Superfund Proposed Plan

   Nepera  Chemical Company,  Inc.  Superfund  Site

                          Hampton burgh, Orange County, New York
                                                                                July 2007
&EPA
PURPOSE OF THE PROPOSED PLAN

This  Proposed  Plan describes the remedial alternatives
considered for the contaminated soil and groundwateratthe
Nepera Chemical Company Superfund Site, and identifies the
preferred remedy with the rationale for this preference. This
Proposed Plan was developed by the  U.S. Environmental
Protection Agency (EPA) in consultation with 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, as amended (commonly
known as the  federal  "Superfund" law), and Sections
300.430(f) and 300.435(c) of the National Oil and Hazardous
Substances Pollution Contingency Plan (NCP).  The nature
and  extent of  the  contamination  at the site and  the
alternatives summarized in this Proposed  Plan are further
described in the June 16, 2006 Remedial Investigation (Rl)
Report and the June 26, 2007 Feasibility Study (FS) Report,
respectively.  EPA and NYSDEC encourage the public to
review these  documents to gain a more  comprehensive
understanding of the site and Superfund activities that have
been conducted at the site.

This Proposed Plan is being provided to inform the public of
EPA's preferred remedy and to solicit public comments
pertaining to the remedial alternatives evaluated, including
the preferred alternatives. EPA's preferred remedy consists
of the following components:

      Excavation of the soil in the source area (former
      lagoon area), the design and construction of a biocell
      to contain the excavated soil, the installation of a soil
      vapor extraction (SVE) system within the biocell, and
      operation  of the SVE  and biocell to remediate
      contaminated soil.  This soil remedial alternative is
      referred to as Soil Alternative 4 (S4). In addition, the
      excavated area  will be treated with oxygenating
      compounds (e.g., Oxygen Releasing Compounds) to
      create  an aerobic  environment   and, thereby,
      stimulate biodegradation within  the  area of elevated
      groundwater contamination.   This groundwater
      remedial alternative is referred to as Groundwater
      Alternative 2 (GW2).  The injection of oxygenating
      compounds directly into the groundwater at location-
      specific  injection   points   to  further  enhance
      biodegradation of groundwater contamination will be
      evaluated  during the remedial design. This will be
      followed by  a long-term groundwater monitoring
      program where  groundwater  samples would be
                                                     Mark Your Calendar

                                                     July 31,2007 -August 29,2007: Public Comment Period
                                                     on the Proposed Plan.

                                                     August 16, 2007 at 7:00 p.m.:  The U.S. EPA will hold a
                                                     Public Meeting to explain the Proposed Plan. The meeting
                                                     will be held at Campbell Hall in Hamptonburgh, New York.

                                                     For more information, see the Administrative Record
                                                     file (which  will include the Proposed Plan  and
                                                     supporting documents), which  is available at the
                                                     following locations:

                                                     Hamptonburgh Town Hall
                                                     18 Bull Road
                                                     Campbell Hall, New York 10916
                                                     Tel. 845-427-2424
                                                     Hours: Monday - Friday 9:00am - 3:30pm

                                                     and

                                                     USEPA-Region II
                                                     Superfund Records Center
                                                     290 Broadway, 18th Floor
                                                     New York, NY 10007-1866
                                                     (212)637-4308
                                                     Hours: Monday-Friday, 9:00 a.m. - 5:00 p.m.

                                                     Written comments on this Proposed Plan should be
                                                     addressed to:

                                                     Mark Dannenberg
                                                     Remedial Project Manager
                                                     Eastern New York Remediation  Section
                                                     U.S. Environmental Protection Agency
                                                     290 Broadway, 20th Floor
                                                     New York, New York 10007-1866
                                                     Telephone: (212)637-4251
                                                     Telefax:  (212)637-3966
                                                     Email address:  Dannenberg.mark@epa.gov

                                                     The EPA has a web page for the Nepera Chemical
                                                     Company Site at
                                                     www.epa.gov/region2/superfund/npl/neperachemical.

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       collected and analyzed regularly in order to verify
       that  the   concentrations  and  the  extent  of
       groundwater contaminants are declining. The exact
       frequency and parameters of sampling and location
       of  any  additional  monitoring  wells  would be
       determined during the design phase.

The remedy described in this Proposed Plan is the preferred
remedy for the site.  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. EPA is soliciting public comment on all of the
alternatives considered  in 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, this
Proposed   Plan,  along  with  the  supporting  Remedial
Investigation and Feasibility Study Reports, have been made
available to the public for a public comment period which
begins on July 31,  2007  and concludes on August 29,
2007.

A public meeting  will be held during the public comment
period at Campbell  Hall in Hamptonburgh, New York on
August 16,2007 at 7:00 P.M. to elaborate on the reasons for
the proposed remedy and to receive public comments.

Comments  received at the public meeting, as well as written
comments,  will be  documented in  the Responsiveness
Summary Section of the  Record of Decision (ROD), the
document which formalizes the selection of the remedy.
SCOPE AND ROLE OF ACTION

This Proposed Plan presents the preferred alternatives to
remediate the site.  The objectives of the proposed remedy
are to remediate contaminated soil, reduce and minimize the
migration  of  contaminants in  the  groundwater, restore
groundwater quality, and minimize any potential future health
and environmental impacts.

SITE BACKGROUND

Site Description
The property is located on the south  side of Orange County
Highway 4  in Hamptonburgh,  Orange County, New York,
approximately 1.5 miles southwest of the Village of Maybrook
(see Figure 1).   The site  is owned by  Nepera Chemical
Company, Inc. (Nepera).   The site  is 29.3 acres in area;
approximately 5 acres of the site were used for the historical
lagoon operations (see  Figure 2). The site is located in a
rural residential/agricultural area, bounded by Orange County
Highway 4 to  the north, Beaverdam Brook to the west, the
Otter Kill to the south, and an undeveloped tract of land to the
east.  Three residences  exist in the immediate vicinity of the
site, one to the southwest, one to the north and one to the
northeast (on the other side of Orange County Highway 4).

Approximately 7,000 people live within three miles of the
site, with the closest residences located approximately 250
feet to the west-southwest and 175 feet to the northeast.
The public water supply wells for the Village of Maybrook
are located approximately 800 feet to the northeast of the
site property.  All residences in the vicinity of the site rely
on private wells for the potable water supply.

Site Geology/Hydroqeology
The site  is in  an  area of rolling  hill topography and is
located within a 4.5 square mile watershed  consisting of
Beaverdam Brook and its tributaries, which  discharge to
the Otter Kill, located approximately 500 feet to the south of
the property. The geologic units at the site are divided into
two primary units, the overburden (comprised of topsoil, fill,
and gravel) and the bedrock (comprised of shale). Ground
surface topography is generally bedrock controlled in that
the ground surface generally follows the  bedrock surface
topography.  The overburden thickness at the site is also
related to bedrock topography in that it is generally thinner
(or absent) over bedrock ridges, while greater overburden
thicknesses have been deposited in bedrock depressions
and valleys. The overburden ranges in thickness from 0 to
20 feet.

Most of the site is forested. The former lagoon area, which
was stripped of vegetation while in use, is  now covered
with grasses, wild flowers, and mixed brush. There are two
aquifers that exist beneath the site, the overburden aquifer
and the bedrock aquifer.  The overburden aquifer is the
surficial  unit which overlies the bedrock aquifer.  The
bedrock aquifer is the primary source for public water in the
area.   No significant  layers of impeding clays were
observed between the two aquifers within the study area.
An east to west trending groundwater divide is present in
the bedrock aquifer underlying (and transecting) the lagoon
area.  As such, groundwater flow has a northerly and  a
southerly component radiating from this divide.

Site History
The site was used for the disposal of industrial wastewater
generated at  the Nepera Chemical Company  facility in
Harriman, New York, located approximately 25 miles from
the site. Wastewater was trucked to the site and disposed
of in six constructed lagoons from 1953 through December
1967. Approximately 5 acres of the site were used for the
historical  lagoon  operations,  six lagoons  in  all.   No
wastewater disposal  has occurred  at  the Site since
December 1967. Three of the lagoons were backfilled with
clean  soil in 1968 and the remaining  three lagoons were
backfilled with clean soil in 1974.

Beginning  in   1967,   numerous  investigations  were
conducted by various consultants to Nepera  to determine
the extent of contamination at the site.  Based on the
results of these investigations, NYSDEC placed the site on
the New York Registry of Inactive Hazardous Waste
Disposal  Sites. On August 17, 1984, the State of New
York entered into a Consent Decree with Nepera Chemical
Company, Inc. to conduct  a remedial  investigation  to
determine the type and extent of contamination at the site.
EPA Region II - July 2007
                                     Page 2

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On  June 1, 1986, the EPA placed the Nepera site on the
National   Priorities  List  (NPL)  of  sites   under   the
Comprehensive Environmental Response Compensation and
Liability Act  1980  (CERCLA),  as  amended. NYSDEC
continued as the lead  regulatory agency overseeing the
implementation of the RI/FS.

Under  an Administrative Order with  NYSDEC, signed on
March  21, 1988, the Potentially Responsible Party (PRP),
namely Nepera Chemical Company, Inc., hired a contractor
to conduct a Remedial Investigation/Feasibility Study (RI/FS)
of the site in 1988. The first draft Rl was submitted in March
1996.  EPA determined  that further work was necessary to
define the type and extent of soil contamination at the site
and to determine the downgradient extent of the contaminant
plume which emanated from the site. In March 2005, an
updated draft Rl was submitted to NYSDEC and USEPA.
This document was revised  and a  Final Rl Report  was
submitted on June 16 2006.

The  lead  agency for  the  Nepera site  was  recently re-
designated, at the conclusion  of the RI/FS process,  from
NYSDEC to USEPA.
SUMMARY OF SOIL AND GROUNDWATER SAMPLING

Major Rl activities performed during field data collection
activities included:  on-site  soil borings, soil  sampling,
monitoring  well   drilling  and   installation,  groundwater
sampling, and residential well sampling. The results of the Rl
are summarized below.

Soil
The PRP performed the Rl in several phases. Soil sampling
activities were conducted  in 1991 and 1996.  Focused soil
sampling identified contamination in the lagoon area and
determined the lagoon area to be the primary source of the
contaminants  in  the groundwater  plume.   The  primary
contaminants identified during soil sampling activities include
benzene (maximum concentration  of  13 milligrams per
kilogram (mg/kg)), chlorobenzene (maximum concentration of
12 mg/kg), ethylbenzene (maximum concentration of 22
mg/kg),  toluene  (maximum concentration of 52  mg/kg),
xylenes  (maximum concentration of 300 mg/kg) and pyridine-
related compounds (maximum concentration of 74 mg/kg of
2-amino  pyridine).   Each   of  these  contaminants are
considered as Contaminants of Concern (COCs) forthe Site.
In  addition, several samples detected elevated  levels  of
metals,  including mercury and manganese. An additional
120 soil samples were collected from the lagoon area in 2003
to  evaluate concentration levels of metals. Soil samples
were also collected from locations not impacted by the site to
determine  Site-specific  background  levels  for  metals.
Analytical data from the 2003 sampling activities  indicated
that the metals in  the lagoon area were analogous to
background concentrations and, as such, metals are not
considered to  be COCs.   The presence of mercury in
earlier samples (from 1991 and 1995) was of additional
concern as the form of mercury (e.g., organo-mercury or
inorganic mercury) can significantly change its toxicity. As
such,  additional analyses were  performed on selected
samples from the 2003 activities to determine form (or
species) of mercury present in Site soils.  These analyses
determined that over 99% of the mercury present in Site
soils  is in the form  of  inorganic mercury,  which is
significantly less toxic than organo-mercury.

As stated  earlier, the former lagoons are within an area
approximately 5 acres in size, but the total area of the
actual  six lagoons  is smaller.    The  total  area  of
contaminated soils (i.e., the six lagoons) is estimated to be
128,850 square feet (approximately 3 acres). The volume
calculations for contaminated soil are based  on the actual
surface  area of each lagoon, the average  depth of the
overburden within each lagoon (down to  bedrock),  the
thickness of a distinct black-stained layer observed during
the completion of test pits, and the clean fill put on  the
lagoons.    The  average  overburden  thickness  was
estimated to range from 3.4 (for lagoon 6) to 13.3 feet (for
Lagoon  3).  The  total volume of contaminated  soil is
estimated  to be 30,086 cubic yards.  Furthermore, it is
estimated that 20% (approximately 6,000 cubic yards) of
this is comprised of shale and cobble which will be sorted-
out prior to implementing a soil remedy.  Therefore,  the
remedial alternatives assessed in this Proposed Plan  are
based on  the  total volume of contaminated soil  being
24,086 cubic yards, which is equivalent to approximately
38,700 tons of contaminated soil.

Groundwater
The groundwater monitoring program included sampling of
groundwater monitoring wells located at  (and bordering)
the site  and analyses of these samples  for organic and
inorganic compounds.  These efforts were comprised of
several separate field mobilizations conducted between
1995 and 2003.  The investigation was conducted in an
iterative manner, where the results of each task were used
to develop the scope of each subsequent task. The Rl
included:

•   Installing permanent groundwater monitoring wells to
    act as fixed monitoring and/or compliance points within
    both the overburden aquifer and the bedrock aquifer.
    A total of 38  groundwater  monitoring  wells  were
    installed in the study area.

•   Collecting a series of groundwater samples from the
    assembled monitoring network;

•   Identifying the Contaminants of Potential Concern in
    both aquifers;
EPA Region II - July 2007
                                    Page 3

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•   Characterizing the horizontal and vertical extent of site-
    related contaminants in the overburden and bedrock
    aquifers and determining the extent of the groundwater
    contaminant plume;

As  with the contaminated  soil, the primary contaminants
identified in groundwater include benzene, chlorobenzene,
ethylbenzene,  toluene,   xylenes  and  pyridine-related
compounds.   These contaminants were detected  above
MCLs in the wells located within the property boundary.

Residences in the vicinity of the site rely on private wells for
their potable water supply.  As a precautionary measure, to
ensure that these wells are not impacted by the Site, private
wells in the immediate vicinity of the Site have routinely been
sampled for Site-related contaminants. With the exception of
minor levels of Site-related contaminants detected below
drinking water standards  (e.g.,  MCLs)  in May 2002 and
September 2003,  sampling data indicates  nondetectable
levels of Site-related contaminants in  private wells.   Also,
because of their close proximity to the Site (approximately
800 feet), the public wells  located on County Highway 4,
which are used to supply drinking waterto customers served
by the Village of Maybrook, are monitored on a quarterly
basis for Site-related contaminants and must comply with the
New  York  State  Department  of Health drinking  water
standards.  Site-related contaminants have not been detected
in the Village of Maybrook Public Wells.

Sediment
As stated earlier, the Site is bounded by Beaverdam Brook to
the west  and  the Otter Kill to the  south.   Since  the
hydrogeological link between groundwater and these water
bodies was not clear, sediment samples were collected in
1985, 1991, and 1995 from  Beaverdam Brook and the Otter
Kill.

The EPA performed additional sediment sampling from  the
floor of Beaverdam Brook in  2003.   Groundwater flow
direction  was considered to  determine sampling location
points. Samples were collected from a total of 27 sampling
locations, upstream, downstream, and adjacent to the Site,
and were analyzed for volatile organic compounds and semi-
volatile organic compounds (including Site-related COCs).
Site-related COCs were not detected in these samples.
RISK SUMMARY

The purpose of the risk assessment is to identify potential
cancer  risks and  noncancer  health  hazards at the site
assuming that no further remedial action is taken. A baseline
human health risk assessment was performed to evaluate
current and future cancer risks and noncancer health hazards
based on the results of the Remedial Investigation.

A baseline ecological risk assessment was also conducted to
assess the risk posed to ecological receptors due to site-
related contamination.
      WHAT IS RISK AND HOW IS IT CALCULATED?

A  Superfund baseline human health  risk assessment  is an
analysis of the potential  adverse health  effects  caused by
hazardous substance releases from a site in the absence of any
actions to control or mitigate these under current- and future-land
uses. A four-step process is  utilized for assessing site-related
human health risks for reasonable maximum exposure scenarios.

Hazard Identification: In this step, the contaminants of concern
(COC) at a site in various media (i.e., soil, groundwater, surface
water, and air) are identified based on  such factors as toxicity,
frequency  of  occurrence,  and  fate  and  transport of the
contaminants  in  the  environment,  concentrations  of the
contaminants in specific  media,  mobility, persistence, and
bioaccumulation.

Exposure  Assessment: In  this step,  the different exposure
pathways  through which  people  might  be  exposed to the
contaminants identified in  the  previous step are evaluated.
Examples of exposure  pathways include incidental  ingestion of
and dermal contact with contaminated  soil. Factors relating to
the exposure assessment include, but are not limited to, the
concentrations that people might be exposed to and the potential
frequency  and duration of  exposure.  Using these factors, a
"reasonable  maximum  exposure" scenario, which portrays the
highest level of human exposure that could reasonably be
expected to occur, is calculated.

Toxicity Assessment: In this step, the types of adverse health
effects associated with  chemical exposures and the relationship
between magnitude of exposure and severity of adverse effects
are determined.  Potential health effects are  chemical-specific
and may include the  risk of developing cancer over a lifetime or
other noncancer health effects, such as changes in the normal
functions of organs within the  body (e.g.,  changes  in the
effectiveness of the  immune  system).  Some  chemicals are
capable of causing both cancer and noncancer health effects.

Risk Characterization: This step  summarizes and combines
outputs of the exposure and toxicity assessments to provide a
quantitative assessment of site risks. Exposures are evaluated
based on the potential risk of developing cancer and the potential
for non-cancer health hazards.  The likelihood of an individual
developing cancer is  expressed as a probability. For example, a
10"4 cancer risk means a "one-in-ten-thousand excess cancer
risk"; or one additional cancer may be seen in a population of
10,000 people as a result of exposure to site contaminants under
the conditions explained in the Exposure Assessment.  Current
Superfund guidelines for acceptable exposures are an individual
lifetime  excess cancer risk  in  the  range  of 10"4  to 10"6
(corresponding to a  one-in-ten-thousand to a one-in-a-million
excess cancer risk) with 10"6 being the point of departure. For
noncancer health effects, a "hazard index" (HI) is calculated. An
HI represents the sum of the individual exposure levels compared
to  their corresponding reference doses. The key concept for a
non-cancer HI is that a "threshold level" (measured as an HI of
less than 1) exists below which non-cancer health effects are not
expected to occur.
EPA Region II - July 2007
                                       Page 4

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Human Health Risk Assessment
As  part of the RI/FS,  a baseline human  health  risk
assessment was conducted to estimate the risks associated
with the current and future effects of contaminants on human
health and the environment.  A baseline human health risk
assessment is an analysis of the potential adverse human
health effects caused by hazardous-substance exposure in
the absence of any actions to control or mitigate these under
current and future land uses. A four-step human health risk
assessment process was used for assessing site-related
cancer risks and noncancer health hazards. The four-step
process is comprised of: Hazard Identification of Chemicals
of Potential Concern  (COPCs), Exposure Assessment,
Toxicity  Assessment,  and  Risk  Characterization  (see
adjoining box "What is Risk and How is it Calculated").

The  human health risk  estimates summarized below are
based on reasonable maximum exposure scenarios and were
developed  by taking  into  account  various  conservative
estimates about the frequency and duration of an individual's
exposure to the site-related contaminants both for adults and
children, as well as the toxicity of these contaminants.

The baseline risk assessment began with selecting COPCs in
the various media (e.g., soil and groundwater) that would be
representative of site risks. The property is currently zoned
as agricultural/residential.  Though  the  land  is currently
undeveloped, the reasonably anticipated  future land use,
based on its current zoning, is residential. As such, the risk
assessment was based  on a future anticipated residential
land-use scenario (the most conservative scenario), though,
an open-space, park setting was also  considered  in the
baseline risk assessment. In addition, the potential future
use of groundwater as a drinking water source is consistent
with the State use designation of the aquifer. The  baseline
risk   assessment   considered   health   effects   for
trespassers/hikers, maintenance workers, and residents who
may be exposed to contaminants in the soils by ingestion,
inhalation, and dermal contact, and ingestion and inhalation
of groundwater used as a potable water supply.   In this
assessment, exposure point concentrations were estimated
using either the  maximum detected concentration of a
contaminant or the 95 percent upper confidence limit of the
average concentration. Chronic daily intakes were calculated
based on the reasonable maximum exposure (RME), which is
the highest exposure reasonably anticipated to occur at the
site.   The  RME is intended  to estimate a conservative
exposure scenario that is still within the range of possible
exposures. Central tendency exposure (CTE) assumptions,
which  represent typical  average exposures, were also
developed. A complete summary of all exposure scenarios
can be found in the baseline human health risk assessment.

Human Health Risks
In the Human Health Risk Assessment, chemical data were
used to calculate cancer risks and noncancer health hazards
expressed  as individual  Hazard Quotients  (HQ).   These
cancer  and noncancer  risks,  for the most conservative
scenario (namely, future residential use  of the  Site) are
expressed below.
EPA's statistical analysis of the groundwater sampling data
indicates that the probable exposure concentrations  of
benzene (330  ug/l), xylenes (270  ug/l), 2-aminopyridine
(189 ug/l), and aniline  (16  ug/l), when evaluated under
future residential exposure scenarios, are associated with
noncancer  hazard quotients of 21, 4,  570,  and 23,
respectively. In addition, the concentration of benzene is
associated with an excess lifetime cancer risk of 1 x 10~3.
All of these  values  exceed  EPA's acceptable  levels  of
noncancer hazard or excess lifetime cancer risk.

Similarly, EPA's evaluation of the soils indicates that direct
exposure to the  probable  exposure concentrations  of
benzene  (4,440   ug/kg),   toluene   (10,000   ug/kg),
chlorobenzene (1,000 ug/kg), xylenes (69,000 ug/kg), and
2-aminopyridine (23,400 ug/kg) are associated with hazard
quotients of 42, 7, 5, 61, and 2, respectively. All of these
values exceed  EPA's  acceptable  levels of noncancer
hazard.  In  addition,  the concentration of benzene  is
associated with an excess lifetime cancer risk of 1 x 10'4.

These  risk  and hazard  levels indicate that  there  is
significant potential risk to receptors from direct exposure
to contaminated soil and groundwater. The risk estimates
are based  on  current  reasonable maximum exposure
scenarios and were  developed by taking into account
conservative  assumptions  about  the   frequency  and
duration  of  an individuals'  exposure to the  soil  and
groundwater, as well as the toxicity of these chemicals.

These calculated risks to human health indicate that action
is necessary by EPA to undertake  remedial measures to
reduce   the   risks   associated  with   the  observed
contamination  in soil and groundwater and restore the
groundwater to beneficial  use.

Ecological Risk Assessment
A baseline  ecological risk assessment (BERA) was
prepared to identify the  potential environmental risks
associated with surface water, groundwater, sediment, and
soil.  The results of the BERA suggested that there are
contaminants in groundwater, soils,  and sediment, but they
are not  present  at  levels  posing  significant  risks  to
ecological receptors.  The potential for risk to ecological
receptors exposed to site-related contaminants was limited
to isolated locations,  primarily in Lagoon 6,  and the risk
associated with this area used the conservative assumption
that the  ecological  receptors  (e.g.,  soil invertebrates,
mammalian insectivores, and carnivores) spend 100% of
their lives in the area of Lagoon 6. The contaminants that
were identified in the BERA (outside of Lagoon 6) were
determined not to pose a  potential  for adverse ecological
effects because they were common elements of soil that
were  not related to  Site operations,  the  detected
concentrations were  lower  than background levels, the
frequency of detections was low, or the  HQs were only
slightly above 1 with  no adverse impacts to populations
expected. A detailed presentation of these  data can be
found in the Rl Report.

Risk Summary Conclusion
EPA Region II - July 2007
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Exposure to contaminated soil poses risks to human health.
Furthermore, the contaminated soil continues to be a source
of groundwater contamination. As such, it was decided that a
remedial action should be taken to reduce contamination in
the soil to levels  below cleanup objectives.  In addition,
exposure to contaminated groundwater poses risks to human
health. As such, it was decided that a remedial action should
be taken to restore the contaminated groundwater for future
use.
REMEDIAL ACTION OBJECTIVES

Remedial action objectives (RAOs) are media-specific goals
to protect human health and the environment. These objec-
tives are based on available information and standards such
as applicable  or relevant  and appropriate  requirements
(ARARs), to-be-considered  (TBC) guidance, and risk-based
levels established in the risk assessment.

The  overall  remedial  action objective is to ensure  the
protection  of human health  and  the environment.   The
general remedial objectives identified for the Site are to:

           1.   prevent exposure, to contaminated soils and
               contaminated groundwater, to human and
               ecological receptors;
           2.   minimize migration  of  contaminants from
               soils to groundwater;
           3.   restore the  aquifer(s) to beneficial use;
           4.   ensure that hazardous  constituents within
               the soil and groundwater  meet acceptable
               levels consistent with reasonably anticipated
               future use;  and
           5.   minimize  potential  human  contact  with
               waste constituents.

Preliminary Remediation Goals
Preliminary Remediation Goals (PRGs) were selected based
on federal and state promulgated ARARs, risk-based levels,
background  concentrations, and guidance values.  These
PRGs were  then used as a benchmark in the technology
screening, alternative  development and screening,  and
detailed  evaluation  of alternatives   presented  in   the
subsequent  sections of the  FS Report.   The PRGs for
groundwater and soil are shown in Table 1 below.

Table 1: Preliminary Remediation Goals
identified
compounds
Contaminant
Benzene
Chlorobenzene
Ethylbenzene
Toluene
Xylenes
2-amino pyridine
Pyridine
Alpha picoline
Acetone
Aniline
Pyridine-related
tentatively
PRG for
Groundwater
(ug/L) *
1
5
5
5
5
1
50
50
50
5
50
PRG for Soils
(ug/kg)
60***
1,100***
1 ,000 ***
700 ***
1 ,600 ***
400 ****
400 ****
575 ****
50 ***
1,510****
400 ****
* Groundwater cleanup levels for organic COCs are based
on  the  more  conservative  of the  Federal  Maximum
Contaminant Levels (MCLs) and the New York Ambient
Groundwater Standards and Guidance Values (NYSDEC
TOGs 1.1.1, June 1998).
*** The  values shown are from NYSDEC Subpart 375:
Remedial Program Soil Cleanup Objectives.
**** The values shown were derived by NYSDEC based on
the  Division  Technical and Administrative  Guidance
Memorandum: Determination of Soil Cleanup Objectives
and  Cleanup  Levels,  Division  of  Hazardous  Waste
Remediation, January 24, 1994.
SUMMARY OF REMEDIAL ALTERNATIVES

CERCLA Section 121(b)(1), 42 U.S.C. Section 9621 (b)(1),
mandates that remedial actions  must be protective of
human health and the environment, cost-effective, comply
with other statutory laws (ARARs), and utilize permanent
solutions  and alternative  treatment  technologies and
resource recovery  alternatives 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 Section 121(d), 42  U.S.C.  Section 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 Section 121(d)(4),42U.S.C.
Section 9621 (d)(4).

The objective of the feasibility study (FS) was to identify
and evaluate cost-effective remedial action  alternatives
which would minimize the risk to public  health and  the
environment  resulting   from  soil  and groundwater
contamination at the site.

Detailed descriptions  of  the  remedial  alternatives  for
addressing the contamination associated with the site can
be found  in the FS report. This document presents  a
summary of the six soil remediation alternatives and  five
groundwater remediation alternatives that were evaluated.

The remedial alternatives are described below.

Common Elements for All Alternatives

All  alternatives  would  include   institutional  controls.
Specifically,   an   environmental  easement/restrictive
covenant would be filed in the property records of Orange
County.  The easement/covenant would, at a minimum,
require:   (a) with  the exception of Alternative  S6  -
Excavation  and   Off-Site  Disposal,   restricting  any
excavation below the soil  surface layer  in those  areas
undergoing remediation, unless the excavation activities
are in compliance with an EPA approved site management
plan; (b) restricting new construction at the Site unless an
evaluation of the potential for vapor intrusion is conducted
EPA Region II - July 2007
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and mitigation, if necessary, is performed in compliance with
an EPA approved site management plan;  (c) restricting the
use of groundwater as a source of potable or process water
unless groundwater quality standards are met; and (d) the
owner/operator to complete and submit periodic certifications
that the institutional and engineering controls are in place.

A Site Management Plan (SMP) would  be developed to
address soils and groundwater at the Site. The SMP would
provide for  the proper management  of all  Site  remedy
components post-construction, such as institutional controls,
and shall also include: (a) monitoring of Site groundwater to
ensure that,  following the soil excavation, the contamination
is attenuating and groundwater quality continues to improve;
(b)  identification of any use restrictions  on  the Site; (c)
necessary provisions for implementation of the requirements
of the above easement/covenant; and (d)  provision for any
operation and maintenance required of the components of
the remedy.

In addition, physical controls, such as regular maintenance of
the  perimeter fence, would be implemented to restrict Site
access  and  thereby  prevent the  potential  exposure to
chemicals present in the  soils in the vicinity of the former
lagoons.

Finally, all groundwater remedial alternatives would include
the requirement that those  private wells, in the vicinity of the
Site, currently being monitored  in relation to this  Site will
continue to   be  monitored on  an ongoing  basis.   The
frequency of the residential well sampling will be determined
during Remedial Design.
Soil Remedial Alternatives

Alternative S1 - No Action

Capital Cost:                  $0

Annual Cost:                  $0

Present-Worth Cost:            $0

Construction Time:             Not Applicable


The "No Action" alternative is considered in accordance with
NCP requirements and provides a baseline for comparison
with other alternatives.  If this alternative were implemented,
the current  status of the site would  remain  unchanged.
Institutional  controls would not be  implemented to  restrict
future site development or use. Engineering controls would
not be implemented to prevent site access or exposure to site
contaminants.  Although existing security fencing at the site
would remain, it would not be monitored or maintained under
this alternative.

Alternative S2 - Institutional Controls with Limited Actions

Capital Cost:                  $12,600

Annual Cost:                  $13,550
Present-Worth Cost:

Construction Time:
$217,000

3 months
This alternative is comprised of the institutional controls
mentioned  previously.  Physical  controls would also  be
used to eliminate the future potential for on-Site exposures.
A perimeter security fence (with appropriate warning signs)
has been constructed to restrict Site access and thereby
prevent the potential exposure to chemicals present in the
surface soils in the vicinity of the former lagoons. The Site
security fencing and warning  signs would be routinely
inspected and maintained at the Site to restrict access to
the Site.

Institutional controls as the sole remedy would not be an
adequate substitute for engineering controls at this  Site.
This Alternative would  not achieve the Remedial Action
Objectives. Accordingly, this alternative will not be retained
for further consideration. Institutional controls, however, as
described   in  this   alternative,  will  be  retained  as
components of other remedial alternatives.

Alternative   S3  -  Installation  of a  Cap  Over  the
Contaminated Soils
Capital Cost:

Annual Cost:

Present-Worth Cost:

Construction Time:
$2,290,000

$24,000

$2,647,000

8 months
Underthis alternative, a cap would be constructed overthe
area with contaminated soils. This area has soils above
the  water table with  concentrations  exceeding  the
NYSDEC Soil Cleanup Objectives.

Chemicals in the soils above the water table would  be
contained  by a  cap.   The  cap would  serve to inhibit
infiltration  of precipitation and thereby reduce leaching of
chemicals from the soils to groundwater, and, therefore,
reduce chemical  concentrations in the overburden and
bedrock groundwater overtime. The decreased infiltration
over the former lagoon area would result in a lowering of
the water table in the overburden aquifer directly  beneath
the Site and, hence, further reduce the chemical migration
from this area via groundwater transport.

Alternative S4 - Excavation and On-Site SVE and Biocell
Capital Cost:

Annual Cost:

Present-Worth Cost:
$2,388,000

$406,000

$3,119,000
Construction Time:             2 years
This alternative would involve the excavation of the soils
within the former lagoons and treatment of the soils with
concentrations  of Contaminants of  Concern  (COCs)
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exceeding the NYSDEC  Soil Cleanup Objectives on-Site
utilizing SVE and biological degradation within an engineered
below-grade biocell.  Excavated  soils would be treated to
reach target cleanup levels.

The soils would be treated within the biocell by installing
perforated pipes within multiple layers of the biocell.  The
perforated pipes would be connected to a blower unit to draw
air through the piles; contaminants would be volatilized into
this air. The air would be treated,  if necessary, using carbon
adsorption, prior to being recirculated or exhausted to the
atmosphere.  Nutrients would be added to the treatment
layers as required to enhance biological degradation.

In general, the biocell would be operated in two primary
modes: SVE mode (high airflow rate); and bioremediation
mode (low airflow rate).

During the SVE mode, the system would  be operated at
higher air flow rates which would be selected to optimize the
removal  of  the  volatile  organic   compounds  (VOCs)
constituents using SVE. After the removal rate of the VOCs
decreases to an asymptotic  or nominal rate, the system
would be switched over to the  bioremediation mode. During
the bioremediation mode, the  system  would be operated at
an optimized air flow rate selected to sustain the aerobic
biodegradation  of the remaining VOCs and semi-volatile
organic compounds (SVOCs).

Alternative S5 - In-Situ Soil Vacuum Extraction
Capital Cost:

Annual Cost:

Present-Worth Cost:

Construction Time:
$1,211,000

$460,900

$2,302,000

4 years
This alternative involves the installation of an in situ soil
vacuum extraction system (ISVE) in the area identified for
potential soil remediation.   A drainage swale  would be
constructed along the edge of the treatment area to prevent
surface water run-on to the treatment area.

The soil vapor extraction wells would be strategically placed
within the area of soil to  be treated to ensure that airflow
within the area is maximized.  The  extraction wells would
consist of a screened section of pipe (or pipes) placed in a
permeable packing with the top few feet of the well grouted to
prevent the  short circuit of airflow from the surface.  An
impermeable temporary cap would be placed over the
treatment area to minimize infiltration of precipitation, lower
the water table and increase the volume of the unsaturated
zone, and prevent short circuiting of airflow directly from the
surface.

The  extraction wells would be installed with vacuum and
positive pressures being applied at alternating well locations
to create an induced pressure gradient to move the vapors
through the soil.  Extracted vapors would be treated utilizing
carbon  filters,  if required,  prior to  being reinjected  or
exhausted to the atmosphere. Vapor-phase nutrients would
                              also be injected into the soils, if needed,  to enhance
                              biodegradation.

                              Alternative S6 - Excavation and Off-Site Disposal

                              Capital Cost:                  $11,208,000

                              Annual Cost:                  $22,000

                              Present-Worth Cost:           $11,228,000

                              Construction Time:             1 year
Alternative S6 involves the excavation of soils within the
former  lagoons  containing  COCs  at concentrations
exceeding  NYSDEC  Soil  Cleanup  Objectives.   The
excavated soils would  be  disposed of off Site  at  an
appropriate landfill.

The  Capital  Cost associated with Alternative S6,  as
reported in the FS Report, has a significant range because
it is not exactly known how much of the contaminated soil
would  be classified  as  hazardous waste and  would,
therefore, be more expensive to handle and dispose. The
Capital Cost cited above represents the high end  of the
range. The Capital Cost associated with the low end of the
range is $5,736,000.

Alternative S6  would   include  the   following   major
components:
    •    pre-design investigation;
    •    excavation of on-site soils exceeding soil
        cleanup objectives for the COCs;
    •    post excavation sampling to verify achievement
        of soil cleanup objectives;
    •    disposal of excavated soils at appropriate off-site
        facility (or facilities);
    •    backfilling of excavated areas with clean fill.
                              Groundwater Remedial Alternatives

                              Alternative GW1 - No Action

                              Capital Cost:                  $0

                              Annual Cost:                  $0

                              Present-Worth Cost:           $0

                              Duration Time:                 0 months
                              The No Action alternative was retained for comparison
                              purposes as required by the NCP.  No remedial actions
                              would be  implemented  as  part  of this alternative.
                              Groundwater would continue to migrate and contamination
                              would continue  to  attenuate  through  dilution.   This
                              alternative does not include institutional controls or long-
                              term groundwater monitoring.
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Alternative GW2 - Enhanced Bioremediation with Long-Term
Groundwater Monitoring
Capital Cost:

Annual Cost:

Present-Worth Cost:

Duration Time:
$13,200

$106,700

$528,000

8 years
This alternative involves the manipulation of Site groundwater
conditions to enhance in situ bioremediation of the COCs by
the indigenous microbial  population.  The design details for
enhanced bioremediation would be established following the
removal of the source area soils. The excavated area will be
treated with  oxygenating compounds to create an aerobic
environment and, thereby, stimulate biodegradation within the
area  of  elevated  groundwater contamination.   Multiple
applications  of  the  oxygenating  compounds  may  be
necessary. This will be followed by a long-term groundwater
monitoring program where groundwater samples would be
collected and analyzed regularly in  order to verify that the
concentrations and the extent of groundwater contaminants
are declining.   The exact  frequency  and parameters of
sampling  and  location of any additional monitoring wells
would be  determined during the design phase.  The site-
related COCs  are susceptible to degradation  in aerobic
conditions. To enhance  aerobic biodegradation outside of
the source  area, the  remedial design will consider the
controlled,  location-specific injection(s)  of  oxygenating
compounds into the groundwater contamination plume(s) at
various  locations to  stimulate biodegradation  of COCs.
Multiple injections overtime may also be necessary for this
action to be fully effective.

The groundwater monitoring program would be conducted to
ensure  that  this  remedy  was   protective,   that  the
concentrations of COCs were  attenuating, and to evaluate
the rates of biodegradation/bioremediation (in  both  the
bedrock and overburden aquifers).

Alternative GW3 - Groundwater Extraction and Treatment
(Pump And Treat)
Capital Cost:

Annual Cost:

Present-Worth Cost:

Duration Time:
$1,656,000

$229,000

$3,339,000

13 years
Under this   alternative,  an  overburden   and  bedrock
groundwater   collection  system  would   be   installed
downgradient  of each  area  with  identified  soil  and
groundwater  concentrations above the potential cleanup
levels.  The  components of this alternative  include the
installation   of  several  strategically  located  bedrock
groundwater extraction wells and a water table tile collection
system   installed  in   two   areas  of  the  overburden
(downgradient of the source area to capture  both the north
and south components of the groundwater flow from the
source area). The collection systems would be designed to
minimize the migration of contaminants in groundwater and
to restore the aquifer(s) to beneficial use.  The bedrock
extraction wells would pipe contaminated groundwaterto a
groundwater treatment system for treatment; the tile
collection system would route contaminated groundwater in
the overburden to the  groundwater treatment system for
treatment.  This  alternative would prevent the  potential
migration of chemicals off Site via groundwater transport.
The collected groundwater would be treated via a carbon
adsorption system located along the western edge of the
Site to meet discharge standards as well as water quality
requirements for discharge to Beaverdam Brook.

An ongoing groundwater monitoring program would be
conducted to ensure that this remedy was protective.

Alternative GW4 - Enhanced Bioremediation
                             Capital Cost:

                             Annual Cost:

                             Present-Worth Cost:

                             Duration Time:
                             $332,000

                             $106,700

                             $846,000

                             8 years
This  alternative  involves  the  manipulation  of  Site
groundwater conditions to enhance in situ bioremediation
of the COCs by the indigenous microbial population.  The
design details for enhanced  bioremediation would be
established following the treatment/removal of the source
area soils.  Treatment would involve either the controlled
injection  of  oxygenating compounds  (e.g.,  Oxygen
Releasing Compounds (ORCs)) to enhance biodegradation
of the COCs or the controlled injection of a chemical
oxidizer (e.g., hydrogen  peroxide) and nutrients into the
groundwater contamination plumes to  chemically convert
the organic contamination into nonhazardous compounds.
The preliminary design assumes that 440 injection points
would  be  required  for  the injection  of ORC  into the
overburden groundwater. The area would encompass both
the source area and locations downgradient of the source
area, including both the north and south components of the
groundwater flow.  Multiple injections  over time may be
necessary for this action  to be fully effective.

An ongoing groundwater monitoring program would be
conducted to ensure that this remedy was protective, that
the concentrations of COCs were attenuating,  and to
evaluate  the  rates of biodegradation/bioremediation (in
both the bedrock and overburden aquifers).

Alternative  GW5 - Biosparging

Capital Cost:                  $191,000

Annual Cost:                  $106,700

Present-Worth Cost:           $738,000

Duration Time:                8 years
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Under this alternative, pressurized gas (i.e., oxygen) would
be injected into the groundwater at very low flowrates to
enhance  bioremediation.  Specifically,  the  biosparging
technology considered here is "in situ Submerged Oxygen
Curtain" (iSOC).  This  technology injects supersaturated
oxygen into the groundwater such that oxygen is infused into
groundwater without the formation of bubbles. This prevents
vapors (e.g., the bubbles) from entering the vadose zone.
The vadose zone is that portion of the soil between the land
surface  and the zone of saturation, or, in other words, the
vadose zone extends from the ground surface to the water
table.

An  ongoing  groundwater  monitoring  program  would be
conducted to ensure that this remedy was protective.
EVALUATION OF ALTERNATIVES

In selecting a remedy for a site, EPA considers the factors set
forth in CERCLA §121, 42 U.S.C.  §9621, by conducting a
detailed analysis of the viable remedial alternatives pursuant
to the NCR, 40 CFR §300.430(e)(9) and OSWER Directive
9355.3-01. The detailed analysis consists 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.

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

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

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

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

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

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

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

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

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

A  comparative  analysis  (one  for soils  and one  for
groundwater)  of these alternatives,  based upon  the
evaluation criteria noted above, follows.

Comparative Analysis for Soils

       Overall Protection of Human  Health and  the
       Environment

       Alternatives S1 and S2 would not be protective of
       human health  and the  environment, since they
       would not actively address the contaminated soils,
       which present unacceptable risks of exposure and
       are  a  source of groundwater  contamination.
       Alternative S3 would be protective of human health
       and the environment in that the cap would prevent
       exposure to contaminated soil  and  would also
       serve to minimize infiltration of precipitation and
       thereby reduce leaching of chemicals from  the
       soils    to   groundwater,    hence,    reducing
       contamination  of the  groundwater; however,
       Alternative  S3 would  not  actively  remediate
       contaminated soil.  Alternatives  S4,  S5, and S6
       would be protective  of human  health and  the
       environment, since each alternative relies upon a
       remedial strategy or treatment technology capable
       of eliminating human exposure and removing the
       source of groundwater contamination.

       Compliance with ARARs

       The soil cleanup objectives used for the Site  are
       based on NYSDEC values (NYSDEC Subpart375:
       Remedial Program  Soil Cleanup Objectives  -
       and/or-  NYSDEC's  Division   Technical  and
       Administrative     Guidance     Memorandum:
       Determination  of  Soil Cleanup  Objectives and
       Cleanup Levels, Division  of Hazardous Waste
       Remediation, January 24, 1994.)  These NYSDEC
       soil cleanup objectives were utilized as PRGs for
       the site-related contaminants.
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       Since the contamination  in the soils would not be
       addressed under Alternatives S1 and S2, they would
       not achieve the soil cleanup objectives.  While the
       cap installed under Soil Alternative S3 would comply
       with RCRA design standards, this alternative would
       not actively remediate contaminated soil  and, as
       such, would not achieve the soil cleanup objectives.
       Alternatives S4 and S5 would each attain the soil
       cleanup objectives specified.  Alternative S6 would
       involve   the  excavation  and  removal  of  the
       contaminated soil from the site, and thereby achieve
       soil cleanup objectives for the Site property.

       Alternatives S4 and S6 both involve  the excavation
       of contaminated soils  and would, therefore, require
       compliance  with  fugitive  dust and VOC emission
       regulations.  In addition, Alternative S6 would be
       subject to New York State and federal  regulations
       related   to   the  transportation  and    off-site
       treatment/disposal of wastes.   In the  case  of
       Alternatives S4 and S5, compliance with air emission
       standards would  be required  for the SVE  or ISVE
       system.  Specifically,  treatment of off-gases would
       have to meet the substantive requirements of New
       York State Regulations for Prevention and Control of
       Air Contamination and Air Pollution (6 NYCRR Part
       200,  et  seq.)  and comply with the  substantive
       requirements of other  state and federal air emission
       standards.

       Lonq-Term Effectiveness and Permanence

       Alternatives S1 and S2 would  not involve any active
       remedial measures, and, as such, not be effective in
       eliminating the potential exposure to contaminants in
       soil and would result  in the continued migration of
       contaminants  from the soil  to  the groundwater.
       Alternative 3 involves  installation of  a landfill cover
       which would eliminate the potential exposure  to
       contaminants in the soil and also reduce leaching of
       contaminants   from   the  soil  to  groundwater.
       Alternatives S4, S5, and S6 would each be effective
       in the long term by either removing the contaminated
       soils from the Site or treating them in place.

       Reduction in Toxicity,  Mobility or Volume

       Alternatives S1 and S2 would provide no reduction in
       toxicity,  mobility, or volume of  contaminants.
       Alternative  S3 would reduce the  migration  of
       contaminants from soil to groundwater but would not
       provide  a  reduction   in  toxicity  or volume  of
       contaminants. Alternatives S4 and S5 would reduce
       toxicity,  mobility,  and  volume of contaminants
       through on-site treatment. Under Alternative S6, the
       toxicity, mobility,  and  volume  of the contaminants
       would be eliminated by removing contaminated soil
       from the Site property.

       Short-Term Effectiveness

       Alternative S1 and S2 do not include any  physical
       construction measures in any areas of contamination
       and, therefore, would not present any  potential
adverse impacts to on-property workers or the
community as a result of their implementation.
Alternatives S3,  S4, S5,  and S6 could result in
some adverse  impacts  to  on-property workers
through dermal contact and inhalation related to
the installation of the remedial systems associated
with  each  of these alternatives.  Alternatives S4
and S6 involve significant excavation activities that
would need to be properly managed to prevent or
minimize  adverse  impacts.    For  instance,
excavation activities would  need to be properly
managed to prevent transport of fugitive dust and
exposure of workers through dermal contact and
by inhalation of volatile organic compounds in the
air.   Noise from  the  treatment unit  and  the
excavation work associated with Alternatives S3,
S4,  S5,  and  S6  could  present some  limited
adverse impacts to on-property workers, while
truck traffic related to Alternative S6 could provide
nuisance impacts (e.g., noise and traffic) to nearby
residents. In addition, interim and post-remediation
soil sampling activities would pose some risk to
on-property  workers.  The  risks to on-property
workers and nearby residents under all of the
alternatives  could,  however,  be mitigated  by
following appropriate health  and safety protocols,
by exercising sound engineering practices, and by
using proper protective equipment.

Alternatives  S4  and  S6  involve  significant
excavation  activities that  would  need  to  be
properly managed to prevent or minimize adverse
impacts. For instance, excavation activities would
need to be properly managed to prevent transport
of fugitive dust and exposure of workers to volatile
organic compounds in the air.

Since  no  actions  would be  performed under
Alternative S1, there would be no implementation
time.   Since only  limited  actions  would  be
performed under Alternative S2, there would  be
very little implementation time.  It is estimated that
Alternative S3 would require 3 months to complete
the landfill  cap,  Alternative S4 would require 2
years to complete, Alternative S5 would require 4
years to complete, and Alternative S6 would
require approximately one year to complete.

Implementability

Alternatives S1  and S2 would be the easiest soil
alternatives to implement  in that there are no field
activities to undertake.

Alternatives S3, S4, S5, and S6 would all employ
technologies known to be  reliable (though the
biocell proposed as a component of Alternative S4
is a  lesser known technology relative to the site-
related  COCs)  and  that   can  be   readily
implemented.  In addition, equipment, services,
and  materials needed for these alternatives are
readily available, and the  actions under these
alternatives  would be administratively  feasible.
Furthermore, sufficient facilities are available for
EPA Region II - July 2007
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       the treatment/disposal of the excavated materials
       under Alternative S6.

       Monitoring the effectiveness of the SVE system (in
       Alternative S4), and the ISVE system (in Alternative
       S5) would be easily accomplished through soil and
       soil-vapor sampling and analysis.  Under Alternatives
       S4, S5,  and S6, determining  the extent  of soil
       cleanup would be easily accomplished through post-
       excavation soil sampling and analysis.

       Cost
       The  estimated  capital,  annual  operation  and
       maintenance (O&M)  (including  monitoring),  and
       present-worth costs for each of the soil remediation
       alternatives are presented in Table 2. All costs are
       presented in U.S. Dollars.

Table 2: Cost Analysis for Soil  Remediation Alternatives
Remedial
Alternative
S1
S2
S3
S4
S5
S6
Capital
Cost
0
12,600
2,290,000
2,388,000
1,211,000
5,736,000
Annual
O&M
Cost
950
13,550
24,000
406,000
460,900
22,000
Present
Worth
Cost
15,000
217,000
2,647,000
3,119,000
2,302,000
5,756,000
Construction
Time
No time
Months
Several
months to
install cap
2 years
4 years
1 year
       According to the capital cost, O&M cost and present
       worth cost estimates, Alternative S1 has the lowest
       cost and Alternative S6 has the highest cost when
       comparing all Alternatives.
Comparative Analysis for Groundwater

       Overall  Protection  of Human  Health  and  the
       Environment

       All alternatives except GW1 would provide adequate
       protection of human health and the environment. As
       noted above in the risk assessment section, there
       are unacceptable human health cancer risks or non-
       cancer  health  hazards  associated  with   the
       groundwater contamination at the site.  Though no
       private wells exist on the Site property, the future  use
       of groundwater  as a drinking  water  source is
       consistent with the State  use designation of  the
       aquifer and such use would present unacceptable
       present and future carcinogenic and noncarcinogenic
       risks at the Site.  These calculated risks to human
       health require  EPA to  enact remedial measures to
       reduce the  risks  associated with  the observed
       contamination  and restore  the groundwater to
       beneficial use.  EPA believes that Alternatives GW2,
       GW4 and  GW5  would   ultimately  provide  full
protection  of  human   health  by   reducing
contaminant concentrations to cleanup objectives.
Alternative GW3 would also reduce contaminant
concentrations through treatment, would prevent
migration of chemicals  off-Site via  groundwater
transport, and, ultimately, restore the aquifer(s) to
best use.

Compliance with ARARs

EPA and  the New York State Department  of
Health (NYSDOH) have promulgated  health-based
protective  MCLs  (40   CFR  Part  141,  and
10NYCRR, Chapter 1  and Part  5), which are
enforceable standards for various drinking water
contaminants (chemical  specific ARARs).  The
aquifer at the Site  is classified as Class GA  (6
NYCRR 701.18), meaning that it is designated as
a potable water supply.

Alternative  GW1 does not include any active
groundwater  remediation; contamination in the
groundwater would likely attenuate  naturally,  to
some degree, particularly after a  soil remedy is
implemented. Alternatives GW2, GW4, and GW5
involve  the manipulation of  Site  groundwater
conditions to enhance in situ bioremediation of the
COCs by the indigenous microbial population, and,
thereby,  break-down   the   COCs  into  non-
hazardous compounds.  Alternatives GW2, GW4,
and GW5, each focus on the most contaminated
regions  of the bedrock and  overburden  aquifers
(e.g., under and immediately downgradient of the
source  area)  and, as such,  would decrease the
amount  of time needed  to  achieve   cleanup
objectives.      Following   implementation   of
Alternatives GW2, GW4 or GW5,  it is estimated
that ARARs would be achieved throughout the Site
within  ten years  after  the  soil  remedy  is
implemented.      Under   Alternative   GW3,
groundwater would be  extracted  from  both the
bedrock and the overburden aquifers, treated by a
carbon   adsorption  system, and  discharged  to
Beaverdam Brook.  The discharge to Beaverdam
Brook would comply with surface water discharge
requirements  and  the  disposition of  treatment
residuals would have to be consistent with the
Resource   Conservation  and  Recovery  Act
(RCRA). Alternative  GW3  would  prevent the
potential migration  of  chemicals  off  Site via
groundwatertransport and, as such, ARARs would
be  met  downgradient  of  the   groundwater
containment system (e.g., off the site  property);
ultimately,  treatment  of  the  contaminated
groundwater would achieve ARARs within the site
property and would restore the aquifer(s) to best
use.

For Alternatives  GW2,  GW3, GW4, and GW5,
compliance with ARARs would be demonstrated
through   a  long-term  groundwater monitoring
program.
EPA Region II - July 2007
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       Long-Term Effectiveness and Permanence

       Once the source control remedy is implemented, it is
       anticipated that all of the groundwater alternatives
       would  achieve  groundwater  ARARs,  although
       Alternative GW1  would be expected  to take the
       longest. The time to achieve groundwater standards
       would  vary for the other alternatives due to the
       complex nature of the subsurface environment.

       Alternative GW3  would  prevent the  potential
       migration  of  chemicals off Site via  groundwater
       transport,  but would take longer to achieve cleanup
       objectives than Alternatives GW2, GW4, or GW5.
       As Alternatives GW2, GW4, and GW5 focus on the
       most contaminated regions of the bedrock and
       overburden aquifers, these alternatives would  be
       expected to achieve aquifer restoration more quickly
       than the other alternatives.

       Reduction in Toxicity, Mobility or Volume

       Alternatives GW2, GW4, and GW5  would each
       reduce the volume and toxicity of the contaminants
       through treatment by chemically breaking down the
       bulk of the dissolved VOC and SVOC contamination
       as it migrates through the aquifer.  The VOC and
       SVOC  contaminants   would   be  changed  into
       degradation products.

       Alternative GW3 would reduce the toxicity, mobility,
       and  volume of contaminated groundwater through
       removal and treatment with the goal of restoring the
       aquifers to their beneficial uses.

       GW1  provides no further reduction  in  toxicity,
       mobility or volume of  contaminants of any media
       through treatment. Following implementation of the
       source area remedy, natural attenuation processes
       would likely occur to some degree even under this
       alternative.   Future risks  posed  by  the  site will
       depend on future site usage.

       Short-Term Effectiveness

       Alternative GW1 presents virtually no change to the
       short-term  impacts to human  health  and  the
       environment  since  no  construction  or active
       remediation is involved. Alternatives  GW2, GW3,
       GW4,  and GW5  each present some risk to on-
       property workers  through  dermal contact and
       inhalation   from    activities    associated   with
       groundwater remediation.  Specifically, construction
       and  remedial  activities  required  to  implement
       Alternatives GW2, GW4, and GW5 would potentially
       pose a risk of worker exposure to the oxygenating
       compound(s) when injected into  the aquifer.  The
       possibility of having to readminister  oxygenating
       compound(s)  in future injections is likely. Alternative
       GW3 would potentially result in  greater short-term
       exposure  to  contaminants to  workers who install
       extraction wells and the groundwater tile collection
       system, as well  as come  into  contact with the
       treatment system. In  addition,  under  Alternatives
       GW2,  GW3, GW4,  and GW5,  some  adverse
       impacts would  result from disruption  of traffic,
       excavation  activities, noise,  and fugitive  dust
       emissions.  However, proper health and safety
       precautions would minimize short-term exposure
       risks as well as disturbances.

       Implementability

       Alternative GW1 would be the easiest groundwater
       alternative to implement, since it would require no
       activities.   Alternative GW3 would be the  most
       difficult alternative to implement in that it would
       require the construction  of  a groundwater
       extraction system including piping and a tile water
       collection  system.   Alternative  GW2 would  be
       easier to implement than Alternatives GW4 and
       GW5.  The services and materials necessary for
       each of the groundwater alternatives are readily
       available.  Under Alternatives GW2, GW3, GW4,
       and  GW5,  groundwater  sampling  would  be
       necessary to  monitor treatment  effectiveness.
       Each   of  the  alternatives  have  been  proven
       effective for most,  if not all,  of the  COCs  in
       groundwater.

       Cost

       The  estimated   capital, annual  operation and
       maintenance (O&M)  (including monitoring), and
       present-worth   costs   for  each  of  the   soil
       remediation alternatives are presented in Table 3.
       All costs are presented in U.S. Dollars.

Table 3: Cost Comparison for Groundwater Remediation
Alternatives
Remedial
Alternative
GW1
GW2
GW3
GW4
GW5
Capital
Cost
0
13,200
1,656,000
332,000
191,000
Annual
Cost
950
106,700
229,000
106,700
106,700
Present
Worth
15,000
528,000
3,339,000
846,000
738,000
Duration
of
Operation
N/A
8 years
1 3 years
8 years
8 years
       According to the capital cost,  O&M  cost  and
       present worth cost estimates, Alternative GW1 has
       the lowest cost and  GW3 has the highest cost
       when comparing all alternatives.

       State Acceptance

       NYSDEC concurs with the preferred remedy.

       Community Acceptance

       Community acceptance of the preferred remedy
       will be assessed in the ROD following review of
       the  public  comments received  on the  Post
       Decision Proposed Plan.
EPA Region II - July 2007
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PREFERRED ALTERNATIVES
Basis for the Remedy Preference
Based upon an evaluation of the various alternatives, EPA
recommends employing Alternative S4 (Excavation and On-
Site  SVE  and Biocell) to remediate the source area and
Alternative GW2 (Enhanced Bioremediation with Long-Term
Groundwater Monitoring) to remediate  the groundwater.
Implementation  of  these  alternatives  would  include
institutional controls to restrict groundwater use and prevent
disturbance  of the soils  in the biocell until groundwater
ARARs and/or soil cleanup objectives are met.

Specifically, an environmental easement/restrictive covenant
would be filed in the property records of Orange County. The
easement/covenant would, at a minimum, require:   (a)
restricting  any excavation below the soil surface layer in the
area of the biocell, unless the excavation activities are in
compliance with an EPA-approved site management plan; (b)
restricting  new construction at the Site unless an evaluation
of the potential for vapor  intrusion  is conducted  and
mitigation, if necessary, is performed in compliance with an
EPA approved site management plan; (c) restricting the use
of groundwater as a source of potable  or  process water
unless groundwater quality standards are met;  and (d) the
owner/operator to complete and submit periodic certifications
that the institutional and engineering controls are in place.

A  Site Management  Plan (SMP) would be developed  to
address soils and groundwater at the Site. The SMP would
provide for  the proper  management  of all Site  remedy
components post-construction, such as institutional controls,
and shall also include: (a) monitoring of Site groundwater to
ensure that, following the soil excavation, the contamination
is attenuating and groundwater quality continues to improve;
(b) identification of any use  restrictions  on the Site;  (c)
necessary provisions for implementation of the requirements
of the above easement/covenant; and (d) provision for any
operation and maintenance required of the components of
the remedy.

Upon completion of remediation, no hazardous substances
would remain above levels that would prevent unlimited use
or unrestricted exposure.  Under the preferred remedy, EPA
would conduct reviews of the site at least once every five
years  until  groundwater  remediation  has restored the
aquifer(s) to drinking water quality standards and soil cleanup
objectives  are met.
EPA believes that Alternative S4 is the most cost-effective
option  for the contaminated soils given the evaluation
criteria and reasonably anticipated future land use. While
Alternative S4 may involve potential short-term community
impacts  in  the form  of  nuisances associated  with
construction (e.g., noise and truck traffic), Alternative S4
would be protective of human health and the environment.
Furthermore, Alternative S4 would provide a permanent
solution, and would achieve soil cleanup objectives forthe
site-related COCs in the shortest amount of time and in the
most cost-effective manner. Therefore, EPA and NYSDEC
believe  that Alternative S4 would  effectuate the  soil
cleanup while providing the best balance of tradeoffs with
respect to the evaluating criteria.

Alternative  S1  was  not  identified  as the preferred
alternative because it calls for no action and would not be
protective of human health and the environment. Similarly,
Alternative 2 would only provide limited action by imposing
institutional  controls  and  site  fencing  and  warning
maintenance  signs.   Alternative 3  was  not proposed
because, while it is slightly less expensive than Alternative
4, it calls for containment of the waste constituents and
provides no treatment of the contamination. Alternative 5
was not proposed because, while it includes the soil vapor
extraction technology of Alternative 4, it does not include
the biological treatment component, which  EPA believes
will  be  effective  in  addressing  the  pyridine-related
compounds. Alternative 6 was not proposed because it
would not appear to be cost-effective compared to the
other alternatives.

EPA  is  proposing  Alternative GW2 to  address  the
contaminated groundwater because the Agency believes it
would be protective of human health and the environment
and would achieve the ARARs in the  most  cost-effective
manner.  Alternative GW1 would rely solely on natural
processes to restore groundwater quality to beneficial use,
and,  as such, would take significantly longer than the
preferred alternative. While Alternative GW3 would prevent
the  potential   migration   of  chemicals  off Site  via
groundwater transport, it  would take longer to achieve
cleanup objectives and would cost significantly more than
Alternatives GW2,  GW4, and  GW5.  While Alternatives
GW2, GW4, and GW5 are similar in that they each involve
the addition of oxygen into the groundwater environment to
enhance biodegradation of the  contaminants, Alternative
GW2  would  be easier to implement then the  other
alternatives, and is expected to cost significantly less.

Therefore, EPA and NYSDEC believe that the combination
of Alternatives S4 and GW2 would successfully remediate
the contaminated soils and expedite  the remediation of
contaminated groundwater at the Site, while providing the
best  balance of tradeoffs among the alternatives  with
respect to  the evaluation  criteria.   Furthermore,  the
preferred remedies would utilize permanent solutions and
treatment technologies to the maximum extent practicable.
EPA Region II - July 2007
                                    Page 14

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                                                    SOURCE: USGS MAYBROOK NEW YORK AND
                                                         GOSHEN NEW YORK QUADRANGLE MAP
                             LOCATION
          SOURCE: RAND McNALLY ROAD ATU\S
                                                                     figure 1
                                                               SITE LOCATION
                                                       FORMER LAGOON SITE
                                                       Hamptonburgh, New York
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