-4308
Hours: Mon-Fri:  (9:00 AM to 4:30 PM)

A public meeting will be held during the public comment period at the Bohemia Recreation Center Hall on
Thursday, September 17, 1998 at 7:00 PM to discuss the OU-1 remedial action and the supplemental groundwater
sampling data to elaborate further on the reasons for recommending the preferred remedial alternative and to
receive public comments.

DATES TO REMEMBER

August 29, 1998 to September 27, 1998
Public comment period on Proposed Plan

Thursday, September 17, 1998 - 7:00 PM
Public meeting at the
Bohemia Recreation Center
One Ruzicka Way - off Smithtown Avenue
Bohemia, New York 11716
(516) 472-7037

Comments received at the public meeting, as well as written comments, will be documented in the
Responsiveness Summary section of the OU-2 Record of Decision  (ROD), the document which formalizes the
selection of the remedy.

All written comments should be addressed to:
             Damian J. Duda
        Remedial Project Manager
    U.S. Environmental Protection Agency
         290 Broadway, 20th Floor
       New York, New York 10007-1866
             (212)  637-4269

SITE BACKGROUND

The 34-acre Site is located at the intersection of Veterans Memorial Highway and Broadway Avenue in the Town
of Islip, New York (see Figure #1)  and consists of two one-story buildings that occupy six acres, three acres
of pavement surrounding the buildings and twenty-five acres of undeveloped land. Current zoning at the Site
is retail/commercial. The area surrounding the Site is primarily residential and
mixed forest, with some commercial and light industrial development. The Site is bordered to the north and
east by mixed forest, to the south by Veterans Memorial Highway and to the west by Broadway Avenue (see
Figure #1).

A municipal water supply wellfield, the Church Street wellfield, which provides drinking water for the
Suffolk County Water Authority  (SCWA) ,  is located approximately 1200 feet south and downgradient of the Site.
The closest dwellings are located about 700 feet north of the Site.  A New York State  (NYS)  regulated wetland
is located approximately one-half mile south of the Site. A Sunoco gasoline station is located on the
southeast corner of Veterans Memorial Highway and Broadway Avenue, just south of the Site.  Currently, a spill
from the Sunoco station

is being remediated in order to alleviate any impact on the Church Street wellfield.

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From 1968 to 1990, the two buildings were occupied by several different companies that generated and
stored hazardous substances on the Site. These companies included Goldisc Recordings, Inc. (Goldisc), which
produced phonographic records; ElectroSound Group, Inc. (ElectroSound), a company that manufactured audio
visual and optical devices; and Genco Auto Electric, Inc. (Genco), which rebuilt automotive engine parts. The
First Holbrook Company (First Holbrook) owned the property from 1973 to 1985. In 1985, the Red Ground
Corporation (Red Ground) became the owner of the property. The tenants occupying the buildings since 1990 are
dry goods merchants that do not perform any on-site manufacturing.

Between 1968 and 1990, various discharges were known to have occurred at the Site; these included wastewater
from the various production processes, waste oils, metals, solutions containing high concentrations of xylene
and trichloroethylene and other degreasing agents. These substances were
reportedly discharged to the environment through dry wells, leaching pools, storm drains and leaking
storage containers located around the buildings.

Since the late 1970's, the Suffolk County Department of Health Services (SCDHS), NYSDEC and EPA
conducted various inspections and environmental protection enforcement activities at the Site. In 1978,
a representative from the SCDHS inspected the Site and noted stains, puddles and leaking drums suspected to
be related to industrial wastes. In the early 1980's, the SCDHS collected samples from leaching pools, storm
drains and cesspools located on the Site. Laboratory analyses of the samples revealed violations of NYS
Groundwater Effluent Guidelines. Between 1981 and 1983, laboratory analyses of groundwater samples collected
from monitoring wells located on-site revealed elevated levels of solvents and metals, including:
trichloroethane, trichloroethylene, tetrachloroethylene, lead, nickel, chromium and silver. Analyses of
samples obtained from the Church Street wellfleid showed concentrations of tetrachloroethylene slightly
exceeding the Maximum Contaminant Level (MCL) of 5 Ig/1 for public drinking water. Based on these findings,
the Site was added to the EPA National Priorities List in June 1986.

In 1988, NYSDEC entered into an Administrative Order on Consent (AOC) with two of the potentially
responsible parties (PRPs), namely, First Holbrook and ElectroSound. The AOC reguired the two PRPs to conduct
an RI at the Site, as reguired under CERCLA. The 1988 Phase I RI investigated 19 areas of potential
contamination. Groundwater and soil samples were collected and analyzed to determine the nature and extent of
contamination in these areas. Elevated levels of lead and tetrachloroethylene were found in groundwater
samples. Soil samples were found to contain elevated levels of several metals, volatile organic compounds
(VOCs) and semi-VOCs (SVOCs).

Based on a review of the results, EPA and NYSDEC determined that additional information was necessary in
order to define fully the extent of contamination at the Site. In late 1990, NYSDEC reguested that EPA take
over as lead agency for the Site. EPA notified First Holbrook, ElectroSound and Red Ground of their potential
liability at the Site, and reguested they finance or undertake the continuing RI/FS. Red Ground refused to
enter into negotiations with EPA to conduct additional RI/FS activities. Subseguently, in
1991, EPA entered into an AOC with First Holbrook and ElectroSound. This AOC specifically reguired
the PRPs to conduct a supplemental or Phase II RI/FS.

In August 1995, EPA issued a Proposed Plan for OU-1 which identified the preferred remedy for the source
areas (contaminated surface soils and sediment in dry wells) at the Site. In September 1995, after
considering public comment on this action, EPA issued a ROD to address the contaminant source area.

In September 1996, EPA entered into a Consent Decree (CD) with First Holbrook, ElectroSound, Genco, and Red
Ground to perform the remedial action, as identified in the 1995 ROD. Also in September 1996, as part of the
CD, EPA negotiated and approved a final Remedial Activity Work Plan (RAWP) that was prepared by
ERM-Northeast, ElectroSound's contractor. This RAWP identified the course of action necessary to complete the
remedial action, according to the reguirements of the 1995 ROD. The remedial action was completed during the
Summer of 1997.

SCOPE AND ROLE OF OPERABLE UNIT ONE AND OPERABLE UNIT TWO

EPA divided the remedial work necessary to mitigate contamination stemming from the Site into two operable
units. OU-1 addressed the source of contamination at the Site and included the removal of surface soils,

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removal of soils and sediments from seven dry wells and removal of soils and sediments from a production well
vault. Approximately 300 cubic yards of contaminated soils were excavated and disposed of off-site during the
Summer of 1997. Nickel was the main contaminant in all areas that were excavated except for one area [Area
#14]. which was contaminated with SVOCs, namely chrysene and benzo(a)anthracene. Confirmatory
sampling indicated that contaminants in soils had been reduced to levels that would be protective of human
health and the environment and would minimize cross-media impacts to groundwater.

OU-2 is the subject of this Proposed Plan and addresses the remediation of nickel contamination in
the groundwater.

REMEDIAL INVESTIGATION SUMMARY

In 1988, groundwater remedial investigation field work began at the Site with the Phase I RI conducted by the
PRPs, pursuant to an AOC with NYSDEC. The results of this investigation, as well as the results of the Phase
II RI, conducted by the PRPs pursuant to an AOC with EPA, are summarized in the August 1995 RI report. In
order to evaluate the groundwater further, ERM-Northeast, under the direction of EPA performed supplemental
groundwater sampling before (May 1997) and after (December 1997) the implementation of the remedial action
which was completed in the Summer of 1997. The intent of this supplemental groundwater investigation was to
obtain additional information regarding the fate of nickel in the groundwater at the Site after the removal
of the contaminated surface soils and dry well sediments.

Groundwater investigation field work at the Site has included the collection of groundwater samples from
17 on-site monitoring wells, four off-site monitoring wells, one on-site production well and the three SCWA
Church Street public water supply wells. Of the 17 on-site monitoring wells, 15 are shallow (less
than 50 feet depth), one is intermediate (75 to 90 feet depth) and one is deep (over 100 foot depth). Of the
five off-site monitoring wells, three are shallow, one is intermediate and one is deep. Two of these off site
monitoring wells are installed upgradient of the Site. All on-site monitoring wells are installed in the
Upper Glacial aguifer. The thickness of the Upper Glacial aguifer underlying the Site is approximately 135
feet. Depth from the surface to the water table ranges across the Site from 18 to 32 feet. Church Street
wells #1 (CS-1) and #2 (CS-2) are both shallow wells, installed, at similar depths of
approximately 160 feet, in the Upper Glacial aguifer. Church Street well #3 (CS-3) is screened at
approximately 500 feet in the lower Magothy aguifer.

The groundwater flow direction in the northern portion of the Site is generally south to southeast. However,
the southeast portion of the Site shows a shift in flow direction to the southwest in response to
the radial drawdown resulting from the pumping operations of the Church Street wellfield. The groundwater
flow velocity ranges from 1.3 to 2.9 feet/day, depending on the pumping operations at the wellfield.

Monitoring Well Data

The Phase I RI included the collection of groundwater samples from 18 monitoring wells, the production well
and the three Church Street public water supply wells. The results indicated inorganic contamination,
including nickel, chromium and lead, and VOC-contamination, including 1,1,1-trichloroethane, tetrachlorethene
and 1,1-dichloroethane.

Two rounds of groundwater samples were taken during Phase II. The groundwater samples were analyzed for
Target Analyte List (TAL) metals and/or Target Compound List (TCL) volatile organic compounds (VOCs).

The April 1993 Phase II (first round) groundwater sampling effort included collection of samples from eight
on-site monitoring wells. The resultant metals analyses did not indicate the presence of metals,
including nickel, above any federal or state drinking water standards. Wells impacted by nickel
contamination were not sampled at that time.

The September 1994 Phase II sampling (second round) was initiated to investigate further the presence of
heavy metals, particularly nickel, in the groundwater at the Site. ERM-Northeast collected samples from 15
on-site monitoring wells and analyzed these samples for nickel, chromium, iron and manganese. All 15 samples
were split and analyzed by EPA for all TAL metals. Based on its freguent detection at elevated concentrations

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at the Site and the potential impact to the Church Street wellfield, nickel had been deemed to be the primary
contaminant of concern at the Site. Table 1 provides results of all nickel analyses performed on samples
collected from the monitoring wells since 1994. This Phase II (second round) of metals analysis detected
nickel at some wells above the federal MCL, which was 100 Ig/1. Subsequently, in 1995, the MCL for nickel was
remanded so a health-based action level for nickel was developed for the Site, utilizing Superfund risk
assessment methodologies. This health-based action level, detailed further in the risk discussion, was
calculated to be 730 Ig/1. Only one sample, collected from MW-12 (959 Ig/1), exceeded this level.

Following the remand of the MCL for nickel, EPA issued a Health Advisory of 100 Ig/1 for nickel; this Health
Advisory is intended to serve as informal technical guidance only. The Health Advisory incorporates
additional conservative assumptions related to potential nickel exposure from media other than drinking
water. It should be noted that, in February 1998, the NYSDEC established a Class GA standard for nickel of
100 Ig/1. Of the 15 wells sampled during Phase (second round), only three had levels of nickel above 100
Ig/1, namely, MW-11 (140 Ig/1), MW-12 (959 Ig/1) and MW-16 (278 Ig/1).

The Phase II second round of metals analysis also detected the presence of both iron and manganese
above their respective secondary drinking water standards. The secondary federal and state MCLs for iron and
manganese are both based on aesthetic properties and are intended to prevent potential problems, such as poor
taste, odor, and staining of plumbing fixtures, and do not specifically present a health risk. The highest
concentrations of iron (34,900 Ig/1) and manganese (2,840 Ig/1) were present in the unfiltered sample
collected from MW-11R. A filtered sample collected from MW-11R detected iron and manganese at reduced levels
of 189 Ig/1 and 459 Ig/1, respectively. In the filtered sample, manganese was still detected in excess of the
secondary standard. However, the manganese levels detected represent background conditions in the area.

Comparison of the Phase I and Phase II (first round) groundwater sampling results indicated that the VOC
concentrations had decreased. For the Phase II data, the only VOC detected at a concentration above its
drinking water standard was carbon disulfide in monitoring well 17D (MW-17D). This concentration was not
confirmed by its split sample and was determined to be a laboratory artifact and not a contaminant of
concern.

In May 1997, 10 monitoring wells were sampled in order to establish a nickel level baseline prior to the
remedial action for OU-1. The May 1997 results showed that only one well, MW-12, contained nickel levels
above EPA's Health Advisory level and NYS Class GA standard of 100 Ig/1. Nickel was present at a
concentration of 394 Ig/1 in this well, significantly below the 980 Ig/1 detected in 1994. Similarly, nickel
concentrations in the other wells which had also been above 100 Ig/1 in 1994 decreased significantly; the
nickel concentration in MW-16 decreased from 278 Ig/1 to 95 Ig/1, while the concentration in MW-11 decreased
from 140 Ig/1 to below the detection limit of 14 Ig/1. Nickel was also not detected in five of the remaining
seven wells sampled.

In December 1997, 13 wells were sampled for nickel in order to assess the post-remediation nickel
concentration. The December 1997 results also showed a general decline in nickel concentrations. In
particular, MW-12 results showed a reduction from 394 Ig/1 (May 1997) to 300 Ig/1 and was the only well
that exceeded the NYS Class GA standard of 100 Ig/1 for nickel. Nickel was not detected in 10 of the
remaining 13 wells sampled.

Church Street Wellfield

In late 1993, routine monitoring performed by SCWA on the Church Street wellfield detected the presence
of nickel in CS-2 in excess of 100 Ig/1 for nickel. This prompted SCWA to remove CS-2 from service and
conduct testing to evaluate a suitable method of reducing the concentration of nickel in the supply well.
Since January 1995, the highest level of nickel detected at CS-2 was 112 Ig/1 in January 1996. Overall
results of the SCWA sampling of the Church Street wells has shown a general decrease in the nickel levels.
CS-2 has been returned to service, and SCWA has closely monitored the quality of water in CS-2, in addition
to its other wells to ensure that the water distributed from its wellfield meets all federal and state
drinking water standards.

From June 1997 until March 1998, CS-2 was sampled weekly; the highest nickel level of 99.7 Ig/1 was found in

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July 1997. The levels since that time have decreased steadily, and for the period from January 1998 through
June 1998 the average concentration in the influent to CS-2 has been 55 Ig/1.

This decreasing trend of nickel concentrations to levels below 100 Ig/1 is consistent with the solute
transport modeling results provided in the 1995 FS.  The model incorporated conservative assumptions intended
to overestimate the concentrations of nickel which might reach CS-2. The model, which utilized
the maximum concentration that had been found at the Site  (980 Ig/1 rounded up to 1000 Ig/1),  predicted
that nickel concentrations reaching CS-2 would peak at 325 Ig/1 in 1996, prior to decreasing to levels
below 100 Ig/1 in 1997. In fact, CS-2 sampling data available to EPA indicate that the model assumptions
were conservative, since the nickel concentrations entering CS-2 reached a peak of 112 Ig/1 in January
of 1996.  [It should be noted that, while the sample results since January of 1996 have generally indicated
concentrations in the 50-70 Ig/1 range, concentrations did approach 100 Ig/1 in late June of 1997, only to
decline shortly thereafter.] Given these results, coupled with the source removal and the significant decline
of nickel on-site, it is anticipated that nickel concentrations will continue to decrease on-site and that
levels of nickel at CS-2 will continue to decrease and remain below 100 Ig/1.

In order to monitor the nickel concentration upgradient of the Church Street wellfield, a cluster of two
additional monitoring wells, identified as MW-191 and MW-19D, are currently being installed south of
MW-12 in the direction of CS-2. These wells will be sampled as part of the monitoring program identified
in the preferred remedy.

SUMMARY OF SITE RISKS

The 1995 RI included a baseline risk assessment which estimated the risks associated with current and future
uses of the 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.

Health Assessment

As part of the baseline risk assessment, the following 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 pathway
(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 (e.g., one-in-a-million excess cancer risk) assessment of site-related risks.

The 1995 baseline risk assessment began with selecting contaminants of concern which would be representative
of Site risks associated with soil, sediments and groundwater at the Site. These
contaminants included tetrachloroethylene, 1,1-dichloroethane, 1,1,1-trichloroethane, vinyl chloride,
benzo(a)anthracene, chrysene, cadmium, copper, lead, nickel and zinc.

Exposure pathways were evaluated under possible on-site present and future land use conditions. The Site was
assumed to retain its current zoning status of commercial/industrial. The exposure pathway considered for
groundwater was domestic use of groundwater  (including ingestion and inhalation of volatiles by nearby
residents using the Church Street wellfield as the exposure point).

EPA's acceptable cancer risk range is 10 -4 to 10 -6 under a reasonable maximum exposure (RME) scenario. This
ran be interpreted to mean that an individual may have a one in ten thousand to a one in a million increased
chance of developing cancer as a result of exposure to a site-related carcinogen over a 70-year lifetime
under the specific exposure conditions at a site and other exposure assumptions that result in an overall
exposure estimate that is conservative but within a realistic range of exposure. The results of the baseline
risk assessment indicated that the groundwater at the Site poses no unacceptable carcinogenic risk to human

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health. The overall carcinogenic risk for domestic use of groundwater, through ingestion and inhalation, is
estimated to be 9.5 x 10 -6 (risk of 9.5 in a million) under RME assumptions. Much of this risk is
attributable to vinyl chloride, which was detected at low levels in some soil samples during Phase I but has
not been detected in recent sampling events on site nor at the Church Street wellfield.

Since significant nickel contamination exists the Upper Glacial Aguifer, potential risks related to this
contamination were closely evaluated. An acceptable health-based action level was developed for nickel in
groundwater at the Site. Assuming that the groundwater would be used for domestic purposes, it was determined
that groundwater concentrations of nickel below 730 Ig/1 would result in an acceptable HI for the Site, i.e.,
an HI less than or egual to 1.0; conversely, levels above 730 Ig/1 could present an unacceptable
noncarcinogenic risk for the Site. Consistent with EPA guidance for conducting Superfund risk assessments,
this calculated value assumes that there are no other significant sources of nickel exposure from other
environmental media (e.g., air, soil, diet). As a point of reference, the 95% Upper Confidence Level of the
arithmetic mean, calculated utilizing nickel data from all monitoring wells sampled during Phase I and II was
66.5 Ig/1, well below the 730 Ig/1 action level. A solute transport model, used to show the potential future
concentrations of nickel at the Church Street wellfield, determined that under existing conditions.
concentrations f nickel in CS-2 are unlikely to ever approach the 730 Ig/1 EPA risk-based level. Modeling,
using conservative assumptions, indicated that levels of nickel on-site would need to increase to greater
than 2200 Ig/1 in order to exceed the 730 Ig/1 risk-based value at the Church Street wellfield. As noted
above, levels of nickel on-site have decreased from a high of 980 Ig/1 in 1994 to 300 Ig/1 in 1998. Since the
source of nickel contamination has been removed, the concentrations of nickel in the Site groundwater are
expected to decrease significantly.

Ecological Assessment

The ecological risk assessment considered potential exposure routes of Site contamination to terrestrial
wildlife. Much of the Site is paved or covered by structures and there is little, if any, potential for
wildlife to be exposed to contaminated subsurface soils on-site. The only potential route of exposure to
wildlife in the Site vicinity is if contaminants were transported through groundwater and discharge via
groundwater into surface waters, particularly the NYS wetlands, located one-half mile south of the Site.
Phase II sampling indicated that the wetland had not been impacted by Site contaminants. Therefore, it
was determined that no significant effect on aguatic organisms in the wetland in the vicinity of the Site
could be attributed to groundwater discharge from the Site.

Actual or threatened releases of hazardous substances from this Site, if not addressed by the
preferred afternative or one of the other active measures considered, would not present a current or
potential threat to the environment through contact with soils or groundwater.

REMEDIAL ACTION OBJECTIVES

Remedial action objectives are specific goals to protect human health and the environment. These
objectives are based on available information and standards such as applicable or relevant and
appropriate reguirements (ARARs) and risk-based levels established in the risk assessment.

The remedial action objective for, OU-2 is to prevent the ingestion of drinking water containing
concentrations of nickel above the 100 Ig/1 NYS Class GA standard, which is an ARAR at the Site.

SUMMARY OF REMEDIAL ALTERNATIVES

CERCLA reguires that each selected site remedy be protective of human health and the environment, be

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cost-effective, comply with other statutory laws and utilize permanent solutions, alternative 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.

The OU-2 groundwater remedial alternatives were screened based on implementability, effectiveness and cost.
The screening resulted in remedial alternatives upon which a detailed evaluation was performed. It should be
noted that the alternatives discussed below, i.e., Alternatives GWR-I, GWR-II and GWR-III, have been modified
from those presented In the 1995 FS; the costs for these three alternatives have been updated to reflect 1998
costs. In addition, a new alternative, Alternative GWR-IV

(Monitored Natural Attenuation) has been added, and the monitoring component of Alternative GWR-I
(No Action) has been eliminated. These alternatives are discussed below.

Construction time is defined as the period of time needed to construct or implement the remedy and
does not include the time required to design the remedy, procure contracts for design and
construction or to negotiate with responsible parties for implementation of the remedy.

The remedial alternatives for groundwater (GWR) are as follows:

GWR-I: No Action
GWR-II: Water Supply - Wellhead Treatment
• GWR-III: Recovery Well - Groundwater Remediation
GWR-IV: Monitored Natural Attenuation

Alternative GWR-I: No Action

Capital Cost: $0
0 & M/yr Cost: $0
Present Worth: $0
Construction Time: N/A

The Superfund program requires that the "no action" alternative be considered as a baseline for
comparison with other alternatives. Under this no action alternative, no active or passive remediation
nor monitoring would occur.

Alternative GWR-II: Water Supply - Well Head Treatment

Capital Cost: $3,319,920
0 & M/yr Cost: $ 195,307
Present Worth: $5,033,741
Construction Time: 2 years

This alternative would include the installation and operation of a groundwater treatment system at the
well head for CS-2 for nickel removal, followed by discharge of the treated groundwater to the existing
public water supply distribution system.

At an estimated flow of 200 gpm, the groundwater would be pumped from a holding tank through a particulate
filter and through a multi-vessel ion exchange system. The ion exchange process would remove the metal ions,
primarily nickel, from solution, using e.g., hydrous aluminum silicates or organic resins. It is estimated
that 8,000 gallons of the concentrated nickel waste stream per month would be generated, requiring off-site
disposal in a RCRA Subtitle C facility in accordance with land disposal restrictions. Following treatment,
the groundwater would be pumped into the existing water supply storage tank and/or into the water
distribution system. Use restrictions would be imposed on the development of potable water supply wells at
the Site.

Alternative GWR-III: Recovery Well - Groundwater Remediation

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Capital Cost: $1,694,585
0 & M/yr. Cost: $ 135,583
Present Worth: $2,884,328
Construction Time: 2 years

This alternative would include the installation of a groundwater recovery well and treatment system for
nickel removal and the discharge of treated groundwater to an existing recharge basin.

A groundwater recovery well, operating at 100 gpm, would be installed immediately downgradient of the Site on
the south of Veteran's Highway. The groundwater would be pumped through a particulate filter and a
multi-vessel ion exchange system; this ion exchange process is similar to that of Alternative GWR-II. It is
estimated that 4,500 gallons of the concentrated nickel waste stream per month would be generated, reguiring
off-site disposal in a RCRA Subtitle C facility, in accordance with EPA land disposal restrictions. The
groundwater would be treated to meet federal and state groundwater and drinking water standards prior to
discharge to an existing storm water recharge basin. Use restrictions, as described in GWR-II, would also be
implemented.

Alternative GWR-IV: Monitored Natural Attenuation

Capital Cost: $ 27,000
0 & M/yr Cost: $ 26,213
Present Worth: $382,983
Construction Time: 6 months

contamination within a three-year timeframe. Groundwater monitoring would include sampling of existing
on-site and off-site monitoring wells, both outside and within the area of nickel contamination, as well as
the Church Street wellfield. Sampling of the wells, i.e., those identified in the monitoring program, would
be conducted on a guarterly basis. In order to ensure that the Church Street wellfield is able to continue to
supply water that meets all federal and state drinking water standards, an additional monitoring well cluster
is being installed to monitor the guality of the groundwater just upgradient of CS-2; monitoring of this well
cluster will occur on a more freguent basis. If this well cluster reveals nickel levels above 300 Ig/1, then
the appropriateness of the natural attenuation remedy would be reconsidered and contingency measures would be
evaluated to ensure that the Church Street wellfield can continue distributing safe drinking water to its
customers. These contingency measures might include well-head treatment, installation of a new supply well
and/or the installation of a groundwater extraction and treatment system.

EVALUATION OF ALTERNATIVES

During the detailed evaluation of remedial alternatives, each alternative is assessed against nine evaluation
criteria, as described below:

• Overall protection of human health and the environment addresses whether or not a remedy
provides adeguate protection and describes how risks are eliminated, reduced, or controlled
through treatment, engineering controls or institutional controls.

• Compliance with ARARs addresses whether or not a remedy will meet all of the applicable or
relevant and appropriate reguirements and/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 overtime, once cleanup goals have
been met. It also addresses the magnitude and effectiveness of the measures that may be
reguired to manage the risk posed by treatment residuals and/or untreated wastes.

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

• Short-term effectiveness addresses the period of time needed to achieve protection from 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 both estimated capital and operation and maintenance costs and net present worth
costs.

• State acceptance indicates whether, based on its review of the RI/FS reports and Proposed Plan,
the State concurs with, opposes or has no comment on the preferred alternative.

• Community acceptance will be assessed in the ROD and refers to the public's general response
to the alternatives described in the RI/FS reports and the Proposed Plan.

Comparison Among Groundwater Alternatives

• Overall Protection of Human Health and the Environment

• Compliance with ARARs

Alternative GWR-I would not comply with ARARs, since it would not address localized levels of nickel
above the NYS Class GA standard in the on-site groundwater. The other three alternatives would achieve
the NYS Class GA standard for on-site groundwater in approximately the same timeframe.

Compliance with ARARs would be demonstrated through monitoring.

The treated effluent from Alternatives GWR-II and GWR-III would also comply with federal and state
drinking water standards and standards for the transport and disposal of the concentrated nickel waste
stream from the ion exchange system.

• Long-Tenn Effectiveness and Permanence

Each of these alternatives, as well as Alternative GWR-I, is expected to result in cleanup levels
being achieved within the aguifer within three years.

• Reduction in Toxicity, Mobility or Volume Through Treatment

Alternatives GWR-II and GWR-III would provide the greatest degree of reduction in toxicity and
volume of affected groundwater through treatment. Alternative GWR-III would control mobility of nickel
in the groundwater through operation of the groundwater recovery system. Alternative GWR-II would
control the mobility of nickel in the groundwater through continued normal operation of the Church

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Street wellfield. Alternatives GWR-I and GWR-IV would not actively reduce the toxicity mobility or
volume of the nickel in the groundwater.

• Short-term Effectiveness

Alternative GWR-III would include excavation activities, installation of collection and discharge
systems and construction of the treatment plant, any potential impacts to residents and workers
would be minimized though the use of proper protective eguipment. Similarly, Alternative GWR-II would
reguire some construction activities. Residuals from the treatment process could pose a minor impact to
workers handling and transporting these materials; safe handling and transport procedures would be
easily implemented.

The implementation of Alternatives GWR-I and GWR-IV would result in no additional risk to the
community or on-site workers during remedial activities, since no major construction activities
would be conducted.

• Implementability

All services, materials and technologies reguired to implement Alternatives GWR-II and GWR-III are
readily available. However, Alternative GWR-III would reguire approval and coordination of SCWA to
install the water treatment system at the Church Street wellfield. Treatability study testing may need
to be conducted to design the treatment systems for Alternative GWR-II and GWR-III.

There are no actions to implement under Alternative GWR-I. The groundwater monitoring program under
Alternative GWR-IV would be easily implemented.

Cost

Alternative GWR-II ($5,033,741) would be the most costly alternative to implement, followed by
Alternatives GWR-III and GWR-IV. There are no implementation costs associated with Alternative GWR-I.

• Community Acceptance

Community acceptance of the preferred groundwater alternative, Monitored Natural Attenuation
(Alternative GWR-IV), will be assessed in the ROD, following a review of the public comments received
on the RI/FS reports and the Proposed Plan.

• State Acceptance

NYSDEC concurs with the preferred alternative, Monitored Natural Attenuation (GWR-IV).

SUMMARY OF THE PREFERRED MONITORED NATURAL ATTENUATION REMEDY

Based on the results of the OU-1 RI/FS, the OU-1 remedial action and the supplemental groundwater sampling
and the installation of well cluster MW-19, EPA and NYSDEC have determined that limited contamination exists
in the groundwater at the Site and that the levels of contamination are decreasing and are below the
risk-based level established for the Site. The guality of drinking water provided by CS-2 is improving, and
the SCWA is able to distribute water that meets all federal and state drinking water
standards.

The removal of the source of nickel contamination in groundwater, namely the soils and sediments in the
dry wells, that was completed during the Summer of 1997, will continue to result in further decreases in
the nickel concentration in groundwater.

As a result, EPA and NYSDEC have determined that a Monitored Natural Attenuation remedy for the groundwater
is fully protective of human health and the environment. Sampling of the wells identified in
the monitoring program would be conducted on a guarterly basis. In order to ensure that the Church Street

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wellfield can continue to supply water that meets all federal and state drinking water standards,  an
additional monitoring well cluster is being installed to monitor the guality of the groundwater just
upgradient of CS-2.  Monitoring of this well cluster will occur on a more frequent basis.  If this well
cluster reveals nickel levels above 300 Ig/1,  then the appropriateness of the natural attenuation remedy
would be reconsidered and contingency measures would be evaluated to ensure that the Church Street welifield
can continue distributing safe drinking water to its customers. These contingency measures might include
well-head treatment, installation of a new supply well and/or the installation of a groundwater extraction
and treatment system.

It is important to note that the remedy described above is the preferred remedy for OU-2.  The final selected
remedy will be documented in the ROD only after consideration of all comments on the preferred
remedy addressed in this Proposed Plan and the RI/FS reports.

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APPENDIX B

PUBLIC NOTICE

PAID ADVERTISEMENT

The United States Environmental Protection Agency Announces
Preferred Remedy for the
GOLDISC RECORDINGS SUPERFUND SITE
Village of Holbrook, Town of Islip,
Suffolk County, New York

The U.S. Environmental Protection Agency (EPA) has completed its investigation for the Second Operable Unit
(OU-2) forthe Goldisc Recordings Superfund site (Site) in Holbrook, New York. This operable unit addresses
the groundwater at the Site. Last summer, the Agency supervised the successful removal of approximately 300
cubic yards of contaminated soil and sediments on the property, which were the principal source of the nickel
contamination, which is the contaminant of concern for the groundwater. With the sources of the contamination
eliminated, EPA' s proposed plan is to rely on the natural breakdown and dilution of the low level nickel
contamination present in the groundwater to gradually reduce the concentrations to meet State drinking water
standards. The effectiveness of this process, called natural attenuation, will be measured through a
long-term monitoring program, which is a component of EPA's proposed plan.

Before selecting a final remedy, EPA will consider written and oral comments on this preferred remedy. All
comments must be received on or before September 27, 1998. The final decision document will include a summary
of public comments and EPA's responses.

EPA will hold an informational public meeting on September 17, 1998, at 7:00 P.M. at the Bohemia Recreation
Center, located at One Ruzicka Way, Bohemia, New York, to discuss the findings of the groundwater
investigation and the preferred remedy.

The OU-2 Proposed Plan, the Remedial Investigation/Feasibility Study reports, the Remedial Action Report for
the First Operable Unit and other site-related documents can be reviewed at the information repositories
listed below:

Islip Town Hall
655 Main Street
Islip, New York 11751

Sachem Public Library
150 Holbrook Road
Holbrook, New York 11741

Written comments on the preferred remedy should be sent to:

Damian J. Duda
Remedial Project Manager
U.S. Environmental Protection Agency
290 Broadway, 20th Floor
New York, New York 10007-1866

Written comments must be received at the above address on or before September 27, 1998.

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APPENDIX C

SEPTEMBER 17, 1998 PUBLIC MEETING ATTENDANCE SHEET

APPENDIX D

LETTERS SUBMITTED DURING THE PUBLIC COMMENT PERIOD

September 25, 1998

Mr. Damian Duda
Remedial Project Manager
Environmental Protection Agency
Emergency Response Division
290 Broadway - 20 th Floor
New York, New York 10007-1866

Re: Goldisc Recording Proposed Plan (Site No. 1502022)

Dear Mr. Duda:

This letter is in response to the Draft Proposed Plan for the Goldisc Recording Superfund Site in
Holbrook, New York dated August 1998. The Suffolk County Water Authority (SCWA) supports the position and
comments submitted by Mr. Sy F. Robbins of the Suffolk County Department of Health Services (SCDHS) in his
lefter dated August 21, 1998 (copy attached). The SCWA will also work with the SCDHS to try to identify
potential receptors downgradient from the Goldisc site.

In addition to the above-referenced comments, the SCWA would also like to reiterate a position
previously taken regarding the financial and production impacts incurred by the SCWA due to the nickel
contamination in our supply well. The Draft Report does not include any costs incurred by the SCWA for
additional water guality monitoring performed on our Church Street Wells, due to the nickel contamination.
The SCWA has sampled all Church Street Wells weekly since the early 1990's snd will continue to do so until
nickel is no longer detectable in the wells. Under normal circumstances, with no nickel contamination, On
SCWA would only be reguired to sample the Church Street wells for metals two (2) times
per year. Therefore, as a minimum, the SCWA reguests that the final remedy selected by the EPA in it's Record
of Decision include reimburseiment of all future costs associated with the additional monitoring that will be
iincurred by the SCWA.

Engineering Office: 3525 Sunrise Highway, Great River, NY

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DL ROTHBERG & ASSOCIATES, P.C.
COUNSELLORS AT LAW

230 PARK AVENUE, SUITE 615
NEW YORK, NEW YORK 10169
TEL. 212-490-2220
FAX 212-490-2336

September 2, 1998
BY HAND

Damian J. Duda
Remedial Project Manager
U.S. Environmental Protection Agency
Region ii
290 Broadway — 20th floor
New York, NY 10007-1866

Re: Comments on USEPA Superfund Proposed Plan
for Former Goldisc Recordings Superfund Site. OU-2

Dear Mr. Duda:

These comments to the Superftind Proposed Plan for second operable unit ("OU-2") at the Goldisc
Site (the "Proposed Plan"), issued by the United States Environmental Protection Agency ("USEPA") are
submitted on behalf of Red Ground Co. and Red Ground Corporation (collectively, "Red Ground"), former owners
of the Goldisc Recordings Superfund Site ("Goldisc Site"). Red Ground reguests that these comments be
docketed and made a part of the administrative record in this matter.

1. The Proposed Plan Incorrectly Identifies the Goldisc Site

The Site Background section of the Proposed Plan incorrectly identifies the Goldisc Site as be a
"34-acre Site" consisting of six developed acres, three acres of pavement, and 25 undeveloped acres. The site
map attached to the Proposed Plan shows the 34-acre property described in the Proposed Plan.

In fact, the Goldisc Site is substantially smaller than as described in the Proposed Plan. As
defined in the Consent Decree entered into by the USEPA, Red Ground and several other responsible parties,
the site is approximately half the size stated in the Proposed Plan, and excludes most of the vacant land:

"Site" shall mean the Goldisc Recordings Superfund Site, encompassing
approximately 17.34 acres, comprising the northern portion of the two parcels

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Damian J. Duda
September 2, 1998
Page 3

against ESG and First Holbrook in the Supreme Court, Suffolk County. Red Ground also made every effort to
cooperate with the Agency to implement the remedial program, and in fact has assisted the USEPA in obtaining
the cooperation and performance of ESG and First Holbrook.

Given the continued legal responsibility for the remediation of First Holbrook and ESG, and the
fact that it was ESG that caused the contamination at the Site, Red Ground's actions have been appropriate
and Red Ground has acted in good faith. Ultimately, the efforts of all parties resulted in the Consent Decree
governing the soil remediation of the property, which has recently been completed.

3. Description of Preferred Natural Attenuation Remedy

The description of Alternative GWR-IV in the Proposed Plan omits several important details.
First, while the press release dated August 27, 1998 concerning the Proposed Plan refers to a "long-term
monitoring program," the only reference to the duration of the monitoring effort is made in the text of the
Proposed Plan is a statement that the EPA expects final cleanup levels to be met "throughout the entire area
of nickel contamination within a three-year timeframe." We understand this to mean that the EPA is proposing
a three-year monitoring effort. This should be made explicit. In a related point, the
presentation of the costs of Alternative GWR-IV makes little sense in the absence of an explanation of the
length of the monitoring period. The present worth value for this Alternative of $382,983 seems to assume a
longer monitoring period than three years without any basis in the text.

Finally, the Proposed Plan should include at least a general discussion of the criteria that the
EPA would employ in determining that monitoring may cease, assuming that concentrations of nickel detected
continue to decline.

We look forward to a response to the above comments, including a correction of the Site
description, in the EPA's Responsiveness Summary.

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                            ROD FACT SHEET
SITE
Name:
Location/State:
EPA Region:
HRS Score/date:
Site ID #:
Goldisc Recordings, Inc.
Village of Holbrook, Suffolk County, New York
2
33.39  (6/1/86)
NYD980768717
ROD
Date Signed:
Remedy:
Operating Unit#:
Capital cost:
Construction:
Completion:
O&M:
Present worth:

LEAD
09/30/98
Monitored Natural Attenuation with Monitoring
OU-2
$0
None
Sept. 2001
$2,300/year
$9,430
Enforcement:
Primary contact:
Secondary contact:
Main PRP(s):
PRP Contact:
EPA oversight/PRP
Damian Duda:  (212) 637-4269
Doug Garbarini:  (212) 637-4263
ElectroSound Group, Inc.
First Holbrook Co.
Red Ground Corp.
Leslie Levine:  (516)  829-6900
WASTE
Type:
Medium:
Origin:
Est. guantity:
nickel
groundwater
plating-type wastes
N/A

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