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.

                                 7

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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.

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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
                               15

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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


                                16

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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.

                                20

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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.
                                21

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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)

                               22

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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.


                                23

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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

                                24

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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

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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.
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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

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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,

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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.

                                35

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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

-------
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

                                37

-------
     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

-------
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

-------
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

-------
                            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

-------
                                   **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

-------
Figure 2
     Chemicals Site Map

-------

-------

-------
                                                                                      Monitoring W«b, Mov««lb4f 26,1B97
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                                                                                                                                     mtn MoriNctlngWvta
                                                                                                                                     . ISM. ma D^rnmbm 1,1097

-------
         MonNorlnfl Wtta, O*c*mt*r 1.1997
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-------
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                                                                   8
                                           11

-------
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-------
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
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                                            <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
-------
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                                                                                                                                                                  Table  3
                                                                                                                                                                  Page 3 of 3
-------
                                             SUMMARY Of RECEPTOR RISKS ANC HAZARDS t'OR COPCs

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                                                                                                                           Page 1 of 2
-------
SUMMARY u(: M CUMOH HISKS ANU IUVARLIS ten CDPCs
         J«:AVONAlHC MAXIMUM IXPOSUKt
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                                                                               Table 4
                                                                               Page 2 of 2
-------
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                                             SOURCE MANAGEMENT 2ONF, JONCS CHEMICALS, CALEDONIA, MY
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                                                                                                                                            Table 5
                                                                                                                                            Page 2 oi 3
-------
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                                                    SUMMARY UK Ni:ci;r>7on KIKKS AND HAIMRDS ron cnno?
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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
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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
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;'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
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Rd rtQ
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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;
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12
2190
15
                                                                6   TOTAL CANCER RI$K
MR CONC
 (MQMS)
                                                                               LX)SE
                                                                             (MG'KGJD)
                                                                                            2 isE-no4
                                                                                           ?:>;F«OD1
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CPF
           CANCER
            RISK
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HO
PCE
0033
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3 SO?
00012
0 5
0 5
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as
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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
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: 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
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 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
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     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
-------
     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
-------
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
-------
         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 .
-------
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
-------
                   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
-------
               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
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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
-------
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
                                              Page?
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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
-------
 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
                                             Page 9
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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
-------
 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
-------
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
-------
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
-------
       Appendix V-b
July 20, 2000 Public Notice
-------
                       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
                  V-xii
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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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               ALLIANCE SHORTHAND REPORTERS, INC.
       1<716)546-4920                     1(800)724-0836
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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
               ALLIANCE SHORTHAND REPORTERS, INC.
       1 C716] 546-4920                     1(BOO)724-0836
-------