EPA/ROD/R02-00/527
2000
EPA Superfund
Record of Decision:
JONES CHEMICALS, INC.
EPA ID: NYD000813428
OU01
CALEDONIA, NY
09/27/2000
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RECORD OF DECISION
Jones Chemicals, Inc. Superfund Site
Caledonia, Livingston County, New York
United States Environmental Protection Agency
Region II
New York, New York
September 2000
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DECLARATION FOR THE RECORD OF DECISION
SITE NAME AND LOCATION
Jones Chemicals, Inc. Superfund Site
Caledonia, Livingston County, New York
Superfund Site Identification Number: NYD000813428
Operable Unit 11
STATEMENT OF BASIS AND PURPOSE
This Record of Decision (ROD) documents the U.S. Environmental
Protection Agency's selection of a remedy for the Jones Chemicals, Inc.
Superfund site (Site), which is chosen in accordance with the require-
ments of the Comprehensive Environmental Response, Compensation,
and Liability Act of 1980, as amended (CERCLA), 42 U.S.C. §9601 et
seq., and the National Oil and Hazardous Substances Pollution
Contingency Plan,40CFR Part 300. This decision document explains the
factual and legal basis for selecting the remedy for the Site. The
attached index (see Appendix III) identifies the items that comprise the
Administrative Record upon which the selection of the remedy is based.
The New York State Department of Environmental Conservation was
consulted on the planned remedy in accordance with CERCLA Section
121(f), 42 U.S.C. §9621(f), and it concurs with the selected remedy (see
Appendix IV).
ASSESSMENT OF THE SITE
Actual or threatened releases of hazardous substances from the Site, if
not addressed by implementing the response action selected in this ROD,
may present an imminent and substantial endangerment to public health,
welfare, or the environment.
This response action applies a comprehensive approach; therefore, only one operable unit is required
to remediate the site.
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DESCRIPTION OFTHESELECTED REMEDY
The major components of the selected remedy include the following:
• Treatment of soils in the Former Solvent Tank Source Area at the
JCI Jones Chemicals, Inc. (Jones) plant grounds exceeding .New
York State soil cleanup objectives by in-situ soil vapor extraction;
• Extraction of contaminated ground water in the Former Solvent Tank
Source Area utilizing a network of recovery wells in the overburden
and bedrock aquifers;
Treatment of the extracted groundwater with the existing air
stripper, which allows for the utilization of the treated water as
noncontact cooling water within the Jones plant, and discharge of
the noncontact cooling water to the on-Site lagoons until
groundwater standards in the Former Solvent Tank Source Area are
achieved;
In-situ treatment of the dense nonaqueous phase liquid (DNAPL)
in the aquifer under lying the Former Sol vent Tank Source Area2 with
an oxidizing agent, such as potassium permanganate or hydrogen
peroxide;
• Continued extraction and treatment of contaminated groundwater
from the North Well;
Discontinued pumping from the West Well to eliminate the potential
to draw contaminants to deeper water-bearing zones;
Monitored natural attenuation of the contaminated groundwater
located outside the Former Solvent Tank Source Area and beyond
the influence of the North Well; and
• Implementation of institutional controls (i.e., deed restrictions) to
limit future on-Site groundwater use to nonpotable purposes until
groundwater cleanup standards are achieved.
2 The magnitude of the tetrachloroethylene(PCE) concentrations in the bedrock aquifer in the Former
Solvent Tank Area indicates the potential presence of such PCE in the form of a DNAPL, a
"principal threat waste." As noted above, this "principal threat waste" will be treated via the in-well
injection of an oxidizing agent.
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During the design phase, samples will be collected to- optimize the
placement of the extraction wells in the Former Solvent Tank Source Area
and to better characterize the extent of the DNAPL contamination.
As part of a long-term groundwater monitoring program, groundwater
samples will be collected and analyzed quarterly in order to verify that the
level and extent of groundwater contaminants (e.g., volatile organic
compounds) are declining and that conditions are protective of human
health and the environment. In addition, biodegradation parameters
(e.g., oxygen, nitrate, sulfate, methane, ethane, ethene, alkalinity, redox
potential, pH, temperature, conductivity, chloride, and total organic
carbon) will be used to assess the progress of the degradation process.
If it is determined that monitored natural attenuation is not effective in
restoring groundwater quality outside of the Former Solvent Tank Source
Area in a reasonable time frame, then remedial actions, such as
enhanced reductive dechlorination3 or groundwater extraction and
treatment, may be implemented.
DECLARATION OF STATUTORY DETERMINATIONS
The selected remedy meets the requirements for remedial actions set
forth in CERCLA Section 121, 42 U.S.C. §9621, in that it: 1) is protective
of human health and the environment; 2) meets a level or standard of
control of the hazardous substances, pollutants and contaminants, which
at least attains the legally applicable or relevant and appropriate
requirements under federal and state laws; 3) is cost-effective; and 4)
utilizes permanent solutions and alternative treatment (or resource
recovery) technologies to the maximum extent practicable. In keeping
with the statutory preference for treatment that reduces toxicity, mobility,
or volume of contaminated media as a principal element of the remedy,
the contaminated groundwater will be collected and treated. In addition,
the contaminated soil in the Former Solvent Tank Source Area and the
DNAPL in the aquifer underlying the Former Solvent Tank Source Area
will be treated in-situ.
This remedy will result in the reduction of hazardous substances,
pollutants, or contaminants on-Site to levels that will permit unlimited use
of and unrestricted exposure to the Site. However, because it may take
more than five years to attain cleanup levels in the groundwater, a Site
Under this process, microbes remove the chlorine from the volatile organic compounds, allowing the
compounds to further degrade into carbon dioxide and water.
HI
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review may be conducted no less than once every five years after
initiation of the remedial action to ensure that the remedy is, or will be,
protective of human health and the environment.
ROD DATA CERTIFICATION CHECKLIST
The ROD contains the remedy selection information noted below. More
details may be found in the Administrative Record file for this Site.
Chemicals of concern and their respective concentrations (see
ROD, pages 5-7);
• Baseline risk represented by the chemicals of concern (see ROD,
pages 8-13);
• Cleanup levels established for chemicals of concern and the basis
for these levels (see ROD, Appendix II, Table 7);
How source materials constituting principal threats are addressed
(see ROD, pages 7-8);
• Current and reasonably-anticipated future land use assumptions
and current and potential future beneficial uses of groundwater
used in the baseline risk assessment and ROD (see ROD, page 8);
• Potential land and groundwater use that will be available at the Site
as a result of the selected remedy (see ROD, page 36);
• Estimated capital, annual operation and maintenance, and total
present-worth costs, discount rate, and the number of years over
which the remedy cost estimates are projected (see ROD, pages 38-
39); and
• Key factors that led to selecting the remedy (i.e., how the selected
remedy provides the best balance of tradeoffs with respect to the
balancing and modifying criteria, highlighting criteria key to the
decision) (see ROD, pages 33-40).
AUTHORIZING SIGNATURE
Date
RegionaJ/^raministrator
iv
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Site name:
Site location:
MRS score:
RECORD OF DECISION FACT SHEET
EPA REGION II
Jones Chemicals, Inc. Site
Caledonia, Livingston County, New York
33.62
Listed on the NPL:
Record of Decision
Date signed:
Selected remedy:
Capital cost:
Monitoring cost:
Present-worth cost:
Lead
Primary Contact:
Secondary Contact.
Main PRPs
Waste
Waste type:
Waste origin:
Contaminated media:
February 21, 1990
September 27, 2000
In-situ soil vapor extraction of the
contaminated soil, groundwater extraction
and treatment in the source area, in-situ
dense nonaqueous phase liquid treatment,
and monitored natural attenuation of the
groundwater outside the source area.
$844,000
$237,000, annually
$2.3 Million (7% discount rate for 15 years)
EPA
George Jacob, Remedial Project Manager,
(212) 637-4266
Joel Singerman, Chief, Central New York
Remediation Section, (212) 637-4258
JCI Jones Chemicals, Inc.
Volatile organic compounds
On-Site spills
Soil and groundwater
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DECISION SUMMARY
Jones Chemicals, Inc. Superfund Site
Caledonia, Livingston County, New York
United States Environmental Protection Agency
Region II
New York, New York
September 2000
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TABLE OF CONTENTS
PAGE
SITE NAME, LOCATION, AND DESCRIPTION 1
SITE HISTORY AND ENFORCEMENT ACTIVITIES 2
HIGHLIGHTS OF COMMUNITY PARTICIPATION 4
SCOPE AND ROLE OF OPERABLE UNIT 5
SUMMARY OF SITE CHARACTERISTICS 5
Surface and Subsurface Soils 5
Groundwater 6
PRINCIPAL THREAT WASTE 7
CURRENT AND POTENTIAL FUTURE SITE AND RESOURCE USES ... 8
SUMMARY OF SITE RISKS 8
Human Hea It hRisk Assessment 9
Ecological Risk Assessment 12
Basis for Action 13
REMEDIAL ACTION OBJECTIVES 13
DESCRIPTION OF ALTERNATIVES 14
Soil Remedial Alternatives 15
Alternative S-1 15
Alternative S-2 15
Alternative S-3 16
Alternative S-4 17
Groundwater Remedial Alternatives 18
Alternative GW-1 18
Alternative GW-2 18
Alternative GW-3 20
Alternative GW-4 22
COMPARATIVE ANALYSIS OF ALTERNATIVES 22
SELECTED REMEDY 33
STATUTORY DETERMINATIONS 36
DOCUMENTATION OF SIGNIFICANT CHANGES 40
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TABLE OF CONTENTS continued
PAGE
ATTACHMENTS
APPENDIXI. FIGURES • A-l
APPENDIX II. TABLES A-l I
APPENDIXIII. ADMINISTRATIVE RECORD INDEX A-lll
APPENDIX IV. STATE LETTER OF CONCURRENCE A-IV
APPENDIXV. RESPONSIVENESS SUMMARY A-V
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SITE NAME, LOCATION, AND DESCRIPTION
The Jones Chemicals, Inc. site1 (the "Site"), situated in a relatively flat,
sparsely populated, lightly industrialized suburban area of the Village of
Caledonia, includes the JCI Jones Chemicals, Inc. (Jones) plant. The site
is bordered by Iroquois Road to the south, farmlands to the north, and
homes to the east and west (see Figure 1). A construction company and
a printing company are located immediately northwest of the plant. A golf
course, baseball field, and tennis court are present immediately south of
Iroquois Road. The site vicinity to the west and southwest is populated
with light service industries, including hardware stores, gasoline stations,
dry cleaners, restaurants, and other commercial businesses.
There are nine buildings located on the 10-acre manufacturing plant
grounds, consisting of office space, drum storage sheds, interconnected
ware house buildings, a bleach manufacturing building, and a chlorine and
sulfur dioxide repackaging building. The areas around the buildings are
paved with asphalt. The Main Service Railway lines run west to east to
the north of the buildings. A large area south of the buildings, facing
Iroquois Road, is grass-cove red. The area north of the buildings is known
as the "North Property." The eastern portion of the North Property is
covered by gravel; the western portion by grass. Three unlined lagoons
are located to the northwest of the bleach manufacturing building. (See
Figure 2.)
The plant property, which has been used for industrial purposes since
1939, is presently zoned industrial and light industrial; it is anticipated
that the land use will not change in the future2.
The United States Environmental Protection Agency (EPA) is the lead
agency for this Site; the New York State Department of Environmental
Conservation (NYSDEC) is the support agency. The investigatory work at
this Site was performed by Jones, the identified potentially responsible
party (PRP), under an Administrative Order on Consent (AOC) with EPA.
1 Superfund Site Identification Number NYD000813428.
2 Source: Letter from Michelle M. Chapman, Code Enforcement Officer, Village of Caledonia,
Caledonia, New York, to Joel Singerman, Chief, Central New York Remediation Section, EPA, dated
May 23, 2000 (This letter is included in the Administrative Record file for this Site.)
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SITE HISTORY AND ENFORCEMENT ACTIVITIES
Jones purchased the majority of the plant property in 1939, which, at the
time, included an orchard, agricultural fields, and pasture lands. Soon
after the purchase of the property, Jones began the production of sodium
hypochlorite (bleach). In 1942, Jones purchased properties located
adjacent to the plant to the north and east, and began repackaging
chlorine from bulk sources to cylinders and 1-ton containers there.
Titanium tetrachloride was briefly manufactured between 1942 and 1943
for the U.S. Government during World War II for use in smokescreen
operations. Repackaging of anhydrous ammonia and acids began in 1947.
The production of aqua ammonia and bulk storage of hydrochloric,
sulfuric, nitric, and hydrofluosilicic acids started in 1953. Between 1960
and approximately 1977, volatile organic compounds (VOCs), including
tetrachloroethene (PCE), trichloroethene (TCE), toluene, 1,1,1-
trichloroethane (1,1,1-TCA), methylene chloride, and Stoddard solvent,
were repackaged from bulk to smaller containers for sale/distribution.
Aqua ammonia was produced by combining water and ammonia until
1995.
In 1971, Jones began to transport commercial hazardous wastes not
generated by Jones. The hazardous waste materials were temporarily
stored on-Site prior to transport and disposal off-Site. Jones
discontinued the transportation and on-Site storage of hazardous wastes
in 1980.
Repackaging of chemicals from bulk to small containers has been one of
the primary activities at the plant. These repackaged chemicals not only
include the chemicals manufactured atthe plant, butalsothosethatwere
brought in bulk loads for redistribution. Materials brought in bulk form
were generally stored in shipping containers (i.e., railroad tank cars or
tanker trucks), aboveground storage tanks, and underground storage
tanks. The majority of these tanks were taken out of service and removed
between 1981 and 1986.
Commercial activities at the Site presently include the manufacturing of
sodium hypochlorite through the reaction of chlorine and dilute sodium
hydroxide, manufacturing of sodium bisulfite through the reaction of dilute
sodium hydroxide and sulfur dioxide, repackaging and distribution of
chlorine, sulfur dioxide, sodium hydroxide, and various acids, such as
muriatic acid and hydrofluosilicic acid, from bulk to small containers, and
the distribution of various inorganic water treatment chemicals, such as
soda ash and lime.
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The principal waste stream from the plant has been wastewater from tank
washings, floor washings, and other waste liquids from handling and
packaging. This waste stream is first treated by the on-Site elementary
neutralization system through the addition of sulfur dioxide or caustic
soda. The wastewater is then mixed in an approximately 1-to-99 ratio
with noncontact cooling water. This mixture is then discharged to the
infiltration lagoon system in accordance with a New York State Pollutant
Discharge Elimination System (SPDES) permit.
Available records indicate that the sludge that forms in the infiltration
lagoons (which were constructed in the mid-1950s) has been excavated
at least three times. The excavated sludge from the first two excavation
events was spread on the ground in the vicinity of the lagoons, while the
sludge from the third excavation event was disposed of in a municipal
landfill.
VOCs were first reported in July 1981 in the production wells at the plant
and in the discharge water to the lagoons. A subsequent hydrogeologic
investigation by Jones indicated the presence of VOCs in the soil and
groundwater underlying the plant's property. In June 1986, relatively high
concentrations of PCE at 1,160 and 765 micrograms per liter (ug/l) were
detected in the plant's production wells, referred to as the "North Well"
and the "West Well," respectively (see Figure 2). The North Well,
located in the northern portion of the plant property, has a capacity of 300
to 400 gallons per minute (gpm). The West Well, located in the western
portion of the plant, has a capacity of approximately 1 5 gpm. The North
Well and the West Well are screened in the overburden and bedrock
aquifers, respectively.
Throughout the plant's operation, spills occurred during the handling of
many of the above-mentioned chemicals, contaminating the Jones soil
and underlying groundwater.
The Site was proposed for inclusion on the National Priorities List (NPL)
inJune1988;itwas listed onthe NPLin February 1990.
On August 8, 1990, EPA notified Jones that EPA considered Jones a PRP
with respect to the Site, and provided Jones with the opportunity to enter
into an Administrative Order on Consent (AOC) with EPA to perform a
remedial investigation and feasibility study (RI/FS) for the Site to
determine the nature and extent of the contamination at and emanating
from the Site and to identify and evaluate remedial alternatives. In March
1991, Jones entered into an AOC with EPA.
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To comply with its SPDES permit and to collect data for treatability study
work related to the RI/FS, in May 1996, Jones installed an air stripper to
treat the noncontact cooling water from the North Well and the West Well
prior to discharge to the lagoons. Monitoring of the discharge water
indicates that VOCs are below detection limits after treatment.
The final Rl and FS reports, completed by Jones' contractor pursuant to
the 1991 AOC, were delivered to EPA in June and September 1999,
respectively.
HIGHLIGHTS OF COMMUNITY PARTICIPATION
The Rl report, FS report, and Proposed Plan for the Site were made
available to the public in both the Administrative Record and information
repositories maintained at the EPA Docket Room in the Region II New
York City office and two local information repositories: the Village of
Caledonia Library, 31 08 Main Street .Caledonia, New York and the Village
of Caledonia Clerks Office, 30-95 Main Street, Caledonia, New York. A
notice of availability of the above-referenced documents was published
in the Livingston County News on July 20, 2000. A public comment period
was held from July 20, 2000 to August 19, 2000. On August 14, 2000,
EPA conducted a public meeting at the Caledonia-Mumford Central
School, 99 North Street, Caledonia, New York, to present the findings of
the RI/FS and answer questions from the public about the Site and the
remedial alternatives under consideration and the preferred soil and
groundwater alternatives.
The public generally supports the selected remedy. Public comment was
related to Site contaminants, the threat to public and private water
supplies, the risks posed by the Site, the selected soil and groundwater
treatment processes, and the financing of the project. Responses to the
comments received at the public meeting (no written comments were
received) a re in eluded in the Responsiveness Summary (see Append ixV).
Since it is not anticipated that the industrial zoning of the plant property
will change in the future, efforts were not made to solicit the public's
views on the assumptions about reasonably anticipated future land use.
Although it is not likely that the groundwater underlying the plant will be
used for potable purposes in the foreseeable future, at the public
meeting, representatives from EPA solicited community input on the
potential future beneficial groundwater uses at the Site as a whole.
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SCOPE AND ROLE OF OPERABLE UNIT
The National Oil and Hazardous Substances Pollution Contingency Plan
(NCP), 40 CFR Section 300.5, defines an operable unit as a discrete
action that comprises an incremental step toward comprehensively
addressing Site problems. This discrete portion of a remedial response
manages migration, or eliminates or mitigates a release, threat of a
release, or pathway of exposure. The cleanup of a Site can be divided
into a number of operable units, depending on the complexity of the
problems associated with the Site. Operable units may address
geographical portions of a Site, specific Site problems, or initial phase of
an action, or may consist of any set of actions performed over time or any
actions that are concurrent but located in different parts of a Site.
This response action applies a comprehensive approach; therefore, only
one operable unit is required to remediate the Site. The primary
objectives of this action are to control the sources of contamination at the
Site, to minimize the migration of contaminants, to minimize any potential
future health and environmental impacts, and to restore the groundwater
to cleanup standards.
SUMMARY OF SITE CHARACTERISTICS
The purpose of the Rl, conducted from 1991 to 1999, was to determine
the nature and extent of the contamination at and emanating from the
Site. The results of the Rl are summarized below.
Surface and Subsurface Soils
The results of 19 soil samples collected across the Site showed PCE
concentrations ranging from below detection to 330,000 micrograms per
kilogram (ug/kg) and TCE concentrations ranging from below detection to
320 ug/kg. The highest soil concentrations of PCE and TCE were
detected in a 150-foot by 20-foot area located at the Site of a former
aboveground solvent tank (hereinafter, referred to the "Former Solvent
Tank Area"), located in the western portion of the property. (See Figure
3.)
Groundwater
The Site is underlain by two distinct stratigraphic zones, an upper
overburden zone and an underlying bedrock zone, as shown in Figure 4.
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The overburden zone consists of approximately 30 to 70 feet of glacial
deposits (a mixture of gravel, sand, and silt). Groundwater elevations
measured at the Site indicate that the principal ground water flow direction
in the overburden zone is toward the northeast. (See Figure 5.)
Carbonate bedrock (dolomite) is found below the glacial deposits. The
surface of the bedrock slopes steeply to the west. Cores taken at the Site
indicate that the upper portion of the zone (10 feet or less) is highly
weathered and fractured. The ground water yield within the bed rock occurs
primarily in the weathered portion and/or through fractures. Groundwater
elevation data indicates that groundwater flow in the bedrock is both to
the west and northeast. There also appears to be an upward vertical
gradient indicating flow from the deeper to shallower water-bearing
zones. (See Figure 6.)
An approximately 1,500-foot (along the northeast-southwest axis) by 720-
foot (along the north-south axis) groundwater VOC plume, consisting of
primarily PCE, and its degradation products TCE and 1,2-dichloroethene
(1,2-DCE), extends from theFormerSolventTankSourceAreatotheeast
and the northeastern property boundary. Vertically, the contamination
extends to at least 48 feet below the ground surface in the source area.
(See Figure 7.)
Groundwater sampling results from the overburden aquifer in the Former
Solvent Tank Area showed concentrations of PCE and TCE as high as
5,500 ug/l and 130 ug/l, respectively. Although there is groundwater
contamination in the overburden aquifer out side the Former Solvent Tank
Area, it appears that the North Well has helped to limit the migration of
the plume (while 140 ug/l PCE was detected at the North Well, PCE
concentrations significantly taper off beyond it, ranging from below
detection to 22 ug/l). (See Figure 8.)
In the bedrock aquifer in the vicinity of the Former Solvent Tank Area,
PCE and TCE were detected at concentrations as high as 62,000 ug/l and
100 ug/l. respectively. With the exception of the detection of 340 ug/l
PCE in the West Well, relatively low concentrations of PCE and TCE (less
than 10 ug/0 were detected outside the Former Solvent Tank Area. (See
Figure 9.)
Periodic sampling of the Village of Caledonia's water supply wells from
1983 through 1989 showed the presence of PCE, TCE, and 1,1,1-TCA.
In 1991, the Village installed an air stripper to treat the water prior to
distribution. The results from March 21, 2000 sampling indicate that the
contaminant concentrations meet drinking water standards prior to
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treatment3. While the Jones plant's southern boundary is located
approximately 700 feet from the Village of Caledonia's water supply wells,
it has not been determined that the Site was the source of this
contamination. Observing groundwater flow paths would ordinarily allow
a determination as to whether or not the Site was a source of this
contamination. However, since the groundwater flow path has been
altered (the Village took a water supply well out of service in 1994 and
the prolonged pumping of the on-Site production wells has altered the
natural groundwater flow path), such a determination cannot be made.
There are two private residential wells located approximately one mile
from the plant which have shown chlorinated solvent contamination.
NYSDEC installed and is presently maintaining treatment systems on
these wells. The contaminants found in these wells are only slightly
above drinking water standards. Given the low levels of contamination
and considering the distance of the wells from the Site, it is unlikely that
the Site is the source. The source of the contamination of these wells
has yet to be identified.
PRINCIPAL THREAT WASTE
The NCP establishes an expectation that EPA will use treatment to
address the principal threats posed by a Site wherever practicable (NCP
Section 300.430 (a)(1 )(iii)(A)). The "principal threat" concept is applied
to the characterization of "source materials" at a Superfund Site. A
source material is material that includes or contains hazardous
substances, pollutants, or contaminants that act as a reservoir for the
migration of contamination to groundwater, surface water, or air, or acts
as a source for direct exposure. Principal threat wastes are those source
materials considered to be highly toxic or highly mobile that generally
cannot be reliably contained, or would present a significant risk to human
health or the environment should exposure occur. The decision to treat
these wastes is made on a Site-specific basis through a detailed analysis
of alternatives, using the remedy selection criteria which are described
below. This analysis provides a basis for making a statutory finding that
the remedy employs treatment as a principal element.
The magnitude of the PCE concentrations in the bedrock aquifer in the
Former Solvent Tank Area indicates the potential presence of such PCE
3 The sample results are included in Table 1.
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in the form of a DNAPL, a principal threat waste. Since much lower levels
of PCE were detected in groundwater samples collected outside the
Former Solvent Tank Area, it appears that the DNAPL may be limited to
the source area.
CURRENT AND POTENTIAL FUTURE SITE AND RESOURCE USES
The plant property, which has been used for industrial purposes since
1939, is presently zoned industrial and light industrial; it is anticipated
that the land use will not change in the future4.
The groundwater underlying the plant is contaminated. Although the
plant's production wells provide noncontact cooling water for the plant
after treatment, potable water for the plant is obtained from the Village
of Caledonia's well system. Therefore, it is not likely that the
groundwater underlying the plant will be used for potable purposes in the
foreseeable future.
The Jones plant's southern boundary is located approximately 700 feet
from the Village of Caledonia's water supply wells5. Based upon
groundwater sampling results, it appears that the on-plant production
wells are preventing the migration of contaminated groundwater beyond
the property boundaries. Should the on-plant production wells cease to
operate, the migration of contaminated groundwater beyond the plant
boundaries might occur.
SUMMARY OF SITE RISKS
Based upon the results of the Rl, a baseline risk assessment was
conducted to estimate the risks associated with current and future Site
conditions. A baseline risk assessment is an analysis of the potential
adverse human health and ecological effects caused by hazardous
Source: Letter from Michelle M. Chapman, Code Enforcement Officer, Village of Caledonia,
Caledonia, New York, to Joel Singerman, Chief, Central New York Remediation Section, EPA, dated
May 23, 2000. (This letter is included in the Administrative Record file for this Site.)
Although the Village of Caledonia's water supply wells were contaminated in the past, they presently
meet drinking water standards. It has not been determined that the Site was the source of this
contamination.
8
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substance releases from a Site in the absence of any actions to control
or mitigate these under current and anticipated future land uses.
The complete risk information for this Site is available in the following
documents, which are located in the Administrative Record: Health Risk
Assessment, Jones Chemicals, Inc. Facility, Caledonia, New York (LFR
Levine-Fricke, Inc., September 30, 1999) and Jones Chemicals Site Risk
Assessment for a Hypothetical Off-Plant Direct Contact with
Contaminated Groundwater Scenario Where the On-Plant Production
Wells Cease to Operate, Allowing the Migration of Contaminated
Groundwater Beyond the Plant Boundaries (U.S. Environmental
Protection Agency, July 19, 2000).
Human Health Risk Assessment
A Superfund baseline human health risk assessment is an analysis of the
potential adverse health effects caused by hazardous substance exposure
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
the 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.,
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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 out puts 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 noncancer health hazards. The
likelihood of an individual developing cancer is expressed as a
probability. For example, a 10 ' 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"' 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 noncancer HI is that a "threshold level"
(measured as an HI of less than 1) exists below which noncancer health
effects are not expected to occur.
The baseline risk assessment began with selecting chemicals of concern
in the various media that would be representative of Site risks. The
primary COCs include PCE, TCE, and 1,2-DCE in the soil and
groundwater media (see Table 2).
The potential human receptors evaluated were on-plant workers and off-
plant adult and child residents (see Table 3). The baseline risk
assessment evaluated the exposure that may potentially impact such
receptors.
Based upon groundwater sampling results, it appears that the on-plant
production wells are preventing the migration of contaminated
groundwater beyond the property boundaries. The risk assessment
evaluated the threat posed by a hypothetical off-plant direct contact with
contaminated groundwater (e.g., through ingestion of groundwater and
inhalation of volatiles released into indoor air from groundwater while
showering in an enclosed space) where the on-plant production wells
cease to operate, allowing the migration of contaminated groundwater
beyond the plant boundaries.
The results of the risk assessment indicate that the estimated excess
cancer risks for on-plant workers (see Table 4) and adult off-plant
residents (see Table 5) were lower than or within the acceptable excess
10
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cancer risk range of 10~4 to 106 (the highest total cancer risk was
attributable to an adult off-plant resident at 2.91 x 10 5 ).
The estimated excess cancer risks for off-plant receptors under the
hypothetical future-use scenario where the on-plant production wells are
turned off, thus allowing contaminated groundwater to migrate off-plant,
poses an unacceptable risk. The carcinogenic risk from exposure to
contaminants in the overburden aquifer is 2.0 x 1 0~3 for the adult resident
(1.9 x 10 ~3 from ingestion and 1.4 x 1 0~4 from inhalation ofvolatiles while
showering), and 1.3 x 10"3forthe child resident (1.1 x 10 "3 from ingestion
and 1.9 x 10"4 from inhalation of volatiles while showering). The risk to
a resident overthe entire exposure duration of 30 years is 3.3 x 10"3 (3.0
x 10"3 from ingestion and 3.3 x 10'4 from inhalation of volatiles while
showering). The primary risk driver is PCE. In the assessment of risk
from exposure to contaminants in the bedrock aquifer, the carcinogenic
risk to the adult resident is 1.6 x 10 4 (1.5 x 1 O"4 from ingestion and 1.1 x
10 5 from inhalation of volatiles while showering), andtherisktothe child
resident is 1.0 x 10~4 (8.5 x 10"5 from ingestion and 1.6 x 10'5 from
inhalation of volatiles while showering). The risk to a resident over the
entireexposuredurationof30yearsis2.6x10"4(2.4x10"4fromingestion
and 2.7 x 10'5 from inhalation of volatiles while showering). As is the
case with the overburden aquifer, the primary risk driver in the bedrock
aquifer is PCE (see Table 6).
Total estimated HI values for individual chemicals and combinations of
chemicals under current and future on-plant worker and adult off-plant
residents exposure scenarios at the Site range up to a maximum of
0.1939 (attributable to an adult off-plant resident) (see Table 5). Since
the total estimated HI is less than unity (1.0), there is not a concern for
potential chronic adverse noncancer health effects to such receptors.
The estimated HI for off-plant receptors under the hypothetical future-use
direct contact with contaminated groundwater scenario (where the on-
plant production wells are turned off) is estimated to exceed unity. In the
overburden aqu if er, the HI value fortheadu It resident is 15. Forthechild
resident, the HI is 58. In the bedrock aquifer, the hazard to the adult
resident is 1.1, while the hazard to the child resident is 4. (See Table 6.)
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:
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• 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. Consequently,
there is significant uncertainty as to the actual levels present.
Environmental chemistry analysis uncertainty can stem from several
sources including the errors inherent in the analytical methods and
characteristics of the matrix being sampled.
Uncertain ties in the exposure assessment a re re la ted to estimates of how
ofter\ an individual will actually come in contact with the chemicals of
concern, the period of time over which such exposure will occur, and in
the models used to estimate the concentrations of the chemicals of
concern at the point of exposure.
Uncertainties in toxicological data occur in extrapolating both from
animals to humans and from high to low doses of exposure, as well as
from the difficulties in assessing the toxicity of a mixture of chemicals.
These uncertainties are addressed by making conservative assumptions
concerning risk and exposure parameters throughout the assessment. As
a re suit, 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.
Ecological Risk Assessment
Information from the NYSDEC Bureau of Wildlife indicates that there are
no endangered or threatened plant or animal species at or in the vicinity
of the Site. Therefore, EPA evaluated potential exposure pathways of the
chemicals of concern (primarily PCE) for nonendangered and
nonthreatened animal and plant species.
Since the Site includes an industrial facility, there is minimal habitat
available for ecological receptors; however, the grassy areas could
support some soil invertebrates, terrestrial mammals, and birds.
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Soil samples from the Former Solvent Tank Source Area contained
volatile organic compounds, some of which (e.g., PCE) are present in
concentrations greater than conservative screening criteria considered
protective of soil invertebrate species. Therefore, there is a potential for
an unacceptable risk to burrowing animals that come into contact with
these contaminated surface soils (zero to a two-foot depth).
Considering the depth to the surface of the groundwater (not less than 8
feet below the ground surface), direct contact with groundwater by
ecological receptors is unlikely. Since there are no wetlands or surface
water bodies in the immediate vicinity of the Site, there is no potential for
contaminated groundwater to discharge into surface water. Therefore,
groundwater is not considered to be an exposure pathway for ecological
receptors.
Basis for Action
Based upon the human health and ecological risk assessments, EPA has
determined that the response action selected in this ROD is necessary to
protect the public health or welfare or the environment from actual or
threatened releases of hazardous substances from the Site into the
environment.
REMEDIAL ACTION OBJECTIVES
Remedial action objectives are specific goals to protect human health and
the environment. These objectives are based on available information
and standards such as applicable or relevant and appropriate
requirements (ARARs) and risk-based levels established in the risk
assessment.
The following remedial action objectives have been established for the
Site:
• Restore groundwater to levels which meet state and federal
standards within a reasonable time frame;
• Mitigate the potential for chemicals to migrate from soils into
groundwater; and
• Mitigate the migration of the affected groundwater.
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DESCRIPTION OF ALTERNATIVES
CERCLA §121(b)(1), 42 U.S.C. §9621(b)(1), mandates that remedial
actions must be protective of human health and the environment, cost-
effective, comply with 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 §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).
As was noted previously, principal threat wastes are those source
materials that act as a reservoir for the migration of contamination to
groundwater (such as the DNAPL potentially present in the source area
at the Site), Principal threat wastes are those source materials
considered to be highly toxic and present a significant risk to human
health or the environment should exposure occur, or are highly mobile
such that they, generally, cannot be reliably contained. The decision to
treat these wastes is made on a Site-specific basis through a detailed
analysis of alternatives, using the remedy selection criteria which are
described below. This analysis provides a basis for making a statutory
finding that the remedy employs treatment as a principal element8.
Detailed descriptions of the remedial alternatives for addressing the
contamination associated with the Site can be found in the FS report.
The FS report presents four soil remediation alternatives and five
groundwater remediation alternatives. To facilitate the presentation and
evaluation of these alternatives, the FS report's nine alternatives were
reorganized in formulating the remedial alternatives discussed below.
The construction time for each alternative reflects only the time required
to construct or implement the remedy and does not include the time
required to design the remedy, negotiate the performance of the remedy
with the responsible parties, or procure contracts for design and
construction. The present-worth costs for the alternatives discussed
A Guide to Principal Threat and Low Level Threat Wastes, U.S. Environmental Protection Agency,
Office of Solid Waste and Emergency Response, 938Q.3-Q6FS, November 1991.
14
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below are calculated using a discount rate of seven percent and a 1 5-year
time interval.
The remedial alternatives are:
Soil Remedial Alternatives
Alternative S-1: No Action
Capital Cost: $0
Annual Operation and $0
Maintenance Cost:
Present-Worth Cost: $0
Construction Time: 0 months
The Superfund program requires that the "no-action" alternative be
considered as a baseline for comparison with the other alternatives. The
no-action remedial alternative does not include any physical remedial
measures that address the contaminated soils in the Former Solvent Tank
Source Area.
Because this alternative would result in contaminants remaining on-Site,
CERCLA requires that the Site be reviewed at least once every five years.
If justified by this assessment, remedial actions may be implemented in
the future to remove or treat the waste.
Alternative S-2: Treatment of Contaminated Soils Using Soil Vapor
Extraction
Capital Cost: $365,000
Annual Operation and $122,000
Maintenance Cost:
Present-Worth Cost: $684,000
Construction Time: 3 months
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Under this alternative, VOC-contaminated soils in the Former Solvent
Tank Source Area would be remediated by soil vapor extraction (SVE).
Under this treatment process, air would be drawn through a series of
wells to volatilize the solvents contaminating the soils in the unsaturated
zone (above the water table). The extracted vapors would then be treated
by granular activated carbon before being vented to the atmosphere.
The approximate dimensions of the source area are 150 feet long, 20 feet
wide, and 15 feet deep, y ie Id ing an estimated volume of 1,700 cubic yards
of contaminated soil.
While the actual period of operation of the SVE system would be based
upon soil sampling results which demonstrate that the affected soils have
been treated to the soil cleanup objectives as specified in the New York
State Technical and Administrative Guidance Memorandum No. 94-HWR-
4046 (TAGM), it is estimated that the system would operate for a period
of three years.
Fencing would be in stalled a round the source area for the duration of the
treatment process to minimize worker exposure.
Alternative S-3: Excavation of Contaminated Soils and Off-Site
Treatment/Disposal
Capital Cost: $3,269,000
Annual Operation and $0
Maintenance Cost:
Present-Worth Cost: $3,269,000
Construction Time: 1 year
This alternative includes excavating approximately 1,700 cubic yards of
soil in the Former Solvent Tank Source Area which exceed soil TAGM
objectives. The actual extent of the excavation and the volume of the
excavated material would be based on post-excavation confirmatory
sampling. Shoring of the excavation and extraction and treatment of any
water that enters the trench would be necessary.
The excavated areas would be backfilled with clean fill and revegetated.
All excavated material would be characterized and transported for
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treatment/disposal at an off-Site Resource Conservation and Recovery
Act (RCRA)-compliant facility. Because of the high levels of PCE that
would be present in the excavated soil, it is likely that incineration would
be the only viable form of treatment.
Alternative S-4: Excavation of Contaminated Soils, On-Site
Treatment via Low Temperature Thermal Desorption, and
Redeposition
Capital Cost: $1,154,000
Annual Operation and $0
Maintenance Cost:
Present-Worth Cost: $1,154,000
Construction Time: 1 year
This alternative includes excavating approximately 1,700 cubic yards of
soil in the Former Solvent Tank Source Area which exceed soil cleanup
objectives as specified in the TAGM. The actual extent of the excavation
and the volume of the excavated materiai would be based on post-
excavation confirmatory sampling. Shoring of the excavation and
extraction and treatment of any water that enters the trench would be
necessary.
The excavated soil would be fed to a mobile Low Temperature Thermal
Desorption (LTTD) unit brought to the Site, where hot air injected at a
temperature above the boiling points of the organic contaminants of
concern would allow them to be volatilized into gases and escape from
the soil. The organic vapors extracted from the soil would then be either
condensed, transferred to another medium (such as granular activated
carbon), or thermally treated in an afterburner operated to ensure
complete destruction of the volatile organics. The off-gases would be
filtered through a carbon vessel. Once the treated soil achieved soil
TAGM objectives, it would be tested in accordance with the Toxicity
Characteristic Leaching Procedure (TCLP) to determine whether it
constitutes a RCRA hazardous waste and, provided that it passes the
test, it would be used as backfill material for the excavated area. Soil
above TCLP levels would be either re-treated or disposed of at an
approved off-Site facility, as appropriate.
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Groundwater Remedial Alternatives
Alternative GW-1: No Further Action and Long-Term Monitoring
Capital Cost: $3,000
Annual Monitoring Cost: $51,000
Present-Worth Cost: $633,000
Construction Time: 3 months
The Superfund program requires that the "no-action" alternative be
considered as a baseline for comparison with the other alternatives.
The no further action remedial alternative would not include any physical
remedial measures to address the ground water contamination at the Site7.
This alternative would, however, include a long-term groundwater
monitoring program and the installation of some additional monitoring
wells. Under this monitoring program, groundwater samples would be
collected and analyzed annually.
Because this alternative would result in contaminants remaining on-Site,
CERCLA requires that the Site be reviewed at least once every five years.
If justified by the review, additional remedial actions may be implemented
in the future.
Alternative GW-2: Source Area Extraction and Treatment, Monitored
Natural Attenuation of the Plume Outside the Source Area, and
Institutional Controls
Capital Cost: $362,000
Annual Monitoring Cost: $81,000
Present-Worth Cost: $1,366,000
Construction Time: 4 months
7 Although, since May 1996, contaminated groundwater has been extracted from the North Well and
the West Well, used as noncontact cooling water, treated, and discharged, the no further action
alternative assumes that groundwater is no longer extracted from these wells.
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Under this alternative, the affected groundwater in the Former Solvent
Tank Source Area would be addressed through an extraction system in
the overburden and bedrock aquifers. It is estimated that the
groundwater extraction system would utilize one bedrock and two
overburden wells to withdraw 400 gpm of contaminated groundwater. In
addition, contaminated groundwater would continue to be extracted from
the North Well, which would facilitate the capture of the plume beyond the
Former Solvent Tank Source Area. The extracted groundwater would be
treated by the existing air stripper and would then be used as noncontact
cooling water within the plant prior to being discharged to the on-Site
lagoons. To comply with New York State air guidelines, granular
activated carbon treatment of the air stripper air exhaust stream may be
necessary.
The contaminated groundwater located outside the Former Solvent Tank
Source Area and beyond the influence of the North Well would be
addressed through monitored natural attenuation, a variety of physical,
chemical and biological processes which, under favorable conditions, act
without human intervention to reduce the mass, toxicity, mobility, volume,
or concentration of contaminants in soil and groundwater. These in-situ
processes include biodegradation, dispersion, dilution, sorption,
volatilization, and chemical or biological stabilization, transformation, or
destruction of contaminants. Evidence of biodegradation of the PCE in
the groundwater at the Site includes the presence of its breakdown
products, TCE and 1-2 dichloroethene.
While preliminary modeling results indicate that it may take up to seven
years to remediate the aqueous phase of the PCE in the Former Solvent
Tank Source Area plume through groundwater extraction and treatment,
and from 10 to 15yearsforthecontaminantplume located outside of the
Former Solvent Tank Source Area to be restored through natural
attenuation, the total remediation time for this alternative is expected to
be much greater, since residual PCE DNAPL is suspected to be present
in the Former Solvent Tank Source Area. Groundwater extraction and
treatment can be effective in hydraulically containing DNAPL source
zones, however, it is generally not completely effective in remediating
these zones to groundwater standards.
As part of a long-term groundwater monitoring program, groundwater
samples would be collected and analyzed quarterly in order to verify that
the level and extent of groundwater contaminants (e.g., VOCs) are
declining and that conditions are protective of human health and the
environment. In addition, biodegradation parameters (e.g., oxygen,
nitrate, sulfate, methane, ethane, ethene, alkalinity, redox potential, pH,
19
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temperature, conductivity, chloride, and total organic carbon) would be
used to assess the progress of the degradation process.
Institutional controls, such as deed restrictions limiting future
groundwater use to nonpotable purposes only, would be established.
Additionally, because of the potential that pumping of the West Well
would draw contaminants to deeper water-bearing zones, pumping from
the West Well would be discontinued.
Under this alternative, blodegradation parameters would be used to
assess the progress of the degradation process. If it is determined that
monitored natural attenuation is not effective in restoring groundwater
quality outside of the Former Solvent Tank Source Area in a reasonable
time frame, then more aggressive remedial action approaches, such as
enhanced reductive dechlorination8 or groundwater extraction and
treatment, may be implemented.
Because this alternative would result in contaminants remaining on-Site,
CERCLA requires that the Site be reviewed at least once every five years.
Alternative GW-3: Site-Wide Groundwater Extraction and
Treatment, In-Situ Treatment of DNAPL, and Institutional Controls
Capital Cost: $1,533,000
Annual Operation and $215,200
Maintenance Cost:
Present-Worth Cost: $3,324,000
Construction Time: 6 months
Under this alternative, the affected groundwater would be addressed
through an extraction system in the overburden and bedrock aquifers. It
is estimated that the groundwater extraction system would utilize
10 overburden and six bedrock wells to withdraw 1,200 gpm of
contaminated groundwater. These wells would be placed northeast of the
lagoon system and in the vicinity of the Former Solvent Tank Source
Under this process, microbes remove the chlorine from the VOCs, allowing the compounds to further
degrade into carbon dioxide and water.
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Area. In addition, contaminated groundwater would continue to be
extracted from the North Well, which would facilitate the capture of the
plume beyond the Former Solvent Tank Source Area. A portion of the
extracted water would be treated by the existing air stripper and would be
used as noncontact cooling water within the plant prior to being
discharged to the on-Site lagoons.
Because the present capacity of the air stripper would be exceeded, an
additional air stripper would be constructed to treat the balance of the
extracted groundwater. The treated water that was not used for
noncontact cooling would be discharged to an infiltration gallery to be
constructed to the northeast of the lagoon system. To comply with New
York State air guidelines, granular activated carbon treatment of the air
strippers'air exhaust streams may be necessary.
Preliminary modeling results indicate that, through groundwater
extraction and treatment, it may take up to seven years to remediate the
aqueous phase of the PCE in the Former Solvent Tank Source A re a plume
and up to eight years to remediate the contaminant plume located outside
of the Former Solvent Tank Source Area.
To enhance the treatment of the residual DNAPL in the bedrock beneath
the Former Solvent Tank Source Area, an oxidizing agent, such as
potassiumpermanganate(KMn04) or hydrogen peroxide (H2O2), would be
injected via a well. It has been estimated that the residual DNAPL would
be treated within five years.
As part of a long-term groundwater monitoring program, groundwater
samples would be collected and analyzed quarterly in order to verify that
the level and extent of groundwater contaminants (e.g., VOCs) are
declining and that conditions are protective of human health and the
environment.
Institutional controls, such as deed restrictions limiting future
groundwater use to nonpotable purposes only, would be established.
Additionally, because of the potential that pumping of the West Well
would draw contaminants to deeper water-bearing zones, pumping from
the West Well would be discontinued.
Because this alternative would result in contaminants remaining on-Site
above health-based levels, CERCLA requires that the Site be reviewed at
least once every five years. If justified by the review, additional remedial
actions may be implemented in the future.
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Alternative GW-4: Source Area Extraction and Treatment, In-Situ
Treatment of DNAPL, Monitored Natural Attenuation of the Plume
Outside the Source Area, and Institutional Controls
Capital Cost: $479,000
Annual Monitoring Cost: $115,000
Present-Worth Cost: $1,623,000
Construction Time: 4 months
This alternative would be the same as Alternative GW-2, except, to
enhance the treatment of the residual DNAPL in the bedrock beneath the
Former Solvent Tank Source Area, an oxidizing agent, such as KMnO4 or
H2O2, would be injected via a well.
Preliminary modeling results indicate it may take up to seven years to
remediate the aqueous phase of the PCE in the Former Solvent Tank
Source Area plume through groundwater extraction and treatment and
from 10 to 15 years for the contaminant plume located outside of the
Former Solvent Tank Source Area to be restored through natural
attenuation. It has been estimated that the residual DNAPL would be
treated within five years.
Under this alternative, biodegradation parameters would be used to
assess the progress of the degradation process. If it is determined that
monitored natural attenuation is not effective in restoring groundwater
quality outside of the Former Solvent Tank Source Area in a reasonable
time frame, then more aggressive remedial action approaches, such as
enhanced reductive dechlorination or groundwater extraction and
treatment, may be implemented.
Because this alternative would result in contaminants remaining on-Site
above health-based levels, CERCLA requires that the Site be reviewed at
least once every five years.
COMPARATIVE ANALYSIS OF ALTERNATIVES
In selecting a remedy, EPA considered the factors set out in CERCLA
Section 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)
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and OSWER Directive 9355.3-01 (Guidance for Conducting Remedial
Investigations and Feasibility Studies under CERCLA: Interim Final,
October 1 988). 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.
The following "threshold" criteria are the most important and must be
satisfied by any alternative in order to be eligible for selection:
1. Overall protection of human health and the environment addresses
whether or not a remedy provides 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.
2. Compliance with ARARs addresses whether or not a remedy would
meet all of the applicable or relevant and appropriate requirements of
other federal and state environmental statutes and regulations or
provide grounds for invoking a waiver. Other federal or state
advisories, criteria, or guidance are To-Be-Considered (TBCs). TBCs
are not required by the NCR, but may be very useful in determining
what is protective of a Site or how to carry out certain actions or
requirements.
The following "primary balancing" criteria are used to make comparisons
and to identify the major tradeoffs between alternatives:
3. Long-term effectiveness and permanence refers to the ability of a
remedy to maintain reliable protection of human health and the
environment over time, once cleanup goals have been met. It also
addresses the magnitude and effectiveness of the measures that
may be required to manage the risk posed by treatment residuals
and/or untreated wastes.
4. 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.
5. Short-term effectiveness addresses the period of time needed to
achieve protection and any adverse impacts on human health and
the environment that may be posed during the construction and im-
plementation period until cleanup goals are achieved.
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6. Implementability is the technical and administrative feasibility of a
remedy, including the availability of materials and services needed
to implement a particular opt ion.
7. Cosf includes estimated capital and O&M costs, and net present-
worth costs.
The following "modifying" criteria are used in the final evaluation of the
remedial alternatives after the formal comment period, and may prompt
modification of the preferred remedy that was presented in the Proposed
Plan:
8. State acceptance indicates whether, based on its review of the
RI/FS reports and Proposed Plan, the State concurs with, opposes,
or has no comments on the selected remedy.
9. Community acceptance refers to the public's general response to
the alternatives described in the RI/FS reports and Proposed Plan.
A comparative analysis of these alternatives based upon the evaluation
criteria noted above, follows.
Overall Protection of Human Health and the Environment
Alternative S-1 (no action) would not be protective of human health and
the environment, since it would not actively address the contaminated
soils, which are a source of groundwater contamination.
Alternative S-2 (soil vapor extraction), Alternative S-3 (excavation of
contaminated soils and off-Site treatment/disposal), and Alternative S-4
(excavation of contaminated soils and on-Site treatment via LTTD) would
be protective of human health and the environment, since each
alternative relies upon a remedial strategy and/or treatment technology
capable of removing the source of groundwater contamination in the
unsaturated zone. Under these alternatives, the contaminants would
either be treated on-Site or treated/disposed of off-Site.
Alternative GW-1 (no further action) would be the least protective
groundwater alternative in that it would result in no affirmative steps to
restore groundwater quality to drinking water standards. Therefore,
under this alternative, the restoration of the groundwater would take a
significantly longer time in comparison to Alternative GW-2 (source area
extraction and treatment and monitored natural attenuation of the
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remainder of the plume), Alternative GW-3 (Site-wide extraction and
t re atment of the co ntamina ted groundwater and in-situDNAPL treatment),
and Alternative GW-4 (source area extraction and treatment, in-situ
DNAPL treatment, and monitored natural attenuation of the plume).
Alternative GW-2 would be significantly more protective than Alternative
GW-1 in that it would provide hydraulic containment and treatment of the
affected groundwater at the source. This alternative would, however, rely
upon natural attenuation to address the groundwater contamination
outside the Former Solvent Tank Source Area. While Alternative GW-4
would result in the restoration of water quality in the aquifer more
effectively than Alternative GW-2, since it would actively address the
DNAPL, it would not restore the water quality in the plume as quickly as
Alternative GW-3.
Compliance with ARARs
There are currently no federal or state promulgated standards for
contaminant levels in soils, only New York State soil cleanup objectives
as specified in the TAGM (which are used as TBCs). Table 7 summarizes
the soil cleanup objectives for the contaminants that are present in the
soil at the Site.
Since the contaminated soils would not be addressed under Alternative
S-1 (no action), this alternative would not comply with the soil cleanup
objectives. Alternative S-2 (soil vapor extraction), Alternative S-3
(excavation of contaminated soils and off-Site treatment/disposal), and
Alternative S-4 (excavation of contaminated soils and on-Site treatment
via LTTD) would be implemented to attain the soil cleanup objectives
specified in TAGM.
UnderAlternative S-2, spent granular activated carbon from the SVE units
would need to be managed in compliance with RCRA treatment/disposal
requirements.
Alternative S-3 would be subject to New York State and federal
regulations related to the transportation and off-Site treatment/disposal
of wastes. Alternatives S-3 and S-4 would involve the excavation of
contaminated soils, and would, therefore, require compliance with fugitive
dust and VOC emission regulations. In the case of Alternative S-4,
compliance with air emission standards would be required at the LTTD
unit, as well. Specifically, treatment of off-gases would have to comply
with New York State Air Guide 1 for the Control of Toxic Ambient Air
Emissions and would be required 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.).
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EPA and NYSDEC have promulgated health-based protective Maximum
Contaminant Levels (MCLs)(40 CFR Part 141), which are enforceable
standards for various drinking water contaminants (chemical-specific
ARARs). Although the groundwater at the Site is not presently being
utilized as a potable water source, achieving MCLs in the groundwater is
relevant and appropriate, because the groundwater at the Site is a
potential source of drinking water. Table 7 summarizes the MCLs for the
constituents present in the groundwater at the Site. The aquifer is
classified as Class GA (6 NYCRR 701.18).
Alternative GW-1 (no further action) does not provide for any direct
remediation of the groundwater and would, therefore, involve no actions
to achieve chemical-specific ARARs. Alternative GW-2 (source area
extraction and treatment and monitored natural attenuation of the
remainder of the plume) would be effective in reducing groundwater
contaminant concentrations below MCLs in the Former Solvent Tank
Source Area by treating the dissolved-phase chemicals and hydraulically
containing the affected groundwater at the source; however, this
alternative would not be as effective in meeting ARARs as Alternative
GW-4 (source area extraction and treatment, in-situ DNAPL treatment,
and monitored natural attenuation of the plume), which would employ a
more aggressive approach to addressing the DNAPL. Both alternatives
would rely upon natural attenuation to address a portion of the
contaminated groundwater in the plume. Alternative GW-3 (Site-wide
groundwater extraction and treatment and in-situ DNAPL treatment)
would be the most effective in reducing groundwater contaminant
concentrations below MCLs, since it would include an aggressive
approach to address the DNAPL and would include the collection and
treatment of contaminated groundwater throughout the Site. Therefore,
this alternative would achieve ARARs in the shortest period of time.
Long-Term Effectiveness and Permanence
Alternative S-1 (no action) would involve no active remedial measures
and, therefore, would not be effective in eliminating the potential for
contaminants to continue to migrate in soil and groundwater. Alternative
S-2 (soil vapor extraction), Alternative S-3 (excavation of contaminated
soils and off-Site treatment/disposal), and Alternative S-4 (excavation of
contaminated soils and on-Site treatment via LTTD) would all be effective
in the long term and would provide permanent remediation by either
removing the wastes from the Site or treating them on-Site.
Alternatives S-2 and S-4 would generate treatment residuals which would
have to be appropriately handled; Alternative S-3 would not generate
such residuals.
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Alternative GW-1 (no further action) would be only minimally effective in
the long-term in restoring groundwater quality, since it would not rely on
active measures. Alternative GW-2 (source area extraction and treatment
and monitored natural attenuation of the remainder of the plume) would
be significantly more effective than Alternative GW-1 in restoring
groundwater quality. Although groundwater extraction and treatment can
be effective in hydraulically containing DNAPL source zones, it is
generally not completely effective in remediating these zones to
groundwater standards. Therefore, since Alternative GW-2 would rely
upon groundwater extraction to address the residual DNAPL, it would not
be as effective as Alternative GW-3 (Site-wide groundwater extraction
and treatment and in-situ DNAPL treatment) and Alternative GW-4
(source area extraction and treatment, in-situ DNAPL treatment, and
monitored natural attenuation of the remaining plume), which both would
utilize aggressive in-situ DNAPL treatment. Under Alternative GW-4, by
aggressively addressing the contamination at the source area, it is
expected that low levels of PCE (less than 22 ug/l) outside the source
area would attenuate naturally in a reasonable time frame. Alternative
GW-4 would not, however, provide the same long-term effectiveness and
permanence with regard to this contamination as Alternative GW-3, which
would actively remove contaminants from the entire plume. Alternative
GW-3 would achieve drinking water standards outside the Former Solvent
Tank Source Area mo re quickly than Alternative GW-4.
Alternatives GW-2, GW-3, and GW-4 would generate treatment residuals
which would have to be appropriately handled; Alternative GW-1 would
not gene rate such residuals.
Reduction in Toxicitv. Mobility, or Volume Through Treatment
Alternative S-1 (no action) would provide no reduction in toxicity, mobility
or volume. Under Alternative S-2 (soil vapor extraction) and Alternative
S-4 (excavation of contaminated soils and on-Site treatment via LTTD),
the toxicity, mobility, and volume of contaminants would be reduced
through on-Site treatment. Under Alternative S-3 (excavation of
contaminated soils and off-Site treatment/disposal), the toxicity, mobility,
and volume of the contaminants would be reduced by removing the
contaminated soil from the Site for treatment.
Alternative GW-1 (no further action) would be the least effective
alternative in reducing the toxicity, mobility, or volume of contaminants
in the groundwater through treatment, as this alternative involves no
active remedial measures. All of the action alternatives would, to varying
degrees, reduce the toxicity, mobility, or volume of contaminants in the
groundwater through treatment, thereby satisfying CERCLA's preference
27
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for treatment. Collecting and treating contaminated groundwater in the
Former Solvent Tank Source Area under Alternative GW-2 (source area
extraction and treatment and monitored natural attenuation of the plume)
would actively reduce the toxicity, mobility, and volume of contaminants
in this area. The addition of an oxidizing agent to address the DNAPL
under Alternative GW-4 (source area extraction and treatment, in-situ
DNAPL treatment, and monitored natural attenuation of the plume) would
provide substantially greater reduction of the toxicity, mobility, and
volume of contaminants than Alternative GW-2. Collecting and treating
contaminated groundwater in the Former Solvent Tank Source Area and
the remaining plume, and using an oxidizing agent to address the DNAPL
under Alternative GW-3 (Site-wide groundwater extract)on and treatment
and in-situ DNAPL treatment) would provide the greatest reduction of
toxicity, mobility, and volume of contaminants thro ugh treatment.
Short-Term Effectiveness
Alternative S-1 (no action) does not include any physical construction
measures in any a re as of contamination and, therefore, would not present
any potential adverse impacts to on-Site workers or the community as a
result of its implementation. Alternative S-2 (soil vapor extract ion) could
re suit in some ad verse impacts to on-Site workers through dermal contact
and inhalation related to the installation of SVE wells through
contaminated soils. In addition, interim and post-remediation soil
sampling activities would pose some risk. Similarly, Alternatives S-3
(excavation of contaminated soils and off-Site treatment/disposal) and S-
4 (excavation of contaminated soils and on-Site treatment via LTTD)
could present some limited adverse impact to on-Site workers through
dermal contact and inhalation related to post-excavation sampling
activities. The risks to on-Site workers under all of the alternatives could,
however, be mitigated by utilizing proper protective equipment.
Alt e rn at ive S-3 would require the off- Si tetransportofcontaminated waste
material, which may pose the potential for traffic accidents, which could
result in releases of hazardous substances.
Under Alternatives S-3 and S-4 ,dist urban ceofthe land during excavation
activities could affect the surface water hydrology of the Site. There is
a potential for increased stormwater run off and erosion during excavation
and construction activities that would have to be properly managed to
prevent or minimize any adverse impacts. For these alternatives,
appropriate measures would have to be taken during excavation activities
to prevent transport of fugitive dust and exposure of workers and
downgradient receptors to volatile organic compounds.
28
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Since no actions would be performed under Alternative S-1, there would
be no implementation time. It is estimated that Alternative S-2 would
require 3 months to install the SVE system and would require an
estimated 3 years to achieve soil cleanup objectives. It is estimated that
it would take one year to excavate and transport the contaminated soils
to an EPA-ap proved treatment/disposal facility under Alternative S-3, and
one year to excavate and treat the contaminated soils under Alternative
S-4.
All of the groundwater alternatives could present some limited adverse
impacts to on-Site workers through dermal contact and inhalation related
to groundwater sampling activities. Alternative GW-2 (source area
extraction and treatment and monitored natural attenuation of the plume),
Alternative GW-3 (Site-wide groundwater extraction and treatment and in-
situDNAPL treatment), and Alternative GW-4 (source area extraction and
treatment, in-situ DNAPL treatment, and monitored natural attenuation of
the plume) could present slightly greater adverse impacts to on-Site
workers, since these alternatives would involve the installation of
extraction wells through potentially contaminated soils and groundwater
(Alternative GW-3 could pose the greatest risk since it would require the
installation of the most extraction wells.) The risks to on-Site workers
under all of the alternatives could, however, be minimized by utilizing
proper protective equipment.
It is estimated that Alternative GW-1 would require three months to
implement, since developing a long-term groundwater monitoring program
and installing several monitoring wells would be the only activities that
would be required. It is estimated that the groundwater remediation
systems underAlternatives GW-2, GW-3, and GW-4 would be constructed
in four, six, and four months, respectively.
Preliminary modeling results indicate it may take up to seven years to
remediate the aqueous phase of the PCE in the Former Solvent Tank
Source Area plume underAlternatives GW-2, GW-3, and GW-4. Residual
PCE DNAPL is suspected to be present in the Former Solvent Tank
Source Area. While groundwater extraction and treatment can be
effective in hydraulically containing DNAPL source zones, it is generally
not completely effective in remediating these zones to groundwater
standards. Therefore, for Alternative GW-2, it is likely that the total
remediation time frame for the aqueous phase of the PCE in the Former
Solvent Tank Source Area plume would be significantly greater than the
estimated 7-year time frame.
Under Alternative GW-3, it is estimated that it may take up to eight years
to remediate the contaminant plume located outside of the Former
29
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Solvent Tank Source Area through extraction and treatment. Under
Alternatives GW-2 and GW-4, it is estimated that natural attenuation
would address the contaminated groundwater located outside of the
Former Solvent Tank Source Area in 10 to 15 years. Remediation time
frames were not developed for Alternative GW-1 because of the
difficulties in estimating a natural attenuation rate for the DNAPL in the
Former Solvent Tank Source Area.
Under Alternatives GW-3 and GW-4, it is estimated that it would take five
years to remediate the DNAPL via KMnO4 or H2O2 injection.
The estimated time for the groundwater to be remediated Site-wide under
all of the alternatives would have to be refined based on the results of
groundwater monitoring and additional groundwater modeling.
Implementability
Alternative S-1 (no action) would be easy to implement, as there are no
activities to undertake. Alternative S-2 (soil vapor extraction), would be
less difficult to implement than Alternative S-3 (excavation of
contaminated soils and off-Site treatment) and Alternative S-4
(excavation of contaminated soils and on-Site treatment via LTTD), since
contaminated soil excavation and handling would not be required. All
three action alternatives would employ technologies known to be reliable
and can be readily implemented. In addition, equipment, services, and
materials needed for all three of these alternatives are readily available,
and the actions under these alternatives would be administratively
feasible. Sufficient facilities are available for the treatment/disposal of
the excavated soils under Alternative S-3.
Monitoring the effectiveness of the SVE system under Alternative S-2
would be easily accomplished through vapor and soil sampling and
analysis. Under Alternative S-3, monitoring the effectiveness of the
excavation could be easily accomplished through post-excavation soil
sampling and analysis. Monitoring the effectiveness of the LTTD system
under Alternative S-4 could be easily accomplished through post-
excavation and post-treatment soil sampling and analysis.
Alternative GW-1 (no further act ion) would be the easiest to implement as
the only activity would be installing some additional monitoring wells and
establishing a monitoring program. Since only a limited number of
extraction wells would need to be installed, and since the existing
groundwater treatment system would be utilized, the groundwater
extraction systems related to Alternative GW-2 (source area extraction
and treatment and monitored natural attenuation of the plume) and
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Alternative GW-4 (source area extraction and treatment, in-situ DNAPL
treatment, and monitored natural attenuation of the plume) would be
relatively easy to implement. Alternative GW-3 (Site-wide groundwater
extraction and treatment and in-situ DNAPL treatment), which would
require the installation of more extraction wells than Alternatives GW-2
and GW-4 and the construction of an additional treatment system, would
be slightly more difficult to implement than these alternatives.
Alternatives GW-2 and GW-4 would also involve monitoring of natural
attenuation parameters to demonstrate that natural attenuation is reliably
achieving the specified remedial goals. Alternatives GW-3 and GW-4
would be more complicated to implement than Alternative GW-2, since
they wou Id also require the inject ion of KMnO4 or H2O2to address the PCE
DNAPL.
The groundwater extraction and treatment systems that would be used for
Alternatives GW-2, GW-3, and GW-4 have been implemented successfully
at numerous Sites to extract, treat, and hydraulically control
contaminated groundwater.
The air stripping technology that would be used for Alternatives GW-2,
GW-3, and GW-4 is proven and reliable in achieving the specified
performance goals and is readily available.
The KMn04 or H2O2 injection technologies that would be used for
Alternative GW-4 are emerging technologies that have been successfully
implemented at a few Sites across the United States to treat DNAPL.
Mixing tanks for KMnO4, and injection pumps and all necessary
appu rte nan ce sforKMnO4 and H2O2 a re readily available. Field tests may
be required prior to designing a full-scale system. While utilizing KMnO4
would likely result in the introduction of trace metal impurities and
manganese salts into the groundwater, it is expected that the levels wou Id
be below groundwater standards.
Cost
The present-worth costs associated with the soil remedies are calculated
using a discount rate of seven percent and a 3-year time interval. The
present-worth costs associated with the groundwater remedies are
calculated using a discount rate of seven percent and a 15-year time
interval.
The estimated capital, operation, maintenance, and monitoring (OM&M),
and present-worth costs for each of the alternatives are presented below.
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Alternative
S-1
S-2
S-3
S-4
GW-1
GW-2
GW-3
GW-4
Capital Cost
$0
$365,000
$3,269,000
$1,154,000
$3,000
$362,000
$1,533,000
$479,000
Annual OM&M
Cost
$0
$122,000
$0
$0
$51,000
$81,000
$215,200
$115.000
Present-Worth Cost
$0
$684,000
$3,269,000
$1,154,000
$633,000
$1,366,000
$3,324,000
$1,623,000
As can be seen by the cost estimates, Alternative S-1 (no action) is the
least costly soil alternative at $0. Alternative S-3 (excavation of
contaminated soils and off-Site treatment) is the most costly soil
alternative at $3,269,000. The least costly groundwater remedy is
Alternative GW-1, no further action, at a present-worth cost of $630,000.
Alternative GW-3 (Site-wide g roundwater extract ion and treatment and in-
situ DNAPL treatment) is the most costly groundwater alternative at a
present-worth cost of $3,324,000. The significant difference in the cost
of this alternative as compared to the other action alternatives is mainly
attributable to the construction and operation of an additional
groundwater treatment system under Alternative GW-3.
State Acceptance
NYSDEC concurs with the selected remedy; a letter of concurrence is
attached (see Appendix IV).
Community Acceptance
Comments received during the public comment period indicate that the
public generally supports the selected remedy.
Comments received during the public comment period are summarized
and addressed in the Responsiveness Summary, which is attached as
AppendixV to this document.
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SELECTED REMEDY
Summary of the Rationale for the Selected Remedy
Based upon consideration of the requirements of CERCLA, the detailed
analysis of the alternatives, and public comments, EPA and NYSDEC
have determined that Alternative S-2 (SVE) and Alternative GW-4 (Former
Solvent Tank Source Area extraction and treatment, in-situ DNAPL
treatment, and monitored natural attenuation of the plume outside of the
Former Solvent Tank Source Area) best satisfy the requirements of
CERCLA Section 121, 42 U.S.C. §9621 and provide the best balance of
tradeoffs among the remedial alternatives with respect to the NCR's nine
evaluation criteria, 40 CFR §300.430(e)(9).
While all of the soil action alternatives would effectively achieve the soil
cleanup levels, Alternative S-3, excavation of contaminated soils and off-
Site treatment/disposal, and Alternative S-4, excavation and on-Site
treatment, would be considerably more expensive than Alternative S-2.
On the other hand, Alternative S-2 would take somewhat longer to
achieve the soil cleanup objectives than the other action alternatives (3
years for SVE, as compared to 1 year for excavation and off-Site
treatment/disposal and 1 year for on-Site treatment). While the
co ntamina ted soils a re a continuing source of groundwater contamination,
there are no immediate risks to human health or ecological risks posed
by the contaminated soils. Considering the fact that the groundwater
component of the selected remedy will address the contaminated
groundwater, the increase in the time needed to clean up the soil will not
be a significant concern. Therefore, EPA believes that Alternative S-2 will
effectuate the soil cleanup while providing the best balance of tradeoffs
among the alternatives with respect to the evaluating criteria.
Residual PCE DNAPL is suspected to be present in the bedrock aquifer
underlying the Former Solvent Tank Source Area. While Alternative GW-
2 (source area extraction and treatment and monitored natural
attenuation of the remainder of the plume) would be effective in
hydraulically containing the DNAPL source zone, it would not likely be
effective in remediating this zone to groundwater standards.
Although Alternative GW-3 would provide Site-wide groundwater
extraction and treatment, making it the most effective groundwater
remediation alternative, EPA believes that Alternative GW-4 will result in
the remediation of the contaminated groundwater located both in the
For me r Sol ve nt Tank Source A re a and outside ofthe Former Solvent Tank
Source Area via a combination of in-situ treatment of the DNAPL,
groundwater extraction and treatment, and monitored natural attenuation,
33
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respectively, in a reasonable time frame and at a significantly lower cost
than ground water extract ion and treatment under Alternative GW-3.
Description of the Selected Remedy
The selected remedy involves:
• Treatment of soils in the Former Solvent Tank Source Area at the
Jones plant grounds exceeding New York State soil cleanup
objectives by in-situ SVE;
• Extract ion of contaminated ground water in the Former Solvent Tank
Source Area utilizing a network of recovery wells in the overburden
and bedrock aquifers;
• Treatment of the extracted groundwater with the existing air
stripper, which allows for the utilization of the treated water as
noncontact cooling water within the plant, and discharge of the
noncontact cooling water to the on-Site lagoons until groundwater
standards in the Former Solvent Tank Source Area are achieved;
• In-situ treatment of the DNAPL in the aquifer underlying the Former
Solvent Tank Source Area with an oxidizing agent, such as KMnO4
or H2O2;
Continued extraction and treatment of contaminated groundwater
from the North Well;
• Discontinued pumping from the West Well to eliminate the potential
to draw contaminants to deeper water-bearing zones;
Monitored natural attenuation of the contaminated groundwater
located outside the Former Solvent Tank Source Area and beyond
the influence of the North Well; and
Implementation of institutional controls (i.e., deed restrictions) to
limit future on-Site groundwater use to nonpotable purposes only
until groundwater cleanup standards are achieved.
During the design phase, samples will be collected to optimize the
placement of the extraction wells in the Former Solvent Tank Source Area
and to better characterize the extent of the DNAPL contamination.
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As part of a long-term groundwater monitoring program, groundwater
samples will be collected and analyzed quarterly in order to verify that the
level and extent of groundwater contaminants (e.g., volatile organic
compounds) are declining and that conditions are protective of human
health and the environment. In addition, biodegradation parameters
(e.g., oxygen, nitrate, sulfate, methane, ethane, ethene, alkalinity, redox
potential, pH, temperature, conductivity, chloride, and total organic
carbon) will be used to assess the progress of the degradation process.
If it is determined that monitored natural attenuation is not effective in
restoring groundwater quality outside of the Former Solvent Tank Source
Area in a reasonable time frame, then remedial actions, such as
enhanced reductive dechlorination9 or groundwater extraction and
treatment, may be implemented.
The selected remedy is believed to be able to achieve the ARARs more
quickly, or as quickly as the other alternatives, but at a lower cost.
Therefore, the selected remedy will provide the best balance of tradeoffs
among alternatives with respect to the evaluating criteria. EPA and the
NYSDEC believe that the selected remedy will be protective of human
health and the environment, be cost-effective, and utilize permanent
solutions and alternative treatment technologies or resource recovery
technologies to the maximum extent practicable. The selected remedy
will meet the statutory preference for the use of treatment as a principal
element.
Summary of the Estimated Remedy Costs
The estimated capital, annual O&M, and present-worth costs for the
selected soil remedy are $365,000, $122,000, and $684,000,
respectively. The estimated capital, annual O&M and monitoring, and
present-worth costs for the selected groundwater remedy are $479,000,
$115,000, and $1,623,000, respectively. Tables 8 and 9 provide the
basis for these cost estimates.
It should be noted that these cost estimates are order-of-magnitude
engineering cost estimates that are expected to be within +50 to -30
percent of the actual project cost. These cost estimates are based on the
best available information regarding the anticipated scope of the selected
remedy. Changes in the cost elements are likely to occur as a result of
new information and data collected during the engineering design of the
remedy.
Under this process, microbes remove the chlorine from the VOCs, allowing the compounds to further
degrade into carbon dioxide and water.
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Expected Outcomes of the Selected Remedy
The results of the risk assessment indicate that under the hypothetical
off-plant groundwater-use scenario, where the on-plant production wells
are turned off, there is an unacceptable excess cancer risk and a chronic
adverse noncancer health effect to such receptors. In addition, the
ecological risk assessment indicated that the presence of contaminated
surface soil in the Former Solvent Tank Source Area poses a potentially
unacceptable risk to ecological receptors.
Under the selected remedy, the treatment of the contaminated soils,
which will eliminate the source of the groundwater contamination, in
combination with groundwater extraction and treatment in the source
area, in-situ DNAPL treatment, and monitored natural attenuation of the
groundwater outside the source area, will result in the restoration of
water quality in the aquifer. The treatment of the contaminated soils will
also eliminate the potential threat to ecological receptors.
The plant is presently used for light industry, and the plant's reasonably-
anticipated future land use is industrial. Therefore, it is not anticipated
that achieving the performance standards will alter that land use in the
future. In addition, although on-plant wells provide noncontact cooling
water for the plant after treatment, pot able water for the plant is obtained
from the Village of Caledonia's well system. Therefore, it is not likely
that the groundwater underlying the plant will be used for potable
purposes in the foreseeable future. Beyond the plant's property
boundary, downgradient water supply wells could be used for potable
purposes at present and in the future (until groundwater standards are
met on-plant), due to the continued operation of the plant's production
wells.
Under the selected remedy, it is estimated that it will require 3 years to
achieve soil cleanup objectives and 10 to 15 years to achieve
groundwater standards both in the Former Solvent Tank Source Area and
beyond.
STATUTORY DETERMINATIONS
Under CERCLA Section 121 and the NCR, the lead agency must select
remedies that are protective of human health and the environment,
comply with ARARs (unless a statutory waiver is justified), are cost-
effective, and utilize permanent solutions and alternative treatment
technologies or resource recovery technologies to the maximum extent
36
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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.
For the reasons discussed below, EPA has determined that the selected
remedy meets these statutory requirements.
Protection of Human Health and the Environment
The selected remedy will be protective of the environment in that the
treatment of contaminated soil will eliminate contaminant-related
concerns related to ecological receptors and will eliminate the source of
the groundwater contamination. Groundwater extraction and treatment,
in-situ DNAPL treatment in the Former Solvent Tank Source Area, and
monitored natural attenuation of the groundwater outside the Former
Solvent Tank Source Area will eventually achieve groundwater standards.
The selected remedy will reduce exposure levels to protective ARAR
levels or to within EPA's generally acceptable risk range of 10"4 to 10"6 for
carcinogenic risk and below the HI of 1 for noncarcinogens in the
groundwater. The implementation of the selected remedy will not pose
unacceptable short-term risks or cross-media impacts that cannot
possibly be mitigated. The selected remedy will also provide overall
protection by reducing the toxicity, mobility, and volume of contamination
through the treatment of the contaminated soils and the
extraction/treatment of the contaminated groundwater.
Compliance with Applicable or Relevant and Appropriate Requirements
of Environmental Laws
While there are no federal or New York State soil ARARs, one of the
remedial action goals is to meet NYSDEC soil cleanup objectives as
TBCs. A summary of action-specific, chemical-specific, and location-
specific ARARs which will be complied with during implementation of the
selected remedy is presented below.
Action-specific ARARs:
• National Emissions Standards for Hazardous Air Pollutants (40 CFR
Part 61)
6 NYCRR Part 257, Air Quality Standards
6 NYCRR Part 200, New York State Regulations for Prevention and
Control of Air Contamination and Air Pollution
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6 NYCRR Part 376, Land Disposal Restrictions
40 CFR 50, Air Quality Standards
• New York State Pollutant Discharge Elimination System (6 NYCRR
Parts 750-758)
• Resource Conservation and Recovery Act (42U.S.C.§6901 et seq.)
Chemical-specific ARARs;
Safe Drinking Water Act (SDWA) MCLs and nonzero MCLGs (40
CFR Part 141)
6 NYCRR Parts 700-705 Groundwater and Surface Water Quality
Regulations
10 NYCRR Part 5 State Sanitary Code
Location-specific ARARs:
Fish and Wildlife Coordination Act, 16 U.S.C. 661
Other Criteria, Advisories, or Guidance To-Be-Considereds (TBCs):
• New York State Air Guide—1 for the Control of Toxic Ambient Air
Emissions
• New York Guidelines for Soil Erosion and Sediment Control
New York State Air Cleanup Criteria, January 1990
SDWA Proposed MCLs and nonzero MCL Goals
• NYSDEC Technical and Operational Guidance Series 1.1.1,
November 1991
• Soil cleanup objectives specified in NYSDEC Technical
Administrative Guidance Memorandum No. 94-HWR-4046,
Cost-Effectiveness
For the foregoing reasons, it has been determined that the selected
remedy provides for overall effectiveness in proportion to its cost.
38
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The estimated present-worth cost of the soil component of the selected
remedy is $684,000.
While all of the soil action alternatives would effectively achieve the soil
cleanup levels, Alternative S-3, excavation of contaminated soils and off-
Site treatment/disposal, and Alternative S-4, excavation and on-Site
treatment, would be considerably more expensive than Alternative S-2,
the selected soil alternative. On the other hand, Alternative S-2 will take
somewhat longer to achieve the soil cleanup objectives than the other
action alternatives (3 years for SVE, as compared to 1 year for excavation
and off-Site treatment/disposal and 1 year for on-Site treatment). While
the contaminated soils are a continuing source of groundwater
contamination, there are no immediate risks to human health or ecological
risks posed by the contaminated soils. Considering the fact that the
groundwater component of the selected remedy will address the
contaminated groundwater, the increase in the time needed to clean up
the soil will not be a significant concern. Therefore, EPA believes that
Alternative S-2 will effectuate the soil cleanup while providing the best
balance of tradeoffs among the alternatives with respect to the evaluating
criteria.
The estimated present-worth cost of the groundwater component of the
selected remedy, using a discount rate of seven percent and a 15-year
time interval, is $1,623,000. Although Alternative GW-3 would provide
Site-wide groundwater extraction and treatment, making it the most
effective groundwater remediation alternative, EPA believes that
Alternative GW-4 will result in the remediation of the contaminated
groundwater located both in the Former Solvent Tank Source Area and
outside of the Former Solvent Tank Source Area via a combination of in-
situ treatment of the DNAPL, groundwater extraction and treatment, and
monitored natural attenuation in a reasonable time frame and at a
significantly lower cost than groundwater extraction and treatment under
Alternative GW-3.
U t i I i z a t i on of P e r m a n e n * Solutions a n dA1t e rnative Treatment
Technologies to the Maximum Extent Practicable
The selected remedy provides the best balance of tradeoffs among the
alternatives with respect to the five balancing criteria set forth in NCP
§300.430(f)(1)(i)(B), such that it represents the maximum extent to which
permanent solutions and treatment technologies can be utilized in a
practicable manner at the Site.
The soil component of the selected remedy will employ an alternative
treatment technology (SVE) to reduce the toxicity, mobility, and volume
39
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of the contaminants in the soil in the Former Solvent Tank Source Area.
The selected remedy will permanently address this soil contamination.
With regard to the groundwater, the selected remedy will provide a
permanent remedy and will employ treatment technologies to reduce the
toxicity, mobility, and volume of the contaminants in the groundwater.
Preference for Treatment as a Principal Element
The statutory preference for remedies that employ treatment as a
principal element is satisfied under the selected remedy in that
contaminated soils will be treated in-situ and treatment will be used to
reduce the volume of contaminated groundwater in the aquifer and
achieve cleanup goals.
Fj v e - Y e a rReviewRequirements
The selected remedy, once fully implemented, will not result in hazardous
substances, pollutants, or contaminants remaining on-Site above levels
that allow for unlimited use and unrestricted exposure. However, it may
take more than five years to attain remedial action objectives and cleanup
levels for the groundwater. Consequently, a policy review may be
conducted within five years after initiation of remedial action to ensure
that the remedy is, or will be, protective of human health and the
environment.
DOCUMENTATION OF SIGNIFICANT CHANGES
The Proposed Plan, released for public comment on July 20, 2000,
identified Alternative S-2, SVE, for the soil remedy. For the groundwater
remedy, it identified Alternative GW-4, Former Solvent Tank Source Area
extraction and treatment, in-situ DNAPL treatment, and monitored natural
attenuation of the plume out side of the Former Solvent Tank Source Area.
Based upon its review of the written and verbal comments submitted
during the public comment period, EPA determined that no significant
changes to the remedy, as originally identified in the Proposed Plan, were
necessary or appropriate.
40
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APPENDIX
FIGURES
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FIGURES
Figure 1 Site Location Map
Figure 2 Site Map
Figure 3 Selected Analyte Concentrations in Soil Borings,
Sediment, Sludge, and Direct-push Soil Samples
Figure 4 Generalized East-West Geologic Cross Section
Figure 5 Groundwater Elevation Contour Maps,
Overburden Monitoring Wells
Figure 6 Groundwater Elevation Contour Maps,
Bedrock Monitoring Wells
Figure 7 Generalized East-West Geologic Cross Section(lnset)
Figure 8 Isoconcentration Map of PCE in Groundwater, 17-25
Feet Below Ground Surface
Figure 9 Isoconcentration Map of PCE in Groundwater, 35-48
Feet Below Ground Surface
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**c.
SITE
-r LOCATION
A \? L
nc^ New Itotk, 1950
1937.
. C i / J O r o s. c r, e n i c c i I r. c
Site Location Map
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Figure 2
Chemicals Site Map
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-------
Monitoring W«b, Mov««lb4f 26,1B97
On-iM Producttofi Well* Fuinping
OfvSK» ftwjyc** WfllK Not Pumping
*T"***1 ^ (V
., 1 ~t—.X. -i*
LEG END
i a UP\',0
Qi«uM*N«it«f Elvvttian Contoyr MifM,
mtn MoriNctlngWvta
. ISM. ma D^rnmbm 1,1097
-------
MonNorlnfl Wtta, O*c*mt*r 1.1997
OVSAm Producdon Wrilw Not Pumping
I I
On-Sto ProdtMthm Wafa:
, t M7
r—- ,>-e \
! =^-v, ^
(Nil \
»s«o«cfN
[ Y'
^\ n«
7//I-3 S 3 ! f /
- -J. / I.
LEGEND
9 TVtnr
(H
m
JCI / Jor« v*!*— CQ'E. Inr
QrrwixtwiMr Elmnlon Contour Mip*.
8«*w* MonAoring W*M
1, fDB7
_
IslLFft
ND
Ol
Figure 6
-------
L E C E N D
^'i'iM'ijjjlllSSQZr-a
. . .
*-™"*' «•*'"''t'T-
•VBWnrnT. .—.-JL^p.j^.mjjjjA—-tom-.W.- f i i i i i i t-i i >.
----. —T -i-*---^!, • _' i •. i JL,:.^^: ^p^»,
_
-------
\--BDi <7)
I,
\
1
I
\ ..
\
\
V-
\
,y&
LEGEND
LyJ rer rjnrcrdoiiixi !**•*
—- F*LF -n'p'cd iincarrenliolian
6CL 8r^« diiecJron IH*
Nol:n. Bhak-B T-xi^nrr^- «^
^0 nnrt 7S ftt* *i ^pl
&rrrl-P'Lrtli p»wili iD
17 jrJ 20 '**< •'ji
JCI / Jcin^s C^fmicDh, InC
lMoonc*mrttton M«p of PCE In Qroundmltr,
17 • 25 FMt bg>, Augwt 17 - 32,1906
Caledonia. NOT Yortc
8
11
-------
[--*
mi
I'
^
li'J
^
\ •;-"
LEGEND
& Ur.nlt.ynni} «-|ii (tv*- NM*«f* i
tl«C'
JCt.
"O!
'el t«Hgf Bf I ftp^f- ^ ^^-(|
T.iii' * ?• (( * if,; r.i
-------
APPENDIX II
TABLES
-------
TABLES
Table 1 Sampling Results- Village of Caledonia water supply
wells- March 21, 2000
Table 2 Approximate Concentrations of Potential Chemicals of
Concern
Table 3 Selection of Exposure Pathways
Table 4 Summary of Receptor Risks and Hazards for Potential
Chemicals of Concern - On-Site Worker
Table 5 Summary of Receptor Risks and Hazards for Potential
Chemicals of Concern - Off-Site Adult Resident
Table 6 Future Groundwater Use - Hypothetical Scenario
Table 7 Summary of Soil and Groundwater Remediation Goals
Table 8 Soil Vapor Extraction - Costs
Table 9 Groundwater Remedy - Costs
-------
Wayiand Laboratory S»rvk« _ ELAP#11338
1341
»0.*w*n
, 10T1-WJ
CLIENT: Village of Caledonia SAMFJ-t NUMBER:
3095 Wt»t Mftin S»«rt iAMPLt DATE/TIME; 3/71/00 07 30
Cttadom*. N Y. 14423 DATE/TIME RKC£IVEI>: 3/21/00 U30
DATE REPORTED
¥£DZIUL ID* 250101 3 SAMPLED B V : R
COUNTY: Uv^ton SAMPLE LOCATION:
MATRJX Gnnbng Water
• ••*•*••« •••••••••P •*« •••»! *••••••••••*•••••«• »*t*« !»**••**• It»«*«l«
(EPA 502.2,
<0 5
<,05
<0 5
tfl 3
<0 3
cO 5
<0 3
-------
WAY LAND LABORATORY
Coitlfmii rf,.
Sampk
I 3-Di£lil
-------
Table 2. Approximate Concentrations of Potential Chemicals of Concern
JCI (ones Chemicals, Inc. Site, Caledonia, New York
Potential Chemicals of
Concern
Teirachloroethene {PCE)
Trichloroeihene (TCEj
1,2-Dichloroetriene (1.2-DCE)
1,1-Dichloroethene (1,1-DCE)
Vinyl Chloride
Unsaturated Soil
(m&'kfc)
0.002-330
0.002-0 J 20
0.002-0.010
-------
U It (. 1UT< 111 LXI'OSUIT.
CAi s c.i
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Soil
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Table 3
Page 2 of 3
-------
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Jl«M-|c W* „,., to «.,,,*„ ^U, Un^ ^^ «M.,
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ttallMlcs rrta-^ mi.jf4'fc "*> Jri^nnl «• to -in urt-iil* i**C*|>1i!iC
VO'il'ISS "T«af m'fliaVc ^ wrtiicnl a* to in oil S'lfl lecrpJar
iH,!!^Ll»»h>..«-.Inr.^l(«l
U-j w s'lt i eid wilt ejpCtllO inir* PTMTtttkdlfl ftilurfl
,*, „ „, ,.ni, ,,p.cl,d „„., „„.„.„„,. , ,
:. ^.^OBdiartn.im.iifciHi.if
.'lllj,.^ n,.,,' ,T,,L]l Jl» n »nr,|,.,l flv „ an ryi HI, ,<,,f,,v
KaSid&fll* li-* ncJl Lo Silfl *mirft'M>m U^ w l^uif*N
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Ihi! •wortnrr
:; riiT.hr.Ct1 if*
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FOliirn Ihrmijlf 1hr fp»iii";lRin ?nrt nM|./ rjli'jfi
Table 3
Page 3 of 3
-------
SUMMARY Of RECEPTOR RISKS ANC HAZARDS t'OR COPCs
KCASONADLE MAXIMUM EXF'OSUfiC
SOURCE UANAtJt HINT ZONE. JONES CHEMICALS. CALEDONIA. NY
« Scenario Timer jm« Ciiritimfuiur*
R*Cf plor PqpuljHian Dn Lil« Worker
Rectplo' »gs ASirtl
U^n
Soil
Soil anrf
IVoijrKfiM&ler
!:z
"
Air
Puail
5.le 55,1
flLjIdoDr A*
C^-r,,
(Ituh
|fM>i
Tti
C.-^n.R,,
!..,.„,„
3006.06
: -IJL (ii.-
-
llV-.jl
} J 1 1' 1 1
1 401 05
1 4UI II';
>!><.)), 4Cii'i"p o'»l nriir (.1
Tnlal Pi'H Across AI' Mt?d<3 -3iiJ All Eipi:-t
Oc-nnal
? .'OL-06
] '.ME- 10
? ;ni. ue
-
.r Ruulel
BL*/:e^7c^Jl
5 J0[ 06
•>.'Dt-ul.
< 21E-11
NC
I «r.F P'
l^t. 76E-01
> ME P:
i eiiE-Bi
D.nn^
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! B^l1 (ii
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-
R-^f«J Td*l
i 79C 0?
3 »iE 05
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7 »3E 06
1 'CF 01
1 «<>r 05
1 !-O ai
Tf>1al Mgra/^ Inri*!* Aciu» W| Wci>j jixl AH E'pObn* Hfl\(lf s | 7 DHH-OI
TolailLiverlMi =
fDl-l [Hnarrf--r| Ml -
?OflC ni
; o: 04
NC • No! C*rfi
Table 4
Page 1 of 2
-------
SUMMARY u(: M CUMOH HISKS ANU IUVARLIS ten CDPCs
J«:AVONAlHC MAXIMUM IXPOSUKt
MA»iAi'y;MLNi /oru'. Jutif.SCHiiuicAiS, CAI CDQMIA. NY
ItScenanp iirnffff jirnfi C*JffCnyFulUfC
jme^ep.lof Paimlal'u**1 On-S»il* lArorker
1 lieCefilor *jfK AJ'iM
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f mf
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nt:<l:cii»i>t
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-
ffli'll Hill ikd ImJci /iClDiS "|[ Ml'<].< i«IHl /•!! I '["-'iuff Railfi
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Table 4
Page 2 of 2
-------
Nulri
NC^f1 - Nnt a c
fK". - Ndl EJiici
OF nFCEIMOR RISKS AMU HAZARDS FOR C
REASON AE!» E MAXIMUM HXPOGURE
SOURCE MANAGEMENT 2ONF, JONCS CHEMICALS, CALEDONIA, MY
Aflui
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-------
oil
Scenario
f fmrpiix
KCLC(J''-«
Soil
OH-Si|» Pf-
AOLlM
Pont
SUMMARY OF NCCCCIOR RI5KS ANPIIAZARD3 FCR I'-OPCs
I AfiOOM MANAGEMENT 70NC. JONES CHEMlCAl 5. CALEDONIA. NY
«—,
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Total [l.merj Ml =•
Total IHiooOP Ml - | J?7E
Q 3
Table 5
Page 2 oi 3
-------
pss
M.e&cpiTM
jfegCEJ1^1*
SUMMARY UK Ni:ci;r>7on KIKKS AND HAIMRDS ron cnno?
RlASnNAHl h MAXIMUM EXPOSURE
M IL MANAf.U-Ml-N I /UNH. JONLS CHbMlCAl S. CAI.LUONIA. NY
Cu"«ni,'Fuiuiff
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Table 5
Page 3 of 3
-------
Jones Chemical
Table 6, Page 1 of 6: Future Ground water Use: Overburden Aquifer
RESIDENTIAL INGESTIOfl OF TAP WATER: ADULT
EXPOSURE PARAMETERS TOTAL 3D YR CANCER RISK :
CAHCFR NONGANCER
EXPOSURE DURATION (YEARS)
EXPOSURE FREQUENCY (DAYSfY)
INGCSTIOH RATE I
AVERAGING TlMEfDj
BODY WEIGHT (KG)
COMPOUND
CJ9-1.2-dichkxoethBn
tnch breathe rw
PCE
Dibit) riw>ehlort5i-ii
3902
D0012
RESIDENTIAL INGEST1ON Of DRINKING VYATEP; CHILD (AGE « . 6)
EXPOSURE PARAMETERS
EXPOSURE DURATION (YEARS)
EXPOSURE FREQUENCY (OAYSfr)
INGEET1ON RATE (UDAY>
AVE RAGING T(ME(D>
BODYWEIGHT(KG>
COMPOUND
PCE
0038
0 IlOJfi
0 D'9
3 902
DOT13
303E-003
2A 2<« TOTAL CANCER « is
HSO :3SO
2 ? TOTAL HI
25550 B760
70 70
CANCER
COSE CWfCER DOSE
(MG4 1 04E-003
3.57E-005 BlE-OCi 2 !BE-d07 1.04E-OM
46DE-004 1 1 1E-002 5 06C-OC« 1 ME-tiDJ
35.'ECOJ S2E-Q02 191E-003 1 07E-flOI
1 13E-005 8
CANCER NONC,ANC£fi
s 6 lOtAi CANCER RIS
350 JSD
1 1 TOTAl HI
?J55i} 2190
1S 15
CANCER
DC'SE CANCEft DOSE
fMO/KST) C.Pf RISK i.MGfKG/Dt
7 Q3f -OCA ?4JE-CiQ3
20BE-005 61E-PD1 1 27E-007 2.4JE-OM
;'66.E-004 1 1E-007 2 95E-006 3 UE-PO^
2 UE-002 SJf.-ao? lliEDOl 2d6E-OD1
C 58E-ODB . e4E-C02 S S2E-C07 7 67E-005
K 1 91E-C03
1 1DP»«J1
NONCANCER
RfD HO
| 1 OOE-O'J? 1 04E-001
1 dOE-002 1 04E-M2
6 OOE-DOJ 2 24E-MM
1 OE-D021 1 07E-t001
2 MIE-002 i 64E-003
.K 1 12E-003
25TE-OD1
NONCA^CER
Rd rtQ
1 CHJE-W2 . ?.43e.001
1 OQE^002 2.43E-002
6 QOE-001 <> ?JE-OtM
1 OE-002 249E»Q01
2 OOE-00? 3. (ME -003
-------
Jones Chemical
Table 6, Page 2 of 6: Future Ground water Use: Overburden Aquifer
RESIDENTIAL; INHALATION OF VAPORS AT THE SHOWER HEAD: ADULT
EXPOSURE DURATION (YEARS)
EXPOSURE FREQUENCY (DAYS/Y1
INHALATION RATE (I
TIME Of SHOWER (HR)
TIME AFTER SHOWEP
WATER FLOW RATE (UMR)
BATHROOM VOLUME (M3(
AVERAGING TIME(Df
BOOT WEIGHT (KG)
COMPOUND
cis-1
PGE
EXPOSURf PARAMETERS
CANCER NONCANCER
J* TOTAL CANCER RISK
340
083 TOTAL Ml:
1 16E-OP4
291E*000
TOTAL 30 TR CANCER RIS
33SE-OM
GVM COMC VOL. F«X
!M(VL) (UNITLESS)
DOW D i
0.0039 0 5
D049 OS
3902 05
OO01$ 05
D 33 0 13
750 7iO
1? 12
25S?0 6760
70 70
CfaMAXf AIR COMC
(MG/M3I
fl 2«B7S 023289331687
«02K£7S OD?3?a9j319
« JB2612S 0 30030830603
3D 4B4375 21 91
-------
Table 6, Page 3 0(6: Future Ground water Use: Overburden Aquifer
RESIDENTIAL SHOWER SCENARIO CNd fO to 6 v»*r* oW)
EXPOSURE DURATION (YEARS;
EXPOSURE FREQUENCY (DAY&iVJ
INHALATION RATE (MVHH)
TIME OF SHOWER (HR>
IIME AFTER SHOWER (HPJ
WATER FLOW RATE (LTHR)
BATHROOM VOUPMF <
AVERAGING TIME (Dj
COMPOUND
GW CONG
(MGn.)
EXPOSURE PARAMETERS
CANCER
VOL FRX
(UNITLESS)
NONCANCER
f>
350
OH?
D S
0 5
rsn
12
2S440
15
6
ISO
042
D5
o;
tK
12
2190
15
6 TOTAL CANCER RI$K
MR CONC
(MQMS)
LX)SE
(MG'KGJD)
2 isE-no4
?:>;F«OD1
CANCER
NOHCANCER
CPF
CANCER
RISK
DOSE
K1T>
HO
PCE
0033
(lOQZ*
DQO
3 SO?
00012
0 5
0 5
OS
as
OS
0 59375
0.059375
0 765625
6046375
001875
D 4453175
C(M«53125
0.57421*75
«5 7i65EJS
0011f»25
1 02E-003
1QZE-OD4
112E-003
1.04E-DQ1
7 24E-D05
a IDf -{in;
600E-P03
2 OE-CO3
2 10E-CKM
1 ZPt-OOJ
1.ME-002
l.?3E»aOO
3 7SE-OO4
«%E005
1 40E-OD1
» 39E+CCH
8 T7F*nOO
-------
Jones Chemical
Table 6, Page 4 of 6: Future Ground water Use: Bedrock Aquifer
RESIDENTIAL INCEPTION OF TAP WATER: ADULT
EXPOSURE PARAMETERS TOTAL. 30 y« CANCER RISK :
CANCER
EXPOSURE DURATION (YEARS)
EXPOSURE FREQUENCY (DAYS")
INGESTION RATE (L/DAY)
AVERAGING TIME 1C)
BODY WEIGHT (KG)
Grt*nawat«r Cone
COMPOUND
PCE
0 00 1 1
D D07B
O.Z97
RESIDENTIAL IMCEST1ON OF CHINKING WATER : CHILD (AGE 9 . 6)
EXPOSURE PARAMETERS
EXPOSURE DURATION (YEARS)
EXPOSURE FREO.UENCY(tiAYS,Y|.
1NGESTION RATE jLDAYt
AVERAGING TIME (D)
BODY WEIGHT
COMPOUND
01 1.2-dcfttoroeilhen
Benzene
fMGJl)
0037
own
PCE
0.297
?4
2
aswo
70
DOSE
(MG/KG/D)
3«aF>OW
1.03E-005
7.33E-DO5
27SE 003
GE 9 - 6)
rcDt'
1 ^rf^i
CANCER
6
1
15
DOSE
(MG'KG^D)
2.0JE-004
ROJE-'XJB
427E-OOJ
16JE-003
24 TOTAL CANCER RfSK
2 TOTAL HI.
9760
70
CANCER
ONCEP DOSE
CPE RISK IMG/KG;DJ
i 1 01E-CC3
55E-002 568E-C07 I 301E-005
1 1E-OCZ eO6E-eD7 Z1«E-OQ4
SZE-OOZ 145E-DU4 8 UE-003
NONCANCER
6 TOTAL CANCER RlS>
1 TOTAL HI
15
CAHCRR
CANCER >i DOSE
CPF | RISK ,' (MOKGJD)
i . 2 37E-003
55E-OOZ 3 3^E-O:7 703E-OQ5
VIE-OTZ 4 70E-007 • 4 99E-0»«
SJE-OOJ B46E-Oa5 !' 1 90E-00?
1 49F-CKM
961E-OQ1
NON CANCER
R(D HQ
1 WE-002 i 1 01E-001
3.00E-003 1.ME-OQ5
: 600E-O03 35eE-007
1 OE-OOJ a ME -001
: 854E-M5
2 24E»000
NONCANCER
R(D HO
1 OOE-CW2 , 2.37E-001
3WE-003 2XE-W2
. 600E-M3 B3TE-IXI2
I 1 OE-002 ' 190E400Q
-------
Jones Chemical
Table 6, Page 5 of 6: Future Ground water Use: Bedrock Aquifer
RESIDENTIAL; (NHALATIOW OF VAPORS AT THE SHOWER HEAD: AMJIT
EXPOSURE PARAMETERS.
CANCER
IXPOSURI DURATION i
EXPOSURE FREQUENCY (OAYSfY)
INHALATION RATE (M3/HR)
TIME OF SHOWER (HR|
TIME AFTER SHQVUER
WATER FLOW RATE (LJHR)
BATHROOM VOLUME (Ml)
AVERAGING TIME (D>
BODY WEIGHT (KG)
COMPOUND
W.1.2-«i*kyo«m
PCE
GW COHC
tMGnj
003?
9 00 11
OOD7B
0297
*/OL FRX
OINITLESS)
05
e.s
a 5
05
NONCAMCER
2*
358
OSJ
025
03-1
750
12
25550
70
Wl
24
3SD
093
025
033
750
12
WSfl
70
AIR CONG
WG/MtJ)
02257B454M14
0.006741«4»70»
O.OSD9175 004TB0441»1t»
2320312S 1.B2024515088?
TOTAl CANCER RISK -
TDTAIHI
DOSE
S 13E-004
1 62E-6C5
1 ORE 004
4 12E-083
* J2E-QD6
i IZE-OOI
CAWCER
CPF
290^.00?
600E-003
2QE-OO3
TOTAL M YR CANCER RIS
i.TSE-M!
NONCAMCER
CANCER
RISK
DOSE
l*«3?KG/D>
RID
j 1 50E-OQ3
•»-»2E-P07 ' * 45E-OOS
8OE-M7 .. 3.15E-004
1 7E-DQJ
40E-OD1
2 62E-002
-------
RESIDENTIAL SHOWEH
Table 6, Page 6 of 6: Future Ground water Use: Bedrock Aquifer
Cimd
-------
Table 7
Summary of Soil and Groundwater Remediation Coals
JC1 Jones Chemicals, Inc.
Caledonia, New York
Parameter
TetrachloToelhenc
Tnchloroeihene
cis-i ,2-Djchloroetherw
Tran*- 1,2-DiL'hloroeLhenpe
Soil Medium
(mg/kg)'
1.4
0.7
NA
0.3
i
l.l-Dichloroethene ' 0.4
Vinyl Chloride
0.2
Groundwaler
Medium (v&'lf
5
5
5
5
5
2
1 Values are based on KYSDEC TAGM #H\\rR-944046: Soil Cleanup Objectives
10 Protect Oroundwater Quality. Concentrations are presented in milligrams per
kilogram.
2 MCL values arc based on New York State Groundwaler Quality Standards 6
NYCRR Pan 703.5. Qmctmraiions are presented in rmcroiraTm per liter.
Page I of t
-------
Jones Chemicals
TABLE 8
Soil Vapor Extraction
Costs
Direct Capital Costs
Soil Vapor Extraction Well Installation
Seven, 4-inch diameter PVC wells® 51,000 each $7,000
IDW disposal (as D039 code) @ $350 per drum x 10 drums $3,500
Mobili^ation and demobilization $ 1 ,000
Per Diem - 3 person crew © $125 per day x 3 days 51,125
Soil Vaopr Extraction Piping and Vaulcs
Surface removal and disposal @ $2.00 per square foot (sf) x 400 sf $800
Surface repair - $3.00 per sf x 400 sf $1,200
Excavation, backfill, and compaction of Ihc trench - $10 per ft x 200 linear feet (If) 52,000
Pipe installation and testing - $30 per fool x 200 feet 56.000
SVE well vaults, gauges, valves, well head connections, and concrete -
$1,500 per well x 1 wells $10,500
SVE equipment installation (lump sum) - $ 10,000
Equipment Gusts
SVE system (e.g., structure, moisture, gauges, valves controls, and mufflers) $35,000
GAC purchase and disposal costs @ $4.50 per pound x 4,000 pounds $18.000
Transportation $4.000
Electrical Modifications
Lump sum $15,000
Site restoration $5.000
Confirmatory Direct-Push Soil Sampling
Mobilisation/Demobilization $500
Soil sampling - $200 per boring x 10 borings $2.000
Analysis by USEPA Method 8021
Table 8, Page 1 of 3
-------
(ones CNemfcafs
Twelve samples x $ 110 per sample $ 1,320
Two QA/QC samples x $110 per sample $220
Sample shipping , ,...,.. 1150
Subtotal $124.315
Contingency® 2Q% $24.863
TOTAL $149.178
A4-3: Indirect Capital Costs
Engineering design documents ... $40,000
Project management ., , $15,000
Air permitting ,, S 10.000
Construction and Well Installation Oversight
Staff Engineer @ 12 hours per day x 15 days x S85 per hour 515.300
Per diem, lodging, and vehicle - $150 per day x 15 days ., $2,250
Travel to and from the site @ 20 hours x $85 per hour, plus $1,000 for airfare $2,700
System Startup and Shakedown
Staff Engineer @ 12 hours per day x 5 days x $85 per hour $5,100
Technician @ 12 hours per day x 5 days .x $70 per hour $4,200
Per diem. lodging, and vehicle @ Si50 per day x 5 days x 2 people $1,5(30
Travel to and from die site @ 20 hours x $155 per hour, plus 52,000 for airfare $5.100
Startup equipment and sampling equipment . . $1,000
Off-gas sample analysis - 12 samples x $300 per sample $3,600
Sample shipping - three shipments@ S100each ,.,, ,.,.. $300
Construction completion and startup reporting ...,, $10.000
Confirmatory Direct Push Soil Sampling
Siaff Engineer @ 12 hours per day x 2 days x $85 per hour., $2,040
Per diem, lodging, and vehicle @ Si50 per day x 2 days,, $300
Travel to and from the site @ 20 hours x $85 per hour, pfys $1,000 for airfare ,..,$2,700
Sampling report , ,,,, ,.., $10.000
TOTAL , $131,090
Ttbk 8, Page 2 of 3
-------
\orxx Chemicals.
A4-4: Operation, Maintenance, and Monitoring
Monthly Visits
Two technicians @ $70 per hour x 12 hours each per visit x 12 visits $20.160
Per diem, expendables, and field equipment - $500 per visit x 12 visits $6,000
Sample Analysis
Influent, effluent, and duplicate samples- $250 each x 12 visits $9,000
Shipping - $100 per event x 12 visits „ $1,200
Electricity - 30 horsepower @ $800 per horsepower per year $24.000
Annual repair costs „ $6,000
SAC Rep lacemertt
Replacement and djsposal of spent GAC - $4.50 per pound ,x 4,000 pounds $18,000
Transportation 52,000
Anmia} report . $15,000
Subtotal $101.360
Contingency @ 20^ $20.272
TOTAL $121,632
The net present value of OM&M over the anticipated three years of the SVE system operation
is $319,201.
Table 8, Page 3 «r 3
-------
Chemicals
TABLE 9
Source Area Extraction and Treatment, In-Situ Treatment of DNAPL,
Monitored Natural Attenuation of the Plume Outside the Source Area,
and Institutional Controls
cosrs
Institutional Controls/Other Controls
Direct Capital Costs
It is assumed that this technology will have no mobilization-associated com.
Staff Engineer @ 12 hours per day x 5 days x S85 per hour $5,100
Per diem, lodging, and vehicle - $150 per day x 5 days , ,, $750
Lagoon area fencing - 8-feet high. 900 linear feet x $30,'linear foot $27,000
Source area fencing - 8-feet high, 500 feel long @ $30/line.ar foot $15,000
Warning Signs.,, .$2,000
Subtotal , $49,850
Contingency ® 20%, .,..$9.970
TOTAL $59.820
Indirect Capital Costs
Engineering and project management , SI0,000
Legal fees for deed restrictions $15.000
TOTAL t25.000
Operation, Maintenance, and1 Monitoring Costs
It is assumed that there will be no operation or maintenance coats for this technology It is also
assumed that this technology will not be used as a stand-alone technology; therefore, i( does not
have any monitor ing costs.
, Pag* I of?
-------
Jones Chemicals
Monitored Natural Attenuation
Capital Costs
It us assumed that there would be no direct or indirect capital costs tor implementing this
technology,
Operation, Maintenance, and Monitoring Costs
ll is assumed ihat there would be no operation or maintenance costs for this alternative. It is
assumed thai groundwater samples will b« collected quarterly for the first 2 years and then
semiaimually for 28 years from up to 20 groundwater monitoring wells. It is also assumed that
the most Natural Attenuation Indicative Parameters will be analyzed at a laboratory, and that
no additional shipping charges will be required.
Quarterly Monitoring
Two technicians @ $70 per hour x 6& hours each per visit x 4 visits $38.080
Per Diem @ Si25 per day x 2 people x 4 visits x 5 days per visit 5,5,000
Vehicle @ $400 pei week x 4 weeks per year $1,600
Sampling equipment and materials @ Sl.SOO per visil x 4 visits $7,200
Analysis by United Slates Environmental Protection Agency Method (EPA Method) 8021
Twenty samples from monitoring wells - $110 each x 4 visits $8,800
Four QA/QC samples - $110 each x 4 visits Si,600
Shipping - $250 per visit x 4 visits,.. $1,00(1
Analysis of Natural Attenuation Indicative Parameters
Twenty samples from monitoring wells @ $200 each x 2 visits $8,000
Four QA/QC samples® 5200 each x 2 visits 5J1600
Annual Report $30.000
Quarterly subtotal $102,880
Contingency @ 20% $20.576
Quarterly Total $123.456
Assuming 2 years of quarterly monitored naturaf attenuation and groundwater monitoring, the
net present value of the quarterly sampling is $223,211.
Table 9, Page 2 of 7
-------
Jones Chemicals
Semiannual Monitoring
Two technicians @ $70 per hour x 68 hours each ptr visit x 2 visits 519,040
Per Diem @ $125 per day x 2 peopJe x 2 visits x 5 days per visit $2,500
Vehicle @ $400 per week x 2 weeks per year 5800
Sampling equipment and materials @ $1,800 per visit x 2 visits $3,600
Analysis by United States Environmental Protection Agency Method (EPA Method) 8021
Twenty samples from monitoring wells @ $110 each x 2 visiis $4,400
Four QA/QC samples @ $110 each x2 visits $880
Shipping <$ $250 (each visit) $300
Analysis of Natural Attenuation Indicative Parameters
Twenty samples from monitoring wells @ $200 each x 2 visits $8,000
Four QA/QC samples® $200 each x2 visits $1,600
Annual Report.. $20,000
Semiannual subtotal $61,320
Contingency @ 20%.... $12.264
Semiannual total $73.584
Assuming 28 years of monitoring, the net present value for semiannual monitoring
is $780,064. This number is derived by calculating the semiannual NPV for 30 years and
subtracting the semiannual NPV for Lhe initial 2 years that are addressed in the quarterly
monitoring section.
The total net present value for 30 years of operation, maintenance, anJ monitoring for this
technology is $1.003,275.
Source Area Pump and Treat
Direct Capital Costs
Well installation
Two 10-inch diameter wells to30feetbgs- $12.000 each $24,000
One 6-inch diameter wt\\ to 55 ftet bgs - lump sum $10S000
IDW disposal - 40 drums @ $350 each $14.000
Convert existing west well to a monitoring well $1,000
Tabk 9, Page 3 of 7
-------
/ones
Piping Trench (2 feet wide x 3.5 feet deep x 350 feet long)
Excavation- 350 feet long @ $10 per foot $3,500
Piping - $28 per fool x 350 feet x 2 wells $19.600
Electric conduit - $7.75 per linear foot x 350 feet x 1 welts 55,425
Backfill and compaction- $5 per foot x 350 feet Si,750
Surface replacement - $5 per sfxTCW sf $3.500
Well Vaults
Installation- $1..500 each x 3 $4.500
Piping and appurtenances - $1,200 each x 3 $3,600
Extraction Pumps
TwoGravel well pumps - $2,000 each $4%000
Bedrock zone well pump $1,500
Air Stripping Tower Modifications
Piping - Lump sum $6,000
Control s - Lump sum $ 10,000
Disch a rge - Lump sum , $ 10,000
Surface Replacement
Six-inch pavement base @ SUl/sf x 1,000 .sf Si, 110
Two-inch asphalt pavement @ Jl.87/sfx l.OOOsf Si.870
Electrical Modifications
Lump sum $10,000
Site restoration $5,000
Subtotal $140,355
Contingency © 20% $28.071
TOTAL SI 68.426
Indirect Implementation Costs
Engineering design documents, $50,000
Project management $ 10,000
Air permitting (modifications to the existing air stripper) $10,000
Table 9, Page 4 of 7
-------
/ones Chemicals
Construction Oversight
Staff Engineer @ 12 hours per day x 5 days x $85 per hour $5,100
Per diem, lodging, and vehicle - $150 per day x 5 days $750
Travel to anil from rhe Site - 20 hours x $85 per hour, plus $1.000 Tor airfare $2.700
Ss'Stem Startup and Shakedown
Staff Engineer - 12 hours per day x 3 days x $85 per hour 53,060
Technician - 12 hours per day x 3 days x $70 per hour 52,520
Per diem, lodging, and vehicle @ $250 per day x 3 days $750
Technician travel to and from Site - 20 hours x $70 per hour, plus $1,000 for airfare.,., 52,400
Start-up equipment $ 1,000
Influent and effluent sample analysis - 6 samples x $110 per sample $660
Sample shipping $ 100
Construction completion reporting $20,000
TOTAL $109.040
Operation, Maintenance, and Monitoring Costs
It is assumed thai JCI will use the treated groundwater for its processes at the facility. It is also
assumed that JCf personnel would conduct operation, maintenance and monitoring activities as
part oi their existing process No additional labor costs or expenses will be caused by this
technology tor operation, maintenance, and monitoring during the anticipated 15 years for this
technology to achieve remediation objectives, Groundwacer monitoring costs associated with
this technology are addressed in Monitored Natural Attenuation.
Potassium Permanganate Injection Cost Estimate
Direct Capital Costs
Well Installations
Mobilizat i on/Demobil ization $500
Per Diem and lodging, 2 man crew - $50 per nian per day K 3 days $300
Injection Welis
One 4-inch diameter well to 25 feet bgs $1,000
One 4-inch diameter well to 50 feet bgs $2,200
IDW disposal - 8dnams © $350 each $2,800
Table 9, Page S of 7
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Chemicals
Monitoring Wells
Two2-inch diameter wells to 25 feet bg* - $500 each $1,000
Two 2-inch diameter wells to 50 feet bgs - $1,200 each $2,400
1DW disposal - 20 drums @ $350 each $7,000
Weil Vaults and Piping
Installation, piping and appurtenances - $1,500 each * 6 weils $9,000
Mixing System and Equipment
System and equipment - Lump sum $10,000
System and equipment installation - Lump sum $15,000
Subtotal $51,200
Contingency @ 20% $10.240
TOTAL $61.440
A9-2: tndiretf Implementation Costs
Engineering design documents. $ 10,000
Project management $2.500
Injection permit and regulatory variance $ I0.000
Construction Oversight
Staff Engineer @ 12 hours per day x 5 days x $85 per hour $5,100
Per diem, lodging, and vehicle - $150 per day x 5 days $750
Travel to and from Site - 20 hours x SS5 per hour, plus $1.000 for airfare S2.7QO
Svsteip_Siarmp and Shakedown
Staff Engineer - J2 hours per day x 2 days x $85 per hour ... $2,040
Technician - 12 hours per day x 2 days x $70 per hour $],6SU
Per diem, lodging, and vehicle $250 per day x 2 days $500
Travel to and from the Site - 20 hours x $155 per hour, plus $2,000 for airfare $5.100
Start-up equipment $ 1.500
Groundwater sample analysis - 12 samples x $200 per sample .$2,400
QA/QC samples - 2 samples x $200 per sample ,.. $400
Sample shipping- $100 per event x 2 events $200
Construction completion reporting $) 0,000
TOTAL $54.870
Table 9. Pag* 6 of 7
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fortes Chemicals
Operation, Maintenance, and Monitoring Costs
Monitoring - Annual Visit
Two technicians @ S70 per hour x 10 hours each per day x 8 days $5,600
Per diem, expendables, and field equipment ($500 per day x 8 days) 54,000
Annual Report/ Project Management $ 10,000
Operation
Annual KMnO4 - purchase and transportation $4,(XX)
Utilities (water and electricity) $2,000
Maintenance
Annual repair costs S3,000
Subtotal $28,600
Contingency @ 20%,,.. $5.720
TOTAL $34.320
Table 9, Page Tot 7
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APPENDIX III
ADMINISTRATIVE RECORD INDEX
-------
JOKES CHEMICALS, INC. FACILITY SITE
ADMINISTRATIVE RECORD
INDEX OF DOCUMENTS
1.0 SITE IDENTIFICATION
1.4 Site Investigation Reports
t3 . lOC'COl - Report: Figure 1 , _ H a z a LOCUS .Ran k ing 5 y S *: e-n C :• v e r
100091 Sheet, Jones Chemicals, Inc., Revised: June 2,"-,
1967, 2: ' Hey is ion: September 18, l'i>£?.
3.0 REMEDIAL INVESTIGATION
3.3 Work Plans
P, 3CCDCi - Flan: Tieaiabilnv Study Hork Plan. Re view ?L-
3 C 0 0 3 2 Available Grcundwater 'J'rcairr.e-ni Tecrmo: ocii .; .
r: and Cperat. ion^l Farorigter^ fcr._g. I''-.'."'' .-M
ScriBD_inq System. Jcnos C.lien-:ic3lsr
Caledonia, ft'ew York, prepared by ConestDqo-Roverrs
& Associate 5, pr CD a red for' U.S. EL- A, Regie" IT,
March 1591.
33C033 - Plant r.-.'or:< ?iar.. s-pple::ierr a 1 Remedial
"j o 0 H S 3 I n ve s t i aa t i o n / Ffr a 5 i b J 1 1 1 v 3 1 UG v , c o 1 1 e s C f ; •:•; ir. i c .-. j. 3 ,
Inc., Caledonia, New York, prepared by ri^nestrc:^-
1^ over 3 6 Associates, prepared for U.S. LEA, R.-CI:
II, Mcsrc:-: 1991.
300384 - Plar;: Field Operations PlarL. J5uppleir.enc<3: ."-I/F3.
3 0 0450 Volume I: Sair.pl Ing arid AnalvgjLs Plan •^'Ar; , ,.T r n e ?
Cheir.ica^Sf Inc., Caledonia, Kev.- York, prepared by
Cones tog a -Rover s d Associates, prepared foi n.p.
EPA, Region II, June 1591.
-------
P. 30C451 - F;lar.; Field Operations Flan, Supplemental RI/D'S,
3nC541 VolarT'e II: Quality Assurance PrcnecL Plan :pAPF:- ,
Jor.es Chemicals, In::., Caledonia, New Yc-rk,
prepared by Coriestoca-Rover3 S Associates,
prepared fcr L". 5. E?A, Region II, Jure 19^1.
?. 300 [>42 - Plan: Field Operations Plan, Supplementa 1 FI/l-'S,
300643 VcJune III: :>ealth_j._J.jafctjv'_Fl3n (HS?:, Jone;,
Cbeir.iCd Is, Inc., Caledcr.ia, New York, prepare:! ;;•>'
Cones tog a-Rovers 5 Associates, prepared !•::•!' ',', S .
EPA, Region II, Ju:.o 1^31.
3.4 Remedial Investigation Reports
LJ. 3006^4 - P.eporC; Site Sunniraiy Ropoil, RoirodicU
300810 Investigation, Jcr.cs Cr.cnicjl.?, I::c. F^ci-itiy,
Caiedor-j 5, Nev York, Adr.i ni st rat ivc Order :.T.
Con sen.', Index N D . II, C E RCLA -1C 2 1 u , prepoivrd c/
Lev i n e • Fr i c ke • Re co r; Inc., p r t pa re d C r.; t Jc: •-.•- a
Chemicals, Inc., November 11, 1^96.
P. 3DC611 - Report: Remedial Invest iqation Report, JCI/Cor:65
3DI012 ChGnicals, Inc. Facility, C
prepared by Way land Laboratory Services, Jvjiv ",
2000.
4.0 FEASIBILITY STUDY
4.3 Feasibility Study Reports
?. 400001 - Report: Treatabi1lly Study Evaluation Report;
4COQ63 Jones Crier.icals, I::c. Facility, Calc-ccni:i, New
York- A dm i n i s t r a 11 v e Or de r on Cor sent, I r.de x N •.
-------
II, CFRCI.A-:02'J 10, preps red t-y Le^ i r 10 • 1' r i L-.
22, 2000.
4.6 Correspondence
F, 400208 - Facsimile transnitial 10 Mr. George Jacob,
A C02 1 [> Rened i a ] Pro_i ect f-'a nage r, U.S. F,PA, Req : or: T 7,
from S^ekhdi Melko'-e, ?.G., Senior Hydro ceo 1 o:j - :
LFR Levirie Fricke, March 31, 20 DC. ;ALlac:.:m::;:
Lszter {with a" tacr.rTier.T-S) r,o Mr. George Jacob,
Rerne-d. i a 1 F ro j e c t Mu ri d y o i , U . S , E?A, Reg i o r. T T ,
LICIT; E. Ca.nbeiro, fc^L ohekhar R. Kelkor.e, F .•;!.,
Senior Hydrogeolcgist, ie: JCI Jones Che;n .ca ". -•,
Inc. S u p o r f u r: cl Sit. o; C a 1 e :.•; c r: i j , K e w Y o i <,
A'Jir.in i stz at i ve Orcer o:i Condor.'., Ir.cex N\".,
CE:RCLA-iC2iOr Feasibility Stuay Report.: r-
Docur.ent, March 31, 2CCC.;
7.0 ENFORCEMENT
7.3 Administrative Orders
r\ "?DCDC-1 - Administrative Order on Consent fcr Remedial
70C029 Inves-1 ioa' ion/ Feasibi 1 ity Study/ Ir. The ^citrtor
The Jones Chcnucoio Site, ColC'dcnia, K^w VOVK,
Jones Cr.ercicals, Inc., Respondent, Index Nc. I
CERCLA-10210, Xarch 22/ 13S1.
8.0 HEAiTH ASSESSMENTS
8.2 Toxicological Profiles
?. ' BDGOC1 - Report: H ea 11 h Ri s k As se s snnen t ^ Jcrie s_ C h cni c j_l_
eOC2[>0 lnc.__f'acilitv, Caledonia, New Ycrk, prepared o1
LFP, Levine • Fricke Inc., preparea for Jc-r&s
Ch em i ca 1 s, Inc., 3 cot em.be r 30, 19 v P .
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B . 3 Correspondence
P. £ 'JO 251 - Memcrar.cum to Mr. Gecrge Jacob, Rer.ecisi
5 ] 0 251 Me, nd gcr , EF, R D , Ne v: Y c r k Rened i a t; i or; E r c r. c h , f i :. ::
Ms. S'.na Ferr(rirar Ei:v_rcnnerital ScieriiisT, E?rl',
Program Support Branch, re: Jones l.'rierr.i c<% •
Prop o sed PI a r. , Ju 1 y 1 :? , 2 0 0 C ,
?. 800211:2 - Jones Chemicals Site, .^i.-k Assessment-. ror £
eOC2[":9 Hypothetical Off-Plant Grcundwater 3ce~aric,
yr.err.orajiduir. prepared by U.S. "£PA, Reqicp. 11, ,".._•.•
19, 200C,
F . ri C 0 2 6 C - Jcnc s Chemicals :l i ~ e , G rou ndwa ~ 6 r R^ne-': i s t i o :":
B C 0 2 6 0 Time Frames, memo r a ri d 'J :in. p r e pa r e a D v ". J , £ - F. ? A ,
Re g 1 o r; II, July 19, 2 j C C .
10.0 PUBLIC PARTICIPATION
10,9 Proposed Plan
P. 1U.CC001 - Plan: Superfar.d Proposed ?Igr;^_..Jc"£:s r;-..-= jr.i -•^.^L,
1 0 . GC 01 y in c, Supe r f •.: r. d S : t e, C a 1 e cl or la, L i v i n g s r o r:
f!t;-.:rir y. New Vui k ^ prepared t;y U.S. E?A> Pegi;-r,
71, July 20CO.
10.10 Correspondence
F. -:;.000]9 - !,ei,:ei tu Mi, Cue. Si::aer^a:;, L: , S. EIFA, I-e^i.:.
:•':..00019 II, from Ms. Mi-lid It- K. Ct-.apir.an, Code
Erifcicome/it Officer, Village cf C^l^-dor,i-, M-.v:
Vcrx, i e : Zoning s'..avus <; L' Jones CI:e;v.i Cd 1 ^
property, Hay 23, 20OC.
P. 1C. 00020 - Ler.-er t.o Mr. Richard L. Caspe, Director,
1C. 00 020 Emergency a/id Remedial Response J-ivi?ior,, "J . ''.' .
EPA, Region II, ircm -M. Michael J. Or?-r.o^,
Director, division c-i Eav^ronmcnl.ai Rcr:;crji.-t ic ::,
New 'i'crk State Department of L'nvironr.er.t^l
Conservation, re: Jor,e5 Chemicals, ID Kc, =-:-_':_-
0 03, F r o posed PIan, Ju1y 16, 20 j0.
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APPENDIX IV
STATE LETTER OF CONCURRENCE
-------
09/22'OQ FRJ 16:40 FAI
New York State Department of Environmental Conservation
Division of Environmental Remediation, Room 2BOB
50 Wolf Road, Albany. New York 12233-7010
Phorw:{51B)457-58o1 • FAX: 1518) 485-8404
Website: www.dBC.statB.ny.uS
Jchn P.
CornmissiDnef
Post-i*" Fax Mole
Mr Richard L. Caspe
Director
Emergency and Remedial Response Division
1.5. Environmental Protect] on A^cncry, Region
Floor 19 • £38
290 Broadway
New York, New York 10007-IS66
Dear Mr
Re: Joau Chemicals, 113 No. 8-26-M3
Record of Decision
Tht Nr* York Swtc Department of Environmental Conservation (NYSDEC) and Department of
Health (NYSDOH) have reviewed the Record of Decision daicd September 2000 prepared by the EPA
for this siie. We undr rsund the tPA's remedy for the siw (SoU Altcmalivt S-2. and Ground water
Aliemaove CW^l) includes vapor extraction of VOC contaminants from Ihc Formci Solvent lank
Source Area, ir-4itu DNAPL treatment via advanced oxidation, and the extraction and treatment of
comaminiiied gToundw-ater from ihe on-site plume. The extraction of groundwater will uke place in the
Former Solvent link Souice Area. The extracted groundwawr *>ll be treated by the planr air stripper
and dischaiged to the on-site lagoons. This discharge will meet the requjrements of the e^i?tuig
NYSDfC SPDES Pcrmji, \Vc understand that the remaining on-iite and ot'f-sile groundwaler plume will
not be ccHected hut that a long-term groundwasei monDitonng program will he conducied 10 determine if
groundwater quali^ improves suffiaently under natural condition*. If monitoring indicates that natural
attenuation is not effective in remediating off-site groundwatar contamination active remedial
will be considered. With this understanding, we concur with the Recoid of Decision for Jon«s
If you h&ve any que&tioL& or need additional information, p^ea&e contact Mr. Joseph Moloughney
at (51 g) 457 -031 5,
Michael 1.
Director
Division of Env\6nmCTita;
cc: J SiTitjcTmjiTi'G. Jacob,
A. Carlson.™. VanValkcnburg. NYSDOH
D. Napier. NYSDOH
R Van Houten, Livingston Co. DOH
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APPENDIX V
RESPONSIVENESS SUMMARY
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RESPONSIVENESS SUMMARY
Jones Chemical Superfund Site
INTRODUCTION
This Responsive ness Summary provides a summary of citizens'comments
and concerns received during the public comment period related to the
Jones Chemicals, Inc. site (Site) remedial investigation and feasibility
study (RI/FS) and the Proposed Plan, and provides the responses of the
U.S. Environmental Protection Agency (EPA) and the New York State
Department of Environmental Conservation (NYSDEC) to those comments
and concerns. All comments summarized in this document have been
considered in EPA and NYSDEC's final decision in the selection of a
remedy to address the contamination at the Site.
SUMMARY OF COMMUNITY RELATIONS ACTIVITIES
The July 2000 Proposed Plan, which identified EPA and NYSDEC's
preferred remedy and the basis for that preference, and the RI/FS reports
were made available to the public in both the Administrative Record and
information repositories maintained at the EPA Docket Room in the
Region II New York City office and two local information repositories: the
Village of Caledonia Library, 31 08 Main Street, Caledonia, New York and
the Village of Caledonia Clerks Office, 30-95 Main Street, Caledonia, New
York. The not ice of availability for these documents was published in the
Livingston County News on July 20, 2000. A public comment period was
held from July 20, 2000 to August 19, 2000. On August 14, 2000, EPA
conducted a publicmeeting at the Caledonia-Mumford Centra I School, 99
North Street, Caledonia, New York, to present the findings of the RI/FS
and answer questions from the public about the Site and the remedial
alternatives under consideration. Sixteen people, consisting of local
residents, a representative of the media, a potentially responsible party
(PRP) representative, and state and local government officials, attended
the public meeting.
OVERVIEW
The public generally supports the selected remedy, which includes,
among other things, in-situ soil vapor extraction (SVE) to address the
contaminated soil and groundwater extraction and treatment in the source
area, in-situ dense nonaqueous phase liquid treatment, and monitored
natural attenuation of the groundwater outside the source area to address
the contaminated groundwater.
Responses to the comments received at the public meeting (no written
comments were received) are summarized below. Attached to this
-------
Responsiveness Summary are the following Appendices:
Appendix V-a - Proposed Plan (July 2000)
Appendix V-b - Public Notice published in the Livingston County News
on July 20, 2000
Appendix V-c - August 14, 2000 Public Meeting Sign-In Sheet
Appendix V-d - August 14, 2000 Public Meeting Transcript
SUMMARY OF COMMENTS AND RESPONSES
A summary of the comments provided at the August 14, 2000 public
meeting, as well as EPA and NYSDEC's responses to them thereto, are
provided below. The comments and responses have been organized into
the following topics:
Site Contaminants
Threat to Public and Private Water Supplies
Risks Posed by the Site
Soil and Groundwater Treatment Processes
Financing of the Project
Comment #1
Response #1
Site Contaminants
A commenter asked what contaminants are present on-
Site and whether the extent of the soil and groundwater
contamination has been clearly defined.
Site soils and groundwater are contaminated, primarily,
with tetrachloroethylene (PCE) and trichloroethylene
(TCE). The results of soil samples collected across the
Site showed PCE concentrations ranging from below
detection to 330,000 micrograms per kilogram (ug/kg)
and TCE concentrations ranging from below detection to
320 ug/kg. The highest soil concentrations of PCE and
TCE were detected in a 150-foot by 20-foot area located
at the Site of a former aboveground solvent tank area
referred to as the "Former Solvent Tank Source Area,"
on the western portion of the property.
An approximately 1,500-foot (along the
northeast-southwest axis) by 720-foot (along the
north-south axis) groundwater VOC plume, consisting of
primarily PCE, and its degradation products TCE and
1,2-dichloroethene (1,2-DCE), extends from the Former
Solvent Tank Source Area to the east and to the
V-ii
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northeastern property boundary. Vertically, the
contamination extends to at least 48 feet below the
ground surface in the source area.
Groundwater sampling results from the overburden
aquifer in the Former Solvent Tank Area showed
concentrations of PCE and TCE as high as 5,500
micrograms per liter (ug/l) and 130 ug/l, respectively.
Although there is groundwater contamination in the
overburden aquifer outside the Former Solvent Tank
Area, it appears that the North Well (an on-plant
production well) has helped to limit the migration of the
plume (while 140 ug/I PCE was detected at the North
Weil, PCE concentrations significantly taper off beyond
the well, ranging from below detection to 22 ug/l).
Based upon the data, it does not appear that
co n ta min at ion is migra ting beyondJCI Jones Chemicals,
Inc.'s property boundaries.
In the bedrock aquifer in the vicinity of the Former
Solvent Tank Area, PCE and TCE were detected at
concentrations as high as 62,000 ug/l and 100 ug/l,
respectively. With the exception of the detection of 340
ug/l PCE in the West Well, relatively low concentrations
of PCE and TCE (less than 10 ug/l) were detected
outside the Former Solvent Tank Area.
Based upon the data summarized above, EPA believes
that the nature and extent of the soil and groundwater
contamination have been clearly defined
Throat to Public and Private Water Supplies
Comment #2: Several commenters inquired as to whether the Site
poses a threat to the public and private water supplies
located in the vicinity of the Site.
Response #2: The Site does not pose a threat to the public and private
water supplies located in the vicinity of the Site.
Periodic sampling of the Village of Caledonia's water
supply wells from 1983 through 1989 showed the
presence of PCE, TCE, and 1,1,1-trichloroethane. In
1991, the Village installed an air stripper to treat the
water prior to distribution, The latest sampling results
(June 6, 2000) indicate that the contaminant
concentrations meet drinking water standards prior to
V-iii
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treatment.
While the Site's southern boundary is located
approximately 700 feet from the Village of Caledonia's
water supply wells, it has not been determined that the
Site was the source of this contamination. Observing
groundwater flow paths would ordinarily allow a
determination as to whether or not the Site was a source
of this contamination. However, since the groundwater
flow path has been altered (the Village took a water
supply well out of service in 1994 and the prolonged
pumping of the on-Site production wells has altered the
natural groundwater flow path), such a determination
cannot be made.
There are two private residential wells located
approximately one mile from the plant which have shown
chlorinated solvent contamination. NYSDEC installed
and is presently maintaining treatment systems on these
wells. The contaminants found in these wells are only
slightly above drinking water standards. Given the low
levels of contamination and considering the distance of
the wells from the Site, it is unlikely that the Site is the
source. The source of the contamination of these wells
has yet to be identified.
No other private wells located in the vicinity of the Site
show evidence of Site-related contamination.
Comment #3:
Response #3:
Risks Posed by the Site
A commenter asked what are the risks that the Site
poses.
Based upon the results of the Rl, a baseline risk assess-
ment was conducted to estimate the risks associated
with current and future Site conditions. A baseline risk
assessment is an analysis of the potential adverse
human health and ecological effects caused by
hazardous substance releases from a site in the absence
of any actions to control or mitigate these under current
and anticipated future land uses.
The potential human receptors evaluated were plant
workers and off-Site adult and child residents. The
baseline risk assessment evaluated the exposure that
may potentially impact such receptors.
V-iv
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The results of the risk assessment indicate that the
estimated excess risks for plant workers and trespassers
were lower than or within the acceptable risk range.
Based upon the groundwater sampling results, it appears
that the on-Site production wells are preventing the
migration of contaminated groundwater beyond the
property boundaries. The risk assessment evaluated
the threat posed by a hypothetical scenario where the
plant production wells cease to operate, allowing the
migration of contaminated ground water beyond the plant
boundaries.
The estimated risks for off-Site residents under a
hypothetical future-use scenario where the on-plant
production wells are turned off, thus allowing
contaminated groundwater to migrate off-Site, poses an
unacceptable risk.
With regard to ecological receptors, soil samples from
the Former Solvent Tank Source Area contained volatile
organic compounds, some of which (e.g., PCE) are
present in concentrations greater than conservative
screening criteria considered protective of soil
invertebrate species. Therefore, there is a potential for
an unacceptable risk to burrowing animals that come into
contact with these contaminated surface soils (zero to a
two-foot depth).
Because the groundwater is about 8 feet below the
ground surface, direct contact with groundwater by
ecological receptors is unlikely. Since there are no
wetlands or surface water bodies in the immediate
vicinity of the Site, there is no potential for contaminated
groundwater to discharge into surface water. Therefore,
groundwater is not considered to be an exposure
pathway for ecological receptors.
Soil and Groundwater Treatment Processes
Comment #4: A commenter asked about the safety of the selected soil
and groundwater treatment processes. They also asked
whether these processes would adversely impact the air
or groundwater.
Response #4: The selected soil and groundwater treatment processes
V-v
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could result in some adverse impacts to on-Site
remediation workers, but all of these potential risks
would be readily mitigated by utilizing proper protective
equipment.
Specifically, the selected soil remedy, SVE, could result
in some adverse impacts to on-Site workers through
dermal contact and inhalation related to the installation
of SVE wells through contaminated soils. The selected
groundwater remedy, source area extraction and
treatment and monitored natural attenuation of the
plume, could result in some adverse impacts to on-Site
workers, since it involves the installation of extraction
wells through potentially contaminated soils and
groundwater. This alternative could also present some
limited adverse impacts to on-Site workers through
dermal contact and inhalation related to groundwater
sampling activities.
The vapors extracted by the SVE process will be treated
by granular activated carbon before being vented to the
atmosphere. The extracted groundwater will be treated
by an air stripper and, if necessary, granular activated
carbon, prior to its use as noncontact cooling water
within the plant. As such, the soil and groundwater
treatment processes will not pose a threat to the public
and will not adversely impact the air or groundwater.
Comment #5:
Response #5:
A commenter asked where Jones Chemicals, Inc.'s
wastewater is presently discharged. Another commenter
asked whether the wastewater is tested prior to
discharge.
The principal waste stream from the plant is wastewater,
which is comprised of wash water and other waste
liquids generated from handling and packaging. This
waste stream is first neutralized and then mixed in an
approximately 1-to-99 ratio with noncontact cooling
water, which is extracted from two on-Site production
wells. This mixture is then discharged to an infiltration
lagoon system in accordance with a New York State
Pollutant Discharge Elimination System permit. In May
1996, JCI Jones Chemicals, Inc. installed an air stripper
to treat the noncontact cooling water prior to discharge
to the lagoons. Periodic monitoring of the noncontact
cooling water is performed. This monitoring indicates
that volatile organic contamination is below detection
V-vi
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limits after treatment.
Comment #6:
Response #6:
Since the estimated volume of contaminated soil is only
1,700 cubic yards, a commenter asked why EPA is not
proposing to excavate it and take it off-Site, rather than
treating it in-situ.
While excavation of the contaminated soils and off-Site
treatment/disposal would effectively achieve the soil
cleanup levels in approximately one year, as compared
to 3 years for SVE, at a cost of $3,269,000, the
excavation and off-Site treatment/disposal alternative
would be considerably more expensive than SVE
($684,000). Although the contaminated soils are a
continuing source of ground water contamination, they do
not pose an immediate human health or ecological risk.
Considering the fact that the groundwater component of
the selected remedy will address the contaminated
groundwater, the increase in the time needed to clean up
the soil would, therefore, not be a significant concern.
Consequently, EPA believes that SVE would effectuate
the soil cleanup while providing the best balance of
tradeoffs among the alternatives with respect to the
evaluating criteria.
Comment #7;
Response #7:
A commenter asked for details as to how the SVE
process works. Another commenter asked whether SVE
is a proven technology and whether it has been used to
remediate any sites.
Under the SVE process, air is drawn through a series of
underground, perforated pipes to volatilize the solvents
contaminating the soils in the unsaturated zone (above
the water table). The extracted vapors are then
collected and treated by granular activated carbon
before being vented to the atmosphere. The spent
carbon is transported off-Site for treatment. While the
SVE process is working, the concentrations of volatile
organic compounds (VOCs) being recovered will be
monitored. Based upon these data, when it appears that
the recovery of volatile organic compounds has tapered
off, soil borings will be collected to verify that the
cleanup objectives have been met.
SVE is a proven technology that has been widely used at
Superfund and non-Superfund sites nationwide. In New
V-vii
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York State, SVE was used at the Genzale Plating
Company Superfund site, a metal-plating facility located
in Franklin Square, New York with VOC contamination.
After approximately one year of operation, confirmatory
soil sampling established that the VOC cleanup levels
had been met and the unit was shut down. SVE units are
currently operating at the Mattiace Petrochemical
Company Superfund site, an inactive chemical
distribution facility located in Glen Cove, New York, the
Pasley Solvents and Chemicals Superfund site, a former
tank farm used for the storage of oils, solvents and
chemicals in Uniondale, New York, the Rowe Industries
Groundwater Contamination Superfund site, a motor and
transformer manufacturer located in Sag Harbor, New
York, the Solvent Savers Superfund site, a chemical
waste recovery facility located in Lincklaen, New York,
and in an industrial park associated with the Vestal
Wellfield Superfund site, located in Vestal, New York,
Comment #8:
Response #8:
Financing of the Project
A commenter asked who paid for the RI/FS and who will
be paying to implement the selected remedy.
In March 1991, JCI Jones Chemicals, Inc. entered into
an Administrative Order on Consent (AOC) with EPA to
perform an RI/FS for the Site to determine the nature
and extent of the contamination at and emanating from
the Site and to identify and evaluate remedial
alternatives. Pursuant to the requirements of the AOC,
JCI Jones Chemicals, Inc. also agreed to reimburse EPA
for its oversight of the RI/FS. After the remedy is
selected, EPA intends to commence negotiations with
JCI Jones Chemicals, Inc. for the company's
performance of the design and construction of the
remedy.
V-viii
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Appendix V-a
July 2000 Proposed Plan
-------
Superfund Proposed Plan
Jones Chemicals, Inc. Superfund Site
Caledonia, Livingston County, New York
SEPA
July 2000
MARK YOUR CALENDAR
July 20, 2000 ' August 19,
2000: Public comment period on
ttie Proposed Plan.
August 14, 2000 at 7:00 p,m,:
Public meeting at Caledonia*
Mumford Central School, 99
North Street, Caledonia, NY
14223,
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. trie
remedial investigation and feasibility
study (RI/FS) reports and tnis
Proposed Plan have been made
available to the public for a public
comment period which begins on July
20,2000 and concludes on August 19,
2000.
A public meeting will be held during
the public comment period at the
Caledonia-Mumford Central School,
99 North Street, Caledonia, NY 14223
on August 14, 2000 at 7:00 P.M. to
present the conclusions of the Rl/FS,
further elaborate on the reasons for
recommending the preferred 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), trie
document which formalizes the
selection of the remedy.
PURPOSE OF THE PROPOSED PLAN
This Proposed Plan describes the remedial alternatives considered for
the Jones Cliemicals, inc. Superfimd site and identifies the preferred
remedial aternatave with the rationale for this preference.
The Proposed Plan was developed by the U.S. Environment^ Protection
Agency (EPA) in consultation with ttie New York State Department of
Environmental Conservation (NYSDEC), EPA is issuing the Proposed Plan
as part of its public participation responsibilities under Section 117(a) of the
Comprehensive Environmental Response, Compensation, and Liability Act
(CERCLA) of 19BO: as amended,'and Section 300.430(0(2) Of the National
Oil and Hazardous Substances Pollution Contingency Plan (NCP) The
alternatives summarized here are described in the remedial investigation
and feasibility study (RI/FS) reports and other documents contained in the
Administrative Record file for this site. EPA and ttie NYSDEC encourage
the public to rev lev/ these documents to gain a more comprehensive
understanding of the siie and Superfund activities that have been conducted
at the site.
This Proposed Plan is teing provided as a supplement to the Rt/FS reports
to inform the public of EPA and NYSDEC's preferred remedy and to solicit
public comments pertaining to alt the remedial alternatives evaluated, as
well as the preferred alternative
EPA's preferred soil remedy consists of soil vapor extraction. To address
the contaminated ground water, EPA's preferred remedy is groundwater
extraction and treatment in trie source area, in-srtu dense non-aqueous
phase liquid (DNAPL) treatmenl, and mpnitored natural attenuation of the
groundwater outside the source area.
The remedy desc ribed in this Proposed Plan is the preferred remedy for the
site Changes lo 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. Thefmal 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 the detailed analysts
of the Rl/FS reports because EPA and NYSDEC ma/ select a remedy other
than the preferred remedy,
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Page 3
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$up9rfifnd Proposed Plan,
Chemicals Suoerfund Site
The administrative record file, which
contains the information upon which
the selection of the response action
will be based, is available at the
following locations.
Village of Caledonia Library
3108 Main Street
Caledonia, NY 14423
(716! 533-4512
Hours: Monday and Thursday, 2:OO p.m. Co 5:30
p.m. and 7:00 p.m. to 9;00 p.rn.; Tuesday,
10:00 a.m. to 5;30 p.m.; and Friday, 2:00
p.m. to 5i3Q p.m.
Monday-Friday, S:QQ a.m. - 5:00 p.m
Village of Caledonia Clerks Office
3O-95 Main Street
Caledonia, NY 14423
(716) 538 6565
Hours: Monday-Friday, 8:00 a.m. to 4:00 p.m.
USEPA-Region If
Superfund Records Center
290 Broadway, 18th Floor
New York, NY 10007-1366
(212)637^306
Wrrtten comments on this Proposed Plan should be
addressed to:
George Jacob, Project Manager
United Slates Environmental Protection Agency
290 Broadway. 20lh Floor
New York. NY 10007-1966'
Telephone: (212)637-4266
Telefax (212)637-3966
E-maiJ- Jacob,george@epa 9ov
SITE BACKGROUND
Site Description
The Jones Chemicals, Inc site, situated in a relatively flat,
sparsely populated, tightly industrialized suburban area of
the Village of Caledonia, includes the JCI Jones
Chemicals, nc. (Jones) plant. The site is bordered by
Iroquois Road to the south, farmlands to the north, and
homes to ihe ea&t anrj west A construction company and
a printing company are (ocated immediateJy northwesf Of
the plant A golf course, baseball field, and tennis court are
present immediately south of Iroquois Road. The site
vicinity to the west and southwest is populated with light
service industries, including hardware stores, gasoline
stations, dry cleaners, restaurants, and olher commercial
businesses. (See Figure 1.)
There are nine buildings located on the 10-acre
manufacturing plant grounds, consisting of office space,
drum storage sheds, interconnected warehouse buildings,
a bleach manufacturing building, and a chlorine and sulfur
dioxide repackaging building. The areas around the
buildings are paved wiih asphalt The Main Service
fiarlway tones run west to east to the north of the buildings
A large area south Of the buddings, facing Iroquois Road,
is grass-covered. The area north of the buildings is known
as (he "North Property " The eastern ponion of the North
Property is covered by grave I, the we stern portion by gf a SS
Three unlined lagoons are located to the northwest of the
bleach manufacturing building.
The plant properly, which has been jsed for industrial
purposes since 1939, is presently zoned industrial and light
industrial, it is anticipated that the land use will not change
in the future'
Site Geology^Hydrogoclogy
The s
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Superfuntf Proposed Plan
Jones Chemicals Si>perfand Site
of the zone (10 feel or less) is highly wealhered and
fractured. The ground water yield wi In in the beef rock occurs
primarily in (he weathered portion and/or through fractures.
Groundwaler elevation data indicates that ground water flow
in the bedrock is both to the west and northeast There also
appears to be an upward vertical gradient indicating flow
from the deeper to shallower water-bearing zones.
Site History
Jones purchased the majority of the plant property in 1939
which, at the time, included an orchard, agricultural fields,
and pasture lands. Soon after the purchase of the property,
Jones began the production of sodium hypochlorile
(bleach). In 1942, Jones purchased adjacent properties to
the north and east, and began repackaging chlonne from
bulk sources to cylinders and 1-ton containers there.
Titanium tetrachJoride was briefly manufactured between
1942 and 1943 for the U.S government during World War
II for use in smokescreen operations Repackaging of
anhydrous ammonia and acids began in 1947 The
production of aqua ammoma and bulk storage of
hydrochloric, sulfuric, nitric, and hydrofluosilicic acids
started in 1953. Between 1960 and approximately 1977.
volatile organic compounds (VOCs), including
letrachtoroethene (PCE), trichloroethene (TCE). lofuene,
1,1.1-trichloroethane (1.1.1-TCA). meihylenechloride, and
Stoddard solvent, were repackaged from bulk to smaller
containers for sale/distribulion. Aqua ammonia was
produced by combining water and ammonia until 1995.
In 1971, Jones began to transport commercial hazardous
wastes not generated by Jones. The hazardous waste
materials were temporarily stored on-sile prior to transport
and disposal off-site. Jones crpal threat" concept is applied
to the characteiizauon of "source materials" at a
Superfund Site. A source material is material that
includes or contains hazardous Substance5, pollutants.
or contaminants that act as a reservoir for the migration
of contamination to groundwater, surface water, or air,
or acts as a source for direct exposure. Principal threat
wastes are those source materials considered to be
highly toxic or highly mobile that generally cannot be
reliably contained, or would present a significant risk
to human health or the environment should exposure
occur. The decision to Ireat these wastes is made on
a site-specific basis through a detailed analysis of
alternatives, using the remedy selection criteria which
are described below This analysis provides a basis
for nrrakrrtg a statutory finding that the remedy emp oy s
treatment as a principal element
EPA Region II - July 2000
Page 4
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Superfund Proposed Plan
Jones Chemicafs Suoerfund Sife
the overburden and bedrock aquifers, respectively
Throughout the plant s operation, spills occurred during the
handling of many ofthe above-mentioned chemicals These
spHts contaminated the uncfertying groundwater.
The site was proposed1 for inclusion on the
Priorities List (NPL) in June 1986; it was listed on the NPL
in February 1990.
To comply with its SPDES permit and to collect data for
Ireatability study work related to the Rl/FS, in May 1996
Jones installed an air stripper to treat the nonconlact
cooling w/ater from (he Nolh Wen and the West We If prior
la discharge to the lagaons Monitoring of the discharge
water rndicates thaf VOCs are oelow detection \ur\its after
treatment
RESULTS OF REMEDIAL INVESTIGATION
The results of the Rl are summarized below
Surface and Subsurface Soils
The results of 19 soil samples collEcted across the site
showed PCE concentrations ranging from below detection
to 330,000 micrograms per kilogram (yg/kg) and TCE
concentrations ranging from below detection to 320 ug/kg.
The highest soil concentrations of PCE and TCE were
detected in a 150-foot by 20-fool area located al the site of
a forme; aboveground solvent tank area (hereinafter.
referred (o Ihe "Former Solvent Tank Area") (see Figure 1).
located in the western portion of the property
Groundwater
An approximate!/ 1,500-foot (along the
northeast-southwest axis) by 720-foot faiong the
north-south axis) groundwater VOC plume, consisting of
primarrry PCE, and rts degradation products TCE and 1,2-
dictiloroeihene {1,2-DCE). extends from the Former Solvent
Tank Source Area to the east and to the northeastern
property boundary. Vertically, the contamination extends to
at least 48 feet below the ground surface in the source area.
Groundwaier sampling results from the overburden aquifer
in Ihe Former Solvent Tank Area showed concentrations of
PCE and TCE as high as 5,500 pg/l and 130 pgfl.
res pectjveiy. A llnoug h th e re is g row ndwater contamination
in the overburden aquifer outside the Former Solvent Tank
Area, it appears that the North Well has helped to limit the
migration of the plume (while 140 ug/l PCE was detected at
the North Well. PCE concentrations significantly taper off
beyond ttie well, ranging from below detection to 22 (jg/l).
WHAT 15 RISK AND HOW IS IT CALCULATED?
A Superfund baseline human hearth risk assessment is art
analysis of the potential adverse health effects caused by
hazardous substance exposure from a site fn the absence of
any actions !o control or mitigate these under current- and
future-land uses A lour-slep process is utilized for
assessing site-related human health risks for reasonable
maximum expo-sure
Hazard Identification: In this step, the contaminants of
concern (COC) al the site in various media (1.9 .. 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 (tie environment.
concentrations of the contaminants in s pacific media,
mobility, persistence, and b>oaccumulation.
Exposure flssessmen/. In this step, the different exposure
paihways through which people might be exposed to the
contaminants identified in the previous step are evaluated.
Examples ot exposure pathways include incidental mgestion
of and dermaJ contact with contaminated soil Factors
relating ro the exposure assessment include, but are not
iimited lo, 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.
Toxidty Assessment In this slep, the types of adverse health
effects associated with chemical exposures, and the
relationship between magnitude of exposure and severity qf
ad verse effects are determined. Potential health effects are
chemical-specific and may include the nsk of developing
cancer over a lifelime or otheT non-cancer health effects,
sucn as changes in the normal funclions of organs withen the
body (e.g., changes in the effectiveness of Ihe immune
sysrem) Some cherrncal* are capable ot causing both
cancer and non-cancer health effects
Risk Characterization This slep s-urnmafdes ana combines
outputs of ttie exposure and loxicity assessments to provide
a quar>trta!?ve assessmen! of site risks. Exposures are
evaluated based on the potential nsk of developing cancer
and the potential for non-cancer health hazards The
li kelih oad of an mcJivid u a I deve loping cance r is expressed a s
a probability For example, a 10J cancer risk means a
'one-rn-ten-jhowsartd excess cancer risk"; or one additional
cancer may be seen in a population of 10,000 people as a
result of exposure to sile contaminants under tne conditions
explained in the Exposure Assessment. Current Superfund
gui deli ne s f a r a cceptabl e ex p o s u res are an in d ivid ua I iifebrrie
excess cancerrisfcin the range of 10"* to 10"8 (corresponding
lo a one-in-ten-ttiousand to a one-in-a-million excess gancer
nsfc) with 1 0s being (he point of departure For non-cancer
health effects, a 'hazard index' (HO is calculated. An HI
represents the sum of the individual exposure levels
compared (Q tneir carre spending reference doses The key
concept for a non-cancer Hi is lhat a 'threshold level"
(measured as an HI of less than 1 ) exists below which non-
cancer health effects are no! e*pected to occur.
EPA Region tf • July 2000
Page 5
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Superfunti Proposed Plan
Jones Chemicals SuperfundSite
In the bedrock aquifer in the vicinity of the former Solvent
Tank Area, PCE and TCE were detected at concentrations
as high as 62,000 ug/i and 100 ug/l. respectively. With the
exception of the detection of 340 ug/l PCE in the West Well.
outside the Former Solvent Tank Area, relatively low
concentrations Of PCE and TCE (less than 10 ugfl) were
delected.
The magnitude of the PCE concentrations in the bedrock
aquifer in the Former Solvent Tank Area indicates ihe
potential presence of such PCE in the form of a DNAPL, a
principal threat waste. Since much tower levels of PCE
were delected in groundwaier samples collected outside the
Former Solvent Tank Area, it appears that the DNAPL may
be limited to a smaJI area in the source area-
Periodic sampling of the Village of Caledonia's water
supply wells from 1983 through 1989 showed the presence
of PCE and 1.1.1-TCA. A limited study conducted by
NYSDEC in t996 characterized the chemicals affecting
these wells, but did not identify a source. The Village
instated art ajr stopper to treat 1he wale/ prior to distribution
in 1991 The latest sample results (June 6, 2000} indicate
that the contaminant concentrations meet drinking water
standards prior to treatment/. While the Jones Chemicals
site's southern boundary is located approximately 700 feet
from the Village of Caledonia's water supply wells, il has not
been determined that the site was ihe source of this
contamination. While both PCE and 1.1.1-TCA were
detected in the Village's wells. 1.1 1-TCA has not been
detected in groundwater samples collected from the Jones
Chemicals site Observing groundwater flow paths would
ordinarily allow a determination as to whether or nol the site
was a source of this contamination However, since ihe
groundwater How path has been altered (Ihe Village took a
water supply well out Of service in 1994 and the prolonged
pumping of the on-site production wells has altered the
nalu ral ground water flow path), such a determination can not
be made.
There ire two private residestraf weWs located approximately
one mile from the plant which have shown chlorinated
solvent contamination. NYSDEC installed and 15 piesenlly
maintaining treatment systems on these wells. The
contaminants found in these wells are only matginstty above
drinking water standards. Given the low levels of
contamination and considering the distance of the wells from
the site, il is unlikely thai Jones Chemicals site is the source.
The source of the contamination of these wells has yet to be
identified.
The sample results are included in Ihe Atimimsdaiive Record
lie for Ihis site.
SUMMARY Of SITE RISKS
Based upon the results of the Ri. a baseline risk assess-
ment was conducted to estimate the risks associated with
current and future site conditions A baseline risk
assessment is an analysis of the potential adverse human
health and ecological effects caused by hazardous
substance exposure m the absence of any actions to
control or mitigate these under current and fulure land
uses
The human health anrj ecological risk estimates
summarized below are based on current 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 coniaminants of concern (COCs), as well as thetoxicity
of tfiese contaminants
Human Heafth Risk Assessment
As- was noted above, the current land use of the sire is
industrial, and it is anticipated that the land use will not
change in the future. In addition, although on-site wells
provide noncontact cooling water for the plant after
treatment, potable water for the plant is obtained from fhe
Village of Caledonia's well system. Therefore, it is not
lately that the groundwafer underlying the site will be used
for potable purposes m ihe foreseeable future
The baseline risk, assessment began wrth selecting
chemicals of concern in the various media that would be
representative of site risks. The primary COCs include
PCE. TCE. afKJ 1.2-DCE in the soil and groundwater
media
The potential human receptors evaluated were on-pianf
workers and trespassers and Off-plant adult and child
residents. The baseline rtsk assessment evaluated the
exposure that may potency impact such receptors.
Based upon the groundwater sampling results, it appears
thai the on-site production wells are preventing the
migration of contaminated groirndwater beyond the
property boundaries The risk assessment evaluated the
threat posed by a hypothetical off-plant direct contact with
contaminated groundwater (e.g., through ingestion of
g round wa te r a n d in ha la rion of v01 aJrtes releas ed into indoor
air from groundwater while showering in an enclosed
space) scenario where the on-plant production wells cease
lo operate, allowing the migration of contaminated
groundwater beyond the plant bountfartes.
The results of the risk assessment indicate that the
estimated excess cancer risks for on-plarit workers and
trespassers were lower than or within the acceptable
excess cancer risk range or 1CT1 to 10"6 (the highest total
cancerrisKwdS attributable loa trespasser at 2.91 x 10"s)
EPA Region II - July 2000
Page 6
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Suoetfund Proposed Plan
Jones Chemicals Suoerfund Site
The estimated excess cancer risks for off-plant receptors
under the hypothetical future-use scenario where the on-
plartt production wells are turned off, thus allowing
contaminated ground water to migrate otf-pfant. poses an
unacceptable risk.
Total estimated HI values for individual chemicals and
combinations of chemicals under current and future on-
plartt worker and trespasser exposure scenarios an he s.'te
range up to a maximum of 0.193& (attributable to a
trespasser). Since the total estimated HI is less than unity
(1 0), there is not a concern for potential chronic adverse
non-cancer health effects to such receptors.
The estimated HI for off-plant receptors under the
hypothetical future-use direct ccntact with contaminated
groundwater scenario {where the on-plant production wells
are turned off) is estimated to exceed unity.
Ecological Risk Assessment
Information from the NYSDEC Bureau of Wildlife indicates
tnat there are no endangered or threatened plant or animal
species at or in tne ujcimty of the site Therefore. EPA
evaluated potential exposure pathways for non-end angered
and non-threatened animal and plant species.
Stnce the site includes an industrial facility, there is minimal
habitat available for ecological receptors; however, ihe
grassy areas could support some soil invertebrates.
terrestrial mammals, and birds
Soil samples from the Former Solvent Tank Source Area
contained volatile organic compounds, some of which (e g..
PCE) are present in concentrations greater than
conservative screening criteria considered protective of soil
invertebrate species. Therefore, there t's a potential for an
unacceptable risk to burrowing animals that come into
contact with these con laminated surface soils (zero to a
two-fool depth).
Consrdering the depth to the Surface of the groundwgter
{not tess than B feet below the ground surface), direct
contact with ground water by ecological receptors is unlikely.
Since friere are no wetlands or surface water bodies in the
immediate vicinity of the sile, Ihere is no potential for
contaminated groundwater to discharge inio surface water
Therefore, groundwater is not considered to bean exposure
palhway for ecological receptors
Summary of Human Health and Ecological Risks
The results of (tie risk assessment indicate that under the
hypothetical off-plant groundwater use scenario where the
on-plant production wells are turned off, there is an
unacceptable excess cancer risk. Under all of the other on-
plant scenarios, (he estimated excess cancer risks are
lower than or within the acceptable excess cancer risk
range. Therefore, there is not a concern for potential
chronic, adverse non-Caricer health effecis from chemicals
at the site.
Tne total estimated HI values for all on-piant worker and
trespasser exposure scenarios do not pose a concern for
potential chronic adverse non-cancer health effects to Such
receptors The estimated Ht for off-plant receptors under
the hypothetical future-use scenario, where the on-plant
production wells are turned off. poses a chronic adverse
non-cancer health effect lo such receptors.
The presence of contaminated surface soil in the Former
Solvent Tank Source Area poses a potentially
unacceptable risk to ecological receptors.
Based upon ihe results of the Rl and the risk assessment,
EPA has determined that actual or threatened releases of
hazardous substances from the site, if not addressed by
trie preferred alternative or one of the other active
measures considered, may present a current or potential
threat to the environment
REMEDIAL ACTION OBJECTIVES
Remedial aciion objectives are specific goals to protect
human health and the environment These objectives are
based on available information and standards such as
applicable or relevant and appropriate requirements
(ARARs) and risk-based levels established in the risk
assessment
The following remedial action objectives have been
established for the site.
Restore gjoundwater to levels which meet slate
and federal standards within a reasonable time
frame.
• Mihgale the potential for chemicals to migrate from
soils into groundwater. and
• Mitigate the migration of the affected groundwater.
SUMMARY OF REMEDIAL ALTERNATIVES
CERCLA§121(b)(1).42U SC §9621 (b){1). mandates thai
remedial actions must be protective of human health and
Ihe environment cost-effective, comply with ARARS. and
utilize permanent solutions and alternative treatment
technologies and re source recovery alternatives to the
maximum extent practicable Section 12l(b)(1) also
establishes a preference for remedial actions which
employ, as a principal eJemerM, treatment to permanently
EPA Region II - July 2000
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Superfund Proposed Plan
Jones Chemicals Superfund Site
and significantJy reduce the volume, loxickty. or mobility of
the hazardous substances, pollutants and contaminants at
a Site. CERCLA §12t(d>. 42 U.S.C §9621
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Superfund Proposed Plan
Jones Chemicals Superfund Site
Alternative S-3; Excavation of Contaminated Soils and
Off-Site TreatmenVDisposal
Capita) Cost $3,269,000
Annual Operation and Maintenance Cost $0
Present-Worth Cost $3,269.000
Construction Time 1 year
This alternative includes excavating approximately 1.700
cubic yards of soil in the Former Sofvent Tank Source Area
which exceed soil TAGM objectives. The actual exleni of
the excavation and the volume of the excavated material
would be based on post-excavadon confirmatory sampling
Shoring of the excavation and extraction and treatment of
any water that enters the trench would be necessary
The excavated areas would be backfilled with clean fill and
revegelated All excavated material would be characterized
and transported lor treatment/disposal at an off-Site
Resource Conservation and Recovery Act (RCRA)-
compiiant facility Because of the high levels of PCE that
would be present in the excavated scui it is likely that
incineration would be the only viable form of treatment
soil The-organic vapors extracted from the soil would then
be either condensed. Iransferred to another medium (such
as granular activated carbon), or thermally treated in an
afterburner operated to ensure complete destruction of the
volatile orgarvcs. The off-gases would be filtered through
a carbon vessel Once the treated soil achieved soil TAGM
objectives, it would be tested ir> accordance with the
Toxicity Characteristic Leaching Procedure (TCLP) to
determine whelher it constitutes a RCRA hazardous waste
and. provided that it passes the test, it would be used as
backfill material for the excavated area. Soil above TCLP
levels would be either re-treated or dfSpOSed Of at an
approved off-site facility, as appropriate.
Groundwater Remedial Alternatives
Alternative GW-1: No Further Action and Long Tenrn
Monitoring
Capital Cost
Annual Monitoring Cost:
Present-Worth Cost:
Construction Time:
$3,000
$51 000
$633,000
3 months
Alternative S-4: Excavation of Contaminated Soils, On
Site Treatment via Low Temperature Thermal
Desorption, and Redeposition
Capital Cost: $1 154,000
Annual Operation and Maintenance Cost SO
Present-Worth Cost. $1.154,000
Construction Time: 1 year
This alternative includes excavating approximately 1,700
cubic yards of soil in the Former Solvent Tank Source Area
which exceed soil cleanup objectives as specified in the
TAGM. The actual extent of che excavation and ihe volume
of the excavated malerial would be based on post-
excavation confirmatory sampling. Shoring of the
excavation and extraction and treatment of any water lhat
enters the trench would be necessary.
The excavated soil would be fed to a mobile Low
Temperature Thermal Desorption (LTTDJ unit trough I to the
sile, where hot air injected at a temperature above tne
boiling points of the organic contaminants of concern would
allow them to be volatilized into gases and escape from the
The Superfunct program requires that the "no-action"
alternative be consideredasa baselineforcompanson with
the other alternatives
The no further action remedial alternative would not include
an/ physical remedial measures to address the
groundwater contamination at the site1 This alternative
would, however, include a long-term grouncfwater
monitoring program and the installation of some additional
monitoring wells. Under this monitoring program.
groundwater samples would be collected and analyzed
annually.
Because this alternative would result in contaminants
remaining on-site. CERCLA requires that the site be
reviewed at least once every fcve years. If justified by the
review, additional remedial actions may be implemented in
the future
"" Although, since May 1996. contaminated grounchwater has
been extracted from the North Weil and the West Well, u&ed as
nonconr.act cooling water, treated, and discharged, Ihe no further
action alternative assumes that groundwater is no tangjer
exltacled from Ihese wells.
EPA Region ft - July 2000
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Superfund Proposed
Jones Chemicals Superfund S/te
Alternative GW-2: Source Area Extraction and
Treatment, Monftored Natural Attenuation of the Plume
Outside the Source Area, and Institutional Controls
Capital Cost.
Annual Monitoring Cost
Present-Worth Cost
Construction Time:
$362,000
581,000
$1.366,000
4 months
Under this alternative, the affecled groundwater in the
Former Solvent Tank Source Area would be addressed
through an extraction system >n the overburden a net
bedrock aquifers. It is estimated that the groundwater
extractron system would utilize one bedrock and two
overburden wells to withdraw 400 o,pm of contaminated
g roii ndwater I n ad d i r. ion, con ramtnated g ro u n dwate r wcul d
continue to be extracted from the North Well which would
facilitate the capiure of the plume beyond the Former
Solvent Tank Source Area. The extracted groundwater
would be ireated by the existing air stripper and would then
be used as noncontact cooling water within the plant prior
lo being discharged lothe on-site Jagoons. To comply with
New York State air guidelines, granular activated carbon
treatment of the air stripper air exhaust slream may be
necessary
The contaminated groundwaier located outSJde the Former
Solvent Tank Source Area and beyond the influence of the
North Well would be addressed through monitored natural
attenuation, a variety of physical, chemical and biological
processes which, under favorable condittons, act wrlhout
human intervention to reduce the mass, loxicity. mobility.
volume, or concentration of contaminants in soil and
groundwater. These in-situ processes include
biodegradalion, dispersion, dilution, sorption. volatilization.
and chemical or biological stabilization, transformation, or
destruction of contaminants Evidence of biodegrsdatton of
the PCE jn the groundwater at the site includes the
presence of its breakdown products. TCE and 1-2
dichloroethene.
WTiJSe preliminary modeling results indicate that ii may take
up to seven years to remediate the aqueous phase of the
PCE in the Former Solvent Tank Source Area plume
through groundwater extraction and treatment, and from 10
fo 15 years for the contaminant plume located outside of the
Former Solvenl Tank Source Area to be restored through
natural attenuation, the total remediation lime for this
alternative is expected to be much greater, since residual
PCE DNAPL is suspected to be preseni m the Former
Solvenl Tank Source Area Grounflwater extraction and
treatment can be effective in hydraulically containing
DNAPL source zones, however, it is generally not
completely effective in remediating these zones to
groundwater standards
As part of a long-term groundwater monitoring program,
groundwater samples would be collected and analyzed
quarterly in order to verify that the level and extent of
groundwaier contaminants (e.g., VOCs) are decrinrng and
that conditions are protective of human health and the
environment In addition, biod eg radation parameters (e.g..
oxygen, nrtrate, sulfate. meihane, ethane, ethene,
alkalinity. redo* potentia , pH, temperature, conductivity,
chloride, andtotalorganiccarbon) would be used to assess
the progress of the degradation process.
Institutional controls such as deed restrictions limiting
future groundwater use ID nonpotable purposes only, would
be established. Additionally, because of the potential thai
pumpjng of the West Well would draw contaminants to
deeper water-bearing zones, pumping from the West Well
would be discontinued.
Because this alternative would result in contaminants
remaining on-site. CERCLA requires that the sile be
reviewed at least once every five /ears.
Under this alternative, biod eg radation para meters would be
used to assess the progress of the degradation process
Jf it is determined that monitored natural attenuation is not
effective in restoring groundwater quality outside of the
Former Solvent Tank Source Area in a reasonable time
frame, then remedial actions, such as enhanced
biodegradation or groundwater extraction and treatment.
may be implemented
Al te rn ativ e G W-3: S ite -Wide G rou nd wa te r E xtract io n
and Trealment, In-Situ Treatment of DNAPL, and
Institutional Controls
Capital Cost $1,533,000
Annual Operation and Maintenance Cosl: $215,200
Present-Worth Cosl $3.324.000
Construction Time 6 months
Under this alternative, the affected groundwater would be
addressed through an extraction sysiem in the overburden
and bedrock aquifers. It is estimated thai the grotindwater
extraction system would utilize 10 overburden and six
bedrock wells to withdraw 1,200 gpm of contaminated
groundv/ater These wells would be placed nonheast of
the lagoon system and in the vicinity of the Former Solvent
Tank Source Area. In addition, contaminated groundwater
EPA Region II - July 2000
Page 10
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Superfund Proposed Plan
Jones Chemicals Supertund Si(e_
would continue to be extracted from the North Well, which
would facilitate the capture of the plume beyond the Former
Solvent Tank Source Area A portion of the extracted
water would be treated by the existing air stripper and would
be used as nonconlacl cooling water within (he plant prior
to being discharged to the on-site lagoons.
Because the present capacity of the air stripper would be
exceeded, an additional air stripper would be constructed lo
treat the balance of the extracted groundwater The treated
water that was not used for nonconiact cooling would be
discharged to an infiltration gallery to be constructed to the
northeast Of Ihe lagoon system. To comply with New York
State air guidelines, granular activated carbon treatment of
the air strippers' airexhausi streams may be necessary.
Preliminary modeling results indicate thai through
gnoundwater extraction and treatment it may take up to
seven years lo remediate the aqueous phase of the PCE m
the Former Solvent Tank Source Area plume and up to
eight years to remediate the contaminant plume located
oulside of the Former Solvent Tank Source Area.
To enhance the treatment of the residual DNAPL in the
bedrock beneath the Former Solvent Tank Source Area, an
oxidizing agent, such as potassium permanganate (KMnO J
or hydrogen peroxide (H2O2) would be injected via a well
It has Been estirnaied that The residual DNAPL would be
treated within five years.
As part of a long-term groundwater monitoring program,
groundwater samples would be collected and analyzed
quarterly in order lo verify that the level and extent of
groundwaler contaminants (e g , VOCs) are declining anc
that conditions are protective of human health and the
environment.
Institutional controls, such as deed restrictions limiting
future groundwater use to nonpotable purposes only, would
be established Additionally, because of the potential lhat
pumping of the West Weil would draw contaminants to
deeper water-bearing zones, pumping from the West Well
would be discontinued.
Because, this arternative would result in contaminants
remaining on-site above health-based levels. CERCLA
requires that Ihe site be reviewed ai least once every five
years. If justified by the review, additional remedial actions
may be implemented in the future.
Alternative GW-4: Source Area Extraction and
Treatment, In-Situ Treatment of DNAPL, Monitored
Natural Attenuation of the Plume Outside the Source
Area, and Institutional Controls
Capital Cost.
Annual Monitoring Cost
Present-Worth Cost.
Construction Time
$479.000
$115,000
$1.623.000
4 months
This alternative would be the same as Alternative GW-2.
except, to enhance the treatment of the residual DNAPL in
the bedrock beneath the Former Solvent Tank Source
Area, an oxidising agent, such 35 KMnO, or H/^. would be
injected via a well
Preliminary modeling results indicate it may take up to
seven years to remediate the aqueous phase of the PCE
in the Former Solvent Tank Source Area plume through
groundwaler extraction and treatment and from 10 to 15
years for the contaminant plume located outside ot the
Former Solvent Tank Source Area to be restored through
natural attenuation. It has been estimated that the residuaf
DNAPL would be treated within five years.
Because tnis alternative would result in contaminants
remaining on-site above health-based levels, CERCLA
requires that the site be reviewed at least once every five
years.
Under this alternative, biodegradalion parameters would be
used to assess the progress of the degradation process
If
-------
Superfund Proposed Plan
Jones Chemicals Superfund Srte
• 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 control
• Compliance witr> applicable or relevant and appropriate
requirements addresses whether or not a remedy would
meet all of the applicable or relevant and appropriate
requirements of otner federal and state environmental
statutes and regulations or provide grounds for invoking
a waiver.
• Long-term effectiveness and permanence refer to the
ability of a remedy to maintain reliable protection of
human health and trie environment over time, once
cleanup goals have been rriet It aiso addresses the
magnitude and effectiveness of ihe measures that may
be required to manage the risk posed by treatmen!
residuals and/or untreated wastes.
• Reductipn_gf toxicily. 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 mat may be
posed during the construction and implementation
period until cleanup goals are achieved
• ImplementabilJtY 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 whelrier. based on its
review of the RUFS reports and the Proposed Plan, (he
State concurs with opposes, or has no comment on the
preferred remedy al the present time
Community acceptance, will be assessed in the ROD,
and refers to the pubitc's general response to the
alternatives described in the Proposed Plan and the
RI/FS reports
A comparative analysis of these alternatives based upon
the evaluation cnteria noted above, follows
• Qverarf Protection of Human Health anfl_j_he_
Environment
Alternative S-1 (no action) would not De protective of
human health and (he environment, since it would not
acUvely address the contaminated soils, which are a source
of groundwater contain*nation.
Alternative S-2 (soil vapor extraction). Alternative S-3
(excavation of contaminated soils and off-site
treatment/disposal), and Alternative S-4 (excavation of
contaminated soils and on-site treatment via LTTD) would
be protective of human health and the environment, since
each alternative relies upon a remedial strategy and/or
treatment technology capabfe of removing The source of
groundwater contamination in the unsaturated zone.
Under these alternatives, me contaminants would either be
treated on-site or treated/disposed of off-site.
Alternative GW-1 (no further action) would be the least
protective groundwater alternative in that it would result in
no affirmalive steps to restore groundwater quality to
drmktng water standards. Therefore, under this alternative,
the restoration of the grouncfwaier would lake a srgniflcantly
longer time in comparison to Alternative GW-2 (source
area extraction and treatment and monitored natural
attenuation of The remainder of the plume). Alternative GW-
3 (s.'te-wde exW action and ire aim eni ol the contaminated
groundwater and in-situ DN APL treatment), and Alternative
GW-4 {sou'ce area extraction and treatment, in-situ
DNAPL treatment, and monitored naturaf attenuation of the
plume) Alternative GW-2 would be significantly more
protective than Alternative GW-1 in that it would provide
hydraulic containment and treatment of the affected
groundwater at the source This alternative would.
however, rely upon natural attenuation lo address the
groundwater contamination outsjde the Former Solvent
Tank Source Area. While Alternative GW-4 would result in
the restoraiion of water quality in the aquifer more
effectively than Alternative GW-2, since it would actively
address the DNAPL, it would not restore the water quality
m the plume as quickly as Alternative GvV-3.
• Compliance wilh ARARs
There are currently no federal or state promulgated
standards for contaminant levels in soils, only New York
Slate soil cleanup objectives as specified in the TAGM,
Since the contaminated soils would not be addressed
under Alternative S-1 (no action), this alternative would not
comply with the soil cleanup objectives. Alternative S-2
(soil vapor extraction), Alternative S-3 (excavation of
contaminated soils and off-site treafmenfdisposal), and
Alternative S-4 (excavation of contaminated soils and on-
site treatment via LTTDJ would be implemented to attain
the soil cleanup objectives specified in TAGM
Under Alternative S-2, spent granular activated carbon
from the SVE unjts would need to be managed in
compliance with RCRA treatment/disposal requirements.
EPA Region tt - July 2000
Page 12
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Superfun d Proposed plan
Janes Chemicals Suoeiiund Site
Alternative S-3 would b? Subject to New York State and
federal regulations related to the transportation and off-site
treatment/disposal of wastes. Alternatives S-3 arid S-4
would involve the excavation ol coniammated soils, and
would, therefore, require compliarice with fugitive dust and
VOC emission regulations In the case of Alternative S-4,
compliance with air emission standard? *ould be required
at trie LTTD unit, as well. Specifically, treatment of
off-gases would have to comply with New York state Air
Guide 1 for the Control of Toxic Ambient Air Emissions and
would be required to meet the substantive requirements of
New York State Regulations for Prevention and Control of
Air Contamination and Air Pollution
EPA and NVSOEC have promulgated health-based
protective Maximum Contaminant Levels (MCLs). whichare
enforceable standards for various drinking water
contaminants (chemical-specific ARARs) Although the
groundwater & th« site is no! presently t>&tng utilized as a
potable water source, achieving MCLs in the ground water
is relevant and appropriate, because the 9roundwater at ir>e
site is a potential source of drinking water. The aquifer is
cassified as Class GA (6 NfCRR 701.16}.
Alternative GW-1 (no further action) does not provide for
any direct remediation of the groundwater and would,
therefore, involve no actions to achieve chemical-specific
ARARs. Alternative GW-2 (source area extraction and
treatment and monitored natural attenuation of the
remainder of tne plume) would be effective in reducing
grouncfwaiercontammantconcenrrationsbelow MCLsin the
Former Solvent Tank Source Area by treating the dissolved-
phase chemicals and h yd radically containing the affected
groundwater at the source; however, inis alternative *ould
not be as effective in meeting ARARs as Alternative GW-4
(source area extraction and treatment, in-situ DNAPL
treatment, and monitored natural iltenuatiort Of the plume).
which would employ a more aggressive approach to
addressing the DNAPL Both alternatives would rely upon
natural attenuation to address a portion of the contaminated
groundwater in the? plume. AHernatrt/e GW-3 (site-wide
groundwater extraction ana treatment and in-silu DNAPL
treatment) would be the most effective in reducing
grountfwster contsrninafi! concentrations below MCLs,
since it would include an aggressive approach to address
the DNAPL and would include the collection and treatment
of contaminated groyndwater throughout the site
Therefore, this alternative would achieve ARARs in the
shortest period of time
• Long-Term Effectiveness and Permanence
Alternative S-1 Jno action) would involve no active re media I
measures and, therefore, would not be effective in
eliminating the potential for contaminants la continue (o
migrate in soil and groundwater Alternative S-2 (sort vapor
extraction). Alternative S-3 (excavation ol contaminated
soils and off-site treat me ni/dteposal). arid After native S-4
(excavation of contaminafed soils and on-site treatment via
LTTD) would all be effective in the long term and would
provide permanent remediation by either removing the
wastes from the site or ireaiing them on-site
Alternatives S-2 and S-4 would generate treatment
residuals which would have to be appropriately handled;
Alternative S-3 wouW not generate such residuals
Alternative GW-1 (no further action) would be only
minimally effective in the long-term in restoring
groundwater quality, since it would not rely on aclive
measures. Alternative C5W-2 (source area extraction and
treatment and monitored natural attenuation of the
remainder of the plume) would be significantly more
effective than Alternative GvV-1 in restoring groundwater
quality Although groundwater extraction and treatment
can be effective in hydraulic-ally containing DNAPL source
zones, it is generally not completely effective in remediating
these zones to groundwater standards. Therefore, since
Alternative GW-2 would rely upon groundwater extraction
to address (he residual Dt4APL. i! would not be as effective
as Alternative GW-3 (site-wide groundwater extraction and
treatment and m-situ DNAPL treatment) and Alternative
GW-4 (source area extraction and treatment, in-situ
DNAPL treatment, and monitored naturaf attenuation of the
remaining p»urne), which both would utilize aggressive in-
$i|y DNAPL treatment. Under Alternative GW-4, by
aggressively addressing the contamination at the source
area, it is expected thai low levels of PCE (less than 22
pg/i) outside the source area would attenuate naturally in
a reasonable time frame. Alternative GW-4 would not,
however provide the same long-term effectiveness and
permanence with regard to Jhis contamination as
Alternative GW-3, which would actively remove
contaminants from the entire plume. Alternative GW-3
wou Id ach i e v e d r inking wa ter sta n da rd s outsi de the Fo rme r
Solvent Tank Source Area more quickly than Alternative
Alternatives GW-2. GW-3. and GW-4 would generate
treatment residuals which would have to De appropriately
handled, Alternative GW-1 would not generate such
residuals
» Reduction in TQXI c i tv . Motnli> y . or Volume- T h rough
Treatment
Alternative 5-1 (no action) would provide no reduction m
toxoty, mobility or volume Under Alternative S-2 (soil
vapor extraction) and Alternative S-4 (excavation of
contaminated soils and on-site treatment via LTTD), tne
toxicity, mobility, and volume of contaminants would be
reduced through on -site treatment Under Alternative S-3
{excavation of contaminated soils and off-sile
jreaiment'disposal). theloxicity , mobility, and volume of tfie
contaminants would be reduced by removing tne
contaminated soil from the site for treatment
EPA Region It - July 2000
Page 13
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Superfund Proposed Plan
Jones Chemicals Suoerfund $rte
Alternative GW-1 (no further action) would be the least
effective alternative in reducing ihe tcxicity. mobility, or
volume of contaminants m the groundwater through
treatment, as this alternative involves no active remedial
measures. AH of the aCt'On alternatives would, to varying
degrees, reduce the toxidty. mobility, or volume of
contaminants inthegroundwaterthro jgn treatment, thereby
satisfying CERCLA's preference for treatment. Collecting
and treating contaminated groundwater in the Former
Solvent Tank Source Area unaer Alternative GW-2 (source
area extraction and treatment and monrtofed natural
attenuation of the plume) would actively reduce thetoxicily.
mobility, and volume of contaminants in this area. The
addition of an oxidizing agent to address the DNAPL under
Alternative GW-4 (source area extraction and treatment, in-
situ DNAPL treatment, and monitored natural attenuation of
Ihe plural would p'ovics sufcslantiany greater reduction of
the toxjcily, mobility, and voJume of contaminants than
Alternative GW-2 Collecting and treating contaminated
groundwater in the Former Solvent Tank Source Area and
Ihe remaining pfume. and using an oxidizing agent to
address the DNAPL under Alternative GW-3 (site-wide
groundwater extraction and treatment and in-situ DNAPL
Ireatment) would provide the greatest reduction of toxicily,
mobility, and volume of contaminants through treatment
• ShorvTerm Effectiveness
Alternative S-1 (no action) does not include any physical
construction measures in any areas of contamination and,
therefore, would not present any potential adverse impacts
to on-site workers or the community as a result of its
implementation Alternative S-2 (soil vapor extraction)
could result in some adverse impacts to on-site workers
through dermal contact and inhalation reJated lo the
installation of SVE wells through contaminated soils. In
addition, inierim and post-remediation soil sampling
activities would pose some risk Similarly, Alternatives S-3
(excavation of contaminated soils and off-site
treatment/disposal) and S-4 (excavation of contaminated
soils and on-sile treatment via LTTD) could present some
Jimtted adveise impact to on-site workers through dermal
contact and inhalation related to post-excavation sampling
activities. The risks to on-site workers under all of the
alternatives could, however, be mitigated by utilizing proper
protective equipment
Aliernative S-3 would require the off-site transport of
contaminated waste material, which may pose the potential
for traffic accidents, which could result in releases of
hazardous substances.
Under Alternatives S-3 and S-4 disturbance of the land
during excavation activities could affect the surface water
h/drology of the site. There is a potential for increased
stormwater runoff and erosion during excavation and
construction activiiies that would nave to be property
managed to prevent or minimize any adverse impacts. For
these alternatives, appropriate measures would have to be
taken during excavation activities to prevent transport of
fugitive dusl and exposure of workers and downgradient
receptors to volatile organic compounds
Since no actions would be performed under Alternative S~
1, there would be no implementation time It Js estimated
that Alternate S-2 would require 3 months to install the
SVE system and would require an estimated 3 years lo
achieve soil cleanup objectives. It is estimated that it would
take one year (o excavate and trans port the contaminated
soils to an EPA-approved treatment/disposal facility under
Alternative S-3, and one year to excavate and treat the
contaminated soils under Alternative S-4.
All of the groundwater alternatives could present some
limited adverse impacts to on-site wofKers through dermal
contact and inhalation related lo groundwater sampling
activities Alternative GW-2 (source area extraction and
treatment and monitored natural attenuation of the plume),
Alternative GW-3 {site-wide groundwater extraction and
treatment and jn-situ DNAPL treatment), and Alternative
GW-4 (source area extraction and treatment, in-situ
DNAPL treatment, and monitored natural attenuation of the
pfume) could present slightly greater adverse impacts to
on-site workers, since these alternatives wouPd involve the
installation of extraction wells through potentially
contaminated soils and groundwaler, (Alternative GW-3
could pose the greatest nsk since it would require Ihe
installation of the most extraction wells.) The risks to
on-site workers under ail of the alternatives could,
however, be minimized by utilizing proper protective
equipment
It is estimated that Alternate GW-1 would require three
months to implement, since developing a long-term
groundwater monitonng program and installing several
monitoring wells would be the only activilies that would be
required, it is estimated1 that the groundwater remediation
systems under Alternatives GW-2, GW-3, and GW^ would
be constructed in four, six, and four months, respectively.
Preliminary modeling results indicate It may take up to
seven years to remediate me aqueous phase of tfie PCE
in the Former Solvent Tank Source Area plume under
Alternatives GW-2, GW-3. and GW-4 Residual PCE
DNAPL is suspected to be present in the Former Solvent
Tank Source Area While groundwater extraction and
treatment can tie effective in hydraulically containing
DNAPL source zones, it is generally not completely
effective in remediating these zones to groundwater
standards. Therefore, for Alternative GW-2, it is likely that
the total remedialion time frame for the aqueous phase of
the PCE in the Former Solvent Tank Source Area plume
would be significantly greater than the estimated 7-year
time frame
EPA Region tt - July 2000
Page 14
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Sunerfund Proposed Plan
Jones Chemicals Suoerfund Site
Under Alternative GW-3. It is estimated thai it may lake up
to eight years to remediate the contaminant plume located
outside of the Former Solvent Tank Source Area through
extraction and treatment. Under Alternatives GW-2 and
GW-4, it is estimated that natural attenuation would address
the contaminated groundwaier located outside of the
Former Solvent Tank Source Area in 10 to 15 years.
Remediation time frames were no) developed for Alternative
GW-1 because of the dtfficulties tn estimating a natural
attenuation rate for the DNAPL in the Former Solvent Tank
Source Area
Under Alternatives GW-3 and GW-4. it is estimated that it
would take five years 10 remediate the DNAPL via KMnO^
or HjO;. injection.
The precise time required for the groundwaier to be
remediated site-wrde under all of the alternatives would
have to tie determined based on the results of groundwaier
monitoring and additional ground water modeling
•Imp/erne nfapfrty
Alternative S-1 (no action) would be easy to implement, as
there are no activities to undertake Alternative S-2 (soil
vapor extractton). woijid oe (ess difficult to implement than
Alternative $-3 (excavation of contaminated soils and off-
site treatment) and Alternative S-4 (excavation of
contaminated soils and on-slie treatment via LTTD). since
contaminated soil excavation and handling would not be
required. All three action alternatives would employ
technologies known to be reliable and can be readily
implemented In addition, equipment services, and
materials needed for all three of these alternatives are
readHy available, and the actions under these alternates
would be administratively feasible. Sufficient facilities are
availabPe for the treatment/disposal oi the excavated sods
under Alternative S-3.
Monitoring the effectiveness of the SVF£ system under
Alternative S-2 would be easily accomplished through vapor
and soil sampling and analysis. Under Alternative S-3.
monitoring the effectiveness of the excavation could be
easily accomplished through post-excanation soil sampling
and analysis. Monitoring the effectiveness of the LTTD
system under Alternative S-4 could be easily accomplished
through post-excavation and post-treatment soil Sampling
and analysis.
Alternative GW-1 (no further action) would be the easiest to
implement as the only activity would be installing some
additional monitoring wells and establishing a monitoring
program. Since only a limited number of extraction wells
would need to be installed, and since the existing
groundwaier treatment system would be utilized, the
groundwaterextraction systems regaled fo Alternative GW-2
(source area extraction and treatmeni and monitored
natural attenuation of the plume) and Alternative GW-4
(source area extraction and treatment, in -situ DNAPL
irealment. and monitored natural attenuation of the plume)
would be relatively easy to implement. Alternative GW-3
(site -v.'idegroundwater extraction and treatment and m -situ
DNAPL treatment), which would require the installation of
more extraction wells than Alternatives GW-2 and GW-4
and the construction of an additional treatment system,
would be slightly more difficult to implement tnan these
alternatives
AJrernajives GW-2 and GW-4 would also involve
monitoring of natural attenuation parameters to
demonstrate that natural attenuation is reliably achieving
the specified performance goals. Alternatives GW-3 and
GW-4 wou/d be more complicated to implement than
Alternative GW-2, since they would also require the
of KMnQ, or H;.Oj to address the PCE DNAPL.
The ground water extraction and treatment sysiems that
would be used for Alternatives GW-2. GW-3, and GW-4
have been implemented successfully at numerous sites to
exiract. treat, and hydraulically control contaminated
ground water
The air stripping technology that would be used for
Alternatives GW-2, GW-3, and GW-4 is proven and1 reJrable
in achieving the specified performance goals and is readily
available.
The KMnO, or HS0; injection technologies that would be
used for Alternative GW-4 are emerging technologies that
have been successfully implemented at a few sites across
the Unded States to treat DNAPL. Mixing tanks for KMnO,,
and injection pumps and all necessary appurtenances for
KMn04 and H/3_, are readily available. Field tests may be
required prior to designing a full-scale system. While
uMizjng KMnO., would likely result in the introduction of
trace metal impurities and manganese salts into the
groundwaier. it is expected that the levels would be below
groundwaier standards
• Cost
Tne present-worth costs associated with the soil remedies
are calculated using a discount rale of seven percent and
a 3-year time interval The present-worth costs associated
with ttse ground water remedies are calculated using a
discount rate of seven percent and a 15-year time interval
The estrmated capital, operation, maintenance, and
monitoring (OM&M). ancl present-worth costs for each of
the alternatives are presented below.
EPA Region il • July 2000
Page 15
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Superfund Proposed Plan
Jones Chemicals $uperfund Site
Alt.
S-1
S-2
S-3
S-4
GW-1
GW-2
GW-3
GWM
Capital Cost
$0
5365,000
53.269.000
S1, 154. 000
$3.000
S362.000
$1333,000
3479,000
Annual
OM&MCost
SO
5122000
SO
50
$51.000
$81.000
$215.200
$115,000
Present- Worth
Cost
$0
$684,000
S3. 269.000
51,154,000
56 3 3. 000
$1,366,000
$3.324,000
$1.623,000
As can be seer* by the cost estimates. Alternative S-1 (no
action} is the least costly soil alternative at SO. Alternative
S-3 (excavaiion of contaminated soils and off-site
treatment) is the most costly soil alternative at $3.269,000.
The least cosily groundwater remedy is Alternative GW-1
no further action, at a present-worth cost of 3>6oO.QQQ.
Alternative GW-3 (site-wide groundwater extraction and
treatment and in-situ DNAPL treatment is the most costly
groundwater alternative at a presenf-worth cos? cf
$3,324,000 The significant difference m the cost of this
alternative as compared to the other action alternatives is
mainly attributable to the construction and operation of an
additional groundwater treatment system.
• State Acceptance
NYSDEC concurs wrth the preferred remedy.
• Community Acceptance
Community acceptance of the preferred remedy will be
assessed in toje ROD following review of the public com-
ments received on Ihe RI/FS reports and this Proposed
Plan
PREFERRED REMEDY
Description of the Preferred Remedy
Based upon an evaluation of the various alternatives, EPA
and NYSDEC recommend AItemalive S-2, SVE, for the soil
remedy The preferred alternative to address ihe
groufidWarer can!armial is Alternative GW-4, Former
Solvent Tank Source Area extraction and treatment, in-situ
DNAPL treatment, and monitored natural attenuation of the
plume outside of the Former Solvent Tank Source Area.
Under the preferred soil alternative, VOC-con laminated
so
-------
Superfund Proposed P!an__
Jones Chemicals Suoerfunct Site
excavation and off-site treatment/disposal and 1 year for
en-site treatment} While me contaminated soils are a
continuing source of groundwater contamination, there are
no mnmediate risks to human health or ecological risks
posed by the con lamina led soils Considering the fact that
the groundwater component ofrne preferred remedy would
address the contaminated groundwaler the increase in the
time needed to clean up Ihe soil would not be a significant
concern. Therefore. EPA believes that Alternative S-2 would
effectuate the soil cleanup while providing Ihe best balance
of trade-offs among the alternatives with respect to the
evaluating criteria.
Resrdual PCE DNAPL is suspected to be present in the
bed rock aquifer underlying the Former Solvent Tank Source
Area, While Alternative GW-2 (source area extraction and
treatment and monitored natural attenuation of Ihe
remainder of tne plume) would be effective in hydraulically
containing the DNAPL source zone, it would not likely be
effective in remediating this zone to groundwater standards
Although Alternative GW-3 would provide site-wide
groundwater extraction and treatment, making ir the most
effective groundwater remediation alternative, EPA believes
thai Alternative GW-4 would result in the remediation of the
contaminated g round water located both in the Former
Solvent Tank Source Area ana outside of the Former
Solvenl Tank Source Area via a combination of (n-si1u
treatment of the DNAPL, grounduater extraction and
treatment, and monitored natural attenuation, respectively,
in a reasonable time frame and at a significantly lower cost
than groundwater extortion and treatment under
Alternative GW-3.
EPA and NVSDEC believe that the preferred remedy will be
protective of human health and the environ me nt. will comply
with ARARs, will be cost-effective, and will utilize permanent
solutions and after native treatment technologies or resource
recoven/ technologies to the maximum extent practicable
The preferred remedy will also meet the statutory
preference for the use Of Ireatment as a principal element
EPA Region li - July 2000
Page 17
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Appendix V-b
July 20, 2000 Public Notice
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Livingston County News
July'20, 2000
THE UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
INVITES PUBLIC COMMENT ON THE PROPOSED REMEDY FOR
THE JONES CHEMICALS, INC. SUPERFUND SITE
The L'.S Environmental Prolection Agency (EPA) and the New York State Department
of Environmental Con&ervaliwi (NYSDEC will hold 2 public meeting an
August 14, 2000 at 7 p.m.
in the CtJecfonla-Mumfortl Cefltril School, 99 North Street, Caladonl*, NY
lo dscuss ihe findings of ihe Remedial nvestigation and Feasibility Study[RI/FS)
and the Proposed PJan tor the Jones Chemicals, Inc. Superfund sile.
EPA is issuing the Proposed Plan as part ot its public participation responsibilit>es
under Section 117(a) of Ihe Comprehensive Environmental Response, Compensation.
and Liability Act oM9fiO, as amende*^ and Section 300.430(1) ol the National Contingency Plan.
The primary objectives ol this action are to control ihe sources 01 eontanunalion at the site,
lo mirvnue the migration of contaminants, and lo minimize any potential (mure health and'
environmental impacts. The main leatures of Ihe preferred remedy include soil vapor extraction
lo address the contaminated soil, and source area grounctwaSe? extraction and trealment,
irMHu groundwaler hot spot Irealment, ar>d monitored natural arenuatron ol tne
groundNvater outside the source area
Tti« remedy destriDea in, this Proposed Plan is the piel'erred (emedy lor the sile
Changes to ihe preferred remedy or a change from the preferred remedy to another remedy
may be fTBde il public comments or additional data indicate that $ucn a criange will resull in a
more appropriaie remedial action. The final decision regarding ihe selected remedy will be made
after EPA tos taken into consideration all public comments, EPA 15 soliciting public comment on
air of the alternatives considered in ttie detailed analysis otthe Rl'FS report because EPA and
NYSDEC may select a remedy other than the preferred remedy.
The administrative record file, which contains the information upon which the selection
of the response action will be based, is available at the following locations:
Village of Caledonia Library Village of Caledonia Clerks Office
31 0 B Ma i n SI reel 30-95 Main Slreel
Caledonia, NY 14423 Caledonia, MY 14423
lo Ihe commenis received al the public meelmg and in wiling
during the public commen! period, which runs Irom July 20. 2000 - August 19, 2000.
will be documented in Ihe Responsiveness Summary section ot the Record of Decision,
Ihe document which formalizes the selection o) the remedy.
All written comments should b« addressed lo
George Jacob, Project Manager
United States Environmental Protection Agency
290 Broadway, 2Qlh Floor
New York, NY1D007-1 866
Telefax: (212)
E-mail: J8cob.george@epa.gov
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Appendix V-c
August 14, 2000 Public Meeting Sign-In Sheet
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JONES CHEMICALS, INC.
PUBLIC MEETING
Monday, August 14, 2000
7:OOp,Tn,
Caledonia-Mumford Central School
99 North Street, Caledonia, NY
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Appendix V-d
August 14, 2000 Public Masting Transcript
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UNITED STATES OF AMERICA
ENVIRONMENTAL PROTECTION AGENCY
IN THE MATTER OF
United States Environmental Protection
Agency's presentation of che results of
the remedial investigation and proposed
clean-up plan for Jones Chemicals, inc.,
Super fund Site, Village of Caledonia,
Livingston county. New York
PUBLIC HEARING
Location:
Date :
Caledonia-Mumford Central School
99 North Street
Caledonia, New York 14223
August 14, 2000
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7:15
Reported Bv-. Francis J. LeoGrande
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Appearing on Behalf
Protection Agency:
Environmental
Joel Singerman, Section Chief
George Jacob, Project Manager
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Also Appearing:
Deborah Faberman, Livingston County
Department of Health
Joseph M, Moloughney, NYSDEC
David Napier. HYS Department of Health
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(AUGUST 14, 2000; "7 ; 15 P.M.)
MR. SINGERMAN: I want Co welcome you to
the Jones Chemicals Superfund public meeting.
My name is Joel Smgerman, I ' m from the
Environmental Protection Agency. I'm speaking
on behalf of Michael Basile the Community
Relations Coordinator who was supposed to be
here tonight -- so he won't be attending today.
First again, I'm Joel Singerman. with me
is George Jacob, the project manager. We also
have with us Joe Moioughney with the New York
State Department of Environmental Conservation,
Dave Napier, Department of Public Health, and
Debbie Farberman from the Livingston County
Department of Health-
Before we start the meeting I would like
to call your attention to the fact that we have
several handouts in the back, and there's also
an attendance sheet that we would like to you
sign. If you haven't signed it yet we ask. you
to sign it before you leave so that we can make
sure that you're on our mailing list.
The purpose of tonight's meeting is this
is how we will discuss the results of the
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remedial investigation at the site and our,
EPArs, and DEC'S preferred and not preferred
plans. The remedial investigation that occurred
for the proposed and other supporting documents
are available in the repositories which are
identified on page 2 of this handout in the
back ,
if after tonight's meeting you have some
questions or any comments that you might have
regarding our preferred remedy or the
presentation, you can either call, fax, E-mail
or use regular mail, send these comments or
questions to George, but we ask you to do it by
August 19th, the end of the comment period; and
the fax, E-mail address, and the telephone
number are all identified on page 2 ot the
handout.
Tonight we1re going to make several very
short presentations and then spend the rest of
the evening answering the questions you might
have. So we ask you hold questions until the
end of the meeting.
Several wel1-public!zed toxic waste
disposal disasters in the 1970s, among them Love
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Canal, shocked the Nation and highlighted the
fact that past waste disposal practices were not
safe .
In 1980 Congress responded with the
creation of the Comprehensive Environmental
Response, Compensation, and Liability Act, more
commonly know as Superfund. The Superfund law
provides a Federal fund to be used in the
cleanup of uncontrolled and abandoned hazardous
waste sites and for responding to emergencies
involved in hazardous substances. uncontrolled
the abandon hazardous waste heights, the
hazardous substances.
In addition, EPA was empowered to compel
those parties that are responsible for these
gites to pay for or to conduct, the necessary
response actions.
The work to clean, up a Superfund site is
very complex and takes place in many stages,
Once a site is discovered an inspection
further identifies the hazards and contaminants,
A determination is then made whether to include
the site on the Superfund National Priorities
List, a list of the Nation's worse hazardous
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waste sites.
Sites are placed on Lhe National
Priorities List primarily on the basis of scores
obtained from a ranking system which evaluates
the relative risks posed by the site. Only
sites on the National Priorities List are
eligible for remedial work financed by
Superfund.
The selection of a remedy for a Superfund
site is based upon two studies: A remedial
investigation and a feasibility study.
The purpose of the remedial investigation
is the determine the nature and extent of the
contamination at and emanating from the site and
the associated risk to public health and
environment,
The purpose of a feasibility study is to
identify and evaluate remedial alternatives to
address the site's contamination problems.
Public participation is a key feature of
the Superfund process. The public is invited to
participate in all these decisions that will be
made at the site through the Community Relations
Program. Town meetings such as this one are
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held as necessary to keep the public informed
about what has happened and what is planned for
a site.
The public is also given the opportunity
to comment on the results of the investigations
and studies conducted at the site and proposed
remedi es.
After consideration of public comments on
the results of the studies and investigations,
EPA proposes a remedy and receives public
comments on that, and that's why we're here
tonight.
Following the public comments to proposed
remedy, a Record of Decision is signed. It's a
document which identifies a basis for the
preference to the remedy that was selected.
Following the selection of remedy, the
site enters the design phase where the plans and
specifications associated with the selected
remedy are developed.
The remedial action, which is the
hands-on construction work, follows the
completion of design.
Following completion of all construction
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work at the site, the site is monitored as
necessary; and once the site no longer poses a
threat to public health or the environment it
can be deleted from the National Priorities
List .
Now George will discuss the basis about
the site, history, and a few other items.
MR. JACOB: Good evening. Welcome to the
public meeting again. I'm George Jacob with
USEPA, the project manager for Jones Chemicals
Superfund site.
What you see on the screen is a site map.
My apologies for not having a more legible map.
A couple of things -- few things I would like to
out there. The pointer that you see, that's the
former solvent tank area. In my discussions
I'll mention that area a few times. Then you
have the lagoons there, that also will be
mentioned. Then you have two production wells
there, north well and west well- One other
thing I would like to show is the village of
Caledonia wells (indicating),
With that I'll get into my discussions,
1 basically want to give you a brief overview of
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the background of the site, the remedial
investigations and the feasibility study
conducted which l«?d to a proposed remedy. I
hope you all received a copy of the proposed
plan. I'm going to give you a brief overview of
that, and at the end of tho discussion if you
have any questions we will be happy to answer
that .
Okay, background. Jones Chemicals site
is located at 100 Sunny Sol Boulevard, in Che
Village of Caledonia, This company has been in
operation since 1932. The main operations of
the site, manufacturing of chemicals and
repackaging of chemicals from bulk containers to
small containers for resale — sale or
d i s t ri but ion.
To give you an example, between i960 and
approximately 19? 7 volatile organic compounds --
from here on I'll mention as VQCs -- included
tecrachloroethene and trichloroetbene, From
here on I'll use the commonly-known names as PCE
and TCE. Among other VOCs, these VOCs were
repackaged from bulk containers to smaller
containers, and the site had underground storage
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tanks containing solvents and above-ground
solvent tanks containing solvents. So with the
repacking operation, after a number of years of
operation spills occurred over the years, and it
contaminated certain area, the former solvent
tank area, the soils in there, and the
underlying groundwater.
Storage tanks I have mentioned, to review
potential for the contamination, Jones removed
three underground storage tanks in 1985 which
contained solvents, also all the above-ground
Storage tanlcs containing solvents that was
removed in 1990; and the site was proposed for
inclusion in the Superfund National Priorities
List as proposed in June 1988 and was listed on
the Superfund National Priorities List in 1990.
Then in 1991 Jones signed a consent order
with the United States EPA that is to perform
remedial investigation and feasibility study.
That was done in 1991. And early 1991 Jones
began the remedial investigation and feasibility
study. This was done under the oversight of
EPA, and the study was to determine the nature
and extent of the contamination at and emanating
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from Che site; and two, identify and evaluate
remedial alternatives.
And in 1996 to comply with New York State
waste-to-water discharge permit, also known as
the SPDES permit, to comply with that permit and
collect data for the feasibility study work
related to the remedial investigation and
feasibility study, Jones installed an air
Stripper to treat the noneantact cooling water
from the production wells which I mentioned..
north well and west well, the production wells,-
and after the treatment was discharged to
lagoons, and that test indicates that they were
achieving 39,5, or about, percent efficiency.
That leads us to remedial investigation.
In 1994 Jones submitted documents related to the
remedial investigation study, and they began the
field work in 1994, Investigation included
mainly surface and subsurface soils and
g roundwater,
Okay, the results of the remedial
investigation, soil, the results of 19 soil
samples collected from across the site showed
PCE and TCE contamination. The former solvent
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tank area had the highest contamination of -•
highest soil concentration of PCE and TCE, and
at the same area in the deep bedrock we
suspected a PCE hot spot. And groundwater,
approximately -- the hot spot was approximately
1,500 foot to 720 foot groundwater VOC plume
consisting of primarily PCE, and it's
degradation products of PCE, l,2-dichloroethene,
extends from the former solvent tank source area
to the east and to northeastern property ground,
Particularly, the contamination extends to at
least 48 feet below the ground level in that
source area.
Risk assessment. Risk assessment study
was conducted, Based on the results of the
remedial investigation study and the assessment
study, EPA has determined that actual or
threatened release of the hazardous substances
from the site if not addressed by the preferred
alternative or one of the other active measures
present there, may present current or potential
threat to the environment. We have taken a
hypothetical future risk scenario, which is if
the production wells stop pumping there,
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will happen, and under that scenario, also we
found chat if it stops pumping, that could allow
contaminated groundwater to migrate off plant,
which could cause an unacceptable risk.. Again,
that's a hypothetical scenario. The same thing
with if no action is taken there is a potential
for an environmental threat, too.
Now i would like to present the site, the
two media, soil and groundwater. For soil
remediation -- for soil remediation
alternatives: Number one, no action. The
Super fund program requires that a no-action
alternative be considered as a baseline for
combating with the other alternatives. The
no-action remedial alternative, that's not doing
any physical, remedial measures that addresses
the contaminated soils in the former solvent
tank, source area. That's no action.
The second one, treatment of contaminated
soils using soil vapor extraction. Under this
alternative, contaminated soils in the former
solvent tank source area would be remediated by
soil vapor extraction. Under this treatment
process air would be drawn through a series of
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wells to volatilize the solvents, contaminating
the soils, and extracted vapors will be
collected or treated before vented to the
atmosphere; and it's estimated that 1,700 cubic
yards of contaminated soils will be treated with
this process,
And one thing I would like to point out
here is that there ig no excavation here to
treat the soil. The treatment is an interesting
process *
And that takes me to the third
alternative, excavation of: contaminated soils
and off-site treatment/disposal. This
alternative includes excavating approximately
1,700 cubic yards of soil in that source area,
which is the former solvent tank source area,
which exceeds the clean-up area. The actual
extent of the excavation and the volume of
excavation material will be based on
post-excavation and confirmatory sampling. The
excavated areas will be backfilled with clean
soil and revegetated. All the excavated
material will be characterized and transported
off site. we estimate that to take one year to
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implement this remedy, and the previous one we
estimate -- the second one, treatment of the
contaminant soils using soil vapor extraction,
we estimate that will take three years to
implement that remedy.
And the fourth alternative is the
excavation of contaminated soils, on-site
treatment via low temperature thermal desorption
and redeposition,
This alternative includes excavating,
again, approximately 1,700 cubic yards of soil
in that former solvent tank source area, which
exceeds clean-up objectives. Again, the actual
extent of the excavation and the volume of
excavated material would be based on the
post-excavation confirmatory sampling.
The excavated soil would be fed to a
mobile low temperature thermal degorption unit
brought to the Site where hot air injected at a
temperature about the boiling point of the
organic contaminants of concern would allow them
to be volatilised into gases and escape from the
soil. Again, that escaped gas will be collected
and treated. Implementation for this remedy,
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again, estimated to be one year,
Those are the four remedies for the soil
media. Now I would like to bring you to
groundwater remediation alternatives.
Number one, no further action and
long-term monitoring. Again, the Superfund
program requires that no-action alternative be
considered as a baseline for comparison with the
other alternatives. Here there is no further
action because there is also a remedy in place,
which is the air stripper that I mentioned
before,
If we go with the no further action, that
would include or assume that the groundwater is
no longer extracted from those production wells.
And the second alternative for
groundwater is source area extraction and
treatment, monitored natural attenuation of the
plume outside the source area, and institutional
controls,
Under this alternative the affected
groundwater in the former solvent tank source
area would be addressed through the groundwater
extraction system, and extracted groundwater be
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treated by the existing air stripper and would
then used as noncontact cooling water within the
plant, and the contaminated groundwater located
outside the former solvent tank source area and
beyond the influence of the production wells
would be addres3ed through monitored natural
attenuation, a variety of physical, chemical and
biological processes which under favorable
conditions act without human intervention to
reduce the mass, toxicity, mobility volume, or
concentration of contaminants in the soil and
groundwater.
Some examples of this in-situ processes
include biodegradation, dispersion, dilution,
sorption, volatilization, and cbernical or
biological stabilisation, transformation, or
destruction of contaminants.
It is estimated that it will take over 15
years to clean up the groundwater under this
alternat ive.
That leads me to the third groundwater
alternative. Site-wide groundwater extraction
and treatment, in-situ treatment of DNAPL --
again, that's a PEC hot spot -- and
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institutional controls.
Under this alternative Che affected
groundwater would be addressed through a
groundwater extraction system. It is estimated
that groundwater extraction system would utilize
about 16 regional wells. In addition,
contaminated groundwater would continue to be
extracted from the existing production well
which would facilitate the capture of the plume
beyond the source area. A portion of the
extracted groundwater would be treated by the
existing air stripper and would be used as
non-con tact cooling water within the plant prior
to being discharged to th.« on-site lagoons.
Because the present capacity of the air
stripper would be exceeded an additional air
stripper would be constructed to treat the
balance of the extracted groundwater. The
treated water that was not used for non-contact
cooling would be discharged to an infiltration
gallery to be constructed to the northeast of
the lagoon system. To comply with the New York
State air guidelines, the air exhaust from the
air stripper will be treated as well.
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It is estimated that it will take eight
years to clean up the groundwater under this
alternative.
One additional thing, to enhance the
treatment of the PCE hot spot in the bedrock
beneath the source area an oxidizing agent such
as potassium permanganate Or hydrogen peroxide
would be injected via a we 11« That was the
third groundwater alternative.
And finally, the fourth groundwater
alternative, source area extraction and
treatment, in-situ treatment of the PCE hot
spot -- or DNAPL -- monitored natural
attenuation of the plume outside the source area
and institutional controls.
This alternative would be the saw.e. as the
second alternative -- second groundwater
alternative, to enhance the treatment of the PCE
hot spot in the bedrock beneath the former
solvent area, the potassium permanganate or
hydrogen peroxide would be injected via a well.
it is estimated that it would take 10 to 15
years to clean up the groundwater under this
remedy.
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These are the remedial alternatives for
groundwater and soil.
And now the evaluation process, we use a
nine-step criteria. The first one is protecting
of human health and environment.
Number 2, compliance with applicable or
relevant, and appropriate requirements.
Number 3, reduction of mobility,
toxicity, or volume through treatment.
Number 4, long-term effectiveness.
Number 5, impiecnentability,
Number 6, short-term effectiveness.
Number 1, community acceptance. That's
why we are here in front of you.
Number 8, state acceptance. We have been
working closely with the State and the State
representatives are here.
And number 9, cost.
The remedies that I have described to
you, I would like to show you the cost of them.
For the soil remedies the first remedy,
no action, capital cost is nothing.
Second remedy, 365,000.
Third remedy, 3.2 million.
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And the fourth remedy, approximately
1.1 mi 11ion.
it's the same thing with the groundwater
remedies, First one, no further action, capital
cost of §3,000.
Second remedy, approximately 362,000
capital cost.
Third, approximately 1.5 million.
And the last one, 479,000 capital cost.
Eased on all these studies the preferred
soil remedies that we are proposing to you are,
for the soil, we propose the second soil remedy,
which is treatment of contaminated soils using
soil vapor extraction; and the preferred
groundwater remedies, the fourth one, source
area extraction and treatment, in-situ treatment
of the PCE hot spot, monitored natural
attenuation of the plurne outside the source
area, and institutional controls. And the cost
of the preferred remedies, again, is - - both put
together, the capital cost is under a million
dollars. Thank you.
MR. SINGERMAN: Okay, the preferred
remedy that George has described is just that, a
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EPA preferred remedy. We don't make a decision
until we consider public comments following the
comment period closing.
We're hoping that we can select a remedy
for this site by the end of September, and
subsequent to that we would negotiate the design
and construction remedies with Jones, and so
we're hoping that perhaps by maybe next spring
or summer we may have the design underway and
maybe another year or so after that we would
have -- say after a year or so of design, we
would have construction underway, perhaps, two
years from now. That's just a rough schedule.
It could be shorter, it could be quicker. It's
anyone's guess.
As a reminder all the documents that are
relevant to this proposed plan, the proposed
plan, the investigation and study, they're all
located in the repository identified in page 2
of the proposed plan; and also, you have until
the 19th of August to submit your comments to
us .
In a minute you're going to have an
opportunity to present any questions you might
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have. We have a stenographer present, so if you
do ask questions or comments we asX you identify
yourself and identify either your affiliation or
address. And so at this point if there are any
questions we'll be happy to try to respond to
them ,
In the bach.
LEON CRANSWQRTH: Ky name is Leon
Cransworth, 501 Barker Road in the Town of
Ca1edoui a.
Have you done a profile study of where
the contamination is in relation to elevation on
the ground - -
MR. SINGER-MAN; In the groundwater or the
soil?
LEON CKANSWORTH: Both.
MR. SINGERMAN; Well, we've taken samples
in the ground -- in the groundwater and soil, so
we have a pretty good idea of where the
contamination is in the soil and where it is in
the groundwater.
LEON CRANSWORTH: Height-wise?
MR. SINGERMAN: Yes. I mean, for the
soil we're not -- again, keep in mind the way
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you investigate is basically cake samples. We
took 19 samples of the soil. You have Co
interpret and make presumptions between the
point you're talking samples, but we feel we've
pretty well characterized what's there. After
we do the treatment if we select the remedy we
identified, soil vapor extraction, we'll go back
out and take samples again to make sure we
cleaned up. Same with the groundw-iter . We have
to treat the groundwater down to drinking water
standards. So we'll continue to monitor that
groundwacer, and the treatment process is not
turned off until the groundwater has met
groundwater standards ior a sustained period of
time ,
So the answer is yes, we think we've
characterized the contamination; but again, it's
not an exact science, but we have safety
mechanises in place during the course of the
implementation of the groundwater remedies such
that we can keep track of how things are
working. So we don't need to know exactly where
everything is. That's the bottom line to that.
Does chat answer the question?
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LEON CRANSWORTH: Yes.
MR. siNGERMAN: Anymore questions?
MARY REED: My name is Mary Reed, and I
live in Caledonia, and for the first 14 years
that we were here, which has been early 1950s,
we lived in what today would be termed the
seepage lagoon that Jones Chemicals came out
with. i have a grave concern for what Jones may
be doing or has done. I guess I need to say
what it has done. I'm pretty confident. I
spoke before the State Commission on hazardous
Waste in March of 1998 in Albany, and I am a
cancer survivor, breast cancer survivor. I do
believe that the seepage, the concerns of the
TCEs from the seepage lagoons of that perhaps as
much as we can ever prove will, has affected,
will affect a fetus of one of my children, and I
have also seen the vast numbers of breast cancer
survivors within a very short distance, less
than a quarter of a mile, and they say all the
lagoons are the waste vessels of Jones
Chemicals. Our pet dog for many years, for 14
years, would go down into those pools and come
up totally brown. We would spend tons of money
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curing this dog. That was before we knew, knew
what was happening.
My question is our water, which I know is
a universal question. It's not something --
what this treatment at the exorbitant cost, what
warranty -- is there any warranty -- I'm sure
there isn't -- that can be given to us that it's
not going to seep inro our underground water
system?
I've been working very close on a Well
Health Committee that has been formed in the
Village to monitor and hopefully control what's
happening to our spring-fed wells, but -- and I
talked many times with Mr, Basile. I'm very
sorry for the death -- I was hoping he would be
her* tonight --of his mother. But I'm very
concerned that taking and removing soil and
putting it back -- we also have been through a
costly -- personally ourselves, a costly
environmental clean-up, worked very closely to
the EPA and DEC, and not through the benefits of
a Superfund site, but through a very, very
six-year-long term expensive environmental
clean-up, working with environmental issues on
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our own private property; and moving the soil
chat was supposedly contaminated in that
situation cost us a great deal of money, not to
take to Niagara Falls, but to take to Ohio, and
I don't -- I guess I fail to see what it's --
what taking and removing soil with whatever
system v;e have that we think we're going to
purify it? Is this something that -- you said
50 years down the road -- did you say 50 or 15,
I'm sorry?
MR. SINGERMAN: 15. That's for the
groundwater. With whac we're proposing for soil
is the vapor extraction, basically what we do is
put pipes into the ground and draw -- you draw
volatile organics off the soil. By using the
vacuum you're drawing contaminants out of the
ground and treating it. There, will be no
excavation. We estimate it will probably take
about three years for the soil to reach the
clean-up levels and probably 15 years -- it's
estimated ID ED 15 years to treat the
groundwater; and we believe baaed upon the fact
that we -- such a high production -- the
production wells was pumping at such a high
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rate, Chat basically prevented the off-site
migration and leaching at this point. So it
seems to me to be drawn towards production
levels rather than beyond.
When this process is all done, when we
completed the soil remediation and the
groundwater has been treated and standards have
been maintained for a number of years, we will
scill continue to monitor, but we think that
cnce -- once we eliminated the source and once
we've eliminated the hot spot at depth, that
we'll be in a position to delete the site from
the National Priorities List because it will no
longer pose a threat to health and environment.
MARY REED: I think it's probably been
proven from I960 until when we first became very
aware of soil and what -- of how toxic an
environment we were living in, that many of us
are the un - - the ones that have survived the
breast cancer, no one can ever lay it to what it
may be, but the big point we have to drive home
is how safe can this process be for what will
continue to be our groundwater and air supply?
MR. SINGERMAN: Well, the objective to
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cleaning the soil is primarily to prevent a
future source of groundwater contamination.
MARY REED: Of groundwater.
ME, SINGERMAN: Of groundwater. So by
removing contaminants from the soil -- what
happens every time it rains you have the
rainwater picking up contamination in the soil
and perking it down into the water table.
Again, like I said, based upon the data that we
have, it does not appear that at this point in
-time there's any migration of contamination
beyond the property boundary because the
production wells were pumping such a high rate,
they basically modified the natural groundwater
flow. So in addition to Chat, with then-
growth, the production wells will still continue
to pump, and in addition we will be placing
additional wells tc accelerate the removal
groundwater contaminant.
so the whole objective is to prevent --
i& to eliminate the source of ground
contaminations in the soil, and then to remove
contaminations from the groundwater, actively at
the source and then through natural processes
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downgrade- Primarily at the disposal area, what
we call the source area, there's very high
levels of contamination in soil and groundwater;
but beyond that point the levels drop off
significantly. So that's why we're proposing
natural attenuation, it's a natural process to
disperse, leaching, degradation, that the
present chemicals will degrade by themselves.
MARY REED; The monitoring of this, is
this something that is on che Superfund level?
I mean, is this something that --
MR, SINGERMAN: The monitoring of the --
MARY REED: Well, of our groundwater.
MR, SINGERMAN: Well, the monitoring on
the site, that was part of that process, I
believe the Department of Health has been
monitoring the private wells in the area. So I
don't -- perhaps the Department of Health wants
to discuss what they found in your wells.
MR. NAPIER: The public wells, Mary --
and we've talked. The public wells were
examined. The Village public wells have been
contaminated, and that's why an air stripper was
put in, in '91, installed to remove that, and to
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make it safe from contamination; but it's been,
off the top of my head, I think three or four
years since there's been any identification of
volatile organics in the Village well supply.
So at the present time there hasn't, in a couple
years, any volatile chemicals in the well
supply, I've example occasionally wells around
the periphery of the plant, private wells, and
we found two wells with some volatile
contamination that we haven't been able to trace
back to Jones, but Jones Department of
Environmental Conservation did put carbon
filters on those two private wells to make sure
they had safe water; and they are continually
monitored to make sure they have clean water.
UNIDENTIFIED SPEAKER: How close are the
wells to the Town?
MR. NAPIER: On the Wheatland Center
Road .
UNIDENTIFIED SPEAKER: On what Side of
the tracks?
MR. NAPIER; Up to Norr River.
UNIDENTIFIED SPEAKER: There was tracks
by the -- you know where the lumber yards are?
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MR. NAPIER; Out near the gas company,
right over - -
UNIDENTIFIED SPEAKER; On the south side
of where the tracks are? The gas company is on
the south side.
MR. NAPIER: Yes, it would £>e on the
south s ide.
UNIDENTIFIED SPEAKER: A lot of this Is
on the north side of the tracks down here.
MARY REED: And again, I believe that --
3 really -- I strongly believe that our
monitoring has been very faithful and -- but
I - - I do go back on my knowing -- knowing that
the standards were lowered by the state by 10
percent in the '90s so that they could comply
with what was going on.
MR, NAPIER; Well, they weren't lowered
so they could comply. The Lowering of the
standards actually made them out of compliance
BO they could take more action. That was the
case. The standards were higher. They were
like 50 parts per billion for the volatile^, and
they lowered it to 5; and that's when we made
the Village put the air stripper in.
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MARY REED: And the air stripper is in
Jones Chemicals?
MR. NAPIER; Well, there's two air
strippers. There's one in the Village supply,
and Jones has an air stripper on their
production well where they're pumping water.
UNIDENTIFIED SPEAKER: Where does the
water go that Jones discharges - -
MR. NAPIER: They have a SPDES discharge
permit to discharge that water.
UNIDENTIFIED SPEAKER: Back in the water?
MR, NAPIER: I'm not sure. It the --
UNIDENTIFIED SPEAKER: And that's tested
before it goes to the lagoons?
MR. MOLQUGHNEY: Right, all that water
that leaves that air stripper. it's not tested
continuously, but it is periodically checked.
One thing we have to remember is we're
talking about the volatile compounds. By their
very nature they evaporate very quickly. Air
strippers, what they're currently doing and
what's on the Village wells, they're extremely
effective in moving the volatiles out of the
water. what it does is have an air release of
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the compounds, but it's extremely effective in
removing it from water. So anything that goes
back to the lagoons is cleaned by the air
strippers before it goes back there. And the
ultimately the EPA is banking on -- because
they're so volatile, they're easy to remove by
the air stripper and they're fairly easy to
treat if we make active, attempt to do it,
ANDY GREEN: I'm Andy Gr^e-n, Caledonia.
As far as we get rain and it goes down through
the ground with this chemicals, right, that's
the water you pump out and Che air stripper has
to take the chemicals out arid put it back in the
lagoons. Why not take the ground out of there
and get rid of it. 1,7QO irubic yards is not a
lot. Did you make a mistake? is it 17,000?
MR. SINGERMAN: No, 1,700.
ANDY GREEN: Because 1,700 is not a lot
of area- why don't we get that out of there? I
had to get mine out of there,
MR, NAPIES; Times have changed. Times
have changed in how we approach a lot of this.
It used to be we did what you did, take it out
of the ground and put it someplace else where
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you might have another problem. And we learned
in very recent years that there's better ways to
treat it in place. Rather than take it from one
spot and moving it to someplace else and having
all the handling problems and maybe create
another problem where you put it, treat it in
place. Leave it there and treat it there and
take care of it there.
ANDY GREEN; Logically, it could be
created better on top of the ground than it can
15 feet under the ground.
MR. NAPIER: Not necessarily,
ANDY GREENr You can watch it and the put
bugs in there and the treatment,
MR, NAPIER; Yes, but then you have a
handling problem and you create more exposure.
You know, I'm with the Health Department.
There's more potential for exposure when you
excavate that soil because you make it more air
borne, people are handling it, you're hauling it
around and moving it. There's much more
potential for exposure to it.
MR. SIUGERMAN: And if you look at the
time frame, you're talking one year to dig it up
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and take it off and three years to treat it at
the location. We also evaluate what we're
getting for the increased cost of taking it off.
For the two extra years we can have basically
the same remedy that's just as effective at
substantially less cost. Remember George went
through all the criteria. Cost is criteria.
There's also a preference for treatment is one
of the criteria, You've got the mobility,
toxicity or volume through treatment. So if
we're just picking it up and moving it somewhere
else, you know, it's not -- it's basically not
the EPA's preference. We rather do something
that treats it-
AMD Y GREEN: NOW, you're going to sink
how many wells in this area and how deep?
MR. SINGERMAN: Part of the design would
determine exactly how many wells we'll put in.
We have to go back out -- we took 19 samples
during design. We'll go out and take more
samples and better define the area that has to
be treated, because from that then we'll scope
out how many wells, what depth and whatever.
But your point, it's just visually conceptual at
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this point and we have to fine tune it.
ANDY GREEN: You can take care of it by
putting in wells and pumping water out --
MR. SIBGERMAN; No, these are not water
welis .
MR. NAPIER: Not for the soil.
ANDY GREEN: How do you treat wells at
that point?
MR. SINGERMAN; No, what we do - - what it
is, is volatile organics are basically adhering
to soil particles. You have air spaces between
the soil particles. By putting up the wells --
they're called wells -- they're called wells,
but they're not water wells. Just imagine pipes
put in the ground. They're -- they're -- and
basically what you do is create a vacuum, draw
air through it, and what that does is pulls Che
volatile organics off the soil particles into
the air spaces and sucks them up- So it
continues to draw that -- again, they're called
volatile organics, meaning that if -- they cotne
off very easily.
ANDY GREEN: So they're all going to have
a power vent?
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MR. NAPIER: Not each well. You
manifold -- you tie them together.
ANDY GREEN: You tie them together lie
nine to ten foot underground?
MR. SIMGERMAN: Well, the point you tie
them together may be below the frost line so the
pipe don't freeze. You have to work it out. We
have them all connected going to some location
that has some type o£ vacuum that draws the
material. what is drawn out -- whatever
contaminants are removed will be treated and you
can continue the cycle; and again, the three
years is how long it takes to draw everything
out .
ANDY GREEN: Now, you suck that chemical
off through turbine pump or whatever, and that
goes where? It doesn't go to the air, does it?
MR, 5INGER.MAN: No, it gets collected.
It's collected and treated.
MR. NAPIER: It will be treated before
it's discharged,
ANDY GREEN: And that will be set up OUt
the take it out of the ground and put it high
enough so that --
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MR. NAPIER.- What 2S emitted through the
pipe should be clean air and that will be all
mC'ni t ored.
MARY REED: And there's no warranty after
this three-year period that there won't be more
exceeding grounds.
MR. NAPIER; There will b^ soil tests.
After getting done wich three years that we've
talked about, we'll put more borings and take
more soil samples to verify chat ic has cleaned
it up like ic was supposed to.
MR. SIWGERWAN: It may take less time,
too. it may take a year. it's an estimate. It
may take more time; it may take less time.
Jones is not off the hook until it's clean. So
they will have to operate the system until it's
clean, until the EPA is satisfied that the
contamination in the soil has been cleaned.
UNIDENTIFIED SPEAKER; Now, chemica1 -tvis*
you've got a list of all the chemicals you think
in is in that soil and they all can be sucked
out of that soil, or are some going to stay
permanently in the soil.
MR. SINGERMAN: There's not that many
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chemicals really present. PCE is the primary
chemical in the soil; but basically, all the
concaminants in the soil that are the problem
for us are volatile organics. There are other
contaminants; but again, we don't have them at
the site. PCBs, if you had PCBs at the site you
could not use vacuum to draw them off. You
can't draw metals; but volatile organics, by
their very nature are easy to draw off.
UNIDENTIFIED SPEAKER: And you can draw
them all off, the volatiles?
MR. SINGERMAN: Yes. We've done this
successfully at other sites. I mean, it's not
experimental. it's basically proven technology.
This has been used at other sites.
UNIDENTIFIED SPEAKER: And that will be
there for a lifetime. The one we had west of
town that will be there a lifetime; through the
west of town, that will be there forever?
MR. NAPIER: Through Lehigh Valley?
UNIDENTIFIED SPEAKER: That puts a lot in
my mind about what's going on down there.
MR. NAPIER: What you have down there is
on the other side of the tracks. That's a
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totally different situation there. That's a
much different situation than what we hav^ here
to deal with.
MR. MOLOUGHNEY: Yes, I can speak to
Chat. I'm the project manager for the other
site for the State, for both sites for the
State. I think what we have there is a much
larger volume, and we waited 30 years before we
did anything. Here, after our investigation we
are pretty confident despite the size of the
Jones plant and the size of the property and
building, the actual area inhere there's the most
contamination and the site where the spill was
is a fairly .localized and small area. It's easy
to get to and easy to get in for the treatment
system. Much opposite what have at Lehigh
Valley,
UNIDENTIFIED SPEAKER; This sat down
there and - -
MR, MOLOUGHNEY; Right. This has been
there quite eome- time.
UNIDENTIFIED SPEAKER: I have a brother
there, and we have a whole great --
REED; We can tell you horror
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stories of chemicals.
UNIDENTIFIED SPEAKER: We can tell you
horror stories.
MR- MOLOUGHNEY: One of the beneficial
aspects of Che Jones being there, they've been
pumping water for what they use almost
continuously. Just by using water for their
plant they've been capturing a lot of these
chemicals before they move too far. They
haven't captured all the them, but their wells
are pretty close to where all the contamination
is. They're catching most ot it before it
leaves the property, but you hav$ the lime rock
there, and there's nothing there to capture it,
so that needs to --
UNIDENTIFIED SPEAKER: You have someplace
where this vapor extraction sytem has --
MR. MOLOUGHNEY: Yes, we do it all the
t ime .
UNIDENTIFIED SPEAKER: Be specific.
MR. MOLOUGHNEY: OKay, well, for the
Lehigh site.
MR. AfAPIER: There's a house right down
in Mumford we did it for a petroleum spill about
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three years ago, and worked down there with DEC.
Not this program. It was a fuel spill and
basically it was the same type of system,
there's an accidental spill of fuel oil that got
into the soil in and around the basement, and we
used soil extraction to take that out,
UNIDENTIFIED SPEAKER: How long did it
take?
MR, NAPIER: Oh, a year and a half
probably, and to be honest a nuel oil is not as
easy readily extractable as what these compounds
are. It's a little heavier, and it would take a
little longer.
MR. MOLOUGHNEY: And if you go to any gas
station that is more- than. 20 years old, if you
take a close look at the gas station, there's a
little shed or shack or treatment facility on
the side, and they have a little air stack going
off, and probably they're doing a combination of
air stripping and soil vapor extraction for the
type of chemicals they're using. It's used
everywhere.
JANE HANNA: Jane Hanna, You said that
the lagootts are still being used; is that
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correct?
MR. MOLOUGHNEY: Yes.
JANE HANNA: So that's being added to
what's there?
MR. MOLOUGHNEY: I'm not sure. I think
there may be miscommunication. The way Jones is
using the plants currently, they're discharging
any -- they use their wells for water. They
collected all this with waeer with their wells.
Before the-y discharge it to the lagoon the State
makes them clean it through the air stripper
they installed. So they're basically
discharging clean water back into the lagoons.
JANE HANNA: But they're still putting
something back in the lagoons?
MR. NAPIER: Clean water.
MR, MOLOUGHNEY: Clean water -- yes.
JANE HANWA: There's two air strippers,
correct?
MR, MOLOUGHNEY: Yes.
JAlfE HANNA: We're going to add more
wells, pipes, everything is going into the
atmosphere, how often are those facilities
monitored,- daily? weekly? Monthly? Quarterly?
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MR. MOLQUGHNEY: For the air discharges?
JANE HAKNA: Anything released into the
air?
MR. MQLOUGHNEY: Tim; can you answer --
TIM GAFFNEY: Yfes, Tim Gaffney from
Jones Chemicals, also
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through the soil. They're collected in these
vapor recovery wells, and they're sent to carbon
filters, to these cannisters that have carbon in
that and the vapors are absorbed to into the
carbon. The carbon then goes to an off-site
disposal site for incineration or landfill or
some other type Qf hazardous waste treatment.
We have another Jones Chemicals facility
cut in the San Jose, California, area that had
an extremely large spill of the same chemical
back in the early 1930s, and we used the
identical technology that the EPA is
recommending to all of us to be used at this
site and much greater surface area, much greater
concentration, much more difficult soil to work
with as far as bleeding the vapors out of the
soil, and we turned that system off in under
five years out there.
So we do -- someone asked the question,
we do -- Jones Chemicals has a real life example
of this technology in the soil working. So I
would be happy to talk to anybody about it.
Like I said, I'm a resident of the village of
Caledonia. In addition to being in charge of
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environmental affairs for all of Jones
Chemicals, and we feel this is the most
practical way to deal with. th.e soil
contamination that's on the property down where
our solvent tank used to be. We understand
there's excavation that can be done and other
types of measures, but when you go through the
nine criteria that George explained and you
start comparing the alternative against the
other alternatives, this is the one that makes
the most sense. It does have a track record.
Joe with the DEC has used it. We're confident
that this is going to work. If we didn't have
the track record ourselves at another site we
would be a little worried about it ourselves.
As far as the groundwater is concerned, I
think it's important to know that this is a
closed-loop system that we're talking about. We
have a pond or lagoon, whatever terminology you
want to use, that sits out back of the facility,
and we require about 400 gallons of water a
minute to cool our product, and we extract it
out of the ground, both in the shallow and the
deep water bearing zone, and it goes through the
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air stripper. It's virtually sirnilar to the air
stripper that the village of Caledonia also has.
The air stripper takes the volatile crganics out
of the water and clean water is put back into
the pond.
We monitor for our permit with the DEC
twice a month to collect samples, and we test
for everything from volatile organic compounds
to various metals, pH, chlorine, which is the
main product that we've handled there for 50
years; and since the air stripper has been in,
which I believe is a little over four years, we
haven't had one excedence for any VOC that I'm
aware. We have had an excedence for sulfate,
but that's been attributed to the low water
table in Caledonia. We have nothing in our
process that contributes aulfate whatsoever to
the groundwater. So that's been corrected with
all the rain this summer. AS far as what's
going into the pond, it's clean water. it's
super clean. There's no vOCs detected
whatsoever. We have tests twice a month that
show that,
why is tftere two air strippers?
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Basically because the products of contamination
are different. The Village -- the Village's
contamination is 1,1,1-trichloroethane, the two
chemicals here are perchloroethyiene and
t r i chloroethylene.
At least back into the early 1980s when
we have data --we don't have data prior to
that -- the flow of water in our region is
actually from the Village of Caledonia's barns
to our site when our wells are pumping. The
v;ater does not Clow from Jones Chemicals to the
Village or to the park or to the golf course or
to where che Village wells are, contrary to
popular belief. At least since the early 1980s
when we monitored that and had these wells, that
has been the case. Prior to that we don't know
because the issue hadn't come up. We have had
these extraction wells for our cooling process
well before 1982. We have had our lagoons well
before 19B2. We have had our discharge permit
with the DEC well before 1982.
All I'm trying to say there is most
likely at those times the conditions were also
the same. There's no data to support, confirm
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or refute chat, but that's my belief, and I've
spent almost is years with Jones, this being one
of the more important projects, if not the most
important project being the resident here that I
have, it's my belief the two systems are not
connected and that's why they're separate
treatment units there.
We like the remedy that they put
together. We know that the air stripper works.
we put that in four years ago. Jones paid for
that. Jones is not getting Superfund money for
paying for any of this. It's being paid for
strictly out of operational funds. There's no
insurance coverage for this. This is a major
project for us, and I personally as well many
people in the company have spent tens of
thousands of hours on this project, and we're
very happy that after this length of time that
it has taken for ua to get to this point, that
we're at the point now when we're going to
actually make more headway than we have in the
last four years by having this air stripper in
place.
So that's my speech for the night. I
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would be more than happy to answer Any questions
for anybody on any of this. The documents are
public knowledge. I work in Caledonia now, not
in Florida, not in Leroy. The company is not
being sold. It's not going bankrupt. Any other
rumors you've heard in town are not true. It's
a great company, and we're excited to be working
with the EPA co try to make it better,
UNIDENTIFIED SPEAKER: Where do you live
in the Village?
TIM GAFFNEY: I live down on Stony Hill
Circle. I've lived in Caledonia for about 12
years.
MR. SINGE.R»AN: Any other questions?
VERONICA LAUGHLIN: Mr. Gaffney, would
you clarify something you lust said?
MR. SIHGERMAN: Identify your name,
please.
VEROHICA LAUGHLIH: I'm Veronica
Laughlin. I live on Grand --
The thing that Jones is paying for
themselves is treatment the company began on its
own; is th^t correct, to remedy this condition?
TIM GAFFNEY: Yes.
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VERONICA LAUGHLIN: Where does the
Superfund come in?
MR. SINGERMAN: First of all, the
Superfund is basically slang for the
Comprehensive Environmental Response,
Compensation, and Liability Act. The Superfund
itself is basically a fund for when we have
parties that are unwilling or unable to
basically take whatever -- take the action as
necessary to clean up the site. in this case we
have Jones that has financed the investigation
at the site, and we hope to negotiate with them
and also to design the construction remedy
described if it's selected. So really there
aren't any Superfund monies being used.
UNIDENTIFIED SPEAKER: There are or
aren1t?
MR. NAPIER: Are not.
MR. SINGERMAN: Hot.
VERONICA LAUGHLItf: There are not because
they're willing to do it, but if they weren't
willing or spurned the proposed --
MR. SINGERMAN; First, we can force them
to use it. We can take measures to try to
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convince them it's in their beat interest. The
Government — it usually costs more money for
the Government to do something than for them.
If they were unwilling to do any work -- like,
for example, if we negotiate design construction.
and we don't come to an agreement and we have to
enforce the measures,, we can't convince them to
take action, that's the purpose of the
Superfund. But in this case they're a willing
participant, I don't know how much they've
spent, but it's a lot of money, and they'll be
spending a lot more money because you see what
this remedy is going to coat over the lifetime,
about $664,000 for the soil and 1,6 million for
the groundwater. So that's, you know, a lot of
money they'll still have to spend in. the future.
So we expect they'll negotiate and come on a
settlement and do the designed construction.
We have Superfund monies for the sites
for which — like I said, where we have parties
who are not able or willing, and we have parties
where we can't identify them? they went bankrupt
and disappeared. That's what it's for.
VERONICA LAUGHLIN: It's very unlikely,
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because I think we all have different concept of
what the Superfund is.
MR. NAPIER: An example of what the
Superfund is for is like the -- Road, that's on
the State and Federal Superfund list, and
because they haven't been able to get or find
any reasonable party State or Federal money will
be used to clean that up.
MARY REED: I thought it had to exceed
$50,000?
MR. NAPIER: There's no dollar amount
that I know of.
MR. SINGERMAN: There's no price on it.
DEBBIE BANGUY: I'm Debbie Banguy from
Caledonia. I spoke to Mike Basile about this.
He called me about two weeks ago. I mean, I
heard all the stories about Jones and all this,
and he explained to me the same thing you did.
I didn't realize Jones was paying for this
entire thing. That I felt was Superfund money,
and I would to have to say I'm very happy to see
that Jones is taking control of this and paying
for it themselves.
MR. SINGERMAN: In addition, not only are
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they paying for the study, they're paying for
che oversight, paying for this meeting, paying
for che air fare. By signing the consent decree
they agreed to pay oversight costs and, you
.know, administrative costs. So it's not only
their cost, but also EPA ' s coses and also the
State's cost.
DEBBIE BANGUY: And I talked to Will
Wadsner who is in this charge of the -- I was
concerned, also, hearing so many rumors that
Jones are staying, and he said that yes they
have a smaller group of people working there,
but they are looking to enlarge, and they're
trying to change their image. And 1 think doing
something like this will help them. it made me
feel a lot better about Jones, too, just knowing
that they're doing this. They're paying for
this themselves, Thanks for mentioning that,
letting people know.
JANE HANNA; I still have the same
question. The question is what goes into the
air, how often are you going to monitor?
MR. MOLOUGHNEY: Okay, currently it's not
monitored, and I can explain. The reason for
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that is we know how much water is going in and
how much contaminant is going in and we can
figure out based on how much is going in how
much is going out. That does not meet the
criteria for the State permit. It's far below
what the State will require for an active permit
and monitoring. However, with additional
treatment that they're going to add and as they
start pumping more water that will be
re-evaluated. If it exceeds the threshold
requiring a permit we will have to go through
that process. Currently it's not monitored
because we know it's below a certain level.
That's the best answer I can give you.
MR. NAPIER: Remember, it's lust the one
source. It's just the groundwater that Jones is
Currently pumping and treating on the wells.
The air stripper on the Village wells is not
producing any of these VOCs because there's no
water coming in. The carbon treatment will be
able to remove the VOCs before it's discharged.
MR. SINGERMAN: And when the EPA takes
any action, we have to comply with all.
environmental requirements. So -- there are air
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discharge requirements. So we will
that -- if unacceptable levels of discharge are
not being treated it has to toe shut down. So
there will be treatment to prevent that from
happening. Let's say something goes wrong; the
system gets shut down so the system can be
checked. It's not going to be allowed to
continue running. We're not going to allow that
to occur.
JANE HANNA: I'm sure you would not, but
tiny question was do you do it, and the answer
was, no, you do not.
MR. NAPIER; Not right now.
MR, MOLOt/GHiVBY.- Maybe to enlighten you a
little more. There is no State-wide level of
how much goes into the air before we iasue a
permit. Every air source is checked separately,
There's a whole list of criteria we go through
based on how much air flow is being used. How
high is the stack frotn the ground where the
nearest people are. We come up with a number
based on all thes^ things, put together a
threshold level in each place it's unique. Here
those calculations were done, the amount
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coming out is below that, so we don't conduct
any monitoring.
JANE HANNA: My other question is the
people in this room are taking this as serious
to tiring in professionals, and this has been out
there for how many years. My question is why
does an individual build their home, sink a
well, and have a well that's been in existence
for a hundred years and we have the situation
and we do not check every well in the Town of
Caledonia?
MARY REED: We're a well,
JANE HANNA: We do not check every well
in the town of Caledonia, correct?
MR. NAPIER: rcr what; for these
c hemi cals ?
JANE HANNA: No, we do not check every
well in Caledonia far --
MR. NAPIER; That's what I'm asking you;
what do you want them checked for, these
volatile organic compounds or what?
JANE HANNA: I don't know that I need Co
classify a chemical when there's a situation and
some of the chemicals are known and some of the
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other chemicals are not known why we wouldn't be
checking every individual's well. If they're
going through that expense and they're goirg
through the time to present this, I have some
difficulty when the Mayor goes and gets our
Village water aerated and we have people who are
net on that., why we're nor going out, knocking
on their door and saying we have a situacion.
We would like to come in and we would like to do
a check. We're going to set up a schedule, but
just like we're not checking air, we're not
checking water; and tftose are the two things --
MR. NAPIER: Well, I have checked a lot
of water. There may be a few people here who
could verify that.
JANE HANNA; No, my question is why can't
we check every well --
MR. NAPIER: i can't do the water in
every we 11 or
JANE HANNA: I'm asking that.
MR. NAPIER: But I have in the Jones
site, and any private wells I could find
anywhere close to them i sampled them and I
found the two which had a low level, and we put
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filters on.
JANE HANNA: Well, I think it's more than
one person can do be and the there's other facts
here .
MR. NAPIER: Well, the other thing is
private citizens can have their wells tested as
well, I have a protocol and EPA does, too, for
programs. We only investigate sites such as
Lehigh Valley and other sites where there's a
known source, We investigate that and sample
any wells we feel necessary. Between the
meetings today and tonight I went and took
samples on the Lehigh Valley well for someone
that called ate. There was a concern, and I
sampled it. I have to have a reason, some
suspected cause,
JANE HANNA: It's right here. This is
it.
MR. NAPIER: There's a limitation of how
far this contamination goes.
JANE HANNA: I'm not talking about
contamination, I'm talking about people who
build a home, sink a well or have one that's
been in existence many, many years. If everyone
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is willing to do all of this I don't understand
why we caji1 t go through the community and check
everybody's water source.
MR. NAPIER: It's a nice thought, but
it's not practical for the State to do it. AS 3
say, homeowner's caj) do that. Every homeowner
should test it for bacteriological contaminants.
You can't get a mortgage through A bank unless
you do a bacterial sample. You really should do
it for the nitrates. Ideally you should also
have it checked tor lead, arsenic, barium, stuff
like that. You should do it for all vola tiles
like here. Let alone from this site, you could
have a gasoline spill from another siLe near
your house
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Environmental Coalition. I'm representing Judy
Robinson who is our Western New York Director of
CEC, and we are here because it is a historic
moment in this country in that all source water
or drinking water is being addressed. The
Federal government has mandated that every state
assess possible contamination of its drinking
water and the susceptibility of contaminants to
that drinking water. So the reason I am here
tonight is to inform you about the program and
ask you some questions of how it relates
specifically to this sice.
And first, if I can briefly tell you the
goals of this program and how it relates to
Caledonia; and then I'll ask my specific
quest ion.
The goals of this program are three-fold.
One is to find out exactly where the water comes
from. We know in Caledonia, we know a lot of it
is springwater; but where is that water coming
from before it gets to the spring? Possible
contamination sources is the second goal by
creating an inventory. And then the third goal
is to create -- or to assess the possibility of
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contamination so that people in Caledonia can
feel safe that their water is not contaminated.
And if it is susceptible to contamination this
program will give us the facts and ability to
achieve -- possibly achieve grants and funding
in cleaning that, water if it is contaminated.
So, in other words, by having a complete
inventory of possible contamination sources
Caledonia can receive the help that it needs to
keep it's water safe and effective.
So I think that addresses some of the
questions people have and how that affects
Caledonia. The Department of Health is working
on this program. The program is called the
Source Water Assessment Program. Unfortunately,
there's so many towns the Department of Health
can only do a certain amount in each town and is
relying on limited databases. So what is needed
is the cooperation between the residents and the
Town Department of Health and all other
protection agencies to get a complete picture of
what the drinking water safety level is in
Caledonia and how to keep it clean, which has
been discussed quite a bit tonight and how it's
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going to be kept clean from contamination of
this eite.
I just want to briefly mention for the
benefit of everyone here, if you would like to
leave your name with me or phone number or
address 1 can send you more information about
this program and information about a fall
meeting we're going to have, an educational
meeting about exactly what we're going to be
doing with the Town of Caledonia.
MR, NAPIER: You should point out that
that program is for public water supplies. It
does not cover individual wells these are
talking about.
MR. NAPIER: it does not cover private
well; strictly public.
UNIDENTIFIED SPEAKER: They are meeting
with the well committee on Wednesday night of
this week to discuss this program with --
JANET HIHKEL: The fact that we are
talking about public water does not exclude
people with private wells from participating in
the program.
If you could address -- I know you
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mentioned earlier on the pumps, one of the
proposals was the pumps and if they stopped
working how that would contaminate the water
supply and how that's going to be prevented, and
also how far this plume has reached in this
period of flux of having cleaned the town wells
and before the new remediation goes in,
MR. SINGERMAM: Based on the property
data we have, the migration -- contamination of
groundwater has not migrated beyond the property
bounds of Jones Chemicals. As far as the
•scenario we mentioned that is Jones' wells
ceased operation, that that would present a
threat, one thing we would like to negotiate in
implementation of the remedy we selected, we
would likely include in the consent decree, a
legally binding document enforced by the court,
that Jones would have to continue operating the
wells if they go bankrupt or move or whatever.
They're going to have to at least commit to
continue to operate those wells as long as the
groundwater does not meet drinking water
standards.
JANET HIKKEL: I'm sorry, I must have
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misunderstood. I thought you said town wells
are contaminated.
MR. SIHGERMAtt: Village wells are
contaminated.
JANET HINKEL: I'm sorry, Village.
MR. SINGEftMAN: We don't know Jones is
the source. I think it was Tim that was
mentioning, he was saying based on the data from
the early '80s it does not appear -- they
haven't collected any data before that, but we
have no indication that Jones is the source of
that contamination, and there's no really way to
know because the production wells altered the
natural groundwater flow; and I believe the
Village had three wells and now it has two, and
there's no way to do that except for Jones to
turn off the production wells, and I don't think
they're in a position to do that because they
would have to shut down.
We ran that scenario because in the
process of doing a risk assessment we have to
evaluate present use and the future use
scenario, and one worse case Jones turns off the
wells for whatever reason and someone has a well
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beyond the property boundary, and we presume
that well becomes contaminated because of the
migration of the water, because the flow now as
a result of the production wells toward the
production wells hasn't allowed the
contamination to migrate. So that was the
future years hypothetical scenario, which is a
basis for our taking action. Basically a. risk
assessment is the basis for taking action.
So we demonstrated that is a potential
for the future risk in the hypothetical use of
groundwater if the wells should discontinue
operating,
Also, there is a threat to the animals
that may burrow into the contaminated soil.
We're not saying this is going to happen, but
for the risk assessment we undertake the worse
case scenario, and that's a risk we undertake.
There's no risk for someone putting a
well on the plant property beca.use they're not
public water and it is currently zoned
industrial and there's no expectation there's
going to be houses built in the future until the
zoning changes, but the risk assessment says it
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remains industrial,
MR. JACOB; To stress that point, that is
a worse case scenario. He assumed for the
future, if it happens, to protect the
environment and the public health. Since we
have evaluated that, we have made sure that we
have a mechanism to address that. Like Joel
said, what we do is in the consent decree, in a
legally binding document, we'll -- you know,
we'll address this issue and we'll make sure
that scenario will never happen, or if it
happens we have a way to address it. Okay?
JANET HINKEL: Thank you.
MR. SINGERMAN: If Jones no longer needs
cooling water they're going to have to keep
pumping that as the remedy indicates. In 10 or
15 years when the water meete the standards,
they can atop; but until we say okay they have
to keep pumping.
MARY REED: Is it the EPA who determined
that the contaminant is just in the groundwater.
MR. SINGERMAN: Yes. Well, it was Jones'
contractor under EPA oversight. Their
contractor went out a collected samples, and we
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had people going out and watching the sampling
and selecting that and observing that based upon
that data which goes through rigorous quality
assurance controls to make sure of the quality
of the data. Based upon the data we've -- you
know, we've concluded that the contamination
does not appear to have migrated past the
property boundary,
MR. MOLOUGHNEY: At present.
MR. SINGERMAN: Right.
MR, MOLOUGHNEY: I think we want to
clarify that's based on today, what we know
about the property today. Historically, we
don't have the data. The wells never existed or
we never monitored 20 years ago. We can't say
what used to happen, but today we can say it's
within the property line.
MARY REED: Because I believe it's a
major concern of the residents that we have
contamination perhaps from many different sites
that have been using TCEs in the past and
probably currently are and just how much
enforcement DEC or EPA has in enforcing them
because so much of them are used for printing,
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cleansing. TCE has been used --
MR. NAPIER: It's a very common solvent.
MARY REED: We're not trying to
personalize it with Jones Chemicals, but the
whole controls situation makes many of us
residents very concerned about our cancer
numbers and, you know, whether our water going
to be, as much as we can determine, safe for our
kids and grandchildren.
MR. MOLOUGHNEY: There are two questions
back here (indicating) ..
TIM ANDERSON; Tim Anderson, Clover
Street. And I guess we've had 15 spil tests
taken and Tim, you had the private contractor
take the samples, were they all on Jones' lands?
Did they extend past Jones' land, and possibly
you could put the map up and show some
locations.
TIM GAFFNEY: I was going to expand on
the gentleman's question about 19 samples.
There were 19 discrete soil samples taken in the
investigation, but there's approximately 40
groundwater monitoring wells all over the
property; on the property boundaries, on the
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corners, in the hot spots that you've been
hearing about. And before a monitoring well is
put in, there's a soil boring. what that means
is they drill down to the water table, and every
two feet that soil is sampled; and from that we
were able to select those other 19 samples. So
it wasn't just 19 samples that were taken.
There were a ton of groundwater samples, that
before they were a groundwater well, it was a
soil boring where samples had been taken. And
that was done -- I think the first well probably
went in 1964, 1983, something like that. So
when I first heard you say 19 samples, oh my
God, 19 samples, this is an eight-acre piece of
property, that's not enough. But those samples
were discretely selected in the areas of
concern.
And another thing I wanted to point out,
Mr. Reed, I think, asked the question about the
contaminants and the chemicals that may be on
the property. when we first started we sampled
the volatile organics, but since then we also do
the herbicides, pesticides, PCBs, metals; and
those were compared to the samples George and
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Joel was taking about. And in those it was just
the VQCs and specifically the two solvents that
we're talking about that were above the action
levels that we had to address. I think the
question came up, will this venting system or
vacuum gystem suck up other contaminant a. Any
other contaminants that are there are below the
action levels; so that is to say if the solvent
weren't there, would we be doing any work at
all? Probably not. But we did do sampling for
all kinds of chemicals, not just the two that
were put up on the board tonight.
MR. JACOB: I want to clarify something.
i think Mrs. Reed asked was it a Jones
contractor that did the sampling. Yes, it was a
Jones contractor who did the sampling, but they
go through a selection process and the
contractor is approved by EPA, and the samples
are witnessed by EPA and/or the State and even
there are taken split samplings. It's not we
don't trust them. They take half, the State
takes the other half to an independent lab and
we compare the results. So to clarify your
question, it's a Jones, contractor, an approved
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contractor, and we have witnessed or split -- or
have done split sampling with them.
UNIDENTIFIED SPEAKER: YOU said that the
samples that were taken show contamination not
beyond the property of Jones Chemicals; is that
true?
MR. MOLOUGHNEY: Excuse me?
UNIDENTIFIED SPEAKER: You said the
samples showed there was no contamination beyond
the property?
MR, MOLOUGHNEY: Right, the soil
contamination is all limited to the plant, in
term of the groundwater.
UNIDENTIFIED SPEAKER: Grqmndwater, yea.
MR. MOLOUGHNEY: Anything that we have
detected, again, above standards -- you know,
drinking water standards -- the boundary
appears -- it appears to be within the property.
That's not to say 10 feet on this side, if you
go 20 feet over you're not going to find a
similar response. But everything --
UNIDENTIFIED SPEAKER: Where I'm going
is you said that, and then the gentleman next to
you said that he took care of two houses for
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f iltration.
MR, MOLOUGHNEY: Right.
UNIDENTIFIED SPEAKER: That doesn't sound
like the product is just on there.
MR. MOLOUGHNEY: Right, I agree, it
doesn't. We've looked at these wells and we've
had a lot o£ discussion, Dave and myself and our
folks in Avon about that, and what is the source
of that, contamination in those two wells?
There's a possibility it's related to Jones.
There's also a possibility that there's -- and
this is my personal belief and, you know, other
people -- it's a hard -- it's a tough call for
all of us to take as professionals in tfiis. My
personal feeling is that there may be another
source nearby there that's contributing to that,
UNIDENTIFIED SPEAKER: I agree, I was
picking that direction to go in.
MR. MOLOUGHNEY; That's fairly
complicated. If we look at the numbers, the
types of compounds that are detected in the
Jones water versus th$ wells near there, they're
slightly different. There's different chemicals
in a couple of the wells. One of the wells
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higher actually than in the Jones plumes.
UNIDENTIFIED SPEAKER: How did you pick
those two houses?
MR. NAPIER: I did that, and that was
because those are the only wells I could find.
UNIDENTIFIED SPEAKER.- What about the
wells on Iroquois Road?
MR, NAPIER: I have done Iroquois Road
and haven't found any on Iroguois Road. I went
up Iroquois Road and left and right on Wheatland
Center Road.
UNIDENTIFIED SPEAKER: Barks Road?
MR. NAPIER: I'm trying to think of
Barks.
UNIDENTIFIED. SPEAKER: Off wheatland
Center.
MR. NAPIER: But going to the right, yes,
I've dciie some wells up there, too.
MR. SINGERMAH: Again, based upon our
samples we're saying at this time during the
time we've taken samples in the '90s we don't
see contamination migrating beyond the property
line. We don't know what happened before that
time.
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UNIDENTIFIED SPEAKER: I've had my well
tested a couple of times -- I think it's called
Detox 88 substances -- and it cost about $125
each time. So homeowners can do that, but you
pay for that.
MR. NAPIER: Yes, it's expensive, you're
right.
MR. SINGERMAN: Anymore questions?
MARY REED: The rural wells, there is
nothing mandatory for their testing, unless
perhaps --
MR. NAPIER: The only thing mandatory, if
you go to A bank for financing the banks make
you do a bacteriological testing.
MARY REED: And I think there's some
concern the contamination if it is in
groundwater has gone to the rural --
MR. NAPIER: You go to Leroy with the
geology out there, there's very little soil.
Whereas with the Jones land, the bedrock is 80,
90 feet --
TIM GAFFNEY: Not even.
MR. NAPIER: Right, BO it's 30 or 40 feet
of soil on the fractured rock that allows water
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co move very easily. So there could be someone
40 miles away, and if they've had a leaking gas
tank it could be in your water.
MR, SINGERMAN: Any other questions?
Again, if there are no more questions,
again, the comment period ends on the 19th. If
you think of something you can contact George
and, you know, try to get your comments in by
the end of the comment period. We'll stick.
around after the meeting if anyone has any
questions. Thank you for coming.
(TIME: B:50 P.M.)
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CERTIFICATION
STATE OF NEW YORK:
COUNTY OF WAYNE:
I, FRANCIS J. LEOGRANDE, being a
Shorthand Reporter and Notary Public in and for
Wayne County, New York, do hereby certify that I
reported in machine shorthand the proceedings in
the above-styled cause, and that the foregoing
pages were typed by computer-assisted
transcription under my personal supervision and
constitute a true record of this proceeding.
WITNESS my hand in the County of Wayne,
State of New york.
FRANCIS J/ L^QGRANDE
Notary Puki-lc in and
for Monroe County, New York
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