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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                             -2-


 * 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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                              -2-

~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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                             -3-
(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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                               -6-


  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.

-------
                             -7-

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).

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                                -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.

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                             -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.

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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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                              -19-

-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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                             -25-

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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                             -26-
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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                             -27-


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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                             -28-
  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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                             -30-

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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                             -32-


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:

                                     - 1  -

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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.
                                     - 2 -

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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.
                                     - 3 -

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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.
                                      - 4 .

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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.
                                     - 6 -

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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.
                                     - 7 -

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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.
                                     - 8 -

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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.
                                     - 9 -

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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.
                                     - 10 -

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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.
                                     - 11 -

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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.
                                     - 12 -

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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 -

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 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.

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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 -

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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 -

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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,

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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

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(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

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"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

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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

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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

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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.

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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

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             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

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               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

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           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.

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            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

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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.

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              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

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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.

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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.

-------
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

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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.

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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

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             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

-------
                             - 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.

-------
                             -  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.

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   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 
-------
                             - 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.

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       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.

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                                                       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."

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                 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»>»//-

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                               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

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                                                                                     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

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MAT OF SAMPLING LOCATIONS FDR 66TH STREET SCHOOL AND BISHOP EUFFY HIGH SCHOOL
    •

             •
             i
             ]

             i
             i
                                    I         " i
              x
              K
              V*
                                   <7
                       •w

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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.

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                                                                                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
      *."'
              Jj^^-a  y*^  e\.
              r     '«
              £ ^ '        •   '   /
,JL-  ,'>^,
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                                                                  fi '••£ "AJISL
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                               J- /
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                               It         k ~r •'     ' •'      A      '   *

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                                                                              /U.
      '7-
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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)

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                                                    . «»•». 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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165
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Tilt DsASSENIC  4/23/88                                                Page 2-1



•  rau SflCXCl HJNI351 N1NE3J2


60
61
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.69
?0
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" 77
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85
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'95
96
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105
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107
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-------
fil* D'.ASSIHIC  4/23/88
                                                                       Fast 1-1
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1
2
3
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51
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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.
                                     - 20 -

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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.
                                     - 19 -

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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.
                                     - 13 -

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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
                               - 17 -

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