United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R02-88/063
September 1988
3EPA
Superfund
Record of Decision
Love Canal/93 rd Street, NY
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30?7?-1Q1 ____^_^^_^_
REPORT DOCUMENTATION *• REPORT NO-
PAGE
EPA/ROD/RO2-88/063
3. Recipient* t Acetssion No.
SUP!
-jJ^OVi
^BKU.
[7. Autt
4. Titla and Subtltla
SUPERFUND RECORD OF DECISION
5. Rtport Oat*
09/26/88
: =Schoo 1 , NY
ird Remedial Action
7. Authors)
1
8. Performing Organization Rtpt. No.
9. Performing Organization Nam* and AddrMa
10. Preject/Tastc/Worli Unit No.
11. Contract(C) or Grant(G) No.
(C)
(G)
12. Sponsoring Organization Nam* and Address
U.S. Environmental Protection Agency
401 M Street, s.w.
Washington, D.C. 20460
13. Type of Report & Period Covered
800/000
14.
15. Supplementary Note*
16. Abatract (Umlt: 200 word*)
The Love Canal/93rd Street School site consists of approximately 19 acres and
includes a school and an adjacent vacant lot. The site is located in Niagara Falls, New
York, less than one mile northwest of Love Canal and is within the Love Canal Emergency
Declaration Area. It is bordered by Bergholtz Creek to the north and residential
properties to the east, west and south. A small area east of the school and adjacent to
ergholtz Creek is within a 100-year flood plain. Hooker Chemicals and Plastics
rporation disposed of over 21,000 tons of various chemicals at the Love Canal site
rom 1942 to 1953, when the site was deeded over to the City of Niagara Falls Board of
Education. Sampling has revealed that approximately 6,000 yd3 of soil are
contaminated. During the 1950s, home construction accelerated in the area.
Specifically, in 1950, the 93rd Street School was built, and in 1954, the 99th Street
School was built adjacent to the middle portion of the Canal. Prior to construction of
tne 93rd Street School, a drainage swale crossed the site. Between 1938 and 1951, the
swale was partially filled with soil and rock debris, followed by sand and fly ash
materials. In 1954, the site was graded to its present contours with approximately
3,000 yd3 of fill material, including fill from the 99th Street School. The fill
material is reported to contain fly ash and BHC (pesticide) waste. In 1980, the 93rd
(See Attached Sheet)
17. Document Analytic a. Descriptor!
Record of Decision
Love Canal/93rd Street School, NY
Third Remedial Action
Contaminated Media: soil
i lead), organics (dioxin, PAHs, pesticides), VOCs
(toluene, xylenes)
c. COSATl Field/Group
Availability Statement
19. Security Class (This Rtport)
None
20. Security Class (This Pag*)
None
21. No. of Pages
170
22. Prlc*
(See ANSUZ39.18)
See Instructions on Reverse
OPTIONAL FORM 272 (4-77)
(Formerly NTIS-3S)
Department of Commerce
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EPA/ROD/R02-88/063
Love Canal/93rd -.Street-School.,-. N,i
Third Remedial Action
16. ABSTRACT (continued)
Street school was closed due to public health concerns related to the potentially
contaminated fill material. The primary contaminants of concern affecting soil are
VOCs, including toluene and xylenes, other organics including dioxins, PAHs and
pesticides, and metals including arsenic and lead.
The selected remedial action for this site includes: ' excavation and
solidification/stabilization of 7,500 yd^ of soil; placement of solidified soil back
in excavated location; installation of a RCRA cap; ground water monitoring; and
implementation of treatability studies for solidification process. The estimated
capital cost for this remedial action is $2,295,000 to $3,675,000 with estimated annual
O&M of $121,000.
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DECLARATION FOR THE RECORD OP DECISION
SITE NAME AND LOCATION
Love Canal - 93rd Street School site, City of Niagara Palls,
Niagara County, Nev.* York
STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected remedial action for
the Love Canal - 93rd Street School site, developed in accordance
with the Comprehensive Environmental Response, Compensation, and
Liability Act of 1980 (CERCLA), 42 U.S.C. § 9601, et. seq., as
amended by the Superfund Amendments and Reauthorization Act of
1986, and to the extent practicable, the National Oil and Hazardous
Substances Pollution Contingency Plan, (NCP) 40 C.F.R. Part 300
(November 20, 1985).
This decision is based upon the Administrative Record for the Love
Canal - 93rd Street School site. The attached index identifies
the items which comprise the Administrative Record upon which the
selection of the remedial action is based.
The State of New York concurs with the selected remedy (see
attached).
DESCRIPTION OF THE REMEDY
This remedy addresses the source of contamination by remediation
of the on-site contaminated soil. The remedy addresses the prin-
cipal threats at the site by permanently immobilizing the con-
taminated soil at the Love Canal - 93rd Street School site,
thereby preventing any potential groundwater contamination and
reducing the risks associated with exposure to the contaminated
soil.
The major components of the selected source control remedy include:
• Excavation of approximately 7,500 cubic yards of contaminated
soil followed by on-site solidification/stabilization of this ma-
terial;
* Placement of the solidified soil on-site within the same unit of
contamination from which it originated, with a low permeability
cover (consistent with the Resource, Conservation and Recovery
Act (RCRA) 40 CFR § 264.310 landfill closure requirements) in-
stalled over these areas and extended to other areas which
exhibit lower levels of contaminated soil at the site;
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* Additional sampling and analysis (with the lowest achievable
levels of detection) of the groundwater to determine whether
applicable or relevant and appropriate federal and state
requirements (ARARs) and other criteria to be considered for
groundwater are being met. This sampling was conducted in
May 1988 and the analytical results are anticipated to be
available in the fall of 1988;
* Monitoring of the groundwater in accordance with RCRA regula-
tions, 40 CFR Part 264 Subpart F; and
* Treatability studies during the remedial design to determine
the effectiveness of the solidification process for the partic-
ular soil and its ability to meet specified treatment levels.
Should the treatability studies determine that solidification
would not provide the desired degree of treatment (e.g., Land
Disposal Restriction treatment standards), then treatability
studies would be performed to determine the effectiveness
of other treatment techniques (including thermal treatment)
for the on-site soil.
DECLARATION
The selected remedy is protective of human health and the environ-
ment because all threats associated with soils ingest ion, inhala-
tion and dermal contact would be eliminated. The remedy will
attain federal and state requirements that are applicable or
relevant and appropriate to the remedial action (e.g., by treating
the soils to a level which satisfies the requirements for land
disposal and complying with Subtitle C landfill closure require-
ments), and is cost-effective. This remedy will satisfy the
statutory preference for remedies that employ treatment that
reduces toxicity, mobility or volume as a principal element by
selecting solidification which is expected to permanently
immobilize the contaminated soil and eliminate any potential
for leaching of both organic and inorganic contaminants. The
remedy will utilize permanent solutions and alternative
treatment technologies to the maximum extent practicable.
Because this remedy will result in hazardous substances remaining
on-site, a review will be conducted within five years after com-
mencement of the remedial action and at least every five years,
thereafter, to ensure that the remedy continues to provide
adequate protection of human health and the environment.
'.A6.W
.
J
Date ' Williain/. 'Mvisz^terki, P.E.
Acting Regional Administrator
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ROD DECISION SUMMARY
LOVE CANAL - 93rd STREET SCHOOL SITE
Niagara Falls, New York
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Region II
New Yorlc
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TABLE OF CONTENTS
Page
Site Location and Description 1
Site History. 2
Enforcement Activities. . ^. . , 3
Community Relations History 4
Scope of Response Action. .. ....... 5
Site Characteristics 5
Summary of Site Risks ..... 8
Documentation of Significant Changes 11
Description of Alternatives ..... 11
Summary of the Comparative Analysis of Alternatives . . 18
Selected Remedy 27
Statutory Determinations 29
ATTACHMENTS
A - Administrative Record Index
B - NYSDEC Letter of Concurrence
C - Responsiveness Summary
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FIGURES-
Figure page
1 - Site Location Map .... ....... , .....
2 - 1947 Topography Map ...... . ......... IB
3 - Extent of Hot-Spot Soils .......... . . . . 6A
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TABLES
Table Page
1- Inorganic Soil Compounds and Respective
Guidance/Criteria Considered 5A
2- Organic Soil Compounds and Respective
Guidance/Criteria Considered SB
3- Groundwater Monitoring Well Compounds and Respective
ARARs and/or Other Criteria/Guidance ......... 7A
4- Surface Water Compounds and Respective ARARs
and/or other Criteria/Guidance 7B
5- Compounds for Which CRDLs Exceed
ARARs and/or Other Criteria/Guidance ........ 7C
6- Remedial Alternatives Summary 11A
7- Solidification/Stabilization Alternative
Cost Estimate 28A
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ROD DECISION SUMMARY
Love Canal - 93rd Street School Site
Niagara Falls, New York
SITE LOCATION AND DESCRIPTION
The Love Canal - 93rd Street School site is situated in Niagara
Falls, New York, less than one mile northwest of Love Canal,
and is located in the Love Canal Emergency Declaration Area
(EDA) (see Figure 1). It is bounded by Bergholtz Creek to
the north, 93rd Street to the west, residential properties and
96th Street to the east, and Niagara Falls Housing Authority
property and Colvin Boulevard the south. The total site area
covers approximately 19 acres and includes both the 93rd
Street School and the adjacent vacant land owned by the
Housing Authority.
Although the site is relatively flat, it does slope gently
from the east and west to the drainage swale located in the
central portion of the site (see Figure 2). This swale slopes
from the southeast to the northwest and discharges into a
small gully, which in turn discharges to Bergholtz Creek and
then to the Cayuga Creek, which is a tributary of the Little
Niagara River. A small area east of the school adjacent to
Bergholtz Creek is within the 100 year floodplain.
Overburden overlying bedrock at the site varies in thickness
from 25 to 27 feet, and consists of glacial till covered by
layers of clay, silt and fine sand. In the immediate vicinity
of the school, layers of fill (up to 7.5 feet in thickness)
and a thin layer of topsoil (typically less than 1 foot thick)
have been deposited on top of the native overburden.
Groundwater flow at the site has a very low velocity. Groundwater
contours for the site indicate the presence of a groundwater
mound across the middle of the site in an east-west direction.
The direction of groundwater flow out of this mound appears
to be south-southwest from the southern end of the property
and to the north-northeast from the northern end of the property.
Runoff and evaporation of precipitation far exceed percolation
at the site due to the relatively low permeability of site
soils. As a result, any potential transport of contaminants
from the organic fill material to off-site areas would occur
almost exclusively through erosion caused by surficial runoff
rather than through percolation and movement with the groundwater.
In addition, there are no known drinking water wells in the
vicinity of the site and area residents receive their water
from public water supplies.
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LOVE CANAL EME
DECLARATION AR
FORMER 99th ST. SCHOO
LOVE CANAL AREA
fIGURE 1
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/vxx>^r~"!zs
tiX^x _ "'
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~SITE HISTORY
The Love Canal hazardous waste site is located in the southeast
-corner of the City of Niagara Falls, and is approximately one-
quarter mile north of the Niagara River. Hooker Chemicals &
Plastics Corporation (now Occidental Chemical Corporation)
disposed of over 21,000 tons of various chemicals (including
dioxin-tainted trichlorophenols) at the Love Canal site
between 1942 and 1953.
The Love Canal property was deeded by Hooker in April 1953 to
the City of Niagara Falls Board of Education. During the
1950s, home construction accelerated in the area, and in
1950 the 93rd Street School was built less than one mile
northwest of Love Canal, and in 1954 the 99th Street School was
built adjacent to the middle portion of the Canal. Over the
course of the next two decades, contaminated leachate migrated
to the surface of the Canal and to nearby residential basements.
The homes have since been demolished. Contaminants also migrated
through area sewers to nearby Black and Bergholtz Creeks.
The 93rd Street School is an elementary school that was designed
in 1947 and was constructed in 1950. Prior to the construction
of the school, a drainage swale crossed the site from the south-
east to northwest. This swale intersected 93rd Street and
east-lying properties and discharged into Bergholtz Creek.
Figure 2 depicts preconstruction contours (i.e., elevations
of the land (in feet) above mean sea level) based on the 1947
site development drawing. Between 1938 and 1951, the swale
was partially filled with soil and rock debris followed by
sand and silt-sized carbon waste (fly ash) materials.
The site was graded in 1954 to its existing contours with
approximately 3,000 cubic yards of fill material, among other
fill, from the 99th Street School, which was located in the
EDA on the Love Canal. Low areas east of the 93rd Street
School including the playground (which had previously been
filled with carbon waste) and the swale just south of the
playground were filled with 99th Street School fill material
and then covered with approximately one to three feet of topsoil.
The fill material at the 93rd Street School is reported to
contain fly ash and BHC (pesticide) cake. The horizontal
extent of the fill materials and the thickness and depths of
respective layers at the 93rd Street School site were not
accurately recorded during filling operations. In 1980, the
93rd Street School was closed due to public health concerns
regarding the presence of the potentially contaminated fill
materials.
A number of sampling investigations have been performed by
both the New York State Department of Environmental Conservation
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(NYSDEC) and the~TJTST~ Environmental Protection Agency (USEPA)
since 1979 because of the concern associated with the fill
materials brought from Love Canal. These studies have shown
that there are contaminants present on-site which include volatile
and base/neutral/acid extractable organics, lindane, metals and
dioxin. Two of these investigations indicated the presence of
dioxin in two locations at the site above the Centers for Disease
Control's level of concern of greater than 1 part per billion (ppb)
for dioxin in residential soils (1.2 ppb - USEPA Field Investi-
gation Team (NUS Corporation) - 9/85 and 2.3. ppb - RECRA Research
Ph.ase II investigaton - 8/84 *).
Through a Cooperative Agreement with the USEPA, the NYSDEC
completed a remedial investigation/feasibility study (RI/FS),
dated March 1988, for the 93rd Street School site through its
contractor, Lcureiro Engineering Associates (LEA).
ENFORCEMENT ACTIVITIES
This Record of Decision (ROD) addresses the remediation of the
93rd Street School site. The 93rd Street School is located
within the northwest portion of the EDA of the Love Canal National
Priority List site. A brief chronology of the Love Canal enforce-
ment activities is presented below.
On December 20, 1979, the U.S. Department of Justice, on behalf
of EPA, filed a federal law suit against Hooker Chemicals & Plastics
Corporation (now Occidental Chemical Corporation) pursuant to
numerous environmental statutes, alleging an imminent and
substantial endangerment to human health and the environment.
New York State filed a lawsuit in state court in April 1980,
against Occidental for damages sustained at Love Canal. This
action was stayed on August 8, 1980. On June 8, 1980, New
York State was joined as a defendant in the federal action.
On September 11, 1980, New York State was realigned as a
plaintiff in the federal case, and on September 8, 1980, the
State filed its claims in federal court.
On April 16, 1982, EPA sent Occidental a CERCLA notice letter.
On July 26, 1982, EPA and the State met with Occidental to explain
the remediation activities which would be taken under Superfund.
Occidental at that time refused to assume responsibility for
remedial action at Love Canal. On December 9, 1983, the United
States filed its second amended complaint against Occidental
to include claims under Sections 106 and 107 of the Comprehensive
Environmental Response, Compensation and Liability Act (CERCLA).
Occidental has filed counterclaims against the United States
and the State and cross-claims against the City of Niagara Falls,
the Niagara Falls Board of Education, and Niagara County.
Research,Inc. completed the Phase II Investigation under
contract with the State of New York. The study was intended to
finalize a Hazardous Ranking Score for the site.
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On February 237 1988, the U.S. District Court ruled on the.
governments' summary judgement motion holding that Occidental
is liable under CERCLA for releases of hazardous substances from
the Love Canal site. However, the extent of Occidental's
liability under CERCLA is still subject to litigation.
On March 3, 1988, officials from Occidental formally presented
to USEPA an alternative plan to remediate the sewers and creeks
at Love Canal. USEPA and the NYSDEC rejected Occidental's alter-
native because of the lateness of the submission and the potential
delay to the selected remedy. However, the governments also
responded that they may at a later date reconsider the alternative
if sufficient progress on implementation has been made.
In April 1988, the USEPA provided Occidental with the draft RI/FS
for the 93rd Street School site, and notified Occidental of the
proposed remedial action for the site as well as the close of
the public comment period. The USEPA intends to send notice
letters to the Potentially Responsible Parties (PRPs) upon
approval of the ROD.
COMMUNITY RELATIONS HISTORY
The governmental effort to ensure significant community
involvement at Love Canal has been extensive. A comprehensive
community involvement strategy has been developed by NYSDEC to
keep concerned parties cognizant of CERCLA activities at the
site. NYSDEC maintains a Love Canal public information office
at which Love Canal documents are made avialable for public
review as they are produced. The office is located in the
EDA at 9820 Colvin Boulevard. In addition to this office, the
USEPA has a public information office in the City of Niagara
Falls. The public is also kept informed through frequent
public meetings.
The draft RI/FS identifying six remedial options, and the
proposed remedial action plan (PRAP) was released for public
comment on April 5, 1988. On the same date, USEPA and NYSDEC
published a public notice which appeared in the Niagara Gazette,
the Buffalo Sunrise and the Buffalo Evening News, announcing
the availability of the RI/FS and the PRAP and that a public
meeting would be held in Niagara Falls on April 13, 1988. In
addition, an article announcing the April 13, 1988 public meeting
and an availability session was published by the Niagara Gazette.
NYSDEC also announced the availability of the RI/FS and the PRAP
through a special addition of the Love Canal Landfill Update
which is available at the NYSDEC Love Canal Public Information
Office. The public repositories for the Administrative Record,
which includes the RI/FS, are the NYSDEC Public Information
Office in Niagara Falls and the USEPA Region II Office in New
York City.
USEPA and NYSDEC held a public meeting and an availability
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-5-
liession on April 13, 1988 and April_JL4^ 1988, respectively
RI/FS and the PRAP. The
attached July 1988 Responsiveness Summary adresses questions
and concerns raised by the public during the public comment
period, which closed May 25, 1988. A transcript of the public
meeting was prepared in accordance with Section 117(a)(2) of
CERCLA, and is available to the public at the above-mentioned
Administrative Record repositories.
SCOPE OF RESPONSE ACTION
This response action addresses the principal threat at the Love
Canal - 93rd Street School site which involves eliminating
the potential for direct contact with site wastes; eliminating
the potential for the transport of contaminated volatiles and
fugitive particles into the air; and eliminating the transport
of contaminated particles in surface water runoff.
Additional sampling of the groundwater at the 93rd Street School
site was conducted in May 1988 with the results expected to be avail-
able in the fall of 1988. The additional sampling was performed
to ensure that the groundwater is not being impacted. Should
the additional sampling results indicate that groundwater standards
and other criteria to be considered are exceeded, then an evaluation
of the necessity for remediation of the groundwater would be con-
ducted. Remediation of the groundwater, if warranted, would be
addressed in a subsequent ROD. A further discussion of the necessity
T the additional sampling is presented in the next section.
This response action focuses solely on the remediation of the 93rd
Street School site. A number of other projects related to the
remediation of the Love Canal site are underway. These projects
include Black and Bergholtz Creek remediation (this includes the
development of design documents for the procurement of a thermal
destruction unit to destroy sediments from Black and Bergholtz Creek
remediation and other materials stored on-site), operation of the
Love Canal Treatment Plant, 102nd Street Outfall Delta Area, and EDA
home maintenance and buyout.
SITE CHARACTERISTICS
The RI/FS, prepared by NYSDEC's contractor, LEA (March 1988), con-
cluded that soils at the site are contaminated with inorganics,
volatile organics, base/neutral/acid extractable organics and alpha
and beta BHC which exceed health and environmentally-based values.
Tables 1 and 2 list all inorganic and organic compounds, respec-
tively, detected in soils during the RI, along with the concentra-
tion and station where the highest level was detected, and back-
ground concentrations in soils from around New York State.
Criteria (e.g., cleanup levels for dioxin and background levels
ttpr other compounds) are considered in evaluating the extent
P£ contamination at this site. All compounds that were found
to exceed background are noted on Tables 1 and 2. For example,
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Table 1
INORGANIC SOIL COMPOUNDS AND RESPECTIVE BACKGROUND
CONCENTRATIONS CONSIDERED ~~
Parameter
Aluminum
• Antimony
• Arsenic
Bar 1 on
Beryllium
•Cadmium
Calcium
Chromium
•Cobalt
Cooper
Iron
'lead
'Magnesium
Manqanese
•Mercury
Nickel
Potassium
Selenium
Silver
Thallium
Van ad 1m
Z1nc
Molybdenum
TUmlum
Highest Cone
mg/kgt
(ppm) Sta
10700 1P13A
209n 1P4B
350 1P40
565n 1P4C
3.4n 1P4A
133n 1P4B
202000 1P4A
516 1P1B
52 1P3E
44 1P11E
86600 1P150
843 2P1UA
42000* 1P138
3000n* 1P3E
23 1P1B
47
3550*
4.1s
3.2
1.2
1P8F
1PSB
1P1C
1P9D
1P8F
59 1P15C
18200* 1P4B
229 1P4A
825 1P3C
NY SOIL BKGRNDtttt
Mean No.Samples
mg/kg Exceeding
(ppm) Background
48,000 0
0.75(<9) 59(59)
7.0(10.6) 21(15)
300 4 .
0.6 20
0.4tn(4) 68(27)
5,200 42
34 15
8 a
22 28
28.000 17
21(114) 42(5)
5,000 28
1.100 5
0.15( 0.15)26(26)
14
15,500
0.3
No data
9.08
60
64
No data
to data
66
0
3
0
54
t Subscript definitions for this column are as follows:
n • Indicates spike sample recovery 1s not within control Holts
* • Indicates duplicate analysis 1s not within control limits
s • Indicates value determine* by Method of Standard Addition
ttt Average from Cadmium 1n the Environment. J. 0. NMagu, ed, pg. s
ttttFrom 'Summary of Inorganic Constituent Concentrations In Soil Samples from
Around the State of New York (Boerngen and Shacklettt, 1981) with the
exception of values 1n parentheses which are from Michael E. Hboklm of
Niagara County Health Oept., and were believed to be average background
concentrations for soils 1n the Niagara Falls area.
These parameters exceed guidance/criteria considered.
(See Site Characteristics Section in Text)
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Table 2
ORGANIC SOIL COMPOUNDS
Highest
¥i/*f*
•1.1 Olefeleroetli
Cone
Sta
7700 1P9T
4500 IPS8
1500 2PI3S
S300
2400 2P135
13000* IP10C
1600 1M€
2000 IP10C
I/*/*
1,4-Olchlorofcenzene
PUphtJulcnt
2-ftttftyliiaptithalti*
830 1P4F
15000 1P4C
9100 1P4C
IMI^^ U000° IMC
W&tnwftran 62000 IP4I
POLYNUCLEAR AROMATIC HYDROCARBONS (PAHs)
140000 1P4C
820000 1P4C
220000 1P4C
450000 1P4C
560000 1P4C
260000 1P4C
240000 IMC
floor antfiene 310000 If4C
luoranthgne 49000 1P4C
• Bemo (a
*
190000 1P4C
8m»
Aloha iHC
82000 1P4C
oerylene 2100 1P98
13 1P8C
137 1P4C
Th«»« p«rcMt«r« exceed tuidance /r-' -•
* Subscript definitions for
this colurn art as
follows:
8 * Indicates analyte vas
found In blank as -ell
* »*»ple.
0 * Indicates sample
extract was diluted due
to sMple matrix and/or
eoncenf****** * • ' •
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arsenic was detected in both the surface and subsurface soils
up to 350 ppm, while the average background concentration for
arsenic in soils around New York State is 7 ppm. In addition,
background levels from the Niagara Falls Control Areas in the
EPA study, "Environmental Monitoring at Love Canal" showed no
detectable concentrations of those PAHs which were detected
at the 93rd Street School site.
Dioxin contamination was not detected in any of the 29 composite
soil samples collected and analyzed during the RI. However, as
described previously, NUS Corporation detected dioxin in three
surface soil samples at concentrations of 1.2 ppb, 0.11 ppb and
0.19 ppb (September 1985). In addition to the NUS Corporation
findings, RECRA Research, Inc. also detected dioxin on-site
during the Phase II Investigation (August 1984) at a concentration
of 2.3 ppb at a depth of 4 to 6 feet below the surface.
Based upon a level-of-concern for dioxin for this site of greater
than 1 ppb *, the total volume of dioxin-contaminated soil at the
site exceeding this 1 ppb level is estimated to be 550 cubic yards.
The extent of soil contamination which could impose a significant
risk to nearby populations was determined during the RI. While
contamination was typically greatest in the thickest fill layers
located in the deepest portions of the historic swale, there
was some contamination present in the thinner fill layers also.
Therefore, a preliminary estimate of the volume of soil/fill
potentially requiring remediation was developed based on the
determination that the entire volume of fill should be addressed.
Additional study during the preparation of the risk assessment,
however, indicated that in a hot-spot area directly to the
east of the school, the levels of carcinogenic contaminants of
concern (i.e., ars-enic, dioxin and PAHs) were significantly
greater than for the rest of the site. Figure 3 on the follow-
ing page shows the extent of these hot-spot soils.
The total volume of hot-spot soils was computed by the
average end area method by comparing present day surficial
contours with depths at least 1 foot below depths at which
contaminants posing an unacceptable risk were indentified in
the risk assessment. The final volume of soil obtained by
this method was approximately 6,000 cubic yards (including
dioxin hot-spots). It should be noted that if this volume of
* The Centers for Disease Control has recommended greater than
1 ppb as the level of concern for dioxin in soils in residential
areas for the Times Beach, Missouri site. Since the 93rd street
School is located in a residential area, the level of concern
for dioxin greater than 1 ppb is also recommended for this site.
------- An error occurred while trying to OCR this image.
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soil were td~be excavated, an additional 25 percent-of-material
might be removed using conventional construction equipment during
excavation. Therefore, fcr all excavation alternatives evaluated
in this summary, a volume of 7,500 cubic yards will be considered.
Although the area is served by a municipal water supply and the
groundwater at the site is not currently used, nor is it planned
to be used as a drinking water source, samples were taken and
analyzed. Those analyses indicate that a non-health-based New
York State secondary groundwater standard for aesthetics (taste
and odor) for iron was exceeded at the site, and that the ground-
water and surface water at the site are not otherwise contaminated
at levels exceeding the Contract Required Detection Limits (CRDLs).
Those analyses also indicate that, for certain compounds, the
groundwater and surface water did not exceed promulgated health-
based applicable or relevant and appropriate federal and state
requirements (ARARs). For other compounds, however, the CRDLs used
during the RI exceeded both New York State and USEPA drinking water
standards. In addition, some compounds detected exceeded guidance
values and criteria considered. Consequently, additional sampling
of the groundwater was conducted in May 1988. The analysis of
these samples (with the lowest achievable levels of detection) will
determine whether groundwater ARARs and other criteria to be.
considered are being exceeded. The results are anticipated to
be available in the fall of 1988.
Tables 3 and 4 list all compounds detected at or above CRDLs
in groundwater monitoring wells and surface water, respectively,
along with the concentration and station where the highest
level was detected, and the respective ARARs and/or other
criteria/guidance to be considered. As indicated in Table 3,
antimony, magnesium, manganese, nickel and sodium are present
in groundwater at the site exceeding criteria considered. However,
these criteria are either based on aesthetics or advisories.
Since the groundwater is not being used as a drinking water source,
nor is it planned to be, it has been determined that these criteria
are not considered appropriate for this site. The compounds for
which CRDLs exceeded their ARARs and other criteria considered
for groundwater are listed in Table 5.
As discussed previously, ponding of the groundwater is
evident at the site. This is due to the low permeability of the
clay layer underlying the fill material and the relatively
impermeable clay barrier present at the western (dowr.gradient)
end of the former drainage swale. Therefore, off-site contaminant
transport from the fill area would probably occur due to erosion
caused by surficial runoff of precipitation, rather than by
percolation and movement in the groundwater.
A review of air quality data collected during the RI to ensure
worker health and safety indicates that no significant levels
of volatile contaminants above background were dectected in
the breathing zone of the workers throughout drilling and well
-------
Table 3
t TT*R T MG WFM. rnm*nnNn3 AND RESPECTIVE ARARS
AND/OR OTHER
Parameter
INORGANICS
Alunlmn
Antlaony
Ca
— — - • •
;
+ + • secondary maximum contaminant level(Aesthetic guideline)
( ) « proposed maximum contaminant level
H - lifetime health advisory
R - the concentration in drinking water at which ingestion will be
incompatible with a sodium restricted diet
-------
Table 4
SURFACE WATER COMPOUNDS AND RESPECTIVE ARARS
AND/OR OTHER CRITERIA/GUIDANCE TO BE
(all values in
Hlahest Cone
Parameter ug/jt
INORGANICS
Alunlnun 259
Ant loony 90
Calcium 52300
Chronium 4fi
Iron 378E
lead 12
Magnesium 25200
Manganese 209E
Nickel . 55
Silver 44N
Sodium 7400
Zinc 72
VOLATILE OR6ANICS
None
B/N/A
. 04-N-Qctyl 21
phthalate
PESTICIOES/PCSs/DIOXIN
None
tSubscrlpt definitions
Sta
SU1
SW2
SW2
SU1
SW1
SU1
SW2
SW2
5W1
SW1
SU2
SU1
SMI
uq/l » ppb
NYSOEC
CONSIDERED
)
WO REGS
A A
Std Guidance
None
None
None
SO
300
SO
35000
300
None
SO
None
300
None
for this col»*m art
None
3
None
HA
HA
HA
HA
HA
None
HA
None
HA
NYSDOH
Source
Std
•
None
None
None
50
None
50
None
None
None
50
20,000
300
50 None
as follows:
gE-a mf a ^ if m Jt
* 4m*m*fm*m»t>
E "
6 * inOiCa&CS • w»iue csfc i»«»%cw «*WB »w »«i«. §»*•*»«•««• «»• •••*«• > »• —
N * Indicates spike sanple recovery is not within control 11»1tt
-------
Table 5
COMPOUNDS FOR WHICH CRDLS(l) EXCEED ARARS
AND OTHER GUIDANCE/CRITERIA CONSIDERED FOR- GROUNDWATER
Parameter CRDL(ppb)
Vinyl chloride 10
1,1,2,2-Tetrachloroethane 5
Benzene 5
1,2-Dichloroethane 5
1,1-Dichloroethene 5
Tetrachloroethene 5
Phenols, Total 10
Aniline 10
Bis(2-Chloroethyl)Ether 10
Dichlorobenzenes (3) 10
2,4-Dichlorophenol 10
Hexachlorobutadiene 10
Hexachloropentadiene 10
2,6-Dinitrotoluene 10
Hexachlorobenzene 10
Pentachlorophenol 50
Benzidine 80
Benzo(a)Anthracene 10
Chrysene 10
Benzo(b)Fluoranthene ' 10
Benzo(k)Fluoranthene 10
Benzo(a)Pyrene 10
lndeno(l,2,3-cd)Pyrene 10
Chlordane 0.5
ARAR(2)
2 (Federal MCL)
0.2 (State Guidance)
ND(4.4)
,0.8
0.07 (State Guidance)
0.7 "
1,
1,
0
0
(State Guidance)
1.0
4.7
0.3
0.5
1.0
0.07 (State Guidance)
0.35
21.
0.02 (State Guidance)
0.002 " "
0.002 " "
0.002 " •
0.002 " "
ND
0.002 (State Guidance)'
0.1
(1) Contract required detection limits
(2) ARARs are New York State-groundwater standards except where noted.
(3) Applies to the sum of para (1,4-) and ortho (1,2-) isomers only.
-------
-8-
development operations. In addition, directly above the
borings and monitoring wells, readings did not typically
exceed background levels by more than 2 parts per million
(ppm). In a few cases, however, when borings were first
drilled and when well caps were first removed, readings as
high as 10 ppm above background levels were detected. These
relatively high readings were found directly above the borings
and wells, and they dropped rapidly (i.e., within one to two
minutes) as vapors dissipated.
SUMMARY OF SITE RISKS
The methodology used in the following evaluation is consistent
with that' outlined in the USEPA Superfund Public Health
Evaluation Manual, (October 1986).
The full list of detected chemical parameters were narrowed
down to include those parameters listed in Tables 1 and 2. Some
of the compounds from these tables were eliminated based on
low concentrations present in soil, limited toxicity data
available for the baseline risk assesssment, or low potential for
exposure. The remaining ten indicator chemicals for soil
which are subjected to the baseline risk assessment are antimony,
arsenic, lead, mercury, benzo(a) anthracene*, benzo(b) fluoran-
thene*, benzo(a) pyrene*, chrysene*, indeno (1,2,3-cd) pyrene*
and dioxin.
Based on site conditions, it was determined that plausible routes
of exposure for potential receptors for the 93rd Street School
site would be inhalation of contaminated soils if they were
entrained as a dust and inadvertent ingestion of contaminated
soil (e.g., children playing on the site). Exposure via use of
groundwater as a drinking water was not evaluated because the
site is served with a public water supply, and the probability
of drilling for a potable water supply in this area is extremely
low.
In order to quantitatively estimate human exposure and potential
health risk, two hypothetical scenarios were considered for the
unremediated site: potential exposures at the undisturbed site;
and potential exposure if soils were disturbed by persons unaware
or unconcerned that the site contained potentially hazardous
materials.
* For this site, these high molecular weight PAHs are treated
as a class of carcinogenic PAHs with carcinogenic potency
equivalent to benzo(a) pyrene.
-------
-9-
* Toxicological Information
The main route of exposure for toxic metals is primarily by
ingestion of metal-contaminated food, water, and soil and by
inhalation of metal-contaminated dusts or fumes. Dermal absorp-
tion is generally inefficient unless very high concentrations
of a soluble salt are liberally applied. As a result, dermal
absorption was not considered as a potential route of exposure
in this assessment.
PAHs are formed as a result of combustion or natural petroleum
synthetic mechanisms. PAHs are not generally intentionally
synthesized, but are obtained by refining natural material for
use as fuels, lubricants, preservatives, and starting materials
for petrochemical manufacture. Only a subset of the general
chemical category of PAHs have the potential to cause cancer.
Five PAH compounds, which were mentioned previously, found at
the site have EPA ratings of probable to possible human carcin-
ogens. Of these compounds, only benzo{a) pyrene has experimental
data sufficient for quantatively estimating carcinogenic potency.
Therefore, in doing this risk assessment, it was conservatively
assumed that other PAHs with probable or possible carcinogenic
effects had a carcinogenic potency equal to that of benzo-a-pyrene.
Chlorinated dibenzo-p-dioxins are not intentionally synthesized.
They exist as trace contaminants of synthetic chlorinated aromatic
compounds such as pentachlorophenol and 2,4,5- trichlorophenox-
yacetic acid or, as a combustion product of chlorinated compounds.
Limited data is available on human exposure to dioxin. It
has been documented that exposure to dioxin in the workplace
will produce chloracne. This appears to be the effect seen in
humans that is most clearly correlated with dioxin exposure.
Dioxin has also been shown to be extremely toxic to certain
laboratory animals. It has been demonstrated that 2,3,7,8-
tetrachlorodibenzo-p-dioxin causes tumors in rats and this finding
has been used for dose-response assessment.
* Risk Assessment Results
The baseline risk assessment for this site (See RI Section 6) con-
cludes that under the no-action alternative, a theoretical cumula-
tive cancer risk of 2.4 x 1Q~4 may exist for the undisturbed site
scenario. If the site were disturbed without careful implementation
of direct contact and dust control measures, then an even greater'
cumulative cancer risk of 1.3 x.lQ~3* could be posed. The risk
* The value presented in the RI risk assessment for total carcino-
genic risk for the inhalation exposure (disturbed scenario) is
1.8 x 1Q~5, but should have instead been reported as 2.8 x 1Q~7.
However, this does not change the overall conclusions in the
risk assessment because the total cumulative cancer risk for
the disturbed site remains 1.3 x 10*3.
-------
-10- . ... .._
posed~By the ingestion case contributes almost all of the risk,
i.e., 2.3 x 10~4 and 1.3 x 1CT3 for the undisturbed and disturbed
site scenarios, respectively.
The primary contaminants contributing to othis unacceptable risk
are arsenic, PAHs and dioxin, and the primary route of exposure
for these contaminants is through inadvertent ingestion of soils
(e.g., children playing at the site).
The cancer risks noted above and further detailed in the RI/FS
baseline risk assessment were based on utilizing maximum concen-
trations of contaminants for the soil ingestion scenarios (i.e.,
undisturbed and disturbed site). Even if average concentrations
are used in the ingestion scenarios, total cumulative carcino-
genic risks of 3.2 x 10~5 and 7.1 x 10~5 are derived for the
undisturbed and disturbed site, respectively. Again, most of this
risk is accounted for by the ingestion case, i.e., 2.6 x 10~5 and
7.1 x 10~5 for the undisturbed and disturbed site scenarios,
respectively. Additionally, even assuming arguendo that the
carcinogenic potency factor for dioxin were reduced by a factor
of 16, as suggested by one commentor, the risk posed by the site
would still be unacceptable.
Regardless of whether or not the site is disturbed, it is unlikely
that the non-carcinogenic contaminants will pose a significant
toxic effect.
USEPA concludes that the risks posed by the above described
scenarios are unacceptable. Implementation of the no-action
alternative would lead to continued unacceptable cancer risk
at this site. Human health and the environment would not be
protected on a short-term basis since particles in contaminated
surface soils may become airborne, or come into direct contact
with humans or other environmental receptors at the site. Over
the long-term, it is anticipated that potential exposure risks
may increase since wind and surface water erosion could expose
greater portions of the deeper, more contaminated soils. In
addition, the no-action alternative would not be consistent
with CERCLA § 121 statutory preference for utilizing remedies
which employ treatment as their principal element to reduce
toxicity, mobility or volume of the contaminants at the site.
Based on the results of the baseline risk assessment and a loca-
tional determination of the contaminants at the site, a hot-spot
area containing approximately 7,500 cubic yards of soil was
identified at the site where arsenic, PAHs and dioxin (detected
in previous investigations) are present at significantly higher
levels than identified in other soils at the site.
A description of the analytical methods that were used in making
these risk calculations are provided in the RI report and in the
responsiveness summary.
-------
-11-
DOCUMENTATION OF SIGNIFICANT CHANGES
USEPA and NYSDEC have indentifled in the PRAP that on-site
solidification of the hot-spot soils is their preferred
alternative for remediation of the 93rd Street School site.
Based on CERCLA Section 117(b) requirements, USEPA and NYSDEC
determined that no significant changes have been made to the
proposed remedy from the time it was originally proposed in
the PRAP to final adoption of the alternative in the ROD.
DESCRIPTION OF ALTERNATIVES
As a result of the alternative's development and initial screening
process, a total of six remedial action alternatives were
developed for detailed evaluation for the 93rd Street School
site. Two containment options, three treatment options and
the no-action alternative were carried through to this step.
These six feasible remedial alternatives, and their associated
capital, annual operation and maintenance (O&M), and total
present worth costs are provided in Table 6. This table also
provides the estimated time to implement each remedial alternative
from the completion of the ROD.
This section provides a brief description of the six feasible
remedial alternatives. A more detailed description of the alterna-
tives development and screening process can be found in the FS.
Alternative 1- No-Action with Site Monitoring
This alternative would allow the site to remain in its existing
condition. The contaminated soils would be left in place in
an- uncontained and untreated condition and long-term monitoring
of the groundwater and surface water would be performed as well
as maintenance of the paved areas adjacent to the school and
the existing vegetative cover. The maintenance and monitoring
would be consistent with the relevant and appropriate requirements
of the Resource, Conservation and Recovery Act (RCRA) regulations,
40 CFR Part 264, Subpart F, and 40 CFR § 264.117.
This alternative would result in potential exposure of humans
to contaminants of unacceptable exposure levels. Over time,
risks from these exposures might increase as more contaminated
soils would become exposed due to wind and surface water erosion.
-------
Table 6
Alternative
Nunber
Component •_
1 No Action with Site Monitoring
CONTAINMENTOPTIONS
2 installation of a low permeability soil cover
Remedial Alternatives Summary
Estimated Total Costs (g x 10*}
—Annual Present
Capital o t M Worth*•
Estimated
Time to
implement
fro» ROD
Excavation of soil hot-spot areas, off-site
disposal of these soils at RCRA landfill and
installation of low permeability soil cover
TREATMEHT OPTIONS
41Excavation of soil hot-spot areas* on-slte
solidification of contaminated soils and
installation of a low permeability soil cover
Excavation of soil hot-spot areas, on-site
the mat treatment of contaminated soils at the
93rd Street School and installation of a low
permeability soil cover
A) Case 1- Disposal of treated byproducts at
RCRA landfill
B> Case 2- Solidification of byproducts
followed by on-site disposal
Case 3- Treated byproducts) disposed on-slte
1.3
3.7
C»
Excavation of soil hot-spot areas* on-site
thermal treatment of contaminated soils in the
proposed thermal unit sited at Love Canal proper
and installation of a low permeability soil cover
A) Case 1- Same scenario as Alternative S
B) Case 2 " * "
C) Case 3 * " "
10.0
8.7-10.0
7.8
8.8
7.4-8.8
6.6
0.2 2.0
0.2 3.0
0.1 4.8
3 mo.
3 yre
3 yrs
2.3-3.7 0.1 3.4-4.8
3 yrs
0.1 10.7
0.1 9.7-11.1
0.1 8.9
5 yre
6 yrs
5 yrs
0.1
0.1
0.1
9.9
8.$-10.0
7.7
C yrs
7 yrs.
6 yrs.
Commente
will not protect human
health and environment.
Hot-spot soils exceed:
1 ppb level of concerto
for dloxin. High o*M.
Doesn't meet RCRAJ land
disposal restrictions.
High long- term protection
at site but not off-
site. High short-term
risks from transportation.
Reduces toxiclty and
mobility of organic*
and inorganics* Perma-
nently immobilizes the
waste. Protects human
health and environment.
Meets ARABS. Low DIM.
Reduces toxieity and
mobility. Destroys !or-
ganics. Further treat-
ment (solidification)
of the byproducts may
be required if mstals
remain. Meets ARARs
and protects human
health and environment.
Low OtM.
Same as Alternative S.
Treatment would have
to coincide with sewer
* creek sediment burn*
* Preferred Remedial Alternative.
** £""*nt *orth 4! calculated based on a discount rate of 101 and a performance period of twenty-five years.
* «l°? P*r««abll4ty cover would be placed over the hot-spot soils and extended to other area! whietrexhlbit
of contaminated soils on-site.
lower leve
-------
Alternative "2' - Containment with Low Permeability Soil Cover
Construction of a low permeability cover at the 93rd Street
School site would be performed with the intent of containing
the wastes on-site/ thereby preventing impacts associated
with migration of contaminants via air or surface water at
the site and to prevent direct contact risks. The cover
would be designed and constructed so that it would have the
following capabilities:
(1) Provide long-term minimization of migration of liquids
through the underlying contaminated soils;
(2) Function with minimum maintenance;
(3) Promote drainage and minimize erosion or abrasion of
the cover;
(4) Accommodate settling and subsidence so that the cover's
integrity is maintained; and
»
(5) Have a permeability less than or equal to the permeability
of the natural subsoils underlying the contaminated
fill materials.
The cover would be placed over both the hot-spot soil areas
and extended to other areas which exhibit significantly lower
levels of contaminated soils on-site. It is expected that the
cover would encompass an area of approximately eight acres.
The specific characteristics and thickness of the cover would
be determined during the remedial design phase. It is anticipated
that in order for the covered area to drain properly, the
site would be regraded to ensure effective surface runoff.
Long-term monitoring would be required with this alternative
to ensure that contaminants are not leaching into the groundwater
or surface water. Periodic inspections of the cover and paved
areas would be required consistent with RCRA § 264.117, and
any cover damage detected would require prompt correction.
This alternative would comply with RCRA Subtitle C (40 CFR
§ 264.310) landfill closure requirements. Since wastes are
not being placed with this alternative/ RCRA Land Disposal
Restrictions (LDRs) would not apply. The groundwater monitoring
associated with this alternative would comply with RCRA 40 CFR
Part 264, Subpart F requirements for groundwater monitoring.
To comply with CERCLA Section 121(c), since wastes would
remain on-site following implementation of this alternative,
a review of the performance of the cover would be conducted
^t least every five years to ensure that the remedy continued
Eo provide protection of human health and the environment.
-------
-13-
„,*<*_
Alternative 3 - Soil Hot-Spot Excavation, Off-site Disposal
ataRCRA Landfill and a Low Permeability Cover
This option involves excavating all identified hot-spot soils
followed by transportation of these soils to an approved off-
site RCRA landfill. It has been estimated previously that
the quantity of hot-spot soils requiring remediation at the
site would be approximately 7,500 cubic yards. Following
excavation, the excavated areas would be filled with clean
fill from an off-site location, then a low permeability cover
as described in Alternative 2 would be place over the
approximately eight acre area.
Control technologies that would be required during implementation
of this alternative would include: respiratory and protective
clothing for workers at the site? decontamination equipment?
dust controls which could include water spraying, windscreening,
and temporary surface water controls to prevent migration of
contaminants off-site. In addition, chemical dust suppressants
may be required to control volatilization of organics.
Long-term groundwater monitoring and maintenance requirements
would be similar to those described previously for the low
permeability cover (Alternative 2). Monitoring requirements
might be reduced since hot-spot soils would no longer be present
at the sits. Consistent with the relevant and appropriate
requirements of 40 CFR § 264.117, the Regional Administrator
has the authority to reduce the post-closure care if it is
determined that the reduced period is sufficient to protect
human health and the environment (e.g., groundwater monitoring
results, or alternative disposal or reuse techniques indicate
that the facility is secure).
A potentially limiting factor of this alternative is the fact
that prior to disposal at the off-site RCRA landfill, it may
have to be demonstrated that the hot-spot soils would meet
LDR requirements. LDR standards have not been promulgated
for soil and debris waste (except for dioxin, which requires
the leachate from treated soils to be less than 1 ppb), but when
promulgated, the standards may be relevant and appropriate.
Methods such as the Toxicity Characteristic Leaching Procedure
(TCLP) and total waste analysis could be utilized to determine
if the soils meet the LDR levels. For Alternative 3, without
prior treatment of the hot-spot soils, it is possible that
they would fail the TCLP or total waste analysis test (at
least for dioxin at this time) and, therefore, off-site
-------
-14-
land disposal of these soils after November 8/ 1983 (the date
which LDR requirements for soil and debris are expected to take
effect), may not be allowed. Off-site land disposal without prior
treatment is also the least preferred alternative under CERCLA.
Option 3 must also comply with CERCLA Section 121(d)(3)
regarding off-site disposal of hazardous waste. This section
requires that the off-site facility be operating in compliance
with all federal (e.g., RCRA) and state requirements. As a
result, the hot-spot soils from the site may only be transferred
to an off-site facility if the landfill unit that will accept
the soils is not releasing any hazardous waste into the
groundwater, surface water or soil, and all releases from
other units at that facility are being controlled by a RCRA
corrective action program.
Since the hot-spot soils would be sent off-site, RCRA 40 CFR
Part 262, Subparts A through D manifesting and transportation
requirements would be followed. In addition, the soils would
not require significant temporary storage prior to transportation.
Alternative 4 - Soil Hot-Spot Excavation, On-Site Solidification
of Soils, and a Low Permeability Cover
Alternative 4 involves the solidification/stabilization of the
contaminated soils. The soil hot-spots would be excavated and
then solidified utilizing a transportable treatment unit
located at the 93rd Street School site.
The solidification treatment would involve blending the soils
in mixing tanks with additives which would reduce the toxicity
and mobility of the contaminants and would permanently immobilize
the waste. If the transportable solidification treatment unit
is not a closed system, controls may be required for potential
emissions. Additives typically introduced during the solidifi-
cation process include cement, silicates, polymers and proprie-
tory additives which chemically stabilize the organics in the
contaminated soil for optimum solidification. Once the additives
are mixed with the soil, the final product may resemble concrete
or hardened clay. The treatment of soils would comply with the
appropriate treatment standards of 40 CFR Part 264.
Prior to implementation of this alternative, a treatability
study would be conducted during the remedial design phase to
ensure the effectiveness of this technology and its capability
of reducing the total waste concentration and any possible
leachate from the treated soils to levels below applicable or
relevant and appropriate treatment standards (e.g., LDR
requirements). Should the treatability study determine that
solidification would not provide the desired degree of treatment,
then treatability studies would be performed to determine the
effectiveness of other treatment techniques (including thermal
treatment) for the on-site soils.
-------
-15-
If the solidified soil meets all treatment level requirements,
then the treated soil would be redeposited in the same unit of
contamination from which it originated. A low permeability
cover would then be placed over the area (as discussed in
Alternative 2) and monitored consistent with the technical
requirements for closure and post-closure (e.g., RCRA 40 CFR
§ 264.310). The remedial activities of Alternative 4 would
also comply with the general and record keeping requirements of
40 CFR Part 262, Subparts A and D, respectively.
Long-term monitoring, consistent with RCRA regulations, 40 CFR
Part 264, Subpart F, of the groundwater and surface water would
be required with this alternative as well as monitoring and
maintenance of the cover as described in Alternative 2. Post-
closure requirements might be reduced, however, as discussed
in Alternative 3.
Control technologies required during implementation of this
alternative would be essentially the same as those described
previously for off-site RCRA landfill disposal of the soils.
It is not anticipated that significant stockpiling of the exca-
vated soils would occur prior to the solidification treatment.
On-site storage of soils prior to and after treatment and prior
to disposal would comply with 40 CFR § 262.34 or 40 CFR Part
264 storage requirements.
Since the solidified soil will remain on-site, this remedy
would be reviewed at least every five years to ensure that
human health and the environment continue to be protected.
Alternative 5 - Soil Hot-Spot Excavation, On-Site Thermal
Treatment of Soils at the 93rd Street School, and a Low
Permeability Cover
This alternative involves excavation of the hot-spot soil areas
followed by on-site thermal treatment of these soils at the 93rd
Street School site utilizing a transportable unit and residuals
disposal into the same unit of contamination from which they origi-
nated. A low permeability cover would then be placed over the
area (as discussed in Alternative 2) and monitored and maintained.
On-site thermal treatment would be performed with the intent
of permanently treating the hot-spot soils so that treatment
by-products would meet LDR treatment levels prior to disposal
at the 93rd Street School site (Case 3). If, however, no
thermal treatment unit were available which could achieve
these levels by itself (due to the metal contaminants present
in -the soils), then an additional technology capable of
reducing the remaining levels of the contaminants in the
byproducts could be utilized. Following thermal treatment,
the partially treated byproducts could then be disposed of
either on-site following treatment via a solidfication
technology capable of meeting the LDR treatment levels (Case
2) or at an approved off-site landfill (Case 1).
-------
-16-
Control technologies required during the excavation would be
similar to those described previously for the off-site RCRA
-landf,il.l_disposal and solidification/stabilization alternatives.
If feed preparation operations such as pulverization or drying
were required, then controls would be warranted to minimize
worker contact with the soils during handling operations,
to minimize particulate and possibly volatile emissions, and
to minimize noise pollution. During thermal treatment, air
pollution controls would be required to prevent potential
escape of hazardous byproducts. Finally, if the treatment
byproducts were hazardous, workers would have to be equipped
with the appropriate respiratory and other protection equipment
to handle the partially treated ash and scrubber waters.
Process wastewater from thermal treatment could be treated at
the Love Canal Leachate Treatment Facility. All federal and state
ARARs would be complied with for storage and treatment of these
wastewaters.
To reduce storage' requirements prior to treatment, it is antici-
pated that the hot-spot soils would be excavated in a batch mode
rather than excavate and stockpile all the soils at once.
The time required for thermal treatment of the hot-spot soils
could vary from approximately 12 to 21 months based on 24
hours/day, 365 days/year, and a 75 percent efficiency operation,
depending upon the transportable unit selected. It is anticipated
that a treatability study followed by a test burn would be
required prior to selection of a final thermal treatment unit
for use at the site to determine the level of treatment
attainable, the effectiveness of air pollution controls, and
the time required for treatment. The test burn would also
help to indentify any problems associated with thermally
treating the hot-spot soils from the 93rd Street School site.
Analysis of the byproducts from the treatability study and
test burn could be used to establish whether or not they
would be capable of meeting LDR treatment requirements and,
therefore, whether off-site RCRA landfill disposal (Case 1),
solidification/stabilization (Case 2) or direct on-site disposal
(Case 3) would be appropriate.
Maintenance and monitoring requirements for all cases would
include maintenance of the transportable thermal treatment unit
and the low permeability cover, and monitoring of groundwater,
emissions and byproducts to ensure protection of human health and
the environment.
Since the treated soil would remain on-site in Cases 2 and 3,
this remedy would be reviewed at least every five years to
ensure that the remedy continued to provide protection of human
health and the environment. If the treated byproducts are sent
to an off-site facility (Case 1), then applicable RCRA 40 CFR
Part 262 Subparts A through D manifesting and transportation
requirements would be required.
-------
-17-
-^
This remedy would comply with RCRA § 264 Subpart 0 requirements
for incineration units. Subpart 0 specifies design requirements
for operation of hazardous waste incinerators. In addition,
the thermal treatment unit would comply with State requirements
prohibiting general air pollution and controlling air emissions
from process sources. The site would also be closed in
accordance with landfill closure under 40 CFR S 264.310 (RCRA
Subtitle C).
Alternative 6 - Soil Hot-Spot Excavation, On-Site Thermal
Treatment of Soils at Love Canal Proper, and a Low Permeability
Cover
This alternative involves the same steps as Alternative 5
(thermal treatment at the 93rd Street School) except that the
hot-spot soils would be thermally treated at Love Canal proper.
This alternative is possible because USEPA has previously
selected on-site thermal treatment as the remedy for the
creek and sewer sediments project (see Record of Decision—Love
Canal Site/ October 26, 1987). Under the selected remedy, a
transportable thermal treatment unit will be located at Love
Canal proper, therefore, it is feasible that the hot-spot soils
from the 93rd Street School site could be treated in this same
unit. However, as mentioned previously, a treatability study
and test burn would have to be performed prior to implementation
of this alternative to ensure its continued effectiveness.
This alternative would differ from Alternative 5 in that
transportation of the hot-spot soils to the transportable thermal
treatment unit located at Love Canal proper would be required.
Since both the Love Canal - 93rd Street School site and the Love
Canal proper are located within the EDA, and are, therefore,
considered one site, RCRA manifests would not be required for
transportation of the contaminated soils to the treatment unit,
or for transportation of the treated byproducts back to the 93rd
Street School site for disposal. However, if the treated byproducts
are sent to an off-site RCRA landfill (Case 1), then applicable
RCRA 40 CFR Part 262, Subparts A through D manifesting and trans-
portation requirements would be required.
The time required for thermal treatment of the hot-spot soils
is dependent upon the creek and sewer remediation schedule.
It is anticipated that thermal treatment of the creek and
sewer sediments would be initiated in 1992, thereby delaying
excavation and treatment of the 93 Street School site hot-spot
soils until that time.
-------
As is the case witlr^Alternative 5, thermal treatment of the
soils would comply with all applicable requirements of 40 CFR
Part 264, Subpart 0 of RCRA and more stringent state regulations
pertaining to incinerators. In addition, thermal treatment
operations, closure requirements, cover maintenance, groundwater
monitoring and storage and treatment requirements for process
wastewaters would be the same as Alternative 5.
SUMMARY OF THE COMPARATIVE ANALYSIS OF ALTERNATIVES
The above six alternatives were evaluated using evaluation
criteria derived from the NCP and CERCLA. These criteria
relate directly to factors mandated by CERCLA in Section 121
including Section 121(b)(1)(A-G). The criteria are as follows:
•
Protection of human health and the environment
Compliance with ARARs
Reduction of toxicity, mobility or volume
Short-term effectiveness
Long-term effectiveness and permanence
Implementability
Cost
State acceptance
Community acceptance
A summary of the relative performance of the alternatives with
respect to each of the nine criteria is provided below.
• Protection of Human Health and the Environment
Protection of human health and the environment is the central
mandate of CERCLA. Protection is achieved primarily by re-
ducing health and environmental threats to acceptable levels
and taking appropriate action to ensure that there will be
no unacceptable risks to human health and the environment
through any exposure pathway.
Except for the no-action alternative, all the alternatives
evaluated afford adequate protection of human health and the
environment. The no-action alternative will not be capable
of adequately protecting human health and the environment on
a short-term basis since particles in contaminated surface
soils may become airborne, transported via surface water
runoff or come into direct contact with humans or other
environmental receptors at the site. Over the long-term,
it is anticipated that potential exposure risks may increase
since wind and surface water erosion could expose greater
portions of the contaminated soils. Since the no-action
alternative cannot satisfy this fundamental requirement, it
will not be considered further.
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-Alternatives 2 through 6 all afford adequate protection of
human health and the environment, although they achieve this
through different means. Containment Options 2 and 3 achieve ~
protection through controlling exposure to the waste. Treatment
Options 4 through 6 achieve protection through a reduction of
the inherent hazard posed by the contaminants in addition to
controlling exposure to residuals.
Alternatives 2 and 3 physically contain the contaminants
on-site and off-site, respectively. Alternative 3 ensures
greater level of protection in the long-term since the hot-
spots would be excavated, however, there may be some short-
term risks associated with excavation and transportation.
Alternative 2 provides the greatest protection in the short-
term, however, there is a higher degree of uncertainty in the
long-term if, the hot-spot soils are eventually exposed through
the cover. As a result, significant health risks may be posed.
Of the treatment options, solidification (Alternative 4)
is expected to permanently immobilize the hot-spot soils and
eliminate any potential for leaching of both organic and inorganic
contaminants. All threats associated with soils ingestion,
inhalation and dermal contact would be eliminated. During
the treatability study for solidification, it must be demon-
strated that deterioration of the solidified/stabilized
hot-spot soils will not occur such that the residuals will
pose a significant risk as a result of erosion.
Thermal treatment (Alternatives 5, 6B and 6C) would provide
essentially comparable effectiveness to solidification, assuming
that the byproducts meet all treatment level requirements,
specifically, heavy metals.
Alternatives 5A and 6A would result in comparable effectiveness
at the site, however, the effectiveness provided near the
off-site facility is dependent on proper maintenance of the
landfill.
All alternatives except for the no-action alternative would
include adherence to a site specific health and safety plan
to protect workers during implementation. Occupational
Safety and Health Administration requirements, as well as
more stringent state regulations would be followed by workers
at the site to minimize the potential for harmful exposure
and remediation related accidents.
• Compliance with Applicable or Relevant and Appropriate
Requirements
Section 121(d) of CERCLA requires that remedial actions comply
with all ARARs to the extent that hazardous substances are
present on-site. Alternatives 2 through 6 would attain their
respective ARARs.
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-20-
Although the area is served by a municipal water supply and the
groundwater at the site is not currently used, nor is it planned
to be used as a drinking water source, samples were taken and
analyzed. Those analyses indicate that a non-health-based New
York State secondary groundwater standard for aesthetics (taste
and odor) for iron was exceeded at the site, and that the ground-
water and surface water at the site are not otherwise contaminated
at levels exceeding CRDLs. Those analyses also indicate that, for
certain compounds, the groundwater and surface water did not exceed
health-based ARARs. For other compounds, however, the CRDLs used
during the RI exceeded both New York State and USEPA drinking
water standards. In addition, some compounds detected exceeded
guidance values and criteria considered. Consequently, additional
sampling of the groundwater was recently performed. The analysis
(with the lowest achievable levels of detection) will determine
whether groundwater ARARs and other criteria to be considered
are being exceeded. The results are anticipated to be available
in the fall of 1988, and may be considered in any subsequent
decision on groundwater or surface water remediation.
Based upon the LDR provisions, RCRA hazardous waste in accordance
with 40 CFR Part 261 (i.e., hazardous waste is defined as
listed or characteristic) which is excavated, treated and then
redeposited in the same unit of contamination constitutes
placement and, therefore, the LDR requirements are potentially
applicable or relevant and appropriate.
»
To determine whether a waste is a listed RCRA hazardous waste,
it is necessary to know the source or use of the waste. When
it is not possible to make an affirmative determination that
the wastes are listed RCRA hazardous wastes, RCRA requirements
are not applicable to CERCLA actions, but may be relevant and
appropriate if the CERCLA action involves treatment, storage
or disposal and if the wastes are similar or identical to
RCRA hazardous wastes. Because it has not been determined with
certainty whether the wastes at the 93rd Street School site
are RCRA listed hazardous wastes, EPA has determined that the
RCRA LDR requirements are not applicable.
Although the LDR requirements are not applicable in terms of
a listed hazardous waste, they may be applicable if the waste
is identified as RCRA characteristic hazardous waste. A RCRA
characteristic hazardous waste is identified as a waste which
exhibits the characteristics of either ignitability, corrosivity,
reactivity or toxicity (using the extraction procedure (EP)).
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-21-
The waste at the 93rd Street School site do not exhibit the
characteristics of ignitability, corrosivity or reactivity. In
addition, due to the binding qualities of the fill material at
the site and its ability to tie-up the contaminants within the
soil/fill matrix, it is also improbable that the wastes exhibit
EP toxicity characteristics. Furthermore, the contaminants would
be immobilized after treatment (i.e., at the time placement of
the waste will occur). As a result, the LDR requirements are also
not applicable in terms of RCRA characteristic hazardous waste.
Although the LDR requirements are not applicable because the waste
is not a RCRA hazardous waste, the LOR requirements are still
potentially relevant and appropriate. Dioxin LDR standards
based upon analysis of treated soil have been promulgated for
soil and debris waste. (These standards require the leachate
from treated soils to be less than 1 ppb). Accordingly, the
dioxin waste at the 93rd Street School is sufficiently similar
to LDR dioxin waste, 40 CFR Part 268, Subpart C. Therefore, EPA
believes that the LDR standards for dioxin are relevant and
appropriate for this site.
EPA is undertaking an LDR rulemaking that will specifically
apply to soil and debris. Until that rulemaking is completed,
the CERCLA program will not consider LDR to be relevant and
appropriate (except for dioxin) to soil and debris that does
not contain RCRA restricted wastes.
Following solidification, the treated soils would then be
redeposited back on-site in the same unit of contamination
from which they originated, with a low permeability cover
having a permeability less than or equal to the permeability
of the natural subsoils, placed over the area. Therefore,
these alternatives are consistent with landfill closure
requirements under 40 CFR § 264.310 (RCRA Subtitle C). Under
the above approach, RCRA minimum (design and operating)
technology requirements (e.g., double liner/leachate collection
system) would not be triggered since a new unit is not being
constructed nor is replacement or lateral expansion of the
existing unit occuring.
Containment Option 3 would not comply with the LDR requirements
unless the hot-spot soils meet the treatment levels, using
testing procedures such as the TCLP and 'total waste analysis.
This alternative would also need to comply with CERCLA § 121
(d)(3) regarding off-site disposal of hazardous waste. This
requires that the off-site facility be operating in compliance
with all federal (i.e., RCRA) and state requirements.
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-22-
While permits are not required for on-site remedial actions"'"
at Superfund sites, any on-site action must meet the
substantive technical requirements of the permit process.
The site excavation options (3, 4, 5 and 6) will comply with
all federal and state requirements concerning potential air
emissions (particulates and volatiles) during the excavation
of the hot-spot soils. Thermal treatment of the soils
(Options 5 and 6) would comply with all the requirements of
40 CFR Part 264, Subpart 0 (RCHA) and more stringent state
regulations pertaining to incinerators. Specifically, operation
of an on-site thermal treatment unit would require that the
transportable unit undergo waste specific trial of demonstration
burns to demonstrate satisfactory destruction of the toxic
components of the waste. The trial or demonstration burn
must show that the unit achieves 99.9999% destruction and
removal efficiency (DRE) for dioxin and 99.99% DRE for the
remaining contaminants, and controls air emissions of products
of incomplete combustion, acid gases and particulates to
specified levels.
Options 3, 5A and 6A which involve off-site shipment of waste
would comply with the requirements of RCRA 40 CFR Part 262,
Subparts A through D regarding manifesting and transportation.
A location-specific ARAR which would be complied with for
all the alternatives is the National Historic Preservation
Act. A determination of whether the alternatives would have
any affect on cultural resources would be made during the
design phase.
• Reduction of Toxicity, Mobility or Volume
This evaluation criteria relates to the performance of a remedial
alternative in terms of eliminating or controlling risks posed
by the toxicity, mobility or volume of hazardous substances.
Solidification is expected to permanently immobilize the hot-
spot soils, thereby, eliminating any exposure to toxicity threats
posed by the contaminants. Any future leaching of contaminants
from the solidified soil and risks due to soils ingestion in
the treated areas would also be eliminated by this option.
The thermal treatment options would destroy the organics
(including dioxin), and any toxicity that may remain due to
the heavy metals in the byproduct could be remediated either
through solidification (Options 5B or 6B) or off-site disposal
(Options 5A or 6A). However, the toxicity, mobility or volume
would not be reduced with the off-site disposal options. Thermal
treatment would also eliminate future mobility of the waste.
The containment options (Alternatives 2 and 3) would reduce
exposure to the waste but would not achieve a reduction in
toxicity, mobility or volume through treatment.
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-23-
The volume of the- hot*- spot
materials would not be significantly reduced following thermal
treacaent. The volume of the vegetative layer of soils from the
hot-spot area, however, might be significantly reduced because
of the higher percentage of organic materials in this layer.
The long-term mobility of the hot-spot soils would be reduced
by thermal treatment since the contaminants would be destroyed,
but there would be an increase in the mobility of contaminants
over the short-term due to air release of products of incomplete
combustion and increased materials handling. This would be
controlled through careful handling and operational procedures
for the thermal treatment process (i.e., scrubbers, etc.).
There could also be an increase in the mobility of contaminants
during the solidification process over the short-term due to
increased materials handling.
With solidification, due to the addition of the fixation
agents, the volume of waste material would likely increase.
* Short-Term Effectiveness
Short-term effectiveness measures how well an alternative is
expected to perform, the time to implement the action, and
the potential adverse impacts of its implementation.
The low permeability cover installed with Alternative 2 would
virtually eliminate existing risks on a short-term basis since it
would not be necessary to disturb the contaminated soils.
However, minor exposure during use of construction equipment
on the surface soils prior to placement of the cover could occur.
The excavation options would increase the short-term risks from
air emissions, and additional risks to communities along the
transportation route would be incurred as a result of the off-
site transportation of the hot-spot soils with Alternative 3.
Approximately four hundred 20 cubic yard truck loads of soil
would have to be transported to the off-site RCRA facility.
Therefore, risks due to soils spillage or an overturned truck
could occur.
On-site solidification (Option 4) would significantly reduce
existing risks at the site once the hot-spot soils are treated.
However, both the solidification and thermal treatment alterna-
tives would result in short-term risks from excavation. In
addition, thermal treatment may result in air emissions,
however, as mentioned previously, strict measures would be
implemented to ensure that such emissions would not be harmful
to human health and the environment. Thermal treatment may
also require additional materials handling on-site, such as
pretreatment (e.g., shredding and crushing) of the contaminated
soils prior to feeding to the thernal treatment unit.
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-24-
The time to implement each remedial alternative, except for
the thermal treatment alternatives, is approximately three
years from the signing of the ROD. Depending on the method of
disposal of the byproducts following thermal treatment, the
time to implement Alternatives 5 and 6 could vary from approxi-
mately five to seven years. It should be noted that thermal
treatment of the 93rd Street School site hot-spot soils at Love
Canal proper would begin in 1992, thereby, coinciding with
thermal treatment of the creek and sewer sediments schedule.
* Long-Term Effectiveness and Permanence
Long-term effectiveness and permanence addresses the long-
term protection and reliability of an alternative.
Over the long-term, the on-site solidification and thermal
treatment options provide essentially comparable effectiveness
to the local community, since the byproducts are not expected
to pose a hazard from a health and environmental perspective.
However, thermal treatment is not an effective technology for
the inorganic contaminants in the soils. The inorganics tend
to slag (depending on their volatility) and remain in the
byproducts. Further treatment or off-site disposal of the
byproducts may, therefore, be required (i.e., Alternatives
5B, 6B and 5A, 6A, respectively).
Treatability studies would be performed during the design of
both the solidification and thermal treatment alternatives to
ensure their long-term effectiveness. During the treatability
studies, the byproducts would be analyzed according to methods
such as the TCLP and total waste analysis to determine the
effectiveness each treatment procedure has in meeting the LDR
treatment levels. Even though the solidification process
would permanently immobilize the waste, the testing conducted
during the treatability study would confirm the long-term
effectiveness of this option. If this alternative is implemented,
it is anticipated that any deterioration of the solidified
material would be detected during routine monitoring. Should
the deterioration be significant, then appropriate action would
be taken to ensure protectiveness.
The effectiveness of the low permeability cover would be
better than the no-action option, however, it is necessary to
continually monitor the cover to ensure erosion would not
result in exposure of the hot-spot soils. There is also the
possibility that damage to the cover could occur due to a
major earthquake (since this area has defined seismic activity)
or a flood of a magnitude greater than 100 years.
The long-term effectiveness of Alternative 3 would be high at
the site itself since the hot-spots would be removed, however,
the contaminated soils would be deposited at an off-site
RCRA facility.
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All options in which wastes would remain on-site need to be
reviewed at least every five years to ensure their continued
effectiveness.
* Implementability
Implementability addresses how easy or difficult it would be
to carry out a given alternative. This covers implementation
from design through construction and O&M.
The implementability of the alternatives is evaluated in terms
of technical and administrative feasibility, and availability
of needed goods and services.
Each alternative evaluated is technically feasible, however,
treatment options 4, 5 and 6 would require treatability
studies to determine the optimal conditions to satisfy the
LDR treatment level requirements and provide a high degree of
long-term effectiveness. Frequent monitoring of byproducts
during operations would be needed to ensure system effectiveness
and reliability.
The availbility of necessary equipment and specialists may be
more limited for solidification than for the other alternatives
since solidification of both organic and inorganics is a fairly
recently demonstrated technology. However, based upon recent
use of transportable units for this technology at other CERCLA
sites (e.g., Pepper's Steel and Alloys site, Florida) and its
widescale selection for other CERCLA sites in the country, a
well-established market is becoming available for this technology
for both organics and inorganics.
Thermal treatment implementation would vary in difficulty
depending on the transportable unit selected and its associated
pretreatment and operational requirements.
Sufficient area exists at the 93rd Street School site to
set-up treatment units as called for in Alternatives 4 and 5
and there is ample land area available on-site for redeposition
of the treated soil.
With Alternative 6 (thermal treatment at Love Canal proper),
excavation of the hot-spot soils could either occur during the
1990 construction season (following the creek sediments excava-
tion in 1989), allowing the soils to be temporarily stored with
the creek sediments, or the 93rd Street School site hot-spot
soils could be excavated just prior to thermal treatment during
1992, eliminating the requirements for temporary storage.
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Implementation of a low permeability cover and off-site
disposal (Alternatives 2 and 3, respectively) would not be
difficult technically, however, administrative requirements
with disposal of the waste off-site may prove substantial.
Difficulties can be anticipated with finding an off-site
disposal unit that is in compliance with RCRA regulations and
facilities may not be capable or willing to accept the dioxin-
contaminated waste.
The severe winter weather conditions in this area would limit
the construction season for the alternatives, and the decreased
winter temperatures may require additional precautions to
maintain optimal reaction rates for the solidification option.
• Cost
Costs are evaluated in terms of capital, O&M and present worth.
While comparing treatment Alternatives 4, 5 and 6, which result
in comparable effectiveness, solidification of the hot-spot
soils has been identified as the lowest cost alternative. The
total present worth cost for these options range from approxi-
mately $3.4 to $4.8 million for solidification to $7.7 to
$11.1 million for thermal treatment. The lower end of the
cost range for thermal treatment assumes treatment at Love
Canal proper, with the byproducts meeting LDR treatment levels
disposed on-site at the 93rd Street School site (Option 6C).
The higher cost assumes treatment at the 93rd Street School
site with the byproducts solidified (Option 5B).
The containment options (Alternatives 2 and 3) vary from
approximately $3 milllion to $4.8 million, respectively.
As mentioned previously, Table 6 provides a summary of the
capital, O&M and total present worth cost of each of the six
alternatives. A more detailed breakdown of these costs are
provided within the RI/FS.
" State Acceptance
This section addresses any concerns and degree of support the
State has expressed regarding the remedial alternatives being
evaluated.
The State supports a solution that involves treatment that
reduces the inherent hazard posed by the contaminants for the
Love Canal - 93rd Street School site. Its preference is on-site
solidification/stabilization of the contaminated soils (Alterna-
tive 4), contingent upon the results of a treatability study
which would be performed to ensure the effectiveness of the
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solidification process and its ability to meet specified treat-
ment levels. Should the treatability study indicate that
solidification of the soils would not provide the. desired degree
of treatment, then other treatability studies would be performed
to determine the effectiveness of treating these soils on-site.
* Community Acceptance
This evaluation criterion addresses the degree to which members
of the local community support the remedial alternatives being
evaluated.
Both the draft RI/FS and the PRAP (Alternative 4) were made
available during the public comment period and were presented
at the public meeting. In general, the community indicated a
preference for a treatment based alternative that reduces the
inherent hazard posed by the contaminants at the site and many
favored the solidification/stablization alternative.
Some residents expressed concern at the public meeting that
solidification is not a proven technology. In response to
their concerns, during the subsequent availability session
and throughout the remainder of the public comment period,
information concerning the demonstrated ability and performance
of the soldification process was made available to the local
community by both USEPA and NYSDEC.
Detailed responses to the community concerns are contained in
the attached responsiveness summary.
SELECTED REMEDY
Based upon CERCLA, the detailed evaluation of the alternatives,
and public comments, both USEPA and NYSDEC have determined that
Alternative 4, soils excavation, on-site solidification and a low
permeability cover is the most appropriate remedy for the 93rd
Street School site. This remedy consists of the following
components:
1. Excavation of approximately 7,500 cubic yards of contaminated
soil followed by on-site solidification/stabilization of
this material. Figure 3 illustrates the extent of identified
hot-spot soils to be excavated. Additional testing will be
conducted during the remedial design to further define the
volume of soil needing excavation and treatment. It is
anticipated that the current estimate of 550 cubic yards
of dioxin-contaminated soil would be significantly reduced
based on the results of this additional testing.
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2. The solidified soil would be placed back on-site within
' the same unit of "contamination from which it originated,
with a low permeability cover installed over these areas
and extended to other areas which exhibit lower levels of
contaminated soils at the site.
3. Treatability studies will be conducted during the remedial
design to determine the effectiveness of the solidification/
stabilization process for the particular soil and its ability
to meet specified treatment levels (e.g., LDR treatment
requirements)., Should the treatability studies determine that
solidification would not provide the desired degree of
treatment, than treatability studies would be performed to
determine the effectiveness of other treatment techniques
(including thermal treatment) for the on-site soils. In
addition to meeting the LDR treatment requirements, interim
soil and debris treatment levels will be considered while
evaluating the effectiveness of the solidification process
during the treatability studies.
4. Since the solidified soil will remain on-site, the remedy
will be reviewed at least every five years to ensure that
human health and the environment continue to be protected.
5. Additional sampling (with the lowest achievable levels of
detection) of the groundwater was conducted in May 1988 to
ensure that ARARs for groundwater are not being exceeded.
Should the analytical results indicate that groundwater
standards and other criteria to be considered are exceeded,
then an evaluation of the necessity for remediation of the
groundwater would be conducted. Remediation of the ground-
water, if warranted, would be addressed in a subsequent ROD.
6. A groundwater monitoring program would be established in
accordance with RCRA regulations, 40 CFR Part 264, Subpart F.
7. One hundred percent of the remedial design will be funded
by USEPA. Cost sharing for construction of the remedy
is 90% USEPA and 10% State of New York.
Cost estimates for the selected remedial action are presented
in Table 7.
* Operation and Maintenance
O&M are those costs required to operate and maintain the remedial
action throughout its lifetime. These activities ensure the
lifetime effectiveness of the remedial alternative selected.
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T*bl« 7
"SOUOIFICATION/STABIUZATIOM ALTERNATIVE COST ESTIMATE
CAPITA*. EXPENSE ITEMS QTY. UNITS
1. Preliminary Testing &
Approvals —
2. Hot Spot Soil Excavation 7,500 Cu. Yd.
3. Hot Spot Pavement
Excavation 3,000 Sq. Yd.
UNIT
COST
$100,000
$5.00
8.00
TOTAL COST
$100,000
40,000
25,000
4. Solidification/Stabilization 11,250* Ton 50.00 565,000 to
* 7500 cu.yd. x 1.5 tona/cu.yd.- 11.250 tons *<» 150.00 1,690,000
5. Sampling/Analysis of
Treated Soils
6. Red1s*posa1 of Treated
Soils
7.
Reconstruct Pivtd Areas
a. Base
b. Pavement, 3" thick
8. Place low Permeability Cover
15
7,500
to 13,000
3,000
3.000
Sample
Cu. Yd.
Sq. Yd.
Sq. Yd.
p* Table 4-fi.
1,000.00
5.00
5.00
7.00
15,000
40,000 to
65,000
15,000
25,000
i.oas.ooo
Sub-Total :
201 Eng. and Reg. Contingency:
TOTAL:
$1,910,000 to
$3,060,000
$ 385,000 to
$ 615,000
$2,295,000 to
$3,675,000
PERIODIC EXPEHSE ITf-MS
1. SOT1-Annual Site Inspection
2. Quarterly Ground*ater
Monitoring
3. Detailed Evaluation
(every 5 years)
4. Maintenance
a. Cover Maintenance
b. Misc. Maintenance
50 Manhr./Yr. $50.00
52 Sample/Yr. 1,300.00
0.2 EvaUYr. 100,000.00
Sub-Total:
20X Eng. and Reg. Contingency:
TOTAL COST/YR
$2,500
68,000
20,000
2,500
7,500
$100,500
20.500
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O&M requirenents (primarily for groundwater monitoring and
maintenance of the low permeability cover) are eligible for
Superfund monies for a period of up to one year to assure the
effectiveness of the remedy. Following that year, any additional
O&M costs would be the responsibility of the State.
As part of the remedial action, a long-term groundwater
sampling program is included to monitor changes in the nature
and extent of contamination at the site to determine the
effectiveness of the remedy.
* Future Actions
This ROD addresses the source of contamination by remediation
of the on-site contaminated soils. The remedy will address the
principal threats at the site by permanently immobilizing the
soils at the 93rd Street School site, thereby preventing any
future groundwater contamination and reducing the risks
associated with exposure to the contaminated soils.
Additional sampling of the groundwater was conducted in May
1988. The analysis of these samples (with the lowest achievable
levels of detection) will determine whether groundwater ARARs
and other criteria considered are being exceeded. The results
are anticipated to be available in the. fall of 1988, and may
be considered in any subsequent groundwater remediation.
Remediation of the groundwater, if warranted, would be addressed
in a subsequent ROD.
The selected remedy is not expected to encroach upon the 100-
year floodplain. However, if it is determined during the
remedial design that any portion of the low permeability
cover would be located within the 100-year floodplain, then
appropriate measures such as a floodplain assessment may be
performed.
An evaluation of the area for the potential discovery of uniden-
tified cultural resources is necessary. Accordingly, under the
National Historic Preservation Act, a cultural resources (Stage 1A)
survey would be performed during the remedial design phase to
determine whether the selected remedial action will have any
affect on resources or whether the site is eligible for
nomination to the National Register of Historic Places.
STATUTORY DETERMINATION
The selected remedy best achieves the goals of the nine
evaluation criteria in comparison to the other alternatives.
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Solidification/stabilization- is expected to permanently
immobilize the hot-spot soils and eliminate any potential for
leaching of both organic and Inorganic contaminants. All
threats associated with soils ingestion, inhalation and dermal
contact would be eliminated.
With the solidification option, short-term risks from excavation
of the hot-spot soils would occur, however, strict measures
would be implemented to ensure that such emissions would not
be harmful to human health and the environment. During
implementation, portions of the contaminated soils would be
excavated at a time and then solidified. This method would
eliminate any significant stockpiling of the contaminated
soils prior to treatment, thereby, reducing short-term risks
from direct contact and inhalation.
The selected remedy would comply with federal and state
requirements regarding fugitive volatile and particulate
emissions during excavation. The applicable New York State
air and hazardous waste requirements for excavation which
would be complied with include 6 NYCRR Part 257 and Part 373,
which regulate ambient air standards, and control particulates
from waste piles, respectively. Part 211 also contains
general prohibitions against air pollution and it gives the
State discretion in requiring controls. Controls that are
typically utilized are water spray and chemical dust suppressants
to control fugitive particulate emissions and volatilization
of organics. In addition, Part 212 may also apply to the
solidification process, thereby, requiring controls on emission
sources. The federal requirements that will be complied with
during excavation include 40 CFR Part 50 and § 264.25(f), which
control ambient air standards and control of particulates
from waste piles, respectively.
Based upon the LDR provisions, RCRA hazardous waste (listed or
characteristic) which is excavated, treated and then redeposited
in the same unit of contamination constitutes placement and,
therefore, the LDR requirements are potentially applicable or
relevant and appropriate.
Because it has not been determined with certainty whether the
wastes at the 93rd Street School site are listed hazardous
wastes, EPA has determined that the RCRA LDR requirements are
not applicable. In addition, the waste at the site do not
exhibit the characteristics of ignitability, corrosivity or
reactivity, and it is also improbable that the wastes exhibit
EP toxicity characteristics. As a result, the LDR requirements
are also not applicable in terms of RCRA characteristic hazard-
ous waste.
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-31-
DioxinJLDRJB^^tajndarda_basedijupoii^analyai8_of—treated soi 1 have
been promulgated for soil and debris waste. (These standards
require the leachate from treated soils to be less than 1 ppb).
Therefore, EPA believes that the LDR standards for dioxin are
relevant and appropriate for this site.
EPA is undertaking an LDR rulemaking that will specifically
apply to soil and debris. Until that rulemaking is completed,
the CERCLA program will not consider LDR to be relevant and
appropriate (except for dioxin) to soil and debris that does
not contain RCRA restricted wastes.
Following compliance with the LDR treatment levels for dioxin,
the solidified soils would be redeposited back on-site in the
same unit of contamination from which they originated. The
area would then be covered (the cover material would have a
permeability less than or equal to the permeability of the
natural subsoils) and monitored consistent with the technical
requirements for RCRA Subtitle C closure and post-closure
(i.e., 40 CFR § 264.310). Under this approach, a double liner/
leachate collection system would not be required since; the
hot-spot soils would have been removed during closure for the
purpose of treating them to enhance the effectiveness of the
closure; and RCRA minimum (design and operating) technology
requirements (i.e., double liner/leachate collection system)
would not be triggered since a new unit is not being constructed
nor is replacement or lateral expansion of the existing unit
occuring. A groundwater monitoring program would also be
established for this remedy in accordance with RCRA regulations
40 CFR Part 264, Subpart F.
Since the solidified soil will remain on-site, the remedy will
be reviewed at least every five years consistent with CERCLA
Section 121 requirements, to ensure that human health and the
environment continue to be protected.
Solidification of the hot-spot soils will meet the greater than
1 ppb level of concern established for dioxin in soils at this site.
Surface water and groundwater are not contaminated at levels
exceeding the CRDLs and ARARs for some compounds. For other
compounds, however, the CRDLs exceeded either ARARs or other
guidance values considered. Consequently, additional sampling
of the groundwater was recently performed. The analysis of
these samples (with the lowest achievable levels of detection)
will determine whether groundwater ARARs and other criteria
considered are being exceeded.
•
EPA believes that soils solidification is an available and
reliable technology for the treatment of wastes types identified
at the 93rd Street School site. The treatability study would
ensure the site-specific technical feasibility and operational
reliability of the solidification process.
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The selected remedy is cost-effective since solidification of
the soils provides comparable effectiveness as the other
treatment options, but at a lower cost.
The selected remedy will satisfy the statutory preference for
remedies that employ treatment that reduces toxicity, mobility
or volume as a principal element. This will be accomplished
through solidification, which is expected to permanently
immobilize the soils and eliminate any potential for leaching
of both organic and inorganic contaminants. Solidification
will achieve protection through a reduction of the inherent
hazard posed by the contaminants in addition to controlling
exposure to residuals. The remedy will utilize permanent
solutions and alternative treatment technologies to the maximum
extent practicable.
To summarize, EPA and DEC believe that their selection of on-site
solidification/stabilization of the hot-spot soils (Alternative 4),
will satisfy .the statutory requirements of providing protection
of human health and the environment, will attain all ARARs,
and is cost-effective. Since this option utilizes solidification
to eliminate the principal threat at the site, this alternative
would also satisfy CERCLA preference for remedies which employ
treatment as their principal element to reduce toxicity, mobility
or volume of the contaminants at the site.
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ATTACHMENT B
New York State Department of Environmental Conservation
50 WoltRoad, Albany, Ne^Yort:l2233-=,~»——————--^—
Thomas C. Jorilng
Commissioner
Mr. Stephen D. Luftig
Director, Emergency and Remedial
Response Division
United States Environmental
Protection Agency
Region II
26 Federal Plaza
New York, New York 10278
Dear Mr. Luftig:
Re: 93rd Street School Site, Niagara Falls, Niagara County, Remedial
Investigation/Feasibility Study, Site No. 9-32-078
The New York State Department of Environmental Conservation (NYSDEC) has.
recently completed a Remedial Investigation/Feasibility Study (RI/FS) at the 93rd
Street School Site, Niagara Falls, Niagara County, New York.
The RI/FS work recommended that the following remedial measures be implemented
at this site: 1) Excavate and treat the hot spot soils. 2) Install a low
permeability cover over the hot spot soils and extended areas with lower
contaminated soils. 3) Monitoring of site. The NYSDEC endorses these
recommendations.
Since this site is a Federal Superfund site, it is NYSDEC's understanding
that: 1) One hundred percent of the remedial design costs for this project will be
eligible for federal funding. 2) the remedial costs will be divided 90% federal
and 10% non-federal and; 3) that the operation and maintenance costs for this
project will be eligible for federal funding for at least one year following
construction completion. After this period of time, the State of New York will be
responsible for assuring the operation and maintenance of the implemented remedies.
If you have any questions or comments regarding this matter, please contact
Mr. Robert W. Schick or Mr. Amarinderjit S. Nagi, of my staff, at (518) 457-4343.
f /*? .', •'-' i.
'••'' x ,. •j'-, - .-
< — „—"•'••/ /
Michael J. O'Toole, Jr., P.E.
Acting Director
Division of Hazardous Waste Remediation
AN/tv
cc: G.
J.
R.
Pavlou, USEPA-Reg.II
Singerman, USEPA-Reg.II
Howe, USEPA-Reg.II S
J. Loureiro, LEA
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ATTACHMENT C
REMEDIAL INVESTIGATION/FEASIBILITY STUDY
93rd STREET SCHOOL SITE
City of Niagara Falls, New York
Site No. 9-32-078
RESPONSIVENESS SUMMARY
Prepared By:
NEW YORK STATE
DEPARTMENT OF ENVIRONMENTAL CONSERVATION
50 WOLF ROAD, ALBANY, NEW YORK 12233
Thomas C. Jorling, COMMISSIONER
DIVISION OF HAZARDOUS WASTE REMEDIATION
Michael J. O'Toole Jr.. P.E. ACTING DIRECTOR
July 1988
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TABLE OF CONTENTS
Section Description
I. Introduction
II. Response to connents received during the public meeting
A. Site History
B. Site Contamination/Investigation
C. Remedial Alternatives
D. Preferred Alternative/Remediation
E. Solidification
F. Public Participation
G. Miscellaneous
III. Response to Written Comments
A. Niagara County Health Department
B. Occidental Chemical Corporation
IV. Response to Agency for Toxic Substances and Disease
Registry's (ATSDR) Health Consultantion
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A transcript of the Public Meeting held on April 13, 1988 is
available at the following locations.
New York State Department of Environmental Conservation
Division of Hazardous Waste Remediation
Room 222
50 Wolf Road
Albany, New York 12233-7010
New York State Department of Environmental Conservation
Public Information Office
9820 Colvin Blvd.
Niagara Falls, New York 14304
United States Environmental Protection Agency
Emergency and Remedial Response Division
Region II
26 Federal Plaza
Room 747
New York, New York 10278
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Section 1
INTRODUCTION
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INTRODUCTION
This report summarizes the public comments and the responses relative
to the Remedial Investigation/Feasibility Study (RI/FS) for the 93rd Street
School site in Niagara Falls, New York. This RI/FS was performed by
Loureiro Engineering Associates under contract with the New York State
Department of Environmental Conservation (NYSDEC). The purpose of this
RI/FS was to evaluate the nature and extent of site problems, identify and
evaluate potential remedial actions which could be implemented to mitigate
these problems, recommend an alternative and conceptually design the
recommended alternative.
During the remedial investigation, information was obtained on site
background and history, site features, hazardous substances present,
hydrogeology, groundwater and surface water contamination, and a public
health and environmental risk assessment was conducted. Based on the
information obtained during this investigation, it was concluded that the
groundwater and surface water at the site are not contaminated, above the
Contract Required Detection Limits (CRDL) as well as health based
standards for many compounds. For some compounds, however, the CRDLs used
during RI exceeded both the New York. State and USEPA drinking water
standards. In addition some compounds exceeded guidance values and
criteria considered. Additional sampling of these wells was conducted
during the end of May 1988 to confirm that groundwater ARARs are not being
exceeded.
Analysis of soils indicated that they are contaminated in varying
degrees with( heavy metals, volatile organics, base/neutral/acid extractable
organics and' alpha and beta BHC's. Approximately 3,000 cubic yards (cyd)
of fill material was reported to have been brought to the site in 1954 from
the 99th Street School site located adjacent to Love Canal. The fill
consists of fly ash and possibly pesticide cake, used to regrade a swale
located in the school yard. Although dioxin was not detected during this
investigation, it was detected previously by others in three isolated
surface soil samples and in one soil sample at a depth of 4 to 6 feet at
concentrations ranging from 0.11 to 2.3 parts per billion (ppb).
A risk assessment was also performed for the site and it was concluded
that significant risks are posed by the site in its unremediated condition
primarily due of the presence of Arsenic, Polynuclear Aromatic Hydrocarbons
(PAH) and 2.3.7.8 Tetrachlorodibenzo p-dioxin (Dioxin). As a result of
this risk assessment, a hot spot area containing about 7,500 cyd of soil
was identified at the site where Arsenic, PAHs and Dioxin are present at
significantly higher levels than identified in other contaminated soils at
the site.
Remedial action alternatives for addressing the potential exposure
pathways were developed during the feasibility study including a no action
alternative, two containment alternatives (i.e. on-site low permeability
cover and off-site RCRA landfill disposal of hot spot soils followed by
placement of a low permeability cover) and three treatment alternatives
(stabilization/solidification, on-site thermal treatment, and thermal
treatment at Love Canal). Each of these treatment alternatives involved
treatment of hot spot soils, followed by placement of a low permeability
cover over all identified contaminated soils at the s:.te. The final
alternatives were evaluated on the basis of the following criteria:
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- Protection of Human Health and the Environment
- Compliance with Applicable or Relevant and Appropriate
Requirements (ARARs)
- Reduction of Toxicity, Mobility or Volume
- Short-Term Effectiveness
- Long-Term Effectiveness and Permanence
- Implementability
- Costs
- Community Acceptance
- State Acceptance
Based on this evaluation, the alternative involving the treatment of
soils by solidification/stabilization was chosen as the preferred
alternative. The NYSDEC and the United States Environmental Protection
Agency (USEPA) held a Public Meeting on April 13, 1988 at the Frontier
Volunteer Fire Hall in the Town of Wheatfield, New York to obtain public
comments on the preferred alternative for remediation of the site.
A verbatim transcript of the public meeting was recorded as required under
Section 117 of Superfund Amendment and Reauthorization Act (SARA) and is
available at the NYSDEC Public Information Office in Niagara Falls, NYSDEC
Office at 50 Wolf Road, Albany and USEPA Region II office at 26 Federal
Plaza, New York City. Three public availability sessions were also held at
the NYSDEC Public Information Office, Love Canal, Niagara Falls on
April 14, 1988 to provide citizens an opportunity to discuss the project
with the project personnel on a one-to-one basis. A public comment period
for the submission of written comments was established until May 25, 1988.
All public comments received at the Public Meeting and during the comment
period are discussed in this Responsiveness Summary. This Responsiveness
Summary will be an attachment to the Record of Decision (ROD) which is
to be issued by the USEPA.
Copies of these documents and all pertinent project documents are
available for public information at the NYSDEC Public Information Office,
9820 Colvin Boulevard, Niagara Falls, New York, telephone (716) 297-9637.
Many concerns were raised during the April 13, 1988 public meeting
regarding different components of Love Canal Remedial Program, especially
the Black and Bergholtz Creeks Remediation Project. While effort was made
to respond to these comments during the public meeting, only the comments
relative to 93rd Street School site RI/FS have been addressed in this
Responsiveness Summary.
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A. /SITE HISTORY
Q. There was an old groundwater swale that came from the northwest corner
of the Love Canal site and cut across the 93rd Street School site. It
went right under the school and then continued across where 93rd Street
is now located. It then continued west through the backyards of the
homes on Shantz Avenue and emptied into the Bergholtz Greek. The swale
was filled In and we have a manhole back there. I think the
contamination could have come from the Love Canal through the swale and
through the backyards on Shantz Avenue. Why wasn't the swale ever
sampled on Shantz Avenue? Why wasn't a sample ever collected from that
manhole?
A. From the Board of Education records of the construction and
pre-construction periods, it has been determined that a drainage swale
crossed the site from southeast to the northwest and discharged into
the Bergholtz Creek. The soil borings and analysis showed reduced
quantities of fill and low levels of contamination on the western side
of the school building near 93rd Street. The present study, however,
concentrated on the 93rd Street School site between Bergholtz Creek on
north, Colvin Boulevard on south, 93rd Street on west and residential
properties on east.
Q. How do you know the contaminated soil came from the Love Canal?
A. During January 1954, the Niagara Falls Board of Education (NFBE)
authorized the hiring of a contractor to the transfer soils from the
99th Street School, adjacent to the Love Canal landfill, to the 93rd
Street School to be used as fill for low spots at the site. However,
whether this soil was contaminated is not documented.
Q. When you sampled for dioxin what was the size of the grid you used to
decide where your samples would be collected?
A. During the soil sampling effort in 1985, NUS Corporation under contract
to the USEPA, utilized two grids one on 80 ft. centers and the other on
10 ft. centers. These sampling locations are shown on drawing S-2 of
the RI/FS report.
Q. When was the 93rd Street School put into the Love Canal Emergency
Declaration Area (EDA)?
A. The 93rd Street School was located inside the boundaries of the Love
Canal Emergency Declaration Area when it was established in 1980.
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'Q.._.-Did anybody sample the bedrock? How deep is the bedrock?
A. The bedrock goundwater was not sampled nor were any bedrock monitoring
wells Installed under this Remedial Investigation. However, during
past investigations, (Engineering Investigations Phase II by RECRA
Research, Inc. in 1984) bedrock groundwater was sampled and found to be
within acceptable limits. The depth to bedrock was found to be about
25-27 feet.
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"ET^SIfE CONTAMINATION/INVESTIGATION
Q. Howmany cubic yards ofcontaminatedsoil do you have?
A. As a result of the studies completed during the RI/FS, it is estimated
that a maximum of 7,500 cubic yards of contaminated material requiring
treatment are at the 93rd Street School site.
Q, Did you find dioxin at the site?
Did others find dioxln at the site? If so.how much? How far down In
the sol 1 was i t?
A. During the remedial investigation, dioxin was not found in soil or
groundwater samples. Oioxin was detected in soil during previous
studies performed by others. These locations are indicated on maps in
the RI/FS report and are summarized as follows:
- Recra Research, Inc. found dioxin during the Phase II Investigations
in one soil sample taken 'during the installation of monitoring well
Na. 4 at a depth of 4-6 feet. The concentration of dioxin in this
sample was 2.3 ppb.
- During investigations by NUS Corporation, three out of 60 soil
samples showed the presence of dioxin at concentrations of 1.2, 0.11
and 0.19 ppb.
These locations are included within the hot spot area to be remediated
(treated) as part of this project.
Q. Vlhat contaminants are actually present at the 93rd Street School
Site?
Is the chemistry of the 93rd Street School site similar to the Love
Canal wastes?
A. Some of the chemicals detected in the 93rd Street School Site soils are
reported to have been deposited in Love Canal and are also found in the
Love Canal Leachate Treatment Facility influent. These include
antimony, arsenic, cobalt, copper, methylene chloride, chloroform,
1,1,2-2, tetra chloroethane, toluene, ethylbenzene, 1-4
dichlorobenzene, naphthalene, fluoranthene, pyrene, bis(2-etylhexyl
phthalate) and alpha BHC.
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Q. Why did other people find dioxin and you didn't?
Why didn't you sample for dioxin in the same area where the others
found dioxin before?
A. Areas at the 93rd Street School Site which were sampled during previous
studies (including the creek banks, surface soils, and soils in the
vicinity of some existing monitoring wells) were not resampled during
the remedial investigation for the following reasons:
- the findings of the previous studies were considered to be accurate
- application of the sampling and analysis in the areas described above
was considered unnecessary
In the areas which were sampled during the Remedial Investigation,
dioxin was not detected. Since these samples were collected from
locations not sampled previously, the results are not considered to be
contradictory.
Q. What makes you think the dirt from the 99th Street School was
contaminated? Where did the idea that it was contaminated come from?
The dirt brought from the 99th Street School was placed on top of the
flyash. That's why your sample shows your chemicals are four feet
below the ground surface because that was clean dirt from the 99th
Street School that had nothing to do with contaminants.
A. There is no record of this material having been tested before being
used as fill at the 93rd Street School Site. Therefore, it is .
difficult to say with confidence whether the material brought from Love
Canal was or was not contaminated.
Q. How dangerous is dioxin to humans? How many people died from it?
How far from dioxin should humans be?
A. Dioxin is considered to be a toxic substance and is a suspected
carcinogen. It's effects include gastric ulcers, spleen and kidney
damage, respiratory tract and nervous system damage and teratogenicity.
No reported deaths can be directly attributed to dioxin exposure.
Q. If this area is contaminated, why isn't it fenced off?
A. The remedial investigation report, as well as reports on investigations
conducted in the past, were reviewed by the New York State Department
of Health (NYSDOH). It was considered that the present situation did
not warrant fencing the site to restrict public access. During
remediation of the site, work areas will be fenced to restrict access
to machinery and exposed soils.
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Q. How large is the contaminated area at the site?
A. The hot spot area proposed for excavation encompasses approximately 3.5
acres.
Q. Are there radiation hot spots in the 93rd Street School site area. Is
there any documentation about this?
A. The available data and reports do not indicate the presence of any
radioactive hot spots. NYSOOH during a sampling effort in 1979-80
concluded that no significant levels of beryllium were present in the
511 samples collected from site. No readiation sampling was performed
as part of the study.
Q. Could any contamination from the 93rd Street School site be entering
the sewer system on 93rd Street? They are always pumping on the corner
of Colvin Boulevard and 93rd Street.
A. The present investigation did not indicate any connection of the site
to the sewer system. The site drainage presently is provided by the
gentle slope towards the swale which runs across the middle of the site
and discharges to the Bergholtz Creek.
Q. If you find contaminated groundwater at the site, you'll have to pick a
remedy; what if the contaminated groundwater remedy interferes with the
contaminated soils remedy?
A. Existing data from wells on the site do not indicate any significant
groundwater contamination problem; however, if unacceptable levels of
groundwater contamination are found, adjustments to the proposed
solidification/stabilization alternative may be required. It is not
anticipated, however, that adjustments will be necessary. If any
groundwater remediation technologies are required, they will be
carefully selected and this remediation will be the subject of a
subsequent Record of Decision (ROD).
Q. Which are the upgradient and downgradient monitoring wells? Why
weren't you sure which type of well they were?
A. The monitoring wells where the groundwater level is at a higher
elevation are called upgradient wells while the wells with a lower
groundwater level are called downgradient. These terms are used to
depict the flow of groundwater and in establishing the groundwater
contours. Monitoring of groundwater levels over time and evaluating
the data will further confirm which wells are upgradient and which are
downgradient at the site. Before the wells are installed, designation
as upgradient or downgradient is based on site features, previous
investigations and nearby water bodies.
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Q. Once you resample the groundwater monitoring wells and analyze the data
will you extend the public comment period if you find anything?
A. We do not intend to extend the comment period for the RI/FS to wait for
the analytical results, since they are intended as confirmatory. If,
however, problems requiring remediation of the groundwater are
discovered a ROD detailing any remedial actions needed to address the
problems, with all attendant community participation, will be prepared.
Q. Why don't you collect your additional groundwater data before you
select a remedy?
A. Previous groundwater sampling did not detect contaminatnts in the
groundwater, however, the detection limits for certain compounds did
not allow confirmation that groundwater standards for these compounds
were not being exceeded. This round of sampling will allow such a
determination to be made. Since a problem is not anticipated, it was
decided not to delay remedial design at this time. The groundwater
samples from the monitoring wells at the 93rd Street School site were
collected during the last week of May 1988 and sent for analysis. The
data from the laboratory is expected to be available for the
engineering consultant during the remedial design phase of the project.
Q. Are you going to retest the monitoring wells?
A. The monitoring wells have already been retested. Groundwater samples
were collected from the 13 monitoring wells at the 93rd Street School
site during the week of May 23, 1988 and sent to the laboratory for
analysis.
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C. REMEDIAL ALTERNATIVES
Q. Why don't you excavate the contaminated soil and take it to a hazardous
waste landfill? That would be a permanent solution.
»
A. An alternative to dispose of the 93rd Street School Site soils at an
approved off-site facility was evaluated during the Remedial
Investigation and Feasibility Study and was found to be unimplementable
due to the difficulty of finding a facility that will accept waste from
the Love Canal Emergency Declaration Area (EDA) and meeting RCRA Land
Ban Requirements. In addition, the treatment of wastes as opposed to
their containment is a preferred alternative. Landfill ing of untreated
waste is not considered a permanent solution.
Q. Could we use the same incinerator being used for treating the creek
sediments to destroy the 93rd Street School site contaminants even
though there are heavy metals at this site?
A. An alternative to treat the 93rd Street School site soils using the
proposed thermal treatment unit at Love Canal has been evaluated in the
RI/FS Report. This alternative was determined to be less effective
than the alternative involving treatment of soils by solidification/
stabilization due to possible difficulties in thermally treating the
metals.
Q. Why don't you build an interim containment facility at the Love Canal
site for the contaminated soil at the 93rd Street School site? You
could still solidify these materials later.
A. Construction of a separate storage facility at the Love Canal site for
temporary storage of soils from the 93rd Street School site was not
considered for the following reasons:
- it is impractical to transport the soils to Love Canal if the soils
are to be stabilized/solidified at the 93rd Street School site.
- if the-contaminated soils from the 93rd Street School site are to be
treated using the proposed transportable thermal unit at the Love
Canal site, it will be more economical to temporarily store the
soils from the 93rd Street School site at the Dewatering Containment
Facility to be built under the contract for the Black and Bergholtz
Creeks remediation.
Q. OCC proposed storing wastes in bags for years. Have you considered
this option?
A. NYSDEC does not consider storage of waste in plastic bags, as proposed
by OCC, as a permanent solution to remediation of a site.
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Q. Is Incineration feasible if you have metals present?
A. Yes. However, the presence of metals may require additional handling
and/or disposal requirements, as well as the need for special
operating conditions during the operations of thermal process.
Treatment of 93rd Street School site soils containing metals using a
thermal treatment unit was considered and fully evaluated in the
feasibility study report.
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D. PREFERRED ALTERNATIVE/REMEDIATION
Q. When you place the soil cover on the site you'll change the elevation
or the ground in that area. Water running off the site will flow
towards the creek and towards Colvin Boulevard and 93rd Street. Did
you take any flood control measures? Will Colvin Boulevard and 93rd
Street be able to handle the runoff from the site?
A. During Remedial Design, the Engineer will be required to address issues
such as providing adequate surface drainage and flood control measures.
Runoff to 93rd Street and Colvin Boulevard will be calculated, and the
existing drainage system will be analyzed to determine if it has
adequate capacity or must be modified to accommodate this flow.
Q. As an additional precautionary measure, why don't you place a 40 or 60
mil liner over the area that's being covered or at least over the hot
spots? Clay isn't as impermeable as people think.
A. The Remedial Design Engineer will consider the feasibility*of using
different materials, including clay and/or a synthetic liner as cover
for the site.
Q. Will the solidified soil be properly compacted when it is replaced so
that you don't create voids and possibly trap water in that area? When
. will you decide whether the solidified material will be a brick, a slab
or some other form? Will the public know about it before it is done?
A. The consistency and form of the final product after the treatment of
soil at the 93rd Street School site is technology/vendor dependent.
The vendor will be required to ensure that significant voids are not
created and backfilling is done per the requirements specified in the
contract. More data on the particular vendor and the process will be
made available for public information as it becomes available during
the remedial design and construction stages of the project.
Q. Are you going to monitor this project after you solidify this material?
If so, for how long?
What kind of monitoring program will this be?
A. Following implementation of the solidification/stabilization
alternative, the site will be monitored. The details of the monitoring
program will be developed during the remedial design phase of the
project. It is anticipated that monitoring will include periodic
groundwater sampling, site inspections and detailed site evaluations.
This monitoring program will be subject to public review and comment.
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Q. How were you able to select a remedy without having all the groundwater
data available?
A. No contamination above the contract required detection limits (CRDL) as
well as the health based standards for some compounds has been detected
in groundwater during these investigations. For other compounds,
however, the CRDLs used during RI exceeded the drinking water
standards, guidance values and criteria considered. Consequently
sampling with the low detection limits of the groundwater was again
conducted during May 1988 to determine whether groundwater ARARs are
being exceeded. This resampling of groundwater is to satisfy the
requirements of the Superfund Amendment and Reauthorization Act (SARA).
If unacceptable levels of contamination are detected in the
groundwater, adjustments to the treatment technology (solidification/
stabilization) could be required during the design phase, however, no
major adjustments are anticipated. If groundwater remediation becomes
necessary, it will be addressed in a subsequent ROD.
Q. .How deep will you excavate?
A. The hot spot soils were determined to be up to 6 feet in depth. For
the purposes of the RI/FS report, it was estimated that the depth of
the proposed solidification/stabilization treatment will extend to at
least one foot below the depths of the hot spot soils. Therefore,
unless changes are deemed necessary during the remedial design, hot
spot soils will be solidified/stabilized to a maximum depth of seven
feet.
Q. On your map you show some dioxin hot spots along the creek bank. Is
that a part of the creek cleanup or will that be cleaned up under the
93rd Street School site cleanup program?
A. The remediation of the Bergholtz and Black Creek beds and banks is
covered under the Creek Remediation Project which is underway. The
93rd Street School site does not include the creek banks. Any dioxin
above one ppb outside the limits of excavation of the creeks will be
handled under the 93rd Street School Remediation.
Q. Why don't you use a better soil type such as clay as a cover?
A. The selection of the type of soil cover, its thickness, slopes, etc. is
part of the remedial design for the 93rd Street School site. The
remedial design for this project is expected to begin in late fall of
1988. The remedial design will be subject to public review and
comment.
Q. How much soil will be placed over the solidified materials?
A. The actual depth of soil to be placed over the site will be determined
during the remedial design stage of this project however, it will be a
minimum of one foot in depth. The remedial design for this project
will be subject to public review and comment.
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Q. Will any trees be cut down during the 93rd Street School remediation?
A. No trees are expected to be cut under the 93rd Street School site
remediation project. The trees along the Bergholtz Creek banks may be
cut down as part of the remediation of the Creeks.
Q. When you complete your treatment of the soil and put it all back, could
I build a house there? Would the land be safe enough for anybody to
build a house on?
A. Although the remediation of the site.will immobilize the contamination
present at the site and limit contact with the treated soil, land use
restrictions may still be applicable to prevent or control excavation
at the site. The specific details of any restrictions to be imposed
will depend on the selected solidification/ stabilization process.
Land use restrictions will consider the physical properties of the
treated soil which may limit building on the property, as well as other
factors such as the final design of the cover.
Q. Once the work gets started, how long will it take to complete?
When will you start the actual cleanup project?
A. The time to complete remediation of the site by way of the
. solidification/stabilization technology is expected to be approximately
36 months from the signing of the Record of Decision (ROD) for the 93rd
Street School site. Delays in the creek remediation project will
negatively affect this estimate. Construction will not begin until the
completion of the Creek remediation project, which means the
solidification/stabilization is expected to begin during the 1990
construction season and should be completed in one construction season.
The detailed schedule will be worked out during the remedial design
phase of the project.
Q. Will the 93rd Street School site remediation be done before the Black
and Bergholtz Creek cleanup is done?
A. Due to the fact that part of the 93rd Street School site is being used
as staging and access for the creek remediation project, it will not be
possible to implement the remediation at 93rd Street School site until
after the creek remediation is completed. The creek remediation is
scheduled for completion by end of 1989.
Q. VJill it be safe to walk across the area when this is done?
A. Yes. It will be safe to walk across the site ones the remedy is in
place.
- 13 -
-------
Q. If I walk across a dioxin-contaminated spot right now will I have any
-:-;--ill-effects from walking across it?
A. Based on the data available for the site it is unlikely that walking
across the site would pose a significant threat to human health.
-------
E. SOLIDIFICATION
Q. Is solidification considered a permanent remedy?
Is chemical fixation a permanent solution? I've been told contaminants
will dissolve out.
How long will the contaminants stay fixed after they've been treated?
A. The literature from the various firms working on stabilization and
solidification technologies indicates that the technologies are capable
of locking contaminants both physically and chemically into an
unreactive product. This is accomplished by use of chemical additives
such as silicates, setting agents, etc. which chemically react with
contaminants. Once treated the contaminants should remain immobilized
even if the treated material physically breaks down. During the
Oremedial design phase, the stabilization or solidification contractors
will be required to demonstrate that their technologies are capable of
effectively treating the soils from the 93rd Street School site through
bench scale and/or pilot scale tests.
Q. Has this treatment ever been used any place else?
A.. Various companies dealing with solidification and stabilization such as
Hazcon, Soliditech and Chemfix have been in this business for several
years and have treated industrial wastes containing heavy metals and/or
complex organics for different industries including Amoco Oil,
Monsanto, Mobil Chemical and Atlantic Richfield at various locations
across the U.S. This technology has also been recently utilized as
part of a remedial clean up at other CERCLA sites (eg, Peppers Steel
and Alloys site, Florida). Futher solidfication/stabilization
technology has been demonstrated as part of the USEPA Site Program, and
has been selected as a remedy for other CERCLA sites.
Q. Is this just an experiment?
A. Since solidification and stabilization technologies have been used in
the past for treating different industrial wastes, it is not^considered
an experimental technology.
Q. Do you know if solidification will work?
A. The literature on these technologies indicates that solidification/
stabilization technologies can be used effectively to treat the soils
at the 93rd Street School site. However, during the remedial design
phase, the contractors will be required to demonstrate through bench
and/or pilot scale testing that their solidification/stabilization
processes are capable of effectively treating the soils at the 93rd
Street School site. Information about this technology has been
provided in the RI/FS report and in hand outs made available by NYSDEC
during and after the Public Meeting.
- 15 -
-------
J^. Can citizens'receTve information on the different solidification
processes?
A. Copies of literature on different solidification/stabilization
techniques being considered for the 93rd Street School site are
available at the New York State Department of Environmental
Conservation, Public Information Office, 9820 Colvin Boulevard, Niagara
Falls, New York, telephone (716) 297-9637.
Q. How can citizens comment on these solidification processes if they do
not have enough information to tell them if it works?
A. Literature on the different solidification/stabilization techniques has
been available at the NYSDEC Public Information Office, 9820 Colvin
Boulevard, Niagara Falls, New York since April 13, 1988. In addition,
once a solidification/stabilization process is selected and pilot data
(testing data) is generated, this information will be made available to
the public.
Q. When you replace the solidified contaminants, how far down will it be
buried?
A. It is anticipated that the depths to which the solidified/stabilized
soils will be placed will correspond to the proposed depths of the
excavated hot spot area. Since the selected solidification/
stabilization technology will be capable of immobilizing permanently
the contaminants in the hot spot soil, the treated soils will be placed
in the same area from which they were excavated. As an added
precaution, a low permeability cover will be placed over the treated
soils.
Q. Will solidification completely remove the potential hazards from the
entire contaminated area?
A. The treatment of contaminated hot spot soils by way of solidification/
stabilization is intended to immobilize permanently the contaminants.
The hot spot area and the remaining area with lower levels of
contamination will be covered with a low permeability cover. This will
decrease the potential hazard from the area to what is considered an
"acceptable" risk level.
Q. What is the stabilization/solidification process? What type of
equipment does it use to treat the contaminated materials?
A. Specific procedures and equipment used for each stabilization/
solidification process differ. In general, the basic procedure will be
similar to that described below:
- excavation of soils
- feed soil into enclosed mixers along with process additives
- 16 -
-------
calculation of the median only takes into account the relative rank
of^ke measured concentrations, not their actual value. If the
maximum concentrations were viewed as outliers (i.e., anomalous
values which are not representative of concentrations at any
location on the site), which is apparently ATSDR's view of the
maximum values, the use of median concentrations as representative
of site conditions might be appropriate. However, for almost all of
the contaminants of concern at this site, the maximum concentrations
are less than an order of magnitude higher than the next highest
concentration. As a result, use of the mean is more appropriate.
This would result in somewhat higher site concentrations, e.g., the
median overall site concentration for arsenic is listed as 5.3 ppm
in the ATSDR comments while the mean concentration over the entire
site and all depths is 17 ppm.
11. pp. 5-6 - ATSDR's evaluation of the volatile organic chemicals
confirms the conclusion of the RI/FS risk assessment that these
chemicals do not pose significant potential to induce adverse health
impacts. It should be noted, however, that by relying on Life Time
Health Advisories from the U.S. EPA Office of Drinking Water as
benchmarks for health concern, ATSDR is focusing only on noncancer
*
health effects. Similarly, work place guidelines frequently are not
based on carcinogenic health impacts. However, several of the
chemicals on ATSDR's VOC list (including two for which no guidance
values are given in ATSDR's table) are suspected carcinogens with
cancer potency factors established by EPA (i.e., methylene chloride,
-------
geographic location of concern. The information provided by ATSDR
in its comments is insufficient to allow detailed evaluation of the
appropriateness of the data cited.
In addition, ATSDR uses the maximum reported "background"
concentration as the benchmark for judging the acceptability of
concentrations found at the site.2 This is particularly fallacious
in the second step of ATSDR's screening process where site
concentration medians are compared with maximum literature values.
Because natural levels can vary so widely, it is quite possible
that average concentration levels at a contaminated site could be
less than maximum concentrations reported for a site with naturally
elevated concentrations. Average site concentrations should be
contrasted with average "background" concentrations from an
appropriate comparison location.
10. p. 4, ^3 - ATSDR's use of median rather than mean
concentrations also tends to minimize the impact of high
concentrations in evaluation of site concentrations because
2It should also be noted that in addition to the
methodological deficiencies in the use of background data discussed
in Comment #9, ATSDR appears to have incorrectly applied its own
procedure. Specifically, magnesium appears to have been incorrectly
identified as a substance of concern (maximum reported literature
concentration = 9,000; median site concentration - all samples =
4,095 ppm; 0 to 1 foot = 7,850 ppm). Similarly, the median site
concentration of cadmium (3.5 ppm) is stated to be well below the
maximum literature value of 194 ppm. In fact, this value (194 ppm)
is the maximum literature value listed for arsenic, and the actual
literature maximum listed for cadmium (7 ppm) is very close to the
site median.
7
-------
(e.g., construction). According to the authors of the risk
assessment, this value was replaced in later calculations by 2.5
times the background level (0.150 mg/m3).
8. p.8 - As reflected in the conclusions of ATSDR's comments,
their review focused on the potential health risks posed by
contaminants in surface soils and made much of the fact that the
highest concentrations at the site were found in deeper soils.
Their assessment thus is incomplete as this view ignores potential
disturbances at the site (e.g., construction) which could uncover
the deeper contaminants and thus increase potential exposures and
risks at the site.
Comments Regarding ATSDR's Methods
9. p. 4, f.*Il-3 - ATSDR uses "typical background" concentrations
as a means of screening the metals data for the site for substances
of concern. Their method largely confirms the conclusions of the
RI/FS regarding the elements of potential concern. However, as
discussed in the responses to OCC's comments on the RI/FS,
background concentrations must be used carefully and must represent
appropriate comparisons. For metals in particular, differences in
natural levels can vary widely among geographic locations. This can
be seen in the data presented by ATSDR which contains ranges for
4
some metals which span up to three orders of magnitude. The most
appropriate comparison data, where available, are those from the
-------
"concentrations of total PAH in residential surface soils less than
100 mg/kg do not pose a significant threat to human health by any
route of exposure." The risks posed by total PAHs are highly
dependent on the specific composition of the PAHs of concern. For
example, if the PAHs being considered were 100% benzo(a)pyrene, a
soil concentration of 100 mg/kg would yield a cancer risk of
2.4 x 10~4 for the ingestion scenario presented for the undisturbed
site in the RI/FS. The risk level would be correspondingly less for
lower percentages of carcinogenic PAKs. The mean site
concentrations indicate a total mean surface soil concentration for
the five carcinogenic PAHs considered in the RI/FS of 3.03 mg/kg.
Using this concentration, the exposure scenarios developed in the
RI/FS for the undisturbed site yield risk estimates of 7.3 x 10~6
and 5.4 x 10~° for ingestion and inhalation, respectively.
Moreover, while ATSDR is correct that many of the sample analyses
for PAHs were non-detects, its comments fail to recognize that
almost all of the detected concentrations of PAHs are clustered in
the "hot spot" area proposed for remediation, increasing the
potential exposures and risks posed by that portion of the site.
7. p. 7, !l!l3-4 - ATSDR incorrectly states that the 10 mg/m^ air
particulate level was used to estimate long-term exposures via air.
In fact, long-term exposures to site-related particulates v/ere
based on annual average particulate measurements for Niagara Falls
(0.0525 mg/m3). The higher level was only used in initial risk
calculations for evaluating air impacts during site disturbance
-------
addition, maximum concentrations were only used for the ingestion
scenarios; average concentrations were used for the inhalation
scenarios. Moreover, even if average concentrations are used in the
ingestion scenarios, total carcinogenic risks of 2.6 x 10~5 and
7.1 x 10~5 are derived for the undisturbed (surface soils) and
disturbed (soils at all depths) site scenarios, respectively (see
responses #9 and #11 to OCC comments).
5. p. 5, «14 - The Binder et al. study cited by ATSDR in support
of its contention that soil arsenic levels at the site1 do not
present a health concern relates soil arsenic concentrations to
measures of exposure, not health impact. The health impact of
concern following arsenic ingestion is development of skin cancer.
Failure to induce elevations in urinary arsenic levels does not
necessarily mean that no adverse health impacts will be induced.
Using average soil concentrations at the site and the current U.S.
EPA cancer potency factor for arsenic ingestion, risk estimates of
1.6 x 10~° and 5.7 x 10"3 are obtained for the undisturbed and
disturbed site scenarios, respectively. ATSDR also has ignored the
potential for inhalation of arsenic on windblown dust from the site.
Risk estimates for the site for arsenic inhalation are 6.0 x 10"^
and 2.8 x 10~7 for the undisturbed and disturbed site, respectively.
6. p. 1, ?I*Il-2 - ATSDR provides no health-based, technical
justification either for dismissing the potential health impacts of
PAH levels detected at the site or for its statement that
-------
that the...fill...contains dioxin." ATSDR further states that
conversion of the site to residential use should not be impeded by
dioxin concentrations detected at the site. However, as
acknowledged in ATSDR's comments, earlier sampling detected dioxin
in one subsurface and three surface samples, as well as on the banks
of Bergholtz Creek. The subsequent study undertaken during the
RI/FS does not negate the observations of the prior study for
several reasons. For example, the sampling plan undertaken as part
•
of the RI/FS specifically omitted surface soils in the areas where
dioxin had previously been sampled for and found, and instead
focused on subsurface samples. In addition, the study used
composite samples which could dilute any dioxin present at localized
depths. As a result of this sampling plan and the use of composite
samples, together with the analytical difficulties in detecting low
concentrations of dioxin, the failure to detect dioxin in this round
of sampling cannot be interpreted as negating prior observations. A
further concern is that because of dioxin's high carcinogenic
potency even extremely low concentrations can pose potentially
significant risks.
4. p. 3 , *I5 - ATSDR incorrectly states that the RI/FS risk
assessment did not include exposure considerations and only used
maximum contaminant concentrations in developing risk estimates.
In fact, many contaminants (e.g., volatile organics in soils) were
eliminated from detailed risk calculations because they were only
present at a few site locations or only at low concentrations. In
-------
routes are of concern under existing conditions." No quantitative
justification is provided for this conclusion. Moreover, this
conclusion can be challenged by quantitative risk estimates of
concern developed using the RI/FS exposure scenarios for the
undisturbed site and average surface soil concentrations of arsenic,
TCDD, and PAHs (2.6 x 10~5 and 6.1 x 10~6, for ingestion and
inhalation, respectively). ATSDR'?. view also ignores the
possibility of future site disturbance and exposures to more highly
contaminated soils.
2. p. 3, ?1 - ATSDR states that "there is no apparent route of
exposure that exists between the chemicals and the people in the
community." It is ambiguous from the context of this statement
whether it is referring only to ground water contaminants or to
contaminants in soil as well. Current observations of children
playing on the site, as well as other recreational uses, suggest
that ingestion and inhalation exposures to soil contaminants are
occurring.^ Other on-site and off-site exposures to soil
contaminants may also occur. While ground water exposures appear
less likely, exposures could occur via contacts with contaminants
transported to Bergholtz Creek.
3. p.3, *I2 - Based on the non-detect results of the most recent
dioxin analyses, ATSDR states that there is "no apparent evidence
1A.M. Gabalski (NYSDEC). June 29. 1988. Memorandum to 93rd
Street School Site Administrative Record Re: Recreational Use of
the 93rd Street Site.
-------
July 20, 1988
93rd Street School, Niagara Falls
Response to ATSDR Comments (Memo to W.Q. Nelson, 5/16/88)
In general, ATSDR's health consultation is too limited in scope to
comprehensively address the health risk issues at the site.
Various screens, e.g., comparisons with "background"
concentrations, are applied to the site data to eliminate certain
substances from further evaluation with no consideration of the
inherent toxicity of the eliminated substances or the risks which
may be posed by "background" concentrations or simultaneous
exposure to multiple chemicals. In addition, health criteria used
to evaluate the acceptability of concentrations present at the site
are based on noncancer health effects, even for substances for which
estimates of carcinogenic potency are available. Finally, ATSDR's
evaluation focuses on the undisturbed site and surface soil
concentrations, ignoring the potential for site disturbance and
subsequent exposure to deeper, more contaminated soils. Specific
comments follow.
Comments Regarding ATSDR's Conclusions
1. p. 2, «il - ATSDR states that maximum concentrations of the
compounds of concern were found in subsurface samples and that
because of this "it does not appear that any of [the] exposure
-------
TABLZ 5. POLYNTJCLEAR AROMATIC HYDROCARBON RESULTS
FOR 0 TO 1 FOOT SAMPLES FROM 93RD. STREET SCHOOL SITE
CHEMICAL HIGHEST MEAN NUMBER OF
CONCENTRATION CONCENTRATION NONDETECTS
ug/kg
naphthalene 16J 13J 12 of 15
2-methylnaphtalene - - 15 of 15
acenaphthene 96J 83J 13 of 70
dibenzofuran 9,600 4,820 13 of 15
flourene 120J 90J 13 of 15
phenanthrene 1,300 515 8 of 15
anthracene 270J 116J 10 of 15
fluoranthere 1,900 536 6 of 15
pyrene 3,000 852 7 of 15
benzo(a)anthracene 1,200 695 11 of 15
chrysene 1,400 635 9 of 15
benzo(b)fluoranthene 1|100 502 10 of 15
benzo(k)fluorar.thene 900 707 12 of 15
benzo(a)pyrene 1,000 710 12 of 15
lndeno(l,2,3-cd)pyrene 650 487 12 of 15
b«nzo(g.h.i)perylene 830 765 13 of 15
-------
TABLE 4. CONCENTRATION OF ORGANIC CHEMICALS
FOUND IN SOIL SAMPLES AT THE 93RD. STREET SCHOOL SITE
CHEMICAL
1,4-dichlorobenzcne
naphthalene
2-methylnaphtalene
acenaphthene
dibenzofuran
flourene
phenanthrene
anthracene
fluoranthere
pyrene
benzo(a)anthracene
bis(2-ethylhexyl)phthalate
chrysene
benzo(b)fluoranthene
benzo(k)fluoranthens
benzo(a)pyrene
indeno(l,2,3-cd)pyrene
benzo(g,h,i)perylene
alpha BHC
beta BUC
HIGHEST
CONCENTRATION
NEXT HIGHEST
CONCENTRATION
NUMBER OF
NONDETECTS
830
1,500
910
11,000
62,000
14,000
82,000
22,000
45,000
56,000
26,000
630
24,000
31,000
4,900
19,000
8,200
2,000
20
137
720
520
240
1,800
9,600
2,500
14.000
4,300
9,400
20,000
6,500
210
5,700
3,600
4,200
4,300
2,100 '
870
13
34
64 of 70
57 of 70
60 of 70
64 of 70
64 of 70
63 of 70
47 of 70
59 of 70
47 of 70
46 of 70
57 of 70
21 of 70
54 of 70
55 of 70
61 of 70
59 of 70
63 of 70
65 of 70
67 of 70
64 of 70
-------
TABLE 3. CONCENTRATION OF VOLATILE ORGANIC CHEMICALS
FOUND IN SOIL SAMPLES AT THE 93RD. STREET SCHOOL SITE
CHEMICAL
HIGHEST
REPORTED
tig/kg
nethylene chloride 7,700
acetone 4,500
1,1-dlchloroethene 670
chloroform 1,100
2-butanone 5,300
1,1,2,2-tetrachloroethane 1,600
toluene
ethylbenzene
xylenes
13.000
1,600
2,000
NEXT
HIGHEST
,400
,000
ND
,100
,500
520
,100
,500
1,800
NUMBER 0?
NONUSTECTS
13 of 68
35 of 68
67 of 68
26 of 68
38 of 68
66 of 68
41 of 68
46 of 68
46 of 68
GUIDANCE
LTHA (1)
no value
no value
35,000
500,000
850,000
no value
12,100,000
3,400,000
2,000,000
Guidance value obtained by assuming that a child might ingest 0.5
grams of contaminated soil per day for s 0,4 part of the year and the
Life Time Health Advisory (LTHA) publish by EPA, Office of Drinking
tater, March 1987.
-------
TABLZ 2. COMPARISON OF NE2T HIGHEST REPORTED VALUE,
MEDIAN FOR ALL VALUES, AND MEDIAN OF 0 TO 1 FOOT VALUES
FOR THE 93RD. STREET SCHOOL SITE SOIL SAMPLES
ELEMENT
MAXIMUM SITE
CONCENTRATION
(PP»>
NEZT HIGHEST
CONCENTRATION
antimony
arsenic
cadmium
magnesium
mercury
molybdenum
thallium
Zinc
209
350
133
42,000
23
229
1.2
18,200
92
105
11
33,900
21
132
MEDIAN
ALL SAMPLES
agAg
41.2
5.3
3.5
4,095
0.13
70.5
MEDIAN
0 TO 1 FOOT
22.6
4.5
2.4
,850
0.14
76
NO OTHER POSITIVE VALUE DETECTION LIMIT 1.1 TO 3.7
182 84.5 82
-------
Parr, James F., Marsh, Paul B., Kit., Joanne M. , Land Treatment of
.Hazardous Wastes, Agricultural Environmental Quality Institute,
Agricultural Research Service, USDA, Beltsville, Maryland, Noyes Data
Corporation, Park Ridge, Nev Jersey, 1983.
Shaklette, H. T. , et al., Elemental Composition of Surficial Material
in the Conterminous United States, USGS Professional Paper 574-D 1971.
Lechler, T. J., et al., "Major and Trace Metal Analysis of 12
Reference Soils by Inductively Coupled Plasma-Atomic Emission
Spectrometry." Soil Science 130 238-241, 1980.
-------
TABLE 1. COMPARISON OP 93RD. STRZZT SCHOOL SITE
MAXIMUM SOIL CONCENTRATIONS TO SOIL VALUES REPORTED
IN THE LITERATURE FROM UNCONTAMINATED AREAS
ELEMENT
MAXIMUM SITE
CONCENTRATION
CONCENTRATION
RANGE IN US SOILS
TYPICAL MEDIAN SOURCE
mg/kg
71.000
6
11
500
0.3
0.5
24,000
100
8
30
40,000
29
5,000
1,000
0.098
2
50
14,000
0.4
0.4
0.2
5,000
100
90
1. Boven, H. J. M., Environmental Chemistry of the Elements. Academic
Press, New York. 1979.
2. Ragaini, R. C., «t al., "Environmental Trace Contamination in Kallog
Idaho Near Lead Smelting Couples." Envir Sci and Tachnol 11 773-780
1977
3. Liak, D. J., "Trace Metala in Soils, Plants, and Animals." Adv Agron
24 267-311, 1972.
4. "Geochemistry of Some Rocks, Soil, Plant and Vegetables in the
Conterminous United States," Geological Survey Professional Paper 574
F 1975
5. Ure, A. M., et al., "Elemental Constituents if Soils" Environmental
Chemistry, Vol 2, pp 94-204 ad H. J. M. Bowen, Royal Society of
Chemistry, Burlinghouse, London, U.K. 1983.
aluminum
antimony
arsenic
barium
beryllium
cadmium
calcium
chromium
cobalt
copper
iron
lead
magnesium
manganese
mercury
molybdenum
nickel
potassium
selenium
silver
thallium
titanium
vanadium
zinc
10,700
209
350
565
3.
133
202,000
516
52
44
86,600
177
42,000
3,000
23
229
47
3,550
4.
3.
1.
825
59
18,200
4
1
2
2
10,000 -
0.2 -
0.1 -
100 -
0.01 -
0.01 -
< 150 -
5 -
0.05 -
2 -
100 -
< 1 -
400 -
20 -
0.01 -
0.1 -
0.1 -
80 -
0.1 -
0.01 -
0.1 -
150 -
3 -
1 -
300,000
150
194
3,000
40
7
500,000
3,000
65 -
250
550,000
888
9,000
18,300
4.6
40
1,530
37,000
38
8
0.8
25,000
500
2,000
1
1
5
1
1
6
1
6
1
1
1
5
1
1
5
1
1
1
1
5
1
1
1
1
.2.3 & 4
and 7
and 5
. 3 & 6
and 6
and 5
and 6
, 6 & 7
and 5
-------
Page 8 - Mr. William Q. Nelson
CONCLUSIONS AND RECOMMENDATIONS
It is the opinion of ATSDR:
That the concentration of arsenic and all other metals found in
the surface soils pose no threat to human health by any route of
exposure.
That the reported soil contamination by VOC's do not pose a human
health threat by any route of ezposure.
That reported concentrations of total PAH's in the surface soils
at the 93rd Street School Sites does net pose a threat to human
health by any route of ezposure.
That the presence of molybdenum in the surface soil on the site
does not present a threat to human health.
The potential for this sits to generate a substantial portion of the total
(on a yearly basis) suspended particulate within the local community is
apparently rather small. In addition, the reported surface concentration
for most of the chemicals found at this site are, on average, lov.
The biased sampling reported in tha RI has demonstrated little
contamination in the surface soils of the 93rd Street School site.
However, a more complete sampling of the immediate surface soil (0 to 2
inches) in the area of fill vould provide a better data base upon vhich to
evaluate the potential for that araa to provide a source for significant
ezposure for persons using the site.
If it becomes necessary to determine more accurately whether there are
surface soils in need of remediation, use the 95 percent confidence
sampling procedure developed for EPA Region VII.
rk A. HcClanahan, Ph.D.
-------
Page 7 - Mr. William Q. Nelson
Polynuclear Aromatic Hydrocarbons were in less than 35 percent (Table 4)
of all the samples analyzed. The maximum reported concentration in the
soil samples for several of the specific PAH's, could be of concern, if
they represented the average value in residential surface soils. However,
the contamination is not uniformly distributed, as shown by more than 65
percent of the samples showing no detectable contamination.
Table 5 presents the maximum reported surface soil results for PAH's at
the site. The total of these highest reported surface soil concentrations
is less than 25 mg/kg- Because of the distribution of PAH contamination
at any one sample location, no single sample achieves this ma-r-timitn
concentration. At any given sample location the opportunity for exposure
is less than 25 ug/kg total PAH. Considering the limited spacial
distribution and the low concentration of PAH's in the surface soils the
opportunity for erposure is slight. It is ATSDR's opinion that
concentrations of total PAH in residential surface soils less than 100
mg/kg do not pose a significant threat to human health by any route of
exposure.
The 93rd Street School Site covers about 20 acres. The majority of the
surface soils on the site apparently have little contamination. The
School's building or parking lot cover about half of tha surface area for
which soil samples show some contamination. Thus, the exposed portion of
the site that may have surface soil contamination covers perhaps 0.5
acre. It is possible to envisage an unvegetated 20 acre area contributing
substantial dust to the air during extreme climatological events.
However, it is difficult to conceive of this 0.5 acre part of the 93rd
Street School Site contributing a significant portion to the air borne
particulate for the immediate residential community at any tiae.
The 1986 annual geometric mean suspended particulate value reported for
Buffalo, New York ("National Air Duality and Emissions Trends Report,"
1986, EPA-450/4-88-001, February 1988) is 48 ug/ia3. This value (1986)
for the 1435 sites in the report was 50 ug/m . In comparison to these
values, the Remedial Investigation (RI) uses a 10,000 ug/m" value to
estimate potential long-term exposure to chemicals from site related
particulate. Based upon the EPA national air monitoring data this 10,000
ug/m value is excessive for any exposure. This value is nearly 40
times the former National Primary Ambient Air Quality 24-hour Standard for
particulate of 260 ug/m . Recent revision of this standard addresses
the respirable range rather than total particulite. Nevertheless, the 260
ug/m is the appropriate value to use in comparison to the 10,000
ug/m used in the RI. With RI particulate, the health concern would not
be for the chemicals within the soil nearly so much as for the particulate
matter itself.
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Page 6 - Mr. William Q. Nelson
Only tvo samples reported the presence of 1,1,2,2-tetrachloroethane. One
«t the surface (1,600 ug/kg) and the other (520 ug/kg) tinder A feet of
soil. This chemical has produced liver tumors in one species of animal
(mouse); however, tests in other species have produced equivocal results.
Thus, it is not a proven animal carcinogen. The National Institute for
Occupational Safety and Health (NIOSH) recommended ma^nnmm vork place
concentration (10 hour day) is 7 mg/m . For a 70 kg adult, this is
equivalent to 70 mg per vork day. If one assumes a 0.5 absorption factor
for the tetrachloroethane from inhaled air, the adult male vorker could
have an intake of 35 mg/day 4 to 5 days per veek or 380 ug/kg/day. If a
10 kg child vould ingest soil, based upon the childhood scenario developed
previously, froa the area vith 1,600 ug/kg of soil tho tetrachloroethane
ingested would be 0.032 ug/kg. This is less than 1/10,000 of the NIOSH
recommended maximum industrial exposure. Since this chemical vas in only
one surface sample, the likelihood for a young child to ingest soil from
this location on a daily basis is small. In addition, it i4 very unlikely
that parents vould allow an 13 month old child to play frequently 100
yards or more from its residence. The worst case scenario predicts a very
lov potential exposure vith the real likelihood of exposure even lover.
Therefore, the reported tetrachloroethane soil contamination does not pose
a human health threat from either direct contact or ingestion.
There is no guidance value for Acetone in Table 3. It is chemically
similar to, and present on the site at concentrations similar to
2-butanone. The maximum concentration of 2-butanone is belov the guidance
value and therefore of no health concern. Therefore, the presence of
Acetone does not pose a threat to human health by either direct contact or
ingestion.
Methylene chloride, the remaining VOC without a guidance value in Table 3,
lias lov toxicity. The NIOSH vork place guideline for this compound is
equal to 26,600 ug/kg/day. Based on the 10 kg child soil ingestion
scenario used for tetrachloroethane, the estimated ingestion for methylene
chloride is 0.15 ug/kg/day. This is about 5.8 X 10" time a the maviimrm
allowable workplace exposure. The vorst case scenario predicts a very lov
potential exposure vith the real likelihood of exposure even lower.
Therefore, the reported soil contamination by methylene chloride does not
pose a human health threat from either direct contact or ingestion.
Only soil samples greater than 2 feet deep reported lov concentrations of
p-uichlorobenrene. Based upon the LTHA for p-dichlorobenzene (75 ug/1) a
guidance value for soil can be derived equal to 375 mg/kg. The maximum
concentration of p-dichlorobenzene found on the site vas 830 ug/kg.
Therefore, p-dichlorobenzene does not pose a human health threat from
either direct contact or ingestion.
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Page 5 - Mr.-William Q. Nelson
A child ingesting 0.5 g/d of toil from this site for the 0.4 of the year
that the soil is accessible (climatological limitations) would ingest
0.015 mg/d. This is one tenth the HAS estimated safe level. Thus,
molybdenum in the surface soil does not present a threat to human health.
The same HAS report states that the average daily intake for magnesium for
a child betveen 1 and 3 years old is 150 mg. Studies show that this age
group ingests the most soil. Using the values for daily soil ingestion
previously presented, the average daily magnesium ingestion from the site
for a child would be 1.6 mg, about 0.01 of the average daily intake.
Thus, although the highest magnesium concentration in the soil is above
the maxlatin reported literature surface soil value, there is no apparent
threat to human health from ingestion of the soil.
Our earlier evaluation of arsenic demonstrated that the median
concentration in the on-site surface soil vas less than the typical median
value reported in the literature. The maximum value reported for on-site
surface to 1 foot soil vas 6.8 mg/kg. This value is also less than the
typical median value (11 mg/kg) from the literature for turface soils.
A study by the Centers for Disease Control, Center for Environmental
Health (Binder, S., Forney, D., Kaye, W. , and Paschal, D., "Arsenic
Exposure in Children Living Dear a Former Copper Smelter," Bull. Environ.
Contam. Toxicol. 39:114-21, 1987) found that children living in an area
where the soil contained an average of about 130 mg/kg of arsenic showed
no elevation in urinary arsenic. Eovever, some of a similar group of
children living in an area with average soil arsenic levels of about 700
mg/kg did show elevated urinary arsenic. Thus, at some arsenic level
between 130 mg/kg and 700 mg/kg soil ingestion is great enough to
demonstrate, in some children, an increased exposure. With the maximum
reported arsenic concentration located beneath four fact of soil, it is
not likely to cause a threat to human health. It is the opinion of ATSDR
that the concentration of arsenic found in the surface soils does not pose
a human health threat.
Except for the methylene chloride and chloroform, less than half of the
samples analyzed reported any detectable quantity of the VOC's. Table 3
shows soil guidance values derived by assuming that a 10 kg child would
ingest 0.5 g/d of soil contaminated with a quantity of th« chemical equal
to the EPA Office of Drinking Water, Lifetime Health Advisory (LTHA)(March
1987). For VOC's the LTHA is generally equal 0.2 times the amount of
chemical considered to be safe for lifetime daily ingestion. This value
usually comes from either chronic or sub-chronic animal data. Dividing
either a no observed adverse effect level (NOAZL) or a lowest observed
adverse effect level (LOAZL) value by a safety factor produces an LTHA.
Table 3 presents these guidance values for site related VCC's. Comparing
the reported values with the guidance values shows that the concentrations
for 6 of the VOC's are of no health concern.
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Page A - Mr. William Q. Nelson
While Region II requested ATSDR's opinion specifically of the health
threat associated vith arsenic at the site, ve have evaluated all the
metals data reported from the site. Table 1 presents the comparison of
the maximum concentrations reported for the metals with surface soil data
reported in the literature. Several of the site TM-r-tmtm reported values
exceed the typical medium literature values vhich might shov the influence
of man's activity. There are a fev metals vhose maximum reported
concentrations are more than the maximum reported literature values. Some
of these concentrations could be of health concern under certain site
specific situations.
Table 2 presents the results for those metals vhose n»T*™™ soil
concentrations might be of concern under certain site specific
conditions. Evaluation of possible human exposure must consider: the
opportunity for contact, the frequency for contact, and the concentration
of the chemical. Table 2 shows that the concentration of the next highest
value dropa by a factor of tvo or more, one (zinc) by a factor of 100.
Using the next to Tn«T
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Page 3 - Mr. William Q. Nelson
The release of this acetone contaminated groundvater to Bergholtr creek
should have little effect on the aquatic organisms in the creek. Since
this compound is not significantly bio-accumulated, food chain exposure is
not a concern. The organic chemical results for the tvo on-site surface
vater samples shov concentrations similar to the blanks. Thus, this does
not appear to represent a significant exposure pathway.
The results for inorganic chemicals in vater samples from this site are
not significant. While elevated antimony concentrations are in both soil
and vater samples, these values do not pcse a threat to human health at
this site. Thus, there is no apparent route of exposure that exists
betveen the chemicals and the people in the community.
DISCUSSION
The reported results from all the most resent samples analyzed for dioxin
vere "non-detect." These samples vere composite samples of subsurface
soil collected from the fill material. Although, some sample locations
there vas an aliquot from the surface to 1 foot core included in the
sample. Hovever, in most the composite did not include this uppermost
portion of soil. In order to identify.the vorst contamination on the site
the investigators use a biased sampling plan. This plan concentrated on
sampling the fill material. Thus, there is no apparent evidence that the
material used as fill material at the 93rd Street School contains dioxin.
Earlier sampling at the 93rd Street School site reportedly identified four
locations vith positive dioxin findings. These ranged from 0.11 to 2.3
ug/kg. The highest result vas in a sample 4 to 6 feet belov the surface.
The other three positive findings vere for surface samples collected
during September 1985 by NUS Corporation. ATSDR does not have the maximum
dioxin value for surface samples in the data revieved. Hovever, it vas
less than 2.3 ug/kg vhich shovs there is a rather lov level of dioxin in
one-site surface soils.
For any environmental chemical the opportunity for exposure depends upon
both concentration and areal distribution in the soils as veil as human
access. The dioxin data shovs the combination of conditions for this site
does not provide a significant opportunity for excessive exposure. Based
on the data available, th» small amount of dioxin on the site vould not
prevent conversion of the area to residential use.
Region II did not specifically request an evaluation regarding the dioxin
results. Hovever, ve included it in order to demonstrate the components
of exposure to chemicals in soil. In the documents reviaved there vas no
consideration of these concepts. Site evaluation used only the maximum
concentration of each chemical vithout consideration for vhere this
occurred or whether the data shoved vide spread distribution.
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Page 2 - Mr. William Q. Nelson
3. Appendices - "Remedial Investigation Summary, Remedial
Investigation/Feasibility Study Report for the 93rd Street School Site
City of Niagara Falls Niagara, New York," Volume I, Loureiro
Engineering Associates, December 4, 1987.
4. "Feasibility Study, Remedial Investigation Summary, Remedial
Investigation/Feasibility Study Report for the 93rd Street School Site
City of Niagara Falls Niagara, New York," Volume II, Loureiro
Engineering Associates, December 4, 1987.
5. Memorandum, Robert V. Schick, NYDEC to Joel Singerman, EPA Region II,
December 9, 1987.
6. Memorandum, George Pavlou, EPA Region II to William Q. Nelson, ATSDR,
December 23, 1987.
7. Memorandum, George Pavlou, EPA Region II to William Q. Nelson, ATSDR.
July 15, 1987.
8. Request for Assistance, William Q. Nelson, ATSDR to Chief, Office of
Health Assessment, ATSDR, July 31, 1987.
CONTAMINANTS AND PATHWAYS
The contaminants of interest are metals, PAH'a, and VOC'a. The primary
routes of exposure are those of: direct contact vith, and either
inhalation or ingestion of, the soil containing these contaminants. There
are high concentrations of chemicals reported at several locations on the
93rd Street School Site. However, most of these vere from subsurface
samples. Thus, it does not appear that any of these exposure routes are
of concern under the existing conditions.
There is a shallow perched aquifer within the fill. However, there is no
one using this water, and the reported contamination is low. With the
concentration for most organic compounds reported not being significantly
different from the concentration reported in the blank samples. The
reported concentration of acetone J.n well 7140 is 1100 ug/1. However,
since this water is not being used for eithe:: human consumption or contact
there is no apparent opportunity for exposure.
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Public Health Service
DEPARTMENT OF HEALTH & HUMAN SERVICES Agency for Toxic Substances
and Disease Registry
Memorandu
Date . May 16, 1988
From Health Scientist
Emergency Response Branch
Subject Health Consultation: 93rd Street School (SI-87-006B) Niagara Palls,
New York
To Mr. William Q. Nelson
Public Health Advisor
EPA Region II
Through: Chief, Emergency Response Branch, CHA, ATSDR
STATEMENT OF PROBLEM
Filling of a drainage svale occurred before construction of the school In
1950. The fill material (primarily fly ash) vas from the Love Canal
Site. This material reportedly had 0.5 to 3 feet of cover placed on It.
Several investigations of the 93rd Street School site have occurred
because of concern that chemicals found at the Love Canal might be in this
fill material. These studies were to determine if there are chemicals
present at concentrations which would potentially cause a threat to public
health.
The Environmental Protection Agency (EPA) has requested the Agency for
Toxic Substances and Disease Registry (ATSDR) to evaluate the data
available for the soil and water from the site and comment on the
potential threat to human health posed by the presence of:
-- Arsenic,
Volatile Organic Chemicals (VOC's), and
Polynuclear Aromatic Hydrocarbons (PAH's).
DOCUMENTS REVIEVED
1. "First Round Data Analysis for 93rd Street School Site, City Of
Niagara Falls, Niagara, New York," Loureiro Engineering Associates,
marked "preliminary for review purposes only," Dated May 26, 1987.
2. "Remedial Investigation Summary, Remedial Investigation/Feasibility
Study Report for the 93rd Street School Site City of Niagara Falls
Niagara, New York," Volume I, Loureiro Engineering Associates,
Decemb-r 4, 1987.
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SECTION IV
-------
adjusted by air particulate concentrations;
hence they are not actual soil
concentrations. While maximum
concentrations were used in the ingestion
scenarios in the RI/FS, even if the actual
average soil concentrations are used, the
total risk estimate for arsenic, TCDD, and
PAH contamination at the site is 7.1 x 10""^
•
(for soil at all depths in the fill area).
This risk value corresponds to average soil
concentrations in the fill area of 18 ppm,
220 ppt, and 3 ppm for arsenic, TCDD, and
PAHs, respectively, and uses an air
particulate level of 0.15 mg/m3 (2 1/2
times background) as used by the authors of
the RI/FS risk assessment.
b) Exposure Duration - The RI risk assessment used a 5 year child
exposure because it was assumed that,
although "construction" may last for only a
year, a soil pile could remain or excavated
soils could be redistributed by surface
grading. The 182 day/yr exposure is a
reasonable, conservative estimate allowing
for no exposures during frozen soil
periods.
12
-------
although a less conservative value,
0.15 mg/m^/ was used in the RI/FS.
c) Exposure Duration - The worker inhalation scenario in the RI/FS
envisions exposure for one year, five work
days per week. This year, however, need
not be limited to a single calendar year.
Instead, it encompasses a construction
project which involves 52 work weeks of
exposure, but which could span more than
one year, thus allowing for no exposure
during certain portions of the calendar
year. OCC provides no justification for
its assumption of exposure of only one day
of every four; this assumption is not
conservative enough.
11. pp 12 and 13 - 15 (Assumptions for Ingestion/Disturbed Site
a) Soil Concentrations - As in the undisturbed site ingestion
scenario, OCC again incorrectly used the
airborne contaminant concentrations ("Ca"
in Table 3 of the RI risk assessment) to
represent average soil concentrations.
Although these values were derived from the
full-depth averages, they were then
11
-------
use to account for frozen soil periods (wet
soils may still be ingested); OCC's use of
91 days/yr is not conservative enough.
Moreover, soil wetness could actually
increase the amount of exposure to soil
contaminants because more soil could stick
to the hands and accidentally be ingested.
10. pp 11 and 13 - 15 (Assumptions for Inhalation/Disturbed Site)
a) Soil Concentrations - OCC provides no justification for the soil
concentration it suggests, i.e., one-half
the values used in the RI. The values used
in the RI were based on the full-depth
average o:: the soils to represent soils
excavated from depth and either left in a
pile or rcgraded along the surface.
b) Air Particulates
(Soil Exposure)
Although the RI describes using 10 mg/m3
as an air particulate concentration, a
lower level was actually used in the
calculations and the text was never
corrected. OCC's suggestion of using 20
times Niagara Falls background, i.e.,
1 mg/m3, is also a reasonable assumption,
10
-------
exposure per day for 25% of the time is an
appropriate worst-case estimate.
9. PP 10 and 13 -15 (Assumptions for Ingestion/Undisturbed Site)
a) Soil Concentration - OCC suggests that the ingestion scenario
should have used average soil
concentrations. Initially, it should be
noted that OCC's calculations incorrectly
used the airborne contaminant concentration
(2nd line of Table 3 in the RI risk
assessment) to represent average surface
soil concentrations. This error results, in
an underestimate of the average soil
concentration by a factor of 20 (i.e.
1/0.0525 mg/m^). Moreover, even if the
actual average soil concentrations are
used,* the total-risk estimate for arsenic,
TCDD, and PAH contamination at the site is
2.6 x 10~5 (for surface soil in the fill
area).
b) Exposure Duration - The value of 182 days/yr us;ed in the RI
risk assessment is a reasonable value to
*The average surface soil concentrations in the fill area for
arsenic, TCDD, and PAHs are 5 ppm, 220 ppt, and 1.5 ppm, respectively,
-------
b) Airborne Particulates - The value used in the RI,
0.0525 mg/m3, is based on ambient Niagara
Falls measurements and is thus justified.
OCC used 20% or this value, perhaps again
to account for dilution with clean
particulates. This would result in double
counting of this effect, thus making it
even more difficult to justify. As with
the soil concentration assumption, no
justification is provided for this
assumption.
c) Exposure Duration - A 24 hour duration does not assume a
lifetime in the school yard. Rather, it
includes exposures in a home adjacent to
the site.
While assumption of exposure 365 days per
year is very conservative, this level is
frequently used in risk assessment and
provides an upper bound on exposure and
risk. Moreover, selection of some lower
number of days of exposure (which would
reduce the risk proportionally) would be
arbitrary. OCC provides no justification
for its statement that an eight-hour
-------
Therefore, it is reasonable to conclude that the dioxin found at the
site is not attributable solely to background.
Comments Regarding Risk Assessment Assumptions
In general, OCC's alterations of the RI/FS risk assessment
assumptions are arbitrary and unsupported. Because substantial
uncertainties exist regarding the true magnitude of exposure to site
contaminants, assumptions are developed in the RI/FS which are
conservative (i.e., more likely to overestimate than underestimate
risk), yet which are possible and provide an upper bound on
estimates of exposure and risk. The following are responses to
specific risk assessment elements where disagreement exists between
the RI/FS and OCC.
8. pp 9 and 13 - 15 (Ass'omptions for Inhalation/Undisturbed Site)
a) Soil Concentrations - OCC suggests using 20% of the
concentrations used in the RI. Although no
justification is provided for this
assumption, it presumably accounts for
windblown dilution by dust from offsite
areas. A realistic worst case should be
based on 100% of the average surface soil
concentration, as was used in the RI.
-------
0.01 - 10 ppm 90% of urban soils examined (U.S. EPA,
1982. "An exposure assessment for
Benzo(a)pyrene and other polycyclic
aromatic hydrocarbons")
• 0.006 ppm Swiss alpine soils (Bluner et al.,1977.
Envi. Sci. Technol. 11(12) :1082-1084.
Finally, lake sediments might be a reasonable reference for
particulate PAH levels resulting from surface runoff and atmospheric
deposition. The Adirondack lake sediments example provided by OCC
indicates concentration from 1.2 to 5.6 ppm for the 6 PAKs. Based
on these above examples it remains unclear whether or not average
soil levels found at the 93rd Street School (1.1 to 2.9 ppm, surface
and full depth averages, respectively) fall into "background"
classification.
7. pp 6 - 7 (TCDD Background)
EPA's Dicxin Strategy (EPA report No. EPA/530 -SW-87-025) Tier 7
samples were intended to represent "ambient" concentrations of
2,3,7,8-TCDD. U.S. urban soils where TCDD was detected (7 of 15
cities; 17 of 221 samples) ranged in values from 0.4 to 11.2 ppt.
In contrast, 93rd Street School soils where TCDD was detected (4
•
out of > 50 samples) had values ranging from 110 to 2,300 ppt.
-------
In addition, OCC's comparison of intake via soil at the 93rd Street
School site with daily food intake is skewed by use of incorrect
average soil concentrations (see Comments #5, 9, and 11). Using the
lower food intake rates (8.6 ug arsenic/day), ingestion of the most
highly contaminated soils (350 ppm) would result in arsenic intake
that was 4.1 times the intake rate from food.
6. pp 4 - 6 (PAH Background)
As with arsenic, OCC presents some background examples which are not
relevant representations of a schoolyard in a residential area.
Asphalt, used motor oil, and vegetables are not comparable matrices
to soils at the 93rd Street School. Probably the most
representative background levels are the observations from the
Niagara Falls Control Areas in the 1980 EPA Love Canal study cited
above. In that study, the Control Area samples showed no detectible
concentrations of the PAHs being considered at the 93rd Street
School. By comparison several studies have found levels of total
PAHs (up to 17 individual PAHs) in the following soils:
• 1.1 ppm Canadian farm soil near a highway
(Edwards, 1983. J. Envi. Qual. 12(4): 427-
441.
-------
The second part of OCC's arsenic comment regarding dietary intake
of arsenic appears to be simply an attempt at rationalization. If
soil ingestion from this site poses a health concern, the fact there
may be comparable or higher exposures to arsenic by dietary routes
means that such exposures also may pose a health concern. It does
not mean that the potential health threats at the 93rd Street School
are acceptable. More importantly, the arsenic present at the site
is a controllable source of risk which can be minimized, thus
minimizing the risk to arsenic as a whole.
It should also be noted that OCC's estimates of arsenic intake from
food (Schroeder and Balana, 1966) are at the high end of values
reported in the literature. In contrast to that paper, which
estimated daily arsenic intakes of 400-1000 ug/day, more recent
studies have estimated daily intakes of total arsenic of
approximately 50 ug/day (US EPA, 1984; JRB, 1984).* Decreases in
arsenic levels in food are thought to be due to decreased use of
arsenical pesticides since the 1960s. In addition, these studies
have noted that much of this intake is from arsenic in seafood,
which is typically an organic form of arsenic which is rapidly
excreted unchanged. Thus, inorganic arsenic intake is estimated as
8.6 ug/day (JRB, 1984), approximately two orders of magnitude less
than the value used by OCC (900 ug/day).
*US EPA. March 1984. Health Assessment Documentfor Inorganic
Arsenic. Office of Health and Environmental Assessment. EPA-6QQ/8-
83-021F.
JRB Associates. September 27, 1984. Occurrence of Arsenic in
Prinking Water, Food, and Air. Prepared for US EPA.
-------
Response to Occidental
Chemical Corporation's
Comments
-------
observed PAH levels at the 93rd Street School are not above
background levels is questionable. Study of Niagara Falls Control
Areas for the Love Canal monitoring program resulted in no
detectable observations of PAHs (see response No. 6 to OCC
comments). These data are probably the most appropriate comparison
data. Also, the examples provided by the County are mostly of
contaminated areas, not of relatively undisturbed areas. For
example, three of the five examples are former dumps and the other
two are industrial sites; hence high observed PAH levels are not
surprising. The County's examples are therefore not appropriate
comparisons of contaminant levels. In addition, the cited ATSDR
conclusions of insignificant risks at these five sites specifically
assume different exposure scenarios than envisioned for the 93rd
Street School site. For example, most exposures in these
comparison sites were assumed to be limited to infrequent adult
exposures in industrial settings.
2. p. 5, Comment M6.
The County's proposal for an incremental risk assessment, combined
with its prior comments about Niagara Falls background levels,
implies that risks due to residual anthropogenic contamination are
acceptable. If a site poses unacceptable risks and it is possible
to mitigate such risks, a remedy may still be appropriate for that
site.
-------
July 20, 1988
93rd Street School, Niagara Falls,
Responses to the Niagara County Health Department Comments
on the RI/FS
1. p. 3, Comment #4.
The County's approach to determining the acceptability of the
site's soils is a comparison to local "background" concentrations.
While it is reasonable to give consideration to background levels,
one must distinguish between ambient or "natural" background and
anthropogenic background levels. Favorable comparisons to the
latter are not in themselves justification for no remedial action.
Judging by the PAH examples given (more details are provided below)
it appears that the County has relied primarily on data from areas
influenced by industrial activities.
Metals. Insufficient information was provided in order to respond
meaningfully to this comment. The County did not describe its
method of statistical analysis, e.g., the confidence level used, or
its data sources, so it is not possible to comment on its
conclusions.
PAH. The County inappropriately compared the 93rd Street School
site with industrial sites. Therefore, its conclusion that the
-------
ruiyaromatie Hydrocarbons (PAHs)
93rd Street School
Soil Sample Results 1
Highest Total PAH Levels
Location IP-9 IP-3 2P-122 IP-4 2P-115 2P-115 IP-2 IP-2 2P-121 2P-143
Depth (1-2') (0-1) (0-.5') (0-1') (0.5-2.5') (0-0.5') (0-1') (1-2') (0-0.5') {0-0.5'J
Total PAH'S
Kg/kg 76.6
12.6 11.5
9.9
5.6
5.3
4.6
4.2
3.9
3.0
Background levels 2 - virgin soil (covered with grass) - 0.56 ng/kg
- cultivated soil - 0.81 »g/Kg
(samples were collected at 15 en depth)
at 50 other sample locations in the top two soil horizons the
range was 0.032 to 2.9 nig/kg for total PAll's
Wang, D.T. and 0. Neresz, 1982, Occurrence and potential uptake
of polynuclear aromatic hydrocarbons of highway traffic origin by
proximally grown food crops. ]n: Polynuclear Aromatic
Hydrocarbons: Physical and Biological Chemistry, Cooke N.,
A.J. Dennis and G.L. Fisher, eds. Columbus: Battelle Press.
-------
INORGANICS (METALS)
Ranges for Metal Concentrations
Metal(mg/kg)
93rd St. School
(O-l1 depth)
93rd St. School
(1-21 depth)
Average Background
Levels
Eastern United States3
Average Background
Levels
Niagara Falls, NY4
Antimony(Sb)
(average)
Arsenic (As)
(average)
Cadmium (Cd)
(average)
Cobalt (Co)
(average)
Lead(Pb)
(average)
Mercury (Hg)
(average)
21-92 !
(19.6)
1.8-425
(8.4)
1.3-6.8
(1.8)
9.9-17
(12.7)
9.3-343
(54.2)
0.12-7.60
(0.40)
S2-762 0.76
(29.6)
2.7-96 7.40
(21.7)
1.4-6.7
(6.2)
11-17 9.2
(13.1)
7.4-177 . 17
(41.9)
.11-23 0.12
(1.1)
-
13.31
6.60
—
137
1.45
(1)
(2)
(3)
(4)
(5)
Only 4 positive values of 50 samples were above detection levels,
detection level was generally 12 mg/kg.
The
Only 4 results for 32 samples were above detection levels. The detection
level was generally 12 mg/kg.
Shacklette and Boernger, Element Concentrations in Soils and Other
Surficial Materials of the Conterminous United States, U.S. Geological
Survey Professional Paper 1270, 1984.
Average background levels determined from approximately 20 data sets of
surface soil sample results compiled by the Niagara County Health
Department, Michael Hopkins, 1987.
Average of all analytical results regardless of QA/QC notes such as spike
or duplicate analysis were not within control limits.
NOTE: For all non-detects, the detection limit was used.
-------
Overall, the compounds detected and their concentrations do not
in the opinion of DOH necessitate the construction of a RECRA cap to
protect the public from exposure to the surface soils. Since the area
was once used as a schoolyard/playground area and may once again be
used as such, it is appropriate to eliminate or reduce the potential
for contact by the public. The areas cited above with elevated total
PAH levels should be excavated to a depth of at least 2 1/2 feet and
the soils appropriately disposed or treated. The entire area should
be covered using appropriate methods and with as little change in the
present elevation as possible.
DOH concurs with the recommendation for a groundwater monitoring
program and the proposed handling of dioxin contaminated soils.
Should you have any questions, please call me at 458-6309.
Sincerely,
Allison C. Wakeman, P.E.
Chief, Niagara County Section
Bureau of Environmental Exposure
Investigation
jlh
cc: Dr. Stasiuk
Dr. Kim
Mr. Tramontane
Ms. Sviatyla/Mr. VanValkenburg
Mr. Willson
Mr. Hopkins
Page 2
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STATE OF NEW YORK
DEPARTMENT OF HEALTH
Corning Tower The Governor Nelson A. Rockefeller Empire State Plaza Albany, New York 12237
David Aitf'OO. M 0
March 2, ISS^^-— ^ , ,^_
Mr. Robert Schick
NYS Dept. of Environmental Conservation ?:r.m •-•• .. „,...,.
50 Wolf Rd.
Room 222 " '
Albany, NY 12233
RE: Remedial Investigation/Feasibilit-
Study
Dear Mr. Schick:
The New York State Department of Health has reviewed the Remedial
Investigation/Feasibility Study for the 93rd Street School Site and
has evaluated the soil data for the first two soil horizons (O-l1 and
1-2' depths). Exposure to contaminated soil by the public utilizing
the playground area is likely to occur in the top horizon (O-l1) and
could occur in the 1-2' soil horizon should children dig excessively.
The data was presented in 3 major groupings consisting of
inorganics (metals), volatiles, and Base/Neutral/Acid (B/N/A)
extractable organics. Metal levels present in the first two soil
horizons were found to be generally comparable to "background" metal
levels found in the Eastern United States and the Niagara Falls area.
The attachment presents the average metal levels found at 93rd Street
School with "background" metal levels from the above referenced areas.
Information regarding the references from which these background
levels were obtained is provided in the attachment.
Analytical results for the volatile compounds indicate the
presence of these compounds at low levels. Of those volatiles
detected, two, methylene chloride and acetone, are common laboratory
contaminants. Furthermore, many of the volatiles detected were also
present in the blank samples. In any event, the volatile
concentrations present do not on their own require a remedy to
eliminate potential exposure to the public.
The B/N/A data shows the presence of polyaromatic hydrocarbons
(PAH's) which are associated w_th petroleum products or combustion
sources. The levels range from one to almost two orders of magnitude
greater than those found in areis not directly impacted by disposal of
fill materials or soil (see attachment). The areas of highest total
PAH concentrations are IP-9 (1-21); IP-4 (O-l1); IP-3 (O-l1); and
IP-122 (0-.51) with concentrations ranging from 9.9 to 76.6 ppm.
-------
Mr. Hopkins April 26, 1988 letter referred to five cases (64th
Street - South & North, National Fuel Gas, 59th Street, and Niagara
Falls Business Forms Site) that the NYSDOH and ATSDR had concluded
that PAH levels were typical of urban areas and no further actions
were justified based on the health risks associated with the PAH
levels. The Department concurs with ATSDR that there is no imminent
health threat at those sites. However, the ATSDR preliminary health
assessments for each of the above 5 cases highlight that "very little
toxicological information is available on low level exposure to
PAH's." This is also the case for the 93rd St. School area. The
Department believes it is appropriate to be conservative in evaluating
the potential long term impacts to the public that may utilize the
93rd St. School area. Such an evaluation leads to the conclusion that
the Department's recommendation of limited excavation and subsequent
covering of the area, especially the infield of the baseball diamond,
with clean soil is a prudent public health approach to minimize
potential exposure of the public to these soils.
Sincerely,
Nancy K. -Kim
Director
Division of Environmental Health
Assessment
jlh/81620475
cc: Mr. Tramontane
Mr. Wakeman
Mr. Schick
Page 2
-------
misleading when applied to sites in residential areas or
schoolyards. Probably the best representation of background
arsenic concentrations for this site are the New York,
uncontaminated ranges cited by OCC and LEA in the RI (3-12 ppm,
Walsh et al., 1977; 7 - 10.6 ppm, RI report) and the mean value of
\
soil samples taken from the Control Area during EPA's 1980 Love
Canal study, 9.4 ppm (EPA, 1982, "Environmental Monitoring at Love
Canal"). By comparison, geometric mean arsenic levels in soils from
various U.S. cities were observed to be (Carey, Wiersma, and Tai,
1970):
Augusta, ME 4.1 ppm
Philadelphia, PA 8.5
Honolulu, HA 2.1
Portland, OR 4.5
Mobile, AL 0.8
Considering that the average concentration in the surface soils at
this site (8.4 ppm) is within this range, it is reasonable to
suspect that the average over all soil depths (17 ppm) and the
maximum concentration (350 ppm) reflect contributions from unnatural
sources.*
*It should also be noted that OCC mistakenly interpreted the
air concentrations based on soil concentrations at the site as the
soil concentrations themselves (e.g., 0.43 and 2.7 ppm arsenic for
surface soils and all depths, respectively). In actuality, these
average concentrations are 8.4 and 17 ppm.
-------
and deep soils. The observed non-detects for TCDD in the most
recent Remedial Investigation do not negate the prior observations
for two reasons: 1) sampling was designed so as not to repeat prior
locations; and 2) samples were depth-composites which could lead to
clean depth subsamples diluting contaminated subsamples resulting in
a composite non-detection.
Comments Regarding "Background" Concentrations
•
4. p.l, ?2 (Selection of Indicator Chemicals)
The indicator chemicals were selected within the guidelines put
forth in the Superfund Public Health Evaluation Manual (EPA, 1986).
Because a) many of the chemicals analyzed for at the site were not
detected and b) an inadequate database existed for some of the
chemicals, professional judgment was exercised in selecting the
indicators. Using toxicity and quantity as criteria, the list was
narrowed to 10 contaminants that warranted further attention with
regard to increased risk at the site.
5. pp. 2 - 5 (Arsenic Background)
The choice of appropriate reference concentrations representing
"background" is often difficult. Although some of the background
examples provided may be relevant, the references to volcanoes and
pesticide-applied areas such as orchards are inapplicable and
-------
July 20, 1988
93rd Street School, Niagara Falls
Response to OCC (T. Truitt) May 24, 1988 Letter
Letter
1. P.I, 32 . -
The construction fill examples refer to the use of fly ash in
solidified matrices such as concrete. This is not analogous to
soils at the site that are mixed with flyash and other chemical
wastes.
P.2, 32
The letter seems to imply that the PAHs present at this site are due
to the presence of asphalt and possible spilled motor oil. This is
unlikely. Asphalt is not likely to leach extensive amounts of PAH
into the soil and the volume of spilled motor oil, if any, is not
likely to account for the total mass of observed PAH.
3. p.2, 113
It is not true that the presence of TCDD at this site has not been
confirmed. Two prior studies at the site observed TCDD in shallow
-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION VII
726 MINNESOTA AVENUE
KANSAS CITY. KANSAS 66101
Oloxln Sites Cleanup Activities March 11 1988
Weekly Update
The Environmental Protection Agency will continue to receive public
comment on Its Proposed Plan for the Final Management of 01ox1n-Contaminated
Soil and Final Disposition o' Structures and Debris at Tlacs Reach until
March 18. 1988.
The proposed plan reviews alternatives to manage dloxln contaminated
soils at the Times Reach and M1nker/Stout/Roma1ne Creek sites and Identifies
the.Agency's preferred alternative. The alternatives reviewed Include placing
a cap on all contaminated soil In the Times Beach area and putting topsoll over
the contamination, placing the contaminated soil Into concrete storage facilities
on the site, onslte thermal treatment of contaminated soil at the Times Beach
Site only, and onslte thermal treatment of the contaminated soil from the
Beach Site along with other designated Missouri dloxln sites.
The Agency's pr«ferred alternative 1s onslte thermal treatment of all
contaminated soil from the Times Reach site along with other designated
Missouri dloxln site*. This preferred alternative also plans for excavation
of all d1ox1n-contamlnated soil above 20 parts per billion (ppb) and placing
12 Inches of topsoll and vegetation over any areas with levels between one
and 20 parts per billion.
Written comments concerning the proposed plan should be addressed to:
Rowena Michaels, Director, Office of Public Affairs, U.S. Environmental
Protection Agency, 726 Minnesota Avenue, Kansas City, Kansas 66101.
The proposed plan, feasibility studies for Times Reach and the M1nk«r/
Stout/Komalne Creek Site and the administrative records *h1ch document our
activities at eastern Missouri dloxln sites are available for public review
at the Tines Beach Information center. The center 1s located at 97 North
Outer Road at lewis Road 1n front of the former Galley West Restaurant. Our
phone number 1s (314) 938*6869. The hours of the center are 9 a.m. to 6 p.m.
Monday through Friday and 9 a.m. until noon Saturday.
Information Center Coordinator
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- 2 -
(11) IARC Monographs on the Evaluation of the Carcinogenic
Risk of Chemicals to Humans. Vol. 32, I ARC, Lyon,
France 1983.
(12) Kimbrough, R.D., et al. Health Implications of
2,3,7,8-Teterachlorodibenzdioxin (TCDD) Contamination
of Residential Soil. Journal of Toxicology and
Environmental Health, 14:47-93, 1984
-------
REFERENCES:
(1) Handbook on the Toxicology of Metals, Lars Freiberg et
al: Editors. Elsevier/North-Holland Biomedical Press,
Ainsterdanj — New York — Oxford, 1979.
(2) Hooper, P.R., et al. Mount St. Helen's Ash from the
May 1980 Eruption. Science, Vol. 209, September 1980.
(3) Carey A.E., et al. Pesticide Residue Concentrations
in Soils of Five United States Cities, 1971 — Urban
Soils Monitoring Program. Pesticides Monitoring
Journal, Vol. 13, No. 1, June 1979.
(4) Drinking Water and Health, Vol. 1. National Academy
of Science, National Research Council, Washington,
D.C. 1977
(5) Walsh, L.M., et al: Occurrence and Distribution of
Arsenic in Soils and Plants. Environ. Health
Perspecat. 19, 67-71, 1977.
(6) Schroeder, Henry A., et al: Abnormal Trace Metals in
Man: Arsenic. J. Chron.. Dis., Vol. 19, 1966.
(7) Polynuclear Aromatic Hydrocarbons: Chemistry and
Biological Effects. Page 1085. Editors: Alf
Bjorseth and Anthony J. Dennis. Battelle Press,
Columbus, Ohio. 1980
(8) Polynuclear Aromtic Hydrocarbons: Chemical Analysis
and Biological Fate. Page 566. Editors: Marcus
Cooke and Anthony J. Dennis. Battelle Press,
Columbus, Ohio 1981
(9) Polynuclear Aromatic Hydrocarbons: Chemistry and
Biological Effects. Page 1034. Editors: Alf
Bjorseth and Anthony J. Dennis. Battelle Press,
Columbus, Ohio, 1980
(10) IARC Monographs on the Evaluation of the Carcinogenic
Risk of Chemicals to Humans. Vol. 35, IARC, Lyon,
France 1985.
-------
- 15 -
yard 25% of the days would still be a conservative estimate of
exposure time.
For the exposure duration on the disturbed site, the
number of days that the worker is exposed to excessively dusty
conditions is overstated. This would not occur every.work day
and for the whole year. Exposure to dusty conditions for one
day out of four days during the one year construction project
still provides a worse case estimate.
The child's exposure is overstated to an even greater
extent. Since the area is now a construction area the child
would not be playing at a construction site as much as they
would play in the school yard. Also, the construction would
alter the use of the site and would presumably cover the site
with a structure, parking lots, walk ways, lawns, etc. This
would then eliminate further exposure to the soil contaminants
and the exposure duration would be limited to one year.
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- 14 -
The dust level reported in air in the Niagara area is
a reasonable level to apply to general on-Site exposure to dust
by inhalation, but the use of the 'nuisance dust" limits of
ACIGH for dust levels during construction for all the working
days in the year is a gross exaggeration of the probable dust
level encountered at any construction sites, even under the
dustiest conditions. A dust level 20 times the ambient level
(0.0525) is suggested as a more reasonable worst case estimate
for a construction site.
RZCEPTORS—The receptors evaluated by the RI/FS appear
to be the receptors that would have the greater potential for
exposure.
EXPOSURE DURATION—All day, every day, for 70 years is
an unreasonable exposure scenario for inhalation dust with the
site undisturbed. It assumes that an individual will live out
their life on the school yard. Exposure for eight hours per
day, and 25\ of the days would be a more appropriate worse case
estimate.
For the exposure of a child, the five years is not
unrealistic since a young child living near the school would be
expected to play on the yard during school period and in the
summer time while attending the school, but the number of days
per year this would involve is overestimated when winter,
inclement weather, and the days a child would play at some
•
other location are taken into account. Playing at the school
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- 13 -
RATIONALE FOR MORE PROBABLE ASSUMPTIONS
CHEMICAL CONCENTRATION—The RI/FS uses the average
concentration for evaluation of the risk from inhalation of
contaminated soil but uses the highest concentration reported
when evaluating the risk from ingestion of soil. The average
concentration is the logical and the technically reasonable
concentration to represent the conditions on the surface of the
school yard. As was discussed above in relation to the impacts
of TCDD in soil, the average concentration present in an area
best depicts the chemical environment unless there are unusual
hot spots involving a significant percent of the area. The
school yard data does not show hot spots which would require
special consideration.
The RI/FS does not mention the matrix effect or effect
of the absorption of the chemical -to the soil particles which
hinders absorption and decreases the effective concentration of
chemical in the soil. For inhalation exposure it is also
important to realize that all the dust over an undisturbed site
will not originate from the site itself but will be carried
there from other areas. The concentration of dust from the
Site will decrease as the distance from the site increases.
These factors would all decrease the exposures estimated in the
RI/FS.
£OIL EXPOSURE—The RI/FS generally uses a reasonable
exposure level for soil ingested by individuals who are five
years of age or older (100 mg/day).
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- 12 -
COMPARISON OF RI/FS WITH PROBABLE WORST CASE ASSUMPTIONS
DISTURBED SITE
Assessment
Input
RI/FS
Assumpti
SCENARIO 2—INGESTION
Concentration
in soil rug/kg
Arsenic 3.5E-04
PAHd 1.1E-04
TCDD 1.2E-09
Soil Exp.
rag/day 100
Receptor (child)
weight-kg 17
Exposure
duration
days/year 182
years 5
Exaggeration in assumptions
Arsenic 6,500
PAH 32,350
TCDD 230
Risk
Arsenic
PAH
TCDD
Total
1.1E-03
1.9E-04
3.9E-05
1.3E-03
Probable
Assumptions^
Ratio of RI/FS
To ProbableC
2.7E-06f
1.7E-07f
2.16E-10e
100
17
18
1
130
647
4.6
1
1
10
5
1.7E-07
5.8E-09
1.7E-07
3.5E-07
a-Assumptions as presented in.Exhibit 1, RI/FS.
b-Assumptions which more reasonably meet the EPA requirement
for "probable worse case* exposure assessment.
c-Ratio of RI/FS assumptions and the more reasonable probable
worst case assumptions.
d-Sum of the carcinogenic PAH used in the assessment presented
in the RI/FS.
e-Average for TCDD calculated using detection limit where
non-detects were reported. (NUS Corporation report dated
March 20, 1986)
f-Mean of concentrations used to estimate inhalation exposure in
the RI/FS.-
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- 11 -
COMPARISON OF RI/FS WITH PROBABLE WORST CASE ASSUMPTIONS
DISTURBED SITE
Assessment RI/FS Probable Ratio of RI/FS
Input Assumptions3 Ass, mptions^ To ProbableC
SCENARIO 1—INHALATION
Concentration "*•
in soil-mg/kg
Arsenic 2.7E-06 1.3E-06 2
PAHd 3.4E-07 1.7E-07 2
TCDD NOT INCLUDED IN ASSESSMENT
Soil Expos.
rog/M3 '10 1 10
Air intake
M3/day 10 10 1
Receptor's
weight-kg 70 70 1
Exposure
duration
hours 88 1
days/yr. 260 65 4
years 11 1
Total-hrs. 2,080 520 4
Exaggeration in assumptions (2X10X1X1X4=80) 80
Risk
Arsenic 1.8E-05 2.0E-07
PAH 2.1E-07 2.6E-09
Total 1.802E-05 2.003E-07
a-Assumptions as presented in Exhibit 1, RI/FS.
b-Assumptions which more reasonably meet the EPA requirement for
"probable worse case* exposure assessment.
c-Ratio of RI/FS assumptions and the more reasonable probable
worst case assumptions.
d-Sura of the carcinogenic PAH used in estimating the inhalation
exposure in the RI/FS.
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- 10 -
COMPARISON OF RI/FS WITH PROBABLE WORST CASE ASSUMPTIONS
UNDISTURBED SITE
Assessment
Input
RI/FS
Assumptions3
Probable
Assumptions0
Ratio of RI/FS
To ProbablgC
SCENARIO 2—INGESTION
Concentration
in soil mg/mg
Arsenic 5.2E-05
PAH 9.7E-06
TCDD 1.2E-09
Soil Exp.
mg/day 100
Receptor (child)
weight 17
Exposure
duration
Says/year 182
years 5
Exaggeration in assumptions
Arsenic—240
PAH —340
TCDD —9.2
4.3E-07f
5.7E-Q8f
2.1i-10e
100
17
91
5
120
170
4.6
1
1
2
1
Risk
Arsenic
PAH
TCDD
Total
1.6E-04
2.4E-05
3.9E-05
2.2E-04
6.7E-07
7.1E-08
4.2E-06
4.9E-06
a-Assumptions as presented in Exhibit 1, RI/FS.
b-Assumptions which more reasonably meet the EPA requirement for
"probable worse case* exposure assessment.
c-Ratio of RI/FS assumptions and the more reasonable probable
worse case assumptions.
d-Sura of the carcinogenic PAH used in the assessment presented
in the RI/FS.
e-Average for TCDD calculated using detection limit where
non-detects were reported. (NUS Corporation report dated
March 20, 1986}
f-Mean of.concentrations used to estimate inhalation exposure
in the RI/FS.
-------
COMPARISON OF RI/FS WITH PROBABLY WORSE CASE ASSUMPTIONS
UNDISTURBED SITE
ssessment
Input
RI/FS
Assumptions3
Probable
Assumptions*3
Ratio of RI/FS
Ttj_P_r i biblec
SCENARIO 1—INHALATION
Concentration
in soil-rag/mg
Arsenic
- PAHd
TCDD
Soil Expos.
mg/H3
Air intake
4.3E-07 8.6E-08
3.2E-08 6.5E-09
NOT INCLUDED IN ASSESSMENT
5
5
0.0525
0.0105
Receptor's
Weight-kg
Exposure
duration
hours
days/yr,
ears
20
70
20
70
1
1
24
365
70
6.1E+05
8
91
70
5.IE+04
3
4
1
12
Exaggeration in assumptions (5X5X12-300): 300
Risk
Arsenic
PAH
Total
6.1E-06
5.6E-08
6.106E-6
2.2E-08
1.9E-10
2.202-08
a-Assumptions as presented in Exhibit 1, RI/FS.
b-Assumptions which more reasonably meet the EPA requirement for
."probable worse case" exposure assessment.
c-Ratio of RI/FS assumptions and the more reasonable probably
worst case assumptions.
d-Sum of the carcinogenic PAH used in estimating the inhalation
exposure in the RI/FS.
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- 8 -
assumptions which are considered to more closely meet the EPA
definition of a probable worse case scenario. The
justification for changing the assumptions are presente••'• for
each scenario. These tables present the risk level calculated
for each set of assumptions.
Examination of the risk levels calculated for the
probable worse case assumptions show risk levels that are
acceptable (less than 10~ ) in all cases except one where the
total risk is slightly greater at 4.9X10"6. This risk level
would be considered acceptable because it applies to a worse
case exposure scenario. The risk determination also uses the
more stringent EPA potency value which is being evaluated and a
recent report suggests that this value will be decreased by a
factor of 16. This would lower the total risk of this exposure
scenario (Ingestion, undisturbed site) to 1X10 .
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- 7 -
trash and municipal wastes, TCDD is probably ubiquitous in the
ban/suburban environment.
Although a comparison with background data is net
possible, this is an appropriate place to discuss the RI/2'3
application of the 1 ppb TCDD limit for a level of concern in
soil. The RI/FS states that this limit is exceeded because a
single sample exceeded this limit although scores of samples
were below 1 ppb or non-detect. In the original report which
established the 1 ppb level of concern, Kimbrough et al. stated
that their estimate of human intake of TCDD assumed "uniform
distributions of TCDD in soil at 1 ppb." This assumption is
discussed further where they state, "It must be stressed that
the exposure assessments used in estimating risks for
arcinogenicity .and reproductive health effects contain
ritical assumptions that are not likely to be actually
encountered. Most prominent of these is the assumption of
uniform levels of contamination throughout the living
(12}
space."v ' The RI/FS has taken a single sample exceeding
1 ppb and assumed that this represented a uniform distribution
of 1 ppb over the entire area. This is totally unrealistic
when there is a significant body of data which states that the
average concentration is well below the 1 ppb level of
concern. TCDD is not a chemical of concern at this site.
CALCULATION OF CANCER RISK FSOM ARSENIC. PAH AND TCDD
CONTAMINATION OF THE SOIL.
The following tables present a comparison of the
assumptions used in the RI/FS risk assessment and set of
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- 6 -
Foods also contain PAH. Charcoal broiled steak and
smoked ham are reported to contain 3.7-50.4 and 0.5-14.6 ppb of
benzo(a)pyrene, respectively.(11) Due to the ubiquitous
presence in air and the resulting fall-out, leafy vegetables
can have comparatively high levels such reported below:* ^*
PAH Lettuce Soinach
Benz(a)anthracene 6.1-15.4 16.1
Benzo(a)pyrene 2.8-12.8 7.4
Chrysene 5.7-26.5 28.0
Comparing the concentrations reported above with the
•
concentrations reported in surface soil in the RI it is
apparent that the PAH concentrations are within the range that
would be expected to occur in an urban/suburban area. The
occasional sample containing comparatively higher
concentrations could easily be the result of contamination with
materials related to school construction or paving of drives
and parking lots.
TCDD environmental distribution has been studied
extensively, but because the analytical programs generally
relate to areas of expected contamination, data which can be
used to evaluate background concentrations are not available at
this time. TCDD can theoretically be produced by natural
combustion processes and has been reported in soot. It is also
reported in ash. Because TCDD can be produced in the
combustion of organic material, especially the combustion of
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- 5 -
commonly used in roofing and paving materials and are reported
contain the following concentrations of the carcinogenic PAH
reported at the Site:
RANGE OF PAH REPORTED IN BITUMENS8<10)
PAH RANGE uo/ko
Benz(a)anthracene 0.15-35
Benzo(b)fluoranthene NRC
Benzo(k)f luoranthene ND—+*>
Benzo(a)pyrene 0.03-52
Indeno (l,2,3-cd)pyrene HD-1
Chrysene 0.04-34
a-Eight different bitumen samples
b-ND—Not detected, •»•—not estimated but present in small
amount.
c-Not reported.
Creosote is commonly used as a preservative for posts and
lumber. "PAH's (mostly unsubstituted) generally account for at
ast 75 percent of ccreosote (Lorenz and Gjoviak, 1972)."(10)
Another source of PAH which is common around the
building site is used motor oil. Peake et al. reported the
(Q\
following concentrations of PAH in used motor oil:x '
POLYCYCLIC AROMATIC HYDROCARBONS IN USED MOTOR OIL
PAH uo/ml
Benz(a)anthracene 0.87
Benzo(b)fluoranthene 1.38
Benzo(k)fluoranthene 1.44
Benzo(a)pyrene 0.36
Indeno (l,2,3-cd)pyrene NRa
Chrysene/Trighenylene 2.48
a-NR-Not reported
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- 4 -
and water. If, per chance, the 100 rag. of soil cane from the
most contaminated sample of soil* the daily intake from soil
would be 0.035 mg and would be equivalent to less than 4% of
the estimated daily intake of arsenic from food and water. The
potential exposure to arsenic from soil at the Site 'seems
inconsequential compared to the estimated daily intake from
other sources.
Polyeycllc aromatic hydrocarbon^ (PAH) "occur widely
throughout the environment* both as a result of the
technological activities of man and as a result of natural
production.** ' The primary production by man comes from
heating and power production (combustion of fossil fuels). PAH
can therefore be found even in remote areas. Tan et al.
reported concentrations in the sediment in the bottom of two
Adirondack State Park lakes in the State of New York.*8* The
following data was taken from their published report:
CONCENTRATION OF PAH
IN SAGAMORE LAKE AND WOODS LAKE SEDIMENT
(ug/kg in 0-4 cm depth)
EAJ3 Sagamore Woods
Benz(a)anthracene 78 362
Benzo(b)fluoranthene 358 1*784
Benzo(k)fluoranthene 115 558
Benzo(a)pyrene 128 690
Indeno
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- 3 -
Walsh et al. * ' reported soil concentrations in Hew York
State at 3-12 ppm in uncontarainated soil and 90-625 ppm in
orchard soil that had been treated. The RI Table 3-5 reports
that the New York State background range for arsenic is 7 to
10.6 ppm.
Comparing the above concentrations which are natural
in native soils and in agricultural land with the
concentrations reported in surface soils at the Site, 52 ppm
(maximum) and 0.43 ppm (average above detection limits)/ it is
apparent that the concentrations reported could be expected to
occur in this area. Considering that the area around Love
Canal was agricultural land and orchards were observed in
historical aerial photographs the maximum reported in all
Samples, 350 ppra (maximum) and 2.7 ppm (average above detection
limits), are not unusual. Although the RI determined that
arsenic was the primary risk to health at the Site, the arsenic
concentrations reported in soil are apparently present over
large areas of the State of New York.
Because arsenic is ubiquitous it is present in food
and water. Schroeder et al. ' estimated the average intake
of arsenic from food and water as 0.9 milligrams per day.
Using the assumption that a young child will consume 100 mg. of
surface soil containing the average concentration reported as
detected at the site (0.43 mg/kg), the daily arsenic -intake
from soil would be 0.0000043 mg per day. This would be
equivalent to 0.0048% of the estimated daily intake from food
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- 2 -
COMPARISON WITH BACKGROUND CONCENTRATIONS:
Arsenic is i significant element in the earth's
surface. Average concentrations in soils the world over is
5 ppm. In specific areas arsenic can be much higher. This is
true in areas of volcanic action. The dust plume f*ora Mount
St. Helen contained 22 ppra arsenic. ' '
Arsenic has been added to the earth's surface
environment by man. Many metal ores contain significant levels
of arsenic which are dispersed on the surface by mining and
smelting operations. Man has distributed a significant amount
of arsenic in fertilizers and pesticides (insecticides and
herbicides). The Environmental Protection Agency, National
Soils Monitoring Program ' sampled soils from five United
States cities and reported arsenic present in 98% of the
samples and levels in lawn areas ranged from 0.3 to 50.8 ppm.
(A\
The National Academy of Science % ' reported even higher
concentrations are possible as was noted in the following
quotation:
Large residues have been found on orchard
soils that received 30-60 Ib. of lead
trsenate per acre (34-67 kg/ha) per year
from pesticide applications, which began in
the early 1900's. The soils have therefore
received 1,800-3,600 Ib. of lead arsenate
per acre (2,020-4,035 kg/ha). This is
equivalent to an arsenic concentration of
194-389 ppm, if the arsenate remains in the
top 6 in. (15.24cm) of soil. Arsenic was
accumulated at up to 2,500 ppm in a fine
soil.
-------
COMMENTS ON THE RI/FS FOR THE 93RD STREET SCHOOL
These comments will focus on two aspects of_ the data
•
evaluation and risk assessment which are considered inadequate
or inaccurate, namely, (1) the comparison of reported
concentrations in soil with expected background and (2) the
assumptions used to calculate the potential cancer risk level.
The discussions will be limited to arsenic,
polynuclear aromatic hydrocarbons (PAH) and- 2,3,7,8
tetracholorodibenzo-p-dioxin (TCDD). Although there is some
question that the appropriate procedure and evaluation was used
to select the indicator chemicals, the RI/FS risk assessment
focuses on arsonic, PAHs and TCOO as the chemicals which
contribute the most significant risk at the 93rd Street School
yard (the Site). Addressing these primary indicator chemicals
should reasonably address the total risk from chemicals at the
Site.
Exposure to chemicals in soil is the only exposure
media which has significant complete exposure pathways.
Although inhalation of suspended particles, dermal contact, and
ingestion are all potential routes of exposure, ingest ion is,
by far, the n-ost significant route with respect to the
magnitude" of exposure. A single daily exposure to soil which
is used to assess dose will represent the total dose resulting
from the three routes of exposure.
-------
PIPE* & MARBURY
Mr. Amarinderjit S. Hagi, P.E.
May 24, 1988
Page 2
To remediate the 93rd Street School site on the basis
of arsenic in a common fill material like fly ash is
inappropriate. As the EPA report indicates, fly ash has been
and is in use throughout the country for fill, the same purpose
for which it appears to have been used on the 93rd Street
School grounds. It would be arbitrary and capricious -to spend
large sums of money to remediate situations which are present
throughout the country and which continue to be created. As
long as the ash material is covered, any reasonably postulated
threats are mitigated.
2. Folynuclear aromatic hydrocarbons (PAH) are
present in asphalt and motor oil. The paved parking area under
which PAH were found may well have been used for changing motor
oil or may have received motor oil from leaking automobiles.
Because these PAH compounds are presently covered with asphalt,
there is no reason to remedite these areas.
'3. The presence of 2,3,7,8-TCDD in surface soils at
the 93rd Street School has not been confirmed. At the reported
levels, the presence of 2,3,7,8-TCDD should be addressed by
covering with 12 inches of topsoil and vegetation as is being
done at other Superfund sites, as described in the attached
Region VII USEPA Dioxin Sites Weekly Update of March 11, 1988.
On the basis of the attached comments and the
foregoing. Occidental Chemical Corporation requests that the
remediation of the 93rd Street School be modified as suggested
above.
Sincerely yours,
"7
/
Tho
omas H. Truitt L •
Counsel for 7
Occidental Chemical Corporation
THT/bjw
Enclosure
cc: John Wheeler, Esquire
USEPA OECM
-------
PIPER & MARBURY
NINETEENTH STHEET. N.W.
WASHINGTON. O.C. 2OO36
*02-«ei-3000
MAH W«
IIOO CMAftLCS CCMTCM SOUTH
H T*UITT ae SOU*H CHAMLCS STHCCT
oinccr 01*1. »»oM«e« . BALTIMORE. MARYLAND 2I2OI
May 24, 1988 =»c
Mr. Amarinderjit S. Nagi, P.E. Itio"
New York State Department of
Environmental Conservation
Room 222 MAY 2 .»1938
50 Wolf Road
Albany, New York 12233 IUKAU or WKURM HMCOIAIACTION
DIVISION CF MWA^COUS
Re: United States of America,*Ae€ vf. v. Occidental
Chemical Corporation., et al. (Love Canal
Landfill); 93rd Street School Superfund Site,
Niagara Falls. New York
Dear Mr. Nagi:
This letter and the enclosed comments are submitted on
behalf of Occidental Chemical Corporation regarding the
Feasibility Study for the 93rd Street School Superfund Site.
These comments are being submitted in the spirit of cooperation
and not as any expression of culpability or responsibility.
1. The preferred remedial alternative appears to be
driven by the presence of arsenic at the site. The arsenic
appears to be found in fly ash fill. In the February 1988
USEPA report to Congress entitled "Wastes From The Combustion
of Coal by Electric Utility Power Plants," the median arsenic
content of ash from Eastern coal is 75 ppro with the range 2.0
to 279 ppm. Table, pg. 3-18. This is well within the range at
the site. In addition, the report also states (p. 4-48) that
coal ash is used and will be used:
"as fill in asphalt, road bases, parking lots,
housing developments, embankments. . . In the
future, numerous other construction applications
may use coal ash as .fill, particularly if the ash
is available at lower cost than standard fill
materials."
-------
STATE OF NEW YORK
DEPARTMENT OF HEALTH
Corning Tower The Governor Nelson A. Rockefeller Empire State Plaza Albany, New York
Oavx3 Aiproc M 0
June 13, 1988
Mr. Jack Willson
NYS Dept. of Environmental Conservation
50 Wolf Rd.
Room 222
Albany, NY 12233
Dear Mr. Willson:
As requested by your office we have reviewed April 26, 1988
comments made by the Niagara County Health Department,
Mr. Michael Hopkins, regarding the 93rd Street School Remedial
Investigation/Feasibility Study Report. Mr. Wakeman's March 2, 1988
letter to Mr. Schick of your Department stated that areas with
elevated total PAH levels should be excavated to a depth of at least 2
1/2 feet and the soil appropriately disposed or treated. The entire
area should be covered using appropriate methods and with as little
change in the present elevation as possible. The letter further
referenced 4 areas which showed total PAH concentrations ranging from
9.9 to 76.6 ppm.
The decision to recommend excavation of those areas and covering
the entire area with clean soil was baseid upon the following factors:
1. The area in question is a filled area in which low lying swales
were filled in with soil that presumbly came from the Love Canal
area.
2. Some soil log borings made references to the presence of cinders
thus possibly indicating the presence of fly ash. A previous 1979
report by Earth Dimensions also indicated the presence of fly ash
in the soil log borings in essentially the same areas.
3. Dioxin in the surface soils and subsurface soils have been shown
to be present in past surveys or investigations.
4. The soil sampling methodology used (.such as 0 to 6 inches and 0 to
1 foot) does not adequately characterize the conditions of surface
soils of a depth of 0 to 2 inches.
5. The area may be used as schoolgrounds in the future or for
recreational purposes.
-------
STATE OF NEW YORK
DEPARTMENT OF HEALTH
Coming Tower The Governor Nelson A. Rockefeller Empire State Plaza Albany. New York 12237
DlviO Aiftrod. M.O
June 16, 1988
Mr. Jack Willson
Bureau of Western Remedial Action
NYS Dept. of Environmental Conservation
50 Wolf Rd. - Rm. 222
Albany, NY 12233
Dear Mr.
x
In our letter of June 13, 1988 we addressed concerns regarding
the surface soils of the 93rd Street School. The Department also has
concerns regarding high PAH levels in the subsurface soils. The future
land use of the 93rd Street School and its grounds are unknown at this
time. It is possible that construction may be considered in the
future and could involve the excavation of subsurface soils for the
placement of foundations and/or basements. Since this may occur it is
appropriate to consider excavation of "hot spots" where PAH levels are
j.gh. A review of the data indicates these "hot spots" are 4-6 feet
neath the ground surface and have PAH levels up to 300 ppm. The
Department believes it would be necessary to excavate those areas to
minimize the potential exposure should the area be redeveloped or
developed in the future.
Should you have any questions please contact me at 458-6310.
Sincerely,
Ronald Tramontane
Director
Bureau of Environmental Exposure
Investigation
jlh/81680337 C-C, /-,
cc: Dr. Kim
Dr. Hawley
Mr. Wakeman
Mr. Pavlou "
Mr. Violanti/Ms. Rusin - Buffalo RO
-------
Response to:
Niagara County Health Department's
April 26, 1986 Comment Letter
-------
l! i' V", • •
IL -a™" - Ji ;. ~? J'« "' ••"•"——.
' r~"Znrn ti" ~ -v~
a?»o I ^_ _ 5»>»//-
-------
IJ .('. ..i.i ..:i 1-. .. . 1.1 ,
ornci o;-1 PUBLIC H^.LTH S^
MiiilfiH^iiSMIl
• September 12, 1978
To; Or. LaVerne Campbell, Regional Health Director
Frosc: David A. Dooley, Senior Radiological Health
Subject: 93rd Street School Radiation Measurement
On September 9t 1978 at 2:30 p.m., Robert Wozniak of the Department of
Environmental Conservation and David Doolcy of the New York State Department
of Health performed a survey of the school property for possible presence of
radon and external gamma hazards due to the proximity of the school grounds
to o known site of external gamma levels of approximately 60uR/hr. All
external gamma measurements taken inside the school showed no readings that
were significantly higher than normal background levels (SuR/hr.). In addi-
tion, all air sampling inside and outside the school for radon also gave no
significant readings above background.
Therefore, we conclude th.it, except for the problem of the strip of
land adjacent to the school properly, the school itself and all lls property
Is radiation-free and presents no significant health hazard.
OAD/ki
cc: Mr. Robert LaSala, Niagara Falls Assistant City Manager
Or. Robert Utter, School Superintendent
Mr. Wilfred Young, Super. Principal, 93rd Street School
Mr. Robert Wozniak - Department of Environmental Conservation
-------
J —
•// J.
RECEIVE _
MAR 3 01979
N.' Y.'STA'E OUT. L? I.1ALTII
BUFFALO fCGiO;.:.M Crf
J. Hatuazek • Radiological Sciences Laboratory
T. Coalman • Ladiatlon
Lcnucct for Kadon & Ionizing PjJiotion Readings at 93rd Street School
ilorch 26. 1979
You requested till KolleV.er on March 22 to provide the rending
taVen last fill at the V»JrJ :>tre.-.«t £c;.3ol by Lob U'o/.ni.i'.:, -rnicr J.n:J
Tcchnician-J£C and Oava L»oolt».y, Hcd to logical llenlth Gpecialint-Jtate
Dcparti:u:at. ; ttoched are the rcojinr^o provided by a call frooi liob WozniuU
to the Bureau on Ccptc&bcr 11, 1970.
Bob Wozniak vns providns support to the Stata Ilaalth Dcpnrtncnt
on this aurvcy including tho instrumentation for tieaouring the rndon and
the external radiation. Ha JctercineJ tho nunbcr of counts obtained fron
a five cinuto air sar_ple end Save Dooley calculated the equivalent working
level of radon.
It vaa anticipated that tho report to the State Health Oepartocnt
vould include the data obtained in the aurvcy for your rcviev nnd evaluation.
1C called Bob V.'ozniak on March 23 to obtain a copy of the renort. lie obtnincJ
i» copy fron Bill O'Brien rmd advised that the data wns not included in the
9/12 report but vaa referred to as bcinj at background icvola.
The data for external ionizing radiation in tho achool falls in
t:ha general ranpye of ioaizin^ radiation observed in the environment with
the exception of the aooeunnt higher reading "on contact" for the tiles in
the cy^aaaiua* The data for the radon levcl-s falls within the range of.
noaaureninta node in a DOC study of 21 hoces in the New York-Hew Jersey area.
Tue V3rd Street School rcault.i are in the uopcr portion of this ron;c. Tlie
radon results are hiylier than thoae re03ured at the Lc\.-?art School near t'ne
Lake Ontario Ordnance Works site usin^ the aone inatru.'«ntation In a one day
aurvcy. The first and aeconU floor rarion results are nlso within the ran^e
of radon levels reported by E?A for 21 honca in Florida. Twelve of these
hoces arc believed to be on reclaimed land fron phosphate ora mining and
generally have tho higher lavela.
A one ye*r study of tho effect of rudon releases fron tho aite
en tho envirooa and aolccteJ hoces around the LOG*; is being carried out by
EOii witli CZC cooperation. This IncluJcs one cazplinr, location with.the L«wport
School* The above information inJic£tea that it would be prudent to also
verify the radon levels at the 93rd Street School with instrumentation that
«ill provide average concentrations over two to four week perioda.
Attachment
CC: P.
\* Woaniak
V. lUllehcr
E. Frina
7. Haag
-------
MAT OF SAMPLING LOCATIONS FDR 66TH STREET SCHOOL AND BISHOP EUFFY HIGH SCHOOL
•
•
i
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i
i
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V*
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-------
INTERIM REPORT
RE: Niagara Falls - 93rd and 66th Street Schools
Site Surveys and Soi! Sampling
^
A meeting with Mr. Wilfred Young, Principal of the 93rd Street School,
was held on 9/11/78 at 9:30 a.m. regarding the site just south of school
property where higher than normal levels of radiation were found. Mr. James
Adams of the City Planner's office provided information on the location of
the school property line (see map).
The school building and property were surveyed on 9/9/78 at 2:30 p.m.
by myself and Mr. Robert Wozniak of D.E.C. (see memo to Or. Campbell dated
9/12/78 re same). All readings for external gamma as well as radon on school
grounds showed no significant levels above normal background. Background
rates varied from 7-10>jR per hour for gamma, and 0 CP.M for radon. Dr. Fred
Haywood and Woodrow Cottrell of Oakridge National Labs (DOE) accompanied me
on .a rcsurvey of the areas which were soil tested 8/23/73 on the Love Canal
by Mr. O'Brien (BAD), Dr. Mueller (Albany), and myself, and those locations
on the 93rd Street lot which were found to be above background. At those
locations where the highest dose rates were found, charcoal filters were
placed for radon collectors. Filters will be collected 9/12/78, 2'» hrs. Ister.
*
Soil sampling of the vacant lot due south of the 93rd Street School
property started at 10:15 a.m. Four sites v/cre selected for sampling on the
basis of highest possible surface reading in the area. A fifth site was
selected adjacent to the area for normal background level comparison. Sample
holes were dug v/ith the assistance of a power auger on the back of a tractor
supplied by D.E.C. Mr. Joe Slack and Mr. Paul Counterman lent great
assistance in the sampling and mapping procedures. Dr. Haywood and Mr. Cottrel)
(DOE) took samples at all sites which are identical to all samples taken by
me for the NYSHD and EPA. They also performed independent dose rate measure-
ments for external gamma and beta radiation present.
Samples were then collected from the playground area behind the 99th
Street School where higher than normal readings were found. A hole was cut
into the asphalt at a point where ihe highest reading was found, and it was
discovered that some type of rock bed material under the asphalt was the
source of activity. The material appeared to be a combination of limestone
and slag material. Samples of the material were collected and established as
priority samples for analysis. Investigation has already begun on the source
of this material by identifying contractors and construction firms for the
99th Street School .
At A:30 p.m.. Dr. Haywood, Mr. Cottrell, and myself went to the
Street School for an initial survey of the property. An area of higher than
normal act i vi ty ~60>iR/HR was found in the playground area directly behind the
school. It was thought that this was the same material that was found at the
99th Street School since the 66th Street School is a carbon copy of 93th, and
they were probably built by similar contractors within a similar time span.
Wo then proceeded to survey the land adjacent to Niagara Catholic High School
and found that the parking lot in the southwest corner of the Bishop Duffy
section of the school also contained activity (dose rates) similar to the
66th and 99th Street Schools. Ho sampling of thase new sites on 66th Street
will be done until analysis on the samples collected at 99th Street School is
-------
AI J-f
el<
«**«
'INC
VASTS ^IIPCSAI s:— - »~c?.r
~
nfscaomc
Haterfal excavated fram =3rd Street School. Check for cantarninet ton of
soil by rr.attrial placed at 93rd Street School from Lave Canal in the
1550's. . \ „, » rk >
..../^1 /,..,/..-/-./ •?, ..,,. ,,.., /://,/.../<
/*/.,-' A //V^X/-'; • ///. ,/ // S'.t"-*'
/- ^
/ «..
issirarsc iiie
Vasiss r
landfill JS3 L*SOOO(S)
_Acres
Confirzed
ef Htszrtious Vastes;
Material excavated from 93rdr...St._
School
/*
cr- A*. //
<.«'»'V
^ :;u=ier of Psr.ss
i^.' "usrer of lisoccs
l~j Scs?ec:ed ^
tons," gallons)
Unknown
•"Use aiciiisr.ai sheets if sore space is seeded
t i
"-*'''-'
i , , / XV"
-------
ALCLIFf LANDSCAP/NC
103.
DEC SITE * #320-70
£«i 7"o ££
Ct £ I • - «,
• c • * r 3
PLAZA
FILLED AREA
(CLEAN FILL
O.« ,r/»*T ^
' *»« ffc^«%
«--...
To
-------
102.
SDRFACS WATER (continued)
The lite is not within any flood plain although the area was
por.ded prior to fill placement. There are not major wetlands with 2 miles
although scattered small areas of 1 mere or less can be found.
AIR
Air quality problems are not eccpected. If any contaminated
material was not removed, only small quantities are expected to remain.
The nearest residence is 300 feet southeast of the site
(Sffie Drive). There have been no complaints of odors received by the Niagara
County Health Ztepartaent, It is estirated that 500 to 1000 people live within
1 mile of the site and roughly 3000 within 2 miles.
TIRE AND BgLOSICE
Ihere is no possibility of fire or explosion at this site.
DIHSCT Cd.'TAST
If mH contaminated material was removed from the site, there
is no dangsr of direct contact. Contact is possible if the material was no
renoved completely,
t
CONCLUSION:
There should be no problems here if all the material from the
93rd Street School was removed. This topsoil was never confirmed to be hazardous.
If any contaminated soil remains, it should be removed. Sampling is needed to
confirm its presence or absence.
Sampling should include surface sampling at random points ir*
the previous storage area. Handom samples could be taken from nearby areas as
well. Samples taken at depthj of 2 to 3 feet should confirm that no contaminated
material was buried here.
The on-site well could be aanpled to check for groundwater
contamination, although the direction of groundwater flow is not known.
-------
101.
BCAMPUHCN OF HA?S AND ASIAI PHOTOCHAPHS (continued)
The Bite received the material from 93rd Street in 1979.
There Mere no available photographs taken in 1979 and therefore, no inform-
ation on possible dumping was available.
?R57IOtJS SAMPLING JgiD ANALYSIS
Thera is no record of previous sampling at this site or
of "the material excavated from 93rd Street on file with the Niagara County
Health Bepartaent. Mr. LaHarca is unaware of any previous sampling.
SOH5/G3DLOGT
The USUA Soil Conservation Service, Soil Survey for Niagara
County lists the nativsl soil in this area as Lakemont silty clay loam. Diese
soils are generally deep, poorly to very poorly drained and level or depression
al in relief, Lakeinont soils are normally ponded during wet periods .
The area of the previous storage site, has been elevated
several feet using demolition debris (concrete, etc) to fill a formerly low,
marshy area. Bigging in this area is likely to be difficult due to the size
of the concrete rubble (61 dianeter or larger).
Bedrock is Lockport Dolomite of over 120 feet in thickness.
A localized perched aquifer is ejected above the original
Lakenont soils. According to llr. LaHarca this aquifer is expected to flow to
the southeast due to the drainage prior to filling.
The Lockport Iblonite may contain several water bearing zones.
A well recently drilled on-site 150 feet west of the old storage area is said to
be U3 feet deep with 26' of water. The direction of movement of groundwater
aquifers is not known. Bedrock wells in this area eomonly contain noticeable
quantities of hydrogen sulfide, thus providing low quality drinking water. Many
wells are still used for non-drinking uses. Public water is available, however,
there raay be some wells used for drinking within a 2 mile radius. The location
of specific wells, other than the on-site well was not determined.
The potential for any groundvrater contamination is suspected
to be small due to the snail amount of tonic material present, if any, and the
slow permeability of the Lakemont soils.
SPHFAC5 WAf 3R
The nearest surface water is Cayuga Creek, which is 1000 feet
west of the site. Cayuga Creek flows south to the Niagara Biver, 2 miles away.
No drinking water or industrial water is taken from Cayuga Creek. The City of
Niagara Falls drinking water intakes are located 3 miles down stream from the
mouth of Cayuga Creek.
-------
100
MAI-IS
ALCLIFF LANDSCAPING (DEC #932070)
LOCATION
*
The site is located behind Alcliff Landscaping, Inc.,
1975 Military Road in the Town of Niagara.
A site sketch is attached
The site is owned by Alcliff Landscaping and Nursery,
Inc., 1975 Military Road, Niagara Falls, NY 1ii30U. Any* correspondence should
be directed to Martin A. LaHarca, Vice President (297-3590).
HISTORY
In September, 1979, the Walter S. Xozdranski Company
excavated roughly 15 tanden dunp loads of topsoil from the baseball and foot-
ball fields at the 93rd Street School in Niagara Falls, under contract to the
Board of Education. The topsoil vas alledged to be contaminated from contact
with material removed from the Love Canal in the 1950's. Kozdranski back
filled the ballfields with clean soil after placing a plastic liner.
Kozdranski brought the excavated soil to Alcliff Landscaping
where it was stored in an area behind the Alcliff building. According to
Ifr. LaMarca, the DEC informed Alcliff that this material could not be disposed
without a permit and ordered the soil removed. Reportedly, within one week of
arrival at Alcliff, Ebzdranski removed the material and transported it to CSCOS,
where it was used for landfill cover material.
Currently, the area which previously held the material from
93rd Street is level and rough graded. This area was previously filled in 1973
or 197k to raise the grade in a former wetland. Clean fill including debris
from the demolition of lith Street were used for fill. Several piles of fill
material (soil and wood chips) are located nearby. The fill piles are orderly.
There is no visible evidence of chemical contamination.
In the future, this area may be developed as a residential
subdivision .
ECAimiATICK OF MAPS AND AERIAL FHOTQglAPHS
A review of USGS topographic maps, Tonawanda west - 7V series
and USDA aerial photographs ARE 37-82 (1958), ARE 27-31 (1958) and ARE 2GG-27
(1966) revealed little infornation about the previous land use. The land was
apparently swampy and lightly wooded in 1958. At this time, most of the sur-
rounding area was cultivated. By 1966, the surrounding area was developed to
near its present extent.
-------
NIAGARA COUNTY
DEPARTMENT OF HEALTH
Service Request .................. _..:.'. ......... ....'":„£ ........ 1 ":...'.'. ........ *.::;
-f
Oripinator of Complaint . -J. : >..\ ......... .'./.J.-....V>. ................... Address
Owner [[[ Address
Occupant . ............... I. .1 '.....' ........... :. ....... L. ..'.!.-....:'..•' .\ .......... Address
Code Activity .................
Code Location ..............
Service Request No ........
Dtte Received Complaint
lit
Hour?
REPORT OF INVESTIGATION
VV f>'?-/lC/ +J"l
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-------
REQUIRED TESTS
LlIiiOLOCIC TESTS REQUIRED
BOUTIN f POTABLE WATER lOl-M
SIANOARO PLATE COUNT o:saoo
TQTPAL COLI FORMS MF 027000
«HfUB> REPORT: TOTAL CHLORINE RESIDUAL 002101
POTABLE WATER WITH NITRATES I CHLORIDES (02-1)
STANDARD PLATE COUNT 026800
TOTAL COLIFOHMS MF 027000
CHLORIDES 001001
WTHJULS OOU8O1
»W««l»C WATER SUPPLY INSPECTION 103—1)
vnAMtOARu PLATE COUNT 026800
rO>TIAL COLIFOHMS MF 027000
Mfuo REPORT IALL OR PART OF FOLLOWING^ PRECHLOR. 029125
•CWCHLOR. 07U22S. TOTAL CHLOR. RESIDUAL 002101.
:«!«. TYPE 029300. CHIM. AMOUNT 02942S
)A.*H1MG BEACH 104—11
'CWJHi. COLI' OHMS MF 027000
:f£Ali COLIFOnMS MF 027200
IMtfflRlKATEO POOL (04-11
;TAN.OARO PLATE COUNT 026800
•Q.TAt COLIFOflMS.MPN 078UOO
ifilUDi REPORT: TOTAL CHLORINE RESIDUAL 002101
lQl*.POTABLE WATER ISU"F ACE)'lO«-1)
'QOtMH. CQLlFOliMS, MF 027000
MSKfcPOTABLE WATER ICMLOR. SEWAGEl «OS-H
OTAi COLIFOHMS. MPN 026900
TtmiQxOG'CAL TESTS REQUIRED IN ADO. TO ABOVE
ECALCOLIFORMS. MF 027200. MPN 027100
EOW'tST FOR MICROSCO*IC ANALYSIS
CHEMICAL TESTS REQUIRED
ROUTINE SANITARY ANALYSIS 110-21
PALL OF THE FOLLOWING
PFRK AMMONIA NITROGEN ooosoi
P NITRITE NITROGEN 000709
P NITRATE NITROGEN 000801
D CHLORIDES 001001
P ALKALINITY IMETH. ORANGE) 001501
P ALKALIN. (PMENOLPHTMALEINl 001401
PPH IN LAB 001900
D SUSPENDED MATTER OOSOOI
P VOL. SUSP. MATTER OOilOl
P TOTAL PHOSPHATES 007 101
P TOTAL RESIDUE D02S01
P TOTAL VOLATILE RESIDUE 002801
P ORGANIC NITROGEN 003101
[3 SETTLEABLE MATTER IHN«| 004713
P SETTLEABLE MATTER I1HRI OO48 i3
P SETTLEABLE MATTER <2HR| 0049.3
P B.0.0. 15 OAYI 005601
P C.0.0. OOeSOt
CHEM. ANALYSIS-POT. WATfH HI— i)
P ALL OF THE FOLLOWING
P COLOR 000100
P TURBIDITY 000200
[3 ODOR. HOT 000300
pOOOR. COLD 100300
P FLUORIDES 000401
P»H IN LAB 001900
P MANGANESE 010201
£3 IRON 010001
ppREt AMMONIA NITROGEN OOOSOI
P ALBUMINOID NITROGEN 000801
P NITRITE NITROGEN 000709
P NITRATE NITROGEN OOQ801
P OXYGEN CONSUMED FROM
PERMANGANATE 000901
D SODIUM 010701
P CHLORIDES OO1001
P HARDNESS ITOTALJ 001101
P ALKALINITY IMETH. ORANGE) 001501
P A.UIALINITT (CAR*ONATt| 001W1
P ALKALINITY ItlCARBONATfl 001701
CHEM. ANALYSIS.POT. WATFR 11 J-^L^B
PALL OF THE FOLLOWING ^""^^
UN AUDITION TO L1 1 1-23 >
PCTANIO is 002901
P MB AS 003001
P TOTAL F^IOSPHATIS Q07«oi
P ARSENIC 009301
P BARIUM 009401
Q BERYLLIUM 009501
P BORON 009601
P SILVER 010601
P TITANIUM 010001
P CADMIUM 08S70I
P TOTAL CHROMIUM 009801
P COPPER 009901
P LEAD 010101
P LITHIUM 012501
P MERCURY 010301
P POTASSIUM 010401
P SELENIUM 010SOI
P ZINC 010901
P PHENOLS 002701
P SULFATES 002401
P TOTAL DISSOLVED SOLIDS 002001
POTABLE WATER PHYSICAL EXAM i08^BB^
P ALL OF THE FOLLOWING ^^B
P COLOR. TRUE 000100
P TURBIDITY 000200
P ODOR, HOT 000300
P ODOR, COLO 100300
P pH IN LAS 001900
P COLOR APPARENT tOOJOO
OTHER CHfM. TESTS REQUIRED
r~] SPECIAL TEST PATTERN NO.
.COrO
T?fO*(:r.') » /£, Cl\ h r 1 1 1 T -I •
fr^f "7-3 /J C1*
'
c** /tiilt ' t.tf i-
n
.
V.
Itotical distance
.mm {* If north. — If Mush of reference line)
Inference Longitude 7* 'm __..__. ^
Maniontal dist»nce—_^__—__mm {+ If west, — if east of reference line)
-------
. «»•». N T. O70I
NCW YORK STATE DEPARTMENT OF HEALTH
DIVISION OF LABORATORIES AND RESEARCH-ENVIRONMENTAL HEALTH CENTER
ALBANY. N.Y. 12201
REQUEST FOR ANALYSIS
B
< >.
2S£
S = o
IK
LARArePSND .
VtAH
TESTING PATTERN , i_
. 5 SAMPL P_ RFfVD. . , , . , ,
LAB ACC. NO. MONTH "DAY
_j NUMBER OF RECORDS , it
i i it
HOUR
P
SAMPLING
" SIU
NO. or
SAMPLES
IN SHIPMENT
i A/I i t£
RQrjRAM COPE \ i
A. NUMBERED ST>
B. UNNUMBERED
ICITY OX
LOCATION TOWN,
LATITUDE t_Lj_J<
COMMON NAME.S
, / & ./P.tf.V/, ,
iiii.iiiii
, i! N4UE /-3V>/ *^ ' •J^/'V^^/M /-'•A . A/,/ ,
irinM.STA (<;nnnre) wo , , • , . , , i ,•
SITE-DRAINAGE EASIN NO. L_J — i! N.Y. GAZETTEER NO. %£/_j2_2-s I
/Wy9 (^-/l/'s-l /•r'S/JS <~^UNTY ////^ 9 ^ /? /?
ySWATERSHED. MILE POINT, ,/?,/ , ^!/y, / , A A ,// /7 ,/•'*, ^ ,(?,/?,/, , ,
A^i^i iX^^iV'/Pi i/* 1^1 i/5 'Ci ^? >° f i/1 ^i ^/ i i i ii
, 1,11,11.,: ' / J7S CHAR. MAX.,
CT DESCRIPTION OF SITE
i'fl CHARACTEHS UA».I , , t t • t |
TIME OF SAMPLING
GRAB/COMPOSITE FINISH
./.t?,«
MONTH DAY HOUA
COMPOSITE START • ' ' I—I—i • ELAPSED TIME:
DAY HOUB
DAYS HOURS
COMPOSITE ACCORDING TO TIME:
ML. EVERY.
.MIN.
COMPOSITE ACCORDING TO FLOW: VOLUME REPRESENTED BY SAMPLE.
TYPE OF SAMPLE (SELECT FROM LIST)
,: DESCRIPTION:.
COMPLAINTS. OBSERVATIONS. REASONS FOR SUBMISSION
Q
ILLNESS
TASTfc/ODOn
TURBIDITY
jcoion
IMPAIRED USAGE
Q J STANDARDS VIOL.
Q]FISHKILL
^ ] ALGAE. WEEDS
Q] NATURAL DISASTER I
QWUTINESURVEIL
Q SPECIAL STUDY
Q] NEW EQUIP. OR PHOC.
Q'j EQUIP. FAILURE
OTHER I
REPORT RESULTS CO
TO (NO. OF COPIES): IXO
RO
FED
LPHE
«-SLt ENTER 0.1. OR 2
I INTERRUPTION IN CHLORINATlON
| REPAIRS IN DISTRIBUTION SYSTEM
] IMPROPER SHIELDING OF WELL
j APPARENT SOURCE OF POLLUTION
| OTHER
SOURCE OF POLLUTION
DISTANCE TYPE
ATTENTION OF:
'*/
SUOMHTCD DY
TITLE
TYPE OF WELL CONST.:
CHARACTER OF SOIL:
OTHER OBSERV
R DATA AND FIELD MEASUREMENTS I
u
1 Q£utt COVER (%> iii'
1 AH§/"g»l, ,,.,,„, .
-------
TOWN OF NIAGARA
COUNTY OF NIAGARA. STATE OF NEW YORK
NIAGARA FALLS. N. V.
710S LOCKPQBT RO*D
NIAGARA FALLS NEW YORK 14305
• PHONE 29T-J1SO
September 5» 1979
Niagara County Health Dept..
10th and last Falls
Hiagara Falls, N.Y. 1^303
Dear Mr. Maida:
Please accept this letter to confirm our telephone conversation of this
Sate whereby, this office is requesting samples be obtained from the dirt fill
being stored behind Alcliff Nursery on Military Road, in the Town of Niagara.
This material was removed from the baseball field at the 93th St. School
in the Love Canal Area.
Please test this material and Bend a copy of the report to this office.
Re sp e c tf ully ,
A. Valsh
•' Building Inspector
Town of Niagara
JJW/pc
-------
&.,« H*/ •
I'M/••-'',
2t-| ttt-.::Scr H, 137>
Xr. James A. Wai ah
..iiiltiin,; inspector
Town of Niagara
71 DJ Lock;«rt Road
Fall*, *.:.Y.
£•: Uoil Ai.alynlo
".cliool-
Mr. Walsh;
As per your raqucit of 7/1/79, be uuVictJ tint ou 9/1/79 a amber of this
!cpnrtru:r.t ** staff Sasnrf on infor^dcion supplied In '/our letter, obtained
a sanplc of the fill antcrinl beir^ deposited behind /deliff Nursery, Town
of •Tia'.ara. «ew York.
EC advised that said saaple lias been forwarded to the N.I.S. Dcpt. of Health
Laboratorieo, Albany, New York for AiiMlj
Very truly yours,
John C. Malinchoci.
Deputy Chief for
Air Pollution Control
JCH/kb
cc« C. Aaery
J. Ralioe
-------
It DiARSIWC 4/23/88 Pigt 3.!
-out tftCKCI NINI3K1 NINI312
US
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-------
Tilt DsASSENIC 4/23/88 Page 2-1
• rau SflCXCl HJNI351 N1NE3J2
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3.0
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-------
fil* D'.ASSIHIC 4/23/88
Fast 1-1
row BACKCS NINI3I1 NINI3I2
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-------
BACXAft, BACKS SHICT BACXtt X)
Distribution fitting
ata ^tor: N1N£3I2,NINI3K1 SILICT NINI3I1 (350
istr^rations available:
(1) Bernoulli
(2) Binomial
(3) Discrete uniform
(4) Geometric
(5) Negative binomial
(6) Poisson
/*""'* «'
(7) Beta
(8) Chi-s
-------
Two-Sample Analysis iesults
pit
Statistics: Number at Obs.
Average
Variance
Std. Deviation
Hedian
Sample 1
165
1 1.2552
151.67
12.3154
7.2
Sample 2
146
14.4158
380.355
19.502?
5.85
Pooled
311
12.7389
258.982
16.0929
6.5
f. Interval For Jiff, in Hean$: 95 / Percent
qual Vars.) Sample $ - Sample 2 -6/7593 0.438092 309 &.F.
Vars.) Sample 1\- Sample 2 -fr.85965 0.538448 239.1 D.F.
,\
f. Interval for Ratio of Variances
Sample 1 * S
othesis Test for HOs liff * 0
vs Alt: HI
•t Alpha * 0/05
Percent
puted t statistic * -1.72852
Sit. level « 0.084894?
so do not reject HO.
* 4.
I,/*/
/ •
1 / 5
Frequency Histogran
60
80
100 120
Two-Sample Analysis
•pit U BACXAP, IACXCI SILXCT BACKCSX)
.•Pie 2' (N1NI3I1 SZLICT NINI3SK350),N!NI3I2
-------
Distribution Fitting
Data vector: BflCXAD.BftCXCX SZLZCT BACXCS X)
"(3)
(4)
Distributions available'.
<1) Bernoulli
(2) Binomial
Discrete uniform
Ceoaetric
Negative'binomial
•(6) Poisson
Distribution number: 12
Shape (alpha): 0.835226
Scale (beta): 0.0742083
(7)
(8)
(9)
(10)
(11)
(12)
Beta
CM-square
Irlang
Exponential
F
Gamma
^-J.
(13)
(14)
(15)
(16)
(17)
(18)
Lognormal
Normal
Student's t
Triangular
Uni form
Ueibull
Frequency Histogram
BACXAD.BACXC! SZUC7 BACXCZ >0
-------
Two-Simple Analysis Results
•
lanp.le Statistics:
Number of Obs.
Avenge
Variance
Std. Deviation
Hedian
BftCXCR
165
10.7552
161.484
i2. 7076
7.2
Sample 2
147
16.6986
1143.85
33.0209
5.9
Fooled
312
13.5554
624.147
24.9829
6.5
Conf. Interval For^Diff. in Means: 95 Pert
(Iqual Vars.) Sa^Of 1 - Sample 2 -11.52 ?0.366969 310 D.F.
(Unequal Mars.) Samples! - Sample 2 -il.TjrtS -0.102498 182.5
Conf. Interval for latio of Variances:
Sample 1 + SamHe 2
Hypothesis Test for HO: Diff »
vs Alt/HE
at Alpha « 0.05
Percent
Coi^ted t statistic » -2.09759
Si9. Level • 0.0367506
so reject HO.
i
Frequency
f
r
*
u
e
n
c
120
80
0
40
30
120
7*4
3/2^
15 4,1
100
200
300
400
Tretutncu Histogram
-------
5.) A regression curve is fitted to the background data.
Based on numerous trials and past experience, it vas found
that a gamma curve best fits the data. The curve fitted is
then examined for goodness-of-fit. In this case this vas
done by visual examination, however again formal statistical
tests could have been used. Zn this case the fit Is
considered adequate.
6.) Using the same type curve as in 15 (gamma) fit a
similar curve to the sample data. Again examine'the curve
for goodness-of-fit. The fit of this curve is also
considered adequate.
7.) Plot the density functions representing the curves
obtained in 15 and 16 on the same axis. Compare the curve
for similarity. In this case ve feel the curves are quite
similar.
Based on the above analysis ve consider the distribution of
arsenic concentrations in the soil at the 93rd Street site to be
similar to the background arsenic concentrations vith the
exception of the single point at 350 ppm vhich is apparently
elevated.
Copies of appropriate computer output are attached for
reference.
-------
ILLUSTRATIVE EXAMPLE OF METAL DATA COMPARISON METHODOLOGY
In the preceding letter, statements were made which referred
to our comparison of metals concentrations in soil at the 93rd
Street School site to our previously compiled background
profiles. The following is an example of how we compared these
two data sets to reach this conclusion. Arsenic data*was
selected for this example. A similar procedure can be followed
for each metal.
»
The comparison was aided by the use of a statistical
software package (STATGRAPHICS) on a personal computer.
The following steps were followed:
1.) Compile a representative background data set. In this case,
we used the data set previously compiled for arsenic
concentrations in soil for the Niagara Falls/Vheatfield
area. This database was developed for similar use at another
area site. Specifically, it was used as a baseline for
comparison of soil metals concentrations at Gratwick Park in
North Tonawanda (1987) and has subsequently been used at
other area sites. We consider this data base to be
representative of local background conditions.
2.) In this case it was noted that 33 of the 165 background
values for arsenic were reported as below detection limits
(typically 5 ppm). in this comparison we adjusted for this
using two scenarios. The first was to assume that all values
reported as below detection limits were 0 (zero). The
second was to assume all such values were at one half the
detection limit. We found that in this case the analysis
was not very sensitive to which scenario was used. We feel
that scenario two is a better estimate of actual background
conditions and therefore will use it in this example. The
results would be only slightly changed if we would have used
scenario one.
3.)The data from the site (combined round one and two data)
is plotted as a histogram and examined for obvious outliers.
In this case it appears that the single data point of 350
ppm is an outlier.
4.) The neans of the background and sample data are
computed and compared. In this case it was found that the
aean of the background data (11.25) was approximately equal
to the sample mean (14.4) with the outlier excluded. This
is'considered adequately close for this purpose.' Formal
statistical tests could be performed to verify this, however
it Is noted that most coam^nly used statistical testj would not be
valid in this case since the distribution is apparently not
parametric.
-------
Page 6 ApJUl 26, 19&&
determined and i& the uxute
-------
16, 79SS
In all oi the. above, cases, PAH concentAotoon -wall AoweveA we would contideji tome, falloioup tampling
-in the. a*za o& that detection to be. appropriate, to better
the. extend o^ contamination. ThiA thould 6e done pA^oA to
a \ejned4jdl option,
It it noted that none o& thz typical Love. Canal indicator compounds
were, {ound at the. 93rd Stre.e.t tite..
5} Evaluation o £ migration pote.ntial: We con^ide^ thit potential to be.
tmall bated on thz absence oi contamination in the. per4jne.ter wellt
and ^uA^ace wateA and our under.ttandi.ng o& local toitt and qe.ology.
We. do not consider grounduxiter remedial actiont to be. ne.ce^tary.
6) EKpoture. a*te.ttefl\e.nt/Kitk a^^e^Ament; We ie.el that an incremesital
atte.ttme.nt tt.ould have, been peA^oAmed, that -it that in addition to
tttunating absolute, r-itk, an estimate, oi the. incre&ted ritk over
background thould alto havz been provided. SimiLLarly, an estimate.
oi the. decAea*e ritk a^ter Aemedxiitcon thould have, been pAou^ded.
Ba^ed on our zttimzt&t the. -increated ritk over background and the.
decreased ritk aiter remediation are. ne.gligable.. Bated on the^e.
we rfeel that the. no action alternative, way be,
and thould be
We otto .4 eel that the. expo^uAe tcenar4.ot uted wake, a number o&
over-contervative. a&tumptiont. Thz cuimjlativz e^ect o^ thzte.
tLtAunption* -u to grVLtty oueAe^tunate the Ax^fe a^&occated with
thz *itz. We can elaborate, on thit -ii dztirzd.
7] Evaluation oj remedial option* : Bated on thz przviout dLitcuttion,
' we IZZJL tnat thz no action altzrnativz it a viablz altzrnativz.
alternative thould not bz eliminated irom consideration.
We alto question the attumption that any excavated watte. material
would be a RCRA hazardous wn&tf.. We *upect that the watte material
{ound at ^/u-5 titz would pott the EP toiicity tett and that it would
exhibit no other hazardout characteristic*. We do not believe that
thit material would be a listed watte and we tutpect that LCTP extract
concentrationt oi diczin would be well below Ippb. There doet not
teem to be any "Landfill ban" contaminants present in si-Qniiicant
quantities. We ieel that the RCRA status o{> the waste should be
-------
,Page 4 April 26, 19tt
We have attached compute* output wh^ch demonstrates our comparsion
oi the arsenic concentration distribution irom 93rd Street to our
OA^ejuc bacfeg-tound proiile. This analysi* suggest* that only the
single result oi 350ppm at 1-P4V is outside oi the expected distribution.
We can demonstrate similar relationships far the other metals 'ii requested.
Based on the above discussion we {eel that the metals concentration* faund
on-site are essentially typical background far the Niagara falls area with
only rarely isolated and apparently unrelated exceptions. Since these
isolated exception* occur only in area* direct contact is not possible
(either subsuriace or below asphalt pavement), toe *ee little significance
•in these value* and we are not very concerned with them. In addition we note
that the value* in the ranges oi the exceptions (*everal hundred ppm far
ar*enic, over 20ppm far mercury, etc.] have been faund at a number oi other
site* in this county and have not resulted in remedial actions being taken,
even when these concentration* were faund in suriicial sample* irom accessible
area*. We can not j'ustiiy taking any remedial action based on the metal*
concentration* faund at the Ninety-third Street site.
With regard to the organic* data, and pe,!>ticide* we agree with the consultant
that volatile organics do not seem to be oi much concern here.. We do not
agree that PAH compound* are elevated above typical background values in any
sample collected at this site. While we have not compiled farmal background
profiles at this site we have compared the total PAH values at the 93rd Street
site, to those trom other studies -in the LaSalle area sunrrary oi thi* comparsior.
is provided belDia:
Street School: 5! oi sample* exceed 70ppm
(total PAH), maxx'jTum value"
76.6ppm
average is less than 4ppm
64th Street-South: 37.% oi samples exceed lOppm
(1965 WUS data) maximm • 173ppm
average « 14.7ppm
64th Street-North 3*8 exceed 70ppm
(79*5 A/US aata) maxinwn - 100.6ppm
(2 samples exceed. lOOppm)
average* 25.3
National fuel Gas
Site (MUS &ata] 25! exceed 70ppm
rraximun • 63.7ppm
39th 'S&uezt 1U1S )9i5j: 33! exceed 70ppm
maximum • 16.S
average • 1.Q&
UiaojBJia falls Kusine^t. 50! exceed 70ppm
form* Site: maximum • 63.7ppm
-------
Page. 3 April 26, 79££
3) Evaluation oj the zx.te.nt oj waste./Jill nat.iiA.ial: The. horizontial
and vertical extent oi waste/iill material has been adequately
deiined.
4) Evaluation oj the, sianiiicance oj contaminants present on-site:
As previously noted, we 4eel that the. consultant has substantially
overestimated the. significance, oi the. contaminant concentrations
present on-site. By our interpretation, the. distribution oi
contaminant concentration* iound essentially matches the. typical
background distributions typical oi the. general Niagara falls/
Uheatiield area.
This department has complied bcc^round profiles ior arsenic,
chromium, copper, nickle, lead, zinc and mercury in soils in the
Niagara Falls area. These profiles were compiled irom the results
oi about 200 data points in eastern Niagara falls and Wheatiield.
The data was screened to remove anomalies and suspicious data,
compiled and curves iitted to each distribution. These proiiles
have previously been used by this Vepartment and by the WSVOH
to evaluate the significance oi metals contamination at other
area sites. We ieel that these proiiles are adequate ior this
purpose and are the best available source oi background data in
the study area.
The above proiiles were made available to PEC and were used by the
consultant. However, we ieel that the method used to compare the
on-site data to these background proiiles was inappropriate. The
consultant essentially compared the individual concentrations oi
each metal to the average concentration oi the respective back-
ground proiif.es, subsequently labelling an individual concentration
as "exceeding background" ii it exceeded the average background
concentration. Th+s method oi comparision is not satistijcally valid
and yields misleading results. The appropriate method oi comparision
would be to compare the distribution oi metals concentrations in the
on-site samples to the distribution oi the background concentrations.
We have done this. Using this method it is our interpretation that
oi the 147 samples analyzed irom the sitz the only results which are
outiidi oi thi expected background distribution are:
-arstnic at 350ppm in sample 1-P4V
•cadmiumat at 133ppm 4ji sample I-P4P
-lead at t43ppm in sample Z-PH4A
-mercury at 23ppm in sample 7-PIC
The remainder oi the metals data is considered to represent only
area-wide background. This conclusion is reinforced by noting
that the spacial distribution oi metals contamination appears to
be random (except ior lead which is apparently slightly higher
adjacent to the paved driveways and parking lot, possibly suggesting
the iniluence oi past runoH containing traces oi leaded gasoline.
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Ipril 26, W*
"Discussion ok speciiic details oi the. report fallows:
1) Adequaci/ oj the, data base.: While, it may be. necessary to
resampie certain wells to obtain adequately low detection *
limits to meet statutory and regulatory A. equir entente, we
ieel that the. data base, provided is adequate to reasonably.
estimate the. extent and se.vM.ity oi contamination on site.,
to assess possible, exposures attributable, to the. site, and
to evaluate, conceptual Aemed^a£ actions. Some add^tiona£
characterization oi the. areas oi possible dioxin contamination
may be appropriate to better locus on the precise extent oi any
dioxin contamination in order to iinalize a remedial design.
The soil/waste sample data base is adequate to provide a rea-
sonable degree oi statistical confidence, in the data.
2} Historical data: While the historical data presented in the
KJ -aepcAt appear to be accurate, several items are noted below
which should be added ior completeness:
a] A housing project previously existed on the
sooth portion oi the property. It appears
that iormer road beds and foundations are. still
present beneath the top soli in this area. It
is likely that debris irom the demolition oi
these structures my also be present.
It is noted that a 1979 radiation survey conducted
by the WSVOH iound radiation levels somewhat above
background in the area oi the iormer project. This
radiation is apparently associated with slag* material
used in the construction oi the iormer roadways. While
this material appears to be oi little concern in its
present location, some precautions may be. appropriate
ii it is necessary to excavate this material. Several
documents regarding the previous radiation surveys are
attached.
b) In 1979 , suspected met Ate traterial was excavated irom
the ball diamond area and was eventually disposed oi
at CECOS by Walter Kozdranski Trucking Company. It
is reported that a ioot or more oi material was removed
(10 to 20 or more tractor trailer loads] , a plastic sheet
placed and the area backfilled with clean soil. Several
documents irom our iiles regarding this action are attached.
c) We question whether or not any oi the. material at the school
site, was actually contaminated by Love. Canal chemicals. It
is noted that none oi the common Love Canal indicator chemicals
were iound at the 93rd Street site..
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•
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Response to Niagara County
Health Department's Comments
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Section III
Response to Written Comments
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Q. I thought the Superfund was there so the government could take
immediate corrective action to try to stop further contamination
problems until a permanent remedy could be done. Under Superfund what
do you mean by permanent cleanup?
A. Under federal Superfund, an immediate corrective action called an
Expedited Response Action (ERA) could be initiated if justified for a
particular site. The contamination at 93rd Street School site did not
warrant such an action. Under the new Superfund Amendment and
Reauthorization Act (SARA) reduction of toxicity, mobility or volume of
waste is considered to be a permanent cleanup. The stabilization/
solidification process, which reduces toxicity and mobility of the
waste is considered to be a permanent solution.
Q. Why has this site been studied so many times? Why wasn't it studied
once and then get on with the cleanup?
A. Phase I and Phase II investigations at the 93rd Street School site
provided preliminary data upon which a full scale investigation could
be designed. The RI study is a much more detailed and involved
investigation which provides sufficient information to evaluate
alternatives for remediation of the site. Additional sampling/data
collection may occur during design to further define the area to be
remediated. Each investigation builds on the previously gathered data.
Q. Why is it taking so long to get this site cleaned up? With proper
engineering, design and foresight a number of these activities, like
cleanup of the creeks and cleanup of the 93rd Street School site, could
have taken place concurrently?
A. The 93rd Street School site and Creeks remediation are two separate
components of the overall Love Canal remedial program. At the time the
creek remediation project was in the remedial design, the School site
was in the RI/FS stage. In order to combine these projects, the work
on the creeks would have to be delayed until the school project caught
up. Delaying the work on one project to makf-. it occur concurrently
with another project did not seem justified, especially since clean up
of the creeks was a condition of rehabilitation of the EDA, as per the
Habitability Study criteria.
Q. Why wasn't the remediation of the EDA looked .at as a whole? That would
have saved us a lot of time in revitalizing the EDA.
•
A. The Love Canal site is one of the most complicated sites in the
country. Extensive investigation and engineering studies were required
to develop a remedial program. In the beginning, the EDA was looked at
as a whole and various sub-units were developed in order to create
workable components. This allowed the project to proceed in phases,
and the most immediate needs were addressed first. Looking at the EDA
as a whole would have further delayed the work at this site.
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G. MISCELLANEOUS
Q. Are you going to post signs to warn the children?
A. Signs will be posted and work areas will be temporarily fenced to
restrict access during remediation of the site.
Q. How will this 93rd Street School site project affect the habitability
study, the health study or the land use of the area around the site?
A. Remediation of the 93rd Street School site is not one of the criteria
established in the habitability study document. However, the
remediation of the 93rd Street School site is expected to have a
positive impact on revitalization of the area.
Q. Problems with reading the maps in the handouts and in the report.
A. The copies of maps enclosed in the handouts distributed at the
April 13, 1988 public meeting were obtained by reducing the full size
drawings to 8 1/2" x 11" sheets. During the process of reduction some
of the maps became difficult to read. However, the full size drawings
were displayed at the public meeting and they are available at the
NYSDEC Public Information Office for reference.
•
Q. May 6 was long enough for a comment period for this project. Why was
it extended to May 25?
A. The public comment period was extended to May 25, 1988 to satisfy the
federal requirement that the administrative record be available to the
public for 21 days.
Q. There's a supplement with some missing data that you had to get. Where
is that data?
A. The RI/FS report consists of the following volumes:
- Volume I - Remedial Investigations
- Volume I - Appendices
- Volume II - Feasibility Study
- Volumes III & IV - Supplemental data (which the question refers to)
All five bound volumes have been available at the NYSDEC Public
Information Office for your review since March 1988.
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F. PUBLIC PARTICIPATION
Q. Can we look a.t the remedial plan?
A. Yes. All reports, analytical data and evaluations of various remedial
alternatives relative to this project including the remedial plan, are
available for public reference at the NYSDEC Public Information Office,
9820 Colvin Blvd., Niagara Falls. The office is open Monday thru
Friday, 8:30 a.m. - 4:30 p.m.
Q. If solidification is selected as the site remedy, will there be other
public meetings during the preliminary design so that we can take part
In adding to it?
A. Yes. Additional opportunities for public input will be provided as the
project proceeds into and through design.
Q. Vou seem to have made up your mind about how you will remediate the
site. You should wait to make any final decisions until you take the
public's comments into consideration, otherwise we're just going
through the motions of having Citizen Participation.
A. The public comments received within the comment period will be
considered, the proposed alternative will be reevaluated taking the
comments received into consideration, and the comments will be
responded to in a Responsiveness Summary before any decision as to
remedy is finalized. USEPA/NYSDEC are required by section 117(a)(l) of
SARA to present the proposed alternative to the public for their
comments.
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treat the soil (may involve mixing, heating, drying, etc.)
sample and analyze the treated soil
retreat any materials not meeting requirements for disposal criteria
backfill the excavated area with acceptably treated material
monitor the air for volatile organic chemical and dust emissions
monitor the soil for leaching
monitor the groundwater for leaching
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